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ENVIRONMENTAL MANAGEMENT PLAN

DEMOLITION OF ABOVE GROUND STRUCTURES AND

REMOVAL OF RESIDUAL MATERIALS

MUGGAH CREEK REMEDIATION PROJECT

Sydney, Nova Scotia

NOVEMBER 2001REF. NO. 14458 (24)This report is printed on recycled paper.

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ENVIRONMENTAL MANAGEMENT PLAN

DEMOLITION OF ABOVE GROUND STRUCTURES ANDREMOVAL OF RESIDUAL MATERIALS


Sydney, Nova Scotia

NOVEMBER 2001

REF. NO. 14458 (24)This report is printed on recycled paper.

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14458 (24) CONESTOGA-ROVERS & ASSOCIATES

TABLE OF CONTENTSPage

1.0 INTRODUCTION................................................................................................................... 11.1 BACKGROUND.................................................................................................. 11.2 PROJECT ACTIVITIES....................................................................................... 11.3 PURPOSE/OBJECTIVES OF EMP ................................................................... 31.4 PROJECT ORGANIZATION ............................................................................ 4

2.0 PROJECT SCHEDULE........................................................................................................... 5

3.0 WEATHER MONITORING AND WEATHER FORECASTING .................................... 6

4.0 ENVIRONMENTAL CONTROL MEASURES................................................................... 74.1 GENERAL CONTROLS..................................................................................... 84.1.1 DUST AND PARTICULATE CONTROL........................................................ 84.1.1.1 DUST AND PARTICULATE CONTROL – CONTROL MEASURES......... 8

4.1.1.2 DUST AND PARTICULATE COTNROL - RESPONSIBILITIES ................. 94.1.1.3 DUST AND PARTICULATE CONTROL - MONITORING......................... 94.1.2 EROSION AND SEDIMENTATION CONTROL .......................................... 94.1.2.1 EROSION AND SEDIMENTATION CONTROLS – CONTROL MEASURES

............................................................................................................................... 94.1.2.2 EROSION AND SEDIMENTATION CONTROLS - RESPONSIBILITIES 104.1.2.3 EROSION AND SEDIMENTATION CONTROLS - MONITORING ...... 104.1.3 WEATHER AND WIND IMPOSED CONTROLS ...................................... 104.1.3.1 WEATHER AND WIND IMPOSED CONTROLS – CONTROL MEASURES

............................................................................................................................. 104.1.3.2 WEATHER AND WIND IMPOSED CONTROLS - RESPONSIBILITIES. 11

4.1.3.3 WEATHER AND WIND IMPOSED CONTROLS - MONITORING ........ 114.1.4 RESTRICTION OF WORKING HOURS ....................................................... 124.1.5 AIR QUALITY CONTROL.............................................................................. 124.1.5.1 AIR QUALITY CONTROL - CONTROL MEASURES................................ 124.1.5.2 AIR QUALITY - RESPONSIBILITIES ............................................................ 124.1.5.3 AIR QUALITY CONTROL - MONITORING............................................... 134.1.5.4 LONG TERM AIR MONITORING PROGRAM........................................... 134.1.6 HEALTH AND SAFETY.................................................................................. 134.1.6.1 HEALTH AND SAFETY – CONTROL MEASURES................................... 134.1.6.2 HEALTH AND SAFETY – RESPONSIBILITIES .......................................... 134.1.6.3 HEALTH AND SAFETY – MONITORING .................................................. 14

4.1.7 CONTINGENCY AND EMERGENCY RESPONSE.................................... 144.1.7.1 CONTINGENCY AND EMERGENCY RESPONSE – CONTROL MEASURES............................................................................................................................. 14

4.1.7.2 CONTINGENCY AND EMERGENCY RESPONSE – RESPONSIBILITIES144.1.7.3 NOTIFICATION OF INCIDENTS.................................................................. 154.1.8 EQUIPMENT AND PERSONNEL DECONTAMINATION...................... 154.2 PROJECT-SPECIFIC CONTROLS.................................................................. 164.2.1 WASTEWATER DISCHARGE AND DISPOSAL ........................................ 16

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4.2.1.1 WASTEWATER DISCHARGE AND DISPOSAL- CONTROL MEASURESAND MONITORING ....................................................................................... 16

4.2.1.2 STANDING WATER IN DOMTAR TANK, BENZOL TANK AND BENZOLAREA TANK..................................................................................................... 16

4.2.1.3 SANITARY WASTEWATERS......................................................................... 18

4.2.1.4 VEHICLE WASH WASTEWATER ................................................................ 184.2.1.5 TANK CLEANING WASTEWATER............................................................. 204.2.1.6 EQUIPMENT DECONTAMINATION WASTEWATER............................ 214.2.1.7 POTENTIAL WATERS CURRENTLY WITHIN FOUNDATIONS OF

STRUCTURES OR GENERATED FROM WETTING OPERATIONS....... 224.2.1.8 WASTEWATER DISCHARGE AND DISPOSAL – RESPONSIBILITIES . 224.2.2 SOLID WASTE DISPOSAL ............................................................................. 224.2.2.1 SOLID WASTE DISPOSAL – CONTROL MEASURES............................... 234.2.2.2 SOLID WASTE DISPOSAL – RESPONSIBILITIES...................................... 234.2.2.3 SOLID WASTE DISPOSAL - MONITORING............................................... 244.2.3 REMOVAL AND DISPOSAL OF TANK CONTENTS................................ 244.2.3.1 DOMTAR TANK ENCLOSURE..................................................................... 244.2.3.2 CONTROLS SPECIFIC TO REMOVAL AND DISPOSAL OF TANK

CONTENTS ....................................................................................................... 254.2.4 STACK DEMOLITION .................................................................................... 264.2.4.1 CONTROLS SPECIFIC TO THE DEMOLITION OF STACKS................... 264.2.5 BULK MATERIAL REMOVAL....................................................................... 264.2.5.1 CONTROLS SPECIFIC TO THE BULK MATERIAL REMOVAL ............. 264.2.6 DEMOLITION OF STRUCTURES.................................................................. 274.2.6.1 CONTROLS SPECIFIC TO THE DEMOLITION OF STRUCTURES........ 27

5.0 MONITORING DATA REPORTING AND EVALUATION......................................... 285.1 RESPONSE LEVELS......................................................................................... 28

5.2 REPORTING...................................................................................................... 28

6.0 ENSURING COMPLIANCE............................................................................................... 296.1 INSPECTION..................................................................................................... 296.2 REPORTING...................................................................................................... 296.2.1 WEEKLY PROGRESS REPORTING .............................................................. 29

7.0 PUBLIC PARTICIPATION ................................................................................................. 30

8.0 REGULATORY AND OTHER APPROVALS .................................................................. 31

9.0 SUMMARY REPORTS......................................................................................................... 329.1 EVALUATION OF EFFECTIVENESS OF MITIGATION (CONTROL)

MEASURES ....................................................................................................... 329.2 ACCURACY OF ENVIRONMENTAL ASSESSMENT PREDICTIONS... 33

10.0 MODIFICATIONS TO THE ENVIRONMENTAL MANAGEMENT PLAN .............. 34

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LIST OF FIGURES(Following Text)

FIGURE 1.1 SITE PLAN

FIGURE 1.2 SITE SUPPORT PLAN

FIGURE 1.3 PROJECT ORGANIZATION

FIGURE 2.1 SCHEDULE

FIGURE 4.1 WASTEWATER FLOW CHART

FIGURE 4.2 MATERIAL DISPOSAL FLOW CHART

LIST OF TABLES(Following Text)

TABLE 4.1 MITIGATION AND/OR CONTROL MEASURES SUMMARY

TABLE 4.2 EMERGENCY RESPONSE RESPONSIBILITIES

TABLE 4.3 PROPOSED DISCHARGE CRITERIA FOR WASTEWATER FROM TANKS,DECONTAMINATION PAD AND TANK CLEANING

TABLE 4.4 PROPOSED DISCHARGE CRITERIA FOR WASTEWATER FROM VEHICLEWASH PAD

TABLE 4.5 PROPOSED DISCHARGE CRITERIA FOR WASTEWATER FROMFOUNDATIONS AND WETTING OPERATIONS

LIST OF APPENDICES

APPENDIX A AIR MONITORING PLAN

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14458 (24) 1 CONESTOGA-ROVERS & ASSOCIATES

1.0 INTRODUCTION

Conestoga-Rovers & Associates, as the Project Management Consultants (PMC) for the

Muggah Creek Remediation Project, has prepared this Environmental Management Plan

(EMP) for the Demolition of Above Ground Structures and Removal of Residual

Material – Former Coke Oven Site, Sydney, Nova Scotia (Project), to outline measures to

be undertaken for the protection and enhancement of the environment.

The EMP is intended to be a dynamic document that will evolve and be updated to meet

the changing needs of the Project as it proceeds through each element. The EMP

includes environmental protection, air quality monitoring, emergency response and

contingency plans.

1.1 BACKGROUND

The Joint Action Group (JAG) recommended that the government parties implement a

project to demolish the above ground structures and remove the residual materials

presently located at the Coke Ovens Site (Site). The goals of the project are to remove

physical hazards, reduce the potential for human contact with the site materials, prevent

the spread of contaminated materials away from the site and to stabilize the site prior to

further studies and remediation.

1.2 PROJECT ACTIVITIES

Despite previous decommissioning and demolition efforts the Site remains host to

several derelict structures, much surface debris, and an unknown array of subsurface

infrastructure. The purpose of this project is to demolish all of the remaining

aboveground structures and to remove most demolition debris and residual surface

materials from the Site. To facilitate the demolition activities, a new access road to the

Site will be constructed. Site support infrastructure for future remedial efforts will be

established along this new access road.

The Project work will include the demolition, removal and disposal of the followingstructures:

No. 5 and No. 6 Battery Stacks: two reinforced concrete stacks that are 69 metres and

61 metres tall, respectively;

No. 6 Coke Oven Battery: the remains of concrete, brick, and steel structures

reduced to mounds of rubble;

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the By-Products Building: a partially demolished structure of approximately 1520

square meters area;

the Sulphur Building: remnants of a highly deteriorated concrete walled building

located at the eastern extremity of the site;

the Domtar Tank: an open top, 6 metres high, steel tank, 28 metres in diameter, that

contains a consolidation of materials from previous decommissioning activities at

the Site;

the Benzol Tank: a large closed top, steel bottom tank of 23 metres diameter and 16

metres height (removal of contents only). Depending upon the condition of the tank

and possible future needs, the Benzol Tank may remain on-site; and,

the Benzol Plant Area Tank: a 3 metre diameter, 12.6 metre long steel tank lying

horizontally on the ground.

In addition to demolition and disposal of the above structures, the Project will also

include removal and disposal of the following materials:

a stockpile of approximately 473 tonnes of elemental sulphur located within the

remains of and adjacent to the Sulphur Building;

Domtar Tank contents: approximately 1355 cubic metres of liquid, 92 cubic metres

of sludge, and 2247 cubic metres of solid material;

the Benzol Plant Area Tank contents: reported to be equal depths (~ 0.1 metres ) of

sediment, water and oil;

the Benzol Tank contents: approximately 21 cubic metres of petroleum hydrocarbon

sludge (contaminated with benzene, toluene, xylenes and naphthalene);

a stockpile of wood Cooling Grid debris; a quantity of unprocessed coal from the Coal Storage area, the quantity is estimated

to be between 8,000 to 29,000 tonnes (quantity to be surveyed in Spring 2001) ;

a stockpile of coke breeze, estimated quantity 9,000 cubic metres (quantity to be

surveyed in Spring 2001);

miscellaneous surface debris including wood and scrap steel.

A new access road will extend from the end of Teak Street to the southeast corner of the

Coke Ovens Site. Site support facilities including a vehicle wash pad, wastewater

treatment facility, personnel wash house and other site offices will be located at thesoutheast corner of the Site.

Figure 1.1 provides an aerial view of the site showing the location of the various

structures and materials and their proximity to the surrounding community. Figure 1.2

provides general details regarding the new access road and site support facilities.

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The Project does not include demolition and/or removal of underground structures

remaining on the Site, the removal/remediation of the tar cell, or final site reclamation.

The nature of these projects will be evaluated along with the Site’s overall remediation

program.

1.3 PURPOSE/OBJECTIVES OF EMP

The EMP provides details regarding measures to be undertaken during the

implementation of the Project to ensure the protection and enhancement of the

environment and human health.

Specific objectives of the EMP are as follows:

Define activities which may have an impact;

Define mitigation and control measures;

Identify responsibilities;

Development and implementation of an air monitoring plan;

Establish decision making processes;

Emergency response planning including procedures, response actions and

responsibilities;

Development of contingency plans;

Verification of accuracy of selected environmental assessment predictions; and

Assessment of the effectiveness of measures taken to mitigate the adverse effects of

the project.

Each of these objectives is described within the balance of this EMP report.

Although careful consideration is always given to the completion schedule and cost,

these two items will not necessarily be used to limit the types and frequency of control

and contingency measures to be implemented. Imposition of a control or contingency

measure will always be followed by a review of the effectiveness and appropriateness of

the control measure. For all planned activities, stopping of an activity is an available

measure that will be implemented when other control and contingency methods are not

effective. Resumption of the activity is always of paramount importance (the project

needs to be completed) however, resumption will not occur unless effective control

measures have been implemented to the satisfaction of the PMC.

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1.4 PROJECT ORGANIZATION

A project organization chart is presented on Figure 1.3.

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2.0 PROJECT SCHEDULE

The sequence of project activities as of the date of this document is presented on Figure

2.1. This arrangement of activities is based on all activities having undergone a

Canadian Environmental Assessment Act (CEAA) screening. Activities have been

scheduled so that the potential impact of overlapping activities does not result in the

deterioration of air quality to unacceptable levels in residential areas.

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3.0 WEATHER MONITORING AND WEATHER FORECASTING

A weather station has been located at the Site to enable monitoring of precipitation

barometric pressure, temperature, wind velocity, and wind direction. The data will be

automatically logged and recorded for retrieval as necessary.

In addition to monitoring ambient conditions at the Site, the local weather forecast, as

broadcast by Environment Canada, will be monitored by the PMC and contractors

throughout the day. Changes to planned activities may be made when unfavourable

weather is forecast. For example, if high wind speed is forecasted, planned Site activities

for a given day will be restricted to those activities that do not generate dust. Additional

information regarding this item is provided below in Section 4.1.1.

A summary tabulation of the on-site weather conditions will be made daily, and will be

included as part of the daily air monitoring report.

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4.0 ENVIRONMENTAL CONTROL MEASURES

The projects included in the Above Ground Structures and Removal of Residual

Materials at the Coke Ovens Site will be sub-divided into five separate contracts as

follows:

1. Infrastructure: Includes the construction of a new access road from the

southeast corner of the fenced portion of the Coke Ovens Site to Teak Street and

construction of a Site Support Area which will include:

i) a personal hygiene facility;

ii) office trailers;

iii) a vehicle wash pad; and

iv) wastewater treatment facility.

2. Tank Contents Removal: Includes the removal, transportation and disposal and

treatment (if necessary) of the contents remaining within the Domtar Tank,

Benzol Tank and Benzol Area Tank. The Contract will also include the cleaning

of the tanks and the dismantling of the Domtar Tank and Benzol Area Tank. The

Benzol Tank condition will be evaluated for and considered for use in future

projects.

3. Stacks Demolition: Includes the demolition of the Battery Nos. 5 and 6 stacks.

4. By-Products Building Demolition: Includes the demolition of the building and

disposal of the sulphur pile and cooling grids.

5. Bulk Material Removal: Includes the removal and salvage/disposal of the

remaining piles of coal, and coke.

6. Above Ground Structures: Includes the demolition of above ground structures

including Battery No. 6 foundation, coal conveyor structure and sulphur

building. Also includes the removal and disposal of miscellaneous building

debris scattered across the Coke Ovens Site.

Controls will be placed on each contractor to ensure that Site activities do not cause

unacceptable on or off-Site impact. These controls are in addition to monitoring

conducted by the PMC and others during the construction activities. A summary of the

mitigation and/or control measures is presented in Table 4.1.

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4.1 GENERAL CONTROLS

Controls that will be placed on all work include the following:

Dust particulate control;

Erosion and sediment control;

Weather and wind speed controls;

Restrictions of working hours from 7:00 a.m. to 7:00 p.m.;

Air quality controls;

Development and implementation of Site-specific Health and Safety Plan;

Implementation of a Environmental Management Plan;

Implementation of a Contingency and Emergency Response Plan;

Equipment and personnel decontamination.

The specific requirement of each of the above are outlined in the following paragraphs

and in Section 4.2.

4.1.1 DUST AND PARTICULATE CONTROL

All contractors will be contractually required to control the creation of dust.

4.1.1.1 DUST AND PARTICULATE CONTROL – CONTROL MEASURES

Controls will include but not be limited to:

Restricting vehicle speeds while on Site;

Wetting traveled areas;

Wetting removal operations;

Restricting rate of work activities.

Should perimeter air monitoring for PM10 indicate exceedances of 43 ug/m3 then

additional control measure will be implemented by the Contractor to attempt to reduce

the value. Should perimeter air monitoring for PM10 exceed 86 ug/m3 then all activities

will be stopped until an effective control can be implemented.

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4.1.1.2 DUST AND PARTICULATE CONTROL - RESPONSIBILITIES

The contractors will be required to implement dust and particulate control measures.

The PMC and others will be responsible for monitoring perimeter dust and particulate

levels and directing the contractor to implement any necessary controls to maintain dust

and particulate levels below the established criteria.

4.1.1.3 DUST AND PARTICULATE CONTROL - MONITORING

Dust and particulate matter will be monitored at the perimeter of the Site by an

independent air monitoring consultant in accordance with the Air Monitoring Plan

provided in Appendix A.

4.1.2 EROSION AND SEDIMENTATION CONTROL

Measures to control erosion and sedimentation during the course of the Project will be

implemented at the start of each Site activity, and will be maintained until each Site

activity is complete. Objectives of erosion and sedimentation control will include the

minimization of surface soil erosion and sedimentation of waterways at the Site.

4.1.2.1 EROSION AND SEDIMENTATION CONTROLS – CONTROLMEASURES

Erosion control measures will include the installation of silt fences along all down

gradient sides of work areas and around areas of disturbed adjacent surface such that

the drainage channel does not erode the sediments. Erosion and sediment control

measures will be consistent with the Nova Scotia Department of the Environment

publications entitled “Erosion and Sediment Control: Handbook for Constructions Sites”

(1998).

Erosion control measures will be inspected daily and after each rainfall. Maintenance of

the silt fences, straw bales, stockpile covers etc. will be performed at least monthly, and

after heavy rains (rainfall greater than 25 mm in 24 hours) or as required.

Long term erosion control measures include the installation of a temporary soil cover onareas of the Site where coal, coke, sulphur and cooling grids are removed. This

temporary soil cover will reduce the potential for erosion and migration from the site of

remaining coal, coke, sulphur and site contaminants. The temporary soil cover will be

seeded and mulched. The growth of vegetation will serve as a wind buffer to reduce

wind scouring and to control run-off from rainfall. The Site grades will be adjusted in

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the areas of coal, coke, and sulphur removal such that minimal slopes are maintained.

This will keep surface scouring and channeling of the soil cover to a minimum.

4.1.2.2 EROSION AND SEDIMENTATION CONTROLS - RESPONSIBILITIES

Installation, monitoring and maintenance of erosion control features will be the

responsibilities of the contractors selected for the various aspects of the works. Weekly

inspections as described in section 4.1.2.3 below, will also be performed by the PMC to

ensure that the objectives of soil erosion control are being met. An evaluation of the

control measures will be provided to the Nova Scotia Department of Transportation and

Public Works (NSTPW).

4.1.2.3 EROSION AND SEDIMENTATION CONTROLS - MONITORING

Monitoring of erosion control measures will be conducted daily by the contractors,weekly by the PMC and after heavy rain events (rainfall greater than 25 mm in 24

hours). Monitoring will include the visual inspection and evaluation of all erosion

control features, with recommendations for replacement or additional measures to be

taken. The visual inspection of the erosion control features will be made during a

rainfall event so that the effectiveness of surface water control features can be reviewed.

Localized discharge points of channeled surface flow will be monitored such that

sediment carryover can be evaluated. The upstream and downstream flow of brooks

passing through the Site (Coke Oven Brook and Cagney Brook) will be visually

compared to determine whether Site activities are causing degradation of these streams

during rain events.

4.1.3 WEATHER AND WIND IMPOSED CONTROLS

Although the actual weather cannot be controlled, Site activities can be controlled

during periods of unfavourable weather conditions. Unfavourable weather conditions

can cause excessive dust to be created at the Site as well as poor dispersion of emissions

generated during work activities.

4.1.3.1 WEATHER AND WIND IMPOSED CONTROLS – CONTROL

MEASURES

Weather imposed restrictions will be imposed during work activities as follows:

1. Where running average wind speeds during any previous hour exceeds 35 km/hr

and where there is no trend toward diminishing wind speed as measured during the

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previous half hour, the work activity will be suspended until the average one-hour

wind speed is below 35 km/hr.

2. Wind gust speeds exceeding 70 km/hr with a trend towards repeated similar gusts

would result in similar temporary suspension of activities until the frequency and

speed of gusts decrease. Occasional (one or less per hour) gusts greater than 70

km/hr would not require suspension of activities unless indicated by air monitoring

(i.e. frequent exceedances of the air quality criteria).

3. When handling volatile materials, stable wind conditions may result in a need to

shut down operations; the need for this will be assessed based on air monitoring

results.

4. Severe weather conditions such as heavy rainfall or thunderstorms may cause work

activities to be temporarily ceased. Work activities will be temporarily suspendedshould severe weather conditions have the potential to cause harm to the workers,

the public, or the environment if work activities were to continue.

Wind speed and direction will be monitored and recorded, with the average and gust

speeds being continuously determined and displayed at the weather monitoring station.

An exception to the above controls will be work activities conducted within the

temporary enclosure for the Domtar Tank contents removal or indoor, no-intrusive

activities such as plumbing, electrical, etc. As this activity will be protected from

weather conditions such as wind or rain the controls will not apply to work activities

conducted within the enclosures. Air quality controls outside of the enclosure will still

be imposed.

4.1.3.2 WEATHER AND WIND IMPOSED CONTROLS - RESPONSIBILITIES

Weather and wind conditions will be monitored by the PMC. The PMC will be

responsible for evaluating weather conditions and determining when work activities

will be temporarily suspended.

4.1.3.3 WEATHER AND WIND IMPOSED CONTROLS - MONITORING

As discussed previously in Section 3.0, a weather station has been established adjacent

to the Site Support Area. The weather station will be capable of monitoring

precipitation, wind velocity and direction, ambient temperature and barometric

pressure. The data will be automatically logged and recorded for retrieval. In addition,

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weather forecasts will be evaluated daily and planned work activities coordinated with

contractors as necessary.

4.1.4 RESTRICTION OF WORKING HOURS

All contractors working hours will be restricted to 7:00 a.m. to 7:00 p.m. Exceptions will

be the operation and maintenance of the following:

1. Temporary Enclosure and Ventilation System for the Domtar Tank Enclosure;

2. Temporary Wastewater Treatment System.

4.1.5 AIR QUALITY CONTROL

As part of the determination of the interim separation zones as described in the

Development of Interim Separation Zones Report (Separation Zones Report), ambientair criteria (AAC) have been established that are considered to be conservatively

protective of human health. These AAC were developed specifically for the demolition

and removal activities described in Section 1.2 of this EMP. A summary listing of the

AAC is presented in Table 2.1 of the Air Monitoring Plan (AMP presented in Appendix

A).

4.1.5.1 AIR QUALITY CONTROL - CONTROL MEASURES

The control measures described in the Separation Zones Report are focussed on ambient

air quality since AGRA Earth & Environmental Limited (AGRA) identified that

migration of substances via air was the most critical route of exposure to the

environment and human population. Air quality control will be maintained by general

controls described in section 4.1 and by activity specific controls described in Section 4.2.

4.1.5.2 AIR QUALITY - RESPONSIBILITIES

A summary of mitigation control measures, action items and monitoring responsibilities

is provided in Table 4.1.

The selected contractor(s) responsible for performing the various items of the work will

each be responsible for maintaining control of their work, for making adjustments,

including implementation of controls and or contingency measures to their work based

on monitoring results. An air monitoring consultant will be performing the perimeter

monitoring described in the AMP included in Appendix A. Communication at the Site

between the PMC, air monitoring personnel and remedial activity personnel will be

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maintained to ensure that all Site personnel are aware of the site activities and air

monitoring results. As it is most likely that different contractors will be employed at the

Site with different responsibilities, the PMC will ensure that all Site contractors

contractually have programs in place that allow for communication between personnel

of different employers, so that important information regarding monitoring results are

communicated to all personnel in a timely manner.

The PMC will advise NSTPW of Site activities, air monitoring results and invoked

control or contingency measures.

Site personnel will be informed of any changes or enhancements that are adapted to the

EMP or to the AMP. The communication of these requirements to all Site personnel is of

paramount importance to ensure that the EMP and AMP are successfully implemented.

4.1.5.3 AIR QUALITY CONTROL - MONITORING

The procedures to be implemented for real time, and long term (collection of samples for

laboratory analyses) air monitoring are described in the AMP.

4.1.5.4 LONG TERM AIR MONITORING PROGRAM

During the implementation of this project a separate long-term air monitoring program

will be ongoing. The long-term air monitoring program will be conducted external of

this program by the Air Monitoring Consultant.

4.1.6 HEALTH AND SAFETY

4.1.6.1 HEALTH AND SAFETY – CONTROL MEASURES

Work on the Site will be conducted in accordance with the Master Health and Safety

Plan. Each selected contractor and/or consultant will be required to submit to the PMC

for acceptance a Project-specific Health and Safety Plan (HASP) for its workers.

4.1.6.2 HEALTH AND SAFETY – RESPONSIBILITIES

Each contractor and consultant will be responsible for implementing their Project-

specific Health and Safety Plan.

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4.1.6.3 HEALTH AND SAFETY – MONITORING

Each contractor and consultant will be responsible for monitoring their respective

personnel for health and safety. The PMC will monitor the contractor and consultants

implementation of the Project-specific Health and Safety Plan.

4.1.7 CONTINGENCY AND EMERGENCY RESPONSE

Each contractor will be required to prepare and implement a Project-specific Contingency

and Emergency Response plan that will be specific to the work activity being performed or

met the requirements of the Emergency Response Plan developed by the PMC. The

Project-specific Contingency and Emergency Response Plan will be consistent with the

Emergency Response Plan prepared for the Muggah Creek Remediation Project and

provide more specific details regarding the work the contractors completing. The decision

whether a “Site-Specific” Emergency Response Plan is required by certain contractors willbe made by the PMC based upon the complexity of the work being conducted by the

individual contractor.

4.1.7.1 CONTINGENCY AND EMERGENCY RESPONSE – CONTROLMEASURES

1. The Emergency Response Plans will cover topics such as:

Preventative Measures such as training, site security, waste management, storage of

machinery, equipment and materials.

2. Emergency notification procedures including emergency definition, storms, spills,

releases, vehicle accidents, personal injury, crime activity, fire emergency,

notification and investigation, and documentation.

3. Response procedures including: site evaluation, response procedures in the event of

fire, personal injury, spills/releases, and responsibilities

4.1.7.2 CONTINGENCY AND EMERGENCY RESPONSE – RESPONSIBILITIES

As part of the review of the Emergency Response Plan, all personnel and agencies

potentially involved in responding to a non-routine event will attend an emergency

response coordination meeting, prior to the start of each individual demolition contract,

hosted by the PMC. Meeting participants will include representatives from local

emergency responders (fire, police, paramedics), CBRM Emergency Measures

Coordinator, emergency room coordinator from the local hospital, Coast Guard,

Environment Canada, Transport Canada and Nova Scotia Department of the

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Environment and Labour, as well as the contractor, the PMC, representatives from

NSTPW, and JAG. At this meeting, planned site activities and routine operations will be

discussed. Each type of non-routine situation will be reviewed, with duties assigned to

appropriate personnel and designated alternates. The Emergency Response Plan will

include a listing of the potential non-routine events, along with the assigned duties and

responsibilities. All Project team members will have a specific responsibility during a

non-routine event. The roles and responsibilities of the organization and agency

involved in the emergency response are presented on Table 4.2.

4.1.7.3 NOTIFICATION OF INCIDENTS

Depending on the nature of a non-routine event or of an incident, the PMC will notify

interested and responsible parties. Such notification will be in writing, with a copy

provided to NSTPW.

4.1.8 EQUIPMENT AND PERSONNEL DECONTAMINATION

Off-Site contamination migration will be controlled primarily through equipment

decontamination at the work zone, and of the vehicle wash pad for all vehicles leaving

the Site. Wastewaters from the equipment decontamination and vehicle wash pad will

be handed as described in Section 4.2.1. Initial equipment cleaning will comprise bulk

material removal by scraping with a shovel or other suitable tool. The equipment will

then be washed with high pressure, high temperature water amended with detergent or

solvent as required. Following washing, the equipment will then be rinsed with clean

water. The contractor and the PMC will inspect the equipment prior to equipment beingremoved from the Site. Re-cleaning will be conducted, as necessary until the equipment

is visually clean.

Although worker protection will be described in the Site-specific Health and Safety Plan

(HASP), procedures for removal and proper containerization of soiled personal

protective equipment (PPE) will be followed to prevent contamination migration from

the Site via Site workers. All workers in contact with Site contaminants will be required

to wear disposable PPE. Once soiled, the outer layer of PPE will be removed and

containerized at the exclusion or work zone boundary. Workers will then proceed to the

wash house located at the Site support area for showering prior to leaving the Site.

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4.2 PROJECT-SPECIFIC CONTROLS

Section 4.2 describes controls to be imposed on specific activities in addition to those

described in Section 4.1.

4.2.1 WASTEWATER DISCHARGE AND DISPOSAL

Wastewater generated during the course of project activities at the Site will be handled

in several manners depending on the source and nature of the wastewater. Overall

objectives of wastewater discharge and disposal are to ensure that wastewater generated

at the Site is handled in an environmentally sound manner that is reliable and cost-

effective. Different wastewater streams anticipated at the Site include:

Standing water in Domtar Tank, Benzol Tank and Benzol Area tank;

Sanitary wastewater from site support facilities; Vehicle wash pad wastewater;

Equipment decontamination wastewater; and

Potentially waters currently within foundations of structures and/or excess waters

generated from wetting operations (if required).

A flow chart illustrating the wastewater streams and treatment process is presented on

Figure 4.1

4.2.1.1 WASTEWATER DISCHARGE AND DISPOSAL- CONTROL MEASURES

AND MONITORING

Control measures and objectives for each wastewater stream are described in the

following subsections.

4.2.1.2 STANDING WATER IN DOMTAR TANK, BENZOL TANK ANDBENZOL AREA TANK

At present, there is approximately 1,355,000 litres of water above the sludge and solid

layers in the Domtar Tank. This water was characterized during the Material Sampling

Program – Coke Ovens by Cape Breton Environmental Group (CBEG) in 1997. TankContents Removal and Disposal Contractor will remove and treat the water from the

Domtar Tank and discharge the treated water to the municipal sanitary sewer. The

treatment system will include, at a minimum, the following process steps:

Dual bag filtration, operated in series for suspended solids removal; and,

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Dual aqueous phase activated carbon units operated in series, for removal of organic

compounds and final polishing.

The discharge from this treatment process will be required to meet the criteria presented

in Table 4.3. The contractor will be required to initially demonstrate that the treatmentsystem can and has been able to achieve the discharge criteria. Accordingly, the selected

Contractor will be required to treat and then containerize a minimum of 40,000 litres of

treated wastewater, sample and analyze the treated wastewater, and confirm that the

discharge criteria has indeed been met. Once the selected contractor has demonstrated

that the discharge criteria has been achieved, the selected contractor will be allowed to

directly discharge treated wastewater that has been processed by the prescribed

treatment system to the municipal sanitary sewer via a temporary forcemain. Samples

of treated wastewater will be collected and analyzed for the discharge criteria daily,

with analytical results available from the analytical laboratory, within 48 hours after

sample collection. These samples will be collected after the second carbon unit in the

treatment series. As well, breakthough after the first (primary) carbon unit a selected

“compound of concern” after the first (primary) carbon unit will be monitored daily,

utilizing a field kit. The selected “compound of concern” will be determined based on

relative abundance in the influent concentration and ease and reliability of the field test

for the compound. This compound will be determined at the onset of treatment

operations. Once breakthrough of the selected compound has occurred, the contractor

will be required to discontinue treatment and then replace the second (secondary)

carbon unit with a fresh carbon unit, and replace the primary carbon unit with the

secondary carbon unit (i.e. the secondary unit becomes the new primary unit, and thefresh unit becomes the new secondary unit). The spent carbon will be characterized and

disposed of in a manner consistent with its characterization. Similarly, should the

discharge criteria be found to be exceeded, then the carbon units will also be replaced as

described above.

The selected contractor will also be given the option to either treat on the Site any waters

present within the other tanks (i.e. Benzol Tank and Benzol Area Tank) or transport and

dispose of the waters at a permitted off-site facility. Should the selected contractor elect

to treat on the Site the water present within the other tanks, then the procedures and

limits described above would be required for each tank.

Influent water quality will be monitored through a visual opacity test. When influent

water becomes very murky removal and treatment will be suspended, and solid/sludge

removal activity will commence.

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Pressures across each of the bag filter units will be measured and monitored each hour

of operation. Should the pressure drop across a bag filter suddenly decrease, the

treatment system influent will be turned off, the bag filter will be replaced, and the

system will be placed back into operation. Should the pressure drop across a bag filter

become too great, then the bag filter will be replaced.

All piping in the system will be surficial. Piping will be fabricated from the longest

continuous lengths feasible so as to minimize the number of connections. As the work

will be conducted in non-freezing conditions, frozen pipes are not considered to be an

issue. However, as freezing weather can be encountered in early spring or late fall, the

temporary water treatment system will be housed in an enclosure that can be heated, to

protect the carbon units from freezing. All piping will be visibly inspected at least twice

per shift for leaks, kinks and other deleterious conditions. If any leakage is observed,

then the discharge will be suspended until the leaks are repaired. The forcemain will be

direct laid on the surface, and will be provided with a steel containment at locations ofvehicle traffic. All pipes will be emptied and drained at the end of each working day.

The influent piping will be removed to prevent back-siphoning.

4.2.1.3 SANITARY WASTEWATERS

Wastewater generated at the site support area will include both sanitary wastes and

wash water from the worker wash house (worker showers). This flow will be piped

through piping to a holding tank, in which a submersible sewage grinder pump

operating on a level switch control, will transfer the wastewater to the existing

municipal sanitary sewer system through a new buried forcemain. No discharge criteria

will be applied to this wastewater stream.

As an additional control measure a high level alarm within the tank that will be

interlocked with the portable water supply. When the tank level becomes higher than

normal, the water supply to the wash house and the sanitary facility will be

automatically turned off. The pressure on the discharge forcemain will also be

monitored weekly. Pressure rise could indicate a blockage and lower than normal

pressure could indicate a line break. The discharge point of the sanitary forcemain will

be visually inspected weekly to confirm that the sanitary flow is indeed beingdischarged into the municipal sewer system.

4.2.1.4 VEHICLE WASH WASTEWATER

The concrete vehicle wash pad will be used to wash the exterior of vehicles prior to

leaving the site to ensure that no site materials are transferred and deposited off the site

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from vehicles. The vehicle wash pad will be of concrete construction, with sumps being

an integral cast-in feature. Wash waters will be transferred from each sump into a wash

water holding tank. From the wash water holding tank, the wash waters will be treated

in a wastewater treatment system. The wastewater treatment system will include:

1. Grit and oil water separation within the sumps;

2. Dual bag filtration, operated in series for suspended solids removal; and,

3. Dual aqueous phase activated carbon units operated in series, for removal of organic

compounds and final polishing.

The treatment system will be housed within a heated structure to protect the treatment

components. The treatment system will be located on a concrete pad that will be

provided with continuous perimeter curbing. The pad will be sloped such that any

spills or overflows will be directed to the concrete vehicle wash pad.

Adjacent to the wash pad and to the treatment housing will be a wash water storage

tank. The tank will be of polyethylene construction with a closed top and will be

situated on a concrete pad that has continuous curbing and is sloped such that water

will drain to the concrete vehicle wash pad. The concrete of the containment will be

coated with an epoxy coating that will protect the concrete.

A series of baffles within each sump of the wash pad will provide for oil-water

separation and heavy sediment removal. The water will be transferred from the

overflow side of the baffles to the wash water storage tank. The storage tank will be

equipped with a high water level alarm interlocked with the wash pad sump pumps to

prevent the pumps from operating when the storage tank is full. Water from the storage

tank will be passed through a series of bag filter units with progressively smaller mesh

size, followed by passing the water through dual activated carbon units operating in

series. Treated wastewater will than be discharged through a forcemain to the sanitary

sewer. The inlet to the treatment system will be a submersible pump suspended from

the top of the storage tank. The treatment system will be manually operated in a batch

mode whenever sufficient water quantity accumulates.

Pressures on each side of the bag filter units will be measured and monitored hourlyduring operation. Should the pressure drop across a bag filter suddenly decrease, the

treatment system influent will be turned off, the bag filter will be replaced, and the

system will be placed back into operation. Should the pressure drop across a bag filter

become to great, then the bag filter will be replaced. Similarly, pressure drop across the

carbon units will be monitored.

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This wastewater is anticipated to contain only low levels of contaminants and as such

will be subject to the discharge criteria presented in Table 4.4. The criteria are the same

as those presented in Table 4.3 however, considering the smaller volume of water and

the lower level of contamination, a shorter list of contaminants for routine monitoring is

proposed. The first 10,000 litres of treated wastewater will be containerized, sampled

and analyzed for the discharge criteria presented in Table 4.4 prior to discharge. Upon

confirmation that the treated wastewater meets the discharge criteria, wastewater

treated in the prescribed treatment system will then be directly discharged via a

pressure sewer to the sanitary sewer. The discharge will then be tested bi-weekly (i.e.

every two weeks), for verification that the discharge criteria presented in Table 4.4 is

being met. Analytical results will be provided to the PMC within 48 hours from the

project analytical laboratory and to NSDEL with an additional 24-hours.

Breakthough of a selected compound of concern after the first (primary) carbon bed will

be monitored daily, utilizing a field kit. The selected compound of concern will bedetermined based on relative abundance in the influent concentration and ease and

reliability of the field test for the compound. This will be determined at the onset of

treatment operations. Once breakthough of the selected compound has occurred,

operation of the treatment system will be discontinued and the secondary carbon unit

will be replaced with a fresh carbon unit, and the first (primary) carbon unit will be

replaced by the second carbon unit (i.e. the secondary unit becomes the new primary

unit, and the fresh unit becomes the new secondary unit). The spent carbon will be

characterized and disposed of in a manner consistent with its characterization.

Similarly, should the discharge criteria be found to be exceeded, then the carbon units

will also be replaced with fresh carbon units.

Satisfactorily treated effluent will be discharged to the sanitary sewer system through a

buried forcemain. The forcemain will be constructed to the municipal standards and

will be buried below the frost line. A pressure gauge will be located on the discharge

pipe. The pressure gauge will be monitored hourly to confirm that the forcemain is

operating under pressure and that no leaks are occurring. The forcemain effluent at the

manhole will be monitored for apparent changes in water quality and for flow

verification twice per shift when wastewater treatment operations are occurring.

4.2.1.5 TANK CLEANING WASTEWATER

The contractor will give the option to either treat on-site any wastewater generated from

the tank cleanings or to transport and dispose of the generated tank cleaning

wastewaters at an approved and permitted off-site facility. Should the Contractor elect

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to treat the tank cleaning wastewater on the site, then the procedures prescribed for

Section 4.2.1.2 above would be required for each tank.

Tank cleaning wastewater will be generated after all of the solid materials have been

removed from the tank. This wastewater will be transferred to a temporary holding

tank. The holding tank will be provided with secondary containment. Wastewater from

the holding tank will be processed through the treatment system described in Section

4.2.1.2 above, and will then be transferred to the effluent holding tank.

4.2.1.6 EQUIPMENT DECONTAMINATION WASTEWATER

Removal and disposal of tank contents wastewater generated during cleaning of

equipment that has had direct contact with Site contaminants will be containerized and

characterized. The equipment will be cleaned at the location where it was being used.

The following procedure will be used to containerize decontamination wastewaters. Atemporary cleaning station will be set up adjacent to the work area. This station will

include a bermed and HDPE lined cleaning pad setup with a sump. The equipment will

be power washed utilizing a high-pressure, low flow steam cleaner. Wash waters

accumulated in the sump will be transferred into a suitable container using either a

vacuum truck or a sump pump. Wastewaters will be characterized using either

analytical means, or if associated with a specific activity, will be characterized similar to

the waste of that activity. Should the analytical results indicate that the equipment wash

water is amenable to on-site treatment and the contractor elect to do so, then the

wastewater will be transferred to the vehicle wash water holding tank described in

Section 4.2.1.2 above for treatment and disposal. If the wastewaters are not amenable to

on-site treatment, then the wastewater will be directly transferred into a permitted

wastewater haulage vehicle that will transport the wastewater to a licensed and

permitted industrial wastewater treatment facility.

The contractor for the Removal and Disposal of Tank Contents will be given the option

to either treat on the site any wastewater generated from the equipment

decontamination process or to transport and dispose of the decontamination process

wastewater off the site at an approved and permitted facility. Should this Contractor

elect to treat the equipment decontamination wastewater on the site, then theprocedures prescribed for Section 4.2.1.2 above would be required for each tank of

equipment decontamination wastewater generated and stored on-site.

The contractors for all other projects will be permitted to process equipment

decontamination wastewater through the Vehicle Wash Pad Treatment System. The

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procedures described in Section 4.2.1.4 will be then be applied for each tank of

equipment decontamination wastewater.

4.2.1.7 POTENTIAL WATERS CURRENTLY WITHIN FOUNDATIONS OFSTRUCTURES OR GENERATED FROM WETTING OPERATIONS

During the demolition of the above ground structures water within the foundations may

be encountered and in order to effectively demolish the structures it may be necessary to

attempt to remove these waters. If deemed necessary, the waters will first be tested to

characterize the water. In addition, water will be used through the Project for the

control of dust and particulate and excess water may be generated. If treatment is

determined to be necessary then the water will be treated through a wastewater

treatment system similar to the one discussed in Section 4.2.1.4 and discharged to the

sanitary sewer. The discharge will be required to achieve the criteria presented on Table

4.5. The treated wastewater will be tested daily while in operation.

4.2.1.8 WASTEWATER DISCHARGE AND DISPOSAL – RESPONSIBILITIES

Responsibility for the wastewater treatment system operation will rest with the selected

contractor performing the work. In addition to routine operation of the systems, these

responsibilities will include ensuring system(s) integrity, immediate repair of any leaks,

immediate clean up of any spills or leaks, and reporting findings of routine system

operational checks and discharge flows. The PMC will collect and have analyzed

treatment system influent and effluent samples as described in the above sections. The

PMC will prepare operational and analytical summary reports for submission toNSTPW on a monthly basis.

4.2.2 SOLID WASTE DISPOSAL

As part of each activity of the project, solid waste material will require disposal. A flow

chart illustrating material disposal is presented in Figure 4.2. Anticipated waste streams

include non-hazardous, non-dangerous waste such as wood, bricks and other debris;

hazardous waste material; coal; coke; sulphur; and steel. The measures for tracking all

waste materials at the Site will be similar. Objectives of the solid waste management

program are to ensure that non-hazardous wastes are not needlessly added to the

hazardous waste stream, and more importantly, to ensure that hazardous wastes are not

inadvertently added to the non-hazardous waste stream.

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4.2.2.1 SOLID WASTE DISPOSAL – CONTROL MEASURES

Control measures to prevent the cross-contamination of waste streams will include the

identification and delineation of the various waste materials at the Site. Materials that

have not been previously characterized will be sampled and analyzed for waste

characterization parameters.

Non-hazardous wastes will be either loaded directly into waste haul trucks at the

location of the waste, or will be transferred to a staging area adjacent to the access

roadway. All non-hazardous waste, coal, coke, sulphur and steel will be covered with a

sealed tarpaulin. All waste loading and transfer operations will be monitored in

accordance with the AMP. Hazardous waste materials will, to the extent possible, be

loaded directly into waste haul units. Solid waste haul units will be licensed and

permitted for hauling the type of material to be loaded. Furthermore, all hazardous

waste loads will be lined with polyethylene sheathing and will be covered with a sealedtarpaulin. All trucks leaving the Site will be cleaned and inspected at the vehicle wash

pad. Appropriate shipping papers, including waste manifests, bill of lading and

inspection forms will be completed prior to a waste load leaving the Site. Each load of

waste will be given a unique identification number for tracking purposes. Each type of

waste stream will have a unique numerical prefix that will allow for distinction of the

type of waste.

Only those trucks that have been pre-authorized will be allowed on the Site. To avoid

congestion at the loading areas and at the vehicle wash pad, trucks will be scheduled for

arrival at the Site. Trucks that are not ready to be loaded, either due to early arrival at

the Site or if loading of previous trucks takes longer than anticipated, will not be

allowed to wait on Site, but will be staged at a marshalling area near the Site support

area.

Prior to recommending approval and acceptance of a contractor’s selected waste

disposal facility, the PMC may conduct a facility audit to ensure that the selected facility

is not only operating in compliance with their operating permit, but also is appropriate

for the disposal of a given type of waste. The facility audit will be documented and

provided to NSTPW.

4.2.2.2 SOLID WASTE DISPOSAL – RESPONSIBILITIES

The PMC will be responsible for providing initial waste profiling results. The selected

contractor will be responsible for ensuring that all waste materials are handled in a

proper manner that is consistent with all applicable regulations. The selected contractor

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will be required to provide sufficient liability insurance to protect all parties in the event

of a mishap. The PMC will inspect each vehicle prior to the vehicle leaving the Site. The

selected contractor will be responsible for providing the correct forms for each waste

shipment.

4.2.2.3 SOLID WASTE DISPOSAL - MONITORING

Monitoring of solid waste will include the continuous verification that waste materials

are being handled and/or loaded with similar waste materials. Tracking of waste loads

will be performed for each waste load: from the setting up of an appointment for

loading a truck on Site, to the verification of what is being loaded in a truck, to

inspecting the loaded and cleaned truck, to obtaining weigh scale receipts and disposal

facility receipts. A monthly summary providing a status report of volumes of waste

transported from the Site will be provided to NSTPW.

4.2.3 REMOVAL AND DISPOSAL OF TANK CONTENTS

4.2.3.1 DOMTAR TANK ENCLOSURE

The Domtar Tank will be enclosed during the removal of contents. An induction fan

will be used to maintain a negative pressure in the building. Air ventilated by the fan

will be passed through a series of two granular activated carbon vessels to ensure

removal of at least 90 percent of organic contaminants in the evacuated air through each

carbon vessel (i.e. 90 percent in the first followed by 90 percent removal in second). Fourbuilding volumes will be ventilated per hour. Air quality in the building may still

exceed acceptable work place levels requiring use of respirators or self contained

breathing apparatus. Air emitted from the granular activated carbon vessels will be

periodically checked with a Photoionization Detector (PID) to ensure that organic

concentrations are not more than 10 percent of the concentrations within the building.

A continuous logging PID will be installed at both the influent and effluent air streams

of the first carbon unit and on the effluent air stream of the second carbon unit. The

logging device will record the 15-minute rolling average of the total concentration of

VOC in the air streams. The logging device will be equipped with an alarm to notify

project personnel when the VOC concentration has exceeded allowable limits.

The 15-minute rolling average VOC concentration of the air emitted from the first

granular activated carbon unit will not be permitted to exceed the lower concentrations

of:

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1. 10 percent of the influent concentration to the first carbon unit; or

2. 10 ppm

for 15 continuous minutes, and the 15-minute rolling average VOC concentration of the

air emitted from the second granular activated carbon unit will not be permitted toexceed the lower concentration of:

1. 10 percent of the influent concentration to the second carbon unit; or

2. 1 ppm

for 15 continuous minutes.

4.2.3.2 CONTROLS SPECIFIC TO REMOVAL AND DISPOSAL OF TANKCONTENTS

The following controls will be placed upon the Contractor for the removal and disposal

of the tank contents:

Rate of removal of sludge from the Domtar Tank will be limited to 138 m3/day

(based on volume of sludge prior to stabilization, if required);

Equipment directly in contact with the waste material will be decontaminated prior

to leaving the work area by a temporary equipment decontamination facility

adjacent to the Domtar Tank and within the temporary enclosure;

Vehicle speeds will be limited to 15 km/hr while on site;

Waste materials will be sampled and analysed as follows:

Waste Stream Required Analyses Testing Frequency

1. Tank solids, sediments, and

sludge

Waste Characterization for

off-Site disposal

Confirmatory sampling

As required by off-

Site disposal facility

Not less than one

per 500 tonnes

2. Standing water in tanks Confirm treatable on Site Once for each tank

3. Tank cleaning and

decontamination

wastewater

Off-Site disposal criteria

or,

Confirm treatable on Site

As required by off-

Site disposal facility

Once every storage

tank

4. Wastewater treated on Site Per discharge permit Per requirements of

discharge permit

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If vacuum type of pumps is used to remove the waste material the vacuum unit will

be capable of unloading vacuumed material from its holding compartment directly

into suitable transport units. The vacuum unit will have an exhaust that is

controlled through a three stage filter prior to release the three filtering stages shall

be coarse screening followed by HEPA filter followed by vapor phase activated

carbon absorption;

Sludge and a solid phase waste material will be disposed at an approved licensed

waste disposal facility;

All waste materials will be transported in licensed transport vehicle in accordance

with the Federal Transportation of Dangerous Goods Act and Regulations and the

Provincial Dangerous Goods Act and Regulations. If the material is transported to

the United States the appropriate and applicable federal and state transportation

regulations will apply;

All disturbed areas will be seeded and mulched to stabilize the disturbed areas.

4.2.4 STACK DEMOLITION

4.2.4.1 CONTROLS SPECIFIC TO THE DEMOLITION OF STACKS

The following controls will be in place for the demolition of the stacks:

Interior brick lining of the stacks will be dismantled in the wet within concrete

exterior of the stacks. The brick will be allowed to fall within the stack and will beremoved from the base of the stacks;

The concrete exterior of the stack will be dismantled in sections by using a wet

cutting method.

4.2.5 BULK MATERIAL REMOVAL

4.2.5.1 CONTROLS SPECIFIC TO THE BULK MATERIAL REMOVAL

The controls to the bulk material removal are as follows:

Coal and Coke removal activities will not be concurrent with other activities of the

Demolition of Above Ground Structures and Removal of Residual Material Project;

Each of the coal and coke removal activities will not be concurrent with each other;

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A six inch layer of soil will be placed over all disturbed area and the area will be

seed and mulched to stabilize the area to prevent wind and water erosion;

The portion of the sulphur pile not actively being loaded will be covered with

polyethylene sheeting;

Rate of removal of the coal and coke will be limited to 276 m3 per day;

The coal, coke and sulphur will be wetted prior to removal;

No excavation below water table;

A buffer of coal and coke will be left in place in the base of the respective stockpiles.

4.2.6 DEMOLITION OF STRUCTURES

4.2.6.1 CONTROLS SPECIFIC TO THE DEMOLITION OF STRUCTURES

The controls to the Demolition of Structures are as follows:

Workers will manually remove transite siding under wet conditions;

Power wash and vacuum by-product building structure to remove accumulated

dust.

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5.0 MONITORING DATA REPORTING AND EVALUATION

5.1 RESPONSE LEVELS

Within the AMP are action levels that will be used during routine and enhanced

monitoring of Site activities. As described in the AMP, routine air monitoring will be

conducted during all Site activities. Enhanced air monitoring will be initiated when a

routine work zone action level is exceeded. Enhanced air monitoring will be continued

until the conditions have returned to below routine action levels. Should Site conditions

be such that enhanced air monitoring indicates the continued non-attainment of AAC

due to Site activities, appropriate site activities will be suspended. NSTPW will be

notified when changes to the level of air monitoring are required. A follow up

notification will be provided after the first round of enhanced monitoring. The

notification will include a description of site activities, the real-time air monitoring

results, the control measures implemented, along with the timing of the next notificationand what information will be available at that time.

5.2 REPORTING

The results of routine and enhanced air monitoring results will be collated and

assembled in a report by the consultant responsible for implementing the AMP and will

be provided to NSTPW and the PMC daily, for the previous day’s air monitoring. The

daily air monitoring report will include a summation of all air monitoring conducted, a

summation of the air monitoring results for short term air monitoring, a description ofactual daily activities and a copy of the weather station report. Also included will be a

description of control and contingency measures that were invoked and an evaluation of

their short-term effectiveness, together with what notifications of action level

exceedences were given. The report will also include results of the long term monitoring

that was conducted. If the turn around time to obtain the long term monitoring results is

several days, the reported long term monitoring results will be for activities conducted a

few days earlier. An evaluation of the long-term results compared with the short-term

results will be included with the long-term results.

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6.0 ENSURING COMPLIANCE

The key to ensuring compliance with municipal, provincial and federal regulations is to

clearly identify those regulations that will apply and regulations that may apply early in

the design process. Identification will ensure that any and all regulatory requirements

can be resolved and incorporated into the design of the project such that they are a

specific requirement of the contract. All regulators will be consulted to identify potential

regulatory issues prior to the final design of the Project. Once issues are identified,

enforcement of the regulatory requirements must become a contractual obligation.

Failure to perform could be grounds for termination of a contract. A resident engineer

retained during the course of the project who will be responsible for quality control and

will inspect of regulated work activities and who will report accordingly.

6.1 INSPECTION

A resident engineer will be retained to conduct full time engineering oversight of the

Project during its implementation. The role of the resident engineer will be to ensure

that the contractors initiate and complete work activities in accordance with contract

documents, specifications, drawings, site specific EMP, Project-specific HASP, Project-

specific Contingency and Emergency Response Plan, and all municipal, provincial and

federal regulations. Through the use of a resident engineer, any changes required to the

work methods as a result of regulatory issues can be identified and implemented, in the

form of a field order or change order to the contract.

6.2 REPORTING

To provide effective reporting of routine project activities and results, reports will be

made periodically of timely and relevant information as each activity progresses.

6.2.1 WEEKLY PROGRESS REPORTING

The PMC will prepare a weekly summary report that will be submitted to the ContractManager and will summarize progress to date, quality control/quality assurance

documentation and documentation which ensures compliance with all regulations (i.e.

manifests, permits, approvals, authorizations, etc.)

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7.0 PUBLIC PARTICIPATION

Throughout the entire project, public participation in the decision-making process has

been encouraged and supported. Opportunities for public participation and input to the

project activities have included information sessions, presentations to JAG, and public

open houses. JAG has made a commitment to notify residents adjacent to the Site prior

to the start of on-site activities.

Data generated during Site activities will be available to the public through JAG.

Consistent with the open philosophy of JAG, continued public participation in an open

forum that will address legitimate questions and concerns will be established and

maintained throughout the project activities. This forum will include a review of the

activities conducted as well as planned, along with monitoring results.

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8.0 REGULATORY AND OTHER APPROVALS

PROVINCIAL

•

Dangerous Goods Transportation Regulations• Activities Designation Regulations – NSDOE has indicated that work conducted on

the site requires approval by NSDOE under the Activities Designation Regulations.

• Air Quality Regulations – these should be addressed by the AGRA Site Separation

Zone Report and/or by the Air Monitoring Plan.

• Dangerous Goods Management Regulations – Will require authorization for the

temporary storage of dangerous goods at the site. These will include

decontamination water, construction-derived waste such as solids from the

decontamination process.

• Asbestos Waste Management Regulations – All asbestos-containing materials will be

handled in accordance with this regulation.

• Emergency Spill Regulations – Covered by the Emergency Response and

Preparedness Plan and Site-specific HASP

•

Nova Scotia Occupational Health and Safety Regulations

FEDERAL

• Dangerous Goods Transportation Regulations. All waste material transported from

the Site will be managed and handled as required to comply with the Federal

Dangerous Goods Transportation Act.•

Migratory Bird Convention Act (1994)

• Fisheries Act

• Canadian Environmental Protection Act.

MUNICIPAL

• Noise

• Land-use restrictions

• Building Permits

•

Sewer By-Laws

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9.0 SUMMARY REPORTS

Following the completion of each Project, the resident engineer will be required to

submit to NSTPW an overall summary report which will document the quantity of

materials removed and disposed, ultimate disposal type and location, all manifests, bills

of lading, approvals, permits, and authorizations. The Summary Report will also

document the condition of the site at the completion of the project. The Summary

Report will evaluate the effectiveness of the mitigation measures and if required suggest

recommended modifications.

The Summary Report will also assess the accuracy of the environmental assessment

predictions for the Project.

The Summary Report will also consider such issues as:

Was the selected contract process the right method?

Adequacy of the design, plans and specifications

Communication issues

Health and safety issues

Review of remediation processes, products and equipment

9.1 EVALUATION OF EFFECTIVENESS OF MITIGATION (CONTROL)

MEASURES

Control measures will be monitored for effectiveness and appropriateness. If a control

measure is found to be ineffective, then the control measure will be evaluated for future

use. It is anticipated that an ineffective control measure would be modified, or other

types of control measures will be utilized, based on the cause of the control measure

being ineffective. For control measures that are invoked as a part of a response to real-

time air monitoring, a real-time determination of their effectiveness can be made,

resulting in essentially a real-time evaluation. This type of evaluation is included in the

AMP.

Other control measures will be evaluated as they are invoked. For example, containment

booms and erosion control features can be visually inspected after a rain event to check

for continued containment and for erosion protection, with repairs, including upgrading

of features, made to each if found to be ineffective. For each planned activity, a checklist

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of control measures will be prepared that will include prescribed frequencies for control

measure evaluation. A copy of completed checklists will be provided to NSTPW.

9.2 ACCURACY OF ENVIRONMENTAL ASSESSMENT PREDICTIONS

Consistent with the modeling completed for the Separation Zones Report, Site activities

have been carefully planned to control the expected impact to the environment. By only

monitoring and measuring singular activities, actual outcomes should be consistent with

predicted outcomes. The effect that control measures will have on a given activity can be

effectively evaluated as part of the AMP.

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10.0 MODIFICATIONS TO THE ENVIRONMENTAL MANAGEMENT PLAN

As indicated in the introduction section of this EMP report, the EMP is intended to be a

dynamic document that will evolve and be updated to meet the changing needs of the

Project as it proceeds through each element. Modifications to the EMP may arise from

either a result of Site activities, or from external concerns.

For example, should a non-routine event that requires the implementation of

contingency measures occur as a result of following routine procedures, then the routine

procedures will be evaluated and modified. Such modification will be made to the

appropriate part of the EMP, or to the attached AMP, with consultation with NSTPW,

Nova Scotia Department of Environment and Labour and Environment Canada. The

modifications, once adapted, will also be monitored to ensure continued effectiveness.

External influences to the EMP might include changes to legislation that require specific

evaluations or modifications to procedures being utilized. Externally driven changes

will also be reviewed with NSTPW prior to being implemented.

Modifications to procedures will be communicated to all Site personnel, as well as to

external personnel involved in emergency response. The revised EMP will be distributed

along with instructions to discard the previous version of the EMP.

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Table 4.1

Mitigation and/or Control Measures Summary

Muggah Creek Remediation Project

Sydney, Nova Scotia

Act i v i t y M i t i gat i ve and/or Cont rol M easures Act i on Level or Cri t er i a Frequency

1. Infrastructure

- includes construction of site -dust and particulate control (see Table 2.1 of AMP) -continuous during work activity

support facilities, new access or as required

road, vehicle wash pad and -air monitoring (see Table 2.1 of AMP) -continuous during work activity

wastewater handling andtreatment system -wind speed -avg. wind speed >35 km/hr -continuous during work activity

or gusts >70km/hr

-erosion and sediment control -n.a. -weekly monitoring or as required

-emergency and/or spill -spills-Emergency Spill Reg. -n.a.

2. Tank Contents -temporary enclosure (Domtar Tank only) -n.a. -n.a.

-air emission treatment (Domtar Tank only)

-minimum 90% removal through each of

two carbon vessels in series -daily

-dust and particulate control (see Table 2.1 of AMP) -continuous during work activity

or as required

-air monitoring (see Table 2.1 of AMP) -continuous during work activity

-wind speed -avg. wind speed >35 km/hr -continuous during work activity

or gusts >70km/hr

-erosion and sediment control -n.a. -regular monitoring as required

-wastewater treatment

- vehicle wash pad wastewater (see Table4.4 of EMP) -bi-weekly while in operation

- sanitary wastewater -none -n.a.

- Domtar Tank standing water (see Table 4.3 of EMP) -daily while in operation

- equipment decontamination

wastewater (see Table 4.3 of EMP) -daily while in operation

- tank cleaning wastewater (see Table 4.3 of EMP) -daily while in operation

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Table 4.1



Sydney, Nova Scotia


3. Stacks -dismantling of stacks -n.a. -n.a.

-dust and particulate control (see Table 2.1 of AMP) -continuous during work activity

or as required



or gusts >70km/hr



- vehicle wash pad wastewater (see Table 4.4 of EMP) -bi-weekly while in operation


- equipment decontamination wastewater (see Table 4.4 of EMP) -daily while in operation4. Coal, Coke, Sulphur, Cooling

Grids Removal -dust and particulate control (see Table 2.1 of AMP) -continuous during work activity

or as required



or gusts >70km/hr





- equipment decontamination wastewater (see Table 4.4 of EMP) -daily while in operation

- rate of coal and coke removal -276 m3/day or less -n.a.

-buffer of coal or coke remaining - n.a -n.a-a six inch layer of soil with seed and mulch

placed over distributed areas - n.a -n.a

5. Demolition of Above Ground

Structures and Removal of Misc.Debris -dust and particulate control (see Table 2.1 of AMP) -continuous during work activity

or as required



or gusts >70km/hr



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Table 4.1



Sydney, Nova Scotia




- equipment decontamination wastewater (see Table 4.4 of EMP) -daily while in operation

6. By-Products Building

Demolition and Disposal ofSulphur and Cooling Grids -dust and particulate control (see Table 2.1 of AMP) -continuous during work activity

or as required



or gusts >70km/hr





- equipment decontamination wastewater (see Table 4.4 of EMP) -daily while in operation-transite siding removed manually under

wet conditions -n.a -n.a

-by-products building power washed prior

to demolition -n.a -n.a

-a six inch layer of soil with seed and mulch

placed over distributed areas - n.a -n.a

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Table 4.2Emergency Response ResponsibilitiesMuggah Creek Remediation Project

Sydney, Nova Scotia

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Organization /Agency Responsibility

Police Site control, evacuation, traffic control

Fire Emergency Response (fire, injury, spill etc.)

Ambulance Medical Aid

CBRM Emergency MeasuresCoordinator

Coordination of emergency measures

Hospital Medical treatment (i.e. injury)

NSDEL Emergency support and health and safety

Transport Canada Transportation emergencies

Environment Canada Emergency Support

Coast Guard Emergency support

PMC Emergency Support

Contractor Emergency Support

JAG Public Information

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Table 4.3

Discharge Criteria for Wastewater from Tanks, Temporary Decontamination Pad, and Tank Cleaning


Sydney, Nova Scotia

Aluminum 50.0 50.0

Antimony 5.0 5.0

Arsenic 1.0 1.0

Barium 5.0 5.0

Bismuth 5.0 5.0

Cadmium 0.1 1.0

Total Chromium 4.0 4.0

Copper 1.0 1.0

Cobalt 5.0 5.0

Flourides 10.0 10.0

Iron 50.0 50.0Lead 2.0 2.0

Manganese 5.0 5.0

Mercury 0.1 0.1

Molybdenum 5.0 5.0

Nickel 2.0 2.0

Phosphorus 30.0 30.0

Selenium 5.0 5.0

Silver 2.0 2.0

Tin 5.0 5.0

Titanium 5.0 5.0

Vanadium 5.0 5.0

Zinc 3.0 3.0

Cyanide 2.0 2.0

Sulphates (S04-) 1500.0 1500.0

Sulphide (H2S) 2.0 2.0

Benzene 0.11 --

Ethylbenzene 0.025 --

Phenols 1.0 1.0

PCBs (Total) 0.0001 --

Total PAHs 0.100 --

Toluene 0.20 --

Xylenes (Total) 0.50 --

COD 100 100

TSS 300 300

pH 6.5-9.0 --

Total Petroleum Hydrocarbons

Total TPH 15 --

Organics

Miscellaneous

HRM WastewaterDischarge By-law No.

W-100

Inorganics

Proposed Discharge Criteriamg/L

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Table 4.4

Discharge Criteria for Wastewater from Vehicle Wash Pad


Sydney, Nova Scotia

Benzene 0.11 --


Total PAHs 0.100 --

Toluene 0.20 --


COD 100 100

TSS 300 300

pH 6.5-9.0 --


Total TPH 15 --

Organics

Miscellaneous

HRM WastewaterDischarge By-law No.

W-100

Proposed DischargeCriteria mg/L

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Table 4.5

Discharge Criteria for

Wastewater from Foundations and Wetting Operations


Sydney, Nova Scotia

Aluminum 50.0 50.0

Antimony 5.0 5.0

Arsenic 1.0 1.0

Barium 5.0 5.0

Bismuth 5.0 5.0

Cadmium 0.1 1.0

Total Chromium 4.0 4.0

Copper 1.0 1.0

Cobalt 5.0 5.0

Flourides 10.0 10.0

Iron 50.0 50.0

Lead 2.0 2.0

Manganese 5.0 5.0

Mercury 0.1 0.1

Molybdenum 5.0 5.0

Nickel 2.0 2.0

Phosphorus 30.0 30.0Selenium 5.0 5.0Silver 2.0 2.0

Tin 5.0 5.0

Titanium 5.0 5.0Vanadium 5.0 5.0

Zinc 3.0 3.0

Cyanide 2.0 2.0

Sulphates (S04-) 1500.0 1500.0

Sulphide (H2S) 2.0 2.0

Benzene 0.11 --


Total PAHs 0.100 --

Toluene 0.20 --


COD 100 100

TSS 300 300

pH 6.5-9.0 --


Total TPH 15 --

Miscellaneous

Proposed Discharge

Criteria mg/L

HRM Wastewater Discharge

By-law No. W-100

Inorganics

Organics

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M.H.14

M.H.13

M.H.15

M.H.16

M.H.17

M.H.18

M.H.19

M.H.20

No.6 BATTERY STACK

No.5 BATTERY STACK

X

X

X X

X

X

X

X

X

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T E A K S T R E E T

T O L A N

D F I L L

COKE OVENS SITE

MULLINS BANK

SYSCO

SYDNEY

BRICK RUBBLE

COAL STORAGE AREA

COKE BREEZE

BENZOL PLANT AREA

No.6 COKE OVEN BATTERY

BYPRODUCTS BUILDING

COOLING GRIDS

SULPHUR BUILDING

BENZOL TANK

DOMTAR TANK

D O M T A R B R O O K

C N R A I L W

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V I C T O

R I A R O A D

C A G N E Y B R O O K

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S T R E E T

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LANDFILL

SITE SECURITY TRAILER

figure 1.1

SITE FEATURESENVIRONMENTAL MANAGEMENT PLAN

14458-35(024)GN-SY005 APR 18/2001

800 40 120M

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D Task Name Duration

1 1.0 CEAA Screening 0 days

2 2.0 Infrastructure 41 days

3 2.1 Award Tender 0 days

4 2.2 Construct 36 days

5 2 .2 .1 P re pa re H ea lth & S af ety P la n 1 0 d ays

6 2 .2 .2 De ve lo p S it e S pe ci fi c E nv ir on me nt al Ma na ge me nt Pl a 1 0 d ay s

7 2.2.3 Prepare Shop Drawings 20 days

8 2.2.4 Product Development 20 days

9 2.2.5 Mobilize 5 days

10 2.2.6 Construct Access Road 16 days

11 2.2.7 Construct Decontamination Facility 16 days

12 2.3 Contract Closeout 5 days

13 3.0 Tank Contents Removal 91 days


15 3.2 Remediate 86 days

1 6 3 .2 .1 P re pa re H ea lt h & S af et y P la n 1 0 d ay s

1 7 3 .2 .2 D ev el op S it e Sp ec if ic E nv ir on me nt al M an ag em en t Pl a 1 0 d ay s


19 3.2.4 Erect Enclosure 20 days

20 3.2.5 Remove and Dispose Tank Contents 51 days


22 4.0 Demolition of Stacks 62 days


24 4.2 Demolition 57 days




28 4.2.4 Demolish Stacks and Dispose of Materials 41 days


30 5.0 Bulk Mater ial Removal - Coal /Coke/Cooling Gr ids/Sulfur 131 days


32 5.2 Bulk Material Removal and Disposal 101 days




36 5.2.4 Removal and Disposal 85 days

37 5.2.4.1 Remove and Dispose of Coal 40 days

38 5.2.4.2 Remove and Dispose of Coke 30 days

39 5.2.4.3. Remove and Dispose of Sulpher 15 days

40 5.2.4.4 Remove and Dispose of Cooling Grids 5 days


42 6.0 Demol it ion and Debr is Removal (Weather Dependant) 67 days


44 6.2 Demolition 62 days

45 6 .2 .1 Prep are He alth & S afety P lan 10 d ays

4 6 6 .2 .2 D ev el op S it e S pe ci fi c E nv ir on me nt al M an ag em en t 1 0 d ay s


48 6.2.4 Demolish and Dispose of Materials 40 days


30/03

02/05

31/05

31/05

12/09

12/12

Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12 Mon

Task Milestone Summary

Wed 25/04/01 Page 1

FIGURE 2.1

MUGGAH CREEK REMEDIATION

(Note: 5 days = 1 week)

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E Q UI P ME NT

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I ON

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C OA L

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14458 (24)

APPENDIX A

AIR MONITORING PLAN

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14458 (24) Appendix A 1 CONESTOGA-ROVERS & ASSOCIATES

TABLE OF CONTENTS

Page

1.0 INTRODUCTION ....................... ........................... ........................... ........................... ......3

2.0 AIR MONITORING PROGRAM.......................... ........................... ........................... ......52.1 OVERVIEW......................................................................................................52.2 RESPONSIBILITY............................................................................................62.3 SHORT-TERM (REAL-TIME) MONITORING ......................... ....................72.4 LONG-TERM MONITORING........................................... ........................... 112.5 CORRECTIVE MEASURES FOR THE WORK............................... .............132.5.1 WORKER PROTECTION ....................... ........................... ........................... 132.5.2 OFF-SITE PROTECTION............... ........................... ........................... .........13

3.0 REPORTING.....................................................................................................................15

4. 0 SAMPLING PROGRAM................................... ........................... ........................... .........164.1 VOCS..............................................................................................................164.2 PAHS..............................................................................................................164.3 PM-10/METALS........................ ........................... ........................... .............174.4 FIELD PROTOCOLS........................... ........................... ........................... ....17

5.0 ANALYTICAL PROTOCOLS .......................... ........................... ........................... .........185.1 AMBIENT AIR SAMPLING- VOCs........................................... ..................185.2 AMBIENT AIR SAMPLING - PAHS....................... ........................... .........185.3 AMBIENT AIR SAMPLING –PM-10/METALS............................ .............18

6.0 QA/QC CORRECTIVE ACTION ......................... ........................... ........................... ....20

7.0 QUALITY ASSURANCE REPORT....................... ........................... ........................... ....21

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FIGURE 1.1 PERMANENT SAMPLING STATIONS LOCATIONS

FIGURE 2.1 FLOWCHART OF MONITORING FOR PM-10

FIGURE 2.2 FLOWCHART OF MONITORING FOR VOCS AT DOMTAR TANK ANDCOAL PILE RUNWAY


TABLE 1.1 SAMPLING PARAMETERS FOR PERMANENT SAMPLING STATIONS

TABLE 2.1 AMBIENT AIR QUALITY CRITERIA

TABLE 2.2 AIR MONITORING PROGRAM SUMMARY

TABLE 2.3 CONTACT LIST FOR EXCEEDANCES

TABLE 3.1 ANALYTICAL PARAMETERS

TABLE 3.2 OVERVIEW OF SAMPLING DETAILS

TABLE 4.1 SUMMARY OF SAMPLING AND ANALYTICAL METHODS

TABLE 4.2 SUMMARY OF TARGETED DETECTION LIMITS

LIST OF ATTACHMENTS

ATTACHMENT A QUALITY ASSURANCE/QUALITY CONTROL PLAN

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1.0 INTRODUCTION

This Air Monitoring Program (AMP) and Quality Assurance/Quality Control Plan

(QA/QC Plan) included in Attachment A has been developed by Conestoga-Rovers &

Associates (CRA) for the surface cleanup activities at the Former Coke Ovens Site (the

Site) in Sydney, Nova Scotia. The surface cleanup activities include the following:

• Construction of Infrastructure

• Removal of the Domtar tank contents, cleaning the tank and demolishing the tank;

• Removing the benzol tank contents and cleaning tank;

• Demolition/disposal of two stacks

• Demolition/disposal of by-products building;

• Removing contents from sulphur building and demolition/disposal of remains of

sulphur building;• Removal and disposal of above grade coal and coke piles;

• Demolition/disposal of remains of coke batteries;

• Demolition/disposal of cooling tower grids;

• Demolition/disposal of benzol plant area tank; and

• General surface clean-up.

This AMP supplements a broader community monitoring program which includes

sampling not only at the perimeter of the Site but at the Tar Ponds and urban areasremote from the Site, by including sampling specific to individual activities on the Site.

The sampling stations for the broader community program are shown in Figure 1.1 and

parameters to be monitored at each station are provided in Table 1.1.

The air quality criteria for the AMP are the health-based criteria set forth in the

"Development of Interim Separation Zones, Former Coke Ovens Site, Sydney, Nova

Scotia" (AGRA Earth & Environmental, November 2000) (Development of Interim

Separation Zones Report). These criteria are based on 24-hour average concentrations

that are conservatively protective of health. The AMP, once implemented, has been

designed such that on-Site activities can be modified should 24-hour average (long-term)

and real-time (short-term) monitoring indicate that the ambient air criteria (AAC)

established in the Development of Interim Separation Zones Report are approached or

exceeded.

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The QA/QC Plan has been developed to provide a description of the field and

laboratory protocols that will be implemented and the quality control and quality

assurance required to provide reliable data.

This AMP has been organized as follows:

Section 1 - Introduction

Section 2 - The Air Monitoring Program - includes both short term and long

term monitoring activities

Section 3 - Sampling Program – provides a description of the methods that will

be used for the parameters that are being monitored.

Section 4 - Reporting

Section 5 - Analytical Protocols – description of field and laboratory

procedures

Section 6 - Quality Assurance and Quality Control measures

Section 7 - Quality Assurance Report -A description of the Quality Assurance

Report that will be provided at the conclusion of the various air-

monitoring activities.

Attachment A - Quality Assurance and Quality Control Plan

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2.0 AIR MONITORING PROGRAM

2.1 OVERVIEW

During the surface clean-up activities, the potential exists for the emission of air-borne

contaminants to the environment that have the potential to create an impact to the

workers on the Site and to residents off the Site if at high enough concentrations.

The Development of Interim Separation Zones Report indicated that provided controls

were imposed during demolition and removal activities, there would be no adverse

impact to the community outside of the Site. Air contaminants will be monitored at the

Site perimeter and the health-based criteria established in the Development of Interim

Separation Zones Report will be used as the comparative criteria. The health-based

criteria that will be used are based on a 24-hour average concentration. Table 2.1

provides the health-based ambient air quality criteria from the Development of InterimSeparation Zones Report. The table presents criteria presented in the Development of

Interim Separation Zones Report for both less than (LT14) and more than 14 days

(MT14) exposures appropriate for areas occupied by the public. The LT14 criteria

(benzene and methylene chloride only) are based on exposures of less than 14 days, and

the MT14 criteria are based on running 24-hour averages greater than 14 days. The

interim separation zones were developed within the Development of Interim Separation

Zones Report using the MT14 criteria, which are lower than the LT14 criteria. MT14

criteria were used within the Development of Interim Separation Zones Report since the

computer modelling used to predict the interim separation zones could only identify

highest concentrations over the 5-year modelling period and could not predict thesequence of these concentrations necessary to determine if the exposures would be more

or less than 14 days in a row. Both the MT14 and LT14 criteria are based on published

information developed by independent health organizations (e.g. United States

Environmental Protection Agency (USEPA), Health Canada, Agency of Toxic Substances

and Disease Registry (ATSDR)) and are conservative since they incorporate significant

factors of safety. As well occupational limits suitable for workers on the Site are

presented in Table 2.1. Occupational limits are established at higher concentration than

those for the public since workers are typically exposed for shorter periods of time per

day than the public, and since workers are assumed to be healthier than potentially

sensitive members of the public.

To minimize the risk that exceedances of the AAC are encountered, action levels

(referred to as “modified ambient air criteria” (MAAC”)) which are criteria based on 1-

hour averages are developed. The MAACs will be used to trigger corrective measures

along with additional monitoring and frequencies. MAACs for both the MT14 and LT14

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criteria are developed. Action levels have been selected for each monitoring parameter

to provide assurance that the concentrations of compounds of potential concern (COPC)

are not exceeded beyond the Site boundary. Corrective measures will include

modification of Site activities and monitoring parameters as appropriate to reduce the

risk of exceedances of the health-based air quality criteria. MAACs are presented in

Table 2.1 and the method by which they have been calculated are presented in Section

2.3.

A weather station has been located on Site to enable monitoring of precipitation, wind

velocity, and direction. Ambient temperature will also be monitored during the course

of the project.

The following air quality parameters will be monitored to assist in controlling Site

activities:

• volatile organic compounds (VOCs) (total and/or specific compounds);

• polycyclic aromatic hydrocarbons (PAHs);

• particulate matter less than 10 microns in size (PM-10); and

• selected metals.

The monitoring program presented in this AMP consists of two general types of

monitoring, as follows:

• Short-term (real-time monitoring) which provides for instantaneous or quick turn

around sampling and analysis

• Long-term which provides for sampling and laboratory analysis to confirm and

support the results of the short-term program

2.2 RESPONSIBILITY

Overall responsibility for the program during Site activities will be with the Project

Management Consultant (PMC) represented by Conestoga-Rovers & Associates, in itscapacity as construction oversight managers.

An air monitoring consultant (Consultant) will be retained to perform the perimeter air

monitoring described in Sections 2.3 and 2.4 which includes real-time dust and gas

chromatography (GC) monitoring and the collection of samples for laboratory analyses.

Work zone monitoring will be performed by the construction contractor (Contractor)

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retained to implement the Site activities. The Contractor will make use of real-time dust

and VOC monitoring equipment. Both will report to the PMC’s on-site personnel who

will direct the program described in this AMP.

The PMC’s Health and Safety officer will supplement the monitoring of the Consultant

and Contractor using real-time dust and VOC monitoring equipment.

Responsibility for reporting results to health authorities will be with the PMC.

2.3 SHORT-TERM (REAL-TIME) MONITORING

Direct reading instruments will be used to provide short-term (real-time) measurements

of the following air quality parameters:

• PM-10 (using a "DustTrak", or equivalent equipment);

• total volatiles [using a photoionization detector (PID)];

• Portable GC calibrated for benzene, toluene, ethylbenzene, xylene, and napthalene;

and

• Asbestos.

The PMC’s site manager will select specific short-term air monitoring locations on a

daily basis according to an evaluation of the weather conditions, primarily wind

direction, and the Site activity.

A. Routine PM-10 Monitoring

A flowchart presenting the real-time PM-10 monitoring program is presented in

Figure 2.1. The program can be summarized as follows: Five-minute rolling average of

real-time ambient air concentrations of PM-10 particulate is monitored by the Contractor

at the downwind side of the work zone. The parameter will be monitored using a

DustTrak aerosol particulate monitor, calibrated using a comparison with the

gravimetric method (high vol sampler). This comparison will be done by operating boththe gravimetric method and DustTrak beside each other for 8 to 24 hours at the start of

the project and once every five gravimetric sampling events. In addition to the work

zone monitoring performed by the Contractor, PM-10 measurements will be taken at

100-meter intervals generally upwind and downwind of the work activities at the Site

boundary every 1.5 hours by the Consultant. At least three locations upwind and three

locations downwind of the activity will be monitored for five minutes each. More

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upwind and downwind locations will be selected if the size of the activity is large. The

upwind perimeter monitoring will provide a general indication of background levels

and the downwind perimeter monitoring will provide a general indication of the

effectiveness of the work zone monitoring.

Should either the work zone activity, or the perimeter boundary measurement indicate

an exceedance of the MAAC for PM-10, then the PMC’s Site manager will be notified

and additional monitoring will be conducted by the Contractor and Consultant by

immediately and simultaneously taking 1-hour rolling average readings upwind and

downwind of the activity. The PMC’s Health and Safety Officer will assist with these

efforts if necessary. Corrective actions will be implemented at the end of one hour of

sampling when either:

(a) the downwind measurement exceeds the MAAC for PM-10, and the upwind

measurement is below the MAAC, or

(b) the downwind measurement exceeds 110 percent of the upwind measurement,

and the upwind measurement exceeds the MAAC. The allowance of 10 percent

accounts for instrument variability, normal variability between locations in an

unimpacted air shed and the large factors of safety inherent in each of the action

levels.

The corrective actions are described in Section 2.5. Enhanced monitoring at the

perimeter will continue to be performed until the corrective actions successfully

demonstrate that the Site perimeter PM-10 concentration is below either the MAAC, or

below 110 percent of the upwind concentration, if the upwind concentration is above theMAAC.

B. Routine VOC Monitoring Using PID

Real time monitoring of VOC concentrations during Site activities will be conducted by

the Contractor using a PID along the downwind side of the work zone in accordance

with Figure 2.2. Only the Domtar Tank emptying and coal removal operations require

this monitoring. Generally speaking, the monitoring location will be about 15 meters

from the work activity. This monitoring is in addition to the breathing zone monitoring

being performed by the Contractor to verify that appropriate levels of worker protection

are being implemented.

PID measurements are used as an indicator of total volatiles in the air. Since there are no

ambient air criteria for total hydrocarbons and since the action levels for the Site-specific

VOCs (benzene, toluene, xylene, ethyl benzene, and naptyhalene) are small and less

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than the sensitivity of the PID, the implementation of control measures will be based on

a comparison of downwind measurements close to the activity (15 m downwind will be

used initially, but may be changed depending on a comparison of the PID with the GC)

exceeding upwind measurements. The work zone action level 15 m from the activity will

be 0.1 ppm. This level is based on computer modeling which indicates a reduction in

concentrations from a source approximately 10 m in size, by a factor of 100 between 15m

and 500m distance, which is the closest distance between activities and residences.

Should this level be exceeded, then the portable GC monitoring program described

below will be implemented.

C. VOC Monitoring Using GC

A portable GC will be used daily to verify that the established work zone action level is

effective in maintaining the Site perimeter ambient air concentration below the AAC for

the VOC parameters. This verification will only be conducted daily for the first one totwo weeks of removal activities for the Coal Pile Runway and Domtar Tank. This

sampling may be extended beyond the first weeks should the sampling indicate that

results routinely approach or exceed the MAACs. Additional long-term stations may be

required based on the portable GC results.

Should the portable GC be retained on the site, as described above, and should the

Contractor’s PID monitoring indicate that a work zone action level has been exceeded,

then the Consultant’s portable GC will be used to determine the actual concentrations of

benzene, toluene, ethylbenze, xylene, and napthalene at the Site perimeter at the most

downwind perimeter stations. The upwind concentration will be measured at frequent

intervals throughout the day, allowing an immediate comparison to be made to the

downwind concentration. A comparison of upwind and downwind concentrations will

be made, and corrective actions will be implemented when:

(a) either the downwind perimeter concentrations exceeds the MAAC for any

parameter, and the upwind concentration is below the MAAC; or

(b) either one of the downwind perimeter concentrations exceeds 110 percent of the

upwind measurement, and the upwind measurement exceeds the MAAC.

The corrective actions are described in Section 2.5. GC monitoring at the perimeter as

described above will continue to be performed until the corrective actions successfully

demonstrate that the Site perimeter VOC concentration is below either the MAAC, or

below 110 percent of the upwind concentration, if the upwind concentration is above the

AAC.

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GC results will be available to the PMC within 45 minutes of sampling.

D. Asbestos

Asbestos monitoring will be conducted in the breathing zone of workers to confirm that

it does not exceed the NIOSH standard of 0.1 fibres per millilitre. This monitoring will

be performed for the first week of the demolition of the stacks to confirm that work

practices do not result in an exceedance. The sampling and analysis of asbestos will be

done using NIOSH method 7400. The analysis will be performed in the field by a

technician certified in the identification of asbestos fibres.

Provided that there are no exceedances of the NIOSH level in the work zone, there will

be no need to perform additional monitoring since dispersion to public area more than500 m away will result in a reduction of concentration by more than a factor of 20.

E. Short-term Monitoring of Metals and PAHs

It is not possible to perform real-time measurement of metals or PAHs. It is also not

necessary to perform such monitoring since the Development of Interim Separation

Zones Report determined that provided PM-10 requirements were met, there is no

possibility that metals or PAHs would approach their AAC. In any case, the permanent

monitoring stations at Victoria Road (Station 1) and Fredrick Street (Station 2) will be

used to confirm this understanding, since both parameters will be monitored at these

locations.

F. Development of MAACs

Short-term monitoring levels (real-time) cannot be compared against the 24-hour criteria

in the Development of Interim Separation Zones Report, since the 24-hour value is a

time-weighted average concentration. A short-term (1-hour) criteria is required. The 24-

hour average concentration is converted to a 1-hour average by using the following

equation:

MAAC= AAC x (time(lt)/time(st))^p

MAAC = Concentration for short-term averaging period (1-hour)

AAC = Concentration for long-term averaging period (24-hours)

time(lt) = long-term time in hours (24-hours);

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time(st) = short-term time in hours (1-hour); and

p = stability constant for E and F meteorological classification (stable (0.167).

This equation is taken from the Ontario Ministry of Environment's (MOE’s) document

entitled “STB Technical Bulletin No. EES-1, Odour Impacts – An Overview” (Science and

Technology Branch, February 1996) and is considered conservative.

Thus, for example, the PM-10 24-hour average criteria of 25 µg/m3 is converted to a

short-term 1-hour average criteria (MAAC) of 43 µg/m3. Corrective actions, as

described in Section 2.6 will be required if short term monitoring results indicate PM-10

greater than 43 µg/m3.

Table 2.1 provides the MAACs for each compound as converted from 24-hour to 1-hour

average ambient air criteria.

G. Work Zone Air Monitoring

Table 2.1 also presents Occupational Safety and Health Administration (OSHA) levels.

These levels will be used during the short-term monitoring program as levels for which

donning respirators or self-contained breathing apparatuses would be necessary.

2.4 LONG-TERM MONITORING

The results of the short-term monitoring discussed in the above section will be

confirmed by the long-term monitoring performed by the Consultant discussed below.

Decisions regarding activities on the Site will be based on the short-term (real-time)

monitoring since it provides immediate results that can be used to temporarily halt

and/or modify Site activities. However the long-term data provides information

necessary to confirm the short-term results or if necessary modify the interpretation of

the short-term results.

The community ambient air monitoring program presented in Table 1.1 and Figure 1.1

includes two permanent monitoring stations next to the Site which monitor for PM-10,VOCs, PAHs, and metals every 6 days during site demolition activities and every 12

days during periods of inactivity. These will be used to supplement the Site monitoring

described in Section 2.3. Additionally, four permanent locations remote from the Site, as

shown on Figure 1.1, are monitored for the parameters in Table 1.1 every 6 days during

Site activities and every 12 days during periods of inactivity. The permanent monitoring

station locations near to the site are shown on Figure 1.1. This monitoring program will

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continue during the remedial work at the Coke Ovens Site and will provide ambient air

data to evaluate the effects of Site activities to the surrounding area.

The two permanent locations near to the Site are appropriate for monitoring the surface

cleanup activities for the following reasons:

1) Frederick St. Monitoring Station (PM-10, VOCs., metals and PAHs):

• located between the Coke Ovens Site and the residents to the north;

• previous monitoring at this station will provide good baseline;

• located close to an on-site area where PM-10 VOCs was modelled to

potentially exceed health-based criteria in the Development of Interim

Separation Zones Report during remediation of the coal pile; and

• close to possible on-Site PM-10, metals and PAHs emissions for Coal Pile,

and Domtar Tank remedial activities.

2) Victoria Rd Monitoring Station (PM-10 (to be added) VOCs, metals and PAHs):

• located between the Coke Ovens Site and the residents to the west;

• previous monitoring at this station will provide good baseline; and

• located in an area close to stacks removal activity ; and

• close to possible on-Site PM-10 VOCs, metals and PAHs emissions for Coal

Pile, Coke Pile, Benzol Tank, Domtar Tank, Sulphur Pile, Coke Batteries, and

Stacks remedial activities.

A mobile monitoring station will also be used which will be equipped with long-term

monitoring units for PM-2.5, PM-10, PAHs, metals and VOC sampling. The mobile

monitoring station will be located as shown on Figure 1.1 or at other locations as

determined appropriate. The location for this station is flexible and will be located

based on wind direction, Site activities and previous sampling results. This mobile

station can also be used to provide duplicate sampling for quality assurance/quality

control.

The mobile station will be established north of the Domtar Tank and north of the Coal

Pile Runway when removal of these materials is underway. These locations were

selected because VOC emissions for the Domtar tank (benzene) and the Coal Pile

Runway (benzene) emissions has the potential to go off the Site, although the modelling

in the Development of Interim Separation Zones report showed the concentrations of

VOCs would not exceed AAC.

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This monitoring north of the Domtar Tank and Coal Pile Runway will be conducted on a

daily basis for at least the first week during the Domtar tank contents and coal pile

removal. Following the first week, will be monitored once every 6 days.

Should any long-term results indicate an exceedance of an AAC, the real-time action

levels will be revised.

Based on the results on the above described monitoring frequencies and locations may

be modified to better address work activities and analytes identified.

All long-term samples taken adjacent to the Site during Site activities will analyzed and

reported within four days of sampling. Otherwise analyses will only be completed and

reported within 14 days.

2.5 CORRECTIVE MEASURES FOR THE WORK

2.5.1 WORKER PROTECTION

Corrective measures for the work will not be necessary if elevated levels are detected in

the work area. Workers in this area will be protected in accordance with the Site-specific

Health and Safety Plan. Provisions in the health and safety plan will require that

workers use personal protective equipment (PPE) if specific monitoring results indicate

that this is necessary.

2.5.2 OFF-SITE PROTECTION

Should elevated perimeter short-term monitoring results indicate a potential

exceedances of the 24-hour AAC, and it is determined that these exceedances are a result

of the activities at the Site, activities at the Site will be immediately evaluated and

changes will be made to the work until such time that the measured concentrations are

below the 1-hour MAAC. The concentrations of the specific parameters at the off-Site

locations will be monitored during this period until the concentrations fall below the

MAAC criteria.

For parameters with LT14 MAACs (benzene) corrective measures will be imposed when

the long-term MAAC is exceeded. However provided that no more than 5 consecutive

days of readings are between the MT14 and LT14 MAAC and provided that readings for

the previous 14 days did not exceed the MT14 AAC, the readings greater than the LT14

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AAC or MAAC would not be regarded as exceedances. This is consistent with and more

conservative than the ATSDR definition of allowable acute and intermediate exposure.

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3.0 REPORTING

Real-time (DustTrak, PID and GC) results will be reported to the PMC a minimum of

every four hours. Any exceedance as described in the AMP will be reported

immediately to the PMC. Draft long-term results for sampling next to the Site during

Site activities will be provided to the PMC within 24 hours of receipt of the result by the

Consultant performing the sampling. All records will indicate the time, date and

location of sampling, and weather conditions including wind, temperature,

precipitation, and barometric pressure. This information will be available from the on-

Site weather station.

Where there is an exceedance of a MAAC, the sampler will be required to immediately

report the results to the PMC. This will allow for the coordination of additional

sampling as described in the previous section.

Where there is an exceedance of a MAAC for more than four hours, or of an AAC, the

sampler or Consultant, as appropriate, will also immediately notify the PMC, who will

report such to the Medical Officer of Health and those persons listed on Table 2.3. The

same group will also be notified of any reading that causes site activities to shut down.

All long-term sampling results will be documented once per month in a formal report.

The Report will present the validated results, weather information, Site activities

associated with readings and a discussion of the results with respect to sources.

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4. 0 SAMPLING PROGRAM

The groups of parameters selected for analysis are based on the chemicals of potential

concern (COPCs) identified in the Development of Interim Separation Zones Report.

Ambient air sampling will be conducted for the compounds detailed in Table 3.1. The

sampling for the long-term air monitoring will be completed over a 24-hour duration,

starting at 12 midnight, so the sampling results can be readily compared against the

24-hour AAC in the Development of Interim Separation Zones Report.

The general air sample collection protocols are summarised in Table 3.2 and are

discussed further below. These methods may be revised following finalisation of the

ambient air monitoring program being completed by AGRA.

4.1 VOCS

VOCs will be collected using a 1.7 litre SUMMA® canister or equivalent. The canisters

are pre-evacuated in the laboratory and are typically a stainless steel canister. A 24-hour

sample will be collected using a flow regulator. The samples will be collected in

accordance with Method TO-14A as published by the United States Environmental

Protection Agency (USEPA) in the document entitled "Compendium of Methods

TO-14A, Determination of Volatile Organic Compounds (VOCs) in Ambient Air using

Specially Prepared Canisters with Subsequent Analysis by Gas Chromatography"

(USEPA, January 1999).

Portable GC samples will be collected using Tedlar bags.

4.2 PAHS

PAHs will be collected using a Graseby-Anderson PS-1 sampler fitted with a

PUF/XAD-2 cartridge and a 4-inch diameter particulate filter. The cartridge and filter

will be solvent extracted in the laboratory and individual aliquots will be analysed for

PAHs. The samples will be collected in accordance with Method TO-13 as published by

the USEPA in the Document entitled "Compendium Method 13 Determination of Benzol

(a) Pyrene and Other Polynuclear Aromatic Hydrocarbons (PAHs) in Ambient Air using

Gas Chromatographic (GC) and High Performance Liquid Chromatographic (HPLC)

Analysis" (May 1988).

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4.3 PM-10/METALS

Ambient air will be sampled for PM-10 and metals by means of Hi-Volume (Hi-Vol)

sampling.

PM-10 is determined by the use of glass-fibre filters and uses a collection mechanism

that removes particulate larger than 10 microns and deposits only particulate 10 microns

and less on the filter. The method of sample collection for PM-10 is USEPA's "Reference

Method for the Determination of Particulate Matter as PM-10 in the Atmosphere"

(40 CFR Part 50 Appendix M).

4.4 FIELD PROTOCOLS

Attachment A describes the required field considerations to ensure that data of known

quality is produced for the ambient air monitoring program. The detailed sampling

procedures are provided in the reference methods referred to above.

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5.0 ANALYTICAL PROTOCOLS

The analytical methods to be used for analysis of air samples are listed in Table 4.1. A

discussion of the methods is found below.

5.1 AMBIENT AIR SAMPLING- VOCs

Collection of samples will be conducted using Method TO-14A from the USEPA

document entitled "Compendium of Methods TO-14A Determination of Volatile

Organic Compounds (VOCs) in Ambient Air using Specialized Prepared Canisters with

Subsequent Analysis by Gas Chromatography" (USEPA, January 1999). VOCs are

separated in the air stream by gas chromatography and measured by mass selective

detector or multi-detector techniques. The canisters are pre-cleaned in the laboratory.

Targeted detection limits are detailed in Table 4.2

5.2 AMBIENT AIR SAMPLING - PAHS

Samples to be analysed for PAHs will require an Anderson (GMW) PS-1 air sampler to

collect particulate fractions on glass fibre filters (4 inch diameter) and vapour phase

fractions on polyurethane foam (PUF) and XAD-2 resin. Sample collection will follow

techniques as they are outlined in Method TO-131. Extraction procedures include

overnight Soxhlet extraction, column chromatographic cleanup and evaporative

concentration using either a Kuderna-Danish or a rotary evaporator. The sample

extracts are then analysed in accordance with USEPA SW-846 Method 82702. TargetedDetection limits are detailed in Table 4.2.

Sample trains for PAHs analysis are pre-cleaned and proofed in the laboratory. Exposed

cartridges and filters are wrapped in solvent rinsed aluminium foil and are prevented

from excess exposure to heat or light.

5.3 AMBIENT AIR SAMPLING –PM-10/METALS

PM-10 will be analysed using USEPA' Reference Method for the Determination of

Particulate Matter as PM-10 in the Atmosphere (40 CFR Part 50 Appendix M). The

1 Method from USEPA Document entitled "Compendium of Methods for the Determination ofToxic Organic Compounds in Ambient Air". 600/4-84-081 (1984) and supplement (1986).

2 Method from United States Environmental Protection Agency (USEPA). Document entitled "TestMethods for Evaluating Solid Waste," SW-846, November 1986.

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methods consists of desiccating and weighing the glass fibre filters prior to sending the

filter to the field in a special manila envelope. The sample is returned to the laboratory

and the filter is desiccated and weighed again. The difference in weight is the total

amount of PM-10 collected during the sampling period.

The analytical method for metals is based on digestion of the PM-10 filter. A small

portion of the filter and particulate on the filter are digested in an acidic solution. The

solution is then analysed by Inductively Coupled Plasma (ICP).

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6.0 QA/QC CORRECTIVE ACTION

Field QA/QC requirements are as outlined in Attachment A. These methods may be

revised following finalisation of the ambient air monitoring program being completed

by AMEC. The need for corrective action may be identified by system or performance

audits or by standard QC procedures. The essential steps in the corrective action system

will be:

i) checking the predetermined limits for data acceptability beyond which corrective

action is required;

ii) identifying and defining problems;

iii) assigning responsibility for investigating the problem;

iv) investigating and determining the cause of the problem;

v) determination of a corrective action to eliminate the problem (this may includereanalyses or resampling and analyses);

vi) assigning and accepting responsibility for implementing the corrective action;

vii) implementing the corrective action and evaluating the effectiveness;

viii) verifying that the corrective action has eliminated the problem; and

ix) documenting the corrective action taken.

For each measurement system, the QA/QC Officer will be responsible for initiating the

corrective action or the laboratory supervisor, if appropriate, will be responsible for

implementing the corrective action. The corrective action taken will depend upon the

QA/QC results that did not meet the necessary criteria, and may include qualifying the

data

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7.0 QUALITY ASSURANCE REPORT

Reports will be prepared on the performance of the measurement system and data

quality following each long-term sampling round. Sample results, which are reported

prior to completion of data validation, will be labelled as draft.

Validated reports will include:

i) assessment of measurement quality indicators, i.e., data accuracy, precision and

completeness;

ii) results of system audits; and

iii) QA problems and recommended solutions.

The QA/QC Officer will be responsible within the organizational structure for

preparing these reports. The final report for the project will also include a separate QA

section which will summarise data quality information contained in the QA/QC reports

to management, and details an overall data assessment and validation in accordance

with the data quality objectives outlined in this SAP, and in accordance with generally

accepted data validation criteria.

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14458 (24) Appendix A

APPENDIX A: TABLE 1.1

SAMPLING PARAMETERS FOR PERMANENT SAMPLING STATIONSMUGGAH CREEK REMEDIATION PROJECT

SYDNEY, NOVA SCOTIA

VictoriaRoad

Station

#1

FrederickStreet

Station

#2

HenryStreet

Station

#3

FormerCove

Guest

Home

Station

#4

IntercolonialStreet

Station

#5

DesbarresStreet

Station

#6

MobileStation

Station

#7

PAH • • • • • • •

VOC • • • • • • •

PM10 • • • •

PM2.51 • • • •

Metals • • • • • • •

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Page 1 of 1

Long-Term Short-Term

Compound o f Pot en t i al Concern (COPC) 24-Hou r Ambien t 1-Hou r Ambien t

A i r Cri t er i a (1) A i r Cri teri a (2) TWA (4) ST (5)

(AAC) (MAAC) (ug/m3) (ug/m3)

(ug/m3) (ug/m3)

benzene 3190 15950

(<14 days) (LT 14)(4) 73.6 125

(>14 days) (MT 14) (4) 7 12

toluene 760 1292 754,000 1,131,000

ethylbenzene 200 340 434,000

xylene 36 61 434,000

benzo(a)pyrene 22.4 38 200

naphthalene 3 5 52,400

methylene chloride 86,750 433,750

(<14 days) LT 14) 2000 3400

(>14 days) (MT 14) 200 340

beryllium 0.02 0.03 NM NM

lead 0.83 1.41 NM NM

manganese 0.3 0.51 NM NM

arsenic 0.16 0.27 NM NM

asbestos 0.003 F/ml 0.005F/ml 0.1 F/ml

PM-10 25 43

Notes:

(1) Based on AGRA's report entitled "Development of Interim Separation Zone Criteria Former

Coke Ovens Site, Sydney, Nova Scotia" (AGRA September 2000); the ambient air criteria

based on 24-hour average concentration.

(2) Conversion from 24-hour average concentration to 1-hour average concentration is as provided

in MOE's document entitled "STB Technical Bulletin No. EES-1, Odour Impacts - An Overview"

Science and Technology Branch, February 1996.

(3) OSHA - Occupational Safety and Health Administration. For purposes of the realtime monitoring program, PID readings exceeding

0.5 ppm (one-half of the 3119 ug/m3) will be the action level for worker protection

(4) Unless denoted by ST, the OSHA levels shown are allowable limits based on TWA over 8 hours

(5) ST - 15-minute time weighted average exposure not to be exceeded anytime during a work day.

NM Not measured

Monitoring Criteria

OSHA (3)

AMBIENT AIR QUALITY CRITERIA

FORMER COKE OVENS SITE

SYDNEY, NOVA SCOTIA



CRA 14458 (24) Appendix A

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Page 1 of 1


Si te Act iv i ty Paramet er

44 Frederi ck Vi ct ori a M obi l e O thers (4) Real -Time

Road (new ) (Peri met er)

1) Coal Pile Runway PM-10 Yes Yes Yes Yes DustTrak (1)

Metals Yes Yes Yes Yes No

PAH Yes Yes Yes Yes No

VOC (2) Yes Yes Yes New station north of

Coal Pile

PID/GC (3)

2) Coke Pile PM-10 Yes Yes No Yes DustTrak (1)

Metals Yes Yes No Yes No

PAH Yes Yes No Yes No

VOC (2) Yes Yes No Yes PID

4) Benzol Tank PM-10 Yes Yes No Yes DustTrak (1)




5) Domtar Tank PM-10 Yes Yes Yes Yes DustTrak (1)

Metals Yes Yes Yes Yes No

PAH Yes Yes Yes Yes No

VOC (2) Yes Yes Yes New station north

and west of DomtarTank

PID/GC (3)

6) Cooling Tower PM-10 Yes Yes No Yes DustTrak (1)




7) Sulphur Pile PM-10 Yes Yes No Yes DustTrak (1)



VOC (2) Yes Yes No Yes No

8) Coke Oven Batteries PM-10 Yes Yes No Yes DustTrak (1)




9) Stacks PM-10 Yes Yes No Yes DustTrak (1)




Asbestos No No No At work site No

10) By-Products Building PM-10 Yes Yes No Yes DustTrak (1)




(1) PM-10 measured by DustTrak or equivalent

(2) VOC monitoring frequency for coal pile runway and Domtar Tank is every day for the first two weeks and

once every 6 days thereafter (may be increased depending on short term and long term results. For all

other activities it it every six days.

(3) GC- Portable gas chromatography. GC for the first 2 weeks of activity

(4) Stations 3 through 6 will operate every 6 days during site activities and every 12 days thereafter.

PID - Photo Ionization Device

PM-10 - particulate matter <10 micronsNAPS - National Air Pollution Surveillance

PAH - polycyclic aromatic hydrocarbons

VOCs - volatile organic compounds

Sit e Clean-Up Acti vit ies Moni tori ng Locati ons (3)


AIR MONITORING PROGRAM SUMMARY DURING DEMOLITION AND REMOVAL


SYDNEY, NOVA SCOTIA

CRA 14458 (24) Appendix A

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APPENDIX A: TABLE 2.3CONTACT LIST

MUGGAH CREEK REMEDIATION PROJECTSYDNEY, NOVA SCOTIA

14458(24) Appendix A Page 1 of 1

Contact Name Department Phone Mobile Home

Wayne Vervaet Transportation & Public Works (902) 567-1035 (902) 565-9008 (902) 539-9474

Jeff Scott Department of Health (902) 424-8698Terry MacPherson Environment & Labour (902) 563-2508

Vanessa Rodrigues Environment Canada (902) 426-1535

Paul Moore Health Canada (902) 426-7589

Michael Hingston Environment & Labour (902) 424-8207

Roy Kwiatkowski Health Canada (613) 941-3890

After Work Hours

Wayne Vervaet Transportation & Public Works (902) 567-1035 (902) 565-9008 (902) 539-9474

Darren Gardiner PMC (902)564-3313 (902) 565-0507 (902) 539-1467

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Page 1 of 1

1) AMBIENT AIR MONITORING

A. VOCsBenzeneEthylbenzenem & p-Xyleneso-XyleneToluenemethylene chloride

B. PAHs

Benzo(a)pyreneNaphthalene

C. PM-10PM-10

D. Metalsarsenicleadberylliummanganese


ANALYTICAL PARAMETERSFORMER COKE OVENS SITE

SYDNEY, NOVA SCOTIAMUGGAH CREEK REMEDIATION PROJECT


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Page 1 of 1

OVERVIEW OF LONG-TERM SAMPLING DETAILS


SYDNEY, NOVA SCOTIA

A pproxi mat e Tot al A pproxi mat e A pproxi mat e

Parameter Pump Sample Cont ai ner Sample Vol ume Fl ow Rat e Sample Time

Ambient Air Sampling

i) VOCs NA Summa Canister 1.7 litres 1.2 ml/min 24 hours

ii) PAHs PS-1 (1) PUF (3) 324 m30.225 m3/min 24 hours

XAD-2 Cartridge

iii) PM-10/Metals Hi-Vol (2)Glass Fibre Filter 1600 -2400 m3 1.1 - 1.7 m3/min 24 hours

Notes:

(1) Anderson PS-1 PUF Sampler Model GPSI or equivalent

(2) General Metal Works - Hi-Vol Sampler or equvalent

(3) PUF - Polyurethane Foam Plug or equivalentPAHs Polycyclic Aromatic Hydrocarbon, including screening for phenols, cresols and xylenols

VOC Volatile Organic Compounds

PM-10 Particulate Matter less than 10 microns.

m3cubic meters

m3/min cubic metres per minute

ml/min millilitres per minute




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Page 1 of 1

SUMMARY OF SAMPLING AND ANALYTICAL METHODSFORMER COKE OVENS SITE

SYDNEY, NOVA SCOTIA

I t em Paramet er Col l ect i on M ethod Anal y t i cal M ethod

Ambient Air Monitoring

1. VOCs TO-14A 1 GC/Mass selective detector or multi-detectortechnique

2. PAHs TO-13 Modified GC/MS (Method 8270)

3 PM-10 40CFR Part 50 App. M gravimetric

4 Metals 40CFR Part 50 App. M digestion/ICP

Notes:

(1) Method from USEPA document entitled "Compendium of Method TO-14A, Determination of VolatileOrganic Compounds (VOCs) in Ambient Air Using Specially Prepared Canisters with Subsequent Analyisby Gas Chromatography" (USEPA, January 1999).

(2) Method from USEPA document entitled "Test Methods for Evaluating Solid Wastes",SW-846, 3rd Edition, 1986.

PAHs Polycyclic Aromatic Hydrocarbon, including screening for phenols, cresols and xylenols


PM-10 Particulate Matter <10 microns.

GM/MS Gas Chromatography/Mass SpectrometryUSEPA United States Environmental Protection Agency

Code of Federal Regulations




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Page 1 of 1

Targeted I t em Paramet er Det ect i on L imi t

(µg/m ) A. VOCs

1. benzene 0.12. ethylbenzene 0.13. m&p-xylenes 0.1

4. o-xylene 0.15. toluene 0.16. methylene chloride 0.1

B. PAHs

1. Benzo(a)pyrene 8e-52 Naphthalene 8e-5

C. PM-101. PM-10 6

D. Metals

1. arsenic 0.0052. lead 0.0013. beryllium 0.00024. manganese 0.0002


SUMMARY OF TARGETED DETECTION LIMITSFORMER COKE OVENS SITE

SYDNEY, NOVA SCOTIAMUGGAH CREEK REMEDIATION PROJECT


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14458 (24)

ATTACHMENT A

QUALITY ASSURANCE/QUALITY CONTROL PLAN

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QUALITY ASSURANCE/QUALITY CONTROL PLAN


SYDNEY, NOVA SCOTIA

Prepared By:

Conestoga-Rovers & Associates Limited

295 George Street

Sydney, NS B1P 1J7

Phone: (902) 564-3313

Fax: (902) 564-4681

Web Site: www.CRAworld.com

R EF. NO. 14458-01 (24)This report is printed on recycled paper.

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14458(24) Appendix A (Att.A) CONESTOGA-ROVERS & ASSOCIATES

TABLE OF CONTENTSPage

A. FIELD QA/QC...... ........................... .......................... ........................... ........................ 1A.1 GENERAL QA/QC............... ........................... ........................... ............... 2A.2 FIELD BLANKS.......................... ........................... ........................... .......... 2A.3 FIELD DUPLICATES............ ........................... ........................... ............... 3A.4 FLOW MEASUREMENTS............................... ........................... ............... 4A.5 SAMPLE LABELLING................................. ........................... ................... 4A.6 FIELD LOG AND RECORD KEEPING ........................... ........................ 5A.7 CHAIN-OF-CUSTODY FORMS .......................... ........................... .......... 6A.8 FIELD EQUIPMENT CLEANING, SAMPLE CONTAINERS, AND

HANDLING .......................... ........................... ........................... ............... 6

B. LABORATORY QA/QC...................... ........................... ........................... ................... 8B.1 ANALYTICAL METHODS ......................... ........................... ................... 8

B.2 PROOFING OF SAMPLING MEDIA............................................. .......... 8B.3 SURROGATE STANDARDS......................................... ........................... . 8B.4 REAGENT BLANK ........................ ........................... ........................... ...... 8B.5 LABORATORY (PROCESS) BLANKS................. ........................... .......... 9B.6 MATRIX SPIKE.......................... ........................... ........................... .......... 9B.7 SOLVENT PROCESS BLANK..................... ........................... ................... 9B.8 LABORATORY REPORTS AND TURNAROUND TIME ...................... 10

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14458(24) Appendix A (Att.A) CONESTOGA-ROVERS & ASSOCIATES


FIGURE A.1 HI-VOL FIELD DATA FORM

FIGURE A.2 GENERAL AIR SAMPLING DATA FORM

FIGURE A.3 CANISTER SAMPLING DATA FORM


TABLE A.1 QUALITY ASSURANCE/QUALITY CONTROL SAMPLES

TABLE A.2 SUMMARY OF SHIPPING CONTAINERS

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14458(24) Appendix A (Att.A) A-1 CONESTOGA-ROVERS & ASSOCIATES

ATTACHMENT A

QUALITY CONTROL/QUALITY ASSURANCE

A. FIELD QA/QC

The QA/QC requirements for TSP, PM-10, PM-2.5 and metals sampling and analyses

are as specified below:

1) PM-10 - USEPA's Reference Method for the Determination of Particulate Matter as

PM-10 in the Atmosphere (40 CFR Subchapter C Part 50 Appendix M).

2) TSP and Metals – USEPA's Reference Method for the Determination of Particulate

Matter in the Atmosphere (High-Volume Method) (40 CFR Subchapter C Part 50

Appendix B).

3) PM-2.5 - USEPA's Reference Method for the Determination of Fine Particulate Matter

as PM-2.5 in the Atmosphere (40 CFR Subchapter C Part 50 Appendix L)

QA/QC requirements for the methods above are also detailed in 40 CFR Part 58

Appendix A – Quality Assurance Requirements for State and Local Air Monitoring

Stations (SLAMS) and Appendix B – Quality Assurance Requirements for Prevention of

Significant Deterioration.

The QA/QC requirements for PAHs sampling and analyses are as specified in USEPA's

method entitled "Compendium Method TO-13 Determination of Benzo(a)Pyrene (B(a)P)and Other Polynuclear Aromatic Hydrocarbons (PAHs) in Ambient Air Using Gas

Chromatographic (GC) and High Performance Liquid Chromatographic (HPLC)

Analysis".

The QA/QC requirements for VOC sampling and analyses (24-hour sampling) are as

specified in USEPA's method entitled "Compendium Method TO-14A Determination of

Volatile Organic Compounds (VOCs) in Ambient Air Using Specially Prepared

Canisters with Subsequent Analysis by Gas Chromatography". Since this method is an

alternative to Compendium Methods TO-1 and TO-2, the QA/QC requirements of these

methods are also appropriate. The QA/QC requirements for VOC sampling and

analyses (real-time) using portable gas chromatography (GC) is as specified in Appendix

B of the above USEPA method.

General requirements from these sources are outlined below. Refer to the above

documents for full details of the requirements.

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A.1 GENERAL QA/QC

All samplers should be located at least 2 meters from any obstruction. The samplers

should also be placed under a shelter to protect the equipment and sampling activity

from rain.

TSP, PM -10, PM -2.5 and Met al s - Careful handling of the filter between the

presampling and post sampling weighings will be exercised to avoid errors due to loss

of fibres or particles from the filter. Filters will be covered during non-sampling

periods. Only the outer edges of the filter will be handled. The filter will be folded in

half lengthwise so that only surfaces with collected particulate matter are in contact.

Non-Powder nitrile gloves will be used. Continuous flow recorder or elapsed time

meter will be used to provide total sampler running time and indication of powerinterruption. Sampler exhaust will be directed via appropriately sized tubing

downwind of sampler.

PAHs – Use only clean teflon coated forceps while inserting the filter in the filter holder.

Use non-fibre producing cotton or polyester gloves when removing the sorbent

cartridge from the sampler and retain original aluminium foil in which the sample was

originally wrapped. After filter is removed from the filter holder, fold the filter in half

twice with sample side inside and place in glass sample container. Sampler exhaust will

be directed via appropriately sized tubing downwind of sampler.

VOCs – All canisters are to be pressure tested to 207 kPa +/- 14 kPa over a period of

24 hours. All canisters are to be certified clean (<0.2 ppbv of target VOCs) through

humid zero air certification program. When field pressure is checked after the sampling

period, a vacuum in the canister should be observed. This will ensure the sample was

collected over a 24-hour period and that the regulator functioned satisfactorily.

A.2 FIELD BLANKS

Table D.1 provides the number of field blanks required for the AMP.

TSP, PM -10, PM -2.5 or M et al s – The field blank will consist of a glass filter which will

be dried, weighed and placed carefully in a sealed manila envelope. The filter will then

be sent to the field with sampling personnel, but the filter will not be exposed. Upon

submission of the other filter samples, the field blank will also be submitted to test the

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accuracy of the weighing scale. One field blank (for each parameter) will be collected

and submitted blind to the laboratory for each sampling episode.

PAHs - The field blank will be a PUF/XAD cartridge that is shipped to the field and

returned, without drawing air through the sampler. During each sampling episode a

field blank will be submitted blind to the laboratory.

VOCs – For the 24-hour sampling method, the field blank will be an evacuated canister

that is shipped to the field and returned, without drawing air through the sampler.

During each sampling episode a field blank will be submitted blind to the laboratory.

For the portable GC method, 10% of all injections will be field blanks. The field blank

will be nitrogen gas and is the second injection in each sample location.

A.3 FIELD DUPLICATES

Table D.1 provides the number of field duplicates required for the AMP.

TSP, PM -10, PM -2.5 or M et al s - a collocated (or duplicate) sample (each parameter) is

required to assess precision for 10 percent of all samples taken from the permanent

stations. A mobile monitoring station will be used as the collocated station at one of the

existing monitoring stations which is expected to have the highest 24 hour

concentration. The collocated sampler will collect the samples in the same manner as

and concurrently with the existing (primary) sampler. The samplers will be located

within 4 meters of each other, but not closer than 2 meters.

PAHs – Duplicate samples will be collected at the same frequency as the TSP, PM-10,

PM-2.5 and metals methods, above.

VO C –The 24-hour sampling method requires the collection of a parallel sample for

each sampling event at different flow rates. If the results between the parallel samples

are not within 25 percent, then other parallel samples may also be required. If

decreasing concentrations are observed for higher flowrates, lower flowrates should be

used. For the portable GC method, 10% of the injections must be duplicates. This willenhance the probability that the analysis of the sample reflects only the composition of

that sample and not any previous injection.

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A.4 FLOW MEASUREMENTS

TSP, PM -10, PM -2.5 and Met al s - The flow rate transfer standard will be certified

according the method requirements (40 CFR Part 50 Appendix B, L and M). The

certified transfer standard will be used to calibrate the sampler flow indicator. The

calibration data will be recorded on a calibration data form. Calibration will be

conducted prior to commencement of field activities using an orifice calibration unit.

Calibration will be based on at least five separate air flows within the specifed range,

which will be used to develop a calibration curve. The calibration curve produced from

the five point test will be attached to each Hi-Vol unit for use in the field. The sampler

flow rates must be audited for accuracy once each calendar quarter for one quarter of the

samplers such that each sampler is audited once per year. A random audit is required

for less than four samplers such that one of the samplers is selected each quarter. The

flow rate check of each sampler will be at its normal operating flow rate using a flow

rate transfer standard which is certified. The flow rate standard used for auditing willnot be the same used to calibrate the sampler.

PAHs – Calibration of the PS-1 air sampler in the field is performed using a calibrated

orifice flow rate transfer standard. The flow rate transfer standard will be certified in

the laboratory against a positive displacement rootsmeter. Recertification of the orifice

flow rate transfer standards is performed once per year.

VOC – To verify correct sample flow for the 24-hour sampling method, a "practice"

(evacuated) canister is used. A certified mass flow meter is attached to the regulator

which is connected to the sample canister. The canister is opened, and the flow

regulator is adjusted to the desired flow and recorded. The "Practice" canister, the flow

regulator and the certified mass flow meter are disconnected and the flow regulator is

attached to a clean certified canister. For the portable GC flows, flows of 60 and 30

ml/min are adjusted by means of a calibrated rotameter.

A.5 SAMPLE LABELLING

A unique numbering system will be used to identify each collected sample. This system

will provide a tracking number to allow retrieval and class referencing of sample

information. Field personnel will maintain a listing of the sample identification

numbers with written descriptions of sample location, type, and date. The sample

numbering system to be used is described as follows:

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Example: A-1597004-140800-AB-001

Where: A = designates sample type (A = air)

1597004 = project number (last 2 digits is the subcode)

140800 = date of collection (day, month, year)

AB = sampler's initials

001 = sequential number designating sampling location

The total volume of air sampled, calculated using the average flow rate and the total

sampling time will be noted in the field notebook, the chain-of-custody, and the air

sampling data sheet.

All sample labels will be firmly affixed to the sample containers they identify. Labels

will be written using a ball-point pen never permanent marker as the marker couldcontaminate VOC and PAHs samples. Table D.2 details the types of shipping containers

to be used and the labelling protocols.

A.6 FIELD LOG AND RECORD KEEPING

The field logbook will be a bound document with consecutively numbered pages. The

entries for each day commence on a new page, which will be dated. Corrections will be

made by marking through the error with a single line, so as to remain legible, and

initialling this action followed by writing the correction.

The following information will be recorded in the field log book for each sample

collected:

i) site location identification;

ii) unique sample identification number;

iii) date and time interval (in 2400-hour time format) of sample collection;

iv) weather conditions at the time of collection;

v) calibration data;

vi) flow rate of each sampling device;

vii) calculation of total volume sampled using average flowrate and sampling time;

viii) any relevant remarks; and

ix) name of sampler.

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Additionally, Figures D.1, D.2 and D.3 are the data sheets which will be filled out for

each sample to record the flow rates, sampling conditions, and other site specific data.

A.7 CHAIN-OF-CUSTODY FORMS

Chain-of-custody forms will be used to track all samples from the time of sampling to

the arrival of the sample at the laboratory. Each sample cooler being shipped to the

laboratory will contain a chain-of-custody form. Each sample will be identified on a

chain-of-custody form and the total volume sampled (calculated using average flow rate

and sampling time) will be indicated in the comments field. As well, temperature and

barometric pressure will also be denoted in the comments field.

The chain-of-custody form consists of three copies, which are distributed to the sampler(pink), and two copies to the laboratory. The laboratory, upon receiving the samples,

will complete the two copies. The laboratory will maintain one copy for its records

(white). The remaining copy will be returned to the sampler with the data package

(yellow).

A.8 FIELD EQUIPMENT CLEANING,SAMPLE CONTAINERS, AND HANDLING

Cleaning of field sampling equipment will be performed by field staff wearing polyestergloves using a stiff-bristled brush and/or laboratory-supplied analyte-free water.

Drying of equipment, if required, should employ new unbleached paper towels.

Samplers will handle PAH and VOC samples only while wearing non-fibre producing

polyester gloves. PM-10 samples will be handled only with non-powder nitrile gloves.

Smoking will not be permitted and sampling will not be conducted during precipitation

events including rain, sleet, hail and snow. Samplers will not use perfumes, colognes, or

other potential VOC-containing substances during sampling events to avoid

contamination of sample media. Sample media will not be stored in vehicle trunks or

automobile garages during sampling events. Samples will be transported using

shipping media detailed in Table A.2 and will be maintained at a temperature of 4°C or

less during transport to the laboratory.

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Chain-of-custody forms will be completed and placed in a waterproof envelope and

shipped with the samples. Chain-of-custody tape will be placed over the lid at the front

and back of each shipping cooler to monitor sample integrity en route to the laboratory.

The sample custodian will then check the contents of the cooler with those samples

listed on the chain-of-custody form. If damage or discrepancies are noted, they will be

recorded in the remarks column provided, dated, and signed. They will be reported to

the laboratory supervisor who will inform the laboratory manager and QA officer.

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B. LABORATORY QA/QC

B.1 ANALYTICAL METHODS

Analytical methods and associated QA/QC used for the determination of target

compounds will be consistent with the analytical methods. Some general requirements

are outlined below. Refer to the methods for full details on the laboratory QA/QC

requirements.

B.2 PROOFING OF SAMPLING MEDIA

The laboratory should clean and proof all sampling media prior to the commencement

of the field sampling program. As a minimum, the following should be analysed and

confirmed to have less-than-detectable concentrations of the target parameters:

i) PUF/XAD Plugs: One plug from each batch cleaned will be extracted and

analysed for PAHs;

i) Glass Fibre Filters: One filter from each batch will be cleaned, extracted and

analysed for particulate; and

ii) Canister for VOCs: Each canister must be certified clean.

B.3 SURROGATE STANDARDS

PAHs - Surrogate standards will be added to each sample, blank, and spike just prior to

extraction and/or processing as a means of monitoring the effectiveness of the analytical

method. The recovery of all surrogates together with the laboratory's associated control

limits must be included in the analytical report.

B.4 REAGENT BLANK

PAHs – Each time a set of samples is extracted or there is a change in reagents, a reagentsolvent blank should be processed as a safeguard against chronic laboratory

contamination.

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B.5 LABORATORY (PROCESS) BLANKS

PAHs – One PUF/XAD filter from every 20 will be analysed prior to shipment to the

field. The laboratory blank is a sample generated by the laboratory designed to monitor

the introduction of artifacts into the process. The blank level must be less than 10

ng/cartridge/filter assembly for a single PAHs component.

B.6 MATRIX SPIKE

M etal s - Audit strips for lead will be used to check the analytical method. Glass fibre

filter strips containing a known quantity of lead will be tested in the laboratory

consistent with the testing procedure for normal testing procedures. Three audit

samples in each of two known concentration ranges will be tested each quarter. Each

analytical batch (a minimum frequency of one in 20) will contain a check samplecomprised of a subset of the analytes to be determined on media matched to the field

investigative sample. The laboratory's associated control limits must be included in the

analytical report.

PAHs - The laboratory must assess the efficiency of the analytical and sampling

methods by means of matrix spiking activities. The matrix spiking study will involve

spiking the sampling media with the target analytes (or surrogates) in the lab, extracting

and analysing the samples in the laboratory. The matrix spike will be performed once

per 20 samples.

VOCs – Accuracy is determined by injecting VOC standards from an audit cylinder into

a sampler. The contents are analysed for the components contained in the audit canister.

Percent relative accuracy is calculated by the difference between the target and

measured concentrations. The accuracy must fall within 90 to 110 percent for the

canister to be deemed acceptable. If it does not fall within this range, the canister must

be cleaned and certified again. Although frequency is not provided in the method, an

evacuated canister will be charged with a known concentration of contaminant once

every 20 samples.

B.7 SOLVENT PROCESS BLANK/METHOD BLANK SAMPLES

PAHs – For each batch of samples (every 20 samples), at least one solvent process blank

(no cartridge or filter included) will be analysed. Blank levels should be less than

10 ng/sample.

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Metals and VOCs should be addressed - one per every batch of 20 or fewer samples.

Meta ls – For each batch of samples (every 20 samples), at least one method blank (no

filter included) will be analysed. Metals should not be detected in the sample.

VOCs – For every batch of samples, at least one method blank (humidified zero – grade

air or nitrogen) will be analysed. VOCs should not be detected above the detection

limits.

B.8 LABORATORY REPORTS AND TURNAROUND TIME

In addition to the results for the QC samples detailed above, all laboratory results must

include the following:

i) date received, extracted, and/or analysed;

ii) method detection limits for each parameter;

iii) all associated quality control limits;

iv) analytical results for all samples in units of both ppbv and µg/m3 (any samples

containing levels of target analytes near collection media saturation levels will be

clearly identified);

v) case narrative detailing any irregularities associated with samples;

vi) surrogate recoveries;

vii) unique report identifier; and

viii) copy of chain of custody.

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14458(24) Appendix A (Att.A)

ATTACHMENT A: FIGURE A.1

HI-VOL FIELD DATA FORMFORMER COKE OVENS SITE, SYDNEY, NOVA SCOTIA

Project Number 14458-35 Total Sampling Time hr min

Station Location Number Ave. Flow Rate m3/min

Filter Number Air Volume m3

Start Sampling Net PM-10 Weight gm

m d y hr min m3/min

Stop Sampling PM-10 Concentration mg/ m3

m d y hr min m3/min

Wind: calm light gusty Remarks

Visibility: clear hazy

Sky: clear scattered overcast

Humidity: dry moderate humid

Temperature °C: <0 0-10 10-2020-30 >30

Instrument Last Calibrated

GUIDELINES

- Faceplate must be handtight- Flow rate must be ±10% of established flow rate- Faceplate gasket must be in good condition- Rotameter must be free of foreign material- Rotameter operation must be stable- Sampler motor brushes must be changed every 400 hours of operation

Sample was collected within the above guidelines

Signature

Remarks

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GENERAL AIR SAMPLING DATA FORMFORMER COKE OVENS SITE, SYDNEY, NOVA SCOTIA

Project Number 14458-35

Sampling Parameter(s)PAHs

Sample ID Total Sampling Time hr min

Station Location Number Ave. Flow Rate m3/min

Pump Identifier Air Volume m3

Start Sampling Stop Samplingm d y hr min m3/min m d y hr min m3/min

Wind: calm light gusty Visibility: clear hazy

Sky: clear scattered overcast

Humidity: dry moderate humid rain

Temperature °C: <0 0-10 10-20 20-30 >30

Instrument Last Calibrated

Sample Media Information:

Type: Serial Number (if applicable):

Sample Type: Field / Duplicate / Blank / Spike

Flow Rate AmbientItem Time (Q)* mL/min Temperature °C Comments

123

Average

* Flow rate from magnehelic gauge or soap bubble calibrator (specify which)

Remarks

Sampler Name

Signature

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14458(24) Appendix A (Att.A) Page ______ of ______


CANISTER SAMPLING FOR VOCsREFERENCE EPA METHOD TO-14A

FIELD DATA SHEET

CLIENT: Environment Canada SAMPLE ID:

LOCATION: Sydney Coal Tar Site STACK DIA. :

PROJECT #: 14458-35 BAR. PRESSURE: “Hg/kPa

VENT #: AMBIENT TEMP: °F/°C

DATE: REL. HUMIDITY: %

SAMPLED BY: WIND SPEED/DIR.:

SAM PLING DATA

FLOW CALIBRATION

AmbientTemperature

CanisterPressure

RegulatedCanisterFlowrate

Time (°F / °C) (“Hg / kPa / psi) Time ( )

Start

Finish

Comments:

CALI BRATION DETAI LS

Canister Serial No.:Last Canister Leak Check Date:

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Page 1 of 1

Paramet er Dupl i cat e Sample Fiel d Blank Process/M ethod Mat ri x Reagent Surrogate

Blank Spi ke Blank Sample

24-Hour Samples

PM-10/ PM2.5 1 in 10 1 in 10 NA NA NA

Metals 1 in 10 1 in 10 1 per 20 samples 6 tests per quarter NA

PAH 1 in 10 1 in 10 1 per 20 samples 1 per 20 samples 1 per 20 samples

VOCs 1 in 10 1 in 10 1 per 20 samples 1 per 20 samples NA

Real-Time Sampling

Portable GC 10% of all injections 10% of all injections NA NA NA NA

Notes:

PM-10 Particulate matter with diameter no greater than 10 microns.

PM-2.5 Particulate matter with d iameter no gr eater than 2.5 microns.

PAH Polynuclear Aromatic Hydrocarbons

VOCs Volatile Organic Compounds

GC Gas Chromatographic Analyses

QA/ QC Quality Assurance/ Quality Control

NA Not applicable; not required in the method.

Laboratory QA/QC Field QA /QC

ATTACHMENT A: TABLE A.1

QUALITY ASSURANCE/QUALITY CONTROL SAMPLES


SYDNEY, NOVA SCOTIA


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Page 1 of 1

SUMMARY OF SHIPPING CONTAINERSFORMER COKE OVENS SITE

SYDNEY, NOVA SCOTIA

I t em Parameter Sampl i ng M edi a Shi ppi ng Cont ai ner/Det ai l s

Ambient Air Sampling

1. VOCs None - SUMMA CanistePacking Carton

2. PAHs PUF/XAD in glass Wrap glass cartridge in aluminum foil; placecartridge plus glass fibre filter in plastic petri dish; placeglass Fibre Filter cartridge and dish in plastic zip-lock bag; label

bag with sample I.D.

3. TSP,Metals, Glass Fibre Filter Place folded filter into manila envelope.PM-10 & PM-2.5

Notes:

PAHs Polycyclic Aromatic Hydrocarbon, including screening for phenols, cresols and xylenols.


PM-10 Particulate Matter <10 microns

PM-2.5 Particulate Matter <2.5 micronsPUF Polyurethane Foam

ATTACHMENT A: TABLE A.2


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#S

#S

#S

#S

#S

#S

figure 1.1PERMANENT SAMPLING STATIONS

AMBIENT AIR MONITORING PROGRAMSydney, Nova Scotia

N

250 0 250 500 750 Meters

SYDNEYHARBOUR

COKEOVENS

STATION 1

STATION 2

STATION 3

STATION 4

STATION 5

STATION 6

PARCEL BOUNDARY

ROAD EDGE

#S PROPOSED AIR MONITORING STATIONLEGEND

SITE BOUNDARY

M

M

M

M PROPOSED MOBILE STATION SAMPLING POINT

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TEMPORARILY SUSPEND

ACTIVITY, MODIFY

AND RESTART

DOWNWIND READING

REALTIME PM

< 110% OF

UPWIND ?

DOWNWIND REALTIME

PM READING > AAC?

(43ug/m )

COMMENCE MONITORING

AT UP WIND AND

DOWNWIND LOCATIONS

EXCEED AAC

(15 MINUTE ROLLING

AVERAGE ?)(43ug/m )

ROUTINE REALTIME PM

MONITORING AT

WORK ZONE

NO

YES

YES

YES

YES

NO

NO

10

2

2

10

10

figure 2.1

FLOWCHART OF MONITORING FOR PMCOKE OVENS SITE DEMOLITIONMUGGAH CREEK REMEDIATION

14458-35(017)GN-WA001 NOV 02/2000

10

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ROUTINE PID MONITORING

AT 15m DOWNWIND

FROM WORK ZONE

PID READING

EXCEED 0.1ppm

(15 MINUTE ROLLING

AVERAGE ?)

COLLECT GC SAMPLES

2 DOWNWIND AND

1 UPWIND AT

SITE BOUNDARY

DOWNWIND

COPC CONCENTRATION

> MAAC

?

DOWNWIND

COPC CONCENTRATION

> 110% OF UPWIND COPC

CONCENTRATION

NO

NO

NO

YES

YES

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