Shaw Environmental Infrastructure, Inc. EXCAVATION WORK PLAN CITY OF AUSTIN NORTH SERVICE CENTER 10414 PLACE AUSTIN, TEXAS Prepared for: . City Of Austin Department of Public Works 505 Barton Springs Road Austin, Texas Prepared by: Shaw Environmental, Inc. 8501 N. Mopac EXpressway, Suite 320 Austin, Texas 78759 November 2003 Table of Contents Page Table of Contents i List of Appendices ii Glossary of Terms 1.0 introduction 1 1.1 Site Background 1 1.2 Objectives 2 1.3 Schedule 3 1.4 Health and Safety 4 2.0 Pie-Mobilization Activities 4 3.0 Mobilization 5 3.1 Equipment and Personnel 5 3.2 Access and Security 6 3.3 Project Kick-off 6 4.0 Excavation Activities 6 4.1. Schedule 7 4.2 Pro-excavation Requirements 7 4.2.1 Underground Utility Locations 7 4.2.2 Subsurface Encumbrances and Vehicular Traffic 7 4.2.3 COA Notification 7 4.2.4 Excavation Site Set up 8 4.3 High Hazard Excavation 8 4.4 Trenching 10 5.0 Soil Sampling and Chemical Analysis 10 5.1 Soil Sample Collection 10 5.2 Chemical Analysis 11 6.0 Air Monitoring 11 7.0 Demobilization . 11 8.0 Field Documentation 12 9.0 Reporting 13 Shaw Environmentai. Inc. Page i List of Appendices Material Safety Data Sheets DHL Analytical Results Shaw Excavation Standard Operating Procedures 000329 Photographs and Descriptions of Peroxide Containers Shaw Environmental. Inc. Page ii BPO COA DMP EM GPR GSS HASP MEKP mg/kg MWM PPE Shaw 88/880 Surface Soil TCEQ Shaw Environmental. inc. Glossary of Terms benzoyl peroxide below ground surface Certified industrial Hygienist City of Austin dimethyl phtatate eiectromagnetios Ground penetrating radar GeoSurvey Systems Health and Safety Plan methyt ethyl ketone peroxide megahertz Milligram per kilogram Martinez, Wright and Mendez Personal protective equipment Quality Assurance/Quality Control Shaw Environmental, Inc. site supervisor! site safety officer The uppermost foot of soil as measured from ground level Texas Commission on Environmental Quality tert?buty perbenzoate Page 1 .0 introduction At the request of the City of Austin (COA) Department of Public Works, Shaw Environmental, inc. (Shaw) has prepared the following work plan for review and approval by the COA and the Texas Commission on Environmental Quality (TCEQ), to initiate excavation activities at portions of the COA North Service Center construction site (site). The primary purpose of the excavation will be to investigate subsurface anomalies identified during geophysical surveys currently being conducted by Shaw at the site. The work plan for the geophysical survey ?Noninvasive Subsurface Investigation Work Plan" was submitted and approved by the COA and the Texas Commission on Environmental Quality (T CEQ) on November 17, 2003. The entrance to the site is at 10715 Burnet Road in Austin Texas. The address of the future 24~acre North Service Center, formerly known as the Reichhold Chemical Company Plant, is 10414 McKalla Place. The GOA requested that Shaw develop this excavation work plan after an explosion occurred at the site on November 3, 2003 during excavation activities as a part of site underground utility construction. The geophysical survey currently being conducted at the site is the first step towards locating potential hazardous objects in the subsurface. The data acquired from the survey will be used to plan the excavation of the blast area and other areas that may contain unstable chemical compounds posing a potential threat to future construction activities. This work plan describes the use of special equipment and trained personnel to conduct excavation activities for the purpose of (1) determining the cause of the November 3, 2003 blast; (2) determining if subsurface anomalies located during the geophysical survey are buried containers or other materials; and (3) determining if the containers or other materials in the subsurface at the site pose a health and safety hazard to future construction activities. Included in the work plan are descriptions of the excavation methodologies to be used. In addition the COA may request that Shaw perform trenching for the installation of underground utilities for the facility currently under construction. The scope, locations and requirements to perform this I excavation work have not yet been determined. 1.1 Site Background The COA purchased the 24-acre site in 1995 and has been developing the site since 2001. On November 3, 2003. during trench excavation activities for the installation of a storm sewer line at the site, an explosion occurred injuring several workers from the pressure blast and resulting debris. The exact cause of the explosion has not yet been determined. However, after initial investigations led by the COA Fire Marshal, the working hypothesis is that during the excavation of the storm sewer line the bucket of the backhoe ruptured an unseen and unidentified buried container, located at a depth of approximately feet below ground surface (bgs). Shaw Environmental, Inc. Page 1 Prior to purchase by the GOA, the site was the location of the Reichhold Chemical Plant (Reichhold). The plant manufactured and handled several chemicals used to react with polyester resins made for boat and building products. These included methyl ethyl ketone peroxide (MEKP), benzoyl peroxide (8P0), tert- butyl perbenzoate and dimethyl phthalate (UMP). These chemicals are highly reactive and in some cases ?ammable, and can explode when subject to shock, vibration or friction (Appendix A). It is possible that a container holding these reactive chemicals in suf?cient quantity could have caused an explosion of the size and magnitude experienced on November 3, 2003. According to historical records of plant operations, the blast site was located within, or close to former wastewater treatment ponds used by Reichhold. information concerning the possibility of any additional buried hazardous materials has not been located, or is not readily available. An explosion occurred at the MEKP production facility in 1985. After the explosion, Reichhold determined it was no longer economically feasible to continue operations at the plant. That same year Reichhold began site closer activities, submitting a closure plan to the Texas Water Commission (TWO). the predecessor agency to the Texas Commission on Environmental Quality (T CEO). in 1995 the Texas Natural Resource Conservation Commission also a predecessor agency to the TCEQ, issued a letter of closure to Riechhold. On November 3, 2003 Shaw was contacted by the COA and requested to mobilize to the site to collect soil samples from the area of the blast site. On November 4, 2003 Shaw personnel collected three soil samples from the excavator bucket tooth, the bucket itself and from debris that had reportedly been thrown from the trench. In addition, two samples of resin that had reportedly been thrown from the trench were also collected. Shaw accepted custody of three soil samples collected by COA personnel on November 3, 2003 from the excavator tooth, the bucket and from debris found in the trench. All samples were submitted to DHL Analytical Laboratory in Round Rock, Texas for rush analysis. The laboratory analytical report is included in Appendix B. A review of the results by Shaw and GOA chemists indicated that degradation products of MEKP. BOP or were present in the soil. The chemical evidence supported the hypothesis that one of the chemicals produced by Reichhold, probably unstable peroxide, was encountered in a container of some type in sufficient quantity to cause the explosion. 1.2 Objectives The COA Investigation Team has requested that Shaw develop an approach to investigating the blast site and other subsurface areas where additional excavations are required to complete the planned site improvements. Shaw has met on several occasions with the COA investigative Team to discuss approaches to investigating the subsurface for potential unstable compounds. As a result of these Shaw Environmental, inc. Page 2 meetings and a review of data collected after the explosion, Shaw proposed a noninvasive subsurface investigation that uses electromagnetic (EM) and Ground Penetrating Radar (GPR) geophysical techniques to possibly identify buried materials or containers within the planned excavation areas. Once the geophysical surveys are completed and the results reviewed by Shaw geophysicists. Shaw and it's subcontractors will identify the locations of potential subsurface anomalies in relation to utilities planned for the site development. Shaw will confer with the GOA Investigation Team to decide which areas are to be further investigated (in addition to the area of the November 3. 2003 blast site). These areas will be excavated to the depth of the suspected anomaly using specially trained personal with explosion protective equipment and gear to identify the anomaly and assess if it poses a health and safety hazard to future construction activities. Shaw will confer with the GOA on what additional actions required. Soil and material samples may be collected based on field observations or at the request of the COA. A second excavation objective is for Shaw to ore-trench the remaining utility trenches on the site using the specially trained personnel with explosion protective equipment and gear. The decision to retain Shaw to perform this work will be will be made by the GOA. Prior to commencing pro?trenching activities, Shaw ill require that additional information will be made available, including but not limited to the location of the utility trenches to be excavated marked by construction staking, and the required widths and depths of the excavation. 1.3 Schedule Shaw is currently scheduled to mobilize the necessary heavy equipment and trained personnel to the site on November 21, 2003. Excavation of the area around the blast site is scheduled for the weekend days of November 22 and 23, 2003. Demobilization from the site is scheduled for November 24, 2003. The schedule for additional mobilizations and work has yet to be finalized, however the COA has determined that additional work in areas where the potential for explosions exist will take place on weekends to minimize any impact to adjacent businesses. Excavations of utility trenches away from the identified anomalies could be performed on weekdays, with the concurrence of the GOA. The Shaw Site Supervisor/Site Safety Of?cer (SSISSO) Mike Wells, will coordinate work progress in the field under the direction of Shaw Project Manager John Barry, PE. Shaw will submit daily summaries of the excavation activities and updates to the designated GOA representatives. The GOA and Shaw will review and discuss the daily summaries and based upon these results determine additional actions to be taken. Shaw Environmental, Inc. Page 3 1.4 Heath and Safety Plan David Mummert, CH of Shaw?s Health and Safety Emergency Response Group, prepared the "Site Specific Health and SafEty Plan" which includes activities described in this work plan. Mike Wells, the Shaw Site Supervisor coordinating the excavation activities, will be responsible for implementing the HASP. A copy of the was provided to the BOA for review on November 17, 2003. 2.0 Pre-Mobilization Activities Shaw has completed or is currently conducting several activities associated with identifying potentially hazardous conditions and conflicts with planned site construction. These include: Historical research of plant activities in order to determine the likely nature and locations of potentially hazardous containers; Coordination with the GOA investigation Team and site construction contractors to determine the location of planned utility installations; Establishing control points and a base line grid to locate subsurface anomalies and planned utility excavations in the field; Conducting a geophysical survey of the blast site. the former waste water ponds 1A, 18, 2 and 3, the route of the proposed 54-inch diameter re-enforced concrete pipe (RCP) storm sewer line that was under excavation when the blast occurred, and any additional areas that may be designated for subsurface investigation; and Meetings with the COA investigation Team to plan the scope and course of the investigation. When the geophysical survey of the areas described above has been complete and the results reviewed. Shaw will present and review these results and the location of subsurface anomalies with the COA investigation Team. Anomalies lecated by the geophysical survey will be located on a site map and reviewed with the GOA representatives to determine which locations to excavate. Based on this review the extent of the areas to be excavated will be determined. All locations to be excavated will be approved by the COA. The criteria for determining if an area is to be excavated includes, but is not limited to: Likelihood that the identified anomaly is buried container (Class I, II or ill anomaly?see ?Noninvasive Subsurface Investigative Work Plan") Shaw Environmental, inc. Page 4 Location of identified anomaly is within an area of planned excavation Location of identified anomaly is within an area that may contain potentially hazardous container (former ponds, drum storage area, etc) Other criteria determined by COA and Shaw. The excavation depths will be determined based upon the results of the geophysical survey. The excavation of anomalies that are located at depths greater than the planned construction excavation will be performed at the discretion of the COA. 3.0 Mobilization Mobilization activities are scheduled to begin Friday November 21, 2003. Mobilization and site preparation will consist of transporting the necessary trained personnel and equipment to the site. Shaw equipment will be mobilized from the nearest operations centers, as well as from local rental companies. Delivery of equipment to the site will be by Shaw-owned transport, subcontracted transport, or by rental company transport. Subcontract services will be mobilized to the site in accordance with the project schedule. Materials and project supplies will be delivered to the project as needed so that the progress of the work is not interrupted. Materials staged at the site will be staged and stored on pallets, blocking, or other means to isolate and protect the materials from the elements by covering with polyethylene sheeting. All fuels, oils and chemicals will be stored in spill-controlled areas in compliance with applicable regulations. As necessary, materials and supplies on-site will have a Material Safety Data Sheet at the project field of?ce. 3.1 Equipment and Personnel Major equipment to be mobilized will include a PC 200 excavator equipped with a Lawn? blast shield, and supplied air bottle rack, a frame mounted mobile LexanTM blast shield for the spotter, Level personnel protective equipment (PPE) and necessary support equipment, ?ame resistant clothing, a pollution control truck, radio communicators, a crew pick?up truck, Combustion Gas Indicator photo ionization detector real time respirable dust monitors (PRAM) and other personnel monitoring equipment, perimeter air monitoring equipment, remote thermal sensor, and video camera. Temporary fencing, barricades, or barrier tape around the excavation area will be installed as required by the HASP. The excavation team consists of four Shaw personnel: Shaw Environmental. inc. Page 5 The Site Supervisor/Site Safety Officer to oversee ?eld operations, implement the coordinate operations with on?site GOA and other personnel. The Shaw Certified Industrial Hygienist (CIH) will conduct health and safety monitoring, supervise the use proper and effective use of the PPE and health and safety equipment, coordinate with SSISSO in the implementation of the The Equipment Operator (operator) will be responsible for the operating the excavator and coordinating the excavation with the SSISSO. The Excavation Spotter (spotter) will be responsible for working with the operator, observing the excavation, reporting the presence of containers or materials uncovered by the excavation and additional duties as determined by the 3.2 Access and Security Access to the site will be controlled by the COA and the COA construction contractor. Currently the site perimeter is fenced. During daylight hours, access to the site is controlled by the GOA construction contractor. After hours, the site is locked and patrolled by the Austin Police Department. Personnel who will enter the excavation area will be required to read and sign the and attend a site?speci?c health and safety orientation meeting. The limits and extent of the excavation area will be determined in the field by the Shaw CIH and marked by Shaw personnel. 33 Project Kick-off A project kickoff meeting will be held to review this work plan, the the results of the geophysical Survey, and the project organizational structure and responsibilities. Attendees at the kickoff meeting will include the Shaw Project Manager, the Shaw Site Supervisor, Shaw excavation crew and the appropriate GOA Representativeis), including emergency service personnel. The will be on-slte throughout the excavation activities and will organize, plan, and execute the day~to-day field activities. All major activities will be coordinated with the Shaw Project Manager and COA Representative. 4.0 Excavation Activities The COA has requested that Shaw prepare a work plan to excavate the locations of anomalies under high hazard conditions. This consists of the excavation of known or suspected potentially hazardous containers in the subsurface as identified by the geophysical survey or other methods. Excavation under these conditions will require the implementation of additional procedures and safety precautions- Shaw Environmental, Inc. Page 6 In addition the GOA may request that Shaw conduct trenching operations of planned underground utility routes through areas that may pose a risk, but where potentially hazardous containers in the subsurface have not been specificaliy identified or located. This trenching will require the use of speciai equipment, personnel and precautions similar to excavations performed under high hazard conditions. The scope schedule and specifications required to perform pro?trenching work will be determined by the COA and Shaw. 4.1 Schedule The schedule for ali excavation activities will be approved by the COA Investigation Team prior to implementation. Excavation is scheduled for the blast area, beginning Saturday November 22, 2003. All other excavation activities that take place under the high hazard conditions are currently limited to weekends and during daylight hours. 4.2 Pro excavation Requirements 4.2.1 Underground Utilities Shaw will contact the COA Construction inspector and the COA construction contractor and advise them of the location and estimated depth of the proposed work, and request that the location of existing underground utilities be delineated. Prior to opening an excavation, the estimated location of underground utilities such as sewer, telephone, fuel, electric, water, or any other underground installation that may be reasonably expected to be encountered during the excavation work shall be determined. Employees should be careful to protect and preserve the utility markings until they are no longer required for excavation. At least 20 feet of clearance between any underground utility and the cutting edge or point of powered excavation equipment will be maintained until the precise location of the utility is determined. wu?ace Encumbrance and Vehicular Traffic All surface encumbrances (trees, poles, bouiders, etc.) that may create a hazard to employees shall be removed or supported. Since access to the site will be controlled, hazards from vehicular traffic be minimal. Shaw personnel exposed to vehicular traf?c shall be provided with, and shall wear, warning vests or other suitable garments marked with or made of reflective or high~visibility material. 4.2.3 COA Notification Prior to commencing excavation activities Shaw will notify the AFD Fire Marshal and the GOA Contract Representative of the location, start time and estimated duration of excavation activities. During the excavation of the blast site scheduled for November 22, 2003, Shaw has requested that AFD, GOA Bomb Squad and EMT be on site and standing by. Shaw Environmentai. inc. Page 7 4.2.4 EXcavation Site Set up. Prior to beginning excavation, the removal action work zones will be established. A work buffer zone will be established in a 100-yard area around the excavation and an exclusion zone will be established in a 50?yard area around the excavation as per the requirements the if chemical contamination is suspected or found, a contaminant reduction and support zone will established within the work buffer zone but outside of the exclusion zone, as per the requirements of the Shaw personnel will de?ne the excavation limits using plastic construction fencing, barricades, barrier tape, marker paint and/or warning signs as required by the All temporary fences and barricades will be removed after the site has been back?lled or work has been completed. Per the request of the BOA, a ?blast berm" will be constructed around the perimeter of the trench at the blast site. This berm will be constructed of existing spoils from previous trenching operations. The edge of the berm will be set back 2H3 feet from the edge of'the trench and built up as high as practicable without causing sloughing of spoils into the trench, interfering with the operation of the excavator and the line of sight of the spotter. In addition, the outfall of the 54-inch RCP pipe at the detention pond will be plugged with excavated spoils to absorb any shock waves from a potential explosion that would enter the pipe. Equipment set up includes placement of real time respirable dust monitors on the excavation site perimeter, placement of video camera equipment and placement of blast shield for the spotter. The operator and the spotter will be briefed on the nature, size and construction of peroxide containers (Appendix D). 4.3 High Hazard Excavation The method of excavation is intended to provide the maximum protection to site workers, while enabling the team to optimize operational effectiveness and ef?ciency. The method of excavation was developed based upon information obtained from historical and operation records and site observation. With the exception of the operator and the spotter, all personnel will be removed from the exclusion zone once the excavation begins. Under normal conditions, the spotter will remain outside the exclusidn zone, but dressed in PPE necessary to enter and work in the exclusion zone if required. The Shaw Cit-l and SSISSO will remain in the work buffer zone to observe excavation activities activities. All other personnel will remain outside the work buffer zone during excavation activities until work has halted and the all clear is given by the Shaw CIH and 831880. All Shaw personnel will be in communication with each other by portable radio. Shaw Environmental. inc. Page 8 Upon notice to proceed, Shaw will initiate soil excavation and stockpiling from the excavation using the PC 2000 hydraulic excavator. The excavator cab will be outfitted with a specialized clear lexan blast protective shield, customized to protect the glass windshield and prevent injury to the operator. A similar blast shield will be set up for the spotter located approximately 20 to 30 feet back from the excavation. The exact location of the spotter blast shield will be determined by the Cit-i as necessitated by ?eld conditions. Both the spotter and the Operator will be in Level Supplied Air Respirators and PPE as required by the This is necessary during the excavation in the event a sudden rapid chemical reaction. This chemical reaction could occur from one of the following friction. sunlight, oxygen, introduction of vibration. When practical, the operator will maintain a clear line of sight with the excavation location. When the operator does not have a clear line of sight, the spotter will enter the exclusion zone and visually inspect excavation areas from behind the blast shield as frequently as needed to identify potential hazards. Spotters will visually inspect the content and consistency of the soil removed to verify the presence of potentially hazardous containers (if any). During these inspections, the operator will remove the bucket from the ditch, throttle down the equipment, and remove his hands from the controls in order to protect ground personnel while they traverse around the excavation. The operator will remove the soil from the excavation area in ?l-foot lifts, setting soils to one?side of the excavation. When a potentially hazardous container is uncovered, the operator will cease excavation, remove the excavator bucket from the hole and notify the Once excavation is halted and a period of 5 minutes or more has elapsed, the potential of a rapid chemical reaction is reduced. The area will be checked by the Shaw CIH with real time air monitoring equipment and the remote thermal senor, After the Shaw CIH has determined that it is safe to approach, the 881880 will visually inspect the container from behind the blast shield. If it is determined that the container is a potential hazard, the excavation will be halted and the Austin Fire Marshal and GOA Representative will be notified. Shaw and the GOA representative will confer on the appropriate course of action when each container is discovered. If it is determined that a container can be removed from the excavation and the Shaw CIH have cleared the area, a sample of the soil from around the container will be collected at the GOA representatives discretion, using the bucket of the excavator. The location and depth of the soil from which the container was removed will be surveyed. If the container is determined to be non-hazardous (empty, already disturbed container) or identified as a non hazardous object (pipe, construction debris) the object will be segregated from previously excavated soils and set aside on plastic sheeting for further inspection. At the discretion of the Shaw 88/880 and Shaw Environmental, inc. Page 9 approval by the soil samples may be collected. if approved by the COA representative, the samples will be submitted for laboratory analysis. After excavation has been completed, any necessary samples have been collected and the area has been surveyed, the excavation will be back?lled using the previously excavated spoils. it for any reason it is deemed necessary to leave an excavation open, Shaw personnel will de?ne the excavation limits plastic construction fencing, barricades, barrier tape or marker paint required by the HASP. All temporary fences and barricades will be removed after the site has been back?lled or work has been completed. 4.4 Trenching The equipment, personnel and methods required to trench the planned underground utility routes will be similar to those used under high hazard excavations conditions. The determination of if trenching be performed under high hazard conditions and any modifications to the level of PPE required for those operations will be evaluated by the Shaw (NH and 881580. At a minimum blast shields and explosion protective clothing will be used by the spotter and operator, as per the requirements of the The location, widths, depths and specifications of the trenches will be provided to Shaw by COA representatives. if during the trenching, a potentially hazardous container is identi?ed, excavation activities will cease and the procedures for addressing the container described in Section 4.3 of this work plan will be implemented. 5.0 Soil Sampling and Chemical Analysis 5.1 Soil Sample Collection At the discretion of the GOA, soil samples from excavated areas will be collected using the excavator bucket. After the bucket has been removed from the excavated area by the operator, discrete soil samples may be collected with a disposable, or decontaminated spades, trowels. scoop, or other sampling equipment as necessary. Field personnel will wear disposable latex or nitrite gloves during the handling of all sampling equipment and during sampling. Sampling equipment will not be placed directly on the ground or other potentially contaminated surface prior to sampling activities. Samples will be adequately marked for identification and placed on ice in coolers for deiivery to the analytical laboratory. Evidence of collection, shipment, laboratory receipt, and laboratory custody until disposal will documented through Chain-of?Custody forms that list each sample and the individuals performing the sample collection, shipment, and receipt. Each individual who has the sample(s) in their possession will sign the chain of custody. Shaw Environmental, inc. Page 10 5.2 Chemical Analysis At the direction of the COA, soil samples will be analyzed using methods outlined EPA SW-346 for volatile organic compounds (VOCs) (Method 82608), semivolatile organic compounds (SVOCs) (Method 82700), nitrate (Method 9056), pH (Method 90450), and ignitability (Method 1010). Tentatively identi?ed compounds (Tle) will also be reported for samples analyzed for VOCs and SVOCs. DHL Analytical Laboratory (DHL) located in Round Rock, Texas, will perform sample analysis. 6.0 Air Monitoring Air monitoring will be conducted to characterize personnel exposures and fugitive emissions from site contaminants. The principal contaminants of concern are methyl ethyl ketone peroxides (MEKP), benzoyl peroxides (BPO), tert-butyl perbenzoate (His?) and dimethyl phthalate (Dlle). The results of previous investigations and soil sampling indicate it is unlikely there are chemical contaminants in sufficient concentrations to present a hazard to workers inside the exclusion zone or to observers outside the exclusion zone. The use of Level respiratory protection and real time air monitoring is a precaution in case of explosive conditions. Work area air monitoring at the North Austin Service Center site will be by direct reading methods. A lower explosiveioxygen meter and a photoionization detector will be used to survey excavated soil and debris. A total of tour particulate meters (Data RAMs) will used at the site. Two Data RAMs will be placed at the perimeter of the buffer zone in the down?wind locations, one will be placed up~wind and one will be used by the to monitor work activities. The will be reaponsibie for placement of air monitoring equipment and maintaining ?eld logs of the results. Air monitoring results will be used to determine the effectiveness and/or need for dust control methods and to trigger action levels as specified in Calibration and maintenance of air monitoring equipment will follow manufacture specifications and documented. Re-calibration and adjustment of air monitoring equipment will be completed when site conditions and equipment operation reveal the need. 7.0 Demobilization Upon completion of the excavation activities, Shaw equipment and Emergency Response personnel will be removed. if an excavation area is required to be left open, the temporary fencing will be left up. Efforts will be made to remove loose soil and other potentially contaminated materials from the wheels and undercarriage of the vehicles. A site walk will be conducted by the Shaw 38/8 and the COA representative to determine the need for final site cleanup activities. if any. Upon approval of the COA Representative, all site equipment and personnel will be demobilized. Shaw Environmental, lnc. Page 11 8.0 Field Documentation To provide evidence of satisfactory work performance and the basis for subsequent activities. results of the field investigation and sampling will be completely documented. information will be recorded on standardized forms in indelible ink. Documentation will include a Field Activity Daily Log (FADL), sample collection data forms, field instrument calibration records, and chain of custody forms. The Shaw 88/880 and CIH working in the field will each keep a FADL. Each page of the FADL will be signed and dated by the person preparing the form. items to be included, as appropriate, will be: Date of activities - Field activity subject - General work activity Unusual events - Changes to plans and speci?cations . Visitors - Communication with TCEQ, Municipal, County or State, or other personnel - Weather conditions - Personnel on~site. Field logs will be collected and maintained by the Field Supervisor until completion of the field work. or until they are submitted to the project central tile. Visual documentation of excavation activities in the blast area will be collected using a tripod?mounted video camera set up in the area of the excavation. The camera will be turned on prior to commencing excavation activities and set to the record mode. The camera will be pointed at the excavation and allowed to record remotely during high hazard excavation activities. When excavating in other areas with potential hazardous containers in the subsurface, the spotter will record footage of any containers located during the excavation after the CIH has determined that it safe to approach the excavation. A video log containing dateitime/duration and subject of the footage collected will be kept and copies of the tapes will be submitted to the COA with the final report, if required. Shaw Environmental. inc. Page 12 Photographic evidence of any containers located during the excavation will be collected using a digital camera, once the Shaw Cit-i has determine the excavation is safe to approach. Photographic logs including shot number, direction of View, description of subject, time, date, and photographer name will be kept. 9.0 Reporting A report will be prepared that presents the ?ndings of the excavation activities. The report will include discussions of the technical methods and field procedures used to conduct the excavation activities, data evaluation, interpreted results, site photographs, analytical results, a site map locating the areas of excavation, and conclusions and recommendations. A final report (5?copies) will be submitted to the GOA. Shaw Environmental, inc. Page 13 APPENDIX A Material Safety Data Sheets APPENDIX DHL Analytical Results APPENDIX Shaw Excavation Standard Operating Procedures APPENDIX Photographs and Descriptions of Peroxide Containers Form ANALYTICAL REPORT Page 1 of 2 Part 1 of 1 09210414203312RX pf SEP 2 ?i 2304 Date Laboratory Group Account No. 07003 Shaw Environmental Attention: John Barry 8501 North Mopac Expressway 9 Austln, TX 7875 FAX Telephone (5lle9232353 E?mail Sampling Callaction and Shipment Sampling Site EDA NSC Date of Collection Sapxemhanml?mu2?0&w Date Samples Received at Laboratory 16, 200& Analysis Me Lllod UE 5009 DateCS) of AnalysiSSeptember 20, 2004 September 21, 2004 Analytical Results Field Laboratory ample Sample Number Typa Number aazay; Peroxide g/sample enzoic acid g/sample 2111 04127925 2114 04I27925 12119 04127927 2124 04127928 ha mm :30 a 0 1.1. 2125 caravans 2130 04127930 sporting Limit See comment on last page. Paramater not detected above LDD. NR Parameter not requestad. NA Parameter not applicablen See comment on last page. Pa eta: batwaa Lou and LDQ. M?yg?: Vy 20111 Reu??wa?4 Gamrge Motock 960 West LeVoy Drive Salt Lake City, Utah 84123-2547 Phona (801% 266~7700 Web Page: FAX (801) 68?9992 E?mail: lab@datachem?com Form DATAMH ANALYTICAL REPORT Page 2 of 2 0921041420381an :5 23:352.: SEP 2 1 2004 Date Laboratory Group General Set Comments Method Reference: NIOSH Manual of Analytical Methods (NMAM), 4th ed., 8/15/94. The reported results have not been blank corrected. LDDS for samples 04127925 and 04127926: 20 ug/sample for benzoyl peroxide and 10 ugfsample for benzoic acid. LOD for samples 0412792? and 04I27930: 10 ug/sample for benzoyl peroxide. Sample Comments Laboratory Number Comment 04127925 Diluted 20X for both analytes. See set comments for LODS. 04127926 Diluted 203 for both analytes. See set comments for LODS. 0412792? Diluted 10X for benzoyl peroxide. See set comments for LCD. 04127930 Diluted 10X for benzoyl peroxide. See set comments for LCD. General Lab Comments The results provided in this report relate only to the items tested. This page is the concluding page of the report. 960 West LeVoy Drive Salt Lake City, Utah 84123~2547 Phone (801) 256w?700 Web Page: FAX (801) 268F9992 Eumail: labddataohem.oom ANALYTECAL REQUEST FORM OCH. 2Q (19 OK HUSH Status Requested ADDITIONAL CBARGE nesuus aaoumao 3v LABORATORIES, INC. EM we DATACHEM LABS PRTOH TO SENSING SAMPLES 2. Dale Purchase Order No. 4? Guoie No. 3 Company Name 31"? 1? Hm '9 fr)l DBL Project Manager Pd ?Ht: Address Esfi) {Vlnr our. 341: ?ah-a W71 5. Sample Collection Auav . 3 I i Site LC) 1* '3 a; Person to Contact :Ydl?h? Rwrm. j?l'dt? Industrial Process Telephone (5313}. {3?25} - 1 l9 CB 17 Date of Collection 9/lc3: Fax Telephone 6533. 9 229) (30.77 3 Ll 8600 Time Collected 3: ?9 7 f) Email Lil?s-?n . ?lms-n Jr: rm . .(Dm Dale of Shipment S?j?b .- . . 5 Billing Address (if different from above) Li. mo ill 102?: of Custody No. in?: 3. REQUEST FOR ANALYSES Cllonl Number Mulrix? Sample Volume ANALYSES REQUESTED Use malhod number 1! known Unit-s? L, - Specify: Solid sorbantlube.eg Charcoal: Filletlyp :impinger solution; Bulk sample; Blood: Urine; Tissue: Soil; Water; Other 1. ugfsamplo 2 mgfma 3 4 5. (olher) Pleaseindicaie one or more units in me column entitled Units? Comments Possible Contamination and/or Chemical Hazards altar-?n? astral??La: [Swan-r mic: La 3 7. Chain of Custody {Optional} Hellnqulshed be Dalel??me 0? S- 3?1 Received I va/f Dalefl?ime adg MDaieinme 59?15 ~ng 153.3 *1 5? ?w Relinqulshod by 1 I Received by I [275% Dalemme 6 If 'p . I HellnqulShEd by 1 g" Received by Daiemme 960 West LeVoy Drive 1' Salt Lake City, UT 84123 or I FAX: 801-258-9992 DATACHEM LABORATORIES,