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HGI Soil Remediation Section Oct09 Site Remediation Hilton Garden Project Northampton MA 1HILTON GARDEN INN SITE Lot, Northampton, Massachusetts DEP Site #1-14222 Site History The Site was initially developed around 1855, with the construction of the New Haven and Northampton Railroad and the Northampton Gas Light Company manufactured gas plant (MGP). Much of the Site was used for the manufacturing, storage, and distribution of coal gas. Gas production was discontinued in 1951. Most of the gas manufacturing structures formerly present on the property were demolished in 1962. The property and remaining structures were donated to the City in 1973. Past development has significantly affected subsurface conditions at the Site. It was formerly occupied by a coal gasification plant which was first constructed in the mid 19th century and demolished in approximately 1960. Approximately 10 feet of fill are present across the Site as a result of this operation and Site soils and groundwater have been impacted with Manufactured Gas Plant (MGP) waste. In addition, the Mill River formerly flowed through the southern pan of the Site. The river channel was also filled in the past. Environmental assessments have been conducted at the site since 2001 in accordance with the requirements of the Massachusetts Contingency Plan (MCP). The Phase II Comprehensive Site Assessment resulted in a detailed conceptual site model for the Disposal Site. Some MGP impacted material, including ash, coal, and clinkers, was likely used as fill material within the footprint of the former facility or was graded and re-worked around the facility. Tar and oily MGP residuals also were likely released from containers or through foundations into the subsurface. The oily MGP residuals, being denser than water, migrated downward through the heterogeneous subsurface fill and glacio-fluvial sand and gravel underlying the facility. Clay and other fine-grained, impermeable soil are present below the sand and gravel at depths ranging from 10 to 35 feet below ground surface. Where the dense oil encountered these fine grained clay or fine-grained soils, it either accumulated at that location or migrated laterally along the upper surface of the clay/soils. Some MGP constituents have dissolved in groundwater and have migrated advectively with the natural groundwater flow. Reason for Activity and Use Limitation To limit future potential exposures a Method 3 risk characterization was completed to evaluate potential risks associated with the MGP-related compounds in the subsurface fill, soil, and groundwater. There are no risks of harm to human health posed by the MGP residuals that are present at the disposal site under current activities and uses, because humans are not able to contact the MGP residuals in their present location under present activities and uses. However, results of the risk characterization indicate a condition of No Significant Risk of harm to human health, public welfare and the environment does not exist at the Site under reasonably foreseeable future conditions. The remediation work will limit future potential exposures to MGP residuals that are present within 15 feet of the ground surface. In the remainder of the Property no MGP residuals were observed within 15 feet of the ground surface. There are polynuclear aromatic hydrocarbons present in fills and soils at depths less than 15 feet below ground surface in the remainder of the Property but these compounds appear to be related to the former use of this area by the railroad. Site Remediation Hilton Garden Project Northampton MA 2Permitted Activities and Uses (1) Use or development of the Site as an industrial, commercial, or retail property, or use or development of the Site for vehicular parking, vehicular traffic, bicycle path, pedestrian, or other activities and uses which would not compromise the structural integrity of any existing or any replacement surface barrier (e.g. the current pavement, current buildings, and/or a “barrier” as defined in Paragraph 1 ((ii) below) and/or allow direct contact with soil beneath that barrier; (2) Use of the Portion of the Property as a residence, hotel, school, daycare, nursery, playground, recreational area, etc. where a child is likely to be present, provided that access to subsurface soils is prevented through the use of a barrier to direct contact on the Portion of the Property. This barrier would consist of either an impermeable barrier such as a building above a vapor barrier and at least one (1) foot of unimpacted clean soil, or a a permeable barrier consisting of a minimum of three (3) feet of unimpacted clean fill above a geotextile marker layer in concrete, paved, playground or landscaped areas; (3) Excavation and/or removal of soils within three feet of ground surface or within one foot of the bottom and two feet of each side of subsurface utilities associated with maintenance or repair of these subsurface utilities, provided that the excavation is backfilled with an equal thickness of unimpacted soils. (4) Excavation and/or removal of potentially contaminated subsurface soils (greater than three [3] feet below ground surface and/or below geotextile marker layer) or pavement and associated handling and processing (e.g. size reduction, etc.) associated with limited short-term (three months or less) construction work, provided that it is conducted in accordance with the performance standards of the MCP. Potentially contaminated soils are located immediately beneath a vapor barrier and an at least one (1) foot thick layer of clean soil under new buildings or beneath an at least three (3) foot thick layer of unimpacted soil under concrete, paved and landscaped areas. Such activities must be conducted in accordance with the performance standards set forth by the MCP and conducted under the direction of an LSP. Excavation activities must be conducted in accordance with the Soil Management Procedures pursuant to 310 CMR 40.0030, and/or all applicable worker health and safety practices pursuant to 310 CMR 40.0018, and must ensure prompt repair/replacement of the pavement with a comparable barrier immediately following the completion of the project; (5) Maintenance activities related to the repair, resurfacing and/or replacement of buildings, pavement, parking lots, sidewalks, bicycle paths, and driveways, provided that such activities do not result in contact with potentially contaminated soils. Potentially contaminated soils are located beneath a vapor barrier and an at least one (1) foot thick layer of clean soil under new buildings, and beneath an at least three (3) foot thick layer of clean soil above a geotextile marker layer under concrete, paved and landscaped areas. Maintenance activities are allowed provided they do not extend below these depths or compromise contaminated soil located beneath these depths and provided that the barrier (see Paragraph 1 (ii)) is replaced; Site Remediation Hilton Garden Project Northampton MA 3 (6) Landscape activities, including lawn mowing, mulching, and/or planting of flowers and shrubs that do not result in disturbance or direct contact with existing potentially contaminated soil that is located at a depth of over three (3) feet below the ground surface beneath a geotextile marker layer, and provided that the barrier is replaced; (7) Activities and uses which are not identified by this Notice as being inconsistent with maintaining a condition of No Significant Risk; and (8) Such other activities and uses which, in the Opinion of an LSP, shall present no greater risk of harm to health, safety, public welfare, or the environment than the activities and uses set forth in this paragraph. Obligations and Conditions Set Forth for Permitted Use (1) A Soil Management Plan must be prepared and implemented prior to the commencement of any activity that will disturb the contaminated soil located beneath barriers or buildings in the Portion of the Property. The Soil Management Plan must be prepared in accordance with jurisdictional guidelines and regulations. Workers who may come in contact with the soil must be informed of the requirements of the Soil Management Plan; (2) A Health and Safety Plan must be prepared and implemented in accordance with the jurisdictional guidelines and requirements prior to the commencement of any activity which involves the removal and/or disturbance of the barriers or buildings and/or will disturb the underlying contaminated soil within the Portion of the Property; (3) The surface barriers or buildings within the Portion of the Property must be reasonably maintained, repaired and/or replaced with a comparable barrier to prevent future exposures to underlying contaminated soil immediately following the completion of any activity which involves its removal and/or disturbance; (4) The pavement, other surface barriers, or buildings must be maintained within the Portion of the Property to ensure that the contaminated soil located beneath the surface barriers or buildings remains inaccessible; (5) Specifications for buildings to be constructed or substantially modified at the Portion of the Property must include a vapor barrier or must be compared to the assumptions of the vapor intrusion model and risk characterization used to support the Response Action Outcome for the site and re-evaluated by an LSP who must render an Opinion as to whether site conditions, activities, and/or uses associated with the future building potentially pose a significant risk of harm to human health; and (6) Response actions must be conducted in accordance with the Massachusetts Contingency Plan, 310 CMR 40.0000, should an LSP Opinion rendered pursuant to Obligation (i) conclude that future uses and activities at the Portion of the Property, including exposures associated with future building construction, are inconsistent with maintaining a condition of No Significant Risk. Site Remediation Hilton Garden Project Northampton MA 4THE PROJECT The project address is 260 Main Street Northampton MA and consist of a new 76’ ft high 80,000 sf 6-Story limited service HOTEL building that consists of 112 guestrooms. The hotel building will sit in the northern pan of the Site and will have a footprint of approximately14,000 square foot. Structural loads arc calculated to be in the range of 100 kips to 480 kips. This is a Hilton Garden Inn franchised hotel that provides an atmosphere with a strong business orientation and includes practical amenities and services such as a restaurant, lounge, meeting rooms, business center, pool, exercise room and extended lobby area. Typical room amenities consist of work desk, high speed internet, hospitality center, sitting area, flat screen TV and electronic security locks. The building is conventional steel framed structure with concrete on metal deck, masonry façade and punch windows. There is a single corridor mezzanine guest room level on the South South side of the building. The building will be supported by a pile foundation system with pile caps integrated into the reinforced concrete slab. Finished floor of the lower level slab is elevation at (127). Relocation as well as new water, sewer, sanitary, electrical, gas and telephone lines in ductbanks will be part of the project construction. Most of this work will occur in the area commonly known as the Roundhouse parking lot. It is anticipated that impacted soils will be encountered during this operation of the project. SOIL CONDITIONS The majority of the Site is paved with approximately 3 inches of asphalt. In general, five subsurface units were detected, a non-engineered (urban) fill, fine grained post glacial lake deposits, glacial outwash (sand and gravel) and Glacial Till. Each of these units will affect the proposed construction differently. A geotechnical study was conducted that consisted of four soil borings performed for this site. The borings were performed using a truck mounted drill rig rig using casing and drive and wash (rotary) drilling techniques. The borings were advanced to depths between 27 and 44 feet below ground surface. In general, soil samples were collected every five feet beginning at the ground surface, using the Standard Penetration Test (SPT), The SPT is performed by driving a 2-inch outside diameter split-spoon sampler 24 inches into the soil using a 140 pound hammer free falling 30 inches (American Society for Testing and Materials Test Method D1586-99 "Standard Test Method for Penetration Test and Split-Barrel Sampling of Soils"). The number of blows required to advance the split-spoon each 6-inch interval is recorded. The total blows required to drive the sampler the middle 12 inches of the 24-inch drive is the standard penetration resistance or N value. Cuttings with positive photo ionization detector (PID) readings and coal tar odors were drummed and staged on-site. The borings were tremie-grouted to the surface upon completion. The site does contain the presence of non-engineered fill. The fill unit was encountered at ground surface in each of the borings. It consisted of a variable, loose to very dense mixture of sand, silt, and gravel, with some trace amounts of brick, concrete, wood, coal, glass and ash. The fill was observed to extend to depths of between 15 and 25 feet below ground surface in borings HI I-I through 1-U-J.4. The fill extended to a depth of approximately II feet below ground surface in boring WC-31. Site Remediation Hilton Garden Project Northampton MA 5In addition to the fill found, the Site also contains the presence of fine grained post glacial lake deposits. These fine grained soils include varied soils, which are characterized by alternating layers (or varves) of silt and day, or clay with little trace amounts of silt. These soils arc soft and will be compressible under building or fill loads. These soils were encountered beneath the fill layer in borings HH-4 and WC-31 at an approximate depth of 12 feet below ground surface. The fine grained layers extended to approximately 25 feet below ground surface in borings HH-4 and WC-31. SITE REMEDIATION PLAN The following sections describe the remediation plan to be implemented at the site with the intent of achieving compliance with all jurisdictional agencies and project agreements. Areas of Remedial Activity It is the intent of this plan to address the areas that will be disturbed by the construction operation on the entire site but within its property boundaries. Approach to Soil Remediation The approach for site remediation includes the removal of contaminated soil from the surface and the placement of an impermeable barrier below a layer of clean backfill. Specifically, the tasks are as follows: A.􀒏 Site preparation activities B.􀒏 Excavation of surface soil C.􀒏 Post excavation sample collection and analyses D.􀒏 Stockpiling and testing excavated soil E.􀒏 Installation of impermeable barrier F􀒏 Backfill and Site restoration Site preparation activities Due to the extent of the underground utility work the first step to implementing the activities will be to coordinate closure of the existing parking area with City Officials. Concurrently, work to secure the required state and local permits. There will need to be coordination between the developer, the developer’s general contractor, Bay State Gas, Bay State Gas consultants, the various City Departments (Parking, Planning, Building Inspector, DPW, Police, Fire, etc.), the tenants of the Roundhouse and other adjacent buildings, as well as the general public. Prior to the start of work, a temporary, 6-foot high chain link fence will be installed around the perimeter of the site. A vehicle gate and personnel gate will be installed on the eastern side of the fencing to allow access to the work zone by authorized personnel. The gate will be locked at the end of each day to prevent unauthorized people from entering the work zone. Temporary erosion and sedimentation controls will be installed as required by the Drawings and Specifications to prevent off-site migration of the on-site construction activities. Site preparation will include the establishment of site controls using hay bales around the perimeter, as required, for prevention of soil erosion and temporary fencing for security and safety. It is anticipated these will be installed on top of the existing sidewalk at Pulaski Park and around the site to prevent unwanted access to soil. A soil loading and equipment decontamination area will be established to prevent cross contamination of the adjacent road surfaces. The loading area will be located on the adjacent paved municipal parking lot. The hay bales and security fencing noted above will enclose the work area. For control of traffic, it is anticipated that flagman will be provided during periods of high activity. As part of site Site Remediation Hilton Garden Project Northampton MA 6preparation, any existing clean layers will be stockpiled for reuse. The excavation of the clean layer will be completed in a cautious manner to prevent cross contamination from underlying soils. Any visible evidence of cross contamination will be addressed by handling the material as contaminated soil. The clean material will be stockpiled on-site in the predetermined designated areas within the fenced in site on the municipal parking lot. A Licensed Site Professional (LSP) will be on site throughout the duration of the excavation activities. An LSP is an experienced professional in the field of hazardous waste site assessment, cleanup and removal. An LSP must have at least 5 years experience conducting and overseeing assessments, removals or cleanups of sites (7 years without an appropriate degree), suitable technical background and good moral character. An LSP issues Waste Site Cleanup Activity Opinions describing whether contamination is present at a site, what work is needed to clean up any contamination found and whether that work has been completed. These opinions are based on field assessment, sampling and careful study of the site. The law requires that an LSP sign and stamp the Waste Site Cleanup Activity Opinions filed with DEP. An LSP will need to review, evaluate or observe activities that occur prior to filing these documents. Therefore, all private parties who perform assessment, containment or removal activities must retain LSPs to demonstrate that the work complies with the state waste site cleanup law and regulations. Excavation of surface soil The excavation of soil is limited by the following site conditions: 􀀀􀒏Building footprint and property lines on-site 􀀀􀒏􀀨􀁛􀁌􀁖􀁗􀁌􀁑􀁊􀀃and New utilities, including natural gas lines that cross the site 􀀀􀒏􀀨􀁛􀁌􀁖􀁗􀁌􀁑􀁊􀀃parking Lot It is anticipated that the upper 2 feet of soil can be removed safely at the building footprint. It is anticipated that approximately 6100 CY of soil will be excavated on site for the project activities. The estimated volume of soil is based on the area of the building pad, excavation of the North face of the building and the utility ductbanks. To avoid truck travel over the contaminated soil, bulldozers may be used to strip the soil and pile it near the loading pad, where loaders or excavators will be used to remove the soil and place it into dump trucks for transportation to the appropriate and designated soil stockpile area. All vehicles leaving the site during soil excavation will be decontaminated (loose soil removed). To prevent tracking of mud, excavation will not occur during heavy rain events. Post excavation sample collection and analysis Samples of the remaining soils will be collected (post-excavation) at the excavation surface to obtain data to develop plans for future soil management and health and safety considerations (construction services or utility repair work). Three (3) composite soil samples will be collected and analyzed for (ETPH, PAHs, and metals). Stockpiling and testing excavated soil A soil stockpile area will be pre-determined on site for the placement and sampling of the excavated soil. This area will be prepared by placing polyethylene sheeting on the ground surface within a haybale perimeter. Soil will be stockpiled on top of the sheeting and covered with a weather proof tarp, secured with sand bags. Each stockpile will be approximately 300 cubic yards in size for identification and reuse characterization purposes. Samples will be Site Remediation Hilton Garden Project Northampton MA 7collected from the stockpiles and analyzed for contaminants, including additional analyses required for off-site disposal. Planned Utility Corridors Bay State will coordinate with the Northampton DPW to develop a utility relocation and installation strategy that achieves the required construction needs but also is intended to meet the longer term needs of the proposed development project. To the extent feasible, existing utilities will be removed or abandoned and new utilities placed into the proposed clean utility corridor(s) to prevent potential exposure of utility workers to MGP residuals in the future. Due to their depth and the complications associated with trying to move these lines, the sewer and drain lines that are greater than eight feet will be closed in place. Whenever possible, the new utilities will be installed first and connections will be made at a date when the entire service can be transferred, to limit the length of service interruption. As needed, temporary utility lines will be used to maintain service. Portions of the existing parking lot lighting, pavement, curbing, landscaped areas and parking meters will be decommissioned to accommodate the excavation activities. o the extent possible, lighting fixtures and meters will be removed, protected and re-used. After the MGP impacted soils are removed, clean fill will be brought on-site to return original site grades and match existing surface finishes and will be coordinated with the timing and design of the proposed development. Installation of impermeable barrier Upon excavation of the upper 2 feet of existing soil, the surface will be graded and prepared for the installation of the designed and specified vapor barrier geomembrane secured to building foundation system. As part of construction quality control for the liner, testing will be required to demonstrate the liner’s placement. Heavy equipment will not be allowed on the liner. In addition, the liner manufacturer’s quality control results will be required for submission prior to use of the materials at the site. Details of the liner installation quality requirements will be included in the project specifications. SITE CHAIN OF COMMAND AND CONTROL Bay State Gas Engineer/Representative will coordinate on a regular basis with the site staff of the contractor and Licensed Site Professional (LSP). The LSP as well as the BSG Engineer /Representative will provide remediation oversight and will have authority to make judgments regarding site and worker safety, make corrective actions to improve conditions, and if corrective measures do not ameliorate conditions, to stop work until such time as needed engineering controls or other measures are designed and implemented. If, for any reason, efforts being employed to control dust and/or odors are unsuccessful, the following response actions will be implemented in the specified order: 1. Engineer will notify the Remediation Contractor and the specific response action activities causing the dust or odor problem will be halted. 2. Engineer will immediately notify the Bay State Gas team, including Bay State Gas environmental staff, Bay State Gas’s Community Relations team, and the LSP. 3. Contractors will modify or implement additional control measures as necessary, or suspend work until surrounding site conditions improve sufficiently to resume remediation/construction operations within acceptable parameters. 4. Engineer will re-assess site conditions and direct contractor appropriately. Engineer will document all conditions encountered and the corrective actions taken. 5. If additional measures including various engineering controls do not address conditions Site Remediation Hilton Garden Project Northampton MA 8adequately to maintain conditions below action levels, the Engineer will stop work and propose substantial modifications to Owner, the LSP, and MassDEP. Project Chain of Command The sequence of work to be performed on-site will be designed to limit impacts to the public and the environment. The Contractor will be required to perform all work in accordance with the Construction Drawings, Specifications and Health & Safety Plan. In addition, the Contractor will be required to implement good housekeeping work practices at all times. The following measures will also be performed to prevent or limit impacts to the public and the environment: 􀀀 Routine air monitoring both for constituents in air and for odors will be conducted in the work zone and along the perimeter of the property to confirm that concentrations of airborne contaminants do not exceed the allowable ambient limits set in the Health and Safety Plan and that nuisance odors do not create concerns. 􀀀 All excavations involving odorous materials will be minimized and odor suppressant foam and/or other cover materials will be used to further minimize odor generation. 􀀀 Once excavation activities are complete, the Site will be either restored to original condition or to the condition required for subsequent construction of the hotel, garage and/or their associated infrastructure. 􀀀 Erosion controls will be set up down gradient of the work areas to prevent material migration off-Site. 􀀀 All personnel and equipment that enters the ‘hot’ work zone will be required to pass through the decon station to prevent spreading of material into ‘clean’ zones. SITE MANAGEMENT Health and Safety Prior to initiating field activities, a Health and Safety Plan (HASP) will be prepared to meet the requirements of 29 CFR 1910.120. All work will be conducted in accordance with the HASP. It is assumed that modified Level D personal protection will be sufficient for all field work. The objective of the HASP will be as follows: 􀀀􀒏􀀷􀁒􀀃􀁓􀁕􀁒􀁗� �􀁆􀁗􀀃􀁗􀁋􀁈􀀃􀁋􀁈􀁄􀁏􀁗􀁋􀀃􀁄􀁑􀁇􀀃􀁖􀁄􀁉􀁈􀁗􀁜􀀃􀁒􀁉􀀃􀁒􀁑-site personnel. 􀀀􀒏􀀷􀁒􀀃􀁏􀁌􀁐􀁌􀁗􀀃􀁈􀁛􀁓􀁒􀁖􀁘􀁕􀁈􀀃􀁒􀁉􀀃􀁗􀁋􀁈􀀃􀁓􀁘􀁅􀁏􀁌􀁆􀀃􀁗􀁒􀀃􀁋􀁄􀁝􀁄􀁕􀁇􀁒􀁘􀁖􀀃􀁖􀁘􀁅􀁖􀁗􀁄􀁑􀁆􀁈􀁖􀀏􀀃􀁓� �􀁏􀁏􀁘􀁗􀁄􀁑􀁗􀁖􀀏􀀃􀁒􀁕􀀃􀁆􀁒􀁑􀁗􀁄􀁐􀁌􀁑􀁄􀁑􀁗􀁖􀀑 The HASP will include the following: 􀀀􀒏􀀥􀁕􀁌􀁈􀁉􀀃􀀶􀁌􀁗􀁈􀀃􀀧􀁈􀁖􀁆􀁕􀁌􀁓􀁗􀁌􀁒􀁑 􀀀􀒏􀀶􀁌􀁗􀁈􀀃􀀶􀁄􀁉􀁈􀁗􀁜􀀃􀀫􀁄􀁝􀁄􀁕􀁇􀁖 􀀀􀒏􀀦􀁋􀁈􀁐􀁌􀁆􀁄􀁏􀀃􀀦􀁒􀁐􀁓􀁒􀁘􀁑􀁇􀁖􀀃􀁒􀁉􀀃􀀦􀁒􀁑cern 􀀀􀒏􀀳􀁕􀁒􀁍􀁈􀁆􀁗􀀃􀀳􀁈􀁕􀁖􀁒􀁑􀁑􀁈􀁏 􀀀􀒏􀀶􀁌􀁗􀁈􀀃􀀷􀁕􀁄􀁌􀁑􀁌􀁑􀁊􀀒􀀰􀁈􀁇􀁌􀁆􀁄􀁏􀀃􀀶􀁘􀁕􀁙􀁈􀁌􀁏􀁏􀁄􀁑􀁆􀁈􀀃􀀵􀁈􀁔􀁘􀁌􀁕􀁈􀁐􀁈􀁑􀁗􀁖 􀀀􀒏􀀳􀁈􀁕􀁖􀁒􀁑􀁑􀁈􀁏􀀃􀀳􀁕􀁒􀁗􀁈􀁆􀁗􀁌􀁙􀁈􀀃􀀨􀁔􀁘􀁌􀁓􀁐􀁈􀁑􀁗􀀃􀀋􀀳􀀳􀀨􀀌􀀃􀀵􀁈􀁔􀁘􀁌􀁕􀁈􀁐􀁈􀁑􀁗􀁖 􀀀􀒏􀀤􀁌􀁕􀀃􀀰􀁒􀁑􀁌􀁗􀁒􀁕􀁌􀁑􀁊􀀃􀀵􀁈􀁔􀁘􀁌􀁕􀁈􀁐􀁈􀁑􀁗􀁖 􀀀􀒏􀀧􀁈􀁆􀁒􀁑􀁗􀁄􀁐􀁌􀁑􀁄􀁗􀁌􀁒􀁑􀀃� �􀁕􀁒􀁆􀁈􀁇􀁘􀁕􀁈􀁖 􀀀􀒏􀀺􀁒􀁕􀁎􀀃􀀽􀁒􀁑􀁈􀁖 􀀀􀒏􀀬􀁑􀁙􀁈􀁖􀁗􀁌􀁊􀁄􀁗􀁌􀁒􀁑􀀃􀀧􀁈􀁕􀁌􀁙􀁈􀁇􀀃􀀺􀁄􀁖􀁗􀁈􀀃􀀧􀁌􀁖􀁓􀁒􀁖􀁄􀁏􀀒􀀫􀁄􀁑􀁇􀁏􀁌􀁑􀁊 􀀀􀒏􀀨􀁐􀁈􀁕􀁊􀁈􀁑cy Response 􀀀􀒏􀀶􀁓􀁈􀁆􀁌􀁄􀁏􀀃􀀲􀁓􀁈􀁕� �􀁗􀁌􀁒􀁑􀁖􀀃􀀶􀁄􀁉􀁈􀁗􀁜􀀃􀀵􀁈􀁔􀁘􀁌􀁕􀁈􀁐􀁈􀁑􀁗􀁖 􀀀􀒏􀀨􀁐􀁈􀁕􀁊􀁈􀁑􀁆􀁜􀀃􀀵􀁈􀁖􀁒􀁘􀁕􀁆􀁈􀁖 􀀀􀒏􀀪􀁈􀁑􀁈􀁕􀁌􀁆􀀃􀀩􀁌􀁕􀁖􀁗􀀃􀀤􀁌􀁇 Permits and Approvals Site Remediation Hilton Garden Project Northampton MA 9All required jurisdictional permits or approvals will be obtained for the work. A dig safe number will be obtained prior to the start of work. Waste Management Soil to be disposed of off-site will be staged at a designated stockpile location until characterization and disposal facility approval/acceptance is complete. Soil will be staged in 300-cubic yard stockpiles and sampled for disposal or reuse characterization. All soil will be covered with weather proof tarps and secured with sand bags and haybales. When, and if applicable, suitable material will be re-used on site at the direction and approval of the LSP. Suitable reuse locations may be at the proposed building North face or as clean fill used for final grading of the site. If the material is unsuitable for reuse, it will be disposed of at an appropriately permitted facility. Solid materials (such as anti-tracking apron material, plastic sheeting, hay bales, personal protective equipment, etc.) generated during the remediation will be segregated. If solid materials come into contact with contaminated materials, the solid materials will be disposed of along with the contaminated materials. If the solid materials do not come into contact with contaminated materials, they will be disposed of as municipal waste. Waste removal from the site will be documented by manifest or bill of lading. The LSP will be named as generator and representative of the project and will sign waste profile forms and manifests as such. The disposal documentation will be included in the Remedial Action Report by the LSP. Sedimentation and Erosion Control Prior to the excavation of contaminated soils, an erosion and sedimentation control system (hay bales and/or silt fence) will be installed around the site. To prevent off-site migration of materials, all equipment will be decontaminated prior to leaving the site and work will not be done during heavy precipitation events. It should also be noted that during the remediation and and placement of the impermeable barrier, the site will be approximately 2 feet below surrounding grades; therefore, there is a very low possibility of erosion from the site to the surrounding land surface. Dust Control To minimize the potential for the contaminants at the site to be released in particulate form during site activities, dust control measures will be implemented if dust is observed during remedial activities. The dust control measures will include the use of water to pre-wet soil that will be excavated. Water will also be sprayed, where necessary, onto active work areas and other areas of the site that may be subject to the release of dust. Air monitoring procedures will be conducted to monitor the total dust and particulate emissions at the site during remedial activities. Air Monitoring Throughout the project activities, air monitoring will be performed in conjunction with project health and safety requirements. Air monitoring will be conducted in excavation areas using a digital dust meter meter to assess for particulates and with a photoionization detector (PID) to assess for vapors. Air monitoring will be performed in the breathing zone of the work area at the following minimum frequencies: at the start of work each day, at the beginning of any new work task, at the completion of work each day, at noticeable changes in the materials being handled, and at least every two hours during the work day. Site Remediation Hilton Garden Project Northampton MA 10 Decontamination Decontamination of on-site heavy equipment will be performed as necessary to minimize the potential spreading of contamination. Brushing, high pressure water, or a steam cleaner will be used for equipment decontamination, with decontamination fluids collected for infiltration back onto the site. A loading area will be established at the site entrance. The area will be covered with geotextile or plastic sheeting to contain soils that may be spilled during loading. Site Restoration Site restoration will consist of backfilling all excavated areas with “clean” fill and grading to existing site grades (1 to 2 feet above the impermeable barrier). Topsoil and seed will be placed in most areas, and pavement and concrete may be used for additional site enhancements (the final surface landscaping has not yet been determined). Site Security Temporary fencing will be installed around the entire site and loading pad. Signage will be used to alert trespassers to the site conditions, and provide contact information. Demobilization Subcontractor equipment shall be demobilized following completion of remediation activities at the site. All equipment that contacts contaminated materials shall be decontaminated prior to demobilization. SOIL SAMPLING AND ANALYSIS PLAN Soil sampling for remediation will include post-excavation sampling, sampling of clean fill materials prior to their delivery to the site, and waste characterization sampling. Post-Excavation Sampling Upon excavation of soils and prior to the installation of the clean fill, three composite samples of the surface soils (6 inches) will be collected for analysis. These samples will be analyzed for contaminants. Waste Characterization Sampling It is anticipated that sampling frequency will include 1 composite sample for each 100-cubic yards of soil stockpiled, for reuse and disposal characterization. Waste characterization samples will be submitted under chain of custody for laboratory analysis for for waste disposal parameters as needed to supplement the existing soil data, as required by for reuse evaluations or disposal facilities. Clean Fill Sampling The remediation excavation will be backfilled with clean sand, gravel, common fill, and topsoil. Prior to delivery of off-site materials to the site, it will be necessary to collect and analyze representative samples of each. One composite sample of the sand, gravel, common fill, and topsoil will be submitted under chain of custody for laboratory analysis. As an alternative, the suppliers may issue recent analyses for materials from the same source. All data will be reviewed prior to delivery of off-site materials to the site. Site Remediation Hilton Garden Project Northampton MA 11 Sampling Protocol The following equipment will be used for soil sampling: 􀀀􀒏􀀶􀁗􀁄􀁌􀁑􀁏􀁈􀁖􀁖􀀃􀀶􀁗􀁈􀁈􀁏􀀃􀀋􀀶􀀶􀀌􀀃􀀷􀁕􀁒􀁚􀁈􀁏􀁖􀀏􀀃􀀶􀁓 􀁒􀁒􀁑􀁖􀀏􀀃􀁒􀁕􀀃􀀶􀁆􀁒􀁒􀁓􀁖 􀀀􀒏􀀶􀀶􀀃􀀶􀁓􀁄􀁇􀁈􀀃􀁒􀁕􀀃􀀫􀁄􀁑􀁇􀀃􀀤􀁘􀁊􀁈􀁕 􀀀􀒏􀀶􀀶􀀃􀀥􀁒􀁚􀁏􀁖 􀀀􀒏􀀶􀁄􀁐􀁓􀁏􀁈􀀃􀀦􀁒􀁑􀁗􀁄􀁌􀁑􀁈􀁕􀁖 Sample collection procedures will occur as follows: 1. Decontaminate sampling equipment. 2. Record the weather conditions and other notable site conditions. 3. Sketch and record the sampling conditions on the site map and in the field notebook. 4. Photograph the sampling location and conditions. 5. Collect the fill sample in a manner that is appropriate for the depth of the samples and the physical access. 6. Mix the remainder of the sample. Fill containers at least ¾ full for all parameters. 7. Immediately label and refrigerate/ice the sample. 8. Stake location and record in logbook. 9. Submit the samples to the laboratory under chain of custody protocol. 5.5 Laboratory Analysis Laboratory analysis will be performed at a previously approved Laboratories. Clean fill material will be analyzed for the following parameters: volatile organic compounds (VOCs) by EPA method 8260, semi-volatile organic compounds (SVOCs) by EPA Method 8270, ETPH, pesticides by EPA Method 8082, chlorinated herbicides by EPA Method 8150, and total and SPLP DEP metals by EPA Method 6000 and 7000 series. Stockpiled soil samples will be analyzed for potential reuse or disposal via some or all of the following parameters: VOCs, flashpoint, total petroleum hydrocarbons, PAHs by EPA Method 8100, PCBs by EPA Method 8082, reactive cyanide, reactive sulfide, total DEP metals, SPLP or TCLP RCRA metals, pH and conductivity. Post excavation surface samples will be analyzed for PAHs by EPA Method 8270, DEP metals by EPA Method 6000 and 7000 series, and ETPH. Laboratory Quality Assurance/Quality Control The laboratory may be required at the discretion of the LSP to perform all of the internal quality control procedures that are specified in the analytical methods. These include but are not limited to: 􀀀􀒏􀀥􀁏􀁄􀁑􀁎􀁖􀀃– The laboratory will analyze method blanks prepared and analyzed with each set of samples. These are a check of the accuracy of the system and indicate if there are positive biases. 􀀀􀒏􀀦􀁄􀁏􀁌􀁅􀁕􀁄􀁗􀁌􀁒􀁑􀀃􀀦􀁋􀁈􀁆􀁎􀁖􀀃– These are standards, generally from a different source than the calibration standards that are analyzed along with the samples. The purpose of the calibration checks is to determine if the analytical equipment is functioning accurately. 􀀀􀒏􀀰􀁄􀁗􀁕􀁌􀁛􀀃􀀶􀁓􀁌􀁎􀁈􀀃– A matrix spike is an actual sample that is spiked with a known amount of one or more target compounds. The matrix spike recovery is calculated from the results of the analysis. This information is useful for estimating the effect of the sample matrix on the analytical procedure. At least one matrix spike sample will be analyzed for each batch of twenty samples analyzed. Field QA/QC samples will be submitted along with the laboratory samples. A Site Remediation Hilton Garden Project Northampton MA 12 description of each of the sample QC types is described below: 􀀀􀒏􀀨􀁔􀁘􀁌􀁓􀁐􀁈􀁑􀁗􀀃􀀥􀁏􀁄􀁑􀁎􀁖􀀃– These are samples collected in the field by rinsing decontaminated sampling equipment with laboratory grade water and submitting the collected rinsate for analysis. It provides a measure of contamination caused by the sampling equipment. Approximately one equipment blank per 20 samples will be collected. 􀀀􀒏􀀩􀁌􀁈􀁏􀁇􀀃􀁇􀁘􀁓􀁏􀁌􀁆􀁄􀁗􀁈􀁖􀀃– Field supplicates provide an indication of the overall precision of the field sampling and analytical method. Approximately one field duplicate will be collected for every 20 samples analyzed. 􀀀􀒏􀀷􀁕􀁌􀁓􀀃􀀥􀁏􀁄􀁑􀁎􀁖􀀃– Since VOCs are not COCs for the site, trip blanks will not be submitted with confirmation samples. Upon receipt of the laboratory data, a review of the data will be conducted to evaluate its usability. This will include checking of such items as: 􀀀􀒏􀀫􀁒􀁏􀁇􀁌􀁑􀁊􀀃􀁗􀁌􀁐􀁈􀁖􀀞 􀀀􀒏􀀩􀁌􀁈􀁏􀁇􀁇􀀃􀁄􀁑􀁇􀀃􀁏􀁄􀁅􀁒􀁕􀁄􀁗􀁒􀁕􀁜􀀃􀁅􀁏􀁄􀁑􀁎􀁖􀀞 􀀀􀒏􀀩􀁌􀁈􀁏􀁇􀀃􀁄􀁑􀁇􀀃􀁏􀁄􀁅􀁒􀁕􀁄􀁗􀁒􀁕􀁜􀀃� �􀁘􀁓􀁏􀁌􀁆􀁄􀁗􀁈􀁖􀀞 􀀀􀒏􀀶􀁘􀁕􀁕􀁒􀁊􀁄􀁗􀁈􀀃􀁕􀁈􀁆􀁒􀁙􀁈􀁕􀁌􀁈􀁖􀀏􀀃􀁌􀁉􀀃􀁄􀁓􀁓􀁏􀁌􀁆􀁄􀁅􀁏􀁈􀀞 􀀀􀒏􀀦􀁄􀁏􀁌􀁅􀁕􀁄􀁗􀁌􀁒􀁑􀀃􀁆􀁋􀁈􀁆􀁎􀁖􀀞 􀀀􀒏􀀶􀁓􀁌􀁎􀁈􀀃􀁕􀁈􀁆􀁒􀁙􀁈􀁕􀁌􀁈􀁖􀀏􀀃􀁌􀁉􀀃􀁄􀁓􀁓􀁏􀁌� �􀁄􀁅􀁏􀁈􀀏􀀃􀁄􀁑􀁇 􀀀􀒏􀀤􀁑􀁄􀁏􀁜􀁗􀁌􀁆􀁄􀁏􀀃􀁐􀁈􀁗􀁋􀁒􀁇􀀃􀁇􀁈􀁗􀁈􀁆􀁗􀁌􀁒􀁑􀀃􀁏􀁌􀁐􀁌􀁗􀁖􀀃(MDLs). Items such as GC/MS tuning, initial calibrations, calculations, and raw data will be checked by the laboratory. DOCUMENTATION AND REPORTING As required by the State of Massachusetts a Licensed Site Professional (LSP) will be hired to oversee the implementation of remediation activities, and prepare and maintain a record of remediation activities performed. In addition, the LSP will be responsible for monitoring that the project is completed in accordance with all jurisdictional requirements, specifications and generally accepted industry/engineering standards. Field Documentation The following list identifies the specific documentation and reporting requirements that are the responsibility of LSP personnel. 􀀀􀒏􀀰􀁒􀁑􀁌􀁗􀁒􀁕􀁌􀁑􀁊􀀃􀁆􀁒􀁐􀁓􀁏􀁌􀁄􀁑􀁆􀁈􀀃􀁚􀁌􀁗􀁋􀀃􀁓􀁕􀁒􀁙􀁌􀁖􀁌􀁒􀁑􀁖􀀃􀁒f the HASP and air monitoring plan; 􀀀􀒏􀀰􀁄􀁌􀁑􀁗􀁄􀁌􀁑􀁌􀁑􀁊􀀃􀁄􀁑􀀃􀁄􀁆􀁆􀁘􀁕􀁄􀁗􀁈􀀃􀁄􀁆􀁆􀁒􀁘􀁑􀁗􀁌􀁑􀁊􀀃􀁒􀁉􀀃􀁐􀁄􀁗􀁈􀁕􀁌􀁄􀁏􀁖􀀃􀁈􀁑􀁗􀁈􀁕􀁌􀁑􀁊􀀃􀁄􀁑􀁇􀀃􀁏􀁈􀁄􀁙􀁌􀁑􀁊􀀃􀁗􀁋􀁈􀀃􀁖􀁌􀁗􀁈􀀏 including waste soils and other materials; 􀀀􀒏􀀳􀁋􀁒􀁗􀁒􀁊􀁕􀁄􀁓􀁋􀁌􀁆􀀃􀁇􀁒􀁆􀁘􀁐􀁈􀁑􀁗􀁄􀁗􀁌􀁒􀁑􀀃􀁒􀁉􀀃􀁆􀁒􀁐􀁓􀁏􀁈􀁗􀁈􀁇􀀃􀁈􀁛􀁆􀁄􀁙􀁄􀁗􀁌􀁒􀁑􀁖􀀏􀀃􀁓􀁕􀁈􀁙􀁌􀁒􀁘􀁖􀁏􀁜􀀃􀁘􀁑􀁎􀁑􀁒􀁚􀁑􀀃􀁄􀁕􀁈􀁄 􀁖 of contamination, completed remediation areas, and other pertinent observations; 􀀀􀒏􀀰􀁒􀁑􀁌􀁗􀁒􀁕􀁌􀁑􀁊􀀃􀁓􀁕􀁒􀁓􀁈􀁕􀀃􀁖􀁈􀁊􀁕􀁈􀁊􀁄􀁗􀁌􀁒􀁑􀀏􀀃􀁖􀁗􀁒􀁕􀁄􀁊􀁈􀀏􀀃􀁄􀁑􀁇􀀃􀁄􀁆􀁆􀁒􀁘􀁑􀁗􀁌􀁑􀁊􀀃� �􀁉􀀃􀁚􀁄􀁖􀁗􀁈􀁖􀀃􀁄􀁑􀁇􀀃􀁅􀁄􀁆􀁎􀁉􀁌􀁏􀁏 materials that may be stockpiled at the site; 􀀀􀒏􀀧􀁒􀁆􀁘􀁐􀁈􀁑􀁗􀁌􀁑􀁊􀀃􀁄􀁑􀁇􀀃􀁕􀁈􀁓􀁒􀁕􀁗􀁌􀁑􀁊􀀃􀁒􀁉􀀃􀁄􀁑􀁜􀀃􀁖􀁓􀁌􀁏􀁏􀁖􀀏􀀃􀁏􀁈􀁄􀁎􀁖􀀏􀀃􀁒􀁕􀀃􀁒� �􀁋􀁈􀁕􀀃􀁇􀁌􀁖􀁆􀁋􀁄rges occurring at the site; 􀀀􀒏􀀧􀁒􀁆􀁘􀁐􀁈􀁑􀁗􀁌􀁑􀁊􀀃􀁄􀁑􀁇􀀃􀁕􀁈􀁓􀁒􀁕􀁗􀁌􀁑􀁊􀀃􀁒􀁉􀀃􀁄􀁑􀁜􀀃􀁇􀁌􀁖􀁕􀁘􀁓􀁗􀁌􀁒􀁑􀀒􀁇􀁄􀁐􀁄􀁊􀁈􀀃􀁗􀁒􀀃􀁘􀁗􀁌􀁏􀁌􀁗􀁜􀀃􀁖􀁗􀁕􀁘􀁆􀁗􀁘􀁕􀁈􀁖􀀞 􀀀􀒏􀀦􀁒􀁐􀁓􀁏􀁈􀁗􀁌􀁒􀁑􀀃􀁒􀁉􀀃􀁄􀀃􀁇􀁄􀁌􀁏􀁜􀀃􀁕􀁈􀁓􀁒􀁕􀁗􀀃􀁖􀁘􀁐􀁐􀁄􀁕􀁌􀁝􀁌􀁑􀁊􀀃􀁗􀁋􀁈􀀃􀁓􀁕􀁒􀁊􀁕􀁈􀁖􀁖􀀏􀀃􀁈􀁙􀁈􀁑􀁗􀁖􀀏􀀃􀁆􀁒􀁑􀁗􀁕􀁄􀁆􀁗􀁒􀁕 activities and other pertinent details; 􀀀􀒏􀀰􀁒􀁑􀁌􀁗􀁒􀁕􀁌􀁑􀁊􀀃􀁗􀁋􀁄􀁗􀀃􀁈􀁕􀁒􀁖􀁌􀁒􀁑􀀃􀁆􀁒􀁑􀁗􀁕􀁒􀁏􀀃􀁄􀁑d site security measures are adequately maintained throughout the project; 􀀀􀒏􀀰􀁄􀁌􀁑􀁗􀁄􀁌􀁑􀁌􀁑􀁊􀀃􀁗􀁕􀁄􀁑􀁖􀁓􀁒� �􀁗􀁄􀁗􀁌􀁒􀁑􀀒􀁇􀁌􀁖􀁓􀁒􀁖􀁄􀁏􀀃􀁇􀁒􀁆􀁘􀁐􀁈􀁑􀁗􀁄􀁗􀁌􀁒􀁑􀀞 􀀀􀒏􀀰􀁒􀁑􀁌􀁗􀁒􀁕􀁌􀁑􀁊􀀃􀁇􀁈􀁆􀁒􀁑􀁗􀁄􀁐􀁌􀁑􀁄􀁗􀁌􀁒􀁑􀀃􀁓􀁕􀁌􀁒􀁕􀀃􀁗􀁒􀀃􀁇􀁈􀁐􀁒􀁅􀁌􀁏􀁌􀁝􀁄􀁗􀁌􀁒􀁑􀀞􀀃􀁄􀁑􀁇􀀏 Site Remediation Hilton Garden Project Northampton MA 13 􀀀􀒏􀀧􀁒􀁆􀁘􀁐􀁈􀁑􀁗􀁌􀁑􀁊􀀃􀁕􀁈􀁐􀁈􀁇􀁌􀁄􀁗􀁌􀁒􀁑􀀃􀁄􀁕􀁈􀁄􀁏􀀃􀁏􀁌􀁐􀁌􀁗􀁖􀀃􀁄􀁑􀁇􀀃􀁇􀁈􀁓􀁗􀁋􀀑 Post-Remediation Reporting Following completion of remediation activities, an Action Report will be prepared for the site and submitted to the engineer of Record, City of Northampton, BSG, BSG/Engineer and the Owners representative. The report will describe the completed work at the site, and will contain the following specific items: 􀀀􀒏􀀳􀁕􀁒􀁍􀁈􀁆􀁗􀀃􀁑􀁄􀁕􀁕􀁄􀁗􀁌􀁙􀁈􀀞 􀀀􀒏􀀵􀁈􀁆􀁒􀁕􀁇􀀃􀁖􀁌􀁗􀁈􀀃􀁓� �􀁄􀁑􀁖􀀋􀁖􀀌􀀃􀁖􀁋􀁒􀁚􀁌􀁑􀁊􀀃􀁗􀁋􀁈􀀃􀁙􀁈􀁕􀁗􀁌􀁆􀁄􀁏􀀃􀁄􀁑􀁇􀀃􀁋􀁒􀁕􀁌􀁝􀁒􀁑􀁗􀁄􀁏􀀃􀁏􀁌􀁐􀁌􀁗􀁖􀀃􀁒􀁉􀀃􀁈􀁛􀁆􀁄􀁙􀁄􀁗􀁌􀁒􀁑􀀏 sampling locations, and final grades (A-2 survey); 􀀀􀒏􀀶􀁄􀁐􀁓􀁏􀁈􀀃 􀁄􀁑􀁄􀁏􀁜􀁗􀁌􀁆􀁄􀁏􀀃􀁇􀁄􀁗􀁄􀀃􀁌􀁑􀀃􀁗􀁄􀁅􀁘􀁏􀁄􀁕􀀃􀁉􀁒􀁕􀁐􀀞 􀀀􀒏􀀦􀁒􀁐􀁓􀁏􀁈􀁗􀁈􀀃􀁏􀁄􀁅􀁒􀁕􀁄􀁗􀁒􀁕􀁜􀀃􀁕􀁈􀁓􀁒􀁕􀁗􀁖􀀞 􀀀􀒏􀀺􀁄􀁖􀁗􀁈􀀃􀁇􀁌􀁖􀁓􀁒􀁖􀁄􀁏􀀃􀁇􀁒􀁆􀁘􀁐􀁈􀁑􀁗􀁄􀁗􀁌􀁒􀁑 (manifests, bills-of-lading, certificates of disposal, etc.) 􀀀􀒏􀀺􀁄􀁖􀁗􀁈􀀃􀁇􀁌􀁖􀁓􀁒􀁖􀁄􀁏􀀃􀁖􀁘􀁐􀁐􀁄􀁕􀁜􀀃􀁌􀁑􀁇􀁌􀁆􀁄􀁗􀁌􀁑􀁊􀀃􀁗􀁋􀁈􀀃􀁚􀁈􀁌􀁊􀁋􀁗􀁖􀀏􀀃􀁙􀁒􀁏􀁘􀁐􀁈􀁖􀀏􀀃􀁄􀁑􀁇􀀃􀁇􀁌􀁖􀁓􀁒􀁖􀁌 􀁗􀁌􀁒􀁑􀀃􀁒􀁉 excavated materials; 􀀀􀒏􀀧􀁒􀁆􀁘􀁐􀁈􀁑􀁗􀁄􀁗􀁌􀁒􀁑􀀃􀁒􀁉􀀃􀁄􀁏􀁏􀀃􀁐􀁄􀁗􀁈􀁕􀁌􀁄􀁏􀁖􀀃􀁌􀁑􀁆􀁒􀁕􀁓􀁒􀁕􀁄􀁗􀁈􀁇􀀃􀁌􀁑􀁗􀁒􀀃􀁗􀁋􀁈􀀃􀁓􀁕􀁒􀁍􀁈􀁆􀁗􀀃􀀋􀁅􀁄􀁑􀁎􀀃􀁕􀁘􀁑􀀃􀁊􀁕􀁄􀁙􀁈􀁏􀀏 topsoil, etc.); 􀀀􀒏􀀳􀁋􀁒􀁗􀁒􀁊􀁕􀁄􀁓􀁋􀁖􀀃􀁒􀁉􀀃􀁕􀁈􀁐􀁈􀁇􀁌􀁄􀁗􀁌􀁒􀁑􀀃􀁄􀁆􀁗􀁌􀁙􀁌􀁗􀁌􀁈􀁖􀀞􀀃 Construction Health and Safety Plan Prior to site excavation, a HASP would be prepared to address both the known contamination issues and contingency items (e.g., the discovery of unexpected petroleum storage tanks, petroleum-contaminated soil, free liquids, or solvent contamination). The HASP would describe in detail the health and safety procedures that are recommended or proposed to minimize exposure of workers and the public to hazardous materials. Regardless of the procedures for reducing exposure, the HASP will indicate what levels would require specific actions or termination of work. The hazards throughout the District would be evaluated by determining the subsurface contaminants of concern, their chemical and physical characteristics, and health hazards in relation to the various actions and construction efforts that would take place in this area. Appropriate personnel would be designated to ensure that all requirements of the HASP were implemented, including an on-site Site Safety Officer (SSO). The SSO would have completed a 40-hour training course, supervisory training and updated annual refresher courses that meet OSHA requirements codified in 29 CFR Part 1910, Occupational Safety and Health Standards. The SSO would be a competent person responsible for the implementation of the HASP, who would have completed either the 24-hour training course for an Occasional Hazardous Waste Site Worker or the 40-hour training course for the Hazardous Waste Operations Worker that meets OSHA requirements codified in 29 CFR Part 1910. The SSO would have stop-work authorization, which he/she would execute on his/her determination of an imminent safety hazard, emergency situation, or other potentially dangerous situation. If the SSO is to be absent from the site, he/she would designate a suitably qualified replacement who is familiar with the HASP. The HASP would require that on-site personnel are qualified and have received the required training. All those who enter the work area while intrusive activities are being performed must receive instruction regarding the potential hazards to health and safety. All construction personnel upon entering the site must first attend a training meeting to: • Make workers aware of the potential hazards they may encounter; Site Remediation Hilton Garden Project Northampton MA 14 • Provide the knowledge and skills necessary for them to perform the work with minimal risk to health and safety; • Make workers aware of the purpose and limitations of safety equipment; and • Ensure that they can safely avoid or escape from emergencies. Each member of the construction crew would be instructed in these objectives before he/she begins working on the site. The SSO, or other suitably trained individuals would be responsible for conducting the training program. Others who enter the site must be accompanied by a suitably trained construction worker. The HASP would include contingency response plans. All excavation would be monitored for the presence of buried tanks, drums, or soil that shows evidence of potential contamination, such as discoloration, staining, or odors. If any of these were detected, specific procedures would be outlined for the situation, and appropriate personnel would be notified, including the SSO. All contingency response actions would be carried out in accordance with special contingency health and safety procedures. An emergency response plan would also be included in the event that monitoring data indicate a potential major hazard, and protocols for reporting spills or other concerns to relevant governmental agencies would be defined. HILTON GARDEN INN NORTHAMPTON MA PROJECT LOCATION MAIN STREET ÐÜÚ Ý®»¿¬»¼ ©·¬¸ ¼»­µÐÜÚ ÐÜÚ É®·¬»® ó Ì®·¿´ ææ ¸¬¬°æññ©©©ò¼±½«¼»­µò½±³