NCD980729602_20041208_Jadco-Hughes_FRBCERCLA RMVL_Drum Removal Work Plan-OCR

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DRUM REMOVAL WORK PLAN
JADCO-HUGHES SUPERFUND SITE
GASTON COUNTY, NORTH CAROLINA
DECEMBER 2004
REF. NO. 3669 (31)
This report is printed on recycled paper
Prepared by: ·
Conestoga-Rovers
& Associates
651 Colby Drive
Waterloo, Ontario
Canada N2V 1 C2
Office: 519•884•0510
Fax: 519•884•0525
Worldwide Engineering, Environmental, Construction, and IT Services
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TABLE OF CONTENTS
1. 0 INTRO DU CTI ON ................................................................................................................... 1
1. 1 GENERAL ............................................................................................................ 1
1.2 BACKGROUND .................................................................................................. 2
1.2.1 SITE HISTORY ..................................... : .............................................................. 2
1.2.2 TOPOGRAPHY AND SITE HYDROGEOLOGY ........................................... 4
1.3 WORK PLAN ORGANIZATION ..................................................................... 5.
2.0 GEOPHYSICAL SURVEY ..................................................................................................... 6
3.0 DRUM REMOVAL ACTIVITIES ......................................................................................... 8
3.1 GENERAL ......... , .................................................................................................. 8
3.2 SITE CLEARING ................................................................................................. 9
3.3 SITE PREPARATION ......................................................................................... 9
3.3.1 EQUIPMENT DECONTAMINATION FACILITY ........................................ 9
3.3.2 STAGING PADS ............................................................................................... 10
3.4 SITE SECURITY ................................................................................................ 10
3.5 MATERIALS HANDLING PLAN .................................................................. 10
3.5. 1 SO !LS .................................................................................................................. 1 O
3.6 DRUM HANDLING PROTOCOLS ............................................................... 11
3.6.1 EQUIPMENT ..................................................................................................... 11
3.6.2 . PROCEDURE .................................................................................................... 12
3.6.3 ENVIRONMENTAL CONTROL .................................................................... 15
3.6.3.1 SURFACE WATER CONTROL ...................................................................... 15
3.6.3.2 DUST CONTROL ............................................................................................. 16
3.6.3.3 SEDIMENT CONTROL .............................................................................. , .... 16
3.6.3.4 GENERAL HOUSEKEEPING ......................................................................... 16
3.7 INITIAL DRUM SAMPLING .......................................................................... 16
3.8 DRUM STORAGE ............................................................................................. 17
3.9 DRUM SAMPLING .......................................................................................... 18
3. 9 .1 COMPATIBILITY ANALYSIS ........................................................................ 18
. 3.9.2 CHARACTERIZATION ANALYSIS ............................................................. 18
·3.9.3 REMOVAL OF VISUALLY COMPATIBLE WASTE STREAMS ............... 19
3.9.4 REMOVAL, CRUSHING, SHREDDING, AND
OFF-SITE DISPOSAL OF EMPTY CONTAINERS ....................................... 19
3.9.5 REMOVAL OF INTACT CONTAINERS ...................................................... 19
3.10 ATMOSPHERIC EMISSIONS MONITORING AND CONTROL ............. 20
3.11 PREPARATION OF OFF-SITE TRANSPORT VEHICLES .......................... 20
3.12 OFF-SITE WASTE TRANSPORTATION AND DISPOSAL ....................... 20
3.12.1 MANIFESTING AND LABELING ................................................................. 20
3.12.2 AUTHORIZED TRANSPORTERS ................................................................. 21
3.12.3 OFF-SITE CONTINGENCY PLAN ................................................................ 21
3.12.4 OFF-SITE DISPOSAL ....................................................................................... 22
3.12.5 DOCUMENTATION ........................................................................................ 23
3669 (31) CONESTOGA-ROVERS & ASSOCIATES
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TABLE OF CONTENTS
3.12.6 INSPECTION OF TRANSPORT VEHICLES ................................................ 23
3.12.7 OFF-SITE EMERGENCY SPILL RESPONSE ................................................ 23
3.13 BULK LIQUID HANDLING .................................................... , ...................... 24
3.13.1 BULK LIQUIDS ................................................................................................. 24
3.13.2 BULK LIQUID REMOVAL ............................................................................. 24
3.13.3 BULK LIQUID DISPOSAL .............................................................................. 24
3.14 DRUM REMOVAL CLOSEOUT ..................................................................... 25
3.14.1 GENERAL ........................................................................... , .............................. 25
3.14.2 FINAL EQUIPMENT DECONTAMINATION ............................................ 25
3.14.3 WASTEWATER ................................................................................................ 25
3.15 FINAL CLEANUP ............................................................................................ 26
REPORTS ... , ....................... ,.,,, .................................................... , .......................................... 27
PROJECT SCHEDULE ......................................................................................................... 28
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FIGURE 1.1 SITE LOCATION
LIST OF FIGURES
(Following Text)
FIGURE 1.2 SHALLOW GROUNDWATER FLOW PATTERNS -APRIL 30, 1993
FIGURE 1.3 GROUNDWATER EXTRACTION SYSTEM LAYOUT
FIGURE 1.4 SHALLOW GROUNDWATER FLOW PATTERNS -DECEMBER 12, 2000
FIGURE 1.5 SHALLOW GROUNDWATER FLOW PATTERNS -DECEMBER 8, 2003
FIGURE 2.1 LAYOUT OF THE GEOPHYSICAL SURVEY GRID
LIST OF TABLES
(Following Text)
TABLE 3.1 WASTE COMPATIBILITY ANALYTICAL PARAMETERS
TABLE 3.2 DISPOSAL CHARACTERIZATION ANALYTICAL PARAMETERS
TABLE 5.1 SCHEDULE OF DRUM REMOVAL ACTIVITIES
LIST OF APPENDICES
APPENDIX A HEAL TH AND SAFETY PLAN
3669 (3\) CONESTOGA-ROVERS & ASSOCIATES
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INTRODUCTION
1.1 GENERAL
This Drum Removal Work Plan (Work Plan) addresses the discovery of a small number
of buried drums found during drilling at the Jadco-Hughes Site in Gaston County,
North Carolina (Site). Conestoga-Rovers & Associates (CRA) has prepared this Work
plan on behalf of the Jadco-Hughes Steering Committee (Steering Committee) in
response to the discovery of drum fragments and several intact drums during a drilling
program for the implementation of a large-scale enhanced bioremediation pilot study at
the Site.
A Site location map has been presented on Figure 1.1.
The Steering Committee notified the United States Environmental Protection Agency
(USEP A), the North Carolina Department of Environment and Natural Resources
(NCDENR), and the National Response Center (NRC) of the discovery. The Steering
Committee advised those entities that it would prepare this Work Plan to investigate the
extent of the area of buried drums and excavate and dispose of the drums located
outside of the limits of the landfill on Site. .The Steering Committee will remove,
characterize, and properly dispose of drums and other containers and associated visibly
contaminated soils, that is coexistent with the discovered drums in the areas identified
through the investigation. The drum removal activities will be conducted in accordance
with 29 CFR 1910.120 including the handling of drums, which will be conducted in
accordance with 29 CFR 1910.120(j). The off-Site disposal of the excavated materials will
be completed in accordance with the United States Environmental Protection Agency
(USEPA) Off-Site Rule (40 CFR Part 300.440).
The tasks associated with the drum removal activities and described in this Work Plan
are listed below:
i)
ii)
iii)
iv)
v)
vi)
vii)
preparation of the Work Plan including a Health and Safety Plan (HASP);
geophysical survey to identify and inventory of drums/ containers;
procurement of subcontractors;
preparation for mobilization;
removal of drums/ containers/ debris;
drum overpacking, as necessary;
waste compatibility and waste characterization sampling of drum contents;
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viii) excavation of visibly contaminated soils;
ix) characterization and disposal of soils (as required);
x) demobilization and Site closeout activities;
xi) transportation and off-Site disposal of drums and excavated contaminated soils;
and
xii) preparation of Final Report.
The visibly contaminated soils that are excavated from the area surrounding the drums
will be sampled to determine if they are characteristically hazardous in accordance with
the applicable criteria as detailed in the Code of Federal Regulations (CFR) Title 40
Part 261 to determine appropriate disposal options.
The procedures and protocols contained in this Work Plan may be revised based on
actual conditions encountered in the field. The Steering Committee will consult with
USEPA prior to making any significant modifications to the Work Plan.
1.2 BACKGROUND
1.2.1 · SITE HISTORY
The 6-acre Site is a former solvent reclamation and waste storage facility, which had two
operators: C.A. Hughes, Inc. (1971 to 1975); and Jadco, Inc. (1975). The Site was closed
in 1975 and a North Carolina (State)' ordered cleanup was completed by 1983. After
closure of the Site, several reconnaissance evaluations were conducted by USEPA and
the State, which identified residual contamination. The Site was subsequently placed on
the National Priorities List (NPL) in May 1986. Later in 1986, an Administrative Order
of Consent (AOC) was entered into between USEP A and a group of companies
identified as potentially responsible parties (PRPs) who formed the Steering Committee.
A Remedial Investigation and Feasibility Study (RI and FS) and Superfund Risk
Assessment was completed for the Site. The RI/FS identified surface soil contaminated
by polychlorinated biphenyls (PCBs), subsurface soil contaminated by volatile organk
compounds (VOCs), base/neutral and acid extractable compounds (BNAs}, and, to a
-lesser extent, metals, groundwater contaminated by VOCs and BNAs, and VOC
contamination in the surface water in an adjacent tributary.
During the RI and FS, an Interim Remedial Measure (!RM) was completed between
September and December 1990, which resulted in the excavation and disposal of
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PCB-contaminated surface soil in the southeast swale area. Approximately 900 cubic
yards of soils were excavated and disposed of at the Chemical Waste Management Inc.
landfill in Emelle, Alabama.
Upon completion of the RI and FS, the USEP A issued a Record of Decision (ROD) on
September 27, 1990. The final remedy selected by USEPA in the ROD included deed and
access restrictions, the construction and operation of a soil vapor extraction (SVE)
system in the Former Landfill Area, construction of a soil flushing system in the SVE
trenches, construction and operation of a groundwater extraction and treatment system,
consolidation of 500 cubic yards of soil from the Former Operations Area into the
Former Landfill Area, placement of soil cover over Former Landfill Area, slip-lining of
the culvert with polyethylene pipe, and the construction of a gravity drainage line to
carry uncontaminated groundwater across the Site.
Following issuance of the ROD by USEPA, a Unilateral Administrative Order (UAO)
was issued on June 19, 1991 to the Steering Committee for the Remedial
Design/Remedial Action (RD/RA) for the final remedy. Pre-RD investigative activities
included a geophysical survey in the northern portion of the Site to supplement the
subsurface investigation that was completed during the RI, installation of five additional
monitoring wells and six piezometers, groundwater sampling, and completion of a
groundwater treatability study and an SVE pilot study.
Following USEPA approval of the Final Design Report for the Site and the RA Work
Plan, the RA was conducted in accordance with these documents. Operation of the SVE
system commenced in August 1996 and full-scale operation of the groundwater
extraction and treatment system began in August 1996. With USEPA's approval, the
SVE system was shut down in January 2001.
A bioremediation pilot study was conducted at the Site between May and
September 2002. The pilot study included the injection of a reagent (ethyl lactate) into
the Site groundwater in order to determine if groundwater remediation at the Site could
be accelerated. The pilot study confirmed that the injection of ethyl lactate into the Site
groundwater resulted in significant improvement in groundwater quality in the vicinity
of and downgradient from the injection well. In June 2004, the Steering Committee
submitted documentation to the NCDENR Underground Injection Control (UIC)
Division for the implementation of a large-scale enhanced bioremediation pilot study at
the Site, which was approved on August 4, 2004.
The large-scale enhanced bioremediation pilot study includes the installation of six
transects of five injection wells across the Site for the purpose of injecting ethyl lactate
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into the groundwater. The injection well installation commenced in November 2004 and
during the drilling activities, metal fragments including drum fragments and drum
carcasses were observed in the southeast portion of the Site. On November 18, 2004,
CRA supervised the removal of four drum skins and carcasses and uncovered
approximately five more buried drums that appeared to be intact. CRA was not
equipped to remove these drums at the time and thus secured the Site by covering the
excavation with polyethylene liner and securing the liner in place with soil. The four
excavated drums were over-packed and remain on Site pending characterization and
disposal. On November 19, 2004, CRA telephoned USEPA and left a message regardmg
the discovery of the drums.
On November 23, 2004, CRA notified USEPA regarding the events and USEPA
instructed CRA to notify the NRC and the NCDENR. CRA followed up with a
notification letter to USEP A on November 24, 2004.
1.2.2 TOPOGRAPHY AND SITE HYDROGEOLOGY
The Jadco-Hughes Site is located within the Charlotte Granite Belt of the Piedmont
Plateau,. which lies between the Coastal Plain and the Appalachian Mountains. The
topography of the Piedmont Plateau is comprised of well-rounded hills and long ridges
exhibiting a northeast-southwest trend. The hills and ridges are the result of differential
erosion by stream action due to the lithological characteristics of the bedrock. 1n the
Jadco-Hughes area, the Catawba River and its associated tributaries are responsible for
the present-day topography .
In general, the Site is relatively flat, sloping gently to the north. The Site geology is
predominantly weathered granite (saprolite) to a depth of 95 feet below ground surface
(bgs). Leru;es of fluvial deposits of clay, silt, and sand are present on the saprolite at
depths of 10 to 20 feet bgs. The chemical impacts are present primarily in the shallow
saprolite (approximately 15 feet bgs).
The water table is present at a depth of approximately 5 to 19 feet bgs. The groundwater
flow rate is approximately 8 to 14 feet per year. The groundwater flow pattern prior to
the installation and operation of the groundwater collection systems is shown on
Figure 1.2. Groundwater flowed to the north and was strongly influenced by
groundwater discharge into the on-Site culvert and the tributaries to Fites Creek. A
spring is present near the south end of the Site.
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The • layout of the groundwater collection systems is presented on Figure 1.3.
Approximately 500,000 to 600,000 gallons of water is collected and treated monthly. The
groundwater flow patterns shown on Figures 1.4 and 1.5 are representative of the
groundwater flow pattern since the collection system began operating in August 1996.
The collection systems have created complete hydraulic containment of the Site
groundwater. All surficial groundwater that flows across the Site is intercepted by the
collection systems.
1.3 WORK PLAN ORGANIZATION
This Work Plan is organized as follows:
• Section 1.0-presents the introduction and background for this Work Plan.
• Section 2.0 -presents the detailed description of a geophysical survey that will be
completed at the Site.
• Section 3.0 -presents the detailed description of the removal activities to be
completed at the Site.
• · Section 4.0 -presents a description of the report to be completed following the drum
removal.
• Section 5.0 -presents the proposed project schedule.
Also included in this Work Plan is a Health and Safety Plan (HASP) in Appendix A.
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GEOPHYSICAL SURVEY
Prior to initiating drum removal activities, CRA will complete a geophysical survey in
the general vicinity of where the drums were observed in November.
The drums were found at the south end of the Site in an area that is west of the 1994
PCB-contaminated soil excavation and east of the landfill/ spillway berm. The drums
were in a location where there is no historical evidence of disposal and in an area that
was not disturbed during the RD/RA at the Site. The locations of the drums are shown
on Figure 2.1.
A drum carcass was also observed while drilling one of the injection wells located in the
central portion of the south half of the Site, on the downward slope of the Former
Landfill Area. This Work Plan does not propose investigating or completing removal
activities on the downward slope of the Former Landfill Area, except for the removal of
the uncovered drum carcass and the restoration of this area.
The geophysical grid layout and area to be investigated are shown on Figure 2.1.
The geophysical survey will be completed using an EM31 terrain conductivity meter.
The EM31 is a terrain conductivity meter with transmitting and receiving coils located at
either end of a boom measuring approximately 14 feet in length. When these coils are
oriented as vertical dipoles, this instrument has a depth of penetration of approximately
20 feet. The EM31 will be operated in both available modes, to measure both terrain
conductivity and metal detection data. Terrain conductivity measurements will be
utilized to delineate limits of fill for the suspected disposal areas and metal detection
data will be utilized to identify any buried drums or any other metal objects.
Prior to conducting the EM31 survey, grids consisting of parallel lines will be
established over the area of investigation. The grid will utilize a number of control
points that will be surveyed on 100-foot spaced centers. The grid will be designated
with a Cartesian coordinate system, as required by the EM31 data logger.
Measurements of EM31 data will be collected along 20-foot spaced grid lines over the
area of investigation, with 10-foot spaced detailed lines completed over areas of
anomalous EM31 response. The station spacing on all grid lines will be approximately 3
to 4 feet.
Upon completion of the geophysical investigation, the survey results are presented as
colored, contoured plots that will be used to identify the presence of drums or drum
carcasses. The survey results will be used to set the boundaries of drum excavation.
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It is noted that the geophysical survey will not extend to the west beyond the limits of
the spillway berm since the area to the west is the on-Site landfill, which contains
metallic debris, The landfill contents will remain undisturbed,
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DRUM REMOVAL ACTIVITIES
3.1 GENERAL
This Section presents the rationale and sequence of tasks for the drum removal activities.
As the consultant for the Steering Committee, CRA will provide overall project
management with direction from the Steering Committee, provide oversight services
during implementation of removal activities, collect and manage related data, and
prepare the Final Report.
CRA will manage the procurement of all subcontractors including the drum excavation
and removal contractor, project analytical laboratory, on-Site liquid waste removal
contractor, and off-Site waste disposal facilities.
The USEP A and other parties involved in Site activities will be notified of the name and
qualifications of each contractor and key sub-contractors who will conduct activities at
the Site three days prior to each contractor's mobilization to the Site, or as otherwise
agreed to by other parties involved.
Following procurement of the necessary contractors, work activities to be implemented
during the drum removal will include the following:
• implementation of the HASP prior to potential contact with contaminated materials;
• Site clearing;
• mobilization of equipment, and personnel necessary to perform the work;
• preparation of Site including:
work zone identification,
construction of decontamination facilities, and
construction of staging facilities;
• excavation and removal of encountered buried drums. To the extent possible, soil
will be segregated so that soil that has been visually impacted by releases from
disposed containers will be separated from excavated soil which is not visually
impacted;
• overpacking of drums if necessary and staging of excavated drums;
• identification, compatibility and characterization sampling of containerized material;
• sampling and analysis of consolidated waste streams to characterize the wastes for
off-Site disposal;
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• the transportation and disposal of waste material at appropriate disposal facilities in
accordance with State and Federal regulations;
• performance of dmm removal closeout activities including:
decontamination of Site equipment and facilities,
treatment of stored wastewater using the on-Site groundwater treatment system,
and
demobilization of equipment from the Site.
A Final Report will be prepared to present Site dmrn removal activities, as described in
Section 4.0. Photographs will be taken in order to serve as a pictorial record of work
progress, problems encountered, and mitigation activities. CRA's file at the Site will
contain color prints (or have access to electronic photographs), labeled with date and
subject of the photograph. Photographic documentation will also be included in the
Final' Report.
The requirements of the HASP include construction of a decontamination pad and
staging pad, medical examination and training for Site personnel, and planning,
approval, and implementation of the contractor's HASP.
3.2 SITE CLEARING
Brush and vegetation will be removed in the area along the south fence prior to
completing the geophysical survey presented in Section 2.0.
3.3 SITE PREPARATION
Site preparation will include all activities necessary to prepare the Site prior to
commencing dmrn removal activities. The extent of the Site preparation activities
required is described in the following sections. A secure and safe outdoor staging area
will be carefully selected and an equipment decontamination facility will be constructed.
3.3.1 EQUIPMENT DECONTAMINATION FACILITY
An equipment decontamination facility will be constructed prior to initiating any
activity involving the handling or movement of potentially contaminated materials. A
portable decontamination pad will be installed on Site. The decontamination pad will
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include a wastewater collection sump equipped with a pump and hosing to remove
decontamination wastewaters to a wastewater storage tank (size to be determined). A
high-pressure steam cleaner with self-contained tank will be located adjacent to the
decontamination pad for decontaminating equipment, which has potentially contacted
waste material prior to the equipment leaving the Site.
3.3.2 STAGING PADS
Staging pads will be installed with a containment berm and a synthetic liner under each
pad for leak and spill protection. In addition, each pad will be constructed to allow for
the removal of collected liquids. Liquids collected in the sump will be pumped out as
necessary and transferred to the wastewater storage tank.
Typically, ·one staging pad is used for interim storage of removed cqntainers while
sampling, analyses, and compatibility testing of contents is performed, and another
staging pad is used for interim storage of containers that are characteristically distinct.
The staging pads may be constructed in cells in order to accommodate the uncertainty
associated with the number of containers, which will be staged.
A minimum of one ·staging pad will be constructed at the Site near the area in the
southern part of the Site where the buried drums were identified.
3.4 SITE SECURITY
The access gate to the Site will be kept closed and locked to prevent uncontrolled and/ or
unauthorized access to the Site. The access gate is locked at all times when the Site is
unattended. Only authorized personnel are allowed on-Site at all times.
3.5 MATERIALS HANDLING PLAN
3.5.1 SOILS
A hydraulic excavator will complete the drum removal. The excavator will be
configured with an earth excavation non-toothed bucket suitable to safely excavate to a
minimum depth of 20 feet. In the area of the drums, soil will be systematically
excavated in one-foot lifts for each 15-lineal foot section from existing ground surface to
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native undisturbed soils, up to a maximum of 10 feet in depth. Excavated soil will be
lifted from the excavation and placed on either side of the trench at a distance from the
excavation sidewall that will not promote sidewall collapse. Significantly stained or
otherwise apparently (on the basis of visual appearance and real-time air monitoring
data) contaminated soil, to the degree practical, will be segregated into separate
stockpiles from apparently non-contaminated soil.
Segregated visibly contaminated soil will be placed on 6-mil polyethylene sheeting as
they are excavated or placed directly into lined roll-off boxes located next to the
excavation. This soil will be covered with a heavy tarpaulin, which will be securely
fastened at the edges. The tarpaulin will cover the soil to the extent that no soil is visible
once the tarpaulin is in place. The tarpaulin will be placed over staged visibly
contaminated soil during periods of work stoppage and at the end of each working day.
Removal of each one-foot lift will be done in a slow and co_ntrolled manner. When
resistance to the bucket travel is noted or when evidence of potential containers or waste
disposal is present, soil will be removed in sections no longer than one foot in horizontal
measurement. When drums are encountered, removal of adjacent soils will be by hand
until containers are fully uncovered .
3.6 DRUM HANDLING PROTOCOLS
This section applies to all activities involved in the handling of drums or containers that
may have contained, or do contain, potentially harmful waste materials in both solid
and liquid state. The procedures described within this section specify the minimum
requirements that will be implemented to minimize the potential for migration of waste
constituents to the surrounding environment.
3.6.1 EQUIPMENT
a) Safety Equipment
During the handling of drums, safety apparel and equipment as specified in Section 6.0
of the HASP, will be worn or used at all times.
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b) Handling Equipment
All handling, moving, and transporting of drwns will be accomplished with mechanical
equipment whenever possible. Drwns will be moved by grappler, or if necessary, with
non-metallic slings .within a backhoe bucket or front-end loader, or by other approved
means that will prevent damage to drwns/ containers and the release of their contents.
Drwns may be transported in spill pans or skidpans to the staging area. Movement.or
handling of drwns by personnel may be required in the event that mechanical means
cannot be properly or safely employed due to drum breakage or leakage.
Until wastes are characterized, portions of equipment that contact drwns will preferably
be constructed of non-ferrous materials. Should steel construction equipment be used,
contact portions will be coated or lined to preclude spark generation in accordance with
40 CFR § 1910.120 G) (1) (xii). Portable pumps, if used, will be intrinsically safe.
All handling and transport equipment will be equipped with Class ABC fire
extinguishers and self-contained full air respiratory systems, if deemed necessary by the
Health and Safety Officer (HSO). All equipment used for the handling and transport of
drwns or containers will be regularly maintained. In particular, the ignition, manifold,
and exhaust components will be maintained to prevent backfiring or the generation of
sparks in the presence of exhaust gases.
Prior to removal from the Site, equipment will be decontaminated within the equipment
decontamination facility.
3.6.2 PROCEDURE
a) Working Groups
During the removal of the drwns, a team of personnel specifically trained in the
handling of containerized waste will be designated to perform this task. This team will
include no fewer than two people. During the handling of containerized waste, visual
contact will be maintained between members of the working team at all ti_mes. All team
members will be able to easily communicate with each other and will comply with
HASP requirements.
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b) Point-of-Removal Handling
Prior to physically handling a drum, a preliminary classification checklist will be
completed. This list will include a screening of the drum for organic vapors with an
Organic Vapor Analyzer (OVA), photoionization detector (PID), or equivalent, and a
visual description of the drum contents, and labeling information (if available and
legible). If, during this inspection, an open or leaking drum is observed to contain
liquids, the liquids will be pumped or bailed into a repack drum prior to moving the
drum. If an open drum is identified to contain solids, the drum will be carefully
removed. If the drum is neither open nor leaking, the drum will be carefully removed
and examined for structural and hydraulic integrity. Deteriorated intact drums will be
overpacked or loaded into a spill pan or skidpan prior to removal to the staging pad.
Drums will be moved by grappler, non-metallic slings within the backhoe bucket, or by
other means that will minimize damage to containers and release of contents therefrom.
After overpacking or repacking, if required, the drums will be transported to the staging
pad with a front-end loader or forklift configured with a suitable carrying apparatus.
Intact, repacked, overpacked, and secured drums will be opened and sampled at the
staging pad.
c) Spill Prevention and Response
The handling and transport of drummed/containerized waste will be conducted in a
controlled and safe manner, which will minimize damage to the containers and release
of the contents. Repack and overpack units will be provided at the point of removal and
staging pads for use in the event of leakage or spillage.
In the event that a drum of liquid is spilled, the drum handling team will immediately
respond to the spill. The spilled liquids will be confined to the immediate area of the
spill and the liquids will be pumped, with the use of a portable hand pump, into a
repack drum. Diking around the spill with an inert absorbent will confine the spilled
liquids. Residual liquids, which cannot be pumped, will be absorbed with a sufficient
quantity of inert absorbent to ensure that no free liquids remain. If the spill occurred on
soil, the visibly affected soil will be treated as contaminated material based on a visual
determination of spill contamination. The material will then be excavated and placed in
a separate stockpile pending characterization for off-Site disposal.
Liquids spilled within excavations will be pumped, with the use of a portable hand
pump, into a repack drum. Soil/ fill adjacent to the spill area will be placed to absorb
any residual liquid. Materials underlying the spill zone will be treated as contaminated
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materials based on a visual determination of spill contamination. This material will be
excavated and placed in a separate stockpile pending characterization for off-Site
disposal.
d) On-Site Contingency Plan
In the event that a release of a hazardous substances, pollutants, or contaminants occurs
on Site beyond the limit of working areas, the following protocols will be implemented:
i) Notification of Release: If a release occurs outside of the work areas in amounts
that exceed the Reportable Quantity (RQ) for the constituents that may be
present in the waste, then the NRC, the State, and USEPA will be notified as soon
as possible. For the purpose of this assessment, this Work Plan will assume that
the RQ is 100 pounds, based on the lowest RQ for substances present in
groundwater at the Site.
ii) Decontamination Procedures: Decontamination procedures may be required
after cleanup to eliminate traces of the substance spilled or to reduce it to an
acceptable level. Personnel decontamination will include showers and cleansing
or disposing of clothing and equipment, as appropriate. All contaminated
materials including solvents, clothes, soil, and other materials that cannot be
decontaminated will be properly containerized, labeled, and disposed.
iii) If a notification of release is made, a release report will be submitted to the
USEP A summarizing the release and response action.
If a major release of material stored in a tank or drum occurs on Site (such as wastewater
or bulked liquids), the following actions will immediately be taken:
i) notify USEP A, State, and NRC, as required;
. ii) take immediate measures to control and contain the release within the Site
boundaries;
iii) keep unnecessary personnel away, isolate the area of release, and restrict entry;
iv) do not allow anyone to to.uch released material;
v) stay upwind and keep out of low areas; and
vi) keep combustibles away from the released material.
Upon implementing these procedures, the immediate areas of the release will be
scanned with an OVA or PID to identify the level of protection required for personnel
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safety equipment to clean up the released material. At a minimum, personnel will wear
all protective clothing specified in Section 6.0 of the HASP. Air monitoring will
determine the need to modify the level of respiratory protection. The air monitoring
action levels as presented in the HASP will be followed during any clean up of a release.
Releases from drums, which contain solid waste, will be placed into approved
containers and covered. Each container will be labeled according to its contents.
Liquid spills will be first covered with an approved absorbent to absorb any free liquids
to minimize the amount that may infiltrate into the ground. The absorbent material
contacted by the spill will be excavated and placed in approved and labeled containers.
The spill area will be over-excavated to ensure that visibly contaminated soil is removed.
3.6.3 ENVIRONMENTAL CONTROL
3.6.3.1 SURFACE WATER CONTROL
All excavation, backfilling, drum removal and staging operations will be carried out
under dry conditions to the maximum extent possible.
Surface water runoff will be prevented from entering the work area using dikes,
sandbags, ditching, or other available means. The methods used will be subject to the
approval of CRA on the basis of field conditions encountered. Surface water runoff that
may potentially contain waste constituents will not be discharged to watercourses.
Contaminated surface water runoff, if any, associated with potentially contaminated
areas will be contained and stored in wastewater storage tanks.
All equipment necessary to maintain the staging pads free from water will be available
on Site. Collected waters will be transferred to the wastewater storage tanks. At all
times, there will be sufficient pumping equipment, machinery, and tankage in good
working condition for all emergencies, such as a power outage, and there will be
competent workers available at all times for the operation of the pumping equipment.
Drums, situated in the staging area, will be covered with an impermeable tarpaulin
during periods of work stoppage including the end of each working day. All drums will
be secured when they are full or at the end of the day. Liquids collected in the staging
pad sumps will be collected and transferred to the wastewater storage tank.
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3.6.3.2 DUST CONTROL
Dust control measures will be implemented as necessary to prevent the generation of
dust during excavation and handling operations.
3.6.3.3 SEDIMENT CONTROL
Sediment migration should not be a concern during the excavation of the drums since
any storm water will be contained within the excavation. However, should migration of
visually contaminated sediments occur, migration will be controlled using shallow
ditches or low earth dikes to trap and contain sediments. These sediment controls will
be placed in downslope positions from the active working areas. Collected sediment
will be placed in temporary storage for backfilling i.t:tto the trench at the completion of
sampling.
3.6.3.4 GENERAL HOUSEKEEPING
Daily accumulations of solid waste material such as discarded safety equipment, debris
and rubbish will be collected in garbage bags and disposed of in accordance with
Federal and State regulations.
General refuse will be contained in a designated area in the support area. The Site will
not be allowed to be littered with refuse and/or waste materials from the working areas,
but will be maintained in a neat and orderly condition throughout the construction
period.
3.7 INITIAL DRUM SAMPLING
The sampling of drummed materials will be performed at the drum-staging pad.
Material handling operations at the drum staging pads will consist of:
i) assignment of a unique container number to each drum;
ii) notation of approximate volume of contents, condition of drum, pertinent
labeling information, visual appearance of contents, and physical state;
iii) segregating solid and liquid waste drums on the basis of visual observation or, in
the event of uncertainty, in accordance with the Paint Filter Test;
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iv) collection of representative samples for compatibility testing and disposal
characterization; and
v) placement of drums in compatible groupings on the drum staging pad pending
off-Site disposal.
Empty drums, which are removed, will be crushed and stored on Site for eventual
removal off Site. Drums containing less than one inch of residue will be considered
RCRA Empty. RCRA Empty drums will be crushed and staged as a waste pile,
equipped with a 6-mil polyethylene under liner and perimeter berms, prior to off-Site
disposal at a sanitary (Subtitle D) landfill. New drums, which were used, for
repacking/ overpacking, may be reused for similar types of wastes if first cleaned of
gross/visible contamination.
In accordance with 29 CFR 1910.120(j)(iv), unlabelled drums will be considered to
contain hazardous substances and handled accordingly until the contents are positively
identified and labeled. The overpacks will be labeled to indicate that they may contain
hazardous chemicals and may contain hazardous waste, pending characterization.
Samples for waste identification will be collected from the drums as described in
Section 3.9.2.
The handling and packaging of all drums will be conducted in accordance with the
requirements of the HASP.
3.8 DRUM STORAGE
Drurhs will remain stored at the staging pad until the results of the Characterization
Analysis, as outlined in Section 3.9.2 have determined whether or not the waste is
hazardous.
Once compatibility and characterization analyses are completed and an appropriate
method of disposal is determined, the drummed waste will be disposed of off-Site in
accordance with Federal and State regulations for the disposal of hazardous and/ or
non-hazardous wastes.
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3.9 DRUM SAMPLING
The sampling and analytical protocols associated with all sampling events will ensure
that sampling and analyses comply with USEPA guidance on quality assurance/quality
control (QA/QC}, data validation, and chain of custody procedures.
If USEPA requests it, the QA/QC procedures followed by the sampling teams and
laboratories performing the work will be provided to USEPA.
3.9.1 COMPATIBILITY ANALYSIS
Drummed/ containerized wastes will be segregated according to compatibility
characteristics. These characteristics will be determined by analysis of one sample per
drum/container for initial compatibility testing as presented in Table 3.1. This initial
compatibility testing will be completed on intact containers· whose contents are not
visually compatible with known waste streams. Field screening analyses for
compatibility testing of visually distinct wastes is likely to consist of the parameter and
analytical methods that are also listed in Table 3.1.
3.9.2 CHARACTERIZATION ANALYSIS
Disposal characterization analyses will be conducted on representative composite
samples of the materials contained in the drums/containers to determine if the
containerized mate.rial is hazardous, in accordance with 40 CFR 261, to determine the
appropriate action for disposal of the material off Site.
For the purposes of off-Site disposal facility approval, a minbnum of one representative
sample from each waste stream will be collected to characterize the range of hazardous
constituents potentially present at the Site. A summary of specific analytical methods to
be used for disposal characterization analyses is presented in Table 3.2.
Specific characterization analysis will be determined based on the actual contents of the
drums/ containers. Based on Site conditions, Table 3.2 may have to be revised. The
number of samples to be collected will be determined in consultation with the off-Site
disposal facility.
Waste materials will be segregated as liquid wastes or solid wastes when the drums are
opened on the staging pad. Materials for which this classification is not readily
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apparent, classification will be determined using the Paint Filter Test. The results of the
test will govern disposal classification. In accordance with 40 CFR Part 264 -Subpart N -
Landfills, materials passing the Paint Fi1:ter Test will be disposed of in a RCRA or TSCA
compliant landfill, if found to be hazardous. Materials failing the Paint Filter Test will
be considered liquid wastes and will be subject to additional compatibility testing and
characterization as deemed appropriate, prior to disposal. If found to be hazardous, the
wastes will be disposed of at an off-Site RCRA or TSCA compliant facility.
3.9.3 REMOVAL OF VISUALLY COMPATIBLE WASTE STREAMS
Buried drums will be removed in accordance with the protocols as described in
Section 3.6. These containers and the associated spilled contents will be secured in
overpacks, spill pans or skid pans and moved to the staging pad. Samples will be
collected in the staging area and analyzed on Site for the list of compatibility analyses
discussed above.
Once the on-Site analyses indicate that the visually compatible wastes are chemically
compatible, then these wastes will be loaded into roll-off boxes or other waste haulage
units for bulking and the collection of further samples required for acceptance to a
disposal facility, as discussed previously. The need for any bulking of waste is highly
dependent on the amount of material buried on the Site. Off-Site haulage units will
comply with Department of Transportation (DOT} regulations.
3.9.4 REMOVAL, CRUSHING, SHREDDING, AND
OFF-SITE DISPOSAL OF EMPTY CONTAINERS
Upon encountering a drum, the drum will be examined to determine if it is "empty" (a
one-inch heel is an empty drum, as defined in RCRA). Empty drums will be segregated,
removed to the staging area, and crushed or shredded for off-Site disposal as a Resource
Conservation and Recovery Act (RCRA) Subtitle D waste.
3.9.5 REMOVAL OF INT ACT CONTAINERS
If a drum is found to be intact, it will be recovered in accordance with the procedures
described in Section 3.6, and transported in an overpack drum, spill pan, or skid pan to
the staging area for opening, inspection, sampling, and compatibility analyses.
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If after opening and sampling, the drum's contents appear to match one of the
established visually distinct and compatible waste streams, the sample will be submitted
for on-Site compatibility analyses as described in Section 3.9.1, and consolidated
accordingly.
If after opening and sampling, the drum's contents do not appear to match one of the
established visually distinct and compatible waste streams, the sample will be submitted
for off-Site compatibility analyses as described previously. The drum will then· be
secured on the staging pad pending receipt of the compatibility analyses. The results of
these analyses will determine whether or not the drum matches an established waste
stream. A new compatibility group will be created should the contents of the drum not
match one of the established waste streams.
3.10 ATMOSPHERIC EMISSIONS MONITORING AND CONTROL
Air monitoring will be performed during Project activities in accordance with the HASP
presented in Appendix A.
3.11 PREPARATION OF OFF-SITE TRANSPORT VEHICLES
All off-Site transport vehicles will be DOT-approved and will be prepared as
appropriate prior to receiving waste. The boxes of all vehicles, which will transport bulk
materials will be lined with a continuous sheet of polyethylene prior to loading and will
have sealed tailgates. Drummed/ containerized wastes will be loaded and secured in a
manner, which will prevent damage to the containerized materials.
A weatherproof tarp will be provided and secured over each shipment leaving the Site,
with the exception of enclosed box transport units.
3.12 OFF-SITE WASTE TRANSPORTATION AND DISPOSAL
3.12.1 MANIFESTING AND LABELING
Non-hazardous solid waste will be transported under a bill of lading.
Drums/ containers designated for off-Site disposal will be labeled and manifested (if
hazardous) prior to leaving the Site for off-Site treatment, storage or disposal (TSO)
facilities. The analytical results obtained from disposal characterization analyses will be
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used for manifesting purposes and for detennining the necessary placarding of vehicles.
The manifest forms and records will be consistent with 40 CFR Part 262 "Standards
Applicable to Generators of Hazardous Waste", 40 CFR Part 263 "Standards Applicable
to Transporters of Hazardous Waste" and the North Carolina Administrative Code
(NCAC) (Title 15A NCAC 13.0107 and 15A NCAC 13.0108).
A hazardous Waste Generator Number will be obtained from USEPA and will be used
on all manifests. A designee will be responsible for signing all manifests as generator.
The designee will be trained as required by 40 CFR 172 Subpart H (Docket HM126F).
3.12.2 AUTHORIZED TRANSPORTERS
Only transporters that are licensed by USEPA, OOT, and the State of North Carolina will
be used for the transport of hazardous materials if wastes are found to be hazardous. If
wastes are scheduled for transport to facilities outside of the State of North Carolina,
transporters will have current licenses in the appropriate State(s) and comply with other
applicable Federal laws including DOT requirements.
If wastes are deemed to be non-hazardous, then transporters will be licensed for general
transportation of non-hazardous wastes or as required by the State for the transport of
Special Waste.
3.12.3 OFF-SITE CONTINGENCY PLAN
Transportation routes to off-Site TSD facilities will be predetermined prior to
commencing off-Site transport of waste materials. A primary and secondary route to
each TSD facility will be identified. The secondary route will be used only if the primary
route becomes impassable due to weather and road conditions or blockage from traffic
accidents. The appropriate State and interstate officials will be consulted as to whether
any proposed routes are scheduled for construction or seasonal closures, which will
occur during implementation of this Project.
Following disposal characterization analyses and selection of the site(s) for off-Site
disposal, an off-Site contingency plan will be prepared, if required, and submitted to the
USEPA for approval. It is expected that this approval will be granted expeditiousjy.
Items to be included in this plan are as follows:
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• Emergency Response Procedures (fire, explosion, spill);
• Communications; and
• Responsibilities.
3.12.4 OFF-SITE DISPOSAL
a) Approved Disposal Facilities
All off-Site shipments of waste will be appropriately disposed at a facility in compliance
with USEP A's Off-Site Rule, 40 CFR 300.440. Off-Site TSD facilities for drummed wa~tes
and wastewaters will be approved by third party representatives prior to commencing
transport to these facilities. All facilities identified will be RCRA compliant and/ or
Toxic Substances Control Act (TSCA) compliant, as applicable, and will comply with the
requirements specified hereafter.
Any drums/containers deemed to be non-hazardous as determined by the disposal
characterization analyses will be disposed of off Site in accordance to applicable Federal
and State regulations.
Any wastes deemed to be non-hazardous may be transported to a non-hazardous
landfill.
b) Agreement
Each designated disposal facility will provide an agreement to take the waste from the
Site. This agreement can be on any form typically used by the facility (such as a waste
profile form) and will specify the total estimated quantities of wastes and the intended
method of disposal for each waste stream. Agreements will be provided to USEP A for
information purposes only. Each agreement will provide the facility name and USEPA
Identification Number, facility locations, name of responsible contact for facility,
telephone number for the contact, and any additional waste characterization
requirements. It may be necessary to supplement the disposal information provided by
the designated disposal facilities. CRA will provide this supplementary information, if
necessary.
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3.12.5 DOCUMENTATION
· The appropriate documentation will be generated and maintained for material
transported from the Site to an off-Site facility. A waste shipment record, waste
manifest, or bill of lading that identifies the generator, transporter, and disposal facility,
and corresponding USEPA identification number, the nahtre of the material, the date
and time the material was transported from the Site, and the estimated weight or
volume of material will be provided with each loaded transport vehicle. The manifest or
bill of lading will be signed by a representative or agent of the Steering Committee and
the transport vehicle driver before the material is transported from the Site. A copy of
the manifest or bill of lading will be retained by the Engineer for documentation
purposes. Bills of lading will be issued for non-hazardous material removed from the
Site.
Upon receipt of the material, the disposal/reclamation facility will be required to sign
the manifest. A copy of the signed manifest will be rehtmed to CRA for record-keeping
purposes.
3.12.6 INSPECTION OF TRANSPORT VEHICLES
Care will be taken to prevent contamination of transport vehicles during loadout for
off-Site disposal. All vehicles exiting the Exclusion Zone, if necessary, will be
decontaminated at a decontaminatjon station located outside the Exclusion Zone. In the
event effective decontamination cannot be · accomplished using dry methods, a
high-pressure wash will be utilized. Decontamination water will be collected and
contained at the decontamination station for subsequent removal and off-Site disposal.
The Engineer will inspect the Site entrance and street to ensure contamination/ debris is
not being tracked off Site.
3.12.7 OFF-SITE EMERGENCY SPILL RESPONSE
Transport vehicle drivers will be advised to observe the designated route and report any
spills attributable to the transport of waste materials forthwith to CRA. CRA will, as
required by law, provide notification to USEPA, the State, and NRC of any reportable
spill incidents. In the event of an off-Site reportable spill incident, CRA and the
transporter will ensure that appropriate cleanup ~. conducted. CRA will provide
oversight to ensure the cleanup of spilled material. CRA will submit a report to USEPA
within 24 hours of the reportable spill incident, including the spill location, date and
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time of the spilt volume of material spilled, response actions taken to abate the spill, and
precautions implemented to prevent future spills.
3.13 BULK LIQUID HANDLING
3.13.1 BULK LIQUIDS
This section addresses any bulk liquids, which may be required to be addressed during
the drum removal. Based on the observation made during the initial drum carcass
removal, it is unlikely that any bulk liquids will be encountered.
3.13.2 BULK LIQUID REMOVAL
Samples will be collected to determine the compatibility of each potential waste stream,
as well as for waste characterization purposes. Compatibility sampling and waste
characterization sampling will follow procedures as described in Section 3.9.1 and 3.9.2.
To remove all bulk liquid waste, an on-Site vac-truck will be used to vacuum up all
liquid material. In order to remove the liquid waste more efficiently, it may be
necessary to temporarily install steam lines to decrease the viscosity of the liquid waste.
As well, a crew with squeegees may be required to move the liquid material towards the
vacuum hose.
Once the bulk liquid waste has been removed, the tanks/ equipment will be inspected to
evaluate the need for additional waste removal. Additional labor may be employed to
scrape and/ or power wash the interiors. Residual solids, where present, will be scraped
and collected into a designated container(s). Thereafter, the tank may be cleaned with a
low volume, high-pressure water wash, which will minimize the quantity of wastewater
generated. Generated washwater will be collected and characterized for off-Site
disposal at a licensed facility.
3.13.3 BULK LIQUID DISPOSAL
Based on waste characterization sampling analysis, all bulk liquid will be appropriately
disposed of at a facility in compliance with USEPA's Off-Site Rule, 40 CFR 300.440.
Off-Site facilities will be approved by USEPA prior to commencing transport to these
facilities. All facilities identified will be RCRA compliant and/ or TSCA compliant, if
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necessary. Any wastes deemed to be non-hazardous may be transported to a
non-hazardous landfill and/ or POTW system, as applicable, for disposal.
All bulk liquid generated will be transported to appropriate off-Site facilities for final
disposition in accordance with all applicable State and Federal regulations.
3.14 DRUM REMOVAL CLOSEOUT
3.14.1 GENERAL
All closeout activities associated with the drum removal activities will be coordinated
and performed in such a manner that no waste materials scheduled for off-Site disposal
or mobilized facilities remain at the Site upon completion of this activity.
3.14.2 FINAL EQUIPMENT DECONTAMINATION
A final decontamination of all equipment will be performed on the equipment
decontamination pad. Decontamination of equipment will consist of brushing and wire
.brushing to remove loose dirt and debris and adhered residues, and a high-pressure hot
water wash. Particular attention will be paid to joints, sprockets, and undercarriages.
Each piece of equipment will be inspected after decontamination prior to removal from
the Site. An inspection record will be maintained on Site. Each decontaminated piece of
equipment leaving the Site will be recorded on the inspection record along with the
name of the inspector.
3.14.3 WASTEWATER
CRA will notify the City of Mount Holly (City) of the intent to discharge stored
wastewater generated from equipment decontamination ·activities to the on-Site
groundwater treatment facility. CRA will provide analytical data of the wastewater to
the City prior to discharge. If the City approves the discharge, CRA will send the
wastewater through the system such that the discharge criteria will not be exceeded.
If the City does not approve the discharge of wastewater through the groundwater
treatment system, the wastewater will be disposed off-Site in accordance with Federal
and State regulations.
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3.15 FINAL CLEANUP
Final cleanup will involve cleaning the Site of all litter and trash and leaving the Site in a
neat and orderly condition. Litter and trash resulting from the work will be disposed of
at a non-hazardous landfill.
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REPORTS
A draft Final Report will be submitted to USEPA for review within 45 working days
after off-Site disposal of the excavated material. This draft Final Report will contain the
following:
• a summary of drum removal activities;
• a photo log;
• a listing of quantities and types of materials removed off-Site or handled on Site;
• a summary of the analytical results of all sampling and analyses performed;
• a summary of any field observations made during sampling activities;
• a description of the nature and extent of any contamination encountered at the Site;
• a discussion of removal and disposal options considered for materials removed;
• a listing of the ultimate destinations of the materials removed;
• copies of all manifests for the materials removed; and
• appendices containing relevant documentation generated during the drum removal.
The draft Final Report will include the start and completion dates of each removal
activity.
Upon review by USEP A and receipt of comments, if any, CRA will finalize the report
within 15 working days following the receipt of USEP A's comments on the draft Final
Report. This report will constitute the last step in the drum removal project.
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PROJECT SCHEDULE
CRA received NCDENR's verbal concurrence to proceed with the geophysical survey on
December 7, 2004 and thus CRA will complete the geophysical survey on December 9
and 10, prior to receipt of USEPA's approval of this Work Plan. The removal of the
drums and any impacted soil will commence within five days after receiving approval
from the USEPA to proceed. It is estimated that the drum removal program will take
approximately seven days to complete. The schedule is dependent upon the results of
the geophysical survey, weather, maintaining appropriate Site access, and receipt ·of
requisite agency approvals.
An estimated schedule for the drum removal activities is presented in Table 5.1.
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SOURCE: MOUNT HOLLY, N.C. 1 :24,000 QUAD.
03669-10(031)GN-WA001 DEC 08/2004
figure 1. 1
SITE LOCATION
JADCO-HUGHES SUPERFUND SITE
Gaston County, North Carolina
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LEGEND
-----PROPERTY LINE
• MWSS
• PZ9S
SHALLOW MONITORING WELL
r
SHALLOW PIEZOMETER
=;> GROUNDWATER FLOW DIRECTION
650 GROUNDWATER CONTOUR (FT. AMSL)
/656.91) GROUNDWATER ELEVATION (APRIL 30, 1993)
/NMJ WATER LEVEL NOT MEASURED
TRIBUTARY '8'
// t,
II "' ro ~ ~ \\
\o
~ Q MW4S
/656:26
_ __}6'0 C0NCRETE Cl IL VERT
/65350) ~ --;:-
03669-10(031 )GN-WA002 DEC 08/2004
657 • /656:()(})
MWBS
(656.91) MW2S
(657.(XJ)
• MW3S
(655.66)
~
DD
0 50 100ft
I I ""
{:? (if f:fs -~ " (cj (cj (cj ,___ '0~ ;i
.PZ7 (646.89)
MWSS • (646.99)
• PZBS
(646.75)
.\
PZ9S I {646.36)
\
1,
! ) l
figure 1.2
SHALLOW GROUNDWATER FLOW PATTERNS -APRIL 30, 1993
PRE-PUMPING CONDITIONS
JADCO-HUGHES SUPERFUND SITE
Gaston County, North Carolina
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LEGEND
PROPERTY LINE
- - - - - -TREATED WATER DISCHARGE LINE
PIPELINE
-----------PERIMETER COLLECTION TRENCH
ePW1
oMH
■ MH5
EXTRACTION WELL
MANHOLE
PUMP CHAMBER
___ )_\_
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~-
36"0 CONCRETE CULVERT = = --
PW1
11
MH11
J: e
. ' PW4
I 'fil
)
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03669-10(031)GN-WA003 DEC 08/2004
CASON STREET
PW3
= -
MH10
0
SPRING
----'-(._SI_D_EROAD 2035)
RAISED CONCRETE PADS
□□
0 50 100ft
Ji
figure 1.3
GROUNDWATER EXTRACTION SYSTEM LAYOUT
JADCO-HUGHES SUPERFUND SITE
Gaston County, North Carolina
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LEGEND
-------PROPERTY LINE
- - - --- -TREATED WATER DISCHARGE LINE
e MW6S
e PZ9S
SHALLOW MONITORING WELL LOCATION
SHALLOW PIEZOMETER LOCATION
PIPELINE (642.16)
------------PERIMETER COLLECTION DRAIN 651----
GROUNDWATER ELEVATION (ft. AMSL) DECEMBER 12, 2000
GROUNDWATER CONTOUR
A PW1 EXTRACTION WELL
MANHOLE
■ MHS PUMP CHAMBER
GROUNDWATER FLOW DIRECTION
~ SS14 STREAM MONITORING LOCATION
____ )_\_
__31B~7~y .8, -
03669-10(031)GN-WA004 DEC 0812004
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NOTE: 1. GROUNDWATER CONTOURS GENERATED UTILIZING
SURFER VERSION 6.04, SURFACE MAPPING SYSTEM,
KRIGING METHOD.
MW13S
(6..<;Q.52).
0 50 100ft
figure 1.4
SHALLOW GROUNDWATER FLOW PATTERNS
DECEMBER 12, 2000
J_ADCO-HUGHES SUPERFUND SITE
Gaston County, NC
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LEGEND
-------PROPERTY LINE 8 MW6S
-------TREATED WATER DISCHARGE LINE e PZ9S
SHALLOW MONITORING WELL LOCATION
SHALLOW PIEZOMETER LOCATION
PIPELINE (640.46)
------------PERIMETER COLLECTION DRAIN 646----
===:[>
GROUNDWATER ELEVATION (ft. AMSL) DECEMBER 8, 2003
GROUNDWATER CONTOUR
A PWl EXTRACTION WELL
MANHOLE
■ MH5 PUMP CHAMBER
GROUNDWATER FLOW DIRECTION
C!i:J S514 STREAM MONITORING LOCATION
___ L\_
~16!1T~<Ry ·e· ---
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03669-10(031 )GN-WA00S DEC 08/2004
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_t~ __ ----
c,, SON STREET
NOTE: 1. GROUNDWATER CONTOURS GENERATED UTILIZING
SURFER VERSION 7.03, SURFACE MAPPING SYSTEM,
KRIGING METHOD.
0 50 10011
figure 1.5
SHALLOW GROUNDWATER FLOW PATTERNS
DECEMBER 8, 2003
JADCO-HUGHES SUPERFUND SITE
Gaston County, NC
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LEGEND
-------PROPERTY LINE • l.1W6S SHALLOW MONITORING WELL LOCATION
-- - - - --TREATED WATER DISCHARGE LINE e PZ9S SHALLOW PIEZOMETER LOCATION
PIPELINE t) MW6S1 INJECTION WELL LOCATION
------------PERIMETER COLLECTION DRAIN @ NEWLY INSTALLED INJECTION WELL LOCATION
.A, PW1 EXTRACTION WELL
~MH MANHOLE
~ MHS PUMP CHAMBER
0 SS14 STREAM MONITORING LOCATION
□ OP15 OBSERVATION PIT
□ TP2 TEST PIT
■ BH11 BOREHOLE
_)_\_
PROPOSED GEOPHYSICAL
SURVEY GRID
~IB~TARY '8'
. -S51
!:IP-5
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NEWLY INSTALLED SHALLOW
MONITORING WELL LOCATION
MAGNOMETER SURVEY AREA
APPROXIMATE EXTENT OF
FORMER LANDFILL AREA
MW13S
CASON STREET
.MW13D
t,
5S47 PROPOSED GEOPHYSICAL SURVEY GRID
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03669-10(031)GN-WA006 DEC 08/2004
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NOTE: CRA WILL CONDUCT THE GEOPHYSICAL SURVEY TO THE
BASE OF THE FORMER LANDFILL AREA BASED ON VISUAL
OBSERVATIONS IN THE FIELD.
t::,,_S545
6. SS29
~ P-11
l:l P-20
~
CZ]
• MW9S
SEDIMENT SAMPLE
SOIL SAMPLING LOCATION
SOIL SAMPLING LOCATION
SOIL EXCAVATION AREA (10 INCH DEPTH)
SOIL EXCAVATION AREA (20 INCH DEPTH)
0 50
I
DISCHARGE TO 11
~T. HOLLY POTW \ ,------
100ft
-----------~---,, I··\~ J,,-;-;-;---
5S12~
Mw1ss•
figure 2.1
LAYOUT OF THE GEOPHYSICAL SURVEY GRID
JADCO-HUGHES SUPERFUND SITE
Gaston County, NC
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Task
Notes:
2
3
4
5
6
7
8
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TABLE 5.1
SCHEDULE OF DRUM REMOVAL ACTIVITIES
JADCO-HUGHES SUPERFUND SITE ·
GASTON COUNTY, NORTH CAROLINA
Dtscription
Geophysical Survey
Mobilization
Site Preparation
Drum Removal
Characterization Sampling
Laboratory Analysis
Receipt of Analytical Data
Obtain Disposal Facility Approval
off-Site Transport and Disposal
Draft Report ~o USEP A
Final Report to USEPA
Estimated
Durtition (1)
2 days
1 day
1 day
5 days
lOdays
15 days
3days
Estimated
Start Date
9-De<:--04
5 days after receipt of USEP A
approval of the Work Plan
Immediately follows previous
task
Immediately fol!0ws previous
task
Immediately follows previous
task
Immediately follows previous
task
Immediately follows previous
task
(1) All days are working days.
The Steering Committee will discuss the schedule with USEPA if the schedule includes Christmas and New Year's Day
to accommodate contractor availability during these periods.
CRA 3669 (31)
Estimated
End Date
10-Dec--04
6 dilys after receipt of USEl'A
approval of the Work Plan
40 days after Mobilization
45 days after off-Site Disposal
of Excavated Mat~rial
Complete
15 days following receipt of
USEPA's comments on the
Draft Report
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I HEALTH AND SAFETY PLAN
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HEALTH AND SAFETY PLAN
JADCO-HUGHES SUPERFUND SITE
GASTON COUNTY, NORTH CAROLINA
DECEMBER 2004
REF. NO. 3669 (32)
This report is printed on recycled paper.
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TABLE OF CONTENTS
1.0 INTRODUCTION ................................................................................................................... 1
1.1 PROJECT ORGANIZATION ............................................................................. 2
2.0 SITE CHARACTERIZATION AND POTENTIALLY
HAZARDOUS COMPOUNDS ............................................................................................. 5
3.0 BASIS FOR DESIGN ............................................................................................................... 6
4.0 RESPONSIBILITIES AND ADMINISTRATION ................................................................ 7
5.0 WORKER TRAINING AND EDUCATION ........................................................................ 9
6.0 PERSONAL PROTECTIVE EQUIPMENT (PPE) ............................................................. 10
6.1 PROTECTIONLEVELS .................................................................................... 10
6.2 REASSESSMENT OF PROTECTION LEVELS ............................................. 12
6.3 DURATION OF WORK TASKS ...................................................................... 13
6.4 LIMITATIONS OF PROTECTIVE CLOTHING ............................................ 13
6.5 RESPIRATORY PROTECTION PROGRAM ................................................. 15
6.6 SITE CONTROL ................................................................................................ 17
7.0 ACTIVITY HAZARD /RISK ANALYSIS ........................................................................... 21
7.1 CHEMICAL EXPOSURE ...................... , ........................................................... 21
8.0 AIR MONITORING .............................................................................................................. 24
8.1 REAL-TIME AIR MONITORING ................................................................... 24
8.2 BACKGROUND MONITORING .................................................................... 25
8.3 CALIBRATION AND DATA REPORTING .................................................. 25
'
10.0 DECONTAMINATION PROCEDURES ........................................................................... 26
10.1 EQUIPMENT DECONTAMINATION PROCEDURES .............................. 26
10.2 PERSONNEL DECONTAMINATION PROCEDURES ............................... 27
11.0 GENERAL SAFETY AND PERSONAL HYGIENE .................................................... : .... 28
11.1 SAFETY MEETINGS .......... : .............................................................................. 28
12.0 MEDICAL SURVEILLANCE .............................................................................................. 29
13.0 ENVIRONMENTAL CONTROL PROGRAM .................................................................. 30
13.1 WEATHER MONITORING ............................................................................. 30
13.2 RAIN AND SNOW ........................................................................................... 30
13.3 TEMPERATURE ................................................................................................ 30
13.4 WIND .................................................................................................................. 31
3669(32) CONESTOGA-ROVERS & ASSOCIATES
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TABLE OF CONTENTS
14.0 EMERGENCY RESPONSE .................................................................................................. 32
14.1 EMERGENCY CONT ACTS ............................................................................. 32
14.2 EMERGENCY EQUIPMENT AVAILABLE ON SITE .................................. 32
14.3 PROJECT PERSONNEL RESPONSIBILITIES
DURING EMERGENCIES ............................................................................... 33
14.4 MEDICAL EMERGENCIES ............................................................................. 33
14.5 FIRE OR EXPLOSION ...................................................................................... 34
14.6 SPILLS OR CONTAINER LEAKS ................................................................... 34
15.0 RECORDKEEPING ............................................................................................................... 35
3669(32) CONESTOGA-ROVERS & ASSOCIATES
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FIGURE 1.1 SITE LOCATION
LIST OF FIGURES
(Following Text)
FIGURE 14.1 DIRECTIONS TO HOSPITAL
LIST OF TABLES
(Following Text)
TABLE 2.1 TOXILOGICAL DATA OF SITE CONTAMINANTS
TABLE 6.1 SPECIFIC PERSONAL PROTECTION LEVELS
TABLE 6.2 AIR MONITORING ACTION LEVELS
TABLE 7.1 ANTICIPATED HAZARDS/RISKS AND APPROPRIATE PRECAUTIONS
TABLE 14.1 EMERGENCY CONTACT INFORMATION
LIST OF APPENDICES
APPENDIX A CRA'S STANDARD HEALTH AND SAFETY PROCEDURES
APPENDIX B HASP PLAN ACKNOWLEDGEMENT SHEET
APPENDIX C SAFETY (TAILGATE) MEETING FORM
3669(32) CONESTOGA-ROVERS & ASSOCIATES
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1.0
3669(32)
INTRODUCTION
The Health and Safety Plan (HASP) presented herein describes the health and safety
procedures and emergency response guidelines to be implemented during the. drum
removal and associated activities at the Jadco-Hughes Superfund (Site) located in Gaston
County, North Carolina. Figure 1.1 presents the Site location.
The scope of work to be completed during the project activities include the following
work activities:
• implementation of the HASP prior to potential contact with contaminated materials;
• Site clearing;
• mobilization of equipment, and personnel necessary to perform the work;
• preparation of Site including:
work zone identification,
construction of decontamination facilities, and
construction of staging facilities;
• excavation and removal of encountered buried drums. To the extent possible, soil
will· be segregated so that soil that has been visually impacted by releases from
disposed containers will be separated from excavated soil which is not visually
impacted;
• overpacking of drums if necessary and staging of excavated drums;
• identification, compatibility and characterization sampling of containerized material;
• sampling and analysis of consolidated waste streams to characterize the wastes for
off-Site disposal;
• the transportation and disposal of waste material at appropriate disposal facilities in
accordance with State and Federal regulations;
• performance of drum removal closeout activities including:
decontamination of Site equipment and facilities,
treatment of stored wastewater using the on-Site groundwater treatment system,
and
demobilization of equipment from the Site.
During a portion of these activities, personnel may come in contact with both solid and
liquid waste materials, which may contain hazardous substances. This HASP has been
CONESTOGA-ROVERS & ASSOCIATES
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developed to minimize direct contact by Site personnel with materials potentially
having chemical presence by ensuring:
i) that Site personnel are not adversely exposed to the compounds of concern;
ii) that public health and the environment are not adversely impacted by materials
with elevated chemical presence which may potentially migrate outside of the
work zone during project activities at the Site;
iii) compliance with applicable governmental and non-governmental (American
Conference of Governmental Industrial Hygienists [ACGIH]) regulations and
guidelines. In particular, the amended rules of the Occupational Safety and
Health Administration (OSHA) for Part 1926 (Title 29 Code of Federal
Regulations [CFR] Part 1926.65) will be implemented for all Site work; and
iv) initiation of proper emergency response procedures to minimize the potential for
any adverse impact to Site workers, the general public, or th~ environment.
For the purpose of this HASP, activities involving contact with materials with
potentially elevated chemical concentrations will be considered contaminated operations
requiring Personal Protective Equipment (PPE). A detailed description of the PPE
required is presented in Section 6.0.
The applicability of this HASP extends to all personnel who will be. on Site. Contractors
and subcontractors who will work with CRA at the Site will be required to prepare and
implement a HASP and provide all applicable Health and Safety Standard Operating
Procedures (SOPs) for use by their Site personnel. In addition, contractors and
subcontractors will be responsible for the health and safety of their personnel.
All project activities at the Site will be conducted in accordance with the provisions of
the 1997 USEPA-approved Site-specific HASP and this drum removal HASP. A copy of
the Site-specific HASP and employer-specific SOPs will be maintained on Site whenever
activities are in progress.
1.1 PROTECT ORGANIZATION
The project activities will be organized as follows. CRA will provide oversight for the
project and various environmental contractors and subcontractors will assist with
project activities as necessary. Additionally, CRA will be responsible for ensuring
compliance with the Site-specific HASP and this drum removal HASP.
2 CONESTOGA-ROVERS & ASSOCIATES
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To ensure compliance with the HASP, CRA will:
i) be responsible for daily monitoring and enforcement of the HASP;
ii) be responsible for assisting pre-construction training of all on-Site personnel with
regard to this HASP and other safety requirements to be observed during Site
work, including:
a) potential hazards,
b) personal hygiene principles,
c) personal protective equipment,
d) respiratory protection equipment usage and fit testing,
e) emergency procedures dealing with fire and medical situations,
f) emergency response procedures,
g) cold and heat stress principles,
h) severe weather, and
i) decontamination procedures and PPE requirements during
decontamination procedures;
iii) be aware of situations when the Contractor is starting any particularly hazardous
work;
iv) be responsible for the maintenance of separation of Exclusion Zone and Support
Zone areas as described hereafter including maintenance of entry and exit logs
and daily sign in sheets;
v) maintenance of the emergency contingency plan found in Section 4.0;
vi) conduct all on-Site air monitoring (see Section 6 for frequency of monitoring);
vii) provide supervision for decontamination activities;
viii) have authority to suspend work activity due to unsafe working conditions;
ix) maintain the on-Site Hazard Communication Program including copies of
Material Safety Data Sheets (MSDSs);
x) ensure that all drum handling procedures are in accordance with
29 CFR 1910.120 (j) and the Resource Conservation and Recovery Act (RCRA);
xi) conduct brief daily safety meetings including improving or updates on work
practices;
xii) regularly verify that the route to the hospital from the Site has not been
compromised by construction, etc.;
3 CONESTOGA-ROVERS & ASSOCIATES
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3669(32)
xiii) have a nummum of 2 years Site related working experience specific to the
handling and excavation of containerized waste or contaminated soils; and
xiv) have a working knowledge of State and Federal occupational safety and health
regulations; and
The on-Site CRA representative (Engineer) will be certified in first aid and
cardiopulmonary resuscitation. CRA will be responsible for ensuring that all contract
specifications are met, including those related to Site health and safety.
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2.0
3669(32)
SITE CHARACTERIZATION AND POTENTIALLY
HAZARDOUS COMPOUNDS
Previous Site assessment and sampling of the Site has identified the presence of known
chemical compounds at the Site. The chemical compounds that are known to be on the
Site include a list of volatile organic compounds (VOCs), semi volatile organic
compounds (SVOCs), polychlorinated biphenyls (PCBs), and metals.
Table 2.1 presents a list of chemicals known to be present at the Site including the
exposure routes and exposure limits for the chemical compounds present at the Site.
The list also includes occupational exposure limits in air. These levels are set to protect
the health of workers. It should be noted that there is drummed waste material that is of
unknown origin on-Site, including potentially flammable or corrosive compounds.
5 CONESTOGA-ROVERS & ASSOCIATES
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3.0
3669(32)
BASIS FOR DESIGN
Regulations set forth by OSHA in Title 29, Code of Federal Regulations, Parts 1910 and
1926 (29 CFR 1910 and 1926) form the basis of this HASP. Emphasis is placed on
Sections 1926.65 (Hazardous Waste Operations and Emergency , Response),
1910 Subpart I (Personal Protective Equipment), Subpart D (Occupational Health and
Environmental Controls), and 1910 Subpart Z (Toxic and Hazardous Substances). In
addition, current Potential Exposure Limits (PEL) formulated by OSHA have been
considered in the development of the selection of PPE. Some of the specifications within
this section are in addition to. the OSHA regulations, and reflect the positions of the
United States Environmental Protection Agency (USEPA), the National Institute for
Occupational Safety and Health (NIOSH), and ,the United States Coast Guard (USCG)
regarding safe operating procedures at uncontrolled hazardous waste Sites.
The health and safety of the public and Site personnel and the protection of the
environment will take precedence over cost and schedule considerations for all project
work.
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4.0
3669(32)
RESPONSIBILITIES AND ADMINISTRATION
The Engineer shall be responsible for all decisions
stoppage due to health and safety considerations.
experience in working at Hazardous Waste Sites.
regarding operations and work
The Engineer will have prior
In addition to the responsibilities described above, the Engineer's responsibilities
include:
i) supervision and enforcement of safety equipment usage, including the required
use of extra equipment if appropriate;
ii) supervision and inspection of equipment cleaning; supervision of
iii)
iv)
decontamination activities;
conduct the on-Site personnel safety indoctrination session for potential hazards,
personal hygiene principles, all other SOPs, safety equipment usage, emergency
procedures, and location of first aid kits and fire extinguishers, and identification
of personnel trained in first aid and cardiopulmonary resuscitation (CPR);
maintain Exclusion Zone (EZ) and Contaminant Reduction Zone (CRZ) work
areas;
v) review and modify, and maintain the HASP amendments as more information
becomes available or conditions warrant;
vi) authority to suspend work activity due to unsafe working conditions or failure to
strictly adhere to the HASP;
vii) coordination of emergency procedures;
viii) be responsible for conducting the air monitoring and air sampling program;
ix) ensure that all on-Site personnel have obtained the required medical examination
prior to arrival at the Site, have met the OSHA training requirements, and have
been fit tested for the respiratory equipment they may use;
x) maintain records to be kept on Site and on-Site generated safety records, which
includes fit testing;
xi) ensure compliance to OSHA's standards .including the maintenance of
OSHA 300 logs;
xii) administer the accident prevention program;
xiii) provide instruction to Site personnel regarding operating, procedures, hazards,
and safeguards of tools and equipment when necessary to perform their job;
7 CONESTOGA-ROVERS & ASSOCIATES
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I xv) document work conducted by maintaining written and photographic records.
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5.0
3669(32)
WORKER TRAINING AND EDUCATION
The selected Contractor will execute a Site-specific Health and Safety Plan for work
performed at the Site. The executed plan will address, at minimum, the requirements
outlined in this Health and Safety Plan. A copy of the Site-specific Health and Safety
Plan will be maintained on-Site during removal activities.
Prior to commencing Site activities, a Health and Safety /Site Indoctrination Session will
be presented. Attendance is mandatory foi-all personnel who will be or who are
expected to be involved with project activities.
The training program will stress the importance that each attendee understands the
basic principles of personal protection and safety, be able to perform their assigned job
tasks in a safe and environmentally responsible manner, and be prepared to respond in
an appropriate manner to any emergency which may arise. The various components of
the project HASP will be presented followed by an opportunity to ask questions to
ensure that each attendee understands the HASP. Personnel not successfully
completing this training program will not be permitted to enter or work in potentially
contaminated areas of the Site. In addition, daily "tailgate" safety meetings will take
place each day prior to beginning the day's work. All Site personnel will attend these
safety meetings. The safety meetings will be documented with written sign-in' sheets
containing a list of topics discussed.
This training will be given in addition to the basic training required under OSHA and is
not intended to meet the requirements of 29 CFR 1926.65. Prior to working in or
entering an Exclusion Zone environment (as defined in Section 6.0), all personnel will be
required to provide documentation to the Engineer indicating successful completion of
the training requirements of 29 CFR 1926.65.
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6.0
3669(32)
PERSONAL PROTECTIVE EQUIPMENT (PPE)
This section of the HASP describes the requirements for PPE and the specific levels of
protection required for each work task to be conducted at the Site during project
activities. Basic PPE in all Site areas will consist of hard hats, safety glasses, and safety
boots/ shoes.
6.1 PROTECTION LEVELS
Personnel will wear protective equipment when project activities involve potential
exposure to chemicals from vapors, gases, or particulates that may be generated on Site
or when direct contact with potentially hazardous substances may occur. Chemical
resistant clothing protects the skin from contact with skin-destructive and absorbable
chemicals. Respirators protect lungs, the gastrointestinal tract, and if a full-face
respirator is worn, the eyes, against airborne toxicants. Respiratory protection levels
will be based on the real-time air monitoring results during initial drum handling and
the action levels that are presented in Section 6.5. Analytical results of initial sampling
of unknown materials will also be incorporated into the proper selection of PPE.
Protection levels are selected based upon the following:
i) measured concentrations of the Site chemicals and expected concentrations in the
ambient atmosphere compared to allowable exposure levels;
ii) potential for exposure to chemicals in air, splashes of liquids, or other contact
due to the nature of work tasks;
iii) compliance to OSHA's lead standards;
iv)
v)
Site chemical toxicity, route of exposure, and chemical matrix; and
real-time air monitoring results during initial drum handling of unknown
material.
The specific protection levels to be employed at the Site for each work task are listed in
Table 6.1. Air monitoring action levels are listed in Table 6.2. All project activities
conducted at the Site will require the use of one of the following levels of PPE.
Level B:
i) supplied air respirator (Mine Safety and Health Administration [MSHA]/NIOSH
approved). Full-face respirators may be positive pressure-demand,
10 CONESTOGA-ROVERS & ASSOCIATES
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self-contained breathing apparatus (SCBA) or positive pressure-demand airline
respirator (with escape bottle for Immediately Dangerous to Life and Health
[IDLH) or potential for IDLH atmosphere);
ii) disposable hooded polycoated tyvek® or saranex® coveralls;
iii) steel toe and shank work boots and chemical resistant disposable boot covers or
rubber boots;
iv) disposable nitrile inner gloves;
v) chemically protective outer gloves;
vi) hearing protection as necessary; and
vii) hard hat.
Level C:
i) tyvek® coveralls (polycoated tyvek® when handling or working with liquids
[e.g., decontamination));
ii) steel toe and shank work boots and chemical-resistant overboots or booties;
iii) disposable nitrile inner gloves;
iv) nitrile outer gloves;
v) half-face or full-face air purifying respirator (APR), equipped with appropriate
cartridges (NIOSH approved);
vi) safety glasses (where half-face APR is used);
vii) hearing protection_ as necessary; and
viii) hard hat.
Modified Level D:
i) tyvek® coveralls (polycoated tyvek® when handling or working with liquids);
ii) steel toe and shank work boots;
iii) disposable nitrile inner gloves;
iv) outer nitrile work gloves;
v) safety glasses;
vi) splash shields as necessary;
vii) hearing protection as necessary; and
viii) hard hat.
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Level D:
i) standard work uniform or coveralls;
ii) steel toe work boots;
iii) gloves as necessary;
iv) safety glasses;
v) splash shield as needed;
vi) hearing protection as necessary; and
vii) hard hat.
PPE will be maintained in a clean sanitary condition and ready for use. Disposable
coveralls shall be discarded when tom and as an employee leaves the Exclusion Zone.
Hard hats shall be thoroughly cleaned after leaving the Exclusion Zone. Respirators
shall be cleaned after each day's use and cartridges discarded. A sufficient quantity of
potable water shall be supplied for washing, cleaning PPE, and drinking. A potable
water supply for washing and cleaning PPE will be maintained adjacent to the
decontamination area described in Section 9.0. Fresh potable water for drinking will be
supplied on a daily basis and be maintained at a location removed from the active work
area.
6.2 REASSESSMENT OF PROTECTION LEVELS
Protection levels provided by PPE selection shall be upgraded or downgraded based
upon a change in Site conditions or the review of the results of air monitoring.
. When a significant change occurs, the hazards shall be reassessed. Some indicators of
the need for reassessment are:
i) commencement of a new work phase;
ii) change in job tasks during a work phase;
iii) change of season/weather;
iv) when temperature extremes or individual medical considerations limit the
effectiveness of PPE;
v) chemicals other than those expected to be encountered are identified;
vi) change in ambient levels of chemicals; and
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vii) change in work scope, which effects the degree of contact with areas of
potentially elevated chemical presence.
All proposed changes to protection levels and PPE requirements will be reviewed and
approved prior to their implementation by the Engineer.
6.3 DURATION OF WORK TASKS
The duration of project activities involving the usage of PPE will be established by the
Engineer based upon ambient temperature and weather conditions, the capacity of
personnel to work in the designated level of PPE (heat stress and cold stress, see
Section 12.0 -Environmental Control Program), and limitations of the protective
equipment (i.e., ensemble permeation rates, life expectancy of air-purifying respirator
cartridges, etc.). As a minimum, rest breaks will be observed at-the following intervals:
i) 15 minutes midway between shift startup and lunch;
ii) ½-hour for lunch; and
iii) 15 minutes in the afternoon, between lunch and shift end.
All rest breaks will be taken in a clean area (e.g., support zone) after full
decontamination and PPE removal. Additional rest breaks will be observed, based upon
the heat stress monitoring guidelines presented in the Health and Safety SOP provided
in Appendix A.
6.4 LIMITATIONS OF PROTECTIVE CLOTHING
PPE ensembles designated for use during project activities have been selected to provide
protection against chemicals at known or anticipated concentrations in the waste
materials. However, no protective garment, glove, or boot is chemical-proof, nor will it
afford protection against all chemical types. Permeation of a given chemical through
PPE is a complex process governed by the chemical concentrations, environmental
conditions, physical condition of the protection garment, and the resistance of a garment
to a specific chemical; chemical permeation may continue even after the source of the
chemical has been removed from the garment.
In order to obtain optimum usage from PPE, the following procedures are to be
followed by all Site personnel using PPE:
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i) when using disposable coveralls, don a clean, new garment after each rest break
or at the beginning of each shift;
ii) inspect all clothing, gloves, and boots both prior to and during use for:
a) imperfect seams,
b) non-uniform coatings,
c) tears, and
d) poorly functioning closures; and
iii) inspect reusable garments, boots, and gloves both prior to and during use for:
a) visible signs of chemical permeation,
b) swelling,
c) discoloration,
d) stiffness,
e) brittleness,
f) cracks,
g) any sign of puncture, and
h) any sign of abrasion.
Reusable gloves, boots, or coveralls exhibiting any of the characteristics listed above will
be discarded. PPE used in areas known or suspected to exhibit elevated concentrations
of chemicals will not be reused.
Additional PPE usage guidelines are as follows:
i) ankles/wrists will be secured tightly with the use of _duct tape;
ii) prescription eyewear used on Site shall be safety glasses equipped with side
shields when full-face respirators are not required;
iii) all Exclusion Zone workers will have received training in the usage of a half-face
and/or full-face air purifying respirators and SCBA which may be required in an
emergency;.
iv) steel toe leather footwear shall be covered with neoprene overboots prior to
entering the Exclusion Zone and immediately upon entering the Contaminant
Reduction Zone; and
v) safety footwear and hard hats are to be worn by Site personnel at all times.
Exclusion Zone personnel also carry certain responsibilities for their own health and
safety, and are required to observe the following safe work practices:
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i) familiarize themselves with this HASP;
ii) use the ''buddy system" when working in a contaminated operation;
iii) use the safety equipment in accordance with training received, labeling
instructions, and common sense;
iv) maintain safety equipment in good condition and proper working order;
v) refrain from activities that would create additional hazards (i.e., smoking, eating,
etc., in restricted areas, leaning against dirty, contaminated surfaces);
vi) smoking, eating, and drinking will be prohibited except in designated areas.
These designated areas may change during the duration of the project to
maintain adequate separation from the active work area(s). Designation of these
areas will be the responsibility of the Engineer; and
vii) soiled disposable outerwear shall be removed and placed into a covered
container prior to washing hands and face, eating, using lavatory facilities, or
~~~~ .
6.5 RESPIRATORY PROTECTION PROGRAM
Prior to arriving at the Site, all on-Site personnel will have received training in the use
of, and have been fit tested for the air-purifying respirator that they may need to wear.
All on-Site personnel will be required to comply with their employer specific written
respiratory protection program developed in accordance with OSHA 29 CFR 1910.134.
Cartridges to be used with full-facepiece APRs will be made by the same manufacturer
as the facepieces in accordance with OSHA regulations. All APRs will be provided with
combination organic vapor, acid gases and high efficiency particulate cartridges or other
required cartridges.
Real-time instrument action levels for organic vapors and particulate to determine the
level of respiratory protection necessary during Project activities are based on the
concentration of the Site chemicals measured within the breathing zone. The action
levels and appropriate respiratory protection for these Site activities are as follows:
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Sustained Organic Vapor Reading
Above Background Within Worker
Breathing Zone in Parts Per Million
(ppm)
0 or Background
1-10 above background
10-250 above background
>250 above background
Engineering Controls
. Action Taken
Half-or Full-Face Respirator Available
Wear Half or Full Face Respirator
Must Wear Supplied Air Respirator
Cease Operations/ Additio11al
Prior to commencing work, both the Contaminant Reduction Zones and the Exclusion
Zones will be monitored with an organic vapor analyzer (OVA) [flame ionizing detector
(FID)] or photoionization device (PID} to document the level of organic vapors present.
In the absence of additional air monitoring information, the action levels presented will
be determined by monitoring with an OV A/PID, and the Engineer will determine the
level of respiratory protection for Site activities.
Soil excavation and drum removal personnel will be at a minimum of Level B protection
until ·the contents and associated respiratory hazards and air monitoring results, if any,
are known. Waste characterization and compatibility sampling personnel who are
required to handle intact drums/ containers of unknown content will be at a minimum
Level B protection· until the contents and associated respiratory hazards and air
monitoring results, if any, are known. Subsequent handling of characterized
containerized materials will be performed under the appropriate level of respiratory
protection to be determined by the Engineer based on the characterization data in
consultation with CRA's Regional Health and Safety Manager. The handling of
overpacked/repacked waste containers during on-Site transportation and at the staging
pad (container closed) will require the use of Level D protection unless air monitoring
results indicate that a different level of protection is appropriate.
Personal and perimeter air monitoring data will be collected. Data generated by this
sampling will also be used to modify on-Site activities or to determine if the level of
respiratory protection may require adjustment.
The Engineer will be responsible for implementing, maintaining and enforcing the
respirator program.
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On-Site personnel unable to pass a respirator fit test will not enter or work m the
Exclusion Zones or Contaminant Reduction Zones.
All on-Site personnel will be required to comply with their employer specific respiratory
protective program developed in accordance with OSHA 29 CFR 1910.134.
All efforts will be made to implement additional engineering controls to minimize the
need to wear a supplied air respirator. If the ambient concentrations of organic vapors
are due to identifiable substances, the level of respiratory protection may be altered by
the Engineer.
6.6 SITE CONTROL
While drum removal activities are in progress, visitors may gain access to the Site only if
they are escorted. The intention is to keep them out of the Exclusion Zone. Designated
work areas will be set up as appropriate inside the fence during the Site field activities,
as required. Only authorized visitors will be permitted entry to active work areas at the
Site. The purpose of these procedures is to limit access to areas with potentially elevated
chemical presence, and prevent the migration of potentially hazardous materials into
adjacent clean areas. These areas are described in the following:
i) The Exclusion Zone (EZ) is the area immediately surrounding the active work
area. Sufficient area will be provided for efficient movement of personnel and
equipment as well as chemical control. Boundaries are modifiable depending on
operational requirements. The Engineer will be responsible for maintaining the
boundaries of this area. Personnel entering this area are required to wear the
PPE as defined previously. A wind direction indication device (i.e., flagging,
windsock, etc.) will be mounted "in the area of any Exclusion Zone during Site
activities.
All personnel (including visitors) entering the Exclusion Zone or Contaminant
Reduction Zone using respiratory protection must have successfully passed a
respirator fit test in accordance with OSHA 29 CFR 1910.134. Documentation of
· fit testing is the responsibility of each employer.
In the event that unauthorized personnel enter the Exclusion Zone, work will
stop. Work will not resume tmtil the unauthorized personnel have been
removed from the Exclusion Zone or have been moved to an acceptable on-Site
area. A log of all visitors to the Site, including those entering the Exclusion Zone,
will be maintained.
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The hazards presented to workers conducting general Exclusion Zone activities
(excluding the handling of intact waste containers) will include potential
inhalation and dermal contact with Site substances in addition to general
construction related hazards. There will also be a cut and puncture hazard
should metallic debris be encountered. The use of respiratory protection will
also increase the potential for slip and trip type accidents to occur.
Safety equipment and apparel as required for general work and surface removal
work within the Exclusion Zone will be generally completed at Level_ C
protection based on air monitoring results, which will consist of the following:
• half-face or full-face air purifying respirator (APR), equipped with
appropriate cartridges (NIOSH approved);
• tyvek® coveralls (polycoated tyvek® when handling or working with liquids
[e.g., decontamination]);
• disposable nitrile inner gloves;
• nitrile outer gloves;
• · work boots with steel toe and shank;
• chemical-resistant overboots or booties;
• safety glasses or goggles (where half-face APR is used); and
• hard hat.
The handling of intact drums of unknown content during
overpacking/repacking and sampling will be conducted under Level B
protection. Subsequent handling once the contents and associated respiratory
hazards, if any, a_re known will be performed under the appropriate level of
personal protection to be determined by the Engineer. The handling of
overpacked/repacked waste containers during transport to and at the staging
pads will be conducted under Level D protection, if air monitoring results
indicate this level, protection is appropriate.
All personnel involved in the handling or sampling of waste containers of
unknown content will conform to the following PPE requirements, for Level B
work activity:
• disposable hooded polycoated tyvek® or saranex® coveralls;
• supplied air respirator.
• chemically protective outer gloves;
• disposable nitrile inner gloves;
• steel toe work boots;
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ii)
• chemical resistant disposable boot covers or rubber boots;
• hard ha ts; and
• two-way radio (intrinsically safe).
Additional PPE usage guidelines to be implemented include:
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prescription eyeglasses in use on the Site will be safety glasses;
all disposable or reusable nitrile, latex and/ or cotton gloves worn on the Site
will be changed, decontaminated or discarded at the end of each day;
during periods of respirator usage, respirator filters will be changed at least
daily;
on-Site personnel who have not passed a respirator fit test will not be
permitted to enter or work in the Exclusion Zone. Personnel will not be
perrniUed to have facial hair which may interfere with a proper fit of the
respirator;
• all PPE worn on Site will be decontaminated or discarded at the end of each
work day;
• duct tape will be used to ensure that disposable coveralls and gloves are
tightly secured when personnel are working within the Exclusion Zone; and
• no watches, rings or other accessories will be permitted during drum
handling, and sampling activities.
The Engineer will perform air monitoring to document the appropriateness of
the level of protection and consult with CRA's Regional Health and Safety
Manager, should modifications to the level of protection be deemed necessary.
Off-site transport drivers must meet the same requirements of personnel
handling drums (Level D) and must have available respiratory protection or an
escape respirator in the event the circumstances at the site elevate to a hazardous
condition.
The Contaminant Reduction Zone (CRZ) will provide a location for removal of
PPE which has contacted material with elevated chemical presence and final
removal and decontamination of personnel and equipment. Supplemental safety
equipment, such as fire extinguishers, portable eyewash, and extra quantities of
PPE may be stored in this area. The order in which safety equipment is to be
donned is as follows:
• tyvek® suit;
• rubber boot;
• gloves;
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• respirator (if required); and
• hard hat.
The following order applies when removing safety equipment:
• wash off boots and outer gloves prior to removal;
• tyvek® suit;
• hard hat;
• respirator; and
• inner gloves.
The Support Zone (SZ) is situated in clean areas where there is a minimal risk of
encountering hazardous materials or conditions. PPE beyond standard
construction safety equipment is therefore not required.
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7.0
3669(32)
ACTIVITY HAZARD/RISK ANALYSIS
The potential hazards to personnel working during drum removal activities at the Site
have been identified as chemical contamination and physical hazards. This .section
identifies the general hazards associated with specific project activities and presents the
documented or potential health and safety hazards that exist at the Site. Every effort
will be made to reduce or eliminate these hazards, Those that cannot be eliminated
must be guarded against by use of engineering controls and/or PPE. Table 7.1 presents
the anticipated hazards/risks and hazard controls.
In addition to the chemical hazards presented in Section 2.0 of this HASP, physical
hazards including slippery surfaces, the use of heavy equipment, the use of
decontamination equipment, and potential heat and cold stress exist at the Site. It will
be the responsibility of each on-Site contractor and their personnel to identify the
physical hazards posed by the various Site project activities and implement preventative
and corrective action.
7.1 CHEMICAL EXPOSURE
The chemical health and safety hazards associated with this project are chemicals which
may be contained in drums and in grossly contaminated soils as a result of potential
leakage from the buried drums. The proposed drum removal activity is necessary to
mitigate the immediate threat to public health and the environment posed by the
presence of these uncontrolled hazardous substances and wastes. Preventing acute
exposure to these toxic chemicals is a primary concern.
Chemical substances can enter the unprotected body by inhalation, skin absorption,
ingestion, or through a puncture wound (injection). A contaminant can cause damage at
the point of contact or can act systematically, causing a toxic effect at a part of the body /
distant from the point of initial contact.
Chemical exposures are generally divided into two categories: acute and chronic.
Symptoms resulting from acute exposures usually occur during or shortly after
exposure to a sufficiently high concentration of a chemical. The concentration required
to produce such effects varies widely from chemical to chemical. The term "chronic
exposure" generally refers to exposures to "low" concentrations of a contaminant over a
long period of time. The "low" concentrations required to produce symptoms of chronic
exposure depend upon the chemical, the duration of each exposure, and the number of
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exposures. For a given chemical, the symptoms of an acute exposure may be completely
different from those resulting from chrome exposure.
For either chrome or acute exposure, the toxic effect may be temporary and reversible, or
may be permanent (disability or death). Some chemicals may cause obvious symptoms
such as burning, coughing, nausea, tearing eyes, or rashes. Other chemicals may cause
health damage without any such warning signs (this is a particular concern for chronic
exposures to low concentrations). Health effects such as cancer or respiratory disease
may not become manifest for several years or decades after exposure. In addition, some
toxic chemicals may be colorless and/or odorless, may dull the sense of smell, or may
not produce any immediate or obvious physiological sensations. Thus, a worker's
senses or feelings cannot be relied upon in all cases to warn of potential toxic exposure.
The effects of exposure not only depend on the chemical, its concentration, route of
entry, and duration of exposure, but may also be influenced by personal factors such as
the individual's smoking habits, alcohol consumption, medication use, nutrition, age,
and sex.
An important exposure route of concern at the Site is inhalation. The lungs are
extremely vulnerable to chemical agents. Even substances that do not directly affect the
lungs· may pass through lung tissue into the bloodstream, where they are transported to
other vulnerable areas of the body. Some toxic chemicals present in the atmosphere may
not be detected by human senses (i.e., they may be colorless, odorless, and their toxic
effects may not produce any immediate symptoms). Respiratory protection is therefore
extremely important if there is a possibility that the work Site atmosphere may contain
such hazardous substances. Chemicals also can enter the respiratory tract through
punctured eardrums. Where this is a hazard, individuals with punctured eardrums
should be medically evaluated specifically to determine if such a condition would place
them at an unacceptable risk and preclude their working at the task in question.
Direct contact of the skin and eyes by hazardous substances is another important route
of exposure. Some chemicals directly injure the skin. Some pass through the skin into
the bloodstream where they are transported to vulnerable organs. Skin absorption is
enhanced by abrasions, cuts, heat, and moisture. The eye is particularly vulnerable
because airborne chemicals can dissolve in its moist surface and be carried to the rest of
the body through the bloodstream (capillaries are very close to the surface of the eye).
Wearing protective equipment, not using contact lenses in chemical atmospheres (since
they may trap chemicals against the eye surface), keeping hands away from the face, and
minimizing contact with liquid and solid chemicals can help protect against skin and
eye contact.
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Although ingestion should be the least significant route of exposure at the Site, it is
important to be aware of how this type of exposure can occur. Deliberate ingestion of
chemicals is unlikely; however, personal habits such as chewing gum or tobacco,
drinking, eating, smoking cigarettes, and applying cosmetics at the Site may provide a
route of entry for chemicals.
The last primary route of chemical exposure is injection, whereby chemicals are
introduced into the body through puncture wounds (i.e., by stepping or tripping and
falling onto contaminated sharp objects). Wearing safety shoes, avoiding physical
hazards, and taking common sense precautions are important protective. measures
against injection.
When handling drums containing or suspected of containing shock-sensitive or reactive
wastes, the following special precautions should be followed.
• All non-essential employees shall be removed from the area of transfer.
• Material handling equipment shall be fitted with explosion containment devices or
protective shields to protect operators.
• An audible notification system will be used to signal the beginning and end of the
procedure.
• Continuous communications will be maintained between the employee in charge of
the operation and the Engineer during the operation.
• Pressurized drums shall not be moved until the cause of the excessive pressure is
determined and appropriate measures are implemented.
• All drums and containers containing packaged laboratory waste lab packs shall be
considered shock-sensitive until proven otherwise.
• Work will proceed in clear, dry weather.
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8.0
3669(32)
AIR MONITORING
Air monitoring will be performed during drum removal activities to ensure that all Site
personnel and the surrounding community will not be adversely impacted , during
project activities. This section of the Site-specific HASP presents the requirements for
conducting active work area and personnel air monitoring/ sampling at the Site.
During the progress of Site activities monitoring of organic vapors will be taken by the
Engineer using a PIO or OVA detector.
All monitoring equipment will be calibrated on a daily basis in accordance with the
manufacturer's guidelines, and such calibrations will be recorded in the Site daily log
book along with the prevailing wind direction as indicated by the windsock. Results of
all daily air monitoring also will be recorded in the Site daily logbook.
Air monitoring will be conducted continuously during all drum removal and handling
activities in the breathing zone of workers in the Exclusion Zone or as deemed necessary
by the Engineer based on Site-specific conditions. Background measurements
immediately upwind of the Exclusion Zone will be taken before activities commence.
Respiratory action levels for organic vapors are discussed in Section 6.5.
Immediately upon identifying sustained elevated levels of organic vapors greater than
250 ppm within the Work Zone, the air monitoring results will be reported to the
Engineer and work activities will be shut down. The Engineer will determine the cause
of the sustained elevated levels of organic vapors and alternate work methods or
engineering controls will be implemented to rectify the release of elevated
concentrations of organic vapors.
. 8.1 REAL-TIME AIR MONITORING
Real-time air monitoring will be conducted using a PIO/OVA, which have been
appropriately calibrated. OVA readings will be taken by the CRA at a minimum
frequency of once every two hours during activities that involve potential exposure to
contaminated materials and continuously during initial drum handling activities.
If actual field operations reveal that bi-hourly sampling is not practical or necessary,
adjustments may be made after consultation between the Engineer and CRA's Regional
Health and Safety Manager. Such modifications will be documented.
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If, during the real-time monitoring, an unexplained OVA reading of greater than 1 ppm
above background ('background" will mean the readings obtained at an ,upwind
location which is riot being impacted by Site activities) is sustained for a duration of
sixty seconds, CRA will review and modify the perimeter of the Exclusion Zone or work
procedures at the Site to minimize the potential of air emission levels greater than 1 ppm
above background (i.e. the perimeter action level).
Exclusion Zone
CRA and the Contractor will monitor the area of active work in the breathing zone to
evaluate requirements for respiratory protection. These data will be evaluated to
determine when work activities need to be modified or shut down due to poor air
quality.
8.2 BACKGROUND MONITORING
Background monitoring for total organic vapors using real-time monitoring will be
conducted at the beginning of each workday. Any departures from general background
will be reported to the Engineer who will, in conjunction with CRA's Regional Health
and Safety Manager, determine the cause-of the deviation and need to adjust Site
operations.
8.3 CALIBRATION AND DATA REPORTING
Calibration of air monitoring equipment will be completed on a daily basis in
accordance with the manufacturer's specifications.
The Engineer will be immediately advised when results indicate:
• required modifications to existing Site protocols;
• excessive exposure to employees; and
• possibility of off-Site migration of airborne organic vapors and/or particulate.
Results will be reported orally to the Engineer immediately if they require a decision on
Site operations or daily when no excursions are reported. Written data sheets detailing
monitoring results will be prepared and maintained by the Engineer.
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10.0 DECO NT AMINA TION PROCEDURES
3669(32)
In general, everything that enters the Exclusion Zone at the Site must either be
decontaminated or properly discarded upon exit from the Exclusion Zone. All
personnel must enter and exit the Exclusion Zone through the decontamination area.
Prior to demobilization, potentially contaminated equipment will be decontaminated
and inspected by the Engineer before it is moved into the clean zone.
The type of decontamination solution to be used is dependent on the type of chemical
hazards. The decontamination solution for this Site is Liquinox or an equivalent low
phosphate detergent/soap for equipment and for any reusable PPE. MSDS for Liquinox
and all other chemical containing products will be maintained on Site by the Engineer.
10.1 EQUIPMENT DECONTAMINATION PROCEDURES
All equipment must be decontaminated within the_ Contaminant Reduction Zone or on a
decontamination pad by a high-pressure steam washer upon exit from the Exclusion
Zone. Decontamination procedures should include: knocking soil/mud from machines;
water rinsing using a solution of water and Liquinox; scraping and brushing with
long-handled brushes to remove remaining soils and a final water rinse. Particular
attention should be paid to tire treads, equipment tracks, springs, joints, sprockets, and
under carriages. Equipment will be allowed to air dry in a clean zone before being
moved from ·the Site or travelling onto clean areas. Personnel shall wear Level C or
Modified D protection when decontaminating equipment. Modified D protection may
be used if authorized by the Engineer. Runoff and sediments will be collected and
stored until appropriate treatment arrangements are made. Appropriate measures (i.e.,
wind shields) will be taken to minimize the drift of mist and spray during
decontamination. Following decontamination and prior to equipment removal from the
Site or travel on clean areas, each piece of equipment will be inspected by the Engineer
to ensure that the equipment has been properly cleaned. This inspection shall be
included in the Site logbook.
In general, equipment decontamination pads or areas should be installed and operated
under the following guidelines:
i) Sized for the width and weight of the heaviest equipment expected, leaving
sufficient room for decontamination equipment, personnel, and waste fluid
storage drums.
26 CONESTOGA-ROVERS & ASSOCIATES
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ii) Provide an impermeable barrier capable of containing all decontamination
liquids.
iii) Durably constructed to withstand the wear and tear of equipment tires/ tracks.
iv) Provided with a low point sump where all decontamination fluids can be
collected and pumped out.
v) Be constructed such that a minimum amount of materials will require special
disposal when the decontamination pad is decommissioned. The use of granular
fills or stone as the primary load-bearing surface should be avoided.
vi) The length of the decontamination pad need not be sufficient to contain the
entire vehicle. The vehicle can be decontaminated in sections as it passes over
the pad.
vii) If possible, vehicle access into the work zone should be made around the
decontamination pad rather than over it. This will reduce the wear and tear on
the pad. If such access is made possible, the pad . should remain blocked
whenever it is not in use.
An equipment decontamination inspection record will be maintained on site, which
includes:
• equipment descriptions with identification numbers or license plates
• time and date entering decontamination facility
• time and date exiting the decontamination facility
• name of inspector(s) with comment stating that decontamination was performed and
completed.
10.2 PERSONNEL DECONTAMINATION PROCEDURES
Personnel decontamination will be completed in accordance with the Health and Safety
SOP for personnel decontamination that is provided in Appendix A. Washwater and
sediments will be collected and stored with any runoff water collected for later
treatment/ disposal. PPE, trash, etc. within the Contaminant Reduction Zone will be
sent off Site for disposal. It will be kept separate from trash generated in clean areas of
the Site. The general guidelines for this are described in Section 6.6.
27 CONESTOGA-ROVERS & ASSOCIATES
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I 11.0 GENERAL SAFETY AND PERSONAL HYGIENE
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l. Eating at the Site is prohibited except in. specifically designated areas.
Designation of eating areas will be the responsibility of the Engineer. The
location of these areas may change during the duration of the project to maintain
adequate separation from the active work area(s).
2. Smoking at the Site is strictly prohibited except in specifically designated areas.
3.
4.
5.
6.
11.1
Individuals getting wet to the skin with effluent from the washing operation
must wash the affected area immediately. If clothes in contact with skin are wet,
then these must be changed.
Hands must be washed with soap and water before eating, drinking, smoking,
and before using toilets.
All disposable coveralls and soiled gloves will be placed in covered containers at
the end of every shift or sooner, if deemed necessary by the Engineer. Wastes
will be stored until proper disposal arrangements have been made.
Personnel working on Site will not be permitted to wear facial hair that interferes
with the mask-to-face seal on air-purifying respirators.
SAFETY MEETINGS
The Engineer will be responsible for conducting a daily tailgate health and safety
meeting with CRA personnel and subcontractors associated with field activities. The
meeting will consist of reviewing the contents of the health and safety plan along with
chemical and physical hazards associated with the project. A Health & Safety Plan
acknowledgement sheet and a tailgate safety meeting form are included in Apperidix B
for documentation purposes.
Should any unforeseen or Site-peculiar, safety-related factor, hazard, or condition
become evident during the performance of work at the Site, the Contractor will inform
the Engineer immediately. In the interim, the Contractor will take prudent acti'on to
establish and maintain safe working conditions and to safeguard employees, the public,
and the environment.
No visitors or personnel _will be allowed to enter the Exclusion Zone or Contaminant
Reduction Zone unless they have the prior approval of the Engineer.
28 CONESTOGA-ROVERS & ASSOCIATES
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I 12.0 MEDICAL SURVEILLANCE
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In accordance with the requirements detailed in 29 CFR 1926.65, 29 CFR 1926.62, and
29 CFR 1910.134, all Site personnel who will come in contact with materials with
potentially elevated chemical presence will have received, within 1 year prior to starting
field activities, medical surveillance by a licensed physician or physician's group.
standard, 29 CFR 1926.62.
Medical records for all on-Site personnel will be maintained by their respective
employers. The medical records will detail the tests that were taken and will include a
copy of the consulting physician's statement regarding the tests and the employee's
suitability for work.
The medical records will be available to the employee or his/her designated
representative upon written request, as outlined in 29 CFR 1910 .. 1020.
Each employer will provide certifications to CRA that its personnel involved in Site
activities will have all necessary medical examinations and will have obtained medical
certification prior to commencing work, which requires respiratory protection or
potential exposure to hazardous materials. Personnel not obtaining medical certification
will not perform work within the Contaminant Reduction Zone and Exclusion Zone.
Copies of such certification will be maintained with the on-Site HASP.
Interim medical surveillance will be completed in accordance with 29 CFR 1926.62 or if
an individual exhibits poor health or high stress responses due to any Site activity or
when accidental exposure to elevated concentrations of chemicals occur.
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13.0 ENVIRONMENTAL CONTROL PROGRAM
3669(32)
This section of the HASP outlines measures to be implemented at the Site to prevent
hazards associated with environmental conditions.
13.1 WEATHER MONITORING
The Engineer will be responsible for checking weather forecasts for the next day and
week of work to provide advance notification of any severe weather conditions. Severe
weather conditions (e.g., heavy rains, lightning) may cause unsafe conditions at the Site
and in some situations work may have to be stopped.
13.2 RAIN AND SNOW
Excessive amounts of precipitation may cause potential safety hazards for all work
tasks. The hazards would be most commonly associated with slipping, tripping, or
falling due to slippery surfaces and further hazards are detailed by work task
(Table 7.1).
Severe weather conditions will result in work stoppage and the implementation of
further emergency measures, as described in the Health and Safety SOP provided in
Appendix A.
13.3 TEMPERATURE
The construction activities are expected to be conducted this winter. Winter weather is
typically moderate in North Carolina; however low temperatures may be experienced
which require measures to be implemented to prevent health and safety hazards from
occurnng. Potential hazards arising from temperature extremes are heat stress and cold
exposure.
The potential hazard due to worker heat stress is particularly important if 'high
protection levels of PPE are in use (e.g., respirators). A detailed monitoring program
a:1d prevention measures to implement to reduce heat stress are detailed in Health, and
Safety SOP provided in Appendix A. It is the responsibility of the Engineer to
determine which measures are appropriate to implement to prevent heat stress; these
will depend largely on daily Site conditions.
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Exposure to cold is similar to heat stress in that the Engineer must dete~e the
appropriate preventative measures to implement. Some of the measures which may be
implemented include: more frequent breaks, additional clothing, and partial enclosure
of work areas. Detailed cold exposure prevention measures are also included in the
Health and Safety SOP provided in Appendix A.
13.4 WIND
High winds may be encountered at the Site and these can cause hazards that may affect
Site personnel health and safety. Preventative measures that will be implemented if
necessary are as follows:
i) restricted Site activity;
ii) battening down light equipment or building materials;
iii) partially enclosing work areas; and
iv) reduction or stoppage of work activities.
31 CONESTOGA-ROVERS & ASSOCIATES
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14.0 EMERGENCY RESPONSE
It is essential that Site personnel be prepared in the event of an emergency. Emergencies
can take many forms; illnesses or injuries, chemical exposure, fires, explosions, spills,
leaks, releases of harmful contaminants, or sudden changes in the weather. The
following sections outline the general procedures for emergencies. Emergency
information should be posted as appropriate. All emergencies will be reported to the
appropriate emergency responders. In general, Site personnel will shut down
equipment and evacuate to a safe pre-determined meeting area during Site emergencies.
This location will be communicated during the Health and Safety Site indoctrination
session prior to commencing work at the Site.
14.1 EMERGENCY CONTACTS
The emergency contact information is presented in Table 14.1.
Directions to the hospital from the Site have been presented on Figure 14.1.
This route will be verified at least weekly by the Engineer, or other .Site personnel to
determine if road construction activities warrant an alternative route.
14.2 EMERGENCY EQUIPMENT AVAILABLE ON SITE
Communication Equipment
Emergency Alarms/Homs
Medical Equipment
OSHA Approved First Aid Kit (Bloodborne pathogens kit)
Sized for a Minimum of 20 people
Portable Emergency Eyewash
Fire Fighting Equipment
Location
CRZ
CRZ or Support Zone
Two 20-Pound ABC Type Dry Chemical Fire Extinguishers CRZ
(inspected monthly)
TwoSCBAs
3669(32) 32 CONESTOGA-ROVERS & ASSOCIATES
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14.3 PROJECT PERSONNEL RESPONSIBILITIES
DURING EMERGENCIES
ENGINEER
As the administrator of the HASP, the Engineer has primary responsibility for
responding to and correcting emergency situations. The Engineer will:
i) take appropriate measures to protect personnel including: withdrawal from the
Exclusion Zone, total evacuation and securing of the Site or upgrading or
downgrading the level of protective clothing and respiratory protection;
ii) take appropriate measures to protect the public and the environment including
isolating and securing the Site, preventing runoff to surface waters and ending or
~on trolling the emergency to the extent possible;
iii) ensure that appropriate Federal, State, and local agencies are informed, and
emergency response plans are coordinated. In the event of fire or explosion; the
local fire department should be summoned immediately. In the event of an air
release of toxic materials, the local authorities should be informed in order to
assess the need for evacuation. In the event of a spill, sanitary districts and
drinking water systems may need to be alerted;
iv) ensure that appropriate decontamination treatment or testing for exposed or
injured personnel is obtained;
v) determine the cause of the incident and make recommendations to prevent the
recurrence; and
vi) ensure that all required reports have been prepared.
14.4 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 decontamination
should be completed and first aid administered prior to transport. If the patient's
condition is serious, at least partial decontamination should be completed as much as
possible without causing further harm to the patient. First aid should be administered
whlle awaiting an ambulance or paramedics. All injuries and illnesses must
immediately be reported to CRA's Regional Health and Safety Manager.
33 CONESTOGA-ROVERS & ASSOCIATES
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Any person transporting an injured/exposed person to a clinic or hospital for treatment
should take with them directions to the hospital and a listing of the contaminants of
concern to which they may have been exposed.
Any vehicle used to transport contaminated personnel will be cleaned or
decontaminated as necessary.
14.5 FIRE OR EXPLOSION
In the event of a fire or explosion, the local fire department should be summoned
immediately. Upon their arrival, the Engineer or designated alternate will advise the
fire commander of the location, nature, and identification of the hazardous materials on
Site.
If it is safe to do so, Site personnel may :
i) if hazardous, report to the Project Coordinator, and/ or Project Manager;
ii) use fire fighting equipment available on Site; or
iii) . remove or isolate flammable or other hazardous materials which may contribute
to the fire.
14.6 SPILLS OR CONTAINER LEAKS
In the event of a spill or leak, Site personnel will:
i) report spills and releases to the USEP A, State, Project Manager, and the NRC;
ii) locate the source of the spillage and stop the flow if it can be done safely; and
iii) begin containment and recovery of the spilled materials.
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15.0 RECORDKEEPING
3669(32)
The Engineer shall establish and maintain records of all necessary and prudent
monitoring activities as described below:
i) name and job classification of the employees involved on specific tasks;
ii) records of qualitative fit testing and · physical examination results for Site
personnel;
iii) records of all OSHA training certification for Site personnel;
iv) records of training acknowledgment forms; and
v) records of all air sampling/monitoring equipment calibration logs and results.
The Contractor will maintain daily safety inspection logs on Site as part of the Health
and Safety Program. All daily logs will be signed by the Engineer. Contents of these
reports will be as follows:
i) Daily Safety Inspection Logs
These logs will record the following information:
• date;
• areas inspected;
• employees in designated areas;
• equipment being utilized by employees named;
• protective equipment being worn by employees named; and
• air-monitoring data reported;
• records to document work conducted; and
• problems and resolution.
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SOURCE: MOUNT HOLLY, N.C. 1 :24,000 QUAD.
03669-10(032)GN-WA001 DEC 08/2004
figure 1. 1
SITE LOCATION
JADCO-HUGHES SUPERFUND SITE
Gaston County, North Carolina
- - ------
LEGEND
EMERGENCY ROAD
03669-10(032)GN-WA002 DEC 08/2004
-liiill - - ---
0 3600ft
figure 14.1
HOSPITAL ROUTE MAP
JADCO-HUGHES SUPERFUND SITE
Gaston County, NC
D Page 1 of 5
• TABLE2.1
TOXILOGICAL DATA OF SITE CONTAMINANTS I JADCO-HUGHES SUPERFUND SITE
GASTON COUNTY, NORTH CAROLINA
I RI Data RI Data Ocwpational
Representative Representative Exposure Exposure
I ConcentTation Concentration Routes Limits
in Soil in Groundwater in Air
(mg/kg! (µg/L) /1)
I Volatile Or'i_nnir. Com12011nds
Acetone 9.9 30,524 Inhalation, skin absorption, 1,000 11 I
Ingestion 250 [2[
I Benzene 277 Inhalation, skin absorption, 11 I
Ingestion 0.1 [2[
2-Butanone 72 57,124 Inhalation, skin absorption, 200 11 I I Ingestion 200 [2[
Carbon Disulfide NA 1.8 Inhalation, skin absorption, 20 11 I
Ingestion [21 I Carbon Tetrachloride NA 7,153 Inhalation, skin absorption, 10 Ill
Ingestion 2 [21
I Chlorobenzene NA 96 Inhalation, skin absorption, 75 Ill
Ingestion 75 [21
Chloroethane NA 7.7 NI NI
I Chlorofonn NA 17,083 Inhalation, skin absorption, 50 11 I
Ingestion 2 [21
I 1,1-Dichloroethane O.Dl 22 Inhalation, skin absorption, 100 [11
Ingestion 100 [21
I 1,2-Dichloroethane 5.7 986 Inhalation, skin absorption, 50 111
Ingestion 121
1, 1-Dichloroethene NA 141 NI NI
I 1,2-Dichloroethene (total) NA 2,561 Inhalation, skin absorption, 200 111
Ingestion 200 [21
1,2-Dichloropropane NA 0.32 Inhalation, skin absorption, 75 [!] I Ingestion
Ethylbenzene 36.4 749 Inhalation, skin absorption, 100 :111
Ingestion 100 [21 I 2-Hexanone NA 900 Inhalation, skin absorption, 100 [!J
Ingestion [21
I Methylene Chloride 3.1 1,750 Inhalation, skin absorption, 25 [11
Ingestion
4-Methyl-2-Penta none 14.5 6,688 NI NI
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I CRA366<l(32)
I Page2of5
I TABLE2.1
TOXILOGICAL DATA OF SITE CONTAMINANTS I JADCO-HUGHES SUPERFUND SITE
GASTON COUNTI, NORTH CAROLINA
I RI Data RI Data Occupational
Representative Representative Exposure &posure
I Concentration · Concentration Routes Limits
in Soil in Groundwater in Air
(mg/kg) (µg!L) [1/
·I 1,1,2,2-Tetrachloroethane 0.01 0.26 Inhalation, skin absorption, 5 Ill
Ingestion 121
Tetrachloroethane 4.7 6.2 Inhalation, skin absorption, 100 111
I Ingestion
Toluene 303.6 17,359 Inhalation, skin absorption, 200 IIJ
Ingestion 100 121
I 1, 1, I-Trichloroethane 0.01 168 NI NI
1,1,2-Trichlooethanc O.QI 1.6 Inhalation, skin absorption, 10 ]I I
Ingestion 10 ]2] I· Trichloroethene 1.8 69 Inhalation, skin absorption, 100 111
Ingestion
I Vinyl Chloride NA 11,451 Inhalation, skin absorption, 111
Ingestion
Total Xylenes 134.6 1,376 Inhalation, skin absorption, 100 11 I
I Ingestion
Base(Ne11traf/Atids
Acenaphthene 0.58 NA NI NI
I· Anthracene 1.0 NA NI NI
Benzo(a)pyrene 3.6 NA NI NI
I Benzo(b )fluoranthene 2.7 NA NI NI
Benzo(g,h,i)perylene 1.4 NA NI NI
I Benzo(k)fluoranthene 2.2 NA NI NI
Benzoic Acid 19.4 2,675 NI NI
Bis(2-chloroethyl)ether 1.5 4,623 Inhalation, skin absorption, 15 II I I Ingestion 5 · 121
Bis(2-chloroisopropyl)ether NA 11 NI NI
I Bis(2-ethylhexyl)phthalate 53.8 41 Inhalation, skin absorption, 5 l!J
Inge:stion 5 121
Butylbenzylphtha\ate 5.0 NA NI NI
I 2-Chlorophenol 42.4 NA NI NI
Chrysene 1.8 NA NI NI
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I Page3of5
I TABLE2.1
TOXILOGICAL DATA OF SITE CONTAMINANTS • JADCO-HUGHES SUPERFUND SITE
GASTON COUNTY, NORTH CAROLINA
I RI Data RI Data Occupational
Representative Representative Exposure Exposure
I Concentration Concentration Routes Limits
in Soil in Groundwater in Air
(mg/kg) (µg/L) /1/
I 1,2-Dichlorobcnzene 1.7 56 Inhalation, skin absorption, 50 Ill
Ingestion 50 121
1,3-Dichlorobenzene NA 19 Nl NI
I 1,4-Dichlorobenzene 0.78 121 Inhalation, skin absorption, 75 Ill
Ingestion
Di-n-butylphthalate 3.4 196 Inhalation, skin absorption, 5 I !J I Ingestion 5 121
Di-n-octylphthalate 5.4 1.9 NI NI
I Fluoranthene 2.9 NA NI NI
Fluorene 0.44 NA NI NI
I lndcno(l,2,3-cd)pyrcne 2.0 NA NI Nl
2-Mcthy!naphthalene 1.1 NA Inhaltion, Ingestion 0.2 Ill
2-Mcthylphenol 5.1 26 Inhalation, Ingestion, 5 11 I I Skin Absorption 5 121
4-Methylphenol 1.9 74 Inhalation, Ingestion, 5 11 I
Skin Absorption 5 121 I Naphthalene 3.6 8.1 Inhalation, Ingestion, 10 Ill
Skin Absorption 10 121
I· Phenanthrene 3.4 NA NI NI
Phenol 16.0 1,109 lnhala_tion, Ingestion, 5 Ill
Skin AbSorption 5 121
I· Pyrcne 3.0 NA NI NI
1,2,4-Trichlorobenzene 24.2 606 NI Nl
I Pesticides(Polyc/1/orinated Bir,henyls
Arochlorl248 20.3 ND Ingestion, Skin Absorption 0.5 (41
Arochlor 1232 NA ND 151 I Metals and Total C1J_anidr
Aluminum 13,856 35 Inhalation, Ingestion, 15 Ill
I· Skin Absorption 10 121
Antimony 30.9 0.22 Inhalation, Ingestion, 0.5 Ill
Skin Absorption 0.5 121'
I Arsenic 39.0 0.04 Inhalation, Ingestion, 0.01 Ill
Skin Absorption 0.002 121
I CltA3M9(32)
I Page 4 of 5
I TABLE2.1
TOXILOGICAL DAT A OF SITE CONTAMINANTS I JADCO-HUGHES SUPERFUND SITE
GASTON COUNIT, NORTH CAROLINA
I RI Data RI Data Occupational
Representative Representative Exposure Exposure
I, Concentration Concentration Routes Limits
in Soil in Groundwater in Air
(mglkg) (µg/L) /1/
I Barium 102 0.2 NI NI
Beryllium 1.2 0.001 Inhalation, 0.005 [JI
Skin Absorption . 0.0005 [21 I Cadmium 2.5 0.0067 Inhalation 0.005 Jl I
Calcium 4,031 136 Inhalation 5 [lj
I Chromium 66 0.14 Inhalation, Ingestion 11 I
0.5 121
,I Cobalt 20 0.068 Inhalation 0.1 JI!
0.05 121
Copper 219 0.17 Inhalation, Ingestion, 11 I
I Skin Absorption
Iron 36,354 55 NI NI
Lead 301 0.0095 Inhalation, Ingestion, 0.05 Ill
·I Skin Absorption 0.05 121
Magnesium 4,087 63 Inhalation 15 [IJ
I Manganese 487 8.9 Inhalation, Ingestion 5 III
121
Mercury 0.11 NA Inhalation, Ingestion, 0.1 Jlj
I Skin Absorption 0.1 121
Nickel 21 0.15 NI I [I I
0.□15 [21
I Potassium 358 7.7 NI NI
Silver NA 0.Dl Inhalation, Ingestion, 0.Dl [11
I Skin Absorption 0.Dl 121
Sodium 530 18 NI NI
Thallium 0.09 0.001 Inhalation, Ingestion, 0.1 Jll I Skin Absorption 121
Vanadium 122 0.14 Inhalation, Ingestion, 0.5 [JI
Skin Absorption 0.05 121
I Zinc 71 0.18 Inhalation 0.Dl 11 I
Total Cyanide 6.8 ND NI NI
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Notes:
TABLE2.1
TOXILOGICAL DATA OF SITE CONTAMINANTS
JADCO-HUGHES SUPERFUND SITE
GASTON COUNTY, N_ORTH CAROLINA
RI Data RI Data
Representative Representative Exposure
Concentration ConcentTatian Routes
in Soil in Groundwater
(mg/kg/ (µg/L)
11] Federal Occupational Safety and Health Administration (OSHA) Permissible Exposure Limit (PEL).
12] National Institute of Occupational Safety and Health (NIOSH) Recommended Exposure Limits (REL).
14] PCB 54% Chlorine
[SJ PCB 42% Chlorine
ND Not Detected
NI No Information
Occupational
Exposure
Limits
in Air
/1/
All values for VOCs, and SVOCs, are presented in parts per million. All values for PCBs and metals are presented in
mg/m3.
CRA366'l(32}
Page 5 of 5
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TABLE 6.1
SPECIFIC PERSONAL PROTECTION LEVELS
JADCO-HUGHES SITE
GASTON COUNTY, NORTH CAROLINA
Work Task
Mobilization and Demobilization of Construction Labor,
Materials, and Equipment to and from the Site
Provision and Maintenance of Construction Facilities and
Temporary Controls
Site Preparation
Implementation of Environmental Controls
Soil excavation and Drum Removal and Staging
Compatibility and Characterization Sampling
Overpacked Drum Handling by Transporters
Removal of Miscellaneous Debris
Closeout Activities
Personnel and Equipment Decontamination Activities
Notes:
Maximum
Protection
Level <11
Modified D
Modified D
Level C(3J
Modified D
Level C
LevelB
Level C
Modified D
Level C
Level C
Specific requirements for protection levels are detailed in Section 6.1.
Alternate
Protectio11
Level 121
D
D
Modified DID
D
Modified D
Level Cl Modified D
Modified DID
D
Modified DID
Modified D
11! Level C: To be worn when the criterion for using air purifying respirators (APRs) are met and a
lesser level of skin protection is needed.
Modified D: To be worn when dermal protection is required, however, no respiratory hazards
are present. It provides minimal protection against chemical hazards.
12> Alternate protection levels will be used if monitoring indicates that conditions are appropriate or
the Resident Engineer, HSO, and Site Superintendent agree that there is a reduced potential of
exposure.
CRA 3669 (32)
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Total Organic Vapor
Concentration Above Background
Instrument Reading
1-10 ppm
10-250 ppm
>250 ppm
TABLE 6.2
AIR MONITORING ACTION LEVELS
JADCO-HUGHES SUPERFUND SITE
GASTON COUNTY, NORTH CAROLINA
Action Required
Full or half-face APR
Supplied Air or SCBA
Shutdown activities -Move to
safe area -Confer with HSO
Combustible Gases (Non-confined Space)
Instrument Reading
0-10% LEL
10-20% LEL
>20% LEL
Oxygen
Continue working and monitor atmosphere
for combustible gases.
Continue working with caution. Inform
personnel in area. Be prepared to Cease
operations.
Cease operations, move to a safe place.
Re-evaluate work plan. Ventilate. Do not
continue working until conditions are
constantly below 20% LEL.
Instrument Reading
Notes:
1)
2)
3)
CRA 3669 (32)
<19.5% or >23.5%
APR -Air Purifying Respirator.
Cease operations, move to a safe
area. Re-evaluate work plan. Do
not continue working until oxygen
levels are between 19.5% and 23.5%.
SCBA -Pressure Demand Self Contained Breathing Apparatus.
An atmospheric oxygen level of less than 19.5% may affect the readings from a combustible
gas meter give lower than actual levels. Test oxygen content first.
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Page 1 of 2
TABLE 7.1
ANTICIPATED HAZARDS/RISKS ANO APPROPRIATE PRECAUTIONS
· JAOCO-HUGHES SUPERFUNO SITE
Work Activity
Mobilization and Demobilization
Activities Moving Intact Drums or
Drums that have been placed into
overpacks, and Drum/Debris
Removal
Conduct Excavation ahd Drum
Removal/Conduct Drum Sampling/
Containment Area Cleaning, and
Decontamination Activities
CRA 32444 (I)
GASTON COUNTY, NORTH CAROLINA
Anticipated Hazards/Risks
• slip/trip/fall hazards
• potential back injuries from
lifting or moving heavy
objects
• potential heat or cold stress
• poor lighting conditions
• electrical hazards from
power sources
• moving or backing vehicles
• pinch points while moving
drums
• slip/trip/fall hazards
• potential back injuries from
lifting or moving heavy
objects
• potential heat or cold stress
• electrical hazards from power
sources
• moving or backing vehicles
and equipment
• direct contact with waste
materials
• hazards presented by the use
of a forklift or other drum
moving equipment
Appropriate Precautions
• Level D personal protection
• practice safe lifting techniques
• participate in on-Site training
sessions
• practice good personal hygiene
principles
• mark open pits and sumps with
cones and/or caution tape
• use a spotter around moving
or backing vehicles and
•equipment
• grounded plugs should be used
to reduce the hazard of
electrical shock. Do not stand
in water when handling
equipment. Electrical equipment
will be approved. Pneumatic
tools are preferred
• keep first aid supplies readily
available
• use appropriate equipment to
move and handle drums
• Level B and (Level C based on
real time air monitoring for
containment area cleaning)
• practice safe lifting techniques
• participate in all on-Site training
programs
• be trained with all appropriate
equipment standard operating
procedures
• practice good personal hygiene
• take proper precautions in Unsafe
areas
• mark open pits and sumps with
cones and/or caution tape
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. Page 2 of 2
TABLE 7.1
ANTICIPATED HAZARDS/RISKS AND APPROPRIATE PRECAUTIONS
JADCO-HUGHES SUPERFUND SITE
Work Activity
Conduct Excavation and Drum
Removal/Conduct Drum Sampling/
Containment Area Cleaning, and
Decontamination Activities
(confd.)
CRA 32444 (I)
GASTON COUNTY, NORTH CAROLINA
Anticipated Hazards/Risks
• potential overhead objects
(e.g., power lines when backing
transport vehicles in)
• reduced field of vision from
wearing supplied air or full-
facepiece respirators
• hazards presented by use of
specialized floor cleaning
equipment (e.g., steam cleaner)
Appropriate Precautions
• use the "Buddy System"
• only essential personnel allowed
in work area
• use a spotter around moving or
backing equipment
• groundwater plugs should be
used to reduce the hazard of
electrical shock. Do not stand
in water when handling equipment.·
Electrical equipment will be
approved. Pneumatic tools are
preferred
• keep first aid supplies readily
available
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Contact
Local Police
Belmont Fire Deoartment
Ambulance
Police
Local Hospital:
Gaston Memorial Hosoital
USEPA Region IV -Michael
Townsend
NCDENR -Kvle Hagen
National Resnonse Center
Poison Information
Duke Power (24-hour)
Citv of Mount Hollv
TABLE 14.1
EMERGENCY CONTACT INFORMATION
JADCO-HUGHES SUPERFUND SITE
GASTON COUNTY, NORTH CAROLINA
EMERGENCY INFORMATION
Phone Number
(911)
(911)
(911)
(911)
866-2000 See Figure 14.1
[phone]
[phone] ext. 299
[phone]
800-764-7661
[phone]
[phone]
.
North Carolina One Call Center [phone]
Project Health and Safety Officer -704-676-0502 CRA -Accident Reporting System
' John Uteck 704-491-3719 (cell) Please call [phone] and
provide:
Onsite Coordinator -704-676-0502 • Name and location of caller
John Uteck 704-491-3719 (cell) • Description of incident
• Name of any injured persons
Project Manager -519-884-0510 • Description of injuries
Colleen Dietrich • Phone number for return call
Regional Safety and Health Manager -225-292-9007
Perrv Hawkins 585-755-6009 (cell)
Site Contact: 704-676-0502
John Uteck 704-491-3719 (cell)
Client Contact:
Stephen Quigley 519-884-0510
519-580-9976 (after
6om)
CRA 3669 {32)
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I APPENDIX A
I CRA'S STANDARD HEALTH AND SAFETY PROCEDURES
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I 3669 (32)
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TABLE OF CONTENTS
Page
DECONTAMINATION
1.0 DECONTAMINATION ......................................................................................................... 1
1.1 SCOPE .................................................................................................................. l
2.0 DECONTAMINATION METHODS ................................................................................... 2
2.1 PROCEDURES .................................................................................................... 2
2.2 EQUIPMENT DECONTAMINATION ............................................................ 2
3.0 WASTE DISPOSAL ................................................................................................................ 3
3.1 MANAGEMENT AND DISPOSAL OF DECONTAMINATION
SOLUTIONS ........................................................................................................ 3
4.0 SHOWERS AND CHANGE ROOMS .................................................................................. 4
5.0 DECONTAMINATION LEVELS ............................................... : ......................................... 5
5.1 LEVEL A· ROUTINE DECONTAMINATION .............................................. 5
5.2 LEVEL B · ROUTINE DECONTAMINATION .............................................. 7
5.3 LEVEL C • ROUTINE DECONTAMINATION .............................................. 9
5.4 LEVEL D · MODIFIED ROUTINE DECONTAMINATION ...................... 11
2866 (1) PART 3 • Decontamnation Rev. 1 -03/0212001 CONESTOGA-ROVERS & ASSOCIATES
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1.0
DECO NT AMINA TION
DECONTAMINATION
1.1 SCOPE
Personal protective equipment (PPE) and monitoring equipment must either be
decontaminated or properly discarded upon exiting from the exclusion zone., This
practice prevents cross-contamination to clean areas. All Conestoga-Rovers &
Associates (hereby referred to as CRA) employees must enter and exit the exclusion
zone through the contaminant reduction zone and decontamination area. The
configuration of these zones will vary from site to site and will be defined .in the
site-specific Health and Safety Plan (HASP).
2B66 (1) PART 3-Decontamination Rev. 1 • 03/02/2001 CONESTOGA-ROVERS & ASSOCIATES
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2.0
-(J2)
DECONTAMINATION METHODS
Decontammation methods shall involve physically removing contammants, neutralizing
contammants, or removing contammants through a combination of both physical and
chemical means. The types, locations, physical states, and concentrations of
contammation present will determme the appropriate method of decontammation.
2.1 PROCEDURES
This Standard Operating Procedure (SOP) contains personnel decontammation
procedures for Levels A, B, C, and D. The site Health and Safety Officer is responsible to
monitor these procedures and may modify them to suit the site conditions and specific
levels in use. General standard operating procedures to be followed are:
• mmirnize contact with contammants in order to mmirnize the need for extensive
decontammation;
• gloves, boot covers, and disposable outer clothing shall be rolled down with the
insides out;
• sampling/ monitoring equipment, when feasible, shall be enclosed in plastic bags to
prevent cross-contamination; and
• decontammation solutions of soap and water or trisodium phosphate (TSP)
detergent and water shall be used as a mmimum requirement.
2.2 EQUIPMENT DECONTAMINATION
Monitoring equipment will be decontammated before leaving the site by wiping with a
damp cloth or by removing and properly disposing of a protective covering.
Construction equipment will typically be manually scraped then steam cleaned. The
HSO is responsible to verify that this has been done satisfactorily.
2866 (1) PART 3-Decontamination Rev. 1 -03/02/2001 2 CONESTOGA-ROVERS & ASSOCIATES
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3.0 WASTE DISPOSAL
CRA project management will detemtine a disposal method based on an approval plan
for each specific site.
3.1 MANAGEMENT AND DISPOSAL OF DECONTAMINATION
SOLUTIONS
Decontamination solutions must be treated or properly disposed of. In detemtining if a
particular management disposal option is appropriate, the following should be
considered:
• the contaminants, their concentrations, and the total volume of decontamination
solution;
• media potentially affected (e.g., groundwater, soil) under management options;
• location of the nearest population(s) and the likelihood and/ or degree of site access;
• potential exposure to workers; and
• potential for environmental impacts.
All wastes belong to clients and are to be left on site. CRA will notify the client what has
been left on site and offer to help in arranging proper disposal/ treatment.
2866 (1) PART 3 -Decontamination Rev. 1 • 03/02/2001 3 CONESTOGA-ROVERS & ASSOCIATES
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4.0
-()l)
SHOWERS AND CHANGE ROOMS
Showers and/or change rooms may be provided for CRA employees when the duration
of project activities extends for a long period of time or will be provided when site
conditions warrant the need for a separate change area. Showering requirements vary
from site to site and are defined in the site-specific HASP based on site-specific
conditions.
2866 ( 1) PART 3 • Decontammalion Rev. 1 • 03102/2001 4 CONESTOGA-ROVERS & ASSOCIATES
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5.0
-fll)
DECONTAMINATION LEVELS
5.1 LEVEL A-ROUTINE DECONTAMINATION
Step 1 -Segregated Equipment Drop
• Deposit equipment used on site (tools, sampling devices and containers, m01;iitoring
equipment, radios, clipboards, etc.) on plastic drop cloths or in different containers
with plastic liners. Each will be contaminated to a different degree. Segregation at
the drop reduces the probability of cross-contamination.
Step 2 -Boot Cover and Glove Wash
• Scrub outer boot covers and gloves with decontamination solution or
detergent/water.
Step 3 -Boot Cover and Glove Rinse
• Rinse off decontamination solution from Step 2 using copious amounts of water.
• Repeat as many times as necessary.
Step 4 -Tape Removal
• Remove tape around boots and gloves and deposit in container with plastic liner.
Step 5 -Boot Cover Removal
• Remove boot covers and deposit in container with plastic liner.
Step 6 -Outer Glove Removal
• Remove outer gloves and deposit in container with plastic liner.
Step 7 -Suit/Safety Boot Wash
• Thoroughly wash fully encapsulating suit and boots. Scrub suit and boots with
long-handle, soft-bristle scrub brush, and copious amounts of decontamination
solution or detergent/water. Repeat as many times as necessary.
Step 8 -Suit/Safety Boot Rinse
• Rinse off decontamination solution or detergent/water using copious amounts of
water. Repeat as many times as necessary.
2866 {1) PA~T 3 -Decontamnallon Rev. 1 • 03/02/2001 5 CONESTOGA-ROVERS & ASSOCIATES
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Step 9 -Tank Change
• If worker leaves the exclusion zone to change air tank, this is the last step in the
decontamination procedure. Worker's air tank is exchanged, new outer gloves and
boot covers donned, and joints taped. Worker then returns to duty. '
Step 10 -Safety Boot Removal
• Remove safety boots and deposit in container with plastic liner.
Step 11 -Fully Encapsulating Suit and Hard Hat Removal
• With assistance of helper, remove fully encapsulating suit (and hard hat}. Hang
suits on rack or lay out on drop cloths.
Step 12 -SCBA Backpack Removal
• While still wearing facepiece, remove backpack and place on table. Disconnect hose
from regulator valve and proceed to next step.
Step 13 -Inner Glove Wash
• Wash with decontamination solution or detergent/water that will not harm skin.
Repeat as many times as necessary.
Step 14 -Inner Glove Rinse
• Rinse with water. Repeat as many times as necessary.
Step 15 -Facepiece Removal
• Remove facepiece. Deposit in container with plastic liner. Avoid touching face with
fingers.
Step 16 -Inner Glove Removal
• Remove inner gloves and deposit in container with plastic liner.
Step 17 -Inner Clothing Removal
• Remove clothing soaked with perspiration. Place in container with plastic, liner.
Inner clothing should be removed as soon as possible since there is a possibility that
2866 (1) PART 3. Decontamination Rev. 1 • 03/02.12001 6 CONESTOGA-ROVERS & ASSOCIATES
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small amounts of contaminants might have been transferred in removing fully
encapsulating suit.
Step 18 -Field Wash
• Shower if highly toxic, skin-corrosive, or skin-absorbable materials are known or
suspected to be present. Wash hands and face if shower is not available.
Step 19 -Redress
• Put on clean clothes. A dressing trailer is needed in inclement weather.
5.2 LEVEL B -ROUTINE DECONTAMINATION
Step 1 -Equipment Drop
• Deposit equipment used on site (tools, sampling devices, monitoring equipment,
radios, etc.) on plastic drop cloths.
• Decontaminate or dispose of items before removal from the exclusion zone.
Step 2-Outer Boot/Glove Wash and Rinse
• Scrub outer boots/ gloves with decontamination solution.
• Rinse using water.
Step 3 -Outer Boot/Glove Removal
• Remove outer boots/ gloves.
• If outer boots/ gloves are disposable, deposit in container with plastic liner.
• If outer boots/gloves are non-disposable, store in a clean, dry location.
Step 4 -Outer Garment Removal
• If using self-contained breathing apparatus (SCBA), remove SCBA backpack and
keep the facepiece on until garments are removed. Remove chemical protective
outer garments and deposit in appropriate container.
Step 5 -Respiratory Protection Removal
• Remove hard hat and face piece, and place them on a clean surface.
2866 (1) PART 3 • Decontarnnation Rev. 1 • 03/02/2001 7 CONESTOGA-ROVERS & ASSOCIATES
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• Wash and rinse face piece.
• Wipe off and store face piece in a clean, dry location.
Step 6 -Inner Glove Removal
• Remove inner gloves.
• Deposit in container for disposal.
Step 7 -Field Wash
• Thoroughly wash hands and face with soap and water.
• Shower as soon as possible.
For Air Tank Exchange Only, Complete the Following Steps:
Step 1 -Equipment Drop
• Deposit equipment used on site (tools, sampling devices, monitoring equipment,
radios, etc.) on plastic drop cloths.
• Decontaminate or dispose of items before removal from the exclusion zone.
Step 2 -Glove Removal
• Remove gloves.
• If gloves are disposable, deposit in container with plastic liner
• If gloves are non-disposable, store in a clean, dry location.
Step 3 -Tank Change
• Exchange air tank.
• Don new gloves.
• Tape joints and return to the exclusion zone.
5.3 LEVEL C-ROUTINE DECONTAMINATION
Step 1 -Equipment Drop
• Deposit equipment used on site (tools, sampling devices, monitoring equipment,
radios, etc.) on plastic drop cloths.
2866 (1) PART 3 -Oecootamina11on Rev. 1 -03/02/2001 8 CONESTOGA-ROVERS & ASSOCIATES
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• Decontaminate or dispose of items before removal from the exclusion zone.
Step 2-Outer Boot/Glove Wash and Rinse
• Scrub outer boots/ gloves and/ or splash suit with decontamination solution.
• Rinse using water.
Step 3 -Outer Boot/Glove Removal
• Remove outer boots/ gloves.
• If outer boots/ gloves are disposable, deposit in container with plastic liner.
• If outer boots/ gloves are non-disposable, store in a clean, dry place.
Step 4 -Outer Garment Removal
• Remove chemical protective outer garments and deposit in appropriate container.
Step 5 -Respiratory Protection Removal
• Remove hard hat and respirator and deposit on a clean surface.
• Discard respirator cartridges in appropriate container.
• Wash and rinse respirator.
• Wipe off and store respirator in a clean, dry location.
Step 6 -Inner Glove Removal
• Remove inner gloves.
• Deposit in container for disposal.
Step 7 -Field Wash
• Thoroughly wash hands and face with soap and water.
• Shower as soon as possible.
For Cartridge Exchange Only, Complete the Following Steps:
Step 1 -Equipment Drop
• Deposit equipment used on site (tools, sampling devices, monitoring equipment,
radios, etc.) on plastic drop cloths.
2866 (1) PART 3-Decontamination Rev. 1 • 03/02/2001 g· CONESTOGA-ROVERS & ASSOCIATES
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HU()l)
• Decontaminate or dispose of items before removal from the exclusion zone.
Step 2 -Glove Wash and Rinse
• Scrub gloves and/ or splash suit with decontamination solution.
• Rinse using water.
Step 3 -Glove Removal
• Remove gloves.
• If gloves are disposable, deposit in container with plastic liner.
• If gloves are non-disposable, store in a clean, dry place.
Step 4 -Respirator Cartridge Change
• Exchange respirator cartridges.
• Don new outer boots/ gloves.
• Tape joints and return to the exclusion zone.
5.4 LEVEL D -MODIFIED ROUTINE DECONTAMINATION
Step 1 -Equipment Drop
• Deposit equipment used on site (tools, sampling devices, monitoring equipment,
radios, etc.) on plastic drop cloths.
• Decontaminate or dispose of items before removal from the exclusion zone.
Step 2 -Outer Boot/Glove Wash and Rinse
(Optional, include if necessary for gross decontamination).
• Scrub outer boots/ gloves and/ or splash suit with decontamination solution.
• Rinse using water.
Step 3 -Outer Boot/Glove Removal
• Remove outer boots/ gloves.
• If outer boots/ gloves are disposable, deposit in container with plastic liner.
• If outer boots/ gloves are non-disposable, store in a clean, dry place.
2B66 (1) PART 3-Decontaminaboo Rev.1 • 03/02/2001 10 CONESTOGA-ROVERS & ASSOCIATES
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Step 4 -Outer Garment Removal
• Remove chemical protective outer garments and deposit in an appropriate container.
• Remove hard hat and safety glasses. Decontaminate as necessary. Deposit on a
clean surface.
Step 5 -Inner Glove Removal
• Remove inner gloves.
• Deposit in a container for disposal.
Step 6 -Field Wash
• Thoroughly wash hands and face with soap and water.
• Shower as soon as possible.
2866 (1) PART 3 -Decontamination Rev. 1 • 03/02/2001 11 CONESTOGA-ROVERS & ASSOCIATES
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TABLE OF CONTENTS
Page
COLD STRESS ..................................................................................................................................... 1
1.0 OVERVIEW ............................................................................................................................. 1
2.0 PREDISPOSING FACTORS .................................................................................................. 2
3.0 PREVENTION OF COLD STRESS ....................................................................................... 3
3.1 EMPLOYEE EDUCATION ................................................................................ 4
3.2 COLD STRESS PREVENTION GUIDELINES ................................................ 4
3.3 ADJUST WORK-REST SCHEDULES IN SEVERELY COLD
ENVIRONMENTS .............................................................................................. 5
4.0 FIRST AID TREATMENT GUIDELINES ............................................................................ 6
4.1 FROSTBITE .......................................................................................................... 6
4.2 GENERAL HYPOTHERMIA ............................................................................ 6
TABLE 1
TABLE 2
-(J2)
LIST OF TABLES
(Following Report)
WIND CHILL CHART
WORK/REST SCHEDULE FOR A 4-HOUR SHIFT
2866 (1) PART 2. Cold Stress Rev. 0. 09/15199 CONESTOGA-ROVERS & ASSOCIATES
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1.0
HUllll
COLD STRESS
OVERVIEW
Fatal exposures to cold have been reported in employees failing to escape from low
environmental air temperatures or from immersion in low temperature water.
Hypothermia, a condition in which the body's deep core temperature falls significantly
below 98.6°F (37°C), can be life threatening. A drop in core temperature to 95°F (35°C)
or lower must be prevented.
Air temperature is not sufficient to determine the cold hazard of the work environment.
The wind-chill must be considered as it contributes to the effective temperature and
insulating capabilities of clothing. An equivalent chill temperature chart relating actual
dry bulb air temperature and the wind velocity is presented in'Table l. The equivalent
chill temperature should be used when estimating the combined cooling effect of wind
and low air temperatures on exposed skin or when determining clothing insulation
requirements to maintain the body's core temperature.
The body's physiologic defense against cold includes constriction of the blood vessels,
inhibition of the sweat glands to prevent loss of heat via evaporation, glucose
production, and involuntary shivering to produce heat by rapid muscle contraction.
The frequency of accidents increases with cold temperature exposures as the body's
nerve impulses slow down, individuals react sluggishly and numb extremities make for
increased clumsiness. Additional safety hazards include ice, snow blindness, reflections
from snow, and possible skin bums from contact with cold metal.
Pain in the extremities may be the first early warning of danger to cold stress. During
exposure to cold, maximum severe shivering develops when the body temperature has
fallen to 95°F (35°C). This must be taken as a sign of danger to the employees on site,
and cold exposures should be immediately terminated for any employee when severe
shivering becomes evident. Useful physical or mental work is limited when severe
shivering occurs.
There are certain predisposing factors that make an individual more susceptible to cold
stress. It is the responsibility of the project team members to inform the Health and
Safety Officer to monitor an individual, if necessary, or use other means of
preventing/reducing the individual's likelihood of experiencing a cold related illness or
disorder.
2866 (1) PART 2 · Cold Stress Rev. 0-09/15199 CONESTOGA-ROVERS & ASSOCIATES
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2.0
HUIUI
PREDISPOSING FACTORS
Predisposing factors that will increase an individual's susceptibility to cold stress are
listed below:
• Dehydration: The use of diuretics and/ or alcohol, or diarrhea can cause
dehydration. Dehydration reduces blood circulation to the extremities.
• Fatigue During Physical Activity: Exhaustion reduces the body's ability to constrict
blood vessels. This results in the blood circulation occurring closer to the surface of
the skin and the rapid loss of body heat.
• Age: Some older and very young individuals may have an impaired ability to sense
cold.
• Alcohol Consumption: Alcohol dilates the blood vessels near the skin surface
resulting in excessive body heat loss.
• Sedative Drugs: Sedatives may interfere with the transmission of impulses to the
brain, thereby interfering with the body's physiological defense against cold. Some
prescription drugs may react the same way.
• Poor Circulation: Vasoconstriction of peripheral vessels reduces blood flow to the
skin surface.
• Heavy Work Load: Heavy work loads generate metabolic heat and make an
individual perspire even in extremely cold environments. If perspiration is absorbed
by the individual's clothing and is in contact with the skin, cooling of the body will
occur.
• The Use of PPE: PPE usage which traps sweat inside the PPE may increase an
individual's susceptibility to cold stress.
• Lack of Acclimatization: Acclimatization, the gradual introduction of workers,into a
cold environment, allows the body to physiologically adjust to cold working
conditions.
• Histoi:y of Cold Injui:y: Previous injury from cold exposures may result in increased
cold sensitivity.
2866 (1) PART 2 · Cold Stress Rev. 0 • 09/15199 2 CONESTOGA-ROVERS & ASSOCIATES
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3.0
HllljU)
PREVENTION OF COLD STRESS
There are a variety of measures that can be implemented to prevent or reduce the
likelihood of employees developing cold related ailments and disorders. These include
acclimatization, fluid and electrolyte replenishment, eating a well balanced diet, wearing
warm clothing, the provision of shelter from the cold, thermal insulation of metal
surfaces, adjusting work schedules, and employee education.
• Acclimatization: Acclimatization is the gradual introduction of workers into the cold
environment to allow their bodies to physiologically adjust to cold working
conditions. However, the physiologic changes are usually minor and require
repeated uncomfortably cold exposures to induce them.
• Fluid and Electrolyte Replenishment: Cold, dry air can cause employees to lose
significant amounts of water through the skin and lungs. Dehydration affects the
flow of blood to the extremities and increases the risk of cold injury. Warm, sweet,
caffeine-free, non-alcoholic drinks and soup are good sources to replenish body
fluids.
• Eating a Well Balanced Diet: Restricted diets including low salt diets can deprive the
body of elements needed to withstand cold stress. Eat high energy foods throughout
the day.
• Warm Clothing: It is beneficial to maintain air space between the body and outer
layers of clothing in order to retain body heat. However, the insulating effect
provided by such air spaces is lost when the skin or clothing is wet.
The parts of the body most important to keep warm are the feet, hands, head, and face.
As much as 40 percent of body heat can be lost when the head is exposed.
.. Recommended clothing includes:
• Inner layers (t-shirts, shorts, socks) should be of a thin, thermal insulating material.
• Wool or thermal trousers. Denim is not a good protective fabric.
• Felt-lined, rubber-bottomed, leather-upper boots with a removable felt insole is
preferred. Change socks when wet.
• Wool shirts/sweaters should be worn over inner layer.
• A wool cap is good head protection. Use a liner under a hard hat.
• Mittens are better insulators than gloves.
• Face masks or scarves are good protection against wind.
2866 (1) PART 2 · Cold Stress Rev. 0. 09115/99 3 CONESTOGA-ROVERS & ASSOCIATES
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• Tyvek/poJy'.coated Tyvek provides good wind protection.
• Wear loose fitting clothing, especially footwear.
• Carry extra clothing in your vehicle.
• Shelters with heaters should be provided for the employees' rest periods if possible.
Sitting in a heated vehicle is a viable option. Care should be taken that the exhaust is
not blocked and that windows are partially open to provide ventilation.
• At temperatures of 30°F (-1°C) or lower, cover metal tool handles with thermal
insulating material if possible.
• Schedule work during the warmest part of ttie day if possible, rotate personnel and
adjust the work/rest schedule to enable employees to recover from the effects of cold
stress.
3.1 EMPLOYEE EDUCATION
Employees have already been trained to recognize and treat the effects of cold stress
during their 40-hour training. Signs, symptoms, and treatment of cold stress should be
reviewed in project safety meetings where applicable. The buddy system will help in
preventing cold stress once the employees are trained to recognize the signs and
symptoms of cold stress.
3.2 COLD STRESS PREVENTION GUIDELINES
It may not be practically feasible to implement all the above prevention measures.
Follow the guidelines given below when the ambient air temperature is below 0°F
(-18°C):
• Dress warmly.
• Replenish fluids and electrolytes at regular intervals.
• Provide shelter from the cold.
• Adjust work/rest schedules.
2866 (1) PART 2 • COid Stress Rev. 0-09/15/99 4 CONESTOGA-ROVERS & ASSOCIATES
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(U)
3.3 ADJUST WORK-REST SCHEDULES IN SEVERELY COLD
ENVIRONMENTS
Follow the work/rest schedule in Table 2. It is based on the cooling power of air which
is a function of wind speed and ambient air temperature.
2866 (1) PART 2 • Cold Stress Rev. 0. 09/1~ 5 CONESTOGA-ROVERS & ASSOCIATES
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4.0 FIRST AID TREATMENT GUIDELINES
The following describes sxmptoms of different stages in cold stress and the related first
aid treatment guidelines.
4.1 FROSTBITE
Stages
Incipient (frost nip)
Superficial
Deep
First Aid
Incipient
Superficial
Deep
May be painless. Tips of ears, nose, cheeks, fingers, toes,
chin affected. Skin blanched white.
Affects skin/tissue just beneath skin; turns purple as it
thaws. Skin is firm, waxy; tissue beneath is soft, numb.
Tissue beneath skin is solid, waxy, white with purplish
tinge. Entire tissue depth is affected.
Warm by applying firm pressure -blow warm breath on
spot or submerge in warm water (102°F to 110°F) (39°C to
43°C). Do not rub the area.
Provide dry coverage, steady warmth; submerge in warm
water.
Hospital care is needed. Do not thaw frostbitten part if
needed to walk on. Do not thaw if there is danger of
refreezing. Apply dry clothing over frostbite. Submerge
in water; do not rub.
4.2 GENERAL HYPOTHERMIA
Stages
• Shivering.
• Indifference.
• Decreased consciousness.
2866 (1) PART 2 • Cold Stress Rev. 0. 09/15199 6 CONESTOGA-ROVERS & ASSOCIATES
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• Unconsciousness.
• Death.
Symptoms
• Muscle tension .
• Uncontrollable shivering .
• Glassy stare .
• Decreased muscle function .
• Speech distortion .
• Blue, puffy skin .
• Slow pulse .
• Shallow breathing .
• Coordination loss .
• Stumbling .
• Forgetfulness .
• Freezing extremities .
• Dilated pupils .
• Fatigue .
Emergency Response
• Keep person dry; replace wet clothing.
• Apply external heat to both sides of patient using available heat sources, including
other bodies.
• Give warm liquids -not coffee or alcohol -after shivering stops and if conscious.
• Handle gently.
• Transport to medical facility as soon as possible.
• If more than 30 minutes from a medical facility, warm person with other bodies.
2866 (1) PART 2 -Cold Stress Rev. 0. 09115199 7 CONESTOGA:ROVERS & ASSOCIATES
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TABLE 1
WIND CHILL CHART
Wind SO"F 40"F 30"F 20"F IO"F O"F -IO"F -20"F -30"F
speed
5mph 48°F 37"F 27"F 16°F
10mph 40"F 28'F 16'F
15 mph 36°F 22"F 9'F .5op
20mph 32°F 18°F 4'F -IO"F
25 mph 30"F 16'F O"F
30mph 28'F 13op .zop -ISDF
35mph 27"F 11°F -4'F -21'F
40mph 26°F IO"F -{j0F -21°F
over 40 mph adds little to the LITTLE DANGER
effect (properly clothed)
• TRENCH FOOT & IMMERSION FOOT can occur at any point on the chart!
ADVERSE EFFECTS OF THE COLD
TRENCH FOOT: Caused by a combination of cold wet conditions at 50 and below. The symptoms include redness, swelling,
numbness, blistering, bleeding or having ~welling in severe cases.
IMMERSION FOOT: Caused by the restriction of blood circulation in the presence of moisture and cold starting at 50 and below.
The symptoms are little or no pain, cold feeling, gradual paling, numbness, and the feet feel like blocks of wood.
CARBON MONOXIDE POISONING: Occurs when exhaust fumes from fuel burning equipment such as vehicles, oil heaters, etc.,
enter a closed space such as the inside of a vehicle or tent. The symptoms are extreme weakness and drowsiness. Death will result
unJess individual is moved to fresh air.
FROSTBITE: Is the crystallization of tissue fluid caused by exposure to cold below freezing. Most common areas of frostbit~ are the
face, nose, ears, hands, and feet. The symptoms include redness and pain in the early stages, followed by a waxy white appearance,
numbness and the skin may feel stiff and even brittle.
PREVENTION OF COLD INJURY
To Stay Warm Remember The Word C-0-L-D
C -Cleanliness and Care: Feet, socks, and clothing are warmer when clean. Constant foot care is imperative.
0 -Overheating: Prevent overheating by adjusting your clothing to the job being performed.
L -Loose and Layered: Loose-fitting clothing insures good circulation and insulation. Clothing in layers assures air spaces which
hold body heat. Again, allows an individual to adjust the number of layers to the temperature and activity being performed.
D -Dampness: Any wet garment is a cold garment, just as tight-fitting garments are cold producing garments. Wear a field jacket as
a wind breaker and for its water-repellency. Keep clothing dry.
.. Use the Buddy system, this is the best way to prevent cold injury. If you start feeling cold do some exercises until you start feeling
warm again .
FIRST AID FOR COLD INIURIES
1. Get individual off their feet.
2. Get individual into wann dry clothing.
3. Get individual warm fluids to drink (NO ALCOHOLIC BEVERAGES)
4. Do not smoke.
5. Keep the effected area clean, warm and dry. Do not allow to REFREEZE. If you cannot keep area warm, leave it frozen.,
6. Do not rub effected area.
7. Evacuate through medical channels ASAP.
HYPOTHERMIA
The condition of low internal body heat dropping steadily from a healthy 98.6, and if not reversed, can bring fatal consequences.
Hypothermia can develop without much warning. Dress for the weather and avoid getting wet or damp.
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CRA 2866 (l) PART 2 -Cold Stress Rev. 0-09/15/99
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Air Temperature
TABLE2
WORK/REST SCHEDULE
FOR A 4-HOUR WORK SHIFT
with Sunny Sky Work/Break Schedule (Minutes)
No 5mph 10mph 15mph •f ·c Wind Wind Wind Wind
-05 to -09 -20 to -23 Normal Normal Normal 55/10
-lOto-14 -23 to -26 Normal Normal Normal 40/10
-15 to-19 -26 to -28 Normal Normal 40/10 20/10
-20 to -24 -29 to -31 Normal 40/10 20/10 Stop
-25 to -29 -32 to -34 40/10 20/10 10/10 Stop
-30 to -34 -35 to -37 20/10 Stop Stop Stop
-35 and Below -38 and Below Stop Stop Stop Stop
Notes:
Schedule applies only to employees in dry clothing.
20mph
Wind
40/1-0
20/10
10/10
Stop
Stop
Stop
Stop
Schedule applies to any 4-hour work period with moderate to heavy work activity, with
warm-up periods of 10 minutes in a warm location and with an extended break (e.g., lunch)
in a warm location. For light-to-moderate work: apply schedule one step lower. For example,
at -25°F with no noticeable wind, there should be a maximum work period of 20 minutes and
then a 10-minute break.
This table addresses the health hazards related to cold weather work. The practicality of
working under a work/ rest schedule, together with the ability of the necessary equipment to
function properly in cold weather, may be more restrictive than the health hazards and also
need to be considered.
The cold stress schedule applies to light or sedentary work activities. Light to moderate work
activities can be moved down one level, moderate to heavy work activities can be moved
down two levels if workers are acclimated, have proper protective clothing, and show no
signs of cold stress.
The following is suggested as a guide for wind velocity if accurate information is not available
5mph Wind:
10mph Wind:
15mph Wind:
20mph Wind:
3669 (32)
Light flag moves.
Light flag fully extended.
Raises newspaper sheet.
Blowing and drifting snow.
CRA 2866 {l) PART 2 • Cold Stress Rev. 0 • 09/15/99
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TABLE OF CONTENTS
HEAT STRESS
1.0 OVERVIEW ............................................................................................................................. 1
2.0 PREDISPOSING FACTORS .................................................................................................. 2
3.0 PREVENTION OF HEAT STRESS ....................................................................................... 4
3.1 PREVENTION PRACTICES .............................................................................. 5
3.2 HEAT STRESS MONITORING ......................................................................... 6
4.0 HEAT STRESS FIRST AID .................................................................................................... 7
4.1 HEATCRAMPS .................................................................................................. 7
4.2 HEAT EXHAUSTION ........................................................................................ 7
4.3 HEAT STROKE ................................................................................................... 7
-(llJ
2B66 (1) PART 2 -Heal Stress Rev. 1 • 03/02/2001 CONESTOGA-ROVERS & ASSOCIATES
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1.0
HU Ill)
HEAT STRESS
OVERVIEW
Heat induced occupational illnesses, injuries, and reduced productivity occur in
situations in which the total heat load (environmental plus metabolic) exceeds the body's
capacities to maintain normal body functions without excessive strain. Heat stress is the
sum of the heat generated in the body plus the heat gained from the environment minus
the heat lost from the body to the environment. The body's response to heat stress is
called heat strain. The level of heat stress at which excessive heat strain will result
depends on the heat tolerance of the individual. Certain predisposing factors may
reduce an individual's ability to tolerate heat stress.
Using personal protective equipment (PPE) may put a .hazardous waste worker at an
increased risk of developing heat stress. Health effects may rarige from heat rash or heat
fatigue to serious illness or death. Heat stress is caused by a number of interacting
factors, including environmental conditions such as temperature and relative humidity,
protective clothing which limits natural heat loss through perspiration, workload, and
the individual characteristics of the worker.
It is the responsibility of the project team members to inform the Health and' Safety
Officer (HSO) or the Industrial Hygiene and Safety Group (IHSG) if any of the
predisposing factors listed below apply to them. This enables the HSO to monitor the
individual if necessary, or use other means of preventing/reducing the individual's
likelihood of experiencing a heat related illness or disorder.
2866 {1) PART 2 -Heat Stress Rev. 1 -03/02/2001 CONESTOGA-ROVERS & ASSOCIATES
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2.0
MU(lll
PREDISPOSING FACTORS
Predisposing factors that will increase the individual's susceptibility to heat stress are
listed below:
• Lack of Physical Fitness: Such individuals experience more physiological strain
including a higher heart rate, a higher body temperature, less efficient sweating, and
slightly higher oxygen consumption as compared to fit individuals.
• Obesity: Overweight individuals produce more heat per unit surface area than thin
individuals and have a lowere_d ability to dissipate heat.
• Age: Older individuals may have a decreased ability to cope with heat stress.
• Dehydration: Dehydrated individuals will have a decreased ability to cool the body
by sweating. Diarrhea can cause dehydration.
• Alcohol, Medications, and Drug Use: Alcohol consumption may dehydrate
individuals and certain medications/ drugs may act as diuretics. Hence, the
individual may have a decreased ability to lose heat by sweating.
• Infection, Sunburn, Illness, and Certain Chronic Diseases: These factors may
interfere with the body's normal mechanisms to lose heat.
• Heart Conditions or Circulatory Problems: Heat stress may place an additional
strain on the heart and circulatory system that could harm the individual as well as
decrease the individual's physiologic response.
• Low Salt Diet: Could affect the individual's electrolyte balance.
• Pregnancy
• Previous History of Heat Stroke or Heat Exhaustion: May increase the individual's
susceptibility to heat stress.
• Heavy Workload: Will generate metabolic heat thereby increasing the heat stress
placed on the individual.
• The Use of PPE Over Light Summer Clothing: This will decrease the ability of an
individual to lose heat by sweating as evaporative cooling can no longer occur. •
• Lack of Acclimatization: Acclimatization is the gradual introduction of workers into
a hot environment to allow their bodies to physiologically adjust to hot working
conditions. Acclimatized individuals generally have lower heart rates and lower
body temperatures. In addition, they sweat sooner and more profusely and even
have more dilute sweat (thereby losing less electrolytes) than non-acclimatized
individuals.
2866 {1) PART 2 • Heat Stress Rev, 1 . 03/02/2001 2 CONESTOGA-ROVERS & ASSOCIATES
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3.0
lla(JZI
PREVENTION OF HEAT STRESS
There are a variety of measures that can be implemented to prevent or reduce the
likelihood of employees developing heat stress related disorders. These include fluid
and electrolyte replenishment, the provision of shelter from the sun and heat, work
schedule adjustment, the use of cooling devices, acclimatization, heat stress monitoring,
and employee education, as discussed below:
• Fluid and Electrolyte Replenishment: Personnel should drink about 16 ounces of
water before starting work and drink water at every break. To encourage water
consumption, cool water and disposable cups should be made available. The.normal
thirst mechanism is not sensitive enough to ensure that enough water will be drunk
to replace lost sweat. When hea_vy sweating occurs, personnel should be encouraged
to drink more. Replacing body fluids with Gatorade is an option. It is advisable to
have Gatorade on site if the air temperature is 70°F (21 °C) or more and the workers
are performing tasks with a moderate to heavy work load in chemical resistant
clothing.
• Shelter From the Sun and Heat: Air-conditioned (if possible) or shaded areas should
be made available for rest periods. Sitting in an air-conditioned truck is an
acceptable option.
• Work Schedule Adjustment: Scheduling work for early mornings and/or late
afternoons will avoid the hottest parts of the day and reduce the heat stress placed
on personnel. Rotation of personnel will help reduce overexertion of workers and
adjusting the work-rest schedule will help personnel recover from the effects of heat
stress periodically.
• Use of Cooling Devices: The use of cooling devices like field showers, hose-.down
areas, or cooling vests should be considered for project tasks that involve heavy
work loads in chemical resistant clothing.
• Acclimatization: Acclimatization is the gradual introduction of workers into a hot
environment to allow their body to physiologically adjust to hot working conditions.
Acclimatized individuals generally have lower heart rates and lower body
temperatures. In addition, they sweat sooner and more profusely and even have
more dilute sweat (thereby losing less electrolytes) than non-acclimatized
individuals.
• Heat Stress Monitoring: Monitoring hot environments for potential heat stress
should be initiated when the ambient air temperature is in excess of 70°F. There are
several ways to monitor heat stress: measuring heart rate, oral temperature, loss of
body weight, and the Wet Bulb Globe Temperature using a Reuter-Stokes or Quest
2866 (1) PART 2 • Heat Stress Rev. 1 . 03/02/2001 3 CONESTOGA-ROVERS & ASSOCIATES
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-(i2)
Electronics heat stress monitor. Conestoga-Rovers & Associates (hereby referred to
as CRA) employees are advised to measure their heart rates as a primary means of
heat stress monitoring following the guidelines in Section 13.3.2 and Table 13.1:
• Employee Education: Workers have already been trained to recognize and treat the
effects of heat stress during the 40-hour training course. Signs, symptoms, and
treatment of heat stress should be discussed in site safety meetings. The buddy
system will help in preventing heat stress once the employees are trained. to
recognize the signs and symptoms of heat stress.
3.1 PREVENTION PRACTICES
It may not be practically feasible to implement all of the above prevention measures.
The following has been developed as a field guide for use in actual field situations.
Ambient air temperature is 70°F (21 °C) or more:
• Replenish fluids and electrolytes. Drink cool (50°F to 60°F /10°C to 15°C) fluids
hourly. The fluids should be caffeine-free and non-alcoholic. Do not wait until you
are thirsty. Your normal thirst mechanism is not sufficient to overcome the effects of
dehydration. If you feel thirsty, you are already becoming dehydrated.
• Provide shelter from the sun and heat.
Ambient air temperature is 70°F (21 °C) or more and chemical resistant clothing is being
used:
• Sarne as above.
· • Adjust work schedules if feasible.
• Initiate heat stress monitoring and/or the use of cooling devices.
3.2 HEAT STRESS MONITORING
Heat stress monitoring may be performed by monitoring the heart rate. Heart rate
should be measured at the beginning of the work shift, at regular intervals and at the
start of each rest period.
2866 (1) PART 2. Heat Stress Rev. 1 . 03/02/2001 4 CONESTOGA-ROVERS & ASSOCIATES
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1)
2)
Mff[12)
If the heart rate is <110 beats per minute (bpm), personnel may continue the
current work/rest schedule.
If the heart rate is >110 bpm, take a 10-minute break. Monitor heart rate at the
end of the rest period. If not <110 bpm, rest until the heart rate is <110 bpm.
Reduce the current work time between breaks by approximately 1 hour. If the
next scheduled monitoring session shows a heart rate of >110 bpm, once again
reduce the work time between breaks by 1 hour.
2866 (1) PART 2 • Heat Stress Rev. 1. 03/02/2001 5 CONESTOGA-ROVERS & ASSOCIATES
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4.0 HEAT STRESS FIRST AID
4.1 HEAT CRAMPS
Cause: Excessive water loss/ electrolyte imbalance.
Symptoms
Muscular pain in anns, legs,
abdomen
·Faintness, dizziness, exhaustion
Normal temp, cool moist skin
4.2 HEAT EXHAUSTION
First Aid Guidelines
Administer sips of Gatorade (1 /2 gla~s
every 15 minutes)
Do not massage cramping muscles
Relax person
Cause: Large amount of water loss; blood circulation diminishes.
Symptoms
Moist, clammy, skin, usually pale
Dilated pupils
Weak, dizzy, nauseous, headache
. Normal or low body temperature
4.3 HEAT STROKE
First Aid Guidelines
Move to a cool place
Apply cold, wet compresses to skin
Raise feet 8 to 12 inches
Administer sips of Gatorade (1/2 glass
every 15 minutes)
Get medical attention
Cause: Body overheats; temperature rises; no sweating occurs.
Symptoms
No sweating occurs
Dry, hot skin, usually red
Constricted pupils
First Aid Guidelines
Get emergency medical assistance ASAP
Remove from sunlight
Wet down body with cool water or rubbing
alcohol
2866 (1) PART 2 -Heat Stress Rev. 1 • 03/02/2001 6 CONESTOGA-ROVERS & ASSOCIATES
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HU(lZI
Symptoms
Hot body temperahtre
(105°F to 110°F / 40.5°C to 43.5°C)
Strong, rapid pulse
Unconsciousness may occur
Muscular twitching
2866 (1) PART 2 • Heat Stress Rev. 1 -03/02/2001 7
First Aid Guidelines
Elevate head/ shoulders
Wrap in wet, cold wrapping
Once cooled to 102°F (38.9°C), stop cooling
measures
CONESTOGA-ROVERS & ASSOCIATES
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TABLE OF CONTENTS
SEVERE WEATHER
1.0 SCOPE ...................................................................................................................................... 1
2.0 THUNDERSTORMS AND LIGHTNING ........................................................................... 2
3.0 TORNADOES ......................................................................................................................... 3
4.0 WINTER STORMS ................................................................................................................. 4
2866 (1) PART 4 • Severe Weather Rev. 0 • 09115199 CONESTOGA-ROVERS & ASSOCIATES
THE CONTENTS OF THIS DOCUMENT ARE THE SOLE PROPERTY OF CONESTOGA-ROVERS & AsSOCIATES (CRA). REPRODUCTION OF ANY PART BY ANY MEDIUM IS NOT AUTHORIZED WITHOUT THE EXPRESS WRITTEN CONSENT OF CRA.
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1.0
JI.U(UI
SEVERE WEATHER
SCOPE
As most projects are conducted outside, the potential for severe weather must be
considered. Thunderstorms, tornadoes, and winter storms can develop quickly,
jeopardizing worker safety. The following emergency procedures are to be follo:,ved in
case of severe weather.
2866 (1) PART 4. Severe Weather Rev. 0 -09115/99 CONESTOGA-ROVERS & ASSOCIATES
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2.0 THUNDERSTORMS AND LIGHTNING
Monitor weather conditions at all times while working. Monitor for a sign of an
impending storm such as increased cloudiness, darkened skies, and increased wind. If
any of these signs are observed, listen to a radio for the latest weather information or
contact a local weather reporting service.
When a thunderstorm accompanied by lightning is in the project area, cease work
immediately. All powered equipment, such as drill rigs, are to be shut down.
Seek shelter inside nearby buildings or trailers. If there are no buildings nearby, seek
shelter inside your vehicle.
If you are caught outside, do not stand beneath tall, isolated trees or telephone poles.
Avoid areas projecting above the landscape such as hill tops. In open areas, go to a low
place such as a ravine or valley. Stay away from open water, metal equipment, wire
fences, and metal pipes. If you are in a group of people in the open, spread out, staying
several yards apart.
If you are caught in a level field or open area far from shelter and you feel your hair
stand on end, lightning may be about to strike you. Drop to your knees and bend
forward, putting your hands on your knees. DO NOT LIE FLAT ON THE GROUND.
If someone has been struck by lightning, monitor life signs and begin administering
mouth-to-mouth resuscitation or cardiopulmonary resuscitation as needed. Send for
help. Check conscious victims for bums, especially at the fingers and toes and next to
buck.Jes and jewelry. Administer first aid for shock. Do not let the victim walk around.
2866 {1) PART 4 -Severe Weather Rev. 0 · 09/15/99 2 CONESTOGA-ROVERS & ASSOCIATES
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3.0 TORNADOES
Tornadoes usually develop from thunderstorms and normally occur at the trailing edge
of the storm. Most tornadoes occur in the months of April, May, June, and July in the
late afternoon and early evening hours. ·
When storms are predicted for the project area, monitor weather conditions on a radio.
A tornado watch is issued when favorable conditions exist for the development of a
tornado. A tornado warning is issued by the local weather service office whenever a
tornado has actually been sighted or is strongly indicated by radar.
If a tornado warning is issued, seek shelter immediately. If there are permanent
buildings located on site, go there immediately, moving toward interior hallways or
small rooms on the lowest floor.
If a tornado warning is issued and you are in a vehicle or a site trailer, leave and go to
the nearest building. If there are no buildings nearby, go in the nearest ditch, ravine, or
culvert, with your hands shielding your head.
If a tornado is sighted or a warning issued while you are in open country, lie flat in a
· ditch or depression. Hold onto something on the ground, such as a bush or wooden
fence post, if possible.
Once a tornado has passed the site, site personnel are to assemble at the designated
assembly area to determine if anyone is missing. Administer first aid and seek medical
attention as needed.
2B66 (1) PART 4 • Severe Weather Rev. O • 09115/99 3 CONESTOGA-ROVERS & ASSOCIATES
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4.0
HU(Jl)
WINTER STORMS
When snow or ice storms are predicted for the project area, site personnel should
monitor weather conditions on a radio. A winter storm watch is issued when a storm
has formed and is approaching the area. A winter storm warning is issued when a
storm is imminent and immediate action is to be taken.
When a storm watch is issued, monitor weather conditions and prepare to halt site
activities. Notify the project manager (PM) of the situation. Seek shelter at site
buildings or leave the site and seek warm shelter. If you are caught in a severe winter
storm while traveling, seek warm shelter if road conditions prevent safe travel.
If you are stranded in a vehicle during a winter storm:
• STAY IN THE VEHICLE, disorientation comes quickly m blowing and drifting
snow;
• wait for help;
• keep a window open an inch or so to avoid carbon monoxide poisoning;
• run the engine and heater sparingly;
• keep watch -do not let everyone sleep at the same time; and
• exercise occasionally.
2866 (1) PART 4. Severe Weather Rev. 0 -09/15/99 4 CONESTOGA-ROVERS & ASSOCIATES
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I APPENDIXB
I HASP PLAN ACKNOWLEDGEMENT SHEET
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I 3669 (32)
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HASP Plan Acknowledgement Sheet
This is to certify that I have received a pre-entry briefing regarding this health and safety plan
and I understand its contents. My failure to follow and comply with the requirements
contained in this plan may result in disciplinary action, removal from the site, and/ or
termination.
,
Print Name Signature Date
CRA 3669 (32)
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I SAFETY (TAILGATE) MEETING FORM
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I 3669 (32)
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Safety (Tailgate) Meeting Form
Date: _______________ Tirne:
Site Location:. _____________________________ _
Site Personnel in attendance·
Name (Print)
Safety Topics/Items discussed:
Site Safety Officer
Name:
CRA 3669 (32)
Signature Company
Date: ________ _