Document zdGmgJ5w3BjxMGeYvaz55nrj3

To: CC: Sub j : wWi.vi.OOl VjfrC*I\ gENVIR^ARETY.DIS j.'i-u&u-J.yyu ue:4z:u.bU DRAFT OF CONTRACTOR SAFETY PROCEDURES FOR EXCAVATION OF CONTAM. SOIL ~ canr^vt^' a*** HOECHST CELANESE CORPORATION -\AjXa TECHNICAL CENTER A*v. uM. ^ri^T corpus Christi, Texas From: To: R. A. OPERSTENY DISTRIBUTION f] (v n~*T& RAO-252-90 December 14,1990 Subj: Draft of Contractor Safety Procedures for Excavations of Possible Contaminated Soil Attached is a modified draft of procedures that were used for the de-watering of HCTC's surface impoundments (ponds) last year. An early version had been generated by Jones and Neuse, our current environmental consultant, for specific cases involving EPA classified hazardous waste. I have adapted these procedures to allow general use for modifications in our pilot plant areas where contaminated soil has been found. Footing excavation for the Mid-Scale Process Units/Pharmaceutical Intermediates, for example, will require closure procedures as described in the Pilot Plant Area Closure Plan, which calls for appropriate safety procedures, in addition to a 30-dav advanced notice to the Texas Water Commission- Mundy, our on-site contractor, is currently reviewing their capabZil-iZtiXecstioa.jnhd training * for this work. Other situations, where prior sampling has indicated waste or soil to be non-hazardous, may allow less extensive actions for handling and disposal, and should be reviewed by the ESHA department. Please review the attached and return comments to me or Andy Savage. Distribution: Arnold, D. D. Atkins, B. Butts, S. K. Cooper, C. E. Hartman, L. W. Helmer, W. Kenesson, T. M . Mancias, J. B. Mather, R. W. Muniz, T. Nunn, D. C. Pasquino, R. Poole, B. R. Pulse, C. H. Rhyne, M. cc: Martinson, M. (Bridgewater-Legal) Nativi, R. (Stubbs-Overbeck and Associates) Roberts, K. A. Savage, A. Starr, D. Steele, B. Vaughn, G. J. Ward, J. L. Wells, P. M. I PLAINTIFF'S 1 EXHIBIT 1 CEL-670 009017