work plan: addendum 5 to the remedial investigation work ... · the ground surface and pit bottom...

Addendum 5 to the Remedial Investigation Work Plan Response Action for PCB-Impacted Soil Operable Unit 2

Former Frenchtown Mill Missoula County, Montana Prepared for: M2Green Redevelopment, LLC 210 Market Street Alton, IL 62002 WestRock CP, LLC P.O. Box 4098 Norcross, GA 30097 International Paper Company 6400 Poplar Avenue Memphis, TN 38197 Prepared by: NewFields Companies, LLC 700 SW Higgins, Suite 108 Missoula, MT 59803

Version 4 November 22, 2017

•1NewFields

ADDENDUM 5 TO THE REMEDIAL INVESTIGATION WORK PLAN Response Action for PCB-Impacted Soil, Operable Unit 2

Former Frenchtown Mill, Missoula County, Montana

David Tooke Project Coordinator NewFields

sa;;,;;rks Remedial Project Manager

Version• Issued: November 22, 2017

Date

Date

U.S. Environmental Protection Agency Region 8

Addendum 5 to the Remedial Investigation Work Plan - Version 4 Former Frenchtown Mill November 2017

Page | i

TABLE OF CONTENTS

INTRODUCTION ................................................................................................................. 1 1.0

1.1 BACKGROUND ................................................................................................................................... 1 1.2 REMEDIAL PURPOSE AND PROPOSED CLEANUP LEVELS ............................................................................ 1 1.3 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARS) .................................................... 2

PROPOSED SOIL RESPONSE ACTION ................................................................................... 3 2.0

2.1 SAMPLING BACKFILL MATERIAL ............................................................................................................ 3 2.2 EXCAVATION OF CONCRETE AND DEBRIS ................................................................................................ 3 2.3 SOIL EXCAVATION .............................................................................................................................. 3 2.4 DISPOSAL AND BACKFILL ..................................................................................................................... 4 2.5 DATA QUALITY OBJECTIVES AND CONFIRMATION SAMPLING .................................................................... 4 2.6 DECONTAMINATION PROCEDURES ........................................................................................................ 5 2.7 QUALITY ASSURANCE AND QUALITY CONTROL (QA/QC) ......................................................................... 6 2.8 FIELD DOCUMENTATION ..................................................................................................................... 6 2.9 DATA VALIDATION AND REPORTING ...................................................................................................... 6

HEALTH AND SAFETY ......................................................................................................... 7 3.0

SCHEDULE ......................................................................................................................... 8 4.0

REFERENCES ...................................................................................................................... 9 5.0

LIST OF FIGURES

Figure 1: Site Location

Figure 2: PCB-Impacted Areas (OU2)

Figure 3: Proposed Excavation Footprint, High Density Pulp Tank Area

Figure 4: Proposed Excavation Footprint, Transformer Storage Building Area

•• •


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LIST OF TABLES

Table 1: Summary of Soil Sample Results by Depth - PCB Investigation (OU2)

Table 2: Proposed Cleanup Levels

Table 3: Applicable or Relevant and Appropriate Requirements (ARARs)

Table 4: Data Quality Objectives for Confirmation Sampling After Excavation of PCB-Impacted Soil

Table 5: Laboratory Methods, Containers and Preservatives

LIST OF APPENDICES

Appendix A: State Identification of Applicable or Relevant and Appropriate Requirements (ARARs)

Appendix B: Standard Operating Procedures (SOPs)

Appendix C: Contaminated Soil Management Plan

Appendix D: Field Forms

•• •


Page | 1

INTRODUCTION 1.0

This Remedial Investigation Work Plan (RIWP) Addendum describes a proposed action to remove soils containing Polychlorinated Biphenyls (PCBs) from Operable Unit 2 (OU2) of the Former Frenchtown Mill (hereafter referenced as the “site”; Figure 1). This plan is Addendum No. 5 to the RIWP (NewFields, 2015a).

1.1 BACKGROUND

Initial investigation of PCB concentrations in soil of OU2 was completed in 2015 (NewFields, 2016). A subsequent targeted investigation in 2016 identified PCBs in soils at elevated concentrations in the vicinity of the High Density Pulp Tank (HDPT) and the Transformer Storage Building (TSB) (NewFields, 2017). The HDPT and TSB areas are shown on Figure 2. In the HDPT area, only Aroclor 1260 was detected. In the TSB area, Aroclors 1254 and 1260 were detected. Historical sampling locations are shown on Figure 3 (HDPT area) and Figure 4 (TSB area). Historical results for PCBs in soil of OU2 are summarized in Table 1.

PCB concentrations in soil were above Residential Direct-Contact Regional Screening Levels (RSLs) in surface soil (0 to 2 feet below ground surface (bgs)) samples SS18, SS19, HDPT38, and HDPT40 in the HDPT area (Figure 3), as well as surface soil samples SS28, TSB46, and TSB47 in the TSB area (Figure 4).

1.2 REMEDIAL PURPOSE AND PROPOSED CLEANUP LEVELS

The purpose of the proposed remedial action is to prevent unacceptable human exposure to PCBs by removing and disposing of soil from areas of OU2 where elevated PCB concentrations have been identified. Proposed PCB soil cleanup levels are presented in Table 2. The proposed cleanup levels are:

Residential direct-contact RSLs for surface soil from 0 to 2 feet – 0.12 milligrams per kilogram (mg/kg) (Aroclor 1254) and 0.24 mg/kg (Aroclor 1260).

Construction worker RSLs for subsurface soils (> 2 feet) – 0.97 mg/kg (Aroclor 1254) and 0.99 mg/kg (Arclor 1260).

Proposed soil cleanup levels are consistent with the U.S. Environmental Protection Agency (EPA) conservative and protective approach to selection of soil cleanup levels (EPA, 2002). Soil cleanup levels for the proposed remedial action are based on a target excess cancer risk of 1x10-6 and a target non-cancer hazard quotient of 0.1. For surface soil (0 to 2 feet bgs), residential direct-contact soil screening levels are proposed as cleanup levels and are protective of all uses despite the intent to redevelop OU2 as commercial/industrial land. For subsurface soil (greater than 2 feet bgs), construction worker soil screening levels are proposed as cleanup levels. Use of the construction worker exposure scenario for subsurface soil is consistent with EPA guidance regarding cleanup levels (EPA, 2004). In addition, use of construction worker exposure scenario for subsurface soil is consistent with guidance from MDEQ (2012), which states, "When evaluating current and future exposure…DEQ considers soils from 2 – 10 feet below ground surface as short-term excavation or construction worker exposures."

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1.3 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARS)

In collaboration with the State of Montana, EPA identified the Applicable or Relevant and Appropriate Requirements (ARARs) for the proposed response action. ARARs and the associated compliance measures are summarized in Table 3, and the full ARARs summary provided by EPA is Appendix A.

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PROPOSED SOIL RESPONSE ACTION 2.0

The proposed response action consists of excavation to remove soil containing PCBs at concentrations above select soil cleanup levels. The two areas proposed for excavation were identified during an EPA approved site investigation completed in 2015 (NewFields, 2016). Excavation is proposed in areas and depths consistent with the site investigation findings. Proposed excavation areas and depths are shown on Figures 3 and 4. Tasks for the response action include:

• Identification and sampling of clean backfill prior to use; • Excavation of concrete and debris to allow access to impacted soils; • Excavation and disposal of PCB- impacted soils; • Confirmation sampling; • Backfilling.

Excavation in the HDPT area would occur inside the HDPT foundation. Excavation in the TSB area would occur immediately adjacent to the TSB foundation. Soil would be hauled using tarped trucks under manifest to the Missoula Landfill, and the excavation areas would be backfilled with clean coarse-grained material. Greater detail regarding the proposed response action is provided below.

Methods previously described in planning documents approved by EPA will be employed during the response action. This includes standard operating and quality control procedures described in the Field Sampling Plan included in the RIWP (NewFields, 2015b), and the Quality Assurance Project Plan (NewFields, 2015c). Site safety will be employed in accordance with the EPA-approved Health and Safety Plan (NewFields, 2015d). Standard Operating Procedures (SOPs) relevant to the proposed response action are provided in Appendix B.

2.1 SAMPLING BACKFILL MATERIAL

One five-point composite sample of the proposed backfill material will be collected and analyzed for PCBs (prior to use) to ensure that soil used to backfill the excavations does not contain PCBs above proposed cleanup levels. The sample will be collected in accordance with SOP-13 (Appendix B), and will be packaged and shipped under chain-of-custody to Pace Analytical of Minneapolis, Minnesota for PCB analysis by EPA Method 8082.

2.2 EXCAVATION OF CONCRETE AND DEBRIS

Prior to excavation, obstructions and debris will be removed from the proposed excavation areas. During excavation, some of the foundation for the former HDPT may be removed to provide access to impacted soil as the excavation progresses to full depth in the areas shown on Figure 3.

2.3 SOIL EXCAVATION

In the HDPT area (Figure 3), the excavation depth will vary based on previous sampling results. Soils will be excavated to 4 feet bgs in the southwestern portion of the HDPT foundation to remove surface soil in the vicinity of borehole 40, 38, SS18, and SS19, and to a depth of 8 feet bgs in the southwestern portion of the HDPT foundation to remove soil near borehole 39. In the TSB area, excavation is proposed in an area approximately 9 feet by 10 feet, and 3 feet deep (Figure 4) to remove PCB-impacted soil near

•• •


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sample SS28 and boreholes 46 and 47. Proposed excavation depths in both the HDPT and TSB areas are approximately 2 feet below the deepest sample with PCB concentrations above cleanup levels to ensure impacted soils are removed. Excavation depths shown on Figures 3 and 4 are the excavation total depths.

The ground surface and pit bottom footprints of each excavation will be measured and documented in the field using both a measuring wheel accurate to the nearest 0.1 feet and a GPS device with actual field precision of approximately 1 foot for individual points. Excavation depths will be measured using a laser level and survey rod accurate to within 0.2 feet, with one station used per excavation. Excavation depths shown on Figures 3 and 4 are the proposed total depths. Excavation depths and/or areas will increase if confirmation samples indicate further PCB contamination.

2.4 DISPOSAL AND BACKFILL

Waste soil and debris from the response actions will be hauled by truck (tarped) to the Missoula Landfill operated by Republic Services. The soils will be disposed of as Special Waste. Each load of material will be accompanied by a manifest documenting custody and disposal of the material, as well as weight of the material. A map of the transportation route to the landfill and a contingency plan on how to handle the waste if it was to be spilled on the roadway during transportation to the landfill are provided in Appendix C.

The excavation areas will not be backfilled with clean materials until the results from the confirmation sampling are provided to EPA and EPA provides approval to begin the backfilling. If after confirmation sampling, results are not below cleanup levels, additional excavation will take place until confirmation sampling indicates PCB concentrations in soil are below cleanup levels.

Each excavation area will be backfilled with coarse-grained material shown not to contain elevated concentrations of PCBs above EPA Residential RSLs. The material will be placed in lifts up to 18-inches thick and compacted using the excavator bucket.

2.5 DATA QUALITY OBJECTIVES AND CONFIRMATION SAMPLING

Table 4 presents the Data Quality Objectives (DQOs) for soil confirmation sampling after response action at the site. EPA’s Seven-Step Planning Approach (EPA, 2006) was used to identify the DQOs. Based on historical sample results summarized in Table 1 and shown on Figure 3 and 4, data gaps for PCBs for the two areas include:

Presence/absence of PCB impacts beneath the concrete slab of the former TSB;

Depth of PCB impacts in the southeastern portion of the HDPT foundation near borehole 39; and

Lateral extent of PCB impacts to soil to the northwest, northeast, and southeast from the impacts observed in boreholes 38 and 39 in the HPDT area.

•• •


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Confirmation samples from the excavations will fill these data gaps. After excavation in both areas, discrete soil samples will be collected from the sidewalls and pit bottoms of the excavations to evaluate whether remaining PCB concentrations in soil are below cleanup levels (Table 2). Sidewall samples will be collected at a minimum frequency of one for every 20 linear feet of sidewall, and excavation bottom samples will be collected at a frequency of one for every 625 square feet of excavation bottom. Resulting sampling frequency will also be no less than four evenly-spaced sidewall samples and one excavation bottom sample per excavation. The resulting sampling frequency will be four sidewall samples and one excavation bottom sample for the TSB excavation (which is square and less than 10 feet on each side), and five sidewall samples and two excavation bottom samples for the HDPT excavation (which round and approximately 30 feet wide).

Confirmation samples will be collected from excavation surfaces using a stainless steel trowel, or excavator bucket when collected at depths greater than 4 feet below ground surface. Procedures for sample collection are detailed in the discrete soil sampling section of SOP-13 and the excavations section of SOP-14 (Appendix B). Detailed sample handling procedures for chain of custody (SOP-3) and packaging/shipping (SOP-4) will be followed as stipulated in Appendix B. Confirmation soil samples will be transferred to laboratory-provided 8-ounce glass jars with Teflon®-lined lids, stored in a cooler with ice, and then shipped under chain of custody to Pace Analytical of Minneapolis, Minnesota. The confirmation samples will be analyzed for PCBs by EPA Method 8082. Requirements for containers, preservation, and hold times for samples collected are shown in Table 5. All samples submitted for laboratory analysis will be analyzed using standard turnaround times.

2.6 DECONTAMINATION PROCEDURES

All non-disposable field equipment that will be used for soil sampling, including the excavator before use and between excavation of soils from the two areas, will be decontaminated in accordance with the applicable section of SOP-2 (Appendix B). A list of field equipment to be used during this investigation is provided in SOP-13 (Appendix B). To prevent cross-contamination, all non-disposable sampling (small) equipment will be decontaminated between sampling locations using distilled water, alconox detergent, and a hexane rinse in accordance with EPA (2011) guidance. Revised SOP-2 (Appendix B) specifies the use of hexane. Disposable equipment intended for one-time use will not be decontaminated, but will be disposed of as described in SOP-2.

To prevent inadvertent contamination during transport of PCB-impacted soils, trucks will be tarped during transport to and from the landfill. In addition, the wheels on each truck will be dry decontaminated in a designated area prior to leaving the site, and the excavator bucket will be dry decontaminated prior to movement away from each excavation area. If dry decontamination is not sufficient due to wet conditions or caking of material on the truck tires, a wet decontamination will be performed on the concrete slab for the Transformer Storage Building Foundation (Figure 2), which has a closed sump to collect decontamination water. To dispose of the water, it will be periodically pumped onto the soil in the truck and hauled to the landfill. In addition, soils will be excavated and loaded directly into trucks to minimize the potential spread of PCBs during soil handling.

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2.7 QUALITY ASSURANCE AND QUALITY CONTROL (QA/QC)

QA/QC procedures will be followed in accordance with the Quality Assurance Project Plan (QAPP) which was included as Appendix E of the RIWP (NewFields, 2015c) and CERCLA QAPP guidance. In accordance with the QAPP, field quality control samples will include a field duplicate (FD), and an equipment rinse blank (ERB). The field quality control samples will be collected in accordance with SOP-24 (Attachment B), and will be analyzed by EPA Method 8082. One additional sample container will be collected for the use as in site-specific Matrix Spike (MS) testing. The sample container will be from the same homogenized material used for the FD.

2.8 FIELD DOCUMENTATION

NewFields personnel will document all activities in accordance with SOP-1 (Appendix B). A daily field record will be completed, as well as to-scale field drawings showing excavation and sampling locations, and log of photographs. Example forms for daily field record and photograph log are provided in Appendix D.

2.9 DATA VALIDATION AND REPORTING

Analytical data will be verified and validated in accordance with the approved QAPP (Appendix E of the RIWP; NewFields, 2015c). Results will be organized in a NewFields data management system and then uploaded to the SCRIBE project database in accordance with procedures outlined in the QAPP and the technical memo submitted to EPA on May 6, 2016 (NewFields, 2016).

A response action report will be prepared and submitted to EPA on behalf of the PRPs upon completion of excavation and laboratory analysis. The report will document the locations/depths of excavation, the methods and results of confirmation sampling, backfill material, and disposal (including landfill weight tickets and manifests). The report will evaluate the data with respect to the DQOs outlined in Table 4 and compare confirmation samples to soil cleanup levels. Field drawings of excavation and sampling locations, and analytical data tables will be appended to the report along with figures showing the excavation. Data validation summaries and laboratory analytical reports will also be included in the report as well as field notes and sampling forms.

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HEALTH AND SAFETY 3.0

Staff overseeing excavation and collecting samples will complete work in accordance with the approved Health & Safety Plan (Appendix F of the RIWP; NewFields, 2015d). The HASP will be complemented by a Job Safety Analysis (JSA) worksheet to address safety concerns related specifically to overseeing excavation and collection of soil samples. Field team leaders will conduct daily staff safety meetings guided by the HASP and JSA at the beginning of each work day.

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SCHEDULE 4.0

NewFields will schedule the response actions in general accordance with the milestones shown below. It’s anticipated that this Addendum will be approved by EPA in August 2017 and all work will be completed in 2017.

Milestone Schedule for Completion (business days)

EPA Approval of Addendum 5 to RIWP Day 0

Schedule Excavation Contractor, Order Sampling Containers, Sample Proposed Backfill Day 5

Request Utility Locate Day 15

Initiate Excavation Day 20

Complete Excavation and Confirmation Sampling Day 22

Ship Samples Day 23

Receive Laboratory Results from Confirmation Samples Day 37

Complete Backfill Day 50

Submit Response Action Report Day 60

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REFERENCES 5.0

Environmental Protection Agency (EPA), 2002. Supplemental Guidance for Developing Soil Screening Levels for Superfund Sites, Office of Solid Waste and Emergency Response. December.

EPA, 2004. Guidance on Surface Soil Cleanup at Hazardous Waste Sites: Implementing Cleanup Levels - Draft, Office of Emergency and Remedial Response. May.

EPA, 2006. Guidance on Systematic Planning Using the Data Quality Objectives Process. EPA QA/G-4. February.

EPA, 2011. Standard Operating Procedure for Sampling Porous Surfaces for Polychlorinated Biphenyls (PCBs) - Revision 4, Office of Environmental Measurement and Evaluation. May.

Montana Department of Environmental Quality (MDEQ), 2012. Voluntary Cleanup and Redevelopment Act Application Guide. April.

NewFields, 2017. PCB Soils Investigation Report, Operable Unit 2, Former Frenchtown Mill, Missoula County, Montana. February.

NewFields, 2016. Preliminary Data Summary Report, November/December 2015 Sampling Event, Smurfit Stone/Frenchtown Mill, Missoula County, Montana. September.

NewFields, 2015a. Remedial Investigation Work Plan, Smurfit Stone/Frenchtown Mill, Missoula County, Montana. Prepared for International Paper Company, M2Green Redevelopment, LLC, and WestRock CP, LLC. November.

NewFields 2015b. Field Sampling Plan for the Smurfit Stone / Frenchtown Mill Site, Missoula County, Montana. Version 2, 11/09/2015. Included as Appendix D of the Remedial Investigation Work Plan, November 2015.

NewFields 2015c. Quality Assurance Project Plan for the Smurfit Stone / Frenchtown Mill Site, Missoula County, Montana. Version 2, 11/05/2015. Included as Appendix E of the Remedial Investigation Work Plan, November 2015.

NewFields 2015d. Health and Safety Plan for the Smurfit Stone / Frenchtown Mill Site Remedial Investigation, Missoula County, Montana. Version 1.0, 11/10/2015. Included as Appendix F of the Remedial Investigation Work Plan, November 2015.

•• •

F I G U R E S

O ' K e e f e C r e e k

Color RemovalPlant

CL

SWBF

SWBG

SWBCb

SPP

SB20

AB3

AB1

AB2

SWBA

P8dc

SWB6

NPP

SWBCa

P8

HP2

P3

P17

P5

P4

HP13a

HP11 HP10

HP1a

HP7

HP12

HP9

HP1

HP13

C l a r k F o r k R i v e r

INTERSTATE 90

MULLAN ROADParcel Sold

in 2012

HP18

Former Industrial Area

Ancillary Parcels

LF

FP

HP16

AG2

AG1

AG3

AG4

AG5

AG6AG7

AG8

AG9

WR2

WR1

SB19

IBK

IBJ

S e e F i g u r e 2

O0 1,600Feet

Site LocationFormer Frenchtown Mill Site

Missoula County, MontanaFIGURE 1

P:\350.0065 M2Green\AGIS\Projects\2016_RIWP_Addendum\FIGURE 1 - Site Location.mxd Revised 5/17/2016

Aerial Photo Source: NAIP 2011 andNewfields 2016 (Within Site Boundary) Notes

AG - Agricultural LandAB - Aeration Stabilization BasinCL - ClarifyerFP - Flood PlainHP - Holding or Storage PondIB - Rapid Infiltration BasinLF - Landfarm

NPP - North Polishing PondP - Settling PondSB - Spoils BasinSPP - South Polishing PondSWB - Solid Waste BasinWR - West of River

Mill Site Boundary (Approximate)100-Year Floodplain*OU1 - Agricultural LandsOU2 - Industrial AreaOU3 - Wastewater Treatment and Storage Areas

LEGEND

*Floodplain Source:As defined by the Federal EmergencyManagement Agency (FEMA) 2013Digital Flood Insurance Rate Map(DFIRM). (NFIP 2013)

•: Newfields

High Density PulpTank Foundation

Transformer StorageBuilding Foundation

O0 200Feet

PCB Impacted Areas (OU2)Former Frenchtown Mill Site


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017

Aerial Photo Source: Newfields 2016

OU2 - Industrial Area BoundaryC

•1NewFields

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42-SB •

38-SB• • S518-IN (12) / ,

(12,36) S519-IN (24) / .,

40-SB (24) •

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, , , ,

, , ,

' ' ' ' ' ' !I. • 41-SB

Cement Ring Foundation for Tank (26-inches above ground)

• 43-SB

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~.__ __ ......,,..... ____________________________________ ____. ___ _.

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0 Feet 10

•1NewFields

• Soil Sample Locations (depth of soil sample with PCB concentrations above screening level, inches below grade)

D Proposed Excavation

[!:] Proposed Excavation Depth in Feet

Proposed Excavation Footprint High Density Pulp Tank Area

Former Frenchtown Mill Missoula County, Montana

FIGURE 3

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grade)

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• 45-SB

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0 Feet 10

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• Soil Sample Locations (depth of soil sample with PCB concentrations above screening level, inches below grade)

D Proposed Excavation

[!] Proposed Excavation Depth in Feet

Proposed Excavation Footprint Transformer Storage Building Area

Former Frenchtown Mill Missoula County, Montana

FIGURE 4

TABLES

SS18‐IN‐(12)

SS19‐IN‐ (24)

IN‐HDPT38‐SB‐1,2,3,4



IN‐HDPT41‐SB‐1,4



SS28‐IN‐(0‐2)c

SS29‐IN‐(0‐2)c

SS30‐IN‐(0‐2)c

SS31‐IN‐(0‐2)c

IN‐TSB

44‐SB

‐1,2,3

IN‐TSB

45‐SB

‐1,2,3

IN‐TSB

46‐SB

‐1,2,3

IN‐TS B

47‐SB

‐1,2,3

IN‐TSB

48‐SB

‐1,2,3

IN‐TSB

49‐SB

‐1,2,3

IN‐TSB

50‐SB

‐1,2,3

1

1440

ND7490 J 154 J 37.7 U 88.1 J

2

1740

ND

3

4H H H H H

5172

6

7

8

9

10

Notes:

156 ‐ Blue font; Aroclor 1254 concentration in µg/kg, if not shown, result is ND with reporting limig of 34.5 µg/kg ID ‐ identification

1020 ‐ Black font; Aroclor 1260 concentration in µg/kg J ‐ Concentration is considered estimated.

H ‐ Held, not analyzed ND ‐ Not Detected

HDPT ‐ High Density Pulp Tank QA/QC ‐ Quality Assurance/Quality Control

TSB ‐ Transformer Storage Building µg/kg ‐ micrograms per kilogram, or parts per billion

Sample depths are based on professional judgment due to poor sample recovery in sampling sleeve. OU ‐ Operable Unit

Sample locations are shown on Figure 3 (HDPT) and Figure 4 (TSB)

‐ initial soil samples collected in 2015 Bold

‐ soil samples collected in 2016 Underline

‐ not investigated ...... depth driven by sample sleeve ___ total depth of borehole

TABLE 1Summary of Soil Sample Results By Depth

PCB Investigation (OU2)


SAMPLE

ID

High Density Pulp Tank (HDPT) Area Transformer Storage Building (TSB) Area

Soil Sample Soil Sample

SAMPLING DEP

TH

(feet)

70.7

747

125

50.3

Inside Ring

65.8

614

126

1020

17.1J

42.9

ND

2840

1470

Outside Ring

H

H

H

H

H

H

H

H

ND

H

66.7

156

H

H

‐ exceeds the construction worker direct contact screening level of 990 µg/kg (Aroclor 1260) or

970 µg/kg (Aroclor 1254).

‐ sample from 0 to 2 feet, and exceeds residential direct contact screening level of 240 µg/kg

(Aroclor 1260) or 120 µg/kg (Aroclor 1254).

H H

15.2

14.8

ND

893

H

H

H

H

-

-

- -- -

Surface Soil (0‐2 feet bgs),

Residential RSLs

Subsurface Soil (>2 feet bgs),

Construction Worker RSLs

Aroclor 1254 120 970

Aroclor 1260 240 990

Notes:

bgs ‐ below ground surface

ug/kg = micrograms per kilogram

RSLs = EPA Regional Screening Levels assuming cancer risk of 10‐6 and hazard quotient of 0.1.

Proposed Cleanup Levels (µg/kg)Contaminants of Concern

(COCs)

Table 2

Proposed Cleanup Levels

Response Action for PCB‐Impacted Soil, Operable Unit 2

Frenchtown Mill Site, Missoula County, Montana

Page | 1 of 5

TABLE 3 State Identification of

Applicable or Relevant and Appropriate Requirements (ARARs) Response Action for PCB‐Impacted Soil, Operable Unit 2 (OU2)


Standard, Requirement, Criteria or Limitation

Citation Description Status Compliance Measures

State: Location Specific Montana Nongame and Endangered Species Act

§§ 87‐5‐101 et seq Endangered species should be protected in order to maintain and to the extent possible enhance their numbers. These sections list endangered species, prohibited acts and penalties.

Applicable The site is an industrial facility and it is unlikely that endangered species are present. The work area will be restored to existing conditions at the completion of the project. In addition, the site activities are expected to be completed quickly (~30 days) and are unlikely to have any lasting impacts.

See also § 87‐5‐201, MCA

Protection of wild birds, nests and eggs Applicable The work is tentatively scheduled for December 2017 and will not be performed during the nesting season.

ARM 12.5.201 Prohibits certain activities with respect to specific endangered species Applicable No endangered species have been identified in the project area, and the project area is unlikely to provide habitat for the threatened species listed in Table 3‐1.

State: Action Specific Air Standards Sections 75‐2‐101, et

seq., MCA, Provides that state emission standards are enforceable under the Montana Clean Air Act Applicable

Work will be completed in December, when dust generation will be limited. Dust control measures in the proposed action work plan include wetting and other best management practices (BMPs) related to fugitive dust control. Removal actions will be halted if significant dust is generated and will not resume until adequate dust control measures are in place. Dust control measures will ensure that air standards will not be exceeded during the removal action.

ARM 17.8.802 Incorporates by reference the air regulations in certain parts of CFR Title 40 regarding quality assurance requirements for prevention of significant deterioration air monitoring; standards of performance for new stationary sources; emission standards for hazardous air pollutants, and other standards and requirements.

Applicable

ARM 17.8.805 Provides ambient air ceilings, and states that no concentrations of a pollutant shall exceed concentrations permitted under either the applicable secondary or the primary national ambient air quality standard, whichever concentration is lowest for the pollutant for a period of exposure.

Applicable

ARM 17.8.204 Provides for ambient air monitoring and provides that, generally, all ambient air monitoring, sampling and data collection, recording, analysis and transmittal must be in compliance with the Montana Quality Assurance Manual except when DEQ determines that more stringent requirements are necessary.

Applicable

ARM 17.8.223 These standards, promulgated pursuant to section 109 of the Clean Air Act, are applicable to releases into the air from any Site cleanup activities. Particulate matter that is 10 microns in diameter or smaller (PM‐10): No person shall cause or contribute to concentrations of PM‐10 in the ambient air which exceed:

150 ug/m3 of air, 24 hour average, no more than one expected exceedance per calendar year; 50 ug/m3 of air, annual average.

Dust suppression and control of certain substances likely to be released into the air as a result of earth moving, transportation, and similar actions related to remedial activity at the Site may be necessary to meet air quality requirements.

Applicable

Page | 2 of 5






Air Standards, cont. ARM 17.8.308 Provides that no person shall cause or authorize the production, handling, transportation or storage of any material, cause or authorize the use of any street, road, or parking lot, or operate a construction site or demolition project, unless reasonable precautions to control emissions of airborne particulate matter are taken. Normally, emissions of airborne particulate matter must be controlled so that they do not “exhibit an opacity of twenty percent (20%) or greater averaged over six consecutive minutes.” See also ARM 17.8.304 (Applicable). In addition, state law provides an ambient air quality standard for settled particulate matter. Particulate matter concentrations in the ambient air shall not exceed the following 30‐day average: 10 grams per square meter. ARM 17.8.220 (Applicable). Whenever this standard is exceeded, the activity resulting in such exceedance shall be suspended until such time as conditions improve.

Applicable

Work will be completed in December, when dust generation will be limited. Dust control measures in the proposed action work plan include wetting and other best management practices (BMPs) related to fugitive dust control. Removal actions will be halted if significant dust is generated and will not resume until adequate dust control measures are in place. Dust control measures will ensure that air standards will not be exceeded during the removal action.

ARM 17.24.761 Specifies a range of measures for controlling fugitive dust emissions during mining and reclamation activities. Some of these measures could be considered relevant and appropriate to control fugitive dust emissions in connection with excavation, earth moving and transportation activities conducted as part of the action at the Site. Such measures include, for example, paving, watering, chemically stabilizing, or frequently compacting and scraping roads, promptly removing rock, soil or other dust forming debris from roads, restricting vehicle speeds, revegetating, mulching, or otherwise stabilizing the surface of areas adjoining roads, restricting unauthorized vehicle travel, minimizing the area of disturbed land, and promptly revegetating regraded lands.

Relevant and Appropriate

Transportation of Hazardous or Contaminated Waste

ARM 17.53.701‐708 Adopts the equivalent to RCRA regulation at 40 CFR Part 263, establishing standards that apply to transporters of hazardous waste, with certain State exceptions and additions.

Applicable Truck tires will be decontaminated prior to leaving the site to prevent tracking of materials off‐site. All loaded trucks will be tarped prior to leaving the site to prevent loss of dust/soil during transport. The proposed action work plan includes a spill contingency plan in the unlikely event that a release of excavated material occurs during transport to the landfill.

ARM 17.50.523 Specifies that solid waste must be transported in such a manner as to prevent its discharge, dumping, spilling or leaking from the transport vehicle.

Applicable

Reclamation Requirements: Noxious Weed Control Act

Section 7‐22‐2101 et seq., MCA, and ARM 4.5.201 et seq.

Applicable

Existing soils within the excavation areas are coarse‐grained and do not support vegetation. Excavated areas will be back‐filled with coarse‐grained soil from the site that is unlikely to support vegetation growth. No revegetation is planned. Clean gravel from the approved on‐site borrow source will be placed at the surface to avoid weed growth.

Section 7‐22‐2101(8)(a), MCA

Defines “noxious weeds” as any exotic plant species established or that may be introduced in the state which may render land unfit for agriculture, forestry, livestock, wildlife, or other beneficial uses or that may harm native plant communities and that is designated: (i) as a statewide noxious weed by rule of the department; or (ii) as a district noxious weed by a board, following public notice of intent and a public hearing.

Applicable

Page | 3 of 5






Noxious Weed Control Act, cont.

Section 7‐22‐2152, MCA

Requires that any person proposing certain actions including but not limited to a solid waste facility, a highway or road, a commercial, industrial, or government development, or any other development that needs state or local approval and that results in the potential for noxious weed infestation within a district shall notify the district weed board at least 15 days prior to the activity. The board will require that the areas be seeded, planted, or otherwise managed to reestablish a cover of beneficial plants. The person committing the action shall submit to the board a written plan specifying the methods to be used to accomplish revegetation at least 15 days prior to the activity. The plan must describe the time and method of seeding, fertilization practices, recommended plant species, use of weed‐free seed, and the weed management procedures to be used. The plan is subject to approval by the board, which may require revisions to bring the revegetation plan into compliance with the district weed management plan. The activity for which notice is given may not occur until the plan is approved by the board and signed by the presiding officer of the board and by the person or a representative of the agency responsible for the action. The signed plan constitutes a binding agreement between the board and the person or agency. The plan must be approved, with revisions if necessary, within 10 days of receipt by the board.

Applicable


Montana Strip and Underground Mine Reclamation Act and Montana Metals Mining Act

§§ 82‐4‐201 through 254, MCA

Technically applies to coal and uranium mining, but that statute and the regulations promulgated under that statue and discussed in this section set out the standards that excavation activities and reclamation of excavated areas should attain. Those requirements identified here have been determined to be relevant and appropriate requirements for this action.



Requires the reclamation and revegetation of the land as rapidly, completely, and effectively as the most modern technology and the most advanced state of the art will allow. In developing a method of operation and plans of backfilling, water control, grading, topsoiling and reclamation, all measures shall be taken to eliminate damages to landowners and members of the public, their real and personal property, public roads, streams, and all other public property from soil erosion, subsidence, landslides, water pollution, and hazards dangerous to life and property.



Requires vegetation as is necessary to establish a diverse, effective, and permanent vegetative cover of the same seasonal variety native to the area of land to be affected and capable of self‐regeneration and plant succession at least equal in extent of cover to the natural vegetation of the area except that introduced species may be used in the revegetation process where desirable and necessary to achieve the approved postmining land use plan.


ARM 17.24.501 Gives general backfilling and final grading requirements. Backfill must be placed so as to minimize sedimentation, erosion, and leaching of acid or toxic materials into waters, unless otherwise approved. Final grading must be to the approximate original contour of the land, and final slopes must be graded to prevent slope failure. The disturbed areas must be blended with surrounding and undisturbed ground to provide a smooth transition in topography.


Excavated areas will be backfilled to match the existing grade of the surrounding area with coarse‐grained material. The work areas are relatively flat and not proximal to surface water. Therefore, erosion and sedimentation of backfill materials is not anticipated.

ARM 17.24.519 Provides that an operator may be required to monitor settling of regraded areas. Relevant and Appropriate

Excavations will be backfilled with coarse‐grained material, in 18‐inch lifts, that will be compacted with the excavator bucket during placement. Significant settlement is unlikely.

Page | 4 of 5






Montana Strip and Underground Mine Reclamation Act and Montana Metals Mining Act, cont.

ARM 17.24.702(4), (5), and (6)

Requires that during the redistributing and stockpiling of soil (for reclamation):

1. regraded areas must be deep‐tilled, subsoiled, or otherwise treated to eliminate any possible slippage potential, to relieve compaction, and to promote root penetration and permeability of the underlying layer; this preparation must be done on the contour whenever possible and to a minimum depth of 12 inches;

2. redistribution must be done in a manner that achieves approximate uniform thicknesses consistent with soil resource availability and appropriate for the postmining vegetation, land uses, contours, and surface water drainage systems; and

3. redistributed soil must be reconditioned by subsoiling or other appropriate methods.


All soil within the limits of the excavations will be transported off‐site for disposal at the landfill. Excavated site soil will not be permanently stockpiled on site.

ARM 17.24.703 Requires that when using materials other than, or along with, soil for final surfacing in reclamation, the operator must demonstrate that the material (1) is at least as capable as the soil of supporting the approved vegetation and subsequent land use, and (2) the medium must be the best available in the area to support vegetation. Such substitutes must be used in a manner consistent with the requirements for redistribution of soil in ARM 17.24.701 and 702.



ARM 17.24.711 Requires that a diverse, effective, and permanent vegetative cover of the same seasonal variety native to the area of land to be affected shall be established except on road surfaces and below the low‐water line of permanent impoundments. See also § 82‐4‐233, MCA (Relevant and Appropriate). Vegetative cover is considered of the same seasonal variety if it consists of a mixture of species of equal or superior utility when compared with the natural vegetation during each season of the year. This requirement may not be appropriate where other cover is more suitable for the particular land use or another cover is requested by the landowner.


ARM 17.24.713 Provides that seeding and planting of disturbed areas must be conducted during the first appropriate period for favorable planting after final seedbed preparation.


ARM 17.24.714 Requires use of a seedbed preparation, mulch, or cover crop until an adequate permanent cover can be established. This requirement may be suspended under certain conditions.


ARM 17.24.716 Establishes the required method of revegetation Relevant and Appropriate

ARM 17.24.717 Trees or other shrub species necessary to meet the approved postmining land use must be adapted for local site conditions and climate. Trees and shrubs must be planted in combination with herbaceous species as necessary to achieve the postmining land use and as approved by the department. If necessary to increase tree and shrub survival, seeding of the herbaceous species may be delayed providing that measures are taken to control air and water pollution and erosion.


Page | 5 of 5






Montana Strip and Underground Mine Reclamation Act and Montana Metals Mining Act, cont.

ARM 17.24.718 Requires the use of soil amendments and other means such as irrigation, management, fencing, or other measures, if necessary to establish a diverse and permanent vegetative cover. Reclamation land use practices including, but not limited to, grazing, haying, or chemical applications, may not be conducted in a manner or at a time that interferes with establishment and/or persistence of seeded and planted grasses, forbs, shrubs, and trees or with other reclamation requirements.



ARM 17.24.723 Sets forth requirements for vegetation, soils, wildlife, and other monitoring. Relevant and Appropriate

ARM 17.24.724 Specifies that revegetation success must be measured against approved unmined reference areas or by comparison with technical standards from historic data. More than one reference area or historic record must be established for vegetation types with significant variation due to a number of factors.


ARM 17.24.726 Sets forth vegetation production, cover, diversity, density, and utility requirements. Relevant and Appropriate

Federal ARARs Toxic Substances Control Act

40 C.F.R. Part 761 The PCB materials will be managed and disposed according to the TSCA requirements. Soil cleanup standards will be applied to the extent practicable.

Applicable Soil Cleanup Standards proposed for this response action are more restrictive (i.e. are lower concentration) than the lowest TSCA requirements.

Category Scientific Name Common Name Status

Lynx canadensis Canada Lynx Threatened

Gulo gulo luscus Wolverine Proposed Threatened

Calidris canutus rufa Red Knot Threatened

Coccyzus americanus Yellow-billed cuckoo (western pop.) Threatened

Fishes Salvelinus confluentus Bull Trout Threatened;Designated Critical Habitat

Mammals

Birds

Source: U.S. Fish and Wildlife Service, Information for Planning and Consultation (IPaC). Queried July 2017.

Table 3-1. Federally Listed Species at the Smurfit-Stone/Frenchtown Mill Site

Smurfit SLERA OU2 and OU3 Tables_v2.xlsx

Step 1:

Problem Statement

Step 2:

Identifying the

Decisions

Step 3:

Decision Inputs

Step 4:

Study Boundaries

Step 5:

Decision Rules

Step 6:

Tolerance Limits on

Errors

Step 7:

Optimization of Sample Design

Historical operations at

the Mill have resulted in

Polychlorinated Biphenyl

(PCB) impacts to soil in

the vicinity of the High

Density Pulp Tank (HDPT)

and Transformer Storage

Building (TSB) areas

within Operable Unit 2

(OU2).

Excavation is proposed to

eliminate these impacts.

Post‐excavation data is

needed to verify whether

excavation was effective.

Are PCBs present in soil

of OU2 at

concentrations that

pose a threat to human

health under current or

reasonably anticipated

future land use?

Concentrations of PCBs

in soil samples from the

pit bottom and

sidewalls of

excavations in the

HDPT and TSB areas.

Contaminants of

Concern (COCs) are

PCBs (Aroclor 1254 and

Aroclor 1260).

Soil sampling will be

performed from the pit

bottoms and sidewalls

of excavations in the

HDPT and TSB areas of

OU2.

After excavation, are

PCBs present in

remaining soil at

concentrations above

cleanup levels?

Proposed cleanup

levels are the EPA

residential Regional

Screening Levels (RSLs)

for surface soil (0 to 2

feet below ground

surface) and the EPA

construction worker

RSLs for subsurface soil

(deeper than 2 feet

below ground surface).

Quality assurance and

quality control

procedures will be

conducted and data

validation will be

performed in

accordance with the

Quality Assurance

Project Plan approved

by the EPA.

Acceptance criteria for

the data collected as

part of this study are

outlined in the QAPP.

Sidewall soil samples will be collected

in all cardinal directions, including to

the south under the TSB foundation.

Pit bottom soil samples will be

collected from the center of each

excavation area at a frequency of one

sample for every 625 square feet or

less.

TABLE 4

Data Quality Objectives: Confirmation Sampling After Excavation of PCB‐Impacted Soil

Former Frenchtown Mill Site, Missoula County, Montana

Parameter GroupAnalytical Method &

ParametersNumber of Containers Container Type Preservation Hold Time

Polychlorinated

Biphenyls (PCBs)

8082;

PCBs (Aroclors 1254

and 1260)

7 (HDPT Area) +

5 (TSB Area) +

1 Homogenized Field Duplicate +

1 Rinsate Blank +

1 Container for Matrix Spike =

15 Total

8 ounce glass jar Cool to 6oC but above

freezing

Extract within 1 year of sample

collection. Analyze within 40 days of

extraction.

Notes:oC ‐ degrees celsius

HDPT ‐ High Density Pulp Tank

TSB ‐ Transformer Storage Building

Table 5

Laboratory Methods, Containers and Preservatives

Confirmation Sampling After Excavation of PCB‐Impacted Soil

Frenchtown Mill Site, Missoula County, Montana

APPENDIX A State Identification of Applicable or Relevant and Appropriate

Requirements (ARARs)

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State Identification of ARARs1 for the Removal Action at Operable Unit 2 of the Smurfit Stone Mill Site, Missoula County, Montana

The description of applicable or relevant and appropriate requirements (ARARs) that follows includes summaries of the legal requirements to help facilitate evaluating compliance with these requirements for the removal action at the Smurfit Stone Mill Site (the Site). The descriptions are provided to allow the user a basic indication of the requirement without having to refer back to the statute or regulation itself. However, in the event of any inconsistency between the law or regulation itself and the summaries provided in this document, the actual requirement is ultimately the requirement as set out in the law or regulation, rather than any paraphrase of the law or regulation provided here. Location Specific Requirements 2 3 Montana Nongame and Endangered Species Act:

1 The State is identifying these ARARs based on the limited scope of the proposed removal action at Operable Unit (OU)2 of the Site, as identified in Addendum 5 to the Administrative Settlement Agreement and Order on Consent for Remedial Action/Feasibility Study, CERCLA Docket No. CERCLA‐08‐2016‐0001. The State will identify a comprehensive ARARs package for the Remedial Action at this Site at a later time. Given the limited scope of this interim removal action, this ARARs narrative only identifies ARARs for the proposed action to remove PCB contaminated materials outside of the 100‐year floodplain, and dispose of those contaminated materials off‐site. Should the scope of the proposed removal action change, the State will identify additional ARARs consistent with the change in scope. 2 The State understands that the proposed action is an interim removal action to remove PCB contaminated materials from certain areas of OU2 at the Site, and that this removal action will occur outside of the 100‐year floodplain. Should the scope of this removal action change to include work inside the floodplain, the State will identify additional ARARs associated with work conducted within the 100‐year floodplain. These ARARs include, but are not limited to, §§ 76‐5‐401 et seq. (Floodplain and Floodway Management Act) and implementing regulations found in Administrative Rules of Montana, Rule 36, Chapter 15; § 87‐5‐502 and 504, MCA (substantive provisions only, prohibition against activities that may or will adversely affect fish or game habitat); §§ 75‐7‐101 (Natural Streambed and Land Preservation Act); ARM 36.2.410 (establishes minimum standards that would be applicable if the response action impacts any natural perennial‐flowing stream or portions thereof). Additionally, the final remedy at the site will fully consider these ARARs. 3 The State understands that the proposed action is an interim, non‐time critical removal action to remove PCB contaminated materials from the Facility. The purpose of the proposed removal action is to prevent unacceptable human exposure to PCBs by removing and disposing materials from areas of OU2 where elevated PCB concentrations have been identified. As such, contaminant specific ARARs, such as the Montana Water Quality Standards, may not be fully attained by this action. Surface and groundwater ARARs will be considered fully in the remedy selection process for this Site. The final remedy at the site will attain all ARARs, including contaminant specific ARARs, unless a waiver is appropriate. The State contaminant specific requirements include, but are not limited to, compliance with ARM 17.30.1006 (compliance with groundwater standards based on class of groundwater); § 75‐5‐303, MCA (Montana non‐degradation policy) and associated rules found at ARM 17.30.701 et seq.; § 75‐5‐101 et seq. (Montana Water Quality Act); ARM 17.30.607 (1) (classification of waters of the site, in particular classification of the Clark Fork River as B‐1); ARM 17.30.623 (criteria for B‐1 waters, including DEQ‐7 standards). DEQ‐7 standards will be applied to both point sources affected or created by the Site cleanup and to ambient water in the Site.

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§§ 87-5-101 et seq. (Applicable): Endangered species should be protected in order to maintain and to the extent possible enhance their numbers. These sections list endangered species, prohibited acts and penalties. See also § 87-5-201, MCA, (Applicable) concerning protection of wild birds, nests and eggs, and ARM 12.5.201 (Applicable) prohibiting certain activities with respect to specified endangered species. Action Specific Requirements4 A. Air Standards Sections 75-2-101, et seq., MCA, (Applicable) provides that state emission standards are enforceable under the Montana Clean Air Act. ARM 17.8.802 (Applicable) incorporates by reference the air regulations in certain parts of CFR Title 40 regarding quality assurance requirements for prevention of significant deterioration air monitoring; standards of performance for new stationary sources; emission standards for hazardous air pollutants, and other standards and requirements. ARM 17.8.805 (Applicable) provides ambient air ceilings, and states that no concentrations of a pollutant shall exceed concentrations permitted under either the applicable secondary or the primary national ambient air quality standard, whichever concentration is lowest for the pollutant for a period of exposure. ARM 17.8.204 (Applicable) provides for ambient air monitoring and provides that, generally, all ambient air monitoring, sampling and data collection, recording, analysis and transmittal must be in compliance with the Montana Quality Assurance Manual except when DEQ determines that more stringent requirements are necessary. ARM 17.8.223 (Applicable) These standards, promulgated pursuant to section 109 of the Clean Air Act, are applicable to releases into the air from any Site cleanup activities. Particulate matter 4 The State understands that the proposed removal action will include disposal of solid waste off‐Site at the Missoula County Landfill. Should the scope of the removal action change to include on‐Site disposal of solid waste, the State will identify the pertinent Solid Waste requirements. These include, but are not limited to, the Solid Waste Management Act found at §§ 75‐10‐201 et seq., MCA, and its implementing regulations found at Administrative Rules of Montana, Rule 17, Chapter 50. The requirements will also be included as Location Specific Requirements, and further include prohibitions on the locations of landfills, See ARM 17.54.505 and § 75‐10‐212, MCA. Additionally, the scope of this limited removal action is not expected to implicate ARARs associated with discharge to surface water or hydrology regulations associated with excavation or grading. Should the scope of the removal change to trigger these requirements, the State will identify the pertinent ARARs associated with such action, including but not limited to the MPDES requirements found in ARM Rule 17, Chapter 50, Water Quality Statutes and Regulations found at §§75‐5‐601 et seq., MCA and §§ 75‐5‐301, et seq., MCA and Hydrology Regulations associated with reclamation activities found at §§82‐4‐201 et seq., MCA, and ARM Rule 17, Chapter 24. Additionally, the final remedy at the site will fully consider these ARARs.

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that is 10 microns in diameter or smaller (PM-10): No person shall cause or contribute to concentrations of PM-10 in the ambient air which exceed:

150 ug/m3 of air, 24 hour average, no more than one expected exceedance per calendar year;

50 ug/m3 of air, annual average. Dust suppression and control of certain substances likely to be released into the air as a result of earth moving, transportation, and similar actions related to remedial activity at the Site may be necessary to meet air quality requirements. ARM 17.8.308 (Applicable) provide that no person shall cause or authorize the production, handling, transportation or storage of any material, cause or authorize the use of any street, road, or parking lot, or operate a construction site or demolition project, unless reasonable precautions to control emissions of airborne particulate matter are taken. Normally, emissions of airborne particulate matter must be controlled so that they do not “exhibit an opacity of twenty percent (20%) or greater averaged over six consecutive minutes.” See also ARM 17.8.304 (Applicable). In addition, state law provides an ambient air quality standard for settled particulate matter. Particulate matter concentrations in the ambient air shall not exceed the following 30-day average: 10 grams per square meter. ARM 17.8.220 (Applicable). Whenever this standard is exceeded, the activity resulting in such exceedance shall be suspended until such time as conditions improve. ARM 17.24.761 (Relevant and Appropriate) specifies a range of measures for controlling fugitive dust emissions during mining and reclamation activities. Some of these measures could be considered relevant and appropriate to control fugitive dust emissions in connection with excavation, earth moving and transportation activities conducted as part of the action at the Site. Such measures include, for example, paving, watering, chemically stabilizing, or frequently compacting and scraping roads, promptly removing rock, soil or other dust forming debris from roads, restricting vehicle speeds, revegetating, mulching, or otherwise stabilizing the surface of areas adjoining roads, restricting unauthorized vehicle travel, minimizing the area of disturbed land, and promptly revegetating regraded lands. The proposed action involves handling impacted soil. Removal actions at the site will include wetting and other best management practices (BMPs) related to fugitive dust control. Removal actions will be halted if significant dust is generated and will not resume until adequate dust control measures are in place. Dust control measures will ensure that air standards will not be exceeded during the removal action.

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B. Transportation of Hazardous or Contaminated Waste ARM 17.53.701-708 (Applicable) adopts the equivalent to RCRA regulation at 40 CFR Part 263, establishing standards that apply to transporters of hazardous waste, with certain State exceptions and additions. ARM 17.50.523 (Applicable) which specifies that solid waste must be transported in such a manner as to prevent its discharge, dumping, spilling or leaking from the transport vehicle. C. Reclamation Requirements Noxious Weed Control Act, Section 7-22-2101 et seq., MCA, and ARM 4.5.201 et seq. (Applicable) Section 7-22-2101(8)(a), MCA, (Applicable) defines “noxious weeds” as any exotic plant species established or that may be introduced in the state which may render land unfit for agriculture, forestry, livestock, wildlife, or other beneficial uses or that may harm native plant communities and that is designated: (i) as a statewide noxious weed by rule of the department; or (ii) as a district noxious weed by a board, following public notice of intent and a public hearing. Section 7-22-2152, MCA, (Applicable) requires that any person proposing certain actions including but not limited to a solid waste facility, a highway or road, a commercial, industrial, or government development, or any other development that needs state or local approval and that results in the potential for noxious weed infestation within a district shall notify the district weed board at least 15 days prior to the activity. The board will require that the areas be seeded, planted, or otherwise managed to reestablish a cover of beneficial plants. The person committing the action shall submit to the board a written plan specifying the methods to be used to accomplish revegetation at least 15 days prior to the activity. The plan must describe the time and method of seeding, fertilization practices, recommended plant species, use of weed-free seed, and the weed management procedures to be used. The plan is subject to approval by the board, which may require revisions to bring the revegetation plan into compliance with the district weed management plan. The activity for which notice is given may not occur until the plan is approved by the board and signed by the presiding officer of the board and by the person or a representative of the agency responsible for the action. The signed plan constitutes a binding agreement between the board and the person or agency. The plan must be approved, with revisions if necessary, within 10 days of receipt by the board. The Strip and Underground Mine Reclamation Act, §§ 82-4-201 through 254, MCA (Relevant and Appropriate), technically applies to coal and uranium mining, but that statute and the regulations promulgated under that statue and discussed in this section set out the

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standards that excavation activities and reclamation of excavated areas should attain. Those requirements identified here have been determined to be relevant and appropriate requirements for this action. Section 82-4-231, MCA, (Relevant and Appropriate) requires the reclamation and revegetation of the land as rapidly, completely, and effectively as the most modern technology and the most advanced state of the art will allow. In developing a method of operation and plans of backfilling, water control, grading, topsoiling and reclamation, all measures shall be taken to eliminate damages to landowners and members of the public, their real and personal property, public roads, streams, and all other public property from soil erosion, subsidence, landslides, water pollution, and hazards dangerous to life and property. Section 82-4-233, MCA, (Relevant and Appropriate) requires vegetation as is necessary to establish a diverse, effective, and permanent vegetative cover of the same seasonal variety native to the area of land to be affected and capable of self-regeneration and plant succession at least equal in extent of cover to the natural vegetation of the area except that introduced species may be used in the revegetation process where desirable and necessary to achieve the approved postmining land use plan. D. Reclamation and Revegetation Requirements Certain portions of the Montana Strip and Underground Mining Reclamation Act and Montana Metal Mining Act as outlined below are relevant requirements for the selected action. While no mining activities are occurring at the facility, these requirements are relevant and appropriate for the management and reclamation of areas disturbed by excavation, grading, or similar actions. ARM 17.24.501 (Relevant and Appropriate) gives general backfilling and final grading requirements. Backfill must be placed so as to minimize sedimentation, erosion, and leaching of acid or toxic materials into waters, unless otherwise approved. Final grading must be to the approximate original contour of the land, and final slopes must be graded to prevent slope failure. The disturbed areas must be blended with surrounding and undisturbed ground to provide a smooth transition in topography. ARM 17.24.519 (Relevant and Appropriate) provides that an operator may be required to monitor settling of regraded areas. ARM 17.24.702(4), (5), and (6) (Relevant and Appropriate) requires that during the redistributing and stockpiling of soil (for reclamation):

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1. regraded areas must be deep-tilled, subsoiled, or otherwise treated to eliminate any possible slippage potential, to relieve compaction, and to promote root penetration and permeability of the underlying layer; this preparation must be done on the contour whenever possible and to a minimum depth of 12 inches; 2. redistribution must be done in a manner that achieves approximate uniform thicknesses consistent with soil resource availability and appropriate for the postmining vegetation, land uses, contours, and surface water drainage systems; and 3. redistributed soil must be reconditioned by subsoiling or other appropriate methods.

ARM 17.24.703 (Relevant and Appropriate) requires that when using materials other than, or along with, soil for final surfacing in reclamation, the operator must demonstrate that the material (1) is at least as capable as the soil of supporting the approved vegetation and subsequent land use, and (2) the medium must be the best available in the area to support vegetation. Such substitutes must be used in a manner consistent with the requirements for redistribution of soil in ARM 17.24.701 and 702. ARM 17.24.711 (Relevant and Appropriate) requires that a diverse, effective, and permanent vegetative cover of the same seasonal variety native to the area of land to be affected shall be established except on road surfaces and below the low-water line of permanent impoundments. See also § 82-4-233, MCA (Relevant and Appropriate). Vegetative cover is considered of the same seasonal variety if it consists of a mixture of species of equal or superior utility when compared with the natural vegetation during each season of the year. This requirement may not be appropriate where other cover is more suitable for the particular land use or another cover is requested by the landowner. ARM 17.24.713 (Relevant and Appropriate) provides that seeding and planting of disturbed areas must be conducted during the first appropriate period for favorable planting after final seedbed preparation. ARM 17.24.714 (Relevant and Appropriate) requires use of a seedbed preparation, mulch, or cover crop until an adequate permanent cover can be established. This requirement may be suspended under certain conditions. ARM 17.24.716 (Relevant and Appropriate) establishes the required method of revegetation.

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ARM 17.24.717 (Relevant and Appropriate) Trees or other shrub species necessary to meet the approved postmining land use must be adapted for local site conditions and climate. Trees and shrubs must be planted in combination with herbaceous species as necessary to achieve the postmining land use and as approved by the department. If necessary to increase tree and shrub survival, seeding of the herbaceous species may be delayed providing that measures are taken to control air and water pollution and erosion. ARM 17.24.718 (Relevant and Appropriate) requires the use of soil amendments and other means such as irrigation, management, fencing, or other measures, if necessary to establish a diverse and permanent vegetative cover. Reclamation land use practices including, but not limited to, grazing, haying, or chemical applications, may not be conducted in a manner or at a time that interferes with establishment and/or persistence of seeded and planted grasses, forbs, shrubs, and trees or with other reclamation requirements. ARM 17.24.723 (Relevant and Appropriate) sets forth requirements for vegetation, soils, wildlife, and other monitoring. ARM 17.24.724 (Relevant and Appropriate) specifies that revegetation success must be measured against approved unmined reference areas or by comparison with technical standards from historic data. More than one reference area or historic record must be established for vegetation types with significant variation due to a number of factors. ARM 17.24.726 (Relevant and Appropriate) sets forth vegetation production, cover, diversity, density, and utility requirements.

Federal ARARs

Toxic Substances Control Act, 40 C.F.R. Part 761 (applicable). The PCB materials will be managed and disposed according to the TSCA requirements. Soil cleanup standards will be applied to the extent practicable.

TO BE CONSIDERED DOCUMENTS (TBCS)

OTHER LAWS (NON-EXCLUSIVE LIST) The following "other laws" are included here to provide a reminder of other legally applicable requirements for actions being conducted at the Smurfit Stone Mill Site. They do not purport to be an exhaustive list of such legal requirements, but are included because they set out related concerns that must be addressed and, in some cases, may require some advance planning. They are not included as ARARs because they are not "environmental or facility siting laws." As applicable laws other than ARARs, they are not subject to ARAR waiver provisions.

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Section 121(e) of CERCLA exempts removal or remedial actions conducted entirely on-site from federal, state, or local permits. This exemption is not limited to environmental or facility siting laws, but applies to other permit requirements as well. Other Federal Laws Occupational Safety and Health Regulations The federal Occupational Safety and Health Act regulations found at 29 CFR § 1910 are applicable to worker protection during conduct of RI/FS, removal actions, or remedial activities. Other Montana Law Occupational Health Act, §§ 50-70-101 et seq., MCA. ARM § 17.74.101 addresses occupational noise. In accordance with this section, no worker shall be exposed to noise levels in excess of the levels specified in this regulation. This regulation is applicable only to limited categories of workers and for most workers the similar federal standard in 29 CFR 1910.95 applies. ARM § 17.74.102 addresses occupational air contaminants. The purpose of this rule is to establish maximum threshold limit values for air contaminants under which it is believed that nearly all workers may be repeatedly exposed day after day without adverse health effects. In accordance with this rule, no worker shall be exposed to air contaminant levels in excess of the threshold limit values listed in the regulation. This regulation is applicable only to limited categories of workers and for most workers the similar federal standard in 29 CFR § 1910.1000 applies. Montana Safety Act Sections 50-71-201, 202 and 203, MCA, state that every employer must provide and maintain a safe place of employment, provide and require use of safety devices and safeguards, and ensure that operations and processes are reasonably adequate to render the place of employment safe. The employer must also do every other thing reasonably necessary to protect the life and safety of its employees. Employees are prohibited from refusing to use or interfering with the use of safety devices. Employee and Community Hazardous Chemical Information Sections 50-78-201, 202, and 204, MCA, state that each employer must post notice of employee rights, maintain at the work place a list of chemical names of each chemical in the work place, and indicate the work area where the chemical is stored or used. Employees must be informed of the chemicals at the work place and trained in the proper handling of the chemicals.

APPENDIX B Standard Operating Procedures (SOPs)

Extracted from the EPA-Approved Quality Assurance Project Plan

STANDARD OPERATING PROCEDURES TABLE OF CONTENTS

SOP TITLE

1 Field Log Book and Field Sampling Forms

2 Equipment Decontamination

3 Sample Nomenclature, Documentation, and Chain-of-Custody Procedures

4 Sample Packaging and Shipping

13 Surface Soil Sampling

14 Subsurface Soil Sampling

22 Management of Investigative-Derived Waste

•• •

SOP-1 Field Forms Page 1 of 2

SOP-1

FIELD LOG BOOK AND FIELD SAMPLING FORMS

Pertinent field investigation and sampling information should be recorded on a daily field log book and appropriate sampling forms to provide a continual record of actions taken each day on the site. Each employee is responsible for completing a record of the day’s activities in a log book and field forms of sufficient detail such that someone can reconstruct the field activities without relying on the memory of the field crew. Field Books will be bound, with consecutively numbered pages and all information must be recorded with permanent ink. If changes need to me made within the field book, a single strikethrough line will be used to mark out incorrect information. Initials of the employee making the corrections and the date of the correction must accompany the strikeout. At a minimum, daily entries on the field log book shall include, as appropriate:

• Project and client name

• Date, times and locations.

• Purpose of the field effort

• Names of field crew leader and team members present on the site, and other site visitors

• Description of site conditions and any unusual circumstances, including weather conditions

• Details of actual work performed, particularly any deviations from the field work plan or standard operating procedures

• Location of sample site, including map reference, if relevant

• Field observations including documentations of conditions and procedures used when collecting, handling or treating samples.

• Field measurements made (e.g., PID readings, pH, temperature) on appropriate forms.

• Date and time of initiation and cessation of work.

Specific details for each sample collected should be recorded using NewFields standardized field forms. These field forms contain blank queries to be filled in by field personnel. Items typically recorded on field sampling forms consist of the following:

• Sample name

• Time and date samples were collected

• Number and type (media; natural, duplicate, QA/QC) of samples collected

• Analysis requested

• Sample depth

Purpose To provide guidance on how to document activities completed in the field by NewFields employees

Goal and Objective To provide a record of our project work and the decisions made in the field

Equipment Needs Field Note Book Field Sampling Forms Permanent Writing Utensils Camera

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SOP-1 Field Forms Page 2 of 2

• Sample preservative (if applicable) and volume

• Sampling method, particularly any deviations from standard operating procedures

• Additional field observations, including collection of field parameters

• Decontamination procedures (if applicable)

• Photo documentation; including a photo board in the photograph with details such as date, time and location or an accompanying photo log with descriptions, dates, and times.

• Signature of sampler

The field log book and field data sheet must be signed on a daily basis by the author of the entry. Upon completion of the field effort, the original field forms will be electronically scanned and both hard copies and electronic documents will be filed in their respective project file. Photocopies of the original field forms can be made and used as working documents.

•• •

SOP-2 Equipment Decontamination Page 1 of 2

SOP-2

EQUIPMENT DECONTAMINATION

Decontamination of field equipment is necessary to prevent cross contamination between sites to be investigated and sampling locations on a site. Decontamination should be performed on all non-dedicated and non-disposable sampling equipment that may contact potentially contaminated media.

The following should be done to decontaminate field sampling equipment:

Set up a decontamination area, preferably upwind from the contaminated zone to reduce the potential for windborne contamination.

Wear disposal gloves while decontaminating equipment.

Prior to initiating decontamination, visually inspect sampling equipment for evidence of contamination; use stiff brush to remove visible material.

Once rough brushing is complete, decontaminate each piece of equipment following a sequential process of washing with Liquinox or an equivalent degreasing detergent; rinsing with distilled water; rinsing with 10% dilute nitric acid, methanol, or hexane (dependent upon Contaminant of Concern (COC)); and finally rinsing with distilled water three times. Best procedure is to set up wash tubs for each of the above processes.

Rinse equipment with methanol instead of nitric acid if sampling for organic contamination.

Decontaminated equipment that is used for sampling organics should be wrapped in aluminum foil or another inert material if not used immediately.

The following should be done for oversized equipment, such as drilling rigs, excavators, and haul trucks:

Prior to exiting the excavation area, the equipment operator will ensure that the equipment is inspected for adhering soil or other material. Visible soil adhering to equipment will be removed using dry decontamination techniques (shovels and brooms) as necessary to prevent cross-contamination of the site during site work.

If dry decontamination techniques cannot remove visible soil, in a designated decontamination area, high pressure

Purpose

The purpose of this SOP is to describe general decontamination procedures for field equipment

Goal and Objective

To sufficiently clean field equipment to prevent cross contamination between sites and sample locations

Equipment Needs

5-gallon plastic tubs/buckets Distilled water 10% Nitric Acid rinse (if metals are COC) 10% Methanol (if organic COC are present) Hexane (if PCBs are COC) Liquinox Soap Hard Bristle Brush Garbage Bags Disposable Gloves Paper Towels 55-gallon drums (optional depending on need to containerize wash water) High pressure washer* Tap Water* *(for oversize equipment)

•• •

SOP-2 Equipment Decontamination Page 2 of 2

wash with heated tap water will be used to clean the portions of equipment that contact soil (i.e. tracks, auger flights, wheels and excavator buckets). For haul trucks, special attention must also be given to mud flaps, wheel wells, undercarriage, and foot surfaces (cab floor, control pedals, or walking boards).

If rinseate generated during the decontamination process requires containerization, establish a lined decontamination area and move equipment into this area during decontamination. Rinseate should either be tested and managed accordingly (see below), or loaded on to trucks hauling contaminated soil/waste from the same source for disposal. If testing indicates the rinseate is not hazardous waste and would not cause or contribute to excess health risks or groundwater concerns, rinseate may be allowed to infiltrate into the ground.

Where water is used in decontamination of oversize equipment, the vehicles will be held in the area for at least 2 minutes after completion of washing to allow for collection of drippings in the designated area.

All disposable items (e.g., paper towels, latex gloves) should be deposited into garbage bags and disposed as Class II common refuse, unless investigating a site known to contain hazardous wastes. Check with the project manager before initiating investigation to confirm proper handling of disposable items. Handling and disposal procedures for rinse water, wash water, and disposable items will depend on the type of contaminant being assessed; and the project Field Sampling Plan should be reviewed to determine the process for disposal.

If equipment rinse blank samples are to be collected as part of quality control procedures, they should be collected from decontaminated sampling equipment in accordance with the project-specific Field Sampling and documented in accordance with SOP-1.

A list of materials for decontamination is provided in the text box on Page 1. The amount of distilled water and rinse solutions needed on site will depend on the number of samples to be collected and the sampling methods. For this reason, equipment needs should be evaluated prior to going in the field.

•• •

SOP-3 Sample Nomenclature, Documentation, and Chain-of-Custody Procedures Page 1 of 3

SOP-3

SAMPLE NOMENCLATURE, DOCUMENTATION, AND CHAIN-OF CUSTODY PROCEDURES

When completing sampling it is critical that the process used to label and transport samples to the laboratory for analysis is sufficient to demonstrate with confidence that the samples were collected from the location indicated, and that during transport to the lab no actions were taken to potentially alter the integrity of the samples. Without following strict sample labeling and chain-of-custody procedures, analytical data collected at a site has little to no value.

SAMPLE NOMENCLATURE

Samples should be labeled in such a way to allow a person unfamiliar with the site to understand where the samples were collected. Samples should be labeled sequentially as follows:

General location designation - sampling method and site number – sample media type – sequential sample number and composite designation (if needed).

For example, the soil sample P3-TP1-SB-01, indicates the sample was collected in Pond 3 (P3), test pit number 1 (TP1), it was a sub-surface soil sample (SB), and it’s the first sample collected (01). Discrete samples are assumed. If the sample is a composite (C), Additional designation should be added after the sequential sample number ie: P3-TP1-SB-01C.

Sediment samples are labeled similar to soils. CFR indicates the sample was collected along the Clark Fork River, these samples will be collected in either the Flood Fringe (FF) of the 100-year floodplain or subaqueous (SA) within the river channel and will be designated as sediment samples (SE). An example of the first location Flood Fringe sample in the CFR would be named CFR-FF1-SE-01. The first subaqueous sample would be named CFR-SA1-SE-01. Similarly, surface water samples would use the designation (SW) ie: (CFR-SA1-SW-01).

Newly installed groundwater monitoring wells will be named by the field oversight person, and include NF for NewFields, followed by a designation of the well type (MW) for monitoring well, and a well number. An example groundwater sample name would be: NFMW1. If multiple groundwater samples were to be collected from NFMW1 then they should be named sequentially NFMW1-01, NFMW1-02…. .

Prior to initiating sampling, field personnel should familiarize themselves with the Field Sampling Plan and the nomenclature to be used for the site. The character prefixes in the table below are recommended for sample types.

Purpose To identify the specific requirements for labeling and documenting sample collection

Goal and Objective To increase the confidence in sample locations and to submit samples to the laboratory without risk of integrity loss

Equipment Needs Indelible ink pen

Chain-of-custody forms

Field Log Book

Field Sampling Form

•• •


SAMPLE DOCUMENTATION

In addition to the chain-of-custody forms discussed below, field person must keep a list of samples collected in the field in the field log book and on appropriate field sampling forms. This allows you to go back and verify sample locations and numbers should there be any confusion at a later time. Upon returning to the office, the field log book and forms should be kept in the project file and subsequent copies sent to the laboratory, or other designated parties, as needed.

Each person in the field is responsible for putting entries into the field log and sampling forms. Designating an individual from the sampling team for record keeping is fine, provided all field personnel come to an agreement as to who this will be, and the field crew leader is certain field personnel are familiar with the record keeping requirements. All entries on the log book and field sampling forms must be made in indelible ink.

Sampling Acronym Label EB Equipment Blank TB Trip Blank FB Field Blank

MW Monitoring Well DW Domestic Well IW Injection Well OB Observation Well UST Underground Storage Tank VE Vapor Extraction AA Ambient Air

SUMP Sump (Water sample) P Pond

SPR Spring SE Sediments SW Surface Water, Stream or River SR Surface Runoff SA Subaqueous FF Flood Fringe (Floodplain) FW Flood Way (Floodplain) GR Grab Sample TP Excavated Test Pit BH Borehole SS Surface Soil Sample SB Subsurface Soil Sample

GW Groundwater Sample

•• •


CHAIN OF CUSTODY PROCEDURES

A chain-of-custody form must be generated for all samples collected in the field for laboratory analysis. Samples from more than one project should not be included on the same chain of custody; however, multiple samples from a specific project can be included on the same custody form.

Copies of the chain-of-custody form should be maintained in the project file. The sampler may use a NewFields’ chain-of-custody form or a chain- of-custody form provided by the laboratory. Sample custody records must be maintained from the time of sample collection until the time of sample delivery to the analytical laboratory and should accompany the sample through analysis and final disposition. The information to be included on the chain-of-custody form will include, but is not limited to:

• Project number/site name

• Sampler’s name and signature

• Date and time of sample collection

• Unique sample identification number or name

• Number of containers

• Sample media (e.g., soil, water, vapor, etc.)

• Sample preservative (if applicable)

• Requested analysis

• Comments or special instructions to the laboratory

Each sample must be assigned a unique sample identification number as described above. The information on the chain-of-custody form, including the sample identification number, must correspond to the information recorded by the sampler on the field forms and field log book and the label on the sample container.

A sample is considered under a person’s control when it is in their possession. When custody of a sample is relinquished by the sampler, the sampler will sign and date the chain-of-custody form and note the time that custody was relinquished. The person receiving custody of the sample will also sign and date the form and note the time that the sample was accepted into custody. The goal is to provide a complete record of control of the samples. Should the chain be broken (signed by the relinquished but not receiver or vice versa), the integrity of the sample is lost and the resulting analytical data suspect. Samples must be shipped to the analytical laboratory following the procedures described in in SOP-4. If an overnight shipping service is used to transport the samples to the laboratory, custody of the samples must be relinquished to the shipping service. If possible, have the shipping service sign the chain-of-custody form prior to placing the chain of custody in the sample cooler. If this is not possible (i.e. form placed in the sealed cooler), a note should be included on the chain of custody that the shipping company has received the samples with the chain of custody inside the cooler.

•• •

SOP-4 Sample Packing and Shipping Page 1 of 2

SOP-4

SAMPLE PACKAGING AND SHIPPING

SAMPLE PACKAGING

Samples must be packaged to preclude breakage or damage to sample containers, and shipped under chain of custody, complying with shipper, U.S. EPA, and U.S. DOT regulations. When packaging samples:

• Chain of custody procedures must be strictly adhered to. This applies to sample collection, transportation, shipment and laboratory handling. The COC will provide documentation from collection to analysis.

• Use sample labels from the laboratory whenever possible. Place the sample label on the side of the sample container and use indelible ink when completing the label. Sample containers should be new and stored in an environment free from dust, dirt and fumes.

• Sample should never stand in the sun. After collection and preservation, place labeled sample bottles in a high quality cooler. Place the samples in an upright position inside the cooler and wrap the samples with cushioning material for protection during transport. The cooler should be able to withstand tough handling during shipment without sample breakage.

• Make sure the cooler has an adequate amount of “wet” or “blue” ice (inside sealed Ziploc bags) at all times containers or in them and make sure ice volume is sufficient and appropriate for the season in order to maintain a temperature of 4°C or less inside the cooler from the time the samples are placed in the cooler until they are received by the laboratory. When in doubt put in more ice. Ensure the cooler drain plug is taped shut.

• Fill out the appropriate chain-of-custody forms and place them in a Ziploc bag and tape it to the inside lid of the shipping container. If more than one cooler is used per chain of custody, put a photocopy in the other coolers and mark them as a copy. Commercial carriers are not required to sign the COC, but the tracking number and name of the carrier should be documented on the original cahin-of-custody.

• Close and thoroughly secure the cooler with packing tape.

Purpose To ensure samples are properly packaged for shipment to the analytical laboratory

Goal and Objective To have samples received by the analytical laboratory in good condition and within EPA temperature thresholds

Equipment Needs Indelible ink pen

Chain-of-custody forms

Custody Seals

Sample Labels from Lab

Coolers and Ice

Field Sampling Form

Packing Tape

Bubble wrap/absorbent pads

•• •

SOP-4 Sample Packing and Shipping Page 2 of 2

• Place completed sample custody seals on the outside of the cooler such that the seals will be broken when the cooler is opened. Secure the custody seals on the cooler with clear strapping tape.

• Secure a shipping label with address, phone number, and return address on the outside of the cooler where it is clearly visible. Shipping samples should be coordinated and scheduled to prevent exceeding of hold times or temperature requirements of analytical tests. Check with the lab if there are questions regarding holding times. If Saturday delivery is necessary, confirm with the lab that they will be able to receive the sample delivery before it is shipped.

SHIPPING HAZARDOUS MATERIALS/WASTE

Transportation regulations for shipping of hazardous substances and dangerous goods are defined by the U.S. DOT in 49 CFR, Subchapter C, Part 171 (October 1, 1988); IATA and ICAO. These regulations are accepted by Federal Express and other ground and air carriers.

According to DOT regulations, environmental samples are classified as Other Regulated Substances (ORS). ORS are articles, samples, or materials that are suspected or known to contain contaminants and/or are capable of posing a risk to health, safety, or property when transported by ground or air. Samples, substances, or materials from sources other than material drums, leachate streams, or sludge, should be considered as ORS or environmental samples. Materials shipped under the classification of ORS must not meet any of the following definitions:

Class 1: Explosives; Class 2: Gases- compressed, liquefied, dissolved under pressure, or deeply refrigerated; Class 3 Flammable Liquids; Class 4: Substances susceptible to spontaneous combustion; Class 5: Oxidizing substances; Class 6: Poisonous (toxic and infectious); Class 7: Radioactive materials; Class 8: Corrosives.

If your samples might meet any of the above definitions, contact the project manager to obtain instructions on sample shipment.

•• •

SOP-13 Surface Soil Sampling Page 1 of 2

SOP-13

SURFACE SOIL SAMPLING

This SOP describes the field equipment and sampling methods for sampling of surface soil. Be sure to review the project specific Field Sampling Plan (FSP) in addition to this SOP.

All sampling equipment must be decontaminated before arriving on site in accordance with SOP-2. All sampling equipment should be decontaminated between collection of samples.

SURFACE SOIL SAMPLING

Commonly, there are two different methods of surface soil sampling completed on a site: Discreet or Grab Samples, and Composite Samples. The methods for each of these are described below.

For both methods, surface soil samples should be collected from the surface to a depth of six inches unless otherwise specified in the project specific FSP. The FSP will outline the appropriate sampling approach for collection of composite vs. discrete samples.

Soils should be described according to the procedures outlined in the United Soil Classification System (USCS; method ASTM D2487) or the Soil Conservation Service (SCS) classification system. Soil texture should be classified by either the USCS or the U.S. Department of Agriculture (USDA) classification. Descriptions shall be recorded in the field books.

Discrete or Grab Soil Samples

• Locate the site as directed in the appropriate FSP. If location is not staked, confirm location with GPS unit.

• Prep sample containers by labelling in accordance with naming conventions outlined in the FSP, and SOP-3.

• Wearing disposable latex or nitrile gloves collect a sample by scraping the 0-6 inch interval of soil with a decontaminated stainless steel spoon or trowel.

• Place the soil in a stainless steel bowl, unless testing of the soil for volatile organic compounds is required. If VOC analysis is required, place representative soil sample directing into sample container.

• If sample is place in a bowl (no VOC analysis), remove all coarse fragments greater than 0.5 inches from the bowl. Remove leaves, grass, and debris from sample.

•

Purpose Provide guidelines for sampling of surface soil.

Goal and Objective To employ a method of collecting surface soil samples representative of field conditions.

Equipment Needs Stainless steel mixing bowl and sampling trowel

Sample Containers

Hand lens (10) power

pH and electrical conductivity meters for soil (if required)

Munsel color book (if required)

Latex or Nitrile gloves

Locating Flags

Coolers and Ice

GPS Unit

Field forms, field book COC

Camera/photo board

•• •

SOP-13 Surface Soil Sampling Page 2 of 2

• Transfer the soil sample directly from the bowl into a glass sample jar with Teflon cap (4 or 8 ounce, depending on number of analyses required) and store in a cooler at 4 degrees Celsius or less. Retain approximately 30 grams of the sample in a plastic bag for field measurement of pH or PID screening, if required.

• Push a marking flag into the ground at the sample location, which will allow for obtaining the coordinates of the sample location later with a GPS Unit, or take a coordinate reading using the GPS unit prior to moving to another sample location.

• Record information about the sample collection on the appropriate forms in accordance with SOP-1 . Document sample collection and location with photographs.

Composite Samples

Review the FSP to determine the location and spacing of sampling area grids for the collection of composite samples. When reviewing, determine the grid to be cordoned off in the field and the number of composite samples to be collected within the each grid. Follow the process below to collect the composite samples. Composite soil samples should never be collected for analysis of volatile organic compounds.

• Prior to collecting composite samples, mark off the sampling grid or detail as described in the FSP. This may include collection of a sub-set of samples within a grid, or subset of samples a set radial distance from a sampling point.

• If sampling within a grid, divide the grid into five to eight (as indicated in the FSP) smaller grids and collect a surface soil sample randomly from within the smaller grid. Sample from each smaller grid should be of equal volume and collected using a decontaminated trowel. Place each composite sample into a mixing bowl. If a sod or duff layer is present, this layer should be peeled back to the top of the mineral soil. Remove all coarse fragments greater than 0.5 inches from the bowl. Mix the composite samples in the mixing bowl and then a fill a laboratory supplied sample container with the mixed soil.

• Push a marking flag into the ground at each of the composite sample locations to allow for obtaining the coordinates of the sample location later with a GPS Unit, or take a coordinate reading using the GPS unit prior to moving to another composite sample location.

• Complete appropriate field sampling forms and the chain of custody in accordance with SOP-1 and SOP-3. Store all samples in a cooler with ice and ship samples in accordance with SOP-4.

•• •

SOP-14 Subsurface Soil Sampling Page 1 of 3

SOP-14

SUBSURFACE SOIL SAMPLING

SUBSURFACE SOIL SAMPLING

Subsurface soil sampling is commonly completed using a hand auger, split spoon sampler and drill rig, direct push drilling equipment, or backhoe or excavator. Sampling procedures for each type of equipment is described below. Be sure to review the project specific Field Sampling Plan (FSP) in addition to this SOP. For any subsurface soil sampling event, locate the site to be sampled and ensure that drilling equipment can safely access the site. Minimize off road travel to prevent off site damage to surrounding vegetation. One call utility locate will be called and ticket number recorded prior to initiating any subsurface work below two feet.

Hand Auger

• Arrive on-site equipped with a decontaminated stainless steel auger rod and hand auger. If you intend to collect samples from different intervals below grade, bring several sizes of stainless steel augers (e.g. 2-inch, 4-inch, 6-inch, etc.).

• Hand auger holes can be drilled as one size or in a telescoping manner if you wish to collect discreet samples at intervals below grade and prevent risk of cross contamination between intervals. If a single depth sample is required, advance the auger bucket to the top of the desired sampling interval depth and empty the contents of the auger and remove all cutting from borehole. Decontaminate the auger and advance it to the bottom of the hole and collect a sample. Place the sample in a stainless steel mixing bowl. Mix and place soil into appropriate sample containers.

For the telescoping method, advance the largest auger first to the desired depth. Collect sample at that depth. Install temporary decontaminated PVC casing with a diameter slightly smaller than the borehole to keep the hole open and reduce possible cross-contamination between depth intervals. Using the next size smaller auger, auger down to the next desired depth and repeat collected of sample at the desired depth.

• Record lithology of soil encountered according to USCS classification system on a boring log.

• Fill out appropriate sample labels, field forms and chain-of-custody paperwork in accordance with SOP-1 and SOP-3.

• Place samples for lab analysis in a cooler with ice and ship according to SOP-4.

Purpose Provide guidelines for sampling of subsurface soil.

Goal and Objective To employ a method of collecting subsurface soil samples representative of field conditions.

Equipment Needs Will depend on sampling method

Stainless steel mixing bowl and sampling trowel

Hand lens (10) power

Munsel color book (if required)

Latex or Nitrile gloves

Locating Flags

GPS Unit

Sample containers

Coolers and Ice

Field forms and field book

Decontamination supplies

•• •


• Decontaminate all sampling equipment between sampling sites in accordance with SOP-2.

Split Spoon Sampling using a Hollow-Stem Auger Drill Rig

This SOP does not include procedures for operating drilling equipment. Equipment operation will be subcontracted to a qualified third party that is properly trained.

• Driller should arrive on-site equipped with at least two standard 1.4 inch inside diameter decontaminated split spoon samplers and decontaminated auger flights.

• To collect a sample at depth, driller should advance hollow-stem auger to the desired depth. Driller should remove rod and bit and install split-spoon sampler on end of rod. Driller should then lower rod to desired sampling depth with the hollow-stem auger. Using a 140 pound drop hammer, driller should pound the sampler into the underlying soil, recording the number of blow counts necessary to drive it over the entire length of the sampler (18 inches). Blow counts should be counted for each driven 6-inch interval.

• Retrieve sampler and place on work table. Using the other sampler, repeat this sequence again when driller has reached desired depth of sampling, decontaminating the split spoon in accordance with SOP-2 after every sample.

• Record lithology of soil within the sampler according to USCS classification system on standard boring log. In addition, record the blow counts and percent recovery from cores retrieved from split spoon sampler on the field boring log.

• If required by the field sampling plan, composite like core intervals by mixing soil the soil in stainless steel bowl. When sampling for volatile organic compounds, the sample should never be composited.

• Containerize samples, and follow standard procedures for recording field information, sample labeling, and sample shipment and packaging in accordance with SOP-1, SOP-3 and SOP-4, respectively.

• Decontaminate all sampling equipment between sampling sites in accordance with SOP-2.

Direct Push Drilling Equipment

This SOP does not include procedures for operating drilling equipment. Equipment operation will be subcontracted to a qualified third party that is properly trained.

• Advance sampling rods lined with acetate sleeves to the prescribed depth. Retrieve the rods, remove the sample sleeves, and secure on the work table.

• Record lithology in accordance with USCS standard practices and percent recovery from the retrieved sample sleeve on standard field forms.

• If required by the project work plan or sampling and analysis plan, composite like core intervals by mixing in stainless steel bowl in a similar manner as described for surface sampling (SOP-13). When sampling for volatile organic compounds, the sample should not be mixed.

• Containerize samples, and follow standard procedures for recording field information, sample labeling, and sample shipment and packaging in accordance with SOP-1, SOP-3 and SOP-4, respectively or as outlined in the FSP.

•• •


• Decontaminate sampling equipment between each interval sampled in accordance with SOP-2 as required by the FSP. Decontaminate sampling equipment between sampling sites.

Backhoe or Hand Dug Excavations

This SOP does not include procedures for operating heavy equipment. Equipment operation will be subcontracted to a qualified third party that is properly trained. Additional information regarding goals and objectives of test pitting can be found in the SAP.

• Orient excavation to maximize use of the angle of the sun to illuminate the pit for photographs.

• Excavate to the prescribed depth. Place excavated material a sufficient distance from the excavation. Sampling personnel should never enter a pit excavated greater than three feet deep to collect samples, unless the pit is adequately shored and sloped in accordance with OSHA standards. Failure to follow this directive shall be grounds for dismissal from NewFields.

• Soil profile descriptions shall be made for ground surface and of the pit sidewall on standard field forms or in the test pit field log.

• Complete profile descriptions in accordance with USCS standard practices and take photographs before pit is sampled.

• Soil samples shall be collected from depth intervals specified in the SAP. Soil samples should be collected using the excavator bucket. When a depth interval is sampled, soil should be collected from the entire interval exposed on the pit wall by the excavating bucket. When the bucket is brought to the surface, soil samples should be collected from the bucket with a stainless steel trowel, collecting a representative sampling and using extra caution to avoid collecting soil that has touched any portion of the excavator bucket.

• Place soil in a stainless steel bowl and mix thoroughly (this should not be done when analyzing for volatile organics). Containerize mixed soil in appropriate sample containers samples, and follow standard procedures for recording field information, sample labeling, and sample shipment and packaging in accordance with SOP-1, SOP-3 and SOP-4, respectively.

• After sampling is completed, the pit should be backfilled with excavated material in the reverse order that it was excavated so that topsoil material is returned to the top of the pit. When backfilling is complete the area should be cleaned up to its original condition. No test pit should be left open overnight unless temporary fencing and appropriate signs and flagging tape is used to prevent access to the pit.

• Decontaminate the excavator bucket and all sampling equipment between sampling sites in accordance with SOP-2. Excavation equipment should be steam cleaned between sites with hot water after visible dirt and mud has been physically removed.

•• •

SOP-22 Management of Investigative-Derived Waste Page 1 of 2

SOP-22

MANAGEMENT OF INVESTIGATIVE-DERIVED WASTE

Prior to the field sampling event, review the Sampling and Analysis Plan to understand how wastes generated during the investigation should be handled. This standard operating procedure is applicable to non-hazardous wastes. If hazardous wastes may be generated, please consult with the project manager and the Field Sampling Plan (FSP).

SOIL

Whenever possible, soils excavated from test pits should be placed back in the test pit in the reverse order that it was excavated.

To determine appropriate methods for handing of drill cuttings from soil borings or monitoring well installation, soils exhumed from the borehole should be monitored for staining and field screened for VOCs using a PID in accordance with standard operating procedures. Based on the PID screening, cuttings with organic vapor concentrations greater than 100 ppm should be containerized in labeled 55-gallon drums (or roll-off containers if large volumes of cuttings are anticipated) pending further characterization. Alternatively, project personnel may elect to containerize all drill cuttings based on the presence of known contamination and anticipated contaminant concentrations. Containerized soil must be properly labeled, documented and disposed of in accordance with state and federal regulations based on of soil analytical results.

Soil that does not appear to be contaminated based on observations by field personnel and PID screening may be spread on the ground near the point of origin.

GROUNDWATER

Groundwater purged from a well during development or sampling that has a sheen or contains free product must be containerized in an appropriately labeled 55-gallon drums or tank pending receipt of analytical results. A drum should be dedicated to each well sampled so that the analytical results of the groundwater sample from the well can be used to characterize the water in the drum. If groundwater from several wells is placed in a drum, the water in the drum should be sampled for adequate characterization. The containerized water must be disposed of in accordance with state and federal regulations based on the analytical results. Groundwater that does not have a sheen or contain free product or other know contamination may be discharged to the ground surface in the vicinity of the well location for evaporation and infiltration. All surface discharge areas should not allow for migration of discharge water to a surface water body.

Purpose To outline the procedure for handling wastes generated during site investigation

Goal and Objective To employ a method for appropriate handling investigative-derived wastes that limits contamination of the environment

Equipment Needs PID

Field Forms and field book

DOT approved 55-gallon drums

Drum wrench

•• •

SOP-22 Management of Investigative-Derived Waste Page 2 of 2

RINSEATE WATER ORIGINATING FROM DECONTAMINATION

All source water for sampling equipment decontamination purposes will be distilled water. For larger equipment when power washing procedures are used for decontamination, potable water will be used. Decontamination will be conducted in a specified area that limits the spread of decontamination water. Decontamination water will be discharged to the ground in the vicinity of the source of dirt and mud to evaporate and infiltrate.

•• •

APPENDIX C Contaminated Soil Management Plan

Contaminated Soil Management Plan PCB-Impacted Soil in Operable Unit 2

Former Frenchtown Mill 14577 Pulp Mill Road Frenchtown, Montana

Prepared for:

M2Green Redevelopment, LLC 210 Market Street Alton, IL 62002 International Paper Company 6400 Poplar Avenue Memphis, TN 38197 WestRock CP, LLC P.O. Box 4098 Norcross, GA 30097

Prepared by:

NewFields Companies, LLC 700 SW Higgins Ave. Suite 108 Missoula, MT 59803

August 2017 Project 350.0065.000

•1NewFields

•• •

Former Frenchtown Mill Contaminated Soil Managment Plan August 2017

Page | i

TABLE OF CONTENTS

INTRODUCTION ................................................................................................................. 1 1.0

1.1 PURPOSE .......................................................................................................................................... 1

1.2 ROLES AND RESPONSIBILITIES .............................................................................................................. 1

1.3 SUMMARY OF PCB-IMPACTED SOIL PROPOSED FOR EXCAVATION .............................................................. 2

SOIL EXCAVATION AND DISPOSAL ..................................................................................... 3 2.0

2.1 RESPONSE ACTION PLANNING .............................................................................................................. 3

2.2 EXCAVATION AND DISPOSAL ................................................................................................................ 3

2.3 ONSITE DUST CONTROL ...................................................................................................................... 3

2.4 SPILL CONTINGENCY PLAN - TRANSPORT OF SOIL TO LANDFILL .................................................................. 4

LIST OF FIGURES

Figure 1 PCB Impacted Areas (OU2)

Figure 2 Transport Route to the Landfill

LIST OF TABLES

Table 1 Summary of Soil Sample Results by Depth - PCB Investigation (OU2)

•• •


Page | 1

INTRODUCTION 1.0

This Contaminated Soil Management Plan (CSMP) describes the methods that will be employed to safely remove Polychlorinated Biphenyl (PCB)-contaminated soil from Operable Unit 2 at the Former Frenchtown Mill (site, Figure 1) and disposed of the soil at the Republic, Inc. landfill in Missoula, Montana (Figure 2). The plan is intended to guide oversight personnel and excavation/hauling contractors on how to manage the contaminated soil to minimize impacts to health, safety, and the environment.

1.1 PURPOSE

The purpose of this CSMP is to:

Summarize the locations where PCB-impacted soil is designated for excavation within OU2 at the site;

Outline the roles and responsibilities for personnel involved in the soil response actions; and

Detail the proposed disposal methods for contaminated soil, including the appropriate control measures to minimize environmental and human health risks.

A copy of the approved CSMP will be kept on site during the soil excavation activities.

1.2 ROLES AND RESPONSIBILITIES

Individuals having key roles during the PCB-impacted soil excavation in OU2 are shown in Table 1-1.

Table 1-1: Key Personnel

Personnel Representing Primary Role Contact Information David Tooke NewFields Construction Manager (406) 240-8360 Wilhelm Welzenbach NewFields Field Supervisor (406) 529-2577 Sara Sparks EPA Regulatory Oversight (406) 491-4016 Larry Dears EPA Contractor Regulatory Oversight (406) 548-8396 Keith Large DEQ Regulatory Oversight (406) 444-6569

David Tooke, Project Coordinator for the Frenchtown Mill Project, will be the Construction Manager and will be responsible for implementation of the CSMP including training personnel in the required procedures, and coordination of work by contaminated site specialists. He will also be responsible for liaison with regulatory personnel at the Environmental Protection Agency (EPA) and Montana Department of Environmental Quality (DEQ).

•• •


Page | 2

Mr. Wilhelm Welzenbach will be the Field Supervisor, and will be responsible for implementation of the soil response actions consistent with this CSMP and the Health and Safety Plan (HASP). In this role, he will:

Ensure compliance with the HASP, including facilitation of safety meetings each day prior to beginning work;

Oversee the excavation activities, directing the contractor hired to excavate and haul contaminated soil to the landfill;

Advise on classification of excavated material for disposal;

Collect soil confirmation samples upon completion of soil excavation activities; and

Document all work activities in accordance with the EPA-approved Quality Assurance Project Plan (QAPP) dated November 2015, and Addendum 5 to the Remedial Investigation Work Plan dated August 2017.

1.3 SUMMARY OF PCB-IMPACTED SOIL PROPOSED FOR EXCAVATION

There are two areas in OU2 where PCB-impacted soil is proposed for excavation. These are referred to as the High Density Pulp Tank (HDPT) and the Transformer Storage Building (TSB) areas (Figure 1). Investigation in these areas identified PCBs in soil at elevated concentrations. In the HDPT area, only Aroclor 1260 was detected. In the TSB area, Aroclors 1254 and 1260 were detected.

Results for PCBs in soil of OU2 are summarized in Table 1. PCB concentrations in soil were above the residential direct-contact Regional Screening Levels (RSLs) in surface soil (0 to 2 feet below ground surface (bgs)) in samples SS18, SS19, HDPT38, and HDPT40 in the HDPT area, as well as surface soil samples SS28, TSB46, and TSB47 in the TSB area. Soil with elevated concentrations of PCBs is the target for the response actions. More details on excavation depths, site-specific cleanup levels, and confirmation sampling is presented in Addendum 5 to the Remedial Investigation Work Plan.

•• •


Page | 3

SOIL EXCAVATION AND DISPOSAL 2.0

2.1 RESPONSE ACTION PLANNING

All personnel involved in soil excavation and disposal will undergo a project awareness and health and safety training. Prior to beginning of field work, a pre-earthwork site meeting will be held and attended by personnel involved with the response actions to discuss the risks and site procedures for handling contaminated soil from point of generation to the Republic, Inc. landfill in Missoula, Montana.

2.2 EXCAVATION AND DISPOSAL

The Field Supervisor will oversee the excavation work and be responsible for site safety and defining which materials are clean and may remain on site, and which are contaminated and therefore require disposal offsite. Access to the excavation area shall be restricted to authorized personnel. Clean overburden soil, if any, will be stored on an impermeable concrete or asphalt surface pending use as backfill. Any overburden soil or imported soil used to backfill the excavation must be tested for polychlorinated biphenyls (PCBs), and shown to meet residential RSLs prior to use as backfill.

Soil to be hauled offsite will be loaded directly onto trucks, and will not be stockpiled. To prevent inadvertent contamination during transport of PCB-impacted soils, the wheels on each truck will be dry decontaminated in a designated area prior to leaving the site, and the excavator bucket will be dry decontaminated prior to movement away from each excavation area. If dry decontamination is not sufficient due to wet conditions or caking of material on the truck tires, a wet decontamination will be performed on the concrete slab for the Transformer Storage Building Foundation (Figure 1), which has a closed sump to collect decontamination water. To dispose of the water, it will be periodically pumped onto the soil in the truck and hauled to the landfill. This will be done in a manner whereby the soil is not liquefied and no water is discharged from the truck en route to the landfill.

All trucks leaving the site en route to the landfill will be tarped to prevent loss of soil during transport. The route trucks will follow to the Republic, Inc. Class II landfill in Missoula, Montana is shown in Figure 2.

2.3 ONSITE DUST CONTROL

Dust suppression will be implemented during the excavation work. Elements of the dust suppression shall include:

Reducing vehicle speeds to a maximum of 10 miles per hour;

Minimizing drop heights from loaders;

Orienting excavation and loading work so that no personnel will be located downwind; and

Wetting on-site haul roads and the excavation area, if needed.

NewFields personnel will monitor the work to ensure dust suppression activities are being implemented and visible dust is minimized in excavation areas or along onsite haul roads.

•• •


Page | 4

2.4 SPILL CONTINGENCY PLAN - TRANSPORT OF SOIL TO LANDFILL

This section outlines the steps to be taken, if there should be a release of contaminated soil during transport to the landfill. The risk of spill is low, and the following procedures will be followed to prevent vehicular accidents and spills of contaminated soil during transport to the landfill:

Use the route from the site to the landfill shown on Figure 2.

Use trucks that are maintained on a regular basis and are in good condition. Those having tailgates that are damaged such that soil may be released during transport will not be used. A visual inspection of each truck prior to it leaving the site will be conducted.

Ensure that the truck is decontaminated and tarped prior to leaving the site.

Maintain speeds at or below the speed limit at all times.

Have a cell phone or radio to contact appropriate personnel in the event of an accident and/or potential for release of soil to the environment during transport.

Restrict the use of cell phones (including texting) while driving.

Should soil be released during hauling, or there is a vehicle accident with the potential for a release of soil, the truck driver shall immediately contact 911 to report the accident. Following this call, the truck driver shall contact David Tooke, Construction Manager, at the phone number on Table 1-1. If for some reason he is not available, Chris Cerquone at NewFields shall be contacted at (406) 830-6102. One of these individuals will immediately notify the client and EPA of the incident, and respond to the incident. Upon arrival on the site of the accident, the following actions will be taken to prevent further release of contaminated soil:

The nearest storm drain, if any, will be sealed to ensure storm water that has or may come in contact with soil does not discharge into the drain. If there is no drain, straw bales, straw wattles, or other sediment control structures should be used to prevent release off of the roadway.

Soil will be removed from the incident site and disposed of at the Republic, Inc. landfill. If the contaminated soil was spilled on a paved surface, the paved surface shall be cleaned using a street sweeper and all collected material shall be disposed of at the landfill. If the contaminated soil has left the roadway, and/or rainwater potentially mobilized contaminants to soil on the shoulder of the road, approximately 0-6 inches of the soil in the spill area shall be removed and disposed of at the landfill. Should soil in the shoulder of the road be removed, confirmation sampling will be performed to verify that the remaining soil is not contaminated with PCBs.

The NewFields responder shall maintain contact with regulatory personnel during all response actions and document all actions taken to address the situation.

•• •

FIGURES

High Density PulpTank Foundation

Transformer StorageBuilding Foundation

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PCB Impacted Areas (OU2)Former Frenchtown Mill Site


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•1NewFields

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TABLES

SS18

-IN-(1

2)SS

19-IN

- (24

)

IN-H

DPT

38-S

B-1,

2,3,

4

IN-H

DPT

39-S

B-1,

2,4,

6

IN-H

DPT

40-S

B-1,

2,3,

4

IN-H

DPT

41-S

B-1,

4

IN-H

DPT

42-S

B-1,

2,4,

5

IN-H

DPT

43-S

B-1,

2,5,

6

SS28

-IN-(0

-2)c

SS29

-IN-(0

-2)c

SS30

-IN-(0

-2)c

SS31

-IN-(0

-2)c

IN-T

SB44

-SB-

1,2,

3

IN-T

SB45

-SB-

1,2,

3

IN-T

SB46

-SB-

1,2,

3

IN-T

SB47

-SB-

1,2,

3

IN-T

SB48

-SB-

1,2,

3

IN-T

SB49

-SB-

1,2,

3

IN-T

SB50

-SB-

1,2,

3

1

1440ND

7490 J 154 J 37.7 U 88.1 J

2

1740ND

3

4H H H H H

5172

6

7

8

9

10

Notes:

156 - Blue font; Aroclor 1254 concentration in µg/kg, if not shown, result is ND with reporting limig of 34.5 µg/kg ID - identification

1020 - Black font; Aroclor 1260 concentration in µg/kg J - Concentration is considered estimated.

H - Held, not analyzed ND - Not Detected

HDPT - High Density Pulp Tank QA/QC - Quality Assurance/Quality Control

TSB - Transformer Storage Building µg/kg - micrograms per kilogram, or parts per billion

Sample depths are based on professional judgment due to poor sample recovery in sampling sleeve. OU - Operable Unit

Sample locations are shown on Figure 3 (HDPT) and Figure 4 (TSB)

- initial soil samples collected in 2015 Bold

- soil samples collected in 2016 Underline

- not investigated ...... depth driven by sample sleeve ___ total depth of borehole

TABLE 1Summary of Soil Sample Results By Depth

PCB Investigation (OU2)Former Frenchtown Mill, Missoula County, Montana

SAMPLEID

High Density Pulp Tank (HDPT) Area Transformer Storage Building (TSB) Area

Soil Sample Soil Sample

SAM

PLIN

G D

EPTH

(f

eet)

70.7

747

125

50.3

Inside Ring

65.8

614

126

1020

17.1J

42.9

ND

2840

1470

Outside Ring

H

H

H

H

H

H

H

H

ND

H

66.7156

H

H

- exceeds the construction worker direct contact screening level of 990 µg/kg (Aroclor 1260) or 970 µg/kg (Aroclor 1254).- sample from 0 to 2 feet, and exceeds residential direct contact screening level of 240 µg/kg (Aroclor 1260) or 120 µg/kg (Aroclor 1254).

H H

15.2

14.8

ND893

H

H

H

H

-

-

-

-- -

-

APPENDIX D Field Forms

FIELD FORMS

# Description

1 Daily Field Record

2 Test Pit Field Form

7 Photo Log

8 Incident Report Form

9 Pace Analytical – Chain of Custody

11 Field Investigation Form

•• •

Page_____ of _____

Time in Time Out

Steel-toed boots

Safety Goggles Ear Protection

TIME

Hard Hat

Personnel: Name Company

DAILY FIELD RECORD

Location:

Project Name:

Project and Task Number: Date:

Field Activity:

Weather:

PERSONAL SAFETY CHECKLIST

Gloves

Traffic Vest

DESCRIPTION OF WORK PERFORMED

• • Newfields • Perspective. Vision. Solutions.

Page_____ of _____

TIME DESCRIPTION OF WORK PERFORMED

Date:____________________

DAILY FIELD RECORD • • Newfields • Perspective. Vision. Solutions.

Project: Project #:

Project Location: Date:

Equipment: Contractor: Logged by:

Lat/Long (N/E): Elevation: Total Pit Depth:

Shoring (if used): Surface Condtions: Backfilled:

(depth & type)

Small disturbed sampleLarge disturbed sampleThin-walled tube sample (vert / horz.)Block sampleIn-situ density testWater contentWater table encountered

Additional NotesProfile of face (refer to plan view of pit below): _______Profile Width = __________

Pit ID:D

epth Sample Pit Wall Profile

Description

Legend: Plan View of Pit: (include width, length, and North direction)SDLDSTBL

•: Newfields

- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -

----

Page_____ of _____

ID# TimeDirection of

View

1

Subject of Photograph

PHOTOGRAPH LOG

Location:

Project Name:

Project and Task Number: Date:

Field Activity:

• • Newfields • Perspective. Vision. Solutions.

INCIDENT REPORT Occupational Accident, Injury, or Illness

1. Employee Name:

2. Employee No.: 3. Office location:

4. Job title:

5. Home address:

6. Phone number:

7. Sex: M F 8. Date of birth:

9. Type of incident: Exposure Physical injury

10. Address where incident occurred (include county):

11. Date and time of incident:

12. Date incident was reported: _________ To whom:

13. What were you doing when injured? (Be specific identify tools, equipment, or materials you were using.)

14 How did the accident or exposure occur? (Describe events fully. Tell what happened and how it happened. Use additional sheets if needed.)

15. Object or substance that directly injured you:

16. Describe the injury or illness (e.g., cut, strain, fracture, skin rash):

D D D D

17. Part of body affected:

18. Did you receive medical care? Yes No If so, when? By whom? (Name and address of physician/paramedic/hospital.)

If hospitalized, name and address of hospital:

19. Did you lose time from work? Yes No If so, how much?

20. Have you returned to work? Yes No If so, date returned:

21 List anyone else affected by this incident.

22 List any witnesses to this incident.

Signature Date

D D

D D D D

CHAIN-OF-CUSTODY / Analytical Request DocumentThe Chain-of-Custody is a LEGAL DOCUMENT. All relevant fields must be completed accurately.

Section A Section B Section C Page: of Required Client Information: Required Project Information: Invoice Information:Company: Report To: Attention: REGULATORY AGENCYAddress: Copy To: Company Name:

Address:

Email To: Purchase Order No.: Pace Quote Reference: SITE Phone: Fax: Project Name: Pace Project Manager:

Requested Due Date/TAT: Project Number: Pace Profile #: Filtered (Y/N)

Section D Required Client Information Preservatives Requested

LOCATION

NPDES GROUND WATER DRINKING WATER

UST RCRA OTHER_________

Pace Project No. Lab I.D.

GA IL IN MI NC

OH SC WI OTHER_____

# O

F C

ON

TAIN

ER

S

ITEM

#

SA

MP

LE T

EM

P A

T C

OLL

EC

TIO

N

MA

TRIX

CO

DE

SA

MP

LE T

YP

E

G=G

RA

B C

=CO

MP

DRINKING WATER WATER WASTE WATER PRODUCT SOIL/SOLID OIL WIPE AIR OTHER TISSUE

SAMPLE ID One Character per box.

(A-Z, 0-9 / ,-) Sample IDs MUST BE UNIQUE

Valid Matrix Codes MATRIX CODE COLLECTED

DW WT WW P SL OL WP AR OT TS DATE TIME DATE TIME U

npre

serv

ed

H2S

O4

HN

O3

HC

I

NaO

H

Na 2

S2O

3

Met

hano

l

Oth

er

Analysis:

Resid

ual C

hlorin

e (Y

/N)

Pace Project No. Lab I.D.

# O

F C

ON

TAIN

ER

S

ITEM

#

SA

MP

LE T

EM

P A

T C

OLL

EC

TIO

N

MA

TRIX

CO

DE

SA

MP

LE T

YP

E

G=G

RA

B C

=CO

MP

DRINKING WATER WATER WASTE WATER PRODUCT SOIL/SOLID OIL WIPE AIR OTHER TISSUE

SAMPLE ID One Character per box.

(A-Z, 0-9 / ,-) Sample IDs MUST BE UNIQUE

1

2

3

4

5

6

7

8

9

10

11

12

Additional Comments: RELINQUISHED BY / AFFILIATION DATE TIME ACCEPTED BY / AFFILIATION DATE TIME SAMPLE CONDITIONS

Y/N

Y/N

Y/N

Y/N

Y/N

Y/N

Y/N

Y/N

Y/N

Y/N

Y/N

Y/N

SAMPLER NAME AND SIGNATUREPRINT Name of SAMPLER:

SIGNATURE of SAMPLER: DATE Signed (MM / DD / YY)

Rec

eive

d on

Ic

e

Tem

p in

°C

Cus

tody

S

eale

d C

oole

r

Sam

ples

In

tact

COMPOSITE START COMPOSITE END/GRAB

e-File(ALLQ020rev.3,31Mar05))22Jun2005

Project Name: Date:

Project Number: Investigation Date(s):

Project Address: Site Contact:

Project City: Client Contact:

EPA/DEQ Manager:

Yes No

Hours

Sampling Methods

Lab Pack

Laboratory

Shipping by:

Natural or QC Sample?

Number of Hours Approved for Sampling Effort (include all that apply)

# of Samples

Notes

Standard Operating Procedure

Task

ACM/LBP Inspection

Soils Investigation

Groundwater Sampling

Sample Locations

Field Investigation Form

SOP #

ContainersAnalytical Parameters Media

Project Manager: Site Investigator:

Other Instructions

Overall Reason For Investigation

Required Check Offs

SAP ReviewedUtility Locate Number

Owner NotifiedHealth & Safety Plan

Other

DEQ/EPA Approved SAP

Hold Time

Sample Location Map

Holding times work

PreservativeMethod #

=Newfields

work plan: addendum 5 to the remedial investigation work ... · the ground surface and pit bottom...

Documents