industrial waste control health and safety plan

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003523

003524

TABLE OF COHT£MTS

(Continued)

PAGE3.2 REGULATED AREAS 3,4

3.2.1 Delineated 2ones 3-.43.2.2 Access 3,4

3.2.3 Posting/Barricades 3-53.2.4 Labeling 3^53.2.5 Site Drilling 3,5

3.3 GENERAL WORK PRACTICES 3-5

3.4 PERSONAL AND AMBIENT AIR MONITORING 3-83.5 HEAT STRESS 3,9

3.6 COLD STRESS 3.10

3.7 OCCUPATIONAL NOISE 3.H3.8 HEAVY EQUIPMENT OPERATION AND HEAVY MATERIALS

HANDLING SAFETY 3_H3.9 CONFINED SPACE ENTRY 3.123.10 HOT WORK 3_^

3 . 1 1 DRUM HANDLING AND SAMPLING 3.12

3 .12 TRENCHING 3.134.0 EMERGENCY PROCEDURES 4,1

4 .1 GENERAL 4.1

4.2 RESPONSES TO SPECIFIC SITUATIONS 4-24 .2 .1 Worker Injure 4,2

4.2.2 Fires 4.24.2 .3 Spills 4,3

4.2.4 Security 4-3

4.2.5 Emergency Horns/Coinnunications 4-34.3 NOTIFICATION 4-3

4.3 .1 Checklist 4-34.3.2 Procedures 4-34JL3 Documentation 4-34.3.4 Evacuation Plan -4-4

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TABLE OF CONTENTS(Continued)

5.0 . DATA COLLECTION/ONSITE COMPLIANCE5.1 DATA COLLECTION

5.2 SUBCONTRACTOR COMPLIANCE

5.3 STANDARD SAFETY PROCEDURES FOR SUBCONTRACTORS5.4 HEALTH AND SAFETY PLAN COMPLIANCE/OSHA

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LIST OF ATTACHMENTS

ATTACHMENT NUMBER TITLE

A-lA-2A-3A-4A-5A-6

Tailgate Safety MeetingEmergency Phone Number ListSupervisors Employee Injury ReportVehicle Accident ReportGeneral Liability, Damage and Loss ReportOSHA Job Safety and Health Protection Poster

003527

INTERNATIONAL TECHNOLOGY CORPORAL

HEALTH AND SAFETY PLANINDUSTRIAL WASTE CONTROL SITE

FORT SMITH. ARKANSAS

This occupational health and safety plan contains the requirements forprotection of onsite personnel and the general public during the supplementalfield investigation at the Industrial Waste Control (IWC) site located in FortSmith, Arkansas. Onsite activities w'll involve soil borings with soil sam-pling and analysis; well construction, sampling and pump testing; and trench-ing with waste sampling and possible drum excavation and sampling.

The protection of workers and environmental safety and health are majorconcerns during project design and cannot be compromised. The objective ofthis health and safety plan is to assure that safe working conditions exist atthe site. The safety organization and procedures have been established basedon an analysis of potential ha2ards and personnel protection measures havebeen selected in response to these risks.

Al l work wil l be performed iii accordance with applicable federal, state,local and IT Corporation regulations and recommendations; the U. S. Departmentof Labor, Occupational Safety and Health Administration (OaHA) requirements of29 CFR 1910, Arkansas Department of Pollution Control and Ecology regulations(ADPCE), the United States Environmental Protection Agency (USEPA) require-ments, and thv° International Technology Corporation (IT) Safety and Healthpolicies and procedures manual (9000 Series).

Plans and procedures for onsite health and safety will be presented asfollows:

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INTERNATIONAL TECHNOLOGY CORPORATION

- Assignment of Responsibilities (Section 2 . 1 )- Discussion (Section 2.2}- Procedure (Section 2 . 3 )- Employee Training and Information (Section 2.4)- Employee Oecontamination (Section 2.5)- Trench Excavation (Section 2 . 6 )

- Personnel Protective Equipment and Procedures (Section3.0)- Respiratory Protection and Protective Clothing(Section 3 . 1 )- Rc-gulated Areas (Section 3 . 2 )- General Work Practices (Section 3 . 3 )- Personnel and Ambient Air Monitoring (Section 3 . 4 )- Heat Stress (Section 3 . 5 )- Cold Stress (Section 3 . 6 )- Occupational Noise (Section 3 . 7 )- Heavy Equipment Operation and Heavy

Materials Handling Safety (Section 3 . 8 )- Confined Space Entry (Section 3 . 9 )- Hot Work (Section 3.10)Emergency Procedures (Section 4.0)- General (Section 4 . 1 )- Responses to Specific Situations (Section 4.2)- Notification (Section 4 . 3 )Data Collection/Onsite Compliance/Future Safety Plans(Section 5 . 0 )- Oata Collection (Section 5 . 1 )- Subcontractor Compliance (Section 5 . 2 )- Standard Safety Procedures for Subcontractors(Section 5 . 3 )- Health and Safety Plan Compliance (Section 5.4 )

003529

INTERNATIONAL TECHNOLOGY CORPORATE

2-0 SCOPE

^•1 ASSIGNMENT OF RESPONSIBILITIES2.1.1 General

• A 1 1 operations which excavate, drill, trench, handle, sample, dispose, orotherwise have an exposure to site specific contaminated materials are subjectto this safety and health plan. ,

AFi personnel wil l be responsible for continuous adherence to the safetyprocedures during the performance of the work. In no case may work be per-formed in a manner that conflicts with the intent of. or the inherent safetyand environmental cautions expressed in, these procedures. After due warn-ings, personnel violating safety procedures wil l be dismissed from the siteand potentially terminated. All field personnel should be properly trained 1nheaHh and safety regulations associated with handling hazardous materials.AP subcontractors will be trained as necessary as per the specifications set,-\Jrth by the Health and Safety Coordinator.

The requirements listed may change as work progresses due to changingco.iditions, but none will be made without prior approval by the Health andSurety Coordinate;.

AVOIDING ADVERSE HEALTH EFFECTS AN-) INJURIES TO THE SITE WORKERS ISTOTALLY DEPENDENT ON THE CONTRIBUTION OF ALL PROJECT PARTICIPANTS. THE PERSONMOST RESPONSIBLE FOR AN INDIVIDUAL'S HEALTH AND SAFETY IS THE EMPLOYEE HIM-SELF.

2 . 1 . 2 Hea_l.th and safety SupervisorThe Health and Safety Supervisor, wil l be responsible for providing

technical coordination of the health and safety program. The health andsafety program includes Information on medical programs, training require-ments, hazard assessment, personnel air monitoring, personnel protectiveequipment, re$p1ratory protection, field implementation, audits, etc. Liaisonwith officers, or representatives of EPA and ADPCE on matters relating tohealth and safety will be handled by the Health and Safety Coordinator or anappointed hsftUh and safety coordinator/technician. The Health and Safety

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Coordinator also provides the on-scene Supervisor with details concerning thecomplete, work specific, safety and health program. The Health and SafetyCoordinator wi l l be on site of the start of th.° job and wi l l audit criticalfunctions through completion.

2.1.3 $ a f ety Je Ch n i c i ansThe onsite Safety Technicians may be assigned to monitor the daily

activit ies to assure that all health and safety procedures/policies are beingfol loweo.

2 .1 .4 Project ,ManagerThe Project Manager is ultimately responsible for ensuring that a l

project participants abide by the requirements set forth in this plan. TheHealth and Safety Coordinator will report directly to the Project Manager.

2 . 1 . 5 Onsite Supervisor fHydrogeoloqist, Civi.l. engineer, ,etc)_.The Onsite Supervisor is responsible for field implementation of the

health and safety program. This Includes communicating the specific require-ments to all personnel, audits, and consultation with the Health and SafetyCoordinator regarding appropriate changes in health and safety requirements.

2 . 1 . 6 F i e1d _£ngineers/ScientistsField Engineers/Scientists r'.re directly responsible for the technicians

wnom they are supervising, but (i.ust also be aware of the general site safe-ty. All Field Engineers/Scientists are responsible for understanding andcomplying with all si te health, safety and operational requirements.

2.2 DISCUSSIONThe EWC site is an eight acre industrial waste landfill established in an

abandoned coal strip mine. Industrial liquids, solids, sludges and drummedwastes froia a variety of industries were deposited In surface impoundments andburied in the landfill. Bulk liquids were deposited In evaporation ponds.wastes sn<i drums (unknown number) were deposited In abandoned strip mine. 'site 1 $ unvegetaled In two central locations where two evaporation ponds werelocated. Remnarts of a surface Impoundment benn used in the landfill ingoperations exist "in the central section of the site and a red stained barren

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area occurs in the southwest corner of the site. The l a n d f i l l has been inac-tive since 1978.

Industrial solvents, liquids, and solids were accepted for disposal.Inorganic compounds found onsite include arsenic, cadmium, chromium, lead,nickel, zinc and copper. Organic compounds include hatogenated solvents, non-halogenated solvents^ polynuclear aromatics (PAH's) , phth.lates, nitrosamines,pentachlorophenol, methlyene chloride, trichloroethene and other chlorinatedsthenes. The site represents both dermal and inhalation hazardous. Althoughtne site is covered and mostly vegetated, unvegetated portions remain whichcould present a dust inhalation hazard. Seeps or standing water may be con-taminated and should be avoided.

ResuHs of the RI/PS investigation indicate high levels of ethyl benzene*to'luene and trichloroethene in IMC-12, 13, and 14. Carcinogens have beendetected in onsite surface and core soil samples, primarily at 1WC-33(PAHS). AH samples have low heavy metal concentrations.

Some of the onsite contaminants have high vapor pressures and may presenta respiratory hazard. During field activities respiratory protection will beavailable as a precautionary measure if action levels are detected. Alsocontaminated partkulate distribution may occur when certain site activitiesdisturb the soil surface Different atmospheric conditions (pressure, humid-ity* wind, temperature, precipitation) can also have an effect on the concen-trations of the contaminants emitted.

Pathways of exposure exist both onsite and offsite. the degree of '.vhichwill vary widely. The following potential pathways should be avoided:

" Ingestion of contaminated groundwater

• Dermal contact with contaminated groundwater

• Ingestion of contaminated sediments and surface soils(accidental/poor hygiene)

• Dermaf contact wi th contaminated sediments and surfacesoils „ ;

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* Inhala t ion and ingestion of contaminated particles andvapors

• uermal contact w i t h contaminated equipment and struc-tures.

Skin and eye contact should also be avoided by all onsite personnel.

Overall t h i s direct ive prescribes the work place practices and controlsrequired to prevent employee exposure to site contaminants during hand l ing ,processing, cr disposal operations. For enviromientaJ considerations, refer*ence should be made to appl icable EPA regula*. -:ns, state rules and regula-t ions , and pertinent ITC procedures.

2.3 PROCEDURJ2.3.1 Hazard Ana lys i s

An eva lua t ion of potential hazards has been conducted u t i l i z i n g informa-tion suppl ied by EPA to ensure that site ac t iv i t ies , personnel protection, andemergency response are consistent w i t h the levels of contaminated mater ia lsexpected to be encountered.

Other data obtained dur ing the project w i l l be used to update this evalu-a t ion- Oue to the wide variety and number of contaminants , a central f i l e ofMater ia l Safety Data Sheets (MSOS) or other sui table information w i l l bea v a i l a b l e for site contaminants .

If other contaminants are encountered on$1te, a l l personnel w i l l be madef u l l y aware of their hazardous properties and the appropriate procedures wh ichw i n be u t i l i z e d to prevent exposure.

2 .3 .2 Permiss ib le jxpogu.re L i m i t (General )Conventional indust r ia l hygiene monitoring (personnel sampling pumps and

sampl ing media) w i l l be conducted where app l i cab le on employees and In areasto determine the employee's atmospheric exposure to onsite contaminants. An'1NU photoionlmlon meter w i t h a 10.2 eV probe w i l l be u t i l i zed dur ing a11t i e l d activities. A reading must be written down every 30 minutes. Theresul ts of the moni to r ing w in be u t i l i zed primari ly for documentation pur-poses and w i n influence among other th ings the selection of the personnel

003533


protective equipment. Also, monitoring may be conducted 1n adjacent areas toassure that, dusts, vapors, fumes, mists, and participates from the decontmi-nation process are not leaving the work area. Results of Industrial hyg-ieneffionitoring and surveillance shall be compared with the applicable OSHA PELs,ACGIH TLVs, NIOSH recommendations and/or £PA requirements.

The following is a list of potential onsite airborne contanr'iants andtheir respective limits*

AnthraceneBenzeneEthyl BenzeneNaphthalenePhenanthrenePhenolTolueneTnchloroethylene

SSM iL200 ug/m3

10 ppm100 ppm10 ppm,

200 ug/m3

5 ppm200 ppm100 ppm

ACGJHJTy/

200 ug/ni310 ppm

100 ppm10 ppm ,

200 ug/m3

5 ppm100 ppm50 ppm

Information regarding the toxicity of these substances will be availableensile, v ia MSOS or other pertinent information, and be disseminated at theinitial health and safety site briefing.

2. 3. 3 Engineering Controls

Nhdre feasible, engineering controls shall be the primary means utilizedto maintain contaminant exposures within the limits set forth in Section2.3.2. Oust suppression may be util ized using water to reduce or eliminatedust during onsite operations.

2.3. /I Hed ica1..Su_ryei_n a nee

Current pre-employment and periodic/update screening medical examinationswi l l be continued for those IT and subcontractor personnel working with orthose who may be assigned to work on this project and with the potentialcontaminants onsite. The exam shall consist of the followino:

" Medical and Occupational Health History Questionnaire

• General Physical (attention to skin, liver examina-tion)

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INTERNATIONAL TECHNOLOGY CORPC;<AT:QN

- Audiometry in keeping with OSHA Noise Standard

- Urinalysis (Dipstick and microscopic)

- EK6 for persons older than 45 years of age. or wheremedically indicated

- SMAC 20 (liver function tests)

" Chest X-ray (PA only)

- Complete blood count (C6C)

- Complete blood count with differential L

(" Drug screen

All subcontractor personnel shall have successfully completed a similarexamination to the IT Corporation preplacement physical. The_cogt_for medical <surveillance shdl1_be_ paid by the subcontractor.

2.3.5 Emergency Medical Treatment _and Accjdent^Notification

Should site personnel suffer an injury or illness, the following re-sources w i l l be utilised, as appropriate:

a Initiate the site specific emergency plan.

• Several people onsite shall be qualified to renderfirst-aid and cardiopulmonary resuscitation.

• Fire Department/Rescue Squad (specifycity/county/phone)

• Ambulance Service (company name/phone)

• Sheriff/Police (phone)

• Hospital/Emergency Room (name/address/phone)

These numbers must be listed on the Tailgate Safety Meeting form as wellas posted at the site preferably near each telephone. (Attachment No. 1 andAttachment No. 2). An Inspected and tagged first aid kit and fire extin-guisher will be present onsite during the initial Investigation.

If an injury/illness is the result of a site specific material exposure.provide this Information to the treating physician and the Health and SafetyCoordinator.

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INTERNATIONAL TECHNOLOGY CORPOR/C:CN

Any injury, Illness or accident Involving IT personnel or subcontractorswill require the completion of the appropriate ITC Form 9300.1-1. "Superinten-dent's Employee Injury Report." in accordance with ITC PRO 9300.1 (Attachment3) as soon as possible.

Document on the SEIR any contractor/subcontractor (employed or not em-ployed by IT) injuries (documentation purposes only).

Any injury/illness not limited to a first aid case will require that theIT representative inmediately notify the Health and Safety Coordinator. Thiswi 1 1 allow the coordination of internal resources to assist the treatingphysician in rendering the appropriate care.

Any vehicular accidents or other accidents which result in loss or lia-bility shall be documented using the IT Vehicle Accident Report, (Attachment4) or the General Liability, Damage and Loss Report (Attachment 5).

2 - 4 EMPLOYEE TRAINING AND INFORMATIONAll employees (IT. Contractor. Subcontractor) who are subject to exposure

to onsite contaminants shall have completed some form of or a minimum of sitespecific and safety/health training approved by the IT Health and SafetyDivision. The following is a general list of the topics covered:

• General Site Safety ( s l ips , trips, f a l l s , noise,heat/cold stress)

• Information of employee rights (Worker Right ToKnow)

» The specific nature of the operations which couldresult in exposure to contaminants above the actionlevel

• The purpose, proper selection, fitting, use, andlimitations of respirators and other safety equip-ment/clothing applicable to onsite work

• A description of the medical surveillance program

• Information concerning the adverse health effectsassociated with excessive exposure to onsitecontaminants including potential effects of contami-nants to skin, $y@s. kidneys, liver, etc.

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• Routes of exposure. Including skin penetration/irri-tation, inhalat ion, ingestion

• The engineering controls and safe work practicesassociated with the employee's job assignment

• Methods and procedures u t i l i zed for decontaminationof personnel and equipment.

^ • 4 . 1 Tailgate Safety MeetingsJob site Tailgate Safety Meetings, in accordance with ITC PRO 9540.1

shall be conducted for IT and IT subcontracted personnel at the beginning ofeach shift for each job or whenever new employees arrive at the job site.Information covered shall be safety concerns that may be encountered duringthe day. and emergency procedures and information on the toxicity and poten-tial hazards associated with major chemical contaminants that may be encoun-tered at thfc.' job site. Safety meeting information shall be recorded on aTailgate Safety Meeting form and will be posted in the work area. An exampleof the tailgate meeting form is attached (Attachment A-l).

2.4.? Material Safety Data SheetA complete set of site MSOSs prepared with ITC PRO 9552 for site speci-

f ics shall be available at the job site.

2.5 EMPLOYEE QECOHTAMINATION

2.5 .1 Decontamination FacilitiesOecontamlnation line facilities will be provided for all employees who

work In the area designated as the contamination reduction zone. Employeesworking in this zone will be required to change from street clothing toprotective clothing before entering the zone, and remove the protective cloth-ing and field wash after leaving the zone. Modifications will be made to the"decon" plan as applicable to the particular job site.

2.5.2 Port^e Eye_Wash and ShowerFor emergency purposes, a portable eye wash and shower (or other flowing

potable water) win be provided in the contamination reduction zone In orderfor employeos to wash the affected skin or flush the eyes (at least 15 min-utes) if they come into contact with site contaminants, [f irritation arisescontact a physician immediately.

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2.5.3 Breaks

All breaks must be taken in a shaded, clean area specifically providedfor that purpose. When employees leave the contamination area and enter thecontamination reduction zone they will undergo a modified decontaminationprocedure. Employees will wash their hands and face with soap and water inthe contamination reduction zone and go to an appropriate break area zone.Employees are encouraged to drink plenty of fluids during breaks.

2.6 TRENCH JLXCAVATtON

Trench excavations up to 30 feet deep are planned in order to samplewaste material at the base of the landfill. H personnel will not enter thetrench excavations. However, the slope stability of the excavations will be asignificant, concern given the poor consolidation of landfill material and thepresence of groundwater. All trench excavation work will conform with ITCProcedure 9532.48 and OSHA instruction CPL 2.69 (September 19. 1985).

ReaUime monitoring of any emissions from the trenching operation, asdescribed in Section 2.3.2 of this plan (and using other sampling equipmentdeemed necessary by the Project Health and Safety Officer), will be used toprovide guidance to the project Health and Safety Officer for monitoring thetrenching operations. As described in Section 2.3.2 of the Health anu SafetyPlan. industrial hygiene monitoring and surveillance shall be compared toapplicable OSHA PEL'S. ACGIH TLV 's . NIOSH recommendations, and/or EPArequirements on a regular schedule to assist in evaluating the risksassociated with continued trenching.

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INTERNATIONAL TECHNOLOGY CORPORAT:ON

3.0 PERSONAL PROTECTIVE EQUIPMENT AND PROCEDURES

3.1 R£SPIRATQRY_PRQTECnQN/PROTECTlVE CLOTHING3 . 1 . 1 Respj raJtory Protect jon (General)

• Only properly cleaned, maintained* NIOSH/MSHA ap-proved respirators (half-face, full-face, or RASCALpositive air pressure units) shall be used onsite.

« Selection of respirators, as well as any decisionsregarding upgrading or downgrading of respiratoryprotection win be made by the Health and SafetyCoordinator.

fl Air purifying cartridges shall be replaced at theend of each shift or when loadup or breakthroughoccur.

• Only employees who have had pre-issue qualitativefit tests and semi-annual fit tests thereafter,shall be allowed to work in atmospheres where respi-rators are required.

• If an employee has demonstrated difficulty -inbreathing during the fitting test or during use. heor she shall have a physical examination to deter-mine whether the employee can wear a respiratorwhile performing the required duty.

« No employee shall be assigned to tasks requiring theuse of respirators if* based upon the most recentexamination, a physician determines that the em-ployee will be unable to function normally wearing arespirator or that the safety or health of the em-ployee or other employees will be impaired by use ofa respirator*

•* Contact lenses are not to be worn while using anytype of respiratory protection,

• Air supplied respirators shall be assembled permanufacturer's specifications regarding hose length,couplings, valves, regulators, manifolds, etc.Though not anticipated air line respirators may needto be used onsUe.

• Excessive facial ha1r (e.g. beards) prohibits properface fit and effectiveness of respirators. Personsrequired to wear full face or half face respiratorsmust not have beards, etc. AH personnel wearingfull-face or half-face respirators will be requiredto be clean shaven prior to each day's shift.

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* Regular eyeglasses cannot be worn with full face>-espirator3 (breaks the facepiece seal). Inserts mustbe utilized.

- The respiratory protection utilized onsite will be incompliance with OSHA. 29 CFR 1910.134.

• Where respirators are designated for protection againstcontaminants, the employee shall be permitted to changecanisters or cartridges whenever an increase inbreathing resistance is detected.

• Self contained breathing apparatus (SCBA) will beutilized for emergency procedures and as back up toconfined space entry work.

3 . 1 . 2 Respiratory, Protection (Specific)If the HNU monitor indicates a reading of 5 ppm above background during

the field investigation, half- or full-face respirators with organic vaporcartridges (OA) and dust. mist. funie (DMF) prefilters must be utilized toprotect workers from potential exposure. The field drilling crew may utilizeRASCAL positive airflow respiratory protection units. The use of full facerespirators (1) provides greater protection factors in the event that a "hotspot" of contamination is encountered (sampling drums) and (2) eliminates theneed for additional eye protection (e.g. goggled/face shields) which is oftenconsidered cumbersome when used with half face APRs. Nose Cups along withanti-fog cloths can be utilized to reduce fogging.

Industrial hygiene air monitoring will be conducted as applicable oncewori< begins as well as during certain phases of the project to determinewhether respiratory protection and other protective equipment needs to beupgraded or downgraded respectively. If HNU readings exceed 20 ppm in theworker's breath'ng zone. work shall stop and further evaluation will be madeto determine the exact components of reading. Per IT Respiratory policy. APRsmay be used up until 2X the TLV. Utilizing benzene as the target andcalibration gas for the HNU. a reading of 20 ppm would be twice the TLV. Atthis point IT policy stipulates supplied air for further work.

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3 .1 .3 Protective,Apparel/Respiratory Protection

Employees shall be provided and required to wear the following protectiveequipment. Decisions regarding the upgrading/downgrading of protective cloth-ing wil l be made in conjunction with the Regional Health and Safety Coordi-nator.

3 . 1 . 4 Protective.Clothjnq

The following apparel may be worn during site activities onsite. Protec-tive clothing for this site investigation work shall be as follows for drilloperators on site:

• Disposable polyethylene coated Tyvek coveralls withhoods

* Neoprene outer gloves with inner latex surgicalglobes

• Neoprene boots

• Hara Hat

* Hear ing Protection (as appl icable)

* Goggles shall be worn at all times in the work area(Coni-amination zone). (Contact lenses shall not bepermitted in the contaminated area.)

• Sleeves shall be taped to gloves and cuffs taped toboots.

Protective c l o t h i n g for sampling and sample preparation workers are thefo l lowing :

• Hard Hat

• Disposable Tyvek coveralls without hoods (optional)

• N i t r i t e undergloves

" Latex surgical overgloves

• Neoprene boots

• Safety glasses wi th side shields

• Goggles (Impact/splash) for work in wet or dustyconditions

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003541

• Half - face respirators wi th organic vapor cartridgesand dust, mis t , fume pref i l ters shall be avai lableonsi te*

Other gear appl icable to cold weather work shall include:

• Long Johns (thermal underwear)* Thermal socks* Hard hat l iners

Upgrading or downgrading of selected protective equipment will be thedecision of the hea l th and safety representative based on assessment of ex-posure potential .

3.2 RE6ULATED..AREAS

3.2.1 Delineated,Zones

The site sha l l be d i v i d e d into three delineated zones» as fo l lows:

• Contaminated ^one - This zone includes the actualareas of contamination. This zone has the highestinha la t ion exposure potential and/or presents a highprobabi l i ty of s k i n contact wi th cutaneous or percu-taneous e f fec t ing chemicals ,

" Contamination Reduction Zone - T h i s 2one includesthe areas immediate ly surrounding the ContaminationZone. This zone has the next highest inha la t ionhazard, but does not have a h igh probabi l i ty of sk incontact wi th cutaneous or percutaneous effectingchemicals , and

» Clean Zone - This zone covers a l l area outside ofthe contamination reduction zone. Adverse exposureto chemicals is u n l i k e l y .

3.2.2 Access

Access to contaminated work areas (contaminated and contamination reduc-tion zones) shall be regulated and l imited to authorized persons. A da i lyroster containing the date, the person's name, the person's signature, thetime of entry, and the time of exit shall b2 kept of all persons working Insuch areas. Any visitors to the area titust present proper identification andbe authorized to be onsite. Visitors must comply with all aspects of thehealth and safety plan.

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3-2.3 Posti ng/BarricadesWarning signs shall be posted and hung, as applicable, in readily visible

locations in or near contaminated work areas. Barricades and barricade tapeshall be utilized to prevent access to various work areas.

3.2,4 LabelingAl l bags, containers, drums, etc. containing contaminated materials must

be labeled according to specifications.

3.2 .5 Site DrJUingSite core drilling sha1"l comply with the following rules:

1 . Before drilling or excavation work the existence and location of under-ground pipe, electrical equipment, etc.. must be determined. This shallbe done. if possible, by contacting the appropriate utility company tomark the location of their lines. If the utility company cannot be uti-lized, an appropriate device, such as the cable avoiding tool» shall beused to locate the service line.

No ignition sources are permitted if the ambientflammable vapors exceeds 10 percent of the lowerwhen core drilling. A combustible gas indicatormake this determination.

airborne concentration ofexplosive limit (L£L)shall be available to

3.3

Operations must be susperded and corrective acUon taken if the airborneflammable concentration reaches 40 percent of LEL in the limiedtate area (aone-foot radius) of the point of drilling.

Operations must be suspended and corrective action taken If the flammablevapors exceed 10 percent of the LEL at a distance of greater than two feetfrom the point of drilling.

Combustible gas readings of the general work area sh&ll be made if neces-sary.

GENERAL WQRKiRACTICES

• At least one copy of this procedure shall be availableat each Job work site.

• Contaminated protective equipment, such as respirators,hoses, boots, etc.. shall not be removed from the regu-lated area until H has been cleaned, or properly pack-aged and labeled.

B Legible and understandable precautionary labels shallbe affixed prominently to containers of contafMnatedscrap, waste, debris, and clothing.

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Removal of contaminated soil from protective clothingor equipment by blowing, shaking, or any other meanswhich disperse contaminants into the air is prohibited.

No food or beverages shall be present or consumed inthe regulated area. No tobacco products shall be pres-ent or used and cosmetics shall not be applied, in t(ieregulated area.

Transportation and disposal of contaminated materialsshall comply with alt applicable local, state, andfederal regulations. These Uems will be addressed bythe transporter and disposer.

Contaminated materials shall be stored in tightlyclosed containers in hell ventilated areas.

Containers shall be moved only with the proper equip-ment and shall be secured to prevent dropping or lossof control during transport.

Emergency equipment shall be located outside the stor-age areas in readily accessible locations which willremain minimally contaminated with materials in anemergency.

All trenching, shoring, and excavation work must complywith all federal OSHA rules.

Disposable equipment, such as protective clothing,shall be disposed of in containers labeled in accord-ance with Section 3.2.4.

During the operation, all employees shall be requiredto wash their hands and face before eating, dr-tnking,smoking, or applying cosmetics.

Storage facilities shall be designed to contain spillscompletely within surrounding dikes.

Portable or fixed emergency shower/eyewash stationsshall be located in the regulated area near work acti-vities.

AH personnel shall be required to field wash as aminimum at the end of their shift before leaving thejob site if they are contaminated. Hands and faceshall be washed during breaks.

AH personnel sial! avoid contact with potentiallycontaminated substances. Walking through puddles ormud, kneeling on the ground, or leaning against drumsshould be avoided whenever possible.

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INTERNATIONAL TECHNOLOGY CORPOKA::ON

• Monitoring equipment shall not be placed on potentiallycontaminated surfaces.

• Field personnel must observe each other for signs oftoxic exposure. Indications of adverse effects in-clude, but are not "limited to:

- changes in complexion and skin discoloration- changes in coordination- changes in demeanor- excessive salivation and pupillary response- changes in speech pattern

Field personnel shall be cautioned to inform each otherof non-visual effects of toxic exposure such as:

- headaches- dizziness- nausea- blurred vision" cramps- irritation of eyes, skin. or respiratory tract

a Prompt remedial action shall be taken whenever an Inad-vertent release of a hazardous material occurs.

• Appropriate action to provide secure footing she. 1 1 betaken at a t1 locations where personnel will be working.

• Portable sanitary facilities will be provided.

• Provision must be made for cleaning gross contaminationfrom boots and suits in the Contamination ReductionZone.

• Oecon assistance personnel shall be appropriatelyclothed In the next lower level of protective equipmentequipment to the contamination zoiie workers.

• Whenever solvents, cleaners, or other chemical sub-stances are used for decontanilnation, a properly com-pleted Material Safety Data Sheet for the chemicalsubstance, prepared in accordance with ITC PRO 9552,shall be available at the worksite.

(- Whenever flammable or combustible solvents are used fordecontaminatlon, specific procedures for the control offlammable gases and vapors may be necessary. Whenconcentrations of flaiwiable vapors cannot be controlledby ventilation, this would include, but not Halted to,the fo1lowing:

" Tests shall be made by a qualified person to ensurethat concentrations of flammable vapors 1n the workarea do not exceed 105^ of the lower explosive limit.

003545

- An adequate supply of fire extinguishers with annmmufli rating of 10 B:C. shall be strategicallylocated throughout the work area so as to limit thetravel distance required by any worker to reach theextinguisher to less than 75 linear feet.

• Appropriate action to pcovioe secure footing shall betaken at all locations where personnel win be working.

• A qualif ied person shall take positive steps to ensurethat employees are protected from physical hazardswhich would include, but are not limited to, thefollowing:

- Discharge of steam, high pressure air, water or oil,

- Tools or other objects dropping from overhead,

- Fal ls from scaffolds, stairs, or ladders.

- Tripping over hoses, pipes, tools or equipment,

- Slipping on wet. oily surfaces.

- Insufficient or faulty personal protective equip-ment,

" Insufficient or faulty operations equipment andtools, and

- Noise in excess of acceptable levels*

3.4 PERSONAL AND AMBIENT ALB_MOy[TQRJNGIndustrial hygiene monitoring win be conducted at the beginning of the

job and periodically thereafter to determine the employee's potential ex-posures to onsite contaminants. The results of the monitoring win be used asonsHe documentation and to aid in dictating the selection of the personalprotection equipment. Ambient air monitoring at the surrounding area winalso be conducted. Employee exposure records win be kept consistent withOSHA requirements.

3 o••0

003546

INTERNATIONAL TECHNOLOGY CORPORAHC;';

3.5 HEAT SmSS

Heat stress may be of concern depending upon the ambient temperature.The heat stress of employees onsite win be monitored by the Met Bulb GlobeTemperature Index (WBGT) technique. This method will require the use of aheat stress monitoring device, such as the Midget Heat Stress Monitor (ReuterStokes).

The MBGT shall be compared to the Threshold Limit Values (TLVs) outlinedin the ACGIH TLVs Manual, and a work-rest regimen established, as necessary,accord-ing to the WBGT obtained. Note that 3" to S^C must be subtracted fromthe l^BGT due to the wearing of impermeable protective clothing.

One or more of the following control measures can be used to nelp controlheat stress:

• Provision of adequate liquids to replace lost bodyfluids. Employees must replace water and salt lostfrom sweating. Employees must be encouraged to drinkmore than the amount required to satisfy thirst.Thirst satisfaction 1 s not an accurate indicator ofadequate salt and fluid replacement.

• Replacement fluids can be a OA% salt water solution,commercial mixes such as Gatorade or Quick Kick, or acombination of these and fresh water.

• Establishment of a work regimen that will provide ade-quate "est periods for cooling down. This may requireadditional shifts for workers or earlier/later workschedules.

• Cooling devices such as vortex tubes or cooling vestscan be worn beneath protective garments.

• A l l breaks are to be taken in & shaded rest arpa.

• Employees shall remove impermeable protective garmentsduring rest periods.

• Employees shall not be assigned other tasks du'-ing restperiods.

• A l l employees shall be informed of the importance ofadequate rest. accllmatiratlon and proper diet 1r> theprevention of heat stress.

3-9

003547

Persons working outdoors in temperatures at or belowfreezing may be frostbitten. Extreme cold for a shorttime may cause severe Injury to the surface of thebody. or result In profound generalized cooling, caus-ing death. Areas of the body which have high surface-area-to-volume ratio such as fingers, toes, and ears.are the most susceptible.

Two factors influence the development of a coldinjury: ambient temperature and the velocity of thewind. Mind chill is used to describe the chillingeffect of moving air in combination with tow tempera-ture. For instance, 10°F with a wind of 15 miles perhour (mph) is equivalent in chilling effect to stillair at -18°F.

As a general rule, the greatest incremental increase inwind chill occurs when a wind of 5 mph increases to 10mph. Additionally, water conducts heat 240 timesfaster than air. Thus. the body cools suddenly whenchemical-protective equipment is removed if the cloth-ing underneath is perspiration soaked.

Local injury resulting from cold is included in thegeneric term frostbite. There are several degrees ofdamage. Frostbite of the extremities can be cate-gorized into:

- Frost nip or Initial frostbite: characterized bysuddenly blanching or whitening of skin.

- Superficial frostbite: skin has a waxy or whiteappearance and Is firm to the touch, but tissuebeneath is resilient.

" Deep frostbite: tissues are cold, pale. and solid;extremely serious Injury.

- Systemic hypothermia is caused by exposure to freez-ing or rapidly dropping temperature. Its symptomsare usually exhibited in f ive stages: 1) shivering.2) apathy, listlessness, sleepiness, and sometimesrapid cooling of the body to less than 95°?. 3)unconsciousness, glassy state, slow pulse, and slowrespiratory rate, 4) freezing of the extremities*and finally 5) death.

3-10

003548


• Thermal socks, long cotton or thermal underwear, hardhat liners and other cold weather gear can aid in theprevention of hypothermia^

• Blankets, warm drinks (other than caffeinated coffee)and warm break areas are essential.

• The overall goal is to keep from getting wet. If onedoes get wet, he should dry off and change clothes.

• Cold stress training Is also appropriate for work atthe site.

3.7 OCCUPATIONAL NOISE

Requirements set forth in the OSHA hearing Conservation Amendment (OSHA1910 .95) will be adhered to during work onsite. Both area noise monitoringand personnel noise dosimetry may be conducted by the Industrial Hygienist todetermine the level of noise and the adequate level of protection. Hearingconservation is of major concern due to the extensive use of light, medium,heavy mobile equipment as well as noisy portable equipment to be utilizedonsite. Hearing protection will be provided where sound pressure levelsexceed 8S dB (A weighted scale, slow response). Hearing protection win berequired where sound pressure levels In areas and/or on equipment exceed 90 d8(A weighted scale^ slow response).

3-8 HEAVY EQUIPMENT OPEJ^TION AND HEAVY MATERIALS HANDLING SAFETYThe following information warrants extra attention regarding work around

he&vy equipment (drilling rigs, front end/backhoe loaders, etc.) and heavymaterials.

" Use common sense.

» Hard hats are to be worn at all times onsite. Otherprotective gear as specified In the health and safetyplan is applicable as well.

• Pay attention at all times.

• Maintain visual contact at all times.

• Establish hand signal communication when verbalcommunication 1 s difficult. Determine one person perwork group to ^ive hand signals to equipment operators.

» Be aware of footing at all times.

3-11

003549

• All heavy equipment shall have backup alarms of sometype.

• Only qualified people are to operate heavy equipment.• Use chains hoists, straps and any other equipment tosafety aid in moving heavy materials.• Use proper personal lifting techniques. Use your legs.not your back.• Never walk directly In back, of or to the side of heavy

equipment without the operators' knowledge.• Never use a piece of equipment unless you are familiarwith its operation. This applies to heavy as well aslight equipment ( e . g . chainsaws).• Pipe sections and other materials to be uti1i2ed duringthis project are exttsme1y heavy. Make sure allprecautions have been taken prior to the moving. Letthe equipment, not your body do the moving.• Be sure that no underground or overhead power l i n e s ,sewer lines, gas lines or telephone lines w i l l present

a hazard in the work area.• Get help whenever you're in doubt about a material's

weight. Use the buddy system.• Ensure that air bottles are secured properly to heavymobile equipment.

3.9 CONFPjED SPACE IN TRYNo confined space entries are planned for this field investigation. Any

confined space entries (trenches, holes etc) shall be made in accordance withthe IT Procedure 9531.1.

3.10 HOT, WORKAn hot work shall be conducted in accordance with IT Procedure 9571, A

Hot Work permit will be completed prior to any hot work.

3.11 DRUM HANDLING_ANDJJAMPLIHGThe following job activities have special Health and Safety considera-

tion:

3-12

003550

• Bungs will be opened slowly without excessive pres-sure. Once the bung 1 s loosened, if a pressure leak Isdetected (by sound), step back and wait for the drum tovent* Once the drum has vented, remove the bung andproceed with samples.

• If the bung cannot be removed, the drum shall be segre-gated and opened by means of an automatic drumopener. The employee activating the opener shall bepositioned behind a barrier.

• Drums which are bulged (due to pressure) shall not bemoved (except to segregate) prior to venting by meansof the automatic drum opener.

Monitorino will be conducted prior to and during sampling of drums. Theinstruments used will be a H^U/PID and combustible gas -indicator MSA 260. Ifconcentrations of gas or vapor exceed 500 ppm, when using the HNU/PIO. or 10percent of , the lower explosive -1-iJHit, when using the combustible gas indi-cator. operations must be suspended and the Health and Safety Coordinatorcontacted.

3 . 1 2 TRENCHING

Treixhing operations wm be performed under OSHA 1910 Subpart Pregulations. Entry into the excavation must follow rules for a trench box orprescribed angle of repose before employee action. A lifeline and harnessMil also be required before entry.

3-13

003551

INTERNATIONAL TECHNOLOGY CORPOr^r:CN

4.0 EMERGENCY PROCEDURES

The health and safety plan has been established to allow site operationsto be conducted without adverse Impacts on worker health and safety. Inaddition, supplementary emergency response procedures have been developed tocover extraordinary conditions that (night possibly occur at the site,

4 . 1 GENERAL,

All accidents and unusua1, events win be dealt with In a manner to mini-nn2e continued health risk of site workers. In the event of an accident orother unusual event, the following procedure wi l t be followed:

• First aid or other appropriate initial action will beadministered by properly trained personnel closest tothe accident/event. This assistance will be conductedin a manner to assure that those rendering assistanceare not placed in a situation of unacceptable risk.

• AU accidents/unusual events must be reported to theHealth and Safety Coordinator and the Onsite Supervi-sor. The Health and Safety Coordinator is responsiblefor assisting/coordinating the emergency response In anefficient, rapid, and safe manner. The Health andSafety Coordinator will decide if off-site assistanceand/or medical treatment is required and arrange forassistance.

• All workers onsite are responsible to conduct them-selves in a mature, calm manner in the event of anaccident/unusual event. All personnel must conducttheaisetves in a manner to avoid spreading the danger tothemselves and to surrounding workers.

The following emergency equipment will b<? available at the site:

• First aid kits• Fire extinguishers• Emergency eyewash station/showers• Portable oxyyen» ndn-resusitation type.

The Onsite Supervisor and Health and Safety Coordinator will document allaccidents/injuries.

003552


4.2 RESPONSES TO SPECIFIC SITUATIONS

Emergence procedures for specific situations are given In the followingparagraphs. .,,.,,,;,^,.;. , -!"

4.2.1 corker Injury

If an employee working in a contaminated area is physically injured. RedCross first aid procedures will be followed. Depending on the severity of the"'"Jury* emergency medical response may be sought. If the employee can bemoved, he wi l t be taken to the clean zone. Decontamination procedures, addi-tional first aid or preparation for transportation will be conducted in thiszone.

If the Injury to the worker is chemical in nature (e.g., overexposure),the following first aid procedures are to be instituted:

' Eye Exposure - If contaminated solids or liquids getinto the eyes, wash eyes immediately at the emergencyeyewash station using large amounts of water and lift-ing the lower and upper lids occasionally, Wash for atleast 15 minutes. Obtain medical attention immedi-ately. Contact lenses shall not be worn when workingon the site.

- Skin Exposure - If contaminated solids or liquids geton the skin, promptly wash the contaminated skin usingsoap or mild detergent and water for at least 15minutes. Obtain medical attention immediately whenexposed to concentrated solids or liquids. Mash faceand hands prior to eating or leaving the site.

4.2.2 FiresFire extinguishers will be provided. If a localized fire breaks out. dry

chemical fire extinguishers will be used to bring the occurrence under con-trol. If necessary and feasible, a fire blanket, soil or other inert mater-ials wi l l be placed on the burning area to extinguish the ^lames and minimizethe potential for spreading. If appropriate, local firefighting authoritieswil l bK contacted for notification and/or assistance. ..„„„„.. . , ^ .

If an uncontrolled fire develops releasing potentially toxic gases, allpersons in tha immediate vicinity will be evacuated. Contact the fire depart-ment immediately and notify them of the materials Involved.

4-2

003553


4.2.3 Spil lsHandling procedures have been developed to limit potential problems with

aaterial spillage. In the event of a spill at the site, the area will beisolated from traffic patterns by the Health and Safety Coordinator. Spilledsolids will be removed and "loaded into appropriate containers for subsequentdisposal. Liquid spills will be solidified with absorbent material and loadedinto appropriate containers for disposal.

4.2.4 SecurityNo entry to the construction area will be allowed by persons unless they

present documentation indicating association with the project. Contact theOnsite Supervisor or Health and Safety Coordinator with questions.

4 .2 .5 Emergency Horns/Cgmifiumcat.iQnsA combination of emergency freon horns and walkie-talkies shall be uti-

lized for emergency communication onsite.

4.3 NQUFI CATION

4.3 .1 ChecklistThe names and phone numbers of all personnel and agencies that could be

involved in emergency response will be established by ;he Health and SafetyCoordinator and posted at several prominent locations at the site. The emer-gency phone list is attached (Attachment 2).

4.3.2 ProceduresIn the event of an onsite emergency requiring notification of off-site

personnel, the Onsite Supervisor is responsible for immediately notifying theappropriate agencies. If for some reason the Onsite Supervisor Is unavail-able, the Health and Safety Coordinator must perform this function. Thedesignated AOPCE and EPA representatives win be notified of the contact of anagency as soon as possible after the contact is made.

4.3.3 DocumentationThe Health and Safety Coordinator will provide a report to the Project

Manager describing the following: „ .. , : ; : • • • • •

4-3

003554


* The event (including date and time) that necessitatedthe notification and the basis for that decision.

* Date, time. and names of al t persons/agencies notifiedand their response.

* Resolution of the incident (including duration) and themethod/corrective action involved.

This report will be submitted within five working days of tha resolutionof the event.

4.3.4 Evacuation_Pj an

Although very unlikely, it is possible that a site emergency could neces-sitate evacuating all personnel from the construction site. If such a situa-tion arises, the Health and Safety Coordinator wilt notify the Onsite Super-visor or vice versa of this event and the appropriate signal given for siteevacuation. It is the responsibility of these individuals to evacuate person-nel in a calm, controlled fashion.

Al t available vehicles located outside of the work zone will be used inthe evacuation. All personnel wil l exit the site and be taken to a designatednearby rendezvous point, IT operations trailer or at an alternate site se-lected by the Health and Safety Coordinator depending on wind direction,severity and type of incident, etc. The routes to these locations wi l t begiven to all responsible persons and posted at the site. The evacuationroutes win depend on which direction affords the most direct route away fromthe site area.

The Onslte Supervisor log of onsite personnel will be used to ensure thata 1 1 individuals are accounted for. If someone is missing, the Health andSafety Coordinator will alert emergency personnel. Control of personnel atthe rendezvous point is the responsibility of the Onsite Supervisor or hisdesignated assistant.

Local police/emergency action coordinators w i11 beemergency and the suspected Impact on the local community.if required, will be the responsibility of law enforcensent.maintained uni.i1 the situation is abated.

4-4

notified of theLocal evacuationsContacts win be

003555


5.0 DATA COLLECHOH/OHSITE COMPLIANCE

5 .1 DATA COLLECTION

Records of alt health and safety activity at the site will be maintained»iacludtfig records of aH health hazard surveys, evaluation of potentialhazards, ano control measures taken. Records required by the state and fed-eral government will be kept current. The records will document potentialexposure levels during waste fnovensent and the degree of hazard. Site em-ployees w 1 1 ' i be continually informed of exposure levels and the degree ofsafety erasures required for protection from the hazards present. The docu-mented exposure monitoring will serve as a record of assessment of the respi-ratory hazards at the particular operation of the project and will include thefollowing:

• Determination of personnel activity in the workingarea:

- Job routines- Work locations- Time spent in work area- Work rates

• Determination of any potential respiratory hazards:

- Chemical composition

- Type of a1r contamination

- ToxicUy at various concentrations (acute versusChronic)

- Established concentration limits for breathing

•• Determination of whether to Improve administrativecontrols.

Al l data will be available to £PA and ADPCE throughout the project.Records of all sampling, methodology, calculations, results, reports, andrecommendations wi l l be kept for a period of at least three years after com-pletion of the project.

003556

5.2 SUBCONTRACTOR COMPLIANCE

All EPA, state, and federal regulations win be adhered to by site em-ployees during excavation, disposal and construction operations. The subcon-tractors wi l t also conduct medical screening examinations for employees,comply with the personnel protective programs, and emergency response proce-dures, etc. Statements of commitment and understanding of procedures will besigned by a 1 1 subcontractor personnel.

5.3 STANDARD SAFETY PROCEDURES FOR SUBCONTRACTORS

Standard safety procedures for all !T subcontractors include the follow-ing:

* Medical surveillance* Training* Personnel protection

Applicable subcontractor personnel will be given environmental baselinephysicals prior to handling hazardous waste materials and after the completionof the project. This medical surveillance allows monitoring for potentialhealth effects from chemical exposure. As part of the training program.personnel are instructed in the use of appropriate safety equipment.

5.4 HEALTH_AND S_AFETY PLAN COMPLIANCE/OSHA

The attached OSHA poster should be placed 1n a viable area at the worksite (Attachment 6).

5-2

003557

003558

*--<— •'VI » . ,_.

003559

ATTACHMENT 2

EMERGENCY NUMBERSAmbulance.....................................................................Doctor..............................................................................Hospital...........................................................................Fire Dept. ................................................................Police.............................................:...................................Sheriff...............................................................................U.S. EPA (24 Hour Hotline) ........800-424-8802Chemtrec............................................800-424-9300National PoisonControl Center .................................404-588-4400

Electric Co.....................................................................Water Co..... ...............................................................Gas Co.............................................................................

IT COSPORKnON. . Creating A Safer Tomorrow

"i—"""v /'"'"N. r-y , r v^ / "" s. iTO G!G](DI J v -^ •—•-_> la^L_JH v__^r^aa ^<i r w&^arw •"(•y

003560

ATTACHMENT 3

IT tfOfl»0«ATtON

SUPERVISORSEMPLOYEE INJURY REPORT

POR DEPARTMS^T useQ Stita CamowsntiwQ FWtrai (. & H

This f$ Art official document to be initiated by the Supervisor.Be thorough and accurate. Answer •11 questions.

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Q DOCTOR CASE 0 MOSPITAU2EO

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MANAGER

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003561

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003562

LIABILITY, PROPERTY DAMAGE,AND LOSS BBPORT

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003563

industrial waste control health and safety plan

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