NCD981475932_19950101_FCX Inc. (Washington Plant)_FRBCERCLA RMVL_Site Specific Work Plan-OCR

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REMOVAL WORK PLAN
DOCUMENTS
I FCX -WASHING TON
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RECEIVED 1
JAN 2 6 1995
suPERFUND SECTION -
SITE SPECIFIC
WORK PLAN
Farmers' Cooperative Exchange
Washington, NC
Contract No. 68-S4-4003
Prepared by:
McLaren/Hart Environmental Engineering Corporation
Great Woods Park
800 South Main Street
Mansfield, MA 02048
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I 1.0
I 2.0
2.1
2.2
I 2.2.1
2.2.2
2.2.3
I 2.2.4
2.3
I 2.4
2.5
2.6
I 3.0
3.1
I 3.2
3.3
I 4.0
5.0
I 6.0
6.1
I 6.2
7.0
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TABLE OF CONTENTS
INTRODUCTION
PROCEDURES AND PLANS FOR MOBILIZATION
Initial Grading
Work Zone
LTTD System
Waste Preparation
Decontamination Pad
Contamination Reduction Zone
Site Trailers and Parking Facilities
Rest Room Facilities
Site Utilities
Site Security
SITE OPERA TING PROCEDURES
Site Activities
Soil Handling
Sampling and Analysis Procedures
HANDLING OF CONDENSATE
TREATMENT SYSTEM MONITORING
PROCEDURES AND PLANS FOR MOBILIZATION
Decontamination Sequence
Decontamination Procedures
SITE CLOSURE AND RESTORATION
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EXHIBIT
A
B
C
D
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SCHEDULE OF EXHIBITS
DESCRIPTION
Site Layout Diagram
Process Flow Diagram
Activated Carbon: Air Pollution Control Barrel
Bio-Might MSDS Sheets
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1.0 INTRODUCTION
The Site Specific Work Plan is designed to provide a detailed description of the operational ·
procedures for site activities. Specifically, the work plan will thoroughly describes mobilization
plans and procedures, the site layout, site operating procedures, treatment system monitoring and
demobilization plans and procedures.
2.0 PROCEDURES AND PLANS FOR MOBILIZATION
McLaren/Hart will commence mobilization activities approximately two weeks prior to the onset
of the Demonstration Program. All equipment, labor, and material necessary to properly
implement the activities described herein will be furnished to the FCX site. Following is a
detailed summary of the specific activities which will be performed to prepare the site for the
Low Temperature Thermal Desorption System (L TTDS) operation. This will include establishing
site command post, site security, a work area/exclusion zone, contamination reduction zones,
decontamination facilities, installation of required utilities, set up of the L TTDS (including
associated air pollution control systems) and set-up of soil handling systems.
2.1 Initial Grading
A small crawler dozer shall be used to improve the present condition of the gravel access road
located on the northwestern side of the bag storage warehouse, as well as all associated temporary
roadways. Any existing vegetation and/or topsoil will be removed from the proposed work area
using the dozer and will be stockpiled separately at the southeast corner of the site.
The final working subgrade will be constructed to drain in the direction of the temporary
decontamination pad using a slight gradient (approximatetly 0.05%) to allow any excessive runoff
to drain and collect. All liquids collected within the decontamination pad area will be considered
as contaminated material and will be pumped to the 20,000 gallon contaminated storage tank for
treatment by the reverse osmosis unit.
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2.2 Work Zone
The perimeter of the existing chainlink fence which surrounds the contaminated soil stockpile will
be enlarged to encompass the entire work area/exclusion zone. The delineation of the work
area/exclusion zone is attached hereto as Exhibit A, Site Layout. The configuration of the ·
existing fence will be adjusted by removing a 160 foot section from the western side of the fence
and reinstalling this section at the southern side of the exclusion zone, extending the perimeter
by 160 feet. New six foot fence material will be utilized to enclose the remaining area. The
total length of the modified western side of the fence will be 160 feet. Two separate twelve foot
gates will be installed along the western side of the fence to enter and to exit the work area. The
fence line will then turn to the east and extend 160 feet to tie back into the existing northern line.
2.2.1 LTTD System
The four (4) LTTDS systems will be assembled in accordance with Sections (3.0) and (4.2.1) of
the Demonstration Plan and will be positioned towards the southwest corner within the fence
enclosure, as detailed in the Site Layout which is attached hereto as Exhibit A. All assembly and
initial start up procedures shall be performed in accordance with the Demonstration Plan and
the manufactures' s recommendations.
The four ( 4) 1,000 gallon propane storage tanks and the chiller unit will be positioned outside
the fenced work area/exclusion zone to ensure accessibility. This will eliminate the necessity to
obtain OSHA 40 hour trained subcontractors to fill and/or maintain the propane tanks and the
chiller unit.
2.2.2 Waste Preparation
As stated in the Demonstration Plan, there will not be a need for waste preparation because it
is anticipated that the material to be treated will be less than twelve inches in diameter. Pieces
of debris as well as oversized material will be manually removed from the treatment bins prior
to being placed within the treatment chamber. Any oversized material or fugitive debris will be
decontaminated in the decontamination pad area utilizing the pressure washer and placed in the
pile of existing debris which is presently stored at the south side of the site.
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2.2.3 Decontamination Pad
The decontamination pad will be constructed from a portion of the 20 mil HOPE liner that is
presently being used to cover the pile of contaminated soil. It is anticipated that ample liner can
be removed from the stockpile without exposing the contaminated soil. In the event that the soil
should become exposed while removing the portion of the liner, a temporary tarp will be installed
to prevent the soil from being, limiting the potential for contaminated run-off.
The pad will be constructed as follows: an 18 inch deep area measuring approximately 20 feet
wide by 30 feet long will be excavated; one corner of the excavated area will be excavated an
additional 18 inches to create a sump from which the liquids will be pumped. The 20 mil liner
will be installed along the bottom of the excavation and 18 inches of 3/4 inch stone will be
spread throughout the excavation. The outer edges of the liner will be anchored into the
surrounding soil. All aqueous materials that are collected within the sump will be pumped to the
20,000 gallon contaminated storage tank utilizing a 2 inch electrical submersible pump or a 2
inch gasoline powered trash pump.
2.2.4 Contamination Reduction Zone
The contamination reduction zone (CRZ) will serve as a buffer zone between the work
area/exclusion zone and the decontamination pad. The CRZ will surround the decontamination
pad on three sides as well as connect the decontamination pad to the personnel decontamination
trailer. The CRZ will consist of a minimum of a three foot wide area of 3/4" stone laid on the
subgrade. A boot wash and boot storage rack will be stationed within the CRZ immediately
outside the personnel decontamination facility. All discarded personal protection equipment
(PPE) will be collected and stored in appropriate containers pending proper disposal.
2.3 Site Trailers and Parking Facilities
There will be one office trailer on site which will be located along the northern side of the
chainlink fence, outside the work area, as detailed in the Site Layout which is attached hereto as
Exhibit A. The personnel decontamination trailer will be located to the east of the office trailer
and will be positioned north to south. The decontamination trailer will penetrate the fence line
in order to permit personnel to enter and to exit the trailer from either side of the chainlink fence.
The decontamination trailer will contain a sink to supply non-potable water for hand washing as
well as ensuring the proper maintenance of the air purifying respirators. In addition, two shower
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stalls will be located inside the decontamination trailer. The waste water generated from the
decontamination trailer will be collected in a plastic storage tank beneath the trailer and ultimately
pumped into the 20,000 gallon contaminated storage tank for treatment. A third trailer will be
located along the northern side of the fence, outside the work area, to serve as the employees
lunch room trailer and tool storage trailer. There will be approximately 1,200 square feet of
gravel parking available in the support area to the north of the office trailer.
2.4 Rest Room Facilities
Rest rooms will be provided at two locations on the site. The office trailer will have one rest
room consisting of a sink and a toilet. The waste water from the office trailer will be stored in
a plastic storage tank located beneath the trailer. The second facility will be a portable toilet
which will be located on the clean side of the fence just beside the decontamination trailer. The
plastic storage tank and the portable toilet will be serviced a minimum of on time per week.
2.5 Site Utilities
Site utilities will consist of water, electricity and telephone. The potable water which will be
used at the site will be obtained from the existing water service that is available at the Campbell
trucking facility. A temporary water line will be installed from the exterior spicket located at the
front of the building. The water line will proceed from the spicket along the base of the building,
to the center of the warehouse, up the side of the building and across the roof to the rear of the
building. From the rear of the building, the water line will advance to the site support area. At
that point, the line will be buried to a depth of approximately 12 inches below ground surface.
The local power company will supply two separate services to furnish the needed electricity at
the site. A 480 volt, 3-phase service will be utilized to power the treatment equipment at the
south end of the work area. A 110/220 volt, single phase service will be supplied to equip the
support area at the north end of the site. Any and all electrical connections to the power sources
will be made by a contracted, licensed electrician.
The local power company will also supply temporary lighting to the work area with three 1,000
watt spotlights. One light will be mounted on the existing utility pole located at the north end
of the contaminated soil stockpile. The two remaining lights will be installed on a temporary
pole to be installed at the support area.
The existing utility poles will be utilized by the local telephone company to supply telephone
service to the site.
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2.6 Site Security
The existing gate located at the main driveway between Grimes road and the Campbell Trucking
company will serve as the primary security for the site. The gate will be closed and locked
during the non-operational hours of the trucking company. Arrangements have been made with
the owner of Campbell Trucking to set up a double padlock system on the gate whereas either
the Campbell employees or the McLaren/Hart employees can open the gate when necessary to
access the site area.
3.0 SITE OPERATING PROCEDURES
Upon completing all mobilization procedures, the soil treatment process shall commence. Prior
to the commencement of the full-scale treatment, McLaren/Hart will successfully perform a
demonstration of the treatment system, utilizing approximately 100 cubic yards of "representative
contaminant waste". As detailed in the Demonstration Plan, the demonstration program will
verify the effectiveness of the L TTDS to achieve all performance requirements as outlined in the
Statement of Work (SOW). The optimum operating parameters (ie. treatment temperature and
treatment duration) will be determined from the results of the demonstration program. These
operating parameters will be utilized throughout the full scale treatment process which will
commence upon receiving a "Notice to Proceed" directive from the EPA.
3.1 Site Activities
All initial start up and shake down procedures, routine treatment procedures, and sampling and
analysis procedures are outlined in the Demonstration Plan and the Sampling and Analysis
Plan. The procedures described in these plans provide a detailed summary of site activities,
sampling and analyses procedures for the demonstration program and for the full-scale treatment,
as well as a description of the methods used to control emissions. Demonstration Plan also
includes a detailed description of the L TTDS assembly procedures and a general process
description. A process flow diagram detailing the configuration of the integral components of
the treatment system is attached hereto as Exhibit B.
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3.2 Soil Handling and Treatment
Upon the commencement of the soil treatment process, the contaminated material that is to be
treated will be obtained from either the soil stockpile or the soil bags which are located in the
warehouse. McLaren/Hart intends to treat all 1,774 bags of soil prior to commencing treatment
of the stockpiled soil.
The bags of soil contained within the warehouse will be removed from the building through the
existing eight foot sliding door which is located at the south end of the building. A gradual ramp
will be constructed using common fill so as to enable the machines to drive in to and out of the
warehouse. The bags will be brought from the interior of the building to the entrance gate of the
work area with the use of a heavy duty all terrain fork lift. The bags are equipped with ·
reinforced straps which will be placed over the forks for transportation purposes. While
transporting the bags, the load will be carried as close to the ground as possible to minimize the
risk of damage or injury. The bags within the work area will be handled by the front end loader
with either the fork attachment or the loader bucket attachment and the contents of the bags will
be dumped directly into the treatment system chambers.
Upon successfully completing the treatment of the materials within the bags, McLaren/Hart will
commence treatment of the contaminated stockpile. The 20 mil HOPE liner which is presently
covering the stockpile will be rolled back on a daily basis to expose the soils that are to be
treated that day. The remaining portions of the stockpile will remain fastened intact to continue
controlling contaminated run-off as well as to prevent possible damage from heavy winds. The
liner will be rolled back over the exposed soils and secured fastened down during poor weather
conditions (ie. precipitation, heavy winds). As the treatment process progresses and the size of
the stockpile diminishes, the excess liner will be cut back to increase its handling ability.
The front end loader with the loader bucket attachment will be utilized to transport the soils from
the stockpile to the treatment area and will deposit the soil directly into the treatment bins. In
order to minimize the potential of injuries and to reduce the possibility of spillage, McLaren/Hart
will ensure that the capacity of the bucket is not exceeded when it is loaded.
Approximately five cubic yards of contaminated material will be transferred into the two
treatment bins of each of the four L TTDS units, to be processed. The procedures outlined in
Section (4.5) of the Demonstration Plan will be followed for the full scale treatment utilizing
the treatment protocol which will be determined from the results of the demonstration program.
Upon completion of the batch treatment process, the L TTDS will be manually deactivated and
the treatment bins will be removed from the treatment chambers. The treated soils will be
stockpiled in a discrete stockpile area located in the northwest quadrant of the work
area/exclusion zone. It will not be necessary to undergo any additional measures to assist in the
cooling of the processed soils due to the low operating temperature of the L TTDS.
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3.2 Sampling and Analysis Procedures
The treated soils will be stockpiled in either daily or 500 ton piles and covered with tarps to
control surface run-off from the piles. In accordance with the Sampling and Analysis Plan,
three composite soil samples will be obtained and sent to an independent laboratory to be
analyzed for total pesticides (EPA Method 8080). The treated soil stockpiles will remain
undisturbed until obtaining preliminary analytical results which indicate that the soil meets the
clean up objective of less than I mg/kg total pesticides, upon which the treated soil will be
moved outside the work area into the clean soils staging area. The soil will be loaded into a
dump truck and transferred to the stockpile area outside the work area. Any vehicle traveling
from inside the fenced . work area to the area outside of the fence will pass over the
decontamination pad and the wheels will be washed using a high pressure spray.
Any soils which do not meet the clean up objective as outlined in the SOW will remain within .
the work area/exclusion zone and will be reintroduced to the L TTDS to undergo additional
treatment. The failed soil pile will be handled as contaminated material and procedures will be
undertaken to ensure the safety of personnel and the surrounding environment, as detailed in the
Health and Safety Program. No soil will be permitted to exit the confines of the work area
until deemed clean by the preliminary analytical results.
Complete descriptions of all sampling and analysis procedures for the full scale treatment as well
as the demonstration program are detailed in the Demonstration Plan and the Sampling and
Analysis Plan, specifically all air monitoring procedures, soil sampling procedures and aqueous
material sampling procedures. Additionally, the Demonstration Plan and the Sampling and
Analysis Plan describe the emissions control procedures which will be followed to ensure that
the L TTDS is in compliance with the performance requirements as outlined in the SOW.
Included in the emissions monitoring which will be performed at the FCX site is a one time stack
sampling test, continuous monitoring for the percent concentration of oxygen and continuous
monitoring for total hydrocarbons.
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4.0 HANDLING OF CONDENSATE
As described in the Demonstration Plan, the condensate that is generated from the system's two
condensers and chiller unit will be transferred to the 20,000 gallon storage vessel where it will
be stored until being processed through the reverse osmosis system (R/0). The condensate
contained within the storage tank will be fed through the R/0 in order to separate the pesticide
contaminants from the water to a residual concentration level of less than IO parts per billion
(ppb).
55 gallon drums will be utilized to collect the liquid contaminants that are separated with the R/0
unit and will be in the drum storage area, as indicated on the site layout. The drums will be
transported off site by Laidlaw Environmental Services for disposal, as necessary.
The water that is separated from the unit will be transferred to the clean water storage vessel to
await sampling. Upon receiving preliminary analytical results that demonstrate the water to be
clean, the clean water storage vessel will be emptied. The primary use for the clean water that
has been stored in the vessel will be dust control.
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5.0 TREATMENT SYSTEM MONITORING
As detailed in the Demonstration Plan and the Sampling and Analysis Plan, the performance
of the treatment system will be monitored throughout the treatment process to ensure that the
system is in compliance with the contract specifications as outlined in the Statement of Work.
McLaren/Hart will monitor specifically for the following five parameters to verify that the system
is operating within the contract requirements and in accordance with the optimum operating
conditions as determined during the demonstration program.
(I) The percent concentration of oxygen in the effluent gas will be measured on a
continuous basis to ensure a concentration range of 0% to 5% oxygen.
(2) The total hydrocarbon emissions from the treatment system stack will be
monitored on a continuous basis to ensure a total concentration between 0 ppm
and 100 ppm.
(3) The discharge flow rate will be measured to ensure a total flow rate of the system
between 0 acfm and 500 acfm.
(4) The level of vacuum within the treatment system will be monitored to ensure that
25 to 28 column inches of mercury are being drawn while the system is in
operation.
(5) The temperature within the treatment chambers will be measured to ensure that the
optimum operating temperature is being obtained. To successfully desorb
pesticides using the L TTDS a temperature between 350 and 400 degrees must be
obtained. The optimum operating temperature will be determined during the
demonstration program.
The specific procedures, equipment, and the manufacturer's specifications of the equipment which
will be utilized for the above detailed monitoring are described in the Demonstration Plan and
the Sampling and Analysis Plan. A process control diagram which illustrate the locations of
all system monitoring equipment is attached hereto as Exhibit B. Calibration and testing
procedures for the monitoring equipment shall be performed in accordance with the
manufacturer's recommendations. Records of all system monitoring, testing, malfunctions and
calibration will be maintained and updated in the site operating log, as detailed in the
Demonstration Plan and the Sampling and Analysis Plan.
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6.0 PROCEDURES AND PLANS FOR DEMOBILIZATION
Specific procedures for the dismantling and decontamination of equipment at the FCX site are
detailed herein. Upon successfully completing the treatment of the total volume of both bagged
and stockpiled contaminated soils, McLaren/Hart will decommission two of the L TTDS treatment
beds and their associated equipment (ie. the two stage condenser and the vacuum pump).
Decontamination sequence and procedures are detailed in Sections (5.1) and (5.2), respectively,
of this plan. A 300 square foot grid system of the handling areas will be developed and soil
samples will be obtained to be analyzed for total pesticides (EPA Method 8080) in accordance
with the Sampling and Analysis Plan. One composite sample, representative of each 300 square
foot area, will be obtained and analyzed in accordance with EPA Method 8080 to confirm that
contaminant levels are either less than or equal to the removal action level of total pesticides or
equal to the previously existing condition, which ever is greater. As discussed with the EPA
Region IV representatives during the pre-construction meeting on October 21, 1994, the area
beneath the stockpile is not to be considered handling area, and therefore grid sampling will not
be conducted in this area. In the event that the grid analytical results indicate that total pesticide
levels are greater than the pre-existing conditions or greater than the removal action level, the
grid area or areas will be scraped down an additional 4 inches and will be treated utilizing the
two treatment chambers which will still be assembled. These areas will then be re-sampled to
confirm compliance with the requirement detailed in Section (1.3.17) of the Statement of Work.
Copies of all of the analytical data will be submitted to the EPA OSC prior to the
decontamination and dismantling sequence of the remaining two treatment chambers and
associated equipment.
6.1 Decontamination Sequence
In order to ensure the proper decontamination of all equipment associated with the L TTDS
assembly, a sequence of decontamination procedures has been established and will be followed
upon successfully treating the total volume of contaminated soils.
(I)
(2)
The first equipment to be decontaminated will be two treatment chambers, one
vacuum pump and two stage condenser.
Upon completion of the confirmatory sampling and analysis of the handling area,
the volume of activated carbon in the pollution control system will be removed
from the vessel and placed in one of the treatment chambers to desorb the
pesticides.
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(3)
(4)
(5)
6.2
NOTE: The remaining operation of the treatment chambers beyond this stage of
decontamination will utilize a portable 55 gallon drum activated carbon unit
known as the "AIR POLLUTION CONTROL BARREL" distributed by The
General Carbon Corp. The flow capacity of the barrel is 100 cfm, this will ensure
proper air pollution control. Specific information regarding the air pollution
control barrel is attached hereto as Exhibit C.
All decontamination wash water that has been collected will be pumped to the
contaminated water 20,000 gallon storage tank and will be treated through the
reverse osmosis unit.
The volume of stone and silt within the decontamination pad and the CRZ will be
placed in the treatment chambers and will be treated.
The final equipment to be decontaminated will be the remaining two treatment
chambers, the two stage condenser, the vacuum pump, the 20,000 contaminated
water storage tank and ultimately the R.O. unit.
Decontamination Procedures
The main components that will be used during the decontamination procedures will be. clean
potable wash water, pressure washer and a biodegradable wash detergent. Bio-Might, a non-
butyl, non-toxic, biodegradable, non-flammable, non-corrosive and non-polluting wash detergent
will be utilized during the decontamination processes. The MSDS for Bio-Might is attached
hereto as Exhibit D.
(I) Treatment Chambers
(2)
After the last treatment cycle of each individual treatment unit, the treatment
chambers will be cleaned of all soils. The chambers will be transported to the
decontamination pad to be washed with the pressure washer and be scrubbed with
a rigid brush and the Bio-Might solution.
Vacuum Pumps
The seal water will first be drained from the vacuum pumps and will then be
transferred to the 20,000 gallon contaminated water storage tank for treatment
through the reverse osmosis unit. The interior of the pump housing will be
flushed and scrubbed with the Bio-Might solution.
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(3)
(5)
(6)
Two Stage Condensers
The design of the two stage condensers enables the side covers to be removed,
allowing the contaminated interior of the unit to be accessed. The interior of the
units will be washed and scrubbed with the Bio-Might solution.
Piping and Equipment
All associated piping and equipment that has been in contact with either the
pesticide contaminated soils or the contaminated liquids will also be flushed and/or
scrubbed with the Bio-Might detergent solution.
Water Tank and Reverse Osmosis Unit
Ultimately the contaminated water storage tank will be completely drained and the
liquids will be treated with ·the reverse osmosis unit. The tank is designed with
a "V" shaped bottom to aid the cleaning process. It will not be necessary to enter
the tank to successfully complete the decontamination process.
7.0 SITE CLOSURE AND RESTORATION
The McLaren/Hart crew will commence returning the site to it's original pre-mobilization
condition upon the completion of all decontamination and dismantling procedures are completed.
The chain link fence will remain in place on the site as acknowledged in the technical questions
included with the Statement of Work. The local power company will remove the temporary spot
lights as well as the two separate electrical services on the site. All temporary telephone lines
that were installed during the mobilization of the site will be removed by the telephone company.
The McLaren/Hart crew will remove the temporary water line, as well as regrade the entire work
area to its preconstruction condition. The six inch depression created beneath the contaminated
soil stockpile will require the use of a portion of the treated soil to return to the area to the
surrounding elevation. With the approval of the OSC, McLaren/Hart has agreed to supply the
labor and equipment required to grade this area.
Any and all temporary signs and or other related accessories on the site that were installed by
McLaren/Hart will be removed from the site prior to closing the job.
The McLaren/Hart project manager will arrange a site walk with the OSC to confirm adequate
site closure prior to final demobilization.
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EXHIBIT A
I Site Layout Diagram
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■ MONITORING
WELL
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c;. '""Zl"'3-~\.•·~, .. -\~ ANr~~r_L
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[ __ GRAVr:;_ PARKING----, _______ ]
CHAIN NX. FEN "-'
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EXHIBIT B
Process Flow Diagram
-- - --
Cootaminale<I
Pesticide
Soil
' TT TT
LTTDS
Clean Soil
Qucnd,cd Soil
-- - -
Chiller
' C
T + 2-Stage
Condensing
r~ • l.
Storage Tank
20,000 gal.
Clean Waler Storage
Vessel (20,000 gal)
.
Reverse
Osmosis
System
--
T .
---- ---
Process Flow Diagram
Vacuum
Pump
T
T -T Thennocouple
+ -Vaamm Gauge
0 -Air flow Meler
ere Atirosph
'
I I Stack
Stand
c+o
Carbon filler
(Vapor Phas<e)
C -Continuous Emissions
Monitoring Equipment
Concentrated Waste
Pesticides
(55 gallon dmm)
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EXHIBIT C
Activated Carbon: Air Pollution Control Barrel
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I GENERAL CARBON CORPORATION
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THE GENERAL
Activated Carbon
Air Pollution Control Barrel
33 Paterson Street
Paterson, New Jersey 07501
Phone: [phone]
Fax: [phone]
The General is a low cost, self-contained activated carbon odor
control system designed to purify air streams of up to 100 CFM.
Specifications
-Dimensions: The General is a 55 gallon steel cannister, which has an
overall height of 35'' and an overall diameter of 23''.
-Carbon: 150 lbs. of pelletized or granular activated carbon.
-Flow rate: Up to 100 CFM.
-Cover: Removable with a bolt type closing ring and pally clad celluose
gasket.
-Connections: Both inlet and outlet are 2'' standard thread.
-Lining: The interior of the barrel is lined with heat and corrosive
resistant epoxy paint.
-Paint: The exterior of the barrel is painted with rust proof enamel.
-Weight: 200 lbs.
Installation
The General can be prepared for operation by using either hose connectior
or hard pipe. Connections are 2'' standard thread. The air inlet is
located 4'' from the base of the barrel. The air outlet is located on the
center of the lid.
Maintenance
Once connected, The General requires no maintenance other than the
monitoring of the influent and effluent air streams. Monitoring the air
stream into the last Air Pollution Control Barrel in series mode is a
recommended safeguard against a breakthrough in the final outflow. When
the concentration of contaminants in the outflow equals the concentratior
in the inflow, The General unit is completely saturated and will adsorb
no more. The life of The General is dependent upon the type of contamin-
ant in the air stream as well as its concentration and volume.
Re-charging The General
Once the activated carbon contained in a particular unit is saturated,
that carbon can either be removed and replaced with fresh carbon or be
reactivated and used again. To purchase the replacement carbon or arran,
for the spent carbon to be reactivated, contact us at our offices.
Disposal
Dispose of the spent activated carbon in accordance with Federal, State
and local regulations. Complete carbon reactivation services areavailab
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EXHIBIT D
Bio-Might MSDS Sheets
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FROM !Pc□ SAFETY PHONE NO. Oct. 27 1994 10:48AM P08
08-28--1882 15128 40<1 ~e 2601 ABAT~ TED-KLCXllE9
NFPA: FIR!i -0
t-tlALTH -t
A!ACTlVlTV -0
Hl!AlTH -1 "1.AMMAIILITV -0
REACTIVITY 0
PAtllt 1 OF ~
MA"l'l:'.fltAL 11AFI!'.TV PATA lilHEET • U. S, DEPARTMENT 01"' L.ADOR
CCMPLt~H WITH USDL SAFETY AND HEALTH RE~ULATlON5, <29 CFR 19JO. 12001
Sv.CT10N l
...... _
.I
ABATl!!l1ENT TECHNOLOQJES
8UITE II 160
·t70S BELLE MIUIDE. COURT
LAWRENCEVlLLE, Oill 30i?43
EMlfllOliNC_ l lil&I:. < 404 )-339-.!i!.OO
PRODUCT JDENTlr-JCATION
BIO-HIOBt 100
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INDUSTHIAL CLv.ANtR
~AL: l
REV16IDN DATE: 03/IJZ (I)
I •***********•***"""* ............................ ,._ .... 11 ...................... "*'II'********"
SECTION JJ :
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HAZARDOUS tNgREDIENTS TLV CPPl'II
l'SCDtlll'I tHLICATE SOL.UTION:· CHEM SILATl:l 46/i6 NOT APPLlCfllDLE
r1-1u, PRODUCT IS NOT A CARCINCQEN OR POTENTIAL. CARClNOOl'N AB l>EFXNED DV
OSHA, THE NTP, CR THE lAftC MONDQRAPHS.
SECTION .J l I : PHVSICAI. DATA
BOILXNQ POINI : ~o, DEGREES FAHRENHEIT
VAPOR PR!BRIIAE: NOT APPI.ICABI.E
VAPOR DENSIT~, (AIR111l) : NOT APPLJCADLE
SOLUBILITV JN WATiR: COMPLETE
BPECIPIC QRAVITY, (H~0•11 : 1,04
PERCENT VOLA1IL.E DY VOLUME: 85~
EVAPQRArION NATE, (WATERwll : < l
P H : t:J. u
APPEARANCE ANO ODOR : GREEN, CLEAN s1,e:I..LJNQ, CLEAR LIQUID
U~GTION IV: F1Ra AND KXPLOIION DATA
FLASH POtNT, (M!THOD USED): NO FLASH I BOIL., CC,C. l
FLAMMABLE LIMITS: NOT APPLICABLE
EXTINOUlSHTNo MEDIA : I) DRY CHEMICAL1 2) FOAl'l1 3) CO.!
SPECl~L FIREFIOHTINQ PROCEDURES: NONE
UNVl!IUAL I' J RI! AND EXPL.08 tON MA ZAR Dlt : NONE ~, ..
I FROM
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IPCO SAFETY PHONE NO. Oct. 27 1994 10:47AM P07
013-26--1882 15127 404 JJB 2601 ABA°IEl"ENT TE:a-N:l...OOIES
MATER: ,'II. 8Al'iTV l)ATA BHEET PAQI! l2 OF 2
···••·••···········•·+••·············································~····· . I
SECTHJN II : t,fAL TH HAZARD DATA .
THRtGHOLD LIMlT VALUE TLV HAS NOT BEEN ESTA8Lt8HCD, BOT IT IB EXPECTED
TO EXCEl!:D :ioo PPM. l'lASEP l1N TOX Icr.11 .. 001 CAL TE!ST
RESULTS, THIS CONCENTRATE IS CLABS!l'Il!O
Al: NCN-TOKIC BV ORAL lNQ~ST[CN1 IS NOT A
PRIMARY S~IN tRRlTANTI lS AN EVE ZnRJTANT,
EFFllC'fl!J OF OVER!?Xl"tlS\JRE_ CONT,:OCT WtTH IIYEi WXLL RI\SULT IN ll'!RtTATION.
PROLONGED CONTACT WITH SKIN MAV RESULT IN
IRRITATlON.
~MERQENCY FlRST AID PROCEPUR~B:
. 811.IN: FLUl!iH WtTH WATER.
tVE~• FL~SH WtTH WATER, IF IRRITATION PIHSISTS, CALL PHVfflCIAN.
INQESTlrlN· DFUIIIK I.ARQB VOLUMES OJ::' MILK on OTHER I.IQUil),. (Al.L
" . . PH'fl!IICIAN U111ED1ATELV ..
liECTlON YJ : REACTIVITY DATA
liTASll.ITV.UAIA: BTAOLE
INCOJ'1PATIDILITV : 13TRONQ AClOB ·
HAZARDOUS DECOMPOSITION PRODUCTS:. NONE
.• HAZARDOUS POLYMER [ZATION : WILL. NOT OCCUR . .
SECT?ON YII : SPZLL ON LlAK PROCEDURES
SMALL. SP l l.LJli :
LAROE l!IJIJLLl!I
WlPE UP P~ODUCT, RINSE SOIL!D AREA WITH WATER DOWN
TM£ DRA!N.
BTOP LEAK AT THE aoURC~ ANO COLLECT INTO A QUITABLE
CONTAIN!A, THEN TREAT AS A 6NAL.L SPILL.
POL.LOW STAT£ AND LOCAL "IQULATIONB FOR UIBPO~AL. OF L~ROE NON-RECLAIMABLE
SPILLS,
. 81!:CTION VI U : EIPS:ClAL PROTECTION INFORMAT10111
RESPIRATORY PROT~CTlON: NOT REGUIR20
VENT IL A'rlDJ\I : ME;;CHANICAL, <CENERALl
PRtlTECTXVF. OLOVES: FOR PROLONGED UB~
EVE PFI01'iCTICN: Bi\FETV QLABBEB WlTH StDE lilHTELl>B
OTHER PRUfiCTlVE EGU1PMENT, NONE R!GU[RED
S~CTXON IX; SPECIA~ PRICAUYIQN&
PR~CAUTtON8 TO BE TAKEN IN HANDLING AND BTORAOE:
ALWAVB STORE UNUSED PORTION IN ORIQINAL CONTAINMA WITH CAP SECURE,
AVOtO Tl-l'll-ll!RATUAI! ltXTIUIHl!lil. _ -~,_
OTHER l'RliCAU I I CNS ! , /
. AS WITH ALL. CHEMIC1'L81 UBI! WlTH DUE CAflli ACCOADllllG 10 LAllEL
lNBTRUC'tlCNl3 AND PRliCAUTtONB.
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PROJECT SCHEDULE
Farmers' Cooperative Exchange
Washington, NC
Contract No. 68-S4-4003
Prepared by:
McLaren/Hart Environmental Engineering Corporation
Great Woods Park
800 South Main Street
Mansfield, MA 02048
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1 1 ACTIVITY
1 NUMBER
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100 0
101 0
1020
1030
1040
1050
1060
1070
1080
109 0
1095
1097
1099
1 100
111 0
1 120
1 1 3 0
1 I 4 0
1 145
I 150
LS
OESCRIPTION
AWARD
EPA SITE ACCESS
DEMONSTRATION ~LAN
SAMPLING/ANALYSIS PLAN
PRO-JECT SCHEDULE
WORK PLAN
HEALTH & SAFETY PLAN
SOP MANUAL
EPA APPROVAL DEMO PLAN
MOBILIZATION/SETUP
DELIVER SYSTEM
SITE PREPARATION
STARTUP/SHAKEDOWN
DEMONSTRATION RUN
OPER. PARAMETERS SUBMISSION
NOTICE TO PROCEED
FULL SCALE TREATMENT
DEMOBILIZATION
SITE CLOSURE
FINAL REPORT
FLOAT
' 1 DE 5 C I I I
l. 6, MI LE STONE
~ CRITICAL I -PROGRESS
-PLANNED
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REM PCT EARLY
DUR CMP START
0 0 16SEP94
0
0
0
0
0
0
0
0
1 4
3
I 2
2
5
0
0
1 1 6
7
7
0
0 01 OCT94
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
140CT94
140CT94
140CT94
280CT94
280CT94
280CT94
14NOV94
2BNOV94
02DEC94
30NOV94
OSDEC94
12DEC94
27DEC94
31DEC94
OSJAN95
0 01 MAY95
0 08MAY95
0 31MAY95
EARLY
FINISH
15SEP94
3DSEP94
130CT94
130CT94
130CT94
270CT94
27DCT94
270CT94
13NOV94
11DEC94
04DEC94
11DEC94
060EC94
16DEC94
22DEC94
30DEC94
30APR95
07MAY95
14MAY95
30MAY95
, ........ ..
LATE LATE
START FINISH
16SEP 94 1 SSEP94
010CT94
140CT94
140CT 94
140CT94
280CT 94
2BOCT94
280CT94
14NOV94
28NOV94
07DEC94
30NOV94
10DEC94
12DEC94
27DEC94
31DEC94
OSJAN95
01MAY95
08MAY95
31MAY95
30SEP94
130CT94
130CT94
130CT94
270CT94
270CT94
270CT94
13NOV94
11DEC94
09DEC94
11 DEC94
11 DEC94
16DEC94
22DEC94
30DEC94
30APR95
07MAY95
14MAY95
30MAY95
MCLAREN/HART
ENVIRONMENTAL ENG. CORP.
NAT 'L REMEDIATION SERVICES
1994 1995
SEP iocT !Nov JAN If EB
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D, AWARD
D. EPA SITE ACCESS
D, DEMONSTRATION PLAN
D, SAMPLING/ANALYSIS PLAN
D. PROJECT SCHEDULE
WORK PLAN D,
D. HEALTH & SAFETY PLAN
SOP MANUAL D.
D. EPA APPROVAL DEMO PLAN
MOBILIZATION/SETUP ~
I DELIVER SYSTEM [}H
SITE PREPARATION ~
STARTUP/SHAKEDOWN [}-H
DEMONSTRATION RUN l§il
!MARCH !APRIL !MAY
D. □PER. PARAMETERS SUBMISSION
NOTICE TO PROCEED D.
FULL SCALE TREATMENT ~
DEMOBILIZATION ~
SITE CLOSURE ~
FINAL REPORT D.
RUN DATE 130CT94 BASELINE SCHEDULE
START DATE 165EP94 LOW TEMP THERMAL DESORPTION
DATA DATE 16SEP94 FARMER'S COOPERATIVE EXCHANGE
! FINISH DATE 30MAY95 WASHINGTON, NORTH CAROLINA
SURETRAK FCX Superfund SI le
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SAMPLING
and
ANALYSIS PLAN
Farmers' Cooperative Exchange
Washington, NC
Contract No. 68-S4-4003
Prepared by:
McLaren/Hart Environmental Engineering Corporation
Great Woods Park
800 South Main Street
Mansfield, MA 02048
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I TABLE OF CONTENTS
I 1.0 PROJECT DESCRIPTION
I 2.0 LEVEL of ANALYTICAL SUPPORT
3.0 PROJECT ORGANIZATION AND RESPONSIBILITY
I 3.1 Project Manager
3.2 Project Engineer
3.3 Site Safety Officer
I 3.4 Site Supervisor
3.5 Shift Leader
I 4.0 SAMPLING, FIELD MEASUREMENTS & ANALYTICAL PROCEDURES
4.1 Sampling & Field Measurement Procedures
4.1.1 Soil Sampling I 4.1.2 Sample Collection Protocol for Soils
4.1.3 Aqueous Sampling
I 4.1.4 Sample Collection Protocol for Liquids
) 4.1.5 Soil & Aqueous Quality Control Samples
4.1.6 Air Sampling
I 4.1.7 Decontamination
4.2 Sample Control Program
4.3 Analytical Procedures
I 5.0 QA OBJECTIVES FOR MEASUREMENT DATA
5.1 Data Accuracy and Precision
I 6.0 SAMPLE HANDLING, SHIPPING AND CUSTODY
6.1 Field Documentation
I 6.2 Sample Packaging and Shipment
6.3 Laboratory Documentaion
6.4 Project Documentation
I 7.0 EQUIPMENT CALIBRATION AND MAINTENANCE
7.1 Responsibility
I 7.2 Calibration
7.3 Preventative Maintenance
I 8.0 DATA REDUCTION, VALIDATION AND REPORTING
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9.0
9.1
10.0
10. 1
10.2
11.0
12.0
13.0
14.0
INTERNAL QUALITY CONTROL CHECKS
Laboratory Internal QC Checks
PERFORMANCE AND SYSTEM AUDITS
Laboratory Performance & System Audits
Field Team Performance & System Audits
PREVENTATIVE MAINTENANCE
PRECISION, ACCURACY AND COMPLETENESS OF DATA
CORRECTIVE ACTION
QUALITY ASSURANCE REPORTS TO MANAGEMENT
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Exhibit
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B
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SCHEDULE of EXHIBITS
Description
Table of Organization
Statement of Qualifications of Analytical Laboratory
Statement of Qualifications of Air Sampling Contrator
Specifications for Hydrocarbon Analyzer
Laboratory Method Detection Limits
Project Performance Audits
Example Chain-of-Custody Form
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1.0 PROJECT DESCRIPTION
The Sampling and Analysis Plan has been developed for the Farmers' Cooperative Exchange
(FCX) Project in Washington, North Carolina to describe the specific sampling and analysis
procedures which will be employed throughout the treatment operations. The plan has been'
prepared in accordance with the Statement of Work (SOW), OSWER Directive 9360.4-01,
Guidance for Removal Activities, Sampling QNQC Plan, and Data Validation Procedures (April
1990), EP N540/G-90/004, as well as The Environmental Compliance Branch Standard Operating
Procedures and Quality Assurance Manual, February I, 1991, US EPA Region IV, Environmental
Services Division.
The primary objective of the Sampling and Analysis Plan is to provide defensible quality data
which confirms treatment of contaminated soils in accordance with the SOW, specifically
sampling methods, analytical methods, QNQC samples, and calibration protocols.
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2.0 LEVEL OF ANALYTICAL SUPPORT
Level III Laboratory analysis using SW-846 methodologies and methods contained in U.S. EPA
"Methods for Chemical Analysis of Water and Waste," EPA-60014-79-020, 1983 and ASTM
methodologies (limited to geophysical matrices). This level is used primarily in support of
engineering studies using standard EPA approved procedures. Level III analytical support will
be employed for all soil, aqueous and air samples collected for characterization purposes.
Level I is defined as field screening. This level is characterized by the use of portable
instruments which can provide real-time data to assist in the optimization of sampling point
locations and provide support for health and safety. All routine air monitoring as discussed in
the "Sampling and Analysis Plan" will be conducted using Level I analytical support.
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3.0 PROJECT ORGANIZATION AND RESPONSIBILITY
The key personnel for the FCX project are illustrated in the Table of Organization, attached
hereto as Exhibit A. The individuals who are responsible for ensuring the collection of valid
measurements, data and routine assessment of measurement systems for precision and accuracy
include the Project Manager, Project Engineer, Site Safety Officer, and the Shift Foremen. The
responsibilities of the aforementioned personnel are described in the following sections.
3.1 Project Manager
The Project Manager will be responsible for the coordination and implementation of all
requirements outlined in the Statement of Work (SOW). The Project Manager will be responsible
for ensuring the completion of daily operating log reports, the submission of weekly update
summaries and the final report, as well as participating in all meetings with the Environmental
Protection Agency (EPA).
The Project Manager will also be responsible for adherence to project schedules; preparation of
weekly update summaries; development and monitoring of cost control measures; reviewing and
assessing the adequacy of the performance of technical staff and laboratory subcontractors;
maintaining full orderly project documentation; interacting with EPA throughout the progress of
the project; and managing project specific problems and issue resolutions.
3.2 Project Engineer
The Project Engineer will be responsible for implementing all QA/QC procedures in accordance
with the "Sampling and Analysis Plan". The Project Engineer will be responsible for ensuring
proper sample tracking, sample labeling, chain-of-custody completion and all sample reporting.
The Project Engineer will direct interaction with the Laboratory QA Officer to ensure proper QC
procedures and document reporting. The Project Engineer will assist the Project Manager in daily
activities and reporting procedures.
3.3 Site Safety Officer
The Site Safety Officer (SSO) will be responsible for ensuring the health and safety of personnel
and the surrounding environment. The SSO will be responsible for overseeing the proper
calibration, use, and recording of all monitoring equipment used on site. The SSO will be
responsible for ensuring that the proper sampling techniques be followed, as detailed in Section
4.0.
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3.4 Site Supervisor
The Site Supervisor will be responsible for all activities and personnel while the Project Manager,
Project Engineer and Site Safety Officer are not on site. The Site Supervisor will oversee the
treatment activities and will be responsible for ensuring the completion of the operating log.
3.5 Shift Leader
The Shift Leader will be responsible for overseemg the all team personnel during routine
treatment operations.
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4.0 SAMPLING, FIELD MEASUREMENTS AND ANALYTICAL PROCEDURES
Throughout the treatment process sampling and analysis will be performed to ensure that the
operations are in compliance with the contact specifications, as well as to insure the health and
safety of personnel and the surrounding environment.
4.1 Sampling and Field Measurement Procedures
4.1.1 Soil Sampling
Soil sampling and analysis procedures shall be undertaken throughout the demonstration of the
treatment system as well as throughout the full-scale treatment process. Prior to mobilization,.
the work area will be sampled to determine the pre-existing conditions of the work area before
any soil handling. Prior to the commencement of the demonstration, a composite sample of the·
"representative contaminant mass" will be obtained and will be analyzed for total pesticides (EPA
Method 8080), Dioxins, Furans, semi-volatile organic compounds, total RCRA metals and TCLP
metals to determine the level of existing contamination. Throughout the operations of the
demonstration and full-scale treatment, processed soils will be stockpiled in the treated soils
staging areas for sampling. Sampling and analysis will verify that the processed soils are in
compliance with the treatment standards as detailed in the Statement of Work (SOW). Upon
confirmation from the laboratory certifying a level equal to or less than I mg/kg, the treated soil
will be moved to the clean soil stockpile outside the work area in a location to be determined by
the on-scene EPA Representative. Any soils not meeting the treatment objective of total pesticide
concentration less than or equal to 1.0 mg/kg will be retreated in the L TTDS. The qualifications
of the contracted analytical laboratory are attached hereto as Exhibit B.
Pre-Mobilization Sampling
Prior to the mobilization of equipment to the FCX site, a dozer will be utilized to· strip the top
layer of vegetation and topsoil, if applicable, from the designated work area. Five (5) composite
samples will be obtained and analyzed to determine the present soil conditions of the work area.
Demonstration Test Sampling
Pre-treatment Sampling
Prior to the commencement of the demonstration of the treatment system, one composite sample
will be obtained from the "representative contaminant mass", in accordance with the
"Demonstration Plan", and analyzed for the following parameters: total pesticides, Dioxins,
Furans, semi-volatile organic compounds, total RCRA metals, and TCLP metals. The analytical
results shall be utilized as comparison to the data which will be obtained at the completion of the
demonstration test.
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Initial Sampling
The initial runs of the demonstration test will be utilized to develop a uniform treatment protocol
for the remaining treatment process. In order to determine the optimum treatment temperature,
the temperatures of the first two batches of soil will be brought to 350 and 400 degrees
Fahrenheit, upon which a composite sample will be obtained and will be analyzed for total
pesticides. These results will determine the optimum operating temperature of the system for
treating the site specific soils. The remaining 90 cubic yards of soil will be treated following
receipt of the initial sampling results.
Post Treatment Sampling
After processing a minimum of I 00 cubic yards of soil, one composite sample will be obtained
from the treated stockpile for analysis to verify the ability of the L TTDS to achieve the clean-up
objectives as defined in the SOW. The sample will be analyzed for total pesticides (EPA Method
8080), Dioxins, Furans, Semi-volatile organic compounds, total RCRA Metals and TCLP Metals
in accordance with the demonstration plan.
Full-Scale Treatment Sampling
Throughout the full-scale treatment process, the treated soils will be sampled and analyzed to
verify that the clean-up objectives have been achieved. Three composite samples will be obtained
· from the treated stockpile either every 500 tons or on a daily basis and will be analyzed to
determine the total pesticide concentration using EPA Method 8080 organo chloride Pesticides
and PCB's.
Project Completion
Upon completion of the treatment of the total volume of contaminated waster and prior to the
demobilization of the site, the work area will be sampled to verify that no contamination occurred
to the area while handling the contaminated soils. The work area will be sectioned off into 300
square foot grids, one (1) composite sample will be obtained per 300 square foot grid throughout
work area and will be analyzed for total pesticides using EPA Method 8080. Any area from
which the concentration of the sample is found to be greater than the pre-mobilization conditions
or 1 mg/kg, whichever is greater, will be processed through the L TTDS.
4.1.2 Sample Collection Protocol for Soils
All soil sampling and analysis executed throughout the treatment process will be in compliance
with OSWER Directive 9360.4-01, Guidance for Removal Activities, Sampling QA/QC Plan and
Data Validation Procedures (April 1990), EP A/540/G-90/004, and The Environmental Compliance
Branch Standard Operating Procedures and Quality Assurance Manual, February 1, 1991, US
EPA Region IV, Environmental Services Division.
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) A stainless steel hand auger or trowel will be used to obtain each composite sample. In turn,
each sample will be placed in an eight (8) ounce glass jar equipped with a teflon lined lid. The
sample will be labeled to include the following information: sample number; sample name; date
of collection; analysis to be performed and name of site. The sample will then be placed on ice
and held at 4 degrees Celsius for transport to the laboratory with a chain-of-custody. All
sampling equipment will be decontaminated between samples using an alconox scrub followed
by two organic free water rinses.
4.1.3 Aqueous Sampling
The aqueous materials that are separated from the reverse osmosis (RO) unit will be stored in a
21,000 gallon temporary wastewater storage tank as designated in the site plan. Upon reaching
75 percent capacity, one representative water sample will be obtained from the storage tank and
will be analyzed for total pesticides using EPA Method 8080. No additional water will be added
to the storage tank until the tank is confirmed clean and is emptied. The clean water will be
utilized as dust control throughout the work area and the surrounding areas as needed.
4.1.4 Sample Protocol for Liquids
Aqueous samples will be obtained by lowering a decontaminated teflon or stainless steel bailer
into the tank. The aqueous material will then be transferred from the bailer directly into the
laboratory prepared glassware. The sample jar will be labeled to include the following
information: sample number; sample name; date of collection; analysis to be performed; and
name of site. The sample will then be placed on ice for transport to the laboratory with a chain-
of-custody.
4.1.5 Soil and Aqueous Quality Control Samples
It is anticipated that McLaren/Hart will receive up to two each blank and/or spike samples from
the EPA for analysis. The these samples will be analyzed by the contracted laboratory at no
additional cost to the government. The EPA also has the right to obtain split samples at their
discretion.
4.1.6 Air Sampling
In order to evaluate the operation of the L TTDS as well as to insure the safety of the surrounding ·
environment, the emissions from the vapor phase carbon treatment system will be monitored for
target compounds. Various control monitoring procedures shall be undertaken throughout the
treatment process to confirm that the emissions of the system are in compliance with the
performance requirement outlined in the Statement of Work. Stack sampling, continuous
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emissions monitoring and ambient air monitoring will demonstrate the ability of the condensers
and the carbon units to effectively achieve the treatment criteria required in the contract
specifications.
Stack Sampling
A one time Stack Air Monitoring demonstration test will be performed during the demonstration
of the L TTD System by a qualified air sampling contractor in accordance with the Demonstration
Plan. In accordance with modified Method 5 sampling train, the test shall san1ple for HCL,
particulates, volatile and semi-volatile organic compounds, total pesticides (EPA Method 8080),
dioxins and furans. Triangle Laboratories, an approved laboratory, will be performing the
sampling analyses for the dioxin and furan air sampling. The stack sampling will be performed
during one (I) continuous treatment run involving all four (4) treatment chambers containing a
cumulative soil volume of approximately 20 cubic yards. Moisture and gas volume shall also be
determined during the stack sampling. Information regarding the qualifications of the air
sampling contractor is attached hereto as Exhibit C.
Continuous Emissions Monitoring
Throughout the duration of the treatment process, the emissions from the stack stand will be
monitored on a continuous basis for total hydrocarbons and percent concentration of oxygen.
Total hydrocarbon emissions will be monitored using an Eagle Model EM-700 Partially Heated
Total Hydrocarbon Analyzer in accordance with EPA Method 25. The specifications regarding
the EM-700 Analyzer are attached hereto as Exhibit D. The percent concentration of oxygen
within the treatment will be monitored using a Cole-Porter oxygen meter, model No. 0550-10.
to ensure a non-oxidative environment(< 5% oxygen).
Fugitive Emissions
In order to insure the health and safety of personnel implementing the treatment process as well
as the surrounding environment, the defined work area and location downwind from the work
areas will be continuously monitored for fugitive emissions, specifically the concentration of dust.
A personnel, continuous air sampler, real time aerosol air monitor (mini RAM) will be utilized
to record the concentration of dust. Any reading exceeding the permissible exposure limit (PEL)
detailed in the Health and Safety Plan (HASP) will result in an immediate cessation of operations
as well as the implementation of engineering and controls to mitigate the generation of fugitive
dust emissions. The primary means of dust suppression will be the addition of moisture to the
soil.
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4.1. 7 Decontamination
All sampling equipment will be decontaminated using the following general procedure:
• Liquinox wash
• Tap water rinse
• Distilled water rinse
• Air dry
4.2 Sample Control Program
All activities related to the collection, handling, and analysis of samples must be documented in
order to defend the integrity of the sample and its subsequent analysis. Proper custody
procedures will provide descriptions for sample and container traceability throughout the sampling
and analysis performed at the FCX site. A chain-of-custody will be maintained for each sample
collected at the FCX site. The protocol set forth in USEPA SW-846 concerning chain of custody
procedures will be followed.
Chain-of-custody for sample receipt and handling begins at the time of the sample collection at
FCX. In order to insure proper documentation of the samples collected at the site, each sample
container will be labeled to include the following information: sample number; sample name;
date and time of collection; analysis to be performed and name of site. A chain-of-custody form
will be completed entailing the aforementioned information as well as the signature of the
collector and any noted irregularities. This form will accompany the appropriately preserved
samples to the laboratory and will be retained as part of the permanent study records.
Additionally, a Laboratory Record Book (LRB) shall be maintained at the site to record all
sampling activities.
At the time of sampling in the field, a sample log sheet will be used to document the exact
location, required preservation method, and the time and date of sample acquisition. Labels will
be attached to each sample container at the time of collection. All the information necessary for
proper identification and analysis will be included on these forms. A sample coordinator will be
assigned the responsibility of signing for incoming samples, collecting and retaining the proper
shipping documents and verifying that all data is entered correctly on the chain-of-custody
records.
From the time that the sample is received at the laboratory through the analysis and reporting
results, comprehensive laboratory records will be maintained to ensure proper identification of
all samples. All analytical procedures will be documented and referenced in the Laboratory
Record Book. Any deviations from written procedures will be documented to include the reason
for the deviation, corrective action taken to prevent future deviations as required, and an
assessment of the effects of the deviation in an interpretation of the results.
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4.3 Analytical Procedures
Level III analytical support will be performed m accordance with U.S. EPA SW-846
methodologies for all laboratory analyses.
Example reporting formats and laboratory quality assurance protocols are outlined in the
Analytical Quality Assurance Program (AQAP) and Standard Operating Procedures (SOP)
attached hereto. The AQAP and the SOP's have been provided by the independent laboratory
which has been contracted to perform the analytical work for the remedial activity at FCX.
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5.0 QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT DATA
The overall quality assurance objective is to develop and implement procedures for field
sampling, chain-of-custody reporting, field analysis, laboratory analysis and reporting. The
specific procedures which will be used for sampling, chain-of-custody reporting, calibration, field
and laboratory analysis, reporting, internal quality control, audits, preventative maintenance and
corrective actions are described in other sections of this Sampling and Analysis Plan. The
premiere characteristics of quality measurement data are precision, accuracy, completeness, and
representivity.
5.1 Data Accuracy and Precision
Accuracy is the degree of a measurement with an accepted reference or true value. Analytical
accuracy is determined by comparing the analysis results of surrogates, matrix spikes, or check
standards to their known values. Every sample that is analyzed is spiked with compounds
(surrogates) which behave both chemically and physically like target compounds. The percent
recoveries of all the sample and blank surrogates are reported as a measure of the accuracy of
the method. Percent recovery of matrix spike compounds or check standards can also be used
to assess accuracy for most analities.
Precision is a measure of mutual agreement among individual measurements of the same property.
Precision is measured by analyzing field duplicates and laboratory duplicate samples. The
relative percent difference (RPO) of duplicate measurements can be used to evaluate analytical
precision. Both spike recovery and RPO can be reported from the analysis of matrix spike and
matrix spike duplicate samples (MS/MSO).
The referenced EPA analytical methods cite prec1s10n control limits or give guidance to
establishing precision control limits. Control limits are typically generated from multiple analyses
and inter-laboratory comparison studies. Control limits are method, compound, and matrix
dependent. Specific accuracy and precision goals are attached hereto as Exhibit E.
Laboratory and project QC officers will review all laboratory data to ensure completeness. In
the event that corrective actions must be undertaken to achieve a complete data set, re-analysis,
re-extraction, and/or re-sampling may be necessary.
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6.0 SAMPLE HANDLING, SHIPPING AND CUSTODY
6.1 Field Documentation
Following sampling, the sealed sample containers will be rinsed with tap water, dried and labeled.
The sample labels will include, at a minimum, the following information:
• Matrix
• Sample ID Number
• Sample Location
• Name of Sampling Personnel
• Name of Sampling Organization
• Date and Time Sampled
• Type of Preservative (if any)
• Analysis to be Performed
Sample labels shall be completed in waterproof ink and covered in clear tape. Following
labeling, the sample containers will be placed in a sealed clear plastic zip-lock type bag and
placed in a cooler ( or laboratory supplied sample shuttle) for storage and shipment. Ice will be
placed in each cooler and cushioned with vermiculite foam rubber or other similar packaging
material to maintain all samples at 4 degrees Celsius.
Chain-of-custody forms will be maintained throughout the sample collection and the transport
activities. The chain-of-custody procedures will provide accurate written records which can be
used to trace the possessions and holding of samples from the time of collection through the data
analysis and reporting. The following information will be specified for each sample on the chain-
of-custody form: sequential sample number; sample matrix; sample date and time; sample
location and analysis requested. The chain-of-custody will be fully documented in accordance
with EPA protocols. An example chain-of-custody form is attached hereto as Exhibit G.
The chain-of-custody form will be signed by each member of the field team who takes custody
of the associated samples. The forms will be placed in a water tight plastic bag and will be taped
to the underside of the cooler's lid, or sample shuttle, accompanying the appropriate samples.
A signed and dated custody seal will be placed on the cooler after the lid of the cooler has been
securely taped shut.
Field log books and data sheet, as discussed in Section 4.2, will be utilized to record all data
collection activities. The field log books, which will be bound field survey notebooks will be
assigned to field personnel and will be stored in the project file when not in use. Each log book
will be identified by a project and will contain a title page including the following information:
person or organization to whom the book is assigned; the book number; project name and start
and end dates.
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Measurements made and samples collected will be recorded in the field log books or on data
sheets as detailed in the "Sampling and Analysis Plan". All entries will be made in waterproof
ink and no erasures will be made. If an incorrect entry is made, the information will be crossed
out with a single strike mark and initialed. A detailed description of the sample location will be
recorded when a sample is collected or a measurement is made. The log book will document the
use of, the calibration dates, the operators, and maintenance of all monitoring equipment. The
number and description of any photographs will also be documented. A summary of field
activities will be recorded in the log, referencing any data sheet measurements.
6.2 Sample Packaging and Shipment
All collected samples will be transported to the contract laboratory via overnight delivery.
Sample shipments will be in accordance with DOT and IA TA regulations governing the shipment
of hazardous waste. These regulations describe proper marking, labeling, packaging, and
shipment of hazardous materials, substances and wastes.
6.3 Laboratory Documentation
The laboratory which will be performing the sampling analysis will provide all the sample bottles,
labels, chain-of-custody forms, preservatives and shipping containers required for the project. All
sample bottles shall be properly cleaned and prepared laboratory prior to use.
Upon arrival at the laboratory, samples will be registered by the laboratory representative and the
pH of the sample will be recorded if appropriate. The chain-of-custody forms will be compared
to the samples in the shipping container to verify proper documentation and sample receipt.
Sample custody within the laboratory includes:
• Identification of the sample custodian at the laboratory facility, who is the responsible
party authorized to sign for incoming samples, obtain documents of shipment and verify
the data included on the sample custody records.
• Provision for a laboratory sample custody log consisting of standard lab-tracking report
sheets, which will be serially numbered.
• Specifications oflaboratory sample custody procedures for sample handling, storage and
distribution for analysis.
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6.4 Project Documentation
A project file which will contain complete project documentation will be maintained by the
Project Manager. This file will include: project plans and specifications; field log books and
data records; photographs; maps and drawings; sample identification documents; chain-of-custody
records; the entire laboratory analytical data package, including QC documentation; copies of raw
data computer printouts; gas chromatograms; mass spectra; data validation notes; references and
literature; report notes and calculations; progress and technical reports; correspondence; and other
pertinent information.
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7.0 EQUIPMENT CALIBRATION AND MAINTENANCE
A maintenance, calibration and operation program is implemented to ensure that routine
calibration and maintenance is performed on all field instruments. The program provides
instruments of the proper type, range accuracy, and precision to provide data compatible with the
specified requirements and desired results. Calibration of measuring and testing instruments is
performed internally using in-house reference standards or externally by agencies or
manufacturers.
7.1 Responsibility
The Project Manager,Project Engineer and Site Safety Officer are responsible for ensuring that
the field instruments used in the investigations are calibrated and maintained in accordance with
the manufacturer's specifications. Field instrument instruction manuals describing calibration,
maintenance and field operating procedures will be maintained at the site by the Project Manager,
Project Engineer and Site Safety Officer for easy reference by field personnel.
Team members will be familiar with the field calibrations, operation and maintenance of the
instruments, and will perform the prescribed field operating procedures outlined in the operation
and field manuals accompanying the respective instruments. All field instrument calibrations and
field checks will be documented in the field log books.
7.2 Calibration
Instruction manuals detailing the calibration schedules and the calibration procedures for the
instruments will be maintained by the Project Manger, Project Engineer and Site Safety Officer
at the site. Records of equipment calibration and maintenance will be prepared and maintained
to verify that the established calibration procedures have been followed (ie. results of calibration,
problems, corrective action).
Instruments that fail calibration or become inoperable during use will be removed from service
and tagged to prevent inadvertent use. In the event that on-site monitoring equipment should fail,
the Site Safety Officer will be immediately contacted and will either provide replacement
equipment or ensure that the malfunction is immediately repaired.
7.3 Preventative Maintenance
Periodic preventative maintenance is required for sensitive instruments. Instrument manuals will
be kept on file for reference purposes should the equipment need repair. The trouble shooting
sections of the manuals can often be referred to when performing maintenance tasks.
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8.0 DATA REDUCTION, VALIDATION AND REPORTING
The analytical laboratory will review the appropriate quality control data to assure the validity
of the analytical results. The analytical laboratory will prepare and retain full analytical
documentation and QC documentation as indicated in the AQAP. A hard copy of such
documentation will not necessarily be supplied, but all information will be retained in other
storage media, such as magnetic tape. The analytical laboratory will supply one hard copy of the
analytical and QC documentation to the contractor, which will in turn be submitted to the EPA.
The analytical laboratory will provide the following information in each of the submitted
analytical data packages:
• Analytical test methods and results for submitted samples, with appropriate data quality
notations.
• Narrative including statement of samples received, description of any deviation from the
plan, explanation of qualifications regarding data quality and other significant items
encountered during analysis.
• A QNQC report including:
organic parameters
• surrogate spike results for each sample
• matrix spike and matrix spike duplicate results
• method blank results
• continuing calibration data
• GC/MS tuning and mass calibration
inorganic parameters
• spike and duplicate results
• method blank results
• verification results
• laboratory control sample results
Data assessment will be accomplished by the joint efforts of the Project Manager and the Project
Engineer. The data assessment by the Project Manager will be based on the criteria that the
sample was properly collected and handled in accordance with the "Sampling and Analysis Plan".
The Project Engineer will conduct a systematic review of the data for compliance with the
established QA/QC criteria based on the spike, duplicate and blank results provided by the
laboratory. An evaluation of data accuracy, precision, and completeness will be performed and
presented in the final report.
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The project Engineer will identify any out-of-control data points or data omissions and interact
with the laboratory to correct the data efficiencies. Decisions to repeat sample collection and
analyses may be made by the project manager based on the deficiencies and their importance in
the overall context of the project.
The Project Engineer will provide data validation for I 00 % of the analyses performed by the
laboratory in accordance with OSWER Directive 9360.4-01, Guidance for Removal Activities,
Sampling QA/QC Plan, and Data Validation Procedures, EP A/540/G-90/004, to determine the
data usability.
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9.0 INTERNAL QUALITY CONTROL CHECKS
9.1 Laboratory Internal QC Checks
An independent laboratory with a documented Quality Assurance Program will be selected to
perform the sampling analyses. Inorganic and organic testing will be performed in accordance
with the most recent testing procedures. There are two methodologies used under the SW-846
to ensure the production of analytical data of known and documented usable quality: 1)
analytical method quality control (QC); and, 2) program quality assurance (QA).
It will be the responsibility of the Laboratory QA Officer to ensure that each data package
documents that both initial and ongoing instrument and analytical QC functions have been met.
Any analyzed samples that are found to not be in conformance with QC criteria will be re~
analyzed by the laboratory, upon receipt of sufficient sample volume.
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10.0 PERFORMANCE AND SYSTEM AUDITS
10.1 Laboratory Performance and Systems Audits
The laboratory that is contracted to perform the analytical work will conduct internal quality
control checks (replicates, spikes, and duplicates) in accordance with specific methods and criteria
required under SW-846. Procedures for laboratory performance and system audits are outlined
in the laboratory's Analytical Quality Assurance Program (AQAP), which is attached hereto. The
Laboratory QA Officer will be primarily responsible for conducting these audits.
10.2 Field Team Performance and Systems Audits
The Project Engineer will be responsible for conducting performance audits to evaluate the
implementation of the project QA program and to ensure that proper project documentation is
maintained. These audits will focus on the details of the QA program by surveying project
responsibilities, sample custody procedures, document control, sample identification system, and
QC corrective action procedures. Examples of the performance audit are attached hereto as
Exhibit F.
11.0 PREVENTATIVE MAINTENANCE
A copy of the maintenance and calibration manuals will be maintained by the Project Engineer
for easy access at the site. Preventative maintenance procedures for laboratory instruments will
be provided in the Analytical Quality Assurance Plan (AQAP). The AQAP will be provided by
the contract laboratory performing the analytical work for the remediation activities.
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12.0 PRECISION, ACCURACY AND COMPLETENESS OF DATA
The procedures for assessing the precision, accuracy and completeness of data analysis are
detailed in Sections 5.1 and 5.2. It will be the responsibility of the Project Manager/Project
Engineer to ensure that these procedures are followed.
Precision is determined by the comparison of duplicates, where duplicates result from an original
sample that has been split for identical analyses. The determination of accuracy of a
measurement requires a knowledge of true or accepted value for the analyte being measured.
Completeness is determined in regards to precision and accuracy. To be considered complete,
the data set must contain QC check analysis verifying precision and accuracy for the analytical
protocol. Less obvious is whether the data are sufficient to achieve the goals of the project. Data
are reviewed in terms of goals in order to determine if the database is sufficient.
The equations used to assess accuracy, precision and completeness are detailed in the laboratory's
Analytical Quality Assurance Program and Standard Operating Procedure manuals which are
attached hereto.
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13.0 CORRECTIVE ACTION
Any need for corrective action in regards to the soil remediation activities will be handled by the
Project Manager. The Project Manager, with assistance from the other team member, will
determine the new protocols that should be followed. All alterations in field procedures will be
documented in the field log book and will be documented in the final report.
Corrective actions will be taken if performance audits reveal the need to amend field procedures.
Corrective actions will also be initiated if the results of other quality assurance activities, such
as system audits and quality assurance program audits, prove actions necessary. The Site Safety
Officer, upon consultation with the Project Manager, will have the ultimate authority to make
decisions regarding modifications to health and safety practices and safety emergencies. The EPA
will be notified of any such field decisions or corrective actions that result in modifications the
protocols outline in any of the project plans (ie. "Sampling and Analysis Plan, Health and Safety
Plan).
Laboratory corrective actions will be implemented when accuracy, precision, calibration or other
internal method specific quality assurance criteria are not met. The laboratory will be informed
in the event that there is a need for corrective actions and will take the appropriate actions to
remedy the situation. In the event that any split, blind, or spike sample analyses demonstrates
that the laboratory is not in compliance with the Sampling and Analysis protocol referenced in
the Statement of Work, corrective actions will be taken to rectify any discrepancies. All changes
in laboratory procedures will be documented in the final report.
14.0 QUALITY ASSURANCE REPORTS TO MANAGEMENT
Throughout the treatment process, an operating log will be maintained which will record the
performance of the L TTDS unit, specifically quantities of treated waste and the operating
temperature of the soils. Brief written weekly update summaries shall be provided to the EPA
reviewing the treatment system progress and unreported sampling and analysis activities. Upon
completing the treatment of the total volume of contaminated waste at the FCX site (14,700 cubic
yards) a final report will be generated summarizing the amount of waste treated, the overall
performance of the system, and the project operating log.
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SITE HEALTH
and
SAFETY PLAN
Farmers' Cooperative Exchange
Washington, NC
Contract No, 68-S4-4003
Prepared by:
McLaren/Hart Environmental Engineering Corporation
Great Woods Park
800 South Main Street
Mansfield, MA 02048
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MG@ren® -·HatE
ENVIRONMENTAL ENGINEER/NG CORPORATION
October 28, 1994
Mr. Paul R. Peronard
Onsite Coordinator
Emergency Response and Removal Branch (4WD-ERRB)
USEP A Region IV
345 Courtland Street NE
Atlanta, Georgia 30365
Re: Contract 68-S4-4003
FCX Site
Health & Safety Plan
Dear Mr. Peronard:
Pursuant to the Statement of Work (SOW), please find enclosed a site specific Health and Safety
Plan (HASP) for the aforementioned project. Please note that this plan is transmitted without the
signature of the Certified Industrial Hygienist for this project, Mr. Brian Delmonte. Regretfully,
Mr. Delmonte was unavailable this week to make final review of the HASP. As soon as possible,
Mr Delmonte will complete his review and forward to you a completed signature page. Also note
that this plan has been reviewed and attested to by Mr. D'Eufemia, Mr.Wallace, Mr. Walsh, Mr.
Robinson and myself.
Please call me if you have any questions at [phone].
Very truly yours,
McLAREN/HART ENVIRONMENTAL ENGINEERING CORPORATION
Daniel Sullivan
Project Manager·
National Remediation Services Group
enclosures
cc: E. Walsh
file
Great Woods Park, 800 South Main Street, Mansfield, MA02048 [phone] FAX [phone]
0 rncycJodpap,Y
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CLIENT:
SITE NAME:
MG1arm1 --H§ft-
EPA Region IV
Farmers Cooperative Exchange (FCX)
PROJECT/TASK ID#: 20.0802179.001
SITE ADDRESS: Grimes Road
Washington, North Carolina
DATE: October 25, 1994
I PLAN EXPIRATION DATE:
HASP APPROVALS:
PROJECT MANAGER Dan Sullivan
Name
Ill REVIEW Bryan Del Monte, C.I.H.
Name
SITE SAFETY omcER To be detennined
Name
ALTERNATE
SITE SAFETY OFFICER Danny Wallace
Name
FCX-Washington
Site Name
HEALTH AND SAFETY PLAN
~
Signature
Signature Date
1,1/47,,f:J ,
Signature Date
Bary lJJ1w a 1;;;,. I?.,_ J L q:f. F I
Signature Date
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HEALTH AND SAFETY
MANAGER ~e11:.t~ y&,& Henry Robinson
N.une
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10:30 FPOM· McLAREN/HART
CLIENT: EPA Rc1ion JV
SITENAM£: Fltllletll Coopenlivc Ell (FCX)
PROJECTfl'ASK II»': 20,080'2179,001
SITE ADDRFSS: Grimm lload
Wllhin1-, Nonh Can>lma
DATI:: ~ll, 1994
I Pl.AN EXPIRATION DATE:
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HASP APPROVALS:
PROJECT MANAG£Jl
DI REVIEW
SJTE SAFETY omcu
ALTERNATE
SITE SAn:TY OfflCER
HE4L TN 41'10 SAn:TY
MANAGER
0-Sullivan
Bryann.!Mmit., .LH.
NMM
To be dlwmlBld
N-
Panny Wal!Ke
NIIIIC
8..-y'Ralll-
N-
l'iU.i:J'-tJ
10. 11'1116218677 PAQE 2
ECX-Wolhioslon
Site NlfflC
HEALTII AND SAFETY PLAN
Sipatz...,
Slpature
Slpatat
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TABLE OF CONTENTS
EXECUTIVE SUMJ\,IARY ............................................ .
SECTION 1.0 GENERAL INFORMATION ......................... .
Introduction, Site Personnel, Authorized Subcontractor Site Personnel, Signature
and Acknowledgement, Medical Surveillance
SECTION 2.0 PROJECT INFORMATION ................... .
Site Description, Background Information, Purpose of Site Work, Scope of Work,
Scheduled Dates of Site Work
SECTION 3.0 HEALTH AND SAFETY RISK ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Hazard Analysis, Non-Chemical Hazard Summary, Site Contaminant(s) and Data,
Chemical Hazard Summary
SECTION 4.0 HEALTH AND SAFETY FIELD IMPLEMENTATION
PPE, Monitoring Equipment Requirements, Site Zones/Delineation, Site Communication
II
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SECTION 5.0 SITE OPERATING PROCEDURES ................................... 19'
Initial Site Entry Procedures, Daily Operating Procedures, Additional Site-Specific
Operating Procedures, Decontamination Procedures, Procedures for Waste Handling of Anticipated Wastes
SECTION 6.0 EMERGENCY RESPONSE PROCEDURES ............................. 23
Emergency Response Planning, Lines of Authority, Emergency Procedures, Emergency Telephone Numbers,
Hospital Route Map, Spill Control
SECTION 7.0 RECORDKEEPING ..................... 27
LIST OF TABLES
TABLE 1-1 Personnel Responsibilities and Qualifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
TABLE 1-2 McLaren/Hart Staff Training Summary .................................... 4
TABLE 1-3 Subcontractor Training Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
TABLE 3-1 Assessment of Non-Chemical Hazards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
TABLE 3-2 Known and/or Probable Contaminants . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
TABLE 3-3 Assessment of Chemical Hazards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
TABLE 4-1 Personal Protective Equipment (PPE) Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
TABLE 4-2 Monitoring Protocols and Contaminant Action Levels . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
LIST OF ATTACHMENTS
ATTACHMENT 1 Site Maps(s)
ATTACHMENT 2 Utility Clearance Check and Utilities Location Map
ATTACHMENT 3 Direct Reading Report and Instrument Calibration Log
ATTACHMENT 4 Initial Mobilization Health and Safety Checklist
ATTACHMENT 5 Tailgate Safety Meeting Form
ATTACHMENT 6 Project Manager/Field Supervisor Jobsite Safety Checklist, HS 5-1
ATTACHMENT 7 Additional Health & Safety Protocols
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1.1 INTRODUCTION
SECTION 1.0
GENERAL INFORMATION
This Health and Safety Plan (HASP) addresses those activities associated with the scope of work stated in the HASP
and will be implemented by the Site Safety Officer (SSO) during site work. Compliance with this HASP is required
of all persons and third parties who enter this site. Assistance in implementing this plan can be obtained from the
Site Safety Officer and Project Manager, and/or the Health and Safety Manager (HSM). The content of this HASP
may change or undergo revision based upon additional information made available to health and safety (H&S)
personnel, monitoring results or changes in the scope of work. Any changes proposed must be reviewed by H&S
staff and are subject to approval by the HSM and Project Manager.
This HASP bas been written for the use of McLaren/Hart and its employees. It may also be used as a guidance
document by properly trained and experienced McLaren/Hart subcontractors. However, McLaren/Hart does not
guarantee the health or safety of any person entering this site.
Due to the potentially hazardous nature of this site and the activity occurring thereon, it is not possible to discover,
evaluate, and provide protection for all possible hazards which may be encountered. Strict adherence to the health
and safety guidelines set forth herein will reduce, but not eliminate, the potential for injury at this site. The health
and safety guidelines in this HASP were prepared specifically for this site and should not be used on any other site
without prior research by trained health and safety specialists.
McLaren/Hart claims no responsibility for the use of this HASP by unauthorized persons. The HASP is written
for the specific site conditions, purpose, dates, and personnel specified and must be amended if these conditions
change.
--- ---------------1.2 KEY PERSONNEL
TABLE 1-1
PERSONNEL RESPONSIBlLITIES AND QUALIFICATIONS
Project Manager • Reports to upper-level
Dan Sullivan
Site Safety
Officer/
Alternate Site
Safety Officer
Michael
D'Eufemia
management.
• Has authority to <lirect
response operations.
• Assumes total control over
site activities.
• Advises the Field
Supervisor on all aspects of
health and safety on-site.
• Recommends stopping
work if any operations
threaten worker or public
health or safety.
• Pr~pares and organizes the background review
of the job at hand, the Work Plan, the Health
and Safety Plan, and the field team.
• Obtains permission for site access and
coordinates activities with appropriate officials.
• Ensures that the work plan is completed and on
schedule.
• Briefs the field teams on their specific
assignments.
• Uses the Site Safety Officer to ensure that
safety and health requirements are met.
• Prepares the final report and support files on
the response activities.
• Serves as the liaison with public officials.
• Coordinates safety and health program
activities.
• Conducts Tailgate Safety Meetings and
completes all documentation forms required by
the Health and Safety Plan.
• Monitors site personnel for signs of stress, such
as cold exposure, heat stress and fatigue.
• Monitors on-site hazards and conditions.
• Participates in preparation of and implements
the Health and Safety Plan.
• Ensures that protective clothing and equipment
are properly stored and maintained.
• Knows emergency procedures, evacuation
routes, and the telephone numbers of the
ambulance, local hospital, poison control
center, fire and police department.
• Notifies, when necessary, local public
emergency officials.
• Coordinates emergency medical care.
• 40-hr. Hazardous Waste Training
including 8-hr. update (29 CFR
1910.120)
• 8-hr. Manager/Supervisor Hazardous
Waste Training (29 CFR 1910.120)
• Respirator use training (if on-site work)
• Initial HASP review
• Initial site specific (if on-site)
• Daily site specific "Tailgate" (if on-site)
• Special
• Medical surveillance participant (if on-
site work)
• 40-hr. Hazardous Waste Training
including 8-hr. update (29 CFR
1910.120)
• Respirator use training
• Initial HASP review
• Daily review of site conditions
• Special
• Medical surveillance participant
-
-l!!!!!!I l!!!!!!!!!!I !!!!!I l!!!!I 1111111 == iiiii iiii - - --PERSONNEL RESPONSIBILITIES AND QUALIFICATIONS
Project Engineer • Reports to Project
Nannette Orr
management.
• Site management in absence
of Project Manager.
• Implementation of on-site
Quality Assurance/Quality
Control (QA/QC) and
QA/QC documentation
Field Supervisor • Responsible for field team
operations and safety.
Danny Wallace
• Reports to Project
Justin Huffman Manager.
Team Members • Reports to Field
Supervisor.
To be • Contains at least two
determined people.
• For ,!rilling purposes,
Team Members consist of a
geologist, drilling foreman
and helpers.
• Participates in the preparation and submission
of reporting requirements.
• Ensures the implementation of proper QA/QC
procedures for all sampling and analysis.
• Participates in the preparation of the weekly
reports and final reports.
• Manages field operations.
• Executes the Work Plan and schedule.
• Enforces safety procedures
• Coordinates with the Site Safety Officer in
determining protection level.
• Enforces site control.
• Documents field activities and sample
collection.
• Serves as liaison with public officials.
• Safely completes the on-site tasks required to
fulfill the Work Plan.
• Complies with Health and Safety Plan.
• Notifies the Site Safety Officer or Field
Supervisor of unsafe conditions
··•••i••?···g•.·•IIBQlJIREQTRAININ(;.·•·,\Jl/])••••••·•••·t·•·•·•·••
·••H••> I•·· ]llEl.)ICAi.:SQiiVEfi.:i!ANQE p•······
• 40-hr. Hazardous Waste Training
including 8-hr. update (29 CFR
1910.120)
• 8-hr. Manager/Supervisor Hazardous
Waste Training (29 CFR l9!0.120)
• Respirator use training (if on-site work)
• Daily site specific "Tailgate" (if on-site)
• Special
• M~ical surveillance participant (if on-
site work)
• CPR/FA training
• 40-hr. Hazardous Waste Training
including 8-hr. update (29 CFR
1910.120)
• 8-hr. Manager/Supervisor Hazardous
Waste Training (29 CFR l9!0.120)
• Respirator use training.
• Initial HASP review
• Initial site specific
• Daily site specific "Tailgate"
• Special
• Medical surveillance participant
• 40-hr. Hazardous Waste Training
including 8-hr. update (29 CFR
1910.120)
• Respirator use training.
• Initial site specific
• Daily site specific "Tailgate"
• Special
• Medical surveillance participant
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1.3 AUTHORIZED McLAREN/HART SITE PERSONNEL(To be completed prior to the
commencement of Site activities)
Personnel authorized to enter the subject site while operations are being conducted must be approved by the HSM. Authorization requires confirmation of conformance with OSHA 29 CFR 1910.120 training and medical examination requirements, participate in McLaren/Hart's drug free workplace program, and/or other applicable regulations. All personnel must review/sign-off of this HASP, utilize the buddy system,
or trained escort, and check-in with the Field Supervisor upon arrival on-site.
TABLE 1-2
Name McLaren/Hart Staff Training Summary
Medical Site Initial Refresher Respirator Fit Additional Exam Supervisors Training Training Test and
Training Training
1.4 AUTHORIZED SUBCONTRACTOR SITE PERSONNEL (To be completed as required)
Subcontractor personnel authorized to enter the site while operations are being conducted must be approved by the Project Manager. Authorization will involve completion of appropriate training courses and medical
examination requirements as required by OSHA 29 CFR 1910.120, 8 CCR 5192 and/or other applicable
regulations and review of this HASP. All personnel must utilize the buddy system, or trained escort, and
check-in with the Field Supervisor upon arrival on-site.
TABLE 1-3
Name SubcontractorTraining Summary
Medical Site Initial Refresher Respirator Fit Additional Exam Supervisors Training Training Test and Training Training
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1.5 SIGNATURE AND ACKNOWLEDGEMENT SITE NAl'vlE:FCX-Washington
All McLaren/Hart personnel, and their subcontractors, working at or visiting the site (beyond the Support
Zone) must acknowledge by signing below that the contents of this HASP have been reviewed with them.
All personnel acknowledge that they participate in a medical surveillance program and have been trained
in accordance with 29 CFR 1910. 120 (OSHA's Hazardous Waste Operations and Emergency Response
standa.rd). Each person agrees that he/she has read and understands this HASP and agrees to comply with
the policies and procedures set forth herein.
I Name I Signature I Representing I Date I
1.
2.
3.
4.
5.
6.
7.
8.
9.
10
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
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1.6 MEDICAL SURVEILLANCE
McLaren/Hart personnel, and subcontractors, working at the site will participate in a medical surveillance
program which meets the requirements of 29 CFR 1910. 120. McLaren/Hart's medical surveillance
program is outlined in Health and Safety Policy HS 10, Medical Surveillance Program.
Employees working at hazardous waste sites are provided with pre-employment, annual and termination
medical examinations to ensure that they are medically fit to perform work and wear personal protective
equipment (PPE). The scope of the medical exams includes a physical examination, audiometric testing,
pulmonary function testing, visual testing, blood testing and urinalysis. The results of the examinations
are confidential. Employees are provided with medical certificates and employees and their supervisors
are informed of any restrictions or limitations.
Employees requesting access to their medical records should contact the Health and Safety Manager.
6
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SECTION 2.0
PROJECT INFORMATION
2.1 SITE DESCRIPTION (site features; current site status; site contamination)
The FCX site is located on Grimes Road, Washington, Beaufort County, North Carolina just
immediately inside the city limits of Washington (Figures I and 2 -Attachment I: Site Maps). The
area is lightly populated, with roughly 600 residents living within a one-mile radius of the site.
The site lies in the North Carolina Plain. Surface water from the site drains toward the Kennedy
Creek, which lies approximately 800 feet southwest. Kennedy Creek is a tributary of the Tar River
which flows to the Pamlico River, splitting Beaufort Cou~ty nearly in half travelling 33 miles to
Pamlico Sound. Wetlands and marsh lie within 300 feet of the areas of contamination.
The site covers approximately 12 acres and includes five potentially affected or "source" areas, as
defined by the RI (Figure 3 -Attachment I: Site Maps). Currently, there are both residential units
and commercial businesses located on the site. Approximately 11,000 residents, many on private
wells, reside within three miles of the site. One single family dwelling is located adjacent to the site,
but is connected to the municipal water system.
The site is bound on the northeast by Grimes Road. Agricultural land surrounds the west side and Mt.
Pleasant Canal, a drainage ditch leading to Kennedy Creek lies to the southeast.
See Attachmem I for Sile Map(s)
2.2 BACKGROUND INFORMATION {historical, continued operations, adjacent site contamination)
The FCX Site facility operated from 1945 until the early 1980's as a pesticide storage and blending
facility for distribution to local farmers. The pesticides most prevalent at the Site consisted of the
chlorinated organic pesticides chlordane, methoxychlor, DDT and DDE and various other chlorinated
and non-chlorinated organic chemicals used to mix the pesticides.
The Site was permanently closed and the buildings and warehouses were cleaned out. The majority
of the property was sold to Fred Webb Grain for use as a grain storage facility. During operations
as FXC, the facility routinely buried expired and waste pesticides in on-site disposal trenches. Prior
to the closing of the facility, residual waste, including pesticides and contaminated debris were also
buried in a trench on-site. The trenches were located between the warehouse ( currently leased by Fred
Webb Grain to a trucking company) and the Tar River. The Site is generally open and readily
accessible to the public.
The trenches were located approximately 100 feet east of the grain warehouse. The trenches and
storage area are bordered on the three other sides by farmland which is not owned or controlled by
Fred Webb Grain. Immediately behind the narrow section of farmland is a woodland swamp and the
Tar River.
FCX Washington has been ranked as an NPL Site based upon the potential for possible groundwater
and surface water migration. The NPL Score is 40.39 which resulted in the ranking of the site as
number 449 on the list. See 40 Code of Federal Regulations Part 300, Appendix B, Group 9.
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2.3 PURPOSE OF SlTE WORK
The EPA Region IV is currently undertaking Removal Actions to abate an immediate threat to human
health and the environment at the FXC-Washington Site. The site is currently listed on the Agency's
National Priorities List (NPL), and is currently undergoing a Remedial Investigation/Feasibility Study
(RI/FS). As part of the on-going removal activities, EPA Region IV plans to initiate the on-site
treatment of approximately 14,700 cubic yards of soils contaminated with waste pesticides and
contaminated pesticide soils debris. Of the 14,700 cubic yards of soil, approximately 3,000 cubic
yards was bagged into 1,774 one-ton bags, each holding approximately 1.75 cubic yards, and placed
inside the old FXC warehouse building.
The waste will be treated using a high vacuum Low Temperature Thermal Desorption System
(LTIDS). The LTIDS is a batch treatment system that is capable of desorbing contaminants under
a non-oxidative atmosphere and low temperature such that the desorbed contaminates do not degrade
and generate thermal or oxidative by-products.
2.4 SCOPE OF WORK (BY JOB TASK IN ORDER OF EXECUTION)
I. The Site will he prepared for L TTDS operation. This will include: establishing site command
post, site security, work areas/exclusion zones, decontamination reduction areas; decontamination
facilities, etc.; installation of the required utilities; set-up of the LITDS (including associated air
pollution control systems; and set-up of soil handling systems.
2. A demonstration test will he conducted to confirm that the L TTDS is effective: The
demonstration plan will consist of at least 100 cubic yards of the waste material. This
demonstration will prove that the air pollution control systems function properly and that the waste
clean-up levels can be met.
3. After approval is received from the EPA, soil treatment will commence. This will consist of
all soil handling and soil treatment operations as well as the handling of all residual waste streams.
After the soil is treated it will be stockpiled on-site for sampling to insure compliance with the
treatment standards. In addition, all process residuals and non-treated material will be properly
disposed.
4. Once the soils/material are determined to meet compliance standards1 they will be transported to
a location where the EPA will remove the soils/material from the site.
5. When soil treatment is concluded. the site will be demobilized. This will include: the
decontamination and removal of all treatment systems from the site; the removal of all site utilities,
foundations, or other site modifications; and site restoration.
* Tasks to be performed by subcontractor(s) under McLaren/Hart supervision.
2.5 SCHEDULED DATES OF SITE WORK
The Site workplans will be delivered to the EPA on October 28, 1995. After the EPA approves the
workplans, the site mobilization will begin (Task I) and a demonstration test (Task 2) will be
conducted within 45 days. All site activities must be complete, according to the contract, within 480
days.
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SECTION 3.0
HEALTH AND SAFETY RISK ANALYSIS
3.1 HAZARD ANALYSIS
Non-chemical ha,.ards may be associated with:
I. Underground electrical, gas and water lines: All utility clearances will be performed when intrusive activity (excavation) is conducted or as required. In addition, all temporary utilities will be marked and mapped so that they are easily identified.
2. Overhead/above ground utilities: A minimum of20 feet will be maintained from all existing overhead utilities. The removal of any above ground utility will be conducted as specified in the Construction Specification.
3. Excavation Equipment, Heavy Equipment, and associated machinerv: Remedial construction will require the use of heavy equipment. The OSHA guidelines as specified in the CFR 29 1910.126 will be followed when operating all heavy equipment.
4. Heat Stress: The LTTDS generates heat during the soil treatment process. This radiant heat load in
combination with personnel activity and personnel protective equipment may result in a heat stress condition. All personnel will be thoroughly briefed on the signs, symptoms, monitoring and treatment of beat stress, and the heat stress precautions will be followed as outlined in Attachment 7 which
describes the signs, symptoms, and monitoring procedures to prevent heat stress.
5. Cold Stress: Soil treatment activities will be conducted during cold months (i.e., winter). As with heat stress, all personnel will be thoroughly briefed on the signs, symptoms, personnel monitoring
procedures, and treatment of cold stress as outlined in Attachment 7.
6. Oxygen Deficient/enriched: Oxygen deficient and/or enriched environments may be encounter in the excavations or other confined spaces (i.e., containment tanks). Air monitoring will be conducted to determine oxygen concentrations in the excavations and any other area where an oxygen deficient or enriched environment may be encountered.
7. Confined Space Entry: Entry into tanks may be required for cleaning/decontamination. A confined space entry pennit, checklist, and air monitoring plan is presented in Attachment II.
8. Noise: Hearing protection, including ear plugs and ear muffs, will be worn if the TWA noise levels from machinery is greater than 80 dB. (Note: as a rule of thumb, ear plugs should be worn if you
cannot have a normal conversation without raising your voice above the background noise level.)
Noise monitoring will be conducted in the work zone and at the site perimeter as described in the Construction Specifications. background noise monitoring will also be conducted prior to work activities. If noise levels at the site perimeter are greater than 10 dB above background, engineering
controls will be initiated.
9. Fire: Fire prevention procedures as outlined by the National Fire Prevention Agency (NFPA) and local fire departments. Specifically, fire extinguisher will be located in all on-site buildings and trailers and placed in readily accessible locations in the work areas. In addition, any hot work to be conducted will follow NFPA guidelines and McLaren/Hart policy.
10. Explosive Atmospheres: Explosive atmospheres may be encountered in excavations, confined spaces, and storage areas. Explosivity air monitoring will be conducted before entry is allowed in any of these
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areas and as required based on site activities and the potential for the generation of explosive
atmospheres.
I I. Biological: Ticks, insects and rodents may be encountered. The best protection is adequate skin
pro1tection (i.e., long sleeve shirt and pants).
12. Uneven terrain, holes, excavations, ditches: These areas will be identified and barricaded to prevent
personnel from entering or not seeing these hazards.
13. Overhead Hazards: Hard hats will be worn at all times due to overhead hazards from heavy
equipment.
14. !jg!1ting: During the soil treatment, some work will be performed at night. All work areas will be
well lighted, and dark areas will be off limits.
15. Heavy Lifting: Heavy manual lifting of supplies and other equipment may cause back injury.
16. Low Temperature Thermal Desomtion System (L TTDS): Hot Surfaces, moving parts, and electrical
power: Physical hazards associated with the operation of the L TTDS include: burns, lost limbs, and
electrocution.
17. Traffic: The operation of heavy equipment and vehicle traffic. Site control will include a traffic
control.
18. We:i1ther: The SSO and/or field supervisor will decide on the continuation or discontinuation of work
based on current and pending weather conditions. Electrical storms, tornado warnings, strong winds,
and heavy rainfall are examples of conditions that would call for the discontinuance of work and
evacuation of the site. A telephone will be available on site to enable easy access to weather service
information.
Chemical hazards may be associated with:
In 1986, the North Carolina Department of Human Resources (NCDHR) collected surface soil samples
at the site. This data indicated that chlorinated pesticides (Aldrin, Chlordane, DDT, DDE) and
mercury (one sample) were present in the area of the trenches.
Removal data indicated that the chlorinated pesticides are the most prevalent and widespread in the
trenches. Additional soil samples did not detect mercury which was present in one NCDHR soil
sample. However, additional compounds included DDD, Dieldrin, Heptachlor, Heptachlor Epoxide,
Methoxychlor, and Total BHC's.
The overall ha,,1rd is:
___ Low _X __ Moderate __ High
3.2 NON-CHEMICAL HAZARD SUMMARY
See Table 3-1 for summary assessment of non-chemical hazards.
3.3 SITE CONTAMINANT SOURCE(S) AND DATA
See Table 3-2 for list of known/probable comami11a11ts and/or applicable analytical data reports.
3.4 CHEMICAL HAZARD SUMMARY
See Table 3-3 for summary assessment of chemical hazards.
10
- -- - --- -- ----- - ----
TABLE 3-1
ASSESSMENT OF NON-CHEMICAL HAZARDS
(Hawrd mitigation is discussed in Section 5 for each "Yes" response)
i.1wtij0;r R -····•''•••i··~~ ·••l!tfl¥1I I .... ·cc. . •··. !rt ..
: •·· Ii . ii
I. Electrical X 1-5 16. Shoring X
(overhead lines)
2. Electrical X 1-5 17. Biologic X 1-5
(underground lines)
3. Gas/Water lines X 1-5 18. Holes/Ditches X 1-5
4. Drilling Equipment X 19. Steep Grades X
5. Excavation Equipment X 2-4 20. Slippery Surfaces X
6. Machinery X 1-5 21. Uneven Terrain X 1-5
7. Heat Exposure X 2-4 22. Unstable Surfaces X
8. Cold Exposure X 1-5 23. Elevated Surfaces X 1-5
(scaffolding)
9. Oxygen Deficiency X 24. Lighting X 1-5
IO. Confined Spaces X 5 25. Vehicle Traffic X 1-5
11. Noise X 1-5 26. Insects/vermin X 1-5
12. Ionizing Radiation X 27. Poisonous Plants X 1-5
13. Non-ionizing X 28. Lifting X 1-5
Radiation
14. Fire X 29. Weather X 1-5
15. Explosive Atmospheres 1-5 30.
11
- -- - --
Contaminant
Aldrin
Chlordane
DDT, DDE
Chlordane
DDD
Dieldrin
Heptachlor and Heptachlor Epoxide
Methoxychlor
Source of data: USEPA Request for Proposal
Date of sampling: 1986 and l 992
--- - ---- - ----
TABLE 3-2
KNOWN AND/OR PROBABLE CONTAMINANTS*
Source of Contaminate Sample Type Concentration Range
(mg/kg)
Former FCX Operations Soil 27 -1,585
Former FCX Operations Soil 1.0 -50
Former FCX Operations Soil 1.0 -19,435
Former FCX Operations Soil/Debris 1.0 -6,629
Former FCX Operations Soil/Debris 1.0 -500
Former FCX Operations Soil/Debris 1.0 -47
Former FCX Operations Soil/Debris 1.0 -79
Former FCX Operations Soil/Debris 1.0-<130
12
- - -- --- ---- ----
2-4
2-4
2-4
2-4
1-5
PEL
TLV
§I!a!,
TLV•STEL
£
!Qill
IT!:! voe
u
TABLE 3-3
ASSESSMENT OF CHEMICAL HAZARDS
Aldrin 0.25/0.25 IDLH l00 mg/m3 Inhalation; Head, dizzy, nausea,
mg/m3 absorption; vomit, coma
Ingestion; Contact
Chlordane 0.510.5 None cited Inhalation; Skin, GI &
mg/m3 Ingestion; respiratory irritation;
Dermal tremors & convulsions
DDT 1.0 mg/m3 N.E. Inhalation; Paresthesia tongue, lips
Absorption; and face; tremor;
Ingestion; Contact dizzy; confused;
headache
Dieldrin 0.25/0.25 IDLH 450 mg/m3 Inhalation; Head, dizzy, nausea,
mg/m3 absorption; vomit, coma
Ingestion; Contact
Diesel None cited None cited Inhalation; dermal; Possible skin &
ingestion respiratory irritation;
CNS depression
-OSIIA PecfTIU.'l,ible faposure Limit; rcprucnt,i th: maximum allOWtOble 8-hr. time ...,,jghto:I avcnig:e (fW A) ecxpc'll!lute C<.'.IOC'Cnlnition.
-ACGIH Thrclhokl Limit Value; rcpre!ClllJ th: maximum ~n&:d 8-hr. lWA uposu:,: con,;cntnlion.
.. OSHA Short-term Exposure Limit; rcpl'Cllml5 th: maximum 11!0'\Wblc: 1.5 minute lWA exposure ,;:,:;,ncxnt,-Lion.
.,. ACGIH Short-term ExP""ure Limit; re~ th: maximi= rccommadod 1.5 minuic, lWA ecxpoourc <'<JnClCntnlion.
.. OSIIA C.dlin,: Limit; ~ th: ma:dmum co,.:pc,,urc C'<;lf101:nlr.1tion abovt:: -,hkh 111 ecmpl<l'J'CC ,hall not be u:.po8Cd durini ll!l)' p,:ri«I ..-ilhout rr.apiratory pr,::i1«1ion.
• ln:n:diately Dangc:rou,, to Life llOO lleahh; rcpresenu th: a;nc:cm,-1ion II ..-hich one could be ecxpo8Cd for 30 minutu ._;thro\ up,:ricnring ecscap,:-impairint or irrevc,-ible i'eallh dfoclll.
• Total Petroleum llydrocarb:.ns
• Volatile Organic ~
• ACGUI TLV lri1cnrd O,ani<=
13
- ---
Carcinogenic;
Myoclonic jerks of
limbs; clonic, tonic;
Convulsions
Liver, kidney &
respiratory damage;
dermatitis, suspected
human carcinogen
Carcinogen: CNS;
liver; kidney; skin;
PNS
CNS; liver; kidneys
and skin
Possible respiratory
irritation; dermatitis
--- --- -- --- ----
't,i.;1c••··
N~'.is)
. ·:::·::=::.:.:
1-5
2-4
1-5
2-4
ill
ill
Ell
TLV-STEL
£
!Q!:!!
ill! voe
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TABLE 3-3
ASSESSMENT OF CHEMICAL HAZARDS
'I h. } ,, _,o, ;;..•( ~~ i\, lit /b1ii;;;1,~i~~~~\
··•-1••········•·/i'., .. -... _ ····· }t1 •:~ L, ,:.:_:::::
t•r·••••• ~·· .. :, 1,} ? . i. .1::. . .. _: ._.·•-• . , i{i ....... I .. / ),->••···· 'i.i.' f·/ r-:>· ... f,i)
Gasoline 300/300 ppm STEL = 500 ppm Inhalation; dermal;
ingestion
Heptachlor 0.5/0.5 mg/m3 700 mg/m3 Inhalation;
Absorption;
Ingestion; Contact
Hydraulic oil None cited None cited Inhalation; dermal;
ingestion
Nitric acid 2/2 ppm STEL = 4 ppm Inhalation; dermal;
ingestion
OSIIA Permi,,ible ExP'-"'U!'C Limit; rcp~~nu I}-., maximum 1llowablc 8-lv. time "'-cig.htod avcng.e (TWA) e:<.posUl'C concentration.
ACGIII Thr=hold Limit V1Jue; rcp=nu the muimum ~ 8-lv. TWA exposw-c c,oncentnlion.
,. OSHA Short-term Expo<1U!'C Limit; rcprc-'Cnts LJ-., maximum allowable (5 minute TWA expo11u:c rono:ntnlion.
ACGIII Short-term ExposU!'C Limit; rcpre.-ocnts the rnuimum rccanrr,::ndc,d IS minute 1'-VA exposure ~mration.
•••••I I I
,u
~-i.
Eye, skin & respiratory
irritant; CNS
depression
In animals: tremors,
convulsion and liver
damage
Possible skin &
respiratory irritation;
CNS depression
Eye, skin & respiratory
irritation; pulmonary
edema; pneumonitis;
eye & skin bums
Note: strong oxidizer
in concentrated form
OSHA Ceiling. Limit; rcprc....,nU the rnuimum expo:,ure c,oncentntion above which an employ= shall noc be Cl(po,,od dUfini any period without =pintory prolc-Clion.
lmmedialcly Dang.emu, to Life an:! Health; rcpre9Cf"IU the concentration al which one could be Cl(po,,od for 30 mim.iles without expcricncing. cscapc·Uilf"'irint or irreversible t>:alth crTccu.
T(l(a] Petroleum Hydroo11bon,
Volatile Orianic C~
= ACGIII TLV ul\er"rlo:I Qanic
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i . > / ···•.· .... . ([f([j f·•···
Possible liver &
kidney damage;
dermatitis
Carcinogen
Possible respiratory
irritation; dermatitis
Dermatitis
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SECTION 4.0
HEALTH AND SAFETY FIELD IMPLEMENTATION
4.1 PERSONAL PROTECTIVE EQUIPMENT (PPE) REQUIREMENTS
PPE may be upgraded or downgraded by the site industrial hygienist, HSM, or qualified Site Safety Officer based upon site conditions and air monitoring results. Reference to required PPE will be by Level of Protection (A-D). A summarized description of PPE by level of protection is indicated below:
LEVEL A -This level of PPE should be worn when the highest level of respiratory, skin and eye protection is needed and includes: Self-contained breathing apparatus (SCBA) or supplied
air respirator (SAR) with escape SCBA; totally-encapsulating suit; chemical-resistant boots
and gloves~ two-way radio communications.
LEVEL B -This level of PPE should be worn when the highest level of respiratory protection is needed, but a lesser level of skin protection than level A. Level B is the primary choice
when encountering unknown environments and includes: SCBA or SAR with escape SCBA; hard-hat; steel-toe boots, chemical-resistant suit, overboots, gloves.
LEVEL C -This level of PPE should be worn when the criteria for using air-purifying respirators are met and a lesser level of skin protection is needed. Level C PPE includes: Air purifying respirator (APR) (half or full face); hard-hat; safety glasses (with half-face APR); steel-toe
boots; chemical resistant suit, overboots, gloves
LEVEL D -This level of PPE should be worn only as a work uniform and not in any area with respiratory or skin hazards. Level D PPE provides minimal protection against chemical
hazards and includes: Coveralls or standard work clothes, steel-toe boots, work gloves; safety glasses
See Table 4-1 for specific PPE requiremellls.
4.2 MONITORING EQUIPMENT REQUIREMENTS
Monitoring is conducted by the Site Safety Officer or <lesignee. Conduct contaminant source monitoring initially. Complete breathing zone monitoring if source concentrations are near or above contaminant action level concentrations. Log direct reading monitoring and record results on Direct Reading Report form. Calibrate monitoring instruments daily or in accordance with manufacturers' specifications. Record calibration data on the Instrument Calibration Log.
Results shall be interpreted by the Site Safety Officer. At a minimum, exposures to suspected chemicals of contamination, as defined in this HASP, should be monitored prior to and during intrusive field activities. Additional characterization monitoring shall begin immediately if the operation destabilizes, the
environment changes, or the potential for exposure is otherwise affected. Monitoring should continue on a continuous basis until the operation is stable and the SSO or HSM feels that the monitoring is sufficient to adequately assess and characterize exposure during that operation.
See Table 4-2 for mo11itori11g protocols and comaminam action levels.
See Attachment 3 for Direct Reading Report and lnstrumem Calibration Log.
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- - -- -- - - ------ -
TABLE 4-1
PERSONAL PROTECTIVE EQUIPMENT (PPE) REQUIREMENTS
1,5 D C
2-4 C B
2-4 B Work Stoppage
1 Pn-tonaJ Prvltcilvr Equlpmtt1I {l'PE):
SUIT:
Sid = Sw'liard .,wk cl~
Tyvek • Uncoal.:d Tyvd: disl""'abk =rall
PE Tyvek = PolycUl)·l.:ni:·C011tod Tyvck
Ch:mri:I -0-.:mrcl coverall with hood
Sann::.x ., ~ran.,,,;.J.o.mi:,.ai.:d Tyvck
Lt PVC • LlVJI "'1. PVC n.in&ear
Mod PVC = Medium ,.,,_ PVC 1W1
llvy PVC = Heavy v.1. PVC coverall v.:ith hood
Roiod -Rooidwork Ye.51
GLOVES:
W01k -Work tiOYc.1 {canvas, lcatkr)
Noo .. Ncoprcn: ,1(1','C.S
PVC • PVC 11<.,vca
N = Ni1rik &l<NU
V -Vi11yl cl=
L • Latc.:1 cl=
Std Work
Tyvek N/Work
Saranex N/Work
1 Pnwnal Protedh~ Equlpmffll (PPE):
FEET:
Si.ecl -Si.:cl-toc boots
S1o:el + • Steel-toe PVC boots
Bootic:11 • PVC boot.ii:.
HEAD:
1111 .. Hardhat
EYE:
Gb.» = Safety cW.u
Gouk "'Gau~
Shield = F•oc 1hio:Jd
EAR:
Plup = Earplup
Mull = Ear muff
Steel
Steel+
Steel+
HH Glasses if noise
>80 dBA
HH NA if noise
>80 dBA
HH NA if noise
>80 dBA
1 Pcnonal Prolectlw Equlpmml (PPE):
RESPIRATOR:
APR • Air purifyioi ~pin.tor
Full APR "' Full f1,;e APR
Half APR "' Half f1,;,e APR
PAPR .. Powcn:d Air Pwifyin& ~piratot
SAR • Aitl~ 1upplio:d 1ir n,spin.tor
SCBA • Self conta~ brulhin& app,1111.t,..
£,ape ~ E,cape SCBA
OV .. Organic Vapor cartridge
AG • Acid iu c:artridic
OV/AG z. Organic vapor/Acid iu c:artridge
AM • Ammonia cartridic
DIM • Dust/mist pre-filter and rover for Cilrtridie
IIEPA -Hic}I. efficiency i:-rticula\C air filler cartri:lic
OTHER:
• = Uic if contact with wet soil or water
--Optiq,a] u.,c except if 1pccific, bu.I.rd p"'9Cnl
- -
NA
Full Face APR
with OV/HEPA
SCBA or SAR
COMMENTS: PPE may be uperaded or downgraded based on air monitoring and/or McLaren/Hart HSM or CIH advise. For Tasks 2-4,
PPE will initially be Level C. Ear plugs should be worn when operating heavy equipment and/or when noise levels are greater
than 80 dBA.
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- - - --
2-4 Dusts
----- ---TABLE 4-2
MONITORING PROTOCOLS AND CONTAMINANT ACTION LEVELS
MiniRam Monitoring to establish
background, work activity,
and upwind/Downwind Dust
concentrations in the
breathing zone and at the
source
5 mg/m3
- ----
IO mg/m3
COMMENTS: I) The dust concentration action level for respiratory protection is based on the highest concentration of chlorinated pesticide
reported in the USEPA Request for Proposal (DDT at 19,435 mg/kg), a DDT PEL of 1.0 mg/m3, and a safety factor
of 10 as follows:
Equation:
(% DDT) x (dust action level mg/m3) = (DDT PEL) x (safety factor)
% DDT
Dust action level
PEL
safety factor
19,835 ppm or 1.98%
5.0 mg/m3
1.0 mg/m3
IO
(0.0198) x (Dust action level mg/m3) = (1.0 mg/m3) x (1/10)
Dust action level mg/m3 = (1.0 mg/m3) x (1/10) / 0.0198
Dust action level mg/m3 = 5.0 mg/m3
• Mmitorin& performed at opcr1tor'1 bn:.alhin& zono:.
-Call ttt. hcic:ml Hi:.ahb and Safety MaNger for QOOSultatim.
PlD • Pba.oiaiilitia::i Dcicctor {]!NU, TIP, OVM)
FID -Flanz J<nWltim Dctcd.or (OVA)
LEL • Lo•,u Exp!ooi-.e Limit; reptCKlll.s lb: minimum coo;,rotn,.tj,n of oombunibk vapor in air that MU ipitc, if an ipition 1"'"1«C is ~ (explUIC<I in " by volume:).
LEL-02 • LEL &rd Oxyp M..i.:r
CT -Colorim:.ctic Gu Detector Tub::
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4.3 SITE ZONES/DELINEATION
Exclusion Zone:
_X_ Areas within barricades, cones and/or caution tape
__ Within 40-ft radius of drill rig operations
_X_ Within 40-ft radius of heavy equipment operations
_X_ Within 10-ft radius of hand auguring location
_X_ Within 10-ft radius of groundwater monitoring well locations
_X_ Other (describe): As delineated by site security
Contamination Reduction Zone: At perimeter of Exclusion Zone.
Support Zone: Outside of Contamination Reduction Zone.
4.4 SITE COMMUNICATION
_X_ By two way radio
_X_ By telephone
_X_ By pager
__ By other means (describe): Hand signals to be determined during the Tailgate Safety Meeting.
4.5 SITE SECURITY
_X_ Restricted access
___x_ Fenced
Security guard
Other means (describe):
To be decided during site mobilization, in conjunction with the EPA, and as required by
the specific work task.
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SECTION 5.0
SITE OPERATING PROCEDURES
5.1 INITIAL SITE ENTRY PROCEDURES
•
•
•
•
Review Initial Health and Safety Mobilization Checklist (Attachment 4).
Locate nearest available telephone. lodicate location on Site Map .
Determine wind direction, establish hotline, and set up decontamination facilities. Note wind
direction and location of decontamination facilities on site map.
Post Emergencv Information Confirm/post emergency phone numbers and hospital route .
• Designate at least one vehicle for emergency use.
•
•
•
If toilet facilities are not located within a 5-minute walk from the decontamination facilities,
either provide a chemical toilet and hand washing facilities or have a vehicle available (not the
emergency vehicle) for transport to nearby facilities.
Prior to working on-site, conduct an inspection for physical and chemical hazards .
Conduct or review utility clearance prior to start of work, if appropriate.
• Note any specialized protocols particular to work tasks associated with the project.
5.2 DAILY OPERATING PROCEDURES
•
•
•
•
•
•
•
Hold daily Tailgate Safety Meetings prior to work start.
See Attachme/11 5 for Tailgate Safery Meeting Form.
Conduct air monitoring and follow designated protocol and contaminant action levels .
Use personal protective equipment (PPE) as specified .
Remain upwind of operations and airborne contaminants, if possible .
Establish a work/rest regime when ambient temperatures and protective clothing create a
potential heat stress hazard.
Do not carry cigarettes, gum, etc. into contaminated areas .
Refer to Site Safety Officer for specific concerns for each individual site task .
• USE BUDDY SYSTEM WHERE APPROPRIATE.
•
•
Be alert to your own physical condition. Watch buddy for signs of fatigue, exposure, etc .
All accidents, no matter how minor, must be reported immediately to the SSO .
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•
•
•
•
Contain liquids and cuttings generated during drilling .
Limit contaminants contact with clean equipment.
Design work activities in order to practice contamination avoidance both on-and off-site .
Apply immediate first aid to any and all cuts, scratches, abrasions, etc .
5.3 UTILITY CLEARANCE
Date to be performed:~A~s~r~eg~u~i~re~d~---------------
Will be performed by following personnel: McLaren/Hart, Client. and/or building owner
Method that will be utilized: As built drawings or appropriate utilitv company representative
Follow utility clearance requirements specified in Attachment 2.
5.4 ADDITIONAL SITE-SPECIFIC OPERATING PROCEDURES
Add appropriate prowcols unique to this job. (This section will stand alone to point our special measures unique to work at this site.) Procedures for Penni! Required Con.fined Space Entry Work and Excavation Work can be mentioned here. All non-chemical hazards described in Section 3-1 should have precautions
specified for mitigation.
5.5 DECONTAMINATION PROCEDURES
Depending on the specific job task, decontamination may include personnel theillSelves, sampling equipment, and/or heavy equipment. The specified level of protection for a task (A. B, C, or D) does not in itself define the extent of personal protection or equipment decontamination. For instance, Level C without dermal hazards will require less decontamination than Level C with dermal hazards. And. heavy equipment will always require decontamination to prevent cross-contamination of samples and/or facilities.
The following sections summarize general decontamination protocols.
5.5.1 Heavy Equipment
Heavy equipment will be decontaminated prior to personnel decontamination. Equipment
operators will steam clean heavy equipment at locations near the operations. Contaminant
systems will be set-up for collection of decon fluids and materials. Berms and wind barriers
will be set up, if appropriate.
Vehicles that become contaminated with suspect soil will be cleaned prior to leaving the site.
The wheel wells, tires, sides of vehicles, etc. may be pressure washed or brushed clean of visible debris at a location to be determined by the SSO.
5.5.2 Samples and Sampling Equipment
The same decontamination line will be used for sampling equipment decon as is used for
personnel decon. At a minimum the following is perfonned:
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• Hand augers and buckets will be washed in TSP solution or equivalent and rinsed in
distilled water.
• Sampling equipment will be brushed clean and rinsed with distilled water or other
appropriate cleaning material.
• Samples will be dry-wiped prior to packaging.
5.5.3 Decon Wastes
• Spent decon solutions may be required to be drummed and disposed of as hazardous waste
and/or solvent solutions may be required to be segregated from water rinses.
• Decontamination shall be performed in a manner that minimizes the amount of waste
generated.
5.6 PROCEDURES FOR WASTE HANDLING OF ANTICIPATED WASTES (Note: To be determined in the Project WorkPlan)
5.6.1 Waste Generation
Anticipated: Yes X No __ _
Types: Liquid.JL Solid_ Sludge_ Gas __
Quantity:
Expected Volume of solid. ________ _ (include units)
Expected Volume of liquid Approximately 8,000 gallons
Characteristics:
Corrosive __ Ignitable_ Radioactive __ Volatile_
Toxic __ Reactive __ Unknown_ Carcinogenic __
Other (specify): Pesticides
Known Non-Hazardous: Yes __ No __
Known Hazardous Waste or Extremely Hazardous Waste: Yes.JLNo_
Potentially Hazardous Waste or Extremely Hazardous Waste: Yes __ No
Waste Requires Analysis: Yes__ No __
Specify Type: _______________________ _
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5.6.2 Storage and/or Treatment Methods Proposed:
• These wastes will be (I) temporarily stored• in the following manner(s) and stored within
secondary containment:
Open head 55-gallon drum
Closed head 55-gallon drum
Overpack drum
Baker tanks
Lined waste bins
Other
Approximately 150
and/or (2) treated on-site, ______ _
Neutralization__ Aeration __
Physical Change__ Chemical __
Bioremediation__ Change __
Is a permit required to treat? Yes__ No __
5.6.3 Disposal
• If Extremely Har.ardous waste is identified, an Extremely Hazardous Waste Disposal
Permit is required.
• Hazardous waste must be accompanied with a manifest signed by the client (generator),
Manifest must not identify McLaren/Hart as the generator, McLaren/Hart employees may
not sign manifests as agents or generators.
5. 7 Site Inspections
Conduct site inspections weekly utilizing the Project Manager/Field Supervisor Job Safety Checklist, HS
5-1 (Attachment 7),
"Temporary storage of hazardous waste without a permit is limited to 90 days. Label all temporary storage
containers with:
(!) "Contents Under Analysis"
(2) The·composition of the waste (soil, drilling, cuttings, etc.)
(3) The nature of known contaminants and their hazardous properties; (e.g., soil contaminated
with gasoline-inhalation and dermal hazard);
(4) The name of generator (never McLaren/Hart)
(5) The date of accumulation; and,
(6) A phone contact for questions (the appropriare McLaren/Hart office)
NOTE: Remind client to conduct weekly inspections of all hazardous waste drums.
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SECTION 6.0
EMERGENCY RESPONSE PROCEDURES
6.1 EMERGENCY RESPONSE
The Emergency Response Plan will be prepared to address the site specific nature of hazards and potential
emergencies. Emergency procedures will be implemented as appropriate.
6.1.1
6.1.2
Emergency Response Planning
Step 1:
Step 2:
Step 3:
Step 4:
Step 5:
Step 6:
Post site map which includes topography, layout, evacuation routes, safe distances
and assembly area. Note location of utilities main shut-offs and disconnects on
site map. Review this information during initial Tailgate Safety training and
periodically.
Complete and post Emergency Response Contact List (HS 13-1), directions and
map to hospital. Ensure that emergency communications equipment is available.
Notify local authorities (e.g., fire and police) of your presence and integrate any
emergency plans with local requirements. Post hospital route and verify hospital
route is accessible (Attachment 6).
Provide emergency equipment for first aid, emergency decontamination, fire
protection, personal protection and spill response. Designate vehicle for
emergency transport.
(Include em"ergency equipment as site conditions and characteristics require.)
Assure that personnel certified in first aid and CPR are available to respond to
injuries within four (4) minutes.
Conduct training for site personnel in emergency response during initial
orientation. Establish alarm and methods of notification and communication
during an emergency.
Lines of Authority and Personnel Responsibilities
During an emergency incident, the Field Supervisor shall have the authority .to commit the
necessary resources for responding to the emergency, and he shall assume the following
responsibilities:
Step I:
Step 2:
Step 3:
Determine the extent of the incident and direct the emergency response efforts.
Direct the SSO to conduct perimeter air monitoring, and monitor wind speed and
wind direction to determine the extent of impacted areas.
Alert site personnel of the emergency using an air-horn or other suitable means
of communication. If necessary I initiate evacuation procedures.
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Step 4:
Step 5:
Step 6:
Contact the US EPA Project Officer as well as the other EPA contracting
perconnel to inform them of the situation.
Make the required notifications. As a minimum, the McLaren/Hart Project
Manager and the McLaren/Hart Health and Safety Manager must be notified
immediately. McLaren/Hart's off-site management will also be informed of the
situation. Additional notifications and assistance from outside agencies may be
required based on the extent of the incident.
Prepare the Accident/Injury Report (HS 8-1) and send it to the Corporate Health
and Safety Director and the Health and Safety Manager.
If assistance is requested from an outside agency (i.e., Fire Department), the Incident
Commander will assume charge when he arrives on the scene.
6.1.3 Evacuation Procedures
6.1.4
If evacuation is required, the Field Supervisor shall:
Step l:
Step 2:
Step 3:
Step 4:
Activate the communication system to alert site workers of evacuation. Personnel
shall be advised to remain upwind of contaminants, if possible, and proceed to the
designated assembly area.
Account for all personnel at the assembly area.
Notify the client of the need to initiate evacuation procedures for other site
personnel.
Notify the Fire and Police Departments and request their assistance for evacuating
the surrounding area and residences.
Emergency Medical Treatment
Refer to the Hospital Route Directions and Map. If an injury/medical emergency occurs, the
following procedures shall be used:
Step l:
Step 2:
Step 3:
Step 4:
Step 5:
Notify the Field Supervisor immediately.
The Field Supervisor shall ensure that medical treatment is provided for the
injured person immediately. The Field Supervisor shall summon the first aid
responders and notify the hospital and the local Emergency Medical Service
(EMS) if necessary.
If the injured/ill person is within the exclusion zone, steps should be taken to
decontaminate him/her and remove the PPE if it can be done without worsening
the injury.
First aid responders shall use universal precautions for infection control when
providing first aid. Refer to McLaren/Hart's Health and Safety Procedure HS 27
"Bloodbome Pathogens."
Prepare the Accident/Injury Report (HS 8-1) and distribute it to the Corporate
Health and safety Director and the Health and Safety Manager within 24 hours.
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6.1.3
Step 4:
Step 5:
Make the required notifications. As a mimmum, the McLaren/Hart Project
Manager and the McLaren/Hart Health and Safety Manager must be notified
immediately. Additional notifications and assistance from outside agencies may
be required based on the extent of the incident.
Prepare the Accident/Injury Report (HS 8-1) and send it to the Corporate Health
and Safety Director and the Health and Safety Manager.
If assistance is requested from an outside agency (i.e., Fire Department), the Incident
Commander will assume charge when he arrives on the scene.
Evacuation Procedures
If evacuation is required, the Field Supervisor shall:
Step I:
Step 2:
Step 3:
Step 4:
Activate the communication system to alert site workers of evacuation. Personnel
shall be advised to remain upwind of contaminants, if possible, and proceed to the
designated assembly area.
Account for all personnel at the assembly area.
Notify the client of the need to initiate evacuation procedures for other site
personnel.
Notify the Fire and Police Departments and request their assistance for evacuating
the surrounding area and residences.
6.1.4 Emergencv Medical Treatment
Refer to the Hospital Route Directions and Map. If an injury/medical emergency occurs, the
following procedures shall be used:
Step I:
Step 2:
Step 3:
Step 4:
Step 5:
Notify the Field Supervisor immediately.
The Field Supervisor shall ensure that medical treatment is provided for the
injured person immediately. The Field Supervisor shall summon the first aid
responders and notify the hospital and the local Emergency Medical Service
(EMS) if necessary.
If the injured/ill person is within the exclusion zone, steps should be taken to
decontaminate him/her and remove the PPE if it can be done without worsening
the injury.
First aid responders shall use universal precautions for infection control when
providing first aid. Refer to McLaren/Hart's Health and Safety Procedure HS 27
"Bloodbome Pathogens."
Prepare the Accident/Injury Report (HS 8-1) and distribute it to the Corporate
Health and safety Director and the Health and Safety Manager within 24 hours.
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6.1.5 Spill Control
If a spill occurs, the following steps shall be taken to mitigate the incident:
Step I:
Step 2:
Step 3:
Step 4:
Step 5:
Step 6:
Step 7:
Notify the Field Supervisor, and he/she shall assess the extent of the spill lo
determine if it can be safely mitigated with the personnel and protective equipment
available at the site.
If the release is beyond the field team's capabilities, the Field Supervisor shall
evacuate the site personnel to a safe location upwind of the release, and notify the
Project Manager and Fire Department.
The Project Manager shall notify the client, Health and Safety Manager,
Corporate Health and Safety Director, and regulatory agencies, if necessary.
If the spill can be safely mitigated using defensive actions, first don the
appropriate PPE. Initially, Level C PPE should be worn until air monitoring
indicates a downgrade in PPE is appropriate.
Takes steps to secure the area and to prevent unauthorized persons from entering
the area.
Takes steps to contain the spill and to prevent it from reaching sewers, storm
ditches, etc.
Clean up the spill with absorbent, neutralizers, soil removal as appropriate. Place
waste in sealed, labeled containers for disposal.
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6.2 EMERGENCY TELEPHONE NUMBERS: TO BE POSTED ON SITE
TITLE/DEPARTMENT NAME TELEPHONE NO.
Client Contact Paul Peronard [phone] ext 6121
Site Contact Paul Peronard [phone] ext 6121
Project Manager Dan Sullivan [phone]
Project Engineer Nannette Orr [phone]
Site Safety Officer Michael D'Eufemia
Health & Safety Manager Henry Robinson [phone]
POLICE DEPT. Washington [phone]
FIRE DEPT. Washington [phone]
LOCAL RESCUE/AMBULANCE Washington [phone]
LOCAL HOSPITAL Beaufort Ct. Hospital [phone]
LOCAL EMERGENCY [phone]
RESPONSE (HAZMAT)
National Response Center NIA 911 or 800-424-8802
Utility Companies:
Electric [phone]
Propane (Alligood Owens) Warren Taylor [phone]
Water [phone]
6.3 HOSPITAL NAME/ADDRESS/ROUTE
Name: Beaufort County Hospital
Address: 628 E 12th St.
Route: See hospital route map on the following page.
Note prior to the commencement of site work: 1) Local Emergency services are to be notified of proposed
site activities and 2) verify the hospital route.
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7----1------
' ,
£ -----· ---------
,,.. I "is ~ BEAUFORT COUNTY "''r'~,ib~ -_ t.! Chumber of C:?,mmerce
Hu 11or--·. Gudo~ ~~•2'c!e"s•l~I a"~R~1v=:,;===;F~,h,-
,,.,,., / ,, 'i; tbr,;
ND .,. .
/
Washington.
RODMAN PT
1506-
1545
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7.0 RECORDKEEPING
SECTION 7.0
RECORD KEEPING
The Project Manager (PM) will assure that all field documentation is properly completed in a timely
manner. All HASP documentation, including monitoring results, calibration logs, tailgate safety meeting
forms, utility clearance and utility maps, and Project Manager/Field Supervisor Jobsite Safety Checklists,
are to be forwarded to the Project Manager for review and signature on a regular basis (recommended
weekly). Once reviewed by the PM, HASP fonns should then be distributed to the HSM and to the project
file.
The HSM will review and initial all fonns indicating acceptance of finding. The HSM will contact the PM
to question records finding as appropriate.
(Indicated fonns that should be completed.)
APPLICABLE
FORM NAME FORi'\1 YES NO
Signed Cover Sheet -X
Signature and Acknowledgement SECTION 1.5 X
Training Verification (McLaren/Hart) TABLE 1-2 X
Training Verification (Subcontractor) TABLE 1-3 X
Job Safety Checklist HS 5-1 X
Tailgate Safety Meeting HS 5-2 X
Direct Reading Form HS 5-3 X
Instrument Calibration HS 5-4 X
Emergency Response Contacts SECTION 6.2 X
Confined Space Entry Permit HS 14-2 X
Utility Clearance Request HS 15-1 X
Utility Clearance Checklist HS 15-2 X
Hot Work Permit HS 30-1 X
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I ATTACHMENT 1
I SITE MAP(S)
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KENTUCKY
TENNESSEE
IJISSISSIPPI
JIL.I.B~
• Green,boro
Raleigh •
Charlotte •
Figure 1
E.P .A. Region IV
Regional Location Map
Wilmington
•
TDD #04-92.10-0038-4425
FCX Washington Pesticide Site
Site Locctiori
GEORGI.I.
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NORTH
CAROLINA
SOt.rrH
CAAa.lNA
Washington, Beaufort County, North Carolina
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Figure 2
E.P.A. Region IV
Site Location Map
TDD #04-9210-0038-4425
FCX Washington Pesticide Site
------_,,,,.,. . .,.-·
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Washington, Beaufort County, North Carolina
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Figure 3
E.P.A. Region IV
Site Sketch
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TOO #04-9210-0038-4425
FCX Washington Pesticide Site
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ATTACHMENT 2
UTILITY CLEARANCE CHECK AND
UTILITIES LOCATION MAP
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UTILITY CLEARANCE CHECK
CLIENT:
5'TE NAME ANO LOCATION:
M/H PfWJECT MANAGER:
USA CONTACT CATE:
,1.ao0-e42-24441
FACILITY DRAWINGS INSPECTION
(INITIALS & DATE)
WATERMAJN:
SANITARY:
STOPM I:
TELEPHONE:
ELECTRIC:
GAS LINES:
STEAM LINES:
UCUIO FUEL;
Cot.FPf:SSED AIR:
OVERHEAD LINES:
DATE PERFORMED:
ClfARANCE ENGINEER:
NOTU:
JOB I:
PROJECT START CATE: Cl.EAF¼NCE REQUEST DA TE:
DRIWNG/CONSTRUCTION SUP€AVISOR:
USA TICKET NUMBER:
FIELD VERIFICATION
(INITIALS & DATE)
WATER MAIN:
SANITARY:
STORM:
TELEPHONE:
ELECTRIC:
GAS LINES:
STEAM LINES:
LIQUID FUEL:
COtl,FPESSED AIA:
OVEA-IEAO LINES:
FACILITY CONTACT:
SUPERVISING ENGIHm VERIACA TION:
J.'37.lrm A1.1th0frty lo, Utility a .. .,c. on-till i, ptO'llided by th• cli.,,t, Wh••--otf•llt• cl••.,c• ,. provodld by Public U1dity Com,,wiin. o, • .,c, .,,. 1M ·••..i. av•labl• •t• dr~ng, indudi,,,g rt110fitting 1nfon-n.t1or,.
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ATTACHMENT 3 I DIRECT READING REPORT AND
I INSTRUMENT CALIBRATION LOG
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SITE :"'A.\tE A,"'0 LOCA Tl0,"1:
•· WH E.¼PLOYEE:
UXATION TASK DESCRlPTIQ,"'1
CO"MMENTI:
J♦JO.frm
DIRECT READING REPORT
JOB I: I PM, I DATE:
WEATHER CO,..,DIT!o:-;s (WlND SPEED, DIRECTIQ,'/' TE.\U> . Hl'M!Dlffi:
E.¼PLOYEE TITLE:
DIRECT READING DATA I TIME INSTilL'MENTTYl'E SUSSTANCE/AGE!<r CONCENTRATION SOL"RCE:1Sl
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CLIENT:
SITE NAIVE ANO LOCATION:
PERSON CAUBRA TING:
INSTRUMENT TYPE:
MOOE!.,
SERIAL I:
CAUBRA TOR MOOEL:
COIIM.ENTS:
PERSON CAUBAA TING:
INSTRUMENT TYPE:
"""""
SE'.Rl.ALI-:.
CAUBRA TOR MOOE\.;
COMMENTS:
PERSON CALIBRATING:
j$TR\JMENT TYPE:
MOOa
ScPtAL I:
CALIBRATOR M00EL:
COMMENTS:
PERSON CAUBAA TING:
INSTRUMENT TYPE:
MOOa
SESIAl."
CAUBRATORMOOEl.;
COMJ,,EN"TS:
PERSON CAUBRA TING:
INSTRU'-ENT TYPE:
MOOE!.,
SERAL ,._
CAIJBRA TOR M00EJ..:
COl,,&ENTS:
.NERAt. C~TS:
11432.FRM
INSTRUMENT CALIBRATION LOG
JOB I:
MIH PROJECT MANAGER:
CALIBRATION EVENT
DATE:
CA.LIBRA TION GAS:
CALIBRATION GAS CONC. lw,nl:
READING (ppn,J:
ADJUSTED REACMNG (ppm):
DATE:
CAUBRA TION GAS:
CA.LIBRA TION GAS CONC. !ppm):
READING /ppml:
ADJUSTED READING !POml:
DATE: --
CAUBAA TION GAS:
CALIBRATION GAS CONC. !ppm):
READING [PQml:
ADJUSTED READING (ppm):
DATE:
CAUBRA TION GAS:
CALIBRATION GAS CONC, [ppm!:
READfNG (POml:·
ADJUSTED READING (ppm):
DATE:
CAUBRA TJON GAS:
CALIBRATION GAS CONC. fppml:
REAotNG !ppm):
ADJUSTED READING !wml:
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ATTACHMENT 4
INITIAL MOBILIZATION HEALTH AND SAFETY CHECKLIST
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INITIAL MOBILIZATION HEALTH AND SAFETY CHECKLIST
This checklist should be used by the Site Safety Officer during the initial site mobilization to ensure that all site personnel are aware
of applicable site H&S requirements and complying with the HASP.
I. HASP cover sheet is signed and current.
2. Review Health and Safety Plan (HASP) with employees.
3. All site personnel (and subcontractors) must sign HASP Acknowledgement Sheet.
4.
5.
6.
7.
8.
9.
10.
11.
Check that training certifications are current and available on-site for all site personnel:
40-Hour HAZWOPER Training
8-Hour Refresher Training (within past year)
Supervisor Training (for Field Supervisor and Project Manager)
Medical Certification
Respirator Fit Test (if Level C PPE may be required)
First Aid and CPR Certification (for at least one person on-site)
The following notices should be posted in the office area:
OSHA Poster
Hospital Route Map
Emergency Contacts/Telephone List
Site Map showing evacuation routes and assembly areas
State posters as required
Check that PPE is available on-site as specified in the HASP. At a minimum, most projects require
Level D with provisions for upgrading to Level C:
Hard hat (check that suspension is properly attached and in good condition)
Safety glasses with side shields (check for ANSI Z87.1 embossment on frames)
Steel-toed safety boots
Ear plugs available, if needed
Respirators stored in a clean, sanitary condition (i.e., sealed bags)
Chemical protective clothing with duct tape (if upgrade is needed)
Ensure that air monitoring equipment and required calibration gas/devices are available
on-site as specified in the HASP.
Ensure that decontamination equipment is available as specified in the HASP. Generally, the
following decontamination equipment is oft.en required for personnel decontamination stations:
Containers and labels for disposal of used PPE
Plastic sheeting to cover ground
Tubs and scrub brushes for outer PPE/boot wash and rinse
Detergent and rinse water
Separate provisions for cleaning, disinfecting and drying respirators
Ensure that the site control and emergency response equipment is readily available on-site as
specified in the HASP. Generally, the following equipment is required for most sites:
First aid kit and bloodborne pathogens response kit and blanket
Communications equipment
Vehicle designated for emergency use
Fire extinguisher (ensure it is charged and inspected monthly)
Emergency eyewash/flushing equipment (if corrosive chemicals are used)
Hazard warning tape
Flashlight and tool kit
Ensure that containers of chemicals brought on-site are labeled with the identity and appropriate
hazard warning. Also, MSDSs must be on-site for each chemical.
Ensure that the required forms are available on-site and used to document field activities in
accordance with the HASP.
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ATTACHMENT 5
I TAILGATE SAFETY MEETING FORM
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TAILGATE SAFETY MEETING
DATE: ______ _ TIME: _______ _ JOB N: ___________ _
CLIENT: __________________ _ PROJECT MGR.: ________ _
SITE LOCATION:---------------------------------
TYPE OF WORK:---------------------------------
SAFETY TOPICS PRESENfED
PROTECTIVE CLOTHING/EQUIPMENT: _________________________ _
CHEMICAL HAZARDS:-------------------------------
ACTION LEVELS:--------------------------------
PHYSICAL HAZARDS:-------------------------------
EMERGENCY PROCEDURES: ____________________________ _
HOSPITAL/CLINIC:--------------------------------
PHONE NO.:----------------------------------
SPECIAL EQUIPMENT:-------------------------------
OTHER: --------------------------------
ATIENDEES
PRINT NAME/COMPANY NAME SIGNATURE
MEETING CONDUCTED BY: _________ _ SUPERY!SOR: ____________ _
DISTlUBUTION: I I PROJECT FU.I! I I OTlfEll: _____ _
1431.FRM
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ATTACHMENT 6
PROJECT MANAGER/FIELD SUPERVISOR
JOBSITE SAFETY CHECKLIST, HS 5-1
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ATTACHMENT 7
ADDITIONAL HEALTH & SAFETY PROTOCOLS
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0 McLaren/Hart Health and Safety Policy
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TITLE: !!EAT AND COLD STRESS
NO: HS 28
APPROVED: Russell B. Palcha DATE: 06-01-93
SEDES: NONE
PAGE: l OP' 8
28.l
28.2
GENERAL POLICY STATEMENT
It is the policy of McLaren/Hart to environments where exposure to heat and
provide guidance to evaluate and control
establish guidelines for work
cold stress are encountered and
these stressors.
in
to
!!EAT STRESS PROCEDURES
28.2.l
28.2.2
28.2.3
The effects of heat stress is dependent on a number of factors. These factors include the source of heat, whether it be radiant heat from an industrial process, o·r ambient temperature with or without sun loads, the type of work performed, duration of work activity, relative humidity, age and phyaical condition of the worker and the type of clothing worn (e.g., impervious clothing vs. standard work attire -Level D).
Given the variety of factors which can result in the development of a heat-related disorder, the following guidelines can be used to implement a work/rest regime based on the Permissible Heat Exposure Threshold Limit Value (TLV) published by the American conference of Governmental Industrial Hygienists (ACGIH). The work/rest regime is based on exposure to an acclimatized fully-clothed worker wearing breathable (cotton) attire. The actual rest periods and frequency will be dependent on the worker's level of acclimatization, the type · of heat stress environment encountered (e.g., radiant vs. solar), use of protective clothing and type of work performed.
The Permissible Heat Exposure Threshold Limit Values are presented in Table 28-1 as a guide to monitor and control worker exposure for heat stress environments. The Heat Stress TLV is based on the following Table. Heat stress measurement using the Wet Bulb'Globe Temperature Index on which the TLV is based is presented in Section 28.3.
TABLE 28-l
PERMISSIBLE !!EAT EXPOSURE THRESHOLD
LIMIT VALUES [MEASUREMENTS ARE PRESENT IN (0 P') WBGTJ
WORK LOAD WORK -REST
REGIMEN LIGHT MODERATE HEAVY
Continuous Work 86 80 77
75% Work -
25% Rest, each hour 87 82 78
so, Work -soi Rest, each hour 89 85 82
25% Work -
75% Rest, each hour 90 88 86
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McLaren/Hart Health and Safety Policy
TITLE: HEAT AND COLD STRESS
HO: HS 28
APPROVED: Russell B. 06-01-93
EDES: HONE
PAGE: 2 OP' 8
28.3
28.4
28.2.3.1 Definitions of work-load categories.
A. Light Work Load -sitting, standing to control machines, performing light hand and arm work.
B. Moderate Work Load -walking about with moderate lifting and pushing.
C. Heavy Work Load -pick and shovel work.
BEAT STRESS MEASUREMEHT
The method of heat stress measurement required to assess the permissible heat exposure TLV is by the Wet Bulb Globe Temperature Index (WBGT). This technique is the most practical method to evaluate environmental factors which most nearly correlate with deep body temperature and other physiological responses to heat.
28.3.l
28.3.2
WBGT measurements can be made with a Reuter-Stokes, or equivalent, direct reading Heat Stress Monitor. This instrument measures dry bulb temperature, natural aspirated wet bulb temperature, and Vernon globe equivalent temperature and electronically calculates the Wet Bulb Globe Temperature Index (formula presented in Section 28.3.2). An alternate method of measuring the WBGT Index using dry, natural wet bulb and globe temperature is presented in the ACGIH Threshold Limit Values for Chemical Substances and Physical Agents under "Heat Stress: Evaluation and Control."
WBGT values are calculated using the following formula:
A. Outdoors with solar load:
WBGT = 0.7 NWB + 0.2 GT+ 0.1 DB
a. Indoors or outdoors with no solar load:
WBGT = 0.7 NWB + 0.3 GT
WBGT = Wet Bulb Globe Temperature Index NWB = Natural Wet Bulb Temperature
DB~ Dry Bulb Temperature
GT• Globe Temperature
CLASSIP'ICATIOH AND PREVENTION OP' HEAT ILLNESSES
28.4.l Heatstroke
28.4.1.l
28.4.1.2
Condition: (a) hot dry skin: red, mottled, or cyanotic; (b) high and rising core temperature, lOS'C and over; (c) brain disorders: mental confusion, loss of consciousness, convulsions, or coma, as core temperature continues to rise. Fatal if treatment delayed.
Predisposing Factors: (a) Sustained exertion in heat by unacclimatized workers; (b) obesity and lack of physical fitness; (c) recent alcohol intake; (d)
U:\J"Ol.lClES\N'EW\NEW .~l
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TITLE: HEAT AND COLD STRESS
NO: HS 28
APPROVED: Russell B. Palcha~ PAGE: 3 OP' 8
28.4.3
28.4.4
p'/1'. ;.,....
28.4.1.3
28.4.1.4
dehydration; (e) individual susceptibility; ( f) chronic cardiovascular disease in the elderly.
Corrective Actions: Immediate and immersion in chilled water with wrapping in wet sheet with vigorous dry air. Avoid overcooling. Treat Seek medical attention.
rapid cooling by
massage, or by
fanning with cool
shock if present.
Prevention: Medical screening of workers. Selection based on health and physical fitness. Acclimatization for 8 to 14 days by graded work and heat exposure. Monitoring workers during sustained work in severe heat environments.
Heat Syncope
28.4.2.l
28.4.2.2
28.4.2.3
28.4.2.4
Clinical Features:
immobile in heat.
Fainting while standing and
Predisposing Factors: Lack of acclimatization.
Treatment:
attention.
Prevention:
Remove to cooler area. Seek medical
Acclimatization.
Heat Exhaustion
28.4.3.1
28.4.3.2
28.4.3.3
28.4.3.4
Beat Cramps
28.4.4.l
Clinical Features: ( a) Fatigue, nausea, headache, giddiness; (b) skin clammy and moist, complexion pale, muddy, or with hectic flush; (c) may faint on standing, with rapid pulse and low blood pressure.
Predisposing Factors: (1) sustained exertion in heat, (2) lack of acclimatization, (3) failure to replace water and/or salt lost in sweat.
Treatment: Remove to cooler environment. Provide salted fluids such as Gatorade or equivalent. seek medical attention.
Prevention: Acclimatize workers using a breaking-in schedule for l or 2 weeks. Supplement dietary salt only during acclimatization. Ample drinking water, gatorade or equivalent, to be available at all times and to taken frequently during work day.
Clinical Features: Painful spasms of muscles used during work (arms, legs, or abdominal). Onset can occur during or after work hours.
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McLaren/Hart Health and Safety Policy
TITLE: HEAT AND COLD STRESS
NO: HS 28
APPROVED: Russell B. Palcha 06-01-93 PAGE: 4 01" 8
28.S
28.6
28.4.5
28.4.4.2
28.4.4.3
28.4.4.4
Heat Rash
28 .... s.1
28.4.5.2
28.4.5.3
28.4.S.4
Predisposing Factors: (l) Heavy sweating during hot work, (2) drinking large volumes of water· without replacing salt loss.
Treatment: Drinking liquids with salt supplement such as Gatorade or equivalent. Seek medical attention.
Prevention: Adequate salt intake with meals. In unacclimatized men, provide salted (0.1 percent) drinking water.
Clinical Features:
on affected areas.
exposure.
Profuse tiny raised red blisters
Pricking sensations during heat
Predisposing Face.ors: Unrelieved
heat with skin continuously wet sweat.
Treatment: Seek medical attention.
exposure to humid
with unevaporated
Prevention: Cooled resting and sleeping quarters to allow skin to dry between heat exposures.
TRAINING REQUIREMENTS
Train staff to recognize heat stress conditions and the methods necessary to prevent and treat heat stress.
28.5.l
28.5.2
28.S.3
28.S.4
Proper clothing and PPE requirements.
Recognition, prevention and first aid treatment for heat stress.
Suggested work/rest regimes and fluid intake.
safe work practices in heat stress environments.
HEAT STRESS CONTROL
28.6.l Working in a hot environment requires that employees take precautions and provide adequate protection to p'revent heat stress. The following are guidelines to recognize and prevent heat stress conditions.
28.6.1.l
28.6.l.2
Make staff assignments for work involving physical labor and/or involving heat stress, baaed on physical f itnesa level of available labor pool. Employees newly exposed to heat should begin their work level at 50\ of suggested work schedule and increase level by 10\ per day to allow for acclimatization.
Supervision and "buddy system" should be used to carefully observe workers in heat stress environments
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TITLE: !!EAT AND COLD STRESS
APPROVED: Russell B. Palcha
28.6.l.3
28.6.l.4
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28.6.l.S
11 U:\POLIClES\."ffl'W\NEW,f"':S\4,'YJ)
06-01-93
SEDES1 HONE
HO: HS 28
PAGE: 5 OP' 8
to evaluate each individual's susceptibility to heat stress. Any behavior exhibiting signs of heat stress should be promptly investigated.
Initiate a modified work/rest regimen when Ambient Temperature• and protective clothing create a potential heat stress hazard. If ambient temperatures exceed 75°F, the following work/rest regimen is recommended (guidelines assume light to moderate work) :
Temperature Work Period Rest Period
75 -80°F 90 Minutes 15 Minutes 80 -85°F 60 Minutes 15 Minutes 85 -90°F 45 Minutes 15 Minutes 90 -95°F 30 Minutes 15 Minutes
Rest periods should be taken in a shaded area if available, as this will considerably reduce the effects of heat stress.
A. When temperatures reach above 75°F, the site supervisor or SSO will monitor the heat rate of each working employee every 90 minutes. When temperatures are above 80°F, the heart rate will be monitored every 60 minutes and above 90°F, every 30 minutes.
B.
C.
If individuals' heart rates are 110 beats per minute or less at the end of the rest period, they can resume work. If greater than 110 beats per minutes, individuals will rest another 10 minutes. If the heart rate is reduced below 110 at the end of 10 minutes, the employee may return to work and the next work period should be reduced by 33 percent (e.g., at 75°F to BO"F, the work period should be reduced to 60 minutes; at 80°F to 85°F, reduced to 45 minutes; at 85°F to 90°F, reduced to 30 minutes; and at greater than 90°F, reduce to 20 minutes.
If at the end of the 10 minute rest period, the heart rate is still above 110, the individual must leave the area through proper decontamination procedures and rest in a cool place outside the exclusion zone for one hour.
D. The rest periods will be modified as the employees became acclimatize ta heat.
Provide plenty of water and/or other drink which replenishes electrolytes (eg.: Gatorade) at each rest period. Generally, salt intake is sufficient from dietary intake, however, the best way to compensate
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~ITLE: HEAT AND COLD STRESS
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APPROVED: Russell B.
28.6.1.6
DATE: 06-01-93
SEDES: HONE
HO: HS 28
PAGE: 6 01" 8
for excessive sweat loss is to drink replacement fluids which contain electrolytes, including salt, such as Gatorade, or equivalent. Alternately, a little extra salt in the diet can accomplish the same thing. Salt tablets should JlQt be used. Workers on a low sodium diet should consult with their physician prior to engaging in work in heat stress environments.
Protective clothing inhibits the transfer of heat between the body and the surrounding environment. This can increase the onset of heat stress symptoms. The following consideration should be.evaluated when protective clothing is worn in heat stress environments.
A. More frequent rest breaks;
B. Worker rotation to provide frequent breaks in cool areas;
C. Wear ice vests or vortex tubes, if practical; and
D. schedule changes to accommodate work at night or early morning hours.
28.7 COLD STRESS PROCEDURE
28.7.l Cold stress can present a significant hazard to workers and can result in hypothermia. Hypothermia is a potentially , life threatening condition which results in a drop in the body's core temperature. At lower body temperatures the body can react by a reduction in mental awareness, reduced rational decision-making, loss of consciousness and death. Several factors incorporate the harmful effects of cold: wet clothing, smoking, drinking alcoholic beverages, fatigue, emotional stress and certain diseases and medications. Workers exposed to severe cold can suffer hypothermia or frostbite.
28.8 CLASSIFICATION AND PREVENTION 01" COLD ILLNESSES
28.8.l
U:\l'OLICIES\,~.~)
.The following are the most prevalent and significant cold stress conditions:
Hypothermia: The signs and symptoms of hypothermia include shivering, dizziness, numbness, confusion, weakness, impaired judgement, impaired vision and drowsiness. The stages of hypothermia are: shivering, apathy, loss of consciousness, decreasing pulse rate and breathing rate and death.
First aid measures for hypothermia are: call Emergency Medical Services and move the victim to a warm area and into dry clothing.
Frostbite:
It .happens
nose, ears,
Frostbite is the most common injury caused by cold. when ice crystals form in body tissues, usually the chin, cheeks, fingers, or toes. Thia restricts blood
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·XITLE: HEAT AND COLD STRESS
H01 HS 28
APPROVED: Russell B. Palcha PAGE: 7 OP' 8
28.9
28 .10
flow to the injured parts. The effect is worse if the frostbitten parts are thawed and then refrozen.
Signs and symptoms of frostbite may be that the skin is slightly flushed. The skin color then changes to white and then grayish blue. Pain is sometimes felt early but later goes away. The frostbitten parts feel very cold and numb, and the victim may not be aware of the injury. In severe cases, frostbite may result in blisters or gangrene.
First aid measures for frostbite are: Move the victim to a warm area and place the frozen parts in warm water (100-lOS"F). Handle them ge1tly and do not rub or massage them. Loosely bandage the injured parts. Seek prompt medical attention.
TRAINING REQUIREMENTS
28.9.l Worker training should be provided to discuss the hazards of cold stress environments and to review preventative work practices. The training should include:
28.9.1.l
28.9.1.2
28.9.1.3
28.9.1.4
Proper clothing and PPE requirements.
Recognition, prevention and first aid treatment of frostbite and hypothermia. Discussion should include rewarming procedures.
suggested work/rest
habits.
regimes and eating/drinking
Safe work practices in cold stress environments.
RECOGNITION CONTROL AND PREVENTION
28.10.l The first signs of cold stress are pain in the extremities. Severe shivering may result as body temperature drops.
28. 10. 1. l
28.10.1.2
28.10.1.3
28.10.l.4
Protection from cold stress must be considered in addition to provisions for personal protective equipment.
Provisions for insulating dry clothing must be provided.
Wind chill can substantially reduce the cooling rate experienced by personnel. Prevention of excessive cooling exacerbated by windchill condition requires increased insulation value of the protective work clothing.
The effects of wind chill and temperature can be referenced in the ACGIH TLVs for Chemical Substances and Physical Agents.
U:\J"OLl□!S~.f"::1""7ll
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McLaren/Hart Health and Safety Policy
TITLE: HEAT AND COLD STRESS
HO: HS 28
APPROVED: Russell B, Palcha DATE, 06-01-93 PAGE: 8 OP' 8
28.10.2
U:I.POLIC1£S~.~l
. SUP RSEDES l HONE
The following work practices should be followed to minimize the
effects of cold stress conditions:
28,10,2,l Wear adequate layers of insulating dry clothing. Keep
a change of dry clothes available in case clothing
becomes wet.
28.10.2.2 Use the buddy system to look for signs of cold stress.
28,10,2,3 If appropriate, use wind shields to reduce the effects
of wind.
28.10,2,4 Heated warming shelters should be available when the
Equivalent Chill Temperature (ECT) is less than 20°F (-
7"C). The CET is used for the purpose of assessing the
combined effects of wind and low air temperatures on
exposed skin.
28 .10. 2. 5 To prevent dehydration which can increase the
susceptibility of workers to cold injuries, warm sweet
drinks and soups should be provided. Coffee intake
should be limited due to its diuretic effects.
28.10.2.6 Should a work-warming regime be necessary, the ACGIH
TLVs should be consulted.
I ~~r,ffilln I ENVIRONMENTAL ENGINEERING CORPORATION
Pagelof2
PERMIT SPACE PRE-ENfRY CHECKLIST
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ocatloo or Permit Space: _____________________________________ _
t'urpose or Entry Work:. ______________________________________ _
Employees aod Assigned Duties:
Entrant(s): ______________________ _
Attendant(,):. _____________________ _
Entry Supervisor.. _____________________ _
First Aid/CPR Certified Person(s): _______________ _
Re.scue Service: _____________________ _
Eolry Dale: __________________ Eolry Time: ___________________ _
Authorized Duration for Entry:, ___________________________________ _
Outside Contrnctor(s) and Assigned Duties:. _______________________________ _
Yes
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RESPONSES
(l:IPOILM.NUl4-I""'")
No
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QUESTIONS
TESTING
Were the instruments used in atmospheric testing properly calibrated before and after testing?
Was the Permit Space Calibration fonn filled out completely and attached?
Is the attendant a qualified person for using the atmosphere testing equipment?
Was the atmosphere in the confined space tested prior to entry? (If no, then go to the
Monitoring questions)
Was Oxygen greater than 19.5% and less than 23.5%?
Were flammable/combustible gases present?
Were toxic gases/vapor, present?
-Hydrogen Sulfide
~ Carbon Monoxide
-Methane
~ Carbon Dioxide
-Other (list)
Was the Permit Space Monitoring Results form filled out completely and attached?
MONITORING
Will the atmosphere in the space be monitored while entry task are performed?
Will the atmosphere be continuously monitored?
Will the atmosphere be periodically monitored? (if yes, give interval: ---~per hour)
REMEMBER -ATMOSPHERIC CHANGES OCCUR DUE TO THE WORK TASK OR
THE MATERIALS FORMERLY STORED IN THE PERMIT SPACE. THE
ATMOSPHERE MAY BE lNITIALL Y ACCEPT ABLE FOR ENTRY, BUT CAN CHANGE
QUICKLY.
CLEANING
Will the space be cleaned before entry is made?
If steam cleaning is used, will the space be allowed to cool before entry?
Did the tank store materials which may have permeated the lining (e.g., propane)?
Did the tank contain materials that are irritants, corrosive, or readily absorbed through intact
skin?
U yes, is the resp:>nse to the prior question, was verification made that such materials have
been completely removed?
HS 14-1
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RESPONSES
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PERMIT SPACE PRE-ENTRY CHECKLIST
Page 2 of2
QUESTIONS
No VENTILATING
[ ] Will the space be ventilated before entry by supplying air into the space, not exhausting it out?
[ ] Will ventilation he continued during entry?
[ ] Is the air intake for the ventilation system located in an area that is free of combustible dusts,
flammable gases and vapors, and toxic substances?
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ISOLATING
Will the space be isolated from other systems?
Will the electrical equipment be locked out?
Will disconnects be used where possible?
Will the mechanical equipment be blocked, checked, and disengaged where necessary?
Will lines under pressure be blanked and bled?
CLOTHING/EQUIPMENT
Will special clothing be required (e.g., chemical resistant boots, chemical suits, chemical splash
goggles, etc.) (If yes, specify· .. _______ __,
Will special equipment be required (e.g., rescue devices, communications systems, etc.)? (If yes,
specify: ______________ _,
RESPIRATORY PROTECTION
Arc MSHA/NIOSH-approved respirators of the type required available at the job location?
Will respiratory prot.cction he required (e.g., air-purifying. supplied air, self-rontained breathing
apparatus)? (Ifyes, specify: _________ _,
If supplied air respirators are required, does the rescue service have similar respiratory
protection?
Can the permit space be accessed while donning a respirator?
TRAINING
Arc field personnel trained in proper use of the required type of respirator?
Is at least one rescue person trained in first aid/CPR training?
Aie affected personnel trained in permit space entry and hazard recognition?
RESCUE
Will there be a attendant on the outside in constant visual or auditory communication with the
entrant?
Will the attendant be able to sec and/or bear the person inside at all times?
Has the attendant been instructed in non~ntry rescue?
Is a rescue service available for quick J'CSJX>DSC in the event of an emergency?
Person Completing Checklist ______________________ _ Dale, ________ _
Approved by Site Supervisor _____________________ _ Date. ________ _
(Copy to Health & Safety Manager and project file.)
H&S Manager Review _________ Date. ______ _
(J:'.POIJO.Kll._"-"l)
HS 14-1
I fmA1-7~<Jf en· I ENVIRONMENTAL ENGINEERING CORPORATION
CONFINED SPACE ENTRY PERMIT
All confined space entry must conform lo HS 14 • Penn it-Required Confined Spaces
, .. ,ii;.~ti'i(i~g;;; t•·••·•·•· ····•·•·•····•····•·•·•·••·•(••··········••·••·•·····••+r<\??•••t•··r·••t••• (••••I ~Mj~~Fi-iMi••?
m Qualified Person: _________________ _
Supervisor of Crew: __________________ _
Project Manager:, ____________ _
Tank or Vessel No./Name: _______________ _
0 Anticipated Hazards: ________________________________________ _
Describe Material Previously
Purpose of Entry: _______________________________________ _
I Mani tori ng
in Confined Space: ____________________________ _
Used: _____________ _
Project Address: _____________ _
Frequency of Testing: ___________ _
I
•f--------+---1-----+---+------+----+-----,
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CHECKLIST
I ::mitoi-in E nt Calibrated
Electrical E ui roved for Ex losive Atmos ere
I Grourd Fault Circuit Interr ters GFJ O rational
I nition Sources Removed Isolated
I 1-_,Sc;!a.!_fe~t,.Y...!!;Ha!.!r..!n!!;e.:ess!!!•c!s~&.JL,.Ji..!fs.el..l i!.!.n!lce!!.S.JO~,_ra,etc,i..so'-!na,el,__ ______ --j----+----!
Res irater Protective E ui rational
Fire S ression E t Available
S ecial ~arnin Caution Sins Posted I '--"C"O<!T!JJ=,cne_i cs,ae.,tcei.,,one,s'-"A"-v,,_a ,,_,· lc,a"'b-"l e'-"a'-'nd"-'T_,e.,_s.,;ted,,,_ _________ ..,_ ___ --J,__ ___ ....1
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Communications Procedures: ________________________________________ _
This perait is issued only for the abow:-naaed ~loyecs. ~loyees will initial the perait in spoce provided to
irdicate that 8R)f"opriate training end entry procedJre instructions have been provided~
I ,.rson Completing
Approved By: ___________________________ _
Site Supervisor: _____________________________ _
Pennit: ________________________ _ Date: _________ _
Date: ----------Date: _________ _
Copy to Hulttl and Sahty Mana,;,tr and proJ"t flla. Huitt\ and Saftty Mana,;,tr ReYltw: _______________ Oat.: ________ _
HS 14-2
--------------

-
----· -.. . . ----
· JOB TITLE (and numbe, pplicable): DATE: □ NE\\
JOB SAFETY ANALYSIS
□ REVISED
PAGE OF !SA NO
(INSTRUCTIONS ON REVERSE SIDE) TITLE OF PERSON WHO DOES JOB: SUPERVISOR: ANALYSIS BY:
COMPANY/ORGANIZATION: PLANT /LOCATION: DEPARTMENT: REVIEWED BY:
REQUIRED AND/OR RECOMMENDED PERSONAL PROTECTIVE EQUIPMENT: APPROVED BY:
SEQUENCE OF BASIC JOB STEPS POTENTIAL HAZARDS RECOMMENDED ACTION OR PROCEDURE
(J :\fOR},1S'JIS7-1 \6.93)
HS 7-1
I
,I INSTRUCTIONS FOR COJ\1PLETING JOB SAFETY ANALYSIS FORM
Safety Aoalyai■ (HS 7-1) ia aa ~ accid«m& prevention iool lha1 worb by findma" hazard.a and cilimiaering or minimizing them t>eforw tboy have• chance
I to bccomo ac.cidooU, Uao your JSA for job clari6"1ioo. aod hazard ■W.roDWI. u a IUMM in DOW empk>yee training, for periodic coouw;aa and fOC' retnioina of lilllDl(JI'
cmployc:ca, u a rcfteahcr on job• which run infrcqucatiy,aa an ac.cidcnl invUUptioa tool, and for informing omp&oyeca of apecific job b.u.arda and pf'CIIOCtive
mcuurca. g Set priorilica for dou,g JSA'" job, lb.o1 bavo a lwtory of many accidcnu, job, lb.o1 bavo produced diaabling injury or death, and ocw job, with oo accidcm lwlory.
Herc'• how to do each of the th.rec pan.a of a Job Safety Ana.lyail:
D I. SEQUENCE OF BASIC JOB STEPS
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Break the job dQWU in1o 1tep1. Each of tho llep• of• job lhould accompliah aomo major 1aat. The wk will comul of a KA of movcmcnu. Loot 11 tho fint
aet of movcmcau uacd to perform a lalk. and Lbcn dctermioo tho next k>gical act of movemema. For example, the job might be to move a box from a coovoyOC'
in tho receiving area to • &bell in Ibo aionge area. How doca that break down m10 job acpa? Pickina up &be box from tho ccavoyor and punin, ii oa a .bandtnact
i1 ooo logic.a.I Kl of movcmcnu, 10 ii. ia ooo job acp. Evcryth.i.o,e rclalod 10 ttw. ooo logical 1e1 of mc,yemie.ma ia part of thal job ltep.
Tho next &ogical ~ of movemeau might bo puahioa tho k)adcw:I bandwct to tbo IIOl'eroom. R.cmoving \ho boxoa from tho truck and placina tbom oa. Iba abolf
ia anoc.hcr logical Kt. of move menu. And finally, rewrning lbc handuuct. to lbo tteciving area might be tho final a:tq, in \hi• type of job.
Be auro to lilll ail lbc step• in a job. Some stepa might not be done each time -checking \he c.ulcn on a baodtruct., for example. However. that lUi; ia a part
of \ho job aa a whole. and ab.ould be lilted and analyzed.
l. POTENTIAL HAZARDS I JdeDlify the hazard■ auociatcd wilb each step. Examine each attp to find and identify hazudl -actioo,1 cooditioll.l and pouihilit.ica that could lead to an &C(;idcot.
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It'1 not enough to look: at the obviou1 hu.ardl. It's alao important to look at the cntlre enviroomcm and diacover every conceivable b.az.ard lhl1 mighl exist.
Bo mro to list. bc.allb bazania aa well, even tboup tho humfu1 effect may oot bo immecti11c. A ,ood example i• tho bannfuJ effect of iob.a1iaa a IOlveal or
chemical dwt over a Iona: period of time.
It'a importAnl to list ail ha:u.rd1. Hazard■ comributo to a"idcnu, injurie, and occupational illoouoa.
In order to do part three of a JSA effectively, you mull identify potential and exiating hazard■• Th.at'■ why it'• unporun,. to di■tinguiah between a hazard, an
accident and an injury. Each oftheae tcrma baa• ■pccific muning:
HAZARD-A poteOliaJ danger. Oil on the floor ia a hazard.
ACCIDENT-An uninr.eoded happening that may reau.lt in injury, lou or damage. Slipping on the oil i1 an accident.
INJURY-The result of the accide01. A apn.incd wrist from tho fall would be an injury.
Some people find it cuier to ideotify pouiblo a"ideOla and illDcuca and wort. back from them to tha hazard■• If you do lhal, you can list tho ace idem and illncu
type■ in parentbcaca following tho hazard. But ho auro you focua on lho Juuard for developing recommended action■ and ufc work procedure■.
3. RECOMMENDED ACTION OR PROCEDURE
Uaing 1 and 1 above aa a guide. decide what action,, arc occcaaary to eliminate or minimize the hazard.a that could lead to an accident, injury, or occupational
illaeu.
Among the actiom that can be taken are l) engineering the hazard out, 1) providing penoaal protective cquipmcn1, 3) job instruction training, 4) good
houaci:ceping, and 5) good ergonomic• (positioning the peraon U1 relation to the machine or other elemcw in the environment in 1UCh a way -. to eliminate
st.rcuc1 and 1tn.im).
Lut recommended aafe openting procedure, on the form, and alao list required or recommended penonal protective equipment for each llCp of tho job. I Bo ,pccific. Say exactly what need, to ho dooo to correct tho hazard, such u. lil\ using your kg muaclc■• Avoid gcoen.1 ■talt:mcnta like •bo careful.•
Give • recommended ■ction or procedure for every hazard. I If lhe hazard i1 • 1erioua one, it &bould be corrected immediately. Tho JSA ■hould then be changed to n::floct the new cooditioau.
I fJ:FORMS\JlS"1.J'&'9l\ HS 7-1
I fm~1aren~ . C; µ arL
1.
HOT WORK PERMIT
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ENVIRONMENTAL ENGINEERING CORPORATION
I IN CASE OF FIRE CALL: I
AM AM
GOOD THIS DATE ONLY: FROM: PM TO: PM
CLIENT NAME: PROJECT NAME:
LOCATION:
DESCRIPTION OF WORK PERMITTED:
FLAME PERMITTED: □YES ONO SPARK PRODUCING DEVICE PERMfITED: □YES ONO
I certify that the area and equipment have been inspected and found free of flammable and combustible hazards and
proper precautions have been taken. Permission is granted for the use of flame or spark producing devices.
Site Supervisor:
Site Sa(ety Officer:
CHECK LIST REQUIRED TO BE COMPLETED BEFORE STARTING HOT WORK:
L Flammable vapor test performed and < 10% of LEL? □Yes □No □ Not Applicable
2. Combustibles removed? □Yes □ Not Applicable
3. All flammables removed, covered, or properly secured? □Yes □ Not Applicable
4. Handling of flammables in the area stopped? □Yes □ Not Applicable
5. Floor and wall openings adequately protected? □Yes □ Not Applicable
6. Fire watch provided? □Yes D Not Required
If so, name:
7. Fire protection provided, i.e., fire extinguishers, hoses? □Yes □ Not Required
8. Did equipment contain flammable material? □Yes □No
If Yes: a. Vapor test performed? □Yes □ Not Required
b. Oeaned and purged? □Yes □ Not Required
9. Workers instructed on reporting a fire? □Yes
10. Hot Work equipment inspected and found safe? □ Yes
11. Personal Protective Equipment Required:
12. Other precautions:
POST-HOT WORK INSPECTION
Area has been inspected after the completion of hot or flame work and has been found to be free from flame, sparks, or smoldering
' material.
Site Supervisor Date Time
.:JISTRIBUTI0N: Original · Post Copy -SS0, Health and Safety Manager and Project File
Health and Safety Manager Revicw: ____________ Date: _________ _
(l;\FORMNISJ0-1\S,Vl)
HS 30-1