5251NorthgateCompleteHASP10132015

Site-Specific Health and
Safety Plan for Earthwork,

Excavation and other Field
Activities
Northgate Marketplace
Corner of Central Avenue

and McAndrews Road 97501
Prepared for:
Regency Centers, L.P.
Prepared by:
Stantec Consulting Services Inc.
9400 SW Barnes Road, Suite 200
Portland, OR 97225
October 13, 2015

SITE-SPECIFIC HEALTH AND SAFETY PLAN FOR EARTHWORK, EXCAVATION AND OTHER
FIELD ACTIVITIES
Purpose and Approval

Our work can be hazardous, and it is imperative that we never forget that! It is the purpose of this
Health and Safety Plan (HASP) to proactively aid Stantec employees in:
 Identifying and understanding the risks/hazards they are likely to encounter at the site.
 Mitigating those risks/hazards.
Stantec’s policy is to complete our work on this site without any type of incident (injury, illness,
impact to the environment, impact to property and equipment). In order to achieve this goal,
the project team will work together to perform an effective hazard assessment. The team will
then establish appropriate precautions and communicate these daily among project staff. Staff
will be responsible for communicating changing field conditions to the project management so
these conditions and appropriate precautions may be re-evaluated as needed. Staff will
implement STOP WORK AUTHORITY at any time they believe that conditions may be inherently
unsafe or might cause damage to property or harm to the environment. Staff may refuse to
participate in work they believe will be unsafe. If such conditions exist, staff will communicate
immediately with the Project Manager to resolve the situation. We expect all subcontractors
and project personnel to share this goal.
Client: Regency Centers, L.P. Site Name: Northgate Marketplace
Project Name: Northgate Marketplace Project Number: 185750185
Start Date: October 19, 2015 End Date: October 19, 2016
Plan Review Date: April 19, 2016
(Last day of expected fieldwork or no longer than 6 months).
Patrick Vaughan______
Signature: Date:
Stantec Project Manager
Marc Sauze___________
Signature: Date:
Stantec Northwest OE
Coordinator
Robert McAlister_______
Signature: Date:
Stantec Site Health and
Safety Officer
Robert McAlister_______
Stantec Office Safety Signature: Date:
and Environment
Coordinator
Emily Harper___________ Signature: Date:

Stantec Peer Reviewer
The health and safety guidelines in this HASP were prepared exclusively for this site. This HASP will
be amended (with changes recorded on the Health and Safety Plan Modification Log) if site
conditions, scope of work, training dates, personnel, or other critical items change before the
scheduled HASP review date above. This HASP is intended to be used in conjunction with the
Stantec Field Binder, which will be available on site. Contents of this binder are listed in
Attachment 1.
i
FIELD ACTIVITIES
Acknowledgement and Agreement Form

“Zero Tolerance for Incidents of ANY Kind.
Work Together to Ensure A SAFE and High Quality Project”
This HASP has been developed for the purpose of proactively aiding Stantec employees in identifying,
understanding, and mitigating the risks/hazards they are likely to encounter at the site. This HASP may also
be used as a guidance document by properly trained and experienced Stantec subcontractors and
clients; Stantec is readily available to assist subcontractors in identifying and addressing their employees’
risks; however, sub-contractors and other contractors at the site must develop their own HASP to address
the hazards faced by their own employees.
All parties are required to review Attachment 2, Preventing Serious Injury & Fatalities Field Guide prior to
commencing work. All parties conducting site activities are required to coordinate their activities and
practices with the Stantec Site Health and Safety Officer (SHSO). Stantec has provided a copy of this HASP
to contractors in the interest of full disclosure of hazards of which we may be aware and to satisfy Stantec's
responsibilities under the Occupational Safety and Health Administration (OSHA) Hazard Communication
standard. Similarly, contractors are required to inform Stantec of any hazards of which they are aware or
that the contractor's work on site might possibly pose to Stantec employees including (but not limited to)
the Material Safety Data Sheets for chemicals the contractor may bring on site. This HASP should NOT be
understood by contractors to provide information on all of the hazards to which a contractor's employees
may be exposed as a result of their work. Stantec claims no responsibility for use of this HASP by others for
purposes unrelated to this project.
Your signature below confirms the following: you have read and understand the hazards and associated
mitigation measures discussed in this HASP; you have received training and medical surveillance according
to this HASP and the OSHA Standard on Hazardous Waste Operations and Emergency Response (29 CFR
1910.120), as applicable; you understand that sub-contractors and contractors must develop their own
HASP for their employees; and you understand that you could be prohibited by the SHSO or other Stantec
personnel from working on this project for not complying with any aspect of this HASP.
(All Stantec and subcontractor personnel must sign.)

Name Signature Company Date
ii
FIELD ACTIVITIES
Table of Contents
1.0 EMERGENCY RESPONSE................................................................................................ 1
1.1 PHONE NUMBERS .............................................................................................................. 1
1.2 DIRECTIONS AND MAP TO THE HOSPITAL ....................................................................... 3
1.3 DIRECTIONS AND MAP TO OCCUPATIONAL CLINIC .................................................... 4
1.4 EMERGENCY RESPONSE PROCEDURES: EVACUATION................................................. 5
1.5 EMERGENCY RESPONSE PROCEDURES: INJURY OR ILLNESS ........................................ 6
1.5.1 Injuries or Illnesses Requiring Hospital Service WITHOUT
Ambulance Service........................................................................................ 6
1.5.2 Injuries or Illnesses Requiring Hospital Service WITH Ambulance
Service.............................................................................................................. 7
1.5.3 Death of an Individual or Hospitalization of Three or More
Employees ....................................................................................................... 7
1.6 EMERGENCY RESPONSE PROCEDURES: SPILLS OR CUT LINES...................................... 8
1.7 INCIDENT REPORTING PROCEDURES .............................................................................. 9
2.0 SCOPE OF WORK......................................................................................................... 11
3.0 SITE BACKGROUND AND CHEMICAL HAZARDS ........................................................ 12
4.0 POTENTIAL AIRBORNE CONCERNS AND AIR MONITORING ACTION LEVELS ........... 14
5.0 OTHER SITE HAZARDS .................................................................................................. 19

5.1 PHYSICAL HAZARDS ........................................................................................................ 19
5.2 WEATHER AND NATURAL DISASTERS ............................................................................. 19
5.3 BIOLOGICAL HAZARDS................................................................................................... 23
6.0 SITE CONTROL AND SAFETY PROCEDURES ................................................................. 25
7.0 WASTE MANAGEMENT ................................................................................................ 31
8.0 PROJECT TEAM INFORMATION ................................................................................... 32

8.1 TRAINING.......................................................................................................................... 32
8.2 ORGANIZATION AND RESPONSIBILITIES ........................................................................ 33
ATTACHMENTS
Attachment 1 Stantec Field Safety Reference Binder Checklist

Attachment 2 Preventing Serious Injury & Fatalities Field Guide
Attachment 3 Personal Protective Equipment Assessment
Attachment 4 Job Safety Analyses
Attachment 5 Daily Tailgate Meeting, Permit To Work, & Job Hazard Assessment
Attachment 6 Site Health and Safety Quiz
Attachment 7 Journey Management Plan
Attachment 8 Equipment Calibration / Air Monitoring Logs
Attachment 9 Safety Data Sheets
Attachment 10 Subcontractor HASP and JSAs
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FIELD ACTIVITIES
Emergency Response
1.0 Emergency Response
1.1 PHONE NUMBERS
Cell Phone carried by the Stantec SHSO – Robert McAlister (714)686-4435

The number of the nearest telephone is in the REI (541)732-1938
Emergency Response
Name Telephone Verification

Rogue Valley Medical Center
Hospital 2825 E. Barnett Road (541) 789-7000 RM 8/21/15
Medford, OR 97504
Providence Occupational
Occupational Medicine
1390 Biddle Road, #101
(541)732-5554 RM 8/21/15
Clinic
Medford, OR 97504
911 or (800)903-
Ambulance Mercy Flights RM 8/21/15
9000
911 or (541)770-
Police Medford Police Department RM 8/21/15
4784
911 or (541)774-
Fire Department Medford Fire and Rescue RM 8/21/15
2300
Spill Response Cowlitz Clean Sweep (503)247-9466 RM 8/21/15
Environmental National Response Center (24-
hour hotline)
(800) 424-8802 RM 8/21/15
Response
Environmental US Environmental Protection
Agency (24-hour hotline)
(800) 424-9346 RM 8/21/15
Protection
Emergency Office of Emergency Services
(24-hour hotline)
(800) 852-7550 RM 8/21/15
Services
U.S. National Poison Control
Poison Control Center (24-hour hotline)
(800) 222-1222 RM 8/21/15
Agency / Line Locator

National Line National 811 Call-Before-You- 811 or (800)332-
RM 8/21/15
Locator Dig Hotline (24-hour hotline) 2344
Private Line Locator Rogue Locating (541)865-3968 RM 8/21/15
Drilling Contractor Stratus Corporation (503) 985-7912 RM 8/21/15

ODEQ Project
Cathy Rodda (541) 687-7325 RM 8/21/15
Manager
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FIELD ACTIVITIES
Emergency Response
Project Team Phone Numbers
Name Telephone Verification

Stantec Project (503)349-5389 Cell
Patrick Vaughan RM 1/23/15
Manager (971)230-5206 Office
Stantec Site Health (714)686-4435 Cell
Robert McAlister RM 1/23/15
and Safety Officer (971)230-5215 Office
Stantec Project (541)646-4080 Cell
Antonela Vadan RM 1/23/15
Staff (541)770-6977 x 123 Office
Stantec Business (425)894-2329 Cell
Marc Sauze RM 1/23/15
Unit Leader (425)289-7372 Office
(306) 667-2592 Office
US HSE Director Richard Weishaupt RM 1/23/15
(306) 491-6821 Cell
Fred Miller (610) 840-2565 Office
(610) 235-7315 Cell
Regional HSE
RM 1/23/15
Coordinator
Keith Kuhlmann (614) 486-4383 Office
(740) 816-6170 Cell
National HSE
Coordinator – (805) 234-6227 Cell
Tony Wong RM 1/23/15
Environmental (805) 250-2860 Office
Services
Workers
(513)720-3706 Cell
Compensation Melissa Helton RM 1/23/15
(513)842-8245 Office
Coordinator
1-800-350-4511
Occupational
All-One Health (24 hours/day,7 RM 1/23/15
Health Services
days/week)
Stantec Human
Peggy Ramos (949)923-6061 Office RM 1/23/15
Resources Director
Subcontractor Stratus Corp. (503)985-7912 RM 1/23/15
2
FIELD ACTIVITIES
Emergency Response
1.2 DIRECTIONS AND MAP TO THE HOSPITAL
The SHSO will verify and validate the route to the hospital by driving it before work begins.
3
FIELD ACTIVITIES
Emergency Response
1.3 DIRECTIONS AND MAP TO OCCUPATIONAL CLINIC
The SHSO will verify and validate the route to the occupational clinic by driving it before work
begins.
4
FIELD ACTIVITIES
Emergency Response
1.4 EMERGENCY RESPONSE PROCEDURES: EVACUATION
In the event of an on-site or off-site emergency requiring site evacuation (e.g., fire, release,
explosion, etc), the following procedures will be followed:
 Stop Work and notify the SHSO.

 Evacuate the site and go to the emergency meeting location if safe conditions exist. The
generic evacuation point is at traffic circle near the Alba Village Shopping Center. If
safe conditions prevent evacuation to this location, move upwind, away from the source
of the emergency. Maintain a safe distance from the source.
 Check in with the SHSO at the emergency meeting location. The SHSO will take
attendance once all personnel have gathered.
 Dial the appropriate emergency response number(s). State the problem clearly and
completely and remain on the line until dismissed by the operator.
 Only attempt extinguishing small fires with portable dry chemical equipment on-hand.
When in doubt, emergency response personnel shall be notified.
 Do not reenter the emergency site without specific approval from emergency response
personnel.
Randomly scheduled evacuation drills may be conducted at any time during field activities.
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FIELD ACTIVITIES
Emergency Response
1.5 EMERGENCY RESPONSE PROCEDURES: INJURY OR ILLNESS
If an injury or illness occurs, take the following action:
 Stop Work, stabilize the situation, and secure the site.

 Administer First Aid for the person immediately using a first aid and blood-borne
pathogens kit.
 Determine if emergency response (fire/ambulance) is necessary. If so, call appropriate
emergency response numbers on closest available phone. Provide the location of the
injured person and other details as requested. Drive the individual to the hospital only if it
makes sense.
 If emergency decontamination is required:
o Immediately remove any contaminated personal protective equipment (PPE) or
clothing.
o If possible, wash contaminated area with mild soap and water.
o Use eyewash station if necessary.
o Personnel assisting the contaminated individual will don the proper PPE to avoid
unnecessary exposures.
 For all injuries or illness, even minor cuts, scratches, and bruises, notify the SHSO
immediately. The SHSO is responsible for initiating incident reporting procedures
immediately after the victim(s)/site have been stabilized. The SHSO will assume
responsibility during a medical emergency until more qualified emergency response
personnel arrive at the site as needed.
 As promptly as possible following an injury or illness, ensure appropriate notification has
been made to the family of the individual involved.
 Please see Section 1.7 for incident reporting procedures.
1.5.1 Injuries or Illnesses Requiring Hospital Service WITHOUT Ambulance

Service
Injuries or illnesses requiring hospital service without ambulance services include minor
lacerations, minor sprains, etc. The following procedures will be taken immediately:
 The SHSO will ensure prompt transportation of the injured person to a physician or
hospital.
 A representative of Stantec will always drive the injured employee to the medical facility
and remain at the facility until the employee is ready to return.
 If the driver of the vehicle is not familiar with directions to the hospital, a second person
shall accompany the driver and the injured employee and navigate the route to the
hospital.
 If it is necessary for the SHSO to accompany the injured employee, provisions will be
made to have another employee, properly trained and certified in First Aid, to act as the
temporary SHSO.
 If the injured employee is able to return to the job site the same day, he/she will bring
with him/her a statement from the doctor containing such information as:
o Date
o Employee's name
o Diagnosis
o Date he/she is able to return to work, regular or light duty
6
FIELD ACTIVITIES
Emergency Response
o Date he/she is to return to doctor for follow-up appointment, if necessary

o Signature and address of doctor
If the injured employee is unable to return to the job site the same day, the employee who
transported him will bring this information back to the job site and report it to Richard
Weishaupt, Stantec Practice and Risk Management (PRM), and their regional Human
Resources Specialist.
1.5.2 Injuries or Illnesses Requiring Hospital Service WITH Ambulance Service
Injuries or illnesses requiring hospital service with ambulance services include severe head
injuries, amputations, heart attacks, heat stroke, etc. The following procedures will be taken
immediately:
 Call for ambulance service and notify the SHSO.

 Administer First Aid until ambulance service arrives.
 While the injured employee is being transported, the SHSO will contact the medical
facility to be utilized.
 One designated representative will accompany the injured employee to the medical
facility and remain at the facility until final diagnosis and other relevant information is
obtained.
1.5.3 Death of an Individual or Hospitalization of Three or More Employees
The emergency response procedures above will be followed. If the injured person dies, follow
the incident reporting procedures. PRM will notify the Human Resources Department, local
officials and coroner immediately. Human Resources will notify the local OSHA office within 8
hours of the incident or fatality in the event of fatality or hospitalization of three or more
employees.
7
FIELD ACTIVITIES
Emergency Response
1.6 EMERGENCY RESPONSE PROCEDURES: SPILLS OR CUT LINES
Prevent problems by documenting the location of underground lines (e.g., product, sewer,
telephone, fiber optic) before starting site work. If a line or tank is drilled through, or another leak
occurs, document the event as soon as possible using the Incident Investigation Report.
In the event of a spill/release, follow this plan:
 Stop Work, stabilize the situation, and secure the site.

 Stay upwind of the spill/release.
 Wear appropriate PPE.
 Turn off equipment and other sources of ignition.
 Turn off pumps and shut valves to stop the flow/leak.
 Plug the leak or collect drippings, when possible.
 Use sorbent pads to collect product and impede its flow, if possible.
 Call Fire Department immediately if fire or emergency develops.
 Notify the SHSO to begin the incident reporting procedures. The Stantec PM will notify
Stantec Incident Review Team Members, Stantec H&S Team Members, and the PM
immediately after the situation is under control.
 Determine if the client wants Stantec to repair the damage or if the client will use an
emergency repair contractor.
 Based on agreements, contact emergency spill contractor for containment of free
product. The contacts for this project will be Medford Fire and Rescue Department (911
OR 541-774-2300) and Cowlitz Clean Sweep (503-547-9466).
 Advise the client of spill discharge notification requirements and determine who will
complete and submit forms. (Do not submit or report to agencies without the client’s
consent.) Document each interaction with the client and regulators and note, in writing;
name, title, authorizations, refusals, decisions, and commitments to any action.
 Do not transport or approve transportation of contaminated soils or product until proper
manifests have been completed and approved. Be aware that soils / product may
meet criteria for hazardous waste.
 Do not sign manifests as generator of wastes unless you have been given appropriate
training and approval for signing on behalf of the generator; contact Project Manager or
Waste Compliance Manager to discuss waste transportation.
The Project Manager will involve the client/generator in the Incident Investigation process. The
client/generator is under obligation to report to the proper government agencies. If the spill
extends into waterways, the Coast Guard and the National Response Center will be notified
immediately by the client or by Stantec Project Manager with the client’s permission.
Prevention of spills is key. Use proper equipment inspection forms and inspect all equipment
prior to use onsite. Do not use equipment that has not been inspected, that is improperly
maintained, or shows signs of belt or hose wear, or leaks. Stantec field personnel will request all
equipment that is not fit for duty be returned for repair.
8
INCIDENT REPORTING GUIDELINES
(MEDICAL EMERGENCY, FIRST AID, MVC, SPILL, PERMIT
EXCEEDANCES, NOV, & ALL NEAR LOSSES)
1.7 INCIDENT REPORTING PROCEDURES
INSTRUCTION GUIDE FOR INTERNAL INCIDENT REPORTING

This section outlines the procedures that will be followed in the event of an incident. A flowchart and a
table with necessary contact information (phone numbers, fax numbers, and email addresses) for incident
reporting are also provided.
In the event of an incident:

1. Stop work, stabilize the situation, and secure the site.
2. Report all incidents, injuries, spills, non-conformance events, permit exceedances, and
potential incidents (near losses) immediately to the SHSO, who will then notify the Stantec
Project Manager. If you are unsure whether or not something should be reported, Stop Work
and proceed with notification anyway.
3. The Stantec Project Manager will make internal notifications* to the following: and
 Stantec H&S Team Members (Richard Weishaupt and one of the RSECs (Fred Miller);
 Tony Wong
If a team member does not answer, leave a detailed message with a number at which
you can be reached.
*Internal notification is a requirement for our Stantec team members. Internal reporting
requirements were established for two primary reasons: (1) provide a pathway for employees
to obtain the assistance of company health and safety experts during an incident or near loss,
and (2) to help Stantec track injuries and near losses that occur to our employees. The data
captured during the reporting process is then used to identify trends that can be pro-actively
addressed to improve overall health and safety within our company. This helps everyone go
home safely.
4. The Stantec Project Manager will obtain concurrence from at least one of the Stantec Incident
Review Team Members regarding client specific reporting requirements.
5. A: If the incident is determined to not be reportable to the client, the SHSO or Stantec Project
Manager will submit an initial copy of the Stantec Incident Investigation/Near Loss Investigation
(IINLI) report (RMS-3 Form) to Stantec’s PRM group in Edmonton (via email to
hse@stantec.com) and Richard Weishaupt within 24 hours of the event. The final report is due
within 5 business days.
B: If the incident is determined to be reportable to the client, the Stantec Project Manager or
Director will:
 Notify the client Project Manager and, if requested, complete a Flash Report and other
associated documentation.
 Provide a written report of the incident on a Stantec IINLI (RMS-3) form to Stantec’s PRM
group (via email to hse@stantec.com) and Richard Weishaupt. An initial copy of the
report will be submitted within 24 hours, and the final will be completed within 5 business
days.
9
INCIDENT REPORTING GUIDELINES
(MEDICAL EMERGENCY, FIRST AID, MVC, SPILL, PERMIT
EXCEEDANCES, NOV, & ALL NEAR LOSSES)
Stop Work, stabilize situation,

and secure site.
If you are unsure

Immediately notify whether or not
If a H&S team Stantec SHSO. something should be
member does not reported, Stop Work
answer, leave a and proceed with
detailed message notification anyway.
with a number at Notify Stantec PM immediately.
which you can be
reached.
Stantec PM makes verbal notification

immediately to at least one of the
Stantec PM or Director following people:
Notifies Client PM & and
completes associated Stantec HSE Team: Submit initial copy of
internal and external Richard Weishaupt Stantec IINLI report to
paperwork, within required Fred Miller/ Keith Kuhlmann Edmonton Office within
Clint Reuter 24 hours of event.
timeframes
Tony Wong Final Report Due within 5
business days.
Incident Reportable to Incident Not

client Stantec PM or Director determines if
incident is reportable to client Reportable to client
Stantec HSE Team Notification Phone Numbers:

Richard Weishaupt Office (306) 667-2592 Cell (306) 491-6821
Fred Miller Office (610) 840-2565 Cell (610) 235-7315
Keith Kuhlmann Office (614) 486-4383 Cell (740) 816-6170
Clint Reuter Office (949) 923-6258 Cell (818) 395-8556
Tony Wong Office (805) 250-2860 Cell (805) 234-6227
Stantec OE Network
National OE Coordinator Dianne Burnia Office (248) 489-5900 Cell (517) 304-0214
Account Management Steward Tom Madsen Office (801) 261-0900 Cell (801) 448-1351
MBU East OE Lead Gabe Knight Office (860) 948-1628 Cell (860) 830-4003
MBU West OE Lead Laurie Gier Office (916) 861-0400 Cell (916) 281-8057
RBU OE Lead Mike Winkler Office (248) 489-5900 Cell (248) 631-9636
UBU/Mid Continent Abandonment Chris Beall Office (303) 285-4541 Cell (970) 214-1126
Superfund/Special Projects Eric Bassett Office (651) 255-3952 Cell (651) 327-7235
Stantec’s Practice and Risk Management Group

Fax (780) 969-2030 E-mail = riskmgt@stantec.com
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FIELD ACTIVITIES
Scope of Work
2.0 Scope of Work
The scope of this project is to:
1. Drive to/from Job Site; and

2. Earthwork and Grading.
The above-stated tasks will be conducted in a manner consistent with the methods and
assumptions outlined in the: Work Plan for Additional Site Investigation – Northgate Phase 1b, Tax
Lot 700 and 800 and the Grading and Excavation Plan, date pending. All work plans referenced
in this HASP will be available for Stantec personnel on site.
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FIELD ACTIVITIES
Site Background and Chemical Hazards
3.0 Site Background and Chemical Hazards
The Site (Tax Lots 700 and 800) and surrounding area were formerly part of a much larger
property that was in use as a lumber mill from the 1920s until 1993. In the early 1960s, a plywood
fabrication building was constructed on the above-referenced property. In 1988, the Medite
sawmill (formerly MEDCO) was shut down and permanent closure of the plywood plant was
initiated in 1992.
The Medite property began cleanup for regulatory closure under the ODEQ Voluntary Cleanup
Program in 1993. The property underwent extensive cleanup that utilized on-Site methods to
treat soil impacted by petroleum hydrocarbons, polycyclic aromatic hydrocarbons (PAHs), and
other contaminants; no groundwater contamination was encountered. The ODEQ authorized
regulatory closure with no further action in a letter dated July 24, 1995.
In August 2011 Stantec, at the request of Regency, installed 17 borings across the former mill
property, including portions of Tax Lots 700, 800 (collectively “the Site”) and 1400 (Hereafter
referred to as “Alba Village”). Of these, eight borings (SV-1 through SV-8) were placed within the
Site, and borings SV-9 through SV-17 were located on the Alba Village property. Soil and grab
groundwater samples were collected at each location and submitted for laboratory analysis of
semi-volatile organic compounds (SVOCs) by EPA Method 8270C, volatile organic compounds
(VOCs) by US EPA Method 8260B, total petroleum hydrocarbons in the gasoline range (TPH-G)
using NWTPH-Gx.
Procedures used and results obtained are described in their entirety in the Soil and Groundwater
Sampling Report, Proposed Alba Village, Medford, Oregon, September 15, 2011 which was
submitted to ODEQ on the date of the report. On September 30, 2011, the ODEQ issued
approval of the report in a letter entitled Approval of Soil and Groundwater Sampling Report,
dated September 15, 2011 and Additional Work Needed to Provide a No Further Action
Determination. The ODEQ also stated in the letter that “consistent with ODEQ’s Contaminated
Aquifer Policy, and based on our understanding of Site conditions and contaminant
characterization, ODEQ does not consider Regency Centers responsible for HVOC and
petroleum contamination in groundwater at the northeast corner of the Site”.
12
FIELD ACTIVITIES
Site Background and Chemical Hazards
In April 2014, as part of groundwater monitoring well installation, Stantec identified the presence
of TPH in the diesel range, dioxins/furans and four semi-volatile organic compounds at low
concentrations in Site groundwater. Dioxins/furans were also detected in two shallow soil
samples collected during the installation of monitoring well MW-2.
In April 2015, Stantec completed an extensive shallow soil assessment at the Site. Included in this
assessment was the advancement of 44 soil borings and collection of soil and groundwater
samples. Results of this assessment indicated that the nature and extent of dioxin and furan
impacts have been adequately defined across the Site and allowed Stantec to prepare
appropriate risk-management analysis. As a result, Stantec determined that excess lifetime
cancer risk is well below the maximum acceptable risk specified in published Oregon DEQ
guidance.
To date, dioxin and furan congeners are the constituents of concern at the Site.
The following table summarizes the maximum concentration of dioxin and furan congeners
observed in all environmental samples collected at the Site to date.
Constituents of Potential Concern and Maximum Concentrations

Constituent Sample Date Media Concentration
DIOXIN and FURAN
CONGENERS (see following
4/21/2015 SOIL TEQ = 681.43 pg/g
table for individual
compounds)
1,2,3,4,6,7,8-HpCDD
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
1,2,3,7,8-PeCDD
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
2,3,7,8-TCDD
2,3,7,8-TCDF
Sample ID
OCDD
OCDF
S-31-2.5’-4.5’
1,700 pg/g
2,000 pg/g
9,700 pg/g
1,200 pg/g
2,400 pg/g
210 pg/g
130 pg/g
400 pg/g
180 pg/g
140 pg/g
130 pg/g
3.6 pg/g
12 pg/g
29 pg/g
13 pg/g
63 pg/g
74 pg/g
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FIELD ACTIVITIES
Potential Airborne Concerns and Air Monitoring Action Levels
4.0 Potential Airborne Concerns and Air Monitoring Action Levels
Note: additional potential contaminants have been included to ensure adequate protection of workers if additional out-
of-scope contamination is encountered at the Site at any time
POTENTIAL AIRBORNE CHEMICALS ONSITE IN THIS PROJECT

REVIEW THIS TABLE AND CONTACT SHSO WITH QUESTIONS
CHEMICAL OSHA PEL OTHER WARNING ROUTES OF ACUTE HEALTH CHRONIC
(OR CLASS) ACGIH TLV PERTINENT PROPERTIES EXPOSURE EFFECTS HEALTH
LIMITS OR EFFECTS/
IRRITATION TARGET
ORGANS
FedOSHA PEL NIOSH REL Yellowish to Inhalation, Nausea, eye Kidneys,

TPH-d
400 ppm 350 ppm light brown skin irritation, increased circulatory
liquid absorption, blood pressure, system
ingestion, skin headache, light-
and/or eye headedness, loss of
contact. appetite, poor
coordination, and
difficulty
concentrating.
[Potential
occupational
carcinogen
CalOSHA PEL CalOSHA Clear liquid Inhalation, Irritation eyes, skin, Eyes, skin,
TPH-g
300 ppm STEL 500 with a skin mucous respiratory
ppm characteristi absorption, membrane; system,
FedOSHA PEL c odor ingestion, skin dermatitis; central
None and/or eye headache, nervous
Established contact fatigue, blurred system, liver,
vision, dizziness, kidneys
No REL slurred speech,
Established confusion,
convulsions;
TLV 300 ppm chemical
pneumonia
(aspiration liquid);
possible liver,
kidney damage;
[Potential
occupational
carcinogen]
14
FIELD ACTIVITIES

LIMITS OR EFFECTS/
IRRITATION TARGET
ORGANS
Cal/FedOSHA CalOSHA & Characteristi Inhalation, Skin (dermatitis), Carcinogen,

Benzene
PEL 1.0 ppm FedOSHA c Dermal, eye, respiratory CNS, eye
(1910.1028) STEL 5.0 ppm benzene ingestion, tract irritant, damage,
TLV 0.5.0 ppm NIOSH REL odor eyes headache, bone
(skin) 0.1 ppm dizziness, nausea. marrow,
IDLH 500 blood, skin,
ppm leukemia.
CalOSHA PEL NIOSH REL Sweet, Inhalation, Skin (dermatitis) CNS, liver,
Toluene
50 ppm 100 ppm pungent, dermal, eye, respiratory kidneys, skin.
TWA; 150 benzene-like ingestion, tract irritant,
FedOSHA PEL ppm STEL odor eyes headache,
200 ppm ILDH 500 dizziness,
ppm weakness, and
TLV 50 ppm CalOSHA C fatigue.
500 ppm
CalOSHA
STEL 150
ppm
Cal/FedOSHA PEL-STEL 125 Pungent Inhalation, Skin/eye/mucous Eyes,

Ethylbenzene
PEL 100 ppm ppm aromatic dermal, membrane irritant, respiratory
TLV STEL 125 odor ingestion, headache, tract, skin,
TLV 100 ppm ppm eyes dizziness, CNS, blood,
NIOSH REL drowsiness kidneys, liver.
100 ppm;
REL-STEL 125
ppm
IDLH 800
ppm
CalOSHA
STEL 125
ppm
Cal/FedOSHA TLV STEL 500 Aromatic Inhalation, Throat and skin CNS, liver,
Xylenes
PEL 100 ppm ppm odor dermal, irritant kidneys, skin,
NIOSH REL ingestion, (dermatitis), gastrointestin
TLV 100 ppm 100 ppm eyes headache, al damage,
REL STEL 100 nausea, eye damage
ppm drowsiness, fatigue
IDLH 900
ppm
CalOSHA C
300 ppm
CalOSHA
STEL 150
ppm
15
FIELD ACTIVITIES

LIMITS OR EFFECTS/
IRRITATION TARGET
ORGANS
Cal/FedOSHA TLV-STEL 15 Mothball Like Inhalation, Skin/eye/mucous/ Eyes, blood,
PEL 10 ppm ppm Odor dermal, membrane irritant, skin, liver,
Naphthalene
NIOSH REL 10 ingestion, eye nausea kidneys RBC,
TLV 10 ppm ppm contact. and CNS.
REL-STEL 15
ppm
IDLH 250
ppm
CalOSHA
STEL 50 ppm
CalOSHA PEL Fed OSHA Colorless Inhalation, Irritation to eyes, Cardiac

Trichloroethene
25 ppm Ceiling 200 liquid (unless dermal, skin; headache, arrhythmias,
ppm dyed blue) ingestion, vertigo (an illusion paresthesia;
(TCE) Fed OSHAPEL with a eyes of movement); liver injury;
100 ppm CalOSHA chloroform- visual disturbance, Potential
STEL 100 like odor. fatigue, giddiness, occupationa
TLV 50 ppm ppm tremor, l carcinogen
somnolence of liver and
NIOSH (sleepiness, kidney
considers unnatural
trichloroethyl drowsiness),
ene a nausea, vomiting;
carcinogen. dermatitis;
CalOSHA PEL REL – 25 ppm Clear, Inhalation, Irritation eyes, skin, Eyes, skin,
1, 3, 5, -
25 ppm colorless ingestion, skin nose, throat, respiratory
Trimethyl- liquid with a and/or eye respiratory system; system,
benzene PEL – None distinctive, contact bronchitis; central
established aromatic hypochromic nervous
odor. anemia; system,
TLV – 25 ppm headache, blood
drowsiness, fatigue,
dizziness, nausea,
in coordination;
vomiting,
confusion;
chemical
pneumonia
(aspiration liquid)
16
FIELD ACTIVITIES

CHEMICAL OSHA PEL OTHER PERTINENT WARNING ROUTES OF ACUTE HEALTH CHRONIC
(OR CLASS) ACGIH TLV LIMITS PROPERTIES EXPOSURE EFFECTS HEALTH
OR EFFECTS/
IRRITATION TARGET
ORGANS
Dioxin OSHA PEL: Occupational Colorless to Inhalation, Irritation to eyes, possible
[reference none Carcinogen white Skin allergic reproductive
chemical: crystalline absorption, dermatitis, or
2,3,7,8- TLV not Time-weighted (needle-like ingestion, chloracne, teratogenic
Tetrachloro- established average for crystals) solid. skin and/or porphyria, effects,
p-dibenzo- airborne 2,3,7,8- Contaminant eye contact gastrointestinal kidney and
dioxin TCDD is 0.5 migration disturbance liver
(2,3,7,8 mg/m3 may occur as damage,
TCDD)] wind-blow potential
dust or bio- occupation
accumulate al
in food. carcinogen
Abbreviation Explanation
PEL Permissible Exposure Limit
REL Recommended Exposure Limit set by NIOSH
C Ceiling Limit
STEL Short Term Exposure Limit
IDLH Immediately Dangerous to Life or Health
TLV Threshold Limit Value set by the ACGIH (American Conference of
Governmental Industrial Hygienists)
AIHA WEEL Workplace Environmental Exposure Limits set by the AIHA (American
Industrial Hygiene Association)
SKIN Skin Absorption
NIOSH National Institute for Occupation Safety and Health
CNS Central Nervous System
CVS Cardiovascular System
17
FIELD ACTIVITIES
MONITORING LEVEL FOR

CHEMICAL MONITORING LEVEL FOR
TASK FREQUENCY/ WORK
(OR CLASS) EQUIPMENT RESPIRATOR USE
LOCATION STOPPAGE
Volatile PID During any Sampling will be Full-Face respirator. 25 ppm in
Organic scope of done at no more breathing
Vapors fieldwork than 30 minute The level for zone = stop
intervals in the respirator use will be work
breathing zone 5 ppm sustained for immediately
for all personnel 2 minutes. and
on-Site. assemble at
upwind
location.
Dioxins and For extensive Particulate Mitigation Plan Without a Without a
Furans soil monitoring Avoid creating particulate monitor: particulate
disturbance in should only excessive dust: Stop work and monitor:
Refer to the areas with be Drive on paved move upwind if Excessive
following EPA known high employed roads on-Site, excessive dust is dust in work
Fact Sheet on concentrations when Immediately present in work area
the of Dioxins: significant containerize area. Do not
Management Particulate amounts of (DOT-drums) all resume work until When using a
of Dioxin Monitor (i.e. impacted soil waste, dust has dissipated. particulate
Contaminated Microdust Pro) soil are Use dust control monitor:
Soils. disturbed. (water) in any When using a 2.0 mg/m3 in
work areas to particulate monitor: breathing
suppress dust. 0.5 mg/m3 for two zone
minutes in the
breathing zone =
stop work and
evacuate the area
upwind.
 The Level for Respirator Use is the concentration at which a respirator will be put on; it does not
require the job to stop. The respirator is a tool to be used while determining why the exposure has
reached that concentration. Take action to reduce the concentration using engineering controls
such as water mist, spray foam, plastic cover, etc.
 The Level for Work Stoppage is the concentration at which work on the job will stop. Determine
why exposures have reached that concentration and how they can be reduced. Site evacuation
is not necessary at this level. Implement engineering controls to reduce the concentration, and
then resume work.
 Photoionization detectors (PIDs) are used for general hydrocarbon monitoring; an example would
be benzene, toluene, ethylbenzene, and xylene, common on gasoline station sites. The PID
typically uses either a 10.6 eV lamp (responds to pentane and higher hydrocarbons), or 11.7 eV
lamp (responds to ethane [weakly], propane and higher hydrocarbons) to ionize and detect the
gas. The PID will measure hydrocarbons that are ionized, and therefore is a screening device, not
a chemical-specific measurement instrument.
 The Levels for Work Stoppage are based on measurements taken using PIDs calibrated with
isobutylene; PIDs calibrated with gases other than isobutylene may have a different response
factor.
 Action levels can be modified with particular knowledge of contaminants and site conditions.
18
Fact Sheet on the Management of Dioxin Contaminated Soils
/ŶƚƌŽĚƵĐƟŽŶ
This fact sheet provides guidance on the proper management of dioxin- contaminated soils
when carrying out the ƌĞŵ ĞĚǇƐĞůĞĐƟŽŶƉƌŽĐĞƐƐƉƵƌƐƵĂŶƚƚŽƚŚĞŽŵ ƉƌĞŚĞŶƐŝǀĞŶǀŝƌŽŶŵ ĞŶƚĂů
ZĞƐƉŽŶƐĞ͕Žŵ ƉĞŶƐĂƟŽŶ͕ĂŶĚ>ŝĂďŝůŝƚǇĐƚ;Z>Ϳ͕ĂƐĂŵ ĞŶĚĞĚďǇƚŚĞ^ƵƉĞƌĨƵŶĚ
ŵ ĞŶĚŵ ĞŶƚƐĂŶĚZĞĂƵƚŚŽƌŝǌĂƟŽŶĐƚ;^ZͿ͘1 Regions should consider and evaluate proper
management of dioxin-contaminated soils in a manner consistent with:
overall ƌĞŵ ĞĚǇƐĞůĞĐƟŽŶframework, including:
o ĂĐŚŝĞǀŝŶŐƉƌŽƚĞĐƟǀĞŶĞƐƐŽĨŚƵŵ ĂŶŚĞĂůƚŚĂŶĚƚŚĞĞŶǀŝƌŽŶŵ ĞŶƚ,
o compliance with applicable, or relevant and appropriate requirements [ARARs],
o ƉƌĞĨĞƌĞŶĐĞĨŽƌƚƌĞĂƚŵ ĞŶƚƚŽƚŚĞŵ Ăǆŝŵ Ƶŵ ĞǆƚĞŶƚƉƌĂĐƟĐĂďůĞ [MEP], and
o adherence to the off-site rule;
ƚŚĞE ĂƟŽŶĂůK ŝůĂŶĚ, ĂǌĂƌĚŽƵƐ^ƵďƐƚĂŶĐĞƐWŽůůƵƟŽŶŽŶƟŶŐĞŶĐǇWůĂŶ;E WͿ, including:
o ŵ ĞĞƟŶŐƉƌŽŐƌĂŵ ŵ ĂƟĐĞǆƉĞĐƚĂƟŽŶƐŽŶƌĞƐƚŽƌŝŶŐŐƌŽƵŶĚǁ ĂƚĞƌƚŽďeneficial
ƵƐĞƐǁ ŝƚŚŝŶĂƌĞĂƐŽŶĂďůĞƟŵ ĞĨƌĂŵ Ğ,
o not relying exclusively on ŝŶƐƟƚƵƟŽŶĂůĐŽŶƚƌŽůƐ[ICs], and
o carrying out the nine criteria analysis; 2 and
associated Superfund program guidance, including: A Guide to Preparing Superfund
Proposed Plans, ReĐŽƌĚƐŽĨ ĞĐŝƐŝŽŶ͕ĂŶĚK ƚŚĞƌZĞŵ ĞĚǇ^ĞůĞĐƟŽŶ ĞĐŝƐŝŽŶ ŽĐƵŵ ĞŶƚƐ.
OSWER 9200.1-23P; July 1999).3
1
This document provides guidance to Regional staff regarding how the Agency intends to interpret and implement
the NCP, ǁ ŚŝĐŚƉƌŽǀŝĚĞƐƚŚĞďůƵĞƉƌŝŶƚĨŽƌZ>ŝŵ ƉůĞŵ ĞŶƚĂƟŽŶ͘, Žǁ ĞǀĞƌ͕ƚŚŝƐĚŽĐƵŵ ĞŶƚĚŽĞƐŶŽƚƐƵďƐƟƚƵƚĞ
ĨŽƌƚŚŽƐĞƉƌŽǀŝƐŝŽŶƐŽƌƌĞŐƵůĂƟŽŶƐ͕ŶŽƌŝƐŝƚĂƌĞŐƵůĂƟŽŶŝƚƐĞůĨ͘dŚƵƐ, it cannot impose legally binding requirements
ŽŶW͕ƐƚĂƚĞƐ͕ŽƌƚŚĞƌĞŐƵůĂƚĞĚĐŽŵ ŵ ƵŶŝƚǇ͕ĂŶĚŵ ĂǇŶŽƚĂƉƉůǇƚŽĂƉĂƌƟĐƵůĂƌƐŝƚƵĂƟŽŶďĂƐĞĚƵƉŽŶƚŚĞ
ĐŝƌĐƵŵ ƐƚĂŶĐĞƐ͘ŶǇĚĞĐŝƐŝŽŶƐƌĞŐĂƌĚŝŶŐĂƉĂƌƟĐƵůĂƌƐŝƚƵĂƟŽŶǁ ŝůůďĞŵ ĂĚĞďĂƐĞĚŽŶƚŚĞƐƚĂƚƵƚĞĂŶĚƚŚĞ
ƌĞŐƵůĂƟŽŶƐ͕ĂŶĚWĚĞĐŝƐŝŽŶ-makers retain thĞĚŝƐĐƌĞƟŽŶƚŽĂĚŽƉƚĂƉƉƌŽĂĐŚĞƐŽŶĂĐĂƐĞ-by-case basis that differ
from the guidance, where appropriate.
2
See 40 CFR 300.430(a). For example, dŚĞŶĂƟŽŶĂůŐŽĂůŽĨƚŚĞƌĞŵ ĞĚǇƐĞůĞĐƟŽŶ
ƉƌŽĐĞƐƐŝƐƚŽƐĞůĞĐƚƌĞŵ ĞĚŝĞƐƚŚĂƚĂƌĞƉƌŽƚĞĐƟǀĞŽĨŚƵŵ ĂŶŚĞĂůƚŚĂŶĚƚŚĞĞŶǀŝƌŽŶŵ ĞŶƚ͕ƚŚĂƚŵ ĂŝŶƚĂŝŶƉƌŽƚĞĐƟŽŶ
40 CFR 300.430(a)(1)(iii)(A-F) includes the following
3
See
-23.p, July 1999.)
May 9, 2011 Page 1 of 28

The CERCLA treatment to the MEP4 requirement under ^ĞĐƟŽŶϭϮϭ;ĚͿŝƐĂĚŝƐƟŶĐƚƌĞƋƵŝƌĞŵ ĞŶƚ
ĨƌŽŵ ZĞƐŽƵƌĐĞŽŶƐĞƌǀĂƟŽŶĂŶĚZĞĐŽǀĞƌǇĐƚ;ZZͿ>ĂŶĚ ŝƐƉŽƐĂůZĞƐƚƌŝĐƟŽŶƐ;> ZƐͿĂŶĚŝƐ
not addressed in this fact sheet. A RCRA requirement (or site-ƐƉĞĐŝĮĐĚĞƚĞƌŵ ŝŶĂƟŽŶͿƚŽƚƌĞĂƚŽƌ
ŶŽƚƚŽƚƌĞĂƚĚŽĞƐŶŽƚďǇŝƚƐĞůĨĐŽŶƐƟƚƵƚĞƐƵĸ ĐŝĞŶƚŝŶĨŽƌŵ ĂƟŽŶƚŽƐĂǇƚŚĂƚǁ ĞŚĂǀĞƚƌĞĂƚĞĚƚŽ
MEP in accordance with CERCLA 121 CERCLA and the NCP (40 CFR 300.430(a)). Regions may
ĂůƐŽŶĞĞĚƚŽĞǀĂůƵĂƚĞĂŶƵŵ ďĞƌŽĨĂĚĚŝƟŽŶĂůĨĂĐƚŽƌƐĐŽŶĐĞƌŶŝŶŐƚŚĞƉƌŽƉĞƌŵ ĂŶĂŐĞŵ ĞŶƚŽĨ
dioxin contaminated soils͘dŚŝƐĨĂĐƚƐŚĞĞƚĂůƐŽĞǆƉůŽƌĞƐƚŚĞƉŽƚĞŶƟĂůrĞůĂƟŽŶƐŚŝƉďĞƚǁ ĞĞŶ
dioxin-contaminated soils and the RCRA regulatory program, more specifically, the LDRs.
While th principle focus is the off-site management of soils, dioxin- contaminated

soils may be managed either on site or off site in accordance with CERCLA, the NCP and
Superfund guidance. This fact sheet highlights a number of guidance materials intended to help
site managers determine whether dioxin-contaminated soils are best managed on or off site.
Guidance materials that provide an overview of waste management materials, such as
D ĂŶĂŐĞŵ ĞŶƚŽĨZĞŵ ĞĚŝĂƟŽŶt ĂƐƚĞh ŶĚĞƌZZ (October 1998; EPA 530-F-98-026, OSWER
Memorandum) may be helpful in summarizing the requirements for compliance of off-site
waste management. Under CERCLA and the NCP, on-site managed wastes are subject to
ARARs, but are not subject to the non-ƐƵďƐƚĂŶƟǀĞƌĞƋƵŝƌĞŵ ĞŶƚƐ͕ƐƵĐŚĂƐƉĞƌŵ ŝƫ ŶŐ. On the
other hand, off-site waste management ŶĞĞĚƐƚŽĐŽŵ ƉůǇǁ ŝƚŚĂůůƐƵďƐƚĂŶƟǀĞĂŶĚŶŽŶ-
substanƟǀĞ requirements of the ĂƉƉůŝĐĂďůĞƌĞŐƵůĂƟŽŶƐ͘
4
The National Oil and Hazardous Substances Pollution Contingency Plan (NCP) focused the CERCLA 121(d)
requirement to treat to the maximum extent practicable to wastes that are deemed a principal threat as noted as
a site, wherever practicable. Principal threats are characterized as waste that cannot be reliably controlled in place,
such as liquids, highly mobile materials (e.g., solvents), and high concentrations of toxic compounds (e.g., several
orders of magnitude above levels that allow for unr
9, 1990)
May 9, 2011 Page 2 of 28

RCRA LĂŶĚ ŝƐƉŽƐĂůZĞƐƚƌŝĐƟŽŶƐĂŶĚContaminated Soils
General Applicability of LDRs to Contaminated Soils
Contaminated soils are subject to LDRs, generally, when they contain a listed hazardous waste
or exhibit a hazardous waste ĐŚĂƌĂĐƚĞƌŝƐƟĐ. However, on May 26, 1998, (63 FR 28556), EPA
ƉƌŽŵ ƵůŐĂƚĞĚĂůƚĞƌŶĂƟǀĞƚƌĞĂƚŵ ĞŶƚƐƚĂŶĚĂƌĚƐƐƉĞĐŝĮĐƚŽĐŽŶƚĂŵ ŝŶĂƚĞĚsoils. These standards
were designed to encourage cost-Ğī ĞĐƟǀĞĐůĞĂŶƵƉŽĨŚĂǌĂƌĚŽƵƐĐŽŶƚĂŵ ŝŶĂƚĞĚsoils subject to
> ZƐĂŶĚƚŽĂĚĚƌĞƐƐƚŚĞƵŶŝƋƵĞĐŚĂƌĂĐƚĞƌŝƐƟĐƐŽĨsoils. 5 The 1998 standards require that
contaminated soils be treated to either ƌĞĚƵĐĞĐŽŶĐĞŶƚƌĂƟŽŶƐŽĨŚĂǌĂƌĚŽƵƐĐŽŶƐƟƚƵĞŶƚƐďǇϵϬ
percent or to ŵ ĞĞƚŚĂǌĂƌĚŽƵƐĐŽŶƐƟƚƵĞŶƚĐŽŶĐĞnƚƌĂƟŽŶƐƚŚĂƚĂƌĞϭϬ x the universal treatment
standard (UTS), whichever is greater. (This is typically referred to as 90 percent capped by 10 X
UTS).6
If soil treatment achieves the 90 percent ƌĞĚƵĐƟŽŶƐƚĂŶĚĂƌĚ or reduces individual ĐŽŶƐƟƚƵĞŶƚ

ĐŽŶĐĞŶƚƌĂƟŽŶƚŽůĞǀĞůƐĂĐŚŝĞǀing the standard of 10X UTS, then further treatment is not
required. Treatment for non-metals must achieve 90 percent ƌĞĚƵĐƟŽŶŝŶƚŽƚĂůĐŽŶƐƟƚƵĞŶƚ
conceŶƚƌĂƟŽŶƐ͘dƌĞĂƚŵ ĞŶƚĨŽƌŵ ĞƚĂůƐŵ ƵƐƚĂĐŚŝĞǀĞϵϬ percent ƌĞĚƵĐƟŽŶĂƐŵ ĞĂƐƵƌĞĚŝŶ
leachate from the treated soils ;ƚĞƐƟŶŐĂĐĐŽƌĚŝŶŐƚŽƚŚĞdŽǆŝĐŝƚǇŚĂƌĂĐƚĞƌŝƐƟĐ>ĞĂĐŚŝŶŐ
Procedure [TCLP]Ϳǁ ŚĞŶĂŵ ĞƚĂůƐƚĂďŝůŝǌĂƟŽŶƚƌĞĂƚŵ ĞŶƚƚĞĐŚŶŽůŽŐǇŝƐƵƐĞĚ͕ĂŶĚĂƐŵ easure in
ƚŽƚĂůĐŽŶƐƟƚƵĞŶƚĐŽŶĐĞŶƚƌĂƟŽŶǁ ŚĞŶĂŵ ĞƚĂůƌĞŵ ŽǀĂůƚĞĐŚŶŽůŽŐǇŝƐƵƐĞĚ͘
For contaminated soils ƚŚĂƚĂůƐŽĞǆŚŝďŝƚƚŚĞĐŚĂƌĂĐƚĞƌŝƐƟĐŽĨŝŐŶŝƚĂďŝůŝƚǇ͕ƌĞĂĐƟǀŝƚǇ͕Žƌ

corrosivity, ^ĞĐƟŽŶϮϲϴ͘ϰϵ(c)(2) requires that treatment must eliminate the hazardous property
prior to land disposal.
ŚĂǌĂƌĚŽƵƐĐŽŶƐƟƚƵĞŶƚŝƐĂƌĞŐƵůĂƚĞĚĐŽŶƐƟƚƵĞŶƚƐƉĞĐŝĮĞĚŝŶƚŚĞƚƌĞĂƚŵ ĞŶƚƐƚĂŶĚĂƌĚĂƚϰϬ
CFR 268.40, or it may be an underlying hazardŽƵƐĐŽŶƐƟƚƵĞŶƚ;h , Ϳ͘ŶǇĐŽŶƐƟƚƵĞŶƚƚŚĂƚŝƐ
listed in the UTS Table aƚ^ĞĐƟŽŶϮϲϴ͘ϰϴ͕ĞǆĐĞƉƚĨŽƌŇƵŽƌŝĚĞ͕ƐĞůĞŶŝƵŵ ͕ƐƵůĮĚĞƐ͕ǀĂŶĂĚŝƵŵ ͕ĂŶĚ
zinc, can be a UHC. When using ƚŚĞĂůƚĞƌŶĂƟǀĞsoil treatment standard, all UHCs present at
levels greater than 10 x UTS must be treated--regardless of whether the soils contain a listed
ǁ ĂƐƚĞŽƌĞǆŚŝďŝƚƐĂĐŚĂƌĂĐƚĞƌŝƐƟĐǁ ŚĞŶƚŚĞsoils are generated (i.e., excavated). 7
Hazardous waste-contaminated soils added to products that are subsequently used in a

manner ĐŽŶƐƟƚƵƟŶŐ disposal must meet the treatment standards developed for as-generated
industrial waste at 40 CFR 268.40; the ĂůƚĞƌŶĂƟǀĞƐŽŝůtreatment standards cannot be used.
5
Generators have the choice of using either the applicable universal treatment standards for the contaminated
hazardous waste or the ĂůƚĞƌŶĂƟǀĞƐŽŝůtreatment standards.
6
As def
management unit or staging pile, and includes, but is not limited to, placement in a landfill, surface impoundment,
ǁ ĂƐƚĞƉŝůĞ͕ŝŶũĞĐƟŽŶǁ Ğůů͕ůĂŶĚƚƌĞĂƚŵ ĞŶƚĨĂĐŝůŝƚǇ͕ƐĂůƚĚŽŵ ĞĨŽƌŵ ĂƟŽŶ͕ƐĂůƚďĞĚĨŽƌŵ ĂƟŽŶ͕ƵŶĚĞƌŐƌŽƵŶĚŵ ŝŶĞŽƌ
cave, or placement in a concrete vault, or bunker intended for disposal purposes.
7
Waste Analysis at &ĂĐŝůŝƟĞƐƚŚĂƚ
Generate, Treat, Store, and Disposal of Hazardous Wastes: A Guidance Manual, April 1994, available at
ŚƩ Ɖ͗ͬͬǁ ǁ ǁ ͘ĞƉĂ͘ŐŽǀͬĞƉĂŽƐǁ ĞƌͬŚĂǌǁ ĂƐƚĞͬůĚƌͬǁ ĂƉϯϯϬ͘ƉĚĨ͘
May 9, 2011 Page 3 of 28

Determining whether or not LDRs apply to any given volume of contaminated soils can be
complicated. To assist facility owner/operators or program implementers, it is important to
understand the principles that govern LDR applicability for contaminated soils (see the May 26,
1998 final rule at 63 FR at 28617-18). These three principles state:
Principle 1 - > ZƐŽŶůǇĂƩ ĂĐŚƚŽƉƌŽŚŝďŝƚĞĚŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞ;ŽƌŚĂǌĂƌĚŽƵƐĐŽŶƚĂŵ ŝŶĂƚĞĚsoils) when it is: (1)

generated and (2) placed in a land disposal unit. If contaminated soils are not removed from the land, the
LDRs do not apply. Similarly, if contaminated soils are removed from the land (i.e., generated) yet never
placed in a land disposal unit, the LDRs do not apply, i.e., LDRs do not apply to contaminated soils in situ nor
do they force contaminated soils to be excavated or removed.
Principle 2 - Once a decision has been made to generate (i.e., excavate) and re-land dispose contaminated
soils, LDRs generally only apply to contaminated soils that contain hazardous waste. The Agency considers
soils ƚŽĐŽŶƚĂŝŶŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞ͗;ϭͿǁ ŚĞŶŝƚĞǆŚŝďŝƚƐĂĐŚĂƌĂĐƚĞƌŝƐƟĐŽĨŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞ͖ĂŶĚ;ϮͿǁ ŚĞŶŝƚŝƐ
8
contaminated by listed hazardous wastes.
Principle 3 - K ŶĐĞ> ZƐĂƩ ĂĐŚƚŽĂŶǇŐŝǀĞŶŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞŽƌǀŽůƵŵ ĞŽĨŚĂǌĂƌĚŽƵƐĐŽŶƚĂŵ ŝŶĂƚĞĚsoils, the

> ZƚƌĞĂƚŵ ĞŶƚƐƚĂŶĚĂƌĚƐĐŽŶƟŶƵĞƚŽĂƉƉůǇƵŶƟůƚŚĞǇĂƌĞŵ Ğƚ͘ŽŶƚĂŵ ŝŶĂƚĞĚsoils subject to the LDRs may be
treated to meet the waste-specific treatment standards at 40 CFR 268.40, or to meet the ĂůƚĞƌŶĂƟǀĞƐŽŝů
treatment standards at 40 CFR 268.49. Once the ƚƌĞĂƚŵ ĞŶƚƐƚĂŶĚĂƌĚƐĂƌĞŵ Ğƚ͕ƚƌĞĂƚĞĚĐŚĂƌĂĐƚĞƌŝƐƟĐǁ ĂƐƚĞ
may be disposed in a nonhazardous land disposal unit. For listed waste, the treated waste must be disposed in
a RCRA ^ƵďƟƚůĞůĂŶĚĚŝƐƉŽƐĂůƵŶŝƚ͘
Ʃ ĂĐŚŵ ĞŶƚŽĨƚŚŝƐĨĂĐƚƐŚĞĞƚprovides specific examples on how to comply with the

ĂůƚĞƌŶĂƟǀĞRCRA LDR treatment standards for contaminated soils.
ĞƚĞƌŵ ŝŶŝŶŐt ŚĞƚŚĞƌŽŶƚĂŵ ŝŶĂƟŽŶŝƐĂƵƐĞĚďǇĂZZŚĂƌĂĐƚĞƌŝƐƟĐŽƌ>ŝƐƚĞĚt ĂƐƚĞ
dŚĞƌĞŐƵůĂƟŽŶƐĂĚĚƌĞƐƐŝŶŐƚŚĞĂƉƉůŝĐĂƟŽŶŽĨ> ZƐƚŽsoils exhibiting ĂĐŚĂƌĂĐƚĞƌŝƐƟĐŽĨ

ŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞĂƌĞƌĞůĂƟǀĞůǇƐƚƌĂŝŐŚƞ Žƌǁ ĂƌĚ: such soils, when generated (i.e.,
excavated), are subject to the LDRs.
For soilƐƉŽƐƐŝďůǇĐŽŶƚĂŵ ŝŶĂƚĞĚǁ ŝƚŚĂůŝƐƚĞĚǁ ĂƐƚĞ͕ƚŚĞŝĚĞŶƟĮĐĂƟŽŶƉƌŽĐĞƐƐŵ ĂǇďĞĐŽŵ Ğ

more complicated. In order to determine if given contaminated soils must comply with
LDRs, ŽŶĞŵ ƵƐƚŬŶŽǁ ͗;ϭͿƚŚĞŽƌŝŐŝŶŽĨƚŚĞŵ ĂƚĞƌŝĂůĐŽŶƚĂŵ ŝŶĂƟŶŐƚŚĞsoils (i.e., hazardous
ǁ ĂƐƚĞŽƌŶŽƚŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞͿ͕;ϮͿƚŚĞĚĂƚĞƐ;ƐͿƚŚĞŵ ĂƚĞƌŝĂůǁ ĂƐƉůĂĐĞĚ;ŝ͘Ğ͕͘ďĞĨŽƌĞŽƌĂŌ Ğƌ
ƚŚĞĞīĞĐƟǀĞĚĂƚĞŽĨƚŚĞĂƉƉůŝĐĂďůĞůĂŶĚĚŝƐƉŽƐĂůƉƌŽŚŝďŝƟŽŶͿ͕ĂŶĚ;ϯͿǁ ŚĞƚŚĞƌƚŚĞsoils ƐƟůů
contain hazardous waste (i.e., a contained-in decision).
8
The contained-in principle -ƐƚĂŶĚŝŶŐŝŶƚĞƌƉƌĞƚĂƟŽŶ ƌĞŐĂƌĚŝŶŐĂƉƉůŝĐĂƟŽŶŽĨthe RCRA
^ƵďƟƚůĞƌĞƋƵŝƌĞŵ ĞŶƚƐƚŽmixtures of contaminated media and hazardous wastes. Under the contained-in-policy,
EPA requires that soil, although not waste itself, be managed as if it were hazardous waste if it contains hazardous
waste or exhibits ĂĐŚĂƌĂĐƚĞƌŝƐƟĐŽĨŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞ;ϲϯ&ZĂƚϮϴϲϮϭ͕D ĂǇϮϲ͕ϭϵϵϴͿ͘/ŶƉƌĂĐƟĐĞWŚĂƐĂƉƉůŝĞĚ
the contained-in principle to refer to a process where a site-ƐƉĞĐŝĮĐĚĞƚĞƌŵ ŝŶĂƟŽŶĐĂŶďĞŵ ĂĚĞƚŚĂƚ
ĐŽŶĐĞŶƚƌĂƟŽŶƐŽĨŚĂǌĂƌĚŽƵƐĐŽŶƐƟƚƵĞŶƚƐŝŶĂŶǇŐŝǀĞŶǀŽůƵŵ ĞŽĨĞŶǀŝƌŽŶŵ ĞŶƚĂůŵ ĞĚŝĂ;Ğ͘Ő͕͘ƐŽŝůƐͿĂƌĞůŽǁ ĞŶŽƵŐŚ
May 9, 2011 Page 4 of 28

Facility owner/operators and program implementers should make a good faith effort to
determine if a material is contaminated by listed hazardous waste and ascertain the dates
of placement. The Agency believes that by using available site- and waste-specific
ŝŶĨŽƌŵ ĂƟŽŶ, such as manifests, vouchers, bills of lading, sales and inventory records,
ƐƚŽƌĂŐĞƌĞĐŽƌĚƐ͕ƐĂŵ ƉůŝŶŐĂŶĚĂŶĂůǇƐŝƐƌĞƉŽƌƚƐ͕ƐŝƚĞŝŶǀĞƐƟŐĂƟŽŶƌĞƉŽƌƚƐ͕ƐƉŝůůƌĞƉŽƌƚƐ͕
ŝŶƐƉĞĐƟŽŶƌĞƉŽƌƚƐĂŶĚůŽŐƐ͕ĂŶĚĞŶĨŽƌĐĞŵ ĞŶƚŽƌĚĞƌƐĂŶĚƉĞƌŵ ŝƚƐ͕ƚŚĞƐĞĚĞƚĞƌŵ ŝŶĂƟŽŶƐ
ŵ ĂǇďĞŵ ĂĚĞ͘, Žǁ ĞǀĞƌ͕ŝĨĚŽĐƵŵ ĞŶƚĂƟŽŶƌĞŐĂƌĚŝŶŐĂƐŽƵƌĐĞŽĨĐŽŶƚĂŵ ŝŶĂƟŽŶ͕
contaminant, or waste is unavailable or inconclusive, EPA has stated that one may assume
the source, contaminant or waste is not a listed hazardous waste. Therefore, provided the
ŵ ĂƚĞƌŝĂůŝŶƋƵĞƐƟŽŶĚŽĞƐŶŽƚĞǆŚŝďŝƚĂĐŚĂƌĂĐƚĞƌŝƐƟĐŽĨŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞƐ, the RCRA
hazardous waste requirements (including LDRs) do not apply (see 61 FR 18805, April 29,
1996).
Time of Waste Disposal and RCRA LDR Applicability
The LDRs do not apply to soils contaminated with hazardous waste that were placed on the
ůĂŶĚďĞĨŽƌĞƚŚĞĞī ĞĐƟǀĞĚĂƚĞƐŽĨƚŚĞĂƉƉůŝĐĂďůĞůĂŶĚĚŝƐƉŽƐĂůƉƌŽŚŝďŝƟŽŶƐ͘/ĨƚŚĞ
ĚĞƚĞƌŵ ŝŶĂƟŽŶŝƐŵ ĂĚĞƚŚĂƚƚŚĞĐŽŶƚĂŵ ŝŶĂƟŶŐǁ ĂƐƚĞǁ ĂƐƉůĂĐĞĚŽŶƚŚĞůĂŶĚďĞĨŽƌĞthe
Ğī ĞĐƟǀĞĚĂƚĞ, and if the soils are determined not to contain hazardous waste before they
are removed from the land (i.e., excavated), then the soils can be managed as non-
hazardous contaminated media and are not subject to LDRs (see 61 FR at 18805, April 29,
1996). Given the contained-ŝŶƉŽůŝĐǇ͕ƚŚĞĚĞƚĞƌŵ ŝŶĂƟŽŶŽĨǁ ŚĞƚŚĞƌ> ZƐĂƉƉůǇĂŶĚ
ǁ ŚĞƚŚĞƌƚŚĞǁ ĂƐƚĞƐƟůůĐŽŶƚĂŝŶƐthe ŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞǁ ŝůůďĞĐƌŝƟĐĂůƚŽƚŚŝƐĚĞĐŝƐŝŽŶ͘
ŽŶƐƟƚƵĞŶƚƐ^ƵďũĞĐƚƚŽdƌĞĂƚŵ ĞŶƚh ƐŝŶŐƚŚĞůƚĞƌŶĂƟǀĞSoil Treatment Standards
All contaminated soils subject to the LDRs (i.e., the contaminated soils either exhibit a
hazardous waste ĐŚĂƌĂĐƚĞƌŝƐƟĐŽƌare contaminated with a RCRA listed waste and
hazardous waste) must be treated to achieve the soils treatment standards for each UHC
reasonably expected to be present in the soils ĂƚŐĞŶĞƌĂƟŽŶ;ŝ͘Ğ͕͘ĞǆĐĂǀĂƟŽŶͿǁ ŚĞŶƐƵĐŚ
ĐŽŶƐƟƚƵĞŶƚƐĂƌĞŝŶŝƟĂůůǇĨŽƵŶĚĂƚĐŽŶĐĞŶƚƌĂƟŽŶƐŐƌĞĂƚĞƌƚŚĂŶƚĞŶƟŵ ĞƐh d^͘
/ŶĂĚĚŝƟŽŶƚŽƚƌĞĂƚŵ ĞŶƚŽĨĂůůh , Ɛ reasonably expected to be present in the soils at

ŐĞŶĞƌĂƟŽŶ, soils exhibiting a hazardous waste ĐŚĂƌĂĐƚĞƌŝƐƟĐ must also be treated, in the
case of ƚŽǆŝĐŝƚǇĐŚĂƌĂĐƚĞƌŝƐƟĐ;TC) soils͕ĨŽƌƚŚĞdĐŽŶƐƟƚƵĞŶƚs, and in the case of ignitable,
ĐŽƌƌŽƐŝǀĞŽƌƌĞĂĐƟǀĞsoils, for the applicable ĐŚĂƌĂĐƚĞƌŝƐƟĐƉƌŽƉĞƌƚǇ͘
Generators of contaminated soils can reasonably apply knowledge of the likely

contaminants present and use that knowledge to select the appropriate UHCs or classes of
ĐŽŶƐƟƚƵĞŶƚƐĨŽƌŵ ŽŶŝƚŽƌŝŶŐ͘dŚŝƐapproach is consistent with those EPA typically takes in
remedial programs, where the Agency Ğŵ ƉŚĂƐŝǌĞƐƚŚĂƚƌĞŵ ĞĚŝĂƟŽŶŵ ĂŶŐĞƌƐƐŚŽƵůĚĨŽĐƵƐ
ŝŶǀĞƐƟŐĂƟŽŶƐŽŶĐŽŶƐƟƚƵĞŶƚƐŽĨĐŽŶĐĞƌŶĂŶĚǁ ŝƚŚƌĞŐƵůĂƟŽŶƐƚŚĂƚĂůůŽǁ ŐĞŶĞƌĂƚŽƌƐƚŽƌĞůǇ
on knowledge to determine whether any given solid waste is hazardous.
Finally, if using the ĂůƚĞƌŶĂƟǀĞƐŽŝůtreatment standards, any treatment residues generated

must also be treated to meet any other applicable LDR standards.
May 9, 2011 Page 5 of 28
Do I Have to Comply With RCRA LDRs?9
If LDRs And if LDRs And if Then you

Applied to the listed waste Apply to the listed Must comply with LDRs
when it contaminated the soil waste now
Apply to the listed The soil is determined to Must comply with LDRs
when it contaminated the soil waste now contain the listed waste
when the soil is first
generated.
10
Apply to the listed The soil is determined not
when it contaminated the soil waste now to contain the listed
waste when the soil is
first generated.
when it contaminated the soil listed waste now
Variances from the Soils Treatment Standards at Risk-Based Levels
ƐƉĂƌƚŽĨƚŚĞƌƵůĞĞƐƚĂďůŝƐŚŝŶŐĂůƚĞƌŶĂƟǀĞƚƌĞĂƚŵ ĞŶƚƐƚĂŶĚĂƌĚƐĨŽƌsoils, EPA established a

site-specific variance from the LDR treatment standards. The variance can be used when
ƚƌĞĂƚŵ ĞŶƚƚŽĐŽŶĐĞŶƚƌĂƟŽŶƐŽĨŚĂǌĂƌĚŽƵƐĐŽŶƐƟƚƵĞŶƚƐŐƌĞĂƚĞƌ;ŝ͘Ğ͕͘ŚŝŐŚĞƌͿƚŚĂŶƚŚŽƐĞ
specified in the soils treatment standards minimizes short- and long-term threats to human
health and the environment (See 40 CFR 268.44(h)). In this way, on a case-by case basis,
risk-based LDR treatment standards approved through a variance process (see 40 CFR
268.44) could supersede the technology-based soils treatment standards. (The reader is
ƌĞĨĞƌƌĞĚƚŽϰϬ&ZϮϲϴ͘ϰϰĨŽƌĂĚĚŝƟŽŶĂůŝŶĨŽƌŵ ĂƟŽŶŽŶƚƌĞĂƚŵ ĞŶƚǀĂƌŝĂŶĐĞƐĂŶĚŝŶ
ƉĂƌƟĐƵůĂƌƚŚŽƐĞǀĂƌiances that pertain directly to contaminated soils.)
dŚĞŐĞŶĐǇŝƐƌĞƋƵŝƌŝŶŐƚŚĂƚŵ ŝŶŝŵ ŝǌĞƚŚƌĞĂƚǀĂƌŝĂŶĐĞĚĞƚĞƌŵ ŝŶĂƟŽŶƐĨŽƌĐŽŶƚĂŵ ŝŶĂƚĞĚsoils

ďĞĞǀĂůƵĂƚĞĚƵƐŝŶŐƚŚĞĞǆŝƐƟŶŐƐŝƚĞ-specific variance process set out in 40 CFR 268.44(h).
Variances cannot be approved without the ŽƉƉŽƌƚƵŶŝƚǇĨŽƌƉƵďůŝĐƉĂƌƟĐŝƉĂƟŽŶ͕ŝŶĐůƵĚŝŶŐ
ŶŽƟĐĞďǇĂƉƉƌŽƉƌŝĂƚĞŵ ĞĂŶƐ͕ŽƉƉŽƌƚƵŶŝƚǇĨŽƌƉƵďůŝĐĐŽŵ ŵ ĞŶƚĂŶĚĂĚĞƋƵĂƚĞĞǆƉůĂŶĂƟŽŶŽĨ
ĂŶƵůƟŵ ĂƚĞĚĞƚĞƌŵ ŝŶĂƟŽŶ;ƐĞĞϲϯ&ZĂƚϮϴϲϬϳ;D ĂǇϮϲ͕ϭϵϵϴͿͿ͘
WĂŶƟĐŝƉĂƚĞƐƚŚĂƚĚĞĐŝƐŝŽŶƐabout site-specific minimize threat variances ǁ ŝůůŽŌ ĞŶďĞ

combined with decisions that soils no longer contains hazardous waste. Agency guidance
- -
specific risk-based miŶŝŵ ŝǌĞƚŚƌĞĂƚĚĞƚĞƌŵ ŝŶĂƟŽŶƐ;ϲϯ&ZĂƚϮϴϲϬϳ;D ĂǇϮϲ͕ϭϵϵϴͿ͘&ŽƌƚŚĂƚ
9
dŚĞƌĞĂĚĞƌŝƐĂůƐŽƌĞĨĞƌƌĞĚƚŽƩ ĂĐŚŵ ĞŶƚǁ ŚŝĐŚƉƌŽǀŝĚĞƐĞǆĂŵ ƉůĞƐŽĨĂƉƉůǇŝŶŐthe aůƚĞƌŶĂƟǀĞLDR treatment
standards for contaminated soils.
10
This includes no requirement ƚŽĚŝƐƉŽƐĞŝŶĂZZ^ƵďƟƚůĞƵŶŝƚ;ƐĞĞϲϯ&ZϮϴϲϭϴ͕D ĂǇϮϲ͕ϭϵϵϴͿ. Whether or
not LDRs apply to contaminated soils ŝƐŐŽǀĞƌŶĞĚďǇĂĚĞƚĞƌŵ ŝŶĂƟŽŶŽĨǁ ŚĞƚŚĞƌĂŶǇŐŝǀĞŶǀŽůƵŵ ĞŽĨĐŽŶƚĂŵ ŝŶĂƚĞĚ
soils soils is determined to contain
ŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞĂƚŝƚƐƉŽŝŶƚŽĨŐĞŶĞƌĂƟŽŶ͕> ZƐĂƩ ĂĐŚ;ƉƌŝŶĐŝƉle 1 and 2, and therefore, the LDR treatment
standards must be met prior to placement of such soils in a land disposal unit (principle 3). If any given volume of
soils ŝƐĚĞƚĞƌŵ ŝŶĞĚŶŽƚƚŽĐŽŶƚĂŝŶŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞĂƚŝƚƐƉŽŝŶƚŽĨŐĞŶĞƌĂƟŽŶ͕ƚŚĞƌĞŝƐŶŽŚĂzardous waste to which a
ůĂŶĚĚŝƐƉŽƐĂůƉƌŽŚŝďŝƟŽŶĐŽƵůĚĂƩ ĂĐŚĂŶĚƚŚĞsoils thus, would not be prohibited from land disposal.
May 9, 2011 Page 6 of 28

reason, EPA believes it will always be appropriate, though not required (see 63 FR at 28620
(May 26, 1998)) to combine a contained-ŝŶĚĞƚĞƌŵ ŝŶĂƟŽŶǁ ŝƚŚĂƐŝƚĞ-specific risk-based
minimize threat variance. In these cases, EPA encourages program implementers and
-
ƉƵďůŝĐŶŽƟĐĞŽĨƚŚĞǀĂƌŝĂŶĐĞ͘
In cases where a site-specific minimize threat variance is combined with a decision that the
soils no longer contain hazardous waste due to achieving the treatment standard imposed
by the variance), the soils could be managed including land disposed without further
ĐŽŶƚƌŽůƵŶĚĞƌZZ^ƵďƟƚůĞ͘(see 63 FR at 28607 [May 26, 1998]).
Site-ƐƉĞĐŝĮĐĚĞƚĞƌŵ ŝŶĂƟŽŶƐƚŚĂƚƚŚƌĞĂƚƐĂƌĞŵ ŝŶŝŵ ŝǌĞĚĐĂŶŶŽƚďĞďĂƐĞĚŽŶƚŚĞƉŽƚĞŶƟĂů

safety of land disposal units or engineered structures, such as liners, caps, slurry walls, or
ĂŶǇŽƚŚĞƌƉƌĂĐƟĐĞŽĐĐƵƌƌŝŶŐĂŌ ĞƌůĂŶĚĚŝƐƉŽƐĂů͘;ϲϯ&ZĂƚϮϴϲϬϳ;D ĂǇϮϲ͕ϭϵϵϴͿ͘
dŚĞƌĞĂĚĞƌŝƐƌĞĨĞƌƌĞĚƚŽƩ ĂĐŚŵ ĞŶƚŽĨƚŚŝƐĨĂĐƚƐŚĞĞƚĨŽƌŐĞŶĞƌĂůŝŶĨŽƌŵ ĂƟŽŶŽŶƚŚĞZZ> Z

program.
Applicability of RCRA LDRs to Dioxin Contaminated Soils
ƉƉůŝĐĂƟŽŶŽĨƚŚĞƐĂŵ ĞƚŚƌĞĞLDR applicability principles will determine whether dioxin-

contaminated soils are subject to requirements. (LDRs may be applicable for waste
disposed of on site or off site.)
Principle 1 > ZƐŽŶůǇĂƩ ĂĐŚƚŽĚŝŽǆŝŶ-contaminated soils when they are: (1) generated (i.e., excavated) and
(2) placed in a land disposal unit. If the dioxin- contaminated soils are not removed from the land, LDRs do not
apply. Similarly, if dioxin-contaminated soils are removed from the land (i.e., generated) yet never placed in a
land disposal unit, LDRs do not apply; that is, LDRs do not apply to dioxin-contaminated soils in situ and they
11
do not require soils to be excavated or removed. If contaminated soils are managed in an area of
soils would not be
considered generated, and the LDR treatment requirements do not apply.
Principle 2 - Once a decision has been made to generate (i.e., excavate) and re-land dispose the dioxin-
contaminated soils, LDRs only apply to dioxin-contaminated soils that contain hazardous waste. The Agency
considers dioxin-contaminated soils to contain hazardous ǁ ĂƐƚĞ͗;ϭͿǁ ŚĞŶŝƚĞǆŚŝďŝƚƐĂĐŚĂƌĂĐƚĞƌŝƐƟĐŽĨ
hazardous waste; or (2) when it is contaminated with listed hazardous wastes.
-- If dioxin-contaminated soils ĚŽŶŽƚĞǆŚŝďŝƚĂŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞĐŚĂƌĂĐƚĞƌŝƐƟĐ͕> ZƐĚŽŶŽƚĂƉƉůǇ͘

-- If dioxin-contaminated soils ĐĂŶŶŽƚďĞůŝŶŬĞĚƚŚƌŽƵŐŚĚŽĐƵŵ ĞŶƚĂƟŽŶƚŽĂůŝƐƚĞĚǁ ĂƐƚĞ͕> ZƐĚŽŶŽƚĂƉƉůǇ͘
11
' ƵŝĚĂŶĐĞŽŶ Ğŵ ŽŶƐƚƌĂƟŶŐŽŵ ƉůŝĂŶĐĞǁ ŝƚŚƚŚĞ>ĂŶĚ ŝƐƉŽƐĂůZĞƐƚƌŝĐƟŽŶƐ;> ZͿůƚĞƌŶĂƟǀĞ^ŽŝůdƌĞĂƚŵ ĞŶƚ
Standard Final Guidance. July 2002. EPA530-R-02-003. (AOC) policy. Because an AOC
is equated to a RCRA land-ďĂƐĞĚƵŶŝƚ͕ĐŽŶƐŽůŝĚĂƟŽŶĂŶĚin situ treatment of hazardous waste within the AOC do
ŶŽƚĐƌĞĂƚĞĂŶĞǁ ƉŽŝŶƚŽĨŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞŐĞŶĞƌĂƟŽŶĨŽƌƉƵƌƉŽƐĞŽĨZZ͘dŚŝƐŝŶƚĞƌƉƌĞƚĂƟŽŶĂůůŽǁ Ɛǁ ĂƐƚĞƐƚŽ
be consolidated or treated in situ within an AOC without triggering the ůĂŶĚĚŝƐƉŽƐĂůƌĞƐƚƌŝĐƟŽŶƐŽƌŵ ŝŶŝŵ Ƶŵ
technology requirements.
May 9, 2011 Page 7 of 28

If it is determined that the dioxin-contaminated soils can be linked to any of the following waste codes, F020,
12
F021, F022, F023, F026, F027, F028 , F032, F039, K043, K099, K174, and K178, LDRs may apply. These waste
ĐŽŶƐƟƚƵĞŶƚƐƌĞƋƵŝƌŝŶŐƚƌĞĂƚŵ ĞŶƚƉƌŝŽƌƚŽůĂŶĚĚŝƐƉŽƐĂůƵŶĚĞƌƚŚĞ> ZƉƌŽŐƌĂŵ ;^ĞĞƩ ĂĐŚŵ ĞŶƚB). If the

dioxin-contaminated soils ĐĂŶďĞůŝŶŬĞĚƚŽĂůŝƐƚĞĚŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞ͕ĚĞƚĞƌŵ ŝŶĂƟŽŶƐŵ ƵƐƚƚŚĞŶďĞŵ ĂĚĞŽŶ
whether (1) LDRs are applicable to the listed waste; and (2) whether the dioxin-contaminated soils contained
the listed hazardous waste when they were ĮƌƐƚŐĞŶĞƌĂƚĞĚ;ŝ͘Ğ͕͘ĞǆĐĂǀĂƚĞĚͿ͘/ĨďŽƚŚƚŚĞƐĞĚĞƚĞƌŵ ŝŶĂƟŽŶƐĂƌĞ
ŝŶƚŚĞĂĸ ƌŵ ĂƟǀĞ͕> ZƐĂƉƉůǇ͘
Principle 3 - K ŶĐĞ> ZƐĂƩ ĂĐŚƚŽĂŶǇĚŝŽǆŝŶ-contaminated soils͕> ZƚƌĞĂƚŵ ĞŶƚƐƚĂŶĚĂƌĚƐĐŽŶƟŶƵĞƚŽĂƉƉůǇ

ƵŶƟůƚŚĞǇĂƌĞŵ Ğƚ͕ƵŶůĞƐƐĂƚƌĞĂƚŵ ĞŶƚǀĂƌŝĂŶĐĞŝƐŐƌĂŶƚĞĚ;ϰϬ&ZϮϲϴ͘ϰϰͿ͘
If the generated dioxin-contaminated soils are a ĐŚĂƌĂĐƚĞƌŝƐƟĐ hazardous waste, using the ĂůƚĞƌŶĂƟǀĞƐŽŝů
treatment standards, the soils ŵ ƵƐƚďĞƚƌĞĂƚĞĚĨŽƌƚŚĞĐŚĂƌĂĐƚĞƌŝƐƟĐ ĐŽŶƐƟƚƵĞŶƚ, as well as any other
ƵŶĚĞƌůǇŝŶŐŚĂǌĂƌĚŽƵƐĐŽŶƐƟƚƵĞŶƚƐƌĞĂƐŽŶĂďůǇĞǆƉĞĐƚĞĚƚŽďĞƉƌĞƐĞŶƚĂďŽǀĞϭϬƟŵ ĞƐthe UTS (e.g., 10 ppb for
ƚŚĞǀĂƌŝŽƵƐĚŝŽǆŝŶƐĂŶĚĨƵƌĂŶƐŝĚĞŶƟĮĞĚŝŶϮϲϴ͘ϰϬ͘ͿŌ ĞƌƚƌĞĂtment is achieved, the contaminated soils may
be disposed in a nonhazardous waste disposal unit.
If it is determined that the dioxin-contaminated soils are ůŝŶŬĞĚƚŚƌŽƵŐŚĚŽĐƵŵ ĞŶƚĂƟŽŶƚŽĂůŝƐƚĞĚŚĂǌĂƌĚŽƵƐ

waste prohibited from land disposal and has been determined to contain the listed hazardous waste, then
using the ĂůƚĞƌŶĂƟǀĞƐŽŝůtreatment standards, the dioxin-contaminated soils must be treated for all UHCs
ƌĞĂƐŽŶĂďůǇĞǆƉĞĐƚĞĚƚŽďĞƉƌĞƐĞŶƚĂƚůĞǀĞůƐĂďŽǀĞϭϬƟŵ ĞƐh d^͘;E ŽƚĞ͗The requirement for listed hazardous
waste to treat for all UHCs under the ĂůƚĞƌŶĂƟǀĞƐŽŝůtreatment standards is a more comprehensive
requirement than what is required for - industrial listed hazardous waste found in 40 CFR
268.40, which only requires treatment for not all UHCs reasonably
ĞǆƉĞĐƚĞĚƚŽďĞƉƌĞƐĞŶƚ;ĂƌĞƋƵŝƌĞŵ ĞŶƚƌĞƐĞƌǀĞĚŽŶůǇĨŽƌĐŚĂƌĂĐƚĞƌŝƐƟĐǁ ĂƐƚĞƐ͘Ϳ
Ʃ ĂĐŚŵ ĞŶt C contains

ŚĂǌĂƌĚŽƵƐĐŽŶƐƟƚƵĞŶƚƐƌĞƋƵŝƌŝŶŐƚƌĞĂƚŵ ĞŶƚƵŶĚĞƌƚŚĞZZ> ZƉƌŽŐƌĂŵ ͘
12
&ϬϮϴŝƐĚĞĮŶĞĚĂƐƌĞƐŝĚƵĞƐƌĞƐƵůƟŶŐĨƌŽŵ ƚŚĞŝŶĐŝŶĞƌĂƟŽŶŽƌƚŚĞƌŵ ĂůƚƌĞĂƚŵ ĞŶƚŽĨsoils contaminated with EPA
hazardous waste F020, F021, F022, F023, F026 and F027. It is unclear whether soils contaminated with F028 would
exist.
May 9, 2011 Page 8 of 28

RCRA Requirements for Dioxin-Listed Wastes (F020-F023 and F026-F028)
dŚĞ ŝŽǆŝŶ>ŝƐƟŶŐZƵůĞǁ ĂƐƉƌŽŵ ƵůŐĂƚĞĚŽŶ:ĂŶƵĂƌǇϭϰ͕ϭϵϴϱ;ϱϬ&ZϭϵϴϳͿ͘dŚŝƐƌĞŐƵůĂƟŽŶ

ĚĞƐŝŐŶĂƚĞƐĐĞƌƚĂŝŶǁ ĂƐƚĞƐĐŽŶƚĂŝŶŝŶŐƉĂƌƟĐƵůĂƌĐŚůŽƌŝŶĂƚĞĚĚŝďĞŶǌŽ-p-dioxin (CDDs),
chlorinated dibenzofurans (CDFs), and chlorinated phenols as acute hazardous waste. See
ZZŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞůŝƐƟŶŐƐ&ϬϮϬ-F023, F026-F028.
The rule also establishes stringent RCRA management standards for these wastes. The
following criteria must be met in order to handle the listed dioxin-containing wastes:
Land disposal facilŝƟĞƐ͗- landfills, waste piles, surface impoundments and land treatment
ĨĂĐŝůŝƟĞƐŵ ƵƐƚĐŽŵ ƉůǇǁ ŝƚŚthe WĂƌƚϮϲϰƌĞƋƵŝƌĞŵ ĞŶƚƐĂŶĚĂĚĚŝƟŽŶĂůůǇƉƌŽǀŝĚĞĂŶ
acceptable waste management plan for the listed wastes ( see applicable standards in 40
CFR 264).
, ĂǌĂƌĚŽƵƐǁ ĂƐƚĞĐŽŵ ďƵƐƟŽŶƵŶŝƚƐ a hazardous waste combustor, as defined in 40 CFR
63.1201, must comply with standards for controlling emissions of hazardous air pollutants if
it burns RCRA hazardous waste. These standards are codified in 40 CFR part 63, Subpart
EEE. If a hazardous waste combustor elects to burn a dioxin-listed waste, Subpart EEE
requires that the combustor achieve a (more stringent) ĚĞƐƚƌƵĐƟŽŶĂŶĚƌĞŵ ŽǀĂůĞĸ Đŝency
(DRE) of at least 99.9999 percent. This requirement is codified in paragraph (c) for the
ĂƉƉůŝĐĂďůĞĐĂƚĞŐŽƌǇŽĨŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞĐŽŵ ďƵƐƚŽƌŝŶ^ĞĐƟŽŶƐϲϯ͘ϭϮϭϲƚŚƌŽƵŐŚϲϯ͘ϭϮϮϭ͘/Ŷ
ĂĚĚŝƟŽŶ͕ŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞĐŽŵ ďƵƐƚŽƌƐĂƌĞĂůƐŽƐƵďũĞĐƚƚŽĂƉƉůŝĐĂďůĞƌĞƋƵŝƌĞŵ ĞŶƚƐƵŶĚĞƌϰϬ
CFR parts 260 through 270. Ʃ ĂĐŚŵ ĞŶƚD of this fact sheet contains a list of commercial
ŝŶĐŝŶĞƌĂƚŽƌƐĂŶĚůĂŶĚĮůůƐƚŚĂƚĂƌĞƉĞƌŵ ŝƩ ĞĚĂŶĚĂĐƟǀĞůǇmanaging RCRA contaminated
soils. While these ĨĂĐŝůŝƟĞƐŵ ĂǇ ŶŽƚďĞƐƉĞĐŝĮĐĂůůǇƉĞƌŵ ŝƩ ĞĚƚŽƚƌĞĂƚĚŝŽǆŝŶ-contaminated
soils, it provides a compreŚĞŶƐŝǀĞůŝƐƚĨƌŽŵ ǁ ŚŝĐŚƚŽŝĚĞŶƟĨǇƉŽƚĞŶƟĂůƚƌĞĂƚŵ ĞŶƚĨĂĐŝůŝƟĞƐ.
Complying With the RCRA LDR Treatment Standard for Dioxin-Contaminated

Soils
Example 1 - Soils were contaminated with F020 waste. Based on sampling of the contaminated soils, it
was determined that they contained 1.5 mg/kg of hexachlorodibenzofurans.
Waste-specific treatment standard. The waste-specific treatment standard for

hexachlorodibenzofurans in F020 waste is 0.001 mg/kg (nonwastewater).
ůƚĞƌŶĂƟǀĞsoil treatment standards. The ĂůƚĞƌŶĂƟǀĞƐŽŝůtreatment standards mandate the

ƌĞĚƵĐƟŽŶŽĨŚĞǆĂĐŚůŽƌŽĚŝďĞŶǌŽĨƵƌĂŶƐŝŶƚŚĞsoils ďǇϵϬƉĞƌĐĞŶƚŽƌƚĞŶƟŵ ĞƐƚŚĞh d^͕ǁ ŚŝĐŚĞǀĞƌŝƐ
ŚŝŐŚĞƌ͘ZĞĚƵĐƟŽŶŽĨϭ͘ϱŵ ŐͬŬŐŽĨŚĞǆĂĐŚůŽƌŽĚŝďĞŶǌŽĨƵƌĂŶƐŝŶƚŚĞsoils by 90 percent would mean
ƚƌĞĂƟŶŐƚŚĞĐŽŶƚĂŵ ŝŶĂƚĞĚsoils to 0.15 mg/kg. The UTS for hexachlorodibenzofurans is 0.001 mg/kg
;ŶŽŶǁ ĂƐƚĞǁ ĂƚĞƌͿ͕ƐŽϭϬƟŵ ĞƐƚŚĞh d^ǁ ŽƵůĚďĞϬ͘Ϭϭŵ ŐͬŬŐ͘
A facility may treat the contaminated soils to meet the waste-specific treatment standard, or to meet
the ĂůƚĞƌŶĂƟǀĞƐŽŝůƚƌĞĂƚŵ ĞŶƚƐƚĂŶĚĂƌĚƐ͘/ŶƚŚŝƐƉĂƌƟĐƵůĂƌĐĂƐĞ͕ƚŚĞĨĂĐŝůŝƚǇǁ ŽƵůĚůŝŬĞůǇƐĞůĞĐƚƚŚĞ
ĂůƚĞƌŶĂƟǀĞƐŽŝůtreatment standard of 0.15 mg/kg, since it is significantly higher than the waste-
specific treatment standard of 0.001 mg/kg.
May 9, 2011 Page 9 of 28

Example 2 - Soils were contaminated with F027 waste. Based on sampling of the contaminated soils, it
was determined that they contained 100 mg/kg of pentachlorophenol.
Waste-specific treatment standard. The waste-specific treatment standard for pentachlorophenol in

F027 waste is 7.4 mg/kg (nonwastewater).
ůƚĞƌŶĂƟǀĞsoil treatment standards. The ĂůƚĞƌŶĂƟǀĞƐŽŝůtreatment standards mandate the

ƌĞĚƵĐƟŽŶŽĨƉĞŶƚĂĐŚůŽƌŽƉŚĞŶŽůŝŶƚŚĞsoils by 90 percent ŽƌƚĞŶƟŵ ĞƐƚŚĞh d^͕ǁ ŚŝĐŚĞǀĞƌŝƐŚŝŐŚĞƌ͘
ZĞĚƵĐƟŽŶŽĨϭϬϬ mg/kg of pentachlorophenol in the soils ďǇϵϬƉĞƌĐĞŶƚǁ ŽƵůĚŵ ĞĂŶƚƌĞĂƟŶŐƚŚĞ
contaminated soils to 10 mg/kg. The UTS for pentachlorophenol is 7.4 mg/kg (nonwastewater), so
ϭϬƟŵ ĞƐƚŚĞh d^ǁ ŽƵld be 74 mg/kg.
A facility may treat the contaminated soils to meet the waste-specific treatment standard, or to meet the
ĂůƚĞƌŶĂƟǀĞƐŽŝůƚƌĞĂƚŵ ĞŶƚƐƚĂŶĚĂƌĚƐ͘/ŶƚŚŝƐƉĂƌƟĐƵůĂƌĐĂƐĞ͕ƚŚĞĨĂĐŝůŝƚǇǁ ŽƵůĚůŝŬĞůǇƐĞůĞĐƚƚŚĞĂůƚĞƌŶĂƟǀĞ
soil treatment standard of 74 mg/kg, since it is significantly higher than the waste-specific treatment
standard of 7.4 mg/kg.
AƩ ĂĐŚŵ ĞŶƚE of this fact sheet ŝĚĞŶƟĮĞƐLDR treatment standards for the specific dioxin-
containing listed hazardous waste.
Disposal of Soils Containing Dioxin Not Subject to RCRA Requirements
For soils that contain dioxin, but are not hazardous waste under RCRA or under state waste
ƌĞŐƵůĂƟŽŶƐ͕ƚŚĞĨŽůůŽǁ ŝŶŐƐƚĞƉƐǁ ŽƵůĚĂƉƉůǇ͗
The dioxin-containing soils can be disposed of in any nonhazardous land disposal unit,
ŝŶĐůƵĚŝŶŐŵ ƵŶŝĐŝƉĂůŽƌŝŶĚƵƐƚƌŝĂůůĂŶĚĮůůƐ͕ƚŚĂƚŝƐƉĞƌŵ ŝƩ ĞĚƚŽĂĐĐĞƉƚƚŚĞǁ ĂƐƚĞ͘
For Superfund cleanups with off-ƐŝƚĞĚŝƐƉŽƐĂů͕ĨĂĐŝůŝƟĞƐĂĐĐĞƉƟŶŐĚŝŽǆŝŶĐŽŶƚĂŝŶŝŶŐsoils that

are not hazardous waste must be in compliance with the off-site rule.
In many cases, the contaminated soils ǁ ŝůůďĞƐĞŶƚƚŽĂ^ƵďƟƚůĞ ůĂŶĚĮůů͖ŚŽǁ ĞǀĞƌ͕ƚŚĞƌĞ

may be instances where, due to significant levels of dioxin in the soils, the decision is made
to dispose of the contaminated soils ŝŶĂ^ƵďƟƚle C landfill.
May 9, 2011 Page 10 of 28

ATTACHMENTS
May 9, 2011 Page 11 of 28

Ʃ ĂĐŚŵ ĞŶƚ
Examples of Complying With the RCRA LDR Treatment Standard for Contaminated Soils
EXAMPLE 1 - ' ĞŶĞƌĂƚŽƌŝƐĞǆĐĂǀĂƟŶŐsoils mildly contaminated with wastewater treatment sludge F006. The
sludge was land disposed before 1980. The soils ĚŽŶŽƚĞǆŚŝďŝƚĂĐŚĂƌĂĐƚĞƌŝƐƟĐŽĨŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞĂŶĚŚĂƐ
been determined by an authorized state not to contain listed hazardous waste. The soils are not prohibited
from land disposal͘dŚŝƐŝƐďĞĐĂƵƐĞ͕ĨŽƌ> ZƉƵƌƉŽƐĞƐ͕ƚŚĞƉŽŝŶƚŽĨŐĞŶĞƌĂƟŽŶŝƐǁ ŚĞŶƚŚĞsoils are first
ĞǆĐĂǀĂƚĞĚĨƌŽŵ ƚŚĞůĂŶĚ;ƉƌŝŶĐŝƉůĞϭͿͿ͘^ŝŶĐĞŶŽƉƌŽŚŝďŝƚĞĚŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞĞǆŝƐƚĞĚďĞĨŽƌĞƚŚĂƚƟŵ Ğ;ŝ͘Ğ͕͘ƚŚĞ
contaminating waste was not prohibited) and the soils do not contain listed hazardous waste or exhibit a
ĐŚĂƌĂĐƚĞƌŝƐƟĐŽĨŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞĂƚŝƚƐƉŽŝŶƚŽĨŐĞŶĞƌĂƟŽŶ͕ƚŚĞƌĞŝƐŶŽŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞƚŽǁ ŚŝĐŚĂůĂŶĚ
ĚŝƐƉŽƐĂůƉƌŽŚŝďŝƟŽŶĐŽƵůĚĂƩ ĂĐŚ;WƌŝŶĐŝƉůĞϮͿ͘
EXAMPLE 2 - ' ĞŶĞƌĂƚŽƌŝƐĞǆĐĂǀĂƟŶŐsoils contaminated by leaks from a closing hazardous waste surface
ŝŵ ƉŽƵŶĚŵ ĞŶƚ͘dŚĞƐƵƌĨĂĐĞŝŵ ƉŽƵŶĚŵ ĞŶƚƌĞĐĞŝǀĞĚůŝƐƚĞĚŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞ<ϬϲϮĂŶĚĐŚĂƌĂĐƚĞƌŝƐƟĐŚĂǌĂƌĚŽƵƐ
waste D018. The surface impoundment stopped receiving K062 in 1987 and D018 in 1993. The soils do not
ĞǆŚŝďŝƚĂĐŚĂƌĂĐƚĞƌŝƐƟĐĂŶĚŚĂƐďĞĞŶĚĞƚĞƌŵ ŝŶĞĚďǇĂŶĂƵƚŚŽƌŝǌĞĚƐƚĂƚĞŶŽƚƚŽĐŽŶƚĂŝŶůŝƐƚĞĚŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞ͘
The soils are not prohibited from land disposal. This is because, for LDR purposes, thĞƉŽŝŶƚŽĨŐĞŶĞƌĂƟŽŶŝƐ
when the soils are first excavated from the land (principle 1). Since no prohibited hazardous waste existed
ďĞĨŽƌĞƚŚĂƚƟŵ ĞĂŶĚƚŚĞsoils do not contain listed wastes at their ƉŽŝŶƚŽĨŐĞŶĞƌĂƟŽŶ͕ƚŚĞƌĞŝƐŶŽŚĂǌĂƌĚŽƵƐ
waste to wŚŝĐŚĂůĂŶĚĚŝƐƉŽƐĂůƉƌŽŚŝďŝƟŽŶĐŽƵůĚĂƩ ĂĐŚ͘;ƉƌŝŶĐŝƉůĞϮͿͿ
EXAMPLE 3 - ' ĞŶĞƌĂƚŽƌŝƐĞǆĐĂǀĂƟŶŐsoils ĐŽŶƚĂŵ ŝŶĂƚĞĚǁ ŝƚŚ&ϬϮϰ͘&ϬϮϰǁ ĂƐůĂŶĚĚŝƐƉŽƐĞĚĂŌ Ğƌϭϵϵϭ͕ĂŌ Ğƌ

it was prohibited from land disposal, and was not first treated to meet the applicable LDR treatment standards
;ŝ͘Ğ͕͘ŝƚǁ ĂƐŝůůĞŐĂůůǇůĂŶĚĚŝƐƉŽƐĞĚŽƌĂĐĐŝĚĞŶƚĂůůǇƐƉŝůůĞĚͿ͘^ŝŶĐĞƚŚĞĐŽŶƚĂŵ ŝŶĂƟŶŐǁ ĂƐƚĞǁ ĂƐƉƌŽŚŝďŝƚĞĚĨƌŽŵ
land disposal and the ƚƌĞĂƚŵ ĞŶƚƐƚĂŶĚĂƌĚƐǁ ĞƌĞŶŽƚĂĐŚŝĞǀĞĚƉƌŝŽƌƚŽůĂŶĚĚŝƐƉŽƐĂů͕ƚŚĞ> ZƉƌŽŚŝďŝƟŽŶ
ĐŽŶƟŶƵes to apply to any soils contaminated by the waste (principle (3)) regardless of whether the soils
The soils are prohibited from land disposal and, before land
disposal, must be treated to meet applicable LDR stanĚĂƌĚŽƌƵŶƟůĂƐŝƚĞ-specific, risk-based minimized threat
ĚĞƚĞƌŵ ŝŶĂƟŽŶŝƐŵ ĂĚĞƚŚƌŽƵŐŚƚŚĞǀĂƌŝĂŶĐĞƉƌŽĐĞƐƐ.
EXAMPLE 4 - ' ĞŶĞƌĂƚŽƌ ŝƐĞǆĐĂǀĂƟŶŐsoils contaminated by an accidental spill of benzyl chloride, which,
when discarded is P028 and are prohibited from land disposal. The accidental spill occurred yesterday. The
contaminated waste was prohibited from land disposal and, since the treatment standards were not achieved
ƉƌŝŽƌƚŽƚŚĞĂĐĐŝĚĞŶƚĂůƐƉŝůů͕ƚŚĞƉƌŽŚŝďŝƟŽŶĐŽŶƟŶƵĞƐƚŽĂƉƉůǇƚŽĂŶǇsoils contaminated by the waste
(principle 3)). Thus, the soils are prohibited from land disposal and, before land disposal, must be treated to
meet the ĂƉƉůŝĐĂďůĞ> ZƚƌĞĂƚŵ ĞŶƚƐƚĂŶĚĂƌĚƐŽƌƵŶƟůĂƐŝƚĞ-specific, risk-ďĂƐĞĚŵ ŝŶŝŵ ŝǌĞĚƚŚƌĞĂƚĚĞƚĞƌŵ ŝŶĂƟŽŶ
is made through the variance process.
EXAMPLE 5 - ' ĞŶĞƌĂƚŽƌŝƐĞǆĐĂǀĂƟŶŐsoils contaminated by F004. The F004 waste was land disposed in 1984,
ƉƌŝŽƌƚŽƚŚĞĞī ĞĐƟǀĞĚĂƚĞŽĨĂŶĂƉƉůŝĐĂďůĞůĂŶĚĚŝƐƉŽƐĂůƉƌŽŚŝďŝƟŽŶ͖ŚŽǁ ĞǀĞƌ͕ŽŶŐĞŶĞƌĂƟŽŶ (ĞǆĐĂǀĂƟŽŶ), the
soils ĐŽŶƚĂŝŶŚŝŐŚĐŽŶĐĞŶƚƌĂƟŽŶƐŽĨĐƌĞƐŽůƐ͕ƐŽƚŚĂƚĂŶĂƵƚŚŽƌŝǌĞĚƐƚĂƚĞĚĞƚĞƌŵ ŝŶĞƐthey
waste. The soils are prohibited from land disposal. ůƚŚŽƵŐŚƚŚĞĐŽŶƚĂŵ ŝŶĂƟŶŐǁ ĂƐƚĞǁ ĂƐŶŽƚƉƌŽŚŝďŝƚĞĚĨƌŽŵ
land disposal ĂƚƚŚĞƟŵ Ğŝƚwas land disposed, since the soils contained hazardous waste at the point of
ŐĞŶĞƌĂƟŽŶ, ƚŚĞůĂŶĚĚŝƐƉŽƐĂůƉƌŽŚŝďŝƟŽŶĂƩ ĂĐŚĞƐƚŽƚŚĞĐŽŶƚĂŵ ŝŶĂƚĞĚsoils and must be treated to the LDRs or
ƵŶƟůĂƐŝƚĞ-specific, risk-ďĂƐĞĚŵ ŝŶŝŵ ŝǌĞĚƚŚƌĞĂƚĚĞƚĞƌŵ ŝŶĂƟŽŶis made through the variance process
(Principles (1), (2), and (3)).
May 9, 2011 Page 12 of 28

Ʃ ĂĐŚŵ ĞŶƚC
RCRA Waste Codes w s Requiring Treatment
as Part of the LDR Program13
EPA , ĂǌĂƌĚŽƵƐt ĂƐƚĞ ĞƐĐƌŝƉƟŽŶ

Hazardous
Waste No.
F020 t ĂƐƚĞƐ;ĞǆĐĞƉƚǁ ĂƐƚĞǁ ĂƚĞƌĂŶĚƐƉĞŶƚĐĂƌďŽŶĨƌŽŵ ŚǇĚƌŽŐĞŶĐŚůŽƌŝĚĞƉƵƌŝĮĐĂƟŽŶͿĨƌŽŵ ƚŚĞƉƌŽĚƵĐƟŽŶŽƌ
ŵ ĂŶƵĨĂĐƚƵƌŝŶŐƵƐĞ;ĂƐĂƌĞĂĐƚĂŶƚ͕ĐŚĞŵ ŝĐĂůŝŶƚĞƌŵ ĞĚŝĂƚĞ͕ŽƌĐŽŵ ƉŽŶĞŶƚŝŶĂĨŽƌŵ ƵůĂƟŶŐƉƌŽĐĞƐƐͿŽĨƚƌŝ- or
tetrachlorophenol, or of intermediates ƵƐĞĚƚŽƉƌŽĚƵĐĞƚŚĞŝƌƉĞƐƟĐŝĚĞĚĞƌŝǀĂƟǀĞƐ͘;dŚŝƐůŝƐƟŶŐĚŽĞƐŶŽƚŝŶĐůƵĚĞ
ǁ ĂƐƚĞƐĨƌŽŵ ƚŚĞƉƌŽĚƵĐƟŽŶŽĨ, ĞǆĂĐŚůŽƌŽƉŚĞŶĞĨƌŽŵ ŚŝŐŚůǇƉƵƌŝĮĞĚϮ͕ϰ͕ϱ-trichlorophenol.)
F021 t ĂƐƚĞƐ;ĞǆĐĞƉƚǁ ĂƐƚĞǁ ĂƚĞƌĂŶĚƐƉĞŶƚĐĂƌďŽŶĨƌŽŵ ŚǇĚƌŽŐĞŶĐŚůŽƌŝĚĞƉƵƌŝĮĐĂƟŽŶͿĨƌŽŵ ƚŚĞƉƌŽĚƵĐƟŽŶŽƌ
ŵ ĂŶƵĨĂĐƚƵƌŝŶŐƵƐĞ;ĂƐĂƌĞĂĐƚĂŶƚ͕ĐŚĞŵ ŝĐĂůŝŶƚĞƌŵ ĞĚŝĂƚĞ͕ŽƌĐŽŵ ƉŽŶĞŶƚŝŶĂĨŽƌŵ ƵůĂƟŶŐƉƌŽĐĞƐƐͿŽĨ
ƉĞŶƚĂĐŚůŽƌŽƉŚĞŶŽů͕ŽƌŽĨŝŶƚĞƌŵ ĞĚŝĂƚĞƐƵƐĞĚƚŽƉƌŽĚƵĐĞŝƚƐĚĞƌŝǀĂƟǀĞƐ
F022 Wastes (except wastewater and spent carbon from hydrogen ĐŚůŽƌŝĚĞƉƵƌŝĮĐĂƟŽŶͿĨƌŽŵ ƚŚĞŵ ĂŶƵĨĂĐƚƵƌŝŶŐƵƐĞ
;ĂƐĂƌĞĂĐƚĂŶƚ͕ĐŚĞŵ ŝĐĂůŝŶƚĞƌŵ ĞĚŝĂƚĞ͕ŽƌĐŽŵ ƉŽŶĞŶƚŝŶĂĨŽƌŵ ƵůĂƟŶŐƉƌŽĐĞƐƐͿŽĨƚĞƚƌĂ-, penta-, or
ŚĞǆĂĐŚůŽƌŽďĞŶǌĞŶĞƐƵŶĚĞƌĂůŬĂůŝŶĞĐŽŶĚŝƟŽŶƐ
F023 Wastes (except wastewater and spent carbon from hydrogeŶĐŚůŽƌŝĚĞƉƵƌŝĮĐĂƟŽŶͿĨƌŽŵ ƚŚĞƉƌŽĚƵĐƟŽŶŽĨ
ŵ ĂƚĞƌŝĂůƐŽŶĞƋƵŝƉŵ ĞŶƚƉƌĞǀŝŽƵƐůǇƵƐĞĚĨŽƌƚŚĞƉƌŽĚƵĐƟŽŶŽƌŵ ĂŶƵĨĂĐƚƵƌŝŶŐƵƐĞ;ĂƐĂƌĞĂĐƚĂŶƚ͕ĐŚĞŵ ŝĐĂů
ŝŶƚĞƌŵ ĞĚŝĂƚĞ͕ŽƌĐŽŵ ƉŽŶĞŶƚŝŶĂĨŽƌŵ ƵůĂƟŶŐƉƌŽĐĞƐƐͿŽĨƚƌŝ- ĂŶĚƚĞƚƌĂĐŚůŽƌŽƉŚĞŶŽůƐ͘;dŚŝƐůŝƐƟŶŐĚŽĞƐnot include
ǁ ĂƐƚĞƐĨƌŽŵ ĞƋƵŝƉŵ ĞŶƚƵƐĞĚŽŶůǇĨŽƌƚŚĞƉƌŽĚƵĐƟŽŶŽƌƵƐĞŽĨ, ĞǆĂĐŚůŽƌŽƉŚĞŶĞĨƌŽŵ ŚŝŐŚůǇƉƵƌŝĮĞĚϮ͕ϰ͕ϱ-
trichlorophenol.)
F026 t ĂƐƚĞƐ;ĞǆĐĞƉƚǁ ĂƐƚĞǁ ĂƚĞƌĂŶĚƐƉĞŶƚĐĂƌďŽŶĨƌŽŵ ŚǇĚƌŽŐĞŶĐŚůŽƌŝĚĞƉƵƌŝĮĐĂƟŽŶͿĨƌŽŵ ƚŚĞƉƌŽĚƵĐƟŽŶŽĨ
materials on equipment previously used for the manufacturing use (as a reactant, chemical intermediate, or
ĐŽŵ ƉŽŶĞŶƚŝŶĂĨŽƌŵ ƵůĂƟŶŐƉƌŽĐĞƐƐͿŽĨƚĞƚƌĂ-, penta-͕ŽƌŚĞǆĂĐŚůŽƌŽďĞŶǌĞŶĞƵŶĚĞƌĂůŬĂůŝŶĞĐŽŶĚŝƟŽŶƐ
F027 ŝƐĐĂƌĚĞĚƵŶƵƐĞĚĨŽƌŵ ƵůĂƟŽŶƐĐŽŶƚĂŝŶŝŶŐƚƌŝ-, tetra-͕ŽƌƉĞŶƚĂĐŚůŽƌŽƉŚĞŶŽůŽƌĚŝƐĐĂƌĚĞĚƵŶƵƐĞĚĨŽƌŵ ƵůĂƟŽŶƐ
ĐŽŶƚĂŝŶŝŶŐĐŽŵ ƉŽƵŶĚƐĚĞƌŝǀĞĚĨƌŽŵ ƚŚĞƐĞĐŚůŽƌŽƉŚĞŶŽůƐ͘;dŚŝƐůŝƐƟŶŐĚŽĞƐŶŽƚŝŶĐůƵĚĞ ĨŽƌŵ ƵůĂƟŽŶƐĐŽŶƚĂŝŶŝŶŐ
Hexachlorophene synthesized from prepurified 2,4,5-trichlorophenol as the sole component.)
F028 ZĞƐŝĚƵĞƐƌĞƐƵůƟŶŐĨƌŽŵ ƚŚĞŝŶĐŝŶĞƌĂƟŽŶŽƌƚŚĞƌŵ ĂůƚƌĞĂƚŵ ĞŶƚŽĨsoils contaminated with EPA Hazardous Waste
Nos. F020, F021, F022, F023, F026, and F027
F032 Wastewaters (except those that have not come into contact with process contaminants), process residuals,
ƉƌĞƐĞƌǀĂƟǀĞĚƌŝƉƉĂŐĞ͕ĂŶĚƐƉĞŶƚĨŽƌŵ ƵůĂƟŽŶƐĨƌŽŵ ǁ ŽŽĚƉƌĞƐĞƌving processes generated at plants that currently
ƵƐĞŽƌŚĂǀĞƉƌĞǀŝŽƵƐůǇƵƐĞĚĐŚůŽƌŽƉŚĞŶŽůŝĐĨŽƌŵ ƵůĂƟŽŶƐ;ĞǆĐĞƉƚƉŽƚĞŶƟĂůůǇĐƌŽƐƐ-contaminated wastes that have
ŚĂĚƚŚĞ&ϬϯϮǁ ĂƐƚĞĐŽĚĞĚĞůĞƚĞĚŝŶĂĐĐŽƌĚĂŶĐĞǁ ŝƚŚΑϮϲϭ͘ϯϱŽĨƚŚŝƐĐŚĂƉƚĞƌŽƌƉŽƚĞŶƟĂůůǇĐƌŽƐs-contaminated
wastes that are otherwise currently regulated as hazardous wastes (i.e., F034 or F035), and where the generator
ĚŽĞƐŶŽƚƌĞƐƵŵ ĞŽƌŝŶŝƟĂƚĞƵƐĞŽĨĐŚůŽƌŽƉŚĞŶŽůŝĐĨŽƌŵ ƵůĂƟŽŶƐͿ͘dŚŝƐůŝƐƟŶŐĚŽĞƐŶŽƚŝŶĐůƵĚĞ<ϬϬϭďŽƩ Žŵ
sediment sludge from the treatment of wastewater from wood preserving processes that use creosote and/or
pentachlorophenol
F039 >ĞĂĐŚĂƚĞ;ůŝƋƵŝĚƐƚŚĂƚŚĂǀĞƉĞƌĐŽůĂƚĞĚƚŚƌŽƵŐŚůĂŶĚĚŝƐƉŽƐĞĚǁ ĂƐƚĞƐͿƌĞƐƵůƟŶŐĨƌŽŵ ƚŚĞĚŝƐƉŽƐĂůŽĨŵ ŽƌĞƚŚĂŶ
one restricted waste classified as hazaƌĚŽƵƐƵŶĚĞƌƐƵďƉĂƌƚ ŽĨƚŚŝƐƉĂƌƚ͘;>ĞĂĐŚĂƚĞƌĞƐƵůƟŶŐĨƌŽŵ ƚŚĞĚŝƐƉŽƐĂůŽĨ
one or more of the following EPA Hazardous Waste and no other Hazardous Wastes retains its Hazardous Waste
Number(s): F020, F021, F022, F026, F027, and/or F028.)
K043 2,6-DichlŽƌŽƉŚĞŶŽůǁ ĂƐƚĞĨƌŽŵ ƚŚĞƉƌŽĚƵĐƟŽŶŽĨϮ͕ϰ-D.
K099 h ŶƚƌĞĂƚĞĚǁ ĂƐƚĞǁ ĂƚĞƌĨƌŽŵ ƚŚĞƉƌŽĚƵĐƟŽŶŽĨϮ͕ϰ-D.
K174 t ĂƐƚĞǁ ĂƚĞƌƚƌĞĂƚŵ ĞŶƚƐůƵĚŐĞƐĨƌŽŵ ƚŚĞƉƌŽĚƵĐƟŽŶŽĨĞƚŚǇůĞŶĞĚŝĐŚůŽƌŝĚĞŽƌǀŝŶǇůĐŚůŽƌŝĚĞŵ ŽŶŽŵ Ğƌ;ŝŶĐůƵĚŝŶŐ
sludges that result from commingled ethylene dichloride or vinyl chloride monomer wastewater and other
ǁ ĂƐƚĞǁ ĂƚĞƌͿ͕ƵŶůĞƐƐƚŚĞƐůƵĚŐĞƐŵ ĞĞƚƚŚĞĨŽůůŽǁ ŝŶŐĐŽŶĚŝƟŽŶƐ͗;ŝͿƚŚĞǇĂƌĞĚŝƐƉŽƐĞĚŽĨŝŶĂƐƵďƟƚůĞŽƌŶŽŶ-
ŚĂǌĂƌĚŽƵƐůĂŶĚĮůůůŝĐĞŶƐĞĚŽƌƉĞƌŵ ŝƩ ĞĚďǇƚŚĞƐƚĂƚĞŽƌĨĞĚĞƌĂůŐŽǀĞƌŶŵ ĞŶƚ͖;ii) they are not otherwise placed on
ƚŚĞůĂŶĚƉƌŝŽƌƚŽĮŶĂůĚŝƐƉŽƐĂů͖ĂŶĚ;ŝŝŝͿƚŚĞŐĞŶĞƌĂƚŽƌŵ ĂŝŶƚĂŝŶƐĚŽĐƵŵ ĞŶƚĂƟŽŶĚĞŵ ŽŶƐƚƌĂƟŶŐƚŚĂƚƚŚĞǁ ĂƐƚĞǁ ĂƐ
either disposed of in an on-site landfill or consigned to a transporter or disposal facility that providĞĚĂǁ ƌŝƩ ĞŶ
13
ƌĞŐƵůĂƚĞĚĐŽŶƐƟƚƵĞŶƚƐƌĞƋƵŝƌŝŶŐƚƌĞĂƚŵ ĞŶƚƉƌŝŽƌƚŽůĂŶĚĚŝƐƉŽƐĂůƵŶĚĞƌƚŚĞ> ZƉƌŽŐƌĂŵ
May 9, 2011 Page 13 of 28

EPA , ĂǌĂƌĚŽƵƐt ĂƐƚĞ ĞƐĐƌŝƉƟŽŶ
Hazardous
Waste No.
commitment to dispose of the waste in an off-ƐŝƚĞůĂŶĚĮůů͘ZĞƐƉŽŶĚĞŶƚƐŝŶĂŶǇĂĐƟŽŶďƌŽƵŐŚƚƚŽĞŶĨŽƌĐĞƚŚĞ
ƌĞƋƵŝƌĞŵ ĞŶƚƐŽĨƐƵďƟƚůĞŵ ƵƐƚ͕ƵƉŽŶĂƐŚŽǁ ŝŶŐďǇƚŚĞŐŽǀĞƌŶŵ ĞŶƚƚŚĂƚƚŚĞƌĞƐƉŽŶĚĞŶƚŵ ĂŶĂŐĞĚǁ ĂƐƚĞǁ ĂƚĞƌ
treatment sludges from the prŽĚƵĐƟŽŶŽĨǀŝŶǇůĐŚůŽƌŝĚĞŵ ŽŶŽŵ ĞƌŽƌĞƚŚǇůĞŶĞĚŝĐŚůŽƌŝĚĞ͕ĚĞŵ ŽŶƐƚƌĂƚĞƚŚĂƚƚŚĞǇ
ŵ ĞĞƚƚŚĞƚĞƌŵ ƐŽĨƚŚĞĞǆĐůƵƐŝŽŶƐĞƚĨŽƌƚŚĂďŽǀĞ͘/ŶĚŽŝŶŐƐŽ͕ƚŚĞǇŵ ƵƐƚƉƌŽǀŝĚĞĂƉƉƌŽƉƌŝĂƚĞĚŽĐƵŵ ĞŶƚĂƟŽŶ;Ğ͘Ő͕͘
contracts between the generator and the landfill owner/operatoƌ͕ŝŶǀŽŝĐĞƐĚŽĐƵŵ ĞŶƟŶŐĚĞůŝǀĞƌǇŽĨǁ ĂƐƚĞƚŽ
landfill, etc.) that the terms of the exclusion were met
K178 Residues from manufacturing and manufacturing-site storage of ferric chloride from acids formed during the
ƉƌŽĚƵĐƟŽŶŽĨƟƚĂŶŝƵŵ ĚŝŽǆŝĚĞƵƐŝŶŐƚŚĞchloride-ilmenite process
Source: 40 CFR 261.31, 40 CFR 261.32, and 40 CFR 268.40..
May 9, 2011 Page 14 of 28

Ʃ ĂĐŚŵ ĞŶƚB
' ĞŶĞƌĂů/ŶĨŽƌŵ ĂƟŽŶĂďŽƵƚƚŚĞ>ĂŶĚ ŝƐƉŽƐĂůZĞƐƚƌŝĐƟŽŶƐWƌŽŐƌĂŵ
Under the authority of the Hazardous and Solid Waste Amendments of 1984 (HWSA), EPA developed
the LDR program. The LDR program is codified at 40 CFR Part 268. Under Part 268, EPA has established
treatment standards that dictate to what extent hazardous waste must be treated before it can be land
disposed. EPA also has established minimum technical standards for managing restricted wastes, such
ĂƐƌĞƋƵŝƌĞŵ ĞŶƚƐĨŽƌǁ ĂƐƚĞĐŚĂƌĂĐƚĞƌŝǌĂƟŽŶĂŶĚǁ ĂƐƚĞƚƌĂĐŬŝŶŐ;ŝ͘Ğ͕͘ŶŽƟĮĐĂƟŽŶƐͬĐĞƌƟĮĐĂƟŽŶƐͿ͘14 In
ĂĚĚŝƟŽŶ͕WŚĂƐĞƐƚĂďůŝƐŚĞĚǀĂƌŝĂŶĐĞƐ͕ĐĂƐĞ-by-ĐĂƐĞĞǆƚĞŶƐŝŽŶƐƚŽƚŚĞĞī ĞĐƟǀĞĚĂƚĞ͕ĂŶĚŽƚŚĞƌ
mechanisms that provide flexibility in administering the LDR program.
dŚĞƌĞŵ ĂŝŶĚĞƌŽĨƚŚŝƐĂƩ ĂĐŚŵ ĞŶƚƉƌŽǀŝĚĞƐŐĞŶĞƌĂůŝŶĨŽƌŵ ĂƟŽŶŽŶ͗
Waste-specific treatment standards;

ůƚĞƌŶĂƟǀĞsoil treatment standards;
E ŽƟĮĐĂƟŽŶ͕ĐĞƌƟĮĐĂƟŽŶ͕ĂŶĚƌĞĐŽƌĚŬĞĞƉŝŶŐ͖ĂŶĚ
s ĂƌŝĂŶĐĞƐ͕ĞǆƚĞŶƐŝŽŶƐ͕ĂŶĚĞǆĞŵ ƉƟŽŶƐ͘
dŚŝƐĂƩ ĂĐŚŵ ĞŶƚŽŶůǇƐƵŵ ŵ ĂƌŝǌĞƐƚŚĞƉĂƌƟĐƵůĂƌƉƌŽǀŝƐŝŽŶƐ͖ƌĞĨĞƌƚŽƚŚĞƐƉĞĐŝĮĐƐƚĂƚƵƚŽƌǇƐĞĐƟŽŶƐŽƌ

spĞĐŝĮĐƌĞŐƵůĂƚŽƌǇƌĞƋƵŝƌĞŵ ĞŶƚƐĨŽƌĚĞƚĂŝůƐŽŶŵ ĞĞƟŶŐƚŚĞƐĞƉĂƌƟĐƵůĂƌƌĞƋƵŝƌĞŵ ĞŶƚƐ͘
Waste-Specific Treatment Standards
LDR waste-specific treatment standards can be found at 40 CFR 268.40. These treatment standards can
ďĞĞŝƚŚĞƌĐŽŶĐĞŶƚƌĂƟŽŶůĞǀĞůƐĨŽƌŚĂǌĂƌĚŽƵƐĐŽŶƐƟƚƵĞŶƚƐƚŚĂƚƚŚĞǁ ĂƐƚĞŵ ƵƐƚŵ ĞĞƚŽƌƚƌĞĂƚŵ ĞŶƚ
technologies that must be performed on the waste before it can be disposed. EPA bases the LDR
treatment standards on the performance of available technologies that best minimizes the mobility or
ƚŽǆŝĐŝƚǇ;ŽƌďŽƚŚͿŽĨƚŚĞŚĂǌĂƌĚŽƵƐĐŽŶƐƟƚƵĞŶƚƐ͕ǁ ŚŝĐŚŝƐĚĞƐŝŐŶĂƚĞĚĂƐƚŚĞĞƐƚ Ğŵ ŽŶƐƚƌĂƚĞĚǀĂŝůĂďůĞ
Technology (BDAT) for that waste.
t ŚĞŶƚƌĞĂƚŵ ĞŶƚƐƚĂŶĚĂƌĚƐĂƌĞƐĞƚĂƐĐŽŶĐĞŶƚƌĂƟŽŶůĞǀĞůƐ͕ƚŚĞƌĞŐƵůĂƚĞĚĐŽŵ ŵ ƵŶŝƚǇŵ ĂǇƵƐĞĂŶǇ

method or technŽůŽŐǇ;ĞǆĐĞƉƚĚŝůƵƟŽŶͿƚŽŵ ĞĞƚƚŚĂƚĐŽŶĐĞŶƚƌĂƟŽŶůĞǀĞů͘, Žǁ ĞǀĞƌ͕ǁ ŚĞŶW
designates a technology as a treatment standard, the regulated community must treat the waste with
that specific technology (unless an equivalent treatment method variance is granted) in order to meet
the treatment standard.
ŽƚŚůŝƐƚĞĚĂŶĚĐŚĂƌĂĐƚĞƌŝƐƟĐŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞƐŵ ƵƐƚŵ ĞĞƚƚŚĞ> ZƚƌĞĂƚŵ ĞŶƚƐƚĂŶĚĂƌĚƐďĞĨŽƌĞƚŚĞǇĂƌĞ

ĞůŝŐŝďůĞĨŽƌůĂŶĚĚŝƐƉŽƐĂů͘dŚĞƌĞĂƌĞ͕ŚŽǁ ĞǀĞƌ͕ƐŽŵ ĞƵŶŝƋƵĞƐŝƚƵĂƟŽŶƐƚŚĂƚĂƌŝƐĞǁ ŚĞŶĚĞĂůŝŶŐǁ ŝƚŚ
charac
ƚƌĞĂƚŵ ĞŶƚƐƚĂŶĚĂƌĚƐĨŽƌĐŚĂƌĂĐƚĞƌŝƐƟĐŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞƐĞŶƚĂŝůƌĞŶĚĞƌŝŶŐƚŚĞǁ ĂƐƚĞŶŽŶŚĂǌĂƌĚŽƵƐ;ŝ͘Ğ͕͘
de-characterizing the waste/ƌĞŵ ŽǀŝŶŐƚŚĞĐŚĂƌĂĐƚĞƌŝƐƟĐͿ͘, Žǁ ĞǀĞƌ͕ĐŚĂƌĂĐƚĞƌŝƐƟĐŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞƐ
ǁ ŝƚŚh , ƐŚĂǀĞĂĚĚŝƟŽŶĂůƚƌĞĂƚŵ ĞŶƚƌĞƋƵŝƌĞŵ ĞŶƚƐ͘h , ƐĂƌĞĐŽŶƐƟƚƵĞŶƚƐƚŚĂƚŵ ĂǇŶŽƚďĞƚŚĞďĂƐŝƐfor
a ǁ ĂƐƚĞƚŽĞǆŚŝďŝƚĂĐŚĂƌĂĐƚĞƌŝƐƟĐ͕ďƵƚare reasonably expected to be in the waste and can pose hazards
nonetheless. The UHCs must be treated in order to meet the contaminant-specific levels. These levels
are referred to as the UTS levels͕ĂŶĚĂƌĞůŝƐƚĞĚĂƚϰϬ&ZϮϲϴ͘ϰϴ͘dŚŝƐŝƐǁ ŚǇƐŽŵ ĞĐŚĂƌĂĐƚĞƌŝƐƟĐ
hazardous ǁ ĂƐƚĞƐƚŚĂƚŶŽůŽŶŐĞƌĞǆŚŝďŝƚĂĐŚĂƌĂĐƚĞƌŝƐƟĐŵ ƵƐƚƐƟůůďĞƚƌĞĂƚĞĚƚŽŵ ĞĞƚĂĚĚŝƟŽŶĂů> Z
14
Restricted waste is defined as hazardous waste that is prohibited from land disposal if applicable treatment
ƐƚĂŶĚĂƌĚƐĂƌĞŶŽƚŵ Ğƚ͘;>ĂŶĚ ŝƐƉŽƐĂůZĞƐƚƌŝĐƟŽŶƐ͗^Ƶŵ ŵ ĂƌǇŽĨZĞƋƵŝƌĞŵ ĞŶƚƐ͘h ŶŝƚĞĚ^ƚĂƚĞŶǀŝƌŽŶŵ ĞŶƚĂů
WƌŽƚĞĐƟŽŶŐĞŶĐǇ͘K ĸ ĐĞƐŽĨ^ŽůŝĚt ĂƐƚĞĂŶĚŵ ĞƌŐĞŶĐǇZĞƐƉŽŶƐĞĂŶĚŶĨŽƌĐĞŵ ĞŶƚĂŶĚŽŵ ƉůŝĂŶĐĞAssurance.
EPA530-R-01-007. www.epa.gov/osw. Revised August 2001.)
May 9, 2011 Page 15 of 28

ƌĞƋƵŝƌĞŵ ĞŶƚƐ͘K ŶĐĞƐƵĐŚĐŚĂƌĂĐƚĞƌŝƐƟĐŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞƐŚĂǀĞďĞĞŶĚĞ-characterized and treated to
meet the UHCs, they can be disposed of in a nonhazardous waste land disposal unit.
ůƚĞƌŶĂƟǀĞSoil Treatment Standards
Contaminated soils must be handled as hazardous waste if they contain a listed hazardous waste or if
they exhibit ĂĐŚĂƌĂĐƚĞƌŝƐƟĐŽĨŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞ͘Ɛǁ ŝƚŚŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞ͕ůĂŶĚĚŝƐƉŽƐĂůŽĨŚĂǌĂƌĚŽƵƐ
soil ŝƐƉƌŽŚŝďŝƚĞĚƵŶƟůƚŚĞƐŽŝůŚĂƐďĞĞŶƚƌĞĂƚĞĚƚŽŵ ĞĞƚ> ZƚƌĞĂƚŵ ĞŶƚƐƚĂŶĚĂƌĚƐ͘dŚĞƐĞĐŽŶƚĂŵ ŝŶĂƚĞĚ
soilƐ͕ĚƵĞƚŽĞŝƚŚĞƌƚŚĞŝƌůĂƌŐĞǀŽůƵŵ ĞŽƌƵŶŝƋƵĞƉƌŽƉĞƌƟĞƐ͕ĂƌĞŶŽƚĂůǁ ĂǇƐĂŵ ĞŶĂďůĞƚŽƚŚĞǁ ĂƐƚĞ-
specific treatment standards found at 40 CFR 268.40. BecĂƵƐĞŽĨƚŚŝƐ͕WƉƌŽŵ ƵůŐĂƚĞĚĂůƚĞƌŶĂƟǀĞƐŽŝů
ƚƌĞĂƚŵ ĞŶƚƐƚĂŶĚĂƌĚƐĂƚϰϬ&ZϮϲϴ͘ϰϵ͘dŚĞĂůƚĞƌŶĂƟǀĞƐŽŝůƚƌĞĂƚŵ ĞŶƚƐƚĂŶĚĂƌĚƐŵ ĂŶĚĂƚĞƚŚĞƌĞĚƵĐƟŽŶ
ŽĨŚĂǌĂƌĚŽƵƐĐŽŶƐƟƚƵĞŶƚƐŝŶƚŚĞƐŽŝůďǇϵϬƉĞƌĐĞŶƚŽƌƚĞŶƟŵ ĞƐƚŚĞh d^͕ǁ ŚŝĐŚĞǀĞƌŝƐŚŝŐŚĞƌ͘ZĞŵ ŽǀĂů
of ƚŚĞĐŚĂƌĂĐƚĞƌŝƐƟĐŝƐĂůƐŽƌĞƋƵŝƌĞĚŝĨƚŚĞƐŽŝůis ignitable͕ĐŽƌƌŽƐŝǀĞ͕ŽƌƌĞĂĐƟǀĞ͘
A facility may treat contaminated soils to meet the waste-specific treatment standard at 40 CFR 268.40,
ŽƌƚŽƚŚĞĂůƚĞƌŶĂƟǀĞsoil treatment standards at 40 CFR 268.49.
E ŽƟĮĐĂƟŽŶ͕ĞƌƟĮĐĂƟŽŶ͕ĂŶĚZĞĐŽƌĚŬĞĞƉŝŶŐ
In order to properly track the hazardous waste that is generated, transported, treated, stored, and
ĚŝƐƉŽƐĞĚŽĨ͕Wŝŵ ƉŽƐĞƐĐĞƌƚĂŝŶ> ZŶŽƟĮĐĂƟŽŶ͕ĐĞƌƟĮĐĂƟŽŶ͕ĂŶĚƌĞĐŽƌĚŬĞĞƉŝŶŐƌĞƋƵŝƌĞŵ ĞŶƚƐŽŶ
generĂƚŽƌƐĂŶĚƚƌĞĂƚŵ ĞŶƚ͕ƐƚŽƌĂŐĞ͕ĂŶĚĚŝƐƉŽƐĂůĨĂĐŝůŝƟĞƐ;d^ &ƐͿ͘> ZŶŽƟĮĐĂƟŽŶƐŝŶĨŽƌŵ ƚŚĞŶĞǆƚ
waste handler whether the waste must be treated to meet the treatment standard or if it can be
disposed of without treatment. When wastes do not need to meet a treatment standard, or already
ŵ ĞĞƚƚŚĞƐƚĂŶĚĂƌĚ͕WƌĞƋƵŝƌĞƐƚŚĞŚĂŶĚůĞƌƚŽƐŝŐŶĂƐƚĂƚĞŵ ĞŶƚĐĞƌƟĨǇŝŶŐƐƵĐŚĂĐůĂŝŵ ͘
Generators ŵ ƵƐƚƐĞŶĚĂŶŽƟĮĐĂƟŽŶǁ ŝƚŚƚŚĞŝŶŝƟĂůƐŚŝƉŵ ĞŶƚŽĨǁ ĂƐƚĞto each treatment, storage or

disposal facility and keep a copy in their on-site files. If the waste, process, or receiving facility
ĐŚĂŶŐĞƐ͕ĂŶŽƚŚĞƌŶŽƟĮĐĂƟŽŶŝƐƌĞƋƵŝƌĞĚ͘dŚĞŝŶĨŽƌŵ ĂƟŽŶƚŚĂƚƚŚĞŶŽƟĮĐĂƟŽŶŵ ƵƐƚŝŶĐůƵĚĞǀĂƌŝĞƐ
ĂĐĐŽƌĚŝŶŐƚŽƚŚĞƐƚĂƚƵƐŽĨƚŚĞǁ ĂƐƚĞ͘&ŽƌĞǆĂŵ ƉůĞ͕ƚŚĞŶŽƟĮĐĂƟŽŶƌĞƋƵŝƌĞŵ ĞŶts will differ slightly if
ƚŚĞǁ ĂƐƚĞŵ ĞĞƚƐŝƚƐƚƌĞĂƚŵ ĞŶƚƐƚĂŶĚĂƌĚŽƌŝƐƐƵďũĞĐƚƚŽĂŶĂƟŽŶĂůĐĂƉĂĐŝƚǇǀĂƌŝĂŶĐĞ͘;ϰϬ&Z
268.7(a))
dƌĞĂƚŵ ĞŶƚĨĂĐŝůŝƟĞƐ ŚĂǀĞƚŽƐĞŶĚƐŝŵ ŝůĂƌŶŽƟĮĐĂƟŽŶƐĂůŽŶŐǁ ŝƚŚƚŚĞƐŚŝƉŵ ĞŶƚŽĨƚŚĞƚƌĞĂƚĞĚǁ ĂƐƚĞ

ƚŽĚŝƐƉŽƐĂůĨĂĐŝůŝƟĞƐ and keep a copy in their on-ƐŝƚĞĮůĞƐ͘ĐĞƌƟĮĐĂƟŽŶŶŽƌŵ ĂůůǇĂĐĐŽŵ ƉĂŶŝĞƐƚŚŝƐ
ŶŽƟĮĐĂƟŽŶƐƚĂƟŶŐƚŚĂƚƚŚĞǁ ĂƐƚĞŵ ĞĞƚƐŝƚƐƚƌĞĂƚŵ ĞŶƚƐƚĂŶĚĂƌĚƐĂŶĚŵ ĂǇďĞůĂŶĚĚŝƐƉŽƐĞĚ͘;ϰϬ&Z
268.7(b))
ŝƐƉŽƐĂůĨĂĐŝůŝƟĞƐ are the final link in the waste management chain. As a result, they have to test the
waste residue that they receive to ensure that it meets the treatment standards. (40 CFR 268.7(c))
Each hazardous waste handler must comply with certain recordkeeping requirements for LDR
ŶŽƟĮĐĂƟŽŶƐĂŶĚƉĂƉĞƌǁ ŽƌŬ͘' ĞŶĞƌĂƚŽƌƐ͕ƚƌĞĂƚŵ ĞŶƚĨĂĐŝůŝƟĞƐ͕ĂŶĚĚŝƐƉŽƐĂůĨĂĐŝůŝƟĞƐŵ ƵƐƚŬĞĞƉĐŽƉŝĞƐŽĨ
all LDR paperwork associated with the waste they ship or receive in their facility files for three years.
ŚĂƌĂĐƚĞƌŝƐƟĐǁ ĂƐƚĞƐƚŚĂƚĂƌĞĚĞ-characterized subsequenƚƚŽƚŚĞƉŽŝŶƚŽĨŐĞŶĞƌĂƟŽŶ;ŝ͘Ğ͕͘ƚŚĞǇďĞĐŽŵ Ğ

nonhazardous) are handled differently. Once a waste is de-characterized and has met LDR treatment
ƐƚĂŶĚĂƌĚƐ͕ŝƚĐĂŶŐŽƚŽĂZZƐƵďƟƚůĞ ŶŽŶŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞĨĂĐŝůŝƚǇ͘ŽƉŝĞƐŽĨƚŚĞƐĞ> ZŶŽƟĮĐĂƟŽŶƐ
and ĐĞƌƟĮĐĂƟŽŶƐĂƌĞƐĞŶƚƚŽƚŚĞWregion or authorized s
ƚŚĂŶƚŽƚŚĞƌĞĐĞŝǀŝŶŐƐƵďƟƚůĞ ĨĂĐŝůŝƚǇ͘, Žǁ ĞǀĞƌ͕ƚŚŝƐĂƉƉůŝĞƐŽŶůǇƚŽǁ ĂƐƚĞƐƚŚĂƚĐŽŶƚĂŝŶŶŽůŝƐƚĞĚ
hazardous wastes (some wastes may be listed and also exhibit ĂŚĂǌĂƌĚŽƵƐĐŚĂƌĂĐƚĞƌŝƐƟĐͿ͘
May 9, 2011 Page 16 of 28

s ĂƌŝĂŶĐĞƐ͕ǆƚĞŶƐŝŽŶƐ͕ĂŶĚǆĞŵ ƉƟŽŶƐ
dŚĞĨŽůůŽǁ ŝŶŐǀĂƌŝĂŶĐĞƐ͕ĞǆƚĞŶƐŝŽŶƐ͕ĂŶĚĞǆĞŵ ƉƟŽŶƐĂůůŽǁ ǁ ĂƐƚĞƐƚŽďĞĚŝƐƉŽƐĞĚŽĨǁ ŝƚŚŽƵƚŵ ĞĞƟŶŐ

ƚŚĞŝƌƌĞƐƉĞĐƟǀĞƚƌĞĂƚŵ ĞŶƚƐƚĂŶĚĂƌĚƐ͕ŽƌƚŽďĞƚƌĞĂƚĞĚƚŽĂĚŝī ĞƌĞŶƚƐƚĂndard:
E ĂƟŽŶĂůĐĂƉĂĐŝƚǇǀĂƌŝĂŶĐĞƐ;ZZ^ĞĐƟŽŶϯϬϬϰ;ŚͿ;ϮͿͿ͘ When developing a treatment standard, EPA

examines the available treatment capacity to determine whether it is sufficient to handle current
and future waste management needs. If the Agency deƚĞƌŵ ŝŶĞƐƚŚĂƚŶĂƟŽŶĂůůǇƚŚĞƌĞŝƐŶŽƚĞŶŽƵŐŚ
ŵ Ăǆŝŵ Ƶŵ ŽĨƚǁ ŽǇĞĂƌƐ͘t ĂƐƚĞƐƵŶĚĞƌĂŶĂƟŽŶĂůĐĂƉĂĐŝƚǇǀĂƌŝĂŶĐĞĐĂŶďĞĚŝƐƉŽƐĞĚŽĨ͕ǁ ŝƚŚŽƵƚ

ŵ ĞĞƟŶŐƚŚĞƚƌĞĂƚment standards, in landfills and surface impoundments that meet the minimum
technical requirements. (Note: The ŶĂƟŽŶĂůĐĂƉĂĐŝƚǇvariance applies when the Agency first
promulgates the LDR treatment standards for the hazardous waste. Thus, this capacity variance
would only apply for new hazardous waste.)
Case-by-case extensions (40 CFR 268.5). ĨĂĐŝůŝƚǇŵ ĂǇƉĞƟƟŽŶWĨŽƌĂĐĂƐĞ-by-case extension to

ƚŚĞŶĂƟŽŶĂůĐĂƉĂĐŝƚǇǀĂƌŝĂŶĐĞƚŽĚĞůĂǇƚŚĞĞīĞĐƟǀĞĚĂƚĞĨŽƌŽŶĞǇĞĂƌ͕ǁ ŝƚŚĂƉŽƐƐŝďůĞĞǆƚĞŶƐŝŽŶŽĨ
ƚŚĂƚƉĂƌƟĐƵůĂƌǁ ĂƐƚĞ͘t ĂƐƚĞƐŐƌĂŶƚĞĚĐĂse-by-ĐĂƐĞĞǆƚĞŶƐŝŽŶƐĐĂŶďĞĚŝƐƉŽƐĞĚŽĨǁ ŝƚŚŽƵƚŵ ĞĞƟŶŐ

the treatment standards in landfills and surface impoundments that meet the minimum technical
requirements. (Note: The case-by-ĐĂƐĞĞǆƚĞŶƐŝŽŶĂƉƉůŝĞƐĂŌ ĞƌƚŚĞŶĂƟŽŶĂůĐĂƉĂĐŝƚǇǀĂƌŝĂŶĐĞ
expires, and may only be granted for one-ǇĞĂƌ͕ǁ ŝƚŚĂƉŽƐƐŝďůĞĞǆƚĞŶƐŝŽŶŽĨĂŶĂĚĚŝƟŽŶĂůǇĞĂƌ͘
Thus, this capacity variance would only apply for new hazardous wastes.)
No-ŵ ŝŐƌĂƟŽŶǀĂƌŝĂŶĐĞƐ;ϰϬ&ZϮϲϴ͘ϲͿ͘ No-ŵ ŝŐƌĂƟŽŶǀĂƌŝĂŶĐĞƐĂƉƉůǇƚŽƚŚĞĚŝƐƉŽƐĂůƵŶŝƚŝŶƐƚead of

ƚŽƚŚĞǁ ĂƐƚĞ͕ĂŶĚĂůůŽǁ ǁ ĂƐƚĞƐƚŽďĞĚŝƐƉŽƐĞĚŽĨŝŶƚŚĞƵŶŝƚǁ ŝƚŚŽƵƚŵ ĞĞƟŶŐƚŚĞƚƌĞĂƚŵ ĞŶƚ
standards. To obtain a no-ŵ ŝŐƌĂƟŽŶǀĂƌŝĂŶĐĞĨŽƌĂĚŝƐƉŽƐĂůƵŶŝƚ͕ĂĨĂĐŝůŝƚǇŵ ƵƐƚƉĞƟƟŽŶWĂŶĚ
ĚĞŵ ŽŶƐƚƌĂƚĞƚŚĂƚƚŚĞƌĞǁ ŝůůďĞŶŽŵ ŝŐƌĂƟŽŶŽĨthe hazardoƵƐĐŽŶƐƟƚƵĞŶƚƐĨƌŽŵ ƚŚĞƵŶŝƚĨŽƌĂƐůŽŶŐ
as the waste remains hazardous.
Variances from a treatment standard (40 CFR 268.44). Variances from a treatment standard allow
ƚŚĞƌĞŐƵůĂƚĞĚĐŽŵ ŵ ƵŶŝƚǇƚŽƉĞƟƟŽŶWĂŶĚƐŚŽǁ ƚŚĂƚƚŚĞƌĞƋƵŝƌĞĚ> ZƚƌĞĂƚŵ ĞŶƚƐƚĂŶdard is not
appropriate for their waste, or that the treatment standard is not achievable. If a variance is
ŐƌĂŶƚĞĚ͕Wǁ ŝůůƐƉĞĐŝĨǇĂŶĂůƚĞƌŶĂƟǀĞƚƌĞĂƚŵ ĞŶƚƐƚĂŶĚĂƌĚƚŽŵ ĞĞƚ͘
Equivalent treatment method variances (40 CFR 268.42(b)). ĞƚĞƌŵ ŝŶĂƟŽŶƐŽĨequivalent treatment
ĂůůŽǁ ƚŚĞƌĞŐƵůĂƚĞĚĐŽŵ ŵ ƵŶŝƚǇƚŽƉĞƟƟŽŶWĂŶĚĚĞŵ ŽŶƐƚƌĂƚĞƚŚĂƚĂƚĞĐŚŶŽůŽŐǇĚŝī ĞƌĞŶƚĨƌŽŵ
the required LDR treatment technology can achieve comparable results. If approved, the applicant
ĐĂŶƵƐĞƚŚĞĂůƚĞƌŶĂƟǀĞƚƌĞĂƚŵ ĞŶƚƚĞĐŚŶŽůŽgy in place of the required technology.
^ƵƌĨĂĐĞŝŵ ƉŽƵŶĚŵ ĞŶƚƚƌĞĂƚŵ ĞŶƚĞǆĞŵ ƉƟŽŶƐ;ϰϬ&ZϮϲϴ͘ϰͿ͘ Surface impoundment treatment

ĞǆĞŵ ƉƟŽŶƐĂůůŽǁ ƚŚĞƌĞŐƵůĂƚĞĚĐŽŵ ŵ ƵŶŝƚǇƚŽƉĞƟƟŽŶWĨŽƌƉĞƌŵ ŝƐƐŝŽŶƚŽƚƌĞĂƚŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞ
in surface impoundments. Under normal circumstances, owners and operators cannot place
untreated hazardous waste on the land, even if it is in a land-based unit for treatment. Since many
ĨĂĐŝůŝƟĞƐƵƐĞƐƵƌĨĂĐĞŝŵ ƉŽƵŶĚŵ ĞŶƚƐĂƐĂŵ ĞĂŶƐŽĨƚƌĞĂƟŶŐǁ ĂƐƚĞ͕ƚŚĞƐƵƌĨĂĐĞŝŵ ƉŽƵŶĚŵ ĞŶƚ
ƚƌĞĂƚŵ ĞŶƚĞǆĞŵ ƉƟŽŶĂůůŽǁ ƐŽǁ ŶĞƌƐĂŶĚŽƉĞƌĂƚŽƌƐƚŽĐŽŶĚƵĐƚƐƵĐŚƚƌĞĂƚŵ ĞŶƚƵŶĚĞƌĐĞƌƚĂŝŶ
ĐŽŶĚŝƟŽŶƐ͘^ƵƌĨĂĐĞŝŵ ƉŽƵŶĚŵ ĞŶƚƐƚƌĞĂƟŶŐǁ ĂƐƚĞƵŶĚĞƌƚŚŝƐĞǆĞŵ ƉƟŽŶŵ ƵƐƚĐŽŵ ƉůǇǁ ŝƚŚƚŚĞ
double liner and minimum technical requirements, and provisions for the removal of sludges and
treatment residues.
May 9, 2011 Page 17 of 28

Ʃ ĂĐŚŵ ent D
Žŵ ŵ ĞƌĐŝĂů, ĂǌĂƌĚŽƵƐt ĂƐƚĞ/ŶĐŝŶĞƌĂƟŽŶ&ĂĐŝůŝƟĞƐŝŶƚŚĞh ŶŝƚĞĚ^ƚĂƚĞƐ WĞƌŵ ŝƩ ĞĚĂŶĚĐƟǀĞůǇD ĂŶĂŐŝŶŐZZŽŶƚĂŵ ŝŶĂƚĞĚSoils

EPA ID Facility Name Street Address City State Zip Code Phone Contact/e-mail address
EPA Region 5
Veolia ^dĞĐŚŶŝĐĂů^ŽůƵƟŽŶƐ>>
ILD098642424 7 Mobile Ave Sauget IL 62201 6182712804 Doug Harris
(Onyx Environmental Services)
Eric Chokan,
OHD048415665 ZŽƐƐ/ŶĐŝŶĞƌĂƟŽŶ^ĞƌǀŝĐĞƐ/ŶĐ͘ 36790 Giles Rd ' ƌĂŌ ŽŶ OH 44044-9586 4403662038
echokan@rossenvironmental.com
John Audellas
OHD980613541 Heritage - WTI, Inc. 1250 Saint George St East Liverpool OH 43920 3303862167 customerservice@heritage-ǁ Ɵ͘ĐŽŵ
EPA Region 6
ARD006354161 Reynolds Metals Company 500 East Reynolds Rd Arkadelphia AR 71923 8702452720 Lyn Shepherd
Treasa Evans
ARD069748192 Clean Harbors El Dorado, LLC 309 American Circle El Dorado AR 71730 8708637173
evans.treasa@cleanharbors.com
TXD000838896 s ĞŽůŝĂ^dĞĐŚŶŝĐĂů^ŽůƵƟŽŶƐ>> Highway 73 Port Arthur TX 77640 4097362821 Michelle Herman
TXD055141378 Clean Harbors Deer Park LP ϮϬϮϳĂƩ ůĞŐƌŽƵŶĚRd Deer Park TX 77536 2819302300 Craig Elam
EPA Region 7
EBV Explosives Environmental Co. 4147826366 Dave Zoghby
MOD985798164 3078 County Rd 180 Joplin MO 64801
(ICI Explosives Environmental Co.) 6102983085 dave.zoghby@ebveec.com
NED981723513 Clean Harbors Environmental Services 2247 South Highway 71 Kimball NE 69145 3082354012 Jared Hunsaker
EPA Region 8
Melissa Scales
UTD981552177 Clean Harbors Aragonite LLC 11600 North Aptus Rd Aragonite UT 84209 4358848877
scalesm@cleanharbors.com
Sources: (1) EPA. RCRAInfo/Permit Module. Data current as of September 16, 2010; 2007 BR
;ϮͿŽůůĂďŽƌĂƟŽŶǁ ŝƚŚWZĞŐŝŽŶƐĂŶĚ^ƚĂƚĞƐ͘
March 21, 2011 Page 18 of 28

Commercial Hazardous Waste >ĂŶĚĮůů&ĂĐŝůŝƟĞƐŝŶƚŚĞh ŶŝƚĞĚ^ƚĂƚĞƐ WĞƌŵ ŝƩ ĞĚĂŶĚ ĐƟǀĞůǇD ĂŶĂŐŝŶŐZZŽŶƚĂŵ ŝŶĂƚĞĚSoils
Sources: (1) EPA. RCRAInfo/Permit Module. Data current as of September 16, 2010; 2007 BR; ;ϮͿŽůůĂďŽƌĂƟŽŶǁ ŝƚŚWZĞŐŝŽŶƐĂŶĚ^ƚĂƚĞƐ͘
EPA ID Facility Name Street Address City State Zip Code Phone Contact/e-mail address
EPA Region 2
NYD049836679 CWM Chemical Services, LLC 1550 Balmer Rd Model City NY 14107 7167548231 Michael Mahar
EPA Region 4
2056529721 Mike Davis
ALD000622464 Chemical Waste Management 36964 Alabama Highway 17 Emelle AL 35459
8006525755 tscalabama@wm,com
EPA Region 5
Ron Welk
ILD000805812 Peoria Disposal Co Inc 4349 Southport Rd Peoria IL 61604 3096764893
rwelk@pdcarea.com
Winde Hamrick
IND980503890 Heritage Environmental Services LLC 4370 W Cr 1275 N Roachdale IN 46172 7654352704
webmaster@heritage-enviro.com
EQ-The Environmenal Quality Company,Wayne EQ Customer Service
MID048090633 49350 N I94 Service Dr Belleville MI 48111 8005925489
Disposal Inc customerservice@eqonline.com
4196983500 Lisa Humphrey
OHD045243706 Envirosafe Services of Ohio Inc ϴϳϲK Ʃ ĞƌƌĞĞŬZĚ Oregon OH 43616
8005370426 l.humphrey@envirosafeservices.com
EPA Region 6
Chuck Grnat
LAD000777201 Chemical Waste Management Lake Charles 7170 John Brannon Rd Sulphur LA 70665 3375835735
cgrant@wm.com
William J. Clark
LAD010395127 Clean Harbors Baton Rouge LLC 13351 Scenic Highway Baton Rouge LA 70807 2257781234
clarkwj@cleanharbors.com
Clean Harbors Environmental Services
OKD065438376 Route 2 Box 170 Waynoka OK 73860 5806973500 Jay Adair
Lone Mountain Facility
3613873518 Cathy Sturow
TXD069452340 US Ecology Texas Inc 3277 County Rd 69 Robstown TX 78380
ext.255 csturow@americanecology.com
Linda Beach
TXD988088464 Waste Control Specialists LLC 1710 W State Highway 176 Andrews TX 79714 8887892783
ůďĞĂĐŚΛ ǁ ĞƐƩ ĞǆĂƐ͘ĐŽŵ
EPA Region 8
COD991300484 Clean Harbors Deer Trail LLC 108555 E Hwy 36 Deer Trail CO 80105 9703862293 Jack Kehoe
ŶĞƌŐǇƐŽůƵƟŽŶƐ͕/ŶĐ͘ U.S. Interstate 80, Exit 49 One Mile Tye Rogers
UTD982598898 Grantsville UT 84029 8016492000
(Envirocare) South of Clive ƚƌŽŐĞƌƐΛ ĞŶĞƌŐǇƐŽůƵƟŽŶƐ͘ĐŽŵ
3 Miles East, 7 Miles North Knolls Shane Whitney
UTD991301748 Clean Harbors Grassy Mountain, LLC Salk Lake City UT 84122 4358848900
Exit 41, off I-80 whitney,shane@cleanharbors.com
EPA Region 9
CAD000633164 Clean Harbors Westmorland, LLC 5295 South Garvey Rd Westmorland CA 92281 7603449400 Andrew Yadvish
CAD980675276 ůĞĂŶ, ĂƌďŽƌƐƵƩ ŽŶǁ ŝůůŽǁ 2500 Lokern Rd ƵƩ ŽŶǁ ŝůůŽǁ CA 93206 6617626200 Customer Service Department
CAT000646117 Chemical Waste Management, Inc. 35251 Old Skyline Rd <ĞƩ ůĞŵ ĂŶŝƚǇ CA 93239 5593869711 Customer Service
Highway 95, 11 Miles South of 8002393943 Aarin Bermudez
NVT330010000 US Ecology Nevada ĞĂƩ Ǉ NV 89003
ĞĂƩ Ǉ ext.129 Abermudez@americanecology.com
EPA Region 10
IDD073114654 US Ecology Idaho Inc Site B 20400 Lemley Rd Grand View ID 83624 8002741516 Kevin Trader
ORD089452353 Chemical Waste Management of the Northwest 17629 Cedar Springs Ln Arlington OR 97812 5414542643 Cal Palmer
March 21, 2011 Page 19 of 28

Ʃ ĂĐŚŵ ĞŶƚE
>ĂŶĚ ŝƐƉŽƐĂůZĞƐƚƌŝĐƟŽŶƐdƌĞĂƚŵ ĞŶƚ^ƚĂŶĚĂƌĚƐĂƚϰϬ&ZϮϲϴ͘ϰϬ Applicable to EPA Waste Codes Associated with Dioxin
ůƚĞƌŶĂƟǀĞSoil
As-Generated Waste
ZĞŐƵůĂƚĞĚ, ĂǌĂƌĚŽƵƐŽŶƐƟƚƵĞŶƚ Treatment Standard
Treatment Standard
;ϭϬƟŵ ĞƐƚŚĞh d^Ϳ
Waste Code t ĂƐƚĞ ĞƐĐƌŝƉƟŽŶĂŶĚdƌĞĂƚŵ ĞŶƚͬRegulatory Subcategory ŽŶĐĞŶƚƌĂƟŽŶŝŶŵ ŐͬŬŐ ŽŶĐĞŶƚƌĂƟŽŶŝŶ
mg/kg unless noted as
Common Name CAS Number
Technology Code Technology Code
F020, Wastes (except wastewater and spent carbon from hydrogen HxCDDs (All Hexachlorodibenzo-p-dioxins) NA 0.001 0.01
F021, F022, ĐŚůŽƌŝĚĞƉƵƌŝĮĐĂƟŽŶͿĨƌŽŵ ƚŚĞƉƌŽĚƵĐƟŽŶŽƌŵ ĂŶƵĨĂĐƚƵƌŝŶŐƵƐĞ;ĂƐ
F023, F026 ĂƌĞĂĐƚĂŶƚ͕ĐŚĞŵ ŝĐĂůŝŶƚĞƌŵ ĞĚŝĂƚĞ͕ŽƌĐŽŵ ƉŽŶĞŶƚŝŶĂĨŽƌŵ ƵůĂƟŶŐ Hx CDFs (All Hexachlorodibenzofurans) NA 0.001 0.01
process) of: (1) tri- or tetrachlorophenol, or of intermediates used
ƚŽƉƌŽĚƵĐĞƚŚĞŝƌƉĞƐƟĐŝĚĞĚĞƌŝǀĂƟǀĞƐ͕ĞǆĐůƵĚŝŶŐǁ ĂƐƚĞƐĨƌŽŵ ƚŚĞ PeCDDs (All Pentachlorodibenzo-p-dioxins) NA 0.001 0.01
ƉƌŽĚƵĐƟŽŶŽĨ, ĞǆĂĐŚůŽƌŽƉŚĞŶĞĨƌŽŵ ŚŝŐŚůǇƉƵƌŝĮĞĚ͕Ϯ͕ϰ͕ϱ-
trichlorophenol (F020); (2) pentachlorophenol, or of intermediates PeCDFs (All Pentachlorodibenzofurans) NA 0.001 0.01
ƵƐĞĚƚŽƉƌŽĚƵĐĞŝƚƐĚĞƌŝǀĂƟǀĞƐ;ŝ͘Ğ͕͘&ϬϮϭͿ͖;ϯͿtetra-, penta-, or
ŚĞǆĂĐŚůŽƌŽďĞŶǌĞŶĞƐƵŶĚĞƌĂůŬĂůŝŶĞĐŽŶĚŝƟŽŶƐ;ŝ͘Ğ͕͘&ϬϮϮͿ͖ĂŶĚ Pentachlorophenol 87 86 5 7.4 74
ĨƌŽŵ ƚŚĞƉƌŽĚƵĐƟŽŶŽĨŵ ĂƚĞƌŝĂůƐŽŶĞƋƵŝƉŵ ĞŶƚƉƌĞǀŝŽƵƐůǇƵƐĞĚĨŽƌ
ƚŚĞƉƌŽĚƵĐƟŽŶŽƌŵ ĂŶƵĨĂĐƚƵƌŝŶŐƵƐĞ;ĂƐĂƌĞĂĐƚĂŶƚ͕ĐŚĞŵ ŝĐĂů TCDDs (All Tetrachlorodibenzo-p-dioxins) NA 0.001 0.01
ŝŶƚĞƌŵ ĞĚŝĂƚĞ͕ŽƌĐŽŵ ƉŽŶĞŶƚŝŶĂĨŽƌŵ ƵůĂƟŶŐƉƌŽĐĞƐƐͿŽĨ͗;ϭ) tri- or
tetrachlorophenols, excluding wastes from equipment used only TCDFs (All Tetrachlorodibenzofurans) NA 0.001 0.01
ĨŽƌƚŚĞƉƌŽĚƵĐƟŽŶŽĨ, ĞǆĂĐŚůŽƌŽƉŚĞŶĞĨƌŽŵ ŚŝŐŚůǇƉƵƌŝĮĞĚϮ͕ϰ͕ϱ-
trichlorophenol (F023); (2) tetra- penta, or hexachlorobenzenes 2,4,5-Trichlorophenol 95 95 4 7.4 74
ƵŶĚĞƌĂůŬĂůŝŶĞĐŽŶĚŝƟŽŶƐ;ŝ͘Ğ͕͘&ϬϮϲͿ͘
2,4-6-Trichlorophenol 88 06 2 7.4 74
2,3,4,6-Tetrachlorophenol 58 90 2 7.4 74
F027 ŝƐĐĂƌĚĞĚƵŶƵƐĞĚĨŽƌŵ ƵůĂƟŽŶƐĐŽŶƚĂŝŶŝŶŐƚƌŝ-, tetra-, or HxCDDs (All Hexachlorodibenzo-p-dioxins) NA 0.001 0.01
ƉĞŶƚĂĐŚůŽƌŽƉŚĞŶŽůŽƌĚŝƐĐĂƌĚĞĚƵŶƵƐĞĚĨŽƌŵ ƵůĂƟŽŶƐĐŽŶƚĂŝŶŝŶŐ
compounds derived from these chlorophenols͘;dŚŝƐůŝƐƟŶŐĚŽĞƐ HxCDFs (All Hexachlorodibenzofurans) NA 0.001 0.01
ŶŽƚŝŶĐůƵĚĞĨŽƌŵ ƵůĂƟŽŶƐĐŽŶƚĂŝŶŝŶŐŚĞǆĂĐŚůŽƌŽƉŚĞŶĞƐǇŶƚŚĞƐŝǌĞĚ
from prepurified 2,4,5-trichlorophenol as the sole component.) PeCDDs (All Pentachlorodibenzo-p-dioxins) NA 0.001 0.01
PeCDFs (All Pentachlorodibenzofurans) NA 0.001 0.01
Pentachlorophenol 87 86 5 7.4 74
TCDDs (All Tetrachlorodibenzo-p-dioxins) NA 0.001 0.01
TCDFs (All Tetrachlorodibenzofurans) NA 0.001 0.01
2,4,5-Trichlorophenol 95 95 4 7.4 74
March 21, 2011 Page 20 of 28

As-Generated Waste
Treatment Standard
F028 ZĞƐŝĚƵĞƐƌĞƐƵůƟŶŐĨƌŽŵ ƚŚĞŝŶĐŝŶĞƌĂƟŽŶŽƌƚŚĞƌŵ ĂůƚƌĞĂƚŵ ĞŶƚŽĨ HxCDDs (All Hexachlorodibenzo-p-dioxins) NA 0.001 0.01
soils contaminated with EPA Hazardous Wastes Nos. F020, F021,
F023, F026, and F027. HxCDFs (All Hexachlorodibenzofurans) NA 0.001 0.01
PeCDDs (All Pentachlorodibenzo-p-dioxins) NA 0.001 0.01
F032 Wastewaters (except those that have not come into contact with Acenaphthene 83 32 9 3.4 34
ƉƌŽĐĞƐƐĐŽŶƚĂŵ ŝŶĂŶƚƐͿ͕ƉƌŽĐĞƐƐƌĞƐŝĚƵĂůƐ͕ƉƌĞƐĞƌǀĂƟǀĞĚƌŝƉƉĂŐĞ,
ĂŶĚƐƉĞŶƚĨŽƌŵ ƵůĂƟŽŶƐĨƌŽŵ ǁ ŽŽĚƉƌĞƐĞƌǀŝŶŐƉƌŽĐĞƐƐĞƐŐĞŶĞƌĂƚĞĚ Anthracene 120 12 7 3.4 34
at plants that currently use or have previously used chlorophenolic
ĨŽƌŵ ƵůĂƟŽŶƐ;ĞǆĐĞƉƚƉŽƚĞŶƟĂůůǇĐƌŽƐƐ-contaminated wastes that Benz(a)anthracene 56 55 3 3.4 34
have had the F032 waste code deleted in accordance with §261.35
ŽĨƚŚŝƐĐŚĂƉƚĞƌŽƌƉŽƚĞŶƟĂůůǇĐƌŽƐƐ-contaminated wastes that are ĞŶǌŽ;ďͿŇƵŽƌĂŶƚŚĞŶĞ;Ěŝĸ ĐƵůƚƚŽĚŝƐƟŶŐƵŝƐŚĨƌŽŵ 205 99 2 6.8 68
otherwise currently regulated as hazardous wastes (i.e., F034 or benzo(k)fluoranthene)
&ϬϯϱͿ͕ĂŶĚǁ ŚĞƌĞƚŚĞŐĞŶĞƌĂƚŽƌĚŽĞƐŶŽƚƌĞƐƵŵ ĞŽƌŝŶŝƟĂƚĞƵƐĞŽĨ
ĐŚůŽƌŽƉŚĞŶŽůŝĐĨŽƌŵ ƵůĂƟŽŶƐͿ͘dŚŝƐůŝƐƟŶŐĚŽĞƐŶŽƚŝnclude K001 ĞŶǌŽ;ŬͿŇƵŽƌĂŶƚŚĞŶĞ;Ěŝĸ ĐƵůƚƚŽĚŝƐƟŶŐƵŝƐŚĨƌŽŵ 207 08 9 6.8 68
ďŽƩ Žŵ ƐĞĚŝŵ ĞŶƚƐůƵĚŐĞĨƌŽŵ ƚŚĞƚƌĞĂƚŵ ĞŶƚŽĨǁ ĂƐƚĞǁ ĂƚĞƌĨƌŽŵ benzo(b)fluoranthene)
wood preserving processes that use creosote and/or penta-
chlorophenol. Benzo(a)pyrene 50 32 8 3.4 34
Chrysene 218 01 9 3.4 34
Dibenz(a,h) anthracene 53 70 3 8.2 82
2-4-Dimethyl phenol 105 67 9 14 140
Fluorene 86 73 7 3.4 34
March 21, 2011 Page 21 of 28

As-Generated Waste
Treatment Standard
Hexachlorodibenzo-p-dioxins NA 0.001, or CMBST 0.01
Hexachlorodibenzofurans NA 0.001, or CMBST 0.01
Indeno (1,2,3-c,d) pyrene 193 39 5 3.4 34
Naphthalene 91 20 3 5.6 56
Pentachlorodibenzo-p-dioxins NA 0.001, or CMBST 0.01
Pentachlorodibenzofurans NA 0.001, or CMBST 0.01
Phenanthrene 85 01 8 5.6 56
Phenol 108 95 2 6.2 62
Pyrene 129 00 0 8.2 82
Tetrachlorodibenzo-p-dioxins NA 0.001, or CMBST 0.01
Tetrachlorodibenzofurans NA 0.001, or CMBST 0.01
Arsenic 7440 38 2 5.0 mg/L TCLP 50 mg/L
Chromium (Total) 7440 47 3 0.60 mg/L TCLP 6 mg/L
March 21, 2011 Page 22 of 28

As-Generated Waste
Treatment Standard
F039
March 21, 2011 Page 23 of 28

As-Generated Waste
Treatment Standard
K043 2,6- ŝĐŚůŽƌŽƉŚĞŶŽůǁ ĂƐƚĞĨƌŽŵ ƚŚĞƉƌŽĚƵĐƟŽŶŽĨϮ͕ϰ-D 2,4-Dichlorophenol 120-83-2 14 140
2,6-Dichlorophenol 187-65-0 14 140
2,4,5-Trichlorophenol 95-95-4 7.4 74
2,4,6-Trichlorophenol 88-06-2 7.4 74
2,3,4,6-Tetrachlorphenol 58-90-2 7.4 74
Pentachlorophenol 87-86-5 7.4 74
Tetrachloroethylene 127-18-4 6.0 60
HxCDDs (All Hexachlorodibenzo-p-dioxins) NA 0.001 0.01
HxCDFs ( All Hexachlorodibenzofurans) NA 0.001 0.01
March 21, 2011 Page 24 of 28

As-Generated Waste
Treatment Standard
K099 h ŶƚƌĞĂƚĞĚǁ ĂƐƚĞǁ ĂƚĞƌĨƌŽŵ ƚŚĞƉƌŽĚƵĐƟŽŶŽĨϮ͕ϰ-D HxCDDs (All Hexachlorodibenzo-p-dioxins) NA 0.001 0.01
HxCDFs ( All Hexachlorodibenzofurans) NA 0.001 0.01
2.4- ŝĐŚůŽƌŽƉŚĞŶŽǆǇĂĐĞƟĐĂĐŝĚ 94-75-7 10 100
March 21, 2011 Page 25 of 28

As-Generated Waste
Treatment Standard
K174 t ĂƐƚĞǁ ĂƚĞƌƚƌĞĂƚŵ ĞŶƚƐůƵĚŐĞƐĨƌŽŵ ƚŚĞƉƌŽĚƵĐƟŽŶŽĨĞƚŚǇůĞŶĞ 1,2,3,4,6,7,8-Heptachlorodibenzo- p -dioxin (1,2,3,4,6,7,8- 35822 46 9 0.0025 or CMBST 0.025
dichloride or vinyl chloride monomer (including sludges that result HpCDD)
from commingled ethylene dichloride or vinyl chloride monomer
wastewater and other wastewater), unless the sludges meet the 1,2,3,4,6,7,8-Heptachlorodibenzofuran (1,2,3,4,6,7,8- 67562 39 4 0.0025 or CMBST 0.025
ĨŽůůŽǁ ŝŶŐĐŽŶĚŝƟŽŶƐ͗;ŝͿƚŚĞǇĂƌĞĚŝƐƉŽƐĞĚŽĨŝŶĂƐƵďƟƚůĞŽƌŶŽŶ- HpCDF)
ŚĂǌĂƌĚŽƵƐůĂŶĚĮůůůŝĐĞŶƐĞĚŽƌƉĞƌŵ ŝƩ ĞĚďǇƚŚĞƐƚĂƚĞŽƌĨĞĚĞƌĂů
government; (ii) they are not otherwise placed on the land prior to 1,2,3,4,7,8,9-Heptachlorodibenzofuran (1,2,3,4,7,8,9- 55673 89 7 0.0025 or CMBST 0.025
final disposĂů͖ĂŶĚ;ŝŝŝͿƚŚĞŐĞŶĞƌĂƚŽƌŵ ĂŝŶƚĂŝŶƐĚŽĐƵŵ ĞŶƚĂƟŽŶ HpCDF)
ĚĞŵ ŽŶƐƚƌĂƟŶŐƚŚĂƚƚŚĞǁ ĂƐƚĞǁ ĂƐĞŝƚŚĞƌĚŝƐƉŽƐĞĚŽĨŝŶĂŶŽŶ-site
landfill or consigned to a transporter or disposal facility that HxCDDs (All Hexachlorodibenzo- p -dioxins) 34465 46 8 0.001 or CMBST 0.01
ƉƌŽǀŝĚĞĚĂǁ ƌŝƩ ĞŶĐŽŵ ŵ ŝƚŵ ĞŶƚƚŽĚŝƐƉŽƐĞŽĨƚŚĞǁ ĂƐƚĞŝŶĂŶŽī -
site landĮůů͘ZĞƐƉŽŶĚĞŶƚƐŝŶĂŶǇĂĐƟŽŶďƌŽƵŐŚƚƚŽĞŶĨŽƌĐĞƚŚĞ HxCDFs (All Hexachlorodibenzofurans) 55684 94 1 0.001 or CMBST 0.01
ƌĞƋƵŝƌĞŵ ĞŶƚƐŽĨƐƵďƟƚůĞŵ ƵƐƚ͕ƵƉŽŶĂƐŚŽǁ ŝŶŐďǇƚŚĞ
government that the respondent managed wastewater treatment 1,2,3,4,6,7,8,9-Octachlorodibenzo- p -dioxin (OCDD) 3268 87 9 0.005 or CMBST 0.05
ƐůƵĚŐĞƐĨƌŽŵ ƚŚĞƉƌŽĚƵĐƟŽŶŽĨǀŝŶǇůĐŚůŽƌŝĚĞŵ ŽŶŽŵ ĞƌŽƌĞƚŚǇůĞŶĞ
dichloride, demonstrate that they meet the terms of the exclusion 1,2,3,4,6,7,8,9-Octachlorodibenzofuran (OCDF) 39001 02 0 0.005 or CMBST 0.05
set forth above. In doing so, they must provide appropriate
ĚŽĐƵŵ ĞŶƚĂƟŽŶ;Ğ͘Ő͕͘ĐŽŶƚƌĂĐƚƐďĞƚǁ ĞĞŶƚŚĞŐĞŶĞƌĂƚŽƌĂŶĚƚŚĞ PeCDDs (All Pentachlorodibenzo- p dioxins 36088 22 9 0.001 or CMBST 0.01
ůĂŶĚĮůůŽǁ ŶĞƌͬŽƉĞƌĂƚŽƌ͕ŝŶǀŽŝĐĞƐĚŽĐƵŵ ĞŶƟŶŐĚĞůŝǀĞƌǇŽĨǁ ĂƐƚĞƚŽ
landfill, etc.) that the terms of the exclusion were met PeCDFs (All Pentachlorodibenzofurans) 30402 15 4 0.001 or CMBST 0.01
TCDDs (All tetachlorodibenzo- p -dioxins) 41903 57 5 0.001 or CMBST 0.01
TCDFs (All tetrachlorodibenzofurans) 55722 27 5 0.001 or CMBST 0.01
Arsenic 7440 36 0 5.0 mg/L TCLP 50 mg/L TCLP
March 21, 2011 Page 26 of 28

As-Generated Waste
Treatment Standard
K178 Residues from manufacturing and manufacturing-site storage of 1,2,3,4,6,7,8-Heptachlorodibenzo- p -dioxin (1,2,3,4,6,7,8- 35822 46 9 0.0025 or CMBST 0.025
ĨĞƌƌŝĐĐŚůŽƌŝĚĞĨƌŽŵ ĂĐŝĚƐĨŽƌŵ ĞĚĚƵƌŝŶŐƚŚĞƉƌŽĚƵĐƟŽŶŽĨƟƚĂŶŝƵŵ HpCDD)
dioxide using the chloride-ŝůŵ ĞŶƟƚĞƉƌŽĐĞƐƐ
1,2,3,4,6,7,8-Heptachlorodibenzofuran (1,2,3,4,6,7,8- 67562 39 4 0.0025 or CMBST 0.025
HpCDF)
1,2,3,4,7,8,9-Heptachlorodibenzofuran (1,2,3,4,7,8,9- 55673 89 7 0.0025 or CMBST 0.025

HpCDF)
HxCDDs (All Hexachlorodibenzo- p -dioxins) 34465 46 8 0.001 or CMBST 0.01
HxCDFs (All Hexachlorodibenzofurans) 55684 94 1 0.001 or CMBST 0.01
1,2,3,4,6,7,8,9-Octachlorodibenzo- p -dioxin (OCDD) 3268 87 9 0.005 or CMBST 0.05
1,2,3,4,6,7,8,9-Octachlorodibenzofuran (OCDF) 39001 02 0 0.005 or CMBST 0.05
PeCDDs (All Pentachlorodibenzo- p dioxins 36088 22 9 0.001 or CMBST 0.01
PeCDFs (All Pentachlorodibenzofurans) 30402 15 4 0.001 or CMBST 0.01
TCDDs (All tetachlorodibenzo- p -dioxins) 41903 57 5 0.001 or CMBST 0.01
TCDFs (All tetrachlorodibenzofurans) 55722 27 5 0.001 or CMBST 0.01
Thallium 7440-28-0 0.20 mg/L TCLP 2.0 mg/L TCLP
March 21, 2011 Page 27 of 28

Ʃ ĂĐŚŵ ĞŶƚF
References
USEPA; ZZK ƌŝĞŶƚĂƟŽŶD ĂŶƵĂůϮϬϬϴ͗ZĞƐŽƵƌĐĞŽŶƐĞƌǀĂƟŽŶĂŶĚZĞĐŽǀĞƌǇĐƚ͕^ĞĐƟŽŶ

///͗ZZ^ƵďƟƚůĞ- D ĂŶĂŐŝŶŐ, ĂǌĂƌĚŽƵƐt ĂƐƚĞ͕ŚĂƉƚĞƌϲ͗>ĂŶĚ ŝƐƉŽƐĂůZĞƐƚƌŝĐƟŽns;
2008. Available online at: ŚƩ Ɖ͗ͬͬǁ ǁ ǁ ͘ĞƉĂ͘ŐŽǀͬĞƉĂǁ ĂƐƚĞͬŝŶĨŽƌĞƐŽƵƌĐĞƐͬƉƵďƐͬŽƌŝĞŶƚĂƚͬ,
last accessed on August 2, 2010.
USEPA, ' ƵŝĚĂŶĐĞŽŶ Ğŵ ŽŶƐƚƌĂƟŶŐŽŵ ƉůŝĂŶĐĞt ŝƚŚƚŚĞ>ĂŶĚ ŝƐƉŽƐĂůZĞƐƚƌŝĐƟŽŶƐ;> ZͿ

ůƚĞƌŶĂƟǀĞ^ŽŝůdƌĞĂƚŵ ĞŶƚ^ƚĂŶĚĂƌĚƐ- Final Guidance, EPA530-R-02-003, July 2001.
Available online at: ŚƩ Ɖ͗ͬͬǁ ǁ ǁ ͘ĞƉĂ͘ŐŽǀͬǁ ĂƐƚĞƐͬŚĂǌĂƌĚͬƚƐĚͬůĚƌͬƐŽŝůͺĨϰ͘ƉĚĨ, last accessed
on August 2, 2010.
-K-05-013, September 2005.

Available online at:
ŚƩ Ɖ͗ͬͬǁ ǁ ǁ ͘ĞƉĂ͘ŐŽǀͬǁ ĂƐƚĞƐͬŝŶĨŽƌĞƐŽƵƌĐĞƐͬƉƵďƐͬŚŽƚůŝŶĞͬƚƌĂŝŶŝŶŐͬůĚƌϬϱ͘ƉĚĨ, last accessed
on August 2, 2010.
March 21, 2011

FIELD ACTIVITIES
Other Site Hazards
5.0 Other Site Hazards
5.1 PHYSICAL HAZARDS
Physical hazards may include uneven terrain, sharp debris, electrical fencing, holes, noise, etc.
The most likely physical hazards at the site are uneven terrain (curbs and gutters) and sharp
debris. To protect yourself, always look before you step and wear proper PPE for the task being
performed.
5.2 WEATHER AND NATURAL DISASTERS
Hazards associated with weather and natural disasters may include, but are not limited to,
effects of extreme heat (heat exhaustion, heat stroke), effects of extreme cold (hypothermia,
frostbite), high winds/tornadoes, heavy rain, lightening/thunderstorms, heavy snow, ice,
earthquakes, landslides, flooding, etc.
The most likely hazards at the site are effects of extreme heat/cold (heat exhaustion, heat stroke,
hypothermia, frost bite).
To protect yourself from heat, perform the heaviest work at the coolest part of the day; drink
plenty of cool water; wear light, loose-fitting, breathable clothing; and take frequent, short
breaks in the shade. Certain medications, having a previous heat-related illness, and wearing
PPE such as a respirator or protective suit can put you at increased risk.
To protect yourself from cold, perform the bulk of the work during the warmest part of the day,
wear proper PPE and clothing to insulate the body from the cold and protect the body from
coming into contact with moisture, take frequent breaks in a warm, dry shelter, use the buddy
system, and eat warm, high-calorie foods.
19
FIELD ACTIVITIES
Other Site Hazards
Before Extreme Heat

To prepare for extreme heat, you should:
 To begin preparing, you should build an emergency kit and make a communications
plan.
 Install window air conditioners snugly; insulate if necessary.
 Check air-conditioning ducts for proper insulation.
Install temporary window reflectors (for use between windows and drapes), such as aluminum
foil-covered cardboard, to reflect heat back outside.
 Weather-strip doors and sills to keep cool air in.
 Cover windows that receive morning or afternoon sun with drapes, shades, awnings, or
louvers. (Outdoor awnings or louvers can reduce the heat that enters a home by up to
80 percent.)
 Keep storm windows up all year.
 Listen to local weather forecasts and stay aware of upcoming temperature changes.
 Know those in your neighborhood who are elderly, young, sick or overweight. They are
more likely to become victims of excessive heat and may need help.
 Be aware that people living in urban areas may be at greater risk from the effects of a
prolonged heat wave than are people living in rural areas.
 Get trained in first aid to learn how to treat heat-related emergencies
During Extreme Heat

What you should do if the weather is extremely hot:
 Listen to NOAA Weather Radio for critical updates from the National Weather Service
(NWS).
 Never leave children or pets alone in closed vehicles.
 Stay indoors as much as possible and limit exposure to the sun.
 Stay on the lowest floor out of the sunshine if air conditioning is not available.
20
FIELD ACTIVITIES
Other Site Hazards
 Postpone outdoor games and activities.

 Consider spending the warmest part of the day in public buildings such as libraries,
schools, movie theaters, shopping malls, and other community facilities. Circulating air
can cool the body by increasing the perspiration rate of evaporation.
 Eat well-balanced, light, and regular meals. Avoid using salt tablets unless directed to do
so by a physician.
 Drink plenty of water; even if you do not feel thirsty. Avoid drinks with caffeine. Persons
who have epilepsy or heart, kidney, or liver disease; are on fluid-restricted diets; or have
a problem with fluid retention should consult a doctor before increasing liquid intake.
 Limit intake of alcoholic beverages.
 Dress in loose-fitting, lightweight, and light-colored clothes that cover as much skin as
possible. Avoid dark colors because they absorb the sun’s rays.
 Protect face and head by wearing a wide-brimmed hat.
 Avoid strenuous work during the warmest part of the day. Use a buddy system when
working in extreme heat, and take frequent breaks.
 Check on family, friends, and neighbors who do not have air conditioning and who
spend much of their time alone.
Before Winter Storms and Extreme Cold

To prepare for a winter storm you should do the following:
 Before winter approaches, add the following supplies to your emergency kit:
o Rock salt or more environmentally safe products to melt ice on walkways. Visit
the Environmental Protection Agency for a complete list of recommended
products.
o Sand to improve traction.
o Snow shovels and other snow removal equipment.
o Sufficient heating fuel. You may become isolated in your home and regular fuel
sources may be cut off. Store a good supply of dry, seasoned wood for your
fireplace or wood-burning stove.
o Adequate clothing and blankets to keep you warm.
21
FIELD ACTIVITIES
Other Site Hazards
 Make a Communications Plan. Your may not be with coworkers, family, etc. when
disaster strikes, so it is important to know how you will contact one another, how you will
get back together and what you will do in case of an emergency.
 Listen to a NOAA Weather Radio or other local news channels for critical information
from the National Weather Service (NWS). Be alert to changing weather conditions.
 Minimize travel. If travel is necessary, keep a disaster supplies kit in your vehicle.
 Bring pets/companion animals inside during winter weather. Move other animals or
livestock to sheltered areas with non-frozen drinking water.
During Winter Storms and Extreme Cold

 Stay indoors during the storm.
 Walk carefully on snowy, icy, walkways.
 Avoid overexertion when shoveling snow. Overexertion can bring on a heart attack—a
major cause of death in the winter. If you must shovel snow, stretch before going outside.
 Keep dry. Change wet clothing frequently to prevent a loss of body heat. Wet clothing
loses all of its insulating value and transmits heat rapidly.
 Watch for signs of frostbite. These include loss of feeling and white or pale appearance in
extremities such as fingers, toes, ear lobes, and the tip of the nose. If symptoms are
detected, get medical help immediately.
 Watch for signs of hypothermia. These include uncontrollable shivering, memory loss,
disorientation, incoherence, slurred speech, drowsiness, and apparent exhaustion. If
symptoms of hypothermia are detected, get the victim to a warm location, remove wet
clothing, warm the center of the body first and give warm, non-alcoholic beverages if
the victim is conscious. Get medical help as soon as possible.
 Drive only if it is absolutely necessary. If you must drive: travel in the day; don’t travel
alone; keep others informed of your schedule; stay on main roads and avoid back road
shortcuts.
 Let someone know your destination, your route, and when you expect to arrive. If your
car gets stuck along the way, help can be sent along your predetermined route.
 If the pipes freeze, remove any insulation or layers of newspapers and wrap pipes in rags.
Completely open all faucets and pour hot water over the pipes, starting where they
were most exposed to the cold (or where the cold was most likely to penetrate).
 Maintain ventilation when using kerosene heaters to avoid build-up of toxic fumes. Refuel
kerosene heaters outside and keep them at least three feet from flammable objects.
 Conserve fuel.
22
FIELD ACTIVITIES
Other Site Hazards
5.3 BIOLOGICAL HAZARDS
Biological hazards may include, but are not limited to, bees/wasps, spiders, snakes, stray dogs,
and poisonous/allergenic plants.
The most likely biological hazards at the site are bees/wasps and spiders, and these may be
encountered during a number of tasks including: opening well vault covers; opening core or
sample boxes; working in tall grass, weeds, or brush; cleaning or moving materials; performing
site assessment, etc.
To mitigate hazards associated with bees/wasps:
 Avoid known locations of bees/wasps.

 Keep your eyes and ears open for swarms.
 Look for insects flying in and out of openings such as a crack in the wall, an open pipe
end, or a well vault lid.
 Be cautious of tall grass as some bees build their hives at ground level.
 Be cautious of pointed structures, especially in barns, storage sheds, and outbuildings as
bees often build hives in those structures.
 Avoid wearing citrus or floral aftershaves or perfumes as bees/wasps may be attracted
to these odors.
 Wear light colored clothing as insects are generally attracted to dark colors.
 Fill in cracks or crevices and close open ends of pipes when bees/wasps are not around.
 Leave the area as quickly as possible if a nest has been disturbed. Do not retrieve
nearby belongings. Do not stand still. Do not try to fight them.
If stung by a bee or wasp, wash the area with soap and water, and use Benadryl from the First
Aid kit. If you have been stung over 15 times or are having symptoms other than pain and
swelling, seek emergency medical assistance immediately. Staff that are allergic will carry an
EpiPen® as prescribed by a doctor.
To mitigate hazards associated with spiders:
 Be cautious when opening well boxes, pipes, electrical and equipment panels.
 Be cautious when moving materials and/or tools inside the remediation compound; i.e.
corners of the compound or any area where it’s dry and dark.
 Open well boxes, drums, electrical and equipment panels, etc., slowly and be prepared
to step back quickly.
 Visually inspect the work area before placing your hands into a dark space/enclosed
area.
 Use a flashlight to visually inspect the work area for spiders and spider webs.
 Wear appropriate gloves. Never place a bare hand into a dark space/enclosed area.
 Use a brush or equivalent long handled tool to sweep away spider webs and dirt, etc., to
clear your work area.
 Proceed with caution and continue to visually inspect your work area.
 Leave the area immediately if a spider has been encountered. Move work materials out
of the way. Do not use insect sprays or pesticides as these may cause contamination of
sampling.
If bitten by a spider, wash the bite area with soap and water. Immobilize the bitten arm or leg to
limit movement. Try to elevate the area and keep it still to help prevent the spread of venom.
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FIELD ACTIVITIES
Other Site Hazards
Apply a cloth dampened with cold water or lined with ice to the bite to slow down the spread
of the spider's venom. Seek medical attention immediately.
Drug Paraphernalia:
If drug paraphernalia (i.e. used needles) is found at the site, field staff should notify their Stantec
supervisor, Marc Sauze. Field staff should not touch or attempt to dispose of these items.
Instead, a cone or other warning device should be placed near or on top of the items to warn
others not to touch.
24
FIELD ACTIVITIES
Site Control and Safety Procedures
6.0 Site Control and Safety Procedures
Procedures described in this section are intended to aid Stantec personnel in mitigating site
risks/hazards.
Daily Tailgate Meeting

A Daily Tailgate Meeting (DTM) will be held on-site (and documented) each morning and
afternoon involving all staff and subcontractors on-site to review the scope of work, discuss and
address potential hazards, and answer any relevant questions before work begins. The topics of
the meeting will include, at a minimum, general health and safety procedures, reviewing health
and safety policies, and reviewing the JHA and JSA(s) for the tasks to be conducted. Additional
safety meetings may be conducted if the scope of work changes during the day, or if other
health and safety issues are identified. The DTM form is located in Attachment 5.
Driving
 Review the Stantec Safe Driving Procedures provided on-site.
 Utilize the Journey Hazard Assessment Card to identify potential driving/journey/traffic
hazards before each trip. Copies of the Journey Hazard Assessment Card are located
on-site.
 Utilize the Daily Vehicle Checklist at least once a day for each vehicle driven for Stantec
business to identify potential vehicle issues/hazards. Copies of the Daily Vehicle
Inspection Checklist are located on-site.
 Have each team member who will travel to/from the site review the site-specific Journey
Management Plan (JMP) before traveling to identify routes of travel and potential
driving/journey/traffic hazards. JMP(s) will be kept with each traveling employee
throughout the entire course of travel.
 Before a driver enters a vehicle, Get Out and Look (GOAL). Conduct a 360 degree walk-
around of the vehicle to look for bystanders, traffic, obstacles, damage, and leaks in
order to reduce the risk of striking unknown objects in the environment.
 When a driver leaves a vehicle, the engine shall be turned off, the transmission placed in
park (placed in first gear or reverse for manual transmission), the parking brake set, the
keys removed from the ignition and all doors closed. Exception to this is for operational
needs/power take off (e.g., vacuum trucks, drill rigs, or other similar vehicles). Vehicles
that fall into this exception category must have the parking brake set and wheels
chocked.
 A Stantec Vehicle Collision Kit will be kept in every vehicle used for Stantec project work.
A copy of the Stantec Vehicle Collision Kit is located on site.
 Smoking is not permitted in Stantec owned, leased or rented vehicles.
Drug and Alcohol Testing

Following an incident, Stantec will follow the incident reporting procedures. If appropriate,
Stantec will include drug and alcohol testing, consistent with Stantec’s Policies and Procedures,
as well as the client’s contractual requirements for testing.
Emergency Situations and Vehicle Breakdowns

 If the vehicle becomes disabled, it shall be parked with all wheels off the main roadway
whenever possible.
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FIELD ACTIVITIES
 When exiting the vehicle, personnel shall not place themselves between oncoming
traffic and the disabled vehicle.
 If the vehicle becomes disabled within 500 feet of a curve, crest of a hill, or other visual
obstruction, the driver shall place warning devices such as reflective triangles in that
direction to provide passing traffic with ample warning. Recommended placement of
warning devices shall be no less than 100 feet or more than 500 feet from the disabled
vehicle.
 If the vehicle becomes disabled on a divided or one-way highway, the recommended
placement of warning devices shall be so that the first is 200 feet to the rear, the second
is 100 feet to the rear, and the third is not more than ten feet to the rear. Warning
devices should be placed less than two feet to the roadside of the widest portion of the
vehicle or load.
 If the vehicle becomes disabled (not including a flat tire), a professional emergency
roadside assistance company will be contacted to tow or enable the vehicle. If such
company is not available, proper towing equipment (tow strap, cables or other
equipment specifically designed for towing) must be used.
Exclusion Zone and Decontamination

No eating, drinking, or smoking within the exclusion zone. These activities will be conducted only
in designated areas of the site. Use of PDAs, cell phones, pagers, or other electrical devices
(with the exception of intrinsically safe devices) are prohibited in the exclusion zone. Personnel
will properly decontaminate after leaving an exclusion zone. Decontamination procedures may
involve disposing of Tyveks, latex gloves, etc. in a decontamination zone located immediately
outside of the exclusion zone. At a minimum, personnel will wash any exposed skin before
leaving a site using soap and water or pre-moistened cleansing towels. Stantec will evaluate
the hazards and develop site-specific decontamination procedures to address the chemical
hazards at each site. These procedures can be found in the job safety analyses.
Fit for Duty

Safety is influenced by many factors, but the most important is the health and well-being of
Stantec’s employees and partners. Physical and mental health is just as important as good
tools, good practices, and good job planning.
These questions are designed to help you do a quick self-assessment of your physical and
mental health. Any concerns resulting from your assessment regarding your ability to carry out
your job responsibilities safely and in good health need to be discussed with your supervisor
before starting work.
 Am I feeling good today and ready to work at my typical level of physical activity and
responsibility?
 Do I have any sprains, strains, areas of weakness, or soreness?
 Am I managing multiple areas of stress?
 Am I well hydrated?
 Any physically demanding activities recently (chores, sports, hobbies)?
 Am I well rested with a good energy level? When did I eat last?
 Am I taking any medications that can make me drowsy or adversely affect my safe
performance?
 Any cuts or scrapes are clean and bandaged?
 Did I remember to bring with me my health maintenance medications (blood pressure,
diabetes, cholesterol, heart, etc.)?
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FIELD ACTIVITIES
If your answers to any of the questions above indicate that you may not be ready to work,
contact your supervisor immediately to discuss a plan of action.
HASP Inspections
The site-specific HASP should be inspected in the field by the SHSO or other Stantec personnel to
determine the effectiveness of the plan. Any deficiencies should be corrected and changes will
be recorded on the HASP Modification Log.
Jewelry Safety
Jewelry can be dangerous and shall not be worn during field activities. Large earrings, long
necklaces, loose-fitting bracelets, rings, watches, etc. can become entangled in machinery and
cause removal of limbs, as well as be conductive of electricity.
Job Hazard Assessment

A Job Hazard Assessment (JHA) will be developed during the pre-planning phase of a project.
JHAs will be completed for all field jobs and focused on the control, removal, or reduction of
hazards potentially inherent in each job; and in the context of the project scope, contractors
selected, and anticipated work locations. The JHAs and project HASP will be used to enhance
crew training, improve the efficiency of the job, and provide a foundation for behavior based
safety (BBS) observations. On-site workers must review the JHA during a Pre-Field Kickoff Meeting
to ensure a thorough hazard analysis was performed and documented. The JHA form is located
in Attachment 5.
Job Safety Analysis (JSA)

JSAs will be prepared or revised prior to mobilizing to the field. Applicable JSAs will be reviewed
in detail on a daily basis by all affected on-site workers and/or visitors. Any revisions to the JSAs
will be hand written into the JSAs, forwarded to the project manager, and communicated
during Daily Toolbox Meeting (DTM) or Permit To Work (PTW) discussions. JSAs will be compared
to scope-specific Standard Operating Procedures (SOP) as a part of the hazard analysis
planning phase of the project. JSAs are located in Attachment 4.
Management of Change
The purpose of managing change is to reduce the potential for incidents associated with the
ongoing changes inherent in the management of Stantec projects. Stantec has developed a
procedure to ensure all change events are systematically reviewed, communicated, approved
and documented. Changed conditions include personnel changes including subcontractors,
property owner changes, equipment changes, scope changes, project schedule changes or
changes in materials that may be a permanent or temporary change.
The Management of Change (MOC) process outlined below will be implemented by Stantec
project staff and our subcontractors to effectively manage changed conditions when
warranted.
1. Temporary “Stop Work” to assess and communicate the need for a MOC to the Stantec
PM;
2. Document the MOC plan;
3. Evaluate health and safety and environmental impacts associated with the changed
item;
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FIELD ACTIVITIES
4. Evaluate budget and schedule impacts associated with the changed item;
5. Implement the MOC plan, and;
6. Document completion of MOC tasks.
Manual Handling
Any tasks that involve lifting, pulling, pushing, or carrying materials by hand shall be conducted
in accordance with Stantec’s Manual Handling Standard. The goals of the standard are to:
 Plan the work activity and try to eliminate manual handling through pre-job planning.
 If manual handling is the only option then ensure workers stay within lifting and carrying
limits.
 Eliminate or mitigate manual handling incidents by using proper lifting, pushing/pulling,
and carrying techniques.
During the project planning and pre-job analyses, project managers and field crews shall
complete a JHA and/or JSA for any manual lifting, pushing, pulling, or carrying that will be
required. Before manually handling objects, ensure that the Hand Safety Guideline has been
reviewed and that proper PPE is worn. Required manual handling activities shall conform to the
following limits, where “ideal” and “non-ideal” refer to the type of body posture used:
Type of Lift Number of Persons Maximum Weight
Non-ideal 1 25 lbs(11kg)
Ideal 1 50 lbs (22kg)
Ideal Team 2 or more 100 lbs (45kg)
Position # of Persons Hand Contact Maximum Weight Max Travel Distance

Front of Body 1 2 50 lbs (22kg) 10 yds/m
Front of Body 1 2 40 lbs (18 kg) 20 yds/m
Front or Side of Body 1 2 or top handle 30 lbs (13kg) 30 yds/m
Permits
Permits may include, but are not limited to, NPDES permits, City Permits, County permits, etc. and
should be discussed and verified before work begins.
Personal Protective Equipment (PPE) Assessment

The minimum standard PPE at the site is Level D and proper work attire, which includes a hard
hat, safety glasses with side shields, safety-toe boots, hi-viz leather/work gloves (specific glove
type to be determined by the PPE assessment), hi-viz chemical resistant gloves when handling
chemical or hazardous substances, hi-viz reflective safety vest, long sleeve shirt, and pants.
Clothing that is frayed, torn, excessively baggy, or has a hood or drawstring shall not be worn.
In addition, a PPE Assessment form should be completed and signed by the Stantec PM for this
job/project and included in this HASP. The PPE Assessment determines additional PPE beyond
the minimum standard Level D required for the project. Any additional PPE requirements
identified must be specified in the JSA for that task. Depending on the size, scope, and
complexity of the project, additional PPE Assessments may be needed on a task by task basis, in
which case each additional completed PPE Assessment should be attached to the task-specific
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FIELD ACTIVITIES
JSA to which it applies. The PPE Assessment form is included as Attachment 3. Refer to the
CEMC OE Required Personal Protective Equipment document for additional information.
Pre-Entry Briefing
All on-site workers and visitors will receive a pre-entry briefing prior to accessing work areas of
the site. The briefing will include reviewing contents of the HASP, signing the Acknowledgement
and Agreement Form, and completing the Site Health and Safety Quiz (Attachment 6).
Completed quizzes will be kept with the project files. The briefing for visitors may be abbreviated
to be fit-for-purpose based on the intent of the visit.
Public Questions and Press

Questions about the site posed by a neighbor, the press, or other interested parties will be
directed to the Project Manager.
Shutoff Valves/Switches
The SHSO will identify the location of shutoff valves and switches for utilities and products on the
Site Plan and disseminate this information to all site personnel and visitors as appropriate.
Site Security
Security of our staff, subcontractors, equipment, and the public is of paramount importance to
Stantec. Employees are trained in hazard recognition and will follow standard policies and
procedures to report and mitigate site security issues/hazards if identified. Note that security
consideration is different than traffic guidance and control, which also impacts security to some
extent. Security refers to personal safety and freedom from theft or violence. The following
items will be evaluated when considering security measures at the site:
 Daytime activities at the site (e.g., gas station only, gas station with convenience store,
etc.);
 Recent criminal activity at the site and nearby areas (ask site owner/operator and the
police);
 Work hours (security concerns may be different depending on the time of day); and
 Lighting at the site (thieves are generally dissuaded from stealing on well-lit sites).
Standard security measures will be implemented on site to minimize the potential for loss at the
site. Standard security measures include properly maintained lighting, functioning locks for
windows/doors/equipment storage areas, and maintaining control of tools and equipment
when not in use. Security may be implemented in a variety of ways:
 Orange construction fence (minimal security);

 Chain link fencing;
 Extra lighting;
 Specialized locks; and/or
 Contract security.
Site Smoking Policy

Stantec maintains a smoke-free work environment at job sites. Smoking is not permitted inside
the exclusion zone or work zone. Designated smoking areas will be identified and depicted on
job site maps at the start of the project for personnel who are smokers. Site personnel who are
smokers will be required to extinguish all smoking material in a designated smoking receptacle.
Sites located in remove areas or areas where fire hazards are a concern, a portable smoking
pole will be utilized in the designated smoking area to dispose cigarettes. Stantec employees
and subcontractors must adhere to this practice at all times, while working onsite.
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FIELD ACTIVITIES
Utility Location & Clearance

Any task that involves moving, disturbing, or penetrating in-place earth materials must review
and follow Stantec’s Utility Clearance Practice. This includes but is not limited to any task
involving drilling, soil boring, well installation or abandonment, excavating, trenching, auguring,
grading, driving rods or piles, or installing posts.
When on-site and before intrusive work begins, the SHSO is responsible for:
 Locating all overhead hazards such as elevated utility lines, utility poles, or canopies,
 Determining if any work locations or circumstances constitute high risk activity and if so
obtaining the PTW before work begins.
Work Hours
Work on this project will be conducted during the hours of 7:00 AM to 7:00 PM, Monday through
Friday.
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FIELD ACTIVITIES
Waste Management
7.0 Waste Management
A. Waste Generation (Type(s)/Quantities Expected):
Anticipated (YES/NO): ___YES___
Types: Liquid X Solid X Sludge ____ Other (describe) ________
Quantity (Expected Volume): <100 Gallons liquid waste

<10 Yards of soil/solid waste
B. Characteristics (Expected):
Corrosive _____ Flammable/Ignitable _____ Radioactive _____ Toxic _____
Reactive _____ Unknown X___
Other (specify) ________
C. Packaging Requirements for Waste Material (Expected):
 DOT-approved Drums X__

 Baker Tanks (possibly tankers if trucked off-site) _____
 Lined and Covered Waste Bins _X____
 Temporary Stockpile (DO NOT STOCKPILE MATERIAL ON THIS SITE DUE TO AIRBORNE
CONTAMINANT DISTRUBITION CONCERNS)
D. Disposal and/or Treatment Methods Proposed (Expected):
All wastes will be labeled, sampled and analyzed for all applicable chemicals of potential
concern and physical properties (e.g., pH, vapor pressure, etc.) to ensure proper waste
characterization. Results of analysis will determine how and where impacted materials may be
disposed of. Stratus Corp. will be responsible for the categorization and transportation of all
waste generated on this Site. All materials will be disposed of or treated in accordance with
federal, state and local regulations as selected and arranged by Stantec Consulting Services
Inc. The client Regency Centers L.P. will be responsible for signing the manifest.
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FIELD ACTIVITIES
Project Team Information
8.0 Project Team Information
8.1 TRAINING
Site personnel will be trained and certified in hazardous waste operations and emergency
response as follows:
 40-Hour HAZWOPER Training;

 Annual 8-Hour Refresher [29 CFR 1910.120(e)(8)];
 First Aid/CPR Training;
 Physical examination consistent with 29 Code of Federal Regulations (CFR) 1910.120 (and
8 California Code of Regulations (CCR) 5192, if applicable);
 Supervisory 8-hour Training [29 CFR 1910.120(e)(4)] for the Site Manager/SHSO; and
Stantec Safety Requirements:

In addition to the above-mentioned trainings, Stantec personnel are required to have training in
our behavior-based safety program, ALLY. Stantec’s ALLY system will be used to provide all
employees with a safe, healthy, loss-free workplace and prevent or reduce losses using
behavior-based tools and proven management techniques. These tools and techniques
include: Stop Work Authority, Hazard Assessment and Mitigation, Last Minute Risk Assessment
(LMRA), Job Safety Analyses, SAFE Observations, and reporting near losses and losses.
Other requirements include training in defensive driving. Respirator fit tests are required for
respirator use.
Client-Specific Safety Procedures:

No additional HSSE requirements are specified by Regency Centers, L.P.
Project Team Training Dates

CPR / Defensive
40Hr 8Hr ALLY SHSO Fit
Name First Physical Driving
HAZ Ref Training Training Test
Aid Training
Robert
4/28/2007 1/17/15 5/17/14 7/2/15 1/28/14 2/27/14 4/17/08 7/2/15
McAlister
Notes:
40Hr HAZ = 40-Hour HAZWOPER
8Hr Ref = 8-Hour HAZWOPER Refresher
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FIELD ACTIVITIES
Project Team Information
8.2 ORGANIZATION AND RESPONSIBILITIES
An organization chart for project personnel is provided below.
Rusty Benkosky
Stantec Business Unit Leader
Patrick Vaughan
Stantec Project Manager
Robert McAlister
Stantec Human Resources Stantec SHSO Stantec OSEC
Antonela Vadan
Stantec Project Staff Additional Stantec Staff
Stratus Corp.
(Subcontractor) Additional Subcontractors
A table summarizing responsibilities for project personnel is provided below.
Project Job Title General Project Responsibilities

Stantec Project Overall financial and logistics. Contact client and subs to understand all
Manager hazards. Discuss with SHSO. Follow-up all incidents upon notice.
Stantec Site Health Conduct work in accordance with JSA and this HASP. Report all incidents
and Safety Officer and near misses immediately to Project Manager.
Stantec Project
Oversee work
Staff
Stantec Business
Provide immediate support at notice of all incidents
Unit Leader
Stantec Director of Respond with corporate resources to all incidents as appropriate. Assist in
Industrial Hygiene HASP review. Assist in incident investigation.
Stantec Human
Assist with incident review, recordkeeping.
Resources
Stantec Office
Manage Health and Safety responsibilities for personnel in Office. Assist
Safety and
employees with setting up training and attending/completing necessary
Environment
courses.
Coordinator
33
Attachment 1
Stantec Field Safety Reference Binder

Checklist
Attachment 2
Preventing Serious Injury & Fatalities

Field Guide
Attachment 3
Personal Protective Equipment

Assessment
Personal Protective Equipment (PPE) Assessment
Site that this assessment applies to: Northgate Marketplace, Medford, OR
Date: April 1, 2014 Assessment Completed By: Robert McAlister, SHSO
Specific tasks evaluated in this assessment: Driving, Soil borings, Groundwater well installation,
Groundwater sampling.
Are any of the following hazards present No Yes If engineering and administrative controls
during the project/task? do not eliminate the hazard, this PPE is
needed.*
Overhead Hazards
Suspended loads that may fall Hard hat that complies with ANSI Z89.1¹,
X Class A, B
Overhead beams or load that could Hard hat that complies with ANSI Z89.1¹,
strike head X Class A, B
Energized wires or equipment that could Hard hat that complies with ANSI Z89.1¹,
strike head X Class B
Work being performed above where Hard hat that complies with ANSI Z89.1¹,
tools, debris, equipment could be X Class A, B
dropped onto workers below
Sharp objects or corners at head level Hard hat that complies with ANSI Z89.1¹,
X Class A, B, or C
Eye Hazards
Chemical splashes or irritating mists
X Chemical protective goggles that comply
with ANSI Z87.1¹ Non-vented goggles must
be used where gases or vapors are the
primary concern.
Excessive dust Safety glasses or impact goggles that
X comply with ANSI Z87.1¹
Using compressed air, connecting
compressed gas cylinders, bleeding air
X Flexible goggles that comply with ANSI
Z87.1¹
from lines.
Welding/cutting/brazing operations
X Welding goggles and welding helmet or
face shield. Tinted lenses required. PPE must
comply with that comply with ANSI Z87.1¹
Enter the type of eye protection required at
this site here:
Laser/optical radiation
X Laser safety glasses that comply with ANSI
Z136.1¹ required. A Laser Safety Officer
(LSO) to determine the type. The type of
laser safety glasses required at this site to
be entered here:
Drilling, sawing, cutting, chipping, Minimum requirement – safety glasses with
grinding demolition work, wire brushing X side shields. Goggles may be required
and other activities where flying particles dependent upon hazard. PPE must comply
present a hazard. with ANSI Z87.1¹. The type of eye protection
required at this site to be entered here:
Face Hazards
Chemical splashes or irritating mists Chemical protective goggles. Goggles
X must comply with ANSI Z87.1¹. Add face
shield if chemical is irritating to the skin or is
corrosive. If a face shield is required at this
site, enter this requirement here:
Drilling, sawing, cutting, chipping, Consider use of a face shield in addition to
grinding demolition work, wire brushing X safety glasses or goggles. If a face shield is
and other activities where flying particles required at this site, enter this requirement
present a hazard. here:
Hand Hazards – Always Use High-Visibility Gloves
Chemical exposure Use chemical resistant gloves as
X recommended by SDS; Site Health and
Safety Officer to help the One Team
identify proper hand protection
Handling glass vials or sample containers Cut-resistant gloves or liners
X
Sharp edges, splinters, etc. Leather/work gloves
X
Temperature extremes - heat Leather gloves, Kevlar gloves, welder’s
X gloves
Temperature extremes - cold Leather gloves, insulated gloves
X
Blood Nitrile gloves
X
Exposure to electrical current Gloves that meet ASTM D120 (or equivalent
X in non-US jurisdictions) specifications.
Sharp tools, machine parts, etc. Leather gloves, Kevlar gloves
X
Material handling Leather gloves
X
Foot Hazards
Handling heavy materials, construction, Safety shoes or boots that conform to ASTM
demolition, drilling X F2413-05² (Standard Specification for
Performance Requirements for Foot
Protection) or equivalent in non-U.S.
jurisdictions.
Potential to crush whole foot Safety shoes or boots with metatarsal
X guards that conform to ASTM F2413-05² or
equivalent in non-US jurisdictions.
Sharp edges or points – puncture risk Safety shoes or boots with puncture
X resistant soles. Shoes must conform to ASTM
F2413-05² or equivalent in non-US
jurisdictions.
Exposure to electrical wires Safety shoes or boots with electrical
X protection
Slippery conditions Rubber-sole boots or grips
X
Chemical contamination Rubber or nitrile boots or boot covers
X
Fall Hazards
Fall hazards present. Working at a height Personal Fall Arrest System designed or
of 6' or more above a lower surface or X approved by a qualified person
working above dangerous equipment
Water Hazards
Working on or above water where U.S. Coast Guard approved personal
drowning hazards exist X flotation device - Type I, II, or III PFD
Heat, Flame, or Flash Fire or Arc Hazards
Working in extreme heat Consider use of a cooling vest
X
Welding activities, hot work Welding leather clothing or Fire-Resistant
X Clothing (FRC)
Performing hot work (e.g., cutting, FRC
welding, brazing or grinding) on pipe X
and vessels (e.g., tanks, KO drums,
separators) that contain or previously
contained hydrocarbon fuels
Fueling/refueling equipment where FRC
engineering controls do not adequately X
prevent the risk of flash fires
Working at active pipeline sites FRC; ensure compliance with Pipe Line FRC
X requirements
Working in a refinery Adhere to the refinery’s FRC requirements
X
Body and Leg Protection
Chemical exposure Use chemical resistant clothing as
X recommended by SDS
Using a chain saw, cutting brush Chain-saw chaps
X
Risk of being bitten by a venomous Snake chaps
snake X
While working with rotating machinery: Wear proper fitting (i.e. not loose or baggy)
clothing that is hooded or drawstrings, X clothing. Wear a hiz-viz ANSI rated long
or is frayed, torn or excessively baggy sleeve shirt or a long sleeve shirt with a hi-viz
shall not be worn break-away vest
Respiratory Hazards
Respiratory/inhalation hazards present Qualified individual to determine respiratory
X protection requirements – use of respiratory
protection requires a Respiratory Protection
Program be instituted and requires medical
surveillance.
Excessive Noise
Hearing hazards present Qualified individual to determine hearing
X protection PPE requirements. Specify
hearing protection PPE requirements to be
used at this site here:
I certify the above hazard analysis/PPE selection was performed to the best of my knowledge,
based on the hazards present on _4/1/14_ (date).
Signature
*Whether the listed PPE is needed is dependent upon the presence and severity of the hazard –
a qualified individual should determine whether this is the correct PPE and whether additional
PPE is needed to reduce risk of exposure.
¹In jurisdictions outside of the United States, PPE must conform to the local regulatory
requirements – ANSI may not be a recognized standard in non-U.S. jurisdictions.
²Although the ANSI Z41-99 standard has been withdrawn, the protection provided by footwear
meeting this standard is comparable to the newer ASTM F2413-05. For this reason it is not
necessary to replace footwear approved under ANSI Z41-99 if it is otherwise still serviceable.
Attachment 4
Job Safety Analyses

Job Loss Analysis
Driving
Date: 4/1/14
Work Site: Northgate Center Phase 1B
Development Team Position/Title Date Reviewed

Laurie Gier Marketing West OE 3/25/2011 x
Coordinator
Scott Jordan National OE 08/21/2009 x
Coordinator
Gary Sparks Project Geologist 12/5/2006 x
Michael Philipp West Region Health 10/4/2006 x

and Safety Manager
Personal Protective Equipment (PPE) & Other Safety Equipment

Wear reflective vest for traffic, steel toed and shank shoes, long sleeve shirt, hardhat, safety glasses with side
shields, and Hi-Viz work gloves as necessary.
3-lb type ABC Fire Extinguisher, Window Scraper (cold climates), Tire Gauge.
Stantec Insurance & Vehicle Collision Kit (first aid kit, BBP kit, flashlight, etc)
Camera (if possible)
No. Job Step Additional PPE Potential Critical Action(s)

Hazard(s)
1 Perform Slip/trip/falls, ● Assess the potential hazards. Analyze how
HRAC/LPSA struck by traffic. to reduce the risk.
procedures ● Review JLA
prior to ● Use Stop Work if necessary to mitigate risk,
beginning and call supervisor with any questions.
task.
2 Verify Journey Unexpected ● Assure directions are available and
Management traffic detours. understood prior to commencing travel.
Plan is Slip, Trip, Falls. ● Pull the vehicle into a safe location if
complete and additional directions must be confirmed.
current. ● Increase following distance to allow extra
time to stop if you are in unfamiliar territory.
3 Perform Flat tire, ● Complete the Stantec Daily Vehicle
perimeter walk blowout, Checklist prior to travel.
around of impaired vision, ● Assure tires are properly inflated and there is
vehicle for collision, sufficient tread.
damage or slippery ● Assure there are no cuts or bulges in the
unusual surfaces, injury sidewalls.
conditions. or death. ● Assure windshield and window glass is
clean.
● Check behind vehicle for obstructions.
● Check under vehicle engine for evidence of
fluid leaks.
● Scrape windows, front and rear windshields.
4 Check and Back or body ● Adjust seat so back is fully supported, upper
adjust; strain. Blind arms close to body, and pedals within easy
seat, spots. reach.
mirrors, Inability to signal ● Lower steering wheel so hands are below
headlamps, intentions. shoulders and shoulders are relaxed.
turn signals, Streaking ● Check mirror adjustments each time vehicle
washer/wipers, windshield, is re-started.
heater, impaired vision. ● Test operations of front and rear turn signals.
defroster, ● Locate and test operation of headlamps,
Hazard(s)
all gauges, wiper and washer switches.
gas level, and ● Verify air conditioner/heater and windshield
warning lights. defroster fan operates properly.
5 Fasten seat Serious injury or ● Assure all seat belts are in good condition
belts, lock death in and fastened.
doors and turn collision. ● Lock all doors to vehicle.
driver cell Ejection from ● Do not use cellular phones when refueling or
phone to mute vehicle in driving.
or quiet collision.
position. Unwanted
intrusion.
6 Pull out of Collision with ● Check mirrors and over shoulder in all
parking space. other vehicles, directions prior to pulling out of parking space.
pedestrians, or ● Signal if parallel parked along a street.
stationary If reversing with 2 or more personnel in the
objects. vehicle, then at least 1 person must exit the
vehicle and act as a spotter. Before using a
spotter, both driver and spotter should discuss
and pre-plan desired route, destination,
positioning, obstacles, hand signals (and their
meaning) before relocating. If alone before
getting in the car, assess the area looking for
approaching pedestrians/vehicles. When clear
get in vehicle, do a 360 scan then put in gear.
Give two short blasts on the horn and while
looking over your shoulder, slowly back out of
the parking space being prepared to apply the
brakes if needed.
7 DURING TRIP Collision with ● Move eyes at least every 2 seconds.
Scan - Keep other vehicles, ● Scan major and minor intersections before
your eyes pedestrians, or entry (left-right-left).
moving. stationary ● Check mirrors when slowing or stopping
objects. vehicle.
● Scan mirrors frequently, at least one mirror
every 5-8 seconds.
● Avoid staring while evaluating road
conditions.
● Maintain adequate spacing between your
vehicle and the vehicle in front of you. (Rule of
thumb two second for every 10 miles per hour
(minimum of 6 seconds), double the distance
during poor road conditions).
● Watch for ice on road, slow down before
hitting the ice, and keep your foot off the brake.
8 Elevate - your Collision, injury ● Maintain 12 second eye lead time (1 1/2
line sight. or death to blocks in city traffic, 1/4 mile in highway traffic).
occupants or Assess condition of traffic lights (fresh vs.
other parties. stale).
● Assess information from distant objects.
● Adjust eye lead distance to speed.
9 Count - keep Collision, injury ● Maintain safety cushion around vehicle
your distance. or death to (front, sides, and rear).
occupants or ● Adjust vehicle space and speed to avoid
other parties. unsafe intrusion by other drivers.
● Allow a minimum of 1 second for every 10
mph you are traveling between you and the
vehicle in front of you when driving a vehicle
without a trailer.
● At signal controlled intersections, stop 10
feet behind crosswalks or behind other
Hazard(s)
vehicles.
● When stopped, allow vehicle in front to move
for 3 seconds before accelerating.
● Observe approaching merge areas and
choose lane of least resistance.
● Cede right of way and allow other vehicles to
merge, change lanes, make turns.
10 Out - have a Collision, injury ● Avoid being unnecessarily boxed in.
way out. or death to ● Avoid sudden acceleration and deceleration.
occupants or ● Maintain 1 second for every 10 mph (with 3
other parties. second minimum) following distance when
driving a vehicle without a trailer, adjust speed
to traffic conditions, scan immediate and
adjacent lanes before merging.
11 Recognize - Collision, injury ● Seek eye contact with other drivers.
make sure or death to ● Before changing lanes, signal well in
others see occupants or advance, check mirrors and over shoulder, and
you. other parties. allow adequate space before changing lanes.
● Break early to activate brake lights.
● Stay out of blind spots. Gently sound horn or
flash lights if unsure other driver sees you.
● Turn on headlamps in high traffic areas, at
dusk, and in inclement weather.
● Increase the distance between your vehicle
and the vehicle in front of you at night.
12 Backing up. Collision, injury ● Make all backing maneuvers slowly and
or death to cautiously.
occupants or ● Check mirrors and over shoulders. When
other parties. parking, look for pull-through parking to avoid
backing.
● If reversing with 2 or more personnel in the
vehicle, then at least 1 person must exit the
vehicle and act as a spotter. If alone before
getting in the car, assess the area looking for
approaching pedestrians/vehicles. When clear
get in vehicle, do a 360 scan then put in gear.
Give two short blasts on the horn and while
looking over your shoulder, slowly back out of
the parking space being prepared to apply the
brakes if needed.
13 Parking. Collision, injury ● Park away from other cars.
or death to ● Back into parking spot when possible and
occupants or safe.
other parties. ● Maintain cushion of safety from fixed objects.
Set parking brake.
14 POST-TRIP - Conditions ● Report vehicle problems immediately to
Report worsen leading company representative or rental car agency.
maintenance to mechanical
or mechanical failure resulting
problems upon in accident,
returning injury or death.
vehicle.
Signatures
Print Name Company Signature
Job Loss Analysis
Utility Locate
Date: 4/1/14

Laurie Gier Marketing West OE 3/25/2011 x
Coordinator
Coordinator
Heather Stevens Project Engineer 08/21/2009 x

and Safety Manager
Personal Protective Equipment (PPE) & Other Equipment

Wear reflective vest for traffic, steel toed and shank shoes, hardhat, safety glasses with side shields, ear plugs,
and Ansell™ Hyflex 11-500 (ANSI Cut and Abrasion Resistance Level 2 EN 388 3231) gloves.
Utility Clearance Log

Hazard(s)
procedures prior to ● Review JSA
beginning task. ● Use Stop Work if necessary to mitigate risk,
and call supervisor with any questions.
2 Mobilize with Ansell™ Hyflex Vehicle ● Attend pre-field project planning meeting
proper 11-500 (ANSI accident. Lifting (Kick-off Meeting.)
equipment/supplies Cut and hazards. ● Start project with Daily Production Safety
for marking for Abrasion Delay or Meeting.
USA Resistance improper ● Follow safe driving procedures.
Level 2 - EN 388 performance of ● Employ safe lifting procedures.
3231) work due to ● Make sure sub-contractors are aware of their
improper responsibilities for labor, equipment and
equipment supplies.
onsite. ● Review permit conditions.
3 Set up necessary Ansell™ Hyflex Potentially can ● Use buddy system for placing traffic
traffic guidance 11-500 (ANSI be struck by guidance and control equipment.
and control Cut and vehicle during ● Have personal warring device available to
equipment. Abrasion placement. alert other vehicles who are potentially
Resistance Vehicle accident impeding the exclusion zone.
Level 2 - EN 388 as a result of ● Create a traffic guidance and control plan to
3231) improper traffic address traffic issues. Refer to section above
guidance and and Traffic.
control ● Adhere to approved Traffic Guidance and
equipment Control Plans when working in roadways.
placement. ● It is the responsibility of the SHSO to
annotate the Site Plan with the Traffic
Guidance and Control configuration if a
formally developed Traffic Guidance and
Control Plan is not available. .
Hazard(s)
4 Perform Utility Ansell™ Hyflex Potentially can ● Adhere to approved traffic guidance and
Locating, marking 11-500 (ANSI be struck by control plan.
utility locations with Cut and vehicle during ● Verify proposed boring locations on site map
paint. Abrasion placement. and cross reference locations with Chevron’s
Resistance Vehicle accident Subsurface Clearance Review and Statnec’s
Level 2 - EN 388 as a result of Underground Utility Checklist.
3231) improper traffic ● Use proper bending and lifting techniques.
control
equipment
placement.
Muscle
strains/sprains
from lifting
equipment.
5 Clean Ansell™ Hyflex Traffic. Safety ● Use buddy system as necessary to remove
site/demobilize. 11-500 (ANSI hazard left on traffic guidance and control equipment. -
Cut and site. Lifting ● Leave site clean of refuse and debris.
Abrasion hazards. ● Clearly mark/barricade any borings that need
Resistance later topping off or curing.
Level 2 - EN 388 ● Notify site personnel of departure.
3231) ● Use proper bending and lifting techniques to
load field supplies/materials into field vehicle.
Signatures
Job Safety Analysis
Hand Augering
Date: 4/1/14
Work Site: Northgate Phase 1B

Laurie Gier Chevron Team 3/30/2011 X
Marketing OE
Coordinator
Stephen R Zayko RI Manager Purity 1/13/2006 X
and BeeJay Scales
Michael Allen Philipp West Region Health 09/23/05 X
and Safety Manager

Wear reflective vest for traffic, steel toed and shank shoes, hardhat, safety glasses with side shields,
HexArmor Level 6 Series 9010 or equivalent (ANSI Cut and Abrasion Resistance Level 2 - EN 388 33xx)
gloves. Respirator with combination organic vapor/P-100 cartridges, as needed.
Stantec’s Utility Clearance Log & Chevron’s Subsurface Clearance Review

Hazard(s)
1 Perform Slip/trip/falls,  Assess the potential hazards. Analyze how
procedures prior to
 Review JSA.
beginning task.
 Use Stop Work if necessary to mitigate risk,
and call supervisor with any questions.
2 Mobilize with HexArmor Level Vehicle  Attend pre-field project planning meeting
proper 6 Series 9010 or accident. Lifting (Kick-off Meeting.)
equipment/supplies equivalent (ANSI hazards.
 Start project with Daily Production Safety
for hand augering. Cut and Delay or
Meeting.
Abrasion improper
Resistance performance of  Follow safe driving procedures.
Level 2 - EN 388 work due to  Employ safe bending and lifting procedures.
33xx) improper  Make sure sub-contractors are aware of their
equipment responsibilities for labor, equipment and
onsite. supplies.
 Review permit conditions.
 It is the responsibility of the SHSO to
Control Plan is not available.
3 Visually clear HexArmor Level 6 Underground  Complete Pre-Mobilization section of
proposed hand Series 9010 or installations. Chevron’s Subsurface Clearance Review
auguring/soil equivalent (ANSI
Cut and Abrasion form and Stantec’s Utility Clearance Log
sampling locations. (Field Binder). Adjust hand auguring
Resistance Level
2 - EN 388 33xx) locations as necessary.
4 Set up necessary HexArmor Level 6 Struck by  Use buddy system for placing traffic
traffic guidance Series 9010 or vehicle during guidance and control equipment.
and control equivalent (ANSI placement.
Cut and Abrasion  It is the responsibility of the SHSO to
equipment. Vehicle accident
Resistance Level annotate the Site Plan with the Traffic
as a result of
2 - EN 388 33xx) Guidance and Control configuration if a
Hazard(s)
improper traffic formally developed Traffic Guidance and
guidance and Control Plan is not available.
control  Implement exclusion zone set-up.
equipment
 Implement traffic guidance and control plan
placement.
such as setting out delineators, construction
fence and caution tape defining safety area
 Adhere to approved Traffic Guidance and
Control Plans when working in roadways.
 It is the responsibility of the SHSO to
Control Plan is not available.
5 Set up exclusion HexArmor Level 6 Struck by  Implement exclusion zone set-up.
zone(s) and Series 9010 or vehicle during
equivalent (ANSI  It is the responsibility of the SHSO to
workstations (hand set up. Slip, trip
Cut and Abrasion annotate the Site Plan with the Exclusion
auguring and and fall hazards.
Resistance Level Zone set up.
logging/sample
collection).
2 - EN 388 33xx)  Set up workstations with clear walking paths
to and from hand auguring location.
 Use delineators, construction fence, and/or
caution tape as required.
 If utilizing Visqueen, (sheet plastic), for
sampling area, completely secure Visqueen
to the pavement, dirt, etc. with duct tape,
delineators, etc. Do not use objects that are
hard to notice or could become a trip hazard
themselves.
6 Commence hand HexArmor Level Back strain,  Initiate air quality monitoring as outlined in
auguring. 6 Series 9010 or exposure to Section 4 of the HASP, if required.
equivalent (ANSI chemical
 Have appropriate respirator with combination
Cut and hazards, hitting
organic vapor/P-100 cartridges within 3-5
Abrasion an underground
feet of work area, readily available.
Resistance utility, repetitive
Level 2 - EN 388 motion.  Stand upwind to avoid exposure whenever
33xx) possible.
 Use the organic vapor monitor aggressively
to track the airborne concentration of
contaminants close to potential sources such
as the core as it is being raised from the
hole, the core is opened, etc.
 Evaluate any soil samples inside a Ziploc
bag at arm's length. DO NOT EVALUATE
THE SAMPLE WITH THE BAG OPEN. THIS
WILL AVOID UNNECESSARY EXPOSURE.
 Use proper lifting & bending techniques and
correct tools for the task.
 Complete the Pre-Drilling section of
Chevron’s Subsurface Clearance Review &
Stantec Utility Clearance Checklist.
 Decontaminate sampling equipment after
collecting a sample and decontaminate hand
auguring equipment after each borehole.
 Use proper body positioning and avoid
twisting back during the operation;
 Decontaminate equipment after use.
Decontamination will be accomplished by an
Hazard(s)
Alconox wash with tap water rinse followed
by a de-ionized or distilled water rinse.
Collect rinse water in 5 gallon buckets and
transfer to 55-gallon drums and stage drums
in a location agreed upon by the SHSO and
the Property/Station Owner/Manager.
7 Supervisor/SHSO HexArmor Level Possible injuries  Visually inspect each and every borehole.
must confirm all 6 Series 9010 or and damage to
boreholes are equivalent (ANSI property due to
closed, filled in Cut and stepping into or
and/or capped. Abrasion driving over the
Resistance well.
Level 2 - EN 388
33xx)
8 Perform personal Slips/trips/falls.  Perform personal (dry) decontamination
decontamination Splashes, procedures.
procedures. chemical  Drop off tools and perform equipment
contamination. decontamination procedures on the
Contact with equipment.
contaminated
 Perform a “dry” decontamination on
materials.
boots using a stiff bristle fiberglass
long handled brush.
 Remove inner/outer gloves and
dispose of properly.
 Wash hands, face, arms and neck (any
exposed skin) using sink or bottled water. If
water isn’t available, use baby wipes or a
similar product.
9 Clean HexArmor Level Traffic. Safety  Use buddy system as necessary to remove
site/demobilize. 6 Series 9010 or hazard left on traffic guidance and control equipment.
equivalent (ANSI site. Lifting
 Leave site clean of refuse and debris.
Cut and hazards.
Abrasion  Clearly mark/barricade any borings that need
Resistance later topping off or curing.
Level 2 - EN 388  Notify site personnel of departure, final well
33xx) locations and any cuttings/purge water left
onsite.
 Use proper bending and lifting techniques to
load field supplies/materials into field vehicle.
Signatures
Job Safety Analysis
Geoprobe/Hydropunch Drilling
Date: 4/1/14

Laurie Gier Chevron Team 3/30/2011 9/10/2010
Marketing OE
Coordinator
David Stolcenberg Staff Engineer 12/3/2003 12/3/2003
Michael Philipp West Region Health 12/3/2003 12/3/2003

and Safety Manager

Reflective hi-viz vest, steel toed and shank boots, long sleeve shirt, hardhat, safety glasses with side shields,
earplugs, nitrile gloves, HexArmor or equivalent (See attached sheet from subcontractor) (ANSI Cut and
Abrasion Resistance Level 3 - EN 388 4522) and Dura Flock 8 mil nitrile . Respirator with combination
organic vapor/P-100 cartridges, as needed.
No. Job Step Additional Potential Hazard(s) Critical Action(s)

PPE
1 Perform HRAC/LPSA Slip/trip/falls, struck by  Assess the potential hazards.
procedures prior to traffic. Analyze how to reduce the risk.
beginning task.
 Review JSA.
 Use Stop Work if necessary to
mitigate risk, and call supervisor
with any questions.
2 Mobilize to site with HexArmor Muscle strain from lifting. ● Ensure all necessary tools,
proper equipment, Level 6 Series Body injury from handling equipment, supplies, and PPE are
supplies, and 9010 (ANSI materials. Delay or present and in good working
personnel for job. Cut and improper performance of condition.
Abrasion work due to improper ● Ensure all necessary paperwork
Resistance equipment onsite. (sampling plan, site map, field data
Level 2 - EN sheets, permits, JSAs, HASP, labels)
388 33xx) and are present.
Dura Flock 8 ● Check subcontractor’s HASP,
mil nitrile Certs, MSDSs, and equipment
maintenance records.
● Make sure subcontractors are
aware of their responsibilities for
labor, equipment, and supplies.
3 Hold pre-work safety HexArmor Site access and traffic ● Review HASPs and JSAs.
meeting and assess Level 6 Series flow. Expectations and ● Discuss the scope of work. Ensure
the general site 9010 (ANSI requirements not clearly all personnel know their role and
conditions. Cut and communicated. have the proper equipment and
Abrasion supplies to work safely.
Resistance ● Perform HRAC and LPSA prior to
Level 2 - EN task. Assess the potential hazards.
388 33xx) Analyze how to reduce the risks.
● Coordinate with station manager
(or designee) to minimize potential
conflicts.
● All staff should know where the kill
switch is for the CPT rig.
4 Verify borehole HexArmor Underground or overhead ● Complete the Utility Clearance
PPE
locations and utility Level 6 Series utility conflict with Review form.
clearance. 9010 (ANSI borehole locations. Traffic ● Verify that all scheduled public and
Cut and hazards and traffic flow. private utility markings have been
Abrasion completed.
Resistance ● Review proposed locations against
Level 2 - EN available construction drawings,
388 33xx) known utilities, tanks, product lines,
overhead obstructions, etc.
● Adjust borehole locations as
necessary.
5 Maneuver geoprobe HexArmor Motor vehicle accident. ● Verify clear pathway to drilling
rig, support truck, and Level 6 Series Property damage. location and clearance for raising
work vehicles into 9010 (ANSI Overhead clearance. Soft mast. Do not move drill rig with mast
position. Cut and terrain. raised.
Abrasion ● Spotter should provide hand
Resistance signals and guidance to driver
Level 2 - EN moving vehicle.
388 33xx) ● Inspect drill rig (fire extinguisher, oil
or fluid leaks, cabling in good
condition, pressurized hoses secured
with whip-checks?).
● Chock wheels.
● If necessary, use wooden blocks
under jacks to spread load.
6 Set up traffic control, HexArmor Struck by vehicle. ● Traffic control and exclusion zone
exclusion zone(s), and Level 6 Series Civilians in the work zone. may include a combination of
workstations. 9010 (ANSI Slip, trip, fall hazards. delineators, barrier tape, construction
Cut and Spills and leaks. fence, parked vehicles, etc.
Abrasion ● Set up work stations (drilling,
Resistance logging, sampling) with clear walking
Level 2 - EN paths between.
388 33xx) ● Don PPE, including leather work
gloves when loading or unloading
materials.
● Place visqueen underneath drill rig
and support vehicle (water truck,
support truck, etc.). Secure visqueen
in place with duct tape, delineators,
etc. Do not use objects that are hard
to notice or could become a trip
hazard.
● If the use of visqueen presents a
hazard, follow the Management of
Change Process (MOC) by
contacting the Stantec Project
Manager to discuss alternative
secondary containment.
● Have personal warring device
available to alert other vehicles who
are potentially impeding the
exclusion zone.
7 Commence HexArmor or Cross-contamination from ● Geoprobe rig will be used on B-1
Hydropunch/Geoprobe equivalent previous hole. Back through B-4.
operation. (See attached strain, heat or cold, eye ●Decontaminate sampling
sheet from injury, noise, exposure to equipment after collecting a sample.
subcontractor) chemical hazards, hitting Decontaminate equipment after use.
(ANSI Cut and an underground utility, Decontamination will be
Abrasion trip and fall, equipment accomplished by an Alconox wash
Resistance failure with tap water rinse followed by a
Level 3 - EN second distilled or de-ionized water
PPE
388 4522) and rinse. Collect rinse water in 5 gallon
Dura Flock 8 buckets and transfer to 55-gallon
mil nitrile drums and stage drums at an agreed
upon location between the Store
Manager/Property Owner and
Stantec.
● Decontaminate
Geoprobe/Hydropunch equipment
after each evolution.
Decontamination will be
accomplished using a pressure
washer and then air-dried. Decon
water will be collected in 55-gallon
drums and staged at an agreed upon
location between the Store Manager
and Stantec SHSO.
● Use proper bending & lifting
techniques.
● Monitor air quality in accordance
with Section 4 of the HASP.
 Have appropriate respirator with
combination organic vapor/HEPA
P-100 cartridges within 3-5 feet of
work area, readily available.
 Monitor Geoprobe/Hydraulic Push
progress.
 Keep work area clear of tripping or
slipping hazards.
 Perform periodic visual inspections
of Geoprobe/Hydraulic Push rig.
8 Collect samples in HexArmor or Cross-contamination. ● Perform air monitoring in
accordance with equivalent Back strain, inhalation or accordance with Section 4 of the
sampling plan. (See attached dermal exposure to HASP.
sheet from chemical hazards, slip ● Have appropriate respirator with
subcontractor) and fall. Improper combination organic vapor/P-100
(ANSI Cut and labeling or storage, injury cartridges within 3-5 feet of work
Abrasion from broken sample bottle area, readily available.
Resistance (cuts or acid burn). ● Decontaminate sampling
Level 3 - EN equipment between each well
388 4522) and (unless disposable). If the equipment
Dura Flock 8 is reusable, then wash in an Alconox
mil nitrile for wash, rinsed with tap water, then
handling soil rinsed with distilled or de-ionized
only, Nitrile water. Decontamination water will be
gloves less transferred to 55-gallon drums and
than 8ml staged Indicate where the decon
thickness must water will be staged on site? This
be used in must cover both people and
tandem with equipment decontamination.
cut/puncture ● Use proper lifting and bending
resistant will be techniques.
used to handle ● Label samples in accordance with
brass sleeves. sampling plan.
● Keep samples stored in proper
containers, at correct temperature,
and away from work area. Handle
bottles carefully.
● Determine the best location to set
the sample containers (avoid
PPE
stepping on them or other materials
coming into contact with them.
● Fill sample containers slowly and
over a bucket to eliminate potential
spills. Or place sample container on
bucket lid on the ground or other
surface, then fill container to avoid
sample container from slipping out of
your nitrile gloved hand. - Stantec
9 Proper clean up and HexArmor or Exposure to broken glass ● Isolate area where broken glass is
disposal of broken equivalent and acid (from water located.
sample container. (See attached preservation acids)Injury ● Determine if the sample container
sheet from was preserved (did it have acid in
subcontractor) it?).
(ANSI Cut and ● Determine what to contain the
Abrasion broken glass in, and where to
Resistance dispose of the broken glass before
Level 3 - EN beginning to pick up the glass.
388 4522) ● Collect equipment needed to clean
up and contain the broken glass.
● Minimize picking up broken glass
pieces with your gloved hands. Use
a dust pan if possible/practical.
● If broken glass is located inside a
container (i.e. box), to the extent
practical, leave glass inside box and
put entire box into a garbage bag.
Double bag if warranted. Place into
dumpster.
● If broken glass is inside a cooler,
remove all other sample containers
and place in a safe location, then use
hand broom and dust pan to sweep
up glass in cooler.
● After clean up is complete, contact
your Project Manager to report this
Near Loss/Miss.
10 Cuttings will be picked HexArmor or Exposure to public. ● Have proper storage containment
up by shovel and equivalent Traffic hazard or and labeling available onsite.
placed directly in 55- (See attached obstruction/inconvenience ● Place materials in isolated location
gallon drums. sheet from to station operation. away from traffic and other site
subcontractor) Improper storage or functions. (See next section for
(ANSI Cut and disposal. Back strain. Waste Description).
Abrasion ● Use appropriate drum handling
Resistance practices. Do not attempt to lift, push
Level 3 - EN or move drums without the proper
388 4522) and tools and equipment.
Dura Flock 8
mil nitrile for
handling soil
only, Nitrile
gloves less
than 8ml
thickness must
be used in
tandem with
cut/puncture
resistant will be
used to handle
brass sleeves.
PPE
11 Backfill borehole. HexArmor Improper grouting can  Mix grout to specification and
Level 6 Series lead to future vertical completely fill the hole.
9010 (ANSI conduit for contaminant
 Use proper lifting techniques.
Cut and migration. Back strain,
Abrasion trip hazards, and eye  Keep work area clear of tripping
Resistance injury from splashing or hazards.
Level 2 - EN release of pressurized  Use buddy system as necessary to
388 33xx) grout. Unauthorized remove traffic guidance and control
backfilling causes extra equipment.
work.
12 Dispose or store purge HexArmor Back strain. Exposure to  Use appropriate drum handling
water (if any) onsite. Level 6 Series contaminants. If practices.
9010 (ANSI disposing through onsite
 Use proper equipment to transport
Cut and treatment system,
water (pumps, drum dollies, etc.).
Abrasion damage or injury from
Resistance improper use of  Monitor air quality in accordance
Level 2 - EN equipment. Improper with Section 4 of the HASP.
388 33xx) storage or disposal.  Have appropriate respirator with
combination organic vapor/HEPA
cartridges within 3-5 feet of working
location, readily available.
 Label storage containers properly,
and locate in isolated area away
from traffic and other site functions.
 Coordinate offsite disposal (where
applicable).
 Do not attempt to lift, push or move
drums without the proper tools or
equipment.
13 Supervisor/SHSO HexArmor Possible injuries and  Visually inspect each and every
must confirm all Level 6 Series damage to property due borehole.
boreholes are closed, 9010 (ANSI to stepping into or driving
filled in and/or capped. Cut and over the well.
Abrasion
Resistance
Level 2 - EN
388 33xx)
14 Perform personal Slips/trips/falls.  Perform personal (dry)
decontamination Splashes, chemical decontamination procedures.
procedures. contamination. Contact  Drop off tools and perform
with contaminated equipment decontamination
materials. procedures on the
equipment.
 Perform a “dry”
decontamination on boots
using a stiff bristle fiberglass
long handled brush.
 Remove inner/outer gloves
and dispose of properly.
 Wash hands, face, arms and neck
(any exposed skin) using sink or
bottled water. If water isn’t
available, use baby wipes or a
similar product.
15 Clean site/demobilize. HexArmor Traffic. Safety hazard left  Use buddy system as necessary to
Level 6 Series on site. Lifting hazards. remove traffic guidance and control
9010 (ANSI equipment.
PPE
Cut and  Leave site clean of refuse and
Abrasion debris.
Resistance
 Clearly mark/barricade any borings
Level 2 - EN
that need later topping off or
388 33xx)
curing.
 Notify site personnel of departure,
final well locations and any
cuttings/purge water left onsite.
 Use proper bending and lifting
techniques to load field
supplies/materials into field vehicle.
16 Package and deliver Bottle breakage, back  Handle and pack bottle carefully
samples to lab. strain. (bubble wrap bags are helpful).
Use proper lifting techniques.
Signatures
Job Safety Analysis
Monitoring Well Installation via Hollow

Stem Auger Drill Rig
Date: 4/1/14
Laurie Gier Chevron Team 3/30/2011 x
Marketing OE
Coordinator
Dianne Burnia CHBU 10/12/2005 x

Coordinator
and Safety Manager

Reflective hi-viz vest, steel toed and shank boots, long sleeve shirt, hardhat, safety glasses with side shields,
earplugs, nitrile gloves, HexArmor or equivalent (See attached sheet from subcontractor) (ANSI Cut and
Abrasion Resistance Level 3 - EN 388 4522) and Dura Flock 8 mil nitrile . Respirator with combination
organic vapor/P-100 cartridges, as needed.

Hazard(s)
1 Mobilize to HexArmor Level Muscle strain ● Ensure all necessary tools, equipment,
site with 6 Series 9010 from lifting. Body supplies, and PPE are present and in good
proper (ANSI Cut and injury from working condition.
equipment, Abrasion handling ● Ensure all necessary paperwork (sampling
supplies, and Resistance materials. Delay plan, site map, field data sheets, permits,
personnel for Level 2 - EN 388 or improper JSAs, HASP, labels) are present.
job. 33xx) and Dura performance of ● Check subcontractor’s HASP, Certs,
Flock 8 mil nitrile work due to MSDSs, and equipment maintenance records.
improper ● Make sure subcontractors are aware of their
equipment responsibilities for labor, equipment, and
onsite. supplies.
2 Hold pre- HexArmor Level Site access and ● Review HASPs and JSAs.
work safety 6 Series 9010 traffic flow. ● Discuss the scope of work. Ensure all
meeting and (ANSI Cut and Expectations personnel know their role and have the proper
assess the Abrasion and equipment and supplies to work safely.
general site Resistance requirements not ● Perform HRAC and LPSA prior to task.
conditions. Level 2 - EN 388 clearly Assess the potential hazards. Analyze how to
33xx) communicated. reduce the risks.
● Coordinate with station manager (or
designee) to minimize potential conflicts.
● All staff should know where the kill switch is
for the drilling rig.
3 Verify HexArmor Level Underground or ● Complete the Utility Clearance Review form.
borehole 6 Series 9010 overhead utility ● Verify that all scheduled public and private
locations and (ANSI Cut and conflict with utility markings have been completed.
utility Abrasion borehole ● Review proposed locations against available
clearance. Resistance locations. Traffic construction drawings, known utilities, tanks,
Level 2 - EN 388 hazards and product lines, overhead obstructions, etc.
33xx) traffic flow. ● Adjust borehole locations as necessary.
Hazard(s)
4 Maneuver HexArmor Level Motor vehicle ● Verify clear pathway to drilling location and
drill rig, 6 Series 9010 accident. clearance for raising mast. Do not move drill
support truck, (ANSI Cut and Property rig with mast raised.
and work Abrasion damage. ● Spotter should provide hand signals and
vehicles into Resistance Overhead guidance to driver moving vehicle.
position and Level 2 - EN 388 clearance. Soft ● Visually inspect rig (fire extinguisher on
inspect 33xx) terrain. board, no oil or other fluid leaks, cabling and
hollow stem associated equipment in good condition,
rig. pressurized hoses secured with whip-checks
or adequate substitute, jacks in good
condition?).
● Place visqueen underneath air knife rig.
Secure visqueen to the pavement, dirt, etc.
with duct tape, delineators, etc. Do not use
objects that are hard to notice or could become
a trip hazard themselves.
● If the use of visqueen presents a hazard,
follow the Management of Change Process
(MOC) by contacting the Stantec Project
Manager to discuss alternative secondary
containment.
● Chock wheels.
● If necessary, use wooden blocks under jacks
to spread load.
5 Set up traffic HexArmor Level Struck by ● Traffic control and exclusion zone may
control, 6 Series 9010 vehicle. Civilians include a combination of delineators, barrier
exclusion (ANSI Cut and in the work zone. tape, construction fence, parked vehicles, etc.
zone(s), and Abrasion Slip, trip, fall ● Set up work stations (drilling, logging,
workstations. Resistance hazards. Spills sampling) with clear walking paths between.
Level 2 - EN 388 and leaks. ● Don PPE, including leather work gloves
33xx) when loading or unloading materials.
● Place visqueen underneath drill rig and
support vehicle (water truck, support truck,
etc.). Secure visqueen in place with duct tape,
delineators, etc. Do not use objects that are
hard to notice or could become a trip hazard.
● If the use of visqueen presents a hazard due
to rain, cold weather, icy conditions, etc., follow
the Management of Change Process (MOC)
by contacting the Stantec Project Manager to
discuss alternative secondary containment.
6 Perform HexArmor or Cross- ●Hollow stem drill rig will be used on MW-6
drilling equivalent (See contamination through MW-10.
operations attached sheet from previous Monitor drilling progress.
with hollow from hole. Hit an  Stantec personnel should not enter the
stem. subcontractor) underground drilling rig deck.
(ANSI Cut and utility. Muscle  Keep all body parts away from the
Abrasion strain from wrench area.
Resistance handling  Do not put fingers near connection point.
Level 3 - EN 388 equipment.  Driller’s Helper must stay out of the
4522) and Dura Noise. Chemical yellow no-fly-zone while driller is lifting
Flock 8 mil nitrile exposure. drilling head and whenever specified by
Slips/trips/falls. driller.
Equipment ● Keep work area clear of slip/trip/fall hazards.
failure. ● Perform periodic visual inspections of drill
rig.
 Limit number of people working directly in
area of AET operation to avoid getting
blasted by flying debris.
 Stand upwind to avoid exposure whenever
possible.
 Use the PID/FID aggressively to track the
airborne concentration of contaminant
close to potential sources such as the core
as it is being raised from the hole.
● Decontaminate drilling equipment after each
borehole.
● DO NOT USE J HOOKS OF ANY TYPE
FOR LIFTING OF MATERIALS OR
EQUIPMENT.
● DO NOT MOVE DRILL RIG WITH THE
MAST RAISED.
Hazard(s)
7 Log the HexArmor or Cross- ● Evaluate any soil samples inside a sealed
borehole and equivalent (See contamination. Ziploc bag. This will avoid potential skin or
collect attached sheet Improper vapor exposure.
samples in from labeling or ● Decontaminate sampling equipment
accordance subcontractor) storage. between each sampling run.
with sampling (ANSI Cut and Exposure to site ● Label samples in accordance with sampling
plan. Abrasion contaminants. plan.
Resistance ● Keep samples sealed in proper containers,
Level 3 - EN 388 at correct temperature, away from work area.
4522) and Dura ● Use bubble wrap or other insulating material
Flock 8 mil nitrile to cushion glass sample containers.
for handling soil
only, Nitrile
gloves less than
8ml thickness
must be used in
tandem with
cut/puncture
resistant will be
used to handle
brass sleeves.
8 Containerize HexArmor or Inconvenience to ● Have proper storage containment
cuttings. equivalent (See tenant. Traffic (removable top drums or other) and labeling
attached sheet obstruction or available on site. Place materials in isolated
from hazard. Improper location away from traffic and other site
subcontractor) storage or functions.
(ANSI Cut and disposal. Public ● Do not attempt to lift, push or move drums
Abrasion exposure. Back without the proper tools and equipment.
Resistance strain.
Level 3 - EN 388
4522) and Dura
Flock 8 mil nitrile
9 Construct HexArmor or Back strain. Slip, ● Use proper lifting techniques.
and set the equivalent (See trip, fall hazards. ● Keep pathways from well supplies to
well casing. attached sheet Cross- borehole clear of tripping hazards.
from contamination. ● Make sure casing and other materials are
subcontractor) Non-approved clean before going into borehole.
(ANSI Cut and well ● Verify authorization by any required
Abrasion construction. inspectors for well installation and grouting.
Resistance Eye injury from ● Contractor is required to wear chemical
Level 3 - EN 388 splashing grout. splash goggles with full face shield when
4522) and Dura grouting the borehole.
Flock 8 mil nitrile
Hazard(s)
10 Install well HexArmor or Back strain. Skin ● Use proper lifting techniques and equipment
vault and set equivalent (See exposure to to install well vault and concrete.
in concrete. attached sheet concrete. ● Complete well vault smooth to grade to
from Particulate eliminate trip hazard (if slightly elevated to
subcontractor) inhalation. Slip, prevent storm water intrusion, slope concrete
(ANSI Cut and trip, fall hazards. skirt gradually).
Abrasion Traffic hazards. ● Use the right tools to open/close well boxes.
Resistance ● Maintain traffic control during all tasks.
Level 3 - EN 388
4522) and Dura
Flock 8 mil nitrile
11 Dispose or HexArmor Level Back strain. ● Use proper equipment to transport water
store purge 6 Series 9010 Exposure to (pumps, drum dollies, etc.). Do not attempt to
water (if any) (ANSI Cut and contaminants. lift, push, or move drums without the proper
and Abrasion Improper tools or equipment.
decontaminat Resistance storage or ● Ensure that all waste containers are closed
ion water Level 2 - EN 388 disposal. before moving them.
onsite. 33xx) ● Label storage containers properly, and
locate sealed containers in an isolated area
away from traffic and other site functions.
Consult with station manager for an
appropriate location.
12 Perform HexArmor Level Chemical ● Use bristle brush to remove soil from boots.
personnel 6 Series 9010 exposure. ● Remove any tape, outer gloves, Tyvek, and
decontaminat (ANSI Cut and inner gloves. Properly dispose of all used PPE.
ion Abrasion ● Wash hands, face arms, neck, and any
procedures. Resistance exposed skin (use baby wipes if a washing
Level 2 - EN 388 facility is unavailable).
33xx)
13 Clean site HexArmor Level Struck by traffic. ● Leave site clean of refuse and debris.
and 6 Series 9010 Safety hazard ● Clearly mark/barricade any borings that need
demobilize. (ANSI Cut and left on site. later topping off or curing.
Abrasion Lifting hazards. ● Notify tenant of departure, final well locations
Resistance and any cuttings/purge water left on site.
Level 2 - EN 388 ● Use proper lifting techniques, including the
33xx) buddy system or appropriate mechanical aids
as necessary.
Signatures
Job Loss Analysis
Groundwater Monitoring Well Development

Date: 4/1/14

Laurie Gier Chevron Team 3/30/2011 x
Marketing OE
Coordinator
Coordinator
and Safety Manager

Wear reflective vest for traffic, steel toed and shank shoes, long sleeve shirt, hardhat, safety glasses with side
shields, and HexArmor Level 6 Series 9010 (ANSI Cut and Abrasion Resistance Level 2 - EN 388 33xx) and
Dura Flock 8 mil nitrile, as necessary. Respirator with combination organic vapor/P-100 cartridges, as needed.

Hazard(s)
procedures ● Review JSA & permit conditions
prior to ● Use Stop Work if necessary to mitigate risk,
beginning task. and call supervisor with any questions.
2 Mobilize to site HexArmor Level Muscle strain ● Ensure all necessary tools, equipment,
with proper 6 Series 9010 from lifting. Body supplies, and PPE are present and in good
equipment, (ANSI Cut and injury from working condition.
supplies, and Abrasion handling ● Ensure all necessary paperwork (sampling
personnel for Resistance materials. Delay plan, site map, field data sheets, permits,
job. Level 2 - EN 388 or improper JSAs, HASP, labels) are present.
33xx) and Dura performance of ● Check subcontractor’s HASP, Certs,
Flock 8 mil nitrile work due to MSDSs, and equipment maintenance records.
improper ● Make sure subcontractors are aware of their
equipment responsibilities for labor, equipment, and
onsite. supplies.
3 Set up HexArmor Level Struck by vehicle ● Use buddy system for placing traffic
necessary 6 Series 9010 during guidance and control equipment.
traffic (ANSI Cut and placement. ● Implement Traffic Guidance and Control
guidance and Abrasion Vehicle accident Plan such as setting out delineators, snow
control Resistance as a result of fence and caution tape defining safety area.
equipment. Level 2 - EN 388 improper traffic ● Adhere to approved Traffic Guidance and
33xx) control Control Plans when working in roadways.
equipment
placement.
Hazard(s)
4 Set up HexArmor Level Struck by vehicle ● Implement exclusion zone set-up.
exclusion 6 Series 9010 during set up. ● Set up workstations with clear walking paths
zone(s) and (ANSI Cut and Slip, trip and fall to and from rig. Use caution tape and or
workstations. Abrasion hazards. construction fence and delineators.
Resistance
Level 2 - EN 388
33xx)
5 Opening well HexArmor Level Struck by vehicle ● Implement exclusion zone set-up
box or stick-up 6 Series 9010 while opening instructions, Face on-coming traffic and use
vault. (ANSI Cut and the well work vehicle to block on-coming traffic if
Abrasion box/vault. Back possible.
Resistance strain, pinch ● Use proper lifting techniques.
Level 2 - EN 388 points and ● Be aware of pinch points associated with
33xx) biological removal/replacement of the well lid/vault cover.
hazards (i.e. Use appropriate tool to remove well lid cover.
spiders, insects). ● Look for spiders before placing hands in well
box. Use a screwdriver or equivalent tool to
remove spider webs in well box.
6 Gauge water HexArmor Level Back strain, ● Perform air monitoring as outlined in Section
levels and 6 Series 9010 inhalation or 12 if necessary.
product (ANSI Cut and dermal exposure ● Have respirator within 3-5 feet of working
thickness Abrasion to chemical location for quick access.
(where Resistance hazards.
applicable) in Level 2 - EN 388 Repetitive
wells. 33xx) and Dura motion.
Flock 8 mil nitrile
7 If applicable; HexArmor Level Back strain, ● Fill port bottom of pump with de-ionized
Decontaminate 6 Series 9010 inhalation or water for bearing lubrication.
submersible (ANSI Cut and dermal exposure ● Decontaminate pump by scrubbing pump
pump. Abrasion to chemical and an adequate length of hose to prevent
Resistance hazards, cross contamination.
Level 2 - EN 388 repetitive ● Pump water through pump during each
33xx) and Dura motion. stage of decontamination.
Flock 8 mil nitrile ● Check happy hose and wiring for fraying or
stripped insulation.
8 Purge Wells HexArmor (See Cross- ● Position GW rig so that the well is easily
attached sheet contamination. accessible to pump reel and equipme● Be
from Back strain, aware of the added width of the vehicle when
subcontractor) inhalation or the storage area doors are open.
(ANSI Cut and dermal exposure ● Heat shield should be used if the well is a 4
Abrasion to chemical diameter well.
Resistance hazards, slip ● Be aware of hot portions of the generator.
Level 3 - EN 388 and fall. ● When using step stool to access generator,
4522) and Dura Improper be sure of proper position to avoid slipping.
Flock 8 mil nitrile labeling or ● When removing pump from well, pay
storage, injury attention to the speed at which the hose is
from broken retracted to avoid injury from the pump or cuts
sample bottle from the hose or hose clamps.
(cuts or acid ● Decontaminate submersible pump as
burn). Vehicular described above.
traffic, electric ● Perform air monitoring.
shock, burns ● Keep work area clear of tripping or slipping
from generator, hazards.
cuts from ● Store purge water in holding tank on truck for
hose/clamps eventual disposal/storage.
Hazard(s)
9 Collect HexArmor (See Cross- ● Decontaminate sampling equipment
samples in attached sheet contamination. between each sampling run.
accordance from Back strain, ● Label samples according to sampling plan.
with sampling subcontractor) inhalation or ● Store samples in proper containers, at
plan. (ANSI Cut and dermal exposure correct temperature, and away from work area.
Abrasion to chemicals. ● Conduct air monitoring.
Resistance Slip/trip/fall. ● If glass sample containers break, wear
Level 3 - EN 388 Injury from leather work gloves when cleaning up. Limit
4522) and Dura broken sample direct contact with broken glass.
Flock 8 mil nitrile bottle. Cuts or ● Cut away from your body.
impalement.
10 Close well & HexArmor Level Traffic. Safety ● Use spotter to help back in rig to area where
Drain holding 6 Series 9010 hazard left on drums are staged.
tank on GWS (ANSI Cut and site. Lifting ● Ensure that end of hose on drum end will not
rig. Abrasion hazard. slide out of drum.
Resistance Electrocution ● If using electrical transfer pump, be aware of
Level 2 - EN 388 hazard. any moisture around plug, outlet, or cord.
33xx) ● Supervise the filling of each drum to ensure
that the hose does not slide out of drum and is
transferred to a new drum before overflow
occurs.
● Ensure that all remaining water in hose to
drained into drum.
● Verify that all drums are properly sealed and
labeled and that holding tank is empty.
● Check to be sure that all bins and storage
compartments are properly latched and
equipment stowed.
11 Clean HexArmor Level Traffic. Safety ● Use buddy system as necessary to remove
site/demobilize 6 Series 9010 hazard left on traffic control.
(ANSI Cut and site. Lifting ● Leave site clean of refuse and debris.
Abrasion hazards. ● Notify tenant of departure and any
Resistance cuttings/purge water left on site.
Level 2 - EN 388 ● Use proper lifting techniques, including the
33xx) buddy system or appropriate mechanical aids
as necessary.
● Be aware of sharp edges on equipment.
● Ensure that all waste containers are closed
before moving them.
● Use three points of contact when
entering/exiting the truck bed.
Job Safety Analysis
Abandoning Groundwater Monitoring Wells

Michael Weber Senior Scientist 05/14/2012 Bradley Eisenberg
06/25/2012
Melissa Novak Associate Scientist 04/24/2012
Daniel Woodward Project Manager 05/07/2010 Scott Jordan
David Stolcenberg Staff Engineer 10/24/2005 Michael Philipp
Michael Philipp West Region Health 12/3/2003

and Safety Manager
Personal Protective Equipment (PPE) & Other Safety Equipment

Wear Level D PPE: Hard Hat, reflective vest for traffic, steel toed and shank shoes, long sleeve shirt, hardhat,
safety glasses with side shields, leather gloves or similar gloves with higher hand protection factor when
handling materials/equipment, nitrile/chemical resistant gloves when the potential for chemical exposure is
present (wear both types of the aforementioned gloves when handling materials/equipment and chemical
exposure hazards are present). An air purifying respirator with combination organic vapor/P-100 cartridges, as
needed. Foam earplugs with an NRR of 33 or their equivalent. Review client-specific PPE requirements and
adhere to prior to proceeding. Contact Project Manager when in doubt.
3-lb type ABC Fire Extinguisher, Window Scraper (cold climates), Tire Gauge. PID meter. LEL meter (for Hot
Work permitted activities).
Stantec Insurance & Vehicle Collision Kit (first aid kit, BBP kit, flashlight, etc)
Field staff must review job-specific work plan and coordinate with project manager to verify that all up-front
logistics are completed prior to starting work including, but not limited to, permitting, access agreements, and
notification to required contacts (e.g. site managers, inspectors, clients, subcontractors, etc.). A tailgate safety
meeting must be performed and documented at the beginning of each workday. Hazard, Recognition,
Assessment and Control (HRAC and Last Minute Risk Assessment (LMRA) procedures must be used
throughout the project. Weather conditions (heat, cold, rain, and lightning) must also be considered. Each
employee is empowered, expected, and has the responsibility to stop the work performed by him/herself or
another co-worker if the working conditions or behaviors are considered unsafe. All employees should act
proactively to identify and mitigate hazards to the safest extent of their ability.
The expectation from Stantec is that this JSA is a living document and any changes or modifications noticed
during field activities should be hand written within this document.
No. Job Step Potential Critical Action(s)

Hazard(s)
1 Clear well Traffic hazards, ● Coordinate with Site Manger (or designee) to minimize
abandonment overhead and potential conflicts.
locations. underground ● Review abandonment well locations against available
installations, construction drawings and known utilities, tanks, product
product releases, lines, etc.
property damage, ● Develop a traffic guidance and control plan with the client
dealer and local agencies as applicable. Plan may include use of
inconvenience delineators, snow fence, barrier tape, jersey barriers, etc.
Hazard(s)
2 Obtain sub- Improper ● Verify records in possession are for equipment on site.
contractor equipment ● Verify maintenance is current.
equipment maintenance,
maintenance which can cause
records prior to equipment failure
commencing work. and possible
personal injury.
3 Mobilize with proper Vehicle accident. ● Start project with Production Safety Meeting
equipment/supplies Lifting hazards. ● Follow safe driving procedures. ● Employ safe lifting
for drilling. Delay or improper procedures.
performance of ● Make sure sub-contractors are aware of their
work due to responsibilities for labor, equipment and supplies.
improper ● Review permit conditions.
equipment onsite. ●Chemical resistant gloves and suit for potential
groundwater contact
4 Visually clear Overhead ● Visually identify overhead installations and address site
proposed well installations. specific conditions.
abandonment
locations.
5 Set up necessary Struck by vehicle ● Use buddy system for placing traffic guidance and control
traffic guidance and during placement. equipment.
control equipment. Vehicle accident as ● Adhere to approved Traffic Guidance and Control Plans
a result of improper when working in roadways.
traffic guidance ● It is the responsibility of the SHSO to annotate the Site
and control Plan with the Traffic Guidance and Control configuration if a
equipment formally developed Traffic Guidance and Control Plan is not
placement. available.
6 Assist with set up of Vehicle accident ● All staff should know where the kill switch is for the drilling
rig. during rig rig.
movement. ● Verify clear pathway to drilling location and clearance for
Damage caused by raising mast. ● Provide as-needed hand signals and
rig while accessing guidance to driver to place rig.
set-up location. ● Visually inspect rig (fire extinguisher on board, no oil or
Contact with other fluid leaks, cabling and associated equipment in good
overhead condition, pressurized hoses secured with whip-checks or
installations. Soft adequate substitute, jacks in good condition?).
terrain. Rig ● If necessary, use wooden blocks under jacks to spread
movement. load. Chock wheels.
7 Set up exclusion Struck by vehicle ● Implement exclusion zone set-up. It is the responsibility of
zone(s) and during set up. the SHSO to annotate the Site Plan with the exclusion zone
workstations. Slip/fall hazards. configuration.
● Set up workstations with clear walking paths to and from
rig.
● Use safety tape, snow fence and delineators.
8 Well casing should Exposure to public. ● Place materials in isolated location away from traffic and
be collected and Traffic hazard or other site functions.
properly discarded obstruction/inconve ● If you suspect that equipment is contaminated, wear
by subcontractor. nience to station chemical resistant gloves.
operation.
Improper storage
or disposal.
Hazard(s)
9 Backfill borehole. Improper grouting ● Mix grout to specification and completely fill the hole.
can lead to future ●Cap filled borehole with concrete layer.
vertical conduit for ● Use proper lifting techniques.
contaminant ● Keep work area clear of tripping hazards.
migration. Back ● Verify presence or other authorization by required
strain, trip hazards, inspectors for grouting.
eye injury from
splashing or
release of
pressurized grout.
Unauthorized
backfilling causes
extra work.
10 Supervisor/HSC Possible injuries ● Visually inspect each and every borehole.
must confirm all and damage to
boreholes are property due to
closed, filled in stepping into or
and/or capped. driving over the
well.
11 Clean Traffic. Safety ● Use buddy system as necessary to remove traffic
site/demobilize. hazard left on site. guidance and control equipment.
Lifting hazards. ● Leave site clean of refuse and debris.
● Clearly mark/barricade any borings that need later
topping off or curing.
● Notify site personnel of departure, final well locations and
any cuttings/purge water left onsite.
● Use proper lifting techniques.
Task: The following table addresses the concerns with excavation activities.
POC Development Team Position/Title Date Reviewed By Position/Title
Stephen R Zayko RI Manager Purity and BeeJay Scales 09/23/04
 Michael A Philipp West Region Health and Safety Manager 09/23/04
Scott Jordan National Operational Excellence Coordinator 09/23/04
02/05/07 Michael Philipp West Region Health and Safety Manager
Site-specific edits to this JSA were made on and by Robert McAlister - SHSO 8/21/15
If most recent review date is more than six months old, then this JSA must be updated and reviewed again to remain current
POC is the JSA development 'Point Of Contact'
Field staff must review job-specific work plan and coordinate with project manager to verify that all up-front logistics are completed prior to starting work including, but not limited to,
permitting, access agreements, and notification to required contacts (e.g. site managers, inspectors, clients, subcontractors, etc.). A tailgate safety meeting must be performed and
documented at the beginning of each workday. Plan, Prevent, Execute (PPE)/Safe Performance Self Assessment (SPSA) procedures must be used throughout the project. Weather
conditions (heat, cold, rain, and lightning) must also be considered. Each employee is empowered, expected, and has the responsibility to stop the work performed by him/herself or
another co-worker if the working conditions or behaviors are considered unsafe. All employees should act proactively to identify and mitigate hazards to the safest extent of their ability.
 Job Steps  Personal Protective Equipment  Potential Hazard  Critical Actions
Mobilize with the proper Level D (hard hat, long pants, long Back strains. Slip/trip/falls.  Start project with Production Safety Meeting (Attachment 16) -
equipment for excavating with sleeved shirt, safety glasses with side Heat/cold exposure. STANTEC/Contractor. Discuss:
a backhoe. shields, steel toed and shank boots, Traffic/driving hazards. -Ensure all STANTEC/Client permits are filled out appropriately and
reflective safety vest); dust mask, ear Improper equipment discussed - STANTEC.
plugs, and gloves (leather and/or maintenance, which can -potential hazards and ways to avoid them - STANTEC/Contractor.
chemical-resistant) as necessary. cause equipment failure and - motor vehicle safety topic - STANTEC/Contractor.
Snake chaps and sunscreen as possible personal injury. - current days weather conditions - STANTEC/Contractor.
required. Personal injury due to - PPE requirements - STANTEC/Contractor.
improper PPE worn. - check subcontractors HASP, Certs, MSDS’s, and equipment
Biological hazards. Injury maintenance records - STANTEC.
resulting from simultaneous - using safe lifting procedures - STANTEC/Contractor.
operations. Non-project
related personnel in vicinity of  Make sure sub-contractors are aware of their responsibilities for labor,
work site. equipment and supplies - STANTEC/Contractor.
 Review permit conditions (as required) - STANTEC/Contractor.
 Conduct Plan, Prevent, Execute/Safe Performance Self Assessment -
STANTEC/Contractor.
 Take your time. Do not rush - STANTEC/Contractor.
 Assess the work area for hazards/potential hazards -
STANTEC/Contractor?
 Wear safety glasses and leather work gloves when loading, unloading, and
whenever material handling - STANTEC/Contractor.
 Secure load in vehicle - STANTEC/Contractor.
 Use lids on debris/garbage containers. Do not leave buckets open with out
a lid! Material in the bucket can spill - STANTEC/Contractor.
 Coordinate proper equipment for leveling or clearing ground prior to start of

excavation activities – STANTEC.
 Have spider and snake bite kits readily available – STANTEC/Contractor.
Clear excavation locations. Gather necessary PPE. Reflective Traffic hazards, overhead and  Reference Utility Clearance Review form (Attachment 4) – STANTEC.
vest for traffic, steel toed and shank
shoes, long sleeve shirt, hard hat,
underground installations,
product releases, property  Coordinate with Site Manger (or designee) to minimize potential conflicts –
safety glasses with side shields, ear damage, dealer STANTEC/Contractor.
plugs/muffs, and leather gloves for inconvenience.  Review proposed locations against available construction drawings and
the non-chemical aspects of work; known utilities, tanks, product lines, etc – STANTEC/Contractor.
 Mark out the proposed excavation locations – STANTEC/Contractor.
Wear an air purifying respirator with
combination organic vapor/P-100
cartridges, and other PPE as needed.  Call underground utility locating service for public line location clearance
(Use a North 7600 series full face and get list of utilities being contacted. If necessary, coordinate private line
respirator or it’s equivalent. Best locator for private property – STANTEC/Contractor.
brand nitrile gloves or their
equivalent. Howard Leight Max foam  Develop a traffic guidance and control plan with the client and local
earplugs with an NRR of 33 or their agencies as applicable. Plan may include use of delineators, barrier tape,
equivalent. Tyvek, poly coated jersey barriers, snow fence, etc. (Refer to Attachment 2) –
chemical resistant suit or it’s STANTEC/Contractor.
equivalent).  It is the responsibility of the SHSO to annotate the Site Plan with the
Traffic Guidance and Control configuration if a formally developed
Traffic Guidance and Control Plan is not available – STANTEC.
Install check link fence Wear reflective vest for traffic, steel Traffic hazards, overhead  Provide a “spotter” when working close to the street –
around the construction area. toed and shank shoes, long sleeve utilities, property damage, STANTEC/Contractor.
Place gates in appropriate
locations (ex. on side streets
shirt, hardhat, safety glasses with
side shields, and leather gloves as
slip/trip/falls, lacerations from
sharp points on fencing, pinch  Install green mesh material on fence – STANTEC/Contractor.
instead of major streets when necessary. points.  Hold the fence when placing fence posts on stands to avoid pinching
possible) between two fence posts – STANTEC/Contractor.
 Use the buddy system when handling fence panels – two person minimum
– STANTEC/Contractor.
 Place sandbags on stands in windy areas. In areas with high winds,
install “in the ground fence” posts for every three - four panels –
STANTEC/Contractor.
Set up necessary traffic Wear reflective vest for traffic, steel Potentially can be struck by  Use buddy system for placing traffic guidance and control equipment –
guidance and control toed and shank shoes, long sleeve vehicle during placement. STANTEC/Contractor.
equipment. See Attachment
2 for detailed plan.
Vehicle accident as a result of
improper traffic control  Create a traffic guidance and control plan to address traffic issues. Refer to
necessary. equipment placement. section above and Traffic Guidance and Control Plan drawing in
Attachment 2 – STANTEC/Contractor.
 Adhere to approved Traffic Guidance and Control Plans when working in
roadways – STANTEC/Contractor.
 It is the responsibility of the SHSO to annotate the Site Plan with the
Set up Storm Water Pollution Wear reflective vest for traffic, steel Improper equipment  Comply with Storm Water Pollution Prevention Plan as applicable –
Prevention equipment toed and shank shoes, long sleeve maintenance, which can STANTEC/Contractor.
shirt, hardhat, safety glasses with cause equipment failure and
side shields, and leather gloves as possible storm water
necessary. contamination.
Slips/trips/falls. NOV. Traffic
hazards
Set up equipment Wear reflective vest for traffic, steel Slips/trips/falls. Back injuries.  See Equipment Decontamination Job Safety Analysis –
decontamination station. toed and shank shoes, long sleeve Traffic hazards. STANTEC/Contractor.
necessary.
Inspect all equipment prior to Wear reflective vest for traffic, steel Improper equipment  Verify records in possession are for equipment on site – STANTEC.
use. Use the daily Equipment
Inspection Form. / Fuel /
toed and shank shoes, long sleeve
maintenance, which can
cause equipment failure and  Verify maintenance is current and proactive – STANTEC.
Grease side shields, and leather gloves as possible personal injury.  Inspect equipment on flat, level ground – STANTEC/Contractor.
 Maintain good housekeeping – STANTEC/Contractor.
necessary. Slips/trips/falls. Pinch points.
 Use handrails when installed – STANTEC/Contractor.

 Keep spill kit available when servicing equipment – STANTEC/Contractor.
Set up exclusion zone(s), Wear reflective vest for traffic, steel Injury or exposure to public or  Set up exclusion zones – STANTEC/Contractor.
stockpile area and establish
work areas/heavy equipment
other onsite personnel.
Slip/fall hazards. Onsite  It is the responsibility of the SHSO to annotate the site plan with the
pathways. side shields, and leather gloves as vehicular accident with heavy location of the exclusion zones – STANTEC.
necessary. equipment.  Set up clear walking paths between workstations – STANTEC/Contractor.
 Use safety tape, snow fence and delineators – STANTEC/Contractor.
Hand digging/post-holing Steel toed and shank shoes, long Damage to lines (and  Use hand tools whenever possible – STANTEC/Contractor.
where necessary to expose
and protect underground
sleeve shirt, hardhat, safety glasses
with side shields, hearing protection,
associated physical hazards
or property damage). Back  Use proper lifting techniques – STANTEC/Contractor.
installations as needed. reflective safety vest, and leather strain. Injury or vehicle  Barricade/cover trenches until job is complete.
gloves for the non-chemical aspects damage from falling into
of work as necessary. holes.
 Conduct air monitoring as outlined in Section 12.
Include Lower Explosive
Limit (LEL) and oxygen monitoring. If >10% LEL or O2 < 19.5% –
STANTEC/Contractor, discontinue work or ventilate area with explosion-
proof equipment.
 Have appropriate respirator with combination organic vapor/P-100
cartridges within 3-5 feet of working location, readily available –
STANTEC/Contractor.
 Avoid twisting back during post holing; if necessary, decontaminate
equipment after use. Decontamination will be accomplished by an Alconox
wash with tap water rinse followed by a de-ionized or distilled water rinse.
Collect rinse water in 5 gallon buckets and transfer to 55-gallon drums and
stage drums in a position agreed upon by the STANTEC SHSO and the
Property Manager – STANTEC/Contractor.
 Strictly adhere to STANTEC’s Utility Clearance Procedures (Forms 213a
and 213b) – STANTEC/Contractor.
Assist with set up of heavy Wear reflective vest for traffic, steel Damage caused by heavy  Verify clear pathway to excavation and stockpiling locations –
equipment. toed and shank shoes, long sleeve equipment while accessing STANTEC/Contractor.
side shields, hearing protection
set-up location. Struck by
equipment.  Provide as-needed hand signals and guidance to driver to place backhoe –
devices, and leather gloves as STANTEC/Contractor.
necessary.  Visually inspect equipment (fire extinguisher on board, no oil or other fluid
leaks, cabling and associated equipment in good condition, pressurized
hoses secured with whip-checks or adequate substitute, jacks in good
condition) – STANTEC/Contractor.
 Maintain eye contact with operator; check all blind spots and use agreed
upon hand signals – STANTEC/Contractor.
Adjust all operator controls Wear reflective vest for traffic, steel
Pinch Points, Strains & falls  Keep handrails and steps free of mud and other slippery material –
and mirrors etc. & put on toed and shank shoes, long sleeve STANTEC/Contractor.
seatbelt shirt, hardhat, safety glasses with
side shields, hearing protection  Utilize handrails and steps – STANTEC/Contractor.
devices, and leather gloves as  Set controls in a good ergonomic position – STANTEC/Contractor.
necessary.
Start up and warm up Wear reflective vest for traffic, steel Engine damage, Pressurized  Keep handrails and steps free of mud and other slippery material –
equipment. toed and shank shoes, hardhat, Lines (Hydraulics leaks), STANTEC/Contractor.
safety glasses with side shields,
hearing protection devices, and
Slips, Trips and Falls
 Utilize handrails and steps – STANTEC/Contractor.
leather gloves as necessary.  Allow for sufficient time for machine and hydraulics to warm up before
actuating any of the systems – STANTEC/Contractor.
 Inspect for hydraulic leaks after system is pressurized –

STANTEC/Contractor – STANTEC/Contractor.
Drive the machine to the area Use PPE as follows: Obstacles and ground  Maintain visual and audio communications with other personnel –
to be excavated.  Level D (all the time): Safety personnel. Overhead utilities. STANTEC/Contractor.
glasses, hardhat, disposable
earplugs, long-sleeved shirts and
Shallow buried lines.
 Be aware of your surroundings at all times – STANTEC/Contractor.
pants, steel-toed boots.  Stay on designated roads or equipment routes – STANTEC/Contractor.
 For contact with moist soil or
liquid: Gloves: 0.008-inch  Keep the boom tucked in and locked – STANTEC/Contractor.
gauge Best brand nitrile gloves  Know the location of all overhead and underground utilities prior to
or their equivalent, and leather relocating the machine – STANTEC/Contractor.
work gloves
Boot Covers: PVC,
Neoprene
or equivalent
Chemical resistant Suit:
Tyvek, Poly coated,
chemical resistant or it’s
equivalent.
 Upgrade to Level C (if necessary):
Level D plus full face respirator
 Cartridges: Organic Vapor/P-
100
 Gloves: 0.008-inch gauge
inner Best brand nitrile gloves or
their equivalent, with 0.11-inch
gauge outer Best brand nitrile
gloves or their equivalent and
leather work gloves
 Boot Covers: Neoprene
 Chemical Resistant Suit: Wear
Tyvek, poly coated chemical
resistant suit or it’s equivalent.
Lower the stabilizers and Use PPE as follows: Poor Control. Equipment  Maintain visual and audio communications with other personnel –
bucket position backhoe so  Level D (all the time): Safety damage, Operator Fatigue, STANTEC/Contractor.
that excavation area is
parallel to the wheels on
Excessive wear and tear on
machine  Be aware of your surroundings at all times – STANTEC/Contractor.
stable ground. pants, steel-toed boots.  Stay on designated roads or equipment routes – STANTEC/Contractor.
liquid: Gloves: 0.008-inch  Keep the boom low and close to the ground – STANTEC/Contractor.
gauge Best brand nitrile gloves
or their equivalent, and leather
work gloves
 Know the location of all overhead and underground utilities prior to
relocating the machine – STANTEC/Contractor.
Boot Covers: PVC,
Neoprene
or equivalent
Tyvek, Poly coated,
equivalent.
100
leather work gloves
Verify work task and locations Level D (hard hat, long pants, long Heat or cold exposure.  Be aware of your surroundings at all times - STANTEC/Contractor.
to be excavated. Ensure all
utility clearance procedures
sleeved shirt, safety glasses with side
shields, steel toed and shank boots,
Exposure to chemical
hazards.  Stay on designated roads or equipment routes - STANTEC/Contractor.
have been verified completed reflective safety vest); dust mask, ear Hitting an underground or  Wear appropriate PPE - STANTEC/Contractor.
 Be aware of other tasks being performed on-site - STANTEC/Contractor.
prior to beginning excavation. plugs, and gloves (leather and/or overhead utility.
chemical-resistant) as necessary. Flammable or oxygen-
ALSO – snake chaps and sunscreen. deficient atmosphere from  Perform individual tasks from beginning to completion when possible -
accumulated vapors. STANTEC/Contractor.
Trip and fall.
Side wall cave-in.
Equipment failure.
Noise.
Incident resulting from SSE
inexperience.
Personal injury due to
improper PPE worn.
Injury resulting from
simultaneous operations.
Commence excavation Use PPE as follows: Heat or cold exposure,  Monitor weather conditions and take breaks as needed for cold or hot
 Level D (all the time): Safety exposure to chemical weather – STANTEC/Contractor.
hazards, hitting an
underground or overhead  Monitor air around excavation and perimeter in accordance with Section 12 –
pants, steel-toed boots. utility, flammable or oxygen- STANTEC.
 For contact with moist soil or deficient atmosphere from  Include Lower Explosive Limit (LEL) and oxygen monitoring. If >10% LEL
liquid: Gloves: 0.008-inch accumulated vapors, trip and or O2 < 19.5%, discontinue work or ventilate area with explosion-proof
gauge Best brand nitrile gloves fall, side wall cave-in, equipment – STANTEC/Contractor.
or their equivalent, and leather equipment failure, noise.
work gloves
Boot Covers: PVC,
STANTEC/Contractor.
Neoprene
or equivalent  Maintain required trench/excavation setbacks for workers and equipment
Chemical resistant Suit: and monitor condition of sidewalls and surrounding ground conditions –
Tyvek, Poly coated, STANTEC/Contractor.
equivalent.  Keep work area clear of tripping or slipping hazards –
 Upgrade to Level C (if necessary): STANTEC/Contractor.
Level D plus full face respirator  Perform periodic visual inspections of heavy equipment and keep it at least
 Cartridges: Organic Vapor/P- 5' from trench/excavation edge, or one foot away from the edge for every
100 foot of depth if greater than 5' deep – STANTEC/Contractor.
inner Best brand nitrile gloves or  Perform necessary soil classification – STANTEC/Contractor.
their equivalent, with 0.11-inch  Slope/bench walls or shore excavation to prevent cave-in –
gauge outer Best brand nitrile STANTEC/Contractor.
leather work gloves  Keep all spoils > 2 ft from excavation edge – STANTEC/Contractor.
 Keep excavation entry controlled and equipped with required ladders and
crosswalks – STANTEC/Contractor.
resistant suit or it’s equivalent.  Suppress odors and vapors by spraying with Simple Green solution or
other approved vapor suppressant – STANTEC/Contractor.
 NOTE: STANTEC staff are not to enter an excavation without first
contacting Philip Platcow, Director of Industrial Hygiene and Health &
Safety (617) 232-7355.
Collect samples in Steel toed and shank shoes, long Cave-in of sidewalls if  Stay out of excavation, (collect samples from backhoe bucket) –
accordance with sampling sleeve shirt, hardhat, safety glasses entering excavation. Injury STANTEC/Contractor.
plan, as required. with side shields, hearing protection,
reflective safety vest, and chemical
from heavy equipment.
Exposure to site  Use agreed-upon hand signals with heavy equipment operators –
resistant gloves as necessary. Wear contaminants. STANTEC/Contractor.
appropriate respirator with  Monitor air around excavation and perimeter in accordance with Section 12 –
combination organic vapor/P-100 STANTEC.
cartridges as needed.  Have appropriate respirator with combination organic vapor/P-100
STANTEC/Contractor.
Proper clean up and disposal Safety glasses Exposure to broken glass and  Isolate area where broken glass is located - STANTEC/Contractor.
of broken sample container. Long sleeved shirt
Leather Work Gloves
acid (from water preservation
acids)  Determine if the sample container was preserved (did it have acid in it?) -
Hand Broom and Dust Pan Injury STANTEC.
A receptacle for the broken glass  Determine what to contain the broken glass in, and where to dispose of the
(something to contain the broken broken glass before beginning to pick up the glass - STANTEC.
 Collect equipment needed to clean up and contain the broken glass -
glass (double garbage bag, a box, or
bucket).
STANTEC/Contractor.
 Minimize “picking up” broken glass pieces with your gloved hands. Use a
dust pan if possible/practical - STANTEC/Contractor.
 If broken glass is located inside a container (i.e. box), to the extent
practical, leave glass inside box and put entire box into a garbage bag.
Double bag if warranted. Place into dumpster - STANTEC/Contractor.
 If broken glass is inside a cooler, remove all other sample containers and
place in a safe location, then use hand broom and dust pan to sweep up
glass in cooler - STANTEC.
 After clean up is complete, contact your Project Manager to report this
Loss/Incident - STANTEC.
Store excavated materials Steel toed and shank shoes, long Exposure to public. Traffic  Monitor air around excavation and perimeter in accordance with Section 12 -
properly in accordance with sleeve shirt, hardhat, safety glasses hazard or STANTEC
site-specific requirements with side shields, hearing protection,
obstruction/inconvenience to
station operation. Improper  Have appropriate respirator with combination organic vapor/P-100
resistant gloves and suit. storage or disposal. cartridges within 3-5 feet of working location, readily available -
STANTEC/Contractor.
 Have proper storage containment and labeling available onsite -
STANTEC/Contractor.
 Place materials in isolated location away from traffic and other site
functions - STANTEC/Contractor.
 Stockpile excavated materials on suitable plastic or in appropriately
designed container. Cover with plastic and barricade access to waste in
accordance with local regulations - STANTEC/Contractor.
 Suppress odors and vapors by spraying with simple Green solution or other
approved vapor suppressant - STANTEC/Contractor.
 Coordinate proper disposal offsite (where applicable) -
STANTEC/Contractor.
Backfill trench/excavation Steel toed and shank shoes, long Struck by heavy equipment.  Use agreed-upon hand signals with heavy equipment operators -
sleeve shirt, hardhat, safety glasses Sidewall collapse. Future STANTEC/Contractor.
reflective safety vest, and leather
damage or accidents
resulting from subsidence.  Compact soils to meet specifications - STANTEC/Contractor.
gloves for the non-chemical aspects  Maintain eye contact with equipment operators, check blind spots -
of work and chemical resistant inner STANTEC/Contractor.
 Monitor air around trench/excavation in accordance with Section 12 -
gloves as necessary. Wear
appropriate air purifying respirator
with combination organic vapor/P-100 STANTEC.
cartridges within 3-5 feet of working location, readily available-
STANTEC/Contractor.
Perform heavy equipment Chemical splash proof goggles and Chemical exposure to eyes  Avoid twisting back during the operation; Decontaminate equipment after
decontamination procedures. face shield when spraying skin and respiratory system. use. Decontamination will be accomplished by an approved method for the
equipment/personnel. Steel toed Cross contamination. contaminants involved. Collect contaminated rinse water/materials in 5
rubber boots and raingear or other gallon buckets and transfer to 55-gallon drums and stage drums -
appropriate waterproof suits. Long STANTEC/Contractor.
sleeve shirts,  Equipment Decon personnel must wear the same level of protection as the
field personnel. (Chemical splash goggles, face shields, rain suits, etc)
(See Equipment Decontamination JSA) - STANTEC/Contractor.
Perform personnel dry Chemical exposure.  Perform dry boot wash using a stiff bristle, fiberglass handled brush paying
decontamination procedures. special attention to the welt and sole areas of the boot. Remove tape from
boot tops and properly dispose of the tape, remove tape from outer gloves
and properly dispose of the tape, remove outer gloves and properly
dispose of outer gloves, remove Tyvek and properly dispose of Tyvek, ,
remove boots and place in large garbage bag, remove inner gloves and
properly dispose of inner gloves. Put street shoes on. Wash hands, face
arms and neck (any exposed skin) (use baby wipes if a washing facility is
unavailable) Decontamination water will be stored in 55 gallon drums -
STANTEC.
 Drums will be staged in a location determined by the SHSO and the
Property Owner/Station Manager - STANTEC.
 Drums containing flammable/combustible liquids or solids must be
grounded and if there are multiple drums bonded together -
STANTEC.
 Use extreme care when opening the bung caps. Stand an arms length
away and open the bung slowly to relieve any built up pressure -
STANTEC.
Supervisor/SHSO must Possible injuries and damage  Visually inspect each and every trench/excavation - STANTEC/Contractor.
confirm all to property due to stepping  If trench/excavation is left open overnight, cover completely with trench-
trenches/excavations are into or driving over the well. plate or completely surround the trench/excavation with delineators and
closed, filled in and/or orange construction fence - STANTEC/Contractor.
capped.
Clean site/demobilize Steel toed and shank shoes, long Traffic. Safety hazard left on  Use buddy system as necessary to remove traffic guidance and control
sleeve shirt, hardhat, safety glasses site. Lifting hazards. equipment - STANTEC/Contractor.
reflective safety vest, and leather  Leave site clean of refuse and debris - STANTEC/Contractor.
gloves for the non-chemical aspects  Notify station personnel of departure - STANTEC/Contractor.
 Use proper lifting techniques or use mechanical assistance -
of work as needed.
STANTEC/Contractor.
Package and deliver samples Bottle breakage (if any), back  Handle and pack bottles carefully (bubble wrap bags are helpful) -
to lab strain. STANTEC/Contractor.
 Use proper lifting techniques - STANTEC/Contractor.
Task: The following table addresses the concerns with excavation activities.
POC Development Team Position/Title Date Reviewed By Position/Title
Stephen R Zayko RI Manager Purity and BeeJay Scales 09/23/04
 Michael A Philipp West Region Health and Safety Manager 09/23/04
Scott Jordan National Operational Excellence Coordinator 09/23/04
02/05/07 Michael Philipp West Region Health and Safety Manager
Site-specific edits to this JSA were made on and by Robert McAlister - SHSO 8/21/15
Mobilize with the proper Level D (hard hat, long pants, long Back strains. Slip/trip/falls.  Start project with Production Safety Meeting (Attachment 16) -
equipment for excavating with sleeved shirt, safety glasses with side Heat/cold exposure. STANTEC/Contractor. Discuss:
a backhoe. shields, steel toed and shank boots, Traffic/driving hazards. -Ensure all STANTEC/Client permits are filled out appropriately and
reflective safety vest); dust mask, ear Improper equipment discussed - STANTEC.
plugs, and gloves (leather and/or maintenance, which can -potential hazards and ways to avoid them - STANTEC/Contractor.
chemical-resistant) as necessary. cause equipment failure and - motor vehicle safety topic - STANTEC/Contractor.
Snake chaps and sunscreen as possible personal injury. - current days weather conditions - STANTEC/Contractor.
required. Personal injury due to - PPE requirements - STANTEC/Contractor.
improper PPE worn. - check subcontractors HASP, Certs, MSDS’s, and equipment
Biological hazards. Injury maintenance records - STANTEC.
resulting from simultaneous - using safe lifting procedures - STANTEC/Contractor.
operations. Non-project
related personnel in vicinity of  Make sure sub-contractors are aware of their responsibilities for labor,
work site. equipment and supplies - STANTEC/Contractor.
 Review permit conditions (as required) - STANTEC/Contractor.
STANTEC/Contractor.
 Assess the work area for hazards/potential hazards -
STANTEC/Contractor?
 Wear safety glasses and leather work gloves when loading, unloading, and
whenever material handling - STANTEC/Contractor.
 Secure load in vehicle - STANTEC/Contractor.
 Use lids on debris/garbage containers. Do not leave buckets open with out
a lid! Material in the bucket can spill - STANTEC/Contractor.
 Coordinate proper equipment for leveling or clearing ground prior to start of
excavation activities – STANTEC.
 Have spider and snake bite kits readily available – STANTEC/Contractor.
Clear excavation locations. Gather necessary PPE. Reflective Traffic hazards, overhead and  Reference Utility Clearance Review form (Attachment 4) – STANTEC.
vest for traffic, steel toed and shank
shoes, long sleeve shirt, hard hat,
underground installations,
product releases, property  Coordinate with Site Manger (or designee) to minimize potential conflicts –
safety glasses with side shields, ear damage, dealer STANTEC/Contractor.
plugs/muffs, and leather gloves for inconvenience.  Review proposed locations against available construction drawings and
the non-chemical aspects of work; known utilities, tanks, product lines, etc – STANTEC/Contractor.
 Mark out the proposed excavation locations – STANTEC/Contractor.
Wear an air purifying respirator with
combination organic vapor/P-100
cartridges, and other PPE as needed.  Call underground utility locating service for public line location clearance
(Use a North 7600 series full face and get list of utilities being contacted. If necessary, coordinate private line
respirator or it’s equivalent. Best locator for private property – STANTEC/Contractor.
brand nitrile gloves or their
equivalent. Howard Leight Max foam  Develop a traffic guidance and control plan with the client and local
earplugs with an NRR of 33 or their agencies as applicable. Plan may include use of delineators, barrier tape,
equivalent. Tyvek, poly coated jersey barriers, snow fence, etc. (Refer to Attachment 2) –
chemical resistant suit or it’s STANTEC/Contractor.
equivalent).  It is the responsibility of the SHSO to annotate the Site Plan with the
Install check link fence Wear reflective vest for traffic, steel Traffic hazards, overhead  Provide a “spotter” when working close to the street –
around the construction area. toed and shank shoes, long sleeve utilities, property damage, STANTEC/Contractor.
Place gates in appropriate
locations (ex. on side streets
slip/trip/falls, lacerations from
sharp points on fencing, pinch  Install green mesh material on fence – STANTEC/Contractor.
instead of major streets when necessary. points.  Hold the fence when placing fence posts on stands to avoid pinching
possible) between two fence posts – STANTEC/Contractor.
 Use the buddy system when handling fence panels – two person minimum
– STANTEC/Contractor.
 Place sandbags on stands in windy areas. In areas with high winds,
install “in the ground fence” posts for every three - four panels –
STANTEC/Contractor.
Set up necessary traffic Wear reflective vest for traffic, steel Potentially can be struck by  Use buddy system for placing traffic guidance and control equipment –
guidance and control toed and shank shoes, long sleeve vehicle during placement. STANTEC/Contractor.
equipment. See Attachment
2 for detailed plan.
Vehicle accident as a result of
improper traffic control  Create a traffic guidance and control plan to address traffic issues. Refer to
necessary. equipment placement. section above and Traffic Guidance and Control Plan drawing in
Attachment 2 – STANTEC/Contractor.
 Adhere to approved Traffic Guidance and Control Plans when working in
roadways – STANTEC/Contractor.
Set up Storm Water Pollution Wear reflective vest for traffic, steel Improper equipment  Comply with Storm Water Pollution Prevention Plan as applicable –
Prevention equipment toed and shank shoes, long sleeve maintenance, which can STANTEC/Contractor.
shirt, hardhat, safety glasses with cause equipment failure and
side shields, and leather gloves as possible storm water
necessary. contamination.
Slips/trips/falls. NOV. Traffic
hazards
Set up equipment Wear reflective vest for traffic, steel Slips/trips/falls. Back injuries.  See Equipment Decontamination Job Safety Analysis –
decontamination station. toed and shank shoes, long sleeve Traffic hazards. STANTEC/Contractor.
necessary.
Inspect all equipment prior to Wear reflective vest for traffic, steel Improper equipment  Verify records in possession are for equipment on site – STANTEC.
use. Use the daily Equipment
Inspection Form. / Fuel /
maintenance, which can
cause equipment failure and  Verify maintenance is current and proactive – STANTEC.
Grease side shields, and leather gloves as possible personal injury.  Inspect equipment on flat, level ground – STANTEC/Contractor.
 Maintain good housekeeping – STANTEC/Contractor.
necessary. Slips/trips/falls. Pinch points.
 Use handrails when installed – STANTEC/Contractor.

 Keep spill kit available when servicing equipment – STANTEC/Contractor.
Set up exclusion zone(s), Wear reflective vest for traffic, steel Injury or exposure to public or  Set up exclusion zones – STANTEC/Contractor.
stockpile area and establish
work areas/heavy equipment
other onsite personnel.
Slip/fall hazards. Onsite  It is the responsibility of the SHSO to annotate the site plan with the
pathways. side shields, and leather gloves as vehicular accident with heavy location of the exclusion zones – STANTEC.
necessary. equipment.  Set up clear walking paths between workstations – STANTEC/Contractor.
 Use safety tape, snow fence and delineators – STANTEC/Contractor.
Hand digging/post-holing Steel toed and shank shoes, long Damage to lines (and  Use hand tools whenever possible – STANTEC/Contractor.
where necessary to expose
and protect underground
sleeve shirt, hardhat, safety glasses
associated physical hazards
or property damage). Back  Use proper lifting techniques – STANTEC/Contractor.
installations as needed. reflective safety vest, and leather strain. Injury or vehicle  Barricade/cover trenches until job is complete.
 Conduct air monitoring as outlined in Section 12. Include Lower Explosive
gloves for the non-chemical aspects damage from falling into
of work as necessary. holes.
Limit (LEL) and oxygen monitoring. If >10% LEL or O2 < 19.5% –
STANTEC/Contractor, discontinue work or ventilate area with explosion-
proof equipment.
STANTEC/Contractor.
 Avoid twisting back during post holing; if necessary, decontaminate
equipment after use. Decontamination will be accomplished by an Alconox
wash with tap water rinse followed by a de-ionized or distilled water rinse.
Collect rinse water in 5 gallon buckets and transfer to 55-gallon drums and
stage drums in a position agreed upon by the STANTEC SHSO and the
Property Manager – STANTEC/Contractor.
 Strictly adhere to STANTEC’s Utility Clearance Procedures (Forms 213a
and 213b) – STANTEC/Contractor.
Assist with set up of heavy Wear reflective vest for traffic, steel Damage caused by heavy  Verify clear pathway to excavation and stockpiling locations –
equipment. toed and shank shoes, long sleeve equipment while accessing STANTEC/Contractor.
side shields, hearing protection
set-up location. Struck by
equipment.  Provide as-needed hand signals and guidance to driver to place backhoe –
devices, and leather gloves as STANTEC/Contractor.
necessary.  Visually inspect equipment (fire extinguisher on board, no oil or other fluid
leaks, cabling and associated equipment in good condition, pressurized
hoses secured with whip-checks or adequate substitute, jacks in good
condition) – STANTEC/Contractor.
 Maintain eye contact with operator; check all blind spots and use agreed
upon hand signals – STANTEC/Contractor.
Adjust all operator controls Wear reflective vest for traffic, steel
Pinch Points, Strains & falls  Keep handrails and steps free of mud and other slippery material –
and mirrors etc. & put on toed and shank shoes, long sleeve STANTEC/Contractor.
seatbelt shirt, hardhat, safety glasses with
side shields, hearing protection  Utilize handrails and steps – STANTEC/Contractor.
devices, and leather gloves as  Set controls in a good ergonomic position – STANTEC/Contractor.
necessary.
Start up and warm up Wear reflective vest for traffic, steel Engine damage, Pressurized  Keep handrails and steps free of mud and other slippery material –
equipment. toed and shank shoes, hardhat, Lines (Hydraulics leaks), STANTEC/Contractor.
safety glasses with side shields,
hearing protection devices, and
Slips, Trips and Falls
 Utilize handrails and steps – STANTEC/Contractor.
leather gloves as necessary.  Allow for sufficient time for machine and hydraulics to warm up before
actuating any of the systems – STANTEC/Contractor.
 Inspect for hydraulic leaks after system is pressurized –
STANTEC/Contractor – STANTEC/Contractor.
Drive the machine to the area Use PPE as follows: Obstacles and ground  Maintain visual and audio communications with other personnel –
to be excavated.  Level D (all the time): Safety personnel. Overhead utilities. STANTEC/Contractor.
Shallow buried lines.
pants, steel-toed boots.  Stay on designated roads or equipment routes – STANTEC/Contractor.
liquid: Gloves: 0.008-inch  Keep the boom tucked in and locked – STANTEC/Contractor.
work gloves
Boot Covers: PVC,
Neoprene
or equivalent
Tyvek, Poly coated,
equivalent.
100
leather work gloves
Lower the stabilizers and Use PPE as follows: Poor Control. Equipment  Maintain visual and audio communications with other personnel –
bucket position backhoe so  Level D (all the time): Safety damage, Operator Fatigue, STANTEC/Contractor.
that excavation area is
parallel to the wheels on
Excessive wear and tear on
machine
stable ground. pants, steel-toed boots.  Stay on designated roads or equipment routes – STANTEC/Contractor.
liquid: Gloves: 0.008-inch  Keep the boom low and close to the ground – STANTEC/Contractor.
work gloves
Boot Covers: PVC,
Neoprene
or equivalent
Tyvek, Poly coated,
equivalent.
100
leather work gloves
Verify work task and locations Level D (hard hat, long pants, long Heat or cold exposure.  Be aware of your surroundings at all times - STANTEC/Contractor.
to be excavated. Ensure all
utility clearance procedures
sleeved shirt, safety glasses with side
shields, steel toed and shank boots,
Exposure to chemical
hazards.  Stay on designated roads or equipment routes - STANTEC/Contractor.
have been verified completed reflective safety vest); dust mask, ear Hitting an underground or  Wear appropriate PPE - STANTEC/Contractor.
 Be aware of other tasks being performed on-site - STANTEC/Contractor.
prior to beginning excavation. plugs, and gloves (leather and/or overhead utility.
chemical-resistant) as necessary. Flammable or oxygen-
ALSO – snake chaps and sunscreen. deficient atmosphere from  Perform individual tasks from beginning to completion when possible -
accumulated vapors. STANTEC/Contractor.
Trip and fall.
Side wall cave-in.
Equipment failure.
Noise.
Incident resulting from SSE
inexperience.
Personal injury due to
improper PPE worn.
simultaneous operations.
Commence excavation Use PPE as follows: Heat or cold exposure,  Monitor weather conditions and take breaks as needed for cold or hot
 Level D (all the time): Safety exposure to chemical weather – STANTEC/Contractor.
hazards, hitting an
underground or overhead  Monitor air around excavation and perimeter in accordance with Section 12 –
pants, steel-toed boots. utility, flammable or oxygen- STANTEC.
 For contact with moist soil or deficient atmosphere from  Include Lower Explosive Limit (LEL) and oxygen monitoring. If >10% LEL
liquid: Gloves: 0.008-inch accumulated vapors, trip and or O2 < 19.5%, discontinue work or ventilate area with explosion-proof
gauge Best brand nitrile gloves fall, side wall cave-in, equipment – STANTEC/Contractor.
or their equivalent, and leather
work gloves
equipment failure, noise.
Boot Covers: PVC,
STANTEC/Contractor.
Neoprene
or equivalent  Maintain required trench/excavation setbacks for workers and equipment
Chemical resistant Suit: and monitor condition of sidewalls and surrounding ground conditions –
Tyvek, Poly coated, STANTEC/Contractor.
equivalent.  Keep work area clear of tripping or slipping hazards –
 Upgrade to Level C (if necessary): STANTEC/Contractor.
Level D plus full face respirator  Perform periodic visual inspections of heavy equipment and keep it at least
 Cartridges: Organic Vapor/P- 5' from trench/excavation edge, or one foot away from the edge for every
100 foot of depth if greater than 5' deep – STANTEC/Contractor.
inner Best brand nitrile gloves or  Perform necessary soil classification – STANTEC/Contractor.
their equivalent, with 0.11-inch  Slope/bench walls or shore excavation to prevent cave-in –
gauge outer Best brand nitrile STANTEC/Contractor.
leather work gloves  Keep all spoils > 2 ft from excavation edge – STANTEC/Contractor.
 Keep excavation entry controlled and equipped with required ladders and
crosswalks – STANTEC/Contractor.
resistant suit or it’s equivalent.  Suppress odors and vapors by spraying with Simple Green solution or
other approved vapor suppressant – STANTEC/Contractor.
 NOTE: STANTEC staff are not to enter an excavation without first
contacting Philip Platcow, Director of Industrial Hygiene and Health &
Safety (617) 232-7355.
Collect samples in Steel toed and shank shoes, long Cave-in of sidewalls if  Stay out of excavation, (collect samples from backhoe bucket) –
accordance with sampling sleeve shirt, hardhat, safety glasses entering excavation. Injury STANTEC/Contractor.
plan, as required. with side shields, hearing protection,
from heavy equipment.
Exposure to site  Use agreed-upon hand signals with heavy equipment operators –
resistant gloves as necessary. Wear contaminants. STANTEC/Contractor.
appropriate respirator with  Monitor air around excavation and perimeter in accordance with Section 12 –
combination organic vapor/P-100 STANTEC.
cartridges as needed.
STANTEC/Contractor.
Proper clean up and disposal Safety glasses Exposure to broken glass and  Isolate area where broken glass is located - STANTEC/Contractor.
of broken sample container. Long sleeved shirt
Leather Work Gloves
acid (from water preservation
acids)  Determine if the sample container was preserved (did it have acid in it?) -
Hand Broom and Dust Pan Injury STANTEC.
A receptacle for the broken glass  Determine what to contain the broken glass in, and where to dispose of the
(something to contain the broken broken glass before beginning to pick up the glass - STANTEC.
 Collect equipment needed to clean up and contain the broken glass -
glass (double garbage bag, a box, or
bucket).
STANTEC/Contractor.
 Minimize “picking up” broken glass pieces with your gloved hands. Use a
dust pan if possible/practical - STANTEC/Contractor.
glass in cooler - STANTEC.
Loss/Incident - STANTEC.
Store excavated materials Steel toed and shank shoes, long Exposure to public. Traffic  Monitor air around excavation and perimeter in accordance with Section 12 -
properly in accordance with sleeve shirt, hardhat, safety glasses hazard or STANTEC
site-specific requirements with side shields, hearing protection,
obstruction/inconvenience to
station operation. Improper  Have appropriate respirator with combination organic vapor/P-100
resistant gloves and suit. storage or disposal. cartridges within 3-5 feet of working location, readily available -
STANTEC/Contractor.
 Have proper storage containment and labeling available onsite -
STANTEC/Contractor.
 Place materials in isolated location away from traffic and other site
functions - STANTEC/Contractor.
 Stockpile excavated materials on suitable plastic or in appropriately
designed container. Cover with plastic and barricade access to waste in
accordance with local regulations - STANTEC/Contractor.
 Suppress odors and vapors by spraying with simple Green solution or other
approved vapor suppressant - STANTEC/Contractor.
 Coordinate proper disposal offsite (where applicable) -
STANTEC/Contractor.
Backfill trench/excavation Steel toed and shank shoes, long Struck by heavy equipment.  Use agreed-upon hand signals with heavy equipment operators -
sleeve shirt, hardhat, safety glasses Sidewall collapse. Future STANTEC/Contractor.
reflective safety vest, and leather
damage or accidents
resulting from subsidence.  Compact soils to meet specifications - STANTEC/Contractor.
gloves for the non-chemical aspects  Maintain eye contact with equipment operators, check blind spots -
of work and chemical resistant inner STANTEC/Contractor.
 Monitor air around trench/excavation in accordance with Section 12 -
gloves as necessary. Wear
appropriate air purifying respirator
with combination organic vapor/P-100 STANTEC.
cartridges within 3-5 feet of working location, readily available-
STANTEC/Contractor.
Perform heavy equipment Chemical splash proof goggles and Chemical exposure to eyes  Avoid twisting back during the operation; Decontaminate equipment after
decontamination procedures. face shield when spraying skin and respiratory system. use. Decontamination will be accomplished by an approved method for the
equipment/personnel. Steel toed Cross contamination. contaminants involved. Collect contaminated rinse water/materials in 5
rubber boots and raingear or other gallon buckets and transfer to 55-gallon drums and stage drums -
appropriate waterproof suits. Long STANTEC/Contractor.
sleeve shirts,  Equipment Decon personnel must wear the same level of protection as the
field personnel. (Chemical splash goggles, face shields, rain suits, etc)
(See Equipment Decontamination JSA) - STANTEC/Contractor.
Perform personnel dry Chemical exposure.  Perform dry boot wash using a stiff bristle, fiberglass handled brush paying
decontamination procedures. special attention to the welt and sole areas of the boot. Remove tape from
boot tops and properly dispose of the tape, remove tape from outer gloves
and properly dispose of the tape, remove outer gloves and properly
dispose of outer gloves, remove Tyvek and properly dispose of Tyvek, ,
remove boots and place in large garbage bag, remove inner gloves and
properly dispose of inner gloves. Put street shoes on. Wash hands, face
arms and neck (any exposed skin) (use baby wipes if a washing facility is
unavailable) Decontamination water will be stored in 55 gallon drums -
STANTEC.

STANTEC.
 Use extreme care when opening the bung caps. Stand an arms length
away and open the bung slowly to relieve any built up pressure -
STANTEC.
Supervisor/SHSO must Possible injuries and damage  Visually inspect each and every trench/excavation - STANTEC/Contractor.
confirm all to property due to stepping  If trench/excavation is left open overnight, cover completely with trench-
trenches/excavations are into or driving over the well. plate or completely surround the trench/excavation with delineators and
closed, filled in and/or orange construction fence - STANTEC/Contractor.
capped.
Clean site/demobilize Steel toed and shank shoes, long Traffic. Safety hazard left on  Use buddy system as necessary to remove traffic guidance and control
sleeve shirt, hardhat, safety glasses site. Lifting hazards. equipment - STANTEC/Contractor.
reflective safety vest, and leather  Leave site clean of refuse and debris - STANTEC/Contractor.
gloves for the non-chemical aspects  Notify station personnel of departure - STANTEC/Contractor.
of work as needed.
STANTEC/Contractor.
to lab strain. STANTEC/Contractor.
 Use proper lifting techniques - STANTEC/Contractor.
TASK: The following table addresses the concerns of Soil grading.
POC Development
Team Position/Title Date Reviewed By Position/Title
 Michael Allen Philipp West Region Health & Safety Manager 01/04/05
Scott Jordan National OE Coordinator 01/04/05
Cathy Von Euw Senior Project Manager 01/04/05
11/29/06 Michael Allen Philipp West Region Health and Safety Manager
Site specific edits to this JSA were made on and by Robert McAlister 8/21/15
conditions (heat, cold, rain, lightning) must also be considered. Each employee is empowered, expected, and has the responsibility to stop the work performed by him/herself or
 Job Steps  Personal Protective Equipment  Potential Hazard  Critical Actions/Precautions
Mobilize with proper Gather necessary PPE. Reflective vest Vehicle accident. Lifting  Start project with Production Safety Meeting (Attachment 6) -
equipment/supplies for soil for traffic, steel toed and shank shoes, hazards. Delay or improper STANTEC/Contractor. Discuss:
aeration and grading. long sleeve shirt, hardhat, safety performance of work due to -Ensure all STANTEC/Client permits are filled out appropriately and
glasses with side shields, ear improper equipment onsite. discussed - STANTEC.
plugs/muffs, leather gloves for the non- -potential hazards and ways to avoid them - STANTEC/Contractor.
chemical aspects of work as necessary; - motor vehicle safety topic - STANTEC/Contractor.
Wear an air purifying respirator with - current days weather conditions - STANTEC/Contractor..
combination organic vapor/P-100 - PPE requirements - STANTEC/Contractor.
cartridges, and other PPE as needed. - check subcontractors HASP, Certs, MSDS’s, and equipment
(Use a North 7600 series full face maintenance records - STANTEC.
respirator or its equivalent. Best brand - using safe lifting procedures - STANTEC/Contractor.
nitrile gloves or their equivalent. Howard
Leight Max foam earplugs with an NRR
 Make sure sub-contractors are aware of their responsibilities for labor,
equipment and supplies - STANTEC/Contractor.
of 33 or their equivalent. Tyvek, poly
coated chemical resistant suit or it’s  Review permit conditions - STANTEC/Contractor.
equivalent).
STANTEC/Contractor.
 Develop a traffic guidance and control plan with the client and local
agencies as applicable. Plan may include use of delineators,
construction fence, and/or caution tape, jersey barriers, etc. (Refer to
section above) – STANTEC/Contractor.
 Assess the area, are there hazards present - STANTEC/Contractor?
 Wear safety glasses and leather work gloves when loading, unloading,
and whenever material handling - STANTEC/Contractor.
 Secure load in vehicle - STANTEC/Contractor
 Use lids to debris/garbage containers. Do not leave buckets open with
out a lid! Material in the bucket can spill - STANTEC/Contractor.
 Use bubble wrap or other insulating material to cushion the sample
containers during transport – STANTEC
 Use the right tools to open and close well boxes – STANTEC/Contractor.
Obtain sub-contractor Improper equipment  Verify records in possession are for equipment on site –
equipment maintenance maintenance, which can STANTEC/Contractor.
records prior to commencing
work.
cause equipment failure and
possible personal injury.  Verify maintenance is current – STANTEC/Contractor.
Set up necessary traffic Wear reflective vest for traffic, steel Struck by vehicle during  Use buddy system for placing traffic guidance and control equipment –
guidance and control toed and shank shoes, long sleeve placement. Vehicle accident STANTEC/Contractor.
equipment. See Attachment shirt, hardhat, safety glasses with side as a result of improper traffic  Adhere to approved Traffic Guidance and Control Plans when working in
2. shields, leather gloves. guidance and control roadways – STANTEC/Contractor.
equipment placement.
Set up exclusion zone(s) and Wear reflective vest for traffic, steel Struck by vehicle during set  Implement exclusion zone set-up. It is the responsibility of the SHSO
workstations. toed and shank shoes, long sleeve up. Slip/fall hazards. to annotate the Site Plan with the exclusion zone configuration –
shirt, hardhat, safety glasses with side STANTEC.
shields, leather gloves.  Set up workstations with clear walking paths to and from rig –
STANTEC/Contractor.
 Use delineators, construction fence and/or caution tape –
STANTEC/Contractor.
Assist with set up of heavy Wear reflective vest for traffic, steel Damage caused by heavy  Verify clear pathway to stockpiling locations – STANTEC/Contractor.
equipment (if applicable) toed and shank shoes, long sleeve
shirt, hardhat, safety glasses with side
equipment while accessing
set-up location. Struck by  Visually inspect equipment – STANTEC/Contractor.
shields, and leather gloves as equipment. Noise hazards.  Maintain eye contact with operators, check all blind spots –
necessary. Wear hearing protection if STANTEC/Contractor.
 Utilize established hand signals – STANTEC/Contractor.
needed.
Commence turning/stirring of Wear reflective vest for traffic, steel Heat or cold exposure,  Monitor weather conditions and take breaks as needed for cold or hot
stockpiles. toed and shank shoes, long sleeve exposure to chemical weather – STANTEC/Contractor.
shirt, hardhat, safety glasses with side hazards, flammable or
shields, and leather gloves as
necessary. Wear hearing protection if
oxygen-deficient atmosphere
from accumulated vapor
 Initiate air quality monitoring as outlined in Section 12. (Include Lower
Explosive Limit (LEL) and oxygen monitoring. If >10% LEL, discontinue
needed. Wear appropriate air purifying pockets in soil stockpiles (if
work or ventilate area with explosion-proof equipment) –
respirator with combination organic any), trip and fall, equipment
STANTEC/Contractor.
vapor/P-100 cartridges as needed. failure, noise (if noisy
equipment/machinery being  Have appropriate respirator with combination organic vapor/P-100
used). cartridges within 3-5 feet of work area, readily available –
STANTEC/Contractor.
 Suppress odors and vapors by spraying with Simple Green Solution or
other appropriate vapor suppressant – STANTEC/Contractor.
 Keep work area clean minimizing slip, trip and fall hazards –
STANTEC/Contractor.
 Perform periodic visual inspections of equipment –
STANTEC/Contractor.
 Perform necessary soil classification – STANTEC/Contractor.
Collect samples in Wear reflective vest for traffic, steel Injury from heavy equipment.  Perform air quality monitoring as outlined in Section 12 - STANTEC.
accordance with sampling
plan.
shirts, hardhat, safety glasses with side
Exposure to site
contaminants.  Have appropriate respirator with combination organic vapor/P-100
shields, and leather gloves as cartridges within 3-5 feet of work area, readily available –
needed. Wear appropriate air purifying  Stand upwind to avoid exposure whenever possible –
respirator with combination organic STANTEC/Contractor.
 Use the organic vapor monitor aggressively to track the airborne
vapor/P-100 cartridges as needed.
Wear appropriate chemical resistant
gloves as needed. concentration of contaminants near and around stockpiles – STANTEC.
 Evaluate any soil samples inside a Ziploc bag at arm's length.
DO NOT
EVALUATE THE SAMPLE WITH THE BAG OPEN. THIS WILL AVOID
UNNECESSARY EXPOSURE – STANTEC/Contractor.
 Use proper lifting techniques and tools – STANTEC/Contractor.
 Avoid twisting back during the operation; Decontaminate sampling
equipment after use. Decontamination will be accomplished by an
Alconox wash with tap water rinse followed by a de-ionized or distilled
water rinse. Collect wash/rinse water in 5-gallon buckets and transfer to
55-gallon drums and stage drums in a location agreed upon by the
SHSO and the Property/Station Owner/Manager – STANTEC/Contractor.
Proper clean up and disposal Safety glasses. Leather Work Gloves. Exposure to broken glass and  Isolate area where broken glass is located - STANTEC/Contractor.
of broken sample container. Long Sleeve Shirt. Hand Broom and acid (from water preservation  Determine if the sample container was preserved (did it have
Dust Pan. A receptacle for the broken acids) preservative acid in it?) - STANTEC/Contractor.
glass (something to contain the broken Injury  Determine what to contain the broken glass in, and where to dispose of
glass (double garbage bag, a box, or the broken glass before beginning to pick up the glass -
bucket. STANTEC/Contractor.
 Collect equipment needed to clean up and contain the broken glass.
 Minimize “picking up” broken glass pieces with your gloved hands. Use
a dust pan if possible/practical - STANTEC/Contractor.
glass in cooler - STANTEC/Contractor.
Near Loss/Miss - STANTEC/Contractor.
Supervisor/SHSO must
Wear reflective vest for traffic, steel
Possible injuries and damage  Visually inspect each and every trench/excavation –
confirm all to property due to stepping STANTEC/Contractor.
trenches/excavations are into or driving over the
closed, filled in, barricaded
shirts, hardhat, safety glasses with side
excavations/trenches.  If trench/excavation is left open overnight, cover completely with trench-
shields, and leather gloves as plate or completely surround the trench/excavation with delineators and
and/or capped. Incident resulting from SSE
necessary. Wear hearing protection if construction fence – STANTEC/Contractor.
inexperience.
needed. Wear appropriate air purifying
respirator with combination organic
Personal injury due to  SSE’s mentor must be in direct supervision of the SSE at all times
improper PPE worn. to guide him/her throughout all tasks – STANTEC/Contractor.
vapor/P-100 cartridges as needed.
Wear appropriate chemical resistant
gloves as needed.
simultaneous operations.  Wear appropriate PPE – STANTEC/Contractor.
 Be aware of other tasks being performed on-site – STANTEC/Contractor.
 Perform individual tasks from beginning to completion when possible –
STANTEC/Contractor.
Perform personnel dry Chemical exposure.  Perform dry boot wash using a stiff bristle, fiberglass handled brush
decontamination procedures. paying special attention to the welt and sole areas of the boot. Remove
tape from boot tops and properly dispose of the tape, remove tape from
outer gloves and properly dispose of the tape, remove outer gloves and
properly dispose of outer gloves, remove Tyvek and properly dispose of
Tyvek, , remove boots and place in large garbage bag, remove inner
gloves and properly dispose of inner gloves. Put street shoes on. Wash
hands, face arms and neck (any exposed skin) (use baby wipes if a
washing facility is unavailable) Decontamination water will be stored in
55 gallon drums - STANTEC.

STANTEC.
 Use extreme care when opening the bung caps. Stand an arms
length away and open the bung slowly to relieve any built up
pressure - STANTEC.
Clean site/demobilize. Wear reflective vest for traffic, steel Traffic. Safety hazards left on  Use buddy system as necessary to remove traffic guidance and control
Replace caution tape/traffic toed and shank shoes, long sleeve site. Lifting hazards. equipment - STANTEC/Contractor.
control for stockpiles (if
applicable).
shirt, hardhat, safety glasses with side
shields, and leather gloves as  Leave site clean of any refuse and debris other than the stockpiles -
needed.  Notify nearby personnel of departure (if applicable) -
STANTEC/Contractor.
STANTEC/Contractor.
to lab. strain. STANTEC.
 Use proper lifting techniques - STANTEC.
Attachment 5
Permit To Work, Daily Tailgate Meeting

& Job Hazard Assessment
(Forms in field binder)

Attachment 6
Site Health and Safety Quiz

Health & Safety Quiz
Name: Company: Date:
1. True or False: Stantec’s policy is to complete our work on this site without any type of
incident (injury, illness, impact to the environment, impact to property and equipment).
2. Who has Stop Work Authority?
At the site, where is the nearest telephone located?
In the event of site evacuation, where is the emergency meeting location?
In the event of an incident, who should be contacted after work has been stopped and the SHSO
has been notified?
List a constituent of potential concern at the site.
If air monitoring is required, what chemical(s) are being monitored and what are the action
levels?
How many times per day should safety meetings be conducted?
True or False: Eating, drinking, smoking, and use of PDAs, cell phones, pagers, and other
electrical devices (with the exception of intrinsically safe devices) are prohibited within the
exclusion zone.
What minimum PPE is required at the site?
Score:
(If score is less than 100%, SHSO should discuss correct answer with quiz-taker.)
Attachment 7
Journey Management Plan

Attachment 8
Equipment Calibration &

Air Monitoring Logs

Attachment 9
Safety Data Sheets
(Safety Data Sheets in field binder)

Attachment 10
Subcontractor HASP and JSAs
(Pending)

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Site-Specific Health and

Safety Plan for Earthwork,

Corner of Central Avenue

Regency Centers, L.P.

Stantec Consulting Services Inc.

9400 SW Barnes Road, Suite 200

October 13, 2015

Purpose and Approval

Emily Harper___________ Signature: Date:

Acknowledgement and Agreement Form

(All Stantec and subcontractor personnel must sign.)

2.0 SCOPE OF WORK......................................................................................................... 11

3.0 SITE BACKGROUND AND CHEMICAL HAZARDS ........................................................ 12

5.0 OTHER SITE HAZARDS .................................................................................................. 19

6.0 SITE CONTROL AND SAFETY PROCEDURES ................................................................. 25

7.0 WASTE MANAGEMENT ................................................................................................ 31

8.0 PROJECT TEAM INFORMATION ................................................................................... 32

Attachment 1 Stantec Field Safety Reference Binder Checklist

1.0 Emergency Response

1.1 PHONE NUMBERS

Cell Phone carried by the Stantec SHSO – Robert McAlister (714)686-4435

Name Telephone Verification

Agency / Line Locator

Drilling Contractor Stratus Corporation (503) 985-7912 RM 8/21/15

Project Team Phone Numbers

Name Telephone Verification

1.2 DIRECTIONS AND MAP TO THE HOSPITAL

1.3 DIRECTIONS AND MAP TO OCCUPATIONAL CLINIC

1.4 EMERGENCY RESPONSE PROCEDURES: EVACUATION

 Stop Work and notify the SHSO.

1.5 EMERGENCY RESPONSE PROCEDURES: INJURY OR ILLNESS

If an injury or illness occurs, take the following action:

 Stop Work, stabilize the situation, and secure the site.

1.5.1 Injuries or Illnesses Requiring Hospital Service WITHOUT Ambulance

o Date he/she is to return to doctor for follow-up appointment, if necessary

1.5.2 Injuries or Illnesses Requiring Hospital Service WITH Ambulance Service

 Call for ambulance service and notify the SHSO.

1.5.3 Death of an Individual or Hospitalization of Three or More Employees

1.6 EMERGENCY RESPONSE PROCEDURES: SPILLS OR CUT LINES

In the event of a spill/release, follow this plan:

 Stop Work, stabilize the situation, and secure the site.

1.7 INCIDENT REPORTING PROCEDURES

INSTRUCTION GUIDE FOR INTERNAL INCIDENT REPORTING

In the event of an incident:

Stop Work, stabilize situation,

If you are unsure

Stantec PM makes verbal notification

Incident Reportable to Incident Not

Stantec HSE Team Notification Phone Numbers:

Stantec’s Practice and Risk Management Group

2.0 Scope of Work

The scope of this project is to:

1. Drive to/from Job Site; and

Site Background and Chemical Hazards

3.0 Site Background and Chemical Hazards

Site Background and Chemical Hazards

Constituents of Potential Concern and Maximum Concentrations

Potential Airborne Concerns and Air Monitoring Action Levels

4.0 Potential Airborne Concerns and Air Monitoring Action Levels

POTENTIAL AIRBORNE CHEMICALS ONSITE IN THIS PROJECT

FedOSHA PEL NIOSH REL Yellowish to Inhalation, Nausea, eye Kidneys,

Potential Airborne Concerns and Air Monitoring Action Levels

POTENTIAL AIRBORNE CHEMICALS ONSITE IN THIS PROJECT

Cal/FedOSHA CalOSHA & Characteristi Inhalation, Skin (dermatitis), Carcinogen,

Principle 1 - > ZƐŽŶůǇĂƩ ĂĐŚƚŽƉƌŽŚŝďŝƚĞĚŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞ;ŽƌŚĂǌĂƌĚŽƵƐĐŽŶƚĂŵ ŝŶĂƚĞĚsoils) when it is: (1)

Principle 3 - K ŶĐĞ> ZƐĂƩ ĂĐŚƚŽĂŶǇŐŝǀĞŶŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞŽƌǀŽůƵŵ ĞŽĨŚĂǌĂƌĚŽƵƐĐŽŶƚĂŵ ŝŶĂƚĞĚsoils, the

ĞƚĞƌŵ ŝŶŝŶŐt ŚĞƚŚĞƌŽŶƚĂŵ ŝŶĂƟŽŶŝƐĂƵƐĞĚďǇĂZZŚĂƌĂĐƚĞƌŝƐƟĐŽƌ>ŝƐƚĞĚt ĂƐƚĞ

dŚĞƌĞŐƵůĂƟŽŶƐĂĚĚƌĞƐƐŝŶŐƚŚĞĂƉƉůŝĐĂƟŽŶŽĨ> ZƐƚŽsoils exhibiting ĂĐŚĂƌĂĐƚĞƌŝƐƟĐŽĨ

ŽŶƐƟƚƵĞŶƚƐ^ƵďũĞĐƚƚŽdƌĞĂƚŵ ĞŶƚh ƐŝŶŐƚŚĞůƚĞƌŶĂƟǀĞSoil Treatment Standards

/ŶĂĚĚŝƟŽŶƚŽƚƌĞĂƚŵ ĞŶƚŽĨĂůůh , Ɛ reasonably expected to be present in the soils at

WĂŶƟĐŝƉĂƚĞƐƚŚĂƚĚĞĐŝƐŝŽŶƐabout site-speciﬁc minimize threat variances ǁ ŝůůŽŌ ĞŶďĞ

dŚĞƌĞĂĚĞƌŝƐƌĞĨĞƌƌĞĚƚŽƩ ĂĐŚŵ ĞŶƚŽĨƚŚŝƐĨĂĐƚƐŚĞĞƚĨŽƌŐĞŶĞƌĂůŝŶĨŽƌŵ ĂƟŽŶŽŶƚŚĞZZ> Z

-- If dioxin-contaminated soils ĚŽŶŽƚĞǆŚŝďŝƚĂŚĂǌĂƌĚŽƵƐǁ ĂƐƚĞĐŚĂƌĂĐƚĞƌŝƐƟĐ͕> ZƐĚŽŶŽƚĂƉƉůǇ͘

ĐŽŶƐƟƚƵĞŶƚƐƌĞƋƵŝƌŝŶŐƚƌĞĂƚŵ ĞŶƚƉƌŝŽƌƚŽůĂŶĚĚŝƐƉŽƐĂůƵŶĚĞƌƚŚĞ> ZƉƌŽŐƌĂŵ ;^ĞĞƩ ĂĐŚŵ ĞŶƚB). If the

Principle 3 - K ŶĐĞ> ZƐĂƩ ĂĐŚƚŽĂŶǇĚŝŽǆŝŶ-contaminated soils͕> ZƚƌĞĂƚŵ ĞŶƚƐƚĂŶĚĂƌĚƐĐŽŶƟŶƵĞƚŽĂƉƉůǇ

dŚĞ ŝŽǆŝŶ>ŝƐƟŶŐZƵůĞǁ ĂƐƉƌŽŵ ƵůŐĂƚĞĚŽŶ:ĂŶƵĂƌǇϭϰ͕ϭϵϴϱ;ϱϬ&ZϭϵϴϳͿ͘dŚŝƐƌĞŐƵůĂƟŽŶ

In many cases, the contaminated soils ǁ ŝůůďĞƐĞŶƚƚŽĂ^ƵďƟƚůĞ ůĂŶĚĮůů͖ŚŽǁ ĞǀĞƌ͕ƚŚĞƌĞ

EXAMPLE 3 - ' ĞŶĞƌĂƚŽƌŝƐĞǆĐĂǀĂƟŶŐsoils ĐŽŶƚĂŵ ŝŶĂƚĞĚǁ ŝƚŚ&ϬϮϰ͘&ϬϮϰǁ ĂƐůĂŶĚĚŝƐƉŽƐĞĚĂŌ Ğƌϭϵϵϭ͕ĂŌ Ğƌ

EPA , ĂǌĂƌĚŽƵƐt ĂƐƚĞ ĞƐĐƌŝƉƟŽŶ

ƌĞŐƵůĂƚĞĚĐŽŶƐƟƚƵĞŶƚƐƌĞƋƵŝƌŝŶŐƚƌĞĂƚŵ ĞŶƚƉƌŝŽƌƚŽůĂŶĚĚŝƐƉŽƐĂůƵŶĚĞƌƚŚĞ> ZƉƌŽŐƌĂŵ