NCD980840409_19911202_Charles Macon Lagoon & Drum_FRBCERCLA RA_Draft Safety Health and Emergency Response Plan-OCR

I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
D.EC O 2 1991 !SCANNED ------
4WD-NCRS FFR I 7 2017
Ms. Charlotte Jesneck 1 N.C. Superfund Section!
Superfund Section
North Carolina Department of Environment,
Health and Natural Resources
suite 150
401 Oberlin Road
Raleigh, North Carolina 27605
RE: Review of the Draft Safety, Health and Emergency Response Plan for the
Remedial Action at the Chemtronics superfund site
Dear Ms. Jesneck:
Enclosed for the state's review is a copy of the Draft safety, Health and
Emergency Response Plan (SHERP) for the Remedial Action (RA) at the
chemtronics Superfund site. The SHERP was develop by Canonie Environmental
services corporation with the help of the potentially responsible parties
(PRPs) Engineering oversight contractor, Sirrine Environmental Consultants.
The Agency has committed to the PRPs that comments would be provided to the
PRPs on this document by December 20, 1991. Therefore, I would like to
receive the state's comments by December 19. If necessary, you can FAX them
to me at [phone].
If you have any questions, please do not hesitate to call me at [phone].
Sincerely yours,
Jon K. Bornholm
Remedial Project Manager
Enclosure
cc: Lee Crosby, NCDEHNR (w/out encl.)
William Meyer, NCDEHNR (w/out encl.)
NC File
I
I
I
I
~
I
I
I
'E
I
I
I
I
I
I
I
I
I
I
7 1991
·v lS
£PA -REGION IV
A Tl.A!-!'! .I\, GA.
November 1991 91-212
SAFETY, HEAL TH, AND EMERGENCY
RESPONSE PLAN
CHEMTRONICS SITE REMEDIATION
SWANNANOA, NORTH CAROLINA1
· CanonieEnvironmental
I
TABLE OF CONTENTS I
PAGE I LIST OF TABLES
LIST OF FIGURES ii I
LIST OF APPENDICES 111 I 1.0 INTRODUCTION 1
1 .1 Work Tasks Hazards and Standard Operating Procedures 8 I
1.1.1 Drilling 8 I 1.1.2 TrenchinAttO~ 11
I 1.1.3 Construction of the Treatment Facility 14
1.1.3.1 Heavy/Light Equipment Operation 20 I
1.1.3.2 General Site SOPs 24
1.1.3.3 Hazard Communication Information 41 I
1.1.3.4 Health and Safety Inspection 41 I
1.1 .4 Training 41
1.1.4.1 Training Requirements 41 I
1.1.4.2 Daily Tailgate Meetings 42 I
1.1.5 Personal Protective Equipment 42
I 1.1.5.1 Personal Hygiene 44
1.1.5.2 Level of Protection 45 I
1.1.5.2.1 Level "D" Protective Use 45 I 1.1.5.2.2 Level "D" Protection Equipment 45
1.1.5.2.3 Modified Level "D" Use 46 I
I
CanonieErwironmerital I
I
I
I
I
I
I
I
I
••
I
I
I
I
I
I
I
I
I
I
TABLE OF CONTENTS
(Continued)
1.1.5.2.4 Modified Level "D" Equipment 46
1.1.5.2.5 Level "C" Protection 4 7
1.1.5.2.6 Level "C" Protective Equipment 4 7
1.1 :5.2. 7 Level "B" Protection Use 48
1.1.5.2.8 Level "B" Protective Equipment 49
1.1.5.3 Activity-Specific Initial Levels of Protection 50
1.1.6 Air Monitoring Plan 50
1.1.6.1 Purpose and Objectives 51
1.1.6.2 Responsibilities 51
1.1.6.3 Air Monitoring Requirements 52
1.1.6.3.1 Equipment 52
1.1.6.3.2 Calibration 53
1.1.6.3.3 Routine Air Monitoring Require-
ments
1.1.6.4 General Procedures and Action Levels
1.1.6.5 Initial Determination for Lead
1 .1 . 7 Medical Surveillance Program
1 . 1 . 8 Site Control
1.1.8.1 Work Zones
53
53
55
56
58
58
CanonieEnvironmental
TABLE OF CONTENTS
(Continued)
1.1.8.2 Visitor
1.1.9 Organization Structure
1.1.9.1 Roles and Responsibilities
1 . 1. 1 O Emergency Response/Spill Control Plan
1.1.10.1 Emergency Contacts
1.1.10.1.1 Additional Emergency Numbers
1.1.10.1.2 Emergency Equipment Available
On-Site
1.1.10.2 Project Personnel Responsibilities During Em-
ergencies
1.1.10.3 Medical Emergencies
1.1.10.4 Fire or Explosion
1.1.10.4.1 Immediate Action
1.1.10.4.2 Notification
1.1.10.4.3 Rescue
1.1.10.4.4 Fire Fighting Procedures
1.1.10.4.5 Protection of Personnel
1.1.10.4.6 Decontamination
1.1.10.4. 7 Fire Extinguisher Information
PAGE
60
61
61
63
63
64
65
65
68
68
69
69
70
70
71
72
72
CanonieEnvironmental
I
I
I
I I
I
I
I
I
I
I
I I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
·1
I
I
I
I
I
I
I
I
I
I
1 .1 .11
1.1.10.5
1.1.10.6
TABLE OF CONTENTS
. (Continued)
Spill Control Plan
1.1.10.5.1 Isolation
1.1.10.5.2 Notification
1.1.10.5.3 Rescue .
1.1.10.5.4 Assessment/Characterization
1.1.10.5.5 Containment
1.1.10.5.6 Cleanup of Hazardous Materials
1.1.10.5.7 Disposal
1.1.10.5.8 Air Releases
Evacuation Routes and Resources
Decontamination
1.1.11.1 Procedures for General Equipment Decontami-
nation
1.1.11 .2 Procedures for Heavy Equipment and Vehicle
Decontamination
1.1.11.3 Procedures for Decontamination of Personnel
1.1.11.3.1 General Decontamination Proce-
dures
1.1.11.3.2 Emergency Decontamination
PAGE
73
73
74
75
75
77
78
78
79
79
80
80
80
81
81
81
. CanonieEnvironmenta.l
REFERENCES
TABLES
FIGURES
APPENDICES
TABLE OF CONTENTS
(Continued)
1.1.11.3.3 Decontamination Procedures
1. 1.11 .4 Contamination Control
PAGE
. 82
84
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmental I
I
I
I
I
I
I
I
I
·1
DRAFT
HEALTH AND SAFETY PLAN
CHEMTRONICS SITE REMEDIATION
SWANNANOA, NORTH CAROLINA
1.0 INTRODUCTION
This Health and Safety Plan (HASP) has been developed to identify and evaluate safety
and health hazards of each phase of site operations for the remedial action construction
to be performed at the Chemtronics Site remediation in Swannanoa, North Carolina.
This HASP includes the requirements and procedures to be followed during each phase
of site operations in order to ensure worker protection. A copy of this HASP must be on-
site during all phases of the remedial action construction operations. Moreover, all
workers intending to enter the Exclusion Zone prior to conducting any work on-site must
read this HASP or have the materfal presented to them and sign the Health and Safety
Plan Acknowledgment Form which is given in Appendix A. By signing the Health and
Safety Plan Acknowledgement Form, workers are acknowledging that they are aware of I the presence of specific hazards on-site and the policies and procedures required to
safeguard themselves and other workers from those hazards.
I
I
I
I
I
I
I
I
I
Location
The Chemtronics Site is located at 180 Old Bee Tree Road in Swannanoa, North
Carolina. Swannanoa is located in Buncombe County and is approximately eight miles
east of Ashville, North Carolina.
Description
The Chemtronics facility encompasses approximately 1,027 acres in rural Swannanoa.
The site is surrounded by sparsely inhabited woodlands to the north and west and is
bounded on the east by Bee Tree Creek and Bee Tree Road. Local topography is steep,
ranging from 2,200 to 3,400 feet above mean sea level.
CanonieEnvironmental
2
Overview of Work to be Done
There are 6 distinct areas that require capping, comprising approximately 11 acres. Two
of the 6 areas have an approximate slope of 20 to 30 percent. Four of these areas
contain buried drums suspected of containing potential contaminants. These potential
contaminants are of. such a nature that the United States Environmental Protection
Agency (EPA) and the Potentially Responsible Parties (PRPs) agree that the greatest
potential for human exposure would be to the remediation workers. Thus, all brush and
trees on these sites must be cut off above ground with the ground left as undisturbed
as possible using conventional equipment. No grubbing will be allowed in these six
distinct areas. From a grading point of view (cut and fill), there will be large volumes of
fill but very little cut allowed.
The overall site to be remediated for ground water contamination is contained in two
valleys on a 1,000 plus acre facility. The front valley will require conversion of two
monitoring wells to extraction wells, plus a ground water treatment facility. This
treatment facility will be equipped with an equalization tank, air stripper and carbon
absorption units, along with various pumps, filters, flowmeters, etc. The back valley will
have 12 extraction wells feeding to a ground water treatment facility that contains an
equalization tank, air stripper, and associated pumps and flowmeters. The outflow of
each of the treatment units will be piped approximately one-half mile to a sewer outlet
to the Metropolitan Sewer District. In addition, there are series of monitoring wells and
piezometers to be installed. It is anticipated that approximately 39 extraction wells,
monitoring wells, and piezometers will be installed and 9 existing wells will be
abandoned.
Roadways for the transportation of fill dirt will be constructed or current roadways will be
upgraded. In addition, access to the monitoring wells and treatment facilities will be
required.
I
I
I
I
I
I
I
I
I
I
I
I.
I
I
I
I
I
•. I
CanonieErwironmental I
I
I
I
I
9
I
I
I
·1
I
I
I
I
I
I
I
I
I
I
3
Overview of Health and Safety Concerns at the Chemtronics Site.
Work on this site potentially involves several health and safety hazards which must be
considered at every stage of work. The most apparent problem is the potential for
exposure to the variety of chemicals known or suspected to have been disposed of
around the site. Stepping into half-submerged drums or encountering buried explosives
are among the physical safety hazards that must be considered. No less important
however are the "natural" hazards presented by the site itself: ticks carrying Rocky
Mountain Spotted Fever or Lyme diseasE!, chiggers, poison ivy and oak, snakes, and
black bears. These broad categories of hazards are discussed in more detail below.
The two types of disposal areas characterized at the Chemtronics Site, the 3-quinuclid-
inyl benzilate o-chlorobenzylidene malononitrile (BZ/CS) areas and the acid pits disposal •
areas, provide a natural division for discussion of the two broad categories of chemical
exposure which may be encountered. The BZ/CS disposal areas contain primarily BZ
and CS and potentially cyanide. The acid pits disposal areas contain a variety of
solvents, acids and reportedly, cyanide.
In the BZ/CS areas, exposure to BZ and cyanide are of particular concern. BZ is a
potent physchoactive compound developed by the United States Army as an
incapacitating surety agent. Doses as small as 4 to 8 micrograms per kilogram (µg/kg)
' .
of body weight (a dose of approximately 650 µg for a 180 pound person) can produce
the early symptoms of BZ intoxication. Higher doses can lead to the more severe
symptoms (disorientation, agitation, confusion, and stupor) which can last for several
days. The chronic effects of exposure to BZ are unknown.
Although all BZ or Bl-contaminated materials should have been "neutralized" prior to
disposal, interviews with former employees indicate that two batches of off-spec BZ were
buried without neutralization, making exposures to active BZ more probable. The small
CanonieEnvironmenta.l
4
dose producing incapacitation and the duration of the effects make it critical to avoid
possible BZ exposure. BZ is likely to be in particulate form or adsorbed to soil particles ..
Appropriate respiratory equipment and protective clothing will therefore be provided to
workers to prevent inadvertent inhalation, ingestion, or skin contact with dusts that may
be generated during excavation or drilling.
Exposure to cyanide is the other major concern arising from proposed work in BZ/CS
Areas 6, 9, and 10/11, and in the acid pits. Cyanide is a rapidly acting poison which
inhibits oxygen uptake by interrupting electron transport down the cytochrome enzyme
chain. Sufficiently high doses can lead to death from respiratory failure. At low doses
it may simply produce symptoms of weakness, headache, confusion, and in some cases,
nausea and vomiting. Background documents report that "spent" cyanide (probably
cyanide salts in basic aqueous solution) from electroplating operations have been buried
in Area 6 and in the acid pits areas and that cyanide was dumped in Areas 10/11 (form
0
unspecified).
Employee exposure to cyanide could result from direct contact with cyanide salts
released over time from the buried vats or by inhalation of hydrogen cyanide (HCN) gas
which may have formed naturally or, in the case of the acid pits area, by interaction of
cyanide salts with acids discarded in adjacent pits. Analysis of ground water samples
obtained downgradient of the acid pits disposal area showed the Ph of ground water to
be quite low in some wells (pH 4). This low pH ground water when contacting the
cylinder salts can form HCN gas.
The third type of chemical exposure possible in the BZ/CS areas·(in particular Areas 7/8
and 10/11) is contact with CS (tear gas). which is classified militarily as a harassing
agent. CS is a strong, though transient, irritant of mucous membranes and skin.
BZ, CS is likely to be found in particulate form or adsorbed to soil particles,
Like
thus
exposure would likely occur via inhalation of dusts generated during excavation and
drilling or by direct contact with the skin. Unlike BZ, the CS was reportedly not
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmenta.l I
I
~
a
~
a
0
a
u
'E
I
E
I
I
I
I
I
I
I
I
5
neutralized prior to burial. What appeared to be broken bags of CS were visible on the
ground surface during the site visit.
Three types of chemical exposure are of concern for workers in the acid pits disposal
areas; cyanide, solvents, and acids. A metal vat containing "spent" cyanide was
reportedly buried in this area. The acid pits area was also used for laboratory waste
disposal and to evaporate solvents during active use of the pits. Thousands of gallons
of various acids (sulfuric, glacial acetic, and nitric acid) were discharged into this area
from 1975 and 1979. The pits were reportedly lined with polyethylene and crushed
limestone to facilitate neutralization. The pits were also used for open burning.
Contact with cyanide is of particular concern because of its acute toxicity. Also the
proximity of the cyanide wastes to adjacent areas that may contain acids, makes the . .
possibility of encountering HCN gas during drilling greater. Ground water in the vicinity
of the acid pits is slightly acidic (pH 4-6).
Previous ground water data reveal levels of volatile organic compounds (VOCs):
chloroform, 1,2-dichloroethane (1,2-DCA), ethyl benzene, methylene chloride,
perchloroethylene, trans-1,2-dichloroethene (trans-1,2-DCE), picric acid, cyclonite (ROX),
and benzene.
Contaminants found in the soils of the disposal areas include toluene, 1,2-DCA, ROX,
trinitrotoluene (TNT), CS, benzylic acid/benzophenone, trans-1,2-DCE, ethylbenzene,
picric acid, orthochlorobenzaldehyde, TCE, chloroform, several other voes in lower
concentrations, and lead.
The third type of exposure of concern is direct contact with acidic soils and grour:id
water. Although much of the acid disposed of was reportedly neutralized with limestone,
the low pH of ground water in wells, 100 to 200 feet from the acid pits indicates that
some quantity of un-neutralized acid may remain in the pits themselves. Direct contact
CanonieEnvironmental
• 6
with the acidic soil and ground water (skin contact or splashing into th~ eyes) could
cause skin and eye irritation or possibly burns.
There are two basic safety hazards that may be encountered: half-submerged, corroded
drums and undetonated ordinance. Drums in poor condition are visible at the site and
may cause injuries to persons inadvertently stepping through the drums. While all
explosives were reportedly burned, Chemtronics' staff could not rule out the possibility
of encountering live explosives (D. Campbell. personal communication, June 7, 1985).
Field staff may encounter three types of natural hazards during the field work: ticks
carrying Rocky Mountain Spotted Fever or Lyme disease, venomous snakes, and poison
ivy or poison oak. Rocky Mountain Spotted Fever (or Rickettsial disease) is of particular
concern because it can be fatal if untreated. All field staff should beware of snakes
during on-site activities. Poison ivy and oak appear throughout the site.
Lyme Disease is caused by an infectious agent, Borrealia burgdorferi. This agent is a
spirochete transmitted to animals or humans via ticks. The early symptoms and signs,
with one exception, are non-specific and easily attributed to other illnesses, such as the
flu. They include fever, nausea, vomiting, fatigue, headache, photophobia (sensitivity to
light), and, in approximately 75 percent of the cases, a rash. This rash, which appears
at the site of the bite, begins as a small palpable mass. Over several days it enlarges,
sometimes reaching a diameter of 20 centimeters. The border of the enlarging rash is
red, slightly warm, but flat. Often, the center of the rash clears somewhat, so that it
looks like an irregular ring. In about half of the persons with rash, more than one
circular eruption is present. The rash, termed erythema migrans, is essentially diagnostic
of Lyme disease, and therefore is a very important finding.
Undiagnosed/untreated Lyme disease can lead to severe, sometimes life-threatening
medical problems. The principal targets inclu.:a the skin, the nervous system, the heart
•
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmenta.l I
I
I
I
I
I
I
I
I
••
I
I
I
I
I
I
I
I
I
I
7
and the joints. Early treatment is highly desirable since, in most cases, it prevents
progression of the disease, and is a less prolonged, less intense affair.
Preventative Measures
1. Wear light-colored clothing or Tyvek® as a barrier and aid to recognition;
2. Cuff of pants or Tyvek® should be taped to work boot;
3. Wear head/hair protection:
o Hooded Tyvek® coverall;
o Solid material hat with brim (not baseball cap).
4. Use permanone on all non-exposed areas especially feet and legs;
5. Use insect repellant containing Deet on all exposed areas/spray coveralls with
insect repellant.
Check your body thoroughly for ticks and bathe soon after returning home and remove
ticks carefully, using a gentle, firm, tugging motion with fine tweezers. Do not kill the tick
before it has been removed.
Protection
1 . Tick must be on the body for 24 hours before Lyme disease is transmitted to
humans;
2. Tick has antiseptic secretion in bite so victim does not feel it;
CanonieEnvironmental
B
3. Five to 10 days after bite, consult your physician.
Detection
1 . Monitor ticks and tick bites; save ticks that have bitten you;
2. Check for a rash;
3. Check for other symptoms (up to about B weeks after the bite).
1.1 Work Tasks Hazards and Standard Operating Procedures
The following sections describe the various work tasks required to complete the work,
along with anticipated hazards and some Standard Operating Procedures (SOPs) which
may prevent accidents associated with those hazards. Field work often uncovers
unanticipated hazards, so site personnel should be alert at all times on the job, use
common sense, and ask their supervisors any questions which arise.
1.1.1 Drilling
This task involves the drill_ing and installation of 39 extraction wells, monitoring wells and
piezometers and the abandonment of 9 existing wells.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmental I
I
I
I
~
I
I
I
I
·1
I
I,
I
I
I
I
I
I
I
I
8
3. Five to 10 days after bite, consult your physician.
Detection
1 . Monitor ticks and tick bites; save ticks that have bitten you;
2. Check for a rash;
3. Check for other symptoms (up to about 8 weeks after the bite).
1.1 Work Tasks Hazards and Standard Operating Procedures
The following sections describe the various work tasks required to complete the work,
along with anticipated hazards and some Standard Operating Procedures (SOPs) which
may prevent accidents associated with those hazards. Field work often uncovers
unanticipated hazards, so site personnel should be alert at all times on the job, use
common sense, and ask their supervisors any questions which arise.
1.1.1 Drilling
This task involves the drilling and installation of 39 extraction wells, monitoring wells and
piezometers and the abandonment of 9 existing wells.
CanonieEnvironmenta.l
9
Hazards
1. Potential inhalation, ingestion, and skin contact of contaminated materials (i.e.,
BZ, CS, etc.) and contaminated ground water;
2. Physical contact with augers, hazards associated with operation of drill;
3. Fall hazards.
Risk
1. The risk of inhalation or ingestion of contaminated material is considered
moderate to high. The risk of contact with contaminated ground water is
moderate to low.
2. Physical injury is a moderate to high risk. Serious injury could result from
careless operation of the drill rig.
3. The risk of injuries from falls is low.
Drilling operations will begin in Level "O" personal protective equipment (PPE). Previous
drilling on-site did not show HCN gas be encountered. However, drilling breathing
zones will be constantly monitored for HCN. If HCN is encountered, Level "B" PPE will
continue to be utilized for the operation. Protective clothing will be upgraded or
downgraded as conditions indicate. Action levels are shown in Section 1.1.6.4 of this
HASP. The minimum downgrade will be Modified Level ."D" PPE with safety glasses
I
I
I
I
I
I
I
I
I
I
,I
I
I
I
I
I
I
I
CanonieEnvironmental I
I
i
I
I
I
I
I
I
'I
I
I
I
I
I
I
I
I
·I
I
10
and/or goggles as necessary to reduce the possibility of skin contact with contaminated
materials.
Employees are to avoid wearing loose clothing. Care should be taken to minimize
contact with spoils and personnel should position themselves upwind from the borehole
whenever possible.
The drill rig must be level prior to lifting the mast. All ropes, cables, hydraulic lines, and
fluids on the rig must be checked daily. The drill rig· must be shut down prior to any
repairs. Lockout/tagout procedures (as described in Appendix B) should be followed.
Personnel must keep a safe distance from rotating augers, winches, etc. The drill rig
must not be operated beneath or within 30 feet of overhead power lines. Always assume
all electric wires to be live and dangerous. Electric current always flows to the ground
when a suitable path is provided. When the derrick of a drill rig touches an overhead
wire, the rig becomes electrified. Although it may appear safe due to rubber tires,
anyone touching the rig while standing on the ground, creates a path to ground for the
current.
All underground utilities must be located prior to work. The drill rig should never be
operated if lightning is present. Cave-ins or slides are potential hazards.
Keep the rig clean, including all controls, gauges, linkages, windows, and lights.
Remove all oil, grease, mud, or ice. Tools and other items must be stored in tool boxes.
Do not store flammable materials on the rig. Be sure all protective guards and panels
are in-place before starting or operating the rig. Know the location of all personnel, and
be sure they are clear of machinery and are aware the rig is being started. Any open
holes must be covered and temporary barricades placed around them if they must be
left unattended.
CanonieEnvironmenta.l
11
· Mount and dismount the rig carefully. Use the grab irons and handholds. Clean mud,
snow, or grease from steps be~ore mounting. Watch for slippery surfaces or obstacles.
Before starting or moving the rig, check all around the rig and underneath. Never leave
the rig unattended. Do not hoist or brake sharply. Never make a lift or position a load
over the ground crew. Never ride up the mast on a hoist line or the drill. Never wrap
a hoist line around a load instead of a sling or chain.
If personnel are required to ascend to the top of the mast for any reason, a life line and
harness are required and must meet the specifications in Occupational Safety and Health
Administration (OSHA) 29 Code of Federal Regulations (CFR) 1926.104.
Air monitoring will be conducted as per Section 1.1.6 of this HASP.
1.1.2 Trenching and Excavation
This task involves the excavation of ground material, specifically the excavation of
drainage culverts and swales and excavation and trenching for manholes, sumps, and
the installation of utilities (i.e., water, sewer), etc. All excavations should be in clean
material. However, contaminated ground water could be encountered.
Hazards
1. Physical hazards associated with excavation and trenching;
2. High voltage electrical lines buried in the area.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmenta.l I
I
I
I
I
I
I
I
I
'I
I
I
I
I
I
I
I
I
I
I
12
1. Physical injury is the greatest risk. Serious injury or death could result from an
excavation cave-in or accident.
. All personnel with the potential for contact with contaminated ground water are required
to be trained as per OSHA 29 CFR 1910.120(e) and as described in Section 1.1.4 of this
HASP. In addition, if contaminated ground water is encountered, air monitoring with an
Hnu or organic vapor analyzer (OVA) will be performed to detect VOCs in workers
breathing zones at least four times daily.
All excavation work must comply with all federal OSHA regulations (OSHA 29 CFR 1910,
and 29 CFR 1926.650-652):
1. Prior to opening an excavation, underground utility lines shall be identified.
Proper supports and/or guards shall be provided when/if the utility line is
exposed.
2. Trees, boulders, and other surface encumbrances that create a hazard shall be
removed and the area made safe before excavation begins.
3. The walls and spaces of all excavations and trenches five feet or greater in depth
shall be guarded by shoring, sloping, or other equivalent means. This applies to
all excavations which employees are expected to enter. When trenches are
excavated greater than four feet in depth, air monitoring will be performed for
oxygen {02), combustible gas [percent lower explosive limit (LEL)], ·and toxicity.
This monitoring will be performed prior to entry and at least twice daily.
CanonieEnvironmenta.l
13
4. The maximum allowable slopes and bench dimensions shall be determined
according to the requirements of 29 CFR 1926.650. Soil shall be classified by the
site engineer or competent person in accordance with Appendix A of 29 CFR
1926.650, and the results shall be used by the construction superintendent to
establish allowable slopes and bench dimensions as presented in Appendix B of
29 CFR 1926.650.
5. Inspections of excavations shall be made and documented daily during work by
the competent person. If there is evidence of possible cave-ins or slides, the
excavation shall be immediately evacuated and all work in the excavation shall
cease until the necessary safeguards have been taken.
6. Excavations more than 4 feet deep shall have ladders or steps located so as to
require no more than 25 feet of lateral travel between means of access.
7. Workers shall be prohibited from entering and exiting excavation by using the
buckets of backhoes or other equipment not designed for the transport of
personnel.
8. All excavations will be backfilled as soon as practical after work is completed and
all associated equipment removed.
9. Excavation spoils shall be placed far enough away from the edge of the trench
to avoid load strain on walls. Surface rocks or other debris that may fall in shall
be removed. Spoils shall be placed a minimum of two feet from the edge of the
excavation or secured by retaining devices.
10. Vehicles shall not be allowed within two feet of the_ edge of the trench. If closer
proximity is necessary, ·authorization must be obtained from the site safety officer
(SSO) or site engineer. Vehicle operators must have a clear and direct view of
CanonieEnvironmental
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
••
I
I
I
I
I
I
I
I
I
I
. 14
the edge of the excavation at all times. Workers shall be prohibited from working
under the loads of lifting or digging equipment. Workers will not be allowed to
stand or work on the blind side of a trackhoe in operation.
11. Workers will not be allowed to work in excavated areas where water is accumulat-
ing.
12. A warning system such as barricades will be used to alert operators and workers
of the proximity to the edge of excavations. Protection between barricades shall
consist of at least three-inch wide nylon tape, yellow, or yellow and black tape.
The tape shall be stretched between barricades.
13. If excavations must remain open overnight, temporary fencing, or barricades and
tape will be placed around the area.
14. Diversion ditches, dikes, or other suitalble means shall be used to prevent surface
• water from entering an excavation and for drainage of the excavation.
15. The side of the excavation must be shored and/or braced as necessary to resist
the extra pressure of any superimposed loads.
1.1.3 Construction of the Treatment Facility
This task involves the construction of small treatment buildings, including excavation,
foundation, building erection, electrical work, utility installation and finishing.
Hazards
1. General construction hazards including concrete construction, welding, cutting,
hand and power tools, and electrical hazards;
CanonieEnvironmenta.l
2.
Risk
1.
2.
3.
15
Excavation hazards.
The risk of inhalation or ingestion of contaminated material is low because the risk
of contact with contaminated ground water is low.
General construction hazards pose the greatest risks. Careless work habits or
faulty equipment could result in serious injury.
Excavation hazards are low (because trenches are shallow), as long as
underground utilities are located prior to excavation.
Work tasks at this location should involve only soil contact. Because ground water is
the source of contamination at this location, work activities will be conducted in Level "D"
PPE.
General Construction
Concrete Construction
Employees applying cement, sand, .and water mixture through a pneumatic hose will be
required to wear protective head and face proteption.
Eye wash facilities will be present when pouring concrete.
Employees will not be permitted to place or tie reinforcing steel more than six feet above
any adjacent working surface without a safety belt or equivalent protection.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmenta.l I
I
I
I
I
I
I
16
Employees will not be permitted to perform maintenance or repairs on equipment where
the inadvertent operation of the equipment could occur and cause injury unless
lockout/tagout procedures have been utilized (see Appendix B).
Employees will be required to wear appropriate eye and hand protection while working
in this area. This will include, at a minimum, safety glasses and/or goggles and leather
or cotton work gloves.
I ~lding and Cutting
I
••
I
I
I
I
I
I
I
I
I
I
Welding or cutting operations will require the appropriate eye protection (this includes
the fire watch).
A fire watch will be present and fire extinguishers will be located near the welding/cutting
operation.
Proper lighting tools will be used for gas torches. Use a striker. Never use a match or
another torch.
A back-flow preventer is to be used on all gas lines.
Compressed gas cylinders shall be secured in an upright position and shall be kept far
enough away from the actual welding or cutting operation so that sparks, hot slag, or
flame will not reach them. Torches will be inspected periodically for defects.
Whenever practicable, all arc welding and cutting operations shall be shielded by non-
combustible or flame proof screens which will protect employees working in the vicinity
from the direct rays of the arc.
CanonieEnvironmental
17
Hot Work Permits will be completed prior to "Hot Work" activities, including approval of
the construction supervisor. A copy cif a Hot Work Permit can be found in Appendix E
of this HASP.
Ladders
A ladder must be checked for loose steps or rungs; loose nails; screws; or bolts; split,
cracked or broken uprights or rungs; damaged, worn, or missing safety feet, before
being used. Ladders will be regularly inspected. Out-of-date ladders or ladders with
damaged parts are to be removed from service and tagged "do not use".
conform to OSHA standards 29 CFR 1910.26 and 1910.27.
Ladders must
Ladders will be placed so that both side rails have equal footing and the base is properly
secured. The ladder must be placed so that the distance the object it is leaning on is
equal to one-fourth the height of the ladder.
Never place a ladder in.front of a door that opens toward the ladder unless the door is
blocked, locked, tagged "do not use" or guarded.
The top of the ladder must extend at least three feet above the top of the landing.
Tools -Hand and Power
Use of makeshift tools and equipment is strictly prohibited. Ensure the proper tool is
available before starting the job. Hand tools are to be used only for the purpose for
which they were designed.
Tools or other loose material shall not be left on ladders, scaffolding, or stairs.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmental I
I
I
I
I
I
I
I
I
, .•
I
I
I
I
I
I
I
I
I
I
18
.
Tools in need of repair shall not be used. A "do not use" or "out of order" label must be
placed on such equipment until it is repaired.
Tools shall be used, stored, and carried properly.
Appropriate PPE and safety glasses will be required when using hand or power tools.
Never use dull tools, they can easily slip, causing injury. Keep hands clean of grease
or slippery material before using tools.
Sharp or pointed tools shall always be stored properly and held away from the body
while utilized. Know how to use the tool before beginning a project.
Always disconnect power to the tool before changing blade/bit, or conducting repairs.
Never yank a power cord to unplug a tool or carry the tool by the cord.
Only trained or experienced personnel are to use power tools:
Do not try to bypass or circumvent any guards on the equipment. No tool is to be run
with guards removed.
Unless a power tool is specifically designed for a hazardous atmosphere, it should not
be used in an explosive or flammable atmosphere. Never clean electrical equipment
with flammable solvents.
PPE will be used if electrical equipment (i.e., saws) creates dust. Hearing protection
shall be required when operating electrical equipment when noise levels exceed 90
decibels (Obs). A hearing conservation program must be initiated if noise levels exceed
85 dBs on an 8-hour time weighted average (TWA) basis.
CanonieEnvironmenta.l
19
Electrical
All electrical work, installation, and wire capacities will be in accordance with the National
Electrical Code ..
Work space around exposed electrical equipment will not be used as passageways or
for storage when electrical parts are exposed; a minimum clearance work space will not
be less than six and one-half feet high or less than three feet wide in radius. A clearance
will also be allowed to permit at least a 90-degree opening of all doors or hinged pads.
De-energized circuits or equipment will require lockout and tagging (see Appendix B).
The non-current carrying metal parts of portable and/or plug-connected equipment will
be grounded unless protected by approved double insulation. The exposed non-current
carrying metals parts of fixed electrical equipment shall be properly grounded. Extension
cords shall be of the three-wire type conductors used for bonding and grounding. Fixed
and moveable equipment'shall be ample size to carry the anticipated current. Bonding
and grounding clamps should have a secure metal-to-metal contact.
Electrical extension cords shall be protected against damage from traffic, sharp corners,
projections, and pinching. Extension cords shall not be fastened with staples, hung from
nails, or suspended by wire.
All qutdoor electrical circuits or circuits on a mobile unit must have ground fault circuit
interrupters.
Lockout!Taqout Procedures
Lockout/tagout procedures will be adhered to and are outlined in Appendix B.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
••
I
I
I
CanonieEnvironmental I
I
I
I
I
I
I
I
I
'I
I
I
I
I
I
I
I
I
I
I
20
Excavation
The excavation in this area is limited to surface grading in preparation for the installment
of the concrete construction. The excavation at this location is not expected to be more
than three feet deep. However, if a depth of four feet or greater is reached, the SOPs
as described in Section 1.1.2 of this HASP must be adhered to.
1.1.3.1 Heaw/Liqht Equipment Operation
This task involves the use of heavy and light machinery to complete the project including
the following operations:
1. Trenching;
2. Excavation;
3. Well drilling;
4. Grading of the access road;
5. Capping of the existing disposal areas.
This section describes the SOPs associated with general safety during the operation of
heavy and light construction vehicles.
General Information
All machinery, heavy construction equipment, or other mechanized equipment utilized
on-site shall be operated pursuant to the OSHA regulations stated in OSHA 29 CFR 191 O
and 1926 (e.g:, inspection and preventative maintenance).
CanonieEnvironmenta.l
21
On-site machinery shall operate at safe speeds and loads as conditions warrant.
Only trained and qualified personnel shall operate machinery.
Cab glass will be safety glass that allows no visual distortion. Establish hand signal
communication when verbal communication is difficult. Appoint one person per work
group to give hand signals to equipment operators.
Chains, hoist, straps, and any other equipment must be properly rated for the specific
application.
Never walk directly behind, or to the side of, heavy equipment without the operator's
knowledge. Operators will watch for workers who may be in their path and provide
warning before movi_ng. Brake lights and audible backup alarms will be placed on all
equipment and will be operable.
Never use a piece of equipment unless you are familiar with its operation. This applies
to heavy as well as light equipment (e.g., chainsaws).
Be sure that no · underground or overhead power lines, sewer lines, gas lines, and
telephone lines will present a hazard in the work area.
All air cylinders placed on heavy equipment for use by the operator shall be well secured
in a bracket which is bolted or welded to the unit.
Check to ensure a clean· path first and a clear view while carrying loads.
Keep a check on load lines, slings, blocks, clamps, or other tackl!!!. Repair/replace
defects. Hang up slings if not in use.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEmrironmenta.l I
I
I
I
I
I
I
I
I
·1
I
I
I
I
I
I
I
I
I
I
22
Before starting machinery, opening valves, switches, etc., check safety of workmen.
Have safety guards in-place.
Never adjust or repair machinery while in motion. Lock out, block, bleed air as required
to prevent movement. Follow appropriate lockout/tagout procedures as described in
Appendix B.
. Operators will use seat belts on machines that are equipped with seat belts at all times
when the machine is in operation.
Operators will be attentive' to the slope of the ground and never attempt maneuvers
which could possibly result in rollover.
Vehicles will be inspected daily by operator before work begins. The construction
superintendent or foreman will perform monthly inspections of vehicles to assure that all
safety equipment is in good working order (i.e., fire extinguisher, back-up alarms, seat
belts, etc.).
It is the responsibility of every employee who drives a company vehicle to wear seat
belts, know and obey all state, local traffic laws, and all site rules relative to the company
equipment. '
Employees must have a valid license from the state of their permanent home residence
for the type and size vehicle they will operate, Where so designated by the Health and
Safety Department, employees may be required to provide other proof of training or
experience.· Employees must report to their supervisor any revocation, suspension, or
restrictions of their license.
Equipment must be kept in good operating condition and operated in a safe and
business like manner.
CanonieEnvironmenta.l
23
Brakes must be tested before use. If anything is defective, repairs will be made before
the vehicle is put in service.
Lights• and other signaling devices must be checked daily. If anything is defective,
repairs will be made before the vehicle is put into service.
All ignition systems shall be turned off and no smoking is permitted while refueling.
Traffic and Transportation Safety
Containers shall be moved only with the proper equip'ment and shall be secured to
prevent dropping or loss of control during transport.
All Department of Transportation (DOT), EPA, and local requirements pertaining to safe
transfer of hazardous materials/wastes (i.e., loading and operating vehicles, grounding
procedures, hazardous materials, placarding or labeling, use of wheel locks/chocks, and
driver qualifications) will be met.
Do not ride on vehicles or mobile equipment unless specifically authorized.
on hook, ball, rigging, or load.
Do not ride
Always be seated when riding authorized vehicles unless designed for standing.
Removal of the HOPE liner in Area 23
Hazards
1. Physical hazards associated with the slipperiness of the high-density polyethylene
(HOPE) surface.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmenta.l I
I
I
I
I
I
I
I
I
·1
I
I
I
I
I
I
I
I
I
I
24
Risk
1 . Physical hazards associated with slips, trips, and falls is moderate.
SOPs
1. Level "C" PPE will be utilized by all employees removing the existing HOPE liner.
Air monitoring will be performed to determine airborne contaminant concentra-
tions.
2. Only boots with good soles will be utilized by workers walking on the HOPE liner.
1.1.3.2 General Site SOPs
Smoking shall be restricted to the staging area. There will be no smoking in any other
area at any time. Supervisors must instruct employees regarding site or office health
and safety regulations, the proper way of performing their tasks, the locations of fire
extinguishers, first-aid stations, requirements for PPE or clothing, the emergency
response plan, and the procedures for reporting injuries and emergencies.
Danger and warning signs that are posted indicating special hazards must be obeyed
at all times.
Personnel are to only operate machinery and equipment for which they have received
instruction and appropriate training. Where applicable, licenses or permits must be
obtained prior to operating equipment or vehicles.
All safety guards furnished by the company or the manufacturer are to be used. These
include seat belts in company vehicles. Removal or non-use is not permitted unless
authorized by a supervisor with the approval of the health and safety department.
CanonieEnvironmenta.l
25
Horseplay, scuffling, running, and practical jokes are prohibited.
Loose or torn clothing, ties, scarves; wrist watches, bracelets, or rings shall not be worn
if they pose a safety hazard.
Shirts must be worn in work areas at all times. At a minimum, shirts will have four-inch
sleeves, and no short pants, tennis shoes, or sneakers will be allowed.
Operations personnel will wear steel-toe work boots meeting the American· National
Standard Institute (ANSI} Standard Z41 .1 .
Employees will wear all PPE as described by the health and safety department for their
particular job activity, and outlined in Section .1.1.5 of this HASP.
All walkways and walking surfaces will be kept clean, dry, and free of hazard (e.g., loose
boards, protruding nails, holes, etc.). Where conditions are wet, drainage, and dry
standing places will be provided as necessary.
Free access shall be maintained to fire extinguishers, power panels, emergency exits,
first-aid kits, safety showers, and eye-wash stations.
Sup~rvisors shall instruct and monitor employees in proper_ lifting techniques.
The lifting capacity of mechanical equipment shall not be exceeded.
Solvents and chemicals are to be used only for authorized and intended purposes. All
warning labels and precautions are to be followed. Refer to Material Safety Data Sheet
(MSDS) for specific hazard information. Never use solvents or chemicals to wash the
face, hands, etc. Only soap and water are used for personal hygiene.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmenta.l I
I
I
I
•·
I
I
I
I
·1
I
I
I
I
I
I
I
I
I
I
26
Possession of intoxicants, firearms or other weapons, or illegal drugs at the site is
prohibited.
All operations involving the potential for eye injury, splash, etc. will have an approved
eye wash unit available at or near the work area as per 29 CFR 1910.151 (c).
Operations involving the potential for fire hazards shall be conducted in a manner as to
minimize the risk. Non-sparking tools shall be used where appropriate. Fire extinguis-
hers shall be installed at locations where fire hazards exist. Sources of ignition shall be
removed. When necessary, explosion-proof instruments and/or bonding and grounding
will be used to prevent fire or explosion.
Platforms and walkways of six feet or more elevation will be guarded with hand rails,
mid-rails, and toe boards. Platforms and walkways exposing workers to machinery or
electrical equipment will be additionally guarded. Stairs having four or more risers will
be equipped with railings or hand rails. Applicable OSHA standards for walkways,
stairways, etc., as per OSHA 29 CFR 1926, Subpart M shall apply.
Cold Stress
When the temperature falls below 40 degrees Fahrenheit, stress protocol should be
followed. Employees must have adequate clothing to maintain core temperature. Cold
stress is discussed in detail in Appendix C.
Heat Stress
When the temperature exceeds 70 degrees Fahrenheit and personnel are wearing
impermeable pr~tective clothing, a heat stress monitoring program shall be implemented
as appropriate. Employees shall have access to break periods and drinking water as
necessary. Heat stress is discussed in detail in Appendix C.
CanonieEnvironmental
27
Noise
Requirements set forth in the hearing conservation standard (OSHA 29 CFR 1910.95) will
be adhered to during work on-site. Both area noise monitoring and personal noise
dosimetry will be conducted by the SSO to determine the level of noise and the
adequate level of protection. A Noise Survey Form will be completed (see Appendix A).
Hearing protection will be provided when sound levels exceed 85 dB (a weighted scale,
slow response). Hearing protection will be required where sound levels exceed 90 dB
(a weighted scale, slow response). Signs will be posted in high noise areas notifying
workers of these precautions.
Confined Space
A confined space is a space which by design has limited openings for entry and exit.
unfavorable natural ventilation, which could contain or produce dangerous air contami-
nants, and which is not intended for continuous employee occupancy. Confined spaces
include, but are not limited to storage tanks, process vessels, pits, ventilation and
exhaust ducts, trenches, sewers, underground utility vaults, pipelines, and truck trailers.
Confined space entry shall comply with the procedures set forth in Appendix D.
Ergonomics
In order to reduce workers risk of physical stress injuries, human factor engineering
controls will be implemented. These controls are based on the types of conditions the
workers may be exposed to during the course of work.
1 ' Atmospheric conditions:
o Working conditions will be conducted within the comfort zone and preventive
measures will be implemented regarding heat and cold stress (Appendix C).
I
I
I
-I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmenta.l I
I
I
I
I
I
I
I
I
·1
I
I
I
I
I
I
I
I
••
I
28
o Noise levels will be monitored and hearing protection supplied as required
by OSHA.
o In atmospheric conditions where exposure hazards are detected, appropriate
PPE will be required in specified zonal areas.
2. Workplace conditions:
o The work space will be adequate, permitting satisfactory posture and correct
hand/foot control in relation to equipment, controls, and workbench area.
o Workers will be allowed to sit periodically when the work requires prolonged
standing.
o Foot, arm, hand, and back rests will be available when they are required.
o Equipment vibration will be controlled in relation to duration and individual
characteristics taken into consideration prior to assigning specific tasks and
their requirements.
o Appropriate protection will be required in all tasks where burn risks are
present. .
o Artificial and high illumination lighting will be'used when required. Glare will
be avoided to prevent potential hazards.
CanonieErwironmenta.l
29
3. Human Conditions:
o Muscular load, balance, prolonged sitting, standing, or walking will be
considered in relation to the individual and his/her characteristics performing
a specific task.
o Frequency and duration of muscular effort will be monitored and suitable
equipment will be substituted whenever possible, that is, using mechanical
rather than manual lifting.
o Proper lifting techniques will be employed for back injury prevention,
specifically:
Get close to the load.
Tighten stomach muscles, but do not hold your breath.
-Keep the natural curve of your back.
-Uft with your legs -NOT YOUR BACK.
-Pivot, do not twist.
-Turn with your feet not your back.
o Loads should be carried properly, minimizing view reduction.
o The direction . of physical movement and repetitive movement will be
monitored and tasks rotated whenever possible to prevent injury.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
·1
CanonieEnvironmental I
I
I
I
I
I
I
I
I
••
I
I
I
I
I
I
I
I
I
I
30
o Proper footwear will be worn to prevent slips, trips, and falls.
o Appropriate eye protection will be required during welding operations, dusty
environments, bright sunlight (especially when the ground is snow
covered), and on windy days.
Toxicity Profiles
The contaminants found at the site include volatile organic priority pollutants, metals,
chemical agents, and explosives. Toxicity profiles for each of the indicator chemicals,
with reference to the standards developed from the toxicity data, are presented in this
section. For those compounds without standards, the toxicity data will be reviewed and
a lowest observable effect level (LOEL) or no observable effect level (NOEL) will be
presented, and a suggested safe level developed.
Chlorinated Hydrocarbons
Since most of the chlorinated hydrocarbons are fairly volatile, the major route of
exposure is by inhalation. For this site, an emphasis has been placed on toxicity data
concerning exposure by ingestion and dermal contact.
Trihalomethanes
Historically, chloroform has been used as an anesthetic. The molecule is lipid soluble
so it can pass through the cell membranes to reach the central nervous system (CNS)
readily. Chronic exposures have led to adverse effects on the CNS, liver, kidney, and
heart. Chloroform is a known animal carcinogen causing a dose-related increase in
kidney epithelial tumors in male experimental rats and a dose-related increase of
hepatocellular carcinoma in both sexes of mice, following exposures by ingestion (EPA,
1980a). Experimental data on bromoform is more limited; however, adverse effects on
CanonieEnvironmental
31
_the liver, kidney, and CNS systems have been noted. Bromoform has been found to be
mutagenic in bacteria (Clayton, 1982).
In a survey on drinking water by the EPA (EPA, 1980a), an association was found
between increased bladder cancer levels and higher concentrations of trihalomethanes
in drinking water. The studies were reviewed by the National Academy of Sciences, and
it was concluded that, while the association exists, it does not provide a causal
relationship.
The standard for chloroform and bromoform is combined as total trihalomethanes in
both the Maximum Contaminant Level (MCL) and NC ground water quality standards.
The standards are based on the carcinogenicity of trihalomethanes and technological
and economic feasibility (EPA, 1980a). Chloroform is not appropriately classified as a
Group ·s2 -Probable Human Carcinogen using the classification system proposed by
the Carcinogen Assessment Group (CAG) of the EPA Evidence of the carc_inogenicity
of bromoform is not conclusive.
Dichloroethane
The major route of exposure for 1,2-DCE is by inhalation, although it is also toxic to
humans by ingestion and absorption through skin and mucous membranes. The health
effects from exposure to 1,2-DCE are the same regardless of exposure route (EPA,
1980b). Chronic exposures can lead to neurologic changes, appetite loss, and other
gastrointestinal problems. Injury to the liver, kidney, lungs, and adrenal glands has also
been docum~nted following 1,2-DCE exposure. While there are no epidemiological
studies examining chronic oral exposures, inhalation studies have shown that the above-
mentioned health effects, as well as general increased morbidity occur with average 1,2-
DCE concentrations in the. air of 4 to 50 parts per million (ppm). 1,2-DCE has been
shown to be teratogenic, causing reduced litter size, number of live births, and fetal
weights when female rats were exposed to 57 milligrams (mg)/miter (m)3 of 1,2-DCE in
I
I
I
I
I
I
I
I
I
I .
I
I
I
I
I
I
I
I
CanonieEnvironmenta.l I
I
I
I
I
I
I
I
I
·1
I
I
I
I
I
I
I
I
I
I
32
air, four hours a day prior to breeding and throughout gestation. 1,2-DCE is considered
a probable human carcinogen, based on known carcinogenicity in rats and mice. The
ambient water quality criteria is based on the induction of circulatory system hemangio-
sarcomas in male rats exposed to oral doses by average of 47 mg/kilograms (kg)/day.
Methylene Chloride
There are no available human data for oral chronic exposures to methylene chloride.
A subchronic exposure in drinking water of 125 mg/kg/day in rats defines a NOEL.
Acute dermal exposures can lead to eye and skin irritation with drowsiness, tingling of
limbs, and anorexia resulting from mild poisonings (Clements, 1985). Human
occupational exposures to 30 to 125 ppm of methylene chloride in air has been shown
to cause no adverse health effects (EPA, 1984). Methylene chloride is classified as a
probable human carcinogen, due to its carcinogenicity in rats and mice both in
inhalation and ingestion. Findings from the National Toxicology Program (NTP)
inhalation bioassay showed end points of lung and liver tumors in mice and mammary
and subcutaneous tumors in rats (EPA, 1980a).
Trichloroethylene
Trichloroethylene is another chlorinated hydrocarbon which in acute inhaled exposures
cau·ses CNS depression. In the past it has been used as a general anesthetic. Acute
oral toxicity in several animal species has ranged between 6,000 and 7,000 mg/kg
(Clements, 1985). Chronic human exposures have typically been via inhalation.
Occupational exposures of 5 to 15 years at levels below the threshold limit value (TL V)
have shown evidence of increased nervous system disorders (EPA, 1980). Industrial use
of trichloroethylene has been associated with dermatological problems; no such
problems have been reported with exposures to dilute aqueous solutions. Trichloroethyl-
ene has not been shown to be teratogenic, and the laboratory-grade reagent tested with
positive mutagenic results was contaminated with two compounds known to be
CanonieEnvironmenta.l
33
mutagenic. Using the classification system suggested by the CAG of the EPA,
trichloroethylene is classified as a B2 -Probable Human Carcinogen. Human data is
inadequate, and while there have been some positive and negative animal studies, oral
and inhalation exposure in mice have caused hepatocellular carcinogen (EPA, 1980).
Tetrachloroethene
No human chronic oral data is available for tetrachloroethene. A bioassay conducted
for exposure to tetrachloroethenes in corn oil by gavage resulted in toxic nephropathy
with the lowest observable adverse effect levels (LOAEL) for mice of 300 mg/kg/day and
for rats of 471 mg/kg/day. The same bioassay showed increased hepatocellular
carcinoma in mice exposed to the tetrachloroethene (386 mg/kg/day for female mice,
536 mg/kg/day for male mice). No increased cancer rate was seen in exposed rats.
Tetrachloroethene is considered a possible human carcinogen for mice and negative for
rats, and inadequate evidence in short-term mutagenicity tests. The established
standards are based on the concern for possible carcinogenicity.
Aromatic Hydrocarbons
Benzene and toluene were detected at the Chemtronics Site. In general, aromatics are
primary skin irritants, with repeated or prolonged exposure causing dermatitis.· The
toxicity most often associated with aromatics is CNS depression following acute
inhalation exposures. The acute toxicity of toluene is greater than that of benzene,' with
mild upper respiratory tract irritation observed in humans following exposures to tolueme
air concentrations of 100 ppm. Oral exposure data for humans is not available, but an .
oral dose of 3. 0 ml/kg of toluene proved lethal to 50 percent of the 14-day-old rats
exposed (Clayton, 1982). .Chronic oral exposure to 590 mg/kg/day for 193 days in
female rats produced no physiological changes (Clayton, 1982). Chronic human
exposure by inhalation can lead to liver and kidney damage.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmenta.l I
I
I
I
I
I
I
I
I
·1
I
I
I
I
I
I
I
I
I
I
34
The chronic toxicity of benzene is greater than that of toluene due to its hematotoxic
characteristics. Chronic benzene exposures via inhalation lead to a decrease in one or
· all of the circulating elements of the blood (red blood cells, white blood cells, and/or
platelets). Chronic exposure to benzene has also been associated with leukemia, and
mutagenicity tests have shown benzene exposure to cause persistent chromosomal
abnormalities.
Metals
The two metals included in the list of indicator chemicals are chromium and nickel. The
toxicity of metals is greatly affected by the ionic state or chemical form of the metals.
Hexavalent chromium, for example, is more toxic than trivalent chromium, and certain
nickel compounds appear to be more toxic than others.
There are no available data concerning the toxicity of nickel to humans by ingestion.
There are, however, a number of subchronic and chronic animal studies that examined
oral exposure to nickel. In a 6-week study of weanling rats a NOEL was determined to
be 1 O mg/kg/day of nickel in the form of nickel acetate. At higher doses,· effect_s
observed were decreased body weight and hematological changes including reduced
iron content in red blood cells. There are no availalble data concerning the teratogenicity
or mutagenicity of nickel by ingestion. Inhaled exposure to nickel as nickel carbonyl has
proven to be teratogenic and epidemiological studies have associated airborne nickel
exposures with nasal cavity and lung cancers (EPA, 1984). Contact with nickel and
nickel compounds can lead to dermal sensitization (Clement, 1985).
Most of the toxicity data on chromium (Cr)•• is from occupational studies where
perforated nasal septa and ulcerations in humans at airborne concentrations _of 0.1 to
5.6 micrograms per cubic meter (mg/m31 were noted. Dermatitis has also been
observed. In some cases these health effects were seen after less than one year of
exposure.
CanonieEnvironmenta.l
35
There are no human data available on the chronic toxicity of chromium by ingestion. A
study of dogs exposed to 0. 089 mg/kg/day of er+• through drinking water was identified
as a NOEL. Chronic exposure to 1,467 mg/kg/day of Cr+3 in rats resulted in no effect.
Other chronic studies resulted in health effects including atrophy of the spleen and liver
and atrophy of pulmonary bronchi, producing emphysemic like changes. There is no
indication that cr+3 is carcinogenic to humans, but Cr+• is considered a human
carcinogen based on the evidence of respiratory carcinogenicity in occupationally
exposed persons during chromate production. The water standard is not as low as that
for many carcinogens due to the assumption that er+•_ would be reduced in the
gastrointestinal tract to cr+3, which is less toxic (EPA, 1985).
Chemical Agents
Two chemical agents, CS and BZ, were found on-site. BZ is classified as a surety
chemical, whereas CS is classified as a harassing agent. BZ functions as an
incapacitating agent, the purpose of which is to produce no permanent aftereffects but
to produce significant acute toxicity at low concentrations. The effects of BZ are
disorientation and visual and auditory hallucinations. BZ disturbs the integrative
functions of memory, problem solving, attention, and comprehension (Kirk-Othmer,
1979). Subchronic oral exposures to BZ have resulted in LD"° levels ranging from 50
mg/kg for cats to 808 mg/kg for mice. An oral exposure of 0.5 to 1.0 mg/kg in dogs
resulted in a changed physical performance in tested animals. In humans, an
intravenous LO"° has been estimated at 0.5 to 3.0 mg/kg while to ED"° (dose causing
effects in 50 percent of the test population) was estimated at 0.0057 to 0.0067 mg/kg.
No carcinogenicity or teratogenicity tests have been performed, but mutagenicity tests
produced negative results. In 1963, a drinking water standard for BZ was set by the
United States Army at 0.003 mg/I. A provisional maximum permissible concentration of
0.004 mg/I was promulgated by the United States Army in 1977. In water, hydrolysis
products may be present, but they are less toxic than BZ (United States Army, 1977).
\
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmental I
I
I
I
I
I
I
I
I
·1
I
I
I
I
I
I
I ,.
I
I
36
CS is better known as a type of tear gas. It is an irritant aerosol that has been used in
riot control. The effects of exposure are burning of the skin and eyes with profuse
tearing, coughing, difficulty in breathing, chest tightness. stinging, and dizziness (Kirk-
Othmer, 1979). Effects are expected to subside 5 to 1 0 minutes after removal to fresh
air.
There are standards for safe levels of CS in air, but a review of literature provided no
available standards for water. The acute LO.,, for a variety of small mammals ranges
from 143 to 282 mg/kg. The LOEL for intraperitoneal exposure in rats was 1 0 mg/kg/day
for 1 0 days. At concentrations above the LOEL, cellular changes of the adrenal gland
and thyroid were noted. Most of the human exposures documented were due to inhaled
acute exposures. The TLV for CS is set as 0.05 ppm or 0.4 mg/m3.
Three types of CS, known as CS, CS1, and CS2, were produced at the site. They are
identical chemically, but CS1 has been micronized and treated with a Cabosil, an
antiagglomerant. CS2 was treated with Cabosil, plus a silicone water repellant, designed
to allow the material to remain active for days to weeks when dusted on the ground. All
forms are subject to eventual hydrolysis when released to the environment
CS is lethal to rainbow trout within one week at a concentration of greater than 0.1 mg/I
(Abram. 1978).
Explosives ,
ROX, TNT, and picric acid were all detected in samples from the Chemtronics Site.
Human exposures to ROX tend to be from inhalation of dry particles during manufactur-
ing and packaging with acute and chronic exposures leading to epileptiform seizures
and unconsciousness. Convulsions appear without warning or are preceded by one or
two days of insomnia, restlessness and irritability. Seizures are followed by increased
temperature, amnesia, disorientation, and asthenia. While the primary toxic effects are
CanonieEnvironmental
37
to the CNS, gastrointestinal arid renal effects have also been documented. A study with
rats indicated a NOEL of 0.3 mg/kg/day and LOEL of 1.5 mg/kg/day. Toxic effects in the
rats were anemia, hepatotoxicity, possible CNS effects, cataracts, and urogenital lesions.
There is no evidence of teratogenicity of ROX; one long-term feeding study of mice
exposed to ROX suggests the possibility of carcinogenicity, although a high mortality rate
at the highest concentration and contamination of the tested ROX render the results
inconclusive (Etnier, 1986).
TNT intoxication from both acute and chronic exposures result in hematologic changes
where hemoglobin content and circulating red blood cells are reduced. Exposure can
also lead to leukocy1osis and increased capillary fragility, resulting in nose bleeds and
hemorrhages of the skin and mucosa. Other health effects include hepatitis and yellow
atrophy of the liver, nausea, vomiting, changes in CNS, and dermatitis. TNT exposures
can occur from absorption through the skin, inhalation or ingestion.
Subacute oral toxicity studies have produced NOEL of 1.4 mg/kg/day in rats, 7.46
mg/kg/day in mice, and 0.20 mg/kg/day in dogs. Higher doses resulted in depressed
body weights, anemia, and enlarged spleens and livers. Carcinogenicity and
teratogenicity have not been documented.
Picric acid is no longer being produced for use as an explosive and far less toxicological
data is available. · Dermal exposures to picric acid can cause allergic dermatitis.
Ingestion has led to headaches, dizziness, nausea, and diarrhea. High doses have been
shown to result in damage to the liver and kidney arid destruction of red blood cells
[National Institute of Occupational Safety and Health (NI_OSH), 1978]. A search of the
literature indicates that' no .safe drinking water level for picric acid is available. An
' occupational permissible exposure limit (PEL) based on toxicity to skin is available, and
while deriving a safe level for ingestion of drinking water from this standard is not ideal,
absent any other suitable standard an adjustment of the PEL was made. The level
calculated should provide adequate protection since effects on the skin are noted at
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmenta.l I
I
I
I
I
I
I
I
I
·1
I
I
I
I
I
I
I
. I
I
I
38
lower concentrations than those associated with ingestion [American Conference of
Government and Industrial Hygienists (ACGIH), 1971 ]. In deriving a safe drinking water
level from the PEL the following equations were used:
Oral NOAEL (mg/kg/day) =
TLY{mgm~x10m 3/dsyx0.5x5dsys/7dsys
70kg
The TLV for picric acid is 0.1 mg/m3• Incorporated in the equation to calculate the oral
NOAEL are the assumptions that a worker breaths 1 o m3/day of air, weighs 780 kg,
works five days out of every seven, and that the ratio of inhalation absorption to oral
absorption is 0.5 (Dourson, 1986). Since the standard is based not on inhalation, but
on skin effects, this factor of 0.5 and was not used in calculating the suggested safe. . .
level for picric acid.
Because TLVs are established for a working population, they are not set at levels to
protect sensitive populations. The equation to calculate the suggested safe drinking
water level includes two safety factors of 10, 1 to protect the young and the old, and 1
to protect the chronically ill. This equation also incorporates the assumptions of body '
weight of 70 kg and the ingestion of two liters per day of water.
Ordinance
Although no bombs or artillery shells were produced or tested on this site, a number of
relatively small ordinance devices were produced and test fired here on several ranges .
CanonieEnvironmenta.l
39
Because launched devices have been known to land outside the test ranges, and they
do not always detonate, there is a possibility of encountering unfired devices. It is
anticipated that devices are more likely to be found outside of designated disposal areas
at this time, because the disposal areas themselves have already been well examined.
Well drilling outside of disposal areas is the activity expected to present the highest
chance of encountering ordinance.
The following devices may be encountered:
1. 40-mm tear gas grenades (CS-containing, approximate dimensions 1.5-inches
diameter by three-inches long);
2. Rubber tear gas grenades (CS-containing);
3. 40 mm cartridges bodies (may contain unfired primer and propellant);
4. Baseball sized, grey plastic tear gas grenades (contain CS and explosive charge).
These grenades are especially dangerous because they release plastic shrapnel
upon discharge.
5. 40-mm solid aluminum grenades (with blue paint on head, were used for ballistics
tests.) These devices are harmless, but may be difficult to distinguish from firable
types.
6. Magnesium flares (parachute type). The flares are expected to present little
hazard from an explosive standpoint, but they have guidance fin assemblies
made of thin gauge stainless steel. The fin assemblies may be encountered as
separate units, and they have extremely sharp edges that present a penetration
' hazard if stepped on.
CanonieErwironmenta.l
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I.
I
I
I
i
I
I
I
,I
I
I ·,
I
I
I
I
I'
I
I
I
I
I
40
Procedures for encountering ordinance devices:
1 . Devices are not to be handled by site personnel (with the exception of tail fin
assemblies not attached to flares, which may be carefully removed from the work
area) ..
2. Upon discovery of any ordinance device, John Schultheis of Nimmo & Co. is to
be notified immediately. Work activity in the immediate area of the device shall
cease until Mr. Schultheis (or his alternate) arrives. He will characterize the
device and arrange for its removal from the area.
3. When Mr. Schultheis is not available, Mr. Darrell Campbell or Mr. James Moore
of Jet Research Center (JRC) are to be called (in the order presented).
4. No ordinance device may be removed from the site as a "souvenir" or for any
other reason.
Other Items on Site
1. Plastic jugs:
o Numerous 1.5-gallon white plastic jugs which formerly contained Chlorox
bleach have been discarded on the site. They are harmless and may be
disposed of under the cap.
· 2. Drums: ,
o Areas 9, 1 O, and 11: Drums in these locations are to be crushed and
disposed of under the cap;
CanonieEnvironmenta.l
41
o If drums are encountered in any other location, Mr. Schultheis is to be
notified immediately.
1.1.3.3 Hazard Communication Information
In accordance with the OSHA Hazard Communication Standard (29 CFR 1910.1200) a
copy of the MSDS for all regulated chemical materials used during site operations will
be available in the office trailer or from the SSO. Hazard communication training will be
conducted by the SSO in accordance with 29 CFR 1910.1200. Training will include, but
not be limited to, all hazards or potential hazards associated with possible contact with
hazardous materials.
1.1.3.4 Health and Safety Inspection
Health and safety inspections will.be conducted by the SSO as needed. Inspections will
check the conditions of fire ~xtinguishers, first-aid supplies, electric power, heat and cold
stress conditions, fire hazards, housekeeping, and all other safety provisions stated in
the HASP. Any deficiencies or deviations will be noted by the SSO, reported to the
construction superintendent, and corrected immediately.
1 .1 .4 Training
1.1.4.1 Training Requirements
All personnel entering Exclusion Zones (including subcontractors and visitors) must have
completed training requirements for hazardous waste site work in accordance with OSHA
29 CFR 1910.120. Documentation of training requirements is the responsibility of each
employer. However, written documentation verifying compliance with 29 CFR
1910.120(c)(3), (e)(4) (as applicable) and (e)(B) must be submitted to the SSO prior to
working on-site.
I
I
·I
I
I
I,
I
I .• ,
I
I
I
I
II
I
I
I
I
CanonieEnvironmental I
I
I
I
,I
I
I
I
I
·1
I
I
I ,.
I
I
I
I
I
I
42
All personnel working on-site are required to attend 24 hours of site-specific training
conducted by Sirrine Environmental, Inc. in accordance with 29 CFR 1910.120.
All drillers and personnel involved in excavation (all personnel from excavation
subcontractor) shall receive a minimum of 16 hours of additional site-specific instruction
presented by Canonie. These additional 16 hours of training may be waived for
individuals with up-to-date 40-hour training in accordance with 29 CFR 1910.120. In
addition, a minimum of 3 days actual field experience under the direct supervision of a
trained, experienced supervisor must be completed.
1.1.4.2 Daily Tailgate Meetings
All personnel working on-site, with potential of contact to contaminated material, must
attend the daily tailgate meeting. This meeting will be conducted by the site superinten-
dent and the SSO, and will cover the specific health and safety issues, site activities,
changes in site conditions, and a review of topics covered in the initial health and safety
meeting as they apply to daily activities. Issues addressed in the daily tailgate meeting
will be documented along with the signatures of personnel who attend. A daily Health
and Safety Meeting Form is provided in Appendix A and will kept by the SSO.
1 .1 .5 Personal Protective Equipment
The following is a brief description of the PPE which may be required during various
phases of the project. The EPA terminology for protective equipment will be used via
Levels "0", Level "C", and Level "B".
Respiratory protective equipment shall be NIOSH approved and use shall conform to
OSHA 29 CFR Part 1910.134 requirements. Each employer shall maintain a written
respirator program detailing selection, use, cleaning, maintenance, and storage of
CanonieEnvironmenta.l
43
respiratory protective equipment. Respiratory protection is described in Appendix H of
this HASP.
Appropriate and sufficient personal safety equipment and protective clothing shall be
used in the Exclusion Zones (Areas 9 and 23) as well as other work areas as indicated
by personnel and site visitors. Safety equipment and protective clothing shall be
properly used, kept clean, and well-maintained.
PPE shall conform to 29 CFR 1910.120, 133, 104, 126, and 102.
Personal safety and protective clothing shall be compatabile with and provide protection
against the chemical compounds found in the specific work area.
All openings between protective clothing items will be sealed with duct tape.
New respirator cartridges, disposable protective clothing, and disposable booties will be
utilized at the beginning of each work day. Uncoated Tyvek®, Polycoated Tyvek®, and
SARAN EX® suits will be. replaced if torn significantly. Respirator cartridges will be
replaced daily or if breakthrough occurs, whichever is sooner.
All non-disposable PPE will be cleaned daily using a mild detergent and a warm water
rinse. All equipment will be stored in a designated area.
All PPE will be inspected prior to use and after cleaning each day according to the
manufacturer's suggestions. Damaged equipment will be repaired or replaced.
The SSO will periodically evaluate the effectiveness of each worker's PPE cleanliness.
Any deficiencies will be noted and corrections made.
I
I
I
I,
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmenta.l I
I
I
I
1----.
I .
I
..-
1
I
I
. ,
I
I,
I
I
,1
I
I
I
I
I
44
PPE worn on-site shall be decontaminated or properly disposed of at the end of each
work day. The SSO shall ensure that all PPE is decontaminated before being reissued.
Decisions regarding the upgrading/downgrading of protective clothing will be made by
the SSO in conjunction with the construction superintendent.
A respiratory protection program is defined in Appendix H of this HASP and is in
accordance with OSHA 29 CFR 1910.134 and ANSI Number ZBB.2.2
Contact lenses shall not be permitted in Exclusion Zones. On-site personnel requiring
vision correction shall be provided with prescription lens inserts for use with full-face
respirators .
1.1.5.1 Personal Hygiene
The SSO shall ensure that all on-site personnel required to use PPE shall observe and
adhere to on-site personal hygiene provisions.
Personnel shall wear the specified level of PPE at all times as specified by the SSO.
Regardless of protective equipment, all personnel shall avoid contact with potentially
contaminated substances. Avoid walking through puddles or kneeling on the ground.
Used disposable outerwear shall not be re-used and ~hall be placed inside designated
disposal containers provided for that purpose in the Decontamination area. Disposable
o_uterwear and any other materials placed in containers, together with the containers,
shall be disposed of in a capped area in accordance with the applicable regulations.
CanonieEnvironmenta:l
45
1 . 1 . 5. 2 Level of Protection
Personnel shall wear protective equipment when work or response activities involve
known or suspected airborne contamination, when vapors, gases, or particulates may
be generated by site activities, or when direct contact with ground water may occur.
Modifications of these levels are permitted, and are routinely employed during work
activities to maximize efficiency and ensure adequate levels of protection. Activity
specific levels of protection can be found in Section 1.1.5.3 of this HASP.
PPE is designed to prevent/reduce skin and eye contact, as well as inhalation or ·
ingestion of contaminated material.
PPE will be grouped into the following four categories.
1.1.5.2.1 Level "D" Protective Use
Level "D" protection shall be used under the following conditions:
1. The atmosphere contains no known hazard.
2. Concentrations of airborne organic compounds do not exceed background.
3. Work functions preclupe splashes, immersion or the potential for unexpected
inhalation of, or contact with, hazardous concentrations of harmful chemicals.
1.1.5.2.2 Level "D" Protection Equipment
Level "D" protection equipment shall consist of the following:
1. Standard work uniforms or coveralls; ·
I
I
1·
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmental I
·1
.. !
I
I
I
:1
I
I
I
·1
1.
I
I
I
I
·I
I
I
I
I
46
2. Steel-toe safety boots, that meet or exceed ANSI 241 . 1 ;
3. Gloves as needed;
4. Safety glasses and/or goggles, as needed;
5. Splash shield as needed;
6. Hard hat.
1. 1.5.2.3 Modified Level "0" Use
1. Concentrations of airborne organics in the breathing zone are known.
2. Work functions preclude splashes, immersion in, unexpected inhalation of, or
contact with hazardous concentrations of harmful chemicals, or contaminated
ground water.
1.1.5.2.4 Modified Level "O" Equipment
Modified Level "D" shall consist of the following:
1 . Work overalls;
2. Disposable coveralls, Tyvek® or equivalent;
3. Safety steel-toe boots that meet or exceed ANSI 2741.1;
4. . Chemical-resistant outer boots or disposable boot covers [polyvinyl chloride
(PVC) or rubber];
CanonieEnvironmental
47
5. Disposable, surgical, or cotton inner gloves;
6. Disposable, chemical-resistant gloves (nitrile);
7. Safety glasses and/or goggles, as needed;
8. Splash shield, as needed;
9. Hard hat;
10. Ankles/wrists taped with duct tape, as needed.
1.1.5.2.5 Level "C" Protection
Level "C" protection shall be used under the following conditions:
1 .
2.
3.
Whenever exposure to BZ or CS is expected.
Concentrations of airborne volatile organics in the breathing zone are known.
The substance has adequate warning properties and the criteria fonhe use of
APRs has been met.
1.1.5.2.6 Level "C" Protective Equipment
Level "C" protective equipment shall consist of the following:
1. Chemical-resistant coverall-uncoated poly-Tyvek®, or polylaminated Tyvek®;
2. Steel-toe safety boots;
I
I·.•
I
I
I
I;
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmenta.l I
I
I
I
I
I
I
I
I
·1
I
I
I
I
I
I
I
I
I
I
48
3. Chemical-resistant outer boots or disposable boot covers (PVC or rubber);
4. Disposable, surgical, or cotton inner gloves;
5. Disposable, chemical-resistant gloves (nitrile);
6. Full-face APR with organic/vapor high efficiency particulate air (HEPA) cartridges;
7. Half-mask respirators are not permitted;
8. Hard hat;
9. Ankles/wrists taped with duct tape.
1 .1.5.2. 7 Level "B" Protection Use
Level "B" protection shall be used under the following conditions:
1. Concentrations of chemicals in the air are Immediately Dangerous to Life and
Health (IDLH) or above the maximum use limit of an APR with full-face mask.
2. Oxygen deficient or potentially oxygen deficient atmospheres (less than 19.5
percent) are possible.
3. When required by the confined-space entry procedures.
4. The SSO in conjunction with the construction superintendent requires Level "B".
CanonieEnvironmenta.l
5.
6.
49
HCN present in the worker breathing zone at levels greater than or equal to 2
ppm.
Unexpected changes in air quality anticipated.
1.1.5.2.8 Level "B" Protective Equipment
Level "B" protective equipment shall consist of the following:
1.
2 ..
3.
4.
5.
6.
7.
Chemical-resistant coveralls-uncoated, polylaminated SARANEX® or Tyvek®;
Chemical-resistant boots or disposable boot covers (PVC or rubber);
Disposable, inner, surgical gloves;
Disposable, outer, chemical-resistant gloves (nitrile);
Supplied air pressure demand self-contained breathing apparatus (SCBA) or
airline system with five-minute egress bottle;
Hard hat;
Ankles/wrists taped with duct tape.
Use of Level "B" PPE requires that one person be available as backup ready to provide
emergency assistance.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmental I
I
I
I
I
I
I
I
I
·1
I
I
I
I
I
I
I
I
I
I
50
1. 1.5.3 Activity-Specific Initial Levels of Protection
• 1. Level "C" · Initial work in Areas 9 and 23 up to but probably not including
placement of common fill;
2: Level "C" • Removal of the HOPE liner in Area 23;
3. Level "C" • Drilling;
4. Level "B". Drilling if HCN is present at levels greater than or equal to 2 ppm.;
5. Level "D" • General construction in nori-contaminated areas.
Levels of protection may be upgraded or downgraded at any time during site activities
to reflect actual conditions encountered and actual task sequences. Only the Regional
Health and Safety Coordinator (RHSC) or the SSO can downgrade a level of protection.
1. 1.6 Air Monitoring Plan
Air monitoring shall be performed in accordance with OSHA 29 CFR 1910.120(h) where
there is likely to be worker exposure to hazardous concentrations of hazardous
substances and in order to assure the proper selection of engineering controls, work
practices, and PPE, including respiratory protection, so that workers are not exposed to
levels which exceed the PELs, TLVs, or other applicable guidance values for that
t:iazardous substance.
CanonieEnvironmental
51
1. 1.6.1 Purpose and Objectives
' The purpose of this Air Monitoring Plan is to record levels of airborne contaminants at ·
the Chemtronics Site with accuracy, precision, reliability, completeness, and comparabili-
ty. This will allow the achievement of the following objectives:
1. Evaluate the chemical hazards posed to workers and assure adequate PPE and
respiratory protection.
2. Evaluate the chemical hazards posed to workers outside the Exclusion Zone but
within the geographical perimeters of the site.
3. Evaluate and possibly modify operations to assure the safety of workers.
Air monitoring refers to the use of real-time instruments to determine worker exposure.
1. 1.6.2 Responsibilities
All aspects of the Air Monitoring Plan will be implemented by trained, experienced, and
competent field personnel: A member of Canonie's health, safety, and hygiene staff will
be assigned to the Chemtronics Site as the SSO. The SSO is assigned to the project
on a full-time basis with functional responsibilities for implementing and enforcing the
HASP. The SSO's specific responsibilities shall include:
1 . Evaluating health risk potential for each construction activity;
2. Performing daily air monitoring;
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmenta.l I
I
I
I
I
I
I
I
I
·1
I
I
I
I
I
I
I
I
I
I
52
3. Ensuring all on-site personnel observe and adhere to the required PPE,
respiratory protection, and personal hygiene provisions as detailed in Section
1.1.5 of this HASP;
4. Evaluating on-site air quality results related to established action level protocols
to upgrade or downgrade PPE and respiratory protection;
5. Conducting periodic site.inspections to ensure compliance with the HASP;
7. Record keeping.
1.1.6.3 Air Monitoring Requirements
1.1.6.3.1 Equipment
Air monitoring instruments which may be used are as follows:
1. Flame ionization detector (FID), such as an organic vapor analyzer (OVA);
2. PIO, such as an Hnu (10.2 Ev minimum);
3. Dust monitor, such as MiniRAM real-time aerosol monitor;
4. Colorimetric detector tubes;
5. Combustible gas indicator;
6. HCN monitors.
CanonieEnvironmenta.l
53
1.1.6.3.2 Calibration
All air monitoring equipment will be calibrated before each use and maintained in
accordance with the manufacturer's specifications.
A calibration log book will be kept on-site and calibration methods recorded in it. A
copy of a Calibration Log Sheet can be found in Appendix A.
1.1.6.3.3 Routine Air Monitoring Requirements
Routine air monitoring requirements are as follows:
1. When work in contaminated areas encounters ground water directly;
2. During all initial capping activities in Areas 9 and 23;
3. When contaminants other than those previously identified are being handled;
4. When workers are handling leaking containers or working in areas with obvious
liquid contamination;
5. During confined space work;
6. Whenever the SSO deems it necessary.
1.1.6.4 General Procedures and Action Levels
This Air Monitoring Plan has been designed to characterize and/or quantify airborne
levels of contaminants in order to evaluate the hazards posed to workers. Instruments
shall be calibrated, used, and maintained in accordance with the manufacturer's
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmenta.l I
I
I
I
I
I
I
I
I
••
I
I
I
I
I
I
I
I
I
I
54
specifications. The calibration procedures and results will be recorded in a logbook
daily (see Appendix A). The operations manuals for each instrument will be available
during construction activities. Air monitoring shall be conducted:
1. To document background levels of voes and total dust;
2. To document ambient voe and dust levels in each active work area.
To document baseline conditions, work area background voe and dust air monitoring
shall be conducted in Areas 9 and 23 prior to conducting any activities. Background
voe and dust concentrations should also be documented daily during remedial activities
by monitoring an area not impacted by site operations, such as the support zone.
Background voe and dust monitoring data may be subtracted from data collected
during remedial activities to document the impact of site operations.
Action levels have been established for voes, HeN, and total dust.
The action level for voes, is based on the compound detected on-site with the lowest
PEL, which is benzene, with a PEL of 1 ppm. An action level of 2 ppm is proposed for
the following reasons:
1 . Benzene is not anticipated to be encountered by itself (it is expected to be one
of several organic compounds occurring together).
2. Practical limitations of direct reading instruments for the monitoring of low level
concentrations (i.e., zero drift due to temperature and humidity fluctuations).
Level "e" PPE is required whenever a voe measurement of 2.0 ppm or greater
is measured via a PIO or FID in the worker breathing zone, sustained for five
continuous minutes.
CanonieEnvironmental
The maximum use concentration for Level "e" PPE with voes is 50 ppm.
shall be used for voe concentrations exceeding 50 ppm.
55
Level "B" PPE •
The action level for total dust is set at 1.0 mg/m3. sustained for five minutes, as
measured via a MiniRAM or equivalent device. Level "e" PPE shall be required at
concentrations exceeding this value, if adequate control cannot be achieved by dust
controls/work practices.
The HeN action level is based on the PEL .of 4. 7 ppm. Due to the limitations of air-
monitoring equipment, Level "B" PPE is required at concentrations greater than or equal
to 2 ppm, sustained for one minute.
The maximum use concentration for Level "B" PPE with HeN is 50 ppm.
1.1.6.5 Initial Determination for Lead
Because lead has been detected as a site contaminant, air sampling pursuant to the_
requirements of 29 eFR 1910.1025 shall be performed. An initial determination shall be
conducted during intrusive activities at each Exclusion Zone where lead has been
identified as a contaminant.
The determination shall consist of the collection of full shift, breathing zone personnel
samples from a representative number of workers. Samples shall be collected on 37mm
mixed cellulose ester filter (MCEF) cassettes connected to portable sampling pumps
qperated at two to four liters per minute.
Samples will be analyzed via atomic adsorption, in accordance with NIOSH Methods by
an analytical laboratory accredited in metals analysis by the American Industrial Hygiene
Association.
CanonieEnvironmenta.l
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I I
I
I
I
I
I
I
I
I
·1
I
I
I
I
I
I
I
I
I
I
56
If lead-in-air concentrations exceed the OSHA action level of 30 mg/m3, all applicable
portions of 29 CFR 1910.1025 shall be implemented and additional sampling shall be
performed.
1 .1 . 7 Medical Surveillance Program
The medical surveillance program shall be instituted by the employer for the following
employees:
1. All employees who are or may be exposed to hazardous substances or health
hazards at or above the PELs or if there is no PEL above the published exposure
levels for these substances, without regard to the use of respirators, for 30 days
or more a year.
2. All employees who wear a respirator for 30 days or more a year or as required
by OSHA 29 CFR 19190.134.
3. All employees who are injured, becof1le ill, or develop signs or symptoms due
to possible overexposure involving hazardous substances or health hazards from
an emergency response or hazardous waste operations.
.4. The medical surveillance program shall comply with 29 CFR 1910.120(f)
Documentation of medical monitoring is the responsibility of each employer and
must be submitted to the SSO upon arriving on-site.
5. The medical surveillance p,rogram should include the following:
o Medical History Questionnaire;
o Occupational History Questionnaire;
CanonieEnvironmenta.l
57
o Medical evaluation by physician:
Vital statistics;
Physical examination;
-Visual acuity;
-Audiometry;
-Electrocardiogram;
-'Pulmonary function test;
Fecal occult blood (hemoccult).
o Blood and urine screens:
-Blood chemistry profile;
-Complete blood count (CBC) with differential;
-Urinalysis with microscopic;
Heavy metal screen Arsenic (As), Cadmium (Cd), and Mercury (Hg);
Blood lead (Pb) and zinc (Zn) protoporphyrin.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmenta.l I
I
I
I
I
I
I
I
I
••
I
I
I
I
I
I
I
I
I
I
58
o Mandatory Tests:
-Tetanus shot (every seven years);
-Chest x-ray (two views) (mandatory for baseline and exit physical);
o Optional Tests:
-Flexible sigmoidoscopy;
-Mammography;
Pesticide screen;
polychlorinated biphenyls (PCB) screen.
1 . 1 . 8 Site Control
Because only .some work tasks will encounter contaminated material, work zones must
be established for each task. Training and medial surveillance requirements for workers
and visitors will be based upon the work zones to be entered.
1.1.8.1 Work Zones
Work zones will be established and delineated .prior to initiating any work activity. The
primary purpose of work zones is to establish the hazardous area perimeter, to reduce
migration of contaminants into clean areas, and to prevent access or exposure to
hazardous materials by unauthorized persons. At the end of each workday, the site will
be secured to prevent unauthorized entry. The SSO will be responsible for determination.
of the work zones. Due to the nature of the work tasks on this site, work zones will
CanonieEnvironmenta.l
59
change frequently. Each area will be marked with barrier tape and barricades and signs
will be posted to indicate work zones. Site work zones will include the following
sections.
Clean Zone/Support Zone
The uncontaminated support zone or clean zone will be all. areas not marked as
Exclusion or decontamination zones and within the geographic perimeters of the site.
This area is used for staging of equipment and clean materials, office facilities, sanitation
facilities, and receipt of deliveries. Personnel entering the clean/support zone may
include delivery personnel, visitors, security guards, etc. who will not necessarily be
permitted in the Exclusion Zone. All personnel arriving in the support zone will, upon
arrival, sign the site Entry/Exit Log, as shown in Appendix A. There will be one
controlled/entry/exit point from the clean zones to the decontamination zones (if work
necessitates the establishment of more than one Exclusion and decontamination zone).
Decontamination Zone
The decontamination zone will provide a location for removal of contaminated personal
protective equipment and final decontamination of personnel and equipment. All
personmil and equipment that have entered into any portion of the Exclusion Zone must
exit via the decontamination area. Each work area established as an Exclusion Zone will
have its own decontamination zone.
Exclusion Zone/Hot Zone
The Exclusion Zone will be the "hot zone" or contaminated area marked off with
barricades and yellow tape where contaminated ground water is encountered. Entry to
and exit from this zone will be made through the decontamination zone, and all
personnel will be required to sign the Exclusion Zone Entry/Exit Log located at the decon
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I.
CanonieEnvironmenta.l I
I
I
I
I
I
I
I
I
••
I
I
I
I
I
I
I
I
I
I
60
area as shown in Appendix A. Exit from the Exclusion Zone must be accompanied by
personnel and equipment decon as described in Section 1.1.11. Note: All zones will
be clearly separated to ensure that no one enters a zone unknowingly. Separate work
areas may exist within the Exclusion Zone.
The "buddy system" will be in effect during all Exclusion Zone activities.
1.1.8.2 Visitors
Casual visitors (i.e., persons not on-site to periorm tasks related to the execution of the
project) shall be kept to a minimum. Their presence shall be scheduled with the PRP
coordinator (Mr. John Schulteis) prior to arrival on-site. Casual visitors shall be escorted
by the construction superintendent, SSO, or their designee at all times when outside the
support zone. Casual visitors shall be confined to clean roads around the site. They
shall not be permitted access to decontamination or Exclusion Zones.
Visitors seeking to enter decontamination or Exclusion Zones shall meet the following
requirements:
1 . Currently participate in a medical surveillance program in accordance with 29
CFR 1910.120;
2. Have completed 24 hours of Hazardous Waste Operations and Em'ergency
' Response training in accordance with 29 CFR 1910.120;
3. Have been briefed in the contents of this HASP by the SSO.
CanonieEnvironmenta.l
61
The SSO will determine the extent of each work area within the Exclusion Zone on-site
using professional judgement based _on work activity, proximity of work tasks, wind
direction, and air monitoring results.
1. 1.9 Organization Structure
The purpose of this section is to establish the specific chain-of-command and overall
responsibilities of all managers, supervisors, and site employees.
1. 1.9.1 Roles and Responsibilities
Regional Construction Manager -Mr. James Semple is ultimately responsible for all
phases of operations at th~ site. Th~ construction superintendent reports directly to the
regional construction manager. The construction manager deals directly with Sirrine
Environmental concerning this project.
Construction Superintendent -Mr. Nels Pelletier, the on-site construction superintendent,
is responsible for all on-site activities. The construction superintendent reports to the
regional construction manager; all on-site personnel and subcontractors report to the
construction superintendent.
SSO -Mr. William Goodrich, is responsible for implementation of this plan, oversight of
air monitoring programs on-site, and preparation of any written amendments to this plan.
The SSO has the authority to shut down site operations if unsafe conditions are present.
The SSO reports administratively to the construction superintendent and technically to
the RHSC.
Project Engineer -Mr. John O'Toole, the project engineer, is responsible for on-site
activities including sampling, quality assurance, and all on-site engineering activities.
CanonieEnvironmental
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I ·,
I
I
I
I
I
I
I
I
I
I
62
The project engineer may also function as the alternate SSO and reports to the on-site
construction superintendent.
RHSC -Mr. Clayton Bock, the off-site RHSC, is responsible for the development and
oversight of the HASP for this project. Any significant changes in .site operations require
a written amendment prepared by the SSO and authorized either verbally or in writing
by the RHSC. A copy of this form can be found in Appendix A. Significant changes in
site conditions must be reported to the RHSC.
Certified Industrial Hygienist {CIH) -Mr. Donald Abramowitz, CIH, will provide on-site
health and safety oversight during the first day of remedial activities in Areas 9 and 23.
In addition, Mr: Abramowitz will be on-site once initially to inspect site facilities and
ensure this HASP is being implemented in the field. (Mr. Abramowitz shall also serve
in the capacity of RHSC).
General Site Employees and Subcontractors -General site employees and subcontrac-
tors are responsible for conducting themselves in a safe manner and are required to
report all observations of unsafe conditions to the construction superintendent or the
SSO immediately.
As on-site operations develop, field conditions may change and may raise questions
regarding proper health and safety procedures. To ensure that the best technical health
and safety information is provided, all health and safety issues are to be presented to
the SSO and discussed between the SSO and the construction superintendent. If a
solution is not identified, the operation in question must be discontinued and the RHSC
must be consulted immediately.
CanonieEnvironmental
63
1 .1 .1 o Emergency Response/Spill Control Plan
It is essential that site personnel be prepared in the event of an emergency. Emergen-
cies can take many forms: illness or injuries, chemical exposure, fires, explosions, spills,
leaks, release of harmful contaminants, or sudden change in the weather. The following
sections outline the general procedures for emergencies. Emergency information should
be posted as appropriate.
Emergency services must be contacted prior to job startup to inform them of on-site
activities.
1 . 1. 10. 1 Emergency Contacts
Site Location: Jet Research Center, Inc., 180 Old Bee Tree Road, Swannanoa, North
Carolina.
The appropriate emergency contacts are as follows:
1. Fire: 911;
2. Police: 911;
3. Ambulance: 911;
4. Hospital: Memorial Mission Hospital, 509 Biltmore Avenue, Asheville, North
Carolina, [phone] emergency care;
5. Chemical Trauma: Memorial Mission Hospital (see above);
6. Poison Control Center: 1-800-542-4225 or 255-4490;
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmental I
I
I
I
I
I
I
I
I
••
I
I
I
I
I
I
I
I
I
I
64
Directions from site to hospital are included in Appendix G.
1.1.10.1.1 Additional Emergency Numbers
The following are additional emergency telephone numbers:
1. Canonie Regional Construction Manager: Mr. James Semple, [phone]:
2. Canonie Construction Superintendent: Mr. Nels Pelletier, [phone];
3. Canonie Project Engineer: Mr. John O'Toole, [phone];
4. Canonie SSO: Mr. William Goodrich, [phone];
5. Canonie Corporate Office: [phone];
6. Canonie Corporate Health and Safety Manager: Ms. Tamara Renkoski (219) ·
926-8651;
7. EPA Project Contact Coordinator: Mr. Jon Bornholm [phone];
8. National Response Center for Oil and Toxic Chemical Spills: [phone];
9. PAP Coordinator: Mr. John Schultheis, [phone]; -
10. Canonie Regional Health and Safety Coordinator: Mr. Donald Abramowitz, (215)
337-2551 (work), [phone] (home)/ClaY1on Bock [phone] (work),
[phone] (home);
11. JRC Engineering Manager -Mr. Darrell Campbell [phone] ;
CanonieEnvironmental
65
12. Sirrine Environmental Engineer -Mr. James Cloonan, [phone];
13. Sirrine Industrial Hygiene/Hazardous Materials Specialist -Ms. Betty Schnee,
'•
[phone];
14. Community Relations Coordinator -Mr. Donald Higgins [phone].
(Local telephone numbers (site trailers) will be provided as soon as available.]
1.1.10.1.2 Emergency Equipment Available On-Site
Emergency equipment available on-site and location at which it can be found is as
follows:
1. Fire Extinguisher: decontamination area, new building construction;
2. Emergency Shower: decontamination area;
3. Emergency Eye Wash: decontamination area, new building construction;
4. First-Aid Kit: decontamination area, new building construction.
1.1.10.2 Project Personnel Responsibilities During Emergencies
Prior to the start of site activities, the construction superintendent and the SSO will
review the emergency procedures of this plan and ensure that all necessary emergency
equipment is ready for use. The SSO will train all personnel on emergency procedures.
This training will be conducted with employee records. When appropriate, the SSO shall
modify or make additions to the emergency procedures to enhance the effectiveness of
the procedures.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmental I
I
I
I
I
I
I
I
I
·1
I
I
I
I
I
11
I
I
I
I
66
and construction superintendent will address the containment and storage of hazardous
materials, particularly liquids and take measures to prevent leaks, spills, or accidents.
Hazardous materials shall be properly stored and protocol, including, but not limited to,
protection from sun, heat, flames, water, and weather; isolation from personnel,
segregation by hazard classifications; protection from vehicles, equipment, or traffic;
,posting of appropriate warning signs; and providing secondary containment as may be
necessary.
The SSO will ensure that all personnel working on or visiting the site are briefed on
emergency procedures, including alarms or other warning devices and evacuation
routes. On-site personnel will also be briefed on their roles in emergencies such as fire
fighting, spill cleanup, and first aid.
In case of emergency, the construction superintendent will implement the site emergency
procedures. The construction superintendent will work in conjunction with the SSO. The
construction superintendent is specifically responsible for the following:
1. Implementing the Site Conting,ency Plan, including ordering site evacuation,
directing fire fighting efforts, spill control, and cleanup.
2. Contacting local emergency services such as the fire department, ambulance
services, and federal, state, or local emergency or environmental agencies. The
construction superintendent will coordinate with the local emergency services.
In the event of an airborne release of toxic materials, local authorities must be
informed immediately to assess the need for evacuation of the public in the
vicinity of the site. In the event of a spill where runoff may enter sanitary
systems or drinking water supplies, local water and sanitation districts may need
to be alerted.
3. Determining the cause of the incident and its prevention in the future.
CanonieEnvironmenta.l
67
' 4. Filing all necessary reports with federal, state, and local authorities, and a
complete written report to the contractor.
It should be noted that the contractor will not order or conduct evacuations of the
general public. The contractor will make recommendations to the local emergency
authority and assist in any way. However, the decision to call an evacuation will be
made by the agency iri charge.
The SSO will work closely with the construction superintendent in the event of an
emergency and will provide advice and support as necessary. The SSO will be
responsible for the following:
1 . Evaluating the emergency conditions and making recommendations regarding
risks to off-site personnel and the public, the necessity of upgrading PPE to
protect on-site personnel and emergency responders, and recommending
evacuation of on-site personnel.
2. Supervising evacuation and deconta,mination procedures.
3. Providing fist-aid services and medical support or evacuation for injured or
exposed personnel.
4. Preparing a written incident report for submission to the contractor's health and
safety department.
Employees on-site are responsible for reporting emergency situations or conditions
immediately to their supervisors, alerting other employees, helping injured personnel,
and assisting as directed in the mitigation of the incident.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmenta.l I
I
I
I ,-
1
I
I
I
·1
I
I
I
I
I
I
I
I
I
I
68
1. 1. 10.3 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 person's
condition is serious, al least partial decontamination should be completed (i.e, complete
disrobing of the victim and redressing in clean coveralls or wrapping in a blanket). First
aid should be administered while awaiting an ambulanc_e or paramedic. All injuries and
illnesses must be reported immediately to the SSO.
Any person transporting an injured/exposed person to a clinic or hospital for treatment,
should take with them directions to the hospital and information on the chemical(s) they
may have been exposed to. This information is included in Appendix F.
Any vehicle used to transport contaminated personnel will be cleaned or decontaminated
as necessary.
Personnel should be transported by the emergency medical service (EMS) in an
emergency situation if possible and practical.
1. 1. 10.4 Fire or Explosion
In the event of a fire or explosion, the actions listed below should be followed in a
general chronological sequence. Conditions and common sense may dictate changes
in the sequence of actions and the addition, elimination, or modification of specific steps.
CanonieEnvironmental
69
1 .1. 10.4.1 Immediate Action
Upon detecting a fire/explosion, employees will determine whether a fire is small enough
to readily extinguish with immediately available portable extinguishers, or other available
fire fighting methods.
Non-essential personnel will be directed away from the area of the fire.
If it is judged that a fire is small enough to attack with available extinguishing media,
employees will proceed to attempt to extinguish the fire provided that
1. They are able to approach the fire from the upwind side, or opposite to the
direction of the fire's progress.
2. The correct extinguisher is readily available (Type ABC fire extinguishers will be
provided in all work areas and on all vehicles.) Subcontractors must supply the
necessary fire extinguishers for their work activities.
3. No known complicating factors are present such as likelihood of rapid spread,
imminent risk of explosion, or gross contamination.
Personnel leaving a fire/explosion area will account for all employees in that work area
as soon as possible. The foreman or designee will perform a head count for that work
area.
1.1.10.4.2 Notification
The construction superintendent and SSO will be1 notified as soon as possible of the
location, size, and nature of the fire/explosion.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
'·I
I
I
I
CanonieEnvironmental I
I
1·
I
I
I·
I
I·
I
"I
I
I
I
I
I
I
I
I
I
I
70
As conditions dictate, the construction superintendent and/or SSO will declare an
emergency, initiate the remedial procedures, request outside assistance, and perform
the necessary on-site and off-site notifications.
If outside assistance is required, the construction superintendent and/or SSO will appoint
an employee to meet the responders at the appropriate gate and direct them to the
fire/explosion area.
1.1.10.4.3 Rescue
If employee(s) are unable to evacuate themselves from a fire/explosion area for any
reason, their rescue will be the first priority of responders. The construction superinten-·
dent and/or SSO will determine whether on-site resources are sufficient to proceed or
if rescue must be delayed until _the arrival of outside assistance.
1.1.10.4.4 Fire Fighting Procedures
Planned fire fighting procedures are described below. These procedures apply to both
preconstruction and construction work.
Fire During Working Hours
If a fire occurs during working hours, the following measures should be taken to
extinguish the fire. These measures are sequential, that i_s, if the first measure does not
successfully contain the fire, the next measure will be initiated.
Support Zone Fire
1. Utilize fire extinguishers.
CanonieEnvironmental
"
71
2. Confirm that request for assistance from the local fire company has been made.
I
3. Utilize earth moving equipment, as appropriate. Brush fires will be extinguished
with water.
Fire During Non-Working Hours
In the event of a fire during non-working hours, the site security guard will notify the
project superintendent. Additional actions will be consistent with procedures established
for a fire during working hours.
Response Coordination
Upon arrival of outside responders, the construction superintendent and/or SSO will
coordinate with the leader of the outside responders to direct fire fighting activities.
1.1.10.4.5 Protection of Personnel
The primary methods of protecting personnel from fire conditions will be by distance and
by remaining upwind.
On the basis of conditions, the SSO will determine appropriate distances and the
selection of PPE. For approach in close proximity to fire areas, Level "B" or greater
protective equipment suitable for fire fighting will be worn. Level "B" equipment will
minimally entail supplied air respirators and fire fighting turn-out gear.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmental I
I
I
I
I
I
I
I
I ·,
I
I
I
I
I
I
I
I
I
I
72
1.1.10.4.6 Decontamination
At the conclusion of fire fighting activities, the construction superintendent and/or SSO
will:
1. Determine to the extent practicable the nature of the contaminants encountered
during the incident.
2. Arrange for all outside responders' fire response equipment• and on-site
equipment as necessary, to be processed through the site decontamination
zone, using methods appropriate for the contaminants involved.
3. Equipment not easily decontaminated shall be labelled and isolated .for further
action, such as determining specific contaminants by wipe sampling or awaiting
the delivery of specific decontamination media and supplies.
1.1.10.4. 7 Fire Extinguisher Information
The four classes of fire along with their constituents are:
1. Class A: Wood, cloth, paper, rubber, many plastics, and ordinary combustible
materials; .
2. Class B: Flammable liquids, gases, and greases;
3. Class C: Energized electrical equipment;
4. Class D: Combustible metals such as magnesium, titanium, sodium, and
potassium;
CanonieErwironmenta.l
73
Examples of proper extinguishing agents are as follows:
1. Class A: Water, water with 1 percent AFFF Foam (wet water), water with 5
percent AFFF or Fluroprotein foam, ABC Dry Chemical, and Halon 1211;
2. Class B: ABC Dry Chemical, Purple K, Halon 1211, Carbon Dioxide, and water
with 6 percent AFFF Foam;
3. Class C: ABC Dry Chemical, Halon 1211, and Carbon Dioxide;
4. Class D: Metal-X Dry Chemical.
No attempt should be made to fight large fires. Large fires should be handled by the
local Fire Department.
The complete area of the fire should be determined. If human life appears to be in
danger, or the spread of the fire appears to be rapidly progressing, a decision should
be made to move personnel further upwind away from the fire:
1.1.10.5 Spill Control Plan
The actions listed below are in a general chronological sequence. Conditions and
common sense may dictate changes in the sequence of actions and the addition,
elimination, or modification of specific steps.
1.1.10.5.1 Isolation
Upon observing a spill (or leakage or discharge of the contents of a container) of any
size, employees will immediately proceed to a safe distance upwind and direct other
personnel away from the spill.
I
I
I
I
I
I
I
I
I
I
I
I
I
1.
I
I
I
I
CanonieEnvironmental I
I
I
I
I
I
I
••
I
·,
I
I
I
•• .I
I
••
I
I
I
74
1. Until determined otherwise, any unidentified spilled material will be assumed to
be hazardous.
2. See Containment -Preventing Spread of Material (Section 1 1.10.5.5) below.
Sources of ignition within 500 feet will be extinguished immediately or deenergized
(including vehicle engines).
Employees who have had contact with the spilled materials will report immediately to the
decontamination area and undergo decontamination consistent with the extent and
nature of the contact
1.1.10.5.2 Notification
The construction superintendent and SSO will be notified a soon as possible of the
location, size, and nature of the spill.
As conditions dictate, the construction superintendent or SSO will declare an emergency,
initiate remediation procedures, request outside assistance, perform the necessary on-
and off-site notifications, and initiate a response .
If outside assistance is required, the construction superintendent or SSO will appoint an
employee to meet responders at the appropriate gate, advise them of any special
precautions/procedures in effect, and direct them to the location of on-site response
supplies and the spill area. The escort shall direct responders' vehicles over clean fill
roads to the extent possible in order to minimize contamination .
CanonieEnvironmental
75
1.1.10.5.3 Rescue
If employees are unable to evacuate themselves from a spill area tor any reason, their
rescue will be first priority of responders.
Responders will wear the appropriate PPE to perform rescues, as directed by the SSO.
1.1.10.5.4 Assessment/Characterization
Once employees have left a spill area, initial reentry to the area will be performed in the
appropriate level of protection, as directed by the SSO.
Identification
1. An attempt will be made to identify spilled material to the extent possible through
container markings, physical properties of the material, and other available
evidence.
2. When doubt exists as to the identity of a material, it will be_ presumed to be
hazardous until proven otherwise.
3. Actions will be carried out as though all of the following hazard categories apply
unless. evidence indicates otherwise: flammable, water reactive, oxidizing,
corrosive, and acutely toxic by skin contact or inhalation (material will be
presumed to volatilize significantly unless proven otherwise).
4. At the discretion of the construction superintendent or SSO, samples of the
spilled material will be collected for field testing and subsequent laboratory
analysis. Field tests may include tests for pH, response by various instruments
in the headspace of the sample container (detector tubes, organic vapor meter,
I
I
I
I
I
I
I
I
I
I
I
I
I,
I
I
·1
I
I
CanonieEnvironmental I
I
I
I
ll
I
I ,,
.I
••
I
I
I·
I
,1
I
I,
I
I
I
76
combustible gas meter, etc.), and tests for combustibility and reactivity. Note:
Standard procedures for the safe collection and testing of field samples will be
developed separately.
5. Available references will be consulted for 9uidance and toxicity information as
the spill material is identified.
Demarcation of Hazardous Spill Areas
1. The area of the spill will be determined and documented, noting area of soil
contamination .
2. The quantity of the material spilled will be estimated, and the basis for the
estimate will be noted, i.e., remainder in container, direct observation of the spill
. in progress, etc.
3. The· area will be marked with stakes and barrier tape or other means as
appropriate.
Air Monitoring
1. If identification reveals that the material may be detected by a direct reading
instrument, the SSO will arrange for air monitoring around the breathing zone of
the responders, as well as upwind and downwind of the spill response. Results
will ~e used to determine additional protective actions.
CanonieEnvironmental
77
1.1.10.5.5 Containment
Prevent Spread of Material
1. Upright or rotate containers to stop flow of liquids. (DEPENDING ON THE
CIRCUMSTANCES, this ·step may be accomplished as soon as the spill or leak
is observed, providing it can be done without personal contact with the material.)
2. Use surrounding soil, booms, loose sorbent, sorbent pads, etc., as appropriate
to dike or berm around material subject to flow. Choose response materials with
minimum potential for incompatibility.
Suppress Vapors
1 . Vapor suppressing foams may be applied if it has been verified that the spill
material is not water reactive.
2. Sorbent pads with impervious backing may be laid over the spills, PROVIDED
the potential for incompatibility is addressed.
Solidify Liquids
Apply loose sorbents, pads,or pillows to solidify spilled liquids. Clay and inorganic
sorbent should be used on materials not fully identified. Sorbents made from organic
materials (grain husks, etc.) and neutralizers should NOT be applied to m~terials not fully
identified.
I
I
I
:1
I
I .,
I.
I
I
1·
I
:I
I
I
:1
I
I
CanonieEnvironmenta.l I
I
I'
I
I
I
t
I
I
·1
I
I
I
I
I
I
I
I
I
I
78
1. 1. 10.5.6 Cleanup of Hazardous Materials
Place damaged containers in overpack drums of compatible construction and containing
suitable loose sorbents. Empty overpack drums will be maintained on-site.
Collect saturated sorbents, soil, spill-control pads, etc. in compatible drums using non-
sparking equipment as appropriate.
Collect contaminated tools and equipment for subsequent decontamination or disposal.
1.1.10.5. 7 Disposal
The correct route of disposal will be a function of the identity of the spilled material.
Unidentified overpacked material will be stored in a stable, inactive area with secondary
containment located at the on-site facilities area, pending identification of the material.
Restoration
Final cleanup of the spill area, which may include post cleanup environmental sampling,
will be a function of:
1. The identity and quantity of the spilled material;
2. The physical location of the spill;
3. The requirements imposed by regulatory agencies.
CanonieEnvironmental
79
1.1.10.5.8 Air Releases
Air monitoring will be conducted at the discretion of the SSO depending on the type of
spill.
The frequency, duration and type of air monitoring will be determined by the SSO.
1. 1. 10. 6 Evacuation Routes and Resources
Evacuation routes have been established by work area locations for this site. Most
· buildings and outside work areas have been provided with two designated exit points.
Evacuation should be conducted immediately, without regard for equipment under
conditions of extreme emergency.
1 . Evacuation notification will be a continuous blast on an air horn or vehicle horn
or by verbal communication via radio.
2. Keep upwind of smoke, vapors, or spill location, if possible.
3. Exit through the decontamination corridor, if possible.
4. If evacuation is not via the decontamination corridor, site personnel should
remove contaminated clothing once they are in a location of safety and leave it
near the exclusion zone or in a safe place.
5. The SSO will conduct a head count to insure all personnel have been evacuated
safely.
I
I
I
·1
I
I
I
I
I
' I
I
I
I
I
I
I
I
CanonieEnvironmental I
I
I
1·
I
I
I
I
I
·1
I
I
I
I
I
I
I
I
I
I
80
6. In the event that emergency site evacuation is necessary, all personnel are to:
o Escape the emergency situation;
o Decontaminate to the maximum extent practical;
o Meet at the office trailer.
1 . 1 . 11 Decontamination
1 .1 . 11.1 Procedures for General Equipment Decontamination
Equipment used in the Exclusion Zone will be protected from contaminatior:, as much as
possible by enclosure in plastic bags or by preventing contact with contaminated
materials either directly or by transfer through handling with contaminated gloves.
Decontamination of the equipment will be determined by the nature of the equipment .
and contamination.
1.1. 11.2 Procedures for Heaw Equipment and Vehicle Decontamination
Heavy equipment and vehicles leaving the area of Exclusion Zone will be decontaminat-
ed at that area, where the work is performed, before continuing on to the next location.
All heavy equipment, non-disposable equipment, and supplies will be pressure washed
prior to relocating. An inspection will be conducted by the SSO to verify that the
equipment has been properly decontaminated. This will be documented in a certificate
of vehicle decontamination provided in Appendix A. Employees engaged in vehicle
decontamination will wear the same level of protection as required during that specific
work activity. However, polycoated Tyvek® will always be required to ensure adequate
protection.
CanonieEnvironmental
81
1. 1. 11.3 Procedures for Decontamination of Personnel
1. 1. 11.3.1 General Decontamination Procedures
Any respirators used will be inspected and washed in soapy water, if necessary. All
respirators used will be disinfected with sanitary wipes everyday. Use of disposable
protective clothing eliminates the need for extensive evaluation of clothing to determine
the effectiveness of decontamination procedures.
The sequence of decontamination is designed to prevent/minimize direct contact with
waste materials.
All decontamination wash water will be non-phosphate ~cap and water. Decontamina-
tion solution will be changed daily (at a minimum) and collected and stored on-site until
disposal arrangements are finalized.
1. 1. 11.3.2 Emergency Decontamination
Emergency decontamination of site personnel may be necessary for medical reasons
or in the event of a major amount of contamination by contact with contaminated
material.
.Emergency procedures are as follows:
1.
2.
Assistance will be provided by on-site personnel for removal of contaminated
protective clothing so as to minimize the chances of causing direct skin contact
with contaminated material.
If the employee is injured and cannot be moved, attempts will be made to cut
the clothing for removal.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmenta.l I
I
I
I
I
I
I
I
I
·1
I
I
I
I
I
I
I
I
I
I
82
3. If the situation is life threatening, decontamination or removal of protective
clothing will be considered secondary to medical treatment. If appropriate, to
minimize spread of contaminants, contaminated personnel will be wrapped in
blankets and/or plastic sheeting (maintaining an open airway) during transport
to the emergency facility. Emergency personnel will be notified of the nature of
the contaminated material and instructed on the importance of preventing skin
contact.
4. If the employee can walk or be moved without injury, all affected skin areas
should be cleaned.
5. Disposal equipment will be placed in appropriate collection containers.
6. Non-disposable equipment will be placed and cleansed in the area provided for
washdown of non-disposable equipment by assisting on-site personnel.
1.1.11.3.3 Decontamination Procedures
Due to the nature of work, portable decontamination stations may be utilized and will
consist of the following:
1. Equipment drop;
2. Outerboot wash and rinse;
3. Garbage can(s)/bag(s) for disposable PPE;
4. Respirator wipes;
5. Respirator cartridges;
CanonieEnvironmental
83
6. Emergency eye-wash bottle;
7. First-aid kit;
8. Waterless hand cleaners.
It is imperative that proper decontamination procedures are followed to prevent bodily
contact with contaminated materials. This will be closely monitored by the SSO and will
consist of the following:
1. Drop off any equipment at equipment drop and clean_ as necessary.
2. Wash boots in wash tub with brusli.
3. Rinse boots in second tub.
4. Remove tape from ankles; take off boots.
5. Remove tape from wrists; discard outer gloves.
6. Roll down Tyvek®, discard in garbage can/bag.
7: Remove booties, discard.
. 8. Remove gloves, discard.
9. Respirator removal.
1 O. Hand and face wash and rinse.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmental I
I
I
I
I
I
I
I
I
·1
I
I
I
I
I
I
I
I
I
I
84
1.1.11.4 Contamination Control
This section outlines the measures that will be taken to control contamination from
leaving the exclusion areas.
The de<:ontamination procedures described previously will be the primary sources of
contamination control. Also, as indicated in the previous sections, waste water
generated from these decontamination procedures will be collected on-site, stored, and
disposed of when arrangements are finalized.
Eating, drinking, smoking, chewing, and application of cosmetics shall be restricted to
the clean zones, except drinking of replacement fluids which will be permitted at the
reduction zone areas. Personnel shall, at a minimum, remove outer and inner gloves,
respirator and cover top, and clean hands prior to drinking replacement fluids.
Personnel leaving for lunch or leaving the site should wash hands/face thoroughly with
soap and water.
Personnel who may be required to wear respiratory protective equipment, either on a
routine or emergency basis, must remove beards or other facial hair which interferes with
the proper fitting of respirators.
CanonieEnvironmenta.l
I
I
I
I
I
I
I
I
·1 APPENDIX A
I FORMS
I
I
I
I
I
I
I
I
g CanonteEnvironmental
. Canonie Environmental Services
SITE: PROJECT.#:
SITE SAFETY PLAN ACKNOWLEDGEMENT FORM
I have been informed , understand, and will abide by the procedures set forth in the Health
and Safety Plan and Amendments for the Chemtronics Site
A-1 I
CanonieEnvironmenta.l ti
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Canonie Environmental Services A-2
SITE:. ______ .,.._ __ _
DATE:;._ ____________________ _
Initial site-specific training shall consist o_f:
Safe working procedures/enginee;inQ con'trols.
Air monitoring procedures, action levels, PPE and levels of protection.
Hazard communication training.
Lockout/Tag-out Procedures.
_ .
• Emergency procedures and location of_ emergency equipment, and evacuation routes.
Respiratory maintenance and respirator fit testing.
Decontamination procedures .
.....•. __ ._. __ --_ ... _ < \ .• ,~.h~~.+f±s~eti;ft~fALfkA~ci's);:iii¥{+fu(."i~i~h:>
1<\·_ i·, _ 1-•-•----_-_-___ __:N~A=Mc::E _____ +-____ S:::lc::G::..N::..A:..:T..::U::..Rc::E ____ +•-•·-·,·_• ---___ .::cC.::cO.:.:M:..:.P.:..A::..N:..:Y ___ --l
I ,-
1
... '
-_ .\ >------------1------------4--------------i
l<y.-.-.~----------+-------'------+------------1 I<
I
,. ,.,::·1------------------1---------------+---------------l'
'
SITE SAFETY OFFICER
CanonieEnvironmental
Canonie Environmental Services
SITE: .,...-.,.,...--,---,-----,----.,...----,------PROJECT#:
.
DATE:
PRINTED NAME REPRESENTING
SITE SIGN-IN SHEET
TIME
IN SIGNATURE
---------------
TIME
OUT SIGNATURE
jJi:.1---------t----------t---------t-----+----l-----li/.
·.·· {i;••··.· .. •1----------+-~-------1-------;----------+------·f-----------l;../
••• i ·.··•H•---------+------;------t--------t-----+--------1 .. ;. ·•· :\lrl-------+--------i------------i------i
:r<il-------------+------+--------;f------t--------l
. {;il--------l-------,----+------+-------+------+-------i
ffi::01------+-----+--+----+---t-------J
! ' ··;.
CanonieEnvironr11ental !
I!!!!!!!! -.. 11!!1!!!!1 --· -.. -.. ------.. --
I
I
I
I
I
I
I
I
·1
I
I
I
I
I
I
I
I
I
I
A---4
Canonie Environmental Services
SITE: PROJECT#: >
--=-=-=-=-=-=-=-=-=-=-=-=-=-=-=--:,_ __ _____: _ ___;__-=============:: DATE:
NAME
EXCLUSION ZONE SIGN-IN SHEET·
COMPANY
PAGE II:
TIME
IN
-----
TIME
OUT
CanonieEnvironmental
Canonie Environmental Services
SITE:····· ·····• PROJECT#:· ---------------------
DATE: TOPIC: ----------
DAILY HEALTH AND SAFETY MEETING
NAME SIGNATURE COMPANY
., SITE SAFETY OFFICER
I
CanonieEnvironmental E
I
I
I
I'
I
I
I
I
·1
I
I
I
I
I
I
I
I
I
I
Canonie Environmental Services
NOISE SURVEY
DATE:
NOISE DOSIMETER #:
SAMPLE.INFORMATION /., .. , ....... · ..
!CHECK ONE):
PERSONNEL SAMPLE: EQUIPMENT SAMPLE: -,-----------
EMPLOYEE NAME:
EQUIPMENT NUMBER:
ACTIVITY:
% DOSE: 'PROJECTED %: ----___________ L-OSHA:
TOTAL TIME RAN: SEL:
LMAX:
LMIN:
LPEAK:
PEAK EXCDS:
OVERLOADS:
RMS EXCDS:
L 10:
L33:
L50:
L90:
SAMPLED BY
CanonieEnvironmental
Canonie Environmental Services
+
RESPIRATOR FIT TEST CERTIFICATE
EMPLOYEE NAME: DATE:
EMPLOYEE SIGNATURE:
The employee identified above has been given a qualitative fit test in -----accordance with ANSI Standard ZSS.2-1980 using:
isoamyl acetate stannic chloride ----------(banana oil) (irritating smoke)
The employee identified above has been given a quantitative fit test in -----accordance with the test equipment manufacturer's recommendations.
He/she has achieved a satisfactory fit on the following brand(s), style(s), and size(s) of
respiratory protective equipment:
STYLE SIZE* FIT FACTOR+ MANUFACTURER
FF MSA
HF
FF NORTH
HF
FF
HF
FF OTHER
HF
FF OTHER
HF
If applicable
Quantitative only
UNABLE TO ACHIEVE SATISFACTORY FIT WITH THE FOLLOWING BRANDS:
SIGNATURE OF TESTER:
TITLE:
A-7 I
I
I
I
CanonieEnvironmental I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
A-8
Canonie Environmental Services
:.·,: .. , .. , ,: .... ,•_ ... .................. :-;"": :·.:·:,,.:'.(:c: .. . ... :·:t;_:,:-:·;,:.::-':'~--:·. .,.,.,A"•,••,•···'.:·:-·· :: ·< ,.· sire:·· ?:).:\::)/Ji'/. (pft(jJECT'll:••t·tr••>···
SCBA\SBA MONTHLY INSPECTION REPORT
I\ <oATE:i{
,•,,_':"" .-',.,.'."-'.: .. ""'' .·.:.,_.:,,:., .. ' ,:,.•,•·· t?f:\ ··> ,_,:;:::,:-:· :>t> .• i\ •. -:·.;:: .,_, ,:::;::<:,:::::=;:vJ:i\<:-r<:e:: .. _._ .. ,,.,.,,, ... =.,:.c:..;-,_:_:;:·:
Each SCBA or SBA egress/airline unit must be inspected at least once per month
and prior to usage. Any unit not meeting ALL of the criteria listed below must be
tagged "not in service" until corrective measures are taken and the unit is fully ready
for use: CHECK IF OK, use N/A for "not applicable".
'• •·••. i ..... . ,•:.: .. ''·'
ITEM UNIT II: V
CASE/STORAGE AREA ; :t . Clean. sanitary ,dry • ••• ...
• Hasps, etc. in good repair i
GENERAL ••••• • Unit clean, ready to use '• . . Unit accessible '. FACEPIECE } I·.:
• Clean and sanitized . Free of cracks, tears, holes or Ii: ... ,
distortion from improper storage . Rubber parts pliable ,,. •::· ·,• • Facepiece lens clear, free of cracks
and scratches, properly sealed •'
• Valves, gaskets, o-rings in good repair, I·
not missing i, • Connections tight and secure
HEAD STRAPS AND HARNESSES
• Elastic and pliable ,,.
• Buckles in good repair
• Clean
Free of defects ••
REGULA TORS/GAUGES . Clean . Diaphragm in good working order
• Low air alarm in good working order Lil
• Connections secure, free of defects bi! •,•,•
• Hoses free of defects/leaks Fil
• Pressure gauges operating properly •• .
BREATHING AIR SUPPLY
• Cylinders free of rust/ defects, ,.
• inspection date not past due
• Cylinder at least 90% of recommended
pressure it ):,. • Meets ·o· Specifications ' . . Connections clean.in good repair .. , . · ... ,::,, :--· ···•-,·, .. ·,: ,., ·_,,·,,·,'"•,•-::-· . ·• ..... ., .. •·•·· ....• ·••.·
Repairs/Maintenance required (indicate unit Ill:
INSPECTORS SIGNATURE:
CanonieEnvironmental
.
Canon,e Environmental Services I
~s-1T_e_:--============-P_R_o_J_ECT.:__#:-==========---l I
AIR MONITORING SHEET
DATE:
ACTIVITIES:
TSP MONITOR/TYPE: NUMBER:
OTHER:
~~-~,.,.w,..,.,,.,._~!.! --~-<.«v-~,,,_,_,.,_.._..,,_~, '. .,.._._._.,_ .,..._,,d,...,, .. .__...,.,_,,..
RAIN IY/NI: TEMP.: RELATIVE HUMIDITY:
WINO DIR.: OTHER:
.'! · ... .. : MONITORING RESULTS
FIO OR. PPE
TIME PIO OTHER LOCATION/COMMENTS LEVEL
.. ": .. -,-:-22···· ··•·•····•·•·····••··~······ .... , .. ··•··• ..... ·. . :,f· } /· .:•.·•· .. :.··· :·.: . ·.·. >:):,.:, .. .. ...,, ,,.,_ -· ,.:.;-_ '::,-: -.,,. :_t':'::.':' .. _. .
·_··> •····•·· 1 ' .• .. f .... . ..... .· .. ··•••.••.··••······· .-:-:-: ··./.,.;.:, M ··•· I itlll-' •·· ·•·.•·
SIGNATURE
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmental E
I
I
I
I
I
I
I
I
·1
I
I
I
I
I
I
I
I
I
I
A-10
Canonie Environmental Services
SAMPLE DATE: __________ SAMPLE#:
PUMP NUMBER: __________ TYPE:
SAMPLE LOCATION:
SAMPLE START TIME:
SAMPLE END TIME:
TOTAL TIME (MIN.):
CALIBRATION RATE:
TOTAL VOLUME:
COMMENTS:
SAMPLED BY:
ANALYSIS INFORMATION
SUBMITTED TO:
SUBMITTED ON:
VERBAL RESULTS RECEIVED:
RESULTS: --------------------------------
FAX RES UL TS RECEIVED:
WRITTEN RESULTS RECEIVED:
INVOICE RECEIVED: ID #: -------------------------
INVOICE AMOUNT:
SUBMITTED FOR PAYMENT:
CanonieEnvironmental
Canonie Environmental Services PAGE:
A-1,
I
CALIBRATION LOG
DATE EQUIPMENT CALIBRATION .
SAMPLE
NUMBER
SAMPLE
TYPE INTIALS I
l------+--------1----------+---------1-------1---~ g
j
j
1---+-----+-----1--------+--I----I
l---------+-----1---------+-----1-----1----j I
.
1----4--~--+----------_,_j I
1------i-----1---------1----+----+---j
L_____;_____j__ __ ...____---1--_4--------1---~
L------i----~1--------1---4--------1---j
1---------+------1--------1-----1-----l----~•
L-------1.....-----L---------'--------'----,____~
CanonieEnvironmenta.l I
I
I
I
I
I
I
I
I
••
I
I
I
I
I
I
I
I
I
I
Canonie Environmental Services
CERTIFICATE OF VEHICLE DECONTAMINATION
DATE OF DECONTAMINATION:
TIME OF DECONTAMINATION:
TYPE OF DECONTAMINATION:
This certifies that the vehicle described below was decontaminated prior to leaving
the Exclusion Zone:
VEHICLE TYPE :
VEHICLE IDENTIFICATION #:
VEHICLE OPERATOR:
COMMENTS,<··
Signature of Vehicle Operator
Signature of Authorized Representative
Verifying Decontamination
A-12
CanonieEnvironmenta.l
I
I
I
I
I
I
I
I
·1
I
I
I
i
I
I
I
I
I
I
APPENDIX B
LOCKOUT/TAGOUT PROCEDURES
. CanonieEnvironmenta.l ·
APPENDIX B
LOCKOUT /TAGOUT PROCEDURES
Purpose
The purpose of this procedure is to provide guidance to subcontractors, employees, and
contractors for the isolation of hazardous energy during the servicing of machinery or
equipment.
General
Isolation of hazardous energy can be. achieved by various means, but the preferred
method is to have machinery or equipment completely disconnected from the energy .
source. Examples include, but are not limited to, unplugging equipment, disconnecting
power or battery cables, removing fuses or opening circuit breakers, opening disconnect
switches, lowering weights or disconnecting springs to achieve a mechanical energy state
of zero, placing stop blocks, blind flanging; disconnecting or using double block and
bleed pressure systems.
To ensure that energy is isolated and remains so during servicing, it is important that
machinery or equipment is locked out to make reconnection impossible and tagged out
to notify other employees or personnel not to attempt to operate or reconnect the
equipment to the power source. The person authorized to perform service on the
machinery or equipment must have control of the lockout and/or tagout devices and must
be the only person permitted to place or to remove them. Compliance with
lockout/tagout procedures is mandatory.
Step for Shutting Down, Isolating. Blocking, and Servicing Machinery or Equipment
1. As soon as a piece of equipment or machinery is determined to be in need of
servicing or repair, it shall be reported to the supervisor in charge of the
CanonieEnvironmental
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
E I
I
I
I
I
I
I
I
I
'I
I
I
I
I
I
I
I
I
I
I
B-2
equipment, who will in turn arrange for servicing, repair or replacement. The .
unit will be removed from service and all affected personnel will be notified.
Normal shutdown procedures for the equipment will be followed.
2. Whenever practical, the equipment or machine will be physically removed from
the work area and tagged "OUT OF SERVICE". The unit should be isolated in
an area where it will not be mistakenly used or operated. It may be necessary
to lockout or lockup the equipment, especially when it cannot be removed from
the work area. When applicable, equipment may need to be thoroughly
decontaminated before removal and/or servicing.
3. Equipment, such as backhoes, front-end loaders, forklifts, etc., will have the
boom, bucket, forks, etc. lowered to the ground or .to a position where
gravitational force is in equilibrium with the forces borne by stable supports.
If t!'le boom, bucket, or forks cannot be lowered, they will be securely blocked.
Ignition keys will be removed and given to the supervisor in charge. Battery
cables sh.ould be disconnected to prevent accidental or unauthorized operation
while waiting for repair.
4. Moving parts which are not locked in position by isolation of the energy source
must be blocked or secured in a safe position. This applies to moving parts
which could cause injury and does not apply to doors, hoods, or engine
covers. Wooded timbers, chains, and tie-down straps may be useful.
Steps for the Placement, Removal. and Transfer of Lockout and Tagout Devices
1. Only the authorized person(s) who will service, maintain, or repair the
machinery ~r equipment is authorized to place lockout devices and tags on the
units, its power source, and/or operating controls. He/She is also the only
person authorized to remove the locks or tags, except as discussed in Item 6.
CanonieEnvironmental
2.
3.
4.
5.
• B-3
Tags will be placed at one or more of the following locations:
o Operating controls;
o Power disconnect point (e.g., fuse or breaker box, electrical plugs,
valves, main switch, etc.);
o Remote auxiliary controls (e.g., bypass switch pr controls, computer
terminals or controllers, ancillary startup motors, or equipment controls.)
Lockout devices, such as lockout hasps and locks, plug covers.and key blocks,
shall be placed at one or more of the following locations as may be feasible (a
warning tag will accompany every lockout device):
o Operational controls;
o Power disconnect points;
o Power source or generating point;
o Remote auxiliary controls.
Lockout devices and tags must be secured so that they cannot be removed
easily without deliberate and even extreme efforts. Lockout devices shall be
made of materials that are durable and strong. Tags will be secured with wire
or a nylon cable tie and must be attached so that they will not be removed
inadvertently, be lost, or fall off.
Lockout devices and tags will only be removed by the authorized person and
only when the authorized person has verified that all tools, equipment, and
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I ,
I,
m
n
CanonieEnvironmental g ,
I
I
I
I
I
I
I
I
·1
I
I
I
I
I
I
I
I
I
I
B-4
personnel are clear of the machinery, that all parts of the machine are securely
attached (including guards and safety features), and that the machine is ready
for return to service or final operational tests.
6. If the repair or servicing equipment requires more than one shift of work or
goes beyond the end of a normal shift, the authorized person will leave all
lockout devices and tags in-place until the servicing or maintenance is
complete. If another authorized person will be relieving or replacing the first
authorized person or will be finishing the service or maintenance, the original
authorized person will remove his/her lockout device and tags only of the
second authorized person has comparable lockout devices and tags. If not,
the original devices and tags will remain in-place. The responsibility and
authority to remove lockout devices and tags may be transferred from one
authorized person to another provided the second person is fully briefed on all
lockout and tag location, as well as this procedure.
7. Upon completion of the work, the authorized person or responsible supervisor
will inform affected employees that the machine or equipment is released for
use.
Testing and Verification of Energy Control Measures
1. Before servicing any equipment or machinery, the authorized person will review
operations or repair manuals, schematic diagrams, circuits, prints, or other
relevant information to locate all energy disconnect or isolate points, operation
controls, and ancillary power sources. This may also require investigation of
remote control devices, computerized controls, and equipment adjacent to, but
part of, the machinery or equipment to be serviced (e.g., starter motors,
conveyors, etc.).
CanonieEnvironmental
B-5
2. All electrical circuits must be tested with a volt-ohm-ampere multimeter.
3. After lockouts and tags are in-place, all normal and remote start-up control
must be tried. Gauges and other indicators should indicate a zero or safe
condition, depending upon the equipment. Movable parts which have been
blocked must remain immovable after power has been disconnected or
isolated.
4. Work will not proceed until all tests indicate energy sources are isolated or have
been effectively disconnected.
Lockout Devices and Tags
1. Lockout devices and tags provided by the contractor are to be used only for
the purpose of isolating energy or preventing the use of machinery or
equipment.
2. Tags shall be standardized with the following size and message. Tags will be
nominally three inches by five inches and made of plastic or durable paper.
The tags will say "DANGER -DO NOT OPERATE" on one side and "DANGER -
DO NOT REMOVE THIS TAG" on the other side. Space shall be provided to
identify the person who placed the tag and the reason it was placed. Tags will
be affixed with wire or nylon cable ties.
CanonieEnvironmental
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
'1
I
I
I
I
I
I
I
I
·1
·1
I
I
I
I
I
I
I
•
I
APPENDIX C
HEAT STRESS/C ::, STRESS .
CanonieEnvironmental
..
APPENDIX C
. HEAT STRESS/COLD STRESS
Heat Stress
The heat stress of employees on-site will be monitmed by direct observation of
employees arid by environmental measurements such as the Wet Bulb Globe
Temperature Index (WBGT). This method will require the use of a heat stress monitoring
device, such as the Wibget Heat Stress Monitor (Reuter Stokes) or globe, dry, and wet
bulb thermometers.
The WGBT shall be compared to the Threshold Limit Value (TLV) outlined in the American
Conference of Government Industrial Hygenist (ACGIH) TLV booklet and a work-rest
regimen will be established, as necessary, according to the WBGT obtained. In general,
five degrees must be subtracted from the listed TLV for heat stress to compensate for the
wearing of impermeable protective clothing. Other published environmental or
physiological indices, such as the Heat Stress Index of Effective Temperatures, may be
used by the site safety officer (SSO) in establishing tolerance limits and work\rest
regimens.
A combination of the following control measures shall be used to help control heat stress:
1. Provision of adequate liquids to replace lost body fluids. Employees must
replace water and salt lost from sweating. Employees must be encouraged to
drink more than the amount required to satisfy thirst. Thirst satisfaction is not
an accurate indicator of adequate salt and fluid replacement.
2. Replacement fluids can be a 0.1 percent salt water solution, commercial mixes
such as Gatorade/or Quick Kick, or a combination of these with fresh water.
Employees should be encouraged to drink more than they feel they need to.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmental 6
I
I
I
I
I
I
I
I
·1
I
I
I
I
I
I
I
I
I
I
C-2
3. Establishment of a work. regimen that will provide adequate rest periods for
cooling down. This may require additional shifts of workers.
4. Cooling devices such vortex tubes or cooling vests can be worn beneath
protective garments.
5. All breaks are to be taken in a cool or shaded rest area (77 degrees Fahrenheit
is best).
6. Employees shall remove impermeable protective garments during rest periods.
7. Employees shall not be assigned other tasks during rest periods.
8. All employees shall be informed of the importance of adequate rest,
acclimation, and proper diet in the prevention of heat stress.
During periods of high temperature and/or humidity, the SSO or his/her representative
will continually observe the workers for symptoms of heat stress especially in areas where
protective clothing is being ~orn. If the body's physiological processes to maintain a
normal body temperature fail, or are overburdened due to excessive heat exposure, a
number of physical reactions can occur ranging from mild symptoms such as fatigue,
irritability, anxiety, decreases in concentration and movement to death. Heat-related
problems are presented below:
1. Heat Rash -This caused by continual exposure to heat and humid air, and
aggravated by chafing clothes. Heat rash decreases a person·~ ability to
tolerate heat as well as becoming an irritating nuisance.
CanonieEnvironmental
C-3
2. Heat Cramps -This is caused by profuse perspiration with inadequate water
intake and chemical electrolyte imbalance. This results in muscle spasm and
pain in the extremities and abdomen.
3. Heat Exhaustion -Increased stress on various organs to meet increasing
designs and symptoms including shallow breathing; pale, cool, moist skin;
profuse sweating; dizziness and lassitude.
4. Heat Stroke -This is the most severe form of heat stress which must be treated
immediately by cooling the body or death may result, Signs and symptoms
include red, hot, dry skin; no perspiration; nausea; dizziness and confusion,
strong, rapid pulse, and coma.
Cold Stress
Persons working outdoors in temperatures at or below freezing may be frostbitten.
Extreme cold for a short time may cause severe injury to the surface of the body, or result
in profound generalized cooling, causing death. Areas of the body which have high
surface-area-to-volume ratio such as fingers, toes, and ears, are the most susceptible.
Two factors influence the development of a cold injury; ambient temperature and the
velocity of the wind. Wind chill is used to describe the chilling effect of moving air in
combination with low temperature. For instance, 10 degrees Fahrenheit with a wind of
15 miles per hour (mph) is equivalent in chilling effect to still air at minus 18 degrees
Fahrenheit.
As a general rule, the greatest incremental increase in wind chill occurs when a wind of
5 mph increases to 10 mph. Additionally, water conducts heat 240 times faster than air.
Thus, the body cools suddenly when chemical-protective equipment is removed if the
clothing underneath is· perspiration soaked.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmental I
I
I
I
I
I
I
I
I
·1
I
I
I
I
I
I
I
I
I
I
C-4
Local injury resulting from cold is included in the generic term frostbite. There are several
degrees of damage. Frostbite of the extremities can be categorized into:
1. Frost Nip or Initial Frostbite: characterized by suddenly blanching or whitening
of skin.
2. Superficial Frostbite: skin has a waxy or white appearance and is firm to the
touch, but tissue beneath is resilient.
3. Deep Frostbite: tissues are cold, pale, and solid; extremely serious injury.
Systemic hypothermia is caused by exposure to freezing or rapidly dropping temperature.
Its symptoms are usually exhibited in five stages:
1. Shivering;
2. Apathy, listlessness, sleepiness, and (sometimes rapid cooling of the body to
less than 95 degrees Fahrenheit;
3. Unconsciousness, glassy state, slow pulse, and slow respiratory rate;
4. Freezing of the extremities;
5. Death.
Thermal socks, long cotton or thermal underwear, hard hat liners and other cold weather
gear can aid in the prevention of hypothermia.
Blankets, warm drinks (other than caffeinated coffee) and warm break areas are essential.
CanonieEnvironmental
C-5
Measurements shall be taken to keep workers from getting wet, such as issuance of rain
gear. Workers whose cloths become wet shall be given the opportunity to dry off and
change clothes.
Cold stress training shall be addressed during the site specific training, as outlined in
Section 2.6.3.3.8 of this HASP.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmenta.11
I
I
I
I
I
I
I
I
·1
1.
I
I
I
I
I
I
I
I
I
APPENDIX D
CONFINED-SPACE ENTRY
CanonieEnvironmenta.l
APPENDIX D
CONFINED SPACE ENTRY PROCEDURES
Confined Space
A confined space is a space which by design has limited openings for entry and exit,
unfavorable natural ventilation which could contain or produce dangerous air
contaminants, and which is not intended for continuous employee occupancy. Confined
spaces include, are not limited to, storage tanks, process vessels, pits, ventilation and
exhaust ducts, trenches, sewers, underground utility vaults, pipelines, and truck trailers.
Entry Permission
Entry into a confined space shall be by permit only. The permit is a written authorization
and approval that specifies the location and type of work to be done. The permit also
certifies that all potential hazards have been evaluated by both health and safety and the
construction superintendent or foreman, and that all necessary protective measures have
been taken to insure the safety of each worker.
The site safety officer (SSO) shall be responsible for securing the permit and shall sign
off when the following areas and actions have been reviewed and confirmed.
1. Location and description of the work to be done;
2. Hazards expected;
3. Complete isolation checklist;
o Blanking and/or disconnecting;
o Electrical lockout;
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmental I
I
I
I
I
I
I
I
I
·1
I
I
I
I
I
I
I
I
I
I
I
4.
5.
0-2
o Mechanical lockout.
Special clothing and equipment;
o Personal protective equipment and clothing (as determined by the
qualified person);
o Safety harness and/or lines;
o Spark-proof tools and equipment;
o Approved electrical equipment.
Atmospheric Test Readings;
o Instrument identification suitable check of operator (daily or before each
use) and date of last calibration {should be within the past 30 days);
o Direct-reading instrument readings will be incorporated into the confined
space entry permit;
o Oxygen level;
o Percent of Lower Explosive Limit {LEL);
o Toxic gas level.
CanonieEnvironmental
D-3
6. Names of workers assigned;
o Personnel in confined space;
o Standby personnel outside of confirmed space.
7. Signatures (two required);
o Supervisor;
0 sso.
This permit shall be dated and carry an expiration time that will limit the permit to only one
shift. The permit shall be updated for each shift with the same requirements.
Confined space training for pertinent personnel will be conducted by the SSO prior to
initiation of any confined space entry. Training records will be maintained in the site files . .
Standby and Rescue Personnel
For each confined space entry there shall be a trained standby person assigned to that
confined space. Each standby person shall have adequate rescue equipment. Additional
duties of the standby person are to maintain communication with all workers within the
confined space and to summon rescue personnel if necessary. Under no circumstances
will the standby person enter the confined space until he is relieved and is assured by the
SSO that adequate assistance is present.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmental I
I
I
I
I
I
I
I
I
·1
I
I
I
I
I
I
I
I
I
I
0-4
Work Practices
Purging and Ventilating
Environmental control within a confined space is accomplished by purging and ventilating.
Constant monitoring of the atmosphere will determine what precautions· are necessary.
Exhaust systems should be designed to protect workers in the surrounding area from
contaminated air. Care should also be taken to avoid recirculation of contaminated air
and interaction of airborne contaminants.
Continuous general ventilation shall be maintained where toxic atmospheres are produced
as part of a work procedure, such as welding or painting, or where a toxic atmosphere
may develop due to the nature cif the confined space, as in the case of desorption from
walls, or evaporation of residual chemicals.
Local exhaust ventilation shall be provided when general ventilation is not effective due
to restrictions in the confined space or when high concentrations of contaminants occur
in the breathing zone of the worker. Local high concentrations of contaminants may
occur during work activities such as welding, painting, and chemical cleaning. Therefore,
respiratory protection may be needed in addition to the engineering controls. The use
' of respiratory protection will be determined by the SSO.
Isolation /Lockout/Tagging
The isolation procedures shall be specific for each type of confined space. Safety
equipment required during this procedure shall be designated by the SSO and be
dependent upon the potential hazards involved. The confined space shall be completely
isolated from all other system by physical disconnection, double block and bleed, or
blanking off all lines.
CanonieEnvironmental
0-5
Shutoff valves serving the confined space, shall be locked in the closed position and.
tagged for identification. In addition to blanking, pumps and compressors serving these
lines entering the confirmed space shall be locked out to prevent accidental activation.
Electrical isolation of the confined space to prevent accidental activation of moving parts
that would be hazardous to the worker is achieved by locking circuit breakers and/or
disconnects in the open .(off) position which a key-type padlock. The only key is to
remain with the person working inside the confined space. If more than one person is
inside the confined space, each person shall place his own lock on the circuit breaker.
In addition to the lockout system, there must be an accompanying tag that identifies the
operation and prohibits use.
Mechanical isolation of moving parts can be achieved by disconnecting linkages, or
removing drive belts or chains. Equipment with moving mechanical parts shall also be
blocked in such a manner that there can be no accidental rotation.
Procedures and Policies
Procedures and processes used to clean the inside of a confined space shall be reviewed
and authorized by the SSO. The method to be prescribed shall be dependent upon the
product in the space. Initial cleaning shall be done from outside the tank if at all possible.
Special procedures should be adopted to handle the hazards created by the cleaning
process itself.
Equipment and Tools
Equipment and tools to be used in a confined space should be carefully inspected and
should meet the following requirements:
1. Spark proof hand tools shall be kept clean and in good repair;
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmenta.l I
I
I
I
I
I
I
I
I
·1
I
I
I
I
I
I
I
I
I
I
D--6
2. If allowable, portable electric tools, equipment, and lighting (explosion proof
required) shall be equipped with a ground fault circuit interrupter;
3. All electrical cords, tools, and equipment should be of heavy duty type with
heavy duty insulation and inspected for visually detectable defects before use
in a confined space;
4. Air driven power tools should be used when flammable liquids are present.
The use of air driven power tools will reduce the risk of explosion, not eliminate
it. Explosions can arise by tools overheating (drilling), sparks produced by
striking (percussion), grinding or discharge of accumulated electrostatic
charges developed from the flow of compressed air;
5. Cylinders of compressed gases should never be taken into a confined space,
and shall be turned off at the cylinder valve when not in use. Exempt from this
rule are cylinders that are part of self-contained breathing apparatus or
resuscitation equipment;
6. Ladders should be adequately secured, or of a permanent type.
Training
Personnel who are required to work in a confined space should receive training in the
following areas:
1. Emergency entry and exit procedures;
2. Use of personal protective equipment;
3. Isolation/Lockout procedures;
CanonieEnvironmenta.l
D-7
· 4. Potential hazards;
5. Work practices and permits.
Personnel designated as a "qualified person" should receive the above mentioned training
along with the following additional training.
1. Hazard recognition and control;
2. Atmosphere testing instrumentation;
3. Space clearing and ventilation;
4. Procedures and responsibilities.
Training should be provided to all new employees and then annually thereafter to all
employees required to work in a confined space.
Testing and Monitoring
Initial testing of the confined space atmosphere shall be performed from the outside. The
following tests shall be conducted to insure that the atmosphere is safe:
1. Oxygen content -normal air -20.9 percent;
2. Acceptable range 19.5 percent to 25 percent;
3. Flammability -not more than 10 percent of LEL;
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmenta.l E
I
I
I
I
I
I
I
I
••
I
I
I
I
I
I
I
I
I
I
D-8
4. Toxic materials -specifically targeted volatile organic compounds (VOCs) as
outlined in Section 4.1.1.1 of this HASP.
5. When toxic material cannot be kept within the TLV, then appropriate respiratory
protection shall be utilized, as described in Section 6.0 of this HASP.
(NOTE: Any necessary additional tests will be selected and performed to the satisfaction
of the qualified person.)
A confined space should not be entered until the appropriate tests indicate an acceptable
atmosphere. In addition, a confined space with an Immediately Dangerous to Life and
Health (IDLH) atmosphere should not be entered, for any reason, other than emergency
rescue, and only if the SSO authorizes entry. Monitoring of the confined space shall be
done on a continuous basis.
~
All entrances to any confined space shall be posted. Permanent signs should include at
least the following information:
DANGER
CONFINED SPACE
ENTRY BY PERMIT
ONLY
A copy of the entry permit shall be posted while any work is being performed within the
space.
CanonieEnvironmenta.l
D-9
Record Keeping
All records of training, calibration and confined space entry should be kept for a minimum
of one year. A copy of all entry permits should be forwarded to the SSO along with
employee names and dates of any training provided in this area. A confined space entry
permit form is included in Appendix B.1
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CanonieEnvironmental ·I
I
I
I
I
I
I
I
I
·1 APPENDIX E
I HOT WORK PERMIT
I
I
I
I
I
I
•
I
I CanonieEnvironmental ·
Canonie Environmental Services
LOCATION:
HOT WORK PERMIT
Welding (electric or gas)
0 xy-acewlene torch
Abrasive Grinding
Heat treatment
Other
Work area cleared of flammable or combustible materials
Fire extinguishers on hand
Fire watch posted lit required)
Emergency exit route clear and unobstructed
Ventilation provided lit confined area or poor natural ventilation)
Worker has appropriate eye protection, face shield and
respirator (if required)
Welding or cutting work performed behind shielding
(where practical)
Fall protection provided (where applicable)
Potential hazardous atmospheres checked:
% LEL % Oxygen ----------
When applicable, this permit will be used in conjuction with a Confined Space Entry Permit.
Valid from: To:
I have verified that all requirements of the hot work procedure and permit have been met
and therefore issue this permit.
ISSUED BY:
TITLE:
E-1
I
m
CanonieEnvironmental O
I
u
g
I
0
I
I
I
·1
I
I
I
I
I
I
I
I
I
I
APPENDIX F
MATERIAL SAFETY DATA SHEETS
CanonieEnvironmental
CAMEO Response Information, version 2.0, June 1987
NOAA, 7600 Sand Point Way NE, Seattle, WA 98115 [phone]
NAME:
HYDROGEN PEROXIDE
CAS Registry Ni..rrber: 7722841
Label: UM/MA:
NFPA Ratings : Health: 2 Flam: 0 React: 3 Spec: Oxidizer
GENERAL DESCRIPTION:
Colorless liquid. It is odorless or having an odor resen"i:lling that of ozone.
Use: Ant-infective; bleach; pharmaceutical preparations; source of oxygen in
respiratory protective equipnent; chemical interll'll!diates; and rocket propulsion.
Bleaching and deodorizing of textiles, wood pulp, hair, fur, etc; source of
organic and inorganic peroxides; pulp and paper industry; plasticizers; rod:et
fuel; foam rut>ber; manufacture of glycerol; antichlor; dyeing; electroplating;
antiseptic; laboratory reagent; epoxidation; hydroxylation; oxidation and
reduction; viscosity control for starch and cellulose derivatives; refining and
cleaning metals; bleaching and oxidizing agent in foods; neutralizing agent in
wine distillation; seed disinfectant; substitute for chlorine in water and
sewage treatment. (EPA, 1986}
FIRE & EXPLOSIVE HAZARD:
Spontaneous ignition may occur when contact with coobustible materials is made.
Oxygen released in decorrposition will promote corrbustion. Fire can be of the
flaring type but is not explosive unless confined. Vapor concentratio,n greater
than 40 percent by weight.can be dec~sed explosively at 1 atmosphere
pressure. Severe explosion hazard when it is exposed to heat, mechanical
in-pact, detonation of a blasting' cap, or caused to decorrpose catalytically.
Avoid exposing corrpound to light, t~ratures above 95F, or hot wires. Avoid
contact with oxidizable materials including iron, copper, brass, bronze,
chromiLlll, zinc, lead, manganese, silver, catalytic metals. (EPA, 1986}
FIRE FIGHTING:
Fires should be fought with water since the use of chemical extinguishants may
accelerate dec~sition. Small fires: Water only; no dry chemical or carbon
dioxide. Large fires: Flood fire area with water. Move container from fire
area if you can do it without risk. Cool containers that are exposed to flames
with water from the side until well after fire is out. For massive fire in
cargo area, use unarmned hose older or
withdraw from area and let fire burn.
PROTECTIVE CLOTHING:
monitor nozzles; if this is i~ssible,
(EPA, 1986)
~ear self-contained (positive pressure if available) breathing apparatus and
full protective clothing. (EPA, 1986)
SUIT MATERIAL COMPATIBILITY (Based on ACGIH, 1985):
BUTYL
CHLOROBUTYL
CHLOR RUB
Good Resistance/Limited Data.
F-m
D
0
D
D
I
I
I
I
I
I
I
I,
II
II
II
II
D
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CPE
c, 39
EVA/PE
FEP OR T FE
HYPALON
,a, Good Resistance/Limited Data.
NEOPRENE Good Resistance/Good Data.
NEO/RUB
"-IEO/SBR Good Resistance/Limited Data.
,tTOILE Poor Resistance/Limited Data.
, I TO I LE/PVC Good Res is tance/L'i mi ted Data.
PE
POLYCARB
PU Good Resistance/Limited Data.
PVA
PVC Good Resistance/Limited Data,
RUBBER Good Resistance/Limited Data.
RU8/NEO/NBR
,ua1,Eo1sa,
SARANEX
sa, Good Resistance/Limited Data.
VI TON Good Resistance/Limited Data.
v110,1,Eo
NONFIRE RESPONSE:
(eep conbustibles (wood, paper, oil, etc.) away from spilled material. Do not
touch spilled material; stop leak if you can do it without risk. Use 1o1ater
spray to reduce vapors; do not get water inside container. Small dry spills:
otith clean shovel place material ,into clean, dry container and cover; move
containers from spill area. Small spills: flush area with flooding amounts of
. .,ater. Large spills: dilc.e far ahead of spill for later disposal. (EPA, 1986)
HEALTH HAZARDS:
Strong irritant to sic.in, eyes, and rrucous merriJranes. Signs and S~toms of
E~posure: Vapor causes irritation of eyes and nose. Contact causes t~rary
whitening of the skin and a severe stinging sensation. If left on the sic.in for
a Period of time, it may cause blistering. Ingestion may cause bleeding and
severe distention of the stomach. Inhalation causes lung irritation. Contact
lr4i th the eyes causes pain. (EPA, 1986)
FIRST AID:
Move victim to fresh air; call emergency medical care. If not breathing, give
artificial respiration. If breathing is difficult, give oxygen. In case of
contact with material, irrmediately flush skin or eyes with running water for at
least 15 minutes. Remove and isolate contaminated clothing and shoes at the
site. Keep victim quiet and maintain normal body tern perature. Effects may be
delayed; keep victim under observation. (EPA, 1986).
FLASH POI,!:
Not Applicable. May cause fire and react violently on contact with
cont>ustibles and metals. (USCG, 1985)
LOIIEO EXPLOSIVE LIMIT:
Not Applicable. Not flanmable. (USCG, 1985)
UPPEO EXPLOSIVE LIMIT:
Not Applicable. Not flanmable. (USCG, 1985)
AUTO IGNITION TEMPEOATUOE:
Not Applicable. Not flanmable. (USCG, 1985)
F-2
MELTING POINT:
l1 Deg F (EPA, 1986)
VAPOR PRESSURE:
1 nm Hg @ 59.54 Deg F (EPA, 1986)
VAPOR DENSITY (AIR= 1):
Not Appl i cable. (USCG, 1985)
SPECIFIC GRAVITY·LIOUID (H20=1):
1.463 @ 32 Deg F (EPA, 1986)
SPECIFIC GRAVITY-SOLID (H20=1):
BOILING POINT:
306 Deg F (EPA, 1986)
MOLECULAR ~EIGHT:
34.02 (EPA, 1986)
IOLH:
75 PP'l (NIOSH, 1987)
TLV · TIME ~EIGHTEO AVERAGE:
1 PP'l CCC)ACGCH, 1986)
.TLV · SHORT 1TERM EXPOSURE LIMIT:
D
0
D
I
I
I
I
I
I
I
I
I
I
I
II
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CAMEO Response Information, version 2.0, J111e 1987
NOAA, 7600 Sand Point Way NE, Seattle, WA 98115 [phone]
NAME:
SOOIUM HYDROXIDE, LIQUID
CAS Registry Nll?'t)er: 1310732
Label: CORROSIVE MATERIAL
NFPA Ratings : Health: 3 Flam: 0 React: 1 Spec:
GENERAL DESCRIPTION:
UN/NA: 1824
SodiL111 hydroxide liquid is the water solution of sodii..m hydroxide. It is used
in chemical manufacturing, petroleun refining, paper making, cleaning corrpounds,
and for many other uses. The concentrated solutions will dissolve in additional
water with the evolution of heat. It is corrosive to metals and tissue.
((C)AAR, 1986)
FIRE & EXPLOSIVE HAZARD:
Not flarrmable. (USCG, 1985)
FIRE FIGHTING:
Extinguish fire using agent suitable for type of surrounding fire (material
itself does·not burn or burns with difficulty). Use water in flooding
quantities as fog. Apply water from as far a distance as possible. ((C)AAR,
1986)
PROTECTIVE CLOTHl~G:
Avoid breathing vapors or dusts. Avoid bodily contact with the material. ~ear
boots, protective gloves, and goggles. Do not handle broken packages without
protective equi?Jlent. ~ash away any material which may have contacted the body
with copious amounts ot water or soap and water. If contact with the material
anticipated, wear full protective clothing. ((C)AAR, 1986)
SUIT MATERIAL COMPATIBILITY (Based on ACGIH, 1985):
BUTYL Good Resistance/Limited Data.
CHLOROBUTYL
CHLOR RUB
CPE
CR 39
EVA/PE
FEP OR TFE
HYPALON
NBR
NEOPRENE
NEC/RUB
NEO/SBR
NITRILE
NI TR I LE/PVC
PE
POLYCARB
PU
Good Resistance/Limited Data.
Good Resistance/Limited Data.
Good Resistance/Good Data.
Good Resistance/Limited Data.
Good Resistance/Good Data.
Good Resistance/Good Data.
Good Resistance/Limited Data.
Good Resistfe/Limited Data.
F--4
PVA
PVC Good Resi stance/Limited Dau.
RUBBER Good Resistance/Good Data.
RUB/NEO/NBR
RUB/NEO/SBR
SARANEX
SBR
VI TON
VITON/NEO
Good Resistance/Limited Cata.
Good Resistance/limited Data.
NONFIRE RESPONSE:
(eep material out of water sources and sewers. Build dikes to contain flow as
necessary. Land spill: Oig a pit, pond, lagoon, holding area to contain liquid
or solid material. Oike surface flow using soil, sand bags, foamed
polyurethane, or foamed concrete. Absorb bulk liquid with fly ash or cement
powder. Neutralize with vinegar or other dilute acid. Water spill: Neutralize
with dilute acid or removable strong acid. Air spill: Apply water spray or
mist to knock down vapors. ((C)AAR, 1986)
HEALTH HAZARDS:
LIQUID: Will burn skin and eyes. Harmful if swallowed. (USCG, 1985)
FIRST AID:
If this chemical comes in contact with the eyes, inmediately wash the eyes with
large amounts of water, occasionally lifting the lower and upper lids. Get
medical attention irrrnediately. Contact lenses should not be worn when working
with this chemical. If this chemical comes in contact with the skin,
irrmediately flush the contaminated skin with water. If this chemical penetrates
the clothing, irrmediately remove the clothing and flush the skin with water.
Get medical attention.prorrptly. If a person breathes in large amounts of this
chemical, move the exposed person to fresh air at once. If breathing has
stopped, perform artificial respiration. Keep the affected person warm and at
rest. Get medical attention as soon as possible. If this chemical has been
swallowed, get medical attention irrmediately. (NJOSH, 1987)
FLASH POINT:
Not Applicable. Not fla,rmable. (USCG, 1985)
LOSER EXPLOSIVE LIMIT:
Not Applicable. Not flanmable. (USCG, 1985)
UPPER EXPLOSIVE LIMIT:
Not Applicable. Not fllfffflllble. (USCG, 1985)
AUTO·IGNITION TEMPERATURE:
Not .Applicable. Not flanmable. (USCG, 1985)
MELTING POINT:
Not Applicable. (USCG, 1985)
VAPOR PRESSURE:
Not Applicable. (USCG, 1985)
VAPOR DENSITY (AIR• 1):
Not Applicable. (USCG, 1985)
SPECIFIC GRAVITY·LIQUIO (H20•1):
Fl
I
I
I
I
I
I
I
I
I:
II
II
II
II
II
II
II
II
I
I
0
H
I
I
I
I
I
I
I
I
I
I
I
I
I
1.5 • 68 Deg F (USCG, 1985)
SPECIFIC GRAVITY·S0LID (H20•1):
BOILING POINT:
>266 Deg F • 760 nm Hg (USCG, 1985)
MOLECULAR WEIGHT:
40 (NI0SH, 1987)
IDLH:
250 mg/m3 (NI0SH, 1987)
TLV · TIME WEIGHTED AVERAGE:
TLV · SHORT TERM EXPOSURE LIMIT:
F-6
I
D
D
I
I
I
I
I
•• APPENDIX H
RESPIRATORY PROTECTION
I
I
I
I
I
I
I
I
I
I CanonieEnvironmental
APPENDIX H
RESPIRATORY PROTECTION
1.0 RESPIRATORY PROTECTION DEVICES
I.I Standard Operating Procedures for Respiratory Protection Devices
The following subsections define Standard Operating Procedures (SOPs) for
Air-Purifying Respirators (APRs) and Self-Contained Breathing Apparatus
(SCBAs).
I.I.I Proper Use of APRs
I. Be sure there is no facial hair present to interfere with the
facepiece seal.
2. Check to see that the respirator is clean and all parts are
intact.
3. Specifically check that cartridges are in place, the adjustable
straps are not broken, the exhalation valve is present and intact,
D
0
I
I
I
I
II
II
the inhalation valves are present and intact, and the plastic lens EJ
is not badly scratched or cracked.
NEVER USE THE RESPIRATOR IF THESE PARTS ARE DEFECTIVE OR MISSING.
4. Pull the mesh harness over the lens for Scott-0-Vista Masks. For
other full-face masks, pull the head harness over the lens.
5. Be sure the straps are fully extended.
6. Place the chin in first and pull the harness up and over the head.
For half mask respirators, there are two sets of headstraps.
Tighten the temple straps first, and then the lower straps. If
there is a strap at the top of the mask, tighten that one last,
and only if necessary.
II
II
II
II
II
II
CanonieEnvironmental 11
B
0
I
I
R
I
I
••
I
I
I
I
I
I
I
I
I
I
7. For the Scott mask, stroke the harness back over the head and
adjust the neck straps to tighten the mask. The mask should be
snug, but not uncomfortably tight on the face.
1. 1.1.l Limitations and Restrictions
H-2
Cartridge respirators should never be used when contaminants in the air
exceed the ratings for the cartridges, or in an atmosphere containing less
than 19.5 percent oxygen.
Facial hair and eyeglass frames will interfere with the seal of a full-face
piece and decrease the protection level of the mask. Special eyeglass
holders will be provided to adapt glasses to fit inside the mask. Frames
for these special glasses cannot be more than five inches wide .
1.1.2 Cleaning and Disinfecting APRs
APRs in routine use should be cleaned and disinfected at least daily.
Where respirators are used only occasionally, or when they are in storage.
the cleaning interval is weekly or monthly, as appropriate.
l. 1.2.1 Daily Cleaning Routine
The steps to be followed for cleaning and disinfecting daily are as
follows:
1. Respirator Disassembly. Respirators are taken to a clean location
where the filters or cartridges are removed and discarded. For
thorough cleaning, the inhalation and exhalation valves and
speaking diaphragm are removed.
2. Cleaning. In most instances, the cleaning and disinfecting
iolution provided by the manufacturer is used, and is dissolved in
warm water in an appropriate tub. Using gloves, the respirator is
placed in the tube and swirled for a few moments. A soft brush
may be used to facilitate cleaning.
CanonieEnvironmental
H-3
3. Rinsing. The cleaned and disinfected respirators are rinsed
thoroughly in water to remove all traces of detergent and
disinfectant. This is very important for preventing dermatitis.
4. Drying. The respirators may be allowed to dry in room air on a
clean surface. They may also be hung upside down like drying
clothes, but care must be taken not to damage or distort the
facepieces.
5. Reassembly and Inspection. The clean, dry respirator facepieces
should be reassembled and inspected in an area separate from the
disassembly area to avoid contamination. Special emphasis should
be given to inspecting the respirators for detergent or soap
residue left by inadequate rinsing. This appears most often under
the seat of the exhalation valve and can cause valve leakage or
sticking.
1. 1.2.2 Procedures After Routine Use
The steps to be followed for cleaning and disinfecting in the field a~e as
follows:
I. The mask may be washed/rinsed with soap and water.
2. At a minimum, the mask should be wiped with'disinfectant wipes
(benzoalkaloid or isopropyl alcohol), and allowed to air dry in a
clean area.
1. 1.3 APR Inspection and Checkout
I., Visually inspect the entire unit for any obvious damages, defects,
or deteriorated rubber.
.g
D
D
u
g
I
I
I
I
I
I
I
I
I
CanonieErwironmenta.l I
·U
I
D
D
D
I
I
I
••
I
•
I
I
I
I
I
I
I
I
H-4
2. Make sure that the facepiece harness is not damaged. The serrated
portion of the harness can fragment which will prevent proper face
seal adjustment.
3. Inspect lens for damage and proper seal in facepiece.
4. Exhalation Valve -pull off plastic cover and check valve for
debris or for tears in the neoprene valve (which could cause
leakage).
5. Inhalation Valves (two) -screw off cartridges and visually
inspect neoprene valves for tears. Make sure that the inhalation
valves and cartridge receptacle gaskets are in place .
6. Make sure a protective cover lens is attached to the lens.
7. Make sure the speaking diaphragm retajner ring is tight .
8. Make sure that you·have the correct cartridge.
9. Don and perform negative and positive pressure test.
1.1.4 Storage of APRs
OSHA requires that respirators be stored to protect against:
I. Dust;
2. Sunlight;
3. Heat;
4. Extreme cold;
CanonieEnvironmental
H-5
5. Excessive moisture;
6. Damaging chemicals;
7. Mechanical damage.
Damage and contamination of respirators may take place if they are stored
in dirty or questionable areas.
1.1.5 Prooer Use of SCBAs
1. Before using the SCBA, check to see that all of the major parts
are in working order. Specifically, check the mask lens and face
seal, all hos.es and couplings, and the harness.
2. Be sure the air tank gauge reads full.
3. Check out the equipment by opening the cylinder valve. Push in on
the valve knob and rotate it counterclockwise until fully open.
The warning signal should sound briefly and shut off.
4. Hold the facepiece to your face and inhale and exhale several
times. You should be able to breathe easily without restrictions.
5. Open thi purge valve briefly to check its operation. A free flow
of air should be noted in the facepiece. Close the purge valve
and note that there should no longer be any free airflow in the
mask.
6. Test the low pressure warning signal by closing the cylinder valve
knob, pushing in and rotating it fully clockwise. Take slow,
shallow breaths until the signal sounds. If it does not sound,
0
D
D
0
g
g
I
I
I
I
I
I
I
I
I
repeat the test, breathing very slowly. I
I
CanonieEnvironmental I
I
D
I
I
I
I
·1
I
I
I
I
I
I
I
I
I
I
DO NOT USE THE SCBA IF THE WARNING SIGNAL DOES NOT SOUND, OR IF THE AIR
CYLINDER IS NOT FULL.
H-6
7. To put the unit on, turn your back to the unit mounted on the wall
and slide your arms into the shoulder straps as if putting on a
jacket. If wall mounts are not in use, set the SCBA on its end on
a table, or have a co-worker hold it for you.
8. Step away from the wall, bend over slightly, pull down on the
shoulder strap adjustment tabs to tighten the straps, and cinch
the unit up on your back.
9. Buckle the waist belt and tighten it like a seatbelt.
10. Now slightly loosen the shoulder straps to allow the weight of the
unit to .rest on your hips.
11. Put on the facepiece chin first and pull the harness up and over
your head. Stroke the harness down over the back of your head and
adjust the neck straps to give a snug, but comfortable fit.
12. Check to be sure the pressure gauge on the harness reads ''full''.
13. When working in the Canonie Exclusion Area, leave the area as soon
as you hear the low pressure alarm.
14. Before remo·ving the SCBA, be sure to go to a clean area. Close
the cylinder valve by reaching behind you and pushing in on the
knob and turning it fully clockwise.
15. Now remove the facepiece by pulling it up from the chin and over
your head.
CanonieEnvironmental
16. Loosen the shoulder straps, unbuckle the waist belt, slide the
unit off one shoulder, then off the other shoulder.
H-7
17. To change cylinders if a new one is needed, close the cylinder
valve and separate the pressurized hose by rotating the coupling
counterclockwise, pull the toggle to release the cylinder band
clamp, push on the yellow tab of the guarded hook behind the
cylinder valve, and lift the cylinder up and out.
18. Slide the flat end and valve on the cradle or a fully charged
cylinder upward through the band clamp, move the cylinder back
until the hook on the back frame engages in the hanger on the
cylinder and valve assembly. Be sure that hook guard latches into
place.
19. While in the Canonie Exclusion Area, hook directly into the
airline system (if one is.available), thus preserving the air
supply in the 30-minute cylinder. To do this, fasten the pigtail
hose line from the SCBA into an airline from the air trailer. Be
sure to tug on the lines to ensure a secure fit.
20. To connect the pigtail and airline, pull back on the coupling
collar, slide in the pigtail, and release the collar.
21. To leave the area, open the cylinder valve and disconnect the
pigtail. The switch'to the bottle supply will occur
automatically.
1.1.5.1 Limitations of the SCBA
The major limitations stem from the 30-minute supply in the air tank.
While the possibility is slim, a hoseline could rupture or, if a person
slips and falls, the units may be damaged. These occurrences are not
likely, but one should be aware of them.
n
D
a
I
I
I
1.
II
II
II
II
11
I
I
CanonieEnvironmenta.l I
D
u
B
I
I
I
I
I
·1
I
I
I
I
I
I
I
I
I
I
H-8
1.1.6 Cleaning and Disinfecting the SCBA
Cleaning procedures for SCBA facepieces ar~ identical to those for the APRs
outlined above. The piece is cleaned with cleaning solution and a brush.
Following cleanin~, the facepiete is combined with the regulator and an
operational check performed.
1.1.7 SCBA Insp~ction and Checkout.
Monthly inspection:
1. Check cylinder label or stamping for current hydrostatic test
date.
• 2. -Inspect cylinder for large dents or gouges.
3. Inspect cylinder gauge for damage.
4. Complete routine inspection.
5. Fill out the appropriate records with results and recommendations.
1.1.8 Storage of SCBAs
I. Cylinder refilled as necessary and unit cleaned and inspected.
2. Cylinder valve closed.
3. High pressure hose connector tight on cylinder.
4. Pressure bled off high pressure hose and regulator.
5. Bypass _valve closed.
CanonieEnvironmenta.l
6.
7.
8.
H-9
Mainline valve closed.
All straps completely loosened and laid straight.
Facepiece properly stored to protect against dust, sunlight, heat,
extreme cold, excessive moisture, and damaging chemicals.
n
D
m
I
I
I
I
1,
II
II
II
II
H
II
II
ii
II
'I
CanonieEnvironmenta.l I
D
I
·D
D
u
I
I
I
I
I
I
I
I
'I
I
H-10
2·.o TRAINING ANO FIT TESTING REQUIREMENTS
2.1 Fit Test
Every time a respirator is worn, it must be fit tested by the negative and
positive pressure test. Irritant smoke and amyl acetate tests will be
performed prior to initial field activities for all on-site personnel.
Additional irritant smoke and amyl acetate tests will be performed as
required by the SSO.
2.1.1 Negative Pressure Test
1. Remove the cartridges from the respirator.
2. Put the respirator on and adjust it to fit properly.
3. Cover the cartridge ports with the hands and breathe in gentlt.
The mask should collapse ~lightly and there should be no air
entering mask through the face seal. Hold your breath for five
seconds. If the mask remains sealed, go on the next fit test.·
4. If air enters through the face seal, adjust the mask again and
repeat the test until no air leaks in.
2.1.2 Positive Pressure Test
1. Put the cartridges back on.
2. Remove the cover from the exhalation port (if there is one).
3. Cover the· exhalation support with the hand.
4. Exhale slightly while covering the port.
CanonieEnvironmental
H-11
5. The mask should expand slightly, but no air should leak out from
around t~e seal.
6. If there is leakage, adjust the mask and repeat the test until
there is no more leakage.
2.1.3 Amyl Acetate (Banana Oil) Test
I. Conduct odor recognition test (banana odor).
2. After checking the respirator for all the proper parts, put on the
respirator and adjust the fit.
3. Perform the negative and positive pressure tests.
4. While wearing the respirator, the SSO will wave a Vi a 1 of amyl
acetate (~mells like bananas) near the face sea 1 .
5. Move your head from side to side and up and down, speak normally.
and read the rainbow passage out l 6ud.
6. If any odor is detected, adjust the fit of the mask and repeat the
test until no odor is noted.
2.1.4 Irritant Smoke
I. Conduct odor recognition test (cough should be illicited).
2. After checking the respirator for all the proper parts, put on the
respirator and adjust the fit.
3. Perform the negative and positive pressure tests.
4. While wearing the respirator, the SSO will pump irritant smoke
through a hand-held bellows pump near the face seal.
D
I
I
·I
I
I
I
I
I
I
Ii
CanonieEnvironmental II
I
0
I
H-12
5. Move your head from side to side and up and down, speak normally, m and read the rainbow passage out loud.
I
I
I
I
·1
I
I
I
I
I
I
I
I
I
I
6. If any odor is detected or a cough is induced, adjust the mask and
repeat the test until no odor or cough is noted.
Note: Before personnel are fit tested with amyl acetate or irritant smoke,
their respirators should be worn for approximately five minutes.
CanonieEnvironmental