SDMS DOCID # 1146524 SEPTEMBER 10, 2014 …content related to handling of explosives, open burn permitting, monitoring, and air quality. Accordingly, H+A’s certification applies

VIA FEDERAL EXPRESS SEPTEMBER 10, 2014 Ms. Andria Benner Remedial Project Manager U.S. EPA, Region 9Superfund Division SFD 6-2 75 Hawthorne Street San Francisco, CA 94105 Re: Time-Critical Removal Action Work Plan, Building #51 Demolition, Revision 1.0, Prepared for Apache Nitrogen Products, Inc., Benson, Arizona. Dear Ms. Benner: Enclosed is a hard copy of the above-referenced report and a compact disk (CD) containing nine electronic files of attachments. This work plan for a Time-Critical Removal Action (“TCRA”) for the Apache Nitrogen Products, Inc. (ANPI) controlled burn of Building #51 was prepared as a collaborative effort among several ANPI contractors. While the document was compiled and certified by Hargis + Associates, Inc. (H+A), the scope of the TCRA extends beyond the traditional technical expertise of H+A. Therefore there is considerable reliance on the other ANPI contractors for input, primarily for procedural content related to handling of explosives, open burn permitting, monitoring, and air quality. Accordingly, H+A’s certification applies only to its area of technical expertise in hydrogeology, soil characterization, and regulatory compliance. If you have any questions or comments, please contact me at (520) 720-2114 or Dr. Leo Leonhart of Hargis + Associates, Inc. at (520) 881-7300, extension 201. Sincerely, For Craig E. Boudle APACHE NITROGEN PRODUCTS, INC. Craig E. Boudle Safety, Health and Environmental Manager Enclosure cc: Laura Fischer, ADEQ

SDMS DOCID # 1146524

SEPTEMBER 1 o, 2014

TIME-CRITICAL REMOVAL ACTION WORKPLAN

BUILDING #51 DEMOLITION

-----------

REVISION 1.0

APACHE POWDER SUPERFUND SITE

COCHISE COUNTY, ARIZONA

PREPARED FOR:

APACHE NITROGEN PRODUGS, INC. P.O. BOX 700

BENSON, AZ 85602

HARGIS+ ASSOCIATES, INC. HYDROGEOLOGY • ENGINEERING

HARGIS + ASSOCIATES, INC.

ANPI 130 147-TCRA WP-Rev 1 0 FINAL 09/10/14 i

TIME-CRITICAL REMOVAL ACTION WORK PLAN


REVISION 1.0

APACHE POWDER SUPERFUND SITE COCHISE COUNTY, ARIZONA

TABLE OF CONTENTS Section Page ACRONYMS AND ABBREVIATIONS ........................................................................................ vi

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

1.1 SITE LOCATION AND DESCRIPTION .......................................................................2

1.2 OPERATIONAL BACKGROUND ................................................................................3

1.3 REGULATORY COMPLIANCE HISTORY ..................................................................4

1.4 RESPONSIBLE AGENCIES .......................................................................................5

1.4.1 Environmental Protection Agency (EPA) .........................................................5

1.4.2 Arizona Department of Environmental Quality (ADEQ) ...................................6

1.5 PROJECT ORGANIZATION .......................................................................................6

1.5.1 Apache Nitrogen Products, Inc. (ANPI) ...........................................................6

1.5.2 Southwest Energy, LLC (SWE) .......................................................................6

1.5.3 Stantec ............................................................................................................7

1.5.4 Hargis + Associates, Inc. (H+A) ......................................................................7

1.5.5 Spray Systems Environmental (SSE) ..............................................................7

1.5.6 Local Emergency Planning Committee (LEPC) ..............................................8

1.5.7 Local Fire Departments ...................................................................................8

1.5.8 Tucson Police Department – Specialized Response Division .........................8

2.0 AREA DESCRIPTION ......................................................................................................... 9

2.1 HAND PACKED NO. 6 – BUILDING #51 ....................................................................9

2.2 TALLEY MIX HOUSE NO. 4 – BUILDING #232 .......................................................10

2.3 NEARBY AREAS AND STRUCTURES ....................................................................10

3.0 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARS) ......... 12

3.1 FEDERAL ARARS ....................................................................................................12


TABLE OF CONTENTS (continued) Section Page

ANPI 130 147-TCRA WP-Rev 1 0 FINAL 09/10/14 ii

3.2 STATE ARARS .........................................................................................................12

3.2.1 Action-Specific ARARs Identified by ADEQ ..................................................12

3.2.2 Chemical-Specific ARARs Identified by ADEQ .............................................13

3.3 TO BE CONSIDERED (TBCS) ..................................................................................13

4.0 ENVIRONMENTAL CONDITIONS .................................................................................... 14

4.1 TERRAIN SETTING ..................................................................................................14

4.2 VEGETATION ...........................................................................................................14

4.3 METEOROLOGICAL CONDITIONS .........................................................................14

4.4 GEOLOGY AND HYDROGEOLOGY ........................................................................15

5.0 SCOPE OF WORK ............................................................................................................ 16

5.1 APPROPRIATENESS OF TREATMENT TECHNOLOGY........................................16

5.2 SEPARATION DISTANCE CALCULATIONS ...........................................................17

5.3 PROJECT TIMELINE ................................................................................................19

6.0 STANDARD OPERATING PROCEDURES ...................................................................... 21

6.1 PREPARATION AND PLANNING ............................................................................21

6.1.1 Permits, Insurance and License ....................................................................21

6.1.2 Community Notification Plan .........................................................................21

6.1.3 Local Authority Coordination .........................................................................22

6.1.4 Air Quality Modeling, Permit and Monitoring Plan .........................................22

6.1.4.1 Meteorological Monitoring Plan ......................................................22

6.1.4.2 Community Exposure Monitoring Plan ...........................................22

6.1.4.3 Plant Site Area Monitoring Plan ......................................................23

6.1.5 Seismic Monitoring Plan ................................................................................23

6.1.6 Video Monitoring Plan ...................................................................................24

6.1.7 Health and Safety Plan ..................................................................................24

6.1.8 Contingency Plan ..........................................................................................25

6.2 PRE-BURN PROCEDURES .....................................................................................26

6.2.1 Asbestos, Lead Roof Planking and Roof Trusses Removal ..........................26

6.2.2 Grubbing Around Building #51 ......................................................................27

6.3 CONTROLLED BURN PROCEDURES ....................................................................27

6.3.1 Detonation Cord Preparation .........................................................................27

6.3.2 Hod Preparation ............................................................................................28

6.3.3 Air and Seismic Monitoring ............................................................................28

6.3.4 Video Monitoring............................................................................................28

6.3.5 Road Closure ................................................................................................29

6.3.6 Emergency Services Standby .......................................................................29


TABLE OF CONTENTS (continued) Section Page

ANPI 130 147-TCRA WP-Rev 1 0 FINAL 09/10/14 iii

6.3.7 Site Sweep ....................................................................................................29

6.3.8 Initiate Burn ...................................................................................................29

6.3.9 Active Fire Watch ..........................................................................................30

6.3.10 Passive Fire Watch........................................................................................30

6.4 POST BURN INSPECTION AND CONTROLLED RE-BURN (IF NECESSARY) .....30

6.4.1 Post Burn Inspection .....................................................................................30

6.4.2 Controlled Re-Burn (If Necessary) ................................................................30

6.4.2.1 Surface Preparation........................................................................31

6.4.2.2 Controlled Re-Burn Monitoring .......................................................31

6.4.2.3 Controlled Re-burn Road Closure and Emergency Services Standby............................................................................31

6.4.2.4 Controlled Re-burn Site Sweep ......................................................32

6.4.2.5 Initiate Controlled Re-burn ..............................................................32

6.4.2.6 Controlled Re-burn Fire Watches ...................................................32

6.4.2.7 Post Controlled Re-burn Road Inspection ......................................32

6.5 ASH WASTE CHARACTERIZATION...........................................................................32

7. 0 CONFIRMATION SOIL SAMPLING ...................................................................................... 33

7.1 SAMPLING RATIONALE AND METHOD ....................................................................33

7.2 TEST METHODS .........................................................................................................35

7.3 USE OF STANDARD LABORATORY CONFIRMATION DATA ..................................35

7.3.1 Field Quality Control Samples ..........................................................................36

7.3.2 Assessment of Field Contamination (Blanks) ...................................................36

7.3.2.1 Equipment Blanks ................................................................................................36 7.3.2.2 Field Blanks ..........................................................................................................36 7.3.2.3 Trip Blanks ...........................................................................................................36 7.3.2.4 Temperature Blanks .............................................................................................36

7.3.3 Assessment of Field Variability (Field Duplicate or Co-Located Samples) .......37

7.4 BACKGROUND SAMPLES..........................................................................................37

7.5 FIELD SCREENING AND CONFIRMATION SAMPLES .............................................37

7.6 LABORATORY CONTROL SAMPLES ........................................................................38

7.7 WASTE MANAGEMENT AND/OR DISPOSAL ............................................................38

8. 0 DOCUMENTATION AND REPORTING................................................................................ 39

9. 0 REFERENCES ...................................................................................................................... 40


TABLE OF CONTENTS (continued)

ANPI 130 147-TCRA WP-Rev 1 0 FINAL 09/10/14 iv

TABLES Table 1 PROJECT CONTACTS AND EMERGENCY PHONE NUMBERS 2 PROJECT TIMELINE 3 RECOMMENDED POST DEMOLITION ASH WASTE AND CONFIRMATION SOIL

SAMPLING PLAN FOR BUILDING #51 4 RECOMMENDED CLEANUP LEVELS FOR COMPOUNDS NOT PREVIOUSLY

ADDRESSED AT THE SITE

FIGURES Figure 1 LOCATION OF APACHE POWDER SUPERFUND SITE – OVERVIEW 2 LOCATION OF APACHE POWDER SUPERFUND SITE- AERIAL 3 TOPOGRAPHIC LOCATION OF BUILDING #51 WITH CROSS SECTION 4 LOCATION OF BUILDING #51 WITH SEPARATION DISTANCES AND EQUIPMENT POSITIONS 5 PROJECT ORGANIZATION CHART 6 APACHE NITROGEN PRODUCTS, INC. WIND ROSE


TABLE OF CONTENTS (continued)

ANPI 130 147-TCRA WP-Rev 1 0 FINAL 09/10/14 v

APPENDICES Appendix A BUILDING INFORMATION (Buildings #51, #232, and HOD Cover Information) B OPEN BURN PERMIT #5861 C COMMUNITY NOTIFICATION PLAN D AIR MONITORING PROGRAM E SEISMIC MONITORING EQUIPMENT SPECIFICATIONS

COMPACT DISC (CD) SUPPORTIVE MATERIALS E-File

1 WORK PLAN TO DECOMMISSION AND DEMOLISH SITE BUILDINGS, APACHE POWDER SUPERFUND SITE, COCHISE COUNTY, ARIZONA

2 APACHE NITROGEN PRODUCTS, INC. BUILDING DEMOLITION PROGRAM

SAMPLING AND ANALYSIS PLAN (SAP), REVISION 2.0, APACHE POWDER SUPERFUND SITE, COCHISE COUNTY, ARIZONA

3 QUALITY ASSURANCE PROJECT PLAN (QAPP) ADDENDUM FOR BUILDING

DEMOLITION AND SULFUR REMOVAL, REVISION 2.0, APACHE POWDER SUPERFUND SITE, COCHISE COUNTY, ARIZONA

4 CONTRACTORS’ STATEMENT OF QUALIFICATIONS 5 OPEN BURN PERMIT APPLICATION – EMISSIONS INVENTORY AND AIR IMPACT

ANALYSIS 6 APACHE NITROGEN PRODUCTS, INC. HEALTH AND SAFETY PLAN (HASP) 7 APACHE NITROGEN PRODUCTS, INC. SAFETY AND WORK RULES 8 ARIZONA APACHE NITROGEN PRODUCTS, INC. EMERGENCY RESPONSE

PLAN (ERP) 9 MINI-SEIS DIGITAL SEISMOGRAPH OPERATING MANUAL


ANPI 130 147-TCRA WP-Rev 1 0 FINAL 09/10/14 vi

ACRONYMS AND ABBREVIATIONS ACM asbestos-containing material

ADEQ Arizona Department of Environmental Quality

ANPI Apache Nitrogen Products, Inc.

ARARs applicable or relevant and appropriate requirements

ARS Arizona Revised Statutes

bls below land surface

CERCLA Comprehensive Environmental Response, Compensation,

and Liability Act

CFR Code of Federal Regulations

COCs contaminants of concern

dBs Decibels

DU decision unit

EPA U.S. Environmental Protection Agency

Ft Feet

gr grains

H+A Hargis + Associates, Inc.

HASP Health and Safety Plan

HPA Historic Preservation Act

HPLC High Performance Liquid Chromatography

ISM incremental sampling methodology

Lb Pound

Lbs Pounds

LEPC Local Emergency Planning Committee


ACRONYMS AND ABBREVIATIONS (continued)

ANPI 130 147-TCRA WP-Rev 1 0 FINAL 09/10/14 vii

mg/L milligrams per liter

mL milliliter

MSD Minimum Separation Distance

msl mean sea level

NG nitroglycerin

NPL National Priorities List

O&M Operations and Maintenance

OSC on-scene-coordinator

PETN pentaerythritol tetranitrate

PPE personal protective equipment

QAPP Quality Assurance Project Plan

QC Quality Control

RCRA Resource Conservation and Recovery Act

ROD Record of Decision

SAP Sampling and Analysis Plan

SHE Safety, Heath, and Environmental

SOPs Standard Operating Procedures

SOQ Statement of Qualifications

SRLs Soil Remediation Levels

SSE Spray Systems Environmental

SWE Southwest Energy, LLC

TBC To Be Considered

TCLP Toxicity Characteristic Leaching Procedure

TCRA Time-Critical Removal Action


ACRONYMS AND ABBREVIATIONS (continued)

ANPI 130 147-TCRA WP-Rev 1 0 FINAL 09/10/14 viii

TCRA Work Plan Time-Critical Removal Action Work Plan for Building #51 Demolition

the Area Former Powder Line Building Hand Pack No. 6 #51

the Site Apache Powder Superfund Site located in Cochise County, Arizona

TNT trinitrotoluene

TPD Tucson, Arizona Police Department, Specialized Response Division,

Bomb Squad

VOC volatile organic compound


ANPI 130 147-TCRA WP-Rev 1 0 FINAL 09/10/14 1

TIME-CRITICAL REMOVAL ACTION WORK PLAN


REVISION 1.0

APACHE POWDER SUPERFUND SITE COCHISE COUNTY, ARIZONA

1.0 INTRODUCTION

The U.S. Environmental Protection Agency (EPA) received written notification dated

February 14, 2014, from Apache Nitrogen Products, Inc. (ANPI), regarding the discovery of two

potentially explosive residual waste materials at the Apache Powder Superfund Site located in

Cochise County, Arizona (the Site) (ANPI, 2014) (Figures 1, 2 and 3). These potentially

explosive materials were discovered as part of ANPI’s effort to complete the surveying and

inventorying of the structures and buildings in the former Powder Line to comply with its on-

going Section 106 Historic Preservation Act (HPA) review. ANPI plans to destroy these

potentially explosive materials via a controlled burn. All work associated with this TCRA falls

under the umbrella of a comprehensive ANPI demolition program involving efforts to demolish

approximately 160 obsolete buildings in an effort to modernize the plant (H+A, 2012; 2013 a

and b).

Specifically, ANPI discovered two wooden hods (i.e., carts) that potentially contain 5 cubic feet

of nitroglycerin (NG)-mixed waste in Building #51, and approximately 50 linear feet of 85–Grain

pentaerythritol tetranitrate (PETN) detonation cord in Building #232. ANPI plans to transfer the

PETN detonation cord from Building #232 to Building #51 and then burn Building #51.

Demolition survey information, operational history, and photos of both buildings that are located

in the historic Powder Line are provided (Appendix A).

In a letter dated, March 4, 2014, EPA requested that ANPI submit a Removal Action Work Plan

to both EPA and the Arizona Department of Environmental Quality (ADEQ) (EPA, 2014). To

expedite the demolition by means of a controlled burn and based on the urgency of the

situation, this removal action has been categorized by EPA as a Time-Critical Removal Action

(TCRA).



This TCRA Work Plan for Building #51 Demolition (TCRA Work Plan) presents the proposed

scope of work; preparatory tasks; on-site procedures; coordination efforts with the regulatory

agencies and local responders; community notifications; and other relevant information for a

safe removal action.

This work plan for a Time-Critical Removal Action (“TCRA”) for the Apache Nitrogen Products,

Inc. (ANPI) controlled burn of Building #51 was prepared as a collaborative effort among several

ANPI contractors. While the document was compiled and certified by Hargis + Associates, Inc.

(H+A), the scope of the TCRA extends beyond the traditional technical expertise of H+A.

Therefore there is considerable reliance on the other ANPI contractors for input, primarily for

procedural content related to handling of explosives, open burn permitting, monitoring, and air

quality. Accordingly, H+A’s certification applies only to its area of technical expertise in

hydrogeology, soil characterization, and regulatory compliance.

1.1 SITE LOCATION AND DESCRIPTION

The Site is located in Cochise County, Arizona, approximately seven miles southeast of the

incorporated town of Benson and 2.5 miles southwest of the unincorporated town of St. David

(Figure 1). The Site covers approximately nine square miles and includes approximately 1,200

acres of land owned by ANPI, formerly known as the Apache Powder Company (Figure 2). The

Site is located in a portion of Section 12, Township 18 South, Range 20 East, and Portions of

Sections 6, 7, and 8 in Township 18 South, Range 21.

The San Pedro River bounds the eastern side of the Site, running from the southeast corner of

the property north towards the northwest corner (Figures 2, 3 and 4). The San Pedro River is a

significant riparian corridor. The San Pedro River National Riparian Conservation Area, owned

by the Bureau of Land Management, is located approximately two miles south of the Site along

the San Pedro River.

Major land uses within the vicinity of the Site include agricultural and low-density residential use.

The Site is located on an alluvial floodplain and is surrounded by areas of agricultural land with

uses including field and grazing areas. Rural homesteads surround the Site, some which are

farms and livestock properties while others are residential. Outside of town there are localized

areas of low-density residential land use including residents and farm outbuildings.



1.2 OPERATIONAL BACKGROUND

ANPI property was acquired at various times beginning in 1919. Presently the property extends

over an area of approximately 1,200 acres (ANPI, 1998). ANPI officially began operation of its

manufacturing processes in 1922. The primary products manufactured at the start-up were

mixed nitric and sulfuric acids used for the production of NG. The NG was processed and

packaged into dynamite sticks in an area of the plant known as the “Powder Line.” The Powder

Line comprised a series of buildings including nitrators, and mix, pack, and talley houses, etc. in

a configuration strung out along a ravine known as the “Wash 5” watershed. The buildings

containing explosive materials were configured with blast walls and spaced so that, in the event

of an explosion in one building, a chain of explosions involving adjacent buildings would not

occur. In addition, the location of the Powder Line afforded a safety measure by virtue the

manufacturing operations being located in the low areas or the watershed with high ground

adjacent on both sides. This served as a natural barrier for flying debris on those rare

occasions when explosions might occur (ANPI, 1998). The “Powder Line” was abandoned in

the mid-1980s in favor of operational changes that focused on increasing production of

ammonium nitrate.

In 1968, ANPI began manufacturing detonation cord containing PETN at the Cord Plant.

Manufacturing of detonation cord ceased in April 1994 (Hargis + Associates, Inc. [H+A], 1995).

ANPI broadened its product line to include ammonium nitrate, nitrogen-based fertilizers, blasting

agents, and nitric acid. Today, ANPI manufactures various forms of ammonium nitrate

fertilizers, prill, liquid ammonium nitrate, aqua ammonia, nitric acid, and the agricultural product

AN20.

Historically, these operations produced both liquid and solid wastes that were disposed on ANPI

property. These past uses and disposal practices resulted in contamination of soils on the

facility and contamination of groundwater in a perched system underneath the plant operations

area, the nearby shallow aquifer, and the San Pedro River. The groundwater contaminants in

the Southern Area of the Site are nitrate and perchlorate. In the Northern Area of the Site, the

shallow aquifer groundwater is contaminated only with nitrate.

http://en.wikipedia.org/wiki/Ammonium_nitrate



1.3 REGULATORY COMPLIANCE HISTORY

ANPI’s regulatory compliance history stretches over two decades and the highlights are

summarized as follows:

1989 - High levels of nitrates were discovered in the shallow aquifer that supplied

domestic water to certain nearby residences. ANPI began supplying the affected

residences bottled water while this issue was investigated. Subsequently, ANPI

undertook a program to replace eight privately owned domestic supply wells by

constructing new wells tapping the uncontaminated deeper aquifer.

1990 - The Site was listed on the National Priorities List (NPL) by EPA pursuant to its

authorities under the Comprehensive Environmental Response, Compensation, and

Liability Act (CERCLA).

June 1992 - ADEQ and EPA agreed that ADEQ would be responsible for ensuring

ANPI’s compliance with state requirements for aquifer protection, air quality, and

hazardous waste management, and that EPA would be responsible for overseeing

Apache’s CERCLA cleanup.

October 1994 - EPA issued a Record of Decision (ROD) which selected various

remedial alternatives for cleanup of the soils and groundwater contamination at the Site

(EPA, 1994a). ANPI has undertaken various investigative studies and remedial actions

to address both soil and groundwater contamination under the direction of EPA Region

IX and also under the oversight of ADEQ. ANPI also conducted cleanup actions under

regulatory requirements of the ADEQ 1994 Consent Decree (State of Arizona, 1994).

ADEQ entered into a Consent Decree with ANPI for cleanup of other areas of the Site

where manufacturing operations were still ongoing. ADEQ and EPA divided regulatory

oversight for the contaminated evaporation ponds; EPA took responsibility for the

inactive ponds and ADEQ took responsibility for the formerly active ponds.

1998 - ANPI met all the hazardous waste program requirements of the ADEQ 1994

Consent Decree (ADEQ, 1998; State of Arizona, 1998a and 1998b).

2001-2002 - ADEQ decided that the remedy for the formerly active ponds should be

consistent with the soil remedies selected under Superfund for the inactive ponds.

KEH

Rectangle

KEH

Line



September 2008 - ANPI completed, with EPA and ADEQ oversight, the construction of

all remedial actions required at the Site. The Site is currently in the operations and

maintenance (O&M) phase of the remedy. The agencies continue to coordinate

oversight of O&M activities and conduct technical meetings on a periodic basis.

2012 - As part of the HPA review, ANPI surveyed and inventoried the former Powder

Line buildings and infrastructures in accordance with the EPA-approved Work Plan to

Decommission and Demolish Site Buildings (H+A, 2012) (CD E-Files 1, 2, and 3). This

plant improvement initiative by ANPI undertakes the decommissioning and demolition of

approximately 165 obsolete buildings on the Site.

2014 - Because the Site is listed on the NPL under CERCLA, EPA directed ANPI to

prepare this TCRA Work Plan for submittal to EPA and ADEQ. This submittal will

facilitate the necessary coordination and compliance and serve as information that will

be useful to the local support agencies and interested parties for the demolition of

Building #51.

1.4 RESPONSIBLE AGENCIES

The primary regulatory agencies responsible for approval and operational oversight of this

TCRA are the EPA and ADEQ (Figure 5). There is an established commitment for thorough

coordination between EPA and ADEQ associated with this TCRA. EPA is the lead regulatory

agency for the CERCLA action and also has engaged participation of ADEQ throughout the

project. ADEQ is responsible for overseeing the proposed actions involving the controlled burn

and has reviewed ANPI’s application for an Open Burn Permit.

1.4.1 Environmental Protection Agency (EPA)

EPA will consult with ADEQ on the TCRA to be conducted at the Site. Ms. Andria Benner is the

EPA Remedial Project Manager. EPA understands the requirements for Arizona State

participation, and the need to designate an appropriate contact person. EPA has appointed an

on-scene-coordinator (OSC), Mr. Rich Martyn. Furthermore, the EPA OSC will ensure

appropriate Arizona State involvement in all aspects of this TCRA.



1.4.2 Arizona Department of Environmental Quality (ADEQ)

ADEQ will coordinate this TCRA with the EPA and other local agencies, if necessary. ADEQ’s

authority is based on delegated federal programs with specific Arizona State laws and

regulations, which outline a process based on various planned removal actions (e.g., controlled

burn). Oversight by ADEQ generally exists through the open burn permit process. ADEQ’s

involvement with this TCRA partially depends on its communications with EPA. Ms. Laura

Fischer is the ADEQ Federal Program Liaison and Mr. Balaji Vaidyanathan is the ADEQ Air

Quality Program Director.

1.5 PROJECT ORGANIZATION

The primary responsible TCRA team members are identified and depicted in Table 1 and

Figure 5. There is an established commitment for thorough coordination between TCRA team

members and the regulatory agencies.

1.5.1 Apache Nitrogen Products, Inc. (ANPI)

ANPI is the primary responsible party for compliance with the CERCLA Unilateral Administrative

Order (EPA, 1994b). ANPI Safety, Health, and Environment (SHE) Manager, Mr. Craig Boudle,

will provide overall guidance of the TCRA (Table 1). ANPI will coordinate the major aspects of

this TCRA project; review each work product generated for the removal action; and interface

with EPA, ADEQ, Local Emergency Planning Committee (LEPC), ANPI-contractors, and other

local fire departments, as required.

1.5.2 Southwest Energy, LLC (SWE)

ANPI has hired SWE, an experienced subject matter contractor, to implement the controlled

burn of Building #51 located in the historic Powder Line. SWE will contract directly with ANPI

and will perform many of the site preparation, monitoring and burn activities. The primary

controlled burn implementation contacts are subject matter experts, Mr. Jerry Harris and Mr.

Phil Melick (Table 1). SWE is located in Tucson, Arizona, and a Statement of Qualifications

(SOQ) is provided (CD E-File 4).



1.5.3 Stantec

Stantec (formerly JBR Environmental) will contract directly with ANPI and will have the lead role

in air modeling and designing the appropriate air monitoring program, as required. Dr. Louis

Thanukos is the primary Stantec contact (Table 1). Stantec is an experienced environmental

consulting firm specializing in a variety of air quality management services, such as regulatory

guidance, visible emission observation, air quality compliance audits, permit applications, and

pollution transport analysis (CD E-File 4). Since 2011, ANPI has retained Stantec as its primary

air quality consultant.

1.5.4 Hargis + Associates, Inc. (H+A)

H+A will contract directly to ANPI and will have the lead role in CERCLA consulting, as required.

H+A's role will be continued coordination with EPA in assuring that the applicable CERCLA

requirements are met. In addition to preparation of the TCRA workplan, H+A has a role in

performing post-burn sampling of ash and soil materials to determine any residual hazards, and

in working with EPA to determine the fate of any hazardous wastes identified. Dr. Leo Leonhart

is H+A’s project director (Table 1). H+A has over two decades of environmental onsite

consulting history with ANPI. H+A directed a similar controlled burn at the Site in December

1999 in fulfillment of another EPA TCRA. This effort was for the purpose of pre-treating

trinitrotoluene (TNT) waste discovered onsite as a result of a pre-ANPI operation (H+A, 1999a,

1999b, and 2002). For this TCRA, H+A will provide consulting services with regard to CERCLA

matters and will perform the ash waste characterization and confirmatory soil sampling

(Sections 6.7 and 7.0, respectively) as well as preparing the Final TCRA Completion Report.

H+A will also assist ANPI in determining the need for waste disposal, if necessary, in a manner

consistent with the CERCLA offsite rule (Section 7.7). H+A is located in Tucson, Arizona, and a

SOQ is provided (CD E-File 4).

1.5.5 Spray Systems Environmental (SSE)

SSE, an experienced asbestos and lead abatement firm, will contract directly with ANPI and will

have the lead role in performing pre-burn abatement for the demolition of Building #51 (i.e., roof

and window caulking and paint removal). This work is being done in conjunction with the

umbrella demolition plan. Mr. Steve Beirl is the primary SSE contact for the pre-burn asbestos

and lead abatement activities proposed for Building #51 (Table 1). SSE is located in Phoenix,

Arizona and a SOQ is provided (CD E-File 4).



1.5.6 Local Emergency Planning Committee (LEPC)

The Cochise County LEPC is also involved in certain aspects of this TCRA. The LEPC is a

committee appointed by the State Emergency Response Commission, as required by

Emergency Planning and Community Right-to-Know Act of 1986. The Cochise County LEPC

primary contact is Mr. Norman Sturm. The LEPC’s fundamental responsibility is to provide

support for the safety and welfare of the nearby public before, during, and after the controlled

burn. The LEPC will work closely with ANPI to ensure the preparation for, response to, and

recovery from the controlled burn, as required.

1.5.7 Local Fire Departments

The local fire departments are also involved in certain aspects of this TCRA. The local fire

department contacts are Chief Loyal Gephart of the St. David Fire Department and Chief Keith

Spangler of the Benson Fire Department. Chief Keith Spangler of the Benson Fire Department

will act as the Site Incident Commander during the controlled burn. The local fire department’s

fundamental responsibility is to provide support for the safety and welfare of the public. ANPI

will work closely with local fire departments to ensure response to and recovery from the

controlled burn, as required.

1.5.8 Tucson Police Department – Specialized Response Division

ANPI has enlisted the assistance of the Tucson, Arizona Police Department, Specialized

Response Division, Bomb Squad (TPD). The TPD, in collaboration with SWE, will lead the site

preparation, monitoring and burn activities, including the safe ignition of the controlled burn

including fuse setting and fire initiation. The TPD will also provide post-burn examination and

render safe clearance prior to entry for the ash waste sampling event. The primary contact for

the TPD Bomb Squad is Sergeant Timothy Froebe. In addition to the support to be rendered by

TPD, the controlled burn activity will also serve as a training exercise for TPD personnel.



2.0 AREA DESCRIPTION

“The Area” consists of the former Powder Line Building Hand Pack No. 6 (i.e., Building #51). As

previously stated, the PETN detonation cord discovered in Talley Mix House No. 4 (i.e., Building

#232) will be safely moved to Building #51 prior to the controlled burn. Both buildings, when in

operation, handled NG product, but were vacated in the mid-1980s. Since 2012, ANPI has

decommissioned and demolished various buildings and related infrastructure at the former

Powder Line. Pre-demolition survey results and photos of Buildings #51 and #232 are provided

(Appendix A).

2.1 HAND PACKED NO. 6 – BUILDING #51

Historically, Hand Pack Houses like Building #51 were used for packing by hand any of the

following materials: 1) gelatin or gelatinous-type powder; 2) semi-gelatinous or dynamite-type

powder; and 3) quarry or free flowing-type powder. Hand-packed products were placed into

various sized-weight bags; thin-walled shells; thin-walled seismograph shells; and thick-walled

shells.

Building #51 (also referred to as “Hand Pack No. 6) is the last pack house located on at the end

of the former Powder Line #2. It had an 8,000-pound gelatin and 12,500-pound dynamite (both

NG-based compounds) building limit capacity at any one time. The two wooden hods that were

discovered in Building #51 are each filled with approximately 5 cubic feet of what appears to be

a NG-mixed waste, possibly containing ground apricot and/or peach pits (used for packing or

filler in the dynamite sticks) and floor sweepings from decommissioned buildings (Appendix A).

Building #51 is two-stories, approximately 1,080 square feet, and is completely wood framed,

sided, floored, and surrounded by blast berms (Figure 2 and 3; and Appendix A). The blast

berms comprise high wooden stockades filled with earth materials. The hods are located on the

second story (i.e., upper floor). This building has not been in use since the 1980s.



Building #51 was surveyed for asbestos-containing material (ACM), other contaminants of

potential concern (COPCs), and lead containing materials. Building #51 pre-demolition survey

results identified friable asbestos in the roofing materials and lead paint. Two hods were

uncovered and NG-mixed waste was identified by Mr. Richard Coleman, a 40+ year ANPI

employee and former Powder Line worker.

2.2 TALLEY MIX HOUSE NO. 4 – BUILDING #232

Traditionally, Talley Mix Houses like Building #232 were used for the preparation of dynamite

and gelatin or semi-gelatin explosives. The mixing machine, located inside the building,

blended Nitro Cotton (nitrocellulose) and Dope with NG. The “Dope” ingredients depended on

the product being produced and could be any of the following: sawdust, ground apricot and/or

peach pits, ground walnut shells, dried beans, ammonium nitrate, and sugar.

Building #232 is near the beginning of the former Powder Line. An estimated 50 linear feet

of 85-Grain PETN detonation cord was discovered in Building #232 (Appendix A). PETN was

not used or manufactured in Building #232. It appears that the PETN detonation cord was

stored in the building for unknown reasons. As previously stated, the PETN detonation cord can

be safely moved from Building #232, relocated to Building #51, and then burned along with the

two hods containing the NG-mixed waste. Building #232 will not be burned but will be

decommissioned and demolished in accordance with the EPA-approved Work Plan to

Decommission and Demolish Site Buildings (H+A, 2012) (CD E-Files 1, 2, and 3).

2.3 NEARBY AREAS AND STRUCTURES

ANPI has examined the nearby structures and areas along the former Powder Line. The

historical presence of explosive materials in these nearby buildings has been examined to

determine other potential hazards and blast radii. There are no nearby magazines within

approximately 1,200 feet of Building #51. The nearest structures are depicted on Figure 4. All

these nearby buildings have been previously decontaminated and cleared of explosive materials

as follows:

Building #457 Dump House - is located approximately 115 feet on the east side of

Building #232. The Dump House was an end point for water after a wash down and

sometimes contained small amounts of NG.



Building #222 pH House - is located approximately 60 feet to the northeast of Building

#232. The pH House did temporarily contain small quantities of NG while testing the pH

(acidity) before sending it down to the next step of the process.

Building #222 Halfway House # 2, Building No.1 – is located approximately 86 feet to the

north of Building #232. This building was referred to as a "Catch Box"; that is, after a

building was washed down at the end of the day, all the "process" water would collect

here. Some NG would accumulate in the Catch Box but it would be scooped out of the

cradle and added back to the process. The former cradle was lead-lined.

Troughs from Building #212 (Nitrator #2) to Building #232 and from Building #232 to

Building # 240 (Weigh House #2) – have been thoroughly decontaminated. Troughs

were all rubber-lined when they were in use. ANPI decontamination procedures

instructed workers to flush troughs with water at the end of each day and to check for

blockages and leaks at the beginning of the workday. The troughs were last

decontaminated in 1986. The connecting troughs have been surveyed and are clear of

COCs and will be removed and managed with their connecting buildings. The trough

that transported NG from the Nitrator #2 to Building #221 is collapsed in place.

Building #52 - does not have explosive materials present. All buildings were previously

decontaminated, cleared, and re-inspected in 2013. The distance from Building #51 to

Building #52 is approximately 200 feet.

Distance from Building #51 to the small miscellaneous Building #12 located between

Building #51 and Building #52 - appears to be approximately 60 feet. The small utility

building was used for storage of extra machine parts, cleaning supplies, and paper

products. No explosives are present.

Storm water drainage pathways adjacent to Building #51 - Building #51 is

approximately 100 feet from Wash 5. Therefore, post-burn ash waste will be bermed to

protect from runoff if a rain event were to occur.



3.0 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARS) An evaluation of appropriate treatment technologies has been performed. As previously stated,

ANPI performed a similar TCRA at the Site in 1999 that involved an on-site controlled burn of

several tons of TNT waste discovered in the soils. Based on ANPI’s 1999 TCRA experience,

numerous consultations with demolition, subject matter, and explosive experts, as well as

meetings with the regulatory agencies, a controlled burn has been determined to be the most

appropriate treatment technology for this removal action.

In accordance with section 300.415(i) of the National Contingency Plan, on-site removal actions

are required to attain applicable or relevant and appropriate requirements (ARARs) to the extent

practicable. EPA requires that ARARs and items "to be considered" for protectiveness (known

as TBCs) be attained for hazardous substances remaining on-site at the completion of this

removal action. EPA also requires that the implementation of this TCRA comply with ARARs

and TBCs to protect public health and the environment. The Federal ARARs, State ARARs,

and TBCs for identified for this proposed removal action are listed below.

3.1 FEDERAL ARARS

Resource Conservation and Recovery Act (RCRA), 40 Code of Federal Regulations

(CFR) Parts 261 and 268. - The RCRA regulations in 40 CFR 261.23 (a)(6) govern the

classification of reactive waste as hazardous if it is capable of detonation or explosive

reaction if it is subjected to a strong initiating source or if heated under

confinement (D003). The RCRA regulations in 40 CFR 268.42 (a) address the land

disposal restrictions and provide the treatment standards for D003 RCRA wastes.

3.2 STATE ARARS

3.2.1 Action-Specific ARARs Identified by ADEQ

ADEQ Soil Remediation Rules, December 1997, Rule (R)18-7-20, Pre-Determined

Remediation Standards for the Constituents of Concern. - The State Soil Remediation

Rules (SRLs) establish the soil cleanup levels for residential and non-residential

properties to be used for this TCRA for areas within the removal site.



State of Arizona Air Quality Control Rules and Regulations, Title 18, Chapter 2, Article 6,

Emissions from Existing and New Nonpoint Sources, Unlawful Incineration, Arizona

Revised Statutes (ARS), Section 49-501and R18-2-602. - These regulations govern the

burning of dangerous materials in an open area where there is no safe alternative

method of disposal and is authorized by the Director of ADEQ.

ARS, R18-2-607, Storage Piles. - These regulations require taking reasonable

precautions such as chemical stabilization, wetting, or covering to prevent excessive

amount of particulate matter from becoming airborne.

Title 18, Chapter 8, Article 2, State Hazardous Waste Management Act. - The statute

also incorporates the federal RCRA "contained in" requirements for managing a

nonwaste material as if it were a hazardous waste and following specific procedures if

hazardous waste is stored in containers on site for more than 90 days.

3.2.2 Chemical-Specific ARARs Identified by ADEQ

Standards, R18-7-201 through R18-7-209. - These regulations identify State SRLs for

cleanup of contamination in soils which must be met by the party conducting the

cleanup, unless site specific remediation standards have been established.

Pre-Determined Remediation Standards, R18-7-205. These regulations identify the pre-

determined SRLs for the COCs at the Site.

3.3 TO BE CONSIDERED (TBCS)

At this time, no TBCs have been identified.



4.0 ENVIRONMENTAL CONDITIONS The following sections describe environmental conditions present at and near the Site such as

terrain, vegetation, meteorology, geology, and hydrogeology.

4.1 TERRAIN SETTING

The upland areas of the Site can be described as “badland” terrain. In the vicinity are eroded

alluvial terraces composed of northeast tending hills and valleys. Building #51 is located at an

elevation of approximately 3,665 feet mean sea level (msl) and adjacent to Wash 5. At this

location, Wash 5 is approximately 3,660 feet msl and is situated between two approximately 75-

foot high northeast trending terraces with elevations up to approximately 3,735 feet msl. Thus,

in addition to the wooden, earthen-filled berm (i.e., blast) walls, the terraces would provide

additional dampening of a potential blast at Building #51 (Figure 3, and Appendix A). This

configuration is evident in viewing the cross-section and topographic map (Figure 3).

4.2 VEGETATION

The primary undeveloped landscape consists of high desert chaparral mesquite bosques and

riparian cottonwood stands that line the property drainages including the San Pedro River. The

river channel is dominated by mixed riparian vegetation, including mesquite, tamarisk,

cottonwood, and arrow weed. The second dominant type of vegetative cover occurs on the

upland areas west of the river. Desert scrub in this area consists primarily of creosote bush,

catclaw acacia, and brittle bush, which occur in the vicinity of the burn area.

4.3 METEOROLOGICAL CONDITIONS

Weather conditions in the vicinity of the Site generally consist of warm, dry summers and mild

winters. Average precipitation is approximately 10.2 inches per year. Average midday

temperatures in June and July exceed 100 degrees Fahrenheit (F) in only about one summer

out of seven. The normal average midday maximum summer temperature is in the middle

nineties (Sellers and Hill, 1974). The Site lies in a section of Arizona that receives most of its

rainfall in July, August, and September. Almost 60 percent of Benson’s annual precipitation

comes from summer showers.



A secondary wet season is experienced in winter. Mean annual temperatures range from 61.2

F to 64.3 F. The predominant wind direction varies throughout the day. A wind rose plot form

the Apache Generating Station displaying wind speed and direction is provided (Figure 6).

Using data collected from 2008 through 2012, the average wind speed is 3.4 meters per

second.

4.4 GEOLOGY AND HYDROGEOLOGY

Site regional and local geology and hydrogeology have been extensively described in detail as

part of previous investigations (H+A, 1992).

The ANPI site was selected largely based on the type of terrain present, which features a

dominantly “badlands” type of topography. Older terraces of the San Pedro River are dissected

by a series of parallel ephemeral washes that enter the San Pedro River from the west

(Figures 2 and 3). Again, it was this terrain that served as a safe place for the siting of the

Powder Line.

The terraces comprise older alluvium deposited by the ancestral San Pedro River, whereas

younger (Holocene and Recent) alluvium is present in the floodplain of the San Pedro River,

which is situated to the east of the site. Along the reach adjacent to the ANPI site, the San

Pedro River flows intermittently, owing to alternating gaining and losing sections. During

periods of runoff, the River occasionally flows bank to bank, but at most other times, flow is less

than 20 percent of that width. A shallow aquifer is present within the alluvium, east of the ANPI

site. However, throughout most areas within the Site, including in the vicinity of Building #51,

shallow groundwater is not present.

Underlying the Recent and older alluvial terraces is the St. David Formation, which features an

upper clay horizon that, in the St. David area, serves as a confining unit for the regional aquifer.

The thickness of the St. David Formation is up to approximately 650 feet beneath the Site.



5.0 SCOPE OF WORK This TCRA is a controlled burn which will be performed in accordance with the EPA-approved

TCRA Work Plan and ADEQ Burn Permit #5861 (Appendix B). This alternative was selected on

the expectation of its safety in comparison with alternatives involving transportation of the

potentially unstable NG. It is expected to result in destruction of the NG and PETN materials

onsite with minimal risk to public health and safety.

TCRA Team Members will follow the detailed steps and timelines outlined in Section 6.0

Standard Operating Procedures. As previously stated, the open burn will destroy Building #51,

along with the two wooden hods that contain 5 cubic feet of suspected NG-mixed waste in

Building #51, and approximately 50 linear feet of 85–Grain PETN detonation cord to be

removed from Building #232. ANPI will transfer the PETN detonation cord from Building #232 to

Building #51 and then burn Building #51. Ash waste will be characterized and confirmation soil

samples will be collected following the controlled burn to assure proper disposition of any

hazardous residuals.

Work will commence in a logical manner so as to keep safe both public and site personnel. The

controlled burn will also be performed to allow ANPI to resume plant access as soon as

feasible. ANPI plant operations will remain functional during the controlled burn. However,

truck, railcar, and air traffic to ANPI during the controlled burn will be prohibited.

Representatives from the LEPC and local fire departments will be on site during the controlled

burn to provide traffic control and to respond in the event of an emergency.

5.1 APPROPRIATENESS OF TREATMENT TECHNOLOGY

In selecting this treatment method, several potential contractors, subject matter professionals,

and explosives experts were contacted. Various meetings were also held with the EPA, ADEQ,

and LEPC. A consensus was reached that, due to the potential risk of detonation of aged

explosives, 1) the Building #51 NG-mixed waste should not be shipped, but burned in place; 2)

the PETN detonation cord located in Building #232 could be safely transported to Building #51

and burned in place; and 3) asbestos-containing roof materials and lead in the paint from

Building #51 could safely be abated prior to the controlled burn.



Because of the conservative separation distance calculations, described below, and the

proximity of the ANPI operating facility, public roads, and nearest residences, a controlled burn

was selected as a safe treatment technology. It is understood that fires set for the disposal of

dangerous materials are permitted only when there is no safe alternative method of disposal

and when the burning of the materials does not result in the emission of hazardous or toxic

substances in amounts that will endanger safety or health.

5.2 SEPARATION DISTANCE CALCULATIONS

The following assumptions have been made for the purposes of calculating separation

distances for essential and non-essential personnel. Each calculation assumes a full 300

pounds of NG-based product estimated to be the maximum possible mass contained in the

hods, plus the 50 feet of 85-Grain PETN detonation cord. These assumptions are believed to

be highly conservative based on observations that very little NG-based product is visible in the

hods. In fact, the majority of the material in the hods appears to be either floor sweepings or

ground apricot and/or peach pits that were used as filler material. Additionally, each calculation

was based on a theoretical “full order detonation,” which is highly unlikely given lengths that will

be taken to prevent confinement or impact during the controlled burn, as well as the expectation

that the NG is not pure and probably does not represent the assumed mass. Accordingly, the

calculations below should be regarded as a “worst-case scenario” and should be more than

adequate to protect personnel and property.

According to the United States Army Corps of Engineers standards “Intentional Burning of

Buildings Contaminated with Explosives Residues that Present an Explosive Hazard. All

personnel shall be separated by K328 overpressure distance based on the MCE for the

building, but not less than 1,250 feet.” (USACE 2008). The K328 overpressure distance is

calculate by the following formula1:

1 K328 as defined in USACE (2008) is the “Distance non-essential personnel must be for intentional detonations for protection from blast only”. Although the open burn does not constitute an “intentional detonation”, it is recommended by the USACE for the intentional burning of buildings contaminated with explosive residues that present an explosive hazard.



Where:

D = distance in feet (ft) of the blast overpressure; and

W = TNT-equivalent weight of explosive in pounds (lbs).

The weight of nitroglycerine is estimated by ANPI to be 300 pounds (lbs) (worst case scenario).

The weight of PETN in the detonation cored is approximately 0.6071 lbs as calculated by the

following:

Using a 1.5 relative effectiveness (RE) factor for nitroglycerin and 1.66 for PETN (US

Army 1992), the TNT equivalent weight for the combined weight of the explosive materials

is 451 lbs as calculated by:

lbs

And applying these weights, the K328 overpressure distance from the center of the blast is:

Both the observation point (2,752 ft) for those performing the controlled burn and the nearest

uncontrolled occupied dwelling (3,205 ft) (Figure 4) fall outside of the 2,515 ft K328

overpressure distance referenced above. Therefore, it is assumed that project personnel will

occupy positions that are at a safe distance in the event of a detonation.



In addition to the K328 overpressure distance, the “Minimum Separation Distance” (MSD) for

unintentional detonations for nonessential personnel was calculated by the following formula

(USACE 2008):

Applying the same variables and constants as above, the calculated MSD for unintentional

detonations for nonessential personnel is:

The calculated K328 overpressure distance and the MSD for unintentional detonations for

nonessential personnel are conservative and represent a worst-case scenario (Figure 4). Until

the controlled burn is completed and while activities are being performed in Building #51,

nonessential personnel will be no closer than 307 ft. During the controlled burn, all personnel

will be kept at a distance greater than 2,515 ft of Building #51. The nearest road to Building #51

is approximately 1,290 feet to the east (i.e., Apache Powder Road). Portions of the road

within 2,515 ft of Building #51 will be blocked during the controlled burn (Figure 4). The nearest

active ANPI Plant building (i.e., Prill Tower) to Building #51 is approximately 2,752 feet to the

southwest. The nearest residences to Building #51 are located approximately 3,205 feet to the

south/southeast and approximately 4,291 feet (0.8 miles) to the northwest.

5.3 PROJECT TIMELINE

A detailed project timeline for the TCRA Work Plan is provided (Table 2). The primary TCRA

tasks include the following:

Tuesday, September 9, 2014 – SWE and ANPI will install the hod covers and floor

support beams.

Wednesday to Saturday, September 10 and 13, 2014 – SSE will abate the asbestos and

lead materials.

Thursday, September 18 or Friday, September 19, 2014 – The controlled burn is

scheduled to occur on Thursday morning, September 18, 2014 with the alternate

controlled burn date of Friday morning, September 19, 2014.



Friday, September 19, 2014 – Assuming the controlled burn takes place on Thursday,

September 18, 2014, and a clearance is given by TPD, ash waste sampling will be

performed on Friday, September 19, 2014.

Monday, September 29,2014 – Confirmatory soil sampling will be performed.

On or before October 17, 2014 – Air sampling results will be submitted to ADEQ.

Friday, November 15, 2014 – The Final TCRA Completion Report is scheduled for

submittal to the EPA and ADEQ.

Modifications to the TCRA project timeline may be necessitated due to weather conditions,

laboratory turnaround time, or other unforeseen circumstances. If necessary, ANPI will

communicate any project delays to EPA and ADEQ.



6.0 STANDARD OPERATING PROCEDURES The following sections describe the preparations, plans, and procedures that will be used in

implementation of the TCRA. The standard operating procedures (SOPs) sub-sections are

separated into activities to be performed during the pre-burn, controlled burn, post-burn,

controlled re-burn (if necessary), and ash waste characterization phases of the project.

6.1 PREPARATION AND PLANNING

The following sections describe the required preparation and planning actions that will be taken

prior to the controlled burn.

6.1.1 Permits, Insurance and License

ANPI will ensure that permits, insurances, and licenses are secured in accordance with all

applicable regulations. Including a current Certificate of Insurance and, if applicable, any

subcontractor’s Certificate of Insurance. Policies typically include worker’s compensation,

comprehensive general liability, automobile liability and, if applicable,

environmental/asbestos/and pollution liability. Licenses will be kept current for the duration of

project. ANPI will ensure its employees and subcontractors involved in the project are properly

licensed in accordance with State statutes and in accordance with their respective specialties.

ANPI currently operates under Class 1 Air Quality Permit #57484. For this controlled burn,

ANPI has applied for an Open Burn Permit via ADEQ (CD E-File 5) and has received the

ADEQ-approved Open Burn Permit #5861 (Appendix B).

6.1.2 Community Notification Plan

ANPI will notify the local public and plant personnel potentially affected by the controlled burn

activities. The potentially affected public includes those residing or present near building #51, or

those requiring access via Apache Powder Road south of South Flynn Road. Public notification

will be accomplished via the local newspaper and U.S. postal service. ANPI’s Community

Notification Plan materials are provided (Appendix C). A community informational briefing will

be held on Wednesday, August 20, 2014. ANPI SHE Manager, Craig Boudle, will oversee all

media contacts (Table 1).



6.1.3 Local Authority Coordination

Communication and coordination with the local authorities and agency representatives will be

performed well in advance of the controlled burn date. ANPI will coordinate with the LEPC to

ensure radio and telephone communication compatibility, emergency response coverage, and

on-site supervision. ANPI will review the burn plan, radios, personal protective equipment

(PPE), escape routes, safety zones, and fire engines prior to controlled burning. In the event of

a medical emergency or burn injury, Chief Keith Spangler of the Benson Fire Department will

assume control of the medical incident. ANPI will contact the ADEQ representative prior to

ignition on the day of the controlled burn as required by open burning regulations. The fire

departments of St. David and Benson, Arizona and local ambulance provider will also be

contacted by ANPI prior to the controlled burn. Additionally, agencies responsible for air traffic

(such as the Federal Aviation Administration and the U.S. Border Patrol) will be notified by the

Cochise County of the date and time of the controlled burn.

6.1.4 Air Quality Modeling, Permit and Monitoring Plan

Stantec has prepared an Open Burn Permit Application and an Open Burn Monitoring Plan (CD

E-File 5). The Open Burn Permit Application includes an air impact analyses using the EPA

approved Open Burn Open Detonation Model (OBODM). The following types of air monitoring

will be performed and recorded during the controlled burn process.

6.1.4.1 Meteorological Monitoring Plan

Primary meteorological variables (e.g., wind direction, wind speed, temperature, humidity,

atmospheric pressure) will be monitored and recorded by the ANPI Generating Station.

Controlled burn activities will be curtailed if weather conditions are unfavorable or if weather

conditions threaten to become poor. Examples of poor weather conditions will include

precipitation, lightning, or high winds. Controlled burn activities will not be initiated if wind

speeds exceed 25 miles per hour (ADEQ, 1999).

6.1.4.2 Community Exposure Monitoring Plan

Community air exposure monitoring will be performed by ANPI and or Stantec personnel at two

locations near the ANPI property boundary and adjacent to the two nearest occupied residences

located from 3,205 feet and 4,291 feet from Building 51 (Figure 4).



Air samples will be collected from 45 to 15 minutes prior to the start of the open burn event and

from 15 to 45 minutes after the start of the open burn event. Air samples will be collected in 6-

liter Summa ® canisters and analyzed for carbon monoxide using EPA Method 3C, volatile

organic hydrocarbons (VOCs) and hazardous air pollutants (HAPs) using EPA Method TO-15.

Samples will be tracked and shipped under chain-of-custody to Environmental Analytical

Services, Inc. of San Luis Obispo, CA. for analysis. Air monitoring and analysis procedures are

detailed in the Open Burn Monitoring Plan (Appendix D) and Open Burn Permit #5861

(Appendix B). There are no anticipated investigation derived wastes associated with the air

monitoring activities.

6.1.4.3 Plant Site Area Monitoring Plan

Plant site air exposure monitoring will be performed by ANPI and or Stantec personnel near the

Prill Tower, located 3,076 feet from Building 51 (Figure 4). Consistent with the methods and

procedures noted above, air samples will be collected from 45 to 15 minutes prior to the start of

the open burn event and from 15 to 45 minutes after the start of the open burn event. Air

samples will be collected in 6-liter Summa ® canisters and analyzed for carbon monoxide using

EPA Method 3C, volatile organic hydrocarbons (VOCs) and hazardous air pollutants (HAPs)

using EPA Method TO-15. Samples will be tracked and shipped under chain-of-custody to

Environmental Analytical Services, Inc. of San Luis Obispo, CA. for analysis. Air monitoring and

analysis procedures are detailed in the Open Burn Monitoring Plan (Appendix D) and Open

Burn Permit #5861 (Appendix B). There are no anticipated investigation derived wastes

associated with the air monitoring activities.

6.1.5 Seismic Monitoring Plan

Prior to the start of the controlled burn, SWE will install and operate two blast monitoring

seismographs at two locations adjacent to the two nearest occupied residences located

from 3,205 feet and 4,291 feet from Building 51 (Figure 4). The seismographs will continuously

monitor ground vibration and air overpressure throughout the duration of the controlled burn.

The seismic monitoring will be performed utilizing the Mini Seis ™, manufactured by Industrial

Seismology, Inc. The operations manual and specifications are provided (Appendix E and

E-File 9).



Since any ground vibration generated from the potential detonation of the NG-based material in

Building #51 is expected to be minimal at the two monitoring locations, the seismographs will be

programmed to trigger at an air overpressure level of 133 Decibels (dBs). Any setting lower

than this level may result in false triggers. If a detonation occurs, both ground vibration

(measured in inches per second) and air overpressure (measured in dBs) will be recorded,

depending on the resultant level of the air blast from the detonation. If no detonation occurs, a

log of the recording start and stop time can be produced from the seismographs.

6.1.6 Video Monitoring Plan

Two video cameras will be setup by SWE personnel at the Prill Tower to record the controlled

burn. One of the video cameras will video the entire active controlled burn at normal speed,

starting approximately 15 minutes prior the start of the controlled burn and ending when it is

determined that the active controlled burn is finished. The second camera is a high speed video

that can capture greater details if an ignition occurs. The high speed camera will record over a

two second loop. If an explosion occurs, the camera operator will press a button to preserve the

previous two seconds of video.

ANPI will setup a video system on the Prill Tower providing a live feed to the Copper Room of

the controlled burn.

6.1.7 Health and Safety Plan

This TCRA Work Plan will be implemented in accordance with the ANPI Health and Safety Plan

(HASP) (CD E-File 6). The HASP identifies, evaluates, and prescribes control measures for

health and safety hazards, and describes emergency response procedures. HASP

implementation and compliance is the responsibility of all TCRA team members. Copies of the

HASP will be provided to all involved TCRA parties and will be readily available at the Site.

Furthermore, ANPI safety work rules and precautions will be implemented and enforced during

all TCRA activities (CD E-File 7).

ANPI-authorized contractors involved in TCRA activities are responsible for, but are not limited

to, the following:

Complying with applicable regulations associated with their specialty.



Assigning specific tasks to their employees and for ensuring that their employees are

properly trained and are in compliance with applicable regulations.

Providing qualified employees and allocating sufficient time, materials, PPE, and

equipment to safely complete field activities in accordance with applicable regulations,

SOPs, and the ANPI HASP.

Ensuring their health and safety requirements are as stringent as those contained in the

ANPI HASP.

Identifying hazards known by the contractor, or are known to be associated with a

contractor's specialty, and addressing control measures during the field safety briefing

prior to beginning work.

Precautions will be employed to protect TCRA field workers, ANPI plant workers, and any

residents in the nearby area. Starting at midnight the day of the controlled burn, on-Site roads

will be blocked by caution tape and a security watch will be maintained. ANPI will perform a

thorough property sweep prior to the controlled burn. ANPI plant personnel will be informed and

prepared as the ANPI plant will remain operational during the controlled burn. Apache Powder

Road will be shut down and public traffic will be re-routed during the controlled burn. Vehicular,

railcar, and air traffic will be prohibited from entering within 2,515 feet of Building #51 during the

controlled burn. Two road blocks will be set up and supervised by the Cochise County Sheriff’s

Department along Apache Powder Road (Figure 4).

6.1.8 Contingency Plan

If needed, contingency procedures will be implemented and enforced during the TCRA in

accordance with the ANPI Emergency Response Plan (CD E-File 8) and as directed by the

Chief Keith Spangler of the Benson Fire Department. The ANPI Emergency Response Plan

identifies, evaluates, and prescribes contingency measures for health and safety hazards and

describes the necessary response procedures. Implementation and compliance with ANPI’s

Emergency Response Plan is the responsibility of all TCRA team members. Copies of ANPI’s

Emergency Response Plan will be provided to all involved TCRA parties and will be readily

available at the Site.



An ambulance, located in the ANPI parking lot and three fire trucks, located on Site will be

positioned during the active controlled burn (Figure 4). An emergency ambulance route will be

available during the closure of Apache Powder Road (Figure 4).

The Cochise County Sheriff’s representative, located at one of the designated road blocks, will

determine if an emergency exists and will ensure an escort is provided along the emergency

route. All emergencies will be clearly communicated to and response coordinated through the

Site Incident Commander, Chief Keith Spangler of the Benson Fire Department. If necessary,

emergency helicopter evacuation can be performed from ANPI’s landing pad in the parking lot

adjacent to the Administration Building.

6.2 PRE-BURN PROCEDURES

Between 1 and 2 weeks prior to the controlled burn, asbestos, lead, roof planking and roof

trusses will be removed from Building #51, and the vicinity grubbed.

6.2.1 Asbestos, Lead Roof Planking and Roof Trusses Removal

ANPI and SSE personnel will remove asbestos, lead and the roof planking and roof trusses of

Building #51. The removal will be performed consistent with SOPs outlined in [ABATEMENT

WP / SOP]. In addition to the established procedures, the following tasks will be performed:

A hod cover, made of wood, will be constructed by ANPI and SSE personnel and placed

over the hods prior to asbestos, lead, roof planking and roof trusses removal activities.

The purpose of the hod cover is to prevent materials from falling into the hod during the

removal activities. The hod cover will be approximately 6 feet long by 3 feet wide and 3

feet high, with a 1-inch plywood top (Appendix A). Care will be taken during the hod

cover installation to minimize disturbance of the hods.

Prior to asbestos, lead, roof planking and roof trusses removal activities, additional

support will installed by ANPI and SSE personnel to support the floor beneath the hods.

A 3.5-inch by 8-foot single piece adjustable steel column will be placed to support the

floor cross beam beneath the hods. This will better ensure that the hods will be fully

burned before the floor collapses. See details provided in ANPI Drawing A-2 for the floor

supports design (Appendix A).



Following the installation of the hod cover and additional floor supports, asbestos, lead,

roof planking and roof trusses removal activities will be performed by ANPI and SSE

personnel in such a manner minimizing disturbance of the hods. The hod cover will be

removed following the asbestos, lead, roof planking and roof trusses removal activities.

6.2.2 Grubbing Around Building #51

Following the asbestos, lead, roof planking and roof trusses removal activities noted above,

ANPI personnel will remove vegetation, trash, and other loose materials within 200-feet of

Building #51. The purpose of the grubbing is to limit the presence of materials that might ignite

during the controlled burn.

6.3 CONTROLLED BURN PROCEDURES

On the day of the controlled burn, activities before the controlled burn will include final

preparations of the detonation cord and hods, setting up and starting monitoring equipment, and

positioning emergency standby services, and setting up road blocks. At approximately 6:00 am,

all personnel involved in the controlled burn will meet in copper room to conduct a safety

meeting and review the activities to be performed. The meeting will be conducted by Craig

Boudle, of ANPI, Sergeant Timothy Froebe, of the TPD Bomb Squad, and Chief Keith Spangler,

of the Benson Fire Department. On the day of the controlled burn, only authorized personnel

will be allowed within the 2,515 ft radius of Building #51. Authorization to enter within the 2,515

feet of Building #51 must be obtained from Sergeant Timothy Froebe, of the TPD Bomb Squad.

The controlled burn will start at approximately 8:00 am followed by active fire watch period of

between 4 to 6 hours. After the active fire watch, the road blocks will be removed, emergency

services will return to normal operations and a passive fire watch (for an additional 18 hours) will

start. The following procedures involving detonation cord preparation, hod preparation, air and

seismic monitoring, video monitoring.

6.3.1 Detonation Cord Preparation

The detonation cord preparation is anticipated to take 1.5 hours to complete and will start at

approximately 6:00 am. SWE personnel will transport the 50 feet of detonation cord from

Building #232 to Building #51. The 85-Grain detonation cord will be placed in an explosives day

box and hand carried to Building #51. In the lower room of Building #51, SWE and TPD

personnel will prepare a surface for the placement and burning of the detonation cord.



Four evaporative cooler pads (aspen pads) will be placed on the floor forming a square. The

aspen pads are approximately 29” x 29” and filled with aspen fibers held together with plastic

netting. The purpose of the aspen pads is to provide an absorbent material onto which diesel

fuel will be added. Two gallons of diesel fuel will then be applied, by a weed sprayer, to the

aspen pads and allowed to soak into the pads. The detonation cord will then be coiled on top of

the aspen pads, in such a manner not allowing the cord to kink, knot, or lay over itself. The cord

will them be weighted down by carefully placing three rocks 120 degrees apart from each other.

On top of the corner of one of the aspen pads, a half-pound bag of black powder bag will be

placed and connected to 10 feet of (42 second burn rate/foot) safety fuse which will be extended

out along the exit route. The cord length and burn rate will allow an approximately 7 minutes

delay until the aspen pads ignite.

6.3.2 Hod Preparation

The hod preparation is anticipated to take 1 hour to complete and will start at approximately

6:30 AM, when SWE and TPD personnel will arrive at Building #51 to prepare for the burn. Two

aspen pads (as described above) will be placed on the surface of each hod and will be

saturated with approximately 2 gallons of diesel fuel applied by a weed sprayer. Two additional

aspen pads will then be placed on top of the saturated aspen pads. In each hod, on top of the

corner of one of the aspen pads, a half-pound bag of black powder bag will be placed and

connected to 10 feet of (42 second burn rate/foot) safety fuse which will be extended out along

the exit route. The cord length and burn rate will allow an approximately 7 minutes delay until

the aspen pads ignite.

6.3.3 Air and Seismic Monitoring

Starting at 6:30 AM, ANPI and Stantec personnel will arrive at the three air monitor locations

and setup the air monitoring and seismic equipment. The seismic equipment will be setup and

start monitoring. Air samples will be collected from 45 to 15 minutes prior to the start of the

open burn event and from 15 to 45 minutes after the start of the open burn event.

6.3.4 Video Monitoring

Starting at approximately 7:45 am, ANPI and SWE personnel will activate and operate the video

recording systems located at the Prill Tower. The video systems will operate until the end of the

active fire watch.



6.3.5 Road Closure

Starting at approximately 7:45 am, ANPI with the assistance of LEPC and or local fire

departments will start preparation for setting up road blocks on Apache Powder road (See

Figure 4). The road will be completely closed at 8:00 am. All personnel will wear appropriate

traffic control vests. Vehicles equipped with illuminated warning lights will physically be placed

across road ways preventing traffic movement. The road blocks will be placed in such a

manner, that traffic in both directions would have sufficient advanced warning to stop (e.g., road

blocks will not be located near blind corners). ANPI, LEPC, and/or local fire department

personnel will maintain the road blocks and may inform drivers of the purpose, estimated

duration, and alternate detours. The road blocks will be lifted when the active fire watch is

ended.

6.3.6 Emergency Services Standby

Starting at approximately 6:00 am, an ambulance and three fire department trucks will be

positioned at standby locations across the site (Figure 4). The ambulance and three fire

department trucks will remain at the standby locations until the end of the active fire watch. Mr.

Spangler of the Benson Fire Department will act as the Site Incident Commander in the event of

a detonation or other emergency and will be responsible for directing fire and ambulance

personnel. After the active fire watch, the ambulance and three fire department trucks will

resume their normal operations.

6.3.7 Site Sweep

Starting at midnight the day of the controlled burn, on-Site roads will be blocked by caution tape

and a security watch will be maintained. At approximately 7:30 am, ANPI personnel will drive

across the site to conduct a final sweep of the facility to ensure that only authorized personnel

are located within the 2.515 ft of Building #51.

6.3.8 Initiate Burn

At approximately 8:00 am, SWE and TPD personnel will initiate the burn using non-electric pull

wire lighters to light the safety fuses. Once lit, the SWE and TPD personnel will exit to running

vehicles and evacuate the vicinity. The SWE personnel will evacuate to the observation point

near Prill Tower. The TPD personnel will evacuate to the fire truck standby locations. The

safety cord will take approximately 7 minutes to burn to the black powder bags.



6.3.9 Active Fire Watch

The active fire watch will be performed by SWE and ANPI personnel, with LEPC support, and is

anticipated to take approximately 6-hours. During the active fire watch, as noted above, seismic

and video monitoring will be performed. The active fire watch will continue for a minimum of 4

hours after open flames are no longer observed. Following consultation with the local fire

department(s), SWE and ANPI personnel will determine when the active fire watch period is

finished.

6.3.10 Passive Fire Watch

The passive fire watch will start at the conclusion of the active fire watch and continue for an

additional 18 hours, or until 8:00 am the following day, whichever is longer. ANPI personnel will

observe the burn area and be prepared to respond to changing conditions, including the

presence of uncontrolled fire, increased fire activity, detonation, and unauthorized persons

accessing the site. The Site Incident Commander shall be notified in the event of changed

conditions are noted.

6.4 POST BURN INSPECTION AND CONTROLLED RE-BURN (IF NECESSARY)

On the day following the controlled burn, the site will be inspected for residual explosive

materials. If warranted a portion of the site will be re-burned.

6.4.1 Post Burn Inspection

Following the passive fire watch, personnel from SWE and TPD Specialized Response Division

Bomb Squad will reenter the site to inspect for explosive materials. This team will be

responsible for field testing (with Exspray as needed) any suspected explosives materials due to

“kick-out” prior to final clearance. If residual explosive materials are not discovered or

suspected, then ANPI will be informed that the area is clear of explosives and ANPI will proceed

to perform the ash characterization as outlined in Section 6.5 below. If explosive materials are

discovered or suspected, then an estimate of the remaining amount will be determined and

communicated to ANPI. After a review of the site conditions and with consultation with SWE,

TPD and the EPA, portions of the site may be controlled re-burned as outlined in Section 6.4.2

below.



6.4.2 Controlled Re-Burn (If Necessary)

As specified above, if it is determined that a controlled re-burn is necessary, then the following

steps (including initial field testing as needed as described in Section 6.4.1) may be

implemented during the controlled re-burn. It is important to note that all potential site

conditions cannot be anticipated in this workplan, therefore the following provides a broad

framework of tasks for the controlled re-burn. Tasks may be added, modified and or omitted as

deemed appropriate by Sergeant Timothy Froebe, of the TPD Bomb Squad. This included the

necessity of positioning an ambulance and or fire trucks prior to controlled re-burn activities.

Chief Keith Spangler of the Benson Fire Department will at as the Site Incident Commander

during the controlled re-burn.

6.4.2.1 Surface Preparation

SWE and TPD personnel will prepare the site for the controlled re-burn. An aspen pad(s) will be

placed over the explosive materials and soaked with diesel fuel applied by a weed sprayer. If

deemed necessary, additional combustion material may be placed on site to increase the burn

time and temperature. On top of the corner of the aspen pad(s), a half-pound black powder bag

will be placed and connected to 10 feet of (42 second burn rate/foot) safety fuse, which will be

run out along the exit route.

6.4.2.2 Controlled Re-Burn Monitoring

Before the controlled re-burn, ANPI and SWE personnel will activate and operate the video

recording systems located at the Prill Tower. The video systems will operate until the end of the

active fire watch. Since the potential amount of explosive and combustible materials will have

been greatly reduced in the initial controlled burn, community air exposure, plant site area

monitoring and seismic monitoring will not be performed during the controlled re-burn, as

detonation would not be anticipated.

6.4.2.3 Controlled Re-burn Road Closure and Emergency Services Standby

The Apache Powder road will be blocked to all traffic in a manner as outlined in Section 6.3.5.

An ambulance and three fire department trucks will be positioned at standby locations across

the site as outlined in section 6.3.6. The ambulance and three fire department trucks will remain

at the standby locations until the end of the active fire watch.



6.4.2.4 Controlled Re-burn Site Sweep

Prior to initiating the burn, ANPI personnel will drive across the site to conduct a final sweep of

the facility to ensure that only authorized personnel are located within the K328.

6.4.2.5 Initiate Controlled Re-burn

SWE and TPD personnel will initiate the controlled re-burn consistent with the procedure

outlined in Section 6.3.8.

6.4.2.6 Controlled Re-burn Fire Watches

Active and Passive Fire Watches will be performed as outlined in sections 6.3.9 and 6.3.10.

6.4.2.7 Post Controlled Re-burn Road Inspection

Following the passive fire watch, personnel from SWE and TPD will reenter the site to inspect

for explosive materials. If residual explosive materials are not discovered or suspected, then

ANPI will be informed that the area is clear of explosives and ANPI will proceed to the ash

characterization as outline in Section 6.5 below. If explosive materials are discovered or

suspected, then an estimate of the remaining amount will be determined and communicated to

ANPI. After a review of the site conditions and with consultation with SWE, TPD and the EPA,

portions of the site may be repeatedly controlled re-burned as outlined in Section 6.4.2.

6.5 ASH WASTE CHARACTERIZATION

Waste characterization will be used to determine if the ash is a characteristic hazardous waste

as defined by Title 40 Code of Federal Regulations (CFR) Part 261 and to assure proper

disposal of the ash waste and its associated structures (Table 3). Sampling methods outlined in

the EPA-approved Work Plan to Decommission and Demolish Site Buildings will be employed

(H+A, 2012) (CD E-Files 1, 2, and 3). A grab sample of ash, from the proximity of the former

hods, will be collected and analyzed for NG and PETN using method 8330B, Lead using EPA

Method 6010B, Asbestos by Polarized Light Microscopy, D003 Reactive Waste by EPA

Methods 9014 & 9034. Ash waste will be bermed and covered, if necessary, and stored in

place pending characterization.



7.0 CONFIRMATION SOIL SAMPLING In general, sampling associated with this TCRA will follow protocols established in the ANPI

Demolition Sampling and Analysis Plan (SAP) completed April 3, 2013 (H+A, 2013a). The SAP

was developed to institute procedures to systematically evaluate potential for environmental

impacts to the environment from historical activities at each building. Where potential for

contamination exists, the SAP provides procedures to identify the character and extent of the

potential environmental impacts. Post-Burn confirmation soil sampling will be conducted after

the burn area has been declared safe for entry.

7.1 SAMPLING RATIONALE AND METHOD

To assess soil conditions beneath Building #51 shallow soil samples will be collected for

laboratory analyses after post-burn demolition. Shallow soil samples will be collected using

incremental sampling methodology (ISM) techniques as described in detail in the SAP

(H+A, 2013a). This technique has been utilized successfully at numerous sites to allow cost-

effective collection of samples from within each decision unit (DU), while providing a

representative snapshot of the conditions where no other information is available to pinpoint

particular impact areas. In the event visual indications of soil impact are observed, discrete soil

samples will be collected from the suspect areas identified and ISM samples will be collected

from the surrounding area outside the stained area. For areas where visual indications of

asbestos impacts to soil are identified, discrete soil samples will be collected from the suspected

impacted areas.

The site-specific ISM sampling methodology developed for this project will involve collection of a

minimum of 30 aliquots of soil from each DU. For the purposes of the Building #51 TCRA, the

DU will be essentially the area within the blast walls. However, depending on conditions

identified during the preliminary evaluations, the size of the DU may be altered to exclude areas

unlikely to have been impacted.

Aliquots will be collected from the uppermost six inches of soil within each DU, believed to

represent the most likely horizon for powdered compounds to have settled during Building #51’s

operational phase and/or during the implementation of the burn.



If significant disturbance is noted after the burn sampling may be done at a deeper interval.

Other sampling techniques may be used if unexpected conditions are encountered, such as

visual impacts.

Because Site soils are non-cohesive, aliquot samples will be collected using a trowel. Field

sampling will include sieving of material from each aliquot to isolate the sample fraction with

grains less than 2 millimeters in diameter and remove non-soil materials (e.g., organic matter,

building materials, etc.). Large matter sieved will be visually examined for evidence of

contaminants and, if identified, will be included in the sample submitted to the lab. The total

volume of soil submitted to the lab will be based upon requirements for analyses to be

performed. These volumes and sample containers will be determined prior to each sample

event through close communication with the laboratory. It is expected that the minimum sample

volume for ISM samples will be approximately one kilogram (approximately one 16 oz. jar).

This ISM technique includes additional sub-sampling, which will be performed in the laboratory

and will include collection of 30 smaller increments of the materials to assure a representative

sample. At this stage the laboratory will perform any necessary particle size reduction, percent

moisture determinations, or other preparations as appropriate for the particular analyses

requested for the DU. Due to the specialized nature of the sampling method and analytical

methods, ISM soil samples will be submitted to TestAmerica Laboratory, Inc. in Phoenix, AZ for

analysis. This laboratory was selected based upon its experience analyzing ISM samples as

well as performing several analyses for ordnance sites.

Post-burn demolition sampling of sub-foundation soils for lead or asbestos may be performed if

deemed necessary based upon results of pre-demolition assessment by qualified, licensed

contractors and visual observation of soils. This need will be determined based on the

concentrations and conditions of those materials (e.g., the friability of any asbestos) identified as

well as the potential for release to underlying soils and visual observation of the presence of

these materials in soils. For example, non-friable asbestos found in the interiors of buildings

constructed on a concrete pad would be considered unlikely to have affected underlying soils,

whereas damaged friable asbestos pipe wrap located outdoors between buildings would be

considered to have potential to affect nearby soils and additional visual assessments of soil

conditions would be necessary.



Lead and asbestos soil sampling will be performed using discrete sampling protocols as

described in the SAP (H+A, 2013a).

Neither the EPA nor the State of Arizona has promulgated regulatory standards for asbestos in

soils. As stated above, Federal and Arizona standards define ACMs as materials and/or

products that contain greater than one percent (1%) asbestos. Consistent with this definition,

any asbestos encountered on the site be classified as an ACM. Accordingly, the proposed soil

asbestos remediation standard is any material containing greater than one percent asbestos as

determined using the method specified in Appendix E, subpart E, 40 CFR part 763, Section l,

“Polarized Light Microscopy” (H+A, 2013a).

7.2 TEST METHODS

As enumerated in the Site Quality Assurance Project Plan (QAPP) (H+A, 2010) and the QAPP

addendum (H+A, 2013b) soil samples will be submitted for analysis for any combination of the

COCs. Many of these chemicals were identified during previous Site investigations and

applicable regulatory limits developed at that time as presented in the Record of Decision

(EPA, 1994a) and the Explanation of Significant Differences (EPA 2000) as described in

Appendix C of the QAPP. COCs specifically for Building #51 are provided (Table 3).

Site-specific cleanup standards have not been documented for these COCs. The cleanup

standards listed for these compounds are based upon published Non-Residential Arizona Site

Remediation Levels (SRLs) where listed. Because no SRL exists for PETN, ANPI worked with

EPA to establish the cleanup level (EPA, 2012). Cleanup standards specifically for Building #51

are provided (Table 4).

As described in the QAPP addendum (H+A, 2013b) triplicate samples will be collected from 10

percent of the DUs.

7.3 USE OF STANDARD LABORATORY CONFIRMATION DATA

Quality control (QC) samples will be collected to support the sampling activity. These will

include field QC samples, confirmation samples, and laboratory QC samples. An overview of

QC protocols is provided below. Detailed information regarding sample QC is provided in the

Site QAPP Section 6.0 (H+A, 2010) and in the QAPP addendum (H+A, 2013b).



7.3.1 Field Quality Control Samples

As described in the Site QAPP (H+A, 2010) and QAPP addendum (H+A, 2013b) the following

types of field QC samples will be collected as part of the demolition project:

Triplicates

Equipment rinsate blanks.

7.3.2 Assessment of Field Contamination (Blanks)

As described in EPA’s Superfund Program Representative Sample Guidance (EPA, 1995),

additional samples will be prepared to evaluate potential sample cross-contamination.

7.3.2.1 Equipment Blanks

Equipment rinsate blanks will be collected to evaluate field sampling and decontamination

procedures by pouring High Performance Liquid Chromatography (HPLC) organic-free (for

organics) or deionized water (for inorganics) over the decontaminated sampling equipment.

One equipment rinsate blank will be collected per matrix each day that sampling equipment is

decontaminated in the field. Equipment rinsate blanks will be obtained by passing water

through or over the decontaminated sampling devices used that day.

The rinsate blanks that are collected will be analyzed for a list of compounds requested for the

associated environmental samples.

7.3.2.2 Field Blanks

Because no water sampling is expected to take place as part of this work, no field blanks will be

collected.

7.3.2.3 Trip Blanks

Because no water samples will be collected as part of this project and soil VOC samples will be

collected using EnCore™ samplers, no trip blanks will be used for this work.

7.3.2.4 Temperature Blanks

For each cooler that is shipped or transported to an analytical laboratory a 40 milliliter (mL)

volatile organic analysis HPLC vial will be included that is marked temperature blank. This

blank will be used by the sample custodian to check the temperature of samples upon receipt.



7.3.3 Assessment of Field Variability (Field Duplicate or Co-Located Samples)

As recommended in the Technical and Regulatory Guidance - Incremental Sampling

Methodology dated February 2012 and described in the QAPP amendment (H+A, 2013b)

triplicate soils samples will be obtained from 10 percent of ISM samples collected during this

project to assess field variability. For instances where discrete sampling techniques are used,

duplicate samples will also be collected from 10 percent of the sample locations associated with

the demolition project.

Replicate soil samples to be analyzed for non-volatile compounds will be homogenized with a

trowel in a sample-dedicated 1-gallon disposable pail. Homogenized material from the pail will

then be transferred to the appropriate wide-mouth glass jars for both the regular and duplicate

samples. In the event multiple jars are used for a particular analysis, all jars designated for that

analysis will be filled sequentially before jars designated for another analysis are filled.

Soil samples for volatile organic compound analyses will not be homogenized. Equivalent

EnCore™ samples from a collocated location will be collected identically to the original samples,

assigned unique sample numbers and sent blind to the laboratory.

Replicate samples will be preserved, packaged, and sealed in the manner described for the

environmental samples. A separate sample number and station number will be assigned to

each replicate sample and it will be submitted blind to the laboratory.

7.4 BACKGROUND SAMPLES

Characterization of background soils has been determined not to be applicable to the demolition

project. Cleanup standards have already been prescribed or will be prescribed for the COCs

expected to be encountered. Additionally, there is no reason to believe that the identified COCs

exist in the background soils.

7.5 FIELD SCREENING AND CONFIRMATION SAMPLES

This section is not applicable to the demolition project. No analytical based field screening is

expected to be performed during demolition related soil sampling. Field screening will be limited

to visual observation to identify indicators of impact. In areas where potential for impact exists

but no visual signs are present, ISM sample techniques will be used.



7.6 LABORATORY CONTROL SAMPLES

Details regarding laboratory control samples planned for this project are provided in the Site

QAPP (H+A, 2010) and QAPP addendum (H+A, 2013b). In general, a routinely collected soil

sample (a full 8-oz sample jar or two 120-mL sample vials) is expected to contain sufficient

volume for both routine sample analysis and additional laboratory QC analyses. Therefore, a

separate soil sample for laboratory QC purposes will not be collected for non-volatile samples.

Ongoing communication with eth receiving laboratory will verify sample volumes necessary prior

to any sampling event.

Soil samples for volatile organic compound analyses for laboratory QC purposes will be

obtained by collecting double the number of equivalent EnCore™ samples from a collocated

location in the same way as the original samples, assigned a unique sample numbers and sent

blind to the laboratory.

7.7 WASTE MANAGEMENT AND/OR DISPOSAL

Based on ash waste and soil confirmatory analytical results, H+A will assist ANPI in determining

the need for waste management and disposal in a manner consistent with the CERCLA Offsite

Rule.



8.0 DOCUMENTATION AND REPORTING Information generated from the implementation of this TCRA will be incorporated into the

existing ANPI Building Demolition Program monthly progress reports. These monthly reports

include building evaluation, feature identification, pre- and post-demolition sampling activities,

and analytical results. In accordance with the ADEQ Burn Permit #5861 (Appendix B), air

sample results will be provided to ADEQ with 30 days of the sampling event. In addition, a

comprehensive Final TCRA Completion Report will be prepared and submitted to EPA and

ADEQ by November 15,2014.



9.0 REFERENCES Apache Nitrogen Products, Inc. (ANPI), 1998. Personal communication between K. Alter

(ANPI) and L. Leonhart (H+A); re: Property transfers and manufacturing history. March 15, 1998.

_____, 2014. Letter from Craig Boudle (ANPI) to Andria Benner (EPA); re: Discovery of Two

Hods containing Nitroglycerin and Discovery of Detonation Cord in the Historic Powder Line. February 14, 2014.

Arizona Department of Environmental Quality (ADEQ), 1998. Resolution of All Hazardous

Waste Program Requirements Set Forth in the November 1, 1994 Consent Decree (No. CV94000240) between Apache Nitrogen Products, Inc. and the Arizona Department of Environmental Quality: Letter from Lupe M. Buys, ADEQ Hazardous Waste Compliance Unit to Kerstin M. Alter, Apache Nitrogen Products, Inc. August 28, 1998.

_____, 1999. Personal communication between S. Varga (ADEQ) and L. Leonhart (H+A);

re: Allowable wind speeds and air monitoring. November 24, 1999. Arizona, State of, 1994. Consent Decree: State of Arizona, ex. rel. Edward Z. Fox, Director,

Arizona Department of Environmental Quality, and Grant Woods, Attorney General, Plaintiff, v. Apache Nitrogen Products, Inc., a New Jersey Corporation, Defendant. Superior Court of the State of Arizona, Cochise County, Civil Action No. CV94000240, June 15, 1994 (Effective date November 1, 1994).

_____, 1998a. Joint Motion for Order Deeming Certain Provisions of Consent Decree Satisfied:

State of Arizona, ex. rel., Russell Rhoades, Director, Arizona Department of Environmental Quality, and Grant Woods, Attorney General, Plaintiff vs. Apache Nitrogen Products, Inc., a New Jersey Corporation, Defendant. Superior Court of the State of Arizona, Cochise County, Civil Action No. CV94000240. October 26, 1998.

_____, 1998b. Order: State of Arizona, ex. rel., Russell Rhoades, Director, Arizona Department

of Environmental Quality, and Grant Woods, Attorney General, Plaintiff vs. Apache Nitrogen Products, Inc., a New Jersey Corporation, Defendant. Superior Court of the State of Arizona, Cochise County, Civil Action No. CV94000240. November 4, 1998.

Fenneman, N.M., 1931. Physiography of Western United States. New York: McGraw-Hill. Hargis + Associates, Inc. (H+A), 1992. Remedial Investigation Report, Apache Powder

Superfund Site. Prepared for Apache Nitrogen Products, Inc., Benson, Arizona. April 2, 1992.

_____, 1995. Detonation Cord Manufacturing, Carbamite Manufacturing, and Laundry Facilities

Closure Plan, Apache Nitrogen Products, Benson, Arizona. March 1, 1995.



_____, 1999a. Results of Interim Work Plan Phase 1, Tasks 2 through 4; Proposal for

Additional Sampling, Trinitrotoluene-Contaminated Area, Apache Powder Superfund Site, Cochise County, Arizona. May 10, 1999.

_____, 1999b. Results of Additional Soil Sampling, Trinitrotoluene-Contaminated Area, Apache

Powder Superfund Site, Cochise County, Arizona. August 2, 1999. _____. 2002. Removal Action Implementation Report for TNT-Contaminated Area, Apache

Powder Superfund Site, Cochise County, Arizona, Revision 1.0. July 24, 2002. _____, 2010. Quality Assurance Project Plan (QAPP) Performance Monitoring and Operation

and Maintenance of Remedies, Revision 1.0, Apache Powder Superfund Site, Cochise County, Arizona. June 14, 2010.

_____, 2012. Work Plan to Decommission and Demolish Site Buildings, Apache Powder

Superfund Site, Cochise County, Arizona. August 1, 2012. _____, 2013a. ANPI Building Demolition Program Sampling and Analysis Plan (SAP), Revision

2.0, Apache Powder Superfund Site, Cochise County, Arizona. April 3, 2013. _____, 2013b. Quality Assurance Project Plan (QAPP) Addendum for Building Demolition and

Sulfur Removal, Revision 2.0, Apache Powder Superfund Site, Cochise County, Arizona. April 2, 2013.

The Interstate Technology and Regulatory Council (IRCTC), 2012. The Technical and

Regulatory Guidance - Incremental Sampling Methodology. February 2012. U.S. Department of the Army (US Army), 1992. Explosives and Demolitions [Field Manual 5-

250]. June 15, 1992. U.S. Army Corps of Engineers (USACE), 2008. Explosives, Safety and Health Requirements

Manual [EM 385-1-97]. September 15, 2008. U.S. Environmental Protection Agency (EPA), 1994a. Apache Powder Superfund Site, Record

of Decision. October 3, 1994.

_____, 1994b. EPA Unilateral Administrative Order for Remedial Design, Remedial Action, and Other Response Actions, U.S. EPA Docket No. 95-07; Issued to Apache Nitrogen Products, Inc. December 21, 1994, Effective Date: December 29, 1994.

_____, 1995. Superfund Program, Representative Sampling Guidance, Volume 1: Soil, Interim

Final, OSWER Directive 9360.4-10EPA 540/R-95/141PB96-963207. December 1995. _____, 2000. Letter from Andria Benner (EPA) to Kerstin Alter (ANPI), re: Explanation of

Significant Difference (ESD) #2. September 29, 2000. _____, 2012. Communication from Andria Benner (EPA) to Melissa Himebauch (ANPI), re:

PETN-Standard – EPA’s Initial Feedback. October 16, 2012.



_____, 2014. Letter from Andria Benner (EPA) to Craig Boudle (ANPI): re: EPA Request for

Removal Work Plan for Explosives Materials, Apache Powder Superfund Site, dated March 4, 2014.


TABLES


TABLE 1

PROJECT CONTACTS AND EMERGENCY NUMBERS

130.147 TCRA WP Tbl 1

COMPANY/ADDRESS CONTACT NAME/TITLE TELEPHONE NUMBERS/ E-MAIL ADDRESSES

EMERGENCY PHONE NUMBER FIRE, AMBULANCE, POLICE

911 & Consult ANPI Contingency Plan

Benson Hospital 450 Ocotillo Avenue Benson, Arizona 85602

Non-Emergency Number 520-586-2261

US EPA Region 9 Superfund Division SFD 6-2 75 Hawthorne Street San Francisco, CA 94105

Andria Benner Remedial Project Manager

Office: 415-972-3189 E-mail: [email protected]

ADEQ - Central Office 110 West Washington Street Phoenix, Arizona 85007 Arizona Department of Environmental Quality ADEQ - Southern Regional Office 400 West Congress Street, #433 Tucson, Arizona 85701

Balaji Vaidyanathan Air Quality Program Director Laura Fischer Project Manager

Office: 602-771-4527 E-mail: [email protected] Office: 602-771-0200 E-mail: [email protected]

ANPI 1436 S. Apache Powder Road St. David, AZ 85630 Mailing Address: P.O. Box 700 Benson, Arizona 85602

Craig Boudle Safety, Health and Environmental Manager

Office: 520-720-2114 Cell: 520-975-9426 E-mail: [email protected]

H+A 7400 N. Oracle Road, Suite 202 Tucson, AZ 85741

Leo Leonhart, Ph.D. CERCLA Project Director

Office: 520-308-6820 Cell: 520-404-6172 E-mail: [email protected]

SWE 2040 W. Gardner Lane Tucson, AZ 85705

Jerald E. Harris, P.E. Executive Vice President Phil Melick Product Manager

Office: 520-696-9495 Cell: 520-906-2850 E-mail: [email protected] Office: 520-696-9495 Cell: 520-429-4553 E-mail: [email protected]

Stantec 1553 W. Elna Rae Tempe, AZ 85281-6935

Louis C. Thanukos Ph.D. Division Manager


SSE 2202 W. Medtronic Way, Suite 108 Tempe, AZ 85281 (480) 967-8300

Steve Beirl Office: 480-967-8300 E-mail: [email protected]

mailto:[email protected]

http://www.azdeq.gov/environ/sro/index.html










TABLE 1

PROJECT CONTACTS AND EMERGENCY NUMBERS

130.147 TCRA WP Tbl 1

COMPANY/ADDRESS CONTACT NAME/TITLE TELEPHONE NUMBERS/ E-MAIL ADDRESSES

LEPC - Cochise County Local Emergency Planning Committee

Norman Sturm, MS,CEM Cochise County Emergency Services Coordinator


Benson Fire Department Keith Spangler Fire Chief


St. David Fire Department Loyal Gephart Fire Chief


Tucson Police Department Specialized Response Division Bomb Squad 270 S. Stone Ave Tucson, AZ 85701

Sgt. Tim Froebe

Cell: 520-336-7444 E-mail: [email protected]

Environmental Response

National Response Center (If spill over Reportable Quantity [RQ])

Emergency: 800-424-8802

Poison Control Center

1501 N Campbell Ave, Tucson, AZ, US, 85724

Poison Control System Poison Control Center AZ Poison www.arizona.edu

Emergency: 800-222-1222 800-362-0101

National Line Locator National 811 Call-Before-You-Dig Hotline (24-hour hotline) Arizona 811 www.arizona811.com/

811 811 or 1-800-782-5348

Abbreviations:

ADEQ = Arizona Department of Environmental Quality

EPA = Environmental Protection Agency

H+A = Hargis + Associates, Inc.

LEPC = Local Emergency Planning Committee

SSE = Spray Systems Environmental

SWE = Southwest Energy





http://www.arizona.edu/

http://www.arizona811.com/

Task No. TASK NAME DESCRIPTION

DURATION (days)

START DATE

FINISH DATE

1 ANPI & First Responders Meeting ANPI Meets with First Responders (Chiefs of St. David Fire Dept. & Benson Fire Dept.); Reviews Incident Command System & Fire Tender Responsibilities 1 7/2/14 7/2/14

2 ANPI & EPA Conference Call ANPI & EPA Review Action Items & Time Line 1 7/3/14 7/3/14

3 ANPI Draft TCRA Work Plan ANPI Prepares Draft Time-Critical Removal Action (TCRA) Work Plan 21 7/3/14 7/24/14

4 EPA Draft Community Fact Sheet EPA Drafts & Begins Circulating Draft Fact Sheet for Review & Comment 12 7/25/14 8/5/14

5 ANPI Final TCRA Work Plan Due to EPA/ADEQ ANPI Submits Final TCRA Work Plan to EPA & ADEQ for Review & Comment 1 7/28/14 7/28/14

6 EPA Draft Removal Action Memo EPA Drafts & Begins Circulating Draft Action Memo for Review & Comment 5 7/28/14 8/1/14

7 ANPI/EPA/ADEQ Conference Call ANPI/EPA/ADEQ Hold Status Check-in Conference Call at 2:00 PM; Outlook Invitations Already Sent to TCRA Team 1 7/30/14 7/30/14

8 EPA Final Community Fact Sheet EPA Distributes Final Community Fact Sheet Describing Site Activities Since Fiscal Year & Planned Removal Action 1 8/6/14 8/6/14

9 ANPI Community Notification to Neighbors ANPI Mails Community Notification Letters to Nearby Neighbors 1 8/7/14 8/7/14

10 EPA Final Removal Action Memo EPA Signs Final Removal Action Memo 1 9/9/14 9/9/14

11 ANPI/EPA/ADEQ Community Meeting ANPI/EPA/ADEQ Conduct Evening Meeting with Nearby Residents at ANPI Copper Room 1 8/20/14 8/20/14

12 ANPI Asbestos Abatement Building #51 ANPI & Spray Systems Environmental Abates Asbestos in Building #51 which Includes Installation of Hod Covers 5 9/9/14 9/13/14

13 ANPI Building #51 Floor Beam Supports ANPI & Spray Systems Environmental Installs Building #51 Floor Beam Supports 1 9/9/14 9/9/14

14 ANPI Roof Planking & Roof Trusses Removal ANPI & Spray Systems Environmental Removes Roof Planking & Roof Trusses 4 9/10/14 9/13/14

15 ANPI Outlook Invitations Re: Kick Off Conference Call ANPI Distributes Outlook Invitations for TCRA Team Kick Off Conference Call 1 9/3/14 9/3/14

16 ANPI Publication Notice in San Pedro News ANPI Publishes September 18 Burn Notice in San Pedro News 1 9/10/14 9/10/14

17 ANPI TCRA Team Kick Off Conference Call ANPI Conducts TCRA Team Kick Off Conference Call 1 9/10/14 9/10/14


TABLE 2

PROJECT TIMELINE

Page 1 of 2

Task No. TASK NAME DESCRIPTION

DURATION (days)

START DATE

FINISH DATE


TABLE 2

PROJECT TIMELINE

18 ANPI Explosives Removal Action ANPI Conducts 9/18/14 Explosives Removal Action (i.e., Burn in Place); Alternate Burn Date is 9/19/2014 1 9/18/14 9/18/14

19 ANPI Explosives Removal Action (Preparation)A) 6:00 AM- 8:00 AM – ANPI Performs Property Sweep / SWE Prepares for burn / LEPC Mobilizes Fire Depts. / Stantec Places Air Monitoring Instrumentation & SWE Places Seismograph Equipment

1 9/18/14 9/18/14

20 ANPI Explosives Removal Action (Controlled Burn) B) 8:00 AM – LEPC Closes Roads / SWE Starts Burn / ANPI Performs Active Fire Watch 1 9/18/14 9/18/14

21 ANPI Explosives Removal Action (Passive Fire Watch) C) 2:00 PM – LEPC Opens Roads / ANPI Conducts Passive Fire Watch 2 9/18/14 9/19/14

22 ANPI Explosives Removal Action (Inspection) D) 8:00 AM – Next morning, Tucson Bomb Squad Inspects Burn Location & Deems Burn Event Closed, if Appropriate 1 9/19/14 9/19/14

23 ANPI Alternate Date for Explosives Removal Action If 9/18/2014 Burn is Delayed, Perform Above Steps A through D the Following Day 9/19/2014 1 9/19/14 9/19/14

24 ANPI Ash Characterization H+A Characterizes Waste Ash 1 9/22/14 9/22/14

25 ANPI Confirmation Soil Sampling H+A Collects Confirmation Soil Samples 1 9/29/14 9/29/14

26 EPA First & Final Pollution Report EPA Drafts First & Final Pollution Report (POLREP) 1 10/15/14 10/15/14

27 ANPI Draft TCRA Completion Report ANPI Prepares Draft TCRA Completion Report for Review & Comment 35 10/6/14 11/10/14

28 ANPI Final TCRA Completion Report due to EPA/ADEQ ANPI Submits Final TCRA Completion Report to EPA/ADEQ for Review & Comment 1 11/15/14 11/15/14

Abbreviations & Acronyms:ADEQ = Arizona Department of Environmental QualityANPI = Apache Nitrogen Products, Inc.Dept. = DepartmentEPA = U.S. Environmental Protection AgencyH+A = Hargis + Associates, Inc.SSE = Spray Systems EnvironmentalSWE = Southwest EnergyTCRA = Time-Critical Removal Action

Page 2 of 2

6/30 7/7 7/14 7/21 7/28 8/4 8/11 8/18 8/25 9/1 9/8 9/15 9/22 9/29 10/6 10/13 10/20 10/27 11/3 11/10 11/17

ANPI & First Responders Meeting

ANPI & EPA Conference Call

ANPI Draft TCRA Work Plan

EPA Draft Community Fact Sheet

ANPI Final TCRA Work Plan Due to EPA/ADEQ

EPA Draft Removal Action Memo

ANPI/EPA/ADEQ Conference Call

EPA Final Community Fact Sheet

ANPI Community Notification to Neighbors

EPA Final Removal Action Memo

ANPI/EPA/ADEQ Community Meeting

ANPI Asbestos Abatement Building #51

ANPI Building #51 Floor Beam Supports

ANPI Roof Planking & Roof Trusses Removal

ANPI Outlook Invitations Re: Kick Off Conference Call

ANPI Publication Notice in San Pedro News

ANPI TCRA Team Kick Off Conference Call

ANPI Explosives Removal Action

ANPI Explosives Removal Action (Preparation)

ANPI Explosives Removal Action (Controlled Burn)

ANPI Explosives Removal Action (Passive Fire Watch)

ANPI Explosives Removal Action (Inspection)

ANPI Alternate Date for Explosives Removal Action

ANPI Ash Characterization

ANPI Confirmation Soil Sampling

EPA First & Final Pollution Report

ANPI Draft TCRA Completion Report

ANPI Final TCRA Completion Report due to EPA/ADEQ

TABLE 2. PROJECT TIMELINE

Sample Type Potential COCs Potential for Impacts Recommended Samples Analyses Decision Unit Description1

Ash Waste

nitroglycerin, pentaerythritol

tetranitrate, lead, asbestos, reactive

characteristic

Lead (moderate impact: lead-based paint in building to be abated); Asbestos (low

impact: roof top will be abated); Explosive/reactive compounds (low

impact: will be consumed in burn)

One grab sample from the ash

Nitroglycerin and PETN (8330B),Lead (Method 6010B),

Asbestos (PLM),D003 Reactive Waste (Method

9014 & 9034)

A single grab sample for lead and asbestos will be collected from the ash.

Soil Nitroglycerin, lead, asbestos, nitrates

Nitroglycerin (High impact: existing residual NG present in HODs); Lead

(Moderate impact: identified in building and may be present in ash); Asbestos (Low

impact: roof top will be abated prior to burn); Explosive compounds (Not Applicable:

consumed during burning).

1 multi-incremental soil sample.

Nitroglycerin and PETN (8330B), Nitrates (E300), Lead (Method

6010B)

The incremental sample will be collected using the building footprint as the decision unit as the entire building was associated with production of these

NG compounds.

Notes:

NG = Nitroglycerin

TABLE 3

RECOMMENDED POST DEMOLITION ASH WASTE AND CONFIRMATION SOIL SAMPLING PLAN FOR BUILDING #51

APACHE NITROGEN PRODUCTS

COCHISE COUNTY, AZ


1 = Unless otherwise stated, the protocol described in the Sampling and Analysis Plan (SAP) for a specific decision unit will be followed (i.e., an incremental grid sampling scheme with a minimum of 30 discrete locations for compositing)

Compound Name Background Concentration

ANPI Recommended

Cleanup Level Source

Residential Industrial Residential Industrial

Nitroglycerin ND 6.1 62 NC 1,200 6.1

Pentaerythritol tetranitrate (PETN) ND 120 430 NC NC 120 Per EPA Correspondence dated 10/16/12

Perchlorate ND 55 720 55 720 55

Notes:

All Units are mg/kg

1 = EPA Region IX Regional Screening Levels as reported on: http:www.epa.gov/region09/waste/sfund/prg

2 = No AZ residential SRL exists for this compound

RSL = EPA Regional Screeing Level

SRL = Arizona Soil Remediation Level

NC = Not calculated

EPA Region IX RSL1

Arizona SRL2


TABLE 4

RECOMMENDED CLEANUP LEVELS FOR COMPOUNDS NOT PREVIOUSLY ADDRESSED AT THE SITE

APACHE NITROGEN PRODUCTS

COCHISE COUNTY, AZ

1 of 1


FIGURES

_̂

_̂

Service Layer Credits: Sources: Esri, DeLorme, NAVTEQ, TomTom, Intermap,increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN, GeoBase, IGN, KadasterNL, Ordnance Survey, Esri Japan, METI, Esri China (Hong Kong), swisstopo, and theGIS User Community

Benson

Tucson

Tombstone

80§̈¦10

APACHE POWDER SUPERFUND SITE

0 105 Miles

´

PREP BY ______ REV BY ______ RPT NO ______NKR

COCHISE COUNTY

LOCATION OF APACHE POWDER SUPERFUND SITE - OVERVIEW

JWM 130.144

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FIGURE 1

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APACHE POWDERSUPERFUND SITE

S. APACHE POWDER RD

S. FL

YNN

RD

COCHISE COUNTY

FIGURE 2. LOCATION OF APACHE POWDER SUPERFUND SITE - AERIAL

US 80

0.5

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Building 51

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!( Building 232_̂ Building 51

Apache Nitrogen Productcs Inc Property Boundary

¹

Building 232

DISTANCE TO NEAREST NEIGHBORFLYNN ROAD PROPERTIES: 4,291'

AIR AND SEISMIC MONITORING LOCATION

EMERGENCY AMBULANCE ROUTE

DISTANCE TO ACTIVE PLANT: 2,752'

AIR MONITORING LOCATION

307' RADIUS: MINIMUM SEPERATION DISTANCE FOR NONESSENTIAL PERSONNEL

2,515' RADIUS: MINIMUM OBSERVATION SEPERATION DISTANCE FOR ALL

----~~g~O~IN~I~~~~-----------~======;:~========F==L~--------~'--,~----l~_L ______ _L __ -r--H PERSONNELFORINTENTIONAL

APACHE NITROGEN PRODUCTS PROPERTY BOUNDARY

AIR AND SEISMIC MONITORING LOCATION

DISTANCE TO NEAREST NEIGHBORGEORGE PROPERTY: 3,205'

BURNING OF BUILDINGS CONTAMINATED WITH EXPLOSIVE RESIDUE THAT PRESENT AN EXPLOSIVE HAZARD

NOTE: DOES NOT ACCOUNT FOR TERRAIN OR ENGINEERED BARRIERS

800'

CAP

Text Box

FIGURE 4: LOCATION OF BUILDING #51 WITH SEPARATION DISTANCES AND EQUIPMENT POSITIONS

U.S. EPA Region IXAndria Benner

Remedial Project ManagerRich Martyn

On-Scene Coordinator

ADEQLaura Fischer

Federal Programs Liaison

ANPICraig Boudle, SHE

Manager

Tucson Police Dept,

Specialized Response DivisionSergeant

Timothy Froebe

Hargis + Associates,

IncLeo Leonhart

Ph DCERCLA

Consultant

Spray Systems Environmental

Steve BeirlAsbestos

Abatement

ANPIBill HorneJeff Bauer

David CamachoField Team

FIGURE 5. PROJECT ORGANIZATION CHART

ADEQBalaji Vaidyanathan

Air QualityProgram Director

StantecLouis C. Thanukos

Ph DAir Modeling &

Monitoring

Southwest Energy LLC

Jerald E. Harris PE

Phil MelickTCRA

Implementation

Local Fire DeptsSt. David Fire

Chief Loyal Gephart &

Benson Fire Chief Keith Spangler

Cochise County Local Emergency

ServicesNorman Sturm

W&.::D ROSE Pl OT:

Apache Generating Stati on 2008-2012

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TOTAlOOUNT:

1.20% 43609 hrs.

W IND SPEED

(mls l

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5.7 . 8.8

3.6 . 5.7

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Calms: 12m'~

AVG. Wlt.OSP&O: OATf:: PROJECT 00.:

3.41 rrls 12/19/2013

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FIGURE 6. APACHE NITROGEN PRODUCTS, INC. WIND ROSE

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APPENDIX A

BUILDING INFORMATION

BUILDINGS #51, #232, AND HOD COVER INFORMATION


TABLE OF CONTENTS

1. Building #51 – 2014 Photograph

2. Building #51 Wooden Hods – 2013 Photograph

3. Building #51 – June 1968 Hand Pack House Drawing

4. Building #51 – June 1968 Code- Hand Packing Gelatin Equipment, Materials, and

Description Text

5. Building #51 – 2013 Hods with Nitroglycerin-Mix Waste Photo (Duplicate)

6. Building #51 – 2013 Decommissioning Checklist/Information Sheet and Photo

7. Building #232 – 2013 PETN Detonating Cord Photo

8. Building #232 – 2013 Decommissioning Checklist/Information Sheet and Photo

9. Building #51 – Proposed Hod Cover Drawing

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Code -·Hand Packing Gelatin, Etc. - 6/68

III. F. Apparel (cont'd)

11

9. Clothing with exposed metal, watches, rings and. metallic jewelry shall not be worn in a~1y explosive building dul'ing opera.tions and no outer clothing· shall be worn over the powder uniforms •.. ·

I.

lO. No shoes, caps, gloves or uniforms shall be worn or hl,keJ;l off the plant, even for a temporary period. Employees must change into street clothing before leaving the plant. This· applies also to. those who desire to go into· appreved areas to smol\:e or. eat thej,): lunch,

IV. EQUIPMENT AND MAJ'ERlAL

A. General Descr.iption of House and Eq_uipment

1. The Hand Pack Houses are two-level structures constructed of . wood·and ea.ch house is barricaded. Eachhouse.is·equipped.with

an exhaust system· and-a combination.heating and cooling unit,. The exhaust system is located on top of the barvieade and the heater-cooler is located outside the barricade i)lld both have a canvas· isolation section in the· d.uctwork .going. into the house.

· All metal parts of any machinery,. ducting,. etc.,. are grounded .to protect against the possibility of a spark.frem a buildup of static electricity or a. short circuit frem some of the electrical equipment, . See. dra.wing .on next page.

2 •. 'l'he top floor of each h0t1se opens to a narrow gauge ·track where powder· and· shells· are delivered. by .the truckers on.flatbed t,J:;llcks, There· are from one to three hopper openings·which lead to bins on the bottom floor and into which the powder·and .. shells are dumped. The-balance of the topJloor·is·storage space·:[orpowder .buggies and shell racks,

3. The b0tt0m floor of the house -leadS to 'a covered porch and-a , covered-siding of the narrow gaugetr:;tck. The.powder is scoop

. ed.or shoveled.f1•om the bins into bags or shells·which·are·weigh

. ed- and tied or t:J,ped clo$ed. Tl1en .they are put into boxes. which ·are glued and. placed on the· flatbed truck. One exception is. the thick-walled shells-which are crimped and cased or crimped-and wax sealed. The trdcks are·then.pullecj to the magazine-for- stor:.. age or shipment.

4. Originally the nine Hand Pack Houses- were designed lfor speci;fic . type powders and containers but cl!stome:r demands requ:il'ed -that

the houses.be mpdified in order to be·· able to paqk.va,rious.typf! powde1·s in-a variety of containers •. Essentially the hollse& can be

. 12

Code - Hand Packing Gelatin,. Etc. - 6/68

IV. A. General Desc1•iption of House and Equipment (cont'd)

classified into three. t:yJ}es at which only certain design containers can be packed.

a. Type I House These houses car1 only paclc small or lar'ge size

~7 b.

. bags and small size thin-walled shells. They are Hand Packs Nos. 1, 2 and 4. The hollse coutaills only one bin into which the powder is dllmped from the top floor and scooped out of the bin on. the botto;qJ floo1· into bags or shells, The sma.ll size bags are poly-

. ethylene and mn from one-half to three pounds per bag, tied shut with ~·u.bber bands and from seventeen to one hundred bags are put. in. each case. The large sized bag·s are .paper with an inside waxed liner, take twelve and one-half pounds of powder, are taped shut with two-inch gummed paper tape and are packed .with four bags peJ7 case. The f!mall size thin-walled shells are three-ply paper shells, two and one/half-inch dia,meter by six inches long to four-inch diameter by ten. inches long, are hand crimped shut and are packed from twenty six·to nine per case.

Type II House These houses can pack small or large size bags and small or la1•ge size thin-walled shells. They are Hand Pack, Houses Nos •. ~ 8 a;nd 9. Hand Pack No. 6 contains-three bins on the bottom floor. One is a low level bin for the large size shells which are dumped .into the bin from the top floor. One is a high level bin for powder dumped into it from the top floor. This. bin has a lipped shelf on it with one or more· funnel openings on the bottom through which .the powder is shoveled into the shells. The shells .rest on one end of a beam balance scale extending through the wall and the mouth of the shell covers the· mouth of the funnel. The shells· are hand crimped and taped shut with one-half inch fiberglass reinforced tape and cased one or two to ·a box. Shells are thl'ee-ply paper and sizes run from five-JJ1ch diameter by

. twenty-four inches long. to ten-inch diameter by·twelve inches long. The small and large size bags and small size thin-walled shells are packed in the third bin. which is a low level bin and packing is done the same as in a Type I House. Hand Paclr.s Nos. 8 and 9 have only two bins •. A high level bin for packing large size thin~walled shells and. a low level bin. The low level bin can be used for dumping large siloe shells or for packing small and large size bags and small thin-walled shells the same as in a Type I House.

c. Type- III House The~?e houses can only pa.ck large size thin-walled shells, ~?eismograph .thick~walled shells and. large size thiclt-walled 23G shells. They are Hand Packs Nos. 5 and 10 and both contain two bins, one high level bin for packing the shells and one low level

13

See attached photos: o Nitroglycerin (NG) residuals & Building #51

Decommissioning Info Sheet. o PETN detonation cord & Building #232

Decommissioning Info Sheet.

Nitroglycerin (NG) Residuals in Hods

Building #51 “Hand Pack No. 6”

CLL

Cross-Out

14

CLL

Cross-Out

15

PETN Detonating Cord in Building #232 “Talley Mix House #4”

CLL

Cross-Out

16

CLL

Cross-Out

6' -0"

5'-2"

1" 5PLY PLYWOOD TO 2"X4" FRAME

4"X4" LE FASTEN WITH 3" DECK SCREWS

0 OC> .....--I I -- N .....--

1" 5PLY PLYWOOD TO 2"X4" FRAME

4"X4" LE TOP VIEW

FASTEN WITH 3" DECK SCREWS

.... FRONT

:: ~ 0

~"""-- .....--I I -N N

END VIEW SIDE VIEW

HOD COVER


APPENDIX B

OPEN BURN PERMIT 5861

Janice K. Brewer Governor

CERTIFIED MAIL

ARIZONA DEPARTMENT OF

ENVIRONMENTAL QUALITY

1110 West Washington Street • Phoenix, Arizona 85007 (602) 771-2300 • www.azdeq.gov

RETURN RECEIPT REQUESTED

Craig E. Boudle Apache Nitrogen Products Iric. P.O. Box 700 Benson, AZ 85602

Subject: Open Bum Permit# 5861 (LTF #60956)

Dear Mr. Boudle:

Henry R. Darwin Director ·

Enclosed, please find a copy of Open Bum Permit# 5861 for Apache Nitrogen Products Inc. for demolition of Building No. 51 qontaining hazardous aged explosives by an open bum exercise.

· You are advised that this Permit is a legally enforceable document. If your facility fails to comply with the provisions contained in this Permit, you may be subject to enforcement action and could incur civil fines under the Arizona Revised Statutes.

If you have any questions, please contact Vivek Kapur at (602) 771-2323 or me at (602) 771-2308.

Sincerely,

ssey, Director lity Division

ECM: vk2

Enclosures: Open Bum Permit #5861 (LTF #60956)

Southern Regional Office 400 West Congress Street • Suite 433 • Tucson, AZ 85701

(520) 628-6733

Printed on recycled paper

ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY DANGEROUS OPEN BURNING PERMIT # 5861 (LTF #60956)

The Director of the Arizona Department of Environmental Quality (ADEQ) hereby grants permission to conduct open burning to:

Apache Nitrogen Products, inc. ----~.Box 700

Benson, AZ 85602

Telephone Number/Fax Number: (520) 720-2114 I (520) 720-4158 Email: [email protected] Burn Location: 31 deg 53'; 14.18" N/110 deg 14' 07.73" W, St. David, Cochise County, AZ 85630

Nearest Fire Department: 1 St. David Fire Department (520) 720-4045

This permit is subject to the following conditions:

1 This Permit is valid until: October 31, 2014

2 The Permittee is allowed to burn only during the following periods:

a Start igniting no earlier than one hour after sunrise; and

b Fire must be extinguished two hours before sunset.

3 The Permittee is allowed to burn only the following material: [A.A.C.R18-2-602.D.3.a]

Wood, aged nitroglycerin, pentaerythritrol tetranitrate (PETN) based detonation card and Diesel

4 The Permittee shall not burn the following materials: [A.A.C.R18-2-602.A.I3]

ALL PLASTIC MATERIALS: Bottles for household chemical; grocery and retail bags

TOXIC VEGETATIVE MATERIALS: .Oleander, poison oak, poison ivy, poison sumac

WASTE PETROLEUM PRODUCTS: Waste crankcase oil, transmission oil, used oil, oil filters

CONSTRUCTION MATERIAL: linoleum flooring, composite counter tops, asphalt shingles, tar paper, electrical wire insulation, asbestos, thermal insulation. ·

HAZARDOUS WASTE PRODUCTS: Paints, pesticides, cleaners and solvents, stains and varnishes, flammable liquids, plastic pesticide bags and containers

HAZARDOUS MATERIAL Lead compounds, cadmium compounds, mercury, arsenic compounds. CONTAINERS THAT CONTAINED: PLASTIC AND RUBBER Bottles for household cleaning, plastic grocery and retail bags PRODUCTS INCLUDING: AUTOMOTIVE WASTE : Tires, anti-freeze·

POLYESTER PRODUCTS

AEROSOL SPRAY CANS

BATTERIES

NON PAPER FOOD GARBAGE

Page 1 of7

5 The Permittee shal.l observe the following:

a The material to be hurried shall be dry, readily combustible, and placed in the following arrangement(s) in such quantities that it will be completely consumed within the permitted bum hours in Condition 2 above:

b

c

Piled[]

. ii Collected in a pit [ ]

iii Placed in an approved waste burner []

iv Ignite in place (field burning) [X]

v Ditch Burning [ ]

The piled, pit-contained material or approved waste burner must have a minimum clearance of 50 feet from any structure.

[A.A.C.R 18-2-602.D.3.k]

The Permittee may start bum using items such as matches, flares, or hand-held torches fueled by liquefied petroleum gas such as propane or butane.

[A.A.C.R 18-2-306.A.2]

6 Additional Responsibilities

a The Permittee shall notify the nearest firefighting agency or private fire protection service provider, if the service provider is a delegated authority, prior to each open burning. The agency may require the Permittee to obtain a perinit from them before being allowed to bum and may prohibit open burning during periods of smoke dispersion, excessive visibility impairment, or during periods of extreme fire danger. In the case that there is no firefighting agency for the area where the bum will be conducted, the Permittee shall contactthe State Forester.

[A.A.C.Rl8-2-602.D.3.g]

b The Permittee shall not open btim when any air stagnation advisory, as issued by the National Weather Service, is in effect in the area of the bum or during periods when smoke can be expected to accumulate to the extent that it will significantly impair visibility in Class I areas.

[A.A.C.R18-2-602.D.3.m]

c The Permittee shall not open bum when any stage air pollution episode is declared under A.A. C. RlS-2-220, Air Pollution Emergency Episodes.

[A.A.C.Rl8-2-602.D.3.n]

d Open burning shall be conducted only during wind conditions which prevent dispersion of smoke into populated areas, do not caus.e visibility impairment on traveled roads or airports to the extent that a safety hazard results, do not create a public nuisance, and do not cause uncontrollable spreading of the fire.

[A.A.C.R 18-2-602.D.3.d]

e The Permittee may be required by the Director or the Director's assignee to extinguish or abstain from open burning during periods of inadequate smoke dispersion, excessive visibility impairment or at other times when public health or safety could be adversely affected.

[A.A.C.Rl8-2-602.D.3.o]

Page 2 of7

f The Permittee shall be present at all times when C()nducting open burning until the fire is completely extinguished. The Permittee shall be responsible for any damages caused by a fire started by the Permittee's open burning. The Permittee shall be subject to civil penalties from damages caused by fires started by the Permittee's open burning.

[A.A.C.R18-2-602.D.3.i]

g The Permittee shall have 'available any necessary equipment (i.e: 'Yat~r supply, .water hose, shovel, sand, etc.) to control the bum and to put out the fire if the need·ariseS. .

. . [A..;\.C.R18-2-602.D.3.j]

h The Permittee shall have a copy of this permit on-site during open burning, to show that the Permittee has the authorization to conduct open burning.

[A.A.C.R18-2-602.D.3.1]

This permit shall not· be construed to relieve the Permittee from liability from' resulting damages or the obligation to comply with other applicable laws, regulations, or ordinances. The Permittee is responsible to comply with federal, state, county mid/or local fire restrictions in place for the area where the burn will be conducted.

J The Permittee shall also comply with requirements of Arizona Revised Statutes (A.R.S.) § 13. 1706, as listed below:

[A.A.C.R18-2-602.D.3.p]

A.R.S. §13.1706. Burning of wildlands; exceptions; classification

A It is unlawful for any person, without lawful authority, to intentionally, knowingly, recklessly or with criminal negligence to set or cause to be set on fire any wildland other than the person's own or to permit a fire that was set or caused to be set by the person to pass from the person's own grounds to the grounds of another person.

· B This section does not apply to any·ofthe following:

Open burning that is lawfully conducted in the course of agricultural oper~tions.

2 Fire management operations that are conducted by a political subdivision.

3 Prescribed or controlled burns that are conducted with written authority from the state forester.

4 Lawful activities that are conducted pursuant to any rule, regulation or policy that is adopted by a state, tribal or federal agency.

5 In absence of a fire ban or other burn restrictions to a person on public lands, setting a fire for purposes of cooking or warming that does not · spread sufficiently from its source to require action by a fire control agency.

C A person who violates this section is guilty of an offense as follows:

If done with criminal negligence, the offense is a class 2 misdemeanor;

2 If done recklessly, the offense is a class I misdemeanor;

3 If done intentionally or knowingly and the person knows or reasonably should know that the person's conduct violates any order or rule that is issued by a governmental entity and that prohibits, bans, restricts or otherwise regulates fires during periods of extreme fire hazard, the offense is a class 6 felony.

Page 3 of7

Eric C.

4 If done intentionally and the person's conduct places another person in danger of death or serious bodily injury or places any building or occupied structure of another person in danger of damage, the offense is a class 3 felony.

ate: Air Q tty Division Engineer: VK2 Ariz a Department of Environmental Quality (602) 771-4527 or 1(800) 234-5677

Page 4 of7

ATTACHMENT "A" GENERAL PROV,ISIONS

DANGEROUS OPEN BURNING PERMIT #5861 (LTF #60956)

I. RIGHT OF ENTRY

Authorized representatives of ADEQ shall be permitted:

A. To enter the premises where the source is located or in which any recor s are requirea o be kept under the terms and conditions of this permit.

B. At reasonable times to have access to and copy records required to be kept under the terms and conditions of this permit. ·

C. To inspect any equipment, operation, or method required in this permit.

D. To sample emissions from the source.

II. PERMIT REVOCATION

The Director may revoke this bum permit if any ofthe following occur:

A. The Director has reasonable cause to believe that the permit was obtained by fraud or misrepresentation.

B. The person applying for the permit failed to disclose a material fact required by the permit application form or the regulation applicable to the permit of which the applicant had or should have had knowledge of at the time application was submitted.

C. The Permittee is not complying with any terms or conditions of the permit.

D. A determination by ADEQ that the permitted activity constitutes an imminent and substantial endangerment to public health and that such endangerment can only be eliminated by permit revocation.

Page 5 of7

ATTACHMENT "B" SPECIFIC CONDITIONS

DANGEROUS OPEN BURNING PERMIT #5861 (LTF #60956)

I. SUMMARY

This open bum permit is issuecHo-Apache-Nitrogen-Prodttcts;-Inc;-f-or-t-he-pttrpose-o-f--demo-l-itio +------------Af-Building--N0;-5-1-by-an-open-bum-exercise~'fhe-building-contains-hazardous-aged-explosives------

that can not be safely removed in any other manner. The building is constructed of wood (abo11t 3.11 tons) and contains about 250 pounds of aged nitroglycerine. Also, approximately 50 feet of uncoiled pentaerythritol tetranitrate (PETN) based detonation card (0.35 pound) will be disposed during this bum event. The building will be doused with I 0 gallons of diesel fuel to start the bum. The bum event is expected to last less than an hour.

Building No. 51 is located 3,076 feet from the Apache Nitrogen plant active area (Prill tower) and 3,205 feet and 4,291 feet from the nearby residential areas. Monitoring of ambient air will be conducted at or near these locations prior to, and during the bum event by collecting samples in Summa Canisters. The Permittee will be required to analyze the collected samples for carbon monoxide (CO), volatile organic compounds (VOCs) and hazardous air pollutants (HAPs).

II. TYPE OF BURN

A. The Permittee shall bum only the following materials during the bum event:

I. Nitroglycerine, C3HsN309 2. PETN, CsHsN4012 3. Diesel 4. Wood

B. The Bum will be conducted in accordance with the Time-Critical Removal Action (TCRA) work plan for Apache Nitrogen Superfund Site and procedures described therein.

III. MONITORING AND RECORDKEEPING REQUIREMENTS

A. The Permittee shall record the date and time of open bum, the specific items that are ignited, and the quantity of the items.

B. The Permittee shall collect samples of ambient air prior to bum and during the bum at various locations in accordance with the TCRA work plan.

C. The collected samples should be analyzed for carbon monoxide (CO) using EPA Method 3C, and volatile organic compounds (VOCs) & hazardous air pollutants (HAP.s) using method T0-15.

D. Within 30 days of the bum event, the Permittee shall submit the results of samples to the ADEQ.

Page 6 of7

CERTIFICATION OF TRUTH, ACCURACY, ANU COMPLETENESS ARlWNA ADMINISTRo\ T(VE CODE R18-3-

304.R

RI8-2-304.IL Certi]/cafion o} Truih,Accuracy, ana Compl¢teness: Any appliClilt7»rfamr,-nporr;-or·------compliance certifteation submitted pursuant to this Chapter shan contain csrtification by a respensible official of truth. accuracy. and co1t1pletem:sa. Thi.1· ceriiftCOtion and any other certification required under lhls Article shall stale that,. bated on iJiformation and belief formed after reruonabfe Inquiry, the staiement and infonllatidn in tl~ document are true, a'c:curate, and complete.

Typed or printed name of signer: Crail! E Boudle

Page 7 of7


APPENDIX C

COMMUNITY NOTIFICATION PLAN


TABLE OF CONTENTS

1. Outreach Strategy

2. Invitation Letter Format

3. Burn Notification Ad

4. Figure C -1 – Protection Area Radii

Apache Nitrogen Products, Inc. Controlled-Burn Community Information Plan

8/4/14

ANPI Controlled-Burn Community Information Plan

Outreach Strategy: EPA Apache Powder Fact Sheet EPA has developed a relevant fact sheet for distribution to internal and external stakeholders, specific to the controlled-burn. The information sheet also includes images of the ANPI plant site. ANPI Controlled-Burn Informational Briefing ANPI will host an informational briefing detailing the specifics of the September 18, 2014 controlled-burn on August 20, 2014. Personal invitations will be distributed to neighbors within a one-mile radius of the ANPI plant site. ANPI News Paper Notice A community “Notice of Controlled Burn” ad will be placed in the August 13th edition of the Benson News-Sun. -30-

<Print on ANPI Letterhead> <Date, Month, Year> <First Name> <Last Name> <Address #1> <Address #2> <City>, <State> <Zip> Dear <First Name>: As part of our continued community outreach, Apache Nitrogen Products, Inc. (ANPI) is writing to inform you of an informational briefing scheduled for Wednesday, August 20, 104 at 6 p.m. in the St. David Unified School’s Multi Purpose Room, located at 70 E. Patton St, St. David, AZ. This briefing is being held regarding a planned controlled-burn on the ANPI property, currently scheduled for September 18, 2014.

This controlled burn has been planned as part of a remediation effort to destroy materials located inside Building #51 along the historic Powder Line on-site, rather than risk moving the material off-site. This controlled-burn is taking place under the oversight and guidance of the U.S. Environmental Protection Agency (EPA) Superfund program as a Removal Action, with technical support from the Arizona Department of Environmental Quality (ADEQ) and additional subject matter experts. Additionally, this controlled burn will be supported by representatives from the EPA, ADEQ, the Cochise County Local Emergency Planning Committee, and both the Benson and St. David Fire Departments, each of whom will be in attendance at the informational briefing. Currently, the controlled-burn is scheduled for September 18, 2014, with September 19, 2014 being designated as an alternate day in case of weather delays. Please keep the following in mind as some of the safety precautions may affect your plans:

• Apache Powder Road will be closed from 7 a.m. to 1 p.m. on the day of the controlled-burn. • Large vehicles, including fire trucks, will be visible at or near the ANPI facility in support of the

controlled-burn. • Dark smoke may be visible for period of time after 8 a.m. – this is normal, and part of the controlled-

burn. • Visible ANPI perimeter controls will be in place for the duration of the controlled-burn.

As part of our ongoing commitment to safety, ANPI is committed to providing open and transparent communication regarding the controlled-burn to our surrounding community. If you would like more information, or would like to RSVP your attendance at this informational briefing, please contact ANPI Business Development & Public Relations Manager Lyndon Denton at 520.720.2190 or via email at [email protected]. Yours truly, Craig Boudle, Safety, Health & Environmental Manager


NOTICE OF CONTROLLED BURN

This notice is to inform the community of a controlled burn of an abandoned historic Powder Line production building at the Apache Nitrogen Products, Inc.’s facility. Oversight will be provided by EPA, ADEQ and Local Emergency Responders, including St. David and Benson Fire Departments.

Burn Date: Thursday, September 18, 2014 Start Time: 7:00 a.m. Estimated Completion Time: 12:00 p.m. Alternate Burn Date (pending weather) Friday, September 19, 2014 Please call 520-720-2190 for questions


APPENDIX C

FIGURE

FIGURE E-1. PROTECTION AREA RADII

CAP

Text Box

FIGURE C-1. PROTECTION AREA RADII

CAP

Text Box

CAP

Text Box


APPENDIX D

AIR MONITORING PROGRAM


TABLE OF CONTENTS

1. Appendix D Monitoring Plan – (Excerpted from Application to Obtain a Permit for

Conducting an Open Burn of Aged Explosives, by Stantec Consulting Services,

Inc., dated August 2014.)

Appendix D Monitoring Plan August 2014

v:\work in progress\permitting\apache nitrogen\open burn modeling and permit\open burn application final - 2014-08-12.doc D.1

Appendix D MONITORING PLAN

D.1 INTRODUCTION

ANPI will demolish an older building located on-site (Building 51) by conducting an open burn. The building contains hazardous aged explosives that cannot be safely removed in any other manner. Emissions from the open burn will include various pollutants. This monitoring plan details the pollutants of concern, compares modeled pollutant impacts to the NAAQS and OSHA exposure limits, and discusses monitoring and sampling methods to be used to measure the impact of the open burn.

D.2 MONITORING LOCATIONS

Monitoring will be conducted at or near locations where employees or nearby residents will be present. The distances from the open burn location at Building 51 to the plant active area where employees will be located (Prill Tower) and nearby residences to the northwest and south-southeast are listed in the Table D.1 below. Monitoring locations and Building 51 are shown in Figure 7. Monitoring for the two residences may actually occur on nearby or adjacent ANPI property to avoid disrupting the other property owners. If this occurs, the results will be more conservative than if monitoring takes place on the residents’ properties due to the difference in distance.

Table D.1 Monitoring Locations

Location Approximate Distance to Building 51

(Open Burn Location) (ft)

Prill Tower 3,076 Resident South-Southeast 3,205

Resident Northwest 4,291



Figure 7 Proposed Location of Monitors Relative to Burn Location



D.3 POLLUTANTS OF CONCERN

D.3.1 CRITERIA POLLUTANTS

Table C.12 of Appendix C compares the total ambient concentrations (OBODM-model predicted concentrations plus background concentrations) with the applicable criteria pollutant short-term NAAQS. All ambient concentrations are less than the applicable NAAQS. Table C.11 of Appendix C provides the modeled peak concentrations for informational purposes. The largest emissions by mass are for CO and VOCs. The modeled emissions for NO2 are closer to the applicable NAAQS than for other pollutants, however for modeling purposes it has been conservatively assumed that all NOx emissions are NO2 emissions. Even with this assumption, the modeled concentration of NO2 is 31.5 µg/m3 compared to the NO2 1-hour NAAQS of 188 µg/m3.

D.3.2 HAZARDOUS AIR POLLUTANTS

Health based standards for non-criteria pollutants are not available. In the absence of such standards, the standards established by the Occupational Health and Safety Administration (OSHA) have been selected as guidelines for evaluating potential adverse health impacts due to such pollutants. A listing of all pollutants that will result from the open burn and corresponding OSHA limits for each pollutant are presented in Appendix C. The OSHA standards are expressed as short term exposure limits (STEL) and 8-hour time weighted average (TWA).

A comparison between the Peak Concentrations predicted by the OBODM Model and corresponding STEL values and between 1-hour mean concentration vs. the OSHA 8-hour time weighted averages is presented in Table D.2. The closest proximity of a Peak Concentration to a STEL is for methylene chloride, however, the predicted concentration is only 6.2 x 10-6 % of the STEL.

The closest proximity of a 1-hour concentration to an 8-hour TWA OSHA standard is for beryllium, where the 1-hour concentration is 2.61 x 10-4 % of the 8-hour TWA OSHA standard. The predicted 1-hour beryllium concentration is 5.22 x 10-6 µg/m3, which is below normal laboratory detection limits.

Overall, modeled HAP concentrations are multiple orders of magnitude (approximately 10-6 or more) below the OSHA short-term emission limits as can be seen in Table D.2.



Table D.2 Comparison Between Peak and 1-Hour Average Concentrations with OSHA Standards

Comparison of Peak Concentrations with Short Term Exposure Limits

Pollutant Fence Line Peak Concentration STEL Ratio (Peak/STEL) %

Beryllium 4.74E-05 2.50E+04 1.90E-07 1.3 Butadiene 2.06E-05 1.11E+04 1.86E-07 Benzene 5.23E-05 1.60E+04 3.27E-07 Methylene Chloride 2.69E-02 4.34E+05 6.20E-06 Styrene 1.27E-06 2.56E+06 4.96E-11 Toluene 3.01E-05 1.88E+06 1.60E-09

Comparison of 1-Hour Average Concentrations with 8-Hour Weighted Average

Predicted 1-Hour

Weighted Average 8-Hour Weighted

Average Ratio (Predicted 1-

Hr/8-Hr TWA)% ( Antimony 1.05E-06 5.00E+02 2.10E-07 Arsenic 7.12E-06 5.00E+02 1.42E-06 Beryllium 5.22E-06 2.00E+00 2.61E-04 Cadmium 5.44E-06 5.00E+00 1.09E-04 Chromium 1.50E-05 5.00E+02 3.00E-06 Cobalt 1.38E-07 1.00E+02 1.38E-07 Lead 1.67E-05 5.00E+01 3.34E-05 Manganese 1.49E-05 5.00E+03 2.98E-07 Mercury 5.23E-06 1.00E+02 5.23E-06 Nickel 5.65E-06 1.00E+02 5.65E-06 Selenium 2.69E-05 2.00E+02 1.35E-05 1,3-Butadiene 1.56E-06 2.12E+03 7.36E-08 1,1,4 Trimethylpentane 3.24E-07 NA NA Acetonitrile 3.96E-08 6.72E+04 5.89E-11 Benzene 3.96E-06 3.20E+03 1.24E-07 Bis(2-Ethylhexyl) phthalate 7.32E-07 5.00E+03 1.46E-08 Cumene 1.20E-08 2.45E+05 4.90E-12 Dibenzofuran 5.04E-09 NA NA Dibutylphthalate 3.96E-08 5.00E+03 7.92E-10 Ethylbenzene 4.44E-07 4.35E+05 1.02E-10 Formaldehyde 8.17E-04 9.20E+02 8.88E-05 n-Hexane 1.03E-07 1.80E+06 5.72E-12 Hydrogen Cyanide 2.52E-06 1.00E+04 2.52E-08 Methylene Chloride 2.04E-03 5.69E+04 3.59E-06 Naphthalene 1.01E-07 5.00E+04 2.02E-10 Phenol 5.52E-08 1.90E+04 2.91E-10 Phosphorous 1.80E-06 1.00E+02 1.80E-06 Polycyclic Organic Matter (POM) 1.03E-02 NA NA Styrene 9.60E-08 4.26E+05 2.25E-11 Toluene 2.28E-06 7.54E+05 3.02E-10 m-Xylene, p-Xylene, o-Xylene 3.43E-06 4.35E+05 7.89E-10



D.4 MONITORING METHODOLOGY

As indicated in Table C.12, predicted pollutant concentrations are below all applicable short-term NAAQS for criteria pollutants and below 1 µg/m3 for all non-criteria pollutants. All predicted concentrations are below the measurement thresholds of portable or hand-held analyzers, so other options must be considered for measuring the air quality impacts of the open burn.

Operation of sophisticated ambient analyzers capable of measuring concentrations in the µg/m3 range is not practical since the operation of such analyzers requires air-conditioned shelters plus a range of calibration gases to verify proper instrument response. Particularly since multiple locations are to be monitored simultaneously during the open burn, this is not a feasible option.

Monitoring using Summa ® canisters allows for the collection of separate samples prior to and during the open burn at multiple locations. The process is straightforward and samples can be obtained over a period of time to ensure that representative emissions from the open burn are captured. The contents of the Summa ® canisters are then analyzed in a lab, which allows for better detection of low concentrations of pollutants than when using alternative monitoring methods. Air quality monitoring for the open burn will be conducted using Summa ® canisters.

The air samples in the Summa ® canisters will be analyzed for CO, VOCs, and HAPs. CO and VOCs are criteria pollutants and represent the highest- and second highest-emitted species at 799.36 and 712.85 lb/hour, respectively. NO2 cannot be analyzed through the use of Summa ® canisters and the relative emission rate of NO2 is quite low when compared to the predicted emission rates for CO and VOCs, at only 14.92 lb/hr. As indicated above, NO2 was modeled as if all NOx emissions were NO2, which is a very conservative assumption. Methylene chloride represents the HAP with the highest emission rate, yet the modeled concentration is still more than six orders of magnitude below the OSHA STEL. The HAP pollutants will correspond to those listed under EPA Method TO-15. Concentrations of these pollutants are anticipated to be very small and below measurement thresholds, but will be analyzed for information purposes.

Using the results from the CO, VOC, and HAP monitoring, air quality impacts for other pollutants can be calculated from their emission rates relative to the emission rates of CO, VOCs, and HAPs.

The proposed analytical methods and pollutants monitored are listed in Table D.3.



Table D.3 Proposed Air Sampling Time Periods and Methods

Time Period Sample Collection Method CO Analytical Methodology

VOC and HAP Analytical

Methodology From 45 minutes to 15 minutes prior

to start of Open Burn Event 30-minute metered Summa

Canister Sample (2) EPA Method 3C TO-15

From 15 minutes to 45 minutes after the start of the Open Burn Event

30-minute metered Summa Canister Sample (2)

EPA Method 3C TO-15


APPENDIX E

SEISMIC MONITORING EQUIPMENT SPECIFICATIONS

Chapter 2 Specifications

Specifications Data Recorded One (1) acoustic and three (3) seismic channels. Frequency Response Mini-Seis: 2 to 500 Hz. (-3 dB. points) at 2048 samples per second.

Lower sample rates reduce the high frequency response proportionately.

Mini-Seis II: 2 to 250 Hz. (-3 dB points) at 1024 samples per

second. Seismic Sensors Three component mounted velocity geophones or accelerometers,

depending on the ordered recording ranges. Microphone Ceramic element rated to at least 160 dB. Memory Solid state with all summary, setup, and recorded data retained with

power off. A lithium backup battery retains data if primary power fails.

Clock A 24 hour clock maintains the date and time accurate to within 1

minute per month, even if primary power fails. Timer Mode Allows an instrument to be active only during selected hours on a

daily basis. Display The high contrast LCD has two lines of 40 characters to facilitate

the instrument's setup. It also allows the operator to view operating parameters and summary data.

Optional Keypad Contains 6 keys for entering setup data and operating commands. Power on Log A log of the last 64 on/off cycles is kept in memory to indicate the

active monitoring periods. If the timer is used, the log is updated each time it activates.

Battery Internal 6 volt rechargeable. Operating Time With a fully charged battery all models will operate from 7 to 10

days at 1024 samples per sec. Longer times may be obtained using the timer mode or external power from a small solar cell or automobile battery.

External Battery Life A standard automobile battery will keep the internal battery at full

charge for several months at moderate temperatures. If the external battery fails, the unit will continue to operate on its internal battery.

3

Chapter 2. Specifications

Charging An internal charging circuit allows charging with the supplied plug-in wall mount charger or any 10 to 15 volt DC supply. Power supplies for international use are available.

Operating Temperature 0 to 130 degrees F (-18 to 54 degrees C) Case Heavy gauge aluminum for effective electrical shielding and rugged

protection. A stainless steel case is optional. The case is sealed allowing shallow burial.

Size Approximately 7.5 in. x 4.5 in. x 2.5 in. Weight - Aluminum Case Approximately 3.5 lbs. (1.6 Kg.) without accessories. Weight - Stainless Steel Adds 2 lbs. (.9 Kg.) above the aluminum case weight. Weight - Accessories Approximately 6 lbs. (2.7 Kg.) including the storage case. Waveform Data Mini-Seis: The full waveform signature is stored in solid state

memory for up to 340 events. Mini-Seis II 1/8M: Approximately 10 to 20 typical blast events. Mini-Seis II 1/4M: Approximately 50 to 100 typical blast events. Mini-Seis II 1/2M: Approximately 150 to 250 typical blast events. Summary Data Summarized data include the event time, date, battery voltage, peak

measurements, unit serial number and frequencies. The summarized data are stored in solid state memory for the last 341 events.

Sample Rate Mini-Seis: From 2048 samples per second per channel down to 32

samples per second per channel. Mini-Seis II: 1024 or 512 samples per second per channel. Recording Units English (U.S.) or metric. Seismic Recording Ranges Standard (x2)

0.005 IPS to 2.5 IPS (0.125 to 64 MMPS) 0.01 IPS to 5.0 IPS (0.25 to 127 MMPS) 0.02 IPS to 10.0 IPS (0.50 to 254 MMPS)

Optional (x1 - accelerometers)

0.01 IPS to 5.0 IPS (0.25 to 127 MMPS) 0.02 IPS to 10.0 IPS (0.50 to 254 MMPS) 0.04 IPS to 20.0 IPS (1.00 to 508 MMPS)

Optional (x4) 0.0025 IPS to 1.2 IPS (0.063 to 30.5 MMPS) 0.005 IPS to 2.5 IPS (0.125 to 64 MMPS) 0.01 IPS to 5.0 IPS (0.25 to 127 MMPS)

Optional (x8)

0.0013 IPS to 0.6 IPS (0.033 to 15.2 MMPS)

4

Chapter 2. Specifications

0.0025 IPS to 1.2 IPS (0.063 to 30.5 MMPS) 0.005 IPS to 2.5 IPS (0.125 to 64 MMPS)

Acoustic Ranges 0.02 to 2.56 millibars (100 to 142 dB)

0.04 to 5.12 millibars (106 to 148 dB). Trigger Levels Seismic

2.5 IPS Range - 0.01 to 0.57 IPS (0.25 to 14.5 MMPS). 5.0 IPS Range - 0.02 to 1.14 IPS (0.5 to 29 MMPS). 10.0 IPS Range - 0.04 to 2.28 IPS (1.0 to 58 MMPS). Seismic trigger sensitivities are proportionally modified by optional gains.

Acoustic - 106 to 142 dB or 112 to 148 dB. Manual Trigger Allows triggering from the keyboard or by an external input. One unit

may be used to trigger additional instruments. Record Duration Mini-Seis: From 1 to 6 seconds at a sample rate of 2048 samples

per second. At lower sample rates, the duration is automatically increased proportional to the amount of decrease in the sample rate.

Mini-Seis II: From 1 to 9 seconds at 1024 samples per second. Cycle Time Mini-Seis: At 1024 samples per second, up to 12 seconds of data

can be taken with only 50 milliseconds between events. After 12 seconds of data are stored, another event cannot be taken until the previous data have been processed. Processing requires about 3 seconds per second of recording time.

Mini-Seis II: Maximum continuous data time is 9 seconds. Records Stored Up to 341 typical coal mine or quarry blast events. Calibration Test (Seismic) A dynamic transducer test is performed automatically after each

event or manually on command. The test is stored in the summarized data and may be downloaded as an event.

Calibration Test (Acoustic) An electronic test of the microphone is performed with the seismic

test and is stored in memory along with the seismic test. 84 Hour Cal Test In a remote installation, an automatic calibration test occurs if no

event has been recorded for 84 hours. RS232 Serial Port Data can be downloaded and setup commands can be uploaded

directly by computer or remotely by modem. Baud Rate From 1200 to 38.4K.

5

Documents

SDMS DOCID # 1146524 SEPTEMBER 10, 2014 …content related to handling of explosives, open burn permitting, monitoring, and air quality. Accordingly, H+A’s certification applies