NCD003200383_19890811_Koppers Co. Inc._FRBCERCLA RD_Health Safety Plan - Treatability Study-OCR

I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
N
CJ
EPA
DATE: ? I (( .
I
TO: Jgc (c
Fax Transmittal
Transmitted From:
Risk Reduction Engin~ering Laboratory Superfund Technology Demonstration Division Technical Support Branch Cincinnati, Ohio 45268
Phone: [phone] Fax: [phone]
PAGES TRANSMITTED: -4--r S-3
(lhcludln9 Cover)
COMPANY: ;(. c. c;,;e£rc~ullfo ;;1u1 s I oA/ ,
LOCATION: ______________ _
FAX NUMBER: _i'½--1
r_'i_c._\_7_.:1_· 3_4.c...,; J}-'-'-l ! _______ _
FROM: l~y i.. Yo AL S
PHONE NUMBER: ( c.,-, :s) S-(? 7 7 s~cf 9
6=====1h==s===ee=-cSS--S-e.aso====-;aae-S:-='=-·S·-=--=-=====·-=· .Se;--SC-e.as,-=•-•===d
. -. --RUG :. e: , ':,':;, a:::~:=-n-11 t""'r(:_ :.;vi ...
l,EPA Un~od Ststn
Environmtntll Prolo-;tion
~ncy
' ,_, .
r. ~r _,
OH\ot or Solid Wuit ind Emor;,ncy RHponu
Ol!ic.o or Rnwreh and i,.v,1opm1nt
Washin;;:on, CC 204!l0
AUSUJ\1993
I
I
I
I
I
I
PROGRAJ\1 FACT SHEET
De~on of the Base-Catalyzed Decomposition Technoloc: Rl\f \ and SAREX~ THERM-0-DETOX™ System
\) Koppers Company Superfund Site /J
Morrisville, North Carolina
nns FACT SHEET TELLS YOU ABOUT ...
I • EPA'; Su~ Jnnovativc T~ogy Evaluation (SITE)
p~
I
I
A technology demon.rn:ioo tD be performed ll the Koppe11
Company Supcrfund site, located in Morri!Ville, North
Carolin.a
A Vi$ilorr' Day robe held on Augun 2.1, 1993 a.! the
1 Koppen Company aite
INTRODUCTION
I The U.S. Environrnc:nw Protectic:c ~ (EPA) identifies new
rn=:hods for hazardous waste cleanup through its SITE Program.
Unde. thii pl't.V<lffi, crcatx:d ill ln6, inno"l'l!tive tl'eatmc:lt t:ch· I no!Qiies that may sijpiiJicantly reduce the toxicity, roobilit1, or
volume of bul.rdow wa,te are c!emoti.rtratQC and c:valuat:d. The
SITE PJ'Oi!"Mi also~ r-Jiablc pcmmnance and =t I iofurmlltioo oo tho ttlcimo!Ojpel for Uie ir, cvaJuatins cleanup
altamti~ for ~nilariy C01larnina::.d 1il:$
I Toe techooloa:,· proposed fo. damoostntioti i.l the Batc-Cw.1)-zcd
Decompc,8ition (BCD) te::haoloi;)• developc:ci by EI' A' 1 Rm
Reductio:l ~ Laboratory in Cincinnati, Ohio, using the
I S~ THERM-0-DETOX SJ'it:m develoi,o-i by ETG E.ovi-
ronmemal, Inc. (ETG), and Sc:parat!oli IJld R=ve.ry Systems,
Inc. (SRS). Th: puiyosc of th.i.s demO!lS".rntioo is 10 a&Be<J how
I well the t«.bnology n:movcs penta.chlorophenol (PCP), dioxi:u,
and fu:2n! frc:n the soil at the Kopper, Ccrr.p?.ll; Superfunc rr-.
io Morruville, Nor.h Ca.-o!w..
I
I
I l
EPA'S SITE PROGRAM
Ea.ch ytar, EPA 1olicit:J proposals fro.-;i privati: ttcimology c!evcl, .
open 1o demon.rtl"";lle imlovarive technologic$ under the SITE
PrCJirlm TechnolOiY oevelopers can rubinit cbxnon.tr&tioo
propotili &cy ti:ne throujlhout the year, For each teclmoloi)·
selected, EPA, often with inptrt from = r.nd r,:aionaJ ~iet,
docs the followins:
• ldentifi~ a ,~ v.ith wanes suiWi~ far ll'ealment
• l'r;pam a w;hnology demons:ratioc plan
• NotifiCi approprial: ~ for ~v=tal w;i
comrrumit:1rcvicYtl
• P ~ a fact sheet fonhe public, proposilli the 4 ite :in.!
tedmologymatch
• mp= the demoostn.rioo ~
• Cooduc-.1 ~ auc:it! field wnptm. anrl laboratory analy=
• Organizes a Visirors' Day ro view the twmol~ deruomb • ·
tion
E vtl uatcs t:clinology pc:fo:mancc
PreparcnnApplict.tionsAnAlymRcpor.and~ T~-
~Ut.tion Report ~ the ck:norutn:icm =Its,
a.swell as w.-eral other inform:ilional itemJ rue!: u bulletinh,
. .r .imnwi~ and e vidro
CONTAMlNAT.O
MATERIAU
011 &CIIUNID iOILS
FEED
HOPPER
• __ I.!.. .!.l
VAPOR O>SCHAROE9
SCREW CONV.VOR
r'\. r"\ -t V UV
MeC'JrM TI~P. TH'"'~-""-
OCS~PTIOl>i UNfT
{lnTil)
COO:.INC WA TU
TO
A n,,os PH.Ri
CARBON CONDENiOR
~OUSHE II UNI";'
DECHLORINATION
~-L--'( IL ADDITIV! REAGENT5
I
I
I
I
I
I
I
I
I
I
I
I
I
I
-.,._____,_'-__,_'-~,-l
ON•JITl l,.,Cl<1'1LL 011 .... __ ..J
orr-srn or~OllA\.
UCIUID
TANK
Rli:MTOR
(Lill)
D!COtlTAMINAT!O SOLIDS
CONT,O,INIII
TECHNOLOGY DESCRIPTION
'TheBCDtechoolo'a;!i.JIUlEI'A~procc,itor=::diat:roil
and sl\ldgc ~ mth chlorirw.led orglll1ic compounds.
Baa:d on the p~ requirement:! of the BCD ttclmology, ITG
and SRS have de.-elopc,d the SAREX* TIIER.J.J-0-DETOX
syitJ:m in coc,p=tioa witli EPA to ew.1~~ the effu:ti= of
thu p~ ll!lder re.al-time conditioru: in the field.
The S~ THERM-0-DETOX S} -mm ii baaed on a prm,m
illdirect-~ m:dium ~ thermal derorption (MTID)
unit. The unit is equipped with a multiple;b.a.ft Siitator for high
heat tntnmr efficiency and i;xoell~ loc!I! ~ a..'tioo.
The BCD phyaictl/cheroic,J j:-"Oeelll ~0$ and chemically
I dtco1.ipo.ea =-.aminants by rom0"11lg chlo:inc atom.. Com-
pound., 1h11 the BCD proce.s. =~include polycblori-
i=,:i biphecy!J (PCB), PCP, chlorinated dib=odiox.i.-os ar.d I furans, i=ticides, and lx:rbicidcs.
The pl't>CC$$ begin., by mixing an i:"JOrga.nio re>lj1Cnt wi>.h the
I coataminati:d soil, scdi.-nca!, or liquid. Toe mixture i.! heated in tli,e
MTID unit fO.r abou. 1 hour a.t 650 °F to 800 "F. ~ oftbe
chlorinatc>d =t.amina.~ are~ during thi! step. The
I ror.aining o'l,a,lllc 1;00:.aminanu; .re themwly derorbed and re-
move:! with tre off 225.
I 2
Clean soil exitini ilie solid reactor et..n be returned to the site. The
remainm& CO!ltMlln:.nu from the vapor~ and im:!ual
dust are captured and tmuro fur 2 to 4 hours a: app:oximatd:·
650 °Fin a liq-.iid-ta!lk =c\Or (LTR), Toe LTR ;aes, hiih-
boiling-poinl hydrocarlxm, a proprie::a:ry cawyr~ and mum
hydrcrode, Nitrc,scn is puritd throuah the L TR to control~
~els, preven1:iiljl the wik COi1tems from oxidizinj or isnitin..
Oily l'C$1dUALI remaining in the: L TR cootain dust and slu~ aoo
are ccrnbur.ible, They can be burned in an oil-fired power plant
or trca!ro and reclaimed by waste oil =yclcrs, The aqu=
co:-.dema!e fmn the process can be di!charse:J to t publict)·-
ownro treatmcnl wooo 11.fter being poliilied throll$h an a.ctiv=d
carbon trea:mentp~. De.conraminaiedsludaeoan bediJposed
cfin the same nw=r iu municipal slua.,:. Sp<:!ll carbon from the
·.vatcr polishi.nt; can also be tn:at:d in this p=,
Tnc only by-produru produoe,;i by the BCD proc,, .. a.re biphei,·1
w:i low-boilinil oleliniC$, an:: mum chloride.
SITE DESCRIPTION
The Kc,p-,,::~ C-anp:.n)· aitt i.l l=tc:l in ~ Shiloh community,
~ mileg ncrJi of Morruville, North Carol:.r:a. Toe site c:ovm
a;,proximaldy 52 .u;JU al !he inter=tion of ~way 54 i.r,d
Koppers Road (see Fiiure 2),
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
·--· ------'·---:: I •. I_.
HUG 1 e, '93 3~: 58PM PRC ~Ml
The southeastern a,:,;tio:i of the~ was the CELL ON proceuing
a= and former Lia= a."Ca.. TI,c CELLON pro:;cu involved
p~wood1•1i1hPCP Md ll-..:i mamina it Tot "-attr
jCDerairo from this proceu, called J'WAte, WU colJocted, pro-
CCS-'00 to remove tlic PCP by fl=uWioa, and plz.ccd in two
~ at the site for further t==t. Th: riJ'l.l&1e did oowevcr
=in PCP. Toe CELLON proceu WU u,«i lt the lite from
l 968 to l 97 5. Tu two laiooni were clooro and emptied b 197 6.
Waier fro.'TI the lagooni -...111 rpraycd onto the ground al the north
end ofthe site, and the bottom alud,ie8 from the l.ijoocs were iprcad
to dry.
In 19 80, high levels of PCP were found in the: soils in the formt;r
!aioonmaand CELLON p~~. PCP Wa.! alsodetlleted
in~ ifOUod,vater. In I 989 the: site wa.uddo:l to EPA' I National
Priorioo List (NPL). A remed.itJ lnvMtlption (RI) W!l.l coo-
ducted, identifyins the prima.ry coriwnina.'lt:! at the sitc"' PCP,
polychlorinatcd dJb=o-p-diox.lsu (PCD D). polychlorwted
di~ (PCDF), and iropropy! ether (I?E). The RI
indicated that the CELLON processing area and lagoon ar:a
~ u ~ for the migration of contarnina.nts into the
jp'OUlldwater.
The BCD technology B.Dd SAREX-1BERM-O-DETOX S)'"i"!:m
demorutntion~theK~~NConipanyS~uKh:dul~to=
durina Ausus: 1993. The prinwy obj~ of this demonstration
arc to:
Dm."mine how efficie:itlv the BCD proces, removes PCP,
dioitlns, and furw from tho eootam.inat.ed ~il
• Determine \\nether treatment resicfuals (air, waur, oil) meet
cleanup jcv,,lJ
Evaluate the pote:otial fur the BCD proc= to foam additional
volatile organic compounds .... nen heo.ted to high 11:rnpera -
tlreC
Obwn lr\formatian required to estimate treiannem e-;m,
includ.ina captwandopcntlnicxp=Ci, forimure SuJX,f.md
dccision•makini pu:posc,
CHURCH ~OAD DRAFT
\.EGEND
0 EXJSTING WHL!
-PROPER1Y eovND,1,1\Y
--UNIT STRUCTUR,SI
KOPPliRll lllH
PROPI.R1Y LINi
3
•
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
EPA hi.s prepared a detail~ qtU.lit}· lUU."ln<X: project plan
~thcrooho:ls aodp~ forlCrtmil.lldevdlWlllilk
tccimology. Whffl tbe de:mrutrttiOll iJ com;,ltte, EPA will
=ipile and analyu the flndiJlil in :an Applicatiooa Analyli,
Report and , T eclmolO&)' Evaluation Rtpo:t. Th~ rcportl v.ill
be~ to e;'Ull4te &ltmlt.tiva for cleatlllli up similar sites acros1
the COll!ltl'y.
ADDITIONAL Il1iFOR11M noN
Questi= or com.'Tlel!U about the SITE Program or tho prcpolCd
donorutration should be made by Auiu1t 20, 1993 to:
TenyLyons
U.S. EPA SITE Project Ma1~cr
26 Wes: Martin Luther Kiili Drive
Cincinnati, Ohio 45268
(S13} 569·7589
S~ific queitio:u ~ tile demcrutnitioo rite 500.ild be
dirt>Ctedto:
Beverly l:hldson or Diane Barrett
Nor-.h Superf.u:d Rt:mcrlial Branch
Wasu ~~ent Division
U.S. EPA, Rciion 4
345 Co.irt1and Street, NE
Atlanr.i, Otorp. 303 65
(404) 347• 779 l or (800) 43.$-9233
Specinc questions rcgardiJis !he BCD lllclmology a: SAREXO/.l
THERM-0-DETOX 1yrtem s.liould be directed to:
Dr. Yei Sho:'i Shelli
ETG Enviroamemal, Inc.
660 Sentry Parkway
Blue &Ji, Pe:wylvnnia l 9422
[phone]
A U.S. E.nvirowntllU.I Prottetion Agency
26 Wm Martin Lulher Kini Drive
Cm:innati, Ohio 4 5 2 68
Attenti011: Tel'l)' Lyoni
4
I
I
I
I
I
I
I
I
I
I
'I
I
I
I
I
I
I
I
I
,8 EPA
BASE CATALYZED DECOMPOSITION (BCD)
TECHNOLOGY SITE DEMONSTRATION AT
KOPPERS COMPANY, INC.
MORRISVILLE, NORTH CAROLINA
HEALTH AND SAFETY PLAN
·DRAFT
Prepared for:·
U.S. ENVIRONMENTAL PROTECTION AGENCY
RISK REDUCTION ENGINEERING LABORATORY
CINCINNATI, OHIO
Prepared by:
PRC ENVIROMENTAL MANAGEMENT, INC.
JULY 1993
SUPEl'fFUNO INNOVA TTVE
Tl!CHNOLOGY l!'VALUAT10N
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
REVIEWS AJ\'D APPROVALS
CLIENT NAME: U.S. ENVIRONMEl'<'TAL PROTECTION AGENCY RlSK REDUCTION ENGINEERING LABORATORY
CO/\'TRACT NO.: 68-C0-0047
KOPPERS COMPANY, INC.
MORRISVILLE, NORTH CAROLINA
We, the undersigned, have re;id and approve of the health and safety guidelines presented in this
Health and Safety Plan for on-site work activities at Koppers Company, Inc.
. Kurt A. Sorensen
PRC Environme.1t-1l Management,
Inc. (PRC),
Health and Safety Director
Roben Hutcheson
PRC Project Manager
Terry Lvons
EPA Technical Projec; Manager
Signature Date
c..-
((JJ~
~3=~1--
I
I
I
I
I
I
I
I
I
I
I
I
I
I
R
I
I
I
I
Section
1.0
2.0
3.0
4.0
5.0
6.0
7.0
COITTENTS
Page
INTRODUCTION ..................... ' ........... ' . ' .... ' .. '
HEALTH AND SAFETY PLAN ENFORCEMENT ...................... .
2.1 PROJECT PERSONNEL .................................. . 2
2. 1.1 Project Manager and Field Site Manager . . . . . . . . . . . . . . . . . . . . . 2 2.1.2 Health and Safety Director . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 2.1.3 Site Health and Safety Officer . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
2.2 SUBCONTRACTORS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2.3 VISITORS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
SITE BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
3.1 SITE DESCRIPTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 3.2 SITE HJSTORY ......................................... , 4
SITE-SPECIFIC HAZARD EVALUATION ............................. .
4.1 EXPOSUREPATHWAYS ................................. .
4 .1.1 Inhalation ....................................... . 4. I. 2 Dermal Contact . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 .1.3 Jngestion ....................................... .
4.2 HEALTH EFFECTS ..................................... . 4.3 PHYSICAL HAZARDS ................................... .
TRAINING REQUIREMENTS
PERSONAL PROTECTION REQUIREMENTS ......................... .
8
8
13
16
16
18
6.1 LEVELS OF PROTECTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . l 8 6.2 PROTECTIVE EQUlPMENT AND CLOTHING . . . . . . . . . . . . . . . . . . . . 19 6.3 LIMITATIONS OF PROTECTIVE CLOTHING . . . . . . . . . . . . . . . . . . . . 20 6.4 DURATION OF WORK TASKS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 6.5 RESPIRATOR SELECTION, USE, AND MAINTENANCE . . . . . . . . . . . . . 21
. MEDICAL SURVEILLANCE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
7.1 HEALTH MOt-,1TORJNG REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . 24 7.2 DOCUMENTATION AND RECORDKEEPING REQUIREMENTS . . . . . . . . 26 7.3 MEDICAL SUPPORT AND FOLLOW-UP REQUIRE/--.fEJ'<TS . . . . . . . . . . . 26
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
8.0
9.0
10.0
COITTENTS (Continued)
ENVIRONMENTAL SURVEILLANCE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26
8.1 INITIAL AIR MONITORING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
8.2 PERIODIC AIR MONITORING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
8.3 MONITORING PARAMETERS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
8.3.l Ambient Airborne Dust . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
8.3.2 Organic Vapors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
8.4 USE AND MAINTENANCE OF SURVEY EQUIPMENT . . . . . . . . . . . . . . 30
8.5 HEAT STRESS MONITORING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
SITE CONTROL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
9.1 COMMUNICATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
9.2 SAFE WORK PRACllCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
9.2.1 Sampling in Trenches and Confined Spaces . . . . . . . . . . . . . . . . . . . 34
9.2.2 Avoidance of Trips and Falls . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
9.2.3 Site Activities Near Utility and Power Lines . . . . . . . . . . . . . . . . . . 34
9.2.4 Avoidance of Excessive Noise E,;posure . . . . . . . . . . . . . . . . . . . . . 35
9.2.5 Illumination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
9.2.6 Sanitation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
9.2.7 Site Housekeeping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
9.3 HEALTH AND SAFETY PLAN ENFORCEMENT . . . . . . . . . . . . . . . . . . 36
9.4 COMPLAINTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
DECO NT AMJNA TION ................ ' ............ ' .......... . 36
10.l PERSONNEL DECONTAMINATION............ . . . . . . . . . . . . . . . 36
10.2 EQUIPMENT DECONTAMINATION. . . . . . . . . . . . . . . . . . . . . . . . . . . 37
10.2.1 Sampling Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
10.2.2 Field Monitoring Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3S
1 l.O EMERGENCY CONTINGENCY PLANNlNG . . . . . . . . . . . . . . . . . . . . . . . . . . 3S
11.1 INJURY IN THE EXCLUSION OR THE COl'<"T AMINA TION REDUCTION
ZONE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
11.2 INJURY IN IBE SUPPORT ZONE . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
l l .3 FIRE OR EXPLOSION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
l 1.4 PROTECllVE EQUIPMENT FAil.URE .......................... 39
l l.5 EMERGENCY INFORMATION TELEPHONE NUMBERS . . . . . . . . . . . . . ·1-0
11.6 HO SPIT AL ROUTE DTRECTIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40
ii
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
1•
I
COI\Til\'TS (Continued)
F1GURES
Elm Page
3-1 SITE LOCATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
3-2 SITE LAYOUT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
11-1 HOSPITAL LOCATION MAP . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
4-1 HAZARDOUS MATERJALS POTENTIALLY PRESENT AT KOPPERS SITE . . . . . . . 9 4-2 WORK TASK HAZARD ANALYSIS ................................. II 4-3 POTENTIAL HAZARD EVALUATION ............................... 12 4-4 PERMISSIBLE EXPOSURE LEVELS FOR ON-SITE CHEl\-ilCALS . . . . . . . . . . . . 14
ATTACHMENTS
Attachment
A
B
C
D
E
F
COMPLIANCE AGREEMENT FORM
SAFEIT MEETING SIGN-OFF SHEET
DAILY SITE LOG
MA TERIAl.. SAFETY DAT A SHEETS
CONFINED SPACE ENTRY PERMIT
ACCIDENT REPORT FOR.¼
Ill
I
I
ACG!H
I ANSI
I APC
BCD
I CFR
I CRC
CRZ
I EPA
HSP I HRS
I HSD
!PE
I mg/kg
I MSDS
MSHA
I NaOH
I NCDOH -
NIOSH
I 1'.'PL
OSHA I PCP
I PEL
POTW
I
I
I
LIST OF ACRONYMS
American Conference of Governmental Industrial Hygienists
American National Standards institute
Allowable Particulate Concentration
Base Catalyzed Decomposition Process
Code of Federal Regulations
Contamination Reduction Corridor
Contamination Reduction Zone
U.S. Environmental Protection Agency
Health and Safety Piao
Hazard Ranking System
Health and Safety Director
lsopropyl ether
milligrams per kilogram
'.'.faterial Safety Data Shee:
Mine Safety and Health Administration
Sodium hydroxide
North Carolina Division of Health Services
National lnstitu:e for Occupational Safety and Health
National Priority List
Occupational Safety and Health Administration
Pentachloropheool
Permissible Exposure Level
Pubiicly Owned Tre.itment Works
iv
I
I
I PPE
PPM
I PRC
I RCRA
Rl/FS
I RREL
SHSO
I SITE
I SWP
TCDD
I TCDF
I TLV
TPM
I US!
I
I
I
I
D
I
1•
I
LISf OF ACROr-.YMS (continueo)
Personal Protective Equipment
parts per mill ioo
PRC Enviroomental Management, Inc.
Resource Conservation and Recovery Act
Remedial Investigation and Feasibility Study
Risk Reduction Engineering Laboratory
Site Health and Safety Officer
Superfund lonovative Technology Evaluation
Safe Work Practice
2,3, 7 ,81tetrachlorodibenzo-p-dioxin
2,3, 7,8-tetrachlorodibenzofuran
TI1reshold Limit Value
Technical Project Manager
Unit Structures, Inc.
V
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I.t INTRODUCTION
PRC Environmental Management, Inc. (PRC), received Work Assignment No. 0-11 from the United
States Environmental Protection Agency (EPA) under Contract No. 68-C0-0047 to conduct sampling
activities during the Base-Catalyzed_Decomposition (BCD) process delDQnstration at the Koppers site in
Morrisville, North Carolina. Toe following site-specific health and safe!)· provisions bave been developed
for use during the Koppers site Superfund Innovative Technology Evaluation (SITE) BCD demon.stration.
This document addresses those items specified under Occupational Health and Safety Administration
(OSHA) 29 Code of Federal Regulations (CFR) 19 J_0.120 (b) Final Rule. This document will be
provided to all PRC on-site personnel, subcontractors, and site visitors who may be exposed to hazardous
conditions during the SITE BCD demonstration.
The purpose of the health and safety plan (HSP) is to define requirements and designate the protocols to
be followed during the SITE BCD demonstration at the Koppers site. All PRC personnel on site,
including PRC employees, subcontractor employees, and site visitors must be informed of site emergency
response procedures and any potential fire, explosion, health, or safety hazards of on-site activitie$. This
HSP summarizes potential hazards and defines protective measures planned for site activities. A separate
SITE demonstration, to be performed simultaneously with the BCD demonstration, will also be conducted
at the Koppers site. This HSP only applies to the SITE BCD demonstration to be ccnducted at the
Koppers site.
This plan must be reviewed and approved by the PRC health and safety director (HSD), the PRC project
manager, and the EPA Technical Project Manager (fPM). The comp! iance agreement form in
Attachment A mll.\t be signed by all field personnel before they enter the site. Any revisions ta this plan
must be reviewed by the EPA TPM and approved by the PRC HSD.
2,0 HEALTII AND SAFETY PLAN ENFORCEMENT
This section describes the responsibilities of project personnel and summarize., requirements for
subcontractors and visitors who wish to enter the Koppers site.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
2,1 PROJECT' PERSONNEL
The PRC project manager, field site manager, HSD, and site he..lth and safety officer (SHSO) will be
responsible for implementation and enforcement of the health and safety provisions of this HSP. Their
duties are described in the following sections.
2.1.1 Project Manager and Field Site Manager
The PRC project manager, Robert Hutcheson, is ultimately responsible for ensuring that all project
participants abide by the requirements set forth in this plan. Toe PRC field site manager, Gary Benfield,
will oversee and direct field activities, including subcontractor activities. He also is responsible for
ensuring compliance with this plan.
2.1.2 Health and Safety Director
The PRC HSD, Kurt Sorensen, will be responsible for providing technical coordination for the health and
safety program. The HSD will act b an advisory capacity to the SHSO, and will report t0 the PRC
project manager. Liaison with officers and representatives of EPA on matters relating to health and
safety will be handled by the HSD or SHSO. The HSD is responsible for maintaining up-to-date records
of HSP-related documentation and HSP participants. HSP-related documentation will be maintained a,
PRC's Chicago office. This documentation includes the following:
•
•
•
•
Documentation of the physician's examination of each project worker (Section 7.0, Medical Surveillance).
The training record for each worker who has completed the training necessa.--y to perfonn his or her job.
Documentation of a fit test for workers rC<jllired to wear respiratory protection equipment meeting the requirements of OSHA CFR 1910.134 and American National Standards Institute (ANSI) Z88.2-!980.
Task-specific air monitoring infonnation (regarding drumming of waste, reactor emissions, and other activities)
Project employees who do not meet HSP requirements will not be allowed to conduct field work.
2
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
2.1..3 Sile Health and Safety Officer
The PRC SHSO, Tracy Poole, will be responsible for field implementation and enforcement of this HSP.
Toe SHSO will have advanced field worl:: experience aod will be familiar with health and safety
requirements specific to the project. The SHSO will ensure that the Safety Meeting Sign-off Sheet
(Attachment B) will be signed by all personnel who are to perfonn field work. The SHSO must also
ensure that each field work:ex completes a Daily Site Log (Attachment C) before leaving the site.
2.2 SUBCONTRACTORS
SubcootractOr personnel participating in the SITE demonstration will be required to read and comply with
all sections of this plan. AJI subcontractor personnel entering the site must sign the compiiance agreement
form. Subcontractor personnel must comply with all applicable OSHA CFR !910.120 training, fit
testing, and medical surveillance requirements. Subcontractors are responsible for providing personal
protective equipment (PPE) required by this plan for their personnel (see Section 6.2, Protective
Equipment and Clothing), and are ultimately responsible for the health and safety of their employees.
2.3 VISITORS
Any visitor to PRC operatiom; at the site will be required to read the PRC HSP and sign the compliance
agreement form. Each visitor will be expected to comply with relevant OSHA requirements. EJcll
visitor will also be expected to provide their own personal prote<.."tion equipment (PPE) required by the
HSP. Any visitor who does not adhere to the provisions of the HSP will be ordered to leave the work
area. Aay visitor who has not met OSHA training and medical surveillance requirements will not be
permitted to enter areas where e~posure to haz..ardous materials is possible. Exceptions will be strongly
discouraged, but they can be made on a case-by-case basis under the following conditions: (1) respirators
are not required, (2) the visitors· time on site is limited, (3) each visitor is given a pre-entry briefing, (4)
each visitor is accompanied by trained personnel at all times, and (5) SHSO approval is obtain~.
3
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
1•
'I
3,0 SITE BACKGROUND
Past investigations have determined that wood treating processes conducted at the Koppers site from 1968
to 1975 contami.n:Jted site groundwater, surface water, and soil with pentachlorophenol (PCP), 2,4-
dichlorophenol, isopropyl ether (IPE), and other organic contaminants. The following sections describe
the Koppers site and its history.
3.1 SITE DESCRIPTION
Toe Koppen; site (Figure 3-1) is located in Morrisville, North Carolina, at the intersection of Highway
54 and Koppers Road. Toe site property currently is owned by two companies, Beazer East Inc. (Beazer)
and Unit Structures Inc. (US!). The portion of the site owned by Beazer is inactive. The portion of the
site owned by US! currently is used as a wood laminating facility. The site occupies approximately 52
acres and includ:!S the wood laminating facility, an office, and several warehouses (Figure 3-2).
Surrounding land is used for a mixtur6 of co=ercial, light industrial, and rural residential purposes.
3.2 SITE lllSI'ORY
From 1896 to 1961, the site property was owned by the Cary Lumber Company. In I% 1, the site
property was sold to US!. The company operations, however, were different than those of USJ today.
1n 1962, the site property was sold to Koppers. In 1968, Koppers began treating wood using the
CELLON* process. This process consisted of injecting PCP into the wood. Butane was used as the
carrier solvent. JPE was used as a co-solvent to increase the solubility of the PCP in butane. After
application, the butane carrier was evaporated under reduced pressure, leaving a dry, crystalline salt
residual of PCP. After the butane carrier was removed, a vacuum was pulled on the cylinder and tbe
!PE and dissolved PCP were sent to a blowdowo pit. The PCP residual on the treated wood was
removed by steaming. Then the ,team condeILsate was pumped to an aboveground flocculation tanks
where flocculent was added to remove tbe PCP. After flocculation, the condensate passed through a sand
filter before emptying into two unlined lagoons located on the property. The CELLO~ process was
di,continued in 1975, when Koppers began using pre-treated wood for their operations.
4
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
D
I
Reference: t
U.S.G.S. 7.5 Min\/1e To;,~r.iphic Ma~ -N-
C.ary, North C.arolina, 1973 Ptioto R6v~~d 1987
1 ~., •• zooo-
KOPPERS COMPANY, INC.
MORRISVILLE, NORTH CAROLINA
FIGURE 3-1
SITE LOCATION MAP
5 .fVlC ENVIRONMENTAL MANAGEMENT. INC . . ,--------..J-..---.::=~
-
100 0 100 200 300
l¥lC
(,
- -
-
t-i:EDI...IH POt~D /
DUH' .-,LL
I
C
VNil STPtJCTun.ES
PnOP(ATY LINE
KOPPERS COMP MOf1RISVILLE ANY, INC. • NORTH uno " UNA
FIGURE 3-2
SITE LAYOUT
ENVIRONMENT Al MA.NAG EMENT, INC.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Some time after 1975, the name of the facility was changed from Koppers to Beazer. In 1986, Beazer
sold a portion of the site property to USI. US! sold certain portions of the site bacl:: to Beazer in 1992.
In 1976, Beazer began conducting environmental investigations of the CELLO!-.~ process area and the
two lagoons. In 1977, as part of their reclamation project, the liquid contents of the two lagoons were
pumped out and sprayed on the oorthern portion of the site. Fertilizer was added to the soils in this area
and the soils were plowed. This area is now referred to as the Iandfarm area.
The bottom sludges in the lagoons were mixed with the soil surrounding the lagoons and spread out to
dry. This area was fertilized and seeded. It is now referred to as the former lagoon area.
Beginning in 1980, Beazer began conducting additional environmental investigations at the site. These
investigations focused on both soil and groundwater. As a result of the investigations, Beazer removed
about 220 cubic yards of soil from the former lagoon area in the spring of 1980. Later that year,
Koppers removed an additional 240 cubic yards of soil from the former lagoon area. In 1986, soil was
removed from the following areas: 1100 cubic yards from the former lagoon area, 50 cubic yards from
the filter bed area, and 100 cubic yards from the blowdown pit area. According to Beazer, the removed
soils were disposed of at permitted disposal facilities.
In 1986, Beazer began sampling nearby residential wells to determine if the PCP bad migrated off site.
Also in 1986, the North Carolina Division of Health Services' (NCDOH), Superfund Branch, began to
investigate the groundwater in the vicinity of the site. Some of the ne.1rby residential wells showed
detec-.able amounts of PCP and !PE. Beazer provided bottled water to residents whose wells showed
detectable levels. Later, Beazer connected most of the residents to the city water system. Beazer and
NCDOH, under a cooperative agreeme□t, have continued to sample off-site residential wells on a
quarterly basis.
The NCDOH Superfund Branch developed a Hazard Ranking System (HRS) package oft.he site. On June
24, I 988, the site, based largely on its groundwater contmiination, was proposed for inclusion on the
National Priority List (NPL). The final rule and inclusion of the Koppers site on the NPL list occurred
on March 31, 1989.
7
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
1n March of 1989, EPA and Beazer signed an Administrative Order on Consent, which permitted Beazer
to conduct its own Remedial Investigation/Feasibility Study (RI/FS) on the site. The Rl/FS work plan
was approved in November 1989 and the field work: was started in 1990. The RI/FS field worl:: covered
site soils, groundwater, drainage pathways, and ponds.
4.0 SITE-SPECIFIC HAZARD EVALUATION
PCP, 2,4-dichloropheool, isopropyl ether, and 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) and 2,3,7,8-
tetrachlorodibenzofuran (TCDF), commonly referred to as dioxins, are the potential chemical
contaminants expected to be eooountered during field activities. Field activities to be performed during
the SITE demonstration consist of soil sampling and sampling of oil and water from the treatment unit
air scrubber system. In addition, sodium hydroxide and sodium bicarbonate, reagents which will be
mixed with the soil prior to treatment, may be encountered during soil sampling. Hazardous materials
expected to be cnoountered and a work tasl:: hazard analysis are provided in Tables 4-1 and 4-2,
respectively. Table 4-3 presents additional hazards that may or may not be encountered during site
activities. The material safety data sheets (MSDS) and Registry of Toxic Effect<; of Chemical Substances
(RTECS) information included in Attachment D summarize toxicological, human health, and safet1
information for the expected contaminants. The following sections describe the possible exposure
pa1hways and health effects of PCP and dioxins.
4.1 EXPOSUREPA11fWAYS
Exposure to on•site contaminants during field activities may occur through inhalation due to airborne
contaminated dust and organic vapors, dermal contact, or ingestion. Descriptions of these exposure
pathways are provided below. Exposure to sodium bicarbonate and sodium hydroxide may occur through
inhalation and dermal oontaci during sampling of the soil-reagent mixture.
4.1.l Inhalation
A principal pathway of exposure to PCP, 2,4-dichloropbenol, and dioxins during this SITE demonstration
is through inhalation of airborne dust contaminated with these compounds. PCP, 2,4-dichlorophenol, and
dioxin concentrations in contaminated soil are known to be as high as 3,220 milligrams per kilogram
8
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Substanct,
PCP
TCDDffCDF
2 ,4--<jichJoropbenol
Sodium
Hydro;,;ide
TABLE 4-1
HAZARDOUS MATERIALS POTE!'.TIALLY PRE.SENT
AT KOPPERS SITE
Environmental
Media'
Soil
Soil
Soil
Soil
Exposure
PathWl!ys
lnhalation
Sl::in Contact
lngestion
Inhalation
Slci.o Contact
Ingestion
l.nhalation
Skin Contact
Ingestion
Ingestion
Skin Conl;lct
Inhalation
9
Toxic
Characteristics'
Eye, sl::in, and throat irritation,
nausea., dizziness, loss of weight,
chloracne, bronchitis
Chloracne, hepatotoxicity, weight
loss, thymic atrophy, suppression
of cellular immunity, death,
probable hu_man carcinogens
Mucous membrane and respiratory
tract irritation, severe bums
Edematous lips, chin, tongue,
necrosis of mucous membranes,
pneumonia, burns, tissue
corrosion, ulcerations,
pulmonary e.dema, squamous cell carcinoma, death due to shock, asphyxia
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
SubsUlnce
Sodium
Bicarbooate
lsopropyl ether
Notes:
TABLE 4-1 (continuec)
HAZARDOUS MATERIALS POTENTIALLY PRESENT
AT KOPPERS SITE
Environmen!Jll
Medill'
Soil
Soil
Exposure
Pathways
Ingestion
Sl::in Contact
Inhalation
Inhalation
Skin Contact
Ingestion
Toxic
Characteristics•
Irrit.1tion and burns of the sl::in, eyes,
and mucous membranes.
Drowsiness, dizziness, nausea,
vomiting, narcosis, dermatitis,
intoxication and depres5\on,
and weight loss
Environmental media where on-site contaminants may be encountered. Acute and chronic physiological symptoms resulting from exposure to the hazardous materials potentially on site.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Task
Task 1
Soil Sampling
Task 2
Scrubber Oil
Sampling
Task 3
Scrubber Water
Sampling
Notes:
TABLE 4--2
WORK TASK HAZARD ANALYSIS
Potential
Hazard
Chemical
Physical
Chemical
Physical
Chemical
Physical
Anticipated
Leve! or
Protection
Level D'·'
Level D'
Level D'
• Levels of protection are discussc,::! in detail in Section 6. l
Upgra~
Level or
Protect.ion
Level C'
Level C'
Level C'
Soil saroplirJg activities initially will be conducted in Level C. The level of protection will be downgraded to Level D if air monitoring indicates ambient airbome dust concentrations are less than 5.0 milligrams per cubic meter (mg/m3) of air. Air monitoring parameters are discussed in more detail in Section 8.3.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
TABLE 4-3
POTENTIAL HAZARD EVALUATION
Potential Hazard Yes No
Airborne Paniculate Matter: _x_
Toxic Vapors and Gases: _x_
Expiosivity: _x_
Radioactivity: _x_
0, Depl et.ion: _x_
Buried Utilities:
Physical Hazards: _x_
Confine.! Spaces: _x_
Trenching:
Noise:
12
Unknown
_x_
_x_
_x_
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
(mg/kg), 1.120 mg/kg, and 0.270 mg/kg, respectively. W1aJ:uioo of dust will l>e of concern on a windy day when dust is lii::ely to be created. The potential for inhalation of organic vapors also exists. PRC personnel will monitor the concentration of dust and organic vapors with real-time field survey instrumentation. When appropriate, persooal protection will be upgraded to Level C.
4.1.2 Dennal Contact
Dermal contact with either contaminated soil or water and oil from the scrubber unit may occur during on·site sampling activities. Dermal contact will be prevented with the use of the proper PPE, such as inner and outer gloves. Safe operating procedures for PPE are described in Section 6.3.
4.1.3 Ingestion
Ingestion of hazardous materials, although unlikely, may oceur due to lack of proper hygiene or decontamination procedures. Section 9 .2 discusses safe work practices that may prevent ingestion of hazardous materials.
4.2 HEALTH EFFECTS
Tne following sections describe the health effects of PCP, 2,4-dichlorophenol, dioxin.,, !PE, sodium hydroxide, and sodium bicarbonate. Health effect information is taken from the National Institute for Occupational Health and Safety (N1OSH, 1990) handbook and MSDSs. Table 4--4 presents permissible exposure levels (PEL) for chemical exposures to be potentially encountered on site, in accordance with OSHA 29 CFR 1910. Low, medium, or high levels of these contaminants may be encountered during sampling activities at the Koppers site. Potential exposure to contaminated soil or air scrubber water and oil may be through inhalation, skin contact, or ingestion.
Effects of acute exposure to PCP include irritation of the eyes, skin, throat, and lungs, rapid heartbeat and breathing, fever, muscle weakness, loss of appetite, sweating, dizzbess, and nausea. Very high doses may cause unconsciousness, seizures, and death due to cardiac arrest. Hot weather may increase tbe risk of acute poisorung. The effects of chronic exposure to PCP may include chloracne, bronchitis, and weight loss.
13
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
TABLE 4-4
PERMISSIBLE EXPOSURE LEVELS FOR ON-sITE CHEMICALS
On-Site Chemical
Peotachlorophenol (PCP) 0.5 mglm'
2,3, 7,8-tetrachlorodibenzo-p--0ioxin (TCDD) Nooe f!l'tablished
2,3, 7 ,8-tetracbJorodibenzofuran (TCDF) Nooe established
2 ,4--0ichloropbeool Nooe established
sodium hydroxide (NaOH) 2.0 mg/m'
sodium bicarbonate (NaHCO,) Nooe established
On-Site Chemical TLV
isopropyl ether 1,050 mg/m'
14
I
I
I
I
I
I
I
I
I
I
I
I
I
I
,,
Acute exposure to 2,4-dichloropheno! may result in irritation of the mucous membranes and upper respiratory tract. Prolonged contact may produce severe sun irrit.1tion or burns. No chronic symptoms are known to date.
Exposure to bigh concentrations of isopropyl ether vapor may cause drowsiness, dizziness, nausea, vomiting, narcosis, and irritation of the eyes and nose. Repeated or prolonged exposure to the skin may result in drying and irritation of the skin. Ingestion of isopropyl ether causes symptoms similar to those for overexposure to vapor. Cb.ronic exposure may cause headaches, dizziness, weight loss, and intoxication and depression.
Acute and chronic effes.--t.s of 2,3,7,8-TCDD exposure include chloracne, hepatotoxicity, psychological alteration.s, weight loss .. thymic atrophy, gastric ulcers, peripheral neuropathy, tbrombo9topenia, suppression of cellular immunity. and death. The liver appears to be the target organ following acute exposure. It should be noted that 2,3,7,8-TCDD is a probable human carcinogen.
Ingestion of sodium hydroxide may cause: immediate burning of the mouth, esopba_,"Lis, and stomach; edematous lips, chin, and tongue; painful swallowing; necrosis of the mucous membranes; vomiting; and a rapid, fain: pulse. Death usually results from shock, asphyxia, or pneumonia two or three days after ingestion. Skin contict may not be painful for up to three minutes after contact; however, skin damage begins im.me,Jiately. Damage may progress to severe burns, tissue corrosion, ulcerations, and pennanem scarring if not immediately washed off. Inhalation may c;ause burns and pulmonary edema. Cbronic effects may inclu<le squamous cell carcinoma of the esophagus years after ingestion and dermatitis due to repeated exposure.
Acute exposure to sodium bicarbonate may result in irritation, and possible chemical burns, of the skin, eyes, and mucous membranes of the respiratory tract. No effectS from chronic exposure to sodium bicarbonate have been reported.
Work.er exposure to on-site contaminated soil will be controlled through proper U5e of PPE and real-time air monitoring for dust. The need for re..spiratory protection (powered air purifying respirators) wUI be based on rc.1.Himc air monitoring results. Initially, soil sample$ will be collected in Level C. If the concentration of the dust measured on the monitoring in.,trument is less than 5 mgim', the level of
JS
44
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
protection will be downgraded from Level C to Level D. The allowable particulate concentration (APC)
was calculated for PCP based on the highest recorded soil concentration of PCP found on site which was
found to be approximately 155 mg/m'. The PEL value for PCP is 0.5 mgim'. PELs for 2,4--
dichlorophenol and dioxins have not been established.
4.3 PHYSICAL HAZARDS
Physical hazards associated with sampling and other activities present a potential threat to on-site
personnel. Dangers are posed by underground utility lines, unseen obstacles, noise, beat, and poor
illumination.
Injuries may result from the following:
• Accidents due to slipping, tripping, or falling
• Improper lifting techniques
• Moving or rotating equipment
• Equipment mobilization and operation (for example, elearocution from contac: with underground power lines)
• improperly maintained equipment
Injuries resulting from physical hazards can be avoided by adopting safe work practices (SWP) and by
usi.r:g caution when working with machinery. SWPs to be used during on-site sampling are described in
Section 9.2. To ensure a safe work place, the SHSO will conduct and document regular safety
inspections and will ensure that site workers are informed of potential physical hazardl; related to the site.
5.0 TRAINL'IG REQUIREMENTS
All on-site PRC personnel, subcontractors, and site visitors who may be exposed to hazardous on-site
condition, will be required to meet the training requirements outlined in OSHA 29 CFR 1910.120, which
covers hazardous waste operations and emergeocy response. Ali PRC personnel·and each visitor entering
the site will be require<! to read this HSP and sign the compliance agreement fonn, and site workers will
be required to sign the Safety Meeting Sign-off Sheet.
16
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Before on-site activities begin, a briefing will be presented by the SHSO for all personnel who will
participate in on-site activities. Toe following topics will be addressed during the briefing:
• Names of the SHSO and the designated alternate
•
•
•
•
•
•
•
•
•
Site history
Hazardous chemicals that may be encountered during on-site activities
Physical hazards that may be encountered on site
Training requirements
Levels of protection to l>e used for spcr.ific worl:: tasks
Work tasl::s
Environmental surveillance equipment use and maintenance
Action levels (Section 8.3, Monitoring Parameters) and identification of situations requiring an upgrade or downgrade in levels of prote-:tion
Site control measures, including site control zones, communicatio1t,, and safe work practices (Sections 9 .0, .Site Control)
• Emergency communication signals and codes
•
•
•
•
•
Decontamination procedures
Environment2l accident emergency procedures (in case contamination spre-,ds outside the exclusion zone)
Personnel exposure and accident emergency procedures (in case of exposure to hazardous substances, falls, and other hazardous situations)
Fire and explosion emergency procedures
Emergency telephone numbers
Emergency routes
Other health and safety related topics that may arise before on-site activities begin also will be discussed
at the briefing.
17
I
I
I
I
I
Issues that arise during implerneotatioo of on-site activities will be addressed during "tailgate" safety
meetings to be held daily before the shift begins. Any changes in procedures or site-specific health and
safety related matters will be addressed during these meetings.
6.0 PERSONAL PROTECTION RJ-;QUIREME!'.'TS
PPE will be worn to protect field personnel from known or suspected physical hazards, air-, and soil-
borne contamination. Toe levels of personal protection to be used for work tasks have been selected
based oo known or anticipated physical hazards, concentrations of contaminants that may be encountered I on site, their chemical properties, toxicity, exposure routes, and contaminant matrices. Tne following
sections describe levels of protection, limitations of protective clothing, the duration of work tasks, and I
I
I
I
I
I
I
I
I
I
I
I
I
respirator selection, use, and maintenance.
6.1 LEVELS OF PROTECTION
Personnel will wear persona! protective ~uiprnent when site activities involve known or suspected
atmospheric contamination such as when airborne dust is generated by site activities or accidental direct
dermal contact occurs. Full-face powered air purifying respirators will be used to protect the iungs, the
gastrointestinal tract, and eyes against airborne contaminants. Chemical-resistant clothing will be used
to protect the skin and body parts from direct contact.
Levels ofprote;;tion and their respective components are classified under four categories according to the
degrees of protection:
Level D:
Level C:
This level provides minimal protection against chemical hazards. Worn only as a work uniform, worn in areas posing no respiratory or skin hazards.
Worn when the criteria described for Level C protection in Section 8.3 for using air-purifying respirators are met, and a lesser level of skin protection is needed.
18
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
G.2
Level B:
Level A:
Worn when the highest level of respiratory protection is needed, but a
lesser level of sun protection is required. Level B is the primary level
of choice for unknown environments.
PRC does not conduct site activities that require Level A protection.
PROTEC.-I1Y-t:: EQUIPME1''T AND CLOTHING
The following general levels of protection and the associated PPE ensembles have been selected for use
by field personnel during sampling activities (see Table 4-2, Work Task Hazard Analysis). Because the
anticipated hazard level is medium, sampling will be performed using Level C protection. If site
cooditions or the results of air monitoring performed during on-site activities do not warrant Level C
protection, all field personnel will downgnde to Level D protection. Descriptions of equipment and
clothing required for Levels D an<l C protection are provided below. It is not anticipated that site
activities will warrant Level A or Level B protection.
•
•
Level D
Coveralls or work clothes, if applicable
Steel-toed boots with shanks
Hard hat (face shield optional)
Disposable outer gloves (latex or nitrile), if applicable
Safety glasses or goggles
Chemical-resistant clothing (Tyvek4' or Saranex"), if applicable
Disposable boot covers (when entering wet or mudd)· are.\$ with l::no11rn
elevated contamination levels, such as previously excavated waste ar=)
Hearing protection (for areas with a noise level exceroing 85 decibels on
the A-weighted scale)
Level C
Coveralls or worl:: clothes, if applicable
Chemical-resistant clothing (Tyvek:"' or Sa.anex'"), if applicable
19
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Outer gloves (neoprene or nitrile), if applicable
lnner gloves 0atex or polyvinyl chloride)
Steel-toed boots with shanks
Disposable boot covers or chemical-resistant outer boots
Full-face, air-purif)'ing or powered air-purifying respirator with NIOSH-
or Mine Safety and Health Administration (MSHA)-approved carrridges
10 protect against organic vapors, dust, fumes, and mist5 (cartridges will be changed at the end of each shift, with increased breathing resistance,
or at breal"through, whichever occurs first)
Safety glasses or goggles (with half-face respirator only)
Hard hat (face shield optional)
Hearing protection (for areas with a noise level exceeding 85 decibels on
the A-weighted scale)
6,3 LIMITATIONS OF PROTECTIVE CLOTHING
PPE clothing ensembles designated for use during site activities have been selected to provide adequate
protection against contaninants at known or anticipated concentrations in soil matrices and ambient air.
However, no protective garment, glove, or boot is entirely chemical-resistant, nor does any protective
clothing provide protection against all chemicals. Permeation of a given chemical through PPE depends
on contaminant concentrations, environmental conditions, the physical condition of the protective
garment, and the resistance of the garment IO the specific contaminant. Chemical permeation may
continue even after the source of contamination has been removed from the garment.
To obtain optimum use from PPE, the followL,g procedures will be followed by all site personnel:
• Wbe□ using Tyvek"' or Saranex°' coveralls, don a new, clean garment after e;ich rest break or at the beginning of e;ich shift.
• Inspect all clothing, gloves, and boots both before and during use for the following:
-Imperfect seams
--Nonuniform coatings
--Tears
20
I
I
I
I
I
I
I
I
I
•
--Poorly functioning closures
Jn.,pe.:t reusable garments, boots, and gloves both before a□

d

duri□g use for visible signs of chemical permc.,tion such as the following:
·-Swelling
--Discoloration
-Stiffness
-Brittleness
-Cracks
-Any sign of puncture
--Any sign of abrasion
Reusable gloves, boots, or coveralls exhibiting any of the characteristics listed above must be discarded.
PPE clothing used in areas with known or suspe<."ted elevated concentrations of contaminants should not
be reused. Reusable PPE will be decontaminated in accordance with procedures described in Section I 0.1
and will be neatly stored in the support wne, away from work zones.
6.4 DURATION OF WORK TASKS
The duration of site activities involving use of PPE will be established by the SHSO or a designee and I will be based on ambient temperature and weather conditions, the capacity of personnel to work in tbe
designated level of PPE (taking into account such conditions as heat stress), and che limitations of the I protective equipment. All rest breaks will be taken in the support zone after decontamination and
relllQvaJ of PPE.
I
I
I
I
I
I
I
I
6.5 RESPIRATOR SELEC-ITON, USE, Al'/D MAINTENANCE
All PRC personnel and subcontractors taking pan in site activities must fulfill worker provisions outlined
in OSHA 29 CFR 1910.134. PRC and subcontractor personnel wUI be informed of the proper use,
maintenance, and limitations of air-purifying respirators during the daily safety briefing, if applicable.
All site personnel must complete a qualitative fit test for the respirator to be used on site.
Respirator use is anticipated for the ,ite. If necessary, a full-face, powered air-purifying respirator
e.quipped with 1'110SH-or MSHA-approved canTidges will be selected for use to protect against dusts and
vapors. Re,;pirators will be selected by tbe SHSO based on knowledge of the substances that may be
21
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
present and the concentration.s of compounds previously encountered at the site. Air-purifying respirators
will be used only in conjunction with breathing-space air monitoring, which must be conducted in
' adherence to the action limits ouUined in Section 8.1. Air-purifying respirators will be used only when
the devices can provide protection against the substances encountered on site.
Factors precluding the use of air-purifying respirators are as follows:
•
•
•
Concentrations of substances that may be immediately dangerous to life and
health, as defined in the MSDS
High relative humidity (which reduces the sorbent life of the cartridges)
Identified substances with inadequate warning properties (for example, they are
tasteless, odorless, and invisible), and respirator cartridges with an unknown
sorbent service life, and respirator units with oo end-<>f-service-life indicator
Respirators will be inspected daily, and any necessary repairs will be made during the time of inspection.
Damaged respirators will be properly disposed of. Respirators issued to individuals will be cleaned and
disinfected in the support zone at least weekly. When a respirator is used by more than one person, the
respirator will be cleaned and disinfected after each use. After being cleaned, respirators will be placed
in clean plastic bags and stored in the support zone. The following respirator inspection and cleaning
procedures will be followed whenever respirator protection is used:
• Daiiy Inspection and Checkout Procedures:
Visually inspect the entire unit for obvious damage and deteriorated
rubber.
Inspect the face-piece harness for damage.
Inspect the leru; for damage and make sure the face piece has the proper
seal.
Pull the plastic cover off the exhalation valve and check the valve for
debris and tears in the neoprene that could cause leakage. ·
Un.screw the cartridges of both inhalation valves and visually inspect the
neoprene valves for tears. Make sure the inhalation valves and cartridge
receptacle gaskets are in place.
22
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
•
•
Make sure a protective cover is attached to the lens.
Mal:e sure the speal:ing diaphragm retainer ring is band-tight.
Don the respirator, and perform the negative pressure test.
Weekly Cleaning Procedures:
Disassemble the respirator in the support zone by removing the canridges, damaging them to prevent accidental reuse, and discarding them. To clean the respirator thoroughly, remove the inhalation and exhalation valves, spea.l:.:ing diaphragm, and any hoses.
To clean the respirator, dissolve cleaning and disinfecting solution (usually provided by the manufacturer) in warm water in an appropriate tub. With gloved hands, swirl the respirator in the tub for at least 1 minute. A soft brush may be used to facilitate cleaning.
Rinse the cleaned and disinfected respirator thoroughly with potable water to remove all traces of detergent and. disinfectant. This step is very importa.nt in preventing dermatitis.
Air dry the respirator on a clean surface. The respirator may also be hung upside-down, but care must be taken not to damage or distort the face piece.
Reassemble the clean, dry, respirator and inspect it in an area separate from the disassembly are.i to avoid contamination. Inspect the respirator carefully fur detergent or soap residue left by inadequate rinsing. Residue appe.trs most often under the seat of the exhalation valve and can cause valve leakage or stic.lci.ng.
Procedures to Follow after Routine Use in the Exclusion Zone:
Wash and rinse the respirator in the support woe with soap and warm water.
At a minimum. wipe the respirator with disinfectant wipes that have been soaked in benzoali:aloid or isopropyl alcohol. Allow the respirator to air dry in the support wne.
The effectiveness of the respiratory protection program will be monitored continuously by the SHSO or
the SHSO's designee. Monitoring of worl:er mess levels during activities that require respiratory
protection will also be performed by the SHSO or the designee (Section 8.0. Environmental Surveillance).
23
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
7.0 MEDICAL SURVEILLANCE
The following section describes the PRC medical surYeillance prograrn, including health
monitoring, documentation, record keeping, medical support, and follow-up procedures. This program
will be followed for all activities at the Koppers site.
7.1 HEALTII MONITORING REQUIREMENTS
All PRC and subcontractor personnel involved io on-site activities at the Koppers site must
participate in a medical surveillance program, as required by OSHA 29 CFR 1910.120(fJ. PRC has
established a medical surYeillance program with Environmental Medicine Resources, Inc., of Atlanta,
Georgia. Under this program, PRC personnel receive annual or biennial physical examinations consisting
of the following:
•
•
A baseline medical examination that includes the following:
Completion of a personal, family, and environmental history
questionnaire
Physical examination
Vision screening
Laboratory test
Audiometric screening
Pulmonary function test
Resting electrocardiogram
Chest x-ray (required once every 3 years)
A complete blood count that includes the following:
White blood count
Red blood count
24
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
•
•
Hemoglobin test
Hematocrit test
Liver function test
Kidney function test
Lipid metabolism test
Carbohydrate metabolism test
A urinalysis that includes the following:
Sugar content test
Albumin content test
Specific gravity test
Laboratory chemistries for the following:
Cholinesterase
Coproporphyrin and uroporphyrin
Arsenic
Cadmium
lron
PRC receives a copy oftbe examining physician's wTinen opinion after post~xamination laboratory tests
have been completed; PRC employees also receive a copy of the wrinea opinion. This opinion includes
the following information (in accordance wit.h 29 CFR I 910.120{1)(7)):
•
•
The results of the medical examination and tests .
The physician's opinion as to whether or not the employee has any medical conditions that would place the employee at an increased risk of beaJtb impairment from work in hazardous waste operations or during an emergency response.
25
I
I
I
I
I
I
I
7.2
•
•
The physician's recommended limitations, if any, on the employee·s assigned
work. Special emphasis is placed oo fitness for duty, including the ability to
wear any required PPE under conditions expected oo site (for example,
temperature extremes).
A statement that the employee has b~n informed by the physician of the medical
examination results and of any medical conditions that r<XIuire funber
examination or treatment.
DOCUMENTATION M'D RECORDKEEPING REQUIREMENTS
The PRC Chicago of-fice will maintain medical surveillance records for each PRC employee performing
hazardous waste site activities. These records will be in compliance with 29 OSHA CFR 1910.120(f).
The records will also be maintained at Environmental Medicine Resources in Atlanta, Georgia. Any
visitor or observer at the site will be required to provide documentation of compliance with OSHA 29 I CFR 1910.l20(f) before entering the site. In addition, PRC will be responsible for recording and
reporting accidents; illnesses, and injuries involving PRC employees in accordance with OSHA 29 CFR
I
I
I
I
I
I
I
I
I
I
I
1910 and 1926 and EPA requirements. An accident report form, to be completed by the SHSO. is
provided in Attachment F. A copy of this completed report will be added to PR C's medical surveillance
records in the event of a reportable accident, illoe_,s, or injury.
7.3 MEDICAL SUPPORT A1'il) FOLLOW-lit' REQUIREMENTS
PRC personnel will be required to seek medical attention and physical testing in the event of injury or
possible exposure above established exposure limits. Depending upon the type of injury or exposure,
follow'up testing, if required, must be performed within 24 to 48 hours of this incident. The type of test
to be performed to monitor exposure effect, will be based on the circumstances involved and will be
selected by a qualified health professional from Environmental Medicine Resources.
8.0 EN'Vm.ONMEl\'TAL SURVEILLANCE
Radian Corporation will be on site during the BCD demonstration to conduct air monitoring activities.
Radian will monitor gases generated in the reactor at several points in the reactor system.
26
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Off-gases !bat have been treated in !be react0r unit scrubber system also will be monitored to ensure that
!be offgas treatment process is effective and toxic gases are not released. Radian will not perform
personal air monitoring for workers ori site.
Air monitoring will be performed by PRC durini designated sampling and other on-site activities to
protect field personnel against exposure to airborne hazardous substances and to determine appropriate
levels of PPE for work tasks. The following sections discuss initial air monitoring, periodic air
monitoring, monitoring parameters, we and maintenance of survey equipment, and beat stress
monitoring.
8.1 Th'ITIAL AIR MONITORING
Initial air monitoring of the work area will be performed before and during the sampling activity. This
monitoring activity will be performed using real-time field survey instrumentation, such as a Miniram
Model PDM-3 and a Pbotovac Microtip HL200, to determine the airborne concentrations of site derived
dust and organic vapors, respectively. These airborne concentrations will also be monitored at the
beginning of each work day to identify background contaminant concentrations and to detect any
potentially hazardous situations that might have developed during off-shift periods.
8.2 PERJODIC AIR MONITORING
Periodic air monitoring wilt be performerl during all site activities. This type of monitoring will be
performed as a minimum requirement when the following situations arise:
• Work begins on a different ponion of tbe site.
• Workers experien,e physical difficulties.
Required survey instrume.otation, sampling procedures, and monitoring procedures are specified in
Section 8.3. Sampling methods will be subject to review bv the SHSO.
27
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
8.3 M01'<1TORING P AR.AMEIBRS
Air monitoring for ambient airborne dust and organic vapors will be performed at shoulder height (in the
breathing 1-0ne) on workers most likely to be exposed to potentially hazudous concentrations of
contaminants. Situations that will require air monitoring, monitoring parameters, detection devices, and
action levels are disc1.1ssed below.
8.3.1 Ambient Airborne Dust
The following instrument and monitoring frequency will be used to monitor for airborne dust during site
acti11ities.
• Instrument:
• Activity:
• Monitoring Frequency:
Minirarn~ Model PDM-3
Direct Rpl-Tirne Air Monitoring
Monitoring will be performed continuously during on-site
activities. initially, Miniram'" readings will be recorded in
the field logbook: every hour. If continued monitoring docs
not indicate the presence of airborne dust a: or above 5
mg/m', readings may be recorded every rwo hours or
longer, based on the SHSO's review of the monitoring data
collected.
The PEL value of PCP is 0.5 mg/m'. No PEL values for 2,4-dichlorophenol or dioxin have been
established. Ii the dust concentration does not exceed 5.0 mg/m', the protection level will be downgraded
from Level C to Level D. Action levels for on-site dust contaminants are detailed below.
• General Action Levels
Situation: Concentration of airborne dust are below 5 mg/m'
Action: Continue investigation without respiratory protection a:
Level D, continue monitoring
Situation: Concentration of dust at or above 5 mglm'
Action: Notify SHSO; upgrade to Level C protection and continue
work unless otherwise specified
28
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
8.3.2 Organic Vapors
The following instrument and monitoring frequency will be used to monitor for organic vapors during
site activities.
• Instrument:
• Activity:
• Monitoring Frequency:
Pbotovac Microtip HL-200 equipped with a 10.6
electron voltage lamp
Direct Re.11-Time Air Monitoring
Monitoring will be performed continuoU£1y
during on-site activities. Initially, Microtip
readings will be recorded in the field logbook
every 30 minutes. If continued monitoring does
not indicate the presence of organic vapors,
readings may be recorded every hour or longer
based on the SHSO's review of tbe monitoring
data collected.
Individual concentrations .of organic vapors of concern will not be determined by field instrument.,
becaU£e mixtures of organic vapors may be encountered and real-time field survey instrumentation may
react to the total organic vapor mi~ture (by measuring positive interference, or giving a false-positive
reading). Action levels for organic vapors are detailed below.
• General Action Levels
Situation: Concentration at background concentration to 5 part., per
million (ppm) above background concentration
Action: Continue investigation without respiratory protection at
Level D; continue monitoring
Situ.a[jon: Concentration 5 ppm to 25 ppm above background
concentration
Action: Notify SHSO; upgrade to Level C protection and continue
work unless otherwise specified
Situation: Concentration 25 ppm co 500 ppm above background
concentration
Action: Notify SHSO; evacuate exclusion zone; consult HSD about
whether or not to continue site ac:tiviti~
29
I
I
I
I
I
8.4 USE Ah'D MAThTENANCE OF SURVEY EQUIPMD,'T
All personnel using field survey equipment will be briefed by the SHSO on its operation, limititions, and
maintenance. Maintenance and cal ibratioc will be perfonned in accordance with manufacturer guioel ine.s
by a designated individual familiar with the devices. Repairs, maintenance, and routine calibration of
these devices will be recorded io an equipment maintenance logbook that will be signed by the service
technician. The equipment maintenance logbook for each instrument will be kept in that instrument's
case.
Air monitoring equipment (such as the Miniram~) will be calibrated before work begins and at the end
of the work day. Only routine maintenance (such as changing batteries and fans) will be performed by I on-site personnel. Any additional ma.inteoaoce will be performed by a trained service technician.
I
I
I
I
I
I
I
I
I
I
I
8.5 HEAT~ MONITORING
Heat stress is a common and serious illness at hazardous waste sites. Occurrence of heat stress depends
oo such factors as environmental conditions, clothing, workload, an on-site worker's physical condition
and characteristics, and the type of PPE required for the work ~k. Some types of PPE are water
impenneable and heavy and may lead to potential beat stress conditions. Under heat stress conditions,
the body's expenditure of energy increases and reduces the efficiency of the body's normal heat exchange
meclianisms.
Heat stress may be of panicular concern when the dry-bulb air temperature exceeds 70'F. Depending
on the degree and nature of possible heat stress to be encountered on site, the SHSO will cboose from
the following heat stress control actions:
•
•
Provide adequate liquids to replace lost body fluids. These liquids may be water,
commercial mi~es combined with potJble water, or commercial liquids (such as
Gatorade¢).
Establish a work regimen that will provide adequate rest periods for cooling
down. This action may require additional shifts for workers or earlier or later
work schedules.
30
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
,I
I
•
•
•
•
Provide coolin£ devices, such as vortex tubes or cooling vests, to be worn
beneath protective garments.
Require removal of impermeable protective garments during rest periods .
Ensure that all rest periods are taken in a shaded rest area, if possible .
Regulate rest periods, and ensure that workers will oot be assigned other tasks
during rest periods.
• Notify all workers of health hazards and the importance of adequate rest, acclimatization, and proper diet; teach worl::ers to recognize beat stress and to conduct first aid to preYent beat stress.
The following chart contains general guidelines that can be used to pace hot-weather field worl:::
Wet Bulb Globe Temperature'
Degree;; Fahrenheit C'f)
Light Moderate Heavy
Work Worl: Work
Continuous Work 82.4 76.5 73 .4
75 percent worl:: and
25 percent rest e.ich hour 83.5 78.8 75.0
50 percent worl:: and
50 percent rest each hour 84.9 81.4 78.6
25 percent work and
75 percent rest each hour 86.4 84.4 82.4
• Temperature adjusted for worker wearing coveralls. Subtract 5 degrees for water impervious clothing. Source: Modified from ACGIR 1990.
Higher heat exposures than those shown above are permitted if workers have undergone medical
surveillance and if it bas been established that they are more tolerant of bot-weather work than an average
worker. Workers will not be permitted to continue work when deep body temperatures exceerl JOOA 'F.
If the SHSO determines that heat stress is a potential problem, body temperatures will be moni:ored
periodically to ensure tbat overheating does not occur.
31
I
i
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
1 1
I
9.0 SITE COllffROL
Work areas on or near the site will, depending on environmental monitoring, be divided into an exclusion
wne, a contamination reduction wne (CRZ), also known as decontamination wne, and a support zone.
Generally, the exclusion zone will be designated by barricade tape or traffic cones. Access to a
contaminated exclusion zone will be restricted to authorized personnel. A daily roster with the date of
each person's entrance into the contaminated wne; the person's name, signature, and organization; the
time of entry; and the time of exit will be kept for all personnel working in such an area. Any visitors
to the area must present proper identification and be authorized for site entry. Visitors must comply with
all provisions of this HSP. The SHSO will identify work areas that visitors or personnel are authorized
to enter and will enforce site control measures. The following sections discuss site SWPs, HSP
enforcement, and complaints.
9.1 COMMUNICATIONS
The following hand signals will be employed by site personnel in emergency situations or when verbal
communication is difficult.
Sie;nal
Hands clutching throat
Hands on top of bead
Thumbs up
Thumbs down
Arms waving upright
Gripping partner's wrist
9.2 SAFE WORK PRACTICES
Definition
Out of air or cannot breathe
Need assistance
Okay, I am all right, or I understand
No or negative
Send backup support
Exit area immediately
Safe Worl:: Practices (SWP) requirements for site activities include the following:
32
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
•
•
•
•
•
0
•
•
All site pen;onnel will enter a designated exclusion woe only through tile
contamination reduction corridor (CRC). All personnel leaving an exclusion
zone must eidt through the CRC and undergo the CRZ decontamination
procedure.
Only equipment necessary to complete sampling will be permitted within an
exclusion zone. All nonessential equipment will remain within the support zone.
All personnel will avoid contact with potentially contaminated substances .
Walking through puddles or mud and kneeling on the ground will be avoided
whenever possible.
Equipmem will not be placed on potentially contaminated surfaces .
Food and beverages will not be pennitted in the exclusion zone or CRZ .
Possession or use of tobacco products and application of cosmetics are also
prohibited in these areas.
Matches and lighters will not be permitted in the exclusion zone or CRZ.
During rest periods, all personnel will be required to observe each other for signs
of toxic exposure and heat stress. Indications of adven;e effects include, but are
not limited to, the following:
Changes in complexion and skin discoloration
Changes in coordination
Changes in demeaoor
Excessive salivation and pupillary response
Changes in speech patterns
Site personnel will inform each other of noovisual effects of illness, such as the
following:
Headache
Dizziness
Nausea
Blurred vision
Cramps
Irritation of eyes, skin, or the respiratory tract
The following sections describe safe work practices regarding sampling in trenches and confined spaces,
avoidance of trip and fall hazards, site actiYities near utility and power lines, avoidance of excessive noise
exposure, illumination, sanitation, and site housekeeping.
33
I
I
I
I
I
I
I
I
I
I
9.2.1 Sarnplini in Trenches and Confined Spaces
Sampling in trenches and excavations may pose physical hazards to personnel. The following precautions
will be taken when sampling is conducted in excavations or trenches.
•
•
•
•
Trenches will be inspected by a competent person before workers enter them . A confined space entry permit system will be used to prevent workers from entering unsafe trenches.
Workers will oot enter trenches alone. Standby personnel will always be present to respond in the event of an emergency.
The level of protection for entry personnel will be based on the results of air monitoring.
If the depth of the water present in trenches and excavations is 3 feet or above, sampling will not be conducted in those areas.
All site personnel entering confined spaces will observe requirements specified in ANSI Z 117 .1-1977 (or
tbe latest version). Each worker must complete a Confined Space Entry Permit for each confined space
to be entered. This form (Attachment E), must be approved by tbe SHSO before work in tbe confined
space begins. Before entry, a worker must have satisfactorily completed a confined space training
program and a Confined Space Entry Permit. It is not anticipated that site activities will require confined I space enl.r)·.
I 9.2.2 Avoidance or Trips and Falls
I Workers will be informed of any potential trip and fall hazards during regular h~th and safety meetings.
I
I
I
I
I
I
Whenever possible, trip and fall hazards will be eliminated or clearly identified with yellow caution tape.
9.2.3 Site Activities Near Utility and Power Lines
Site activities will proceed with caution in any area where historical data or instrument surveys indicate
the presence of utility lines (such as gas, telephone, and other lineS). All site activity locations will be
coordinated by the PRC project manager.
34
I
I
I
I
I
I
I
9.2.4 Avoidance or Ex=sive Noise E:i:posure
Workers will be protected from excessive noise exposure by means of equipment maintenance. noise
monitoring, and hearing conservation programs that comply with OSHA 29 CPR I 910.95. Hearing
protection will be required if the sound level continuously equals or exceeds 85 decibels on the A-
weighted scale or if the sound level exceeds 140 decibels regardless of the duration of exposure. Sound
level will be me.i.sured with a sound level meter during site activities. The decibel level will be measured
using a slow response setting on the A-weighted scale.
Ear inserts with a noise reduction rating of at least 26 decibels on the A-weighted scale or similar
equipment will be provided to PRC personnel. Such equipment will be worn during work ta,b involving
heavy equipment, internal combustion engines, or other sources of elevated noise levels.
I 9.2.5 Illumination
I
I
I
I
I
I
I
I
I
I
I
Outdoor work will not be performed after sull.let·or when a Jack of artificial or uatural illumination makes
outdoor work difficult.
9.2.6 Sanitation
Potable water, drinking cups, nonpot.able water, toilet facilities, washing facilities, and other sanitation
requirements will be provided in compliance with specifications of OSHA 29 CPR 1910. !20(n).
9 .2. 7 Site Housekeeping
Potentially hazardous wastes generated during site activities will be double bagged and drummed, if
necessary, and handled in accordance with Resource Conservation and Recovery Act (RCRA)
requirements. Nonhazardous waste and debris will be disposed of as standard mun.icipal waste.
35
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
9.3 HEALTH AND SAFETY PLAN El\'FORCEMEJ\'T
The SHSO will be responsible for enforcement of the HSP during on-site sampling activitieS. Personnel
who fail to follow HSP procedures will face disciplinary action that may, at a maximum, include
dismissal from the site.
At least one copy of this HSP will be available to all site personnel at all times. Any necessary changes
in HSP procedures will be made at the beginning of each work day by the SHSO.
9.4 COMPLAINTS
Personnel will be encouraged to report to the SHSO any condition, or practices that they consider
detrimental to their health or safety or that they believe are in violation of applicable health and safety
standards. Such complaints may be made·orally or in writing. Personnel who believe that an imminent
danger threatens human health or the eovimnment will be encouraged to bring the mauer to the
immediate attention of the SHSO for resolution.
10.0 DECONTAMINATION
Decontamination is the process of removing or neutralizing contaminants from personnel or equipment.
When properly conducted; decontamination procedures protect the worker from contaminants that may
have accumulated on PPE, tools, and other equipment. Proper decontamination also prevents transport
of potentially harmful materials to unaffected areas. Personnel and equipment decontamination
procedures are described in the following sections.
10.1 PERSONNEL DEC01''T AMINA 110]';
Minimal personnel decontamination is anticipated for the Koppers site because disposable PPE will be
used. If necessary, personnel decontamination will be completed according to the guidance given in the
"Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities" (N!OSH 1985).
Personnel and PPE will be decontaminated with potable water or a mixture of detergent and water.
Liquid and solid wa.,te_, produced during decontamination will be collected, dru=ed, and disposed of
36
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
pending on-site analysis. If accepted, decontamination wastes will be disposed at the POTW. If
decontamination wastes are not accepted at the POTW, a licensed disposal contractor will be hired for
decontamination waste removal.
The following decontamination procedures will be conducted if personnel decontamination is required:
•
•
•
•
•
•
Wash neoprene boots (or disposable booties) with a Liquioox'" or Alcooox'" solution, and rinse them with water. Remove and retain neoprene boots for reuse, if possible. Place disposable booties in plastic bags for disposal.
Wash outer gloves in a Liquinox'" or Alconox'" solution and rinse them in water. Remove outer gloves and place them in a plastic bag for disposal.
Remove the Tyvel:4 or Saranex'" suit and place it in a plastic bag for disposal .
Remove the air-purifying respirator, if used, and place the spent filter in a plastic bag for disposal. The filter may be changed daily or at longer intervals, depending on the use and application. Clean and disinfect the respirator with towelettes or a non-phosphate cleaning solution. Place it in a plastic bag for storage.
Remove inner gloves and place them in a plastic bag for disposal .
Thoroughly wash hands and face with water and soap .
Used, disposable PPE will be collected in 55-gaJlon drums and disposed of as municipal waste, unles,
otherwise spedfied. Further personnel decontamination procedures may be established as needed.
10..2 EQUIPMENT DECOl1ffAMINATION
Decontamination of all oondisposable sampling and field monitoring equipment used during site activities
will be required. The equipment dewntamination procedures described in the following sections are
based on guidelines appropriate for low-level contamination. When appropriate, Liquinox" or Alconox~
cleaning solutions and deionized water rinses will be used to decontaminate equipment. Wastewater from
equipment decontamination activities will be disposed of in the same manner as personnel decontamination
wastes, as discussed in Section I 0.1.
37
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
10.2.1 Sampling Equipment
Sampling equipment such as stainless steel spades, spoons, soil and groundwater samplers, and stainless
steel or aluminum pans will be decontaminated before and after each use. Distilled water will be used
fur the following sampling equipment decontamination procedures:
• Scrub the equipment with a brush in a bucket containing Liquinox~ or Alcooox<t
solution and potable, distilled water.
• Triple-rinse the equipment with distilled water, and allow it to air dry.
• Reassemble the equipment and place it in a clean area on plastic or aluminum foil. If aluminum foil is used, wrap the equipment with the dull side of the
aluminum foil toward the equipment.
10.2.2 Field Monitoring Equipment
The Miruram~ Model PDM-3 will be used for monitoring conceotr.ations of dust in the atmosphere. This
equipment will be cleaned daily by wiping it with isopropyl alcohol wipe. Also, the equipment will be
stored in a bag to minimize the exposure to the dust.
11.0 EMERGENCY CONTINGENCY PLM'NING
The SHSO will be notified of any on-site emergencies a.nd will be responsible for ensuring that
appropriate emergency procedures are followed. Standard emergency procedures to be used by site
personnel are described in the following sections.
11.1 L"iJURY IN THE EXCLUSION OR THE CONTAMINATION REDUCTION W.NE
In the event of an injury in the exclusion zone or CRZ, all personnel wiJI exit the exclusion zone and
assemble at the deco□:amination line, and the SHSO will be immediately notified of the event if
necessary. The SHSO will contact the HSD, and together they will evaluate the nature and extent of the I injury. The affected person will be decontaminatro to the extent practical before being moved to the
suppon zone. Appropriate first aid procedures will be performed, an immediate request for an ambulance
I
I
I
38
I
I
I
I
I
I
I
I
;
I
I
I
I
I
I
I
I
I
I
I
will be made (if necessary), and the designated medical facility will be notified (if necessary). Emergency
numbers for reaching an ambulance and the designated medical facility are provided in Section 11.5. No
personnel will re-enter the exclusion zone until the cause of injury or illness is determined and re-eotry
is considered safe. In case of severe injury, tl,e SHSO will implement procedures to minimize the
possibility of further injury. If the need to transport the patient to the medical facility supersedes the need
to decontaminate the patient, the medical facility will be notified that the patient bas not been
decontaminated before the patient arrives. Documentation requirements are outlined in Section 7 .2.
11.2 INJURY IN TIIE SUPPORT WNE
lf an injury occurs in the support zone, the SHSO will be notified immediately. Appropriate first aid will
be administered and, if necessary, the injured individual will be transported to the designated medical
facility. If the injury does not affect the safety or performance of site personnel, operations will continue.
Documentation requirements are outlined in Section 7 .2.
11.3 Fl.RE OR EXPLOSION
In the event of a fire or explosion at the site, the Morrisville Fire Department will be contacted at (919)
4-09-2156 as soon as possible, and evacuation of the site will begin immediately.
11.4 PROTECTIVE EQUIPMENT FAILURE
If any worker in the exclusion zone experiences a failure of protective equipment that affects his or her
personal protection, the worl:er and all coworkers will immediately leave the exclusion zone. Re-eotry
to the e~clusion zone will not be pennitted until the protective equipment has been repaired or replaced
and the cause of equipment failure has been determined and is no longer considered a threat.
39
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
11.5 EMERGENCY INFORMATION TELEPHONE hl.JMBERS
PRC will have a mobile telephone on site. Emergency telephone numbers not presented below can be
obtained by calling Kathy Schuessler of PRC at [phone].
11.6
Emergency Service
Morrisville Police Department:
Morrisville Fire Department:
Local Hospital:
Rex Hospital
4420 Lake Boone Terrace
Raleigh, NC 27(:IJ7
I..oca! Ambulance Service:
Poison Control Center:
National Response Center:
CHEMTREC Chemical Transportation
Emergency Center:
PRC (Atlanta office):
Robert Hutcheson, Project Manager:
Kurt Sorensen, HSD:
EPA Risi: Reduction Engineering
Laboratory (RREL)
Terry Lyons, EPA TPM:
HOsPITAL ROUTE DIRECTIONS
Tel1,pbone Number
911 or [phone]
911 or [phone]
[phone]
911
J-{800) 822-3232
J-[phone]
1-[phone]
[phone]
[phone]
(312) &56-8763
(513) 569-75&9
Before performing any site activities, PRC personnel will conduct a pre-emergency hospital run from the
site to the hospital. A map showing the hospital is provided in Figure 11-1. Directions to the hospital
are as follows: turn left out of the plant and go to Highway 54; turn right on:o Route 54 to Airport
40
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Bowevard to I-40; turn right onto 1--40 to Blue Ridge Road; turn left onto Blue Ridge Road and go to
Lake Boone Terrace. Toe hospital is located at 442 Lal::e Boone Terrace.
41
•