corrective action plan for the former verd mont mill …€¦ · the former verd mont mill property...

CORRECTIVE ACTION PLAN FOR THE

FORMER VERD MONT MILL PROPERTY LUDLOW, VERMONT

VERMONT DEC SITE 2005‐3345

May 6, 2011

Responsible Party:

Luzenac America, Incorporated P.O. Box F

Ludlow, VT 05149 (802) 228‐6417

Prepared by:

P.O. Box 787 368 Avenue D, Suite 15 Williston, Vermont 05495

(802) 383‐0486 (802) 383‐0490 fax

info@kas‐consulting.com

KAS Project #510040004

Corrective Action Plan 5/6/2011 Former Verd Mont Mill, Ludlow, Vermont

KAS #510040004 ii DEC Site #2005‐3345

EXECUTIVE SUMMARY This Corrective Action Plan (CAP) addresses human health risk and contaminant migration issues posed by subsurface contamination reported near the western portion of the former Verd Mont Mill Site in Ludlow, Vermont and near monitoring well MW‐1 (“corrective action area”). This CAP contains a summary of the results of environmental testing and risk assessment in the corrective action area, and also contains qualitative technical analysis of potentially applicable technologies to address the estimated human health and environmental risk posed by the contamination. Based on the qualitative technical analysis, a remedial technology is specified and a preliminary design is presented. The corrective action area was studied for environmental impacts between April 2004 and December 2010. A summary of the environmental studies performed is included in this CAP. Based on the results of this work, groundwater, drinking water and surface water human exposure pathways were minimized. Shallow surface soils across portions of the Site were determined to contain contamination at concentrations above direct‐contact human health risk levels (corrective action area #1). Additionally, a limited area of light non‐aqueous phase liquid (LNAPL) was identified near monitoring well MW‐1 (corrective action area #2). A risk analysis has resulted in recommendations to physically isolate these shallow soils from direct human exposure and to impose an Activity Use Limitation to limit disruption of contaminated soil. Recommendations for source area removal were imposed to limit LNAPL contaminant migration. The principal remedial technology examined in the CAP is the installation of a soil barrier layer over corrective action area #1 along with soil excavation and disposal in the vicinity of monitoring well MW‐1 and corrective action area #2. A notice to the land records of on site activity and use limitation will also be prepared. The bases of this recommendation are this system’s ability to isolate contaminated soil from direct human exposure and its ability to minimize contaminated sediment transport. The remedial structure will remain in place until site redevelopment activities begin at which time the corrective action area will be reassessed.


KAS #510040004 iii DEC Site #2005‐3345

TABLE OF CONTENTS

Page

PROFESSIONAL ENGINEER'S REVIEW: ........................................................................................i TABLE OF CONTENTS ................................................................................................................ iii APPENDICES.............................................................................................................................. iii I. INTRODUCTION .................................................................................................................1 II. SITE BACKGROUND............................................................................................................1 A. Description and Environmental Setting ........................................................................1 B. Statement of the Problem ............................................................................................2 C. Synopsis of Previous Environmental Investigations and Actions..................................2 D. Compilation of Soil Contaminant Data..........................................................................6 E. Groundwater Hydrology and Quality............................................................................6 F. Sensitive Receptor Risk Assessment .............................................................................7 G. Impacted Third Parties ..................................................................................................7 H. Adjacent Landowners....................................................................................................8 I. Risk Factor Definition and Analysis ...............................................................................8

III. REMEDIAL TECHNOLOGY OPTIONS...............................................................................9 IV. CORRECTIVE ACTION IMPLEMENTATION DETAILS .....................................................10 A. Description of Remedial Technologies........................................................................10 B. Remediation Details ....................................................................................................10 C. Site Control..................................................................................................................12 D. Construction Details and Sequence ............................................................................13 E. Future Management Issues.........................................................................................14

V. PERMITTING, MONITORING AND REPORTING............................................................14 A. Health and Safety Plan (HASP) ....................................................................................14 B. Contractors and Sub‐Contractors ...............................................................................14 C. Permits/Approvals.......................................................................................................15 D. System and Site Monitoring........................................................................................15 E. Reporting.....................................................................................................................15 F. Schedule ......................................................................................................................16


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APPENDICES A. MAPS

Site Location Map Site Map Corrective Action Area Map PAH Contaminant Distribution Map TPH Contaminant Distribution Map Lead Contaminant Concentration Map Arsenic Contaminant Concentration Map

B. Soil and Groundwater Quality Data C. Proposed Soil Barrier Isolation System Soil Excavation Area Map D. Work Elements and Schedule E. Public Notice F. Health and Safety Plan


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I. INTRODUCTION This document is a Corrective Action Plan as defined by the Vermont Department of Environmental Conservation (DEC), Waste Management Division1, to address potential human health and environmental risk posed by subsurface contamination at the former Verd Mont Mill property in Ludlow, Vermont. A Site Location Map is included in Appendix A. This plan was prepared by KAS, Inc. (KAS) at the request of Luzenac America, Incorporated (Luzenac) of Ludlow, Vermont. This plan presents a summary of the results of previous environmental testing, identification and analysis of the risks to human health posed by the contamination, and the recommended means to minimize risk to human health. Implementation of the recommendations in this plan will reduce potential human exposure and reduce risk to human health and the environement to negligible levels during and after construction.

II. SITE BACKGROUND

A. Description and Environmental Setting

The former Verd Mont Mill property is an approximately 1.1 acre, irregularly‐shaped parcel located off of East Hill Road in Ludlow, Vermont. The property configuration is depicted on the Site Map in Appendix A. The eastern portion of the property hosts an existing, approximately 10,000 square foot warehouse building used by Luzenac to store equipment and parts. The Site used to house a woolen mill. The remaining portion of the mill building was demolished in 2010. The Site Map in Appendix A outlines the former mill building location2. The property is located in a mostly residential portion of the Town of Ludlow. The surrounding area is generally flat and consists of grass and gravel landscape. The Black River is located in close proximity of the Site, approximately 50‐100 feet south from the former mill building location. Groundwater ranges in depth from 5‐8 feet below ground surface3. The portion of the property where the former mill building footprint is shown on the Site Map and in the immediate vicinity of MW‐1 is herein referred to as the corrective action area. The corrective action area is approximately 0.47 acre and is currently accessible to heavy equipment. It is topographically flat, with a grass and/or gravel surface. The property has a gravel access drive that runs to the warehouse building located on site.

1Vermont Agency of Natural Resources, Waste Management Division, “Corrective Action Guidance”, November

1997, 15 Pgs. 2 Phase II Environmental Site Assessment Report. Griffin International, Inc. October 2004. 3 Additional Subsurface Site Investigation Report. KAS, Inc. January 2011.


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B. Statement of the Problem

Historic use of the corrective action area for a woolen mill resulted in subsurface contamination. Subsurface investigations were conducted between 2004‐2010 which fully defined the nature and extent of the contamination. Generally, soils beneath the corrective action area are contaminated with semi‐volatile organic compounds, total petroleum hydrocarbons, and select metals. These materials are close to the ground surface in some areas and inadvertent human exposure could result from excavation; there is no exposed waste and casual Site use does not cause human exposure to waste materials or pose risk to human health. Access to the Site is partially restricted by the existing fence and gate. No volatile contamination has been detected in shallow soils. Light non‐aqueous phase liquid (LNAPL) has been observed in monitoring well MW‐1 over time. The thickness of LNAPL in this well could not be measured during the most recent site visit in December 2010 due to the high viscosity of the product. The product was observed to be yellow to orange in color and had a slight solvent‐like odor. A sample was collected and tested for characterization purposes and according to the analysis the pattern most closely resembled hydraulic fluid in appearance but the difference in retention time was significant enough to prevent a positive identification as hydraulic fluid. Although a positive identification of the product was not made through the laboratory analysis, given the appearance of the product and the history of the Site it is entirely rational to believe the product present in MW‐1 is hydraulic fluid. This CAP addresses risk posed by the contamination by specifying appropriate engineering measures to minimize exposure during construction and occupancy.

C. Synopsis of Previous Environmental Investigations and Actions

Phase I and Phase II Environmental Site Assessments (ESAs) were conducted in 2004. Additional subsurface investigations occurred at the Site in 2007 and 2010. The results of these studies are summarized below. Phase I ESA DSM Environmental (DSM) performed a Phase I ESA and soil sampling in April 2004. Three areas were targeted: the #2 fuel oil storage area inside the mill building; the north side of the mill building; and, the area around the tower. Samples were submitted to Eastern Analytical Inc. of Concord, New Hampshire for laboratory analysis. The results indicated a high concentration of Total Petroleum Hydrocarbons (TPH) in the fuel oil storage area ranging from 1,000 ppm to 26,000 ppm and the downgradient sample was reported to be non‐detect for TPH. The reported TPH concentrations in the fuel oil storage area equaled or exceeded the TPH Soil Cleanup Guideline of 1,000 ppm for non‐residential sites published by the DEC (ref. DEC Memorandum 12/30/92). DSM observed and sampled a black fibrous layer buried at shallow depth along the north side of the building. The reported TPH concentration of the material was 1,000 ppm which


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was equal to the TPH Soil Cleanup Guideline of 1,000 ppm for non‐residential sites published by the DEC (ref. DEC Memorandum 12/30/92). The reported lead concentration of the black fibrous material was 8,800 ppm which was one‐three orders of magnitude in excess of typical naturally occurring lead concentration ranges (ref. USGS Professional Paper 1270, 1984). One sample was collected from the north side of the tower and sampled for lead (not TPH) and was reported to contain 27,000 ppm lead which is two‐four orders of magnitude greater than naturally occurring lead concentrations. Phase II ESA ‐ 2004 In August 2004, Griffin International, Inc. and DSM conducted a Phase II ESA to address the Recognized Environmental Conditions identified during the Phase I ESA. As part of the Phase II ESA, six groundwater monitoring wells (MW‐1 through MW‐6) were installed at the Site. Shallow soil samples were also collected from beneath the woolen mill floor and in select areas around the mill building. In addition, four wood floor samples were collected from inside the woolen mill building. Select metals were reported to be above the Vermont Groundwater Enforcement Standards (VGES) in the sample collected from MW‐2 and MW‐3. No VOCs were reported above the applicable VGES in the groundwater samples. A concentration of TPH was reported above the VTDEC guideline for a commercial property in the soil collected from two of the three locations beneath the woolen mill floor. Also, a concentration of TPH was reported in four wood floor samples collected from inside the woolen mill building. Based on the results of the Phase II ESA, it was determined additional work was needed at the Site. Additional Subsurface Investigation – 2005 In August/September 2005, KAS and DSM conducted an additional subsurface investigation to gather additional data to better characterize the site. As part of this investigation, a total of six shallow soil samples were collected from select areas around the Site. No VOCs were detected above EPA standards for an industrial property in the samples collected from beneath the above ground storage tank (AST). Select polycyclic aromatic hydrocarbons (PAHs) were reported above the EPA standard for an industrial property in one of the samples collected from beneath the AST and one of the samples collected from beneath the wooden floor.

Two wood floor samples were collected from inside the Woolen Mill facility on August 9, 2005 and sent to Freidman & Bruya, Inc for oil identification analysis. The laboratory report indicated the material present in the samples is consistent with a high boiling product such as hydraulic oil, lube oil, or similar materials. According to the TPH data collected at the Site, the wood floor exceeded 5% petroleum which rendered it hazardous according to Vermont regulations. On August 26, 2005, groundwater samples were collected from the site monitoring wells and analyzed for VOCs, PAHs, and RCRA 8 metals. Approximately 0.10 feet of LNAPL was measured and observed in MW‐1 on August 26, 2005. No VOCs or PAHs were reported to be above the laboratory detection limit in the groundwater samples collected from MW‐3


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through MW‐8 on August 26, 2005. Select metals were reported above the laboratory detection limit in the groundwater sample collected from monitoring wells MW‐ 3 through MW‐8 on August 26, 2005. All concentrations were reported to be below the VGES except lead, which was reported to be above the VGES in the sample collected from MW‐3. Based on the results of the additional investigation conducted at the Site, KAS and DSM recommended that monitoring well MW‐1 be gauged to confirm the presence of LNAPL and if it is present be manually recovered. Additional shallow soil samples were also recommended to be collected across the Site to determine if the severity of PAH and arsenic contamination in soil is high enough to warrant future actions. An additional round of groundwater monitoring was also recommended. Building Demolition – Summer 2010 A work plan and cost estimate was prepared in July 2007 to conduct the next round of work; however, Luzenac and the VTDEC mutually agreed to hold off the next phase of work until the former Verd Mont Mill building was demolished. After completion and approval of the Act 250 permitting the building was scheduled to be demolished beginning in the summer 2010. The wood flooring inside the building was removed and properly disposed of by a licensed waste hauler and the building was demolished in the summer/fall 2010. The building demolition allowed for drilling within the building footprint and completion of all drilling efforts associated with the next phase of work within one mobilization. Additional Subsurface Investigation – 2010 In November/December 2010, KAS conducted an additional subsurface investigation to gather additional data to better characterize the site. Shallow soil samples were collected from nine locations on the subject property (SB10‐2 through SB10‐9 and SB10‐18) on November 29, 2010 to further define the extent of PAH, arsenic, and lead contamination in shallow soils across the Site. Lead, arsenic and select PAH compounds were reported above the EPA Regional Screening Level (RSL) for an industrial property in shallow soil samples collected across the Site property. Following building demolition, three soil borings were advanced in the area where the building previously resided (SB10‐10 through SB10‐12) and one monitoring well (MW10‐7) was installed in the vicinity of where the highest lead and TPH concentrations were previously reported. One soil sample was collected from each boring at the 0‐2’ soil interval and at the 7‐9’ soil interval (beginning of the water table) for laboratory analysis of PAHs, arsenic, lead, and TPH. One compound (benzo(a)pyrene) was reported above the EPA RSL for an industrial property in the soil sample collected from soil boring SB10‐12 advanced within the building footprint. A concentration of TPH was also reported in the soil samples collected within the building footprint ranging from 10.6 to 14,900 mg/kg. Five additional soil borings were advanced to a depth of approximately 12’ bsg to evaluate the extent of LNAPL in the vicinity of MW‐1 (SB10‐13 through SB10‐17). One monitoring well (MW10‐8) was installed in the boring hole exhibiting the highest PID reading (SB10‐17). Based on the results of the soil boring advancement and soil screening, LNAPL


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contamination in the vicinity of MW‐1 appeared to be limited. LNAPL was observed in MW‐1 on December 9, 2010. The LNAPL thickness could not be measured due to the high viscosity of the product. Due to the presence of LNAPL in MW‐1, a sample was collected and tested for characterization purposes. The laboratory report indicated the product present in the sample is consistent with a heavy oil. According to the analysis the pattern most closely resembles hydraulic fluid in appearance but the difference in retention time is significant enough to prevent a positive identification as hydraulic fluid. No VOCs were reported to be above the laboratory reporting limit in the groundwater samples collected from MW‐2 through MW‐6, MW10‐7, and MW10‐8 on December 9, 2010. Barium and/or lead were the only metals reported in select wells below the VGES. Soil Quality Results Based on recent and historical data, no VOCs have been reported to be above the laboratory reporting limits in soil samples collected across the Site. PAHs: Select PAH compounds have been reported above applicable EPA RSL in soil samples collected from shallow soil borings advanced across the Site. A PAH Contaminant Distribution Map has been prepared to show the distribution of PAHs in shallow soil samples collected across the Site (Appendix A). Based on recent and historic data collected at the property, the PAH contamination at a depth of 0 to 2 feet bsg appears to widespread with the highest levels present around the former Woolen Mill building the warehouse building. Lower levels of PAHs are present to the north, east, and west of these locations. TPH: A concentration of TPH has been reported in shallow soils on the Site property. A TPH Contaminant Distribution Map has been prepared to show the distribution of TPH in shallow soil samples collected across the Site (Appendix A). Based on recent and historic data collected at the property, the TPH contamination at a depth of 0 to 2 feet bsg appears to be concentrated in the vicinity of the former Woolen Mill building. Non detectable levels have been reported at other areas across the Site. Arsenic: A concentration of arsenic has been reported in shallow soils on the Site property. An Arsenic Contaminant Concentration Map has been prepared to show the distribution of arsenic in shallow soil samples collected across the Site (Appendix A). Based on recent and historic data collected at the property, the level of arsenic in shallow soils appears to be generally consistent throughout except for two areas in close proximity to the warehouse building (SB10‐9 and SB‐8). Given the widespread and generally consistent results of arsenic in shallow soils across the remainder of the Site, it appears there is no statistical difference between the results. Lead: A concentration of lead has been reported in shallow soils on the Site. A Lead Contaminant Concentration Map has been prepared to show the distribution of lead in shallow soil samples collected across the Site (Appendix A). Based on recent and historic


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data collected at the property, the level of lead in shallow soils appears to be highest in the vicinity of the former Woolen Mill building and the warehouse building with lower levels present to the north and south. Elevated concentrations of lead above the EPA RSL standard appear to be limited to two discrete areas near the former mill building (ASTSS‐1 and S04‐6). Based on recent and historic soil sampling the elevated levels of lead are not widespread and the two discrete areas with levels above EPA standards are likely a result of lead based paint from the former mill building. As compared to the background lead concentrations reported in the upgradient shallow soil samples (SB05‐5 and SB05‐6), the concentrations of lead reported in all other shallow soil samples except ASTSS‐1 and S04‐6 are equal to or only slightly above background levels.

D. Compilation of Soil Contaminant Data

KAS compiled and plotted soil contaminant concentration data for the corrective action area to gauge the extent of the contaminated area in need of remediation. A tabular presentation of the soil quality data is included in Appendix B. The maps depict the horizontal spatial distribution of contamination across the corrective action area (see Distribution Maps, Appendix A). The contaminated surface soils extend laterally along the former Verd Mont Mill building footprint in a northwesterly and southeasterly direction. The approximate dimensions of this area are approximately 180 feet in a northwest‐southeast dimension (Appendix A). A small area of PAH contamination in shallow soils also lies in the vicinity of monitoring well MW‐1 (soil boring SB‐8). The contamination has been well defined through soil borings advanced at the Site between 2004 and 2010.

E. Groundwater Hydrology and Quality

Depth to groundwater is between 5 and 8 feet, and groundwater is flowing to the southeast towards the Black River at a hydraulic gradient of 3.3%. Based on recent and historic groundwater data collected across the Site, the historic use of the property does not appear to have resulted in VOC contamination in groundwater above state standards. Select metals have been reported in groundwater collected from monitoring wells MW‐1 through MW‐6, MW10‐7, and MW10‐8 since September 2004. Only two locations, MW‐2 and MW‐3, have historically had groundwater reported to contain metals above the VGES. However, no metals were reported above the VGES during the December 9, 2010 groundwater sampling event. Based on recent and historic groundwater data collected across the Site, the historic use of the property has resulted in low level dissolved phase metal contamination in groundwater but concentrations are currently below enforcement standards. A tabular presentation of the groundwater quality data and groundwater elevations is included in Appendix B.


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F. Sensitive Receptor Risk Assessment

A sensitive receptor risk assessment of the area surrounding the Site is provided below, and a determination of the potential risk to identified receptors has been made based on proximity to the corrective action area, groundwater flow direction, contaminant mobility and volatility, and contaminant concentration levels in subsurface soils and groundwater.

Buildings in the Vicinity

Currently only one building resides; a warehouse with slab on grade construction. This building is used to store parts and is only occupied briefly by personnel dropping off or picking up parts for work purposes. The remaining portions of the former Verd Mont Mill were demolished in 2010. The only other nearby structures are located at least 80‐100 feet away from the corrective action area. Based on the on site building use and construction and the nature of contaminants identified on site, it is expected that there is minimal risk of vapor migration posed to this building. Additionally, off site buildings are not considered to be at risk to vapor migration.

Utility Corridors

No subsurface utility corridors are known to exist in the vicinity of the Site. Electrical and telephone utilities are located overhead near the Site and do not act as utility corridors for contaminant migration.

Wetlands and Surface Water Bodies

No potential jurisdictional wetlands were observed in the immediate vicinity (Site and abutters) of the Site. The Black River is located adjacent to the property to the South. Due to the location of the Black River it is considered to be a potential sensitive receptor. However, soil borings advanced in November 2010 indicated the LNAPL plume was confined to the direct area of monitoring well MW‐1. Additionally, the contaminants identified in shallow soils across the site have been shown to be vertically confined within the top two feet of the subsurface. Given the findings the Black River is not considered to be at risk to subsurface contamination at this time.

Public Water Supplies

The area is currently served by private water supplies. There are approximately seven water supply wells located within 1,000 feet of the Site according to the DEC’s on line water supply well locator.4 The on site supply well has been tested for contaminants in the past and none were reported present. This well is scheduled to be properly abandoned in the near future. Given the findings the risk to nearby drinking water supply wells is considered to be low at this time.

G. Impacted Third Parties

No third parties appear to be impacted from contamination resulting from the subject property at this time.

4 (http://www.anr.state.vt.us/gismaps/index.htm).


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H. Adjacent Landowners

The following landowners abut the Woolen Mill property (mailing addresses listed): Okemo Limited, 77 Okemo Ridge Road, Ludlow, VT 05149 Tom Nowak Sr, PO Box 252, Ludlow, VT 05149 Cody Surething, 500 Route 103 South, Ludlow, VT 05149 Floyd Tyson, PO Box 456, Ludlow, VT 05149 Frederick and Kathy Hart, 510 Route 103 South, Ludlow, VT 05149 Vincent Giardini Jr. and Marianne Giardini, 79 Foster Avenue, Sayville, NY 11782 Richard Reinhardt and James O’Brien, 35315 Main Road, Cutchogue, NY 11935 Richard C. Williams, 629 South Hill Road, Ludlow, VT 05149 Brian and Kimberly Martel, PO Box 403, Ludlow, VT 05149 Walter and Lisa M. Stoma, 82 Joine Road, Port Jefferson, NY 11776

I. Risk Factor Definition and Analysis

This section of the Corrective Action Plan defines risk factors present as a result of the environmental findings presented above, and presents analysis of the risk factors based on the proposed uses of the Site. Planned Development The corrective action area will remain in its present state. No construction is currently contemplated at the Site. The corrective action area is included in Appendix A. Categories of Risk Construction of a remedial technology on the Site poses construction related risks. Risks include short term direct risks to construction workers and others on and off Site as a result of exposure to contaminated soil. Leaving the property in an undeveloped state could pose incidental risk to site trespassers who may advertently or inadvertently come into contact with contaminated soils if the site is left unremediated. Routes of Potential Exposure Human exposure to contaminants can theoretically occur via the following pathways: inhalation of vapors or contaminated dust; ingestion of soil and/or liquids; absorption via dermal contact; and, injection of contaminants. However, the nature and occurrence of contamination at this Site discounts most of these potential exposure pathways as explained below. The residual potential exposure pathways to be addressed at this Site are: inhalation of dust; dermal contact with contaminated soil; and, ingestion of contaminated soil. These residual exposure pathways will be effectively addressed with appropriate construction management techniques, engineering and institutional controls as is described in Section IV. Inhalation Pathway Inhalation of vapors and/or dust constitutes the inhalation pathway. At this Site the absence of significant VOCs in the soils means that exposure to volatile contamination via vapor inhalation will not occur. Although VOCs have been detected at low levels in the


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groundwater at portions of the Site, the depth of the water table and the very low VOC concentrations indicate that vapor migration from groundwater is not a concern. Inhalation of dust containing PAH, TPH, or metals is a potential route of exposure on and off Site and will be addressed via construction practices outlined in Section IV. Implementation of the engineering and institutional controls outlined in Section IV will prevent inhalation of contaminated dust after the construction period. Ingestion Pathway Ingestion of PAH, TPH, or metals contaminated soil is a potential route of exposure. During construction, intrusive activities will be conducted under the jurisdiction of a Health and Safety Plan (HASP) as defined by 40 CFR Part 1910.120 for hazardous Sites. The HASP will contain detailed instructions on worker conduct within the contaminated area including ingestion issues. All intrusive work within the contaminated area will take place under the supervision of the Site Safety Officer (SSO) who will be responsible for training workers about HASP requirements and for enforcing those requirements. A copy of the HASP is included in Appendix F. The engineering and institutional controls described in Section IV will address ingestion issues following construction. Absorption Pathway Absorption of PAH, TPH, or metals through direct contact with skin is a potential route of exposure. In order to minimize human health risk during construction, the HASP will contain provisions relating to personal protective equipment (PPE) designed to minimize dermal contact, likely in the form of protective clothing to cover exposed skin. Potential risk to human health posed by long‐term uses following construction will be addressed by the measures outlined in Section IV. Injection Pathway Injection of PAH, TPH, or metals into the body due to contamination at this Site during construction is not likely as long as the HASP provisions are followed. Measures to minimize dermal contact will also be effective at minimization of injection potential. Potential risk to human health posed by long‐term uses following construction will be addressed by the measures outlined in Section IV.

III. REMEDIAL TECHNOLOGY OPTIONS The proposed remedy for detected contamination must primarily isolate contaminated surface soils from direct human exposure. A second objective of the corrective action is to isolate residual contaminated soils from possible physical transport and dispersion. A third objective is to provide adequate protection to construction workers on the contaminated portion of the corrective action area, during construction of the recommended remedial structures. Construction of a soil isolation barrier, and soil excavation/removal were evaluated qualitatively and deemed feasible as they meet all three objectives for corrective action on the subject property.


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Other remedial technologies considered during CAP preparation included: soil vapor extraction; air sparging; groundwater pumping and treating; reactive and barrier walls; bioremediation; natural attenuation; and in‐situ immobilization. Soil vapor extraction technologies were dismissed because the primary contamination identified at the corrective action area is not volatile and therefore not effectively treated by soil vapor extraction. Air sparging, groundwater pumping and treating and barrier and reactive wall technologies were dismissed because the contamination identified as presenting risk to human health is soil, not groundwater contamination, and these technologies primarily address groundwater contamination. Natural attenuation of TPH, PAH, and metals contamination, if happening at all, is proceeding too slowly to significantly reduce soil concentrations to below risk based levels. In‐situ immobilization was dismissed because its primary benefit is to reduce migration of contaminants via gaseous and fluid flow mechanisms, neither of which appear to be significant in this situation. Other remedial methods considered as a means to specifically target LNAPL removal in the vicinity of MW‐1 included high vacuum extraction (HVE) and manual free product recovery. However, both HVE and manual recovery were dismissed due to the high viscosity of the product and the unliklihood of significant LNAPL recovery occurring from these remedial methods.

IV. CORRECTIVE ACTION IMPLEMENTATION DETAILS

A. Description of Remedial Technologies

KAS recommends that a combined approach be implemented for corrective action at the Site. A soil isolation barrier system should be permitted and constructed over corrective action area #1 (see Corrective Area Map, Appendix A). The bases of this recommendation are this system’s ability to isolate contaminated soil from direct human exposure and its ability to minimize contaminated sediment transport. A map showing the proposed location of the soil isolation barrier system is included in Appendix C. Soil excavation and disposal of contaminated soils in the vicinity of MW‐1 (corrective action area #2) should be completed. The basis of this recommendation is the ability of this remedial method to aggressively target a small area where LNAPL has persisted for many years with direct source removal. A map showing the proposed soil excavation area is included in Appendix C.

B. Remediation Details Soil Isolation Barrier This remedial action specifies that a soil isolation barrier layer consisting of a minimum of 24” of uncontaminated soil will be installed above corrective action area #1 to deter human contact. The isolation barrier will be covered with at least 2” of top soil to support grass growth. Filter fabric will be placed beneath the 24” soil layer to prevent migration of soil and serve as a warning for unauthorized excavation. A typical soil isolation barrier system cross section is included in Appendix C.


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The principal steps in performing this option will include: grading of contaminated soils to a regular, slightly sloping surface; placement of the filter fabric over the regraded contaminated soils; installation of a barrier soil layer over the fabric; and installation of top soil, seed and mulch. Based on preliminary measurements the area for the soil isolation barrier consists of approximately 10,220 ft2. This area encompasses the former woolen mill building footprint and areas beyond. Several groundwater monitoring wells are located within this area; however, these wells will be properly abandoned by KAS prior to construction of the soil isolation barrier to minimize the potential that they can become conduits to the groundwater for spillage or leakage at the ground surface. The depths are approximately 13‐15 feet below grade. Advantages: These soils would be isolated from casual human contact. Direct contact human health concerns would be addressed by this method. The buried filter fabric would serve as a visual warning in the event an uniformed person tried to excavate in the contaminated area. The two foot depth of cover over the membrane would limit human exposure in the event that slight excavations were attempted. And, this remedial alternative is cost effective. Disadvantages: The disadvantages are that it would not result in removal of all contaminated soil from beneath the corrective action area, so future notification and management efforts would continue to be needed to minimize human exposure during construction scenarios. Short‐term exposure to contaminated soils would be necessary during excavation. KAS’ understanding is that the corrective action area is going to remain in its present state, with a gravel driveway surrounded by a grassy area. The residual potential exposure pathways to be addressed at this Site are: inhalation of dust; dermal contact with contaminated soil; and, ingestion of contaminated soil. No construction other than this remediation will take place and no intrusive Site work will be performed at the Site. Soil Excavation KAS has outlined an excavation area immediately around monitoring well MW‐1. This area also includes the the location where soil boring SB‐8 was advanced; which had elevated levels of PAHs. The area of excavation is approximately 300 ft2 with an approximate thickness of 1‐4 feet of “clean” soils and a maximum planned depth of excavation of 15 feet below grade. KAS estimates removal of approximately 100 cubic yards of soil (150 tons) of petroleum contaminated soils. The proposed excavation consists of the area between MW‐1 and the neighboring warehouse to the north. The excavation will also extend to the west slightly to remove the surface soils in the vicinity of where soil boring SB‐8 was advanced. The excavation area is outlined in Appendix C. An elevated PID reading was detected in soils during the installation of MW‐1 at a depth of approximately 5‐7 foot below grade, thus soils below 4 feet below grade will be screened for the presence of VOCs with a properly calibrated PID with a minimum 10.6 eV lamp


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during the excavation. Clean soils would be stockpiled on site where possible until they are backfilled into the excavation. Based on historical data collected from monitoring well MW‐1, groundwater is anticipated to be encountered during the soil excavation activities. However, the presence of groundwater in the excavation is not anticpated to significantly deter the removal of soil therefore dewatering efforts will not be initiated. Excavation of contaminated soils will extend as deep as possible with a total depth of approximately 15 feet below grade anticipated. The sides of the excavation will be sloped adequately to allow for excavation to this maximum depth. Since some of the soil will be saturated upon removal, the soils will be excavated and placed on a sloped side of the excavation for a period of time to allow for the the fluids to drain into the excavation pit. After the soils are drained adequately they will be placed onto 6‐mil poly sheeting for later disposal. The excavation of soil will be conducted in a way to minimize the drainage of fluids onto the ground surface. A berm will be constructed around the stockpiled soil as a precautionary measure to inhibit fluids from draining onto the ground surface. Soil samples will be collected and submitted for waste characterization analysis. The characterization analysis will include analysis for TPH via EPA Method 8015 diesel range organics (DRO), PCBs via EPA Method 8082, and Ignitability. Once the results of the waste characterization analysis have been received (~1‐2 weeks turnaround time), and provided that the soils meet the facility’s permit requirements, soils will be loaded into dump trucks for transport to the New England Waste Services of Vermont landfill in Coventry, Vermont by Cassella. Because MW‐1 is included in the excavation area, this well will be replaced after site restoration. The excavation will not require any permanent equipment or structures and will be backfilled, compacted, and re‐graded upon completion of the excavation process. A one‐day excavation event is anticipated to remove and stockpile the contaminated soils on site. An additional ½ day is anticipated for loading of contaminated soils onto trucks for transport and site restoration. Replacement well installation is expected to occur on a subsequent day. Due to the close proximity of the excavation area to the neighboring warehouse building, a KAS engineer will develop a soil excavation plan and building protection plan to insure that this structure is not at potential risk from the excavation. KAS anticipates this remedial method will eliminate the LNAPL near monitoring well MW‐1 which in turn will help reduce dissolved phase contaminant concentrations in groundwater.

C. Site Control


KAS #510040004 13 DEC Site #2005‐3345

Dust Control Generation of dust from the contaminated area will be addressed as follows to minimize the inhalation pathway during the installation of the soil barrier and excavation of soils. All graded surfaces will be wetted as needed to minimize dust. Calcium chloride may also be used to control dust on exposed surfaces. Visible emissions of dust from the Site will not be permitted. Soil Erosion Control Plan A soil erosion control plan should be implemented to minimize off‐Site migration during construction activities. Isolation Barrier Construction An isolation barrier consisting of minimum 24” of uncontaminated soil will be placed beneath all non‐paved areas. The isolation barrier will be covered with at least 2” of topsoil to support grass growth. Filter fabric will be placed beneath the 24” soil layer to serve as a warning for unauthorized excavation. A typical isolation barrier system cross section is included in Appendix C. The 24” layer of uncontaminated soil will be sufficient to minimize risk of human contact with contaminated soils. The filter fabric warning barrier will serve as an additional defense against unauthorized excavation. Institutional Control A notice to the land records of on site activity and use limitation will be recorded in the city land records to notify interested parties of the existence of contaminated soil beneath the Site and the resulting restrictions on Site activity. The notice will include a brief description of the nature of the contamination, the measures used to minimize exposure to contamination and any restrictions on future activity (in this case, unauthorized excavation). The property’s attorney will be required to provide a survey restricted map in recordable form and a legal description of the property. Once approvals are granted, a property transaction will be completed and official stamped copies will be filed with the lands divisions in Fish Parks and Recreation. The notice to the land records of on site activity and use limitation will also imply that annual inspections occur at the Site to ensure that institutional controls are still in place. This can be completed by the property owner.

D. Construction Details and Sequence

This Corrective Action Plan included a conceptual design plan. Prior to construction a detailed construction plan will be developed including a subgrade and soil cap grading plan. This will require a topographic survey of the Site. It is anticipated that proper finish grades can be attained by regrading of existing materials and without removing contaminated soil from the property (except in the vicinity of MW‐1). Proper finish grades may include a flush or slightly depressed barrier layer top surface with respect to the existing surface, and slight grading which does not increase or inhibit surface runoff.


KAS #510040004 14 DEC Site #2005‐3345

The construction sequencing will be as follows. First, the construction area will be staked out with respect to contamination. Once the construction area is staked out, subgrade elevations will be adjusted to accommodate proposed finish grade and the installation of a two‐foot thick soil barrier layer. It is not anticipated that soils will need to be disposed of off‐Site during Site preparation. Once subgrade elevations have been established a layer of filter fabric will be installed over the residual contaminated soil to serve as a warning to unauthorized excavation. Clean soil will be placed over the filter fabric to a minimum thickness of 24” and to approximate finish grade. Seed, mulch and fertilizer will be applied as soon as topsoil installation is complete. Appropriate signage will be installed indicating that no unauthorized excavation is to occur in this area.

E. Future Management Issues

The recommended remedial measures will not eliminate contaminated soil from corrective action area #1. Thus, future consideration will need to be paid to management of contaminated soils in either case. These will include limitations on excavation in the contaminated area, maintenance and inspection of the area to verify the integrity of the barrier layer, and a a notice to the land records of on site activity and use limitation in the Town land records informing searchers of the existence of residual contaminated soil beneath the corrective action area.

V. PERMITTING, MONITORING AND REPORTING

A. Health and Safety Plan (HASP)

A HASP for the corrective action area will be prepared and implemented to govern the safety aspects associated with the installation of the barrier system in accordance with OSHA requirements. A 40‐hour OSHA 1910.120 trained personnel must be appointed as the Site Safety Officer with a backup also designated. A copy of the HASP will be kept on‐Site and will be available to other parties upon request.

B. Contractors and Sub‐Contractors

Based on discussions with Luzenac the excavation and site work activities will be done by an in‐house contractor. Depending upon contractor availability, the following is a partial list of additional contractors associated with the completion of the corrective action work:

Excavation and Site Restoration:

To Be Determined by Luzenac America, Inc.

Laboratory: Endyne, Williston, VT


KAS #510040004 15 DEC Site #2005‐3345

Waste Disposal: Casella Transportation, Montpelier, VT

Drilling: T&K Drilling, Troy, NH (well replacement)

C. Permits/Approvals

The following permits and approvals are likely needed to accomplish the work as described above. These are identified below. Dig Safe Corrective Action Plan Approval

D. System and Site Monitoring

Persons working beneath the ground surface should be made aware of the contamination and necessary precautions including HASP compliance. Excavation, erosion or other disruption of the structures will require repair to avoid unnecessary exposure of humans to contaminated soil. Annual inspections will be required to ensure the soil cap is maintained. To document remediation of the contamination near monitoring well MW‐1, KAS will collect a confirmatory groundwater sample approximately 1‐2 weeks after well replacement. Prior to sample collection, KAS will measure the water table elevation in the monitoring well to confirm the absence of LNAPL. Assuming LNAPL is not present, the groundwater sample will be collected from the monitoring well using a peristaltic pump. Purge water will be disposed of on site. If LNAPL is measured or observed the well will not be sampled. The monitoring frequency will be reevaluated after this sampling round. If LNAPL is no longer present and dissolved phase contaminant concentrations are below state standards KAS will recommend abandoning the monitoring well. Groundwater samples will be analyzed for VOCs by EPA Method 8260B and RCRA eight metals (As, Ba, Cd, Cr, Pb, Hg, Se, Ag). One trip blank and duplicate sample will be collected and analyzed by EPA Method 8260B (no metals). All samples will be collected in accordance with KAS protocols for low‐flow sampling.

E. Reporting

KAS will prepare a summary report after the successful implementation of the corrective action work and confirmatory round of groundwater monitoring has occurred. The following will be included in the summary report:

• Description of completion of the excavation including recovery estimates; • Description of the completion of the soil isoloation barrier including final area

calculations and surveyed drawings; • Water quality and water level data; • Revised conceptual model;


KAS #510040004 16 DEC Site #2005‐3345

• A discussion on the effectiveness of the remedial technologies; • Conclusions; and, • Recommendations

F. Schedule

CAP implementation may begin on this project following Vermont DEC approval and required public comment period, and acquisition of all of the other required permits. The general order of work will be as follows:

1) Final Design and Permitting 2) Preconstruction survey/establish limits of construction 3) Site Preparation and Monitoring Well Abandonment 4) Contractor Mobilization 5) Soil Excavation 6) Barrier Isolation Layer Installation and survey 7) Topsoil Installation, Seed and Mulch 8) Monitoring Well MW‐1 Replacement 9) Soil Loading and Transport 10) Confirmatory Groundwater Monitoring 11) Prepare as‐built report

The total estimated time required to construct the recommended soil isolation barrier structure and to conduct soil excavation activities once permits are received, is 1‐2 weeks. These times assume fair weather and good access; frozen ground or unfavorable weather conditions could lengthen the time periods. KAS estimates that CAP implementation will begin in late spring or early summer 2011, with the preparation of final design plans and specifications. Construction is anticipated during late summer 2011. A detailed schedule is included in Appendix D.


KAS #510040004 DEC Site #2005‐3345

APPENDIX A

SITE LOCATION MAP SITE MAP

CORRECTIVE ACTION AREA PLAN PAH CONTAMINANT DISTRIBUTION MAP TPH CONTAMINANT DISTRIBUTION MAP

LEAD CONTAMINANT CONCENTRATION MAP ARESNIC CONTAMINANT CONCENTRATION MAP

Source: USGS 7.5 minute quadrangle, Ludlow,NH/VT, Provisional Edition, dated 1973. Scale 1:24,000 Contour interval 20 feet

Site Location Map

Former Verd Mont Mill Ludlow, Vermont 05149

Date: 1/17/11 Drawing: 1/1 Scale: 1:24,000 By: JR


KAS #510040004 DEC Site #2005‐3345

APPENDIX B

SOIL AND GROUNDWATER QUALITY DATA

Soil Sampling Data Summary

Sample Date: 9/1/2004Soil Sample EPA Region IX EPA Region IX

PRG PRGResidential Industrial

PETROLEUM VOCs, EPA Method 8260b SS-1 SS-2 SS-3 SS-4 SS-5 SS-6Benzene ND<17.0 ND<14.0 ND<16.0 ND<16.0 ND<11.0 ND<16.0 600. 1,300.Toluene ND<17.0 ND<14.0 ND<16.0 ND<16.0 ND<11.0 ND<16.0 520,000. 520,000.Ethylbenzene ND<17.0 ND<14.0 ND<16.0 ND<16.0 ND<11.0 ND<16.0 8,900. 8,900.Total Xylenes ND<34.0 ND<28.0 ND<32.0 ND<32.0 ND<22.0 ND<32.0 270,000. 270,000.MTBE ND<34.0 ND<28.0 ND<32.0 ND<32.0 ND<22.0 ND<32.0 62,000. 62,000.1,3,5-trimethylbenzene ND<17.0 ND<14.0 ND<16.0 ND<16.0 ND<11.0 ND<16.0 21,000. 70,000.1,2,4-trimethylbenzene ND<17.0 ND<14.0 ND<16.0 ND<16.0 ND<11.0 ND<16.0 52,000. 170,000.Naphthalene ND<34.0 ND<28.0 ND<32.0 ND<32.0 ND<22.0 155. 56,000. 190,000.NON-PETROLEUM VOCs, EPA Method 8260bTetrachloroethene (PCE) ND<17.0 ND<14.0 ND<16.0 ND<16.0 ND<11.0 ND<16.0 1,500. 3,400.Trichloroethene (TCE) ND<17.0 ND<14.0 ND<16.0 ND<16.0 ND<11.0 ND<16.0 53. 110.1,1-Dichloroethane ND<17.0 ND<14.0 ND<16.0 ND<16.0 ND<11.0 ND<16.0 510,000. 1,700,000.cis-1,2-Dichloroethene ND<17.0 ND<14.0 ND<16.0 ND<16.0 ND<11.0 ND<16.0 43,000. 150,000.trans-1,2-Dichloroethene ND<17.0 ND<14.0 ND<16.0 ND<16.0 ND<11.0 ND<16.0 69,000. 230,000.1,2,3-Trichloropropane ND<34.0 ND<28.0 ND<32.0 ND<32.0 ND<22.0 ND<32.0 5. 11.Chloroform ND<17.0 ND<14.0 ND<16.0 ND<16.0 ND<11.0 ND<16.0 3,600. 12,000.Vinyl Chloride ND<34.0 ND<28.0 ND<32.0 ND<32.0 ND<22.0 ND<32.0 79. 750.PCBs, EPA Method 8082Arochlor-1016 ND<25.0 ND<25.0 ND<1,500. ND<1,000. ND<1,000. ND<25.0 2,100. 3,900.Arochlor-1221 ND<25.0 ND<25.0 ND<1,500. ND<1,000. ND<1,000. ND<25.0 220. 740.Arochlor-1232 ND<25.0 ND<25.0 ND<1,500. ND<1,000. ND<1,000. ND<25.0 220. 740.Arochlor-1242 ND<25.0 ND<25.0 ND<1,500. ND<1,000. ND<1,000. ND<25.0 220. 740.Arochlor-1248 ND<25.0 ND<25.0 ND<1,500. ND<1,000. ND<1,000. ND<25.0 220. 740.Arochlor-1254 ND<25.0 ND<25.0 ND<1,500. ND<1,000. ND<1,000. ND<25.0 220. 740.Arochlor-1260 ND<25.0 ND<25.0 ND<1,500. ND<1,000. ND<1,000. ND<25.0 220. 740.Arochlor-1268 ND<25.0 ND<25.0 ND<1,500. ND<1,000. ND<1,000. ND<25.0 NS NSTOTAL PETROLEUM HYDROCARBONS, EPA Method 8015DROTPH 8015 DRO (mg/Kg) ND<5.0 ND<5.0 4,400. 800. 8,060. 12.1 200* 1,000*TOTAL LEAD, EPA Method 6010Total Lead 87.8 24.5 40.5 312. 96.6 189. 400. 750.

NOTES: All values reported in ug/kg, dry, unless otherwise indicated.EPA Method 8260b used for laboratory analysis for VOCs ND<1.0 = Not Detected< Detection LimitEPA Method 8015DRO used for laboratory analysis for TPH Results reported above detection limits are indicated in boldPRG = Preliminary Remediation Goal NS = No PRG StandardTPH values above the VTDEC TPH Soil Cleanup Guideline are shaded.Soil samples SS-1 and SS-2 were collected at 12-18" below surface grade (bsg), SS-3, SS-4, and SS-6 were collected at 6-12" bsg, and SS-5 was collected at 0-6" bsg.Values based on the VTDEC TPH Soil Cleanup Guideline (ref. DEC Memorandum 12/30/92).Data obtained by Griffin International, Inc.

Former Verd Mont MillLudlow, Vermont


Sample Date: 8/9/2005Soil Sample EPA Region IX EPA Region IX

PRG PRGResidential Industrial

PETROLEUM VOCs, EPA Method 8260b AST SS-1 AST SS-2 SS-3 SS-4 SS-5 SS-6Benzene ND<12.0 ND<12.0 NA NA NA NA 640. 1,400.Toluene 15.5 43.2 520,000. 520,000.Ethylbenzene ND<12.0 37.0 400,000. 400,000.Total Xylenes ND<24.0 125. 270,000. 420,000.MTBE ND<24.0 ND<24.0 32,000. 70,000.1,3,5-trimethylbenzene ND<12.0 17.9 21,000. 70,000.1,2,4-trimethylbenzene ND<12.0 32.9 52,000. 170,000.Naphthalene 224. 120. 56,000. 190,000.n-butylbenzene ND<12.0 14.7 240,000. 240,000.n-propylbenzene ND<12.0 13.9 240,000. 240,000.PAHs, EPA Method 8270Acenaphthene ND<720. 417. ND<220. ND<76.0 NA NA 3,700,000. 29,000,000.Acenaphthylene 2,160. ND<198. ND<220. ND<76.0 NS NSAnthracene 2,230. 744. ND<220. ND<76.0 22,000,000. 100,000,000.Benzo(a)anthracene 8,310. ND<198. 582. ND<76.0 620. 2,100.Benzo(b&k)fluoranthene 10,800. ND<198. 691. ND<76.0 6,200. 21,000.Benzo(a)pyrene 7,200. ND<198. 933. ND<76.0 62. 210.Benzo(g,h,i)perylene 4,430. 238. 527. ND<76.0 NS NSChrysene 9,830. 248. 2,940. ND<76.0 62,000. 210,000.Dibenzo(a,h)anthracene 2,020. ND<198. 395. ND<76.0 62. 210.Fluoranthene 6,590. 258. 505. ND<76.0 2,300,000. 22,000,000.Fluorene 720. 1,050. ND<220. ND<76.0 2,700,000. 26,000,000.Indeno(1,2,3-cd)pyrene 3,960. ND<198. 351. ND<76.0 620. 2,100.1-Methylnaphthalene ND<720. 1,540. ND<220. ND<76.0 NS NS2-Methylnaphthalene ND<720. 873. ND<220. ND<76.0 NS NSNaphthalene ND<720. ND<198. ND<220. ND<76.0 56,000. 190,000.Phenanthrene 4,630. 7,930. 592. ND<76.0 NS NSPyrene 8,390. 952. 1,020. ND<76.0 2,300,000. 29,000,000.Total PAHs 71,270. 14,250. 8,536. ND - - - -TOTAL LEAD, EPA Method 6010 (mg/Kg)Total Lead NA NA NA NA 24.9 33.4 400. 800.

NOTES: All values reported in ug/kg, dry, unless otherwise indicated. NA - Not AnalyzedND<1.0 = Not Detected< Detection LimitResults reported above detection limits are indicated in boldPRG = Preliminary Remediation GoalResults reported above PRG Industrial are shadedNS = No PRG Standard


Sample Date: 8/16/2005Soil Boring Sample SB-7 SB-8 SB-9 EPA Region IX EPA Region IXSampling Depth (ft.) 0-2 0-2 0-2 PRG PRGPID Reading (ppm) 0.0 2.5 2.6 Residential IndustrialPETROLEUM VOCs, EPA Method 8260bBenzene NA ND<14.0 ND<11.0 640. 1,400.Toluene ND<14.0 ND<11.0 520,000. 520,000.Ethylbenzene ND<14.0 ND<11.0 400,000. 400,000.Total Xylenes ND<28.0 ND<22.0 270,000. 420,000.MTBE ND<28.0 ND<22.0 32,000. 70,000.1,3,5-trimethylbenzene ND<14.0 ND<11.0 21,000. 70,000.1,2,4-trimethylbenzene ND<14.0 ND<11.0 52,000. 170,000.Naphthalene ND<28.0 ND<22.0 56,000. 190,000.NON-PETROLEUM VOCs, EPA Method 8260bTetrachloroethene (PCE) NA ND<14.0 ND<11.0 480. 1,300.Trichloroethene (TCE) ND<14.0 ND<11.0 53. 110.1,1-Dichloroethane ND<14.0 ND<11.0 510,000. 1,700,000.cis-1,2-Dichloroethene ND<14.0 ND<11.0 43,000. 150,000.trans-1,2-Dichloroethene ND<14.0 ND<11.0 69,000. 230,000.1,2,3-Trichloropropane ND<28.0 ND<22.0 34. 76.Chloroform ND<14.0 ND<11.0 220. 470.Vinyl Chloride ND<28.0 ND<22.0 79. 750.PAHs, EPA Method 8270Acenaphthene NA ND<400. ND<350. 3,700,000. 29,000,000.Acenaphthylene 555. 596. NS NSAnthracene 436. 351. 22,000,000. 100,000,000.Benzo(a)anthracene 1,190. 1,470. 620. 2,100.Benzo(b&k)fluoranthene 2,540. 2,630. 6,200. 21,000.Benzo(a)pyrene 1,310. 1,330. 62. 210.Benzo(g,h,i)perylene 1,310. 701. NS NSChrysene 1,470. 1,330. 62,000. 210,000.Dibenzo(a,h)anthracene ND<400. 386. 62. 210.Fluoranthene 3,450. 2,980. 2,300,000. 22,000,000.Fluorene ND<400. ND<350. 2,700,000. 26,000,000.Indeno(1,2,3-cd)pyrene 1,150. 736. 620. 2,100.1-Methylnaphthalene ND<400. ND<350. NS NS2-Methylnaphthalene ND<400. ND<350. NS NSNaphthalene ND<400. ND<350. 56,000. 190,000.Phenanthrene 1,470. 421. NS NSPyrene 3,050. 2,590. 2,300,000. 29,000,000.Total PAHs - 17,931. 15,521. - -RCRA 8 Metals (mg/Kg)Total Arsenic ND<5.85 20.7 ND<4.95 0.39 1.6Total Barium 26.1 96.8 25.9 5,400. 67,000Total Cadmium ND<1.46 ND<1.44 ND<1.24 37. 450.Total Chromium 18.4 51.4 10.5 210. 450.Total Lead 47.5 107. 15.6 400. 800.Total Mercury ND<0.350 ND<0.447 ND<0.249 23. 310.Total Selenium ND<5.85 ND<5.76 ND<4.95 390. 5,100.Total Silver ND<1.46 ND<1.44 ND<1.24 390. 5,100.

NOTES: All values reported in ug/kg, dry, unless otherwise indicated.ND<1.0 = Not Detected< Detection LimitResults reported above detection limits are indicated in boldPRG = Preliminary Remediation Goal

former Verd Mont MillLudlow, Vermont

Soil Sample SB10‐1 SB10‐10 SB10‐11 SB10‐12 SB10‐17 EPASample Depth (ft.) 4‐6' 7‐9' 7‐9' 7‐9' 7‐9' RSLPID reading (ppm) 0.0 0.0 0.0 0.0 0.6 IndustrialSample Date 11/29/10 11/29/10 11/29/10 11/29/10 11/30/10VOCs, EPA Method 8260bBenzene ND<20.0 ND<10.0 ND<10.0 ND<10.0 ND<10.0 5,400Toluene ND<20.0 ND<10.0 ND<10.0 ND<10.0 ND<10.0 45,000,000Ethylbenzene ND<20.0 ND<10.0 ND<10.0 ND<10.0 ND<10.0 27,000Xylenes, Total ND<40.0 ND<20.0 ND<20.0 ND<20.0 ND<20.0 17,000,000MTBE ND<40.0 ND<20.0 ND<20.0 ND<20.0 ND<20.0 220,0001,3,5‐trimethylbenzene ND<20.0 ND<10.0 ND<10.0 ND<10.0 ND<10.0 10,000,0001,2,4‐trimethylbenzene ND<20.0 ND<10.0 ND<10.0 ND<10.0 ND<10.0 260,000Naphthalene ND<40.0 ND<20.0 ND<20.0 ND<20.0 ND<20.0 18,000IsoPropylbenzene ND<20.0 ND<10.0 ND<10.0 ND<10.0 ND<10.0 NAn‐Propylbenzene ND<20.0 ND<10.0 ND<10.0 ND<10.0 ND<10.0 NAtert‐Butylbenzene ND<20.0 ND<10.0 ND<10.0 ND<10.0 ND<10.0 NAsec‐Butylbenzene ND<20.0 ND<10.0 ND<10.0 ND<10.0 ND<10.0 NAp‐Isopropyltoluene ND<20.0 ND<10.0 ND<10.0 ND<10.0 ND<10.0 NA1,4‐Dichlorobenzene ND<20.0 ND<10.0 ND<10.0 ND<10.0 ND<10.0 12,0001,2‐Dichlorobenzene ND<20.0 ND<10.0 ND<10.0 ND<10.0 ND<10.0 9,800,000n‐Butylbenzene ND<20.0 ND<10.0 ND<10.0 ND<10.0 ND<10.0 NATetrachloroethene (PCE) ND<20.0 ND<10.0 ND<10.0 ND<10.0 ND<10.0 3,000Trichloroethene (TCE) ND<20.0 ND<10.0 ND<10.0 ND<10.0 ND<10.0 14,0001,1‐Dichloroethane ND<20.0 ND<10.0 ND<10.0 ND<10.0 ND<10.0 17,000cis‐1,2‐Dichloroethene ND<20.0 ND<10.0 ND<10.0 ND<10.0 ND<10.0 10,000,000trans‐1,2‐Dichloroethene ND<20.0 ND<10.0 ND<10.0 ND<10.0 ND<10.0 690,000Vinyl Chloride ND<40.0 ND<20.0 ND<20.0 ND<20.0 ND<20.0 2,000Acetone ND<200 ND<100 ND<100 ND<100 ND<100 610,000,0002‐Butanone (MEK) ND<200 ND<100 ND<100 ND<100 ND<100 190,000,000Dichlorodifluoromethane ND<100 ND<50.0 ND<50.0 ND<50.0 ND<50.0 780,000Methylene Chloride ND<100 ND<50.0 ND<50.0 ND<50.0 ND<50.0 54,000Total Reported VOCs ND ND ND ND ND ‐NOTES:

All values reported in ug/kg, dry, unless otherwise indicated.

RSL = Risk Screening Level November 2010

ND<1.0 = Not Detected< Detection Limit

Results reported above detection limits are indicated in bold

Values above the Residential RSLs are shaded.

Detection limits above the Residential RSLs are shaded.

NA = No RSL Available

VDH = Vermont Department of Health Soil Screening Values

NT = Analyte not tested

Italicized compounds added August 27, 2010


Page 1 of 4Ludlow, Vermont

former Verd Mont Mill

January 2011VTDEC # 2005-3345

KAS # 510040004


Soil Sample SB10‐2 SB10‐5 SB10‐6 SB10‐7 SB10‐8 EPASample Depth (ft.) 0‐2' 0‐2' 0‐2' 0‐2' 0‐2' RSLPID reading (ppm) 0.4 0.0 0.0 0.0 0.0 IndustrialSample Date 11/29/10 11/29/10 11/29/10 11/29/10 11/29/10PAHs, EPA Method 8270Acenaphthene ND<21.8 ND<17.8 ND<18.7 ND<19.0 22.8 33,000,000Acenaphthylene ND<21.8 ND<17.8 71.1 ND<19.0 253 NAAnthracene ND<21.8 ND<17.8 78.6 ND<19.0 116 170,000,000Benzo(a)anthracene 19.2 31.3 271. 17.9 379 2,100Benzo(b)fluoranthene 26.6 41.9 485. 22.8 1,180 2,100Benzo(k)fluoranthene ND<21.8 33.1 485. 19.4 1,180 2,100Benzo(a)pyrene 23.6 38.0 348. 21.7 801 210Benzo(g,h,i)perylene ND<21.8 30.6 165. 20.1 740 NAChrysene 21.8 40.2 277. 19.4 947 210,000Dibenzo(a,h)anthracene ND<8.7 ND<7.1 58.4 ND<7.6 82.2 210Fluoranthene 27.9 60.4 673. 29.6 1,770 22,000,000Fluorene ND<21.8 ND<17.8 22.1 ND<19.0 113 22,000,000Indeno(1,2,3‐cd)pyrene 24.0 30.2 214. 22.4 611 2,1001‐Methylnaphthalene ND<21.8 ND<17.8 ND<18.7 ND<19.0 1232‐Methylnaphthalene ND<21.8 ND<17.8 ND<18.7 ND<19.0 110 4,100,000Naphthalene ND<21.8 ND<17.8 ND<18.7 ND<19.0 92.0 18,000Phenanthrene ND<21.8 ND<17.8 240. ND<19.0 2,100 NAPyrene 27.9 52.6 500. 27.0 1,880 17,000,000Total Reported PAHs 171.0 358.3 3,888. 200.3 10,620 ‐

Soil Sample SB10‐9 SB10‐10 SB10‐11 SB10‐12 SB10‐17 SB10‐18 EPASample Depth (ft.) 0‐2' 0‐2' 0‐2' 0‐2' 0‐2' 0‐2' RSLPID reading (ppm) 0.0 0.0 0.0 0.0 0.0 0.0 IndustrialSample Date 11/29/2010 11/29/10 11/29/10 11/29/10 11/30/10 11/29/10PAHs, EPA Method 8270Acenaphthene ND<18.1 ND<95.9 ND<38.8 360 ND<18.3 20.5 33,000,000Acenaphthylene 23.6 ND<95.9 ND<38.8 553 ND<18.3 53.2 NAAnthracene 36.6 ND<95.9 ND<38.8 1,090 ND<18.3 128 170,000,000Benzo(a)anthracene 174 ND<95.9 ND<38.8 1,710 ND<9.2 427 2,100Benzo(b)fluoranthene 205 ND<95.9 ND<38.8 1,050 ND<9.2 782 2,100Benzo(k)fluoranthene 174 ND<95.9 ND<38.8 901 ND<18.3 488 2,100Benzo(a)pyrene 198 ND<95.9 ND<38.8 1,340 ND<7.3 717 210Benzo(g,h,i)perylene 158 ND<95.9 ND<38.8 711 ND<18.3 731 NAChrysene 282 393 100 1,730 ND<18.3 575 210,000Dibenzo(a,h)anthracene 49.7 ND<95.9 ND<38.8 158 ND<7.3 186 210Fluoranthene 466 ND<95.9 ND<38.8 3,520 ND<18.3 847 22,000,000Fluorene ND<18.1 ND<95.9 ND<38.8 819 ND<18.3 26.8 22,000,000Indeno(1,2,3‐cd)pyrene 186 ND<95.9 ND<38.8 917 ND<9.2 776 2,1001‐Methylnaphthalene ND<18.1 ND<95.9 ND<38.8 634 ND<18.3 24.82‐Methylnaphthalene ND<18.1 ND<95.9 ND<38.8 666 ND<18.3 28.8 4,100,000Naphthalene ND<18.1 ND<95.9 ND<38.8 359 ND<18.3 27.2 18,000Phenanthrene 291 163 77.9 3,930 ND<18.3 422 NAPyrene 415 ND<95.9 ND<38.8 3,250 ND<18.3 801 17,000,000Total Reported PAHs 2,659. 556 178 23,698 ND 7,061 ‐NOTES:

All values reported in ug/kg, dry, unless otherwise indicated.

RSL = Risk Screening Level November 2010







Page 2 of 4Ludlow, Vermont

former Verd Mont MillSoil Sampling Data Summary


KAS # 510040004


Soil Sample SB10‐1 SB10‐17 EPASample Depth (ft.) 4‐6' 7‐9' RSLPID reading (ppm) 0.0 0.6 IndustrialSample Date 11/29/10 11/30/10RCRA 8 TOTAL METALS (mg/kg, dry)Total Arsenic 6.2 2.5 1.6Total Barium 1,000 20 2,000Total Cadmium ND<0.39 ND<0.23 800Total Chromium 34 38 NATotal Lead 500 23 800Total Mercury 0.08 0.06 34Total Selenium ND<2.0 ND<1.1 5,100Total Silver ND<3.9 ND<2.2 5,100

Soil Sample SB10‐2 SB10‐3 SB10‐4 SB10‐5 SB10‐6 EPASample Depth (ft.) 0‐2' 0‐2' 0‐2' 0‐2' 0‐2' RSLPID reading (ppm) 0.4 0.0 1.1 0.0 0.0 IndustrialSample Date 11/29/10 11/29/10 11/29/10 11/29/10 11/29/10TOTAL METALS (mg/kg, dry)Total Arsenic ND<5.0 3.5 3.5 2.8 ND<3.1 1.6Total Lead NT 32 50 NT 8.5 800

Soil Sample SB10‐7 SB10‐8 SB10‐9 SB10‐10 SB10‐10 EPASample Depth (ft.) 0‐2' 0‐2' 0‐2' 0‐2' 7‐9' RSLPID reading (ppm) 0.0 0.0 0.0 0.0 0.0 IndustrialSample Date 11/29/10 11/29/10 11/29/10 11/29/10 11/29/10TOTAL METALS (mg/kg, dry)Total Arsenic 3.6 3.3 26 ND<3.2 NT 1.6Total Lead NT NT NT 9.7 17 800

Soil Sample SB10‐11 SB10‐11 SB10‐12 SB10‐12 SB10‐17 SB10‐18 EPASample Depth (ft.) 0‐2' 7‐9' 0‐2' 7‐9' 0‐2' 0‐2' RSLPID reading (ppm) 0.0 0.0 0.0 0.0 0.0 0.0 IndustrialSample Date 11/29/10 11/29/10 11/29/10 11/29/10 11/30/10 11/29/10TOTAL METALS (mg/kg, dry)Total Arsenic ND<3.6 NT ND<3.3 NT 3.9 4.7 1.6Total Lead 11 12 14 3.2 NT NT 800NOTES:

All values reported in mg/kg, dry, unless otherwise indicated.

RSL = Risk Screening Level November 2010 NT = Not Tested







Ludlow, Vermontformer Verd Mont Mill


Page 3 of 4


KAS # 510040004


Soil Sampling Data Summaryformer Verd Mont Mill

Ludlow, VermontPage 4 of 4

Soil Sample SB10‐10 SB10‐10 SB10‐11 SB10‐11 SB10‐12 SB10‐12 EPA Sample Depth (ft.) 0‐2' 7‐9' 0‐2' 7‐9' 0‐2' 7‐9' RSLPID reading (ppm) 0.0 0.0 0.0 0.0 0.0 0.0 IndustrialSample Date 11/29/10 11/29/10 11/29/10 11/29/10 11/29/10 11/29/10TPH 8015‐DRO 9,970 10.6 14,900 58.6 422 ND<3.0 NANOTES:

All values reported in mg/kg, dry, unless otherwise indicated.



Values above the VTDEC TPH Soil Cleanup Guideline are shaded.




KAS # 510040004

Groundwater Quality Summaryformer Verd Mont Mill

Ludlow, Vermont

MW‐1Sample Date

9/23/2004 8/26/2005 12/9/2010Volatile Organic Compounds (8260b) VGES (ug/L)Benzene ND<1.0 5.0Toluene ND<1.0 Well Well 1000.0Ethylbenzene ND<1.0 Not Not 700.0Xylenes ND<2.0 Sampled Sampled 10,000.0Total BTEX ND1,3,5‐Trimethylbenzene ND<1.0 0.10' 1,2,4‐Trimethylbenzene ND<1.0 Free FreeNaphthalene ND<1.0 Product Product 20.0MTBE ND<2.0 Detected Detected 40.0Acetone ND<10.0 700.02‐Butanone ND<10.0 4200.0Dibromomethane ND<2.0 ‐Diethyl Ether ND<5.0 ‐Tetrachloroethene ND<1.0 5.0Trichloroethene ND<1.0 5.0Vinyl Chloride ND<2.0 2.0Total VOCs ND ‐ RCRA 8 Metals (mg/L) VGES (mg/L)Total Arsenic ND<0.002 0.5Total Barium 0.072 2.0Total Cadmium ND<0.003 0.005Total Chromium ND<0.010 0.10Total Lead ND<0.002 0.015Total Mercury ND<0.001 0.002Total Selenium ND<0.010 0.05Total Silver ND<0.010 0.0001

NOTES:

All values reported in ug/L, unless otherwise indicated.

EPA Method 8260b used for laboratory analysis for VOCs

EPA Method 6010 and 7470 used for laboratory analysis for RCRA 8 Metals

ND<X ‐ Not Detected (Detection Limit)

Values above VGES (Vermont Groundwater Enforcement Standards) are shaded.

Values above the laboratory detection limit are in bold

‐ means no VGES for this compound

Only detected compounds, major petroleum and chlorinated solvents included in table.

350.0


Ludlow, Vermont

MW‐2Sample Date

9/23/2004 8/26/2005 12/9/2010Volatile Organic Compounds (8260b) VGES (ug/L)Benzene ND<1.0 ND<1.0 5.0Toluene ND<1.0 Well ND<1.0 1000.0Ethylbenzene ND<1.0 Not ND<1.0 700.0Xylenes ND<2.0 Sampled ND<2.0 10,000.0Total BTEX ND ND1,3,5‐Trimethylbenzene ND<1.0 ND<1.01,2,4‐Trimethylbenzene ND<1.0 Dry ND<1.0Naphthalene ND<1.0 ND<1.0 20.0MTBE ND<2.0 ND<2.0 40.0Acetone 34.9 ND<10.0 700.02‐Butanone 10.8 ND<10.0 4200.0Dibromomethane ND<2.0 ND<2.0 ‐Diethyl Ether ND<5.0 ND<5.0 ‐Tetrachloroethene ND<1.0 ND<1.0 5.0Trichloroethene ND<1.0 ND<1.0 5.0Vinyl Chloride ND<2.0 ND<2.0 2.0Total VOCs 45.7 ND ‐ RCRA 8 Metals (mg/L) VGES (mg/L)Total Arsenic 0.426 ND<0.001 0.5Total Barium 0.916 ND<0.020 2.0Total Cadmium 0.007 ND<0.002 0.005Total Chromium 0.294 ND<0.005 0.10Total Lead 0.018 ND<0.001 0.015Total Mercury ND<0.001 ND<0.0002 0.002Total Selenium ND<0.010 ND<0.002 0.05Total Silver ND<0.010 ND<0.020 0.0001

NOTES:



EPA Method SM19 3113B, 200.7, and 245.1 used for laboratory analysis for RCRA 8 Metals






350.0


Ludlow, Vermont

MW‐3Sample Date

9/23/2004 8/26/2005 12/9/2010 Volatile Organic Compounds (8260b) VGES (ug/L)Benzene ND<1.0 ND<1.0 ND<1.0 5.0Toluene ND<1.0 ND<1.0 ND<1.0 1000.0Ethylbenzene ND<1.0 ND<1.0 ND<1.0 700.0Xylenes ND<2.0 ND<2.0 ND<2.0 10,000.0Total BTEX ND ND ND1,3,5‐Trimethylbenzene ND<1.0 ND<1.0 ND<1.01,2,4‐Trimethylbenzene ND<1.0 ND<1.0 ND<1.0Naphthalene ND<1.0 ND<1.0 ND<1.0 20.0MTBE ND<2.0 ND<2.0 ND<2.0 40.0Acetone 21.9 ND<10.0 ND<10.0 700.02‐Butanone ND<10.0 ND<10.0 ND<10.0 4200.0Dibromomethane ND<2.0 ND<2.0 ND<2.0 ‐Diethyl Ether ND<5.0 ND<5.0 ND<5.0 ‐Tetrachloroethene ND<1.0 ND<1.0 ND<1.0 5.0Trichloroethene ND<1.0 ND<1.0 ND<1.0 5.0Vinyl Chloride ND<2.0 ND<2.0 ND<2.0 2.0Total VOCs 21.9 ND ND ‐ RCRA 8 Metals (mg/L) VGES (mg/L)Total Arsenic 0.073 0.022 ND<0.001 0.5Total Barium 0.501 0.249 0.020 2.0Total Cadmium 0.004 ND<0.004 ND<0.002 0.005Total Chromium 0.144 ND<0.025 ND<0.005 0.10Total Lead 0.120 0.038 ND<0.001 0.015Total Mercury ND<0.001 ND<0.002 ND<0.0002 0.002Total Selenium ND<0.010 ND<0.005 ND<0.002 0.05Total Silver ND<0.010 ND<0.010 ND<0.020 0.0001

NOTES:









Groundwater enforcement standards do not currenlty exist for PAHs

350.0


Ludlow, Vermont

MW‐4Sample Date

9/23/2004 8/26/2005 12/9/2010 Volatile Organic Compounds (8260b) VGES (ug/L)Benzene ND<1.0 ND<1.0 ND<1.0 5.0Toluene ND<1.0 ND<1.0 ND<1.0 1000.0Ethylbenzene ND<1.0 ND<1.0 ND<1.0 700.0Xylenes ND<2.0 ND<2.0 ND<2.0 10,000.0Total BTEX ND ND ND1,3,5‐Trimethylbenzene ND<1.0 ND<1.0 ND<1.01,2,4‐Trimethylbenzene ND<1.0 ND<1.0 ND<1.0Naphthalene ND<1.0 ND<1.0 ND<1.0 20.0MTBE ND<2.0 ND<2.0 ND<2.0 40.0Acetone ND<10.0 ND<10.0 ND<10.0 700.02‐Butanone ND<10.0 ND<10.0 ND<10.0 4200.0Dibromomethane ND<2.0 ND<2.0 ND<2.0 ‐Diethyl Ether ND<5.0 ND<5.0 ND<5.0 ‐Tetrachloroethene ND<1.0 ND<1.0 ND<1.0 5.0Trichloroethene ND<1.0 ND<1.0 ND<1.0 5.0Vinyl Chloride ND<2.0 ND<2.0 ND<2.0 2.0Total VOCs ND ND ND ‐ RCRA 8 Metals (mg/L) VGES (mg/L)Total Arsenic 0.002 0.002 ND<0.001 0.5Total Barium 0.074 0.042 0.036 2.0Total Cadmium ND<0.003 ND<0.003 ND<0.002 0.005Total Chromium ND<0.010 ND<0.025 ND<0.005 0.10Total Lead ND<0.002 0.002 ND<0.001 0.015Total Mercury ND<0.001 ND<0.001 ND<0.0002 0.002Total Selenium ND<0.005 ND<0.005 ND<0.002 0.05Total Silver ND<0.010 ND<0.010 ND<0.020 0.0001

NOTES:










350.0


Ludlow, Vermont

MW‐5Sample Date

9/23/2004 8/26/2005 12/9/2010 Volatile Organic Compounds (8260b) VGES (ug/L)Benzene ND<1.0 ND<1.0 ND<1.0 5.0Toluene ND<1.0 ND<1.0 ND<1.0 1000.0Ethylbenzene ND<1.0 ND<1.0 ND<1.0 700.0Xylenes ND<2.0 ND<2.0 ND<2.0 10,000.0Total BTEX ND ND ND1,3,5‐Trimethylbenzene ND<1.0 ND<1.0 ND<1.01,2,4‐Trimethylbenzene ND<1.0 ND<1.0 ND<1.0Naphthalene ND<1.0 ND<1.0 ND<1.0 20.0MTBE ND<2.0 ND<2.0 ND<2.0 40.0Acetone ND<10.0 ND<10.0 ND<10.0 700.02‐Butanone ND<10.0 ND<10.0 ND<10.0 4200.0Dibromomethane ND<2.0 ND<2.0 ND<2.0 ‐Diethyl Ether ND<5.0 ND<5.0 ND<5.0 ‐Tetrachloroethene ND<1.0 ND<1.0 ND<1.0 5.0Trichloroethene ND<1.0 ND<1.0 ND<1.0 5.0Vinyl Chloride ND<2.0 ND<2.0 ND<2.0 2.0Total VOCs ND ND ND ‐ RCRA 8 Metals (mg/L) VGES (mg/L)Total Arsenic 0.012 ND<0.002 ND<0.001 0.5Total Barium 0.085 0.140 0.057 2.0Total Cadmium ND<0.003 ND<0.004 ND<0.002 0.005Total Chromium ND<0.010 ND<0.010 ND<0.005 0.10Total Lead ND<0.002 ND<0.001 0.003 0.015Total Mercury ND<0.001 ND<0.001 ND<0.0002 0.002Total Selenium ND<0.005 ND<0.005 ND<0.002 0.05Total Silver ND<0.010 ND<0.010 ND<0.020 0.0001

NOTES:










350.0


Ludlow, Vermont

MW‐6Sample Date

9/23/2004 8/26/2005 12/9/2010 Volatile Organic Compounds (8260b) VGES (ug/L)Benzene ND<1.0 ND<1.0 ND<1.0 5.0Toluene ND<1.0 ND<1.0 ND<1.0 1000.0Ethylbenzene ND<1.0 ND<1.0 ND<1.0 700.0Xylenes ND<2.0 ND<2.0 ND<2.0 10,000.0Total BTEX ND ND ND1,3,5‐Trimethylbenzene ND<1.0 ND<1.0 ND<1.01,2,4‐Trimethylbenzene ND<1.0 ND<1.0 ND<1.0Naphthalene ND<1.0 ND<1.0 ND<1.0 20.0MTBE ND<2.0 ND<2.0 ND<2.0 40.0Acetone ND<10.0 ND<10.0 ND<10.0 700.02‐Butanone ND<10.0 ND<10.0 ND<10.0 4200.0Dibromomethane ND<2.0 ND<2.0 ND<2.0 ‐Diethyl Ether ND<5.0 ND<5.0 ND<5.0 ‐Tetrachloroethene ND<1.0 ND<1.0 ND<1.0 5.0Trichloroethene ND<1.0 ND<1.0 ND<1.0 5.0Vinyl Chloride ND<2.0 ND<2.0 ND<2.0 2.0Total VOCs ND ND ND ‐ RCRA 8 Metals (mg/L) VGES (mg/L)Total Arsenic 0.004 0.004 ND<0.001 0.5Total Barium 0.117 0.111 0.046 2.0Total Cadmium ND<0.003 ND<0.004 ND<0.002 0.005Total Chromium ND<0.010 ND<0.025 ND<0.005 0.10Total Lead 0.002 0.003 ND<0.001 0.015Total Mercury ND<0.001 ND<0.001 ND<0.0002 0.002Total Selenium ND<0.005 ND<0.005 ND<0.002 0.05Total Silver ND<0.010 ND<0.010 ND<0.020 0.0001

NOTES:










350.0


Ludlow, Vermont

MW10‐7Sample Date

12/9/2010 Volatile Organic Compounds (8260b) VGES (ug/L)Benzene ND<1.0 5.0Toluene ND<1.0 1000.0Ethylbenzene ND<1.0 700.0Xylenes ND<2.0 10,000.0Total BTEX ND1,3,5‐Trimethylbenzene ND<1.01,2,4‐Trimethylbenzene ND<1.0Naphthalene ND<1.0 20.0MTBE ND<2.0 40.0Acetone ND<10.0 700.02‐Butanone ND<10.0 4200.0Dibromomethane ND<2.0 ‐Diethyl Ether ND<5.0 ‐Tetrachloroethene ND<1.0 5.0Trichloroethene ND<1.0 5.0Vinyl Chloride ND<2.0 2.0Total VOCs ND ‐ RCRA 8 Metals (mg/L) VGES (mg/L)Total Arsenic ND<0.001 0.5Total Barium 0.039 2.0Total Cadmium ND<0.002 0.005Total Chromium ND<0.005 0.10Total Lead 0.004 0.015Total Mercury ND<0.0002 0.002Total Selenium ND<0.002 0.05Total Silver ND<0.020 0.0001

NOTES:










350.0


Ludlow, Vermont

MW10‐8Sample Date

12/9/2010 Volatile Organic Compounds (8260b) VGES (ug/L)Benzene ND<1.0 5.0Toluene ND<1.0 1000.0Ethylbenzene ND<1.0 700.0Xylenes ND<2.0 10,000.0Total BTEX ND1,3,5‐Trimethylbenzene ND<1.01,2,4‐Trimethylbenzene ND<1.0Naphthalene ND<1.0 20.0MTBE ND<2.0 40.0Acetone ND<10.0 700.02‐Butanone ND<10.0 4200.0Dibromomethane ND<2.0 ‐Diethyl Ether ND<5.0 ‐Tetrachloroethene ND<1.0 5.0Trichloroethene ND<1.0 5.0Vinyl Chloride ND<2.0 2.0

350.0

Vinyl Chloride ND<2.0 2.0Total VOCs ND ‐ RCRA 8 Metals (mg/L) VGES (mg/L)Total Arsenic ND<0.001 0.5Total Barium 0.052 2.0Total Cadmium ND<0.002 0.005Total Chromium ND<0.005 0.10Total Lead ND<0.001 0.015Total Mercury ND<0.0002 0.002Total Selenium ND<0.002 0.05Total Silver ND<0.020 0.0001

NOTES:











KAS #510040004 DEC Site #2005‐3345

APPENDIX C

PROPOSED SOIL BARRIER ISOLATION SYSTEM SOIL EXCAVATION AREA MAP


KAS #510040004 DEC Site #2005‐3345

APPENDIX D

WORK ELEMENTS AND SCHEDULE

ID Task Name Duration Start Finish

1 CAP SUBMITTAL / APPROVAL / PUBLIC NOTICE 30 days Fri 6/10/11 Thu 7/21/11

2 Submit CAP to DEC and EPA 1 day Fri 6/10/11 Fri 6/10/11

3 DEC Review 10 days Mon 6/13/11 Fri 6/24/11

4 CAP Revisions 5 days Mon 6/27/11 Fri 7/1/11

5 Submit Revised CAP to DEC 1 day Mon 7/4/11 Mon 7/4/11

6 Public Notice 10 days Tue 7/5/11 Mon 7/18/11

7 FINAL DESIGN AND PERMITTING 8 days Wed 7/6/11 Fri 7/15/11

8 PRE-CONSTRUCTION SURVEY 1 day? Mon 7/11/11 Mon 7/11/11

9 SITE WORK PREMARKING / WELL ABANDONMENT 1 day? Mon 9/5/11 Mon 9/5/11

10 CONTRACTOR MOBILIZATION 5 days Tue 9/6/11 Mon 9/12/11

11 SOIL EXCAVATION 1 day Mon 8/15/11 Mon 8/15/11

12 SOIL CAPPING 3 days Tue 8/16/11 Thu 8/18/11

13 SITE RESTORATION 1 day Fri 8/19/11 Fri 8/19/11

14 SOIL DISPOSAL COORDINATION / APPROVAL 10 days Mon 8/22/11 Fri 9/2/11

15 MONITORING WELL MW-1 REPLACEMENT 1 day? Mon 8/22/11 Mon 8/22/11

16 SOIL LOADING AND TRANSPORT 1 day? Mon 9/5/11 Mon 9/5/11

17 CONFIRMATORY GW MONITORING 1 day? Mon 9/5/11 Mon 9/5/11

18 AS BUILT REPORT PREPARATION 15 days Tue 9/6/11 Mon 9/26/11

19 Preparation 10 days Tue 9/6/11 Mon 9/19/11

20 DEC Review 5 days Tue 9/20/11 Mon 9/26/11

F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W TMay 15, '11 May 22, '11 May 29, '11 Jun 5, '11 Jun 12, '11 Jun 19, '11 Jun 26, '11 Jul 3, '11 Jul 10, '11 Jul 17, '11 Jul 24, '11 Jul 31, '11 Aug 7, '11 Aug 14, '11 Aug 21, '11 Aug 28, '11 Sep 4, '11 Sep 11, '11 Sep 18, '11 Sep 25, '11 Oct 2, '11 Oct 9, '11 Oct 16, '11 Oct 23, '11 Oct 30, '11 Nov 6, '11 Nov 13, '11 Nov 20, '11 Nov 27, '11

Task Split Progress Milestone Summary Project Summary External Tasks External MileTask Split

Page 1

Project: 2011 CAP ScheduleDate: Fri 6/10/11


KAS #510040004 DEC Site #2005‐3345

APPENDIX E

PUBLIC NOTICE

PUBLIC NOTICE A Corrective Action Plan (CAP) has been prepared to address human health risk and contaminant migration issues posed by subsurface contamination reported near the western portion of the former Verd Mont Mill Site in Ludlow, Vermont and near monitoring well MW‐1 (“corrective action area”). The CAP contains a summary of the results of environmental testing and risk assessment in the corrective action area, and also contains qualitative technical analysis of potentially applicable technologies to address the estimated human health and environmental risk posed by the contamination. Based on the qualitative technical analysis, a remedial technology is specified and a design is presented. The corrective action area was studied for environmental impacts between April 2004 and December 2010. A summary of the environmental studies performed is included in the CAP. Based on the results of this work, groundwater, drinking water and surface water human exposure pathways were minimized. Shallow surface soils across parts of the property were determined to contain contamination at concentrations above direct‐contact human health risk levels (corrective action area #1). Additionally, a limited area of light non‐aqueous phase liquid (LNAPL) was identified near monitoring well MW‐1 and corrective action area #2. A risk analysis has resulted in recommendations to physically isolate these shallow soils from direct human exposure and to impose an Activity Use Limitation to limit disruption of contaminated soil. Recommendations for source area removal were imposed to limit LNAPL contaminant migration. To accomplish the recommendations of the risk analysis, the principal remedial technology examined in the CAP is the installation of a soil barrier layer over corrective action area #1 along with soil excavation and disposal in the vicinity of monitoring well MW‐1 and corrective area #2. A notice to the land records of on site activity and use limitation will also be prepared. The remedial structure will remain in place until site redevelopment activities begin at which time the corrective action area will be reassessed. The recommended remedial action consists of a permeable geosynthetic membrane/soil barrier system on the western portion of the Site. Excavating and disposing of contaminated soil is proposed for a small area on the eastern portion of the site property near MW‐1. The estimated duration of construction is 1 week. Periodic inspection of the integrity of the remedial structure would be required. Groundwater monitoring will be performed following completion of the soil excavation and disposal near monitoring well MW‐1. For more information, Contact Mr. Hugo Martinez‐Cazon of the Vermont Department of Environmental Conservation (802)‐241‐3491, 103 South Main Street, Waterbury, Vermont 05671‐0404.


KAS #510040004 DEC Site #2005‐3345

APPENDIX F

HEALTH AND SAFETY PLAN

HEALTH AND SAFETY PLAN

FOR

FORMER VERD MONT MILL EAST HILL ROAD

LUDLOW, VERMONT

Project #: 510040004

KAS, INC. P.O. Box 787

368 Avenue D, Suite 15 Williston, VT 05495

Date: 5/2/2011

Rev. 10/04

INDEX PAGE GENERAL 1

1. OPERATIONAL INFORMATION 1 1.A CHAIN OF COMMAND 1 1.B EMERGENCY NOTIFICATION 2 1.C SITE PERSONAL PROTECTION EQUIPMENT (PPE) 3 1.D FIRE EXTINGUISHER LOCATION 4 1.E FIRST AID 4 1.F WORKER VISITOR LOG 4 1.G PLAN ACKNOWLEDGMENT FORM 4 1.H DAILY AIR MONITORING RECORD 4 1.I EMERGENCY CONTINGENCY PLANS 4 1.I.1 EVACUATION 5 1.I.2 MEDICAL EMERGENCY 6 1.I.3 ACCIDENTAL CONTAMINATION 8 1.I.4 FIRE 10 1.I.5 RELEASE OF HAZARDOUS MATERIALS 11 2. SITE HISTORY AND TASK DESCRIPTION 12 3. WORK AREAS 13 4. PROTECTIVE EQUIPMENT 13 4.A PROTECTIVE CLOTHING 13 4.B PERSONNEL PROTECTIVE REQUIREMENTS AND METHODS 13 4.C ACTION LEVELS 16 4.C.1 PHOTOIONIZATION DETECTOR RESPONSE 16 4.C.2 COMBUSTIBLE GAS RESPONSE 16 4.C.3 OXYGEN DETECTOR RESPONSE 16 4.D DECONTAMINATION PROCEDURES 17 5. SAFETY EQUIPMENT 18 5.A COLOR CODE 18 5.A.1 RED 18 5.A.2 YELLOW 18 5.B WARNINGS AND NOTIFICATIONS 18 5.C COMMUNICATIONS FOR ENTRY INTO HAZARDOUS AREAS 18

INDEX (cont.) 6. FIRE PREVENTION 19 6.A GENERAL CONSIDERATIONS 19 6.B EXPLOSIVE GAS SURVEY 19 7. ON-SITE MEDICAL PROVISIONS 19 7.A. ACCIDENT REPORTING 19 7.B FIRST AID 20 7.C HEAT STRESS 20 7.D COLD STRESS 21 7.E EMERGENCY NOTIFICATION 22 8. AIR QUALITY/AMBIENT AIR MONITORING 23 8.A PRELIMINARY SURVEY 23 8.B DAILY SURVEY 23 8.C RECORDS 23 8.D HAZARD ASSESSMENT 24 8.E ENGINEERING CONTROLS 26 9. SITE SECURITY 26 10. PROGRESS MEETINGS/PERSONNEL TRAINING 26 10.A TAIL GATE SAFETY MEETINGS 26 10.B ORIENTATION/INDOCTRINATION 27 10.C TRAINING 27 10.D WORKER AND COMMUNITY RIGHT TO KNOW 27 11. CONTRACTOR/VISITOR COMPLIANCE 29 12. OCCUPATIONAL NOISE 29 13. HEAVY EQUIPMENT OPERATIONS AND HEAVY MATERIALS HANDLING SAFETY 29 14. PLAN ACKNOWLEDGMENT 30 15. SITE SAFETY PERSONNEL RESPONSIBILITIES 30 16. CONFINED SPACE ENTRY 32 17. DRILLING SAFETY 33 18. EXCAVATING/TRENCHING SAFETY 33

INDEX (cont.) 19. ELECTRICAL SAFETY 35 APPENDIX A MSDS (MATERIAL SAFETY DATA SHEETS)

KAS, INC. EVACUATION MAP

DIRECTIONS TO THE HOSPITAL: Head north on East Hill Road (0.02 miles) Turn Right onto VT Route 103 (6.2 miles) Turn Left onto VT Route 10; becomes VT Route 106 (4.3 miles) Turn slight right onto VT Route 11 (0.4 miles) Turn Left onto Park Street Turn Right onto Ridgewood Road End at Springfield Hospital 25 Ridgewood Road, Springfield, Vermont SITE EVACUATION MAP:

EVACUATION ROUTES

KAS, INC.

HEALTH AND SAFETY PLAN ACKNOWLEDGEMENT LOG

I have read this Health and Safety Plan and understand its contents. I agree to fully comply with it. Name Organization Date Time

KAS, INC. WORKER/VISITOR LOG

NAME ORGANIZATION DATE TIME IN TIME OUT

GENERAL This site-specific Health and Safety Plan has been developed for site investigations and monitoring at petroleum-contaminated sites. This plan (and subsequent revisions) shall be in effect throughout the duration of the project. All personnel, regardless of their professional affiliation, are subject to the requirements of this plan when they are in the area defined as the site. 1. OPERATIONAL INFORMATION 1.A. Chain of Command - Responsible Individuals Jeremy Roberts , Project Manager Alan Liptak , Project Supervisor On-Site KAS Personnel , Site Safety Officer On-Site KAS Personnel , Assistant Site Safety Officer Non KAS Personnel: The chain of command for this project is as follows:

Immediate job coordination issues and/or scheduling will be brought to the attention of the Project Manager. If the project is of a size where there is no Project Manager assigned, issues will be brought to the attention of the Project Supervisor. Issues relative to personnel health and safety will be brought to the attention of the Site Safety Officer. Job progress meetings and issues requiring Corporate coordination and KAS input will be coordinated by the Project Manager or Project Supervisor.

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1.B Emergency Notification A list of all State and Local Police, Ambulance, and Rescue Departments and a listing complete with routes to hospitals and emergency facilities shall be maintained by the Site Safety Officer. The list must include phone numbers and quickest routes to areas facilities. The Site Safety Officer shall also contact the hospitals or emergency treatment center and inform them of an injured worker. Advice on the transportation method, and if necessary, decontamination or treatment shall be offered. Facilities to be posted on the site are listed below, including telephone numbers. Police Department: Phone 911 Address Fire Department: Phone 911 Address EMS Unit: Phone 911 Address Hospital: 911 Address:

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1.C. Site Personal Protective Equipment (PPE) Personal Protection Equipment (PPE) for this site will be Level D or Level D Plus, as described in Section 4 of this plan, and as dependent upon the task(s) to be conducted.

Task Level of Protection Water/product level monitoring D Water sampling D Soil screening/ sampling D Product bailing D O & M of Remedial Systems D Drilling/ Soil Borings/ Monitoring Well Installation D Plus Trenching D Plus Tank Pull Inspection D Plus Soil Grading D Plus Drum changes D Plus (hard hat optional)

PPE will be automatically upgraded to higher levels if the action limits for Level D are exceeded (see Section 4.C). The Site Supervisor or the Site Safety Officer has the authority to change the PPE level to suit the site conditions in accordance with the prescribed limits contained in this plan.

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1.D. Fire Extinguisher Location At least one fire extinguisher shall be kept in an accessible location on the KAS support vehicle. In addition, a fire extinguisher must be kept in an accessible location on any drill rig used on site. 1.E. First Aid A first aid kit is located in the KAS support vehicle on-site. 1.F. Worker/Visitor Log The attached logs must be completed for each worker or visitor to the site. 1.G. Plan Acknowledgment Form Each worker or visitor must read and understand this plan and then sign the attached acknowledgment form before being allowed on-site. 1.H. Daily Air Monitoring Record The attached Daily Air Monitoring Record must be completed by the end of each work day. 1.I EMERGENCY CONTINGENCY PLANS The following Emergency Contingency Plans represent the most likely emergencies to be encountered on-site. These Emergency Plans shall be followed if they have to be activated. The Site Supervisor has senior authority to implement and modify the plans to suit particular situations until a higher authority is physically on-site. All workers also carry the responsibility to initiate emergency plans if the situation presents and the Site Supervisor is not in the immediate area.

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EMERGENCY CONTINGENCY PLAN

1.I.1. EVACUATION It is possible that a site emergency could necessitate evacuating all personnel from the site. If such a situation develops, the Site Safety Officer, or designated representative, shall notify the Project Supervisor, or vice versa, of the event and they shall ensure that the evacuation is carried out in a calm, controlled fashion. All personnel shall exit the site and congregate in an area designated by the Project Supervisor and/or Site Safety Officer during the daily tailgate safety meeting. The route of evacuation will be dependent on wind direction, severity and type of incident, etc. The Project Supervisor and/or Site Safety Officer shall ensure that all personnel are accounted for. If someone is missing the Site Safety Officer shall alert emergency personnel.

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1.I.2. MEDICAL EMERGENCY The following procedures should be followed in the event of a medical emergency involving illness or injury to on-site personnel. EMS units should be called immediately, unless the injury or illness is determined to be minor, not requiring emergency care. Site operations should be shut-down and the site should be immediately secured. The area in which the injury or illness occurred shall be considered off-limits until the cause of the illness or injury is known. Assess the nature of the injury or illness and insure the site is safe for additional personnel to enter and provide care to the injured/ ill person(s). Assess the victim's condition, noting the level of consciousness and any cardiac or respiratory involvement. Administer first aid treatment to the injured person(s). 1) Check to see if the victim is conscious by talking loudly to them and gently jostling their shoulders. 2) If the victim is unconscious, check to see if they are breathing. Place an ear directly above their mouth and nose, at the same time looking toward the abdomen to watch for rise and fall of the chest cavity. 3) If the victim is not breathing, notify an EMS unit immediately, if one has not already been contacted. Administer rescue breathing if trained in this procedure, and check for a pulse. 4) If the victim is not breathing but maintains a pulse, continue rescue breathing (if trained) until the victim breathes on their own or until EMS rescue staff arrives. 5) If the victim is not breathing and has no pulse, administer Cardiopulmonary Resuscitation (if trained in this procedure) until EMS staff arrives and takes over, or until the victim recovers. If site work has been conducted at Personal Protective Level C or higher, the victim should be decontaminated as soon as possible after removal from the contaminated environment. This should be done in a non-contaminated area well away from the source of the problem. Extreme care should be used to avoid cross-contamination to rescuer personnel. The victim should be washed by water spray or safety shower. Contaminated protective clothing should be removed after washing. The victim should be covered with plastic or fitted with a Tyvek suit. The SCBA or respirator should be removed last, except in the case of a critical injury where the victim requires respiratory support. The victim should not be transported until decontamination is performed to the degree that other personnel will not be unduly subjected to cross-contamination. Instantaneous real-time air monitoring with photoionization detectors should be performed to ascertain if the illness or injury was caused by potential exposure to

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hazardous materials. Monitoring should be done both upwind and downwind of the incident site. The Fire Department should be notified if additional help is immediately needed, or if access to water for decontamination of the victim is not available at the site. If the victim appears to be critically injured, transport them to the nearest Emergency Room as soon as possible. The victim should not be transported to the hospital in anything other than an EMS Unit staffed by qualified personnel. If the victim's condition appears to be non-critical, and is anything more severe than minor cuts or bruises, they can be transported to the nearest hospital in a vehicle other than a EMS Unit staffed by qualified personnel. If the victim has sustained extremely minor injuries or a minor illness, it will be up to the discretion of the Site Safety Officer whether or not the victim should be treated on-site, and whether the victim may resume work. If the Site Safety Officer determines that the victim may not continue to work, the victim should be decontaminated and relieved of duty for the day. A physician or the victim's family physician should be contacted by the victim. Any incident shall be documented both in the project file and on an Injury/Illness Report Form available from KAS management personnel.

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1.I.3. ACCIDENTAL CONTAMINATION The following procedures shall be instituted immediately in the event of contamination of any person on-site by Hazardous Materials. If emergency rescue is needed to remove the victim from the contaminated area, notify EMS, Police, and Fire units immediately. Absolutely no emergency rescue is to be attempted without trained emergency rescuers. If the victim is able to move under their own power, escort them to a non-contaminated area as soon as possible. The site should be shut-down and immediately secured. The area in which the contamination occurred shall be considered off limits until the arrival of trained personnel who are properly equipped with the appropriate personal protective equipment and monitoring instrumentation. Assess the victim's condition for the nature of injury or contamination. The victim should be considered symptomatic if they exhibit any evidence of abnormal symptoms. Monitor the level of consciousness and any cardiac or respiratory involvement. Use special care to insure that you do not become contaminated as well. If any abnormal symptoms are present, notify EMS, Police, and Fire Department units immediately. Attempt to identify the exact type of material involved. If the material cannot be positively identified, attempt to acquire a grab sample. Use extreme caution if the danger of being contaminated exists. The victim should be decontaminated as soon as possible after removal from the contaminated environment. This should be done in a non-contaminated area well away from the source of the problem. Extreme care shall be taken to avoid cross-contamination. The victim should be washed by water spray or safety shower. Contaminated protective clothing should be removed after washing. The victim should be covered with plastic or fitted with a Tyvek suit. The SCBA or respirator should be removed last, except in the case of critical injury where the victim requires respiratory support. The victim should not be transported until decontamination is performed to the degree that other personnel will not be unduly subjected to cross-contamination. If the victim appears to be critically injured (i.e. unconscious, cardiac or respiratory abnormalities, seizures, etc.), support the victim's vital functions. Administer CPR if needed. The Fire Department should be notified if additional help is immediately needed, or, if access to water to wash and decontaminate the victim is not available at the site.

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If the victim appears to be symptomatic, the victim should be decontaminated and then transported to the nearest Emergency Room or appropriate medical assistance facility as soon as possible. The victim should not be transported other than by an EMS unit staffed by qualified personnel. The incident shall be documented both in the project file and on an Injury/Illness report form.

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1.I.4. FIRE The following procedures shall be instituted immediately in the event of a fire on-site. The site should be shut-down and immediately secured. The area in which the fire occurred should be considered off limits until the cause can be determined. All nonessential site personnel shall be evacuated from the site to a safe, secure area. Notify the Fire Department immediately. The four classes of fire along with their constituents are as follows:

Class A - Wood, cloth, paper, rubber, many plastics, ordinary combustible materials. Class B - Flammable liquids, gases and greases. Class C - Energized electrical equipment. Class D - Combustible metals such as magnesium, titanium, sodium, potassium.

Small fires on site may be actively attacked for control and extinguishing. Extreme care shall be taken while in this operation and protective clothing should be worn to protect personnel. If the fire involves hazardous materials, positive pressure self contained breathing apparatus is mandatory. The Site Safety Officer, or his/her representative, shall be responsible for all fire fighting activities on the site until a Fire Department is present. All approaches to the fire should be from the upwind side if possible. Distance from personnel to the fire should be close enough to ensure proper attack of the extinguishing material, but far enough away to ensure that personnel are safe. The proper extinguisher shall be utilized for the Class(es) of fire present on the site. If possible, the fuel source should be cut off or separated from the fire. Care must be taken when performing operations involving shut-off of valves and manifolds, if present. No attempt should be made against large fires. These should be handled by the Fire Department. All fire extinguishers should be recharged and inspected by qualified personnel after any use. All equipment shall be properly decontaminated prior to repair/recharging.

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1.I.5. RELEASE OF HAZARDOUS MATERIAL The following procedures shall be instituted immediately in the event of a spill or air release of a hazardous material on site. Site activities should be shut down and immediately secured. The area in which the spill or release occurred shall be considered off limits until the cause can be determined and site safety can be evaluated. All nonessential site personnel shall be evacuated from the site to a safe, secure area. The spilled or released product should be immediately identified and appropriate measures, such as dikes or berms, instituted to halt and contain the flow. If the spill extends into waterways, the Coast Guard and the National Response Center (1-800-424-8802) and appropriate State and Local Agencies should be notified immediately. Spill booms should be put in place in an attempt to curb downstream contamination. Instantaneous real-time air monitoring with ionization and combustible gas indicators should be started. Monitoring should be performed both upwind and downwind of the spill site or release point. Results of the air monitoring will determine the appropriate level of Personal Protective Equipment. If the released material is unknown, Level B protection is mandatory. Samples of the material should be acquired to facilitate identification of the material. If the results of the air monitoring show that the levels of contaminants exceed immediately dangerous to life or health (IDLH) values, the site shall be immediately evacuated and the appropriate Federal, State, County, and local regulatory authorities and emergency response personnel should be notified. Notify the Police and Fire Department immediately if contaminants are found to have migrated off site into populated areas, a large spill of flammable products is involved, or, the material is considered acutely toxic or exceeding published IDLH values. The procedures listed above shall be instituted if there is a discovery of an acutely toxic material in much larger quantities than expected. In this case, all personnel on the site should be cleared to a safe area and briefed in a tailgate safety meeting. The spill or release shall be reported to the appropriate Federal, State, County and Local regulatory authorities per the reporting standards of those regulatory agencies.

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2. SITE HISTORY AND TASK DESCRIPTION Contamination has been found at the Former Verd Mont Mill property in shallow surface soils in areas across the Site. Additionally, light non-aqueous phase liquid (LNAPL) has been measured in monitoring well MW-1. Tasks to be performed include implementation of remediation as outlined in the Corrective Action Plan.

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3. WORK AREAS Work and support areas shall be established based on ambient air data at the work sites. They shall be established in order to contain contamination within the smallest areas possible and shall ensure that each person on the site has the proper personal protective equipment for the area or zone in which work is to be performed. Adequate safety instruction signs shall be placed in areas where admittance is restricted due to a hazardous environment. Personnel shall not be permitted on the site alone during the following site activities: all work conducted in Level C or above Confined Space Entry activities trenching and pipe installation for remedial system installation drilling activities Personnel in these situations shall use the "Buddy System", in groups of two or more, while on site. Non-KAS personnel (i.e., drillers, excavators) may serve in the capacity of a "Buddy" while on site conducting the above-noted activities. Personnel may be on-site alone for Level D site activities, if Confined Space Entry activities are not in progress. 4. PROTECTIVE EQUIPMENT 4.A. Protective Clothing Protective clothing shall be worn by all persons on site as directed by the Site Supervisor and/or Site Safety Officer for the job. 4.B. Personnel Protection Requirements and Methods Action levels are those concentrations of which an upgrade in protective clothing or equipment is required. Organic vapor concentrations are to be continuously monitored in the field by use of an HNu, or a device of similar capability, with readings being taken in the breathing space occupied by the field personnel to determine whether an action level has been exceeded. The Site Safety Officer shall designate the appropriate level of protection for personnel entering the work area as determined by the predetermined action level. It shall be the responsibility of each contractor to supply their personnel with the required personal protective equipment and to ensure that they are knowledgeable and proficient in its use. The Site Safety Officer has the authority to reject the credentials of any person and disallow their entry to the site if he/she feels that any person is insufficiently qualified or protected for the tasks at hand.

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Respiratory protection shall be selected for use as warranted by breathing zone air monitoring and type of site work being performed. Levels of Protection are as follows, listed in order from highest to lowest protection: Level A Protection Level A should be selected when the highest level of respiratory, skin and eye protection is needed. Level A is generally used when extremely hazardous substances are known to be present in high atmospheric concentrations and were Level B splash gear does no offer adequate protection against any dermal-active substances present or where materials and concentrations are unknown. Level A is used where air-borne compound(s) exceeding the Immediately Dangerous to Life or Health limit may be encountered.

Approved, positive pressure-demand, self contained breathing apparatus (SCBA) or airline Full encapsulating, chemical-resistant clothing Gloves (outer/inner), chemical resistant Chemical-resistant disposable outer-boot coverings, Boots with toe and shank protection Hard hat All seams between protective clothing items will be sealed with duct tape Two-way radio communications

Level B Protection Level B should be selected when the type and atmospheric concentrations of substances have been identified and the highest level of respiratory protection is required, but a lesser level of skin protection is needed. Generally Level B protection is used in situations where the chemical(s) is known, the atmosphere is oxygen deficient (less than 19.5%), no IDLH concentrations of substances which pose a respiratory hazard are present, or where dermal contact with a hazardous substance is unlikely.

Approved, positive pressure-demand, self contained breathing apparatus (SCBA) or airline Chemical-resistant clothing Gloves (outer/inner), chemical resistant Chemical-resistant disposable outer-boot coverings Boots with protective toe and shank Hard hat All seams between protective clothing items will be sealed with duct tape

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Level C Protection Level C should be selected when the type of air contaminants have been identified, concentrations have been measured, and the criteria for using air-purifying respirators are met, and skin-exposure to dermal-hazardous compounds are not expected. Appropriate cartridges must be available removal of the subject contaminant(s) to be encountered. The atmospheric concentration of oxygen must be greater than and equal to 19.5% (but not in-excess of 23%). Use of Level C requires continuing measurement of air contaminants to ensure that IDLH concentrations do no exist and that the concentrations of the contaminants present do not exceed the service limits of the respirator.

Approved, full face or half-face air purifying, cartridge/canister-equipped respirator Chemical-resistant clothing Gloves (outer/inner), chemical resistant Chemical-resistant disposable outer-boot coverings, Boots with protective toe and shank Hard hat All seams between protective clothing items will be sealed with duct tape

Level D Protection: Level D should be selected when the contaminants are known, when airborne contaminant levels are below appropriate TLV limits, and there is no hazard for direct skin contact. At a minimum, Level D protection shall require use of the following protective equipment.

Standard work uniform Substantial boots Goggles or safety glasses w/ side shields Latex gloves Chemical resistant outer gloves are required for work tasks involving contact

with pure petroleum products.

In addition, certain work site tasks will require additional personal protective equipment to protect against injury around heavy machinery and overhead hazards, as well as potential splash hazards. These tasks will be conducted in Level D Plus protection Level D Plus all PPE listed for Level D above except boots must have protective toe and shank hard hat

No person may be assigned a task requiring the use of respiratory protection equipment without first being properly trained in its use and limitations and having passed the appropriate OSHA physical. Before the wearing of any respiratory protection equipment

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is permitted, the wearer must first complete a fit test, and must be completely aware of fitting procedures. No person may be assigned a task requiring the use of respiratory equipment where it has been determined that that person has a physical limitation which might result in injury in conjunction with respiratory equipment use. All respiratory equipment shall be properly fitted to worker(s) who will be using such equipment. All equipment shall be properly cleaned and inspected for work parts as often as necessary. SCBA's should be inspected once a month at a minimum. All respiratory equipment shall be cleaned and a fit test shall be satisfactorily passed before being worn by a different operator. Any persons wearing glasses who must wear respiratory equipment must wear short-templed or no-templed glasses which may be taped to the wearers face, to prevent interference with the respiratory face piece. Applicable protective clothing shall be selected and worn at all times by personnel exposed to, or in areas suspected of, contamination. 4.C. Action Levels All initial site access and activities will be done in Level D attire. 4.C.1. Photoionization Detector Response in breathing zone (ppm):

0 to 100: Level D 101 to 750: Level C 751 to 10,000: Level B or A Above 10,000: Immediately vacate the area

4.C.2. Combustible Gas Response

0.0 to 20.0% LEL: Continue with normal activity Above 20.0% LEL: Immediately vacate the area

Note: Confined Space activities have lower LEL levels. See KAS Confined Space Plan for levels.

4.C.3. Oxygen Detector Response

0.0 to 19.5% Oxygen: Level B is mandatory 19.5% to 23.0% Oxygen: Continue with normal activity Above 23.0% Oxygen: Immediately vacate the area

4.D. Decontamination Procedures

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Where high levels of site contamination are discovered such that respiratory, skin and eye protection are necessary, decontamination will be required. The support area will be positioned so that no one is permitted to enter or leave without passing through the decontamination station. At the boundary between the work and support areas, decontamination processes for equipment and personnel are required. All access to and from the work area will be through this section of the support area. Decontamination shall be performed to protect workers from exposure to dangerous materials and to eliminate the hazard of contamination on equipment. All water used in decontamination procedures, which is not treated at the site, shall be stored in portable storage tanks, until disposal takes place. At each work location reusable sampling and personal protective equipment shall be decontaminated prior to sampling, between each sample, and after sampling. Sampling equipment shall be decontaminated by steam cleaning or washing with a mixture of Alconox and water, then rinsed twice with distilled water and allowed to air dry. All decontamination solutions shall be disposed at the work station where they were generated. Disposable sampling and personal protective equipment will be placed in plastic bags and temporarily stored in designated drums. These drums shall be disposed of according to regulatory guidelines. The sequence of steps for removing and cleaning personal protective equipment follows:

Wash gloves, boots, and outer disposable coveralls Rinse work gloves, boots, coveralls Remove outer boots (if used) and outer gloves Remove hard hat Remove disposable coveralls Remove respirator or masks Wash respirator Package and/or dispose of respirator or filters Dispose of all contaminated items in properly labeled drums If necessary, copy notes from contaminated paper onto clean paper while wearing inner gloves (surgical gloves) at decontamination station area. Remove latex gloves Dispose of latex gloves and contaminated note paper Wash hands and face.

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5. SAFETY EQUIPMENT 5.A. Color Code 5.A.1. Red Red shall be used to identify fire equipment; identify containers of flammable materials; stop bars/buttons on mechanical machinery used for emergency power disconnection. 5.A.2. Yellow Yellow shall be used as the basic color for identifying caution. Physical hazards shall be marked by yellow signs. 5.B. Warnings and Notifications Signs and tags shall be of a design in accordance with 29 CFR 1910.145.d. Specific signs designated in this section are danger, caution, slow-moving vehicle, biological hazard, and safety instruction. Signs shall be worded in a clear, concise manner. Tags shall be used for temporary situations, to warn of broken equipment or other similar hazard. Temporary hazards should be remedied as quickly as possible. Tags will be designed in accordance with 29 CFR 1920.145.f-2. 5.C. Communications for Entry Into Hazardous Areas Where large distances may separate workers or in extremely dangerous areas, a communication network shall be established. The use of hand signals may be employed in close areas where portable radios are inconvenient, or unavailable.

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6. FIRE PREVENTION 6.A. General Considerations Fire prevention and protection techniques shall be instituted on-site to minimize sparks. All smoking and utilization of tools requiring open flames will be used only with the express permission of the Site Safety Officer. A fire extinguisher must be maintained in the immediate vicinity of the open-flame work. Emergency procedures in case of fire shall be discussed with workers before every new work area location or new work activity begins. Diagrams of emergency routes shall be displayed in the work areas and in areas and any other areas where workers will break from work activities. Only Fire Marshall approved metal safety cans will be used to transport and store flammable liquids. All gasoline and diesel-driven engines requiring refueling must be shut down and allowed to cool before filling. No open flame or spark is allowed in any area containing flammable liquids. 6.B. Explosive Gas Survey Before new work locations are entered in which the there is a probability for the buildup of explosive vapors, an explosive gas survey shall be conducted. If there are no explosive gases or vapors, work activities may commence. If explosive levels are registered, then work activities shall stop and workers moved out of the immediate work area. Work shall not begin until explosive levels are no longer registering on the meter or the source of the explosive gases are found and corrected. During work activities, monitoring for explosive vapors shall be continuous. 7. ON-SITE MEDICAL PROVISIONS 7.A. Accident Reporting When an emergency situation occurs, a warning procedure shall be initiated by the first person to recognize the situation. As appropriate, EMS, Fire, and Police Departments shall be notified immediately. In the event of an accident or injury of any type on-site, a report of the incident shall be completed immediately after appropriate first aid has been rendered. The Site Supervisor shall be responsible for remedial plan of action and for completing an injury report.

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7.B. First Aid A first aid kit shall be located on site. It shall be the responsibility of the Site Supervisor/Safety Officer to notify all personnel as to the location and proper use of these items. Vehicles used for site work shall be equipped with a first aid/safety kit and safety equipment. 7.C. Heat Stress Heat stress may be of concern depending upon the ambient temperature. The heat stress of personnel on-site shall be monitored continually when heat stress potential is evident. One or more of the following control measures can be used to help control heat stress:

Adequate replacement of lost body fluids. Personnel must replace water and salt lost from sweating. Personnel must be encouraged to drink more than the amount required to satisfy thirst. Thirst satisfaction is not an accurate indicator of adequate salt and fluid replacement. Replacement fluids can be a 0.1% salt water solution, a commercial mix or a combination of these and fresh water. Establishment of a work regimen that will provide adequate rest periods for cooling down. All breaks are to be taken in cool areas. Personnel shall remove impermeable protective garments during rest periods. Personnel shall not be assigned other tasks during rest periods. All personnel shall be informed of the importance of adequate rest, acclimatization and proper diet in the prevention of heat stress.

Heat Stress Monitoring Heat stress may occur even in moderate temperatures and may present heat rash, heat cramps, heat exhaustion, and/or heat stroke. Monitoring procedures shall be implemented to prevent heat stress arising from any of the following: environmental conditions, use of personal protective equipment, intensity of workload. Such procedures may include the following:

Signs and Symptoms of Heat Stress Treatment

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Heat rash Increase fluid intake - red rash on the skin Heat cramps Rest in cool areas - muscle spasms - pain in the hands, feet, and abdomen Heat exhaustion Loosen clothing - pale, cool moist skin Apply cool water to - heavy sweating skin surfaces - dizziness, nausea, fainting Heat stroke Transport to nearest - red, hot, usually dry skin hospital if symptoms - lack of or reduced perspiration are not reversed by - nausea the above listed - dizziness and confusion measures; - strong, rapid pulse - coma

7.D. Cold Stress If the project is conducted during cold weather, cold stress must be addressed. Persons working outdoors in temperatures at or below freezing may become frostbitten. Extreme cold, even for a short time, may cause severe injury to the surface of the body, or result in profound generalized cooling, causing death. Areas of the body which have high surface-area-to volume ratios such a fingers, toes, and ears are the most susceptible. Two factors heavily influence the development of a cold injury; ambient temperature and the velocity of the wind. Wind chill is used to describe the chilling effect of moving air in combination with temperature. For instance, 10 degrees F., with a wind of 15 miles per hour is equivalent in chilling effect to still air at least 18 degrees below zero. As a general rule, the greatest incremental increase in wind chill occurs when a wind of 5 mph is increased to 10 mph. Additionally, water conducts heat 240 times faster than air. Thus, the body cools suddenly when chemical-protective equipment is removed if the clothing underneath is perspiration soaked. Local injury resulting from cold is generally termed frostbite. Frostbite of the extremities can be categorized into:

Frost nip or initial frostbite: characterized by sudden blanching or whitening of the skin.

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Superficial frostbite: skin has a waxy or white appearance and is firm to the touch, but tissue beneath is resilient. Deep frostbite: tissues are cold, pale and solid; extremely serious injury. Systematic hypothermia is caused by exposure to freezing or rapidly dropping temperature. Its symptoms are usually exhibited in five stages: shivering, apathy/listlessness, unconsciousness/slow responses, freezing of the extremities, death.

Thermal socks, long poly or thermal underwear, hard hat liners and other cold weather gear can aid in the prevention of hypothermia. Cotton should be avoided due to its moisture retention characteristics. Blankets, warm drinks (other than caffinated coffee) and warm break areas are essential. The overall goal is to keep from getting wet. If one does get wet, he/she should dry off and change clothes. 7.E. Emergency Notification A list of all State and Local Police, Ambulance, and Rescue Departments and a listing complete with routes to all hospitals and emergency facilities shall be maintained by the Site Safety Officer (see Section 1 of this HASP). The list must include phone numbers and quickest routes to appropriate emergency facilities. The Site Safety Officer shall also contact the hospitals or emergency treatment center and inform them of an injured worker. Advice on the transportation method, and if necessary, decontamination or treatment shall be offered. Facilities to be posted on the site are listed below.

Police Department Fire Department EMS Unit Hospital

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8. AIR QUALITY/AMBIENT AIR MONITORING 8.A. Preliminary Survey All air monitoring will be conducted by a trained professional. The professional shall have adequate working experience. He/she will have a sound working knowledge of State and Federal Occupational, Safety and Health regulations, and formal training in occupational safety and health. The preliminary survey will be conducted using one or more of the following portable real-time instrumentation:

Photoionization Detector Explosimeter Oxygen Meter Draeger type tube

8.B. Daily Surveys Ambient air monitoring shall be conducted throughout the duration of all operations on site. A minimum of five locations around the perimeter of the site will be established and actively monitored during operations. In the event that daily air analyses determine that ambient air quality exceeds recommended levels for the respiratory equipment utilized, the Project Site Supervisor/Site Safety Officer shall be notified immediately. The Project Site Supervisor/Site Safety Officer shall immediately inspect operating conditions at the site and attempt to determine the cause of the elevated levels in the ambient air. The Project Site Supervisor/Site Safety Officer may require changes in the operating procedures in order to reduce or eliminate elevated conditions. In the event elevated levels persist after several attempts to reduce such levels, the Project Site Supervisor shall immediately stop all operations at that location and either remove workers from the location until conditions are improved or a higher level of PPE is employed. Ambient air monitoring will be continued until safe levels are assured. This program will be conducted and monitored by the Site Safety Officer or his/her designee. All equipment utilized for sampling shall be maintained and calibrated and shall be documented and included in project record documents. 8.C. Records Accurate records shall be kept of all air monitoring results. These records should include date, time, place of sample, air temperature, weather conditions, and a physical description of any obvious hazards that may influence the results of the tests. These records shall be maintained as part of the permanent job records by KAS, Inc.

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8.D. Hazard Assessment Personnel present on-site shall be advised of all potential hazards associated with the substances that are present. The following are physical and chemical parameters of PERC:

Specific Gravity 60/60 deg. F 1.62 Source: www2.hazard.com/msds/mf/cards/file/0076.html (International Chemical Safety Cards)

Physical parameters of other chlorinated solvent are presented in the Material Safety Data Sheets (MSDSs) included in Appendix A of this HASP. The following are air quality limits for gasoline obtained from the MSDSs included in Appendix A.

TLV-TWA - Threshold Limit Value, Time-Weighted Average 50 ppm TLV-STEL - Threshold Limit Value, Short-Term Exposure Limit 200 ppm Source: 1990-1991 Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices, ACGIH

Slippery Surfaces: Skid proof soles are highly recommended. Organic Vapors: The inhalation of volatile organic vapors during any operation can pose a potential health hazard. Hazard reduction procedures include monitoring the ambient air with a PID and use of appropriate PPE. Workers should stand upwind of the source of contamination whenever possible. If ambient air levels in the breathing zone exceed the limits specified in Section 4C of this HASP, upgrades in PPE must be immediately undertaken.

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Flammable Vapors: Presence of flammable vapors can pose a potential fire hazard and health hazard. Hazard reduction procedures include monitoring the ambient air with an O2/LEL meter. If the LEL reading exceeds 20%, leave the site immediately and contact the Fire Department. Oxygen: Atmospheres that contain a level of oxygen greater than 23% pose an extreme fire hazard (the usual ambient oxygen level is approximately 20.5%). This hazard can be compounded by the fact that vapors typical of gasoline retailing facilities are highly flammable. All personnel encountering atmospheres that contain a level of oxygen greater than 23% must evacuate the site immediately and must notify the fire department. If oxygen level is less than 19.5%, do not enter the space. Vehicular Traffic: When working on or near traveled ways, all personnel will be required to wear a fluorescent safety vest. In addition, the following safety equipment procedures must be adhered to for day time work. To secure an ongoing work site overnight in a heavy traffic area, appropriate lighted barricades must be used.

TASK TRAFFIC SAFETY EQUIPMENT Soil boring samples A Drilling A Subsurface Entry A Well Installation A Well Maintenance B Well Survey B Well Gauging B Well Development B Sampling B Pump Test B Excavation A

Safety Equipment Key : A = Cones and barricades required- tapes and flags are recommended but optional. B = Cones are required - flags are recommended but are optional.

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Well Installation; Well Development; Well Gauging; Well Bailing; Soil & Groundwater Sampling: Skin and eye contact with contaminated groundwater and/or soil may occur during these tasks. Nitrile or Viton gloves and approved safety goggles should be worn when contact with contaminated substance and/or splash is possible. This PPE will be worn at the discretion of the Site Safety Officer, dependent on the task. Sample Preservation: When hydrochloric acid is used, skin and eye contact can occur. This hazard can be reduced with the use of Nitrile or Viton gloves and the use of safety goggles or glasses. Cleaning Equipment: Skin and eye contact with methanol, Alconox, or other cleaning substances can occur while cleaning equipment. This hazard can be reduced with the use of Nitrile or Viton gloves and the use of goggles or glasses. 8.E. Engineering Controls Where feasible, engineering controls shall be the primary means utilized to maintain containment exposure within the limits prescribed to be safe. 9. SITE SECURITY The Project Site Supervisor shall be responsible for the management of any security implemented at the site. Access to the site shall be at the discretion of the Site Supervisor. No visitors shall be allowed without the approval of the Project Supervisor. Visitors shall not be permitted to enter known or suspected active hazardous work areas without proper indoctrination by the Site Safety Officer and Project Supervisor. 10 . PROGRESS MEETINGS/PERSONNEL TRAINING 10.A. Tailgate Safety Meetings Tailgate safety meetings shall be held at the beginning of each shift at a central location in a non-contaminated area. All ongoing activities shall be discussed, and air monitoring results will be presented. Safety measures shall be reviewed to ensure all employees are aware of all precautionary methods and emergency procedures.

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10.B. Orientation/Indoctrination Orientation and Indoctrination of all new personnel shall be conducted by the Project Site Supervisor/Site Safety Officer before new workers are allowed access to the work area. The indoctrination shall include discussion of work activities, chain of command, respiratory protection program, emergency work exits and any other applicable information governing everyday work activities. 10.C. Training All personnel are required to be trained in the following areas of health and safety awareness: Basic Safety: this includes cause and prevention of slip, trip and fall hazards, safe drum handling and opening techniques, safe lifting techniques, heat stress illness and its prevention, etc. Hazardous Protection: dealing with the identification, recognition and safe work procedures for toxic materials. This would include having knowledge of the use and limitation of applicable protective clothing, respirators, and decontamination procedures. Respirator fit tests for all personnel required to use respirators fall under this category. Information pertaining to routes of exposure, toxic effects, and specific nature of the job which could result in exposure shall be conveyed at this time. 10.D. Worker and Community Right-To-Know The following contaminants have been identified, or are suspected, in either groundwater or soil samples as being in excess of prescribed limits:

Unleaded Gasoline Leaded Gasoline Kerosene Diesel Fuel Waste Oil

Health Effects: Potential health effects from a chemical exposure are dependent on several exposure factors such as: toxicity of substances, duration of exposure, concentration during exposure and the overall health of the person exposed. The chemicals or chemical constituents potentially contaminating this site are: Gasoline, Benzene, Toluene, Ethyl benzene, and Xylene and methyl tert-butyl ether. The following is a health analysis of these chemicals. Additional information on these chemicals can be found in the generic Material Safety Data Sheets attached in Appendix A.

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Gasoline constituents can be divided into five major groups: alkanes, alkenes, cycloalkanes, aromatics and additives. The aromatics are the constituents generally regarded to be of greatest toxic concern. The major aromatics in gasoline are benzene, toluene, ethyl benzene and xylene. Of these, benzene is considered to be the most toxic. One characteristic effect of gasoline and its aromatic constituents is their ability to irritate the skin when repeated or prolonged exposure occurs. Benzene Benzene can enter the body through inhalation, ingestion and skin contact. Studies have noted that chronic exposure to benzene vapor can produce neurotoxic and hematopoietic (blood system) effects. Other effects can include headache, dizziness, nausea, convulsions, coma and possible death if exposure is not reversed. One significant effect from chronic benzene exposure is bone marrow toxicity. There is also an association between chronic exposures to benzene and the development of certain types of leukemia. OSHA lists benzene as a human carcinogen. Toluene Inhalation exposure to toluene vapor can produce effects such as central nervous system depression. Depending on exposure factors signs and symptoms can include headache, dizziness, fatigue, muscular weakness, in coordination, drowsiness, collapse and possible coma. Toluene can be a skin and mucous membrane irritant and studies have shown that high levels of toluene exposure can cause liver and kidney damage. Xylenes Depending on exposure factors, inhalation exposure to xylene vapor may produce central nervous system excitation followed by depression. Exposure to xylene vapor may produce lung irritation, nausea, vomiting and abdominal pain. Xylene is not known to possess the chronic bone marrow toxicity of benzene, but liver enlargement and nerve-cell damage have been noted from chronic overexposure. Ethyl Benzene Exposure to ethyl benzene at high vapor concentrations may produce irritation to the skin, eyes and upper respiratory tract. Overexposure to ethyl benzene vapors can produce central nervous system depression with symptoms of headache, nausea, dizziness, shortness of breath and unsteadiness. Prolonged skin exposure to ethyl benzene may result in drying and cracking of the skin (dermatitis). Any person needing specific information on any of the chemicals listed above should contact the Site Safety Officer. They will be provided in accordance with OSHA 29 CFR 1910.1200.

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11. CONTRACTOR/VISITOR COMPLIANCE All EPA, State and Federal regulations shall be adhered to by contractors and visitors during excavation, disposal and construction operations or any other site operation. 12. OCCUPATIONAL NOISE Requirements set forth in the OSHA Hearing Conservation Amendment (OSHA 1910.95) shall be adhered to during work on-site. Hearing protection shall be provided where sound pressure levels exceed 85 dBA, 8 hours per day, 90 dBA, 4 hours per day. Hearing protection shall be required where sound pressure levels exceed 90dBA. Hearing Protection shall be worn during all rotary drilling operations. 13. HEAVY EQUIPMENT OPERATIONS AND HEAVY MATERIALS HANDLING SAFETY The following information warrants extra attention regarding work around heavy equipment (drilling rigs, front and back hoe loaders, etc.) and heavy materials:

Use common sense Hard hats shall be worn at all times on-site Pay attention at all times Maintain visual contact at all times Establish hand signal communication when verbal communication is difficult. Designate one person per work group to give hand signals to equipment operators. Be aware of footing at all times All heavy equipment shall have backup alarms of some type Only qualified people are to operate heavy equipment Use chains, hoists, straps, and any other equipment to safely aide in moving heavy materials Never walk directly in back of, or to the side of, heavy equipment without the operator's knowledge Never use a piece of equipment unless you are familiar with its operation

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Pipe sections and other materials to be removed during any project may be extremely heavy. Make sure all precautions have been taken prior to moving. Let the equipment, not your body, do the moving. Be sure that no underground or overhead power lines, sewer lines, gas lines, or telephone lines will present a hazard in the work area Get help whenever you are in doubt about a material's weight. Use the "Buddy System" Ensure that compressed air bottles are secured properly at all times.

14. PLAN ACKNOWLEDGMENT All on-site workers, regardless of their affiliation, are required to have read this entire Health and Safety Plan, and must sign the accompanying form to acknowledge this. 15. SITE SAFETY PERSONNEL RESPONSIBILITIES The responsibilities of all personnel involved in health and safety operations are stated below: KAS, Inc. will oversee and act accordingly during all phases of the project. The following management structure will be used. Project Manager:(If required by work scope) The Project Manager shall be responsible for implementing the project and obtaining any necessary personnel or resources for the completion of the project. Specific duties will include:

coordinating the activities of all subcontractors, to include informing them of the required personal protective equipment and insuring their signature acknowledging this Site Safety Plan, selecting a Site Safety Officer and field personnel for the work to be undertaken on site, ensuring that the tasks assigned are being completed as planned and on schedule, providing authority and resources to ensure that the Site Safety Officer is able to implement and manage safety procedures, preparing reports and recommendations about the project to clients and affected KAS personnel,

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ensuring that all persons allowed to enter the site (i.e., EPA, Contractors, State Officials, visitors) are made aware of the potential hazards associated with the substances known or suspected to be on site, and are knowledgeable as to the on-site copy of the specific site safety plan. ensuring that the Site Safety Officer is aware of all of the provision of this site safety plan and is instructing all personnel on site about the safety practices and emergency procedures defined in the plan, and ensuring that the Site Safety Officer or the Site Safety Officer's designee is making an effort to monitor site safety.

Site Safety Officer The Site Safety Officer shall be responsible for the overall coordination and oversight of the site safety plan. Specifically:

approving the selection of the types of (PPE) to be used on site for specific tasks, evaluating weather and chemical hazard information and making recommendations to the Project Manager/Site Supervisor about any modifications to work plans or personal protection levels in order to maintain personal safety, coordinate upgrading or downgrading PPE with Site Safety Officer, as necessary, due to changes in exposure levels, monitoring results, weather, other site conditions, approving field personnel for work on-site, taking into consideration their level of safety training, their physical capacity, and their eligibility to wear the protective equipment necessary for their assigned tasks, overseeing the air monitoring procedures as they are carried out by site personnel for compliance with all company health and safety policies, monitoring the compliance of field personnel for the routine and proper use of the PPE that has been designated for each task, routinely inspecting PPE and clothing to ensure that it is in good condition and is being stored and maintained properly, stopping work on the site or changing work assignments or procedures if any operation threatens the health and safety of workers or the public, monitoring personnel who enter and exit the site and all controlled access points, reporting any signs of fatigue, work-related stress, or chemical exposures to the Project Manager and/or Site Supervisor,

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dismissing field personnel from the site if their actions or negligence endangers themselves, co-workers, or the public, and reporting the same to the Project Manager and/or the Site Supervisor, reporting any accidents or violations of the site safety plan to the Project Manager and/or the Site Supervisor, and documenting the same for the project in the project records, knowing emergency procedures, evacuation routes and the telephone numbers of the ambulance, local hospital, poison control center, fire and police departments, ensuring that all project-related personnel have signed the acknowledgments form contained in this site safety plan, coordinate upgrading and downgrading PPE , as necessary, due to changes in exposure levels, monitoring results, weather, and other site conditions, and perform air monitoring with approved instruments in accordance with requirements stated in this Site Safety Plan.

Site Supervisor In the event that the Project Manager and the Site Safety Officer are not on site, the Site Supervisor shall assume all their responsibilities and authority. Other Field Personnel All field personnel shall be responsible for acting in compliance with all safety procedures outlined in the Health and Safety Plan. Any hazardous work situations or procedures shall be reported to the Site Safety Officer so that corrective steps can be taken. 16. CONFINED SPACE ENTRY The reader is referred to the KAS Permit-Required Confined Spaces Program on file at KAS offices for more details on confined space entry protocols. A confined space:

a) is large enough and so configured that a person can bodily enter and perform assigned work; and b) has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry); and c) is not designed for continuous occupancy.

Included within this definition are excavations, storage tanks, impoundment, soils, pipelines, pits and vaults.

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All personnel are urged to use caution in identifying any of the area listed above to their immediate Supervisor, and, to plan their approach to operations conducted in these areas to be in compliance with KAS's Confined Space Plan. All personnel are urged to use all engineering controls possible to avoid entering these areas. Examples of this would include using remote sampling equipment, or, using a contractors back hoe bucket to collect soils for sampling, rather than personnel entering the excavation. Entry into a confined space is defined as breaking the plane of the opening to the confined space with any part of the body. 17. DRILLING SAFETY During the drilling operation (2) persons designated as "driller" and "helper" must be present on the rig at all times. The immediate area around the rig shall be cordoned off with temporary barricades, fencing or cones to assist in preventing unauthorized entry. Only personnel authorized by KAS are to be allowed within the area of drilling. If any unauthorized personnel enter the work area, KAS will shut down operations until the area is cleared. The mast of the drilling rig must maintain a minimum clearance of 20 feet from any overhead electrical cables. The drilling rig must not be moved from its set up position without first putting down the mast. All drilling operations shall cease immediately during any electrical storms. KAS, Inc. retains sole authority to shut down the drilling operations at any time a hazardous situation is deemed present. 18. EXCAVATING/TRENCHING SAFETY All excavation and trenching work must comply with all safety regulatory agency rules. Prior to any excavation work, the existence and location of underground pipe, electrical conductors, etc. must be determined. The walls and spaces of all excavations more than four (4) feet deep or excavated below a building footing or foundation shall be guarded properly by shoring, sloping of the ground, or equivalent means. Maximum Allowable Slopes are specified by OSHA for various soil types in 29 CFR Part 1926, Subpart P.

Maximum Allowable Slope (H:V) Soil/ Rock Type for Excavations less than 20 ft

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Stable Rock Vertical (90 degrees) Type A 3/4:1 (53 degrees) Type B 1:1 (45 degrees) Type C 1.5:1 (34 degrees) Type A soils: clays, silty clays, sandy clays, clay loam, and cemented soils (caliche, hardpan) Type B soils: silt, silt loam, sandy loam, unstable dry rock Type C soils: granular soils including gravel, sand, and loamy sand; submerged, unstable soil or rock

Daily inspections of excavations shall be made. If there is evidence of possible cave-ins or slides, all work in the excavation shall cease until the necessary safeguards have been taken. Trenches more than four (4) feet deep shall have ladders or steps located so as to require no more than 25 feet of lateral travel between means of access. All equipment such as pipe, tools, etc. shall be kept out of traffic lanes and access ways. Equipment shall be stored to prevent danger to personnel at any time. Trenches shall be completely guarded on all sides in areas where pedestrian and vehicular traffic is expected. A minimum of two (2) feet from the edges will be maintained. Trench guarding shall consist of wooden, metal, or heavy plastic barricades. Such barricades shall not be less than 36 inches high when erected. Battery-lighted barricades shall be used to secure trenched areas left open overnight, as follows:

A minimum of two (2) battery-lighted barricades shall be used at corners, one on either side of the barricades. At least one (1) battery-lighted barricade shall be used where vehicular traffic approaches the trench at the right angles.

Where trenches parallel roadways the distance between battery-lighted barricades should not exceed 40 feet. All battery-lighted units should be regularly serviced to ensure equipment is operating.

Protection between barricades shall consist of at least 3/4 inch wide nylon tape (yellow or yellow and black). The tapes shall be stretched between barricades.

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All barricaded sections immediately adjacent to where pedestrians cross trenches shall be guarded with a minimum of 2 by 2 inch wooded rails from the bridge to the first adjacent barricade. This barricade shall not be less than eight (8) feet horizontally to the top of the first barricade. All pedestrian bridges shall be of sufficient strength to prevent no greater vertical deflection than 1/2 inch when a 250 pound weight is applied to the center of the bridge. Handrails shall consist of an intermediate and top rail on both sides of the bridge. The top rail shall be a minimum of 42 inches high and capable of withstanding a lateral force of 200 pounds against the center of the top rail. All surfaces which a person could reasonably contact should be sufficiently free of splinters, nails, or protrusions which may cause injury. All bridges intended for vehicular traffic shall be constructed to withstand twice the load of the heaviest vehicle anticipated. All trenches shall be back filled as soon as practical after work is completed and all associated equipment removed. 19. ELECTRICAL SAFETY All electrical equipment and power cables in and around wells or structures suspected of containing chemical contamination must be equipped with a three-wire, ground lead. In accordance with OSHA 29 CFR 1926.404, approved ground fault circuit interrupters (GFCI) must be used for all 120 volt, single phase, 15 and 20 ampere receptacle outlets on the site which are in use by personnel and which are not part of the permanent wiring as defined by the NEC 1987. The GFCI is a fast-acting circuit breaker which senses small imbalances in the circuit caused by current leakage to ground, and in a fraction of a second shuts off the electricity. However, the GFCI will not protect personnel from line-to-line contact hazards (such as a person holding two "hot" wires or a hot and neutral wire in each hand). The GFCI provides protection against the most common form of electrical shock hazard, the ground fault. GFCIs can be used successfully to reduce electrical hazards on construction sites. Tripping of GFCIs, interruption of current flow, is sometimes caused by wet connectors and tools. It is good practice to limit exposure of connectors and tools to excessive moisture by using watertight or sealable connectors. Providing more GFCIs or shorter circuits can prevent tripping caused by the cumulative leakage from several tools or by leafages from extremely long circuits. (Adapted from OSHA 3007; Ground-Fault Protection on Construction Sites, 1987).

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Electrical cords shall be inspected thoroughly prior to each work day for fraying of or damage to the cord. Electrical cords which are frayed or damaged will be permanently removed from service.

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