NCD003200383_19960305_Koppers Co. Inc._FBRCERCLA RD_Site Health and Safety Plan - Groundwater Remediation Revision 2.0-OCR

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SITE HEAL TH AND SAFETY PLAN
GROUNDWATER REMEDIATION
KOPPERS COMPANY SUPERFU!\'D SITE
MORRISVILLE, NORTH CAROLINA
October 1995
Revision 1.0 -January 1996
Revision 2.0 -March 1996
Prepared for:
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Beazer East, Inc.
436 Seventh Avenue
Pittsburgh, PA I 52 I 9
Rust Environment & Infrastructure
55 IO Six Forks Road
Raleigh, NC 27609
Project No. 34321.000
RECEIVED
MAR 18 1996
SUPERFUND SECTION
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34321.000
Site Safety and Health Plan
Review Sheet
Prepared By:
Maria Longcore
Rust E&I Regional Health Safety Specialist Review By:
Sherman Woodson
Certified Industrial Hygienist Review By:
Sherman Woodson
Quality Control Review By:
John Funk
u
0 Pre-Site Briefing
Rust E&I Subcontractor(s)
G·'.-ID.\U.\"Jf&SlJIASP\JJEAZER lfSP
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Koppers Company -Site Health and Safety Plan
TABLE OF CONTENTS
Chapter
1.0 INTRODUCTION ...................................................... 1 -1
I. I OBJECTIVES OF PLAN ........................................ I -I
1.2 PLAN DEVELOPMENT ......................................... I -I
1.3 SITE LOCATION AND BACKGROUND ........................... I -2
1.4 PROJECT DESCRIPTION ....................................... I -3
2.0 ORGANIZATION AND RESPONSIBILITIES ............................. 2 -1
2.1 PROJECT TEAM ORGANIZATION ............................... 2 - 1
2.2 PROJECT TEAM RESPONSIBILITIES ............................ 2 - I
3.0 EMPLOYEE HEALTH AND SAFETY TRAINING ......................... 3 -1
3.1 TRAINING PROGRAM ............................ : ............ 3 - I
3.2 MEDICAL SURVEILLANCE .................................... 3 - I
3.3 JOB EXPOSURE REPORT ...................................... 3 - 2
3.4 DOCUMENTATION ........................................... 3 - 2
4.0 POTENTIAL ENVIRONMENT AL HAZARDS .............................. 4 -1.
4.1 CHEMICALS OF CONCERN .................................... 4 - I
4.2 POTENTIAL IMP ACT ON HUMAN HEAL TH ...................... 4 - 4
4.3 PHYSICAL HAZARDS ......................................... 4 - 8
4.4 BIOLOGICAL HAZARDS ........................................ 4 - 9
5.0 GENERAL WORK RULES .............................................. 5 -1
6.0 STANDARD OPERATING PROCEDURES ................................. 6-1
6.1 PERSONAL PROTECTIVE EQUIPMENT .......................... 6 - I
6.2 SAMPLING ................................................... 6 - 3
6.3 ENVIRONMENTAL MONITORING .............................. 6 - 3
6.3.1 Heat Stress/Cold Stress .................................... 6 -4
6.4 SITE ACCESS CONTROL ....................................... 6 - 6
6.5 FIELD AUDITS ................................................ 6 - 6
7.0 WORK ZONES ........................................................ 7 -1 · .
7.1 SITE ORGANIZATION AND CONTROL .......................... 7 - I
7.2 EXCLUSION ZONE ............................ , ............... 7 - I
7.3 CONTAMINATION REDUCTION ZONE .......................... 7 - 2
7.4 SUPPORT ZONE .............................................. 7 -2
7.5 MODIFICATIONS TO SITE CONTROL ........................... 7 -2
8.0 DECONT AMINA TI ON ................................................. 8 -1
9.0 EMERGENCY PROCEDURES .......................................... 9 -1
9.1 FIRST-AID ................................................... 9 -I
9.2 EMERGENCY RESPONSE ...................................... 9 -I
G:\A/JMl/'.Vf.f.\VIASP\Bf:AZER.HSJ' October 1995
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Koppers Company -Site Health and Safety Plan
9.2.1 Pre-Emergency Planning ................................... 9 - I
9.2.2 Lines of Authority ........................................ 9 - I
9.2.3 Emergency Equipment/Facilities ............................. 9 - 2
9.2.4 Medical Emergencies ...................................... 9 - 2
9.2.5 Emergency Contact/Notification Listing ....................... 9 - 3
9.2.6 General Emergency Procedures .............................. 9 - 3
9.2.7 Personal Injury ........................................... 9 - 3
9.2.8 Chemical Exposure ....................................... 9 - 4 ·
9.2.9 Fire or Explosion ......................................... 9 - 5
9.3 EVACUATION ROUTES AND PROCEDURES ..................... 9-5
LIST OF APPENDICES
Appendices
A Work Zone Entry and Exit Log
B Job Exposure Report
C Site Safety Meeting Form
D Health and Safety Plan Field Modification Form
E Supervisor's Incident Report
F Atmospheric Monitoring Log
G Confined Space Entry Procedures
G:I.A.DAUN\H&SVIA.S/'IJJF.AZFJU/Sl' 11 October 1995
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Koppers Company -Site Health and Safety Plan
1.0 INTRODUCTION
1.1 OBJECTIVES OF PLAN
This document defines the health, safety, and environmental considerations for treatment plant
construction and groundwater sampling activities to be conducted at the Koppers Co., Inc.,
Superfund site, Morrisville, North Carolina. The vicinity map is shown in Figure I. Rust
Environment & Infrastructure (Rust) personnel will supervise the field activities and conduct other
activities on behalf of Beazer East, Inc. This document is required by Rust policies and procedures
and OSHA 29 CFR 1910.120. The basic requirements for the health and safety of the project
workers are delineated in the Corporate Health and Safety procedures. A copy of Rust corporate
health and safety procedures including updates will be available upon request from the Rust
Regional Health Safety Specialist. All on-site personnel will be informed about the pertinent
sections of this Site Safety and Health Plan (SSHP).
1.2 PLAN DEVELOPMENT
Rust is the prime contractor and is responsible for all site health and safety concerns associated with
hazardous and toxic materials as defined in 29 CFR 1910.120 (Hazardous Waste Operations and
Emergency Response Standard) and health hazards as defined by 29 CFR 1910.1200 (Hazard
Communication Standard). Rust will not be responsible for the means and methods of actual
construction operations; i.e., trenching and heavy equipment operation. All subcontractors
performing construction-related services, including heavy equipment operations, must comply with
29 CFR 1926 (OSHA Construction Standard).
The Project Manager must not allow work to begin at a hazardous waste site until a Site-Specific
SSHP has been provided to all field personnel. Prior to performing any on-site work, all Rust and
subcontract personnel must attend a site-specific briefing session, to be conducted by the Rust Health
and Safety Officer (HSO), on the potential site hazards and specific requirements of the SS!-IP. In
addition to the site briefing, all site personnel and authorized visitors must sign an entry/exit
log and provide current documentation of medical clearance, OSHA training, and respirator
fit-test. If any documentation is not available or out-of-date, the Site Health and Safety Officer
(HSO) will escort the non-authorized individual(s) from the work area. The overall
responsibility for the health and safety of project personnel lies with the Project Manager. The !-ISO
will be responsible for ensuring that the Site-Specific SSHP is complied with during site operations.·
The HSO will be certified in first aid/CPR/Blood borne Pathogens and be continuously present
during site operations. If there is any question whether an unplarmed occurrence on-site may
compromise health and safety, the HSO has the authority to interrupt operations and to remove all
personnel from the area. If practical, the Project Manager and Regional Health and Safety Specialist
(RHSS) should be consulted before any operation is interrupted. If work is stopped due to any health
or safety concern, immediate attention should be given by health and safety personnel, working
cooperatively with the Project Manager, to identify and correct the cause of concern as quickly as
possible. Any such incident should be fully documented by the I-ISO in a report to the RHSS and
Project Manager. In the event of a work stoppage, the project manager from Beazer East, Inc. must
be notified as soon as possible, and kept apprised of progress in resolving the incident until normal
operations are resumed.
G: \Arn fl NIH & Slll A.'il'I/JF.A ZfJUISP I - I October 1995
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Koppers Company -Site Health and Safety Plan
1.3 SITE LOCATION AND BACKGROUND
The Koppers Co., Inc. Superfund site is located at the intersection o:f Koppers Road and Highway
54, near Church Street in Morrisville, North Carolina. The Koppers site consists of two large ponds
and supporting out buildings. The property is located in an urban area and is surrounded by
residences and businesses.
Beazer East, Inc., the corporate successor to Koppers Co., Inc., entered into an Environmental
Protection Agency (EPA) Administrative Order for Remedial Design and Remedial Action in
December 1992. The following summary is taken from the Administrative Order: Koppers Co., Inc.
operated the site as a wood preserving facility from 1968 to 1975. The wood preservation process
involved the pressure injection of wood with pentachlorophenol and. was generally located in the
southeastern portion of the site. Koppers initially discharged the wastewaters from the wood
preserving process into the Fire Pond. Koppers later installed two unlined lagoons and discharged
the process wastewaters into those lagoons. The unlined lagoons were: later drained and the liquids
from the lagoons were sprayed over fields on the northern area of the site. The sludges from the
lagoons were spread over fields adjacent to the lagoon area.
Koppers owned the entire site until 1986, at which time Koppers sold a portion of the site. Koppers
retained portions of the site containing the Fire Pond, the lagoon area, and certain process areas. In
March 1989, the EPA placed the Koppers site on the National Priorities List (NPL). A Remedial
Investigation in 1989 confirmed the presence of site contaminants in groundwater, surface water,
surface soils, subsurface soils and sediments.
Contaminated soils in the area of the groundwater treatment system installation activities at the site
were previously removed. Surface waters are not of concern under this HASP. This HASP will only
address activities which are expected to impact contaminated groundwater and some contaminated
soils.
A list of contaminants of concern and the media in which they have been previously detected are
presented in Table 1-1.
TABLE 1-1
POTENTIAL CONSTITUENTS OF CONCERN
Constituent Medium in which
Detected
2,4-Dichlorophenol Groundwater and soil
Dioxin Groundwater and soil
Pentachlorophenol Groundwater and soil
G:\ADMIMH&-,WIAS/'VJF.AZEHHS/' 1 -2 October 1995
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Koppers Company -Site Health and Safety Plan
1.4 PROJECT DESCRIPTION
While on the work site, Rust personnel will be involved in several ac1:ivities. The duration of these
planned site activities is not known. Rust is the prime contractor and INCO will provide
subcontracting support for construction services. The specific activities are summarized as follows:
• The subcontractor, INCO, will install a carbon absorption treatment system for the
contaminated groundwater. A recovery well has been previously installed.
Installation of the treatment system will involve shallow trenching to connect and
bury utilities and pipelines for remediation system connections. The subcontractor
will not be required to enter this confined space in the trenches. If anticipated
situations change and the contractor is required to enter the trench, the contractor is
responsible for satisfying confined space entry requirements addressed in Appendix
F of this plan. The contractor is responsible for the safe means of operating heavy
equipment and is required to comply with applicable OSHA construction safety
standards.
• Rust will oversee the installation of the treatment system to ensure that installation
specifications are met.
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Rust will begin operations of the remediation system when installation is complete .
Rust will collect influent and effluent samples. Adjustments to the system will be
made as necessary.
Rust will oversee the excavation of soil from three locations. !NCO will excavate
the soils using heavy equipment. Approximately two to three waste truck loads of
soil will be taken off-site for disposal. The rest of the excavated soils will be
stockpiled on-site.
G:I.A.DMIMH&~iHA.\1'\HEAZF.R.IISI' I - 3 October I 995
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Koppers Company -Site Health and Safety Plan
2.0 ORGANIZATION AND RESPONSIBILITIES
2.1 PROJECT TEAM ORGANIZATION
Title Name Phone
Project Manager John Funk, P.E.
Dennis Jones
(919) 676-5 I 86
[phone]
[phone]
[phone]
Site Technician/HSO
Regional Health and Safety Specialist
Medical Director
Sherman Woodson, CIH
Elayne Theriault, M.D.
2.2 PROJECT TEAM RESPONSIBILITIES
This section lists specific personnel who will be assigned for control of project activities and
assurance of health and safety.
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Project Manager -The Project Manager is the senior contractor representative and
reports to upper level management and the Beazer East representative. Assigned
responsibilities include the authority to direct daily site work activities, respond to
emergency situations and assume total control over all site activities. The Project
Manager is responsible for the preparation, organization, and review of the project,
including the SSHP and is responsible for the selection, assignment, and conduct of
the site organization. The Project Manager obtains the necessary site access
authorizations, ensures that the appropriate plans are in place to support site work
activities, briefs field team members, coordinates with appropriate regulatory
officials, serves as liaison with the Beazer East representative, coordinates all
activities of site personnel and coordinates preparation of any final reports and
supporting documentation.
Certified Industrial Hygienist (CJH) -The Rust E&l southeast Regional Health and
Safety Specialist (RHSS) is a CJH with experience in hazardous waste site operations
and is responsible for the development, implementation, and oversight of the Rust
Corporate Safety Program and this SSHP. In addition to authorizing this SSHP, all
modifications to this SSHP must be submitted in writing to the RHSS and approvals
obtained prior to implementing changes.
Health and Safety Officer (HSO) -This individual reports to the Regional Health
Safety Specialist and the Project Manager and is responsible for all aspects of health
and safety on the job site. He/she has the authority and responsibility for stopping
site work should activities jeopardize the health and safrty of workers or the public.
Additional responsibilities include selection of protective equipment and apparel,
maintenance of protective equipment and clothing, control of entry and egress from
the work area, coordination of the project safety and health program with advisory
personnel, confirmation of workers' suitability for performance of activities,
environmental monitoring for hazardous contaminants, overview of site work
hazards, enforcement of the requirements of the SSHP, inspection of the work site
G:IA/JAflNVf&.'illlA.~1'1J!F.AZF.R.HSI' 2 - I October 1995
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Koppers Company -Site Health and Safety Plan
on a periodic basis to assure compliance with the safety and health requirements,
conduct of emergency response activities, and coordination of medical care. The
HSO is certified in first aid/CPR by the American Red Cross or equivalent agency,
and will be continuously present during site operations.
• Other Project Personnel -All other personnel assigned as site workers, laborers,
technicians, equipment operators, or other classifications will be selected based upon
the specific project requirements. These individuals will follow proper
decontamination procedures, equipment operation, and sample collection and
shipment, and documentation of field activities. Project personnel are responsible
for the conduct of all assigned tasks in a safe manner which complies with the SSHP
and are responsible for notification of the Project Manager, the Site HSO, or other
responsible personnel in the event of unsafe conditions.
INCO will be working on-site as a subcontractor to Rust. INCO's prime duties include
installing the treatment remediation system. This will involve shallow trenching to bury
underground pipes. INCO will also conduct soil excavation activities under the supervision
of Rust.
It is not anticipated that a Certified Health Physicist (CHP) or Certified Safety Professional
(CSP) will be required for the anticipated work activities addressed by this SSHP. In the
event that unanticipated field situations arise and ·additional specialized personnel are
required, a CHP and/or CSP will become part of the project team and the SSHP will be
modified to incorporate these changes.
G:\AD,\f/N\ll&S\HA.'il'\JJEAZF.R.HSI' 2-2 October 1995
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Koppers Company -Site Health and Safety Plan
3.0 EMPLOYEE HEAL TH AND SAFETY TRAINING
3.1 TRAINING PROGRAM
To remain in compliance with OSHA regulations, all personnel whose duties include participation
in job-related activities on hazardous waste sites must be able to document "a minimum of 40 hours
of initial instruction off the site and a minimum of three days of actual field experience under the
direct supervision of a trained, experienced supervisor."
Prior to arrival on-site, it will be verified that all employees and the subcontractor, INCO, meet the
requirements of 40-hour pre-assignment training in accordance with 29 CFR 1910.120 (e).
Documentation will be included in project records for each employee certifying dates of 40-hour
OSHA training attendance or equivalent, and any subsequent annual 8-hour refresher training. All
I-ISO personnel will have an additional 8 hours of hazardous materials supervisory training.
Site-specific training will be carried out by the site I-ISO prior to site entry. This will consist of a
review of the specific hazards of concern, risks, symptoms of exposure, and an overview of the
SSHP to include delineation of work zones, access, decontamination protocols, safety procedures,
and emergency contacts. Any personnel not initially cleared for site entry will be provided a similar
briefing at the site by the I-ISO before admittance into the Exclusion Zone is permitted.
3.2 MEDICAL SURVEILLANCE
Rust personnel and subcontractors who are required to work in areas where the potential for toxic
exposure exists and who may have to wear personal protective clothing and equipment shall have
passed a pre-assignment and/or periodic medical examination as required in 29 CFR 1910.120 (f).
Additional medical testing may be required by the Corporate Health and Safety Manager in
consultation with the company physician if an overexposure or signs and symptoms of exposure
occur.
Contractors shall maintain the medical records for their own employees, but shall provide the I-ISO
with written documentation certifying that each employee at the site has met the requirements of the
Medical Surveillance Program. This documentation will be provided before the first day of work
for each employee assigned to the site. The pre-assignment and annual examinations are essentially·
the same in content and will include:
• An updated medical and occupational history
• A physical examination
• Blood and Urine laboratory tests
• Chest X-ray
• Electrocardiogram
• Pulmonary function tests
• Audiometry
• Visual acuity test
G:\AIJ.\f!MH&~VIASl'\BEAZFJll/S/' 3 -I October 1995
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Koppers Company -Site Health and Safety Plan
In addition to the pre-employment, annual, and exit examinations, the Rust Medical Surveillance
Program includes provisions for medical examinations in the event of overexposures. Accidents
may warrant special medical considerations. All medical records are maintained with the Rust
Medical Director and are accessible, within the limits of the Privacy Act, through written requests
to the Rust RHSS.
3.3 JOB EXPOSURE REPORT
The HSO will complete a Job Exposure Report Form (Appendix B) and deliver it to the Rust RHSS
at the termination of field activities on the site, or at the ends of discrete phases of prolonged field
activities. The intent of Job Exposure Reports is to provide documentation of actual and/or
suspected job-related exposures for use by the Rust Medical Director in making decisions on
appropriate periodic examination procedures.
In addition, all Job Exposure Reports are reviewed by the Rust RHSS to ensure that any actual
exposures are adequately defined to provide appropriate guidance to the Rust Medical Director.
3.4 DOCUMENTATION
Rust will maintain logs and reports sufficient to document the implementation and execution of the
personnel protection program. This documentation will consist of medical surveillance files, training
files, daily logs and accident reports, and will be submitted as attachments to the Daily Construction
Quality Control Reports. The necessary Rust documentation forms are in Appendices A through G.
Medical Surveillance
Confidential medical surveillance files are maintained by the Rust Medical Director. These files
document employee participation in the medical surveillance program and fitness to work on
hazardous sites. Access to these files and records is controlled by the Rust RHSS.
Training
Documentation of employee training is maintained in Rust Health and Safety files under the
direction of the Rust RHSS. These files document employee attendance, level of training, and
follow-up or refresher instruction.
Work Logs
Daily work logs will be maintained by the site HSO. Copies of daily logs will be forwarded to the
Beazer East representative on request. The daily log will contain:
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Date,
Area(s) or site(s) worked,
List of employees by area and hours exposed,
Personal protective equipment utilized by employees,
Results of monitoring tests,
Description of special or unusual events or incidents, incl.uding all first aid treatments
G:\ADAU,\'\H&.\1l!ASl'Vlf:AZF1~.R\1' 3-2 October I 995
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Koppers Company-Site Health and Safety Plan
not otherwise reportable.
Daily work logs will be checked and approved by the site HSO. Any incident resulting in a work
stoppage will be fully documented in a report prepared by the site HSO and submitted to the RHSS.
Accident Reporting
In addition to descriptions in the daily log and work stoppage reports, any accident and/or chemical
exposure incident will be investigated, analyzed and documented in an accident investigation report
submitted to the Rust RHSS. This report, prepared by the site HSO in consultation with the Rust
RHSS, will contain a full description and analysis of the incident.
Formal accident reports will be prepared for any diagnosed illness or injuries that result in a lost
work day or fatality. The accident report will identify all contributing causes and recommend future
hazard control measures to reduce the risk of recurrence.
G:lAD.'.fJNVi&S\HA.\1'\BEAZf:R.HSP 3 - 3 October 1995
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Koppers Company -Site Health and Safety Plan
4.0 POTENTIAL ENVIRONMENT AL HAZARDS
4.1 CHEMICALS OF CONCERN
Site history indicates the possibility for exposure to semi-volatile organic compounds and dioxins.
Previous analysis of information confirms groundwater and soil contamination. Groundwater and
soil contamination may pose some health hazards from skin contact, ingestion, and inhalation. Table
4-1 presents a variety of exposure limits applicable to workplace exposures for the known chemicals
of concern at this site. The known chemicals of concern were derived from previous investigations
that were conducted at the site. The American Conference of Governmental Industrial Hygienist
(ACGIH 1994-1995) Threshold Limit Values (TL V) for the work environment are given for each
chemical of concern. The Threshold Limit Value-Time Weighted Average (TWA) is the time-
weighted average concentration for a normal 8-hour work day and a 40-hour work week to which
nearly all workers may be repeatedly exposed, day after day, without adverse health effects. The
Short-Term Exposure Limit (STEL) is the concentration to which workers can be exposed
continuously for a short period of time without suffering from 1) irritation, 2) chronic or irreversible
tissue damage, or 3) narcosis of sufficient degree to increase the likelihood of accidental injury,
impairment of self-rescue, or materially reduce work efficiency provided that the daily TL V-TW A
is not exceeded. It is not a separate and independent exposure limit but rather supplements the TL V-
TW A where there are recognized acute effects from a substance whose toxic effects are primarily
of a chronic nature. A STEL is set only when there are recognized toxic effects from acute
overexposures in either humans or animals. The STEL is a 15 minute TWA which should not be
exceeded at any time during a workday even if the eight hour TWA is not exceeded. Exposures
above the TWA up to the STEL should not be longer than 15 minutes, should not occur more than
four times a day and there should be at least 60 minutes between exposures in this range. The TL V
"Ceiling" is the concentration that cannot be exceeded during any part of the working exposure. The
Occupational Safety and Health Administration (OSHA) Permissible Exposure Limit (PEL) values
are presented either as an eight hour TWA, 15-minute STEL, or Ceiling (Ceil) limit. The
Immediately Dangerous to Life and Health (IDLH) value is the maximum concentration from which
one could escape within 30 minutes without escape-impairing symptoms or irreversible health
effects.
ll:\A/JADN\Jl&!lVIASP\BEAZER.HSP 4 - 1 October I 995
Ciiiliil liiiiiil iiiii liliiii1
Contaminant
2,4-Dichlorophenol
Dioxins/Furans
Pentachlorophenol
Al = Confirmed Human Carcinogen
A2 = Suspect Human Carcinogen
A3 = Animal Carcinogen
G:UD.IAJMH&:SIHASl'\Rf:4ZF.R.HSl'
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TLV-TWA
Koppers Company -Site Health and Safety Plan
TABLE 4-1
EXPOSURE LIMITS
TLV-STEL PEL-TWA PEL-STEL
0.5 mg/m3 , skin 0.5 mg/m3, skin
TP = Total Particulate
---= Not Available
-N.E. = Not Established
4-2
Ca = Carcinogen
Ceil = Ceiling
October 1995
IDLH
2.5 mg/m3
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Koppers Company-Site Health and Safety Plan
Any potential for exposure to chemical hazards which may occur during the performance of
project activities will be evaluated on a task by task basis. Any potential exposure of project
personnel to chemical hazards will be reduced to the minimum by characterization sampling as
necessary prior to task performance. The results of these sampling operations will be used for
the determination of potential exposure levels and protective measures will be commensurate with
the specific chemical substance, potential pathways of exposure, work activities to be performed
and physical condition of the worker. The following general exposure considerations were used
for guidance:
Respirable Chemical Hazards. Prior to personnel entry into areas of concern, air sampling
will be performed in accordance with approved protocols for the target contaminant. To
the extent possible, engineering controls (such as increased ventilation flow) and
administrative controls will be utilized to reduce potential personnel exposures, when
necessary. Should additional protection be necessary, appropriate respiratory protective
equipment will be utilized.
Dust monitoring will be performed during soil excavation activities to determine the total
airborne dust concentrations. A dust control plan will be implemented to minimize the
airborne dust during soil excavation activities.
Chemical Absorption Hazards. Any potential for skin conitact with chemical materials
which may constitute a hazard for absorption through the skin will be identified on a task
by task basis. Should survey or sampling results indicate the potential for levels of
materials which could constitute absorption hazards, appropriate use of protective garments
such as coveralls, rubber boots, and gloves will be utilized.
Chemical Ingestion Hazards. To minimize any potential for ingestion of hazardous
chemical materials during conduct of work activities, eating, drinking, smoking and
chewing will be forbidden in any work area. In addition, controls to assure that personnel
utilize appropriate protective measures and decontamination methods will be specified.
Chemical Injection Hazards. Should the potential for injection of chemical hazardous
materials due to penetration of sharp objects be identified, the use of protective gloves and
steel shank protective safety shoes will be required. In addition, good housekeeping
practices will be maintained to minimize exposure to chemical hazards and potentially
hazardous sharp objects.
G: \A l)Af!MH & ,W IASl'\JJF.AZF,R, /fS/' 4-3 October 1995
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Koppers Company-Site Health and Safety Plan
4.2 POTENTIAL IMPACT ON HUMAN HEALTH
Site data indicates that employee exposure to semi-volatile organic contaminants and dioxins is
possible. Site compounds may be a hazard upon contact with the skin or eyes. In addition to skin
and eye contact, contaminants may be inhaled or ingested. Proper PPE will be worn to protect
employees from inhalation and contact. During dusty conditions, dust goggles and air-purifying
respirators utilizing HEPA/Organic Vapor combination cartridges will be mandatory. Other
relevant health-based information that applies to this health and safety plan or to the employee's
right-to-know is discussed in the following contaminant-specific toxicity summaries.*
In October of 1993, soils were analyzed for a variety of dioxins and furans in the area of the Fire
Pond and Medlin Pond. The highest concentration of a dioxin or furan compound detected during
previous soil sampling at the site was the dioxin OCDD at 0.400 mg/kg. Lower concentrations of
this and other dioxin and furan compounds were detected in four additional soil samples at the Fire
Pond and Medlin Pond. The 8-hour exposure limit for one of the conitaminants, pentachlorophenol,
is 0.5 mg/m3 (Exposure limits do not exist for the other contaminants).
The highest concentrations of the contaminants detected at the site in previous soil investigations
are considerably less than I% (I 0,000,000 ppb = I 0,000 ppm= I 0,000 mg/kg= I%). The site health
and safety officer from Rust will monitor total airborne dust concentrations with a Miniram dust
monitor, or similar instrument. An action level of 0.5 mg/m3 of total dust has been set for this site.
It is believed that by selecting an action level equal to the exposure limit of pentachlorophenol that
employee exposure for other contaminants should be minimal based on the concentrations and
locations where contaminants were detected. When the total dust concentration is 0.5 mg/m3 or
greater during soil excavation activities, all personnel in the exclusion zone will be required to wear
a full-face air purifying respirator, equipped with HEPA respiratory cartridges. If concentrations are
sustained below the action level of0.5 mg/m3, respiratory protection will no longer be required. Soil
excavation activities are expected to begin in "modified" Level D, with Tyvek or similar disposable
clothing work to minimize contact of skin with dust and soil. Nitrile gloves will also be worn during
soil excavation activities. Control of airborne dust can be gained by following the dust control Plan.
• The compounds listed are those identified in the previous sampling events at the sites .
(i:vl.DMJNVl&SlHASl'\REA.ZE.R.HSP 4-4 October 1995
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INDUSTRIAL USES:
EXPOSURE LIMITS:
PHYSICAL DATA:
Description:
Solubility:
Incompatibilities:
Boiling Point:
Melting Point:
Vapor Pressure:
Specific Gravity:
Ionization Potential:
Flammability:
Flash Point:
LEL:
UEL:
Respirator Cartridge
Breakthrough Time:
HNu Sensitivity:
OVA Sensitivity:
HUMAN TOXICITY:
Systemic Effects:
Carcinogenic Effects:
Ci:I.A.DMIMH&Sll!ASl'\BF.AZJ-:R.1/SI'
Koppers Company -Site Health and Safety Plan
2,4-DICHLOROPHENOL
(C6H4Cl20 2, 4-DCP)
2,4-Dichlorophenol is a key intermediate in the synthesis of the
herbicide (2,4-Dichlorophenoxy) acetic acid. It is generally prepared
by chlorination of phenol.
TL V: Not established
PEL: Not established
IDLH: Not established
Needle-like crystals; strong medicinal odor
Soluble in carbon tetrachloride, benzene, and chloroform
Not known
210°c
45°c
0.075 mm Hg@25°C
1.383
Not known
Not known
Not known
Not known
Not known
Not known
Not known
Not known
Inhalation:
Ingestion:
External Contact:
4-5
Produces eye, nose, and throat irritation
Toxic by ingestion
Very strong irritant to tissue
Not known
October I 995
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Koppers Company -Site Health and Safety Plan
INDUSTRIAL USES:
EXPOSURE LIMITS:
PHYSICAL DAT A:
Description:
Solubility:
Incompatibilities:
Boiling Point:
Melting Point:
Vapor Pressure:
Specific Gravity:
Ionization Potential:
Flammability:
Flash Point:
LEL:
UEL:
Respirator Cartridge
Breakthrough Time:
HNu Sensitivity:
OVA Sensitivity:
HUMAN TOXICITY:
DIOXINS/FURANS
(Polychlorinated dibenzofurans; PCDF)
Dibenzodioxins occur as 75 different isomers.
TLV:
PEL:
IDLH:
Not established
Not established
Not established
Generally a white crystalline solid
Not known
Not known
Not known
Not known
Not known
Not known
Not known
Not known
Not known
Not known
Not known
Not known
Not known
Not known
Systemic Effects: Inhalation: Not known
Not known
Not known
Ingestion:
External Contact:
Carcinogenic Effects: Not known
G:UDMJ/',Vl&.\VIASPIREAZER.HSI' 4-6 October 1995
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INDUSTRIAL USES:
EXPOSURE LIMITS:
PHYSICAL DAT A:
Description:
Solubility:
Incompatibilities:
Boiling Point:
Melting Point:
Vapor Pressure:
Specific Gravity:
Ionization Potential:
Flammability:
Flash Point:
LEL:
UEL:
Respirator Cartridge
Breakthrough Time:
HNu Sensitivity:
OVA Sensitivity:
HUMAN TOXICITY:
Systemic Effects:
Carcinogenic Effects:
G:\ADA!/MJl&,\VIAS/'VIEAZF.R.HSP
Koppers Company -Site Health and Safety Plan
PENTACHLOROPHENOL
(C2Cl5OH, PCP)
Pentachlorophenol is used as an insecticide for termite control, as
a pre-harvest defoliant, as a general herbacide, and as a wood
preservative.
TLV:
PEL:
IDLH:
0.5 mglm3 TWA, Skin
0.5 mglm3 TWA, Skin
2.5 mglm3
Colorless to white, crystalline solid with a benzene-like odor
Miscible in alcohol, ether, benzene, and cold petr ether
Strong oxidizers
588°F
374°F
0.0001 mm Hg @ 20°C
1.98
NIA
Noncombustible solid
NIA
NIA
NIA
NIA
NIA
NIA
Inhalation: Produces eye, nose, and throat irritation
Produces anorexia, sweat, an increase then.
decrease in respiration, blood pressure, and
urinary output, and fever
Ingestion:
External Contact:
4-7
Produces headache, dizziness, nausea,
vomiting, chest pain, and high fever
None
October 1995
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Koppers Company -Site Health and Safety Plan
4.3 PHYSICAL HAZARDS
In addition to the potential exposure to chemical hazards, various risks are associated with physical
hazards during site work activities. For the project, these are identified on a task by task basis in
Table 4-2.
TABLE4-2
PHYSICAL HAZARDS
Task Hazard Description Prevention/Monitoring
Techniques
General Slip, trip, falls From various debris Ensure adequate lighting,
at site, cluttered buddy system, awareness,
conditions, and good housekeeping
equipment. practices.
General Pinch points, sharp From "tight" spaces Ensure clear work area,
comers, restricted and clearances; risk analysis, good
movement objects and !housekeeping, move
components. unnecessary equipment,
utilize buddy system.
General Heat Stress/Cold Associated with Ensure adequate
Stress protective garment work/rest schedule;
use, respiratory buddy system. Monitor
protection and per section 6.6.3.
exposure.
General Heavy Equipment Associated with Ensure adequately trained
Operations waste handling, personnel operate
trenching. equipment, stay clear of
equipment.
Exterior Work Inclement weather High winds, Restrict working in
lightning, hail, etc. exposed areas, seek
shelter, terminate work
activities.
Mobilization/ Heavy equipment From various Ensure adequate lighting,
Demobiliza-operation, trips and equipment being buddy system, awareness,
tion falls, heavy lifting moved around the and good housekeeping
site and in and out of practices. Exercise care
trucks. when Ii fting heavy
objects.
G:\A/l.\fJN\Jl&.\11/ASP\BE.AZER.HSP 4-8 October 1995
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Heavy Lifting Physical injuries to Associated with Ensure that proper lifting
personnel improper lifting techniques are used;
techniques and lifting multiple personnel or
a load that is too mechanical devices
heavy. should be used to lift very
heavy objects.
Uneven Slip, trip, falls From uneven or Ensure adequate lighting,
Terrain unexpected terrain. buddy system, awareness,
and good footing.
General Fire Associated with Minimize handling of
handling of materials, no burning or
flammables. open flame, segregate
materials.
4.4 BIOLOGICAL HAZARDS
A number of biological hazards may be encountered during general work at the site. These include
the following:
Insects -Encounters with stinging/biting insects and spiders carry a potential for negative
health impact, particularly in sensitive individuals. Conditions may occur which can include
death. In addition, ticks may be found throughout the area and are noted to carry serious
diseases when in an infective state. General first aid procedures must be consulted for initial
treatments when the potential for encounters exist.
Animal Bites -There is a potential for animal bites during field activities. Any animal bite
(snakes, dogs, cats, etc.) must be evaluated at a medical treatment facility. Initial on-site
treatment should be limited to cleansing the wound.
Poisonous Plants -Site operations may involve encounters with poison oak, poison ivy, and
poison sumac. Contact with these plants may present symptoms from mild to severe in
susceptible individuals. Typically, a blistering dermatitis will appear. Small areas may be
treated with a drying lotion (Calamine, Caladryl, etc.). A physician must be consulted when
large areas of body surface are involved. It is important to identify these plants as a measure.
to avoid contact.
G:\Af)M/N\H&.!>1HASi'lllf:AZER.H!:,1' 4-9 October 1995
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Koppers Company-Site Health and Safety Plan
5.0 GENERAL WORK RULES
The following general operating procedures will be followed by all field personnel. These operating
procedures are designed to reduce the risks of inadvertent or accidental chemical exposure or injury
during field operations.
Personal Precautions
Be familiar with all standard operating safety procedures and adhere to all instructions and
requirements in the site-specific SSHP.
Eating, drinking, chewing gum or tobacco, smoking, or any practice that increases the
probability of hand-to-mouth transfer and ingestion of material is prohibited in the Exclusion
and Contamination Reduction Zones. However, a supply of cold water and disposable cups
will be located in the decontamination area such that employees will have access to water
with only removal of gloves, hat, and respirator where used. After leaving the Site,
employees will wash their face and hands before drinking and/or eating.
Contact lenses will not be worn in the Exclusion and Contamination Reduction Zones.
Hands and face must be thoroughly washed upon leaving the work area. Whenever
decontamination procedures for outer garments are in· effect, the entire body should be
thoroughly washed as soon as possible after the protective garment is removed.
No facial hair which interferes with a satisfactory respirator fit of the mask-to-face-seal is
allowed on personnel required to wear respirators.
Avoid contact with contaminated or suspected contaminated surfaces. Whenever possible,
avoid wading through puddles, pools, mud, etc. Avoid kneding or sitting on the ground,
equipment or drums.
Personal articles are prohibited in the Exclusion and Contamination Reduction Zones.
Medicine and alcohol can exacerbate the effects from exposure. to toxic chemicals. Alcoholic·
beverage intake should be minimized or avoided during off-work hours during field
operations where the potential for absorption, inhalation, or ingestion of toxic substances
exists unless specifically approved by a qualified physician. Do not work when ill.
Operational Requirements
All personnel going on the site will be adequately trained and thoroughly briefed on
anticipated hazards, equipment to be worn, safety practices to be followed, emergency
procedures, and communications.
G:UDMJMff&S\HASl'IJJEAZF.R.HS/' 5 -1 October 1995
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Koppers Company-Site Health and Safety Plan
Respiratory protective devices and/or protective clothing appropriate to the designated levels
of protection will be worn by all personnel going into areas designated for wearing protective
equipment.
Personnel on the site will use the buddy system when wearing respiratory protective
equipment.
Visual and/or voice contact will be maintained between paired individuals working at the
site. Entry team members will remain close together to assist each other during emergencies.
During continual operations, workers on the site will act as safety backup to each other.
Personnel off the site will provide emergency assistance.
Personnel should practice new or unfamiliar operations prior to performing the actual
procedure.
G:\AD.\fl.\'Vf&.\11/ASl'I/JF,,IZJ,Jl.HS/' 5-2 October 1995
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Koppers Company-Site Health and Safety Plan
6.0 STANDARD OPERATING PROCEDURES
6.1 PERSONAL PROTECTIVE EQUIPMENT
Rust has written PPE and respiratory protection programs and are available for review from the
RHSS upon request. Respiratory protection requirements for protection from potential exposure to
organic vapors are contained in Table 6-1. The trigger value for respiratory protection is I ppm
above background for organic vapors, and 0.5mg/m3 for total airborne dust concentrations. If vapor
concentrations in the breathing zone exceed the trigger value or airborne dust concentrations exceed
the action level and consistently remain above this level for 5 minutes or longer, all sampling
personnel will adhere to the provisions of respirator protection listed under Table 6-1. More
stringent levels of respiratory protection and protective clothing may be required by site I-ISO.
Exposure to particulates is not expected to be a concern since the contaminants are only in the
groundwater for the activities covered by this SSHP.
It is the responsibility for site personnel to clean, maintain, inspect, and properly store their PPE,
including respirator. All site personnel will have been fit-tested for respirators before arriving on-
site.
TABLE 6-1
RESPIRATORY PROTECTION TRIGGER LEVELS
OVA Reading
Up to I ppm or less than 0.5
mg/m3
I to 10 ppm
IO to 25 ppm or upon
eye/nasal irritation and/or
splash conditions, or
0.Smg/m or greater of dust
Over25 ppm
Non-Respiratory PPE
Response
No respiratory protection
Half-face air-purifying respirator with
HEP A/Organic Vapor cartridges
Full-face air-purifying respirator with
HEP A/Organic Vapor cartridges
Stop work and evacuate the area. Resume
work when below 25 ppm.
During high-noise conditions, (;,_ 90 dBA) including operation of the certain heavy equipment,
hearing protection must be worn within a 50 foot radius of the noise source. A hard hat must be
worn whenever overhead hazards exist. The following items must be available for all site personnel.
• Saranex Suits (Splash Conditions)
• Tyvek Suits (Dusty Conditions)
• Safety Boots (Steel Toe)
• Nitrile Gloves
G:\ADWMJl&,\1HASP\BEAZFR.HSI' 6 - I October 1995
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Koppers Company -Site Health and Safety Plan
• Work Gloves (protect integrity of chemical resistant gloves)
• Ear Plugs
• Hard !-lat
• Fire Extinguisher
• Decon Sprayers
• Drink Cooler
• Eyewash (15 Minute)
• Chemical Splash Goggles (Decon Operations)
• Goggles (Dusty Conditions)
• First-Aid Kit
Bloodborne Pathogen Kit
Additional Operating Procedures
The following are miscellaneous operating procedures to be followed at the sites:
Material Handling Procedures: All materials, including soil and groundwater are to be
handled in a safe manner, following the provisions of this plan.
Drum/container handling procedures: All personnel are to use caution and wear PPE when
opening drums or containers. If available, open the bung cap first and determine the vapor
headspace concentration with an OVA. Use appropriate respiratory protection outlined in
this plan if vapor concentrations dictate. Never open a drum of unknown contents.
Confined Space Entry: The possibility exists that tasks involving trenching to lay the
underground pipes for the remediation system may involve confined space entry. If the
work requires confined space entry, personnel are to follow the Confined Space Entry
Procedures found in Appendix G.
Electrical Safety: Any electrical equipment used on-site must be equipped with ground-fault
protection. If maintenance on electrical equipment is required, OSHA Lock-out,Tag-out
procedures must be followed.
Excavation Safety: Shallow excavation is expected for the trenching operations. All
applicable OSHA construction safety regulations, including those for shoring where
applicable, are the responsibility of the subcontractor, !NCO.
Machine Guarding: Machine guarding is not expected to be an issue on this site and is not
addressed by this plan.
Fall Protection: High climbing is not expected for these field activities and fall protection is
not addressed by this plan.
Illumination: Work activities are expected to be conducted during the daytime and
illumination is not addressed by this plan.
G:\A/JMIMH&.\1J/ASP\REAlf1lHSP 6-2 October 1995
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Koppers Company-Site Health and Safety Plan
Sanitation: Common sense, everyday sanitization practices should be carried out during the
work activities. The nearest restroom facilities should be located prior to the start of any
field work.
Engineering Controls: No additional engineering controls are expected.
Radioactive Material,s: Contact with radioactive materials is not expected during the site
work activities. This SSI-IP does not address radioactive materials. If suspected materials
are encountered, personnel will vacate the area and discuss the situation with the project
manager and the RI-ISS.
6.2 SAMPLING
Sampling activities will include collection of water from the remediation system on the influent and
effluent ends. Post-excavation soil samples will be collected by Cummings Riter.
6.3 ENVIRONMENTAL MONITORING
Environmental Monitoring will be conducted for organic vapors, flammables, and for heal and cold
stress as described on the following pages. All environmental monitoring data will be submitted to
Beazer and the Rust E&I RI-ISS for review upon completion of work activities.
Organic Contaminants
During site sampling operations, the I-ISO will san1plc environmental conditions for organic vapors
with a direct reading instrument (OVA). At a maintained reading of I ppm or greater in the
breathing zone above background, all personnel within the exclusion zone must wear respiratory
protection. For breathing zone concentrations of I to IO ppm, half-mask air-purifying respirators
equipped with HEP A/organic vapor combination cartridges must be worn. If splash conditions exist,
full-face respirators are mandatory.
Full-face air-purifying respiratory protection equipped with HEPA/Organic Vapor combination
cartridges is required during splash conditions and/or airborne concentrations exceeding 10 ppm.
If levels are maintained over 25 ppm, work will cease until concentrations are below 25 ppm. If
organic concentrations are maintained below acceptable limits, the I-ISO may downgrade the
frequency of environmental monitoring to a screening mode of every 15 minutes. If free product is ,
discovered during any sampling activity, continuous environmental monitoring will be conducted.
Flammables
At a LEL concentration of 10%, as measured with the explosimeter, site activity will be postponed
and all personnel will evacuate the work area due to flammability concerns. After allowing 15
minutes for the vapors to dissipate, the site I-ISO will return for additional readings. Screening will
occur from the exclusion zone boundary to the source. If readings are below I 0% LEL, site activity
may resume at this location. If elevated concentrations are still presem, the site I-ISO will notify the
Rust RI-ISS and site activities will be directed to another sampling location.
G:\A/)JvflN\H&.WIAS/'VIF.AZl::R.IISI' 6-3 October 1995
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Airborne Dusts
Total airborne dust concentration will be monitored during soil excavation using a Miniram dust
monitor or similar instrument. At concentrations of 0.5 mg/m3 or greater, full-face respirators
equipped with HEPA cartridges will be donned.
6.3.1 Heat Stress/Cold Stress
a. Heat Exposure
When the body temperatures rises, the body seeks to dissipate the excess heat. The disorders due
to heat stress are heat cramps, heat exhaustion, and heat stroke. Heat cramps are painful spasms
which occur in the muscles of workers who sweat profusely in the heat and drink large quantities
of water, but fail to replace the body's lost salts and electrolytes.
Heat exhaustion is characterized by extreme weakness or fatigue, dizziness, nausea, and headache.
In serious cases, a worker may vomit or lose consciousness. The skin is clammy and moist,
complexion pale or flushed, and the body temperature can be normal or slightly higher than normal.
Treatment consists of rest in a cool place and replacement of body water lost by perspiration. Mild
cases may recover spontaneously with this treatment. Severe cases may require care for several
days. There are no permanent effects.
Heat stroke is caused by the breakdown of the body's heat regulating mechanism. The skin is very
dry and hot with a red or bluish appearance. Unconsciousness, mental confusion, or convulsions
may occur. Without quick and adequate treatment, the result can be death or permanent brain
damage. Medical assistance should be given quickly. The person should be moved to a cool place.
Body heat should be reduced artificially by soaking the person's clothes with water and fanning
them. Table 6-2 provides the work/rest heat stress schedule adopted by the ACGIH. These heat
stress TL V's refer to heat stress conditions under which it is believed that nearly all workers may be
repeatedly exposed without adverse health effects. The TL V's are valid for acclimated workers who
are physically fit. Acclimatization refers to the physiological and psychological adjustments that
occur in an individual during the first week of exposure to hot environments. Extra caution must
be used for unacclimated or physically unfit workers. Higher heat exposures are permissible if the
workers have been undergoing medical surveillance and it has been established that they are more
tolerant to work in heat than the average worker.
The TL V's also assume that employees are dressed in lightweight summer work clothes. Clothing
such as Tyvek suits, gloves, and respirators are impervious and impede the evaporation of sweat.
For tasks in which PPE is worn, physiological monitoring such as described below will be performed
to set the appropriate work/rest schedule.
G.·I.AJJMIN\H&SI/-/ASl'I/Jf:AlFR.HSP 6-4 October I 995
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Work-Rest Regimen
Continuous work
75% Work -25% Rest
50% Work -50% Rest
25% Work -75% Rest
TABLE6-2
HEAT STRESS WORK/REST REGIMEN
(Wet-bulb globe temperature)
Work Load
Light Moderate
op oc op oc
86.0 30.0 80.0 26.7
87.0 30.6 82.0 28.0
89.0 31.4 85.0 29.4
90.0 32.2 88.0 31. I
Heavy
op oc
77.0 25.0
78.0 25.9
82.0 27.9
86.0 30.0
In addition to these work/rest periods, the following steps can be taken to reduce heat stress:
b.
•
•
•
•
•
Acclimate the body.
Drink more liquids to replace body water lost during sweating .
Increase salt consumption (salt tablets are not recommended) .
Wear personal cooling devices.
Count pulse rate during a 30-second period as early as possible in the rest break. If
the heart rate exceeds I 10 beats per minute at the beginning of the rest break, shorten
the next work cycle by one-third and keep the rest break the same. If the heart rate
still exceeds 110 beats per minute at the next rest break, shorten the following work
cycle by one-third.
Cold Exposure
The human body is designed to function at a certain internal temperature. When the body
temperature falls, the body compensates for the heat loss by increasing its rate of metabolism. Fatal
exposures to cold among workers have almost always resulted from exposures involving failure to
escape from low environmental air temperatures or from immersion in low temperature water. The
single most important aspect of life-threatening hypothermia is the fall in the deep core temperature.
of the body. The deep core temperature should not fall below 96.8"F. Lower body temperatures
will likely result in reduced mental alertness, reduction in rational decision-making capability, loss
of consciousness, or death.
Mild to severe pain in the extremities may be the first early warning of cold exposure. During
exposure to cold, maximum severe shivering develops when the body core temperature has fallen
to 95°F. Useful physical and mental work is limited when severe shivering occurs. Since prolonged
cold exposure at temperatures well above freezing can lead to dangerous hypothermic, whole body
protection must be provided. If work activities are performed in temperatures below 40°F, adequate
insulating clothing to maintain core temperature must be worn by all workers. All workers should
be aware of the effect of wind chill on exposed skin. The higher the wind speed, the lower the
G:\AIJADMJJ&.\1HASl''JJEAZER.ll.\1' 6-5 October I 995
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Koppers Company -Site Health and Safety Plan I perceived air temperature in the work area.
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6.4 SITE ACCESS CONTROL
All personnel and visitors entering the project site must sign and date the project log upon each entry
and exit. In addition, all personnel and visitors must read and comply with the provisions of the
SSI-IP.
In the event that an individual does not adhere to the provisions of the site safety and health plan,
he or she will be requested to leave the work area. All non-compliance incidents will be recorded
in the project log and retained in project files.
6.5 FIELD AUDITS
The Rust I-ISO is responsible for performing routine field audits to assure compliance with all health
and safety requirements. The field audits and safety inspections will be performed at least once daily
and will be documented as part of the Daily Report. The I-ISO also has the authority and
responsibility to stop site work and request that personnel and visitors involved in non-compliance
activities leave the site.
G:\AIJMIN\ll&SIJIA!:i1'\JJF.AZ/<JUISI' 6-6 October 1995
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7.0 WORK ZONES
Site work zones will be established to reduce the accidental spread of hazardous substances by
workers or equipment, and will be delineated by a radius of a given width around the "active" work
area. The flow of personnel and equipment among these zones will be controlled through designated
access and egress points by the Site Health and Safety Officer. Control zones will be delineated on
a site map do be developed after site mobilization but before the start of any work activities. The
Control Zone map must be posted at the Site.
7.1 SITE ORGANIZATION AND CONTROL
Site organization and control will be established and maintained according to the recommendations
set forth in EPA's "Standard Operating Safety Guide," November 1984, and the
NIOSH/OSHAfUSCG/EPA "Occupational Safety and Health Guidance Manual for Hazardous
Waste Site Activities," October 1985. Three general areas of operation will be established to reduce
the risk of personnel exposure to hazardous substances. The three areas are:
• Exclusion Zone (Zone A)
• Contamination Reduction Zone (Zone 8)
• Support Zone (Zone C)
The dimensions of each area and the safe working distances between each area will be balanced
against practical work considerations and existing field conditions.
7.2 EXCLUSION ZONE
The Exclusion Zone (Zone A) will consist of the entire work site until further delineation is made
by the HSO. It is expected that the exclusion zone will be a radius of approximately 50 feet of the
active work activities. Since this area will be considered contaminated, all personnel within the area
must use the prescribed levels of personal protection. A checkpoint will be established at the
periphery of the Exclusion Zone to regulate the flow of personnel and equipment in and out of the
area. The initial Exclusion Zone boundary (hotline) is based upon the actual presence of wastes or
spilled materials. The boundary will be readjusted based on subsequent observations and/or
measurements. Any change in the protection level specified by the original safety and health plan
will be approved by the Rust RHSS. The hotline will be well-defined by geographical or physical·
boundaries and will be physically secure.
As defined in this site safety and health plan, there may be some areas where the use of respiratory
protection is not required during normal work activities. However, should a potential hazard become
evident, respirators should be immediately available for use. These areas are identified by the
following characteristics:
• No known airborne hazards are present and there is little or no potential for release
of hazardous airborne contaminants,
Work operations preclude splashing of hazardous materials.
<1: \Al),\ fl!;'\J{ rl:· .\11/ ASl'\l!f:.Alf](. I IS/' 7 - 1 October 1995
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Any item taken in the Exclusion Zone will be considered to be contaminated until carefully
inspected by the site HSO and/or decontaminated. All vehicles, equipment, instruments and
materials taken into the Exclusion Zone will remain in the zone until no longer needed.
7.3 CONTAMINATION REDUCTION ZONE
The Contamination Reduction Zone (Zone B) will serve as a buffer between the Exclusion Zone and
the Support Zone, and is intended to prevent the spread of contaminants from work areas. Zone B
is expected to be approximately I 00 feet of the active work areas. All decontamination procedures
will be conducted within this area, along a defined corridor.
The boundary between the Support Zone and Contamination Reduction Zone is the contamination
control line. This boundary separates the area of possible contamination from clean areas. Entry
into the Contamination Reduction Zone from the Support Zone will be through a controlled access
point. Personnel entering this area will be wearing the prescribed personal protective equipment.
Exit from the Contamination Reduction Zone requires the removal of any suspected or knovm
contaminants through compliance with established decontamination procedures.
7.4 SUPPORT ZONE
The Support Zone (Zone C) will consist of a staging area in a non-contaminated or clean area. It will
contain the command post for field operations, a first aid station, and other elements necessary to
support site activities. Normal work clothes and safety shoes are worn in this area. Location of
access points and the command post will be based upon favorable wind direction, topography and
site accessibility, when conditions allow.
7.5
• Wind direction -Preferably, the command post should be located upwind of the site
Exclusion Zone. However, wind direction shift and other conditions may be such
that the ideal location based upon wind direction does not exist.
• Topography -The terrain, i.e., woods, water or hills, and available space may limit
selection of command post sites.
MODIFICATIONS TO SITE CONTROL
The use of the three-area designation with access/exit control points coupled with established
decontamination procedures provides reasonable assurance against the translocation of contaminants.
This system of control is based on a "worst case" situation.
Less stringent site control and decontamination procedures may be utilized based upon field
activities and results of monitoring data. Any modification will be authorized by the Rust RHSS and
authorized by the site I-ISO and noted in the daily logs.
G:\.ADA!lN\f1&:-,1HAS/'IJJE.AZER.JIS/' 7-2 October 1995
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8.0 DECONTAMINATION
Personnel decontamination areas will be placed in the contamination reduction zone adjacent to each
excavation area. The areas will consist of wash stations for boots and trash receptacles for protective
clothing. Disposable health and safety items used on the project will be placed in the last truck
containing contaminated soils for disposal by Beazer.
All equipment used in the exclusion zone will be decontaminated at the existing on-site
decontamination pad. Decontamination will consist of cleaning using a high pressure water spray
on all equipment that comes in contact with potentially contaminated materials .. Equipment will be
decontaminated at the end of field activities, or at other times deemed necessary as determined by
Cummings Riter or the HSO. Procedures for cleaning will include scraping all loose material from
the surface before leaving the exclusion zone, proceeding to the decontamination pad, and cleaning
the equipment with a high pressure water spray.
Water for decontamination will be supplied from a clean tank, provided by INCO, filled from a
potable water source. All decontamination fluids will be pumped into an on-site holding tank for
disposal by Cummings Ritter.· Sediments from the equipment will be placed either with the staged
soil or in 55-gallon drums for disposal by Cummings Ritter.
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9.0 EMERGENCY PROCEDURES
9.1 FIRST-AID
If first aid and/or CPR is administered by site personnel, the site HSO must ensure full compliance
with the requirements of the Bloodborne Pathogen Standard. A first-aid kit will be maintained at
the control access point between the decontamination and support zones and in all support vehicles.
If the victim cannot be safely moved from the contaminated area, first--aid necessary to stabilize the
victim for safe transport will be administered at the accident location. Appropriate decontamination
of all clothing and equipment will be followed upon leaving the contaminated area. The HSO is
responsible for administering first-aid.
9.2 EMERGENCY RESPONSE
9.2.1 Pre-Emergency Planning
During the site briefings held periodically, all employees will be trained in and reminded of
provisions of the emergency response plan, communication systems, use of the buddy system,
evacuation routes, and location of PPE. These site briefings will also remind site personnel of
emergency recognition and prevention techniques discussed in this plan. During an emergency
situation, the place of refuge will be a predetermined area in the Support Zone. The HSO will be
responsible for determining the criteria and procedures for emergency site evacuation. In the event
of a large scale disaster or far reaching emergency, the HSO will immediately notify the Beazer East
representative and the representative will make the determination what steps are necessary, including
initiating the facilities community alert programs, if applicable. It is the responsibility of the HSO
with input from the Beazer East representative to critique emergency responses and necessary
follow-up to an emergency situation.
The plan will be reviewed and revised, if necessary, on a regular basis. This will ensure that the plan
is adequate and consistent with prevailing site conditions.
Site personnel are required to familiarize themselves of the work site layout, site topography, and
prevailing weather conditions ,before work activities begin.
9.2.2 Lines of Authority
As the administrator of the project, the Project Manager has primary responsibility for responding
to and correcting emergency situations. This includes taking appropriate measures to ensure the
safety of site personnel and the public. Possible actions may involve evacuation of personnel from
the site area. The Project Manager is additionally responsible for ensuring that corrective measures
have been implemented, appropriate authorities notified and follow-up reports completed. All
project personnel are responsible for assisting the Project Manager in responding to emergency
situations within the capabilities of their skills, equipment and training. Additional project personnel
are discussed in Section 2.2 of this plan.
< i: \AIJMINVM .\11/A SPIBl:.AZER. !IS/' 9 - 1 October 1995
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In the event of an environmental spill or relt,ase, or discovery of radioactive materials, the HSO will
immediately notify the Project Manager for notification to appropriate government agencies.
9.2.3 Emergency Equipment/Facilities
All individuals will be familiar with the site and be able to identify the locations of the following
emergency equipment:
• First-Aid Kit/Bloodborne Pathogen Kit
• A-B-C Fire Extinguishers, minimum of2.5 lbs. capacity
• Eye Wash -15 minute continuous flow capacity
• Telephone
• Two-way Radio
• PPE
• Portable Decon Sprayer
Spill control/response material (absorbent such as sand, kitty litter, or spill pillows)
9.2.4 Medical Emergencies
Any person who becomes ill or injured in the Exclusion Zone must be decontaminated to the
maximum extent possible. If the injury or illness is minor, full decontmnination will be completed.
If the patient's condition is serious, partial decontamination will be completed. As a minimum, outer
garments will be removed and clean coveralls or a blanket will be used to cover the victim. First-aid
should be administered by the HSO while awaiting an ambulance or paramedics.
In the event of an injury on-site, all activities will be immediately tem1inated and resources will be
diverted until it can be ensured that decontamination procedures are adequate and that proper
assistance has been provided to ambulance and/or hospital staff responsible for treating the injury.
All injuries and illnesses must be immediately reported to the Project Manager or the Site Health and
Safety Officer who will then notify appropriate off-site personnel and organizations as necessary.
For ambulance, fire or police contacts, give the name of the road and the nearest intersection. In the
event no telephone can be reached, Channel 9 can be accessed with a Citizens' Band (CB) Radio for
emergency assistance.
Notify the Beazer East representative and the Rust RHSS after primary emergency contacts have
been made. The Equipment Manager should be contacted if unforeseen circumstances require the
immediate procurement of additional personnel protective equipment.
Attending emergency physicians should be given the telephone number of the Rust Medical Director
to obtain immediate access to an employee's medical records and for consultation purposes.
G:\ADMl,WM.\VfA5'1".BF.AZF.R.ll,\1' 9-2 October 1995
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9.2.5 Emergency Contact/Notification Listing
PRIMARY CONT ACTS
Morrisville Police Department
Morrisville Fire Department
Western Wake Medical Center
Ambulance
911
911
[phone]
911
Directions to the nearest Hospital
The Western Wake Medical Center is located at 1900 Kildaire Farm Road in Cary, approximately
five to eight miles from the site. A map showing directions to the hospital will be developed by Rust
before field activities begin, and be posted along with the emergency phone numbers.
SECONDARY CONT ACTS
Sherman Woodson, CIH
Rust E&I Regional Health and
Safety Specialist
(Southeast Region)
Dennis Jones
Rust E&I Technician/HSO
Dr. Elayne Theriault, MD
Rust Medical Director
[phone]
[phone]
[phone]
9.2.6 General Emergency Procedures
•
•
In the event that any member of the field crew experiences any adverse effects or
symptoms of exposure while on the scene, the entire field crew will immediately halt
work and act according to the instructions provided by the site HSO.
The discovery of any condition that would suggest the existence of a situation more
hazardous than anticipated, will result in the evacuation of the field team and re-
evaluation of the hazard and the level of protection required.
• In the event that an accident occurs, the site HSO is to complete an Accident Report.
Follow-up action will be taken to correct the situation that caused the accident.
9.2.7 Personal Injury
The Site HSO is trained in first aid procedures and will administer appropriate first-aid treatment,
including CPR, in emergency situations. The following general emergency procedures will be
carried out in the event of injury:
G:\AOM/Nlll&.SVfA.S/'IBE.AZF.R.IISI' 9-3 October 1995
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Koppers Company-Site Health and Safety Plan
Notify the Health and Safety Officer (HSO) of the incident.
If the victim can be moved safely, remove from the contaminated zone to the
decontamination zone using established control points.
Administer first-aid.
Call for ambulance transport, or transport victim to nearest hospital or emergency
medical center, as appropriate.
The Site HSO will direct the removal of injured personnel from the contaminated
zone and will approve any necessary deviation from established decontamination
procedures. Such deviation will be based upon the severity or life threatening nature
of the injury.
Notify the Rust RHSS of the incident and describe the emergency response actions
taken.
9.2.8 Chemical Exposure
Before entering the work areas, all site personnel will be thoroughly acquainted with the types of
toxic/hazardous chemicals present on site and their potential concentrations. The following general
procedures will be followed for chemical exposure emergencies:
I.
2.
3.
4.
•
5.
6.
Move the victim from the immediate area of exposure or contamination, taking
precautions to prevent additional exposure of other individuals.
Notify the site safety and health Officer (I-ISO) of the exposure incident.
If victim can· be moved safely, proceed to the decontamination zone through
established control points.
Decontaminate clothing or remove if safe to do so.
For skin or eye contact, thoroughly wash affected areas with water (eyes should be
flushed for at least 15 minutes).
• For inhalation exposure, ensure that victim has adequate fresh air.
Administer additional first aid treatment as appropriate.
Call for ambulance transport, or transport victim to nearest hospital or emergency
medical center, as appropriate.
7. Notify the RHSS and describe the emergency response actions taken.
NOTE: The HSO will direct the removal of injured personnel from the contaminated zone and will
G:\AlJ,\f/NV/&JlHASl'IBf.AZER.1/SP 9-4 October 1995
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approve any necessary deviation from established decontamination procedures. Such deviation will
be based upon the security or life threatening nature of the injury.
9.2.9 Fire or Explosion
In the event of a fire or explosion:
1. Immediately evacuate injured personnel and leave the area,
2. Administer first aid as appropriate,
3. Notify emergency services,
4. Notify the Rust RHSS.
9.3 EVACUATION ROUTES AND PROCEDURES
I Evacuation routes and procedures will be developed by the Rust HSO upon arrival at the site.
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APPENDIX A
WORK ZONE ENTRY AND EXIT LOG
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Rust Environment & Infrastructure Daily Sign-In/Out Log
PROJECT: ______________ _
PROJECT LOCATION: _________ _
PROJECTNO.: ___________ _
SITE SAFETY OFFICER: ________ _
DATE: _______________ _
PAGE NO.: _____________ _
TIME
I IN OUT NAME FIRM PURPOSE ON-SITE
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~ev. 5195
Note: This form is i'o be completed on a daily basis by all personnel working on the site.
F06-l/Cmp.l l&S
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APPENDIXB
JOB EXPOSURE REPORT
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I ... M9 ENVIRONMENT & • ■~U>I INFRASTRUCTURE Job Exposure Report
I I Instructions: This report is to be completed by the Site Safety Officer at the end of each Rust E&l Employee's participation·
in site activities. A copy of this report must be submitted to the REHSM for placement in the employee's
medical file. ·
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Employee Name:
' I Social Security Number:
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I Project Name:
I Project Number:
I Location: I
I Site Function:
• Level of Protection:
I Dates of Site Participation: -----------------------------------
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I. Were action levels exceeded in the work area (breathing zone)? Yes __ _
2. If yes, list type of monitoring and readings:
3. List known or suspected contaminants on-site (list from HASP):
4. Personal exposure monitoring data attached? Yes No __
SSO Name (Print): ____________________ _
SSO Signature: ______________________ _
Date: ___________________________ _
~Rev. ll/94
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N/A
F016/Corp.l{&S
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APPENDIXC
SITE SAFETY MEETING FORM
I.
I. RIKTENVIRONMENT&
INFRASTRUCTURE
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Projecc _________________ _
Project Number; _______________ _
Meeting Conducted By: ____________ _
Name
Site Safety Meeting
Page __ of __
Date: Time: ____________ _
Signawre I Summary Of Items Discussed: ___________________________ _
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Representing Signature
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3.
4.
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8.
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11. .I 12.
13.
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15.
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20.
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I NOTE: Place in project files.
I j Rev. I li<>4 F027/Cmp.H&S
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11
APPENDIXD
HEALTH AND SAFETY PLAN FIELD MODIFICATION FORM
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Pll llrr ENVIRONMENT & 141.U> I INFRASTRUCTURE Hea//h a11d Safety Pla11
Field M odificatio11 F omz
Page No. __ of __
Project: _______________________________________ _
Project Location:-------------------------------------
Project No.:------------------------------------
Site Safety Officer:----------------------------------
Field Modification To HASP:; _______________________________ _
Prepared By: -------------------------------=----Site Safety Officer Date
Accepted By: ------,-------,-----=--,--,..---------------:::----RUST Environment & Infrastructure Field Manager Date
Accepted By:-----------'-----------------------------,:----Contr.1ctor Representative (If Applicable) Date
Approved By; _____________ -------------------------
RUST Environment & Infrastructure Regional Health and S.c1fcty Specialist D~Hc or Alternate HA3P Reviewer
NOTE: Field Modific21ions to 11/,.SP's must be discu.s.scd with the RUST Environment & Infrastructure RlfSS or CHSI\1 with subsequent written apprnval. Secure approval through fax.
I:.
Rev. 3/93
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APPENDIXE
SUPERVISOR'S INCIDENT REPORT
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1'-U>I INFRASTRUCTURE Supervisor's Incident Report
Date of this report: --~/ __ ~/ __ _
Fax this repon within 24 hours to Rust International Inc.: 708-916-0592
Attenlion: Claims Management Department
Telephone: [phone]
Group: R66 (Rust E&l) Regioo: ______ _ Office/Division: _______ _
TYPE OF INCIDENT: Inspection: ____ Accident: ___ Injury: ___ Spill:. ___ Fire:. ___ Other: __ _
Agency: Inspector's Name: Type Inspection: _______ _
Agency Address: :Phone: ___________ _
EMPLOYEE INFORMATION:
Employee's Name: ______________________ Social Security No.: ________ _
Address: Phone: ____________ _
Date of Birth: Number of Minor Marital Single _____ Widowed __ _
Dependents: ____ Status: Married ____ Divorced ___ _
Date of Hire: _______ Wage Rate:$ Hourly: ___ Annually:___ Job No.: ___ _
Employee Hours on Date of Incident: Employee Hrs. on Project: ___ Days/Wk.: __ Hrs./Day: __
Employee's Occupation Years of Experience in
When Incident Occurred?: This Occupation?: __________ _
INCIDENT INFORMATION:
Date of Incident: ________ Time: ______ Witness(s): ______________ _
Date Reported to Supervisor: ______ Was Incident Believed to be Result of Employment?: Yes ___ _ No
If on Job Site, Location on Job Site
Name of Job: Where Incident Occurred: ____________ _
Address Where Incident Occurred: ---------'--------~--------------If First Aid Applied. by Whom: ____________________________ _
Type of Injury and Part of Body Affected: _________________________ _
Name/Address Medical Provider: ----------------------~------
Brief Description of Incident: ----------------------------------
Employee Activity at Time of Incident: -------------------------------
Description of Property Damaged: --------------------------------
OSHA 200 LOG INFORMATION:
ls incident OSHA Yes □ recordable?: No □
Does incident involve Ye, □ i_.edical treatment?: No □
Employee's
Does incident Yes
involve fatality?: No
Does incident Yes
involve fint aid only?: No
Project
□ □
□ □
Does incident involved lost
time/restricted activity?:
Yes D
No 0
Current Statu,: _______ _
Supervisor: _______________ _ Manager: _________________ _
See reverse side for instructiom.
ILV IW4 F036/Corp.l\S:.S
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SUPERVISOR'S INCIDENT REPORT
INSTRUCTIONS
The following types of occurrences and incidents must be reported using this form:
Serious occupational injury or illness. Includes fatalities and cases resulting in days away from work.
Incidents with high public or client profile potential.
Inspections by State or Federal regulatory agencies.
Reportable quantity spills.
Incidents with property damage >$5,000.
Instructions:
Verbal (Immediate):
I. Employees must report such incidents to their supervisor immediately.
2. The supervisor must verbally notify their Division Manager who in tum must notify their Region Manager and Region
Envirorunental, Health & Safety Manager (REHSM). The REHSM shall notify the Corporate Environmental,
Health & Safety Director.
3. The RM must verbally notify the Rust E&l President and/or Vice President of Operations who will either call or fax a
copy of this report to the Ril President, Director of Environmental, Health & Safety, and Corporate Counsel.
Written (Faxed within 24 hours):
I. The Supervisor must complete the applicable sections describing the specific incident. (Enter NA in blanks on form
which do not apply to incident). If the incident involved a Rust E&l employee: injury or illness subject to workers'
compensation, a copy of the Supervisor's Incident Report must also be faxed by the Supervisor to the Rust
International Inc., Claims Analyst at Fax [phone].
If the incident involved property damage greater than $5,000, a copy of the report must be faxed to Kris Froh, Legal
Assistant, in the Sheboygan office (Fax: [phone] or Phone: [phone]).
2. The Division/Office Manager shall fax a co,iy to their respective Region Manager and REHSM.
3. The RM shall fax a copy to the Executive Vice President of Operations and/or President who in tum shall fax it to Rll
personnel as listed in Item 3 above. The REHSM shall fax a copy of the report to the Rust E&l Corporate
Environmental, Health & Safety Director.
Rev. 11/94 F036a/Corr,.ll&S
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APPENDIXF
ATMOSPHERIC MONITORING LOG
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RIKI' Rust Environment & Infrastructure Atmospl,eric Monitoring Log
Field Hea/tl, and Safety
Page __ of __
Date----~/ ____ ~/ ___ _
Circle: Sun Mon Tue Wed Thu Fri Sat
Site: _________________________ Project No.: _________ _
Site Safety Officer: -==---------=::::-------=:------------------
Action Levels: D D ► C D ►: B D
(Check box and write in levels for upgrade}
--~)Ii►► (stop work, call in for instructions
on all upgrades)
Task/Equipment: ------------------------------------
Weather:--------------------------------------
Circle one: HNu/OV A Readings (ppm}
o, LEL H2S Back Breathing Sample Head
Location Time % % PPM ground Zone Location Space Comments
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Additional Comments: ----------------------------------
Signature: __________________ _
Checked by: ______________ _ Date:
NOTE: Place in project files. I : Rev. 4/95 F024/Corp.H&S
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APPENDIXG
CONFINED SPACE ENTRY PROCEDURES
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RUST ENVIRONMENT & INFRAS'fRUCTURE
CONFINED SPACE ENTRY PROTOCOL
(i:\AfJMIIN/&,\VfA,'1'1/IE.AZF.R.JISP October 1995
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Scope and Objective
This protocol defines confined spaces, identifies applicability of the Confined Space Entry
Permit, and provides a discussion of the information required for completion of the Confined
Space Entry Permit.
This protocol establishes the health and safety requirements and concerns to be followed by all
Rust personnel involved with potential entry into confined space areas.
G:\.AD.\UN\H&.\VIASP\BE.AZER.lf.'i/' October 1995
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TABLE OF CONTENTS
Chapter Page
1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . H -I
2.0 PROTOCOL APPLICATION ........................................ H -2
3.0 DANGERS ASSOCIATED WITH CONFINED SPACE ENTRY ........... H -3
4.0 PRE-PERMIT EVALUATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . H -4
5.0 EXECUTION OF THE ENTRY PERMIT .............................. H -5
5.1 GENERAL INFORMATION .................................... H -5
5.2 REQUIRED SAFEGUARDS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-I -5
5.3 RESCUE PROCEDURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . H -6
5.4 FINAL REQUIREMENT IN COMPLETING
THE ENTRY PERMIT ......................................... H -7
6.0 MONITORING REQUIRED PRIOR TO EACH ENTRY INTO
A CONFINED SPACE ............................................... H -8
7.0 RULES APPLYING TO CONFINED SPACE ATTENDANTS ............. H -9
G:IADAIJNl/f&.\11/ASl'V!F.AZF.R.JIS/' October I 995
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Koppers Company -Sile Health and Safety Plan
CONFINED SPACE ENTRY PROTOCOL
1.0 INTRODUCTION
A confined space is any enclosed area that is not designed for human occupancy and has restricted
entries and exits which would make escape or rescue difficult ( e.g., tank, furnace, vessel, vat, silo,
sewer, bin, hopper, vault, boiler, pit, ditch, pipe, well).
It should be noted that entry into one particular form of confined space, excavations and trenches,
is governed by OSHA standards under 29 CFR Part 1926 -Occupational Safety and Health
Standards -Excavations, Final Rule. The trenching and excavation phase of a job can present the
greatest potential safety risk to workers. The greatest risk is from cave-ins, which are more likely
to result in fatalities than other accidents associated with excavation1•
Table I provides a matrix for evaluating potential confined spaces and associated atmospheric and
other hazards likely to be found in confined spaces or to be generated by activities in such spaces.
U.S. Department of Labor, 1990. Excavations. Occupational Safety and Health Administration Document 2226 (Rev. 1990).
Washington, DC. Reprinted by The Association of Engineering Firms Practicing in the Geosciences, Silver Spring, MD.
G: \ADAIJ.\'V-/ & ~lll ASl'i.JJF.AZFJU/S/' H - I October 1995
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2.0 PROTOCOL APPLICATION
This protocol provides guidelines to help employees recognize and reduce the risks associated with
confined space entry and applies to the following.
•
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All Rust operations and employees, both permam:nt and casual.
Operations conducted by outside organizations and subcontractors under the
direction of Rust.
It does not apply at non-Rust locations where the Rust employee or subcontractor is required to
follow site safety rules which provide for a different but equivalent procedure for confined space
entry.
G:\A/JMIMJM.\11/ASl'I/W.AZ!~R.I/SI' H-2 October 1995
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Koppers Company -Sile Health and Safety Plan
3.0 DANGERS ASSOCIATED WITH CONFINED SPACE ENTRY
Confined spaces sometimes present a risk of accidental injury or death for personnel entering or
working in them because of:
•
•
•
•
Hazardous oxygen levels (outside the range of 19.5 -23 percent) .
Flammable or explosive levels of gaseous materials in the area .
Concentrated levels of toxic substances .
Potential for engulfment by particulate matter or liquids .
G: urn fl NVI& .WI AS/'l/J}-:.4ZFJU/SI' H-3 October 1995
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Koppers Company -Site Health and Safety Pian
4.0 PRE-PERMIT EVALUATION
Before personnel may enter any confined space, the area must be evaluated by a responsible party,
generally the Site Manager, to determine whether or not there is a hazard potential for employees
entering the area. This will be accomplished by:
• Using the results of environmental monitoring to determine whether the space
presents potential for hazardous atmosphere, such as low oxygen or high toxic
vapors, or other condition, such as explosion potential, immediately dangerous
to life or health.
• Evaluating the work to be done in the area, such as welding or cleaning with
solvents, to determine whether or not hazards may be introduced into the
confined space.
Table I will serve to identify potential hazardous conditions associated with confined spaces.
G:\A/JMIN\H&.\VIASl'\JJF.AZfJUIS/' H-4 October I 995
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5.0 EXECUTION OF THE ENTRY PERMIT
Exhibit A to this protocol contains a Confined Space Entry Permit Form. I fan entry permit is
determined to be required for confined space entry, the Permit form should be completed and should
include the information described below.
5.1 GENERAL INFORMATION
General information about the job to be performed, date and time during which the permit is valid,
and general health and safety considerations, such as personal protective equipment and special work
practices should be provided. Specific considerations include:
A.
B.
C.
D.
Description of the job to be performed.
Date and time the permit is issued and when it expires.
Employees for whom the permit is valid.
Specifications for all environmental testing to be performed pnor to entry (oxygen
percentage, flammability, toxicity), and any follow-up testing.
5.2 REQUIRED SAFEGUARDS
It is likely that specific procedures will be required to safeguard the health and safety of workers in
the confined space. On the basis of pre-entry testing, decide which, if any, of the following
safeguards will be required.
A. Ventilation or cleaning prior to entry.
B.
C.
D.
E.
Attenuation of any electrical shock hazards by low voltage systems, ground fault circuit
interrupter, assured grounding program, double insulation, or isolated electrical system.
Outside attendants.
Continuous mechanical ventilation.
Lock/tagout requirements.
• All mechanical or electrical equipment must be physically locked out if
inadvertent energization would create a hazard. T AGO UT ALONE IS NOT
ACCEPT ABLE.
• All process equipment must be locked out to prevent possible hazards. If
lockout is not possible, tagout or other measures shall be taken.
G:\ADAffMH & S\H ASP\BE.AZF.R. HSI' H-5 October 1995
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Physical isolation to prevent the introduction of hazardous materials into the confined space.
• All material-transferring devices must be physically isolated from the confined
space by an appropriate combination of valve or cnergizable device lockouts,
physical disconnects, blanking, or other effective ,control measures.
• If physical isolation of the space is not possible, al.I persons entering the space
must have sufficient personal protective equipment to ensure their safety in case
of exposure.
Personal protective equipment, including respiratory protective equipment.
Special work practices, such as the use of explosion-proof electrical equipment when there
is a potential for the introduction ·of flammable liquids, gases, or solids.).
5.3 RESCUE PROCEDURES
Rescue procedures must be defined prior to allowing entry into any confined space area where the
potential for hazards exists. Appropriate actions will include:
•
•
•
•
5.4
Ensure that appropriate rescue equipment is present at the entrance of the confined
space or would be immediately available for a rescue team.
If the employees entering the space are wearing safety harnesses or wrist harnesses
attached to lifelines, make certain there is a secure tic-of[
If safety harnesses and lines arc not feasible, determine what alternative rescue
equipment will be required.
Be sure that a rescue team is readily available in the area .
FINAL REQUIREMENT IN COMPLETING THE ENTRY PERMIT
When the entry permit has been executed, the final action will be to sign the form and instruct the
person in charge of entry work to:
• Post the permit outside the confined space.
• Return the permit at the end of the shift which it covers .
(;;l,,IIJ.\f/NVl&,\1HASl'VIEAZJ::R.HSI' H-6 October 1995
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6.0 MONITORING REQUIRED PRIOR TO EACH ENTRY INTO A CONFINED SPACE
Environmental monitoring must be conducted before each entry into a permit entry space.
Additional monitoring may be required by the Site Manager at specified intervals. Monitoring shall
be conducted as follows:
A.
B.
C.
D.
E.
If feasible, monitoring should be performed without entering the confined space.
Readings must be taken at a representative number of locations within the confined space.
Testing should be done in the following order, using instrnments that are calibrated at
intervals recommended by NIOSH, OSHA, or the manufacturer:
•
•
•
Percentage of oxygen (must be within 19.5-23% unless special safeguards arc
provided).
Presence of flammable gases or vapors, or combustible solids .
Concentrations of known toxic substances .
If any of the readings fall outside the ranges specified by the permit, employees must not
enter the confined space or must leave it immediately.
If a confined space must be exited, the Site Manager will evaluate the situation and stipulate
whether entry is possible using additional safeguards.
11:WJJ.f/N\Jf&S\J/A.SPI.BE.AZFRHSI' H-7 October 1995
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7.0 RULES APPLYING TO CONFINED SPACE ATTENDANTS
Whenever attendants are required for confined space activities, they must be trained in terms of
specific reference the specific role they are to play as follows:
•
•
•
Attendants must not enter the confined space and must not leave the vicinity of the
entry point except for self-preservation or until replaced by another trained attendant.
Attendants must be trained to summon emergency rescue assistance and must have a
reliable means for summoning the assistance, such as a loud horn, a telephone hotline,
a radio, or other method.
The attendant must be able to maintain visual, voice, sound, or line contact with the
persons in the confined space at all times.
G:IADMIN\Jl&S\HASP\BEAZFRHSI' H-8 October 1995
- - - - --- - --- - -- -.. ---Koppers Company -Site Health and Safety Plan
TABLE 1
CONFINED SPACES AND ASSOCIATED HAZARDOUS CONDITIONS
HAZARDOUS ATMOSPHERE OTHER CONDITIONS IMMEDIATELY DANGEROUS TO LIFE OR HEALTH
Type of Flammable Less than Any OSHA-
potential gas, \'3J)Or, 19.5¾ or more identified Potential Insufficient Remarks or
confined mist or than 2J¼ substance in Mechanical Electrical Extreme Excessive Falling objeru for engulfment maneuver· Other comments
space airborne dust o-..ygen excess of the h=d hazard temperature noise ability (specify)
in excess of PEL or is
l0$ofits otherwise
Lower l..nown to
Flam1112bili1y present a
Limit safety or acute
health hazard
Tunneb
Sewers
Vaults
Tanks (open
Bins (open or
Hoppers
Conveyor
Furnaces
Boilers
G:\Af).',-fINVM-SIHASl'VIF.AZF.R.lfSI' H-9 October 1995
- - - - -- - - -- - ------Koppers Company -Site Health and Safety Plan
TABLE 1 (continued)
CONFINED SPACES AND ASSOCIATED HAZARDOUS CONDITIONS
HAZARDOUS ATMOSPHERE OTHER CONDITIONS IM MEDIATELY DANGEROUS TO LIFE OR HEALTH
Type of Flammable Less titan Any OSHA-
potential gas, vapor, 19.5o/o or more identified Potential Insufficient Remarks or
confined mis101 than 231/o substance in Mechanie&I Electrical """"'" E,,;cessive Falling objects for engulfment maneuver-"""' comments ,,= airborne dust oxygen e,.cess of the huud hu,sd tempen.rure noise ability (specify)
in excess of PEL or is
10% of its otherwise
Lower known to
Flammability present a
Limit safety or acute
health haurd
Ditches
Rooms with
Vessels (open
v,o
Wells
Mixen
Other
,;:IA/J,\f/1>11!&.\11/A.\rl/U.:.AlfJU/SI' 1-1 -I 0 October I 995
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CONFINED SPACE ENTRY PERMIT
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I I-1-11 October 1995
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A confined space is any enclosed area that is not designed for human occupancy and has restricted entries and exits which would
make escape or rescue difficult, such as a tank, furnace, vessel, vat, silo, sewer, bin, hopper, vault, boiler, pit, ditch, pipe, or well.
Before personnel may enter any confined space, the area must be evaluated by a responsible party to determine whether or not
there is a hazard potential for employees entering the area.
IF THE HAZARD POTENTIAL IS DETERMINED TO BE ZERO (0), AN ENTRY PERMIT WILL NOT BE REQUIRED. IF IT IS
ESTABLISHED THAT A POTENTIAL FOR HAZARD EXISTS, AND ENTRY PERMIT WILL BE REQUIRED.
GENERAL INFORMATION
Task to Be Performed:---------------------------------
Location: ____________ Date: _______ Time Issued:
Time Expires: __________ _
Employees Assigned
(Name/Signature), ________________________________________ _
Outside Attendants (Name/Signature), ________________________________________ _
Pre-entry Ventilation
or Cleaning __________________________________ _
Personal Protective Equipment _______________________________ _
Physical Isolation orlockout!Tagout __________________________________ _
Special Work Practices, ___________________________________________ _
Continuous
Ventilation __________________________________ _
(SignaturefTitle of Permit Entry Administrator(Signature/Title of Person Directly Responsibh? for
Verifies that permit is complete and that rescue work to Be Performed)
team and equipment have been determined to be available.)
Time Job Completed ___________ _
TESTING REQUIRED
Oxygen Percentage
(Must fall within 19.5% to 23%, unless permit entry
administrator specifies safeguards.)
Prior to Entry-,-__________________________ _
(Time)(Results)
Follow-up (If Required) ___________________________ _
(Time)(Results)
(Time)(Resulls)
Type and Serial Calibration
Number of Equipment ___________ Date ___________________ _
Name and Signature of Tester __________________________________ _
Flammability
(Specify gases and vapors to be tested, and respective
concentration limits, which must be less than 10% of
the Lower Flammability Limit.)
H - I
tNFINED SPACE ENTRY PERMIT i BE POSTED AT JOB SITE
RUST ENVIRONMENT & INFRASTRUCTURE
5510 SIX FORKS ROAD
RALEIGH, NC 27609
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(Gas)(Limits)
Prior to Entry _________________________ _
(Time)(Results)
(Time)(Results)
Follow-up (If Required) _________________________ _
(Time)(Results)
(Time)(Results)
Type and Serial Calibration
Number of Equipment ________ Date __________________ _
Name and
Signature of Tester _______________________________ _
Toxicity
(Specify substances to be tested, plus concentration
limits, which must be less than the Permissible
Exposure Limit.)
(Substance )(Limits)
(Substance )(Limits)
(Substance )(Limits)
Prior to Entry _________________________ _
(Time)(Results)
(Time)(Results)
(Time)(Results)
Follow-up (If Required) _________________________ _
(Time)(Results)
(Time)(Results)
(Time)(Results)
Type and Serial Calibration
Number of Equipment ________ Date __________________ _
Name and
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LTH & SAFETY
med Space Entry Protocol -PERMIT
(C:\H&S\HASPCSP. 1-1)
PageA-2
H-2
Revision 1. 1
Maren 2. 1992 October HM?e1i on March 4, 1996
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CONFINED WORK SPACE
DO NOT ENTER
WORK PERMIT REQUIRED -CONTACT SAFETY OFFICE
October 1995