Mr. Kurt Kollar Arcadis U.S., Inc.

On-Scene Coordinator 111-D Sanders Lane

Office of Emergency Response Bluefield
Ohio Environmental Protection Agency Virginia 24605
Phone: 276 322 3879
Fax: 276 322 3946
www.arcadis.com
Remedial Action Work Plan
Date: February 10, 2023
Subject: Norfolk Southern East Palestine, Ohio Derailment Site
Preliminary Remedial Action Work Plan

Dear Mr. Kollar:

On behalf of Norfolk Southern Railway Company (NSRC), Arcadis U.S., Inc. (Arcadis) prepared this Preliminary
Remedial Action Work Plan (Plan) for the February 3, 2023 NSRC derailment site located in East Palestine, Ohio
(the Site, Figure 1). This Plan discusses the emergency response characterization and remediation activities
conducted to date and describes the proposed activities to further characterize and remediate the Site to the
extent that those activities are reasonably foreseeable. As additional data are collected and the understanding of
the site evolves, this plan is expected to be revised and expanded.

Site Background
On February 3, 2023, a derailment occurred near the North Pleasant Drive crossing in East Palestine,
Columbiana County, Ohio. The derailment involved rail cars and tank cars that contained hazardous materials
(i.e., vinyl chloride, butyl acrylate, ethylene glycol, monobutyl ether, ethylhexyl acrylate, isobutylene) and non-
hazardous materials. There were resulting releases affected stormwater infrastructure and surface water,
including Sulphur Run and Leslie Run.

NSRC immediately mobilized response personnel to the incident. Response crews continue operations to stop,
contain, and recover the releases. On February 6, 2023, the vent and burn method was used to address hazards
posed by the five unstable vinyl chloride cars in conjunction with a mandatory evacuation. On February 8, 2023,
the evacuation order was lifted and rail operations resumed.

Completed Work
Emergency response activities were conducted immediately following the derailment and are currently ongoing.
Response activities have included:

 Controlled venting and burning/flaring of vinyl chloride

 Transfer of liquids contained in equipment and cars and collection of these liquids for disposal
 Collection of pooled liquids from ground surface via vacuum truck
 Rerouting of surface water flow through Sulphur Run to bypass the derailment location
 Construction of underflow dams along surface water bodies to control and collect floating separate-phase
liquids

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 Construction of an interceptor trench to collect separate-phase liquids before reaching Sulphur Run
 Aeration of surface water bodies to promote volatilization and biodegradation of released constituents
 Surface water sampling
 Air quality monitoring
 Soil sampling
 Waste characterization sampling
 Residential water well surveys and sampling
While most of these activities are outside the scope of this work plan, specific activities and results related to the
overall remedial effort are discussed below in more detail.

Surface Water Sampling and Treatment

During initial response activities, CTEH identified multiple surface water sampling points including sampling points
on Sulphur Run, Leslie, Run, North Fork Little Beaver Creek, Little Beaver Creek and the Ohio River. This
network includes up-gradient or background sampling locations as well. Sampling activities have continued on a
daily basis concurrently with other response work, with locations being adjusted based on access constraints,
visual observations, and installation of mitigation structures. The results of this sampling have been presented
under separate cover and are not discussed in detail in this work plan.
Collection of samples from storm sewers and surficial pooled liquids has also been conducted to support waste
characterization and evaluate the need for short-term remedial actions (e.g., vacuuming or cleaning of storm
sewers). Underflow dam structures were constructed on surface water bodies at locations shown on Figure 2.
Aeration of surface water bodies has also been completed using mobile air compressors at three aeration stations
and approximately 20 sparge bars. A mobile granular activated carbon (GAC) unit is currently treating surface
water pumped from Sulphur Run near the North Pleasant Drive Crossing west of the derailment site. The treated
water is returned to Sulphur Run near the point of withdrawal.

Liquid Recovery Activities

Liquid recovery has been conducted since the onset of initial response activities and has included vacuum truck
recovery of pooled liquids from the ground surface, containment and removal of separate-phase liquids from
surface water, and collection of separate-phase liquids in sumps and interceptor trenches.
Approximately 180,000 gallons of separate-phase liquids and water are stored in nine fractionation (frac) tanks
pending characterization and offsite transportation and disposal. Two 20-cubic-yard roll-off containers of butyl
acrylate and petroleum impacted absorbents are also staged on-site pending characterization and offsite
transportation and disposal. Recovery operations are ongoing, and tracking of waste volumes will continue.

Proposed Additional Work

The following site characterization and remedial activities are proposed to further address impacts in site media.
The exact scope and timeline which activities will be conducted is uncertain and will be dependent upon receipt
and interpretation of further characterization data, access to properties, and other constraints.

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Soil Sampling
Soil sampling will be completed per the Preliminary Soil Sampling Plan submitted to the Ohio EPA on February
10, 2023. In Area 1, the area proximal to the five vinyl chloride cars that were on fire, three transects of surface
soil samples at 25-foot spacing will be collected. An additional three transects of surface soil samples and
subsurface soil samples at 50-foot spacing will be collected in Area 2, the area between the western extent of
Area 1 and the North Pleasant Drive crossing.
Soil sampling efforts will concurrently support site characterization and waste management/waste determinations,
and the results are expected to provide additional guidance and specificity to future remedial actions.

Characterization of Groundwater Impacts

Groundwater monitoring wells will be installed as practicable within and downgradient of source areas to evaluate
the nature and extent of groundwater impacts associated with the derailment.
While the number and spatial distribution of monitoring wells needed is not yet finalized, an approximate well
network can be envisioned including the following elements:

 Wells extending roughly along the northern and southern boundaries of the NSRC right of way.
 Wells downgradient from the release location, in the direction of groundwater flow, and between the
release location and overburden water wells or sensitive receptors.
 A small number (e.g. one to three) of hydrogeologically upgradient wells to support evaluation of
groundwater flow direction and hydraulic gradient across the site.

Wells located between the two active tracks will be avoided wherever possible. Collection of data from these
locations involves substantial additional risk at little additional value relative to wells outside of the immediate
track footprint.
Wells will also be placed to assess potential migration pathways to surface water, supporting (1) measurement of
groundwater elevations relative to surface water bodies and (2) measurement of COC concentrations in
groundwater near surface water bodies.
Following well installation, a periodic groundwater sampling program specifying monitoring locations, constituents,
and frequency, will be developed and submitted for review.

Remedial Action and Objectives

Although the precise nature and extent of impacts requiring remediation is not fully known, the overall objectives
of future remedial actions can be defined now. These objectives include:

 Removal of readily available separate-phase liquid for purposes of overall COC mass reduction
 Mitigation of ongoing expansion or migration of COC impacts to the extent practicable
 Protection of ecological or human health receptors in Sulphur Run and downgradient surface water
bodies
 Protection of human health via prevention of exposure to impacted soil posing a direct contact risk,
impacted drinking water, or impacted soil vapor.
 Removal of readily addressable impacts to storm sewers and similar structures

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These objectives may be achieved through a combination of active engineered efforts (e.g., soil excavation or in-
situ treatment), engineering, institutional, and administrative controls, and natural systems (e.g., monitored natural
attenuation).

Remedial Technologies and Implementation

The anticipated remedy components are described in the table below, and further discussed in the following text.
The details of implementation will become better defined, and likely change over time, as additional data are
collected.
Table 1. Remedial Technologies and Implementation

Conceptual Description of
Technology Category Current Implementation Plan
Implementation

Shallow soil will be removed

where feasible to reduce
direct contact risk and Details of soil excavation will be developed after or
Soil Excavation
remove sources for concurrent with soil sampling.
dissolved-phase or vapor-
phase impacts

Vacuum truck removal from interceptor trenches

and sumps will continue. Sumps and/or extraction
wells will be added at locations of flowable
separate-phase liquid observed during soil
boring/monitoring well installation.
Readily removable liquid
(including butyl acrylate, If separate-phase liquid is observed discharging
Separate-phase Liquid lubricating oil, and similar from a bank to a surface water body via a seep or
Collection substances) will be collected similar feature, a collection trench or sump will
via vac trucks for offsite also be installed adjacent to that feature to allow
disposal for recovery.
Vacuum truck operations will continue daily in
consultation with Ohio EPA, with reductions in
frequency at some or all points being based on
concurrence of all parties.

Existing underflow dams/booms and aeration

stations will be maintained in the short term. Three
Affected surface water will be aeration stations and 20 diffuser/aerator bars are
Surface Water
treated to remove or reduce currently operating. Surface water immediately
Treatment
COC concentrations. downgradient of the release in Sulphur Run is also
being treated using activated carbon to remove
organic contaminants.

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Options to reduce emulsification are currently

being reviewed. Treatment technologies will be
reviewed and adjusted as more data on dissolved
COCs is available.
Surface water treatment operations will continue,
with proposed changes or decreases in operations
being communicated to Ohio EPA.

Dissolved-phase Details of groundwater treatment will be resolved

groundwater concentrations after further characterization of groundwater
will be reduced to prevent conditions (including sampling of water wells,
Groundwater Treatment
migration/expansion of installation and sampling of monitoring wells, and
impacts and prevent impacts assessment of groundwater-surface water
to drinking water receptors. interaction.

Soil Excavation
Where feasible, shallow soil will be removed from areas in and immediately surrounding the release area. This
effort will be guided by results of upcoming soil sampling, as discussed in the Preliminary Soil Sampling Work
Plan currently under Ohio EPA review. Soil removal will focus on heavily impacted material above the water
table, likely in the top few feet of the vadose zone.

Separate-phase Liquid Collection

An existing interceptor trench has been installed near the North Pleasant Avenue crossing, as shown on Figure
3, and has been used as part of daily vacuum truck operations during initial response. Vacuum collection of
separate-phase liquids in this trench and sump will continue, with the goal of preventing westward movement of
separate-phase liquids from the western portion of the derailment site. Vacuum trucks have also been used, and
will continue to be used, to remove separate phase liquids from ditches and low points around the release area as
site restoration is ongoing.
In the event that flowable separate-phase liquids are observed during future soil boring completion or monitoring
well installation, vacuum truck extraction and removal may be incorporated at those locations as well. This may
be done through either installation of a separate recovery trench or through conversion of a monitoring well to a
vacuum extraction/recovery point, depending on location and surrounding context.

Surface Water Treatment

Three air-compressor-driven aeration stations are currently set up within surface water of Sulphur Run and Leslie
Run, as shown in Figure 2. At the west end of the site, near North Pleasant Drive, surface water is also currently
being collected via pumps and treated through activated carbon prior to discharge back to the point of withdrawal.
Aeration is generally expected to be effective as a way to promote volatilization and dissipation of butyl acrylate
and vinyl chloride. Some field observations have indicated that emulsification of oils or separate-phase liquids
may occur as a result of aeration, complicating containment; this is currently being evaluated, and aeration with a

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less aggressive airflow or smaller bubble size may be helpful in reducing this effect. Potential changes will be
discussed with Ohio EPA as part of ongoing site management.

Groundwater Treatment
If data indicate that a dissolved-phase plume exists and warrants active treatment, in situ treatment technologies
will be reviewed and a groundwater remedial design will be completed.
Natural attenuation is also expected to be an important component of groundwater treatment and long-term site
management, and natural attenuation monitoring (including baseline or early-time measurements for later
comparison) will be incorporated into future groundwater monitoring plans.

Schedule
The scope and schedule for the work described above is heavily dependent on the results of ongoing site
restoration and characterization; however, NSRC is committed to maintaining the rapid pace of response activities
and proceeding with remediation. It is anticipated that soil sampling, which will guide future soil removal activities,
will begin in the next several days, and groundwater characterization will begin either concurrent with or following
soil removal.
A key schedule constraint for groundwater characterization is the fact that a permanent on-site well network
cannot feasibly be established while site restoration and large-scale soil removal are ongoing, because wells
would be destroyed by heavy equipment. Approaches to accelerate groundwater characterization, such as the
use of grab groundwater sampling or temporary wells at locations planned for later monitoring well installation, are
currently under discussion and may be used where appropriate in concurrence with Ohio EPA.
Surface water treatment and free-phase liquid treatment are currently ongoing, and as noted above, will continue
on a daily or continuous basis until modified by future agreement with Ohio EPA.

Closing
Arcadis appreciates the opportunity to provide this work plan and looks forward to collaborating with Ohio EPA on
future management of the site. If you have any questions, please do not hesitate to contact the undersigned.

Sincerely,
Arcadis U.S., Inc.

Andy Pennington Jason Artrip

Environmental Scientist Certified Project Manager

CC. Dan Hunt – NSRC

Matt Gernand – NSRC

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Enclosures:

Tables

Figures
1 - Site Location Map
2 - Site Vicinity and Surface Water Remedial Action Locations
3 – Site Layout and Features

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 Lawrence County
Pennsylvania

UNITY

EAST
PALESTINE

GF

Aeration Pump Columbiana

County
1 MILE
Ohio

Beaver County
Pennsylvania

MIDDLETON

Legend 0 800 1,600

Feet NORFOLK SOUTHERN

Freshwater Emergent Wetland FEBRUARY 2023 DERAILMENT
Incident Location EAST PALESTINE, OHIO
GF

Freshwater Forested/Shrub Wetland

1 Mile Radius from Incident Location Freshwater Pond; Lake; Other; Riverine

County Boundary NHD Flowline SITE LOCATION

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Service Layer Credits: Copyright:© 2013 National Geographic Society, i-cubed
 I
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Legend
NORFOLK SOUTHERN
FEBRUARY 2023 DERAILMENT
Incident Location Freshwater Emergent Wetland 1 Mile Radius from Incident Location
EAST PALESTINE, OHIO
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Service Layer Credits: Source: Esri, Maxar, Earthstar Geographics, IGN, and the GIS User Community
 I

East End N Side Staging Area

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Legend
NORFOLK SOUTHERN
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HEPACO vacuuming stream EAST PALESTINE, OHIO
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FIGURE

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Service Layer Credits: Source: Esri, Maxar, Earthstar Geographics, IGN, and the GIS User Community