Addendum One .pdf

COMMONWEALTH OF KENTUCKY

DEPARTMENT FOR FACILITIES AND SUPPORT SERVICES

DIVISION OF ENGINEERING AND CONTRACT ADMINISTRATION

INVITATION TO BID NO: RFB-118-26

FOR: FB Russell Lease Tenorm Remediation Site Department of Environmental Protection Powell County, Kentucky

DATE: December 15, 2025

RFB-785-2600000270

ADDENDUM NO. One (1)

RFB-785-2600000270

BIDDER SHALL CONFORM TO THE FOLLOWING CHANGES AS SAME SHALL BECOME BINDING

UPON THE CONTRACT TO BE ISSUED IN RESPONSE TO THIS INVITATION TO BID.

Item 1: Refer to attached addendum for all additions, deletions, and/or changes to specifications and/or drawings.

END OF ADDENDUM

Invitation to Bid No. RFB-118-26 For: FB Russell Lease Tenorm Remediation Site Department of Environmental Protection

Susan Ward, Statewide Procurement Analyst II Division of Engineering and Contract Administration

CORRECTIVE ACTION PLAN

FB Russell Lease Cleanup Project

37.756046 Lat, -83.822021 Long

AI # 170634

Prepared For:

Kentucky Energy and Environment Cabinet Department for Environmental Protection

Division of Waste Management Superfund Branch

300 Sower Boulevard Frankfort, Kentucky 40601

Prepared by:

114 Fairfax Avenue Louisville, KY 40207 (502) 895-5009 linebachfunkhouser.com

November 15, 2024

Mr. Nathan Bentley Energy and Environment Cabinet Kentucky Department for Environmental Protection Division of Waste Management Superfund Branch 300 Sower Boulevard, 2nd Floor Frankfort, Kentucky 40061

Re: Corrective Action Plan FB Russell Lease Cleanup Project Powell County, Kentucky Linebach Funkhouser Project Number 244-24

AI # 170634

Dear Mr. Bentley:

Linebach Funkhouser, Inc. (LFI), consultant for the Energy and Environment Cabinet (EEC) Kentucky Department for Environmental Protection (KDEP) Division of Waste Management (DWM) Superfund Branch, has completed the enclosed Corrective Action Plan (CAP) for the FB Russell Lease Cleanup Project located at 37.756046° Latitude, -83.822021° Longitude Powell County, Kentucky that was historically used for bulk crude oil storage. The FB Russell Lease site in Powell County contains three wooden crude oil tanks of various sizes, which are in poor condition and are leaking, along with four steel tanks containing liquids and associated miscellaneous piping is also present. The site is located in a rural area with limited access to Mountain Springs Road. DWM personnel collected samples from the wooden tank sludge, soil, and piping for TENORM analysis (radium 226 and radium 228). TENORM was confirmed with the resulting analytical data at concentrations greater than applicable screening levels in soils around the tanks and sludge from the wooden tanks.

This CAP is being submitted in response to LFI’s Proposal for Environmental Services dated September 16, 2024, and authorized by the DWM’s Delivery Order dated October 2, 2024. LFI appreciates the opportunity to prepare the enclosed CAP. Please contact us if you have any questions or comments regarding this document.

Sincerely, Russell H. Brooks, PE, PG R. William Johnston, PG Senior Engineer Principal Geologist

Enclosure iv

TABLE OF CONTENTS

1.0 INTRODUCTION/BACKGROUND

2.0 PREVIOUS ENVIRONMENTAL DOCUMENTATION

2.1 KDEP Limited Environmental Assessments – 2021 and 2023

3.0 EXPOSURE PATHWAY EVALUATION

3.1 Topography

3.2 Soils/Geology

3.4 Constituents of Concern/Extent of Affected Areas

3.5 Human Health Evaluation

3.6 Ecological Evaluation

4.0 CLEANUP CRITERIA SELECTION

5.0 STATEMENT OF WORK

5.1 Objectives

5.2 Summary of Proposed Remedial Activities

5.3 Site Safety Plan

6.0 REMEDIATION PLAN

6.1 Remediation Alternatives

7.0 SITE SPECIFIC QUALITY ASSURANCE PROJECT PLAN

7.1 Project/Task Organization

7.2 Problem Definition/Background

7.3 Project/Task Description and Schedule

7.4 Special Training Requirements/Certification

7.5 Documents and Records

7.6 Data Management and Documents

7.7 Field Data Evaluation

8.0 REFERENCES

LIST OF TABLES

Table 1 – Summary of TENORM Results

LIST OF FIGURES

Figure 1 – Site Location Map Figure 2 – Aerial Photograph Showing Site Location

LIST OF APPENDICES

Appendix A – Generic Health and Safety Plan

Corrective Action Plan – AI # 170634 November 15, 2024 FB Russell Lease, Stanton, KY LFI Project No. 244-24

1.0 INTRODUCTION/BACKGROUND

Linebach Funkhouser, Inc. (LFI), consultant for DWM, has prepared this Corrective Action Plan

(CAP) for the subject site located at 37.756046° Latitude, -83.822021° Longitude Powell

County, Kentucky that was historically used for crude oil storage from nearby production wells.

(Figure 1). The site was identified in 2021 by DWM personnel upon being notified by the

Kentucky Division of Oil and Gas concerning releases and possible TENORM (Technologically

Enhanced Naturally Occurring Radioactive Materials) issues on the property. The sludge material is the source of the low-level TENORM, which resulted from the processing and co-processing of the NORM-containing waters and crude oil materials from nearby oil wells.

Constituents of TENORM are radionuclides primarily from the uranium-238 (U-238) and thorium-232 (Th-232) decay series. These radionuclides are naturally occurring at elevated concentrations in local bedrock and soils. Radium (chemical symbol Ra) is a naturally occurring radioactive metal. Its most common isotopes are Radium-224, Radium-226, and Radium-228. It occurs at low levels in virtually all rock, soil, water, plants, and animals. The primary isotope identified at the Site is Radium-226. There was visible crude oil staining around the tanks and sampling conducted by DWM personnel confirmed TENORM contamination. TENORM is considered "Low-Activity" Radioactive Wastes (LARW) are informally defined as radioactive wastes that contain very small concentrations of radionuclides. The concentrations are small enough that protection of public health and the environment from these wastes may not require all of the radiation protection measures necessary to manage higher-activity radioactive material.

At this time, “low-activity” itself is a concept, not a definition. Among the wastes that could be addressed as “low-activity” are mixed wastes (chemically hazardous and radioactive), wastes containing natural radioactivity, cleanup wastes and other low-level radioactive wastes. Present regulation of “low-activity” radioactive waste is inconsistent, often based on the origin of the waste.

Multiple oil wells were drilled on the subject property in the 1960s, with wells installed in the

Appalachian Basin of Eastern Kentucky in the Irvine Oil field with the reservoir rock identified

Corrective Action Plan – AI # 170634 November 15, 2024 FB Russell Lease, Stanton, KY LFI Project No. 244-24 as “Corniferous” Formation, which is a sequence of dolomite, limestone, and shale of Devonian and Silurian age that underlies the New Albany Shale. The well field played out in the 1970s.

The property is an undeveloped tract of approximately 75 acres, approximately 8.5 miles south of Stanton, Kentucky, accessible from Mountain Springs Road on the east side of the property.

The property is heavily wooded, with no accessible roads to the site. An aerial photograph showing the site layout is provided in Figure 2.

2.0 PREVIOUS ENVIRONMENTAL DOCUMENTATION

A summary of previous environmental documentation associated with the site is provided in the following sections.

2.1 KDEP Limited Environmental Assessments – 2021 and 2023

In November 2021, DWM’s Emergency Response Team (ERT) personnel collected two sludge samples from two intact wooden tanks, three soil samples from around the two wooden tanks and one collapsed tank to evaluate potential TENORM impacts at the site. Samples were analyzed for Gross α/β and Ɣ species. Additionally, radiation readings were collected using Model 12 and

12S radiation detectors, with no readings detected above background levels with the radiation meters. A second sampling event was conducted in September 2023 to collect near surface soil samples from adjacent to the steel ASTs and metal and wooden tank piping. The following table summarizes the sampling events:

Table 1: Summary of TENORM and Radiation Levels Detected at FB Russell Lease

Sample Location

Sample

ID

Sample Date

Radium pCi/g

Radium pCi/g

Total pCi/g

ERT/Maxey Radiation Survey Levels 7/8/21

(Tanks,soil and piping)

Tank 1 (soil) TSS-1 11/24/21 5.71 0.433 6.143 no screening

Tank 1 (sludge) TBS-1 11/24/21 96.4 0.749 97.149 18-35 uR

Tank 2 (sludge)

TBS-2 11/24/21 1.08 0.344 1.424 18 uR

Corrective Action Plan – AI # 170634 November 15, 2024 FB Russell Lease, Stanton, KY LFI Project No. 244-24

Tank 2 (soil) TSS-2 11/24/21 1.76 0.0375 1.7975 no screening

Tank 3 (soil) TSS-3 11/24/21 4.29 0.884 5.174 no screening

Tank 4 (soil) TSS-4 9/20/23 20.1 1.48 21.58 80 uR

Tank 5 (soil) TSS-5 9/20/23 3.45 1.34 4.79 no screening

Tank 6 (soil) TSS-6 9/20/23 5.72 1.36 7.08 no screening

Tank 7 (soil) TSS-7 9/20/23 3.93 1.01 4.94 no screening

Wooden Tank Pipe

WTP-8 9/20/23 -0.0756 -0.0275 0.1031 22 uR

Metal Tank Pipe MTP-9 9/20/23 0.825 0.117 0.942 no screening

Background NS NS NS NS NS 6 uR

Tank 4 NS NS NS NS NS 40-80 uR

Tank 5 NS NS NS NS NS 11-14 u R

Tank 6 NS NS NS NS NS 11-18 uR

Tank 7 NS NS NS NS NS 12-14 uR

30' perimeter from

Tanks

NS NS NS NS NS

10 uR

Bold is above allowable limits (5 pCi/g) Radiation Survey Levels recorded in Micro Roentgen (uR/hr) Tank 3 contained no sludge, Tanks 4, 5, 6, 7 contain liquids only.

NS - Not Sampled

Analytical data indicated TENORM above EPA's cleanup standards for radium in contaminated soil of 0.2 becquerel per gram (Bq/g) (5 picocurie (pCi/g)) in the top 15 centimeters (5.9-inches) and 0.6 Bq/g (15 pCi/g) below 15 cm, as specified in 40 CFR Part 192.12 Subpart B. The cleanup standards for radium in contaminated soil at mill-tailings sites are relevant for natural uranium or thorium with their decay products present and in equilibrium because radium and its decay products are the most important radionuclides in these materials. Additionally, in accordance with 902 KAR 100:180 TENORM related to oil and gas development, materials above 5 pCi/g and less than 200 pCi/g would require disposal at a permitted landfill. Currently, only one permitted landfill in Kentucky is approved to receive TENORM waste. The Bavarian

Landfill in Walton, Kentucky, is the currently only permitted landfill. However, they have chosen not to receive TENORM waste as of the time of preparation of this CAP. Therefore, the disposal of TENORM waste above 5 pCi/g will have to be transported to an approved landfill out of state.

Corrective Action Plan – AI # 170634 November 15, 2024 FB Russell Lease, Stanton, KY LFI Project No. 244-24

3.0 EXPOSURE PATHWAY EVALUATION

3.1 Topography

The general elevation of the property is approximately 1,180 feet above the National Geodetic

Vertical datum of 1929 (NGVD). The overall topography in the area is relatively flat; however, the surface grade of the site gently slopes toward the west. Surface water runoff for the site is to the north towards the headwaters of the South Fork Red River, adjacent to the ASTs.

3.2 Soils/Geology

No soil borings have been advanced on the site. Based on a review of the Geologic Map of the

Stanton Quadrangle, Powell and Estill Counties, Kentucky, the underlying bedrock consists of limestone bedrock of the Mississippian-age Newman Limestone. Multiple oil wells were drilled on the subject property in the 1960s, with wells installed in the Appalachian Basin of Eastern

Kentucky in the Irvine Oil field with the reservoir rock identified as “Corniferous” Formation, which is a sequence of dolomite, limestone, and shale of Devonian and Silurian age that underlies the New Albany Shale approximately 800 feet below ground surface (bgs) based on review of nearby well logs.

3.3 Surface Water Bodies

The ASTs are located adjacent to the South Fork of the Red River, which discharges to the

Lower Middle Fork Red River.

3.4 Constituents of Concern/Extent of Affected Areas

TENORM-impacted media consisting of sludge, debris, and soils and, much to a lesser extent, crude oil derivatives consisting of various polynuclear aromatic hydrocarbons (PAHs) and

RCRA metals are the potential constituents of concern (COCs) at the site.

Corrective Action Plan – AI # 170634 November 15, 2024 FB Russell Lease, Stanton, KY LFI Project No. 244-24

3.5 Human Health Evaluation

As part of this CAP, an evaluation of pathways and receptors associated with potential human exposure is as follows:

Soil

TENORM was identified in soils adjacent to the AST at concentrations ranging from 1.7975 pCi/g to 21.58 pCi/g. No additional sampling has been conducted for other constituents. Even if

PAHs or RCRA metals are present in the soil, based on the remote nature of the apparent source, the potential direct-contact exposure to affected soil would likely be limited to construction workers involved in soil excavation in the area of the site immediately around the ASTs. The exposure of construction workers to affected soil will be short-term, and the generic Health and

Safety Plan included in Appendix A should be followed.

Groundwater

There currently is no known complete exposure pathway to groundwater. The depth of groundwater at the site is unknown. A review of water well records on file with the Kentucky

Geological Survey’s (KGS’s) Groundwater Data Repository shows one registered domestic-use water well approximately 3,500 feet east of the site. The domestic use well is reported to be 280 feet deep, with groundwater encountered at 78 feet bgs. Based on the distance of the plotted well from the site, the plotted wells do not rise to a level of concern as an exposure pathway for affected groundwater beneath the site.

Surface Water

The ASTs are adjacent to the South Fork of the Red River. If a release happens, the runoff will affect soils and potentially surface waters. Therefore, surface water is considered to be an exposure pathway at the site if there is a future release.

Air/Subsurface Vapor

Radon is a radioactive gas that can damage lung tissue and lead to lung cancer over time. It's the leading cause of lung cancer for non-smokers and can increase the risk of lung cancer for

Corrective Action Plan – AI # 170634 November 15, 2024 FB Russell Lease, Stanton, KY LFI Project No. 244-24 smokers by 10 to 20 times. As there are no structures on-site, ambient outdoor air does not constitute a significant exposure pathway to human or ecological receptors.

3.6 Ecological Evaluation

The site is located in a rural forested area. LFI reviewed the U.S. Fish and Wildlife Information for Planning and Consultation (IPaC) website to identify threatened or endangered species that are known to exist at the site. The site's overall remote and forested area is particularly conducive for a permanent habitat for environmental receptors. Site activities may potentially affect various species of mammals, fish, birds, and insects. No critical habitats have been identified at this location.

4.0 CLEANUP CRITERIA SELECTION

EPA's cleanup standards for radium in contaminated soil as specified in 40 CFR Part 192.12

Subpart B, will be used as cleanup criteria for the site. Further discussion of the cleanup goals are as follows.

Soil

Since the contaminants of concern consists of crude oil and TENORM the following constituents of concern should be evaluated:

Constituent

Cleanup Goal Radium-228/228 Crude Oil

5 pCi/g Visual Staining

Note: pCi/g – pico Curies per gram

The site has no complete exposure pathways due to the limited accessibility and remote location, with the exception of surface water, as previously referenced.

Corrective Action Plan – AI # 170634 November 15, 2024 FB Russell Lease, Stanton, KY LFI Project No. 244-24

5.0 STATEMENT OF WORK

Based on the previously referenced assessment results, TENORM-impacted sludge, soils, and debris are the media of concern for this site. The affected area contains the remains of a crude oil AST farm consisting of two wooden storage tanks, a partially collapsed wooden storage tank, and 4 steel storage tanks plus associated piping, as shown in Figure 2.

5.1 Objectives

The overall objective at the site is to eliminate or manage environmental risk to human health and the environment, thereby providing a level of closure that will not present environmental liability/hindrance to future use of the property. Due to the remote location of the ASTs, there are no complete exposure pathways on or off the site at this time. However, due to the location and condition of the ASTs near the South Fork Red River, there is a potential to impact the waters of the State if there was a catastrophic release due to degradation of the wooden ASTs.

Therefore, exposure to the primary potential future receptor (hunter) is likely along with impacts to South Fork Red River.

5.2 Summary of Proposed Remedial Activities

Natural attenuation is not a viable option for reducing concentrations. Radium-226 has a half-life of 1,600 years, which means that every 1,600 years, the mass of the radium will decay to 50% of its previous amount. Therefore, the identified sludge will be solidified with Portland cement, and debris consisting of the wooden tanks and impacted soil will be excavated, containerized, and disposed of at a permitted TENORM disposal facility in accordance with 902 KAR 100:180.

LFI has identified the Republic Services, Inc., Wayne Disposal facility located in Belleville, Michigan, as the receiving facility for TENORM sludge, debris, and soils that contain greater than 5 pCi/g. All other soils or debris containing <5 pCi/g are not considered TENORM waste, and only crude oil-impacted soils or liquids. These soils can be disposed of as crude oil-impacted soils at the nearby Waste Management, Inc. Blue Ridge Landfill in Irvine, Kentucky, or the Rumpke, Inc., Montgomery County Landfill as a non-hazardous special waste. Liquid in

Corrective Action Plan – AI # 170634 November 15, 2024 FB Russell Lease, Stanton, KY LFI Project No. 244-24 the steel ASTs are believed to be a combination of rainwater and residual crude oil that will be evacuated and recycled at an approved wastewater recycling facility.

TENORM waste (soils, solidified sludge, wooden debris, and piping) is to be properly profiled and approved to be received by the Wayne Disposal Facility prior to transporting materials off-site. Waste profiling will be conducted by the selected remediation contractor. Samples of various media (soils and solidified sludge) will be characterized using the Toxicity Characteristic

Leaching Procedure (TCLP) for Resource Conservation and Recovery Act (RCRA) 8 Metals plus beryllium, antimony, thallium, and nickel, total volatile organic compounds (VOCs)and total semi-volatile organic compounds (SVOCs), Total Cyanides, and Gamma Spectroscopy analysis (reporting all peaks).

Crude oil-impacted soils shall be sampled for TCLP RCRA 8 Metals, TCLP VOA, pH, and flashpoint.

The steel ASTs will be cleaned of residual materials and be recycled at an approved scrap metal recycling facility. Associated piping will be disposed of with soils due to the potential for scape buildup that may contain residual TENORM.

5.3 Site Safety Plan

An environmental-based generic site health and safety plan to address potential environmental exposure risk is provided in Appendix A.

6.0 REMEDIATION PLAN

6.1 Remediation Alternatives

Remedial alternatives were conceptually evaluated in terms of general technical feasibility, protectiveness of human health and the environment, cost, the need for treatability testing, ability

Corrective Action Plan – AI # 170634 November 15, 2024 FB Russell Lease, Stanton, KY LFI Project No. 244-24 to achieve remediation goals, and community acceptance. LFI assumes that the KDEP considered the following alternatives:

• No Action

• Site Management Supported By an ERC

• Physical Removal/Disposal

Following their evaluation and discussions with LFI, it was decided that physical removal would be the selected approach, as detailed in the following sections. As stated in Section 5.2, stabilization and excavation are the selected options to remediate the subject site.

7.0 SITE SPECIFIC QUALITY ASSURANCE PROJECT PLAN

7.1 Project/Task Organization

The KDEP selected LFI to prepare this CAP along with a Bid Specification and oversee the remedial effort's technical aspects at the subject site. The work is being financed by the Finance

Cabinet - Division of Engineering & Contract Administration.

Mr. Russell Brooks, PE, PG, will serve as LFI’s Project Manager. Sludge stabilization materials, equipment, and technical expertise will be provided by the selected remedial contractor.

Fieldwork will be conducted by qualified, experienced professionals in accordance with specific procedures identified within this CAP.

7.2 Problem Definition/Background

DWM has initially screened TENORM and the site's radioactivity levels, as previously referenced within this CAP. The approximate area of the bulk AST site is approximately 2,000 square feet, as shown in Figure 2.

Corrective Action Plan – AI # 170634 November 15, 2024 FB Russell Lease, Stanton, KY LFI Project No. 244-24

7.3 Project/Task Description and Schedule

The Nuclear Regulatory Commission (NRC) is not authorized to regulate TENORM as defined in this study because such materials exclude source, special nuclear, and byproduct materials as defined in the Atomic Energy Act, and the Nuclear Regulatory Commission's licensing authority is derived entirely from the act. However, the NRC has issued regulations and guidance for licensed radioactive materials that are potentially relevant to the regulation of TENORM. For unrestricted release of sites containing radium-226, radium-228, or thorium-232, the Health

Physics Society (HPS) recommends a soil concentration limit of 0.2 Bq/g (5 pCi/g) above the normal concentration for the region to prevent excessive radon-222 or radon-220 concentrations in indoor air. It further recommends that the concentration be averaged over an area of 25-100 m2 and a soil depth of 1 meter. A screening level for the same nuclides of 0.04 Bq/g (1 pCi/g) above the normal concentration for the region, averaged over the same area and depth, is also recommended. The objective of the TENORM remedial activities to which this CAP pertains will be to reduce exposure to TENORM “As low as reasonably achievable" (ALARA) is a guiding principle for radiation safety that means to avoid exposure to radiation that doesn't provide a direct benefit. ALARA is a regulatory requirement for all radiation safety programs.

To that end, remediation of the designated affected area of the site will involve the solidification of sludge with Portland cement, excavation of impacted soils on 6-inch lifts and miscellaneous piping, and removal of associated steel ASTs as shown on Figure 2, based on previous assessment results.

Data Quality Objective: Post-remediation confirmation-effectiveness data generated for regulatory review will be of adequate technical quality to compare the results to EPA standards, as appropriate, in order to support property redevelopment/re-use decisions as designated by the

KDEP.

Site Remediation

LFI assumes that applicable equipment will be supplied and operated by the selected remedial contractor that is needed to access the site, extract and stabilize the sludge, and containerize the

Corrective Action Plan – AI # 170634 November 15, 2024 FB Russell Lease, Stanton, KY LFI Project No. 244-24 various waste materials. The stabilization of the sludge is anticipated to require a 10-15% mixture of Portland cement to sludge.

LFI assumes that site work will require heavy equipment, trucks, and trailers to remediate the site and remove the ASTs and associated waste materials. The area outside the potential disturbance limits should be protected from potential releases of sludges and/or liquids and erosion control to prevent the migration of sediments off-site.

Fieldwork involving site remediation will begin once the contract is awarded and at the direction of the KDEP. LFI assumes that remediation (site clearance, solidification, excavation, tank cleaning, and site restoration) field work will require several weeks to complete as determined by the selected remedial contractor.

7.4 Special Training Requirements/Certification

The minimum training requirements for personnel conducting project activities are provided in the following sections. Training records and certificates are kept in personnel files located at the respective company headquarters of the project personnel. LFI’s Project Manager has a current

Kentucky Professional Geologist (PG) and Professional Engineer (PE) registration as previously referenced.

Hazardous Waste Operations and Emergency Response (HAZWOPER):

LFI’s Project Manager will confirm that all on-site project personnel have current certificates of training for the 40-hour Occupational Safety and Health Administration (OSHA) HAZWOPER

Training Class with annual 8-hour refresher courses. All personnel mobilizing to the site shall carry a Certificate of Training identification card.

Corrective Action Plan – AI # 170634 November 15, 2024 FB Russell Lease, Stanton, KY LFI Project No. 244-24

Field Team Training:

LFI assumes that Field Team Technicians are provided hands-on training in graduated phases of explaining, observing, demonstrating, and performing field sampling techniques and standard operating procedures by experienced field personnel. Additional training in field equipment technologies, quality assurance, ethics, and other skills are provided through in-house instruction, online, and external workshops and courses. Field competency is checked through personnel evaluations with direct input from the field team leaders and project managers.

Certifications:

• The technical documentation and report of the cleanup activities will be reviewed and signed by a professional geologist and/or engineer licensed in the Commonwealth of Kentucky.

• The overall design and application plan of the intended cleanup methodology will be developed by a geologist and/or engineer licensed in the Commonwealth of Kentucky.

• OSHA enforces safety regulations on ionizing radiation.

• Other standards may come into play, such as Respiratory Protection (29 CFR 1910.134), PPE, and Hazard Communication (29 CFR 1910.1200).

• The American Petroleum Institute (API) and American National Standards Institute (ANSI) also have recommendations for NORM/TENORM.

• The EPA & CDC are currently working to develop ways to protect the public, workers, and the environment from NORM/TENORM.

7.5 Documents and Records

Documents and records will be prepared and maintained in accordance with this CAP. The following documents and records will apply to this specific site remedial effort:

Site Layout Map Health and Safety Plan Daily Log/Field Book

Site Photo Log

Corrective Action Plan – AI # 170634 November 15, 2024 FB Russell Lease, Stanton, KY LFI Project No. 244-24

7.6 Data Management and Documents

Field documents and records will be prepared and maintained in accordance with the procedures described in this CAP. Field personnel will maintain appropriate paperwork and records to document the remediation work. Field records will contain sufficient information to reconstruct the remediation work. Field records will be kept in a field team member’s possession or in a secure place during the remedial effort. After activities, the field records will become part of the project file and be provided to KDEP upon request.

Data Manipulation and Retention

All field records will be stored in the project file located at the LFI Project Manager’s office.

Electronic records shall be maintained on the company network of computers. The project file will be archived for a period of five (5) years, at which point the records will be destroyed.

7.7 Field Data Evaluation

LFI’s Project Manager will oversee the field activities and discuss any problems identified during the project with the Field Team personnel and the KDEP. Any problems and associated corrective actions will be documented in the field activity report.

LFI’s QA/QC Manager (or his designee independent of the field activities) will be responsible for performing the data validation of the field data. The validation process will include:

• Reviewing the field records;

• Initiating corrective actions.

Corrective Action Plan – AI # 170634 November 15, 2024 FB Russell Lease, Stanton, KY LFI Project No. 244-24

8.0 REFERENCES

Weir, Gordon. 1974. Geologic Map of the Stanton Quadrangle, Powell and Estill Counties, Kentucky. USGS Geologic Quadrangle Map GQ-1182.

https://ipac.ecosphere.fws.gov/endangered-species.

National Research Council (US) Committee on Evaluation of EPA Guidelines for Exposure to

Naturally Occurring Radioactive Materials. Washington (DC). 1999 Evaluation of Guidelines for Exposures to Technologically Enhanced Naturally Occurring Radioactive Materials.

Figures

SITE

LEGEND

SCALE 1:24,000

0.51

01000 1000 2000

1 2

4000 60005000 7000 FEET

1 MILE

1 KILOMETER

CONTOUR INTERVAL 10 FEET

SUPPLEMENTARY CONTOUR INTERVAL 5 FEET

NATIONAL GEODETIC VERTICAL DATUM OF 1929

FIGURE

STANTON, KY.

7.5 MINUTE SERIES

(TOPOGRAPHIC)

UTM GRID AND 2019 MAGNETIC NORTH

DECLINATION AT CENTER OF SHEET

1°44’

109 MILS

6°9’

GN

MN

31 MILS

FB RUSSELL LEASE

37.756046 Lat, -83.822021 Long

STANTON, POWELL COUNTY

KENTUCKY RHB

CONSTRUCTION

ENTRANCE

M O U N T A

IN

S P

RIN

G S R

O A D

PROPOSED

INGRESS/ EGRESS POINT

LAT = 37.7562568°

LONG = 83.8199471°

PROPOSED

WORK LIMITS

LEGEND

MAP AREA

FIGURE

SCALE (ft)

0 60

B

Appendix A

Generic Health and Safety Plan

HEALTH & SAFETY PLAN

FB Russell Lease 37.75611, -83.82194

AI # 170634

Prepared for:

Kentucky Energy and Environment Cabinet Department for Environmental Protection

Division of Waste Management Superfund Branch

300 Sower Boulevard Frankfort, Kentucky 40601

Prepared by:

Linebach Funkhouser, Inc.

Louisville, Kentucky

December 4, 2024

Health & Safety Plan - AI # 170634 LFI Project 244-24 FB Russell Lease – Powell County, KY December 4, 2024 ii

Table of Contents

1.0 INTRODUCTION

1.1 Purpose

1.2 Basis for Design

2.0 RESPONSIBILITIES & ADMINISTRATION

3.0 SUMMARY OF KNOWN SUBSTANCES AT THE SITE

4.0 CONTROL OF POSSIBLE EXPOSURE ROUTES OF UPTAKE

4.1 Inhalation

4.2 Dermal Contact

4.3 Ingestion

5.0 WORKER TRAINING & EDUCATION

6.0 PERSONAL PROTECTIVE EQUIPMENT

7.0 WORK PROCEDURES

8.0 DECONTAMINATION PROCEDURES

9.0 EMERGENCY CONTINGENCIES

10.0 HAZARD COMMUNICATION

Health & Safety Plan LFI Project 244-24 FB Russell Lease, Powell County, KY December 2, 2024

1.0 INTRODUCTION

This Health & Safety Plan (HSP) has been prepared as a condition of the remediation of property located at 37.756046° Latitude, -83.822021° Longitude Powell County, Kentucky, that was historically used for crude oil storage from nearby production wells. The site was identified in

2021 by DWM personnel upon being notified by the Kentucky Division of Oil and Gas concerning releases and possible TENORM (Technologically Enhanced Naturally Occurring Radioactive

Materials) issues on the property. The sludge material is the source of the low-level TENORM, which resulted from the processing and co-processing of the NORM-containing waters and crude oil materials from nearby oil wells.

OSHA's Ionizing Radiation Standard (29 CFR 1910.1096) requires employers to protect workers from exposure to ionizing radiation sources that are not regulated by other federal agencies (e.g., the U.S. Nuclear Regulatory Commission, NRC), such as X-ray equipment, some accelerators (i.e., accelerators that are operated to produce only particle beams and not radioactive materials), incidental accelerator-produced radioactive materials, ion implanters and some NORM.

Technologically Enhanced Naturally Occurring Radioactive Material (TENORM)

Worker exposure to ionizing radiation also occurs when industrial processes or human activity modify or ‘‘technologically enhance'' NORM so that its radioactivity is concentrated (intentionally or unintentionally) to result in a man-made concentration higher than NORM.

Examples of technologically enhanced naturally occurring radioactive material (TENORM) include:

• Oil and gas industry wastes, including hydraulic fracturing or "fracking" wastes, such as flow-back fluids, pipe scale, sludge, and sediments. More information about the oil and gas industry is provided below.

• Fertilizer (phosphate) industry wastes, including phosphogypsum waste byproduct and phosphate slag that may contain radium (Ra-226) or uranium (U-238).

• Commonly used phosphate fertilizer products, which contain naturally-occurring radium

(Ra-226) found in phosphate ores.

https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1096 https://www.epa.gov/radiation/tenorm-oil-and-gas-production-wastes https://www.osha.gov/sites/default/files/publications/OSHA3763.pdf https://www.osha.gov/ionizing-radiation/hazards#oil-gas-industry https://www.osha.gov/ionizing-radiation/hazards#oil-gas-industry https://www.epa.gov/radiation/tenorm-fertilizer-and-fertilizer-production-wastes https://www.epa.gov/radiation/tenorm-consumer-products

Health & Safety Plan LFI Project 244-24 FB Russell Lease, Powell County, KY December 2, 2024

• Coal industry wastes, including fly ash and bottom ash that may contain radium (Ra-226, Ra-228), uranium (U-238), or thorium (Th-232).

• Bauxite and alumina production wastes, including waste (red muds or sands) from alumina

(an intermediate product used to produce aluminum) that can contain uranium (U-238), thorium (Th-232), or radium (Ra-226, Ra-228).

• Water treatment plant wastes, including sludge or sediments and certain resin filtration systems that may contain radium (Ra-226, Ra-228), uranium (U-238), or thorium (Th-232).

• Geothermal energy production, including brine residuals and scale that may contain radium

(Ra-226), uranium (U-238), or thorium (Th-232).

TENORM can result from manufacturing processes, such as the production of materials and equipment from raw materials that contained NORM, and concentrations of NORM materials are sometimes increased as a result of these processes. Fertilizer manufacturing facilities may have potential for worker exposure to TENORM from uranium, thorium, radium (Ra-226), or potassium

(K-40) associated with fertilizer production, along with TENORM concentrations in wastes, filters, products, or metal piping scales. Paint and pigment manufacturing facilities may have the potential for worker exposure to thorium, uranium, or radium (Ra-226) in wastes from titanium ores.

Other examples of TENORM in manufacturing or processing facilities arise from increased concentrations of NORM materials in filters and the solid sludge if large quantities of water containing naturally occurring radionuclides (e.g., Ra-226, Ra-228) are used in some manufacturing processes, such as paper and pulp mills, or from water treatment systems used to supply drinking water. Workers who clean or change filters or handle sludge may be exposed to these increased concentrations. Water treatment facilities may have potential for worker exposure to TENORM from radium scale and sludge contamination in wastes and filters. Paper and pulp mills may have potential for worker exposure to TENORM from radium scale and sludge contamination in various areas of such facilities.

In addition, commercial use of materials containing TENORM can result in worker exposure. For example, workers may be exposed to TENORM in phosphate fertilizers. They may also be exposed to TENORM-contaminated piping and metal in scrap metal recycling facilities.

https://www.epa.gov/radiation/tenorm-coal-combustion-residuals https://www.epa.gov/radiation/tenorm-bauxite-and-alumina-production-wastes https://www.epa.gov/radiation/tenorm-drinking-water-treatment-residuals https://www.osha.gov/ionizing-radiation/background#radionuclide

Health & Safety Plan LFI Project 244-24 FB Russell Lease, Powell County, KY December 2, 2024

Oil and Gas Industry

Flow-back operations that are part of hydraulic fracturing in oil and gas operations may be associated with worker exposure to ionizing radiation.

TENORM can be the byproduct or waste product of oil and gas production. Sludge, drilling mud, and pipe scales are examples of materials that often contain elevated levels of NORM, and the radioactive materials may be moved from site to site as equipment and materials are reused.

OSHA's Oil and Gas Extraction Safety and Health Topics page provides more information about potential NORM exposure in oil and gas well drilling and servicing activities.

The following are recommendations regarding training.

TENORM awareness training (1-2 hours) should be included as part of the health and safety training program:

Such a program should be tailored to TENORM activities. Training Recommended for Workers

Training for all workers should address the following topics.

• Fundamentals of Radiation Safety including:

o introduction to NORM and TENORM;

o characteristics of alpha, beta, and gamma radiation;

o units of radiation dose and quantity of radioactivity associated with TENORM; o o hazards of exposure to the different kinds of radiation;

o levels of radiation from TENORM sources of radiation; and o methods of controlling radiation dose through time, distance, and shielding.

Radiation Detection Instruments including:

use, operation, and limitations of radiation survey instruments for alpha, beta, and gamma radiation; survey techniques including ambient and frisking methods;

use of personnel monitoring equipment (film badge, thermoluminescent dosimeter (TLD), and optically stimulated luminescence dosimeter (OSL) and/or personnel air sampler); and surveying and sampling for NORM and TENORM.

https://www.osha.gov/oil-and-gas-extraction

Health & Safety Plan LFI Project 244-24 FB Russell Lease, Powell County, KY December 2, 2024

• Proper Use of Personnel Protective Equipment (PPE) including: different types of PPE;

o donning of PPE;

o removal of PPE;

o decontamination techniques; and o use of respiratory protection equipment, as needed.

• Posting and Labeling TENORM areas.

• Containerization, storage and disposal of TENORM wastes.

• Requirements of pertinent state and federal regulations.

• Topics and discussions of assigned activities during normal and abnormal situations involving exposure to TENORM which can reasonably be expected to occur during work activities.

1.1 Purpose

OSHA Standards

OSHA's Ionizing Radiation standards protect workers in:

• General industry (29 CFR 1910.1096).

• Construction (29 CFR 1926.53).

The construction standard for ionizing radiation (29 CFR 1926.53) incorporates by reference the provisions of the general industry standard (29 CFR 1910.1096), in addition to requiring a competent person to perform activities involving the use of radioactive materials or X-rays (see 29

CFR 1926.53(b)).

This HSP is specifically designed to reduce direct exposure to potentially affected media (soil, sludge, debris, etc.) associated with the bulk storage tanks containing TENORM above 5 pCi/g levels. The HSP describes procedures for protection to site workers who might be in contact with impacted media as part of future work activities (demolition, excavation, grading, trenching, pumping).

This HSP has been developed to ensure the following:

Site personnel are informed of the specific constituents of concern.

https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1096 https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.53 https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.53 https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1096 https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.53#1926.53(b) https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.53#1926.53(b)

Health & Safety Plan LFI Project 244-24 FB Russell Lease, Powell County, KY December 2, 2024

Site personnel are not adversely exposed to the constituents of concern.

Public health and the environment are not adversely impacted by contaminated materials disturbed during excavation activities at the site, should they occur in the future.

1.2 Basis for Design

This HSP was prepared as a component of an overall Corrective Action Plan (CAP) for the commercial property located at 37.756046° Latitude, -83.822021° Longitude, Powell County, Kentucky. The CAP contains a description of past environmental sampling conducted at the property as well as an overview of potential exposure pathways at the site. Based on the CAP, the predominant constituents of concern at the site are radium-226 and/or radium-228 activity concentrations in sludge and soils associated with the bulk oil storage containment.

As discussed above, the CAP work shows that potential exposure would be limited to hunters or property owners directly encountering the sludge and soils at this location. That exposure would be short-term and would not result in a significant health risk. However, as a conservative measure, the provisions of this HSP shall be followed whenever affected sludges or soils are likely to be encountered as a result of activities conducted on the property.

The applicability of this HSP extends only to personnel and construction workers who are at risk of coming in contact with potentially impacted media. The HSP does not extend to those individuals who may periodically visit or work on a daily basis at the site with no contact with the impacted media.

2.0 RESPONSIBILITIES & ADMINISTRATION

Site personnel with a reasonable potential of contacting affected impacted sludge or soils will be required to be briefed on the HSP.

Health & Safety Plan LFI Project 244-24 FB Russell Lease, Powell County, KY December 2, 2024

Contractors and Subcontractors

Contractors and subcontractors will be informed of the health and safety issues associated with sludge and soil during any activities that may disturb the impacted media. Contractors will be provided access to a copy of the HSP. However, contractors and subcontractors conducting on-site work involving the excavation of soil associated with the bulk oil tank farm or removal of sludge and sludge-impacted media will be responsible for providing a health and safety plan for their own employees.

3.0 SUMMARY OF KNOWN SUBSTANCES AT THE SITE

Based on the results of site assessment work, contaminated sludges and soils are the potential exposure pathways most applicable to the site. The constituents listed below are considered the drivers of the health and safety procedures being implemented at the site.

• Radium-226/Radium-228

These constituents are included because they have been detected at the site or are known to be on-site.

Construction worker exposure to radium-226/228 would mainly occur through direct contact with sludges, sludge-impacted media, and soils containing these constituents.

The United States Environmental Protection Agency (USEPA) has set maximum permissible levels of the above-referenced constituents in drinking water as follows:

• Radium-226/Radium-228 5 pCi/g

The International Atomic Energy Agency (IAEA) recommends a limit of 1 millisievert (mSv) or

100 millirem (mrem) from all sources combined.

Health & Safety Plan LFI Project 244-24 FB Russell Lease, Powell County, KY December 2, 2024

Typical construction tasks that may involve contact with affected soil or sludge, if any, (e.g.

subsurface utility installation, excavation, site demolition, installation of building footers) at this site would be generally completed in timeframes measured in days and weeks rather than years.

Based on the assessment results to date and the limited overall timeframes for construction worker exposure, no significant health risks to construction workers from exposure to Radium-226/228 are expected.

The "traditional" analytical method for quantifying radium-226 and/or radium-228 activity concentrations in soils is through the collection and analysis of discrete ex-situ samples via gamma spectroscopy. There are a number of commercially available real-time methods suitable for field deployment at sites contaminated with radium-226 and/or radium-228.

For this Site, the following methods could be utilized:

1. An in situ sodium iodide (NaI) differential counting system calibrated for radium-226

2. An in situ gamma spectroscopy system

4.0 CONTROL OF POSSIBLE EXPOSURE ROUTES OF UPTAKE

The potential exposure routes of uptake for the constituents of concern present in sludge and soils at the site are inhalation, skin absorption, ingestion, and skin and/or eye contact.

4.1 Inhalation

The tasks that exhibit the greatest potential for inhalation of a constituent of concern include those activities that would involve direct and prolonged exposure to affected subsurface soil or sludge in the wooden tanks and in the soils within the secondary containment area. Radiation monitoring will be conducted during site activities to ensure that OSHA and USEPA standards are not exceeded.

Health & Safety Plan LFI Project 244-24 FB Russell Lease, Powell County, KY December 2, 2024

4.2 Dermal Contact

Physical contact with sludge and soils containing constituents of concern is likely. Appropriate personal protection equipment (PPE) is presented in Section 6.0. At a minimum, work gloves should be worn during any subsurface activities and workers should wash their hands prior to any breaks, before leaving the site, or anytime when workers will be removing gloves for a sustained period of time.

4.3 Ingestion

Chemical exposure through ingestion is a nominal avenue of exposure. Ingestion of matrices containing potentially harmful substances will be controlled through the use of PPE, good hygiene, and enforcement of work area prohibitions outlined in Section 7.0

5.0 WORKER TRAINING & EDUCATION

Prior to commencing any activities that require penetration into the soil or disturbing the sludge in the wooden tanks, a brief Health and Safety/Site Meeting (i.e., tailgate safety meeting) will be presented. The meeting will be targeted at all personnel who will be or are expected to be involved with removing soil and disturbing and solidifying the sludge and wooden tanks. The meeting will stress the importance of each attendee understanding the basic principles of personal protection and safety and being able to perform their assigned job tasks in a safe and environmentally responsible manner.

6.0 PERSONAL PROTECTIVE EQUIPMENT

Basic PPE to be worn when construction activities are likely to disturb potentially affected soil and sludge will consist of Level C consisting of a minimum of hard hats and safety glasses (when appropriate), safety boots/shoes, Tyvek coveralls, respirator with a P-100 or High-Efficiency

Particulate Air (HEPA) filter, and chemical resistant gloves. Only site personnel with a reasonable potential of contacting affected soil and sludge will be required to use PPE. The level of required

PPE may be upgraded or downgraded based on changing site conditions.

Health & Safety Plan LFI Project 244-24 FB Russell Lease, Powell County, KY December 2, 2024

7.0 WORK PROCEDURES

Personnel working on-site also carry certain responsibilities for their own health and safety and are required to observe the following safe work practices:

Become familiar with this HSP.

Use the “buddy system” to the extent practicable.

Maintain safety equipment in good condition and proper working order.

Refrain from activities on-site that would create additional hazards (i.e. smoking, eating, etc. in restricted areas and leaning against dirty or contaminated surfaces).

8.0 DECONTAMINATION PROCEDURES

Potentially contaminated equipment will be decontaminated prior to leaving the site. Material generated by decontamination procedures will be stored in a designated area on-site until disposal arrangements are made. The type of decontamination solution to be used is dependent on the types of chemical hazards. The decontamination solution for this site will be a non-phosphate detergent such as Liquinox, followed by a potable water rinse.

9.0 EMERGENCY CONTINGENCIES

A Site emergency would include an accident involving Site personnel and/or equipment or physical injury to Site personnel. The following numbers may be used in the event of a Site emergency:

Type of Emergency/Need Responder/Agency Contact Number

General Emergency Services 911

Injury Clark Regional Medical Center 859-745-3500 Travel Route See Attached Map

Non-Emergency Fire Stanton Fire Dept. 606-663-2211

Contamination Reporting KDEP – Superfund Branch 502-564-6716

Reportable Spill/Release National Response Center 800-424-8802

Health & Safety Plan LFI Project 244-24 FB Russell Lease, Powell County, KY December 2, 2024

10.0 HAZARD COMMUNICATION

Health information pertaining to the constituents of concern at the Site is attached.

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EPA Facts about Radium

What is radium?

Radium is a naturally occurring radioactive metal that exists as one of several isotopes. It is formed when uranium and thorium decay in the environment. In the natural environment, radium is found at low levels in soil, water, rocks, coal, plants, and food.

What are the uses of Radium?

In the early 1900s, radium was wrongly used to treat rheumatism and mental disorders and as a general tonic. Radium was also used to make luminous paints for watch dials, clocks, glow in the dark buttons, and military instruments. The use of radium for these purposes was discontinued because of the health hazards from these types of exposures. Radium has also been widely used in radiation treatment of cancer, but this use has largely been replaced by other radioactive materials or methods. Radium-226 has also been used in medical equipment, gauges, and calibrators, and in lightning rods.

Alpha emitters such as radium and…