site-wide health and safety plan for the anniston pcb site ... · for the anniston pcb site...

H E A L T H & S A F E T Y P L A N

Site-Wide Health and Safety Plan for the

Anniston PCB Site

Revision 0

Anniston, Alabama

June 2004

Anniston PCB Site Site-Wide HASP

Revision: 0 Date: June 2004

Health and Safety Plan

for the Anniston PCB Site

Anniston, Alabama

June 2004 Revision 0

Approved By: __________________________________________________________________________________ Craig Branchfield: Anniston PCB Site Manager Date __________________________________________________________________________________ John Loper: CERCLA Manager Date __________________________________________________________________________________ Gayle Macolly: OU-1/OU-3 RI/FS Manager Date __________________________________________________________________________________ Alan Fowler: OU-2/OU-4 RI/FS Manager Date __________________________________________________________________________________ Charles Haury, CIH, CSP: HSO, OU-1/OU-3 Date __________________________________________________________________________________ Greg Ertel, CIH, CSP: HSO OU-2/OU-4 Date

05/06/04 HASP Acknowledgement.doc

Anniston PCB Site Anniston, Alabama

Health and Safety Plan Acknowledgment

I have read the Health and Safety Plan for the Anniston PCB Site, or its contents have been presented to me, and I understand the contents and I agree to abide by its requirements.

Name (Print) Signature Representing Date



BLASLAND, BOUCK & LEE, INC. 6/3/04 engineers, scientists, economists 1 F:\FILEXCHG\ANNISTON\June 2004 HASP\Anniston HASP Rev 0.doc

Table of Contents

Section 1. Introduction..............................................................................................................1-1 1.1 General.............................................................................................................................1-1 1.2 Background ......................................................................................................................1-2

1.2.1 Anniston Residential (OU-1) ...............................................................................1-3 1.2.2 Anniston Non-Residential (OU-2) .......................................................................1-3 1.2.3 Facility (OU-3) .....................................................................................................1-4 1.2.4 Choccolocco Creek (OU-4).................................................................................1-4

1.3 Policy Statement ..............................................................................................................1-4 1.4 Definitions.........................................................................................................................1-5

Section 2. Roles and Responsibilities .....................................................................................2-1 2.1 Project Personnel.............................................................................................................2-1

2.1.1 Anniston PCB Site Manager ...............................................................................2-2 2.1.2 CERCLA Manager ..............................................................................................2-2 2.1.3 Operable Unit RI/FS Managers...........................................................................2-2 2.1.4 Health and Safety Officer (HSO).........................................................................2-3 2.1.5 Health and Safety Coordinator (HSC).................................................................2-3 2.1.6 Site Safety Officer (SSO) ....................................................................................2-4 2.1.7 Subcontractors ....................................................................................................2-6

2.2 All On-Site Personnel.......................................................................................................2-6 2.3 Visitors..............................................................................................................................2-7 2.4 Stop Work Authority .........................................................................................................2-7

Section 3. Project Hazards and Control Measures .................................................................3-1 3.1 Introduction.......................................................................................................................3-1 3.2 Field Activities, Hazards, and Control Procedures ..........................................................3-1

3.2.1 Task 1 – Mobilization/Site Survey.......................................................................3-2 3.2.2 Task 2 – Water, Soil, and Air Sampling ..............................................................3-3 3.2.3 Task 3 – Drilling and Monitoring Well Installation ...............................................3-5

3.2.3.1 Geoprobe® Hazards and Control Procedures ....................................3-5 3.2.3.2 Drilling..................................................................................................3-7

3.2.4 Task 4 – Residential Sampling and Excavation................................................3-12 3.2.5 Task 5 – Sediment Sampling and Processing ..................................................3-13

3.2.5.1 Vibracoring/Sediment Sampling ........................................................3-13 3.2.5.2 Manual Coring ...................................................................................3-16

3.2.6 Task 6 – Biota Sampling ...................................................................................3-17 3.2.6.1 Electrofishing .....................................................................................3-18

3.2.7 Task 7 – Personnel and Equipment Decontamination......................................3-20 3.2.7.1 Personnel Decontamination ..............................................................3-20 3.2.7.2 PPE and Equipment Decontamination..............................................3-21

3.2.8 Task 8 – Demobilization....................................................................................3-24 3.3 Chemical Hazards..........................................................................................................3-25

Section 4. General Safety Practices.........................................................................................4-1 4.1 General Safety Rules .......................................................................................................4-1 4.2 Incident Investigation .......................................................................................................4-2 4.3 Safe Work Observation ....................................................................................................4-2 4.4 Activity Hazard Analysis (AHA) ........................................................................................4-3




4.5 Buddy System ..................................................................................................................4-3 4.6 Heat Stress.......................................................................................................................4-4 4.7 Cold Stress.......................................................................................................................4-8 4.8 Biological Hazards .........................................................................................................4-11

4.8.1 Tick-Borne Diseases .........................................................................................4-12 4.8.2 Poisonous Plants ..............................................................................................4-13 4.8.3 Snakes ..............................................................................................................4-13 4.8.4 Dogs ..................................................................................................................4-14 4.8.5 Spiders ..............................................................................................................4-14 4.8.6 Mosquitoes........................................................................................................4-15 4.8.7 Bees, Ants and Other Insects ...........................................................................4-16

4.9 Noise ..............................................................................................................................4-17 4.10 Spill Control ....................................................................................................................4-17 4.11 Sanitation .......................................................................................................................4-18

4.11.1 Break Area ........................................................................................................4-18 4.11.2 Potable Water ...................................................................................................4-18 4.11.3 Sanitary Facilities ..............................................................................................4-18 4.11.4 Lavatory ............................................................................................................4-19

4.12 Emergency Equipment...................................................................................................4-19 4.13 Lockout/Tagout Procedures...........................................................................................4-19 4.14 Electrical Safety .............................................................................................................4-20 4.15 Lifting Safety ..................................................................................................................4-21 4.16 Ladder Safety.................................................................................................................4-22 4.17 Carbon Monoxide...........................................................................................................4-23 4.18 Hot Work Safety Program ..............................................................................................4-25 4.19 Confined Space Entry ....................................................................................................4-28

4.19.1 Confined Space Identification and Designation ................................................4-29 4.19.2 Duties of Personnel...........................................................................................4-29 4.19.3 Procedures for Permit Space Entry ..................................................................4-31

Section 5. Personal Protective Equipment ..............................................................................5-1 5.1 Levels of Protection..........................................................................................................5-1

5.1.1 Level D Protection...............................................................................................5-1 5.1.2 Modified Level D Protection ................................................................................5-1 5.1.3 Level C Protection...............................................................................................5-2

5.2 PPE Selection ..................................................................................................................5-3 5.3 Site Respiratory Protection Program ...............................................................................5-3 5.4 Using PPE........................................................................................................................5-4

5.4.1 Donning Procedures ...........................................................................................5-4 5.4.2 Doffing Procedures .............................................................................................5-5

Section 6. Air and Noise Monitoring ........................................................................................6-1 6.1 Air Monitoring ...................................................................................................................6-1 6.2 Noise Monitoring ..............................................................................................................6-1 6.3 Monitoring Equipment Maintenance and Calibration .......................................................6-1 6.4 Action Levels ....................................................................................................................6-2

Section 7. Work Zones and Decontamination .........................................................................7-1 7.1 Work Zones ......................................................................................................................7-1

7.1.1 Authorization to Enter..........................................................................................7-1 7.1.2 Site Orientation and Hazard Briefing ..................................................................7-1 7.1.3 Certification Documents ......................................................................................7-1




7.1.4 Entry Log.............................................................................................................7-2 7.1.5 Entry Requirements ............................................................................................7-2 7.1.6 Emergency Entry and Exit...................................................................................7-2 7.1.7 Contamination-Control Zones .............................................................................7-2 7.1.8 Exclusion Zone....................................................................................................7-2 7.1.9 Contamination-Reduction Zone ..........................................................................7-3 7.1.10 Support Zone ......................................................................................................7-3 7.1.11 Posting ................................................................................................................7-3 7.1.12 Site Inspections...................................................................................................7-3

7.2 Decontamination ..............................................................................................................7-3 7.2.1 Personnel Decontamination................................................................................7-4 7.2.2 Equipment Decontamination...............................................................................7-4 7.2.3 Personal Protective Equipment Decontamination ..............................................7-4

Section 8. Training and Medical Surveillance .........................................................................8-1 8.1 Training ............................................................................................................................8-1

8.1.1 General................................................................................................................8-1 8.1.2 Basic 40-Hour Course.........................................................................................8-1 8.1.3 Supervisor Course ..............................................................................................8-2 8.1.4 Site-Specific Training ..........................................................................................8-2 8.1.5 Daily Safety Meetings .........................................................................................8-2 8.1.6 First Aid and CPR ...............................................................................................8-3

8.2 Medical Surveillance ........................................................................................................8-3 8.2.1 Medical Examination ...........................................................................................8-3 8.2.2 Pre-Placement Medical Examination ..................................................................8-3 8.2.3 Other Medical Examinations ...............................................................................8-4 8.2.4 Periodic Exam .....................................................................................................8-4 8.2.5 Medical Restriction..............................................................................................8-4

Section 9. Emergency Procedures...........................................................................................9-1 9.1 General.............................................................................................................................9-1 9.2 Emergency Response......................................................................................................9-1

9.2.1 Fire ......................................................................................................................9-1 9.2.2 Contaminant Release..........................................................................................9-2

9.3 Medical Emergency..........................................................................................................9-2 9.3.1 Emergency Care Steps .......................................................................................9-2

9.4 First Aid – General ...........................................................................................................9-3 9.4.1 First Aid – Inhalation ...........................................................................................9-3 9.4.2 First Aid – Ingestion ............................................................................................9-4 9.4.3 First Aid – Skin Contact.......................................................................................9-4 9.4.4 First Aid — Eye Contact......................................................................................9-4

9.5 Reporting Injuries, Illnesses, and Near-Miss Incidents ....................................................9-4 9.6 Emergency Information ....................................................................................................9-5

9.6.1 Directions to Regional Medical Center................................................................9-6 9.6.2 Map to Regional Medical Center.........................................................................9-6

Section 10. References .............................................................................................................10-1




Tables 2-1 Key Personnel 3-1 Minimum Safe Overhead Electrical Clearances 4-1 Work/Rest Schedule 4-2 Chill Temperature Chart 4-3 Carbon Monoxide Exposure Guidelines 5-1 PPE Selection Matrix 6-1 Action Levels for Air 9-1 Emergency Contacts Figures 1-1 Location Map 2-1 Project Organization Chart 9-1 Regional Medical Center Attachments A Underground/Overhead Utility Checklist B Sediment Sampling Checklist C PCB Chemical Hazard Information and Material Safety Data Sheet D Parathion Chemical Hazard Information and Material Safety Data Sheet E Paranitrophenol Chemical Hazard Information and Material Safety Data Sheet F Incident/Near-Miss Investigation Report G Safe Work Observation Form H Air Monitoring Form I Health and Safety Inspection Form J Safety Meeting Log K Hot Work Permit L Confined Space Entry Checklist M Confined Space Entry Permit Appendices (Electronic Only) 1 NTC Removal Action Supplemental Sampling Health and Safety Plan for the Anniston PCB Site




Distribution List

Organization Individual Number of Copies

Solutia Inc. Craig R. Branchfield 2

The Loper Group, Inc. John R. Loper 1

Monsanto Company Peter L. Virden Jr. 1

USEPA Pamela Scully 6 /10 (hard copy/electronic)

Whateley Drake LLC G. Douglas Jones 1

Dahl Environmental Services Thomas Dahl 1

Golder Associates, Inc. Gayle Macolly 1

Golder Associates, Inc. Charles Haury, CIH, CSP 1

Blasland, Bouck & Lee, Inc. Alan S. Fowler 1

Blasland, Bouck & Lee, Inc. Greg N. Ertel, CIH, CSP 1

ADEM Philip Davis 1




Acronyms and Abbreviations

ACGIH American Conference of Governmental Industrial Hygienists AHA Activity Hazard Analysis ANSI American National Standards Institute AOC Administrative Order on Consent BBL Blasland, Bouck & Lee, Inc. °C degrees Celsius CFR Code of Federal Regulations CD partial consent decree CO Carbon Monoxide COC constituent of concern CPR cardiopulmonary resuscitation CSM conceptual site model CRZ contamination-reduction zone dBa decibles adjusted DEET diethyltoluamide EMS Emergency Medical Services EZ exclusion zone °F degrees Fahrenheit Facility the Parties’ Anniston Facility FM Factory Mutual Engineering Corporation FSP field sampling plan Golder Golder Associates, Inc. GFCI ground-fault-circuit interrupter HASP health and safety plan HSO health and safety officer HSC health and safety coordinator LEL lower explosive limit MCC Monsanto Chemical Company mph miles per hour MSDS Material Safety Data Sheet NEC National Electrical Code NESC National Electrical Safety Code NIOSH National Institute for Occupational Safety and Health NTC Removal Agreement Non-time Critical Removal Agreement NRR noise reduction rating OSHA Occupational Safety and Health Administration OU operable unit Parathion ethyl parathion PCB polychlorinated biphenyl PEL Permissible Exposure Limit PID photoionization detector PFD personal floatation device PNP paranitrophenol PPE personal protective equipment psi pounds per square inch




PVC polyvinyl chloride RCRA Resource Conservation and Recovery Act RFI RCRA Facility Investigation RFI/CS RCRA Facility Investigation/Confirmatory Sampling RI/FS Remedial Investigation/Feasibility Study Site Anniston PCB Site SSO Site safety officer Swann Swann Chemical Company SWO Safe Work Observation SZ support zone ta adj adjusted air temperature TLV Threshold Limit Value The Parties Pharmacia Corporation and Solutia Inc., as signatory parties to the CD UL Underwriters Laboratory USCG United States Coast Guard USEPA United States Environmental Protection Agency VOCs volatile organic compounds



BLASLAND, BOUCK & LEE, INC. 6/3/04 engineers, scientists, economists 1-1 F:\FILEXCHG\ANNISTON\June 2004 HASP\Anniston HASP Rev 0.doc

1. Introduction

1.1 General

This Site-Wide Health and Safety Plan (Site-Wide HASP) has been prepared for the Anniston Polychlorinated

Biphenyl (PCB) Site (Site) (Figure 1-1) as a deliverable under the Partial Consent Decree (CD) for the Site

(Docket No. CV-02-PT-0749-E) entered by the United States District Court for the Northern District of

Alabama on August 4, 2003. The Site-Wide HASP addresses activities described in the Remedial

Investigation/Feasibility Study (RI/FS) Work Plan developed for the Site (Blasland, Bouck & Lee, Inc. [BBL],

2004) for the four Operable Units (OUs) identified in the Phase I Conceptual Site Model (CSM) Report (BBL,

2003). The Phase I CSM Report was approved by the United States Environmental Protection Agency

(USEPA) on March 5, 2004 (approval received March 8, 2004). Project activities may include the following:

• Mobilization/Site Survey;

• Groundwater Sampling;

• Soil Sampling;

• Air Sampling

• Residential Sampling and Excavation;

• Sediment Sampling

• Biota Sampling;

• Equipment Decontamination; and

• Demobilization.

While investigative and remedial activities in addition to those listed above may be conducted at the Site, this

Site-Wide HASP provides the framework and flexibility for these activities to be addressed through updates to

this plan. The Site-Wide HASP has been prepared on behalf of Pharmacia Corporation and Solutia Inc. as

signatory parties to the CD (herein after referred to as “the Parties”). The objective of this Site-Wide HASP is

to provide a mechanism for establishing safe working conditions at the Site. The safety organization,

procedures, and protective equipment have been established based on an analysis of potential hazards. Specific

hazard control methodologies have been evaluated and selected to minimize the potential of injury, illness, or

other hazardous incident.




1.2 Background

The Site is located in the north-central part of Alabama (Figure 1-1) and has been evaluated extensively over the

past 20 years. Manufacturing operations at the Parties’ Anniston Facility (Facility) began in 1917 with the

production of ferro-manganese, ferro-silicon, and ferro-phosphorous compounds and, later, phosphoric acid, by

the Southern Manganese Corporation. In 1927, the production of organic chemicals began with the introduction

of biphenyl, which remains a major product of the Facility. In 1930, Southern Manganese Corporation became

Swann Chemical Company (Swann); in May 1935, Swann was purchased by Monsanto Chemical Company

(MCC). Solutia, the present owner, was created as a spin-off of MCC in 1997.

A variety of organic and inorganic chemicals have been produced at the Facility during its history, including

PCBs, ethyl parathion (parathion), paranitrophenol (PNP), and phosphorus pentasulfide. Polyphenyl

compounds, which are used in a variety of heat-transfer fluid, plasticizer, and lubricant applications, are

currently manufactured at the Facility. PCBs were produced at the Facility from the late 1920s to 1971 by

reacting chlorine and biphenyl. Chlorine was also produced at the Facility between the 1950s and 1969 for the

sole purpose of supporting PCB manufacturing. Additional historical manufacturing information is presented in

the Resource Conservation and Recovery Act (RCRA) Facility Investigation/Confirmatory Sampling (RFI/CS)

Report (Golder Associates, Inc. [Golder], 2002).

The Anniston PCB Site includes both the Facility itself and areas beyond the Facility boundaries. The

geographical expanse of the overall Site is extensive, so the Site has been segmented into four Operable Units.

The Facility is defined as Operable Unit 3 (OU-3), and includes the manufacturing plant and two landfills. The

rest of the Site (the Off-Facility areas) is divided into OUs 1, 2, and 4, and includes the in-stream and 100-year

floodplain areas of Snow Creek, a 37-mile reach of Choccolocco Creek between its confluence with Snow

Creek and Lake Logan Martin. The geographic boundaries of the Site, including the extent of Off-Facility

areas, will be refined throughout the RI/FS process as additional data are collected.

Activities conducted under this Site-Wide HASP may occur in any of the four OUs. Each OU is briefly

described in the following subsections, and depicted on Figure 1-1.




1.2.1 Anniston Residential (OU-1)

OU-1 consists of residential properties that will be addressed in accordance with the Non-Time Critical

Removal Agreement (NTC Removal Agreement) (Appendix G to the CD). The definition of this OU was

selected based on the specific land use classification addressed by the NTC Removal Agreement, and the unique

and specific requirements identified under the NTC Removal Agreement that are separate and distinct from the

broader requirements of the CD. Work conducted under this OU will generally be limited to those residential

areas upstream of Highway 78. Residential properties located in the Oxford Lakes Neighborhood Zone (Zone

OLN) as defined in the Removal Agreement are also included in this OU. The process for further identifying

the geographic limits of OU-1 is presented in the Non-Time Critical Removal Supplemental Sampling and

Analysis Plan (Solutia, 2004). There is also an OU-1 specific HASP that has been submitted to the USEPA for

approval under the NTC removal agreement. The OU-1 HASP is included electronically as Appendix 1 to this

Site-Wide HASP (Solutia, 2003). A subcontractor-specific HASP for the removal of PCB-containing soils with

concentrations equal to or greater than 1 milligram per kilogram (mg/kg) will be prepared and submitted under

separate cover prior to the commencement of work under the NTC Removal Agreement.

1.2.2 Anniston Non-Residential (OU-2)

OU-2 includes non-residential properties of the Site upstream of Highway 78 up to and surrounding the On-

Facility area (OU-3). The geography of this area includes properties that are immediately north and east of the

On-Facility area that were historically part of the “On-Site” area, and non-residential areas that have historically

been addressed under the Administrative Order on Consent (AOC) (USEPA, 2001) (e.g., the 11th Street Ditch

and West 9th Street Creek). The lateral bounds of this OU potentially include both floodplain and non-

floodplain properties. Given the immediate focus on the residential portions of the Site (OU-1), the lateral

extent of OU-2 will be refined once the sampling of residential areas has been sufficiently implemented. Near-

term investigative activities under this OU are anticipated to include soil and air sampling as well as habitat and

species identification. A subcontractor-specific HASP for remedial activities to be performed at the 11th Street

Ditch, in accordance with an approved Removal Response Action Plan (Roux Associates, Inc. 2001) submitted

under the AOC, will be prepared following completion of the contractor selection process prior to field

mobilization.




1.2.3 Facility (OU-3)

This OU consists of the Facility itself including the plant Site, the South Landfill, and the West End Landfill.

Keeping this as a separate OU builds upon the significant remedial measures implemented to date at the Facility

and reflects the maturity of these efforts with regard to the RI/FS process (RI completion/FS initiation). In

addition, the consistent industrial character of this area and associated deed restrictions differentiate it from

other areas of the Site. Investigative activities in this OU are anticipated to include soil and groundwater

sampling and field observation of habitat and species identification.

1.2.4 Choccolocco Creek (OU-4)

This OU includes Choccolocco Creek and its floodplain downstream to Lake Logan Martin. It also includes the

lower end of Snow Creek and its floodplain downstream of Highway 78 to the confluence of Snow and

Choccolocco Creeks. This small portion of Snow Creek is more characteristic of Choccolocco Creek than the

upper reaches of Snow Creek and hence, it has been included in this OU. The floodplain and creek areas of this

OU are being kept together within one OU because a single receptor could experience multiple exposure

pathways that include both the creek and floodplain areas. Characterization activities under this OU are

anticipated to include biota, soil, and sediment sampling. Additional characterization activities may be added as

the field sampling plans (FSPs) for the OU are developed.

1.3 Policy Statement

Work activities at the Site will be carried out in a manner that protects the safety and health of contractors’

employees and the Parties’ employees and, where applicable, the public. The basic provisions of this plan are

mandatory for all personnel and contractors assigned to the project. In addition, all visitors must abide by the

requirements of this plan.

To that end, the objective of this Site-Wide HASP is to provide general health and safety information regarding

Site conditions and pertinent activities to allow contractors to develop individual Site-specific HASPs as

necessary. Work at OUs 1 and 3 will be conducted under the direction of Golder, while work at OUs 2 and 4

will be conducted under the direction of BBL. Activities carried out by employees of Golder, BBL,




subcontractors to either Golder or BBL, and contractors to the Parties who are under the direction of Golder or

BBL will be carried out in accordance with the provisions of this Site-Wide HASP. Contractors who are hired

to carry out a unique activity(ies) that is not addressed in this Site-Wide HASP will develop a Site-specific

HASP to outline the health and safety measures that will be implemented during the course of their efforts.

Each contractor’s HASP will be specific to the Site and to the task(s) that the contractor will be conducting. The

requirements in each contractor’s Site-specific HASP must be equivalent to or more stringent than those of this

Site-Wide HASP. Each Site-specific HASP will be distributed electronically and incorporated as an appendix to

this Site-Wide HASP.

The general safety procedures and protective equipment requirement presented in this general Site-Wide HASP

have been established based on an analysis of potential physical, chemical, and biological hazards. The hazard

control methodologies presented are intended to minimize the potential for accident or injury.

This Site-Wide HASP prescribes the procedures that must be followed during activities at the Site. Operational

changes that could affect the health and safety of personnel, the community, or the environment will not be

made without prior approval of the OU RI/FS Manager and the health and safety officer (HSO). This document

will be reviewed periodically to confirm that it is current and technically correct. Any changes in conditions at

the Site and/or the scope of work (as described above) will require a review of, and modification to, this Site-

Wide HASP. As indicated, such changes will be completed in the form of an addendum or a revision to the

Site-Wide HASP.

This Site-Wide HASP provides guidance in order to comply with applicable state and federal Occupational

Safety and Health Administration (OSHA) regulations, USEPA regulations, and the Parties’ health and safety

policies and procedures.

1.4 Definitions

The following definitions (listed alphabetically) are applicable to this Site-Wide HASP:

• Contamination-Reduction Zone (CRZ) - Area between the exclusion zone and support zone that

provides a transition between contaminated and clean areas. Decontamination stations are located in this

zone.




• Exclusion Zone (EZ) - Any portions of the Site where hazardous substances are present, or are

reasonably suspected to be present, and pose an exposure hazard to on-Site personnel.

• Incident - All losses, including first-aid cases, injuries, illnesses, near misses, spills/leaks, equipment

and property damage, motor vehicle accidents, regulatory violations, fires, and business interruptions.

• Near Miss - An incident in which no injury, illness, motor vehicle accident, equipment or property

damage, etc., occurred, but in which, under slightly different circumstances, could have occurred.

• On-Site Personnel - All of the Parties’ employees and subcontractor personnel involved with the

project.

• Project - All on-Site work performed under the scope of work.

• Site - The area described in Section 1.1, where the work is to be performed by the Parties’ personnel and

subcontractors.

• Support Zone (SZ) - All areas of the Site, except the EZ and CRZ. The SZ surrounds the CRZ and EZ.

Support equipment and break areas are located in this zone.

• Subcontractor - Includes contractor personnel hired by the Parties.

• Visitor - All other personnel, except the on-Site personnel.

• Work Area - The portion of the Site where work activities are actively being performed. This area may

change daily as work progresses and includes the SZ, CRZ, and EZ. If the work area is located in an

area on Site that is not contaminated or suspected of being contaminated, the entire work area may be a

SZ.




2. Roles and Responsibilities

2.1 Project Personnel

All of the Parties’ and contractor/subcontractors’ personnel must adhere to the procedures outlined in this Site-

Wide HASP during the performance of their work. Each person is responsible for completing tasks safely and

for reporting any unsafe acts or conditions to his/her supervisor. No person may work in a manner that conflicts

with these procedures. After due warnings, the OU RI/FS Manager will dismiss from the Site any person or

subcontractor who violates safety procedures.

All of the Parties’ and contractor/subcontractors’ personnel will receive training in accordance with applicable

regulations and be familiar with the requirements and procedures contained in this Site-Wide HASP prior to

initiating Site activities. This training will be documented for each individual. In addition, all personnel will

attend an initial hazard briefing prior to beginning work at the Site as well as daily safety meetings.

Any contractor or subcontractor conducting work at the Site is responsible for protection and health and safety of

their own employees, which may include the use of this document. However, any company which uses this

document for field activities must clearly identify the lines of authority for health and safety within their

organization, and evaluate whether the health and safety procedures outlined in this Site-Wide HASP are

appropriate for those activities.

The health and safety position requirements and lines of authority are described below, and key personnel are

identified in both Table 2-1 (see page 2-5) and Figure 2-1 (note that Figure 2-1 also depicts quality assurance

positions that while not directly applicable to the Site-Wide HASP, are important to the integrity/conduct of the

overall project). Compliance with this document will require that each contractor or subcontractor provide names

for the roles of the HSO, Health and Safety Coordinator (HSC), and Site Safety Officer (SSO). One individual may

be named to multiple roles. The names shall be presented in the initial Site health and safety briefing to all on-Site

personnel working for that company.




If the health and safety procedures outlined in this Site-Wide HASP are deemed to be inadequate for the work to be

conducted, or if the work activities are not addressed in this plan, an addendum (or revision) to this plan must be

prepared.

Use of this document also requires that a qualified HSO, HSC, or designee be on Site during all field activities

to oversee implementation of this plan. To be qualified, an HSO, HSC, or designee must have at least two years

field experience in health and safety at hazardous waste sites.

2.1.1 Anniston PCB Site Manager

The Anniston PCB Site Manager has overall responsibility for projects associated with the Site. The Anniston

PCB Site Manager has final authority for decisions made by the contractors and subcontractors implementing

the activities described in the RI/FS Work Plan for the Site.

2.1.2 CERCLA Manager

The Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) Manager has overall

responsibility for the management and technical oversight of the Anniston PCB Site CERCLA project. The

CERCLA Manager offers technical and management support to the Anniston PCB Site Manager.

2.1.3 Operable Unit RI/FS Managers

RI/FS Managers will be established for work conducted at the OUs. One person will be responsible for OUs 1

and 3, and another will be responsible for OUs 2 and 4. The OU RI/FS Managers are responsible for providing

resources so that project activities are completed in accordance with this Site-Wide HASP and for meeting all

regulatory and contractual requirements. The OU RI/FS Managers are also responsible for confirming that the

SSO has the equipment, materials, and qualified personnel to fully implement the safety requirements of this

Site-Wide HASP and/or that those subcontractors assigned to this project meet the minimum requirements. It is

also the responsibility of the OU RI/FS Managers to perform the following duties:

• Consult with the HSO on Site health and safety issues.




• Review Safe Work Observation (SWO) Forms.

• Verify that all incidents are thoroughly investigated.

• Approve, in writing, addenda or revisions to this Site-Wide HASP.

2.1.4 Health and Safety Officer (HSO)

The HSO or his/her designee has overall responsibility for the technical health and safety aspects of the project,

including review and approval of this Site-Wide HASP. Inquiries regarding health and safety procedures,

project procedures, and other technical or regulatory issues should be addressed to this individual. The HSO or

his/her designee must approve revisions or addenda to this Site-Wide HASP.

2.1.5 Health and Safety Coordinator (HSC)

The HSC is responsible for field health and safety issues, including the execution of this Site-Wide HASP.

Questions in the field regarding health and safety procedures, project procedures, and other technical or

regulatory issues should be addressed to this individual. The HSC will advise the OU RI/FS Managers on health

and safety issues and will establish and coordinate the project air monitoring program if one is deemed

necessary (see Section 6.1, Air Monitoring). The HSC is the primary Site contact on health and safety matters. It

is the responsibility of the HSC to perform the following duties:

• Verify that subcontractors meet health and safety requirements prior to commencing work.

• Suspend work or modify work practices, as necessary, for personal safety, protection of property, and

regulatory compliance.

• Provide on-Site technical assistance, if necessary.

• Participate in all Incident Investigations and confirm that they are reported to the HSO and OU RI/FS

Manager within 24 hours.

• Coordinate Site and personal air monitoring, as required, including equipment maintenance and

calibration.

• Conduct Site safety orientation training and safety meetings.

• Verify that personnel and subcontractors have received the required physical examinations and medical

certifications.




• Review Site activities with respect to compliance with this Site-Wide HASP.

• Maintain required health and safety documents and records.

• Assist the SSO in instructing field personnel on project hazards and protective procedures.

• Review SWO Forms.

2.1.6 Site Safety Officer (SSO)

The SSO is responsible for implementing this Site-Wide HASP, including communicating requirements to on-

Site personnel and subcontractors. The SSO will be responsible for informing the OU RI/FS Managers of

changes in the work plan, procedures, or Site conditions so that those changes may be addressed in this Site-

Wide HASP. Other responsibilities are to:

• Consult with the HSC on Site health and safety issues.

• Stop work, as necessary, for personal safety, protection of property, and regulatory compliance.

• Obtain a Site map and determine and post routes to medical facilities and emergency telephone

numbers.

• Notify local public emergency representatives (as appropriate) of the nature of the Site operations, and

post their telephone numbers (e.g., local fire department personnel who would respond for a confined-

space rescue).

• Observe on-Site project personnel for signs of ill-health effects.

• Investigate and report any incidents to the HSC.

• Verify that all on-Site personnel have completed applicable training.

• Verify that on-Site personnel are informed of the physical, chemical, and biological hazards associated

with the Site activities and of the procedures and protective equipment necessary to control the hazards.

• Issue/obtain any required work permits (hot work, etc.).




Table 2-1

Key Personnel

Role Name Address/Telephone No.

Anniston PCB Site Manager Craig Branchfield

702 Clydesdale Avenue

Anniston, AL 36201-5328

(256) 231-8404

CERCLA Manager John Loper



(256) 231-8420

RI/FS Manager (OU-1/OU-3) Gayle Macolly



(256) 231-8412

RI/FS Manager (OU-2/OU-4) Alan Fowler

100 Cummings Center

Suite 322G

Beverly, MA 01915-6112

(978) 921-0442

Health and Safety Officer (OU-

1/OU-3) Charles Haury, CIH, CSP

8933 Western Way

Jacksonville, FL 32256

(904) 363-3430

Health and Safety Officer (OU-

2/OU-4) Greg Ertel, CIH, CSP

155 Corporate Woods

Suite 150

Rochester, NY 14623-6715

(585) 292-6740

Health and Safety Coordinator (OU-

1/OU-3) TBD TBD

Health and Safety Coordinator (OU-

2/OU-4) TBD TBD

Site Safety Officer TBD TBD

TBD = to be determined




2.1.7 Subcontractors

Subcontractors and their personnel must understand and comply with applicable regulations and Site

requirements established in this Site-Wide HASP. Subcontractors who are conducting unique activities that are

not addressed under the Site-Wide HASP must prepare their own Site-specific HASPs; each Site-specific HASP

must be consistent with (or more stringent than) the requirements of this Site-Wide HASP and will be included

as an appendix to this document.

All subcontractor personnel will receive training in accordance with applicable regulations and be familiar with

the requirements and procedures contained in this Site-Wide HASP prior to initiating Site activities. All

subcontractor personnel will attend an initial hazard briefing prior to beginning work at the Site. Additionally,

on-Site subcontractor personnel must attend and participate in the daily Site safety meetings.

Subcontractors must designate individuals to function as the HSO, HSC, and SSO. A subcontractor may

designate one person to perform the duties of both the HSC and the SSO. However, depending on the level of

complexity of a contractor’s scope of work, it may not be feasible for one person to perform both functions

satisfactorily.

2.2 All On-Site Personnel

All on-Site personnel (including subcontractors) must read and acknowledge their understanding of this Site-

Wide HASP before commencing work, and abide by the requirements described in this document. All on-Site

personnel must sign the Acknowledgement Form (included immediately after the title page) after reviewing this

Site-Wide HASP.

All of the Parties’ and subcontractor personnel will receive training in accordance with applicable regulations

and be familiar with the requirements and procedures contained in this Site-Wide HASP prior to initiating Site

activities. In addition, all on-Site personnel will attend an initial hazard briefing prior to beginning work at the

Site as well as the daily safety meetings.

On-Site personnel will immediately report the following to the SSO or HSC:




• personal injuries and illnesses, no matter how minor;

• unexpected or uncontrolled release of chemical substances;

• symptoms of chemical exposure;

• unsafe or hazardous situations;

• unsafe or malfunctioning equipment;

• changes in Site conditions that may affect the health and safety of project personnel;

• damage to equipment or property;

• situations or activities for which they are not properly trained; and

• near misses.

2.3 Visitors

All visitors to Site work areas must check in with the SSO. Visitors will be cautioned to avoid skin contact with

materials that may be, or are suspected to be, impacted by constituents of concern (COCs).

Visitors requesting to observe work at the Site must don appropriate personal protective equipment (PPE) prior

to entry to the work area and must have the appropriate training and medical clearances to do so. If respiratory

protective devices are necessary, visitors who wish to enter the work area must have been respirator-trained and

fit-tested for a respirator within the past 12 months.

2.4 Stop Work Authority

Every employee of the Parties and their contractors and subcontractors is empowered, expected, and has the

responsibility to stop the work of another co-worker if the working conditions or behaviors are considered

unsafe.




3. Project Hazards and Control Measures

3.1 Introduction

Field activities will include the following tasks:

• Task 1 – Mobilization/Site Survey;

• Task 2 – Water, Soil, and Air Sampling;

• Task 3 – Drilling and Monitoring Well Installation;

• Task 4 – Residential Sampling and Excavation;

• Task 5 – Sediment Sampling and Processing

• Task 6 – Biota Sampling;

• Task 7 – Personnel and Equipment Decontamination; and

• Task 8 – Demobilization.

3.2 Field Activities, Hazards, and Control Procedures

The following task safety analyses identify potential health, safety, and environmental hazards associated with

each type of field activity listed above. Because of the complex and changing nature of field projects,

supervisors must continually inspect the Site to identify hazards that may affect on-Site personnel, the

community, or the environment. The SSO must be aware of these changing conditions and discuss them with the

OU RI/FS Manager whenever these changes impact employee health, safety, the environment, or performance

of the project. The SSO will keep on-Site personnel informed of the changing conditions and the OU RI/FS

Manager will write and/or approve addenda or revisions to this Site-Wide HASP as necessary.

Each field activity is described below, along with a discussion of potential hazards and control measures for

each activity.




3.2.1 Task 1 – Mobilization/Site Survey

Appropriate permits will be obtained by the OU RI/FS Manager or designee prior to starting this task.

Site mobilization and area reconnaissance will include establishing staging and decontamination locations,

determining the location of utilities and other installations, and establishing work areas. Mobilization may also

include setting up equipment and establishing a temporary Site office. A break area will be set up outside

regulated work areas. Mobilization may involve clearing areas for the SZ and CRZ.

During this initial phase, the OU RI/FS Manager will walk the Site to confirm the existence of anticipated

hazards and to identify safety and health issues that may have arisen since the writing of this plan. These

activities will be coordinated with personnel representing the Parties. The hazards of this phase of activity are

associated with heavy equipment operation, manual materials handling, installation of temporary on-Site

facilities, and manual Site preparation.

Hazards

Manual materials handling and manual Site preparation may cause blisters, sore muscles, and joint and skeletal

injuries; and may present eye, contusion, and laceration hazards. Installation of temporary field office and

support facilities may expose personnel to electrical hazards, underground and overhead utilities, and physical

injury due to the manual lifting and moving of materials. The work area presents slip, trip, and fall hazards from

scattered debris and irregular walking surfaces. Rainy weather may cause wet, muddy, and/or slick walking

surfaces and unstable soil. Freezing weather hazards include frozen, slick, and irregular walking surfaces.

Utility verification should be done well in advance of activities at a particular location. Attachment A provides

an example check list for use in verifying the location of buried or overhead utilities.

Environmental hazards include plants such as poison ivy and poison oak; aggressive fauna such as ticks,

mosquitoes, dogs, bees, ants, spiders, and snakes; weather such as sun, lightning, rain, and heat- or cold-related

illnesses; and pathogens such as rabies and blood-borne pathogens.




Control of Hazards

The primary controls for mobilization-related hazards include the following:

• selection, inspection, and use of the proper equipment;

• employee qualifications and training;

• establishment of work zones (EZ, CRZ, and SZ);

• use of a ground guide to position or move vehicles;

• use of the buddy system and internal and external communication systems; and

• appropriate PPE for each task (in most, but not all , cases Level D will be adequate.)

More detailed guidance on the control procedures for these hazards is presented in Section 4. Control

procedures for biological hazards are discussed in Section 4.8.

3.2.2 Task 2 – Water, Soil, and Air Sampling

Field sampling operations may consist of the collection of groundwater, surface water, soil, and air samples for

field screening and/or subsequent laboratory analysis. The physical hazards of this operation are primarily

associated with the sample collection methods and procedures implemented.

During the course of this project, several different sampling methodologies may be used based on equipment

accessibility and the types of materials to be sampled. These sampling methods may include hand

auger/sampling probes or hand trowel sampling operations for soils, use of a mechanical pump and bailer for

groundwater, and use of tedlar bags for air sample collection. Sample media are manually transferred to sample

containers for screening or shipment to an analytical laboratory for analysis. The primary hazards associated

with the specific sampling collection procedures are not generally serious and are briefly described below.

Hazards

Inhalation and absorption of COCs are the primary routes of exposure associated with sampling due to the

manipulation of sample media and equipment, manual transfer of media into sample containers, and proximity

of operations to the breathing zone. During this project, several different sampling methodologies may be used




based on equipment accessibility and the types of materials to be sampled. For example, during groundwater

sampling, methods may include hand or mechanical bailing. The primary hazards associated with these and

other sampling procedures are not generally serious; however, other operations in the area, or the conditions

under which samples must be collected may present chemical and physical hazards. The hazards associated

with sampling procedures are generally limited to strains or sprains from hand bailing, and other activities and

potential eye hazards. Chemical hazards include contact with media containing Site COCs and potential contact

with chemicals used as preservatives or for field analyses.

Sample collection may occur in locations accessible to vehicular traffic. In such locations, Site personnel must

isolate the work area with barricades, signs, cones, caution tape, or other appropriate means to alert passing

motorists to the presence of an active work area. Also, personnel who are exposed to vehicular traffic must

wear an outer layer of orange warning garments such as vests, jackets, or shirts. If work is performed in

darkness, workers will be outfitted with reflective garments of either orange, white (including silver-coated

reflective coatings or elements that reflect white light), yellow, fluorescent red-orange, or fluorescent yellow-

orange.

The flora and fauna of the Site that may present hazards are poison ivy, poison oak, ticks, ants, mosquitoes,

dogs, bees, spiders, and snakes. The work area presents slip, trip, and fall hazards from scattered debris and

irregular walking surfaces. Rainy weather may cause wet, muddy, slick walking surfaces and unstable soil.

Freezing weather hazards include frozen, slick, and irregular walking surfaces.

Control of Hazards

Dermal exposure can be controlled during sampling activities by wearing a minimum of Level D protection.

Placement of tools and equipment on the ground should be avoided to minimize contact with poisonous or

irritating flora and fauna. Air monitoring may be conducted during groundwater sampling in OU-3 to assess the

potential for exposure to airborne COCs. If the results of air monitoring indicate the presence of organic vapors

in a concentration causing concern, personnel will upgrade to Level C protection. Section 6.1, Air Monitoring,

describes air monitoring requirements and action levels. Each level of personal protection is described in

Section 5, Personal Protective Equipment. Control procedures for environmental and general hazards are

discussed in Section 4, General Site Safety Procedures




3.2.3 Task 3 – Drilling and Monitoring Well Installation

This task includes the installation of soil borings or monitoring wells at specified locations. The collection of

soil samples will involve the use of direct push type boring equipment (Geoprobe® or equivalent) or a

conventional drill rig. The equipment poses a hazard if it is not properly operated.

3.2.3.1 Geoprobe® Hazards and Control Procedures

Hazards

The primary physical hazards for this activity are associated with the use of the Geoprobe® equipment. The

equipment is hydraulically powered, and uses static force and dynamic percussion force to advance small-

diameter sampling tools.

Accidents can occur as a result of improperly placing the equipment on uneven or unstable terrain, or failing to

adequately secure the equipment prior to the start of operations. Overhead utility lines can create hazardous

conditions if contacted by the equipment. Underground installations such as electrical lines, conduit, and

product lines pose a significant hazard if contacted.

Slippery work surfaces can increase the likelihood of back injuries, overexertion injuries, and slips and falls.

The most common type of accident that occurs in material handling operations is the “caught between” situation

when a load is being handled and a finger or toe gets caught between two objects.

The equipment produces impact noise from the action of the soil-probing hammer.

Control of Hazards

The operator of the equipment must possess required state or local licenses to perform such work. All members

of the crew shall receive Site-specific training prior to beginning work.




The operator is responsible for the safe operation of the rig, as well as the crew’s adherence to the requirements

of this HASP. The operator must ensure that all safety equipment is in proper condition and is properly used.

The members of the crew must follow all instructions of the operator, wear all personal protective equipment,

and be aware of all hazards and control procedures. The operator and crew must participate in the daily safety

meetings and be aware of all emergency procedures.

Each day, prior to the start of work, the rig and associated equipment must be inspected by the operator. The

following items must be inspected:

• Vehicle condition;

• Proper storage of equipment;

• Condition of all hydraulic lines;

• Fire extinguisher;

• Eyewash kit; and

• First aid kit.

The rig must be properly leveled prior to beginning work. The wheels must be chocked.

All sampling locations will be inspected by the equipment operator prior to the deployment of the equipment to

verify a stable surface exists. This is especially important in areas where soft, unstable terrain is common.

Before beginning any intrusive activity, the existence and location of underground pipe, conduit, electrical

equipment, and other installations will be determined. This will be done, if possible, by contacting the

appropriate client representative or outside line locating service to mark the location of the lines. If knowledge

of the area is incomplete, an appropriate device, such as a magnetometer, will be used by a trained contractor to

locate the line. The Underground/Overhead Utility Checklist shall be used to document that nearby utilities

have been marked on the ground, and that each drilling location has been cleared. The checklist shall be in the

possession of the SSO prior to commencement of the intrusive investigation at that point of the Site (see

Attachment A). During any subsurface drilling, boring, or sampling the first five feet of the entry will be made

with minimal force using manual tools such as a post-hole digger or manual direct push method. If any

evidence of a product line or underground utility is encountered a new sampling location will be selected.






irritating flora and fauna. Air monitoring may be conducted when using a Geoprobe® in OU-3 to assess the

potential for exposure to airborne COCs. If the results of air monitoring indicate the presence of organic vapors

in a concentration causing concern, personnel will upgrade to Level C protection. Section 6.1, Air Monitoring,

describes air monitoring requirements and action levels. Each level of personal protection is described in

Section 5, Personal Protective Equipment. Control procedures for environmental and general hazards are

discussed in Section 4, General Site Safety Procedures

If equipment is operated in the vicinity of overhead power lines, the power to the lines must be shut off or the

equipment must be positioned and blocked such that no part, including cables, can come within the minimum

clearances as follows:

Table 3-1

Minimum Safe Overhead Electrical Clearances (all equipment)

Nominal System

Voltage

Minimum Required

Clearance

0-50kV 10 feet

51-100kV 12 feet

101-200kV 15 feet

201-300kV 20 feet

301-500kV 25 feet

501-750kV 35 feet

751-1,000kV 45 feet

3.2.3.2 Drilling

Hazards

The primary physical hazards for this activity are associated with the use of the drilling rig. Rig accidents can

occur as a result of improperly placing the rig on uneven or unstable terrain, or failing to adequately secure the




rig prior to the start of operations. Underground and overhead utility lines can create hazardous conditions if

contacted by drilling equipment. Tools such and equipment such as elevators, cat lines, and wire rope have the

potential for striking, pinning, or cutting personnel. Worn or frayed wire rope presents a laceration hazard if

loose wires protrude from the main bundle.

Cat lines are used on drilling rigs to hoist material. Accidents that occur during cat line operations may injure

the employee doing the rigging as well as the operator. Minimal hoisting control causes sudden and erratic load

movements, which may result in hand and foot injuries.

Slippery work surfaces can increase the likelihood of back injuries, overexertion injuries, and slips and falls.

The most common type of accident that occurs in material handling operations is the "caught between" situation

when a load is being handled and a finger or toe gets caught between two objects. Pipes and/or rolling stock can

shift and/or fall from a pipe rack or truck bed.

Control of Hazards

All drillers must possess required state or local licenses to perform such work. All members of the drill crew

shall receive Site-specific training prior to beginning work.

The driller is responsible for the safe operation of the drill rig as well as the crew's adherence to the

requirements of this HASP. The driller must ensure that all safety equipment is in proper condition and is

properly used. The members of the crew must follow all instructions of the driller, wear all personal protective

equipment, and be aware of all hazards and control procedures. The drill crews must participate in the daily

safety meetings and be aware of emergency procedures.

Each day, prior to the start of work, the drill rig and associated equipment must be inspected by the driller and/or

drill crew. The following items must be inspected:

• Vehicle condition;

• Proper storage of equipment;

• Condition of all wire rope;

• Fire extinguisher;




• Eyewash kit; and

• First aid kit.

The drill rig must be properly blocked and leveled prior to raising the derrick. Blocking provides a more stable

drilling structure by evenly distributing the weight of the rig. Proper blocking ensures that differential settling of

the rig does not occur. When the ground surface is soft or otherwise unstable, wooden blocks, at least 24" by

24" and 4" to 8" thick shall be placed between the jack swivels and the ground. The emergency brake shall be

engaged, and the wheels that are on the ground shall be chocked. The leveling jacks shall not be raised until the

derrick is lowered. The rig shall be moved only after the derrick has been lowered.

All drilling sites will be inspected by the driller prior to the location of the rig to verify a stable surface exists.

This is especially important in areas where soft, unstable terrain is common.

Before drilling, the existence and location of underground pipe, electrical equipment, and gas lines will be

determined. Public utility companies and property owner representatives will be contacted to mark the location

of existing lines. If necessary, an appropriate device, such as a magnetometer will be used buy a trained

contractor to locate the line prior to commencement of intrusive activities. The Underground/Overhead Utility

Checklist shall be used to document that nearby utilities have been marked on the ground, and that the drill site

has been cleared. The checklist shall be in the possession of the SSO prior to commencement of the intrusive

investigation at that point of the Site (See Attachment A). During any subsurface drilling, boring, or sampling

the first five feet of the entry will be made with minimal force using manual tools such as a post-hole digger or

manual direct push method. If any evidence of a product line or underground utility is encountered a new

sampling location will be selected.

Under no circumstances will personnel be permitted to ride the traveling block or elevators, nor will the catline

be used as a personnel carrier.

If drilling is conducted in the vicinity of overhead power lines, the power to the lines must be shut off or the

equipment must be positioned and blocked such that no part, including cables can come within the minimum

clearances as presented in Table 3-1:

When the drill rig is in transit, with the boom lowered and no load, the equipment clearance must be at least 4

feet for voltages less than 50kV, 10 feet for voltages of 50 kV to 345 kV, and 16 feet for voltages above 345 kV.




Drillers should never engage the rotary clutch without watching the rotary table, and ensuring it is clear of

personnel and equipment.

Unless the drawworks is equipped with an automatic feed control, the brake should not be left unattended

without first being tied down. Drill pipe, auger strings, or casing should be picked up slowly. Drill pipe should

not be hoisted until the driller is sure that the pipe is latched in the elevator, or the derrickman has signaled that

he may safely hoist the pipe.

During instances of unusual loading of the derrick or mast, such as when making an unusually hard pull, only

the driller should be on the rig floor; no one else should be on the rig or derrick.

The brakes on the drawworks of the drill rig should be tested by the driller each day. The brakes should be

thoroughly inspected by a competent individual each week.

A hoisting line with a load imposed should not be permitted to be in direct contact with any derrick member or

stationary equipment, unless it has been specifically designed for line contact.

Workers should never stand near the borehole whenever any wire line device is being run.

Hoisting control stations should be kept clean and controls labeled as to their functions.

Only experienced workers will be allowed to operate the cathead controls. The kill switch must be clearly

labeled and operational prior to operation of the catline. The cathead area must be kept free of obstructions and

entanglements.

The operator should not use more wraps than necessary to pick up the load. More than one layer of wrapping is

not permitted.

Personnel should not stand near, step over, or go under a cable or catline that is under tension.

Employees rigging loads on catlines shall:




• Keep out from under the load;

• Keep hands and feet where they will not be crushed;

• Be sure to signal clearly when the load is being picked up;

• Use standard visual signals only and not depend on shouting to coworkers; and

• Make sure the load is properly rigged, since a sudden jerk in the catline will shift or drop the load.

When two wires are broken or rust or corrosion is found adjacent to a socket or end fitting, the wire rope shall

be removed from service or resocketed. Special attention shall be given to the inspection of end fittings on

boom support, pendants, and guy ropes.

Wire rope removed from service due to defects shall be cut up or plainly marked as being unfit for further use as

rigging.

Wire rope clips attached with U-bolts shall have the U-bolts on the dead or short end of the rope; the clip nuts

shall be re-tightened immediately after initial load carrying use and at frequent intervals thereafter.

When a wedge socket fastening is used, the dead or short end of the wire rope shall have a clip attached to it or

looped back and secured to itself by a clip; the clip shall not be attached directly to the live end.

Protruding ends of strands in splices on slings and bridles shall be covered or blunted.

Except for eye splices in the ends of wires and for endless wire rope slings, wire rope used in hoisting, lowering,

or pulling loads, shall consist of one continuous piece without knot or splice. An eye splice made in any wire

rope shall have not less that five full tucks.

Wire rope shall not be secured by knots. Wire rope clips shall not be used to splice rope.

Eyes in wire rope bridles, slings, or bull wires shall not be formed by wire clips or knots.

Pipe and auger sections shall be transported by cart or carried by two persons. Individuals should not carry auger

or pipe sections without assistance.




Workers should not be permitted on top of the load during loading, unloading, or transferring of pipe or rolling

stock.

Employees should be instructed never to try to stop rolling pipe or casing; they should be instructed to stand

clear of rolling pipe.

Slip handles should be used to lift and move slips. Employees are not permitted to kick slips into position.

When pipe is being hoisted, personnel should not stand where the bottom end of the pipe could whip and present

a hazard striking them.

Pipe and augers stored in racks, catwalks, or on flatbed trucks should be secured to prevent rolling.



irritating flora and fauna. If necessary, based on field observations and Site conditions, air monitoring may be

conducted during drilling in OU-3 to assess the potential for exposure to airborne COCs. If the results of air

monitoring indicate the presence of organic vapors in a concentration causing concern, personnel will upgrade to

Level C protection. Section 6.1, Air Monitoring, describes air monitoring requirements and action levels. Each

level of personal protection is described in Section 5, Personal Protective Equipment. Control procedures for

environmental and general hazards are discussed in Section 4, General Site Safety Procedures

3.2.4 Task 4 – Residential Sampling and Excavation

This task involves household surface dust sampling, as well as surface and subsurface soil sampling followed by

potential excavation of PCB-containing soil (including locating and marking underground utilities) and transport

of removed soil and debris to the designated disposal facility(ies). Activities will be performed in accordance

with all applicable OSHA regulations. Detailed hazard and control information for residential sampling and

excavation can be found within Section 4 of the NTC Removal Action Supplemental Sampling Health and

Safety Plan for the Anniston PCB Site (Docket No. CV-02-PT-0749-E) (Solutia, 2003 – included electronically

as Appendix 1 to this document.) Details of the excavation portion of this task, including a subcontractor-

specific HASP, will be submitted to USEPA under separate cover prior to commencement of work.




3.2.5 Task 5 – Sediment Sampling and Processing

Sediment sampling will involve collecting samples and preparing them for subsequent field and/or laboratory

analysis. Vibracoring and/or manual coring methods may be utilized during this work.

In general, the primary hazards for sediment sampling include the following:

• working near and around water (drowning, hypothermia);

• caught-between injuries;

• ergonomic stresses; and

• exposure to chemical and biological (water-borne bacteria and microorganisms) hazards, extreme

weather, plants, and insects.

The primary controls for these hazards include the following:

• using only United States Coast Guard- (USCG-) approved equipment, including boats and personal

flotation devices (PFDs);

• completion of the Sediment Sampling Checklist (Attachment B);


• appropriate PPE for each task.

More specific hazards/controls related to vibracoring and manual coring are described in greater detail below.

3.2.5.1 Vibracoring/Sediment Sampling

Hazards

Working from a boat presents the obvious hazard of drowning, but several other hazards exist. Other ships and

pleasure craft may be present. Visibility can be hampered due to fog and rain. Water can become rough due to

weather and/or the passing of another vessel. Powered craft carry a fuel supply which has the potential for fire




or explosion if vapors accumulate and reach an ignition source. Weather, currents, and other watercraft may

also pose significant hazards to the crew.

Many of the physical hazards of vibracoring activities are associated with the equipment, sample collection

methods, procedures utilized, and the Site environment. Specific vibracore hazards include impact from moving

parts, pinch points, wire rope, use of a winch or windlass, overhead hazards, and noise. There exists a potential

for incidents involving personnel being struck by or struck against objects resulting in fractures, lacerations,

punctures, or abrasions. Manual equipment handling may cause blisters, sore muscles, and joint and skeletal

injuries, and may present eye, contusion, and laceration hazards. Walking and working surfaces may involve

slip, trip, and fall hazards due to slippery, unstable, and irregular walking surfaces.

Inhalation and absorption (contact) of COCs are the primary routes of entry associated with sediment sampling

due to the manipulation of sample media and equipment, manual transfer of media into sample containers, and

proximity of operations to the breathing zone.

Environmental hazards while conducting vibracore activities from a boat include weather, such as sunlight, heat

or cold, lightning, and rain as well as pathogens such as fecal coliform and bloodborne pathogens.

Chemical hazards may include contact with sediment, surface water, or other environmental media containing

COCs.

Control of Hazards

At a minimum, each employee working from a boat is required to participate in a boating safety training session

conducted prior to beginning field operations. The training session shall provide instruction on the following

topics: proper boat and safety equipment inspections; content and frequency of equipment safety inspections;

proper use of onboard safety equipment, including fire extinguisher, radio or cellular phone, flares, horn, etc.;

proper procedures on the completion and filing of a float plan; appropriate boating “rules-of-the-road;”

emergency procedures in the event of capsizing or being thrown overboard; and different types of PFDs and

their proper inspection and use.

On-Site personnel working over, adjacent to, or near water, where the danger of drowning exists, must wear a

USCG-approved PFD. Prior to and after each use, the PFD must be inspected for defects, which would alter its




effectiveness. Defective units must be removed from service. Ring buoys with at least 90 feet of line must be

provided and readily available for emergency rescue operations. Distance from ring buoys shall not exceed 200

feet. At least one boat must be immediately available at locations where personnel are working over or adjacent

to water.

Prior to each day or shift of operations, a vessel inspection must be conducted by the vessel operator. This

inspection shall be conducted in accordance with accepted USCG inspection procedures and applicable state

boating safety inspection procedures. The inspection must verify that necessary safety equipment is aboard and

functioning properly and that all members of the crew are aware of proper procedures that are to be followed on

the water. In addition, this information shall be reviewed during the daily safety meeting to ensure the

procedures have been followed and all crew members are satisfied as to their completion.

It will be the responsibility of the SSO to verify that the daily boat/equipment inspections are completed and

documented and that daily safety meetings are conducted. The following safety procedures shall be observed at

all times:

• Vessels shall not be overloaded with equipment or personnel.

• A minimum of two persons shall be on board during all boat operations.

• Loads shall be distributed evenly throughout the vessel.

• Type I, II, or III PFDs shall be worn at all times when working on or adjacent to the water.

• All PFDs shall be properly inspected to verify that appropriate USCG approvals and ratings information

is available.

• At least one Type IV PFD (seat cushion, ring buoy) shall be available on board.

• An audible signal/alarm (capable of being heard up to 0.5 mile away) shall be maintained in each vessel.

• Each vessel shall be equipped with a ship-to-shore radio, cellular phone, and/or “walkie-talkie” capable

of contacting the USCG, marine police, or other onshore station for help in an emergency.

• Each vessel shall be equipped with some type of visual display signal/device (e.g., flares or appropriate

distress flag).

• All powerboats shall have a valid state registration. This registration shall be maintained on the boat,

and as necessary be made available for USCG or marine police inspection.

• At a minimum, each powerboat shall be equipped with a Type 4-A, 10-B, C-rated fire extinguisher.

• Boats shall not be operated at night without proper lighting and the capability for making visual distress

signals.




In addition to PFDs, personnel who are working from a boat when water temperatures are below 50 degrees

Fahrenheit (ºF) must be equipped with thermal protective clothing/equipment (e.g., wet suits, dry suits). The

thermal protective clothing must be adequate to protect personnel from hypothermic effects of immersion in

water at the temperatures encountered.

Prior to initiating any activities, Site conditions will be discussed with all employees. Hazards will be identified

and protective measures will be explained. Equipment will be inspected and in proper working condition.

Extreme care will be taken when loading and unloading material and equipment. Proper lifting techniques must

be employed and two-person lifting techniques or mechanical assistance shall be provided for lifting heavy

items. PPE will initially be Level D or Modified Level D as outlined in Section 5.1.1 and 5.1.2. Hearing

protection must be utilized during generator operation. Air sampling in the processing area will be performed in

accordance with procedures outlined in Section 6.1. The results of air sampling may dictate upgrading to Level

C PPE. Avoidance of biological hazards as discussed in Section 4.8 will be implemented.

3.2.5.2 Manual Coring

Sediment samples may be collected manually from a boat or by wading into the water. This section outlines the

precautions that will be taken by on-Site personnel in these cases.

Hazards

Working from a boat presents the obvious hazard of drowning, but several other hazards exist. Other ships and

pleasure craft may be present. Visibility can be hampered due to fog and rain. Water can become rough due to

weather and/or the passing of another vessel. Powered craft carry a fuel supply which has the potential for fire

or explosion if vapors accumulate and reach an ignition source. Weather, currents, and other watercraft may

also pose significant hazards to the crew. Other hazards while coring from a boat are similar to those presented

in Section 3.2.5.1 (Vibracoring).

Control of Hazards

Given the similarity between this approach and that of collecting samples via vibracoring, refer to Section

3.2.5.1 for information relative to controls.




Sampling activities may also be carried out using hip waders and the required level of PPE. Waders must be

inspected prior to donning for holes, punctures, tears, or any other defect (i.e., missing straps) that would allow

water to enter. Personnel must wear a USCG-approved PFD or buoyant work vest during all activities

conducted in water. Prior to each use, the PFD or work vest must be inspected for defects that may alter its

strength or buoyancy. Defective units must be tagged “Do Not Use” and removed from service. The “buddy

system” will be strictly adhered to during any water-related activities. At no time will anyone enter the water

without another individual readily available to contact emergency services.

In addition to the drowning hazards associated with working on or near the water, there exists the possibility for

slips, trips, or falls caused by slippery, unstable, and irregular walking surfaces. Waders used for sampling

activities must be properly sized and provide the wearer with adequate traction.

PPE will initially be Level D or Modified Level D as outlined in Section 5.1.1 and 5.1.2. Air sampling in the

processing area will be performed in accordance with procedures outlined in Section 6.1. The results of air

sampling may dictate upgrading to Level C PPE.

3.2.6 Task 6 – Biota Sampling

Biota sampling activities may involve a potential for exposure to physical and health hazards. Hazards may also

be associated with the Site and the environmental conditions present during the collection of these organisms.

Hazards

The physical hazards of biota sampling activities are primarily associated with the Site environment. There

exists a potential for incidents involving personnel being struck by or struck against objects resulting in

fractures, lacerations, punctures, or abrasions. Manual materials handling may cause blisters, sore muscles, and

joint and skeletal injuries; and may present eye, contusion, and laceration hazards. Walking and working

surfaces during sampling activities my involve slip, trip and fall hazards due to slippery, unstable, and irregular

walking surfaces. Boating and drowning hazards exist and will present potential hazards for employees working

in, or near water, or working from a boat or a barge. Electrical hazards are potentially present from

electrofishing techniques that may be utilized to collect resident fish.




Chemical hazards may include contact with soil, sediment, surface water, or other environmental media

containing Site COCs and potential contact with chemicals used for biota sample preservation and equipment

decontamination procedures.

Control of Hazards

During sampling activities, a minimum of Level D protection will be worn. A USCG-approved PFD will be

worn if sampling occurs in open waters. Prior to initiating any biota sampling activities, the Site conditions will

be discussed with all employees. Hazards will be identified and protective measures will be explained.

Equipment will be inspected and in proper working condition. Extreme care will be taken when loading and

unloading samples and sampling equipment. Proper lifting techniques must be employed and mechanical

assistance shall be provided for large lifting tasks. Safety procedures outlined throughout the document shall be

implemented. PPE will initially be Level D or Modified Level D as outlined in Section 5.1.1 and 5.1.2 with a

PFD. Air sampling in the processing area will be performed in accordance with procedures outlined in Section

6.1. The results of air sampling may dictate upgrading to Level C PPE. Avoidance of biological hazards as

discussed in Section 4 will be implemented. Equipment shall be operated only by authorized personnel who

have been trained in accordance with the manufacturer’ instructions and recommendations. .

3.2.6.1 Electrofishing

Portable electrofishing equipment may be used to collect specimens from various areas of the Site. All

unauthorized or non-essential personnel will be moved to a safe distance away from active electrofishing

activities. The use of such equipment involves potential hazards related to the high voltage output. Because

water is an excellent conductor of electricity, the operator of the electrofisher must observe certain precautions

in order to avoid injury.

The electrofisher operates by sending current through the cathode, through the water, and to the anode. The

equipment operator must become part of the circuit in order to be shocked. Touching the cathode and anode

simultaneously would complete the circuit and result in a severe electric shock. Although touching only one of

the electrodes would not result in a shock, operators are not permitted to touch the electrodes.




Symptoms of electric shock range from muscle contraction (unable to let go), potential lung paralysis,

ventricular fibrillation, heart paralysis, severe burns, and death.

General Electrofishing Safety Procedures

The following general safety procedures apply to all types of electrofishers, and should be observed at all times:

• Use electrical lineman gloves of at least 5,000-volt rating. If the gloves become very wet inside, stop

electrofishing and dry them thoroughly.

• Remove wristwatch, rings, and other metal jewelry which is not protected by an insulated material.

• Use only dip nets with insulated or non-conductive handles.

• Make all electrical connections before turning on the power.

• Be sure all personnel are aware that electrofishing is going to begin and that they are clear of electrodes

before turning on the power.

• The equipment must include a switch that keeps the circuit open unless actively and continuously

closed. The operator also will have access to an emergency shut-off switch.

• Operate within acceptable power ranges to prevent overloading the equipment and minimize the

potential of fire hazard.

• During electrofishing, the high voltage flashing light and/or audible tone generator should be working.

• Do not touch people, equipment, or metal objects with the anode or cathode probes/surfaces.

• Wear polarized sunglasses to detect sub-surface hazards and obstacles.

• Turn the power off immediately if a problem occurs and also when the unit is not in use.

The following safety procedures apply specifically to the different types of electrofishing equipment that may be

used.

Backpack Electrofishers

The following safety procedures, including the general procedures listed above, should be observed at all times:

• Use water-tight wading hip boots or chest waders. If the waders or boots become wet inside, stop

electrofishing and dry them thoroughly.

• Operate slowly and carefully to prevent tripping on objects in the stream.




• Sampling must cease if persons, pets, or livestock are observed in the water or on shore within 12

meters of the electrofishing unit.

• To prevent overloading the unit, do not touch the cathode with the anode.

• Check that the mercury tilt switch shuts off the power when the unit is tipped more than 45° from

vertical.

• Backpack electrofishers add a burden to the user, requiring careful body positioning in order to avoid

back strain.

3.2.7 Task 7 – Personnel and Equipment Decontamination

3.2.7.1 Personnel Decontamination

All personnel that have entered the EZ will be decontaminated prior to leaving the zone.

Hazards

Personnel involved in decontamination activities may be dermally exposed to COCs if decontamination

procedures are not followed.

Control of Hazards

All personnel wearing Modified Level D or Level C protective equipment in the EZ must undergo personal

decontamination prior to entering the SZ. The following materials will be available for decontamination as

needed: galvanized wash tub, tap water, plastic sheeting, alkaline soap solution (Alconox® or other heavy duty

detergent), long handle scrub brushes, disposable plastic to cover the station area, disinfectant wipes to clean the

inside of a respirator, and distilled water in a squeeze bottle for rinsing The personnel decontamination area will

consist of the following stations at a minimum:

• Station 1: Personnel leaving the contaminated zone will remove the gross contamination from their outer

clothing and boots.




• Station 2: Personnel will remove their outer garments and gloves and dispose of them in properly labeled

containers. Personnel will then decontaminate their hard hats and boots with an aqueous solution of

detergent or other appropriate cleaning solution. These items will then be hand carried to the next station.

• Station 3: Personnel will thoroughly wash their hands and face before leaving the CRZ. Respirators will

be sanitized and then placed in a clean plastic bag.

3.2.7.2 PPE and Equipment Decontamination

All vehicles that have entered the EZ will be decontaminated at the decontamination pad prior to leaving the

zone. If the level of vehicle contamination is low, decontamination may be limited to rinsing of tires and wheel

wells with water. If the vehicle is significantly contaminated, steam cleaning or pressure washing with manual

scrub brushing of vehicles and equipment may be required.

Operations that have the potential to generate or release hazardous material will be conducted in a controlled

area using the appropriate engineering controls. Specific decontamination techniques will be established based

on Site conditions and tasks. Decontamination procedures will be reviewed with all personnel on Site. The

following materials will be available for decontamination as needed: galvanized wash tub, tap water, plastic

sheeting, alkaline soap solution (Alconox® or other heavy duty detergent), long handle scrub brushes,

disposable plastic to cover the station area, disinfectant wipes to clean the inside of a respirator, and distilled

water in a squeeze bottle for rinsing. If the vehicle is significantly contaminated, steam cleaning or pressure

washing with manual scrub brushing of vehicles and equipment may be required. A decontamination pad on a

suitable surface (concrete or paved area) with polyethylene sheeting or other appropriate containment system

will be established COC-impacted equipment will be determined “clean” through visual inspection of all

equipment.

The decontamination facility will be inspected on a daily basis for evidence of leaks or loss of integrity to the

containment system. If any deficiencies are noted, they will be corrected immediately. All waste water and

waste materials generated on Site will be contained in the decontamination system for characterization and

proper disposal.




Hazards

Personnel involved in decontamination activities may be dermally exposed to contaminated materials and

chemicals brought to the Site as part of the project work. Personnel involved in decontamination including

pressure washing activities may also be exposed to volatile emissions from heavily soiled equipment, high-

pressure water spray, and noise.

Pressure washing is the process of using a stream of water at high pressure to clean or prepare surfaces by

removing foreign matter and contaminants. The hazards of high-pressure water cleaning are related to the high

pressure of the water, which may exceed 10,000 pounds per square inch (psi) at the nozzle.

Contact with the water spray may cause severe lacerations, which may then be contaminated with hazardous

material. Because of the high pressure involved, the opportunity for slicing or injecting the water stream

through soft tissues of the body exists. Pressure washers will also cut through bone at high enough pressures. A

second hazard is repetitive motion, or cumulative trauma disorder. These serious disorders are related to

repeatedly squeezing the trigger or constantly fighting the pressure of the spray gun with the forearm or wrist.

When pressure washing or steaming the health and safety precautions outlined below must be observed.

Pressure washing presents a splash hazard. Protection against splashes to face and skin is mandatory. The

pressure washer is not to be pointed at a person at any time. Steam cleaning presents a thermal burn hazard in

addition to the hazards presented by pressure washing. Adequate protection from the hot surfaces must be

provided.

Control of Hazards

All personnel will review the operating procedures and PPE prior to decontamination. Personnel involved in

decontamination activities must wear PPE that is appropriate for the task (generally Level D) and no more than

one level below the level worn by personnel working in the EZ. Only persons trained in the use and

maintenance of a pressure washer may use such equipment.

Where and whenever possible, single-use, external protective clothing must be used for work within the EZ or

CRZ. This protective clothing must be disposed of in properly labeled containers. Reusable protective clothing

will be rinsed at the Site with detergent and water. The rinsate will be collected for disposal.




When removed from the CRZ, the respirators will be thoroughly cleaned with soap and water. The respirator

face piece, straps, valves, and covers must be thoroughly cleaned at the end of each work shift, and ready for use

prior to the next shift. Respirator parts may be disinfected with a solution of bleach and water, or by using a

spray disinfectant.

The following general requirements are provided for high-pressure water cleaning activities:

• The gun, pressure piping, pressure hose ends, and couplings will have a burst pressure of at least four

times the operating pressure.

• No equipment or component of such equipment will be operated beyond the manufacturer's

specifications or beyond the rated working pressure.

• The maximum operating pressure will be permanently displayed on the pumping unit.

• Safety glasses, face shield, hearing protection, and safety shoes will be worn during operation.

• Hands should be alternated frequently during long periods of use.

• Operators should be rotated periodically.

• A washer with a gun that supplies water to the wand in a straight line as opposed to supplying water

through the grip will be used. This eliminates the gun's twisting motion.

• The equipment will be maintained in good condition.

• The releasing the trigger must stop the flow of water. The trigger must not be tied back to keep it in an

“on” position.

• A hose safety shroud will be placed on hoses whenever operating pressure exceeds 2,000 psi.

• The pressure control will be a "deadman" type to safely reduce the nozzle discharge pressure when

control is released.

• The pressure discharge gauge indicating pump pressure will be clearly visible for monitoring pump

pressure.

• A pressure relief device set to relieve at 110% of the maximum working pressure of the unit or its

components, whichever is lower, will be installed on the pump. The relief will be clearly marked and

displayed on the device.

• A strainer or filter should be installed on the water supply system to prevent debris from entering the

water blasting units and clogging the gun, control, or other device.

• If a water line breaks, it may whip about; therefore, relieve the pressure before trying to grab the line.




3.2.8 Task 8 – Demobilization

Demobilization involves removing all tools, equipment, supplies, and vehicles brought to the Site. The hazards

of this phase of activity are associated with heavy equipment operation and manual materials handling.

Hazards

Manual materials handling may cause blisters, sore muscles, and joint and skeletal injuries and may present eye,

contusion, and laceration hazards. Heavy equipment operation presents noise and vibration hazards and hot

surfaces to operators. Personnel in the vicinity of heavy equipment operation may be exposed to physical

hazards resulting in fractures, contusions, and lacerations and may be exposed to high noise levels. The work

area presents slip, trip, and fall hazards from scattered debris and irregular walking surfaces. Rainy weather may

cause wet, muddy, and slick walking surfaces and unstable sediment. Freezing weather hazards include frozen,

slick, and irregular walking surfaces.

Environmental hazards include plants, such as poison ivy and poison oak; aggressive fauna, such as ticks,

mosquitoes, dogs, bees, ants, spiders, and snakes; weather, such as sun, lightning, rain, and heat- or cold-related

illnesses; and pathogens, such as rabies and bloodborne pathogens.

Control of Hazards

The primary controls for these hazards include the following:

• selection, inspection, and use of the proper equipment;

• employee qualifications and training;

• establishment of work zones: EZ, CRZ and SZ, with adequate containment areas;


• appropriate PPE for each task (generally Level D).

Control procedures for these hazards are discussed in more detail in Section 4. Section 4.8 presents control

measures for biological hazards.




3.3 Chemical Hazards

The chemical hazards associated with Site activities are related to inhalation, ingestion, and dermal exposure to

soil, sediment, surface water, and groundwater containing COCs. Although PCBs are the primary COC at the

Site, parathion and paranitrophenol (and breakdown products) may be encountered in groundwater. Specific

health and safety information regarding PCBs, parathion, and paranitrophenol are found in the Chemical Hazard

Information Tables in Attachment C, D and E respectively. The Material Safety Data Sheet (MSDS) for these

chemicals are also included in these Attachments.

The potential for inhalation of COCs during Site activities is low. The potential for dermal contact during Site

activities is moderate




4. General Safety Practices

4.1 General Safety Rules

At least one copy of this Site-Wide HASP must be in a location at the Site that is readily available to personnel,

and all project personnel shall review the plan prior to starting work. General safety rules for Site activities

include, but are not limited to, the following:

• All work performed on the Facility property will be conducted in accordance with Facility-specific

health and safety requirements.

• Consume or use food, beverages, chewing gum, and tobacco products only in the SZ or other designated

area outside the EZ and CRZ. Cosmetics must not be applied in the EZ or CRZ.

• Wash hands before eating, drinking, smoking, or using toilet facilities.

• Wear all PPE as required and stop work and replace damaged PPE immediately.

• Secure disposable coveralls, boots, and gloves at the wrists and legs and confirm closure of the suit

around neck.

• Upon skin contact with materials that may be impacted by COCs, remove contaminated clothing and

wash the affected area immediately. Contaminated clothing must be changed. Any skin contact with

materials potentially impacted by COCs must be reported to the SSO or HSC immediately. If needed,

medical attention should be sought.

• Practice contamination avoidance. Avoid contact with surfaces either suspected or known to be

impacted by COCs, such as standing water, mud, or discolored sediment. Equipment must be stored on

elevated or protected surfaces to reduce the potential for incidental contamination.

• Remove PPE as required in the CRZ to limit the spread of COC-containing materials.

• At the end of each shift, or as required, dispose of all single-use coveralls, soiled gloves, and respirator

cartridges in receptacles designated for this purpose.

• Do not remove materials containing Site COCs from protective clothing or equipment by using

compressed air, shaking, or any other means that disperses contaminants into the air.

• Inspect all non-disposable PPE for contamination in the CRZ. Any PPE found to be contaminated must

be decontaminated or disposed of appropriately.

• Recognize emergency signals used for evacuation, injury, fire, etc.




• Report all injuries, illnesses, near misses, and unsafe conditions or work practices to the SSO or HSC.

• Use the “buddy system” during all operations requiring Level C PPE and, when appropriate, during

Level D operations.

• Obey all warning signs, tags, and barriers. Do not remove any warnings unless authorized to do so.

• Use, adjust, alter, and repair equipment only if trained and authorized to do so and in accordance with

the manufacturer’s directions.

• Personnel are to perform only tasks for which they have been properly trained and will advise their

supervisor if they have been assigned a task for which they are not trained.

• The presence or consumption of alcoholic beverages or illicit drugs during the workday, including

breaks, is strictly prohibited. If your job requires equipment operation, let your supervisor know if you

must take prescription or over-the-counter drugs that state “do not operate heavy equipment,” or “may

cause drowsiness.”

• Remain upwind during Site activities whenever possible.

• Be aware of your surroundings. Watch out for uneven or slippery terrain. The majority of injuries

occur due to slips, trips, and falls.

4.2 Incident Investigation

An incident is any of the following events: first aid cases, injuries, illnesses, near misses, spills/leaks, equipment

and property damage, motor vehicle accidents, regulatory violations, fires, and business interruptions. All

incidents shall be investigated within 24 hours and reported to the OU RI/FS Manager and the HSO.

The purpose of an incident investigation is to prevent the recurrence of a similar hazardous event. An incident

investigation is set up so that all incidents in are reviewed in the same manner. Using the information gathered

during an incident investigation, appropriate measures will be taken to protect personnel from the hazard in

question. The Incident/Near-Miss Investigation Report is included in Attachment F.

4.3 Safe Work Observation

The SSO or the HSC will perform the SWO according to a schedule established by the HSC (see Section 7.1.12

for more information and Attachment G for the SWO Form). The purpose of the SWO is to identify and correct

potential hazards and to positively reinforce behaviors and practices that are correct. The SSO or HSC must




identify potential deviations from safe work practices that could possibly result in an incident and take prompt

corrective action. The SWO process includes the following steps:

• Identify tasks that have the greatest potential for hazardous incidents.

• Review the standard procedure for completing the task.

• Discuss with the observed employee the task and the SSO/HSC role in observing the task.

• Observe the employee completing the task.

• Reference the SWO Form for criteria. Complete the form, documenting positive actions as well as areas

in need of improvement.

• Discuss the results of the SWO with the employee. Discuss any corrective action that is necessary.

• Implement corrective action.

• Communicate the results of the SWO and corrective action to the OU RI/FS Manager and the HSO.

4.4 Activity Hazard Analysis (AHA)

AHA is a tool used to identify potential hazards and to develop corrective or protective systems to eliminate the

hazard. An AHA lists the potential hazards associated with an activity and shall be performed prior to

implementing any major investigation or remedial activity and will be included in OU-specific or contractor-

specific HASPs. Hazards may be physical, such as lifting hazards or eye hazards, or environmental, such as

those related to weather or biological hazards (stinging insects, snakes, etc.). After identifying the hazards

associated with an activity, control measures are evaluated and protective measures or procedures are then

instituted. AHAs are reviewed periodically to confirm that the procedures and protective equipment specified

for each activity are current and technically correct. Any changes in Site conditions and/or the scope of work

may require a review and modification to the AHA in question. During this review process, comments on the

AHA and its procedures should be obtained from personnel associated with the activity being analyzed.

4.5 Buddy System

On-Site personnel must use the “buddy system” as required by operations. Use of the buddy system is required

during all operations requiring Level C PPE and, when appropriate, during Level D operations. Crew members

in Level C PPE must observe each other for signs of chemical exposure and heat or cold stress. Indications of

adverse effects include, but are not limited to:




• changes in complexion and skin coloration;

• changes in coordination;

• changes in demeanor;

• excessive salivation and pupillary response; and

• changes in speech pattern.

Crew members must also be aware of the potential exposure to possible safety hazards, unsafe acts, or non-

compliance with safety procedures.

Field personnel must inform their partners or fellow crew members of non-visible effects of exposure to toxic

materials that they may be experiencing. The symptoms of such exposure may include, but are not limited to:

• headaches;

• dizziness;

• nausea;

• blurred vision;

• cramps; and

• irritation of eyes, skin, or respiratory tract.

If protective equipment or noise levels impair communications, pre-arranged hand signals must be used for

communication. Personnel must stay within line of sight of another team member.

Less stringent use of the buddy system is beneficial during operations requiring Level D PPE to the extent that

someone other than the person performing the activity knows where work is being performed and what activities

are being performed, especially if work is being performed in isolated areas, around water, or in extreme

temperatures.

4.6 Heat Stress

Heat stress is caused by several interacting factors, including environmental conditions, clothing, and workload,

as well as the physical and conditioning characteristics of the individual. Since heat stress is one of the most




common illnesses associated with heavy outdoor work conducted with direct solar load and, in particular,

because wearing PPE can increase the risk of developing heat stress, workers must be capable of recognizing the

signs and symptoms of heat-related illnesses. Personnel must be aware of the types and causes of heat-related

illnesses and be able to recognize the signs and symptoms of these illnesses in both themselves and their co-

workers.

Heat rash is one of the most common problems in hot work environments. Commonly known as prickly heat, a

heat rash is manifested as red papules and usually appears in areas where the clothing is restrictive. As sweating

increases, these papules give rise to a prickling sensation. Prickly heat occurs in skin that is persistently wetted

by unevaporated sweat, and heat rash papules may become infected if they are not treated. In most cases, heat

rashes will disappear when the affected individual returns to a cool environment.

Heat cramps are usually caused by performing hard physical labor in a hot environment. These cramps have

been attributed to an electrolyte imbalance caused by sweating. It is important to understand that cramps can be

caused both by too much and too little salt.

Cramps appear to be related to a lack of water replenishment. Because sweat is a hypotonic solution (plus or

minus 0.3% NaCl), excess salt can build up in the body if the water lost through sweating is not replaced. Thirst

cannot be relied on as a guide to the need for water; instead, water must be taken every 15 to 20 minutes in hot

environments.

Under extreme conditions, such as working for 6 to 8 hours in heavy protective gear, a loss of sodium may

occur. Drinking commercially available carbohydrate electrolyte replacement liquids is effective in minimizing

physiological disturbances during recovery.

Heat exhaustion occurs from increased stress on various body organs due to inadequate blood circulation,

cardiovascular insufficiency, or dehydration. Signs and symptoms include pale, cool, moist skin; heavy

sweating; dizziness; nausea; headache, vertigo, weakness, thirst, and giddiness. Fortunately, individuals in this

condition respond readily to prompt treatment.

Heat exhaustion should not be dismissed lightly, however, for several reasons. One is that the fainting associated

with heat exhaustion can be dangerous because the victim may be operating machinery or controlling an

operation that should not be left unattended; moreover, the victim may be injured when he or she faints. Also,




the signs and symptoms seen in heat exhaustion are similar to those of heat stroke, which is a medical

emergency.

Workers suffering from heat exhaustion should be removed from the hot environment, given fluid replacement,

and be encouraged to get adequate rest.

Heat stroke is the most serious form of heat stress. Heat stroke occurs when the body’s system of temperature

regulation fails, and the body’s temperature rises to critical levels. This condition is caused by a combination of

highly variable factors and its occurrence is difficult to predict.

Heat stroke is a medical emergency. The primary signs and symptoms of heat stroke are elevated or erratic

pulse; confusion; irrational behavior; loss of consciousness; convulsions; a lack of sweating (usually); hot, dry

skin; and an abnormally high body temperature. If body temperature is too high, it causes death. The elevated

metabolic temperatures caused by a combination of workload and environmental heat load, both of which

contribute to heat stroke, are also highly variable and difficult to predict.

If a worker shows signs of possible heat stroke, professional medical treatment should be obtained immediately.

The worker should be placed in a shady area and the outer clothing should be removed. The worker’s skin

should be wetted and air movement around the worker should be increased to improve evaporative cooling until

professional methods of cooling are initiated and the seriousness of the condition can be assessed. Fluids should

be replaced as soon as possible. The medical outcome of an episode of heat stroke depends on the victim’s

physical fitness and the timing and effectiveness of first-aid treatment.

Regardless of the worker’s protestations, no employee suspected of being ill from heat stroke should be sent

home or left unattended unless a physician has specifically approved such an order.

Proper training and preventive measures will help avert serious illness and loss of work productivity. Preventing

heat stress is particularly important because once someone suffers from heat stroke or exhaustion, that person

may be predisposed to additional heat injuries.




Safety Precautions for Heat Stress Prevention

Heat stress monitoring and work-rest cycle implementation should commence when the ambient adjusted

temperature exceeds 72°F. A minimum work-rest regimen and procedures for calculating ambient adjusted

temperature are described in Table 4-1.

Table 4-1

Work/Rest Schedule1

Adjusted Temperature2

Work/Rest Regimen

Normal Work Ensemble3

Work/Rest Regimen

Impermeable Ensemble

90ºF (32.2ºC) or above After each 45 minutes of work After each 15 minutes of work

87.5º-90ºF (30.8º-32.2ºC) After each 60 minutes of work After each 30 minutes of work

82.5º-87.5ºF (28.1º-30.8ºC) After each 90 minutes of work After each 60 minutes of work



1 For work levels of 250 kilocalories/hour (light to moderate type of work) 2 Calculate the adjusted air temperature (ta adj) by using this equation: ta adj oF = ta oF + (13 x % sunshine). Measure

air temperature (ta) with a standard mercury-in-glass thermometer, with the bulb shielded from radiant heat. Estimate

percent sunshine by judging what percent time the sun is not covered by clouds that are thick enough to produce a

shadow. (100% sunshine = no cloud cover and a sharp, distinct shadow; 0% sunshine = no shadows.) 3 A normal work ensemble consists of cotton coveralls or other cotton clothing with long sleeves and pants. 4 Rest cycle is assumed to last 5-15 minutes.

Source: The information presented above was generated using the information provided in the American Conference of Governmental

Industrial Hygienists (ACGIH) Threshold Limit Values [TLV] Handbook (2003a).

In order to determine whether the work-rest cycles are adequate for the personnel and specific Site conditions,

additional monitoring of individual heart rates will be conducted during the rest cycle. Personnel are

responsible for monitoring their own heart rates. To check the heart rate, count the radial pulse for 30 seconds at

the beginning of the rest period. If the heart rate exceeds 110 beats per minute, shorten the next work period by

one-third and maintain the same rest period.




Additionally, one or more of the following control measures can be used to help control heat stress and is

mandatory if any worker has a heart rate (measure immediately prior to rest period) exceeding 115 beats per

minute:

• Site workers will be encouraged to drink plenty of water and electrolyte replacement fluids throughout

the day.

• On-Site drinking water will be kept cool (50 to 60°F).

• A work regimen that provides adequate rest periods for cooling down will be established, as required.

• All personnel will be advised of the dangers and symptoms of heat stroke, heat exhaustion, and heat

cramps.

• Cooling devices, such as vortex tubes or cooling vests, should be used when personnel must wear

impermeable clothing in conditions of extreme heat.

• Employees should be instructed to monitor themselves and their buddy (if applicable) for signs of heat

stress, and to take additional breaks as necessary.

• A shaded rest area must be provided. All breaks should take place in the shaded rest area.

• Employees must not be assigned to other tasks during breaks.

• Employees must remove impermeable garments during rest periods. This includes white Tyvek®-type

garments.

• All employees must be informed of the importance of adequate rest, acclimation, and proper diet in the

prevention of heat stress disorders.

4.7 Cold Stress

Cold stress normally occurs in temperatures at or below freezing or under certain circumstances in temperatures

of 40°F. Extreme cold for a short time may cause severe injury to exposed body surfaces or result in profound

generalized cooling, causing death. Areas of the body that have high surface area-to-volume ratio, such as

fingers, toes, and ears, are the most susceptible. Two factors influence the development of a cold-weather injury:

ambient temperature and the velocity of the wind. For instance, 10°F with a wind of 15 miles per hour (mph) is

equivalent in chilling effect to still air at -18°F. An equivalent chill temperature chart relating the actual dry-bulb

temperature and wind velocity is presented in Table 4-2.




Table 4-2

Chill Temperature Chart

Actual Temperature Reading (ºF)

Estimated Wind

Speed (in mph)

50 40 30 20 10 0 -10 -20 -30 -40 -50 -60

Equivalent Chill Temperature (ºF)

Calm 50 40 30 20 10 0 -10 -20 -30 -40 -50 -60

5 48 37 27 16 6 -5 -15 -26 -36 -47 -57 -68

10 40 28 16 4 -9 -24 -33 -46 -58 -70 -83 -95

15 36 22 9 -5 -18 -32 -45 -58 -72 -85 -99 -112

20 32 18 4 -10 -25 -39 -53 -67 -82 -96 -110 -121

25 30 16 0 -15 -29 -44 -59 -74 -88 -104 -118 -133

30 28 13 -2 -18 -33 -48 -63 -79 -94 -109 -125 -140

35 27 11 -4 -20 -35 -51 -67 -82 -98 -113 -129 -145

40 26 10 -6 -21 -37 -53 -69 -85 -100 -116 -132 -148

(Wind speeds

greater than 40

mph have little

additional

effect.)

Little Danger

Maximum danger of false

sense of security.

Increasing Danger

Danger from freezing

of exposed flesh

within 1 minute.

Great Danger

Flesh may freeze within 30

seconds.

Trench foot and immersion foot may occur at any point on this chart.

This chart was developed by the U.S. Army Research Institute of Environmental Medicine, Natick, MA.

[Source: ACGIH TLV Handbook, 2003a]

Local injury resulting from cold is included in the generic term frostbite. There are several degrees of tissue

damage associated with frostbite. Frostbite of the extremities can be categorized into:

• Frost Nip or Incipient Frostbite – Characterized by sudden blanching or whitening of skin.

• Superficial Frostbite – Skin has a waxy or white appearance and is firm to the touch, but tissue beneath

is resilient.

• Deep Frostbite – Tissues are cold, pale, and solid; extremely serious injury.

Systemic hypothermia is caused by exposure to freezing or rapidly dropping temperature. It can be fatal. Its

symptoms are usually exhibited in five stages:




1) shivering;

2) apathy, listlessness, sleepiness, and (sometimes) rapid cooling of the body to less than 95°F;

3) unconsciousness, glassy stare, slow pulse, and slow respiratory rate;

4) freezing of the extremities; and

5) death.

Trauma sustained in freezing or sub-zero conditions requires special attention because an injured worker is

predisposed to secondary cold injury. Special provisions must be made to prevent hypothermia and secondary

freezing of damaged tissues in addition to providing for first-aid treatment. To avoid cold stress, Site personnel

must wear protective clothing appropriate for the level of cold and physical activity. In addition to protective

clothing, preventive safe work practices, additional training, and warming regimens may be used to prevent cold

stress.

Safety Precautions for Cold Stress Prevention

The following safety precautions should be followed to prevent cold stress:

• At air temperature of 0°F or less, mittens should be used to protect the hands. For exposed skin,

continuous exposure should not be permitted when air speed and temperature results in a wind chill

temperature of -25°F.

• At air temperatures of 36°F or less, field personnel who become immersed in water or whose clothing

becomes wet must be immediately provided with a change of clothing and be treated for hypothermia.

• If work is done at normal temperature or in a hot environment before entering the cold, the field

personnel must confirm that their clothing is not wet as a consequence of sweating. If clothing is wet,

field personnel must change into dry clothes prior to entering the cold area.

• If the available clothing does not give adequate protection to prevent hypothermia or frostbite, work

must be modified or suspended until adequate clothing is made available or until weather conditions

improve.

• Field personnel handling evaporative liquid (e.g., gasoline, alcohol, or cleaning fluids) at air

temperatures below 40°F must take special precaution to avoid soaking of clothing or gloves with the

liquids because of the added danger of cold injury due to evaporative cooling.




• Employees should be instructed to monitor themselves and their buddy for signs of cold stress and to

take additional breaks if necessary.

Safe Work Practices

The following safe work practices must be employed to prevent cold stress:

• Direct contact between bare skin and cold surfaces (< 20°F) should be avoided. Metal tool handles

and/or equipment controls should be covered by thermal insulating material.

• For work performed in a wind chill temperature at or below 10°F, workers should be under constant

protective observation (buddy system). The work rate should be established to prevent heavy sweating

that will result in wet clothing. For heavy work, rest periods must be taken in heated shelters and

workers should be provided with an opportunity to change into dry clothing if needed.

• Field personnel should be provided the opportunity to become accustomed to cold-weather working

conditions and required protective clothing.

• Work should be arranged in such a way that sitting or standing still for long periods is minimized.

• During the warming regimen (rest period), field personnel should be encouraged to remove outer

clothing to permit sweat evaporation or to change into dry work clothing. Dehydration, or loss of body

fluids, occurs insidiously in the cold environment and may increase susceptibility to cold injury due to a

significant change in blood flow to the extremities. Fluid replacement with warm, sweet drinks and

soups is recommended. The intake of coffee should be limited because of diuretic and circulatory

effects.

4.8 Biological Hazards

Hazards may include ticks, poisonous plants, snakes, dogs, spiders, mosquitoes, and bees.




4.8.1 Tick-Borne Diseases

Hazards

Rocky Mountain Spotted Fever: This disease is transmitted via the bite of an infected tick. The tick must be

attached 4 to 6 hours before the disease-causing organism (Rickettsia rickettsii) becomes reactivated and can

infect humans. The primary symptom of Rocky Mountain Spotted Fever is the sudden appearance of a

moderate-to-high fever. The fever may persist for 2 to 3 weeks. The victim may also have a headache, deep

muscle pain, and chills. A rash appears on the hands and feet on about the third day and eventually spreads to all

parts of the body. For this reason, Rocky Mountain Spotted Fever may be confused with measles or meningitis.

The disease may cause death if untreated, but if identified and treated promptly, death is uncommon.

Lyme Disease: This disease is transmitted primarily via the bite of an infected deer tick, which is smaller and

redder than the common wood tick. It may also be transmitted by immature ticks, which are small and hard to

see. The tick may be as small as a period on this page. Symptoms of Lyme disease include a rash or a peculiar

red spot, like a bull’s eye, which expands outward in a circular manner. The victim may have headache,

weakness, fever, a stiff neck, and swelling and pain in the joints, and eventually, arthritis.

Control of Hazards

Tick repellant containing diethyltoluamide (DEET) should be used when personnel are working in tick-infested

areas, and pant legs should be tucked into boots. In addition, workers should search the entire body every 3 or 4

hours for attached ticks. Ticks should be removed promptly and carefully without crushing, since crushing can

squeeze the disease-causing organism into the skin. A gentle and steady pulling action should be used to avoid

leaving the head or mouth parts in the skin. Hands should be protected with surgical gloves when removing

ticks.




4.8.2 Poisonous Plants

Hazards

Poisonous plants (e.g., poison ivy, poison sumac, and poison oak) may be present in the work area. Personnel

should be alerted to their presence and instructed on methods to prevent exposure.

Control of Hazards

The main control is to avoid contact with the plant, cover arms and hands, and frequently wash potentially

exposed skin. Particular attention must be given to avoiding skin contact with objects or protective clothing that

have touched the plants. Treat every surface that may have touched the plant as contaminated, and practice

contamination avoidance. If skin contact is made, the area should be washed immediately with soap and water,

and observed for signs of reddening.

4.8.3 Snakes

Hazards

The possibility of encountering snakes exists, specifically for personnel working in wooded/vegetated areas.

Snake venoms are complex and include proteins, some of which have enzymatic activity. The effects produced

by venoms include neurotoxic effects with sensory, motor, cardiac, and respiratory difficulties; cytotoxic effects

on red blood cells, blood vessels, heart muscle, kidneys, and lungs; defects in coagulation; and effects from local

release of substances by enzymatic actions. Other noticeable effects of venomous snakebites include swelling,

edema, and pain around the bite, and the development of ecchymosis (the escape of blood into tissues from

ruptured blood vessels). Snakes encountered may range from common garter and watersnakes to rat snakes,

king snakes, and pit vipers.

Control of Hazards

To minimize the threat of snakebites, all personnel walking through vegetated areas must be aware of the

potential for encountering snakes and the need to avoid actions potentiating encounters, such as turning over




logs. If a snakebite occurs, an attempt should be made to safely identify the snake via size and markings. The

victim must be transported to the nearest hospital within 30 minutes. First aid consists of applying a constriction

band and washing the area around the wound to remove any unabsorbed venom.

4.8.4 Dogs

Hazards

Sampling is to take place on residential property. In some instances residents may have dogs, which may be

unfriendly to field personnel.

Control of Hazards

The sampling team will not sample properties where dogs are loose in the yard without the immediate and

constant presence of the dog owner. In most cases, the samplers should not proceed to conduct sampling unless

the dog is restrained. Additionally, the sampling team should be aware that wild, stray or unleashed dogs might

be present in the residential neighborhoods. If such dogs are encountered, the sampling team should not

approach or provoke the animals but they may report the animal(s) to the Anniston Police Department Animal

Control, if encountered within city limits. The Anniston Police Department can be reached at (256) 238-1800.

Otherwise, Calhoun County Animal Control may be called. Calhoun County Animal Control can be reached at

(256) 310-4268. Mace may be used as a deterrent, if attacked.

4.8.5 Spiders

Hazards

The possibility of personnel encountering spiders exists during work activities.

Two spiders are of primary concern: the black widow and the brown recluse. Both prefer dark, sheltered areas

such as basements, equipment sheds and enclosures, and around woodpiles or other scattered debris. The black

widow is shiny black, approximately one inch long, and found throughout the United States. There is a

distinctive red hourglass marking on the underside of the black widow’s body. The bite of a black widow is




seldom fatal to healthy adults, but effects include respiratory distress, nausea, vomiting, and muscle spasms. The

brown recluse is smaller than the black widow and gets its name from its brown coloring and behavior. The

brown recluse is more prevalent in the southern United States. It has a distinctive violin shape on the top of its

body. The bite of the brown recluse is painful, and the bite site ulcerates and takes many weeks to heal

completely.

Control of Hazards

To minimize the threat of spider bites, all personnel walking through vegetated areas must be aware of the

potential for encountering these arachnids. Personnel need to avoid actions that may result in encounters, such as

turning over logs and placing hands in dark places such as behind equipment or in corners of equipment sheds or

enclosures. If a spider bite occurs, the victim must be transported to the nearest hospital as soon as possible.

First aid consists of applying ice packs and washing the area around the wound to remove any unabsorbed

venom.

4.8.6 Mosquitoes

Hazards

Personnel may be exposed to mosquitoes during work activities. Typical exposure to mosquitoes does not

present a significant hazard. However, if West Nile virus is prevalent in the area, exposure to this virus is

increased. West Nile virus results in flu-like symptoms and can be serious if not treated or in immune

compromised individuals.

Control of Hazards

To minimize the threat of mosquito bites, all personnel working outside must be aware of the potential for

encountering mosquitoes and implement the basic precautions listed below:

• Avoid working at dawn or dusk when mosquitoes are most active.

• Prevent accumulation of standing water at the work Site.

• Apply an insect repellent that contains DEET to exposed skin and to clothing.




• Wear light-colored clothes, preferably with long sleeves and full-length pants.

• Do not touch any dead birds or animals that are encountered.

If dead birds are detected near the Site, report them to the local County Health Department. If individuals

experience flu-like symptoms, a doctor or the HSO should be contacted for more information.

4.8.7 Bees, Ants and Other Insects

Hazards

A variety of Insects may be present at the Site. Although stings or bites can be painful, they rarely cause death.

However, some people have a severe reaction to an insect bite or sting that can result in a life-threatening

condition.

Control of Hazards

To minimize the threat of bites or stings, all personnel should implement the following precautions:

• Apply insect repellant as described above.

• Wear proper protective clothing.

• When working in wooded areas, avoid contact with bushes, tall grass, or brush as much as possible.

• Use caution when opening monitoring well caps; inspect potential nesting areas before entering casing,

vaults, etc. If desired, leather gloves may be worn.

• Field personnel who may have insect allergies should provide this information to the HSO prior to

commencing work. If allergic to bees, employee must bring an epi-pen.

• Mark and avoid fire ant mounds and bee hives




4.9 Noise

Hazards

Exposure to noise over the appropriate action level can cause temporary impairment of hearing; prolonged and

repeated exposure can cause permanent damage to hearing. The risk and severity of hearing loss increase with

the intensity and duration of exposure to noise. In addition to damaging hearing, noise can impair voice

communication, thereby increasing the risk of accidents on Site.

Control of Hazards

All personnel must wear hearing protection, with a noise reduction rating (NRR) of at least 20 decibels adjusted

(dBA), when noise levels exceed 85 dBA. When it is difficult to hear a co-worker at normal conversation

distance, the noise level is approaching or exceeding 85 dBA and hearing protection is necessary. All Site

personnel who may be exposed to noise must also receive baseline and annual audiograms and training as to the

causes and prevention of hearing loss. Noise monitoring is discussed in Section 6, Air and Noise Monitoring.

Whenever possible, equipment that does not generate excessive noise levels will be selected. If the use of noisy

equipment is unavoidable, barriers or increased distances will be used to minimize worker exposure to noise, if

feasible.

4.10 Spill Control

All personnel must take every precaution to minimize the potential for spills during Site activities. All on-Site

personnel must immediately report any discharge, no matter how small, to the SSO.

Spill control equipment and materials will be located on Site in the areas that present the potential for discharge.

All sorbent materials used to clean up spills will be containerized and labeled appropriately. In the event of a

spill, the SSO will follow the emergency provisions in Section 9, Emergency Procedures, to contain and control

released materials and to prevent their spread to off-Site areas.




4.11 Sanitation

Site sanitation will be maintained according to appropriate federal, state, and local requirements as described in

the following sections.

4.11.1 Break Area

Breaks must be taken in the SZ, away from the active work area, after Site personnel go through

decontamination procedures. There will be no smoking, eating, drinking, or chewing gum or tobacco in any area

other than the SZ.

4.11.2 Potable Water

The following rules regarding potable water apply to all field operations:

• An adequate supply of potable water will be provided at each project location. Potable water must be

kept away from hazardous materials or media and contaminated clothing or equipment.

• Portable containers used to dispense drinking water must be capable of being tightly closed and must be

equipped with a tap dispenser. Water must not be consumed directly from the container (drinking from

the tap is prohibited) or removed from the container by dipping.

• Containers used for drinking water must be clearly marked and must not be used for any other purpose.

• Disposable drinking cups must be provided. A sanitary container for dispensing cups and a receptacle

for disposing of used cups is required.

4.11.3 Sanitary Facilities

Access to facilities for washing before eating, drinking, or smoking, or alternative methods such as waterless

hand cleaner and paper towels, will be provided.




4.11.4 Lavatory

If permanent toilet facilities are not available, an appropriate number of portable chemical toilets will be

provided. This requirement does not apply to mobile crews or to normally unattended Site locations so long as

employees at these locations have transportation immediately available to nearby toilet facilities.

4.12 Emergency Equipment

Adequate emergency equipment for the activities being conducted on Site and as required by applicable sections

of 29 Code of Federal Regulations (CFR) 1910 and 29 CFR 1926 will be on Site prior to commencing project

activities. Personnel will be provided with access to emergency equipment including, but not limited to, the

following:

• Fire extinguishers of adequate size, class, number, and location as required by applicable sections of 29

CFR 1910 and 1926;

• Industrial first-aid kits of adequate size for the number of personnel on Site; and

• Emergency eyewash and/or shower if required by operations being conducted on Site.

4.13 Lockout/Tagout Procedures

Lockout/tagout procedures are necessary when working around or with a variety of equipment and energy

sources that can present significant life-threatening hazards to workers. Unexpected start-up of equipment or

exposure to hazardous energy must be controlled.

Lockout is the placement of a device that uses a positive means, such as lock, to hold an energy or material-

isolating device such that the equipment cannot be operated until the lockout device is removed. If a device

cannot be locked out, a tagout system shall be used. Tagout is the placement of a warning tag on an energy or

material isolating device indicating that the equipment controls may not be operated until the tag is removed by

the individual who attached the tag. Locks and tags will be issued to authorized personnel by the SSO.




Personnel involved in lockout/tagout activities must be trained according to their role and level of responsibility.

In lockout/tagout procedures there are two types of personnel: authorized personnel and affected personnel.

Authorized personnel are trained and experienced in the hazards and control measures who locks out or tags out

machines or equipment in order to perform servicing or maintenance on that machine or equipment. Affected

personnel become authorized personnel when their duties include performing servicing or maintenance covered

under this section. Authorized personnel possess the skills knowledge or certifications to implement the

lockout/tagout program.

Affected personnel are those job requires him/her to operate or use a machine or equipment on which servicing

or maintenance is being performed under lockout or tagout, or whose job requires him/her to work in an area in

which such servicing or maintenance is being performed. Personnel who may work on or around equipment that

may utilize the lockout/tagout procedure must be considered affected employees, unless they are specifically

prevented from doing so. Affected personnel are not allowed to lockout/tagout equipment or work on machines

or equipment when the guards have been removed.

Contractors performing activities involving locking out or tagging out must have a written lockout/tagout

program that includes provisions to meet OSH 29 CFR 1910.147.

4.14 Electrical Safety

Electricity may pose a particular hazard to Site workers due to the use of portable electrical equipment. If wiring

or other electrical work is needed, a qualified electrician must perform it.

General electrical safety requirements include:

• All electrical wiring and equipment must be of a type listed by Underwriters Laboratory (UL), Factory

Mutual Engineering Corporation (FM), or other recognized testing or listing agency.

• All installations must comply with the National Electrical Safety Code (NESC), the National Electrical

Code (NEC), or USCG regulations.

• Portable and semi-portable tools and equipment must be grounded by a multi-conductor cord having an

identified grounding conductor and a multi-contact polarized plug-in receptacle.




• Tools protected by an approved system of double insulation, or its equivalent, need not be grounded.

Double-insulated tools must be distinctly marked and listed by UL or FM.

• Live parts of wiring or equipment must be guarded to prevent persons or objects from touching them.

• Electric wire or flexible cord passing through work areas must be covered or elevated to protect it from

damage by foot traffic, vehicles, sharp corners, projections, or pinching.

• All circuits must be protected from overload.

• Temporary power lines, switchboxes, receptacle boxes, metal cabinets, and enclosures around

equipment must be marked to indicate the maximum operating voltage.

• Plugs and receptacles must be kept out of water unless of an approved submersible construction.

• All extension cord outlets must be equipped with ground-fault-circuit interrupters (GFCIs).

• Attachment plugs or other connectors must be equipped with a cord grip and be constructed to endure

rough treatment.

• Extension cords or cables must be inspected prior to each use and replaced if worn or damaged. Cords

and cables must not be fastened with staples, hung from nails, or suspended by bare wire.

• Flexible cords must be used only in continuous lengths without splice, with the exception of molded or

vulcanized splices made by a qualified electrician.

4.15 Lifting Safety

Using proper lifting techniques may prevent back strain or injury. The fundamentals of proper lifting include:

• Consider the size, shape, and weight of the object to be lifted. A mechanical lifting device or additional

persons must be used to lift an object if it cannot be lifted safely alone.

• Hands and the object should be free of dirt or grease that could prevent a firm grip.

• Gloves must be used and the object inspected for metal slivers, jagged edges, burrs, or rough or slippery

surfaces.

• Fingers must be kept away from points that could crush or pinch them, especially when putting an

object down.

• Feet must be placed far enough apart for balance. The footing should be solid and the intended pathway

should be clear.

• The load should be kept as low as possible, close to the body with the knees bent.

• To lift the load, grip firmly and lift with the legs, keeping the back as straight as possible.




• A worker should not carry a load that he or she cannot see around or over.

• When putting an object down, the stance and position are identical to that for lifting; the legs are bent at

the knees, and the back is straight as the object is lowered.

4.16 Ladder Safety

When portable ladders are used for access to an upper landing surface, the ladder side rails shall extend at least 3

feet above the upper landing surface to which the ladder is used to gain access; or, when such an extension is not

possible because of the ladder’s length, then the ladder shall be secured at its top to a rigid support that will not

deflect, and a grasping device, such as a grabrail, shall be provided to assist employees in mounting and

dismounting the ladder. In no case shall the extension be such that ladder deflection under a load would, by

itself, cause the ladder to slip off its support.

• Ladders shall be maintained free of oil, grease, and other slipping hazards.

• Ladders shall not be loaded beyond the maximum intended load for which they were built, nor beyond

their manufacturer’s rated capacity.

• Ladders shall be used only for the purpose for which they were designed.

• Non-self-supporting ladders shall be used at an angle such that the horizontal distance from the top

support to the foot of the ladder is approximately one-quarter of the working length of the ladder (the

distance along the ladder between the foot and the top support).

• Wood job-made ladders with spliced side rails shall be used at an angle such that the horizontal distance

is one-eighth the working length of the ladder.

• Fixed ladders shall be used at a pitch no greater than 90 degrees from the horizontal, as measured to the

back side of the ladder.

• Ladders shall be used only on stable and level surfaces unless secured to prevent accidental displacement.

• Ladders shall not be used on slippery surfaces unless secured or provided with slip-resistant feet to

prevent accidental displacement. Slip-resistant feet shall not be used as a substitute for care in placing,

lashing, or holding a ladder that is used upon slippery surfaces, including, but not limited to, flat metal or

concrete surfaces that are constructed so they cannot be prevented from becoming slippery.

• Ladders placed in any location where they can be displaced by workplace activities or traffic, such as in

passageways, doorways, or driveways, shall be secured to prevent accidental displacement, or a barricade

shall be used to keep the activities or traffic away from the ladder.




• The area around the top and bottom of ladders shall be kept clear.

• The top of a non-self-supporting ladder shall be placed with the two rails supported equally unless it is

equipped with a single support attachment.

• Ladders shall not be moved, shifted, or extended while occupied.

• Ladders shall have non-conductive siderails if they are used where the employee or the ladder could

contact exposed energized electrical equipment.

• The top most step of the ladder should not be used as a step, nor should any step above a step on a ladder

that is labeled “not a step”.

• Cross-bracing on the rear section of stepladders shall not be used for climbing unless the ladders are

designed and provided with steps for climbing on both front and rear sections.

• Ladders shall be inspected by the HSO for visible defects on a daily basis and after any occurrence that

could affect their safe use.

• Portable ladders with structural defects, such as, but not limited to, broken or missing rungs, cleats, or

steps; broken or split rails; corroded components; or other faulty or defective components shall either be

immediately marked in a manner that readily identifies them as defective, or be tagged with “Do Not

Use” or similar language, and shall be withdrawn from service.

• Fixed ladders with structural defects, such as, but not limited to, broken or missing rungs, cleats, or steps;

broken or split rails; or corroded components; shall be withdrawn from service.

• Ladder repairs shall restore the ladder to a condition meeting its original design criteria, before the ladder

is returned to use.

• Single-rail ladders shall not be used.

• When ascending or descending a ladder, the user shall face the ladder.

• Each employee shall use at least one hand to grasp the ladder when progressing up and/or down the

ladder.

• Employees shall not climb any ladder while carrying items with their hands.

4.17 Carbon Monoxide

When working indoors with any type of gasoline, diesel or liquid petroleum gas powered equipment carbon

monoxide (CO) is a significant hazard. Recognize that a single generator, propane heater or propane fork truck

can quickly generate CO above the permissible exposure level regardless of the size of the room. The following

guidelines will be implemented to mitigate any CO issues.




• Utilize remotely powered equipment whenever possible. Validate that the exhaust from the generating

unit is not being sucked or blown back into the building.

• Use an approved exhaust extension for stationary work. Run the extension to the outside of the

building.

• Do not use unvented gas or kerosene space heaters in enclosed spaces

• Do not sit in running cars for extended periods of time; if it is necessary to be in an idling vehicle, leave

windows partially opened

• When operating any fossil-fueled equipment indoors, ensure that all pre-operation equipment checks are

completed and that the equipment is running to specifications. Smokey exhaust, sputtering, backfires,

etc. all indicate an equipment problem requiring immediate service.

• Provide ventilation within the building regardless of the weather outdoors. Open vents and intakes as

well as entry and overhead doors.

• Utilize large fans to move air into or out of the building. Sometimes better results can be achieved by

blowing air out than bringing it in. For stationary work be sure to move fresh air through the breathing

zone of employees.

• Operate a properly calibrated CO meter (such as the Multi-Rae) within the worker breathing zone

before, during, and after equipment operation. Recognize that a CO alarm requires immediate action.

Stop work, shut down engines, and move to the outdoors until the alarm subsides and it is safe to

reenter. Exposure guidelines for CO are listed in the following table.

Table 4-3

Carbon Monoxide Exposure Guidelines

Parameter

Reading in Work Area/

Worker Breathing Zone

Action

Carbon

Monoxide

0 ppm to 20 ppm

> 20 ppm

Normal operations; continue monitoring

Stop work, evacuate confined space/work area;

investigate cause of reading, and ventilate area




Symptoms of Carbon Monoxide Exposure

CO is called the silent killer because it has no odor and it slowly overcomes those who are overexposed.

Symptoms include: headache, fatigue, shortness of breath, nausea, and dizziness. Employees in the same room

may or may not have all symptoms simultaneously. As with all work, use the buddy system to keep each other

safe and observe signs and symptoms of overexposure.

Treatment of Carbon Monoxide Exposure

Employees who are or may be experiencing any of the symptoms of CO poisoning, must notify others in the

area and get fresh air immediately. Windows and doors should be opened for more ventilation, any combustion

equipment should be turned off, and the building should be evacuated. Exposed individuals should seek medical

treatment if symptoms persist since overexposure can result in loss of consciousness and death. A doctor should

be contacted immediately for a proper diagnosis and told that CO poisoning is may be the reason. Prompt

medical attention is important if any individuals experience symptoms of CO poisoning while operating fuel-

burning devices.

4.18 Hot Work Safety Program

The purpose of the Hot Work Safety Program is to protect all personnel from hazards associated with activities

producing sparks, flames, or other ignition sources, and to prevent the loss of property due to fire. To effectively

comply with the provisions of the OSHA standards governing fire prevention and hot work activities, the Hot

Work Safety Program establishes procedures to ensure that physical and chemical fire hazards present in the

workplace are isolated from hot work activities. The Hot Work Safety Program is applicable to all welding,

cutting, burning, grinding, and other spark producing work activities. Contractors may utilize their own hot

work safety procedures as long as the requirements of this section are met.

Conditions Prohibiting Hot Work

Hot work activities are prohibited in areas of the project Site as follows:

• In areas where the requirements of the Hot Work Safety Program cannot be met. In these areas, the hot




work is prohibited and alternative methods shall be employed;

• In areas potentially containing explosive atmospheres due to the presence of flammable gases, vapors,

liquids, or dusts; and

• Within 50 feet of an area where flammable or combustible liquids or gases are used or stored.

Hot work activities shall not be conducted within the areas outlined above. All on-Site personnel are

responsible for preventing hot work activities within prohibited areas. Additionally, no hot work will be

conducted on any surface covered with a protective coating whose flammability is not known. Employees

conducting hot work activities on toxic preservative coatings shall wear appropriate respiratory protection and

the preservative coatings shall be removed a sufficient distance from the area to be heated.

Hot Work Permits

A hot work permit is required for welding, cutting, burning, grinding, or spark producing work conducted

outside of designated hot work areas. This section outlines the preparation, issuance, use, and tracking of hot

work permits. Contractors may utilize their own hot work permits if they meet the requirements of this section.

This procedure has been developed to ensure basic precautions for fire prevention and employee safety are

implemented prior to and during hot work activities outside of designated hot work areas. The hot work permit

contains a checklist to be completed by the authorized personnel conducting the hot work activities. The hot

work permit, Attachment K, must be reviewed by the SSO and the HSC prior to the start of hot work activities.

The checklist is designed to ensure the following measures are addressed.

• If possible, the object or equipment on which the hot work is to be conducted shall be moved to a

designated hot work area.

• If an object or equipment on which hot work is to be conducted cannot be moved, all moveable fire

hazards shall be moved at least 50 feet from the hot work operation.

• If an object or equipment on which hot work is to be conducted cannot be moved, or all fire hazards

cannot be removed, then guards, barriers, or screens shall be used to confine any heat, sparks, and slag,

and to protect the immovable fire hazards.

• All floor, wall, and window openings or cracks within a 35-foot radius shall be protected to prevent

exposure of combustible material to heat, sparks, or slag.

• Suitable fire fighting equipment shall be on-hand for immediate use.




• If hot work takes place in an area where flying sparks and slag may injure personnel working near,

above, or below the hot work operation, then additional precautions shall be implemented to prevent

injury to the personnel (i.e. screens, barriers, caution tape, PPE, etc.).

• A fire watch will begin before hot work is initiated and will continue during and for a minimum of 30

minutes after the hot work concludes to ensure that there are no smoldering fires. A fire watch is

required whenever hot work is performed outside of designated hot work areas.

• Verify that flammable and combustible materials adjacent to the opposite side of metal partitions, walls,

ceilings, or roofs which are likely to be ignited by conduction or radiation are protected by guards,

barriers, screens, or are moved 50 feet away from the metal partitions, walls, ceilings, or roofs.

• If hot work is to be conducted in a confined space, the requirements for the confined space entry must

be reviewed and followed.

• Hot work will not be performed in areas where other workers may be affected unless adequate

engineering or administrative controls are used to prevent personnel exposure.

• Welding, cutting, and other hot work will not be undertaken unless adequate ventilation, PPE, and well

maintained equipment are used by trained and authorized personnel.

• After welding and cutting has been completed, the area will be thoroughly cleaned, and equipment

returned to its proper location.

• All personnel involved in hot work activities shall use appropriate PPE.

If any of the basic requirements for fire prevention cannot be implemented prior to or during hot work

conducted outside a designated hot work area, then the hot work activities will not be conducted. At the

conclusion of the hot work activities, the hot work permit will be provided to the HSC for recordkeeping.

Fire Watch Procedures

A fire watch is required whenever hot work is performed outside designated hot work areas. Fire watch

personnel shall be provided by the contractor performing the hotwork. Fire watch personnel are required to

meet the following requirements.

• Fire watch personnel must have fire-extinguishing equipment readily available and ready for immediate

use.

• Fire watch personnel must be trained in the use of the fire fighting equipment provided.




• Fire watch personnel must be familiar with the procedure to sound the fire alarm in the event of a fire

and know the location of the nearest telephone.

• All fire watch personnel shall use appropriate PPE.

• Fire watch personnel must watch for fires, try to extinguish them if safe to do so, or otherwise activate

the fire alarm system.

• If a fire cannot be extinguished with one fire extinguisher, the area shall be evacuated, the fire alarm

system shall be activated, and the appropriate professional fire fighting organization contacted.

• Fire watch personnel must maintain a fire watch for at least 30 minutes after the hot work operations are

completed.

If any of the above requirements cannot be met, hot work shall not be conducted.

4.19 Confined Space Entry

Personnel conducting confined space entry activities or conducting activities near confined spaces which may

create a hazard inside the space must meet the regulatory requirements outlined in 29 CFR 1910.146: Permit-

Required Confined Spaces. Each contractor shall provide qualified/competent and trained personnel as defined

in 29 CFR 1910.146, who are responsible and have authority over confined space entry activities conducted by

the contractor. The following sections include potential hazards and safety procedures associated with confined

space and confined space-related activities. Contractors must implement their written confined space entry

program, meet the minimum requirements outlined herein, and meet the requirements of in 29 CFR 1910.146.

A confined space is defined as a space large enough and so configured that an employee can bodily enter and

perform assigned work, has limited means for entry or exit, and is not designed for continuous employee

occupancy. Potentially contaminated confined spaces may pose additional hazards such as air contamination,

flammable or explosive atmosphere, and oxygen deficiency. Confined space entry may pose the possibility of

engulfment. Personnel must be properly trained in order to supervise and participate in confined space entry

procedures or serve as standby attendants. Requirements and procedures for working in confined spaces are

discussed below.

All confined spaces shall be initially considered permit-required.




4.19.1 Confined Space Identification and Designation The HSC is responsible for identifying confined spaces into which their personnel or contractors will enter.

Entry is considered to have occurred as soon as any part of the entrant's body breaks the plane of an opening into

the space. The Confined Space Entry Checklist (Attachment L) and Confined Space Entry Permit (Attachment

M) must be filled out prior to the start of confined space activities.

4.19.2 Duties of Personnel

Each confined space being entered shall have a minimum of one (1) dedicated attendant and one other support

person (who may have other duties) within sight or call.

Duties of Entrants:

• Know the hazards that may be faced during entry, including information on the mode, signs or symptoms,

and consequences of the exposure.

• Communicate with the attendant as necessary to enable the attendant to monitor entrant status and to

enable the attendant to alert entrants of the need to evacuate the space.

• Alert the attendant whenever:

- The entrant recognizes warning signs or symptoms of exposure to a dangerous situation, or

- The entrant detects a prohibited condition;

• Exit from the permit-required confined space (permit space) as quickly as possible whenever:

- An order to evacuate is given by the attendant or the entry supervisor,

- The entrant recognizes warning signs or symptoms of exposure to a dangerous situation,

- The entrant detects a prohibited condition, or

- An evacuation alarm is activated.

Duties of Attendants:

• Knows the hazards that may be faced during entry, including information on the mode, signs or

symptoms, and consequences of the exposure.

• Is aware of possible behavioral effects of hazard exposure in authorized entrants.

• Continuously maintains an accurate count of authorized entrants in the permit space and accurately

identifies who is in the permit space by tagging the lifelines with the entrant's name, and recording the

names of the entrants.




• Remains outside the permit space during entry operations until relieved by another attendant.

• Communicates with authorized entrants as necessary to monitor entrant status and to alert entrants of the

need to evacuate the space.

• Monitors activities inside and outside the space to determine if it is safe for entrants to remain in the space

and orders the authorized entrants to evacuate the permit space immediately under any of the following

conditions:

- If the attendant detects a prohibited condition;

- If the attendant detects the behavioral effects of hazard exposure in an authorized entrant;

- If the attendant detects a situation outside the space that could endanger the authorized entrants, or

- If the attendant cannot effectively and safely perform all his duties.

• Summon rescue and other emergency services as soon as the attendant determines that authorized entrants

may need assistance to escape from permit space hazards.

• Takes the following actions when unauthorized persons approach or enter a permit space while entry is

underway:

- Warn the unauthorized persons that they must stay away from the permit space;

- Advise the unauthorized persons that they must exit immediately if they have entered the permit

space; and

- Inform the authorized entrants and the entry supervisor if unauthorized persons have entered the

permit space.

• Performs non-entry rescues.

• Performs no duties that might interfere with the attendant's primary duty to monitor and protect the

authorized entrants.

Duties of Entry Supervisors:

• Knows the hazards that may be faced during entry, including information on the mode, signs or

symptoms, and consequences of the exposure.

• Verifies, by checking that the appropriate entries have been made on the permit, that all tests specified by

the permit have been conducted and that all procedures and equipment specified by the permit are in place

before endorsing the permit and allowing entry to begin.

• Terminates the entry and cancels the permit as required.

• Removes unauthorized individuals who enter or who attempt to enter the permit space during entry

operations.




• Determines that entry operations remain consistent with terms of the entry permit and that acceptable

entry conditions are maintained.

• Documents on the entry permit incidents or circumstances requiring review of the confined space entry

program. Such incidents include:

- Unauthorized entry;

- The detection of a condition/hazard not authorized by the permit;

- The occurrence of an injury or near-miss during entry;

- A change in use or configuration of the space; or

- Employee complaints about the program.

• Prescribes procedures for coordination of entry when personnel from multiple employers will work

simultaneously. Contractors shall follow all confined space entry procedures.

4.19.3 Procedures for Permit Space Entry

Procedures for inspecting, monitoring and testing the confined space to verify that acceptable conditions exist

prior to and throughout the entry operation are described in this section.

The acceptable entry conditions for entry into each space are outlined in Table 6-1. The confined space must be

isolated to prevent the introduction of contaminants during entry. Isolation must include disconnecting or

installing slip blanks into lines leading to the space. To prevent injury from physical hazards within the space,

lockout, tagout, tryout and return to service procedures must be implemented for potential sources of hazardous

energy. When isolation is not practical or possible (as in sewer entry) entry conditions must be continuously

monitored.

Atmospheric hazards must be eliminated or controlled to meet the requirements specified in the table below. If

necessary, the space shall be purged or inerted, then ventilated to the extent necessary to meet the criteria in the

table below. Ventilation equipment may be needed to maintain these conditions. In addition, a Multi RAE

instrument (or equivalent) with PID, Oxygen, LEL, CO, and Hydrogen sulfide sensors shall be available for

testing each confined space. All equipment shall be maintained in such quantity and condition, per

manufacturer recommendations, to adequately monitor and assess all confined space entries. Permit

requirements for confined spaces shall be tested continuously to detect changes in atmospheric conditions.

Priority for atmospheric hazard testing shall be oxygen, combustible gases, and then toxic gases.




Provisions for continuous communication between entrants and attendants shall consist of powered

communication equipment (i.e., radio). Powered communication equipment with the appropriate National

Electric Code (NEC) rating shall be provided. If this is not practical or possible, portable air horns must be

provided to all entrants and attendants. The code for air horn blasts is as follows:

• 1 Horn Blast = Are you OK?

• 2 Horn Blasts = Yes, I am OK.

• 3 Horn Blasts = Exit the confined space immediately.

In addition to the PPE required for the task as specified in Table 5-1, PPE worn during confined space entry

should include protective suits, boots, and gloves, face, head, and foot protection; and a chest or parachute

harness with approved lifelines at least ½ inch in diameter and 2,000 pounds test. (NOTE: Wristlets may be used

only when a harness presents a greater hazard to the employee and wristlets are the safest, most effective

alternative). All lifelines shall be secured to a mechanical device or fixed point outside the confined space.

Mechanical devices shall be used for all vertical entry permit spaces greater than five feet deep.

In addition, lighting and electrical shall be of the appropriate NEC rating. Rating should be Class I, Division I

unless the space specifically meets other rating requirements. Protective barriers are to be used to protect

entrants from external pedestrian, vehicle or equipment hazards. Ladders shall meet the requirements of 29 CFR

1926 Subpart X, Ladders. Lifelines must be attached to a mechanical device outside the space such that a rescue

can begin as soon as the rescuer becomes aware that a rescue is necessary.

Before entry is authorized, the contractor’s Entry Supervisor shall complete and sign the contractor’s entry

permit according to their written confined space program and document that all pre-entry requirements have

been met and that acceptable entry conditions exist. The complete permit shall be posted at the primary

entrance to the permit space. See Attachment M for an example of a confined space entry permit.

Entry permits are valid for a maximum of one work shift, and shall be canceled by the Entry Supervisor when

the shift ends, confined space operations are complete, or whenever a prohibited condition arises in or near the

space. All confined spaces shall be securely closed or barricaded whenever the entry permit is canceled. Each

contractor’s entry permit must be completely executed and include all required information.




The SS0/HSS or client shall arrange for outside rescue services. The rescue personnel must be offered an

opportunity to inspect the space, and practice a rescue if necessary. The means for summoning rescue services

must be clearly communicated and documented on the contractor’s entry permit.




5. Personal Protective Equipment

5.1 Levels of Protection

PPE is required to safeguard Site personnel from various hazards. Varying levels of protection may be required

depending on the levels of COCs and the degree of physical hazard. This section presents the various levels of

protection and defines the conditions of use for each level.

5.1.1 Level D Protection

The minimum level of protection that is required of Site personnel and subcontractors is Level D, which is worn

when Site conditions present minimal dermal exposure hazard and no inhalation hazard. Level D protection

includes the following equipment:

• work clothing as prescribed by weather;

• steel-toe work boots, meeting American National Standards Institute (ANSI) Z41;

• safety glasses with side shields or goggles, meeting ANSI Z87;

• hard hat, meeting ANSI Z89, when falling object hazards are present;

• hearing protection (if noise levels exceed 85 dBA, then hearing protection with a USEPA NRR of at

least 20 dBA must be used); and

• PFD if working near or on water where the potential for drowning exists.

5.1.2 Modified Level D Protection

Modified Level D will be used when airborne contaminants are not present at levels of concern, but Site

activities present an increased potential for dermal contact with contaminated materials. Modified Level D

consists of:

• nitrile gloves worn over nitrile surgical gloves;




• latex/polyvinyl chloride (PVC) overboots when contact with COC-impacted media is anticipated;

• steel-toe work boots, meeting ANSI Z41;

• safety glasses or goggles, meeting ANSI Z87;

• face shield in addition to safety glasses or goggles when projectiles or splash hazards exist;

• hard hat, meeting ANSI Z89 when falling object hazards are present;


least 20 dBA must be used);

• Tyvek® suit (polyethylene coated Tyvek® suits for handling liquids) when body contact with COC-

impacted media is anticipated; and

• PFD if working near or on water the potential for drowning exists

5.1.3 Level C Protection

Level C protection will be required when the airborne concentration of COCs reaches one-half of the OSHA

Permissible Exposure Limit (PEL) or American Conference of Governmental Industrial Hygienists (ACGIH)

Threshold Limit Value (TLV) (ACGIH, 2003a and 2003b). The following equipment will be used for Level C

protection:

• full-face, National Institute for Occupational Safety and Health (NIOSH)-approved air-purifying

respirator with a combination cartridge (GME P-100, or equivalent);

• Tyvek® suit with ankles and cuffs taped to boots and gloves;

• nitrile outer gloves worn over nitrile surgical gloves;

• steel-toe work boots, meeting ANSI Z41;

• chemical-resistant boots with steel toes or latex/PVC overboots over steel-toe boots;

• hard hat, meeting ANSI Z89;


least 20 dBA must be used); and

• PFD if working near or on water where the potential for drowning exists.




5.2 PPE Selection

PPE will be selected based on the potential for contact, Site conditions, ambient air quality, and the judgment of

supervising Site personnel and health and safety professionals. The PPE used will be chosen to be effective

against the COCs present on Site.

Specifically, the level of PPE selected will be based on air monitoring of the work environment and an

assessment by the SSO and HSC of the potential for skin contact with COCs. The PPE selection matrix is

presented in Table 5-1. This matrix is based on information available at the time this plan was written.

Table 5-1

PPE Selection Matrix

Task Anticipated Level of Protection

Mobilization/Site Survey Level D

Water, Soil, and Air Sampling Level D/Modified Level D/Level C

Drilling and Monitoring Well Installation Level D/Modified Level D/Level C

Residential Sampling and Excavation Level D/Modified Level D/Level C

Sediment Sampling Level D with PFD/Modified Level D with PFD/Level C

with PFD

Biota Sampling Level D with PFD/Modified Level D with PFD/Level C

with PFD

Personnel and Equipment Decontamination Level D/Modified Level D/Level C

Demobilization Level D

5.3 Site Respiratory Protection Program

Respiratory protection is an integral part of employee health and safety at the Site due to potentially hazardous

concentrations of airborne COCs. The Site respiratory protection program will consist of the following elements

(at a minimum):

• All on-Site personnel who may use respiratory protection will have an assigned respirator.




• All on-Site personnel who may use respiratory protection will have been fit-tested and trained in the use

of a full-face air-purifying respirator within the past 12 months.

• All on-Site personnel who may use respiratory protection must, within the past year, have been

medically certified as being capable of wearing a respirator. Documentation of the medical certification

must be provided to the HSC prior to commencing Site work.

• Only cleaned, maintained, NIOSH-approved respirators will be used.

• If respirators are used, the respirator cartridge is to be properly disposed of at the end of each work shift

or when load-up or breakthrough occurs.

• Contact lenses are not to be worn when a respirator is worn.

• All on-Site personnel who may use respiratory protection must be clean-shaven. Mustaches and

sideburns are permitted, but they must not touch the sealing surface of the respirator.

• Respirators will be inspected and a negative-pressure test performed prior to each use.

• After each use, the respirator will be wiped with a disinfectant, cleansing wipe. When used, the

respirator will be thoroughly cleaned at the end of the work shift. The respirator will be stored in a clean

plastic bag, away from direct sunlight in a clean, dry location in a manner that will not distort the face

piece.

5.4 Using PPE

Depending on the level of protection selected, specific donning and doffing procedures may be required. The

procedures presented in this section are mandatory if Modified Level D or Level C PPE is used. All personnel

entering the EZ must don the required PPE in accordance with the requirements of this Site-Wide HASP. When

leaving the EZ, personnel will remove the PPE in accordance with the doffing procedures to minimize the

spread of COCs.

5.4.1 Donning Procedures

These procedures are mandatory only if Modified Level D or Level C PPE is used on Site:

• Remove bulky outerwear. Remove street clothes and store in clean location.

• Put on work clothes or coveralls.




• Put on the required chemical-protective coveralls.

• Put on the required chemical-protective boots or boot covers.

• Tape the legs of the coveralls to the boots with duct tape.

• Put on the required chemical-protective gloves.

• Tape the wrists of the protective coveralls to the gloves.

• Don the required respirator and perform appropriate fit check (Level C).

• Put hood or head covering over head and respirator straps and tape hood to face piece (Level C).

• Don remaining PPE, such as safety glasses or goggles and hard hat.

When these procedures are instituted, one person must remain outside the work area to confirm that each person

entering has the proper protective equipment.

5.4.2 Doffing Procedures

The following procedures are only mandatory if Modified Level D or Level C PPE is required for the Site.

Whenever a person leaves the work area, the following decontamination sequence will be followed:

• Upon entering the CRZ, rinse contaminated materials from the boots or remove contaminated boot

covers.

• Clean reusable protective equipment.

• Remove outer gloves, tyvek coverall, and respirator (Level C). Remove inner gloves after all potential

of handling of contaminated articles is completed. All disposable PPE should be placed in plastic bags

that are labeled with contaminated-waste labels.

• Wash hands, face, and neck (or shower if necessary).

• Proceed to clean area and dress in clean clothing.

• Clean and disinfect respirator (Level C) for next use.

All disposable equipment, garments, and PPE must be bagged in plastic bags labeled for disposal. See Section

7.2 for detailed information on decontamination stations.




6. Air and Noise Monitoring

6.1 Air Monitoring

Air monitoring for volatile organic compounds (VOCs) using a PID is recommended in OU-3 during tasks 2 and

3 (unless pervious knowledge of a particular well indicates that it is free of VOCs). Air monitoring for

particulates using a MIE data ram particulate monitor or the equivalent will occur during excavation if dusty

conditions arise. If entering a confined space, a multi RAE instrument (or equivalent) with PID, oxygen, LEL,

CO and hydrogen sulfide sensors will be used. Once initiated, monitoring will occur at least hourly and more

frequently if action levels are exceeded. The HSC will be responsible for monitoring, visually assessing for dust

and will initiate particulate monitoring and/or upgrade PPE requirements according to Table 6-1.

Monitoring data, should it be required, will be recorded on the Air Monitoring Form (Attachment H).

6.2 Noise Monitoring

Noise monitoring may be conducted using a rated sound level meter as required. Hearing protection is

mandatory for all employees in noise hazardous areas, such as around heavy equipment. As a general rule,

sound levels that cause speech interference at normal conversation distance should require the use of hearing

protection.

6.3 Monitoring Equipment Maintenance and Calibration

All direct-reading instrumentation calibrations should be conducted under the approximate environmental

conditions under which the instrument will be used. Instruments must be calibrated before and after use, and the

readings and any necessary adjustments noted. All air monitoring equipment calibrations, including the

standard used for calibration, must be documented on a calibration log or in the field notebook. All completed

documentation/forms must be reviewed by the HSC and maintained by the SSO.




All air-monitoring equipment will be maintained and calibrated in accordance with the specific manufacturer’s

procedures. Preventive maintenance and repairs will be conducted in accordance with the respective

manufacturer’s procedures. When applicable, only manufacturer-trained and/or authorized personnel will be

allowed to perform instrument repairs or preventive maintenance.

If an instrument is found to be inoperative or suspected of giving erroneous readings, the HSC must be

responsible for immediately removing the instrument from service and obtaining a replacement unit. If the

instrument is essential for safe operation during a specific activity, that activity must cease until an appropriate

replacement unit is obtained. The HSC will be responsible for confirming that a replacement unit is obtained

and/or repairs are initiated on the defective equipment.

6.4 Action Levels

Table 6-1 presents action levels for air that will be used to determine the procedures and protective equipment

necessary based on conditions as measured at the Site.




Table 6-1

Action Levels for Air

Parameter Reading Action

Airborne Particulates 0 to < 1.5 mg/m3

> 1.5 mg/m3 to 2.5

mg/m3

> 2.5 mg/m3

Normal operations; continue hourly breathing zone monitoring

Initiate dust suppression measures; if suppression measures are

insufficient to reduce particulates below 2.5 mg/m3 upgrade to

Level C and increase monitoring frequency to every 15 minutes

Stop work notify the HSO (or whatever term they are using)

Volatile Organics 0 ppm to 5 ppm

5 ppm to 20 ppm

> 20 ppm

Normal operations with hourly monitoring

Investigate cause of readings to determine source; increase

monitoring frequency to every 15 minutes

Stop work and contact HSO

Hydrogen Sulfide 0 ppm to < 5 ppm

> 5 ppm

Normal operations

Stop work, evacuate confined spaces/work area, investigate cause

of reading, and ventilate area

Oxygen < 19.5%

> 19.5% to < 23.5%

> 23.5%



Normal operations



Flammable Vapors

(LEL)

< 10% LEL

> 10% LEL

Normal operations

Stop work, ventilate area, investigate source of vapors

Carbon Monoxide 0 ppm to < 20 ppm

> 20 ppm

Normal operations



Note: Mg/m³= milligrams per cubic meter Ppm= parts per million




7. Work Zones and Decontamination

7.1 Work Zones

7.1.1 Authorization to Enter

Only personnel with the appropriate training and medical certifications will be allowed to work at the project

Site. The SSO will maintain a list of authorized persons; only personnel on the authorized-persons list will be

allowed to enter the Site work areas.

7.1.2 Site Orientation and Hazard Briefing

No person will be allowed in the work area during Site operations without first being given a Site orientation

and hazard briefing. This orientation will be presented by the SSO or HSC and will consist of a review of this

Site-Wide HASP. This review must cover the chemical, physical, and biological hazards; protective equipment;

safe work procedures; and emergency procedures for the project. Following this initial meeting, safety meetings

will be held each day before work begins.

All people entering the Site work areas, including visitors, must document their attendance at the orientation and

hazard briefing, as well as at the daily safety meetings, on the forms included with this plan.

7.1.3 Certification Documents

A training and medical file may be established for the project and kept on Site during all Site operations.

Records of completion of specialty training, such as first aid/cardiopulmonary resuscitation (CPR), as well as

current medical clearances, will be maintained in that file. All of the Parties’ employees and

contractor/subcontractor personnel must provide their training and medical documentation to the HSC prior to

starting work.




7.1.4 Entry Log

A log-in/log-out sheet will be maintained on Site by the SSO. Personnel must sign in and out on a log sheet as

they enter and leave the work area, and the SSO may document entry and exit in the field notebook.

7.1.5 Entry Requirements

In addition to the authorization, hazard briefing, and certification requirements listed above, no person will be

allowed in any Site work area unless they are wearing the minimum PPE as described in Section 5.

7.1.6 Emergency Entry and Exit

People who must enter the work area on an emergency basis will be briefed of the hazards by the SSO. All

activities will cease in the event of an emergency. People exiting the work area because of an emergency will

gather in a safe area for a head count. The SSO is responsible for confirming that all people who entered the

work area have exited in the event of an emergency.

7.1.7 Contamination-Control Zones

Contamination-control zones are maintained to prevent the spread of contamination and to prevent unauthorized

people from entering hazardous areas.

7.1.8 Exclusion Zone

The EZ is the defined area where there is a possible respiratory and/or contact health hazard. An EZ may consist

of a specific work area or may be the entire area of potential contamination. All employees entering an EZ must

use the required PPE and must have the appropriate training and medical clearance for hazardous waste work.

Cones, caution tape, or a Site diagram will identify the location of each EZ.




7.1.9 Contamination-Reduction Zone

The CRZ or transition area will be established, if necessary, to perform decontamination of personnel and

equipment. All personnel entering or leaving the EZ will pass through this area to prevent any cross-

contamination. Tools, equipment, and machinery will be decontaminated in a specific location. All personnel

will be decontaminated on Site adjacent to the EZ. Personal protective outer garments and respiratory

protection will be removed in the CRZ and prepared for cleaning or disposal. This zone is the only appropriate

corridor between the EZ and the SZ.

7.1.10 Support Zone

The SZ is a clean area outside the CRZ located to prevent employee exposure to hazardous substances. Eating

and drinking will be permitted in the support area only after proper decontamination. Smoking may be permitted

in the SZ, subject to Site requirements.

7.1.11 Posting

Work areas will be prominently marked and delineated using cones, caution tape, or a Site diagram.

7.1.12 Site Inspections

The SSO will conduct a daily inspection of Site activities, equipment, and procedures to verify that the required

elements are in place. The Health and Safety Inspection Form in Attachment I may be used as a guide for daily

inspections. A SWO must also be completed (at a frequency determined by HSC) and forwarded to the OU

RI/FS Manager for review.

7.2 Decontamination

Decontamination procedures are briefly described below, and presented in more detail under Task 7 in Section

3.2.7.




7.2.1 Personnel Decontamination

All personnel wearing Modified Level D or Level C protective equipment in the EZ must undergo personal

decontamination prior to entering the SZ. The personnel decontamination area will consist of the following

stations, at a minimum:

• Station 1 – Personnel leaving the contaminated zone will remove the gross contamination from their

outer clothing and boots.

• Station 2 – Personnel will remove their outer garments and gloves and dispose of them in properly

labeled containers. Personnel will then decontaminate their hard hats and boots with an aqueous solution

of detergent or other appropriate cleaning solution. These items will then be hand-carried to the next

station.

• Station 3 – Personnel will thoroughly wash their hands and face before leaving the CRZ. Respirators

will be sanitized and then placed in a clean plastic bag.

7.2.2 Equipment Decontamination

All vehicles that have entered the EZ will be decontaminated at the decontamination pad prior to leaving the

zone. If the level of vehicle contamination is low, decontamination may be limited to rinsing tires and wheel

wells with water. If the vehicle is significantly contaminated, steam cleaning or pressure washing of the vehicle

and equipment may be required.

7.2.3 Personal Protective Equipment Decontamination

Where and whenever possible, single-use, external protective clothing must be used for work within the EZ or

CRZ. This protective clothing must be disposed of in properly labeled containers. Reusable protective clothing

will be rinsed on Site with detergent and water. The rinsate will be collected for disposal.




When removed from the CRZ, the respirator will be thoroughly cleaned with soap and water. The respirator face

piece, straps, valves, and covers must be thoroughly cleaned at the end of each work shift and ready for use prior

to the next shift. Respirator parts may be disinfected with a solution of bleach and water or by using a spray

disinfectant.




8. Training and Medical Surveillance

8.1 Training

8.1.1 General

All on-Site project personnel who work in areas where they may be exposed to Site COCs must be trained as

required by OSHA Regulation 29 CFR 1910.120 (HAZWOPER). Field employees also must receive a minimum

of three days of actual field experience under the direct supervision of a trained, experienced supervisor.

Personnel who completed their initial training more than 12 months prior to the start of the project must have

completed an eight-hour refresher course within the past 12 months. The SSO must have completed an

additional eight hours of supervisory training and must have current first-aid and CPR certificates.

8.1.2 Basic 40-Hour Course

The following is a list of the topics typically covered in a 40-hour HAZWOPER training course:

• general safety procedures;

• physical hazards (fall protection, noise, heat stress, cold stress);

• names and job descriptions of key personnel responsible for Site health and safety;

• safety, health, and other hazards typically present at hazardous waste sites;

• use, application, and limitations of PPE;

• work practices by which employees can minimize risks from hazards;

• safe use of engineering controls and equipment on Site;

• medical surveillance requirements;

• recognition of symptoms and signs that might indicate overexposure to hazards;

• worker right-to-know (Hazard Communication OSHA 1910.1200);

• routes of exposure to contaminants;

• engineering controls and safe work practices;




• components of a health and safety program and a Site-specific HASP;

• decontamination practices for personnel and equipment;

• confined-space entry procedures; and

• general emergency response procedures.

8.1.3 Supervisor Course

Managers and supervisors must receive an additional 8 hours of training, which typically includes:

• general Site safety and health procedures;

• PPE programs; and

• air monitoring techniques.

8.1.4 Site-Specific Training

Site-specific training will be accomplished by having on-Site personnel read this Site-Wide HASP or attend a

thorough Site briefing by the OU RI/FS Manager, SSO, or HSC on the contents of this Site-Wide HASP before

work begins. The review must include a discussion of the chemical, physical, and biological hazards; protective

equipment and safety procedures; and emergency procedures.

8.1.5 Daily Safety Meetings

Daily safety meetings will be held to cover the work to be accomplished, hazards anticipated, PPE and

procedures required to minimize Site hazards, and emergency procedures. The SSO or HSC should present these

meetings prior to beginning the day’s fieldwork. No work will be performed in an EZ before the daily safety

meeting has been held. The daily safety meeting must also be held prior to new tasks and repeated if new

hazards are encountered. The Safety Meeting Log is included in Attachment J.




8.1.6 First Aid and CPR

At least one employee current in first aid and CPR will be assigned to the work crew and will be on Site during

operations. Refresher training in first aid (triennially) and CPR (annually) is required to keep the certificate

current. These individuals must also receive training regarding the precautions and protective equipment

necessary to protect against exposure to bloodborne pathogens.

8.2 Medical Surveillance

8.2.1 Medical Examination

All personnel who are potentially exposed to Site COCs must participate in a medical surveillance program as

defined by OSHA at 29 CFR 1910.120(f).

8.2.2 Pre-Placement Medical Examination

All potentially-exposed personnel must have completed a comprehensive medical examination prior to

assignment and periodically thereafter as defined by applicable regulations. The pre-placement and periodic

medical examinations typically include the following elements:

• medical and occupational history questionnaire;

• physical examination;

• complete blood count, with differential;

• liver enzyme profile;

• chest X-ray, at a frequency determined by the physician;

• pulmonary function test;

• audiogram;

• electrocardiogram for persons older than 45 years of age or if indicated during the physical examination;

• drug and alcohol screening, as required by job assignment;

• visual acuity; and

• follow-up examinations, at the discretion of the examining physician or the corporate medical director.




The examining physician will provide the employee with a letter summarizing his/her findings and

recommendations, confirming the worker’s fitness for work and ability to wear a respirator. Documentation of

medical clearance will be available for each employee during all project Site work.

Subcontractors will certify that all their employees have successfully completed a physical examination by a

qualified physician. The physical examinations must meet the requirements of 29 CFR 1910.120 and 29 CFR

1910.134. Subcontractors will supply copies of the medical examination certificate for each on-Site employee.

8.2.3 Other Medical Examinations

In addition to pre-employment, periodic, and exit physicals, personnel may be examined:

• at employee request after known or suspected exposure to toxic or hazardous materials; and

• at the discretion of the HSC, HSO, or occupational physician in anticipation of, or after known or

suspected, exposure to toxic or hazardous materials.

8.2.4 Periodic Exam

Following the pre-placement examination, all employees must undergo a periodic examination, similar in scope

to the pre-placement examination. For employees potentially exposed more than 30 days per year above the

applicable PELs, the frequency of periodic examinations will be annual. For employees potentially exposed less

than 30 days per year above the applicable PELs, the frequency for periodic examinations will be 24 months.

8.2.5 Medical Restriction

When the examining physician identifies a need to restrict work activity, the employee’s supervisor must

communicate the restriction to the employee and the HSC. The terms of the restriction will be discussed with the

employee and the supervisor.




9. Emergency Procedures

9.1 General

Prior to the start of operations, the work area will be evaluated for the potential for fire, contaminant release, or

other catastrophic event. Unusual conditions or events, activities, chemicals, and conditions will be reported to

the SSO/HSC immediately.

The SSO/HSC will establish evacuation routes and assembly areas for the Site. All personnel entering the Site

will be informed of these routes and assembly areas.

9.2 Emergency Response

If an incident occurs, the SSO or HSC should take the following steps:

• Evaluate the incident and assess the need for assistance and/or evacuation.

• Call for outside assistance as needed.

• Confirm that the OU RI/FS Manager is notified promptly of the incident.

• Take appropriate measures to stabilize the incident scene.

9.2.1 Fire

In the case of a fire on Site, the SSO/HSC will assess the situation and direct fire-fighting activities. The

SSO/HSC will confirm that the OU RI/FS Manager is immediately notified of any fires. Site personnel will

attempt to extinguish the fire with available extinguishers, if safe to do so. In the event of a fire that Site

personnel are unable to safely extinguish with one fire extinguisher, the local fire department will be summoned.




9.2.2 Contaminant Release

In the event of a contaminant release, the following steps will be taken:

• notify SSO/HSC immediately;

• evacuate immediate area of release;

• conduct air monitoring, using equipment and action levels discussed in Section 6, to determine needed

level of PPE; and

• don required level of PPE and prepare to implement control procedures.

The SSO/HSC has the authority to commit resources as needed to contain and control released material and to

prevent its spread to off-Site areas.

9.3 Medical Emergency

All employee injuries must be promptly reported to the HSC/SSO, who will:

• confirm that the injured employee receives prompt first aid and medical attention;

• in emergency situations, see that the worker is transported by appropriate means to the nearest urgent

care facility (normally a hospital emergency room); and

• notify the OU RI/FS Manager, and appropriate contacts as soon as possible after the injured employee is

safely evacuated.

9.3.1 Emergency Care Steps

Upon entering an accident area, Site personnel must follow the emergency care steps listed below. The steps are

to be performed by trained first aid/CPR providers.




• Survey the scene. Determine whether it is safe to proceed. Try to determine whether the conditions that

caused the incident are still a threat. Protect yourself from exposure before attempting to rescue the

victim.

• Do a primary survey of the victim. Check for airway obstruction, breathing, and pulse. Assess likely

routes of chemical exposure by examining the eyes, mouth, nose, and skin of the victim for symptoms.

• Phone Emergency Medical Services (EMS). Give the location, telephone number used, caller’s name,

what happened, number of victims, victim’s or victims’ condition, and help being given.

• Maintain airway and perform rescue breathing as necessary.

• Perform CPR as necessary.

• Do a secondary survey of the victim. Check vital signs and do a head-to-toe exam.

• Treat other conditions as necessary. If the victim can be moved, take him/her to a location away from

the work area where EMS can gain access.

9.4 First Aid – General

All persons must report any injury or illness to their immediate supervisor or the SSO. Trained personnel will

provide first aid. Injuries and illnesses requiring medical treatment must be documented. The SSO and HSC

must conduct an incident investigation as soon as emergency conditions no longer exist and first aid and/or

medical treatment has been confirmed. Incident investigation reports must be completed and submitted to the

OU RI/FS Manager within 24 hours after the incident.

If first aid treatment is required, first aid kits are kept at the CRZ. If treatment beyond first aid is required, the

injured person(s) should be transported to the medical facility. If the injured person is not ambulatory, or shows

any sign of not being in a comfortable and stable condition for transport, then an ambulance and/or paramedics

should be summoned. If there is any doubt as to the injured worker’s condition, it is best to let the local

paramedic or ambulance service examine and transport the worker.

9.4.1 First Aid – Inhalation

Any employee complaining of symptoms of chemical overexposure as described in Section 4.5 will be removed

from the work area and transported to the designated medical facility for examination and treatment.




9.4.2 First Aid – Ingestion

Call EMS and consult a poison control center for advice. If available, refer to the MSDS for treatment

information. If the victim is unconscious, keep him/her on his/her side and clear the airway if vomiting occurs.

9.4.3 First Aid – Skin Contact

Project personnel who have had skin contact with contaminants will, unless the contact is severe, proceed

through the CRZ to the wash area. Personnel will remove any contaminated clothing and then flush the affected

area with water for at least 15 minutes. The worker should be transported to the medical facility if he/she shows

any sign of skin reddening, irritation, or if he/she requests a medical examination.

9.4.4 First Aid — Eye Contact

Project personnel who have had contaminants splashed in their eyes or who have experienced eye irritation

while in the EZ must immediately proceed to the eyewash station in the CRZ. Do not decontaminate prior to

using the eyewash. Remove whatever protective clothing is necessary to use the eyewash. Flush the eye with

clean running water for at least 15 minutes. Arrange prompt transport to the designated medical facility.

9.5 Reporting Injuries, Illnesses, and Near-Miss Incidents

Injuries and illnesses, however minor, will be reported to the SSO immediately. The SSO will complete an

injury report (see Attachment F – Incident/Near-Miss Investigation Report) and submit it to the HSO and the

OU RI/FS Manager within 24 hours. Near-miss incidents are situations in which no injury or property damage

occurred, but under slightly different circumstances an injury or property damage could have occurred. Near

misses are caused by the same factors as injuries; therefore, they must be reported and investigated in the same

manner.




9.6 Emergency Information

The means to summon local public response agencies such as police, fire, and ambulance will be reviewed in the

daily safety meeting. These agencies are identified in Table 9-1.

Table 9-1

Emergency Contacts

EMERGENCY/CONTINGENCY CONTACT TELEPHONE LIST

LOCAL EMERGENCY CONTACTS

PHONE

NUMBER

FIRE DEPARTMENT 911

POLICE 911

AMBULANCE 911

The Parties (Craig Branchfield) (256) 231-8404

HOSPITAL : Regional Medical Center

400 East 10th Street

Anniston, AL 36207

(256) 235-5121

Poison Control Center (800) 222-1222

National Response Center (800) 424-8802

USEPA (Pam Scully) (404) 562-4300




9.6.1 Directions to Regional Medical Center

From the West: Take Highway 202 East. Pass through the intersection with Quintard Avenue, Highway 202

becomes 9th Street. The Regional Medical Center is 1.5 blocks ahead on the left.

From the South: Take Quintard Avenue North to 9th Street. Turn right on 9th Street. The Regional Medical

Center is 1.5 blocks ahead on the left.

9.6.2 Map to Regional Medical Center

A map showing the location of the regional medical center with respect to the OUs is included as Figure 9-1.




10. References

American Conference of Governmental Industrial Hygienists (ACGIH). 2003a. Threshold Limit Values

Handbook.

ACGIH. 2003b. Guide to Occupational Exposure Values.

Blasland, Bouck & Lee, Inc. (BBL). 2000. Off-Site RCRA Facility Investigation (RFI) Report, June 2000.

BBL. 2003. Phase I Conceptual Site Model Report for the Anniston PCB Site, April 2003.

BBL. 2004. Remedial Investigation/Feasibility Study Work Plan for the Anniston PCB Site, April 2004.

Contaminant Control, Inc. 2003. Residential Soil Removal Project, Health and Safety Plan. September 2003.

Golder Associates Inc. (Golder). 2002. RFI/CS Report for the Anniston, Alabama Facility, October 2002.

Golder. 2004. Operable Unit 3 Field Sampling Plan Anniston PCB Site, April 2004.

Roux. 2001. Removal Response Action Work Plan, 11th Street Ditch, Anniston PCB Site, Anniston, Alabama, July 9, 2001.

Solutia Inc. (Solutia). 2003. NTC Removal Action Supplemental Sampling Health & Safety Plan. Anniston PCB Site. September 2003.

Solutia. 2004. Non-Time Critical Removal Supplemental Sampling and Analysis Plan, Revision 1. March 2004.

United States Environmental Protection Agency (USEPA). 2001. Administrative Order on Consent (AOC). Docket No. CER-04-2002-3752. October 3, 2001.

Figures

LOCATION MAP

5/06/04 SYR-D54-LAS, DJH10293004/10293G19.CDR

FIGURE

1-1

Atlanta, GA

Birmingham, AL

Anniston, AL

ANNISTON PCB SITEANNISTON, ALABAMA

SITE-WIDE HEALTH AND SAFETY PLAN

APPROXIMATE SCALE

LEGEND

APPROXIMATE CHOCCOLOCCO CREEK WATERSHED BOUNDARY AS DELINEATED IN BASINS 2.0 (USEPA,1999)

AOC B AREA

PROJECT ORGANIZATIONCHART

05/27/04 SYR-D90-MFEU:/Solutia/HASP/Fig 2-1.CDR

FIGURE

2-1



Alan Fowler

OU-2/OU-4 QA Officer

OU-2/OU-4 Health and Safety OfficerOU-1/OU-3 Health and Safety Officer

Dennis Capria

Greg Ertel, CIH, CSPCharles Haury, CIH, CSP

Project Staff and Subcontractors

Anniston PCB Site Manager

Craig Branchfield

CERCLA Manager

John Loper

Lori Anne Hendel

OU-1/OU-3 QA Officer

Gayle Macolly

OU-1/OU-3 RI/FS Manager OU-2/OU-4 RI/FS Manager

FIGURE



9-1

REGIONAL MEDICAL CENTER

05/27/04 SYR-D90-MFEU:/SOLUTIA/HASP/Fig9-1.cdr

OXFORD

SN

OW

CR

EE

K

CHOCCOLOCCOCREEK

Solutia

OU-1 and 2

OU-3

OU-4

Choccolocco Creek

Snow Creek

2500 0 2500 5000 Feet

Regional Medical Center400 East 10th St, Anniston

Regional Medical Center

Attachments

Attachment A

Underground/Overhead Utility Checklist

05/27/04 Attach A Utility Checklist.doc


Underground / Overhead Utility Checklist

Project Name: Date:

Project Number: Location:

Prepared By: Site Safety Officer: This checklist must be completed for any intrusive subsurface work such as excavation or drilling. It documents that overhead and underground utilities in the work area are identified and located. The Site Safety Officer shall request utility markouts before the start of field operations to allow the client and utility companies sufficient time to provide them. If complete information is not available, a magnetometer or other survey shall be performed to locate obstacles prior to intrusive subsurface activities. Procedure: A diagram of the work area depicting the proposed location of intrusive subsurface work sites (i.e., boring locations, excavation locations) must be attached to this form. The diagram must clearly indicate the areas checked for underground structures / utilities, and overhead power lines. This form and the diagram must be signed by the Site Safety Officer, the OU RI/FS Manager, and the CERCLA Manager.

Type of Structure Present Not Present Method of Markout

Electric Power Line

Natural Gas Line

Telephone Line

Water Line

Product Line

Sewer Line

Steam Line

Drain Line

Underground Tank

Underground Cable

Overhead Power Line

Overhead Product Line

Other (Specify)

Reviewed By

Name Job Title Date

CERCLA Manager

OU RI/FS Manager

Site Safety Officer

Attachment B

Sediment/Surface Water Sampling Checklist

SEDIMENT/SURFACE WATER SAMPLING CHECKLIST Project Name/Number Date Location Prepared By OU RI/FS Manager

This checklist must be completed for any sediment or surface water sampling. It documents that the required, permits, notifications, procedures and equipment are in place prior to commencing sampling activities. The OU RI/FS Manager or representative shall identify the need for and arrange to obtain sampling permits, clearance or right-of-way access from the appropriate entity during project planning.

Procedure Prior to any work on a navigable waterway or any activity that requires access the following items will be completed:

Activity:

Required for project:

Completed:

Comments:

Access rights to property YES NO YES NO

Activity planned that impedes traffic on navigable waterway

YES NO YES NO

Notification and approval

obtained from United States

Coast Guard and/or other

regulating authority (County,

US Parks Service, EPA)

YES NO YES NO

Buoys, signs markings or

other forms of notification

present

YES NO YES NO

Other (Specify)

Boating/Water Safety Checklist:

Activity: Required for project: Requirement: Comments:

Working on over or near

water (within 6 feet) YES NO

PFD Available for all

personnel

Boat has current registration,

has been inspected and

loaded safely YES NO

Capacity, load distribution

PFDs and throwable

floatation device available

Fire extinguisher on board

Boat operator has appropriate

training (USCG Boating

Safety Course or equivalent) YES NO

Sampling on or near water

below 50 degrees Fahrenheit YES NO

Cold water immersion suit for

affected personnel

Method of communication

available YES NO

Radio, cell phone or

scheduled check-in

CERCLA Manager Date

OU RI/FS Manager Date

Site Safety Officer Date

Attachment C

PCB Chemical Hazard Information Table and Material

Safety Data Sheet



Attachment C CHEMICAL HAZARD INFORMATION

Attach C ChemHzdTbl.doc Page 1 of 2 5/6/2004

Substance [CAS Number]

IP1 (eV)

Odor Threshold

(ppm) Route2 Symptoms of Exposure Treatment TWA3 STEL4 Source5

IDLH (NIOSH

)6 Polychlorinated biphenyls (PCB) [1336-36-3] Aroclor 1242 [53469-21-9] and Aroclor 1254 [11097-69-1]

NA ND Inh Abs Ing Con

Aroclor 1242: irritated eyes; chloracne; acne-form dermatitis; liver damage; reproductive effects; mildly toxic by ingestion; poison by subcutaneous route – carcinogenic Aroclor 1254: irritated eyes; chloracne, acne-form dermatitis; liver damage; reproductive effects; poison by intravenous route; moderately toxic by ingestion and intraperitoneal routes – carcinogenic

Eye: Irrigate immediately Skin: Soap wash immediately Breath: Respiratory support Swallow: Immediate medical

attention

Aroclor 1242: 1 mg/m3 (skin) 1 mg/m3 (skin) 0.001 mg/m3

Aroclor 1254:

0.5 mg/m3 (skin) 0.5 mg/m3 (skin)

0.001 mg/m3

PEL TLV REL

PEL TLV REL

Ca

(5 mg/m3)

Ca (5 mg/m3)

NOTES: 1IP = Ionization potential (electron volts). 2Route = Inh, Inhalation; Abs, Skin absorption; Ing, Ingestion; and Con, Skin and/or eye contact. 3TWA = Time-weighted average. The TWA concentration for a normal workday (usually 8 or 10 hours) and a 40-hour work week, to which nearly all workers may be repeatedly

exposed, day after day without adverse effect. 4STEL = Short-term exposure limit. A 15-minute TWA exposure that should not be exceeded at any time during a workday, even if the TWA is not exceeded. 5PEL = Occupational Safety and Health Administration (OSHA) permissible exposure limit (29 CFR 1910.1000, Table Z). 5TLV = American Conference of Governmental Industrial Hygiene (ACGIH) threshold limit value – TWA. 5REL = National Institute for Occupational Safety and Health (NIOSH) recommended exposure limit. 6IDLH = Immediately dangerous to life or health (NIOSH). Represents the maximum concentration from which, in the event of respirator failure, one could escape within 30 minutes

without a respirator and without experiencing any escape-impairing or irreversible health effects. NE = None established. No evidence could be found for the existence of an IDLH (NIOSH Pocket Guide to Chemical Hazards, Pub. No. 90-117, 1990, 1997). C = Ceiling limit value which should not be exceeded at any time. Ca = Carcinogen. NA = Not applicable. ND = Not Determined. LEL = Lower explosive limits. LC50 = Lethal concentration for 50 percent of population tested. LD50 = Lethal dose for 50 percent of population tested. NIC = Notice of intended change (ACGIH).



Attachment C CHEMICAL HAZARD INFORMATION

Attach C ChemHzdTbl.doc Page 2 of 2 5/6/2004

References:

American Conference of Governmental Industrial Hygienists (ACGIH) Guide to Occupational Exposure Values, 2003, compiled by the ACGIH.

ACGIH Threshold Limit Values, 2003, compiled by the ACGIH

Amoore, J. and E. Hautula, “Odor as an Aid to Chemical Safety,” Journal of Applied Toxicology, 1983.

Clayton, George D. and F.E. Clayton, Patty’s Industrial Hygiene and Toxicology, 3rd ed., John Wiley & Sons, New York.

Documentation of TLVs and BEIs, American Conference of Governmental Industrial Hygienists, 5th ed., 1986.

Fazzuluri, F.A., Compilation of Odor and Taste Threshold Values Data, American Society for Testing and Materials, 1978.

Gemet, L. and J. Van, Compilation of Odor Threshold Values in Air and Water, CIVO, Netherlands, 1977.

Gemet, L. and J. Van, Compilation of Odor Threshold Values in Air and Water, Supplement IV, CIVO, Netherlands, 1977.

Lewis, Richard J., Sr., 1992, Sax’s Dangerous Properties of Industrial Materials, 8th ed., Van Nostrand Reinhold, New York.

Micromedex Tomes Plus (R) System, 1992, Micromedex, Inc.

National Institute for Occupational Safety and health Pocket Guide to Chemicals, Pub. 1990, No. 97-140, National Institute for Occupational Safety and Health, 2003.

Odor Threshold for Chemicals with Established Occupational Health Standards, American industrial Hygiene Association, 1989.

Respirator Selection Guide, 3M Occupational Health and Safety Division, 1993.

Verschuseren, K., Handbook of Environmental Data on Organic Chemicals, Van Nostrand and Reinhold, 1977.

Warning Properties of Industrial Chemicals – Occupational Health Resource Center, Oregon Lung Association.

Workplace Environmental Exposure Levels, American Industrial Hygiene Association, 1992.

Material Safety Data Sheet Collection

Genium Publishing Corp. 1171 RiverFront Center Amsterdam, NY 12010

(518) 842-4111

Polychlorinated Biphenyls (PCBs)

POL2140

Issue Date: 2002-02

Copyright © 2002 by Genium Publishing Corporation. Any commercial use or reproduction without the publisher’s permission is prohibited. Judgments as to the suitability of information herein for the purchaser’s purposes are necessarily the purchaser’s responsibility. Although reasonable care has been taken in the preparation of such information, Genium Publishing Corporation extends no warranties, makes no representations, and assumes no responsibility as to the accuracy or suitability of such information for application to the purchaser’s intended purpose or for consequences of its use.

Section 1 - Chemical Product and Company Identification 54 Material Name: Polychlorinated Biphenyls (PCBs) CAS Number: 1336-36-3 Chemical Formula: Unspecified or Variable Structural Chemical Formula: (C12H10-x)Clx Synonyms: AROCLOR; AROCLOR 1221; AROCLOR 1232; AROCLOR 1242; AROCLOR 1248; AROCLOR 1254;

AROCLOR 1260; AROCLOR 1262; AROCLOR 1268; AROCLOR 2565; AROCLOR 4465; AROCLOR 5442; 1,1'-BIPHENYL,CHLORO DERIVS; BIPHENYL,POLYCHLORO-; CHLOPHEN; CHLOREXTOL; CHLORINATED BIPHENYL; CHLORINATED DIPHENYL; CHLORINATED DIPHENYLENE; CHLORO 1,1-BIPHENYL; CHLORO 1,1-BIPHENYL-; CHLORO BIPHENYL; CLOPHEN; CLOPHEN A 60; DYKANOL; EPA PESTICIDE CHEMICAL CODE 017801; FENCLOR; FENCLOR 42; INERTEEN; KANECHLOR; KANECHLOR 300; KANECHLOR 400; MONTAR; MONTER; NOFLAMOL; PCB; PCBS; PHENOCHLOR; PHENOCLOR; POLYCHLORINATED BIPHENYL; POLYCHLORINATED BIPHENYLS; POLYCHLORINATED BIPHENYLS (PCB'S); POLYCHLOROBIPHENYL; PYRALENE; PYRANOL; SANTOTHERM; SANTOTHERM FR; SOVOL; THERMINOL; THERMINOL FR-1

General Use: Used as dielectric fluids in transformers and capacitors. Prior to 1972, were used as hydraulic and other industrial fluids (e.g., in vacuum pumps, as lubricants and cutting oils), in paints, inks and fire retardants.

Also used in heat transfer systems; gas-transmission turbines; carbonless reproducing paper; adhesives; as plasticizer in epoxy paints; fluorescent light ballasts; wax extenders; coolants; dedusting agents; pesticide extenders; surface treatment and coatings; sealants; caulking material.

This is one of a group of once widely used industrial chemicals whose high stability contributed both to their commercial usefulness and the long term deleterious environmental health effects. Consequently their use has been phased out. Their manufacture in the U.S.A. was discontinued in 1977.

Section 2 - Composition / Information on Ingredients Name CAS % polychlorinated biphenyls (PCB's) 1336-36-3 100

OSHA PEL No data found.

ACGIH TLV No data found.

NIOSH REL No data found.

Section 3 - Hazards Identification

21

0—

Fire Diamond 0 1 2 3 4

FlammabilityToxicity

Body ContactReactivity

Chronic

ChemWatch Hazard Ratings

Min Low Moderate High Extreme

2

0

1

HMIS

Health

Flammability

Reactivity

ANSI Signal Word

Warning!

�� Emergency Overview �� Oily liquid, white crystalline solid, or hard resin. Severely irritating. Suspect cancer hazard. Chronic: chloracne, GI disturbances, neurological symptoms, liver enlargement, menstrual changes, bronchitis. Possible reproductive and teratogenic effects.

Potential Health Effects Target Organs: skin, liver, eyes, mucous membranes, respiratory system Primary Entry Routes: inhalation, skin contact, ingestion

2002-02 Polychlorinated Biphenyls (PCBs) POL2140

Copyright © 2002 Genium Publishing Corporation. Any commercial use or reproduction without the publisher’s permission is prohibited. Page 2 of 6

Acute Effects Inhalation: Not normally a hazard due to nonvolatile nature of product. Inhalation of vapor is more likely at higher

than normal temperatures. The vapor/mist is discomforting and may be extremely toxic if inhaled. Eye: The vapor/liquid is moderately discomforting and may be harmful to the eyes. Skin: The liquid is harmful to the skin, it is rapidly absorbed and is capable of causing skin reactions. Exposure to material may result in a dermatitis, described as chloracne, a persistent acneiform characterized by

comedones (white-, and black- heads), keratin cysts, and inflammed papules with hyperpigmentation and an anatomical distribution frequently involving the skin under the eyes and behind the ears. It occurs after acute or chronic exposure to a variety of chlorinated aromatic compounds by skin contact, ingestion or inhalation and may appear within days and months following the first exposure. Other dermatological alterations including hypertrichosis (the growth of excess hair), an increased incidence of actinic or solar elastosis (the degeneration of elastic tissue within muscles or loss of dermal elasticity produced by the effects of sunlight), and Peyrone's disease (a rare progressive scarring of the penile membrane).

Ingestion: Considered an unlikely route of entry in commercial/industrial environments. The material is moderately discomforting to the gastrointestinal tract and may be harmful if swallowed in large

quantity. Ingestion may result in nausea, pain, vomiting. Vomit entering the lungs by aspiration may cause potentially lethal

chemical pneumonitis. Digestion may lead to nausea, vomiting, abdominal pain, anorexia, jaundice and liver damage, coma and death.

Headache, dizziness, lethargy, depression, nervousness, loss of libido, muscle, joint pains may be found. Symptoms appear after a latent period of 5 to 6 months. PCB's may appear in breast milk of exposed mothers and in newborn infants.

Carcinogenicity: NTP - Class 2B, Reasonably anticipated to be a carcinogen, sufficient evidence of carcinogenicity from studies in experimental animals; IARC - Group 2A, Probably carcinogenic to humans; OSHA - Not listed; NIOSH - Not listed; ACGIH - Not listed; EPA - Class B2, Probable human carcinogen based on animal studies; MAK - Not listed.

Chronic Effects: People occupationally exposed to PCB's have relatively high PCB residue levels in blood plasma. Symptoms include chloracne dermatitis and degreasing the skin, pigmentation of skin and nails, excessive eye discharge, swelling of eyelids, transient visual disturbances, distinctive hair follicles, edema of the face and hands.

In common with other polyhalogenated aromatic hydrocarbons, the chlorinated biphenyls exhibit dioxin-like behavior. Polyhalogenated aromatic hydrocarbons (PHAHs) comprise two major groups. The first group represented by the halogenated derivatives of dibenzodioxins (the chlorinated form is PCDD), dibenzofurans (PCDF) and biphenyls (PCB) exert their toxic effect (as hepatoxicants, reproductive toxicants, immunotoxicants and procarcinogens) by interaction with a cytostolic protein known as the Ah receptor. In guinea pigs the Ah receptor is active in a mechanism which "pumps" PHAH into the cell whilst in humans the reverse appears to true. This, in part, may account for species differences often cited in the literature. This receptor exhibits an affinity for the planar members of this group and carries these to the cellular nucleus where they bind, reversibly, to specific genomes on DNA.

This results in the regulation of the production of certain proteins which elicit the toxic response. The potency of the effect is dependent on the strength of the original interaction with the Ah receptor and is influenced by the degree of substitution by the halogen and the position of such substitutions on the parent compound.

The most potent molecule is 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) while the coplanar PCBs (including mono-ortho coplanars) possess approximately 1% of this potency. Nevertheless, all are said to exhibit "dioxin-like" behavior and in environmental and health assessments it has been the practice to assign each a TCDD-equivalence value.

The most subtle and important biological effects of the PHAHs are the effects on endocrine hormones and vitamin homeostasis. TCDD mimics the effect of thyroxin (a key metamorphosis signal during maturation) and may disrupt patterns of embryonic development at critical stages. Individuals from exposed wildlife populations have been observed to have altered sexual development, sexual dysfunction as adults and immune system suppression.

Immunotoxic effects of the PHAHs (including the brominated congener, PBB) have been the subject of several studies. No clear pattern emerges in human studies however with T-cell numbers and function (a blood marker for immunological response) increasing in some and decreasing in others.

Three incidences have occurred which have introduced abnormally high levels of dioxin or dioxin-like congeners to humans. The explosion at a trichlorophenol-manufacturing plant in Seveso, Italy distributed TCDD across a large area of the country-side, whilst rice-oil contaminated with heat-transfer PCBs (and dioxin-like contaminants) has been consumed by two groups, on separate occasions (one in Yusho, Japan and another in Yu-cheng, Taiwan). The only symptom which can unequivocally be related to all these exposures is the development of chloracne, a disfiguring skin condition, following each incident. Contaminated oil poisonings also produced eye-discharge, swelling of eyelids and visual disturbances. The Babies born up to 3 years after maternal exposure (so-called "Yusho-babies") were characteristically brown skinned, colored gums and nails and (frequently) produced eye-discharges. Delays in intellectual development have been noted. It has been estimated that Yu-cheng patients consumed an average level of 0.06 mg/kg body weight/day total PCB and 0.0002 mg/kg/day of PCDF before the onset of symptoms after 3 months. When the oil was withdrawn after 6 months they had consumed 1 gm total PCB containing 3.8 mg PCDF.



Preliminary data from the Yusho cohort suggests a six-fold excess of liver cancer mortality in males and a three-fold excess in women.

Recent findings from Seveso indicate that the biological effects of low level exposure (BELLEs), experienced by a cohort located at a great distance from the plant, may be hormetic, i.e. may be protective AGAINST the development of cancer.

TCDD induces carcinogenic effects in the laboratory in all species, strains and sexes tested. These effects are dose-related and occur in many organs.

Exposures as low as 0.001 ug/kg body weight/day produce carcinoma. Several studies implicate PCBs in the development of liver cancer in workers as well as multi-site cancers in animals. The second major group of PHAH consists of the non-planar PCB congeners which possess two or more ortho-substituted halogens. These have been shown to produce neurotoxic effects which are thought to reduce the concentration of the brain neurotransmitter, dopamine, by inhibiting certain enzyme-mediated processes.

The specific effect elicited by both classes of PHAH seems to depend on the as much on the developmental status of the organism at the time of the exposure as on the level of exposure over a lifetime.

Section 4 - First Aid Measures Inhalation: Remove to fresh air. Lay patient down. Keep warm and rested. If breathing is shallow or has stopped, ensure clear airway and apply resuscitation. Transport to hospital or doctor. Eye Contact: Immediately hold the eyes open and flush continuously for at least 15 minutes with fresh running water.

Ensure irrigation under eyelids by occasionally lifting the upper and lower lids. Transport to hospital or doctor without delay. Removal of contact lenses after an eye injury should only be undertaken

by skilled personnel. Skin Contact: Immediately remove all contaminated clothing, including footwear (after rinsing with water). Wash affected areas thoroughly with water (and soap if available). Seek medical attention in event of irritation. Ingestion: Contact a Poison Control Center. DO NOT induce vomiting. Observe the patient carefully. Never give liquid

to a person showing signs of being sleepy or with reduced awareness; i.e. becoming unconscious. Give water (or milk) to rinse out mouth. Then provide liquid slowly and as much as casualty can comfortably drink. Transport to hospital or doctor without delay.

After first aid, get appropriate in-plant, paramedic, or community medical support. Note to Physicians: Treat symptomatically. If large amounts are ingested, gastric lavage is suggested. For splash in the eyes, a petrolatum-based ophthalmic ointment may be applied to the eye to relieve the irritating effects of PCBs.

If electrical equipment arcs over, PCB dielectric fluids may decompose to produce hydrogen chloride (HCl), a respiratory irritant. [Monsanto] Preplacement and annual medical examinations of workers, with emphasis on liver function, skin condition, reproductive history, is recommended.

Section 5 - Fire-Fighting Measures Flash Point: > 141 °C Autoignition Temperature: 240 °C LEL: Not applicable UEL: Not applicable Extinguishing Media: Foam.Alcohol stable foam. Dry chemical powder. General Fire Hazards/Hazardous Combustion Products: Noncombustible liquid.

POLLUTANT -contain spillage. Decomposes on heating and produces acrid black soot and toxic fumes of aldehydes, hydrogen

chloride (HCl), chlorides and extremely toxic polychlorinated dibenzofuran (PCDF), polychlorinated dibenzodioxin (PCDD).

Fire Incompatibility: Reacts vigorously with chlorine (Cl2). Fire-Fighting Instructions: POLLUTANT -contain spillage. Noncombustible. Clear area of personnel and move upwind. Contact fire department and tell them location and nature of hazard. Wear full body protective clothing with breathing apparatus. Prevent, by any means available, spillage from entering

drains or waterways. Use fire fighting procedures suitable for surrounding area. Cool fire-exposed containers with water spray from a protected location. Avoid spraying water onto liquid pools. If safe to do so, remove containers from path of fire. Equipment should be thoroughly decontaminated after use.

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Section 6 - Accidental Release Measures Small Spills: POLLUTANT -contain spillage. Clean up all spills immediately. Environmental hazard - contain spillage. Avoid breathing vapors and contact with skin and eyes. Wear protective clothing, impervious gloves and safety glasses. Contain spill with sand, earth or vermiculite. Wipe up and absorb small quantities with vermiculite or other absorbent material. Place spilled material in clean, dry, sealable, labeled container. Large Spills: POLLUTANT -contain spillage. Clear area of personnel. Contact fire department and tell them location and nature of hazard. Wear full body protective clothing with breathing apparatus. Prevent, by any means available, spillage from entering

drains or waterways. Stop leak if safe to do so. Contain spill with sand, earth or vermiculite. Collect recoverable product into labeled containers for recycling. Absorb remaining product with sand, earth or vermiculite. Collect residues and seal in labeled drums for disposal. After clean-up operations, decontaminate and launder all protective clothing and equipment before storing and reusing. If equipment is grossly contaminated, decontaminate and destroy. If contamination of drains or waterways occurs, advise emergency services. Regulatory Requirements: Follow applicable OSHA regulations (29 CFR 1910.120).

Section 7 - Handling and Storage Handling Precautions: Do not allow clothing wet with material to stay in contact with skin Use good occupational

work practices. Observe manufacturer's storing and handling recommendations. Atmosphere should be regularly checked against established exposure standards to ensure safe working conditions are

maintained. Avoid all personal contact, including inhalation. Wear protective clothing and gloves when handling containers. Avoid physical damage to containers. Use in a well-ventilated area and Use only in completely enclosed system. Avoid contact with incompatible materials. When handling, DO NOT eat, drink or smoke. Wash hands with soap and water after handling. Work clothes should be laundered separately: NOT at home. Recommended Storage Methods: Packaging as recommended by manufacturer. Check that containers are clearly labeled. Metal can or metal drum or Steel drum with plastic liner. Regulatory Requirements: Follow applicable OSHA regulations.

Section 8 - Exposure Controls / Personal Protection Engineering Controls: Provide adequate ventilation in warehouse or closed storage areas. If inhalation risk of overexposure exists, wear NIOSH-approved organic-vapor respirator. In confined spaces where there is inadequate ventilation, wear full-face air supplied breathing apparatus. Personal Protective Clothing/Equipment Eyes: Safety glasses with side shields; chemical goggles. Full face shield. Contact lenses pose a special hazard; soft lenses may absorb irritants and all lenses concentrate them. Hands/Feet: Impervious gloves or Viton gloves or Polyethylene gloves or PVC gloves. Protective footwear.



Other: Impervious protective clothing. Overalls. Impervious apron. Eyewash unit. Ensure there is ready access to a safety shower.

Section 9 - Physical and Chemical Properties Appearance/General Info: Clear, colorless to yellow-green, mobile oily to viscous liquid, or sticky to hard resin, or

white crystalline solid, depending on degree of chlorination. Slightly soluble in glycerol and glycols. Soluble in organic solvents and lipids. Viscosity range: 71 - 2500 Saybolt unit sec. at 38 °C. PCBs are resistant to chemical and biological degradation and because of their solubility in fats and oils they tend to be concentrated in living organisms. The highly chlorinated PCBs are retained in animal's bodies longer and seems to delay the excretion of the lower chlorinated PCB's. They have become widely dispersed in the world-wide environment and in the food-chain since their introduction in 1929. They are now recognized internationally to be a major environmental pollutant, their persistence causing ecological damage via water pollution. Consequently loss of PCBs to the environment is to be avoided at all costs.

Physical State: Liquid Vapor Pressure (kPa): Negligible Formula Weight: 188.66 - 395 Specific Gravity (H2O=1, at 4 °C): 1.18 - 1.8 Water Solubility: Solubility in water extremely low Evaporation Rate: Non Vol. at 38 °C

pH: Not applicable pH (1% Solution): Not applicable. Boiling Point Range: 340 °C (644 °F) to 375 °C

(707 °F) Decomposition Temperature (°C): 375-550

Section 10 - Stability and Reactivity Stability/Polymerization/Conditions to Avoid: Product is considered stable. Hazardous polymerization will not occur. Storage Incompatibilities: Avoid storage with oxidizers. Segregate from chlorine. Avoid contamination of water, foodstuffs, feed or seed.

Section 11 - Toxicological Information TOXICITY IRRITATION Oral (human) LDLo: 500 mg/kg Nil reported Oral (rat) LD50: 3980 mg/kg

See NIOSH, RTECS TQ1350000, for additional data.

Section 12 - Ecological Information Environmental Fate: PCBs are mixtures of different congeners of chlorobiphenyl and the relative importance of the

environmental fate mechanisms generally depends on the degree of chlorination. In general, the persistence of PCBs increases with an increase in the degree of chlorination. Mono-, di- and trichlorinated biphenyls (Aroclor 1221 and 1232) biodegrade relatively rapidly, tetrachlorinated biphenyls (Aroclors 1016 and 1242) biodegrade slowly, and higher chlorinated biphenyls (Aroclors 1248, 1254, and 1260) are resistant to biodegradation. Although biodegradation of higher chlorinated congeners may occur very slowly on an environmental basis, no other degradation mechanisms have been shown to be important in natural water and soil systems; therefore, biodegradation may be the ultimate degradation process in water and soil.

If released to soil, PCBs experience tight adsorption with adsorption generally increasing with the degree of chlorination. PCBs will generally not leach significantly in aqueous soil systems; the higher chlorinated congeners will have a lower tendency to leach than the lower chlorinated congeners. In the presence of organic solvents PCBs may leach quite rapidly through soil. Vapor loss from soil surfaces appears to be an important fate mechanism with the rate of volatilization decreasing with increasing chlorination. Although the volatilization rate may be low, the total loss by volatilization over time may be significant because of persistence and stability. Enrichment of the low Cl PCBs occurs in the vapor phase relative to the original Aroclor; the residue will be enriched in the PCBs containing high Cl content.



If released to water, adsorption to sediment and suspended matter will be an important fate process; PCB concentrations in sediment and suspended matter have been shown to be greater than in the associated water column. Although adsorption can immobilize PCBs (especially the higher chlorinated congeners) for relatively long periods of time, eventual resolution into the water column has been shown to occur. The PCB composition in the water will be enriched in the lower chlorinated PCBs because of their greater water solubility, and the least water soluble PCBs (highest Cl content) will remain adsorbed. In the absence of adsorption, PCBs volatilize relatively rapidly from water. However, strong PCB adsorption to sediment significantly competes with volatilization, with the higher chlorinated PCBs having longer half-lives than the lower chlorinated PCBs. Although the resulting volatilization rate may be low, the total loss by volatilization over time may be significant because of persistence and stability. PCBs have been shown to bioconcentrate significantly in aquatic organisms. If released to the atmosphere, PCBs will primarily exist in the vapor-phase; the tendency to become associated with the particulate-phase will increase as the degree of chlorination of the PCB increases. The dominant atmospheric transformation process is probably the vapor-phase reaction with hydroxyl radicals which has estimated half-lives ranging from 12.9 days for monochlorobiphenyl to 1.31 years for heptachlorobiphenyl. Physical removal from the atmosphere, which is very important environmentally, is accomplished by wet and dry deposition.

Ecotoxicity: Aquatic toxicity: 0.278 ppm/96 hr/bluegill/TLm/fresh water 0.005 ppm/336-1080 hr/pinfish/TLm/salt water; Waterfowl toxicity: LD50 2000 ppm (mallard duck); Food chain concentration potential: High

Henry's Law Constant: 5 x10-5 BCF: bioconcentrate in tissue Biochemical Oxygen Demand (BOD): very low Soil Sorption Partition Coefficient: Koc = 510 to 1.33 x104

Section 13 - Disposal Considerations Disposal: Recycle wherever possible. Consult manufacturer for recycling options. Follow applicable federal, state, and local regulations. Due to their environmental persistence and potential health hazards, PCBs cannot be disposed of in landfills or

dumped at sea. The only environmentally acceptable method for the disposal of PCBs is by high temperature incineration.

All wastes and residues containing PCB's (e.g., wiping cloths, absorbent material, used disposable protective gloves, contaminated clothing, etc.) should be collected, placed in proper containers, labelled and disposed of in accordance with applicable regulations.

Section 14 - Transport Information DOT Transportation Data (49 CFR 172.101):

Shipping Name: POLYCHLORINATED BIPHENYLS

Hazard Class: 9 ID No.: 2315 Packing Group: II Label: Miscellaneous Dangerous Goods[9]

Additional Shipping Information: PCB'S

Section 15 - Regulatory Information EPA Regulations:

RCRA 40 CFR: Not listed CERCLA 40 CFR 302.4: Listed per CWA Section 311(b)(4), per CWA Section 307(a) 1 lb (0.454 kg) SARA 40 CFR 372.65: Listed SARA EHS 40 CFR 355: Not listed TSCA: Listed

Section 16 - Other Information Disclaimer: Judgments as to the suitability of information herein for the purchaser’s purposes are necessarily the purchaser’s

responsibility. Although reasonable care has been taken in the preparation of such information, Genium Publishing Corporation extends no warranties, makes no representations, and assumes no responsibility as to the accuracy or suitability of such information for application to the purchaser’s intended purpose or for consequences of its use.

Attachment D

Parathion Material Safety Data Sheet



(518) 842-4111

Parathion

PAR6840 Temp: was 0946.html

Issue Date: 2003-02


Section 1 - Chemical Product and Company Identification 46/57 Material Name: Parathion CAS Number: 56-38-2 Chemical Formula: C10H14NO5PS Structural Chemical Formula: (C2H5O)2P(S)OC6H4NO2 EINECS Number: 200-271-7 Synonyms: AAT; AATP; AC 3422; ACC 3422; ALKRON; ALLERON; AMERICAN CYANAMID 3422;

APHAMITE; ARALO; B 404; BAY E-605; BAYER E-605; BLADAN; BLADAN F; COMPOUND 3422; COROTHION; CORTHION; CORTHIONE; DANTHION; O,O-DIAETHYL-O-(4-NITRO-PHENYL)-MONOTHIOPHOSPHAT; DIETHYL PARA-NITROPHENOL THIOPHOSPHATE; 0,0-DIETHYL 0-(P-NITROPHENYL) PHOSPHOROTHIOATE; O,O-DIETHYL O-(4-NITROPHENYL) PHOSPHOROTHIOATE; O,O-DIETHYL O-(P-NITROPHENYL) PHOSPHOROTHIOATE; DIETHYL 4-NITROPHENYL PHOSPHOROTHIONATE; DIETHYL P-NITROPHENYL PHOSPHOROTHIONATE; DIETHYL P-NITROPHENYL THIONOPHOSPHATE; 0,0-DIETHYL 0-P-NITROPHENYL THIOPHOSPHATE; DIETHYL P-NITROPHENYL THIOPHOSPHATE; O,O-DIETHYL O-4-NITROPHENYL THIOPHOSPHATE; O,O-DIETHYL O-P-NITROPHENYL THIOPHOSPHATE; DIETHYL PARATHION; O,O-DIETHYL-O-(4-NITRO-FENIL)-MONOTHIOFOSFAAT; O,O-DIETHYL-O-P-NITROFENYLESTER KYSELINY THIOFOSFORECNE; O,O-DIETHYL-O(P-NITROPHENYL) PHOSPHOROTHIOATE; O,O-DIETHYL-O-(4-NITROPHENYL) PHOSPHOROTHIOATE; O,O-DIETHYL-O-(P-NITROPHENYL)THIONOPHOSPHATE; DIETHYLPARATHION; DIETIL TIOFOSFATO DE P-NITROFENILA; O,O-DIETIL-O-(4-NITRO-FENIL)-MONOTIOFOSFATO; O,O-DIETYL-O-P-NITROFENYLTIOFOSFAT; DNTP; DPP; DREXEL PARATHION 8E; E 605; E 605 F; E 605 FORTE; ECATOX; EKATIN WF & WF ULV; EKATOX; ENT 15,108; EPA PESTICIDE CODE 057501; EPA SHAUGHNESSY CODE: 057701; ETHLON; ETHYL PARATHION; ETILON; ETYLPARATION; FOLICLAL; FOLICOL E605; FOLIDOL; FOLIDOL E; FOLIDOL E & E 605; FOLIDOL E605; FOLIDOL OIL; FOSFERMO; FOSFERNO; FOSFEX; FOSFIVE; FOSOVA; FOSTERN; FOSTOX; GEARPHOS; GENITHION; KOLPHOS; KYPTHION; LETHALAIRE G-54; LIROTHION; MURFOS; NIRAN; NIRAN E-4; P-NITROPHENOL O-ESTER WITH O,O-DIETHYLPHOSPHOROTHIOATE; NITROSTIGMIN; NITROSTIGMINE; NITROSTYGMINE; NIUIF-100; NIUIF 100; NOURITHION; OLEOFOS 20; OLEOPARAPHENE; OLEOPARATHION; OMS 19; ORTHOPHOS; PAC; PACOL; PANTHION; PARADUST; PARAMAR; PARAMAR 50; PARAPHOS; PARATHENE; PARATHION; PARATHION ETHYL; PARATHION-AETHYL; PARATHION-ETHYL; PARAWET; PENNCAP E; PESTOX PLUS; PETHION; PHENOL,P-NITRO-,O-ESTER WITH O,O-DIETHYLPHOSPHOROTHIOATE; PHOSKIL; PHOSPHEMOL; PHOSPHENOL; PHOSPHOROTHIOIC ACID,O,O-DIETHYL O-(4-NITROPHENYL) ESTER; PHOSPHOROTHIOIC ACID,O,O-DIETHYL-O-(4-NITROPHENYL) ESTER; PHOSPHOROTHIOIC ACID,O,O-DIETHYL-O-(P-NITROPHENYL) ESTER; PHOSPHOSTIGMINE; RB; RHODIASOL; RHODIATOX; RHODIATROX; SELEPHOS; SIXTY-THREE SPECIAL E.C. INSECTICIDE; SIXTY-THREE SPECIAL EC INSECTICIDE; SNP; SOPRATHION; SOPROTHION; STABILIZED ETHYL PARATHION; STATHION; STRATHION; SULPHOS; SUPER RODIATOX; T-47; THIOFOS; THIOMEX; THIOPHOS; THIOPHOS 3422; THIOPHOSPHATE DE O,O-DIETHYLE ET DE O-(4-NITROPHENYLE); TIOFOS; TOX 47; VAPOPHOS; VITREX

Derivation: From sodium ethylate, thiophosphoryl chloride, and sodium p-nitrophenate. General Use: A restricted use pesticide in the US; used as an insecticide for wheat and nuts and as an acaricide.

Section 2 - Composition / Information on Ingredients Name CAS % Parathion 56-38-2 ca 98% vol, technical grade. Also available commercially as an emulsifiable concentrate of 50% or less, 15% or 25% wettable powders, dustable powder, granules, and aerosol. Discontinued formulations include parathion plus chlorbenside.

Trace Impurities: O,O-diethyl thiophosphorylchloride; O,O-triethyl thiophosphate; O,O-diethyl S-ethyl thiophosphate; O,O- diethyl S-ethyl dithiophosphate; nitro-phenetole; nitrophenol; parathion isomers and the dithio analogue of parathion.

OSHA PEL TWA: 0.1 mg/m3; skin.

OSHA PEL Vacated 1989 Limits TWA: 0.1 mg/m3; respirable.

ACGIH TLV TWA: 0.1 mg/m3; skin.

NIOSH REL TWA: 0.05 mg/m3; skin.

IDLH Level 10 mg/m3.

DFG (Germany) MAK TWA: 0.1 mg/m3; skin, simple asphyxiant, measured as inhalable fraction of the aerosol.

2003-02 Parathion PAR6840



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4

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HMIS

Health

Flammability

Reactivity

ANSI Signal Word

Danger! Poison

�� Emergency Overview �� Yellowish (when pure) to brown liquid (technical grade) at temperatures > 43 °F (6 °C); faint garlic-like odor. Highly toxic by all routes of exposure. Handle with extreme caution.

Potential Health Effects Target Organs: Respiratory system, central nervous system (CNS), cardiovascular system (CVS), eyes, skin, blood

cholinesterase. Primary Entry Routes: Inhalation, skin/eye contact/absorption, ingestion. Acute Effects The onset of signs and symptoms usually is prompt, but may be delayed up to 12 hr. Systemic Effects by all routes: Nausea, vomiting, abdominal pain, diarrhea, excessive salivation, sweating, headache,

giddiness, vertigo (dizziness), weakne ss, blurring or dimness of vision, miosis or mydiasis (dilatation of the pupils), tearing, bradycardia (slow heart beat), tachycardia (fast heart beat), cardiac irregularities (arrhythmias, compl ete heart block), loss of muscle coordination, slurred speech, muscle twitching (particularly tongue and eyelids), generalized profound weakness, confusion, disorientation, drowsiness, difficulty in breathing, excessive secretion of saliva and mucus, cyanosis, rales, high blood pressure, random jerky movements, incontinence, convulsions, coma, and death due to respiratory paralysis. Inhalation: Difficulty breathing, tightness in the chest, wheezing, rales, increased rate of respiration, headache,

rhinnorrhea (runny nose), and excessive bronchial secretions. Laryngeal spasms and excessive salivation may add to respiratory distress, and cyanosis (blue discoloration of skin and mucous membranes due to deficient oxygenation of the blood) may also occur. Pulmonary edema (fluid in the lungs) may occur in severe cases. Ocular (eye) effects include miosis (pinpoint pupils), tearing, and blurring of distant vision.

Eye: (See ocular effects above produced with inhalation.) One drop of parathion in the eye can be fatal; it is absorbed from the cornea and conjunctiva.

Skin: Skin absorption produces localized sweating and muscular twitching in the immediate area, usually occurring within 15 min to 4 hr. Dermal sensitization may occur.

Ingestion: Nausea, vomiting, loss of appetite, abdominal cramps, and diarrhea occur within 15 min to 2 hr. Carcinogenicity: NTP - Not listed; IARC - Group 3, Not classifiable as to carcinogenicity to humans; OSHA - Not

listed; NIOSH - Not listed; ACGIH - Class A4, Not classifiable as a human carcinogen; EPA - Class C, Possible human carcinogen; MAK - Not listed.

Medical Conditions Aggravated by Long-Term Exposure: Glaucoma; CVS, hepatic and renal disease; and CNS abnormalities.

Chronic Effects: Individuals may become even more susceptible to parathion's toxic effects after repeated exposure. Parathion binds irreversibly to cholinesterase, causing its depletion, and this is presumably the reason for increased susceptibility to parathion in chronic exposure. Effects include headache, dizziness, fatigue, loss of appetite, memory loss, insomnia, disorientation, muscular twitching and trembling, and occasionally neuritis (an inflammatory or degenerative lesion of a nerve) and paresis (slight or partial paralysis).

Other Health Effects: Parathion is converted in the body in part to paraoxon, an active cholinesterase inhibitor. Parathion has been fetotoxic, but not teratogenic in laboratory animals. It has induced DNA damage in rodents, mutations in Salmonella, and sister chromatid exchanges in vitro (outside the body in an artificial environment).

Section 4 - First Aid Measures Inhalation: Remove exposed person to fresh air and support breathing as needed. Eye Contact: Do not allow victim to rub or keep eyes tightly shut. Gently lift eyelids and flush immediately and

continuously with flooding amounts of water until transported to an emergency medical facility. Consult a physician or ophthalmologist immediately.



Skin Contact: Quickly remove contaminated clothing. Immediately and thoroughly wash exposed area (including hair and beneath nails) with soap and water, followed by a 95% ethanol wash, and finally, a second soap and water wash. Tincture of green soap contains 30% ethanol and is recommended for dermal decontamination.

Ingestion: Never give anything by mouth to an unconscious or convulsing person. Contact a poison control center. Unless the poison control center advises otherwise, have the conscious and alert person drink 1 to 2 glasses of water. Do not induce vomiting due to potential coma and seizures and increased risk of aspiration of gastric contents.

After first aid, get appropriate in-plant, paramedic, or community medical support. Note to Physicians: Delayed respiratory crisis may occur 2 to 3 weeks after acute exposure. Delayed polyneuropathy of the mixed sensory-motor type may occur 6 to 21 days after acute exposure. Recovery may be slow or incomplete. Measure the urinary metabolite, p-nitrophenol, within 48 hr of exposure, to assess parathion absorption. Red blood cell cholinesterase depression to levels substantially below pre-exposure levels (at least 50% and usually much lower) is verification of poisoning.

Treatment: As soon as cyanosis has been overcome, give intravenously, 2 to 4 mg of atropine. Repeat this dose of atropine at 5- to 10-minute intervals until signs of atropinization appear. If muscarinic symptoms reappear, repeat the atropine dose. Maintain a mild degree of atropinization for at least 48 hr. For moderate-to-severe cases, inject 1 to 2 g of 2-PAM intravenously at a rate not in excess of 500 mg/min. If muscle weakness has not been relieved, or if it recurs within 20 min, a second dose of 1 g is indicated. 2-PAM is ineffective if aging, a process of converting to the monoethylphosphoryl enzyme, has occurred. Aging occurs over the following 24 to 48 hr after exposure. Morphine, aminophyline, and phenothiazines are contraindicated.

Section 5 - Fire-Fighting Measures Flash Point: 392 °F (200 °C), Open Cup Autoignition Temperature: None reported. LEL: None reported. UEL: None reported. Flammability Classification: Class IIIB Combustible Liquid Extinguishing Media: For small fires, use dry chemical, CO2, water spray, or standard foam. For

large fires, use water spray, fog, or standard foam. Do not scatter material with high pressure water hoses.

General Fire Hazards/Hazardous Combustion Products: Carbon monoxide, and oxides of nitrogen, phosphorus, and sulfur. Containers may explode in the heat of fire.

Fire-Fighting Instructions: If feasible and without undue risk, move containers from fire hazard area. Otherwise, cool fire-exposed containers until well after the fire is extinguished. Do not release runoff from fire control methods to sewers or waterways. Dike for later disposal. Because fire may produce toxic thermal decomposition products, wear a self-contained breathing apparatus (SCBA) with a full facepiece operated in pressure-demand or positive-pressure mode. Structural firefighter's protective clothing is not effective. Wear chemical protective clothing which is specifically recommended by the manufacturer. Unless stated by the clothing manufacturer, it may not provide thermal protection.

Section 6 - Accidental Release Measures Spill/Leak Procedures: Immediately notify safety personnel, evacuate all unnecessary personnel, shut off heat and

ignition sources, and isolate and ventilate area. Cleanup personnel should protect against inhalation and skin or eye contact.

Small Spills: Treat spilled material with alkaline substances such as sodium carbonate (soda ash), sodium bicarbonate (baking soda), calcium hydroxide (slaked lime), lime or lime water when in dilute solution, and calcium carbonate (crushed limestone). Take up with sand or other noncombustible material (vermiculite) or collect for reclamation.

Large Spills: For large spills, dike far ahead of liquid spill for later disposal. Do not release into sewers or waterways. Further decontaminate with alkaline treatment or concentrated alkaline detergent.

Regulatory Requirements: Follow applicable OSHA regulations (29 CFR 1910.120).

Section 7 - Handling and Storage Handling Precautions: Avoid inhalation and any bodily contact. Wear appropriate personal protective clothing and

equipment. Once on the skin, parathion is very difficult to remove. Parathion residues have been found on the hands of one worker 2 months after last known contact. Practice meticulous personal hygiene procedures.

Never eat, drink, or smoke in work areas. Practice good personal hygiene after using parathion, especially before eating, drinking, smoking, using the toilet, or applying cosmetics.

Recommended Storage Methods: Store in tightly closed containers in a cool ,well-ventilated area away from heat and ignition sources and strong oxidizers and alkaline materials. Protect containers against physical damage and corrosion. Store in areas where any spillage from containers will not endanger workers or contaminate other materials.

Regulatory Requirements: Follow applicable OSHA regulations.

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Section 8 - Exposure Controls / Personal Protection Engineering Controls: Enclose all operations to prevent dispersion into workplace. Provide general or local exhaust

ventilation systems to maintain airborne concentrations below OSHA PELs (Sec. 2). Local exhaust ventilation is preferred because it prevents contaminant dispersion into the work area by controlling it at its source.

Administrative Controls: Consider preplacement and periodic medical exams with emphasis on the respiratory system, nervous system, CVS, eyes, skin (dermatitis), and blood (cholinesterase levels). Obtain blood levels of both red blood cell and plasma cholinesterase as a baseline. Remove from exposure any person whose red blood cell cholinesterase falls to or below 40% of the preexposure baseline until the activity returns to within 80% of the preexposure baseline.

Personal Protective Clothing/Equipment: Wear chemically protective gloves, boots, aprons, and gauntlets to prevent any skin contact. For parathion concentrations 30-70%, Teflon and Saranex, with breakthrough times >4 hr, are recommended materials for protective clothing. Natural rubber is not recommended. Parathion penetrates leather. Do not wear leather items, canvas shoes, or sneakers. Wear protective eyeglasses or chemical safety goggles, per OSHA eye- and face-protection regulations (29 CFR 1910.133). Contact lenses are not eye protective devices. Appropriate eye protection must be worn instead of, or in conjunction with contact lenses. Respiratory Protection: Seek professional advice prior to respirator selection and use. Follow OSHA respirator

regulations (29 CFR 1910.134) and, if necessary, wear a MSHA/NIOSH-approved respirator. For concentrations <= 0.5 mg/m3, wear any chemical cartridge respirator with organic vapor cartridge(s) in combination with a dust, mist, and fume filter or any supplied- air respirator. For concentrations <= 1.25 mg/m3, wear any supplied-air respirator operated in a continuous-flow mode; or an air- purifying respirator with organic vapor cartridge(s) in combination with a dust, mist, and fume filter. For concentrations <= 2.5 mg/m3, wear any chemical cartridge respirator with a full facepiece and organic vapor cartridge(s) in combination with a high- efficiency particulate filter; or any supplied-air respirator that has a tight-fitting facepiece and is operated in a continuous-flow mode; or any powered, air-purifying respirator with a tight-fitting facepiece and organic vapor cartridge(s) in combination with a high-efficiency particulate filter; or any SCBA with a full facepiece; or any supplied-air respirator with a full facepiece. For concentrations <= 10 mg/m3, wear any supplied-air respirator operated in a pressure-demand or other positive-pressure mode. For emergency or nonroutine operations (cleaning spills, reactor vessels, or storage tanks), wear an SCBA that has a full facepiece and is operated in a pressure-demand or other positive-pressure mode. Warning! Air-purifying respirators do not protect workers in oxygen-deficient atmospheres.

Other: Take a shower, washing completely, and change to clean clothes. Separate contaminated work clothes from street clothes. Launder before reuse. Make available hydrogen peroxide or hypochlorous acid (dilute) to decontaminate badly contaminated clothing before it is to be laundered. Remove parathion from your shoes and clean personal protective equipment. Dispose of leather items by incineration. Make emergency eyewash stations, safety/quick-drench showers, and washing facilities available in work area.

Section 9 - Physical and Chemical Properties Appearance/General Info: Yellowish (when pure) to brown (technical grade); faint garlic-like odor. Physical State: Liquid at temperatures > 43 °F (6 °C) Odor Threshold: 0.470 mg/m3 Vapor Pressure (kPa): 3.78 x 10-5 mm Hg at 68 °F

(20 °C) Formula Weight: 291.27 Specific Gravity (H2O=1, at 4 °C): 1.26 at 77 °F

(25 °C) Refractive Index: 1.5370 at 77 °F (25 °C) Boiling Point: 707 °F (375 °C)

Freezing/Melting Point: 43 °F (6 °C) Viscosity: 15.30 cP at 77 °F (25 °C) Surface Tension: 39.2 dyne/cm at 77 °F (25 °C) Water Solubility: 12.4 mg/L at 68 °F (20 °C) Other Solubilities: Alcohols, esters, ethers, chloroform,

ketones, aromatic hydrocarbons, and animal and vegetable oils; practically insoluble in petroleum ether and kerosene.

Section 10 - Stability and Reactivity Stability/Polymerization/Conditions to Avoid: Parathion is stable in distilled water in acid solution; hydrolyzes in the

presence of alkaline material and slowly decomposes in air. Hazardous polymerization does not occur. Avoid contact with incompatibles and heat and ignition sources.

Storage Incompatibilities: Strong oxidizers, alkaline materials, and endrin. It will attack some forms of plastics, rubber, and coatings.

Hazardous Decomposition Products: Thermal oxidative decomposition of parathion can produce carbon monoxide and oxides of nitrogen, phosphorus, and sulfur.



Section 11 - Toxicological Information Acute Oral Effects: Rat, oral, LD50: 2 mg/kg. Human, oral, LDLo: 171 µg/kg. Acute Inhalation Effects: Rat, inhalation, LC50: 84 mg/m3/4 hr; toxic effects included tremor, convulsions or effect on seizure threshold, and dyspnea. Acute Skin Effects: Rat, skin, LD50: 6800 µg/kg produced toxic effects included tremor, convulsions or effect on seizure threshold and excitement. Rabbit, skin, LD50: 15 mg/kg. Human, skin, LDLo: 7143 µg/kg. Other Effects: Rat, oral: 234 mg/kg/90 days/intermittent; toxic effects included kidney, ureter, and bladder changes and multiple enzyme effects. Rat, oral: 1260 mg/kg/80 weeks/continuous; produced adrenal cortex tumors. Rat, oral: 360 µg/kg administered to the female 2-22 days of pregnancy and 15 days after birth; toxic effects included biochemical and metabolic effects on the newborn and other postnatal measures or effects. Mutagenicity: Human, fibroblast: 10 µmol/L caused unscheduled DNA synthesis.

See NIOSH, RTECS TF4550000, for additional data.

Section 12 - Ecological Information Environmental Fate: If released to water, little parathion will be lost through volatilization. Photolysis will be

important in surface waters. Bioconcentration of parathion in aquatic systems will be moderate to low. Biodegradation generally occurs with a half-life of several weeks, but in well acclimated water, complete degradation may occur in 2 weeks. The presence of photosensitizers, free radicals, hydrogen peroxide, or algae may accelerate degradation considerably. When parathion is sprayed on a field, it will exist primarily as an aerosol in the source area (field half-life: 5 min for conversion to paraoxon in summer sunlight; considerably slower after sunset). It may be scavenged by rain. Parathion absorbs strongly to soils. It degrades by both biological and soil-catalyzed hydrolysis. On the surface, photolysis may occur. At ordinary levels of application, parathion is degraded within weeks, but at very high levels of applications, residues will persist; persistence is dependent on soil type.

Ecotoxicity: Fulvous whistling duck, oral, LD50: 0.125 to 0.250 mg/kg; Daphnids, EC50: 0.60 µg/L/48 hr at 59 °F (15 °C); Aquatic Toxicity 0.32 ppm/mosquito fish/acute toxicity/fresh water; 1.6 ppm/96 hr/minnow/TLm/fresh water

Henry's Law Constant: 1.21 x 10-6 atm-m3/mole BCF: Parathion does not build up in the food chain. Octanol/Water Partition Coefficient: log Kow = 3.93, 3.40, 3.47

Section 13 - Disposal Considerations Disposal: Parathion is a potential candidate for rotary kiln, fluidized bed, or liquid injection incineration. For

wastewater treatment, consider reverse osmosis. Contact your supplier or a licensed contractor for detailed recommendations. Follow applicable Federal, state, and local regulations. Handle empty containers carefully as hazardous residues may remain. Triple rinse containers with alkaline detergent and properly dispose of wash water.


Shipping Name: Parathion Hazard Class: 6.1 ID No.: NA2783 Packing Group: I; II Label: Poison


RCRA 40 CFR: Listed P089 CERCLA 40 CFR 302.4: Listed per CWA Section 311(b)(4), per RCRA Section 3001 10 lb (4.535 kg) SARA 40 CFR 372.65: Listed SARA EHS 40 CFR 355: Listed RQ: 10 lb TPQ: 100 lb



TSCA: Not listed



Attachment E

Paranitrophenol (PNP) Material Safety Data Sheet



(518) 842-4111

p-Nitrophenol

NIT5320 Issue Date: 2003-02


Section 1 - Chemical Product and Company Identification 56a/ 57 Material Name: p-Nitrophenol CAS Number: 100-02-7 Chemical Formula: C6H5NO3 Structural Chemical Formula: O2NC6H5OH EINECS Number: 202-811-7 Synonyms: 4-HYDROXYNITROBENZENE; P-HYDROXYNITROBENZENE; MONONITROPHENOL; NIPHEN;

4-NITROFENOL; P-NITROFENOL; 4-NITROPHENOL; P-NITRO-PHENOL; P-NITROPHENOL; PARA-NITROPHENOL; PARANITROFENOL; PARANITROFENOLO; PARANITROPHENOL; PHENOL,4-NITRO; PHENOL,4-NITRO-; PHENOL,P-NITRO-; PNP

General Use: indicator in 0.1% alcohol solution, intermediate in organic synthesis, production of parathion, fungicide for leather, indicator in water analysis, bactericide

Section 2 - Composition / Information on Ingredients Name CAS % p-nitrophenol 100-02-7 100

OSHA PEL No data found.

ACGIH TLV No data found.

NIOSH REL No data found.


31

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Chronic



ANSI Signal Word

Danger! Corrosive

�� Emergency Overview �� Colorless to slightly yellow to brown crystals/prisms/solid; odorless. Irritating. Poison. Other Acute Effects: cyanosis; effects may vary from mild irritation to severe destruction of tissue. Chronic Effects: mutagenic effects.

Potential Health Effects Target Organs: eyes, skin, respiratory system, nervous system, blood Primary Entry Routes: accidental skin and eye contact, inhalation of generated dusts Acute Effects Inhalation: The dust is harmful and discomforting to the upper respiratory tract. Persons with impaired respiratory

function, airway diseases, or conditions such as emphysema or chronic bronchitis may incur further disability if excessive concentrations of particulate are inhaled. Inhalation of nitrophenols may produce mucous membrane irritation and systemic poisoning. The nitrophenols produce central and peripheral vagus stimulation, central nervous system depression, methemoglobinemia, and observable cyanosis with blue lips, earlobes and fingernails. Although signs may be absent, flushed face, headache and euphoria are common. Moderate exposures may produce weakness, dizziness, lightheadedness, increasingly severe headache, ataxia and shallow respiration, drowsiness, nausea, vomiting, confusion, lethargy and stupor. High concentrations may produce tachycardia, convulsions and coma.

Eye: The dust is mildly corrosive and discomforting to the eyes and is capable of causing burns. Skin: The solid/dust is discomforting to the skin. Toxic effects may result from skin absorption. Direct contact may

produce irritation and/or systemic poisoning.

2003-02 p-Nitrophenol NIT5320


Ingestion: The solid/dust is discomforting to the gastrointestinal tract and harmful if swallowed. The substance and/or its metabolites may bind to hemoglobin inhibiting normal uptake of oxygen. This condition, known as "methemoglobinemia", is a form of oxygen starvation (anoxia). Symptoms include cyanosis (a bluish discoloration to skin and mucous membranes) and breathing difficulties. Symptoms may not be evident until several hours after exposure. At about 15% concentration of blood methemoglobin there is observable cyanosis of the lips, nose and earlobes. Symptoms may be absent although euphoria, flushed face and headache are commonly experienced. At 25-40%, cyanosis is marked but little disability occurs other than that produced on physical exertion. At 40-60%, symptoms include weakness, dizziness, lightheadedness, increasingly severe headache, ataxia, rapid shallow respiration, drowsiness, nausea, vomiting, confusion, lethargy and stupor. Above 60% symptoms include dyspnea, respiratory depression, tachycardia or bradycardia, and convulsions. Levels exceeding 70% may be fatal.

Carcinogenicity: NTP - Not listed; IARC - Not listed; OSHA - Not listed; NIOSH - Not listed; ACGIH - Not listed; EPA - Not listed; MAK - Not listed.

Chronic Effects: Chronic exposure to nitrophenols may produce kidney and liver damage. Studies in mammals show changes in neurohumoral regulation and pathology. Colitis, enteritis, hepatitis, gastritis, hyperplasia of the spleen and neuritis may occur.

Section 4 - First Aid Measures Inhalation: • If dust is inhaled, remove to fresh air. • Encourage patient to blow nose to ensure clear breathing passages. • Rinse mouth with water. Consider drinking water to remove dust from throat. • Seek medical attention if irritation or discomfort persist. Eye Contact: • Immediately hold the eyes open and flush with fresh running water. • Ensure complete irrigation of the eye by keeping eyelids apart and away from eye and moving the eyelids by

occasionally lifting the upper and lower lids. • Seek medical attention if pain persists or recurs. • Removal of contact lenses after an eye injury should only be undertaken by skilled personnel. Skin Contact: • Immediately remove all contaminated clothing, including footwear (after rinsing with water). • Wash affected areas thoroughly with water (and soap if available). • Seek medical attention in event of irritation. Ingestion: Contact a Poison Control Center. If more than 15 minutes from a hospital: • INDUCE vomiting with IPECAC SYRUP, or fingers down the back of the throat, ONLY IF CONSCIOUS. Lean

patient forward or place on left side (head-down position, if possible) to maintain open airway and prevent aspiration. NOTE: Wear a protective glove when inducing vomiting by mechanical means.

• SEEK MEDICAL ATTENTION WITHOUT DELAY. • In the meantime, qualified first-aid personnel should treat the patient following observation and employing supportive

measures as indicated by the patient's condition. • If the services of a medical officer or medical doctor are readily available, the patient should be placed in his/her care

and a copy of the MSDS should be provided. • If medical attention is not available on the worksite or surroundings send the patient to a hospital together with a copy

of the MSDS. After first aid, get appropriate in-plant, paramedic, or community medical support. Note to Physicians: For acute or short-term repeated exposures to phenols/cresols: • Phenol is absorbed rapidly through lungs and skin. Massive skin contact may result in collapse and death. • Ingestion may result in ulceration of upper respiratory tract; perforation of esophagus and/or stomach, with attendant complications, may occur. Esophageal stricture may occur.

• An initial excitory phase may present. Convulsions may appear as long as 18 hours after ingestion. Hypotension and ventricular tachycardia that require vasopressor and antiarrhythmic therapy, respectively, can occur.

• Respiratory arrest, ventricular dysrhythmias, seizures and metabolic acidosis may complicate severe phenol exposures so the initial attention should be directed towards stabilization of breathing and circulation with ventilation, intubation, intravenous lines, fluids and cardiac monitoring as indicated.

• Vegetable oils retard absorption; do NOT use paraffin oils or alcohols. Gastric lavage, with endotracheal intubation, should be repeated until phenol odor is no longer detectable; follow with vegetable oil. A saline cathartic should then be given. ALTERNATELY: Activated charcoal (1g/kg) may be given. A cathartic should be given after oral activated charcoal.

• Severe poisoning may require slow intravenous injection of methylene blue to treat methemoglobinemia. • Renal failure may require hemodialysis. • Most absorbed phenol is biotransformed by the liver to ethereal and glucoronide sulfates and is eliminated almost completely after 24 hours.

BIOLOGICAL EXPOSURE INDEX - BEIThese represent the determinants observed in specimens collected from a healthy worker who has been exposed at the Exposure Standard (ES or TLV): Determinant Index Sampling Time Comments Methemoglobin 1.5% of During or B,NS,SQ



in blood hemoglobin end of shift B: Background levels occur in specimens collected from subjects NOT exposed NS: Non-specific determinant; also observed after exposure to other materials SQ: Semi-quantitative determinant - Interpretation may be ambiguous; should be used as a screening test or confirmatory test.

Section 5 - Fire-Fighting Measures Flash Point: 192 °C Autoignition Temperature: 283 °C Extinguishing Media: Water spray or fog. Foam. Dry chemical powder. BCF (where regulations

permit). Carbon dioxide. General Fire Hazards/Hazardous Combustion Products: • Combustible. • Slight fire hazard when exposed to heat or flame. • Heat may cause expansion or decomposition leading to violent rupture of containers. • On combustion, may emit toxic fumes of carbon monoxide (CO). • May emit acrid smoke. May emit poisonous fumes. Other combustion products include carbon

dioxide (CO2) and nitrogen oxides (NOx). Fire Incompatibility: Avoid contamination with oxidizing agents i.e., nitrates, oxidizing acids, chlorine bleaches, pool

chlorine etc. as ignition may result. Fire-Fighting Instructions: • Contact fire department and tell them location and nature of hazard. • Wear full body protective clothing with breathing apparatus. • Prevent, by any means available, spillage from entering drains or waterways. • Use water delivered as a fine spray to control fire and cool adjacent area. • Avoid spraying water onto liquid pools. • Do not approach containers suspected to be hot. • Cool fire-exposed containers with water spray from a protected location. • If safe to do so, remove containers from path of fire. Equipment should be thoroughly decontaminated after use.

Section 6 - Accidental Release Measures Small Spills: • Remove all ignition sources. • Clean up all spills immediately. • Avoid contact with skin and eyes. • Control personal contact by using protective equipment. • Use dry clean up procedures and avoid generating dust. • Place in a suitable labeled container for waste disposal. Large Spills: • Clear area of personnel and move upwind. • Contact fire department and tell them location and nature of hazard. • Wear full body protective clothing with breathing apparatus. • Prevent, by any means available, spillage from entering drains or waterways. • No smoking, bare lights or ignition sources. • Increase ventilation. • Stop leak if safe to do so. • Water spray or fog may be used to disperse/absorb vapor. • Contain or absorb spill with sand, earth or vermiculite. • Collect recoverable product into labeled containers for recycling. • Collect solid residues and seal in labeled drums for disposal. • Wash area and prevent runoff into drains. • After clean up operations, decontaminate and launder all protective clothing and equipment before storing and reusing. • If contamination of drains or waterways occurs, advise emergency services. Regulatory Requirements: Follow applicable OSHA regulations (29 CFR 1910.120).

Section 7 - Handling and Storage Handling Precautions: • Avoid all personal contact, including inhalation. • Wear protective clothing when risk of overexposure occurs. • Use in a well-ventilated area. • Prevent concentration in hollows and sumps. • DO NOT enter confined spaces until atmosphere has been checked. • Do not allow material to contact humans, exposed food or food utensils. • Avoid smoking, bare lights or ignition sources. • When handling, DO NOT eat, drink or smoke. • Avoid contact with incompatible materials. • Keep containers securely sealed when not in used.

31

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Fire Diamond



• Avoid physical damage to containers. • Always wash hands with soap and water after handling. • Working clothes should be laundered separately. Launder contaminated clothing before reuse. • Follow good occupational work practices. • Observe manufacturer's storage/handling recommendations. • Atmosphere should be regularly checked against established exposure standards to ensure safe working conditions are

maintained. Recommended Storage Methods: Glass container. Plastic container. Metal can. Metal drum. Check that all containers

are clearly labeled and free from leaks. Regulatory Requirements: Follow applicable OSHA regulations.

Section 8 - Exposure Controls / Personal Protection Engineering Controls: Local exhaust ventilation usually required. If risk of overexposure exists, wear NIOSH-

approved respirator. Provide adequate ventilation in warehouse or closed storage area. Personal Protective Clothing/Equipment: Eyes: Safety glasses with side shields. Chemical goggles. Full face shield. Contact lenses pose a special hazard; soft

lenses may absorb irritants and all lenses concentrate them. Hands/Feet: Wear chemical protective gloves, e.g. PVC. Wear safety footwear. Other: • Overalls. • PVC Apron. • PVC protective suit may be required if exposure severe. • Eyewash unit. • Ensure there is ready access to a safety shower.

Section 9 - Physical and Chemical Properties Appearance/General Info: Colorless to slightly yellow, odorless crystals; sweetish then burning taste. Freely soluble

in alcohol, chloroform and ether, also soluble in solutions of fixed hydroxides and carbonates. Physical State: colorless to slightly yellow to brown

crystals, prisms, or solid Vapor Pressure (kPa): 2.2 mm Hg at 146 °C Vapor Density (Air=1): 1.244 at 65 °C Formula Weight: 139.11 Specific Gravity (H2O=1, at 4 °C): 1.27 at 20 °C

Boiling Point: Decomposes at 279 °C (534 °F) Freezing/Melting Point: 113 °C (235.4 °F) to 114 °C

(237.2 °F) Water Solubility: 1600 x10 at 25 °C

Section 10 - Stability and Reactivity Stability/Polymerization/Conditions to Avoid: Product is considered stable. Hazardous polymerization will not occur. Storage Incompatibilities: Avoid reaction with oxidizing agents, bases and strong reducing agents.

Section 11 - Toxicological Information Toxicity Irritation Oral (rat) LD50: 250 mg/kg Nil reported Bacterial cell mutagen.

See NIOSH, RTECS SM2275000, for additional data.

Section 12 - Ecological Information Environmental Fate: When released on land, it will biodegrade with a half-life of approximately a day. If released in

water, it will also primarily biodegrade with a half-life of approximately 1-8 days. Half-lives will be markedly shortened when the microorganisms are well acclimated. Half-lives will be much longer in marine waters. Photolysis may also be important in clear surface waters (half-lives 2-14 days); being somewhat faster when the water is acidic or contains nitrate or nitrite ions. Adsorption to sediment should be minor under most circumstances and little or no bioconcentration should take place. If released into the atmosphere, it will be predominately adsorbed to particulate matter or be in aerosols. It will be subject to gravitational settling and photolyze with a half-life that may range from hours to a week or more.

Ecotoxicity: LC50 Pimephales promelas (fathead minnow) 41.0 (37.7-44.6) mg/l 96 hr, wt 84 mg, flow-through bioassay, dissolved oxygen 7.4 (4.6-8.8) mg/l, water hardness 44.9 (42.4-46.6) mg/l as CaCO3, pH 6.9-7.7, alkalinity 42.9 (39.6-61.4) mg/l CaCO3; LC50 Daphnia magna (Cladoceran) 35,000 ug/l/24 hr /Conditions of bioassay not specified

BCF: fathead minnow 79 Octanol/Water Partition Coefficient: log Kow = 1.91



Soil Sorption Partition Coefficient: Koc = estimated at 21

Section 13 - Disposal Considerations Disposal: • Consult manufacturer for recycling options and recycle where possible. • Follow applicable local, state, and federal regulations. • Incinerate residue at an approved site. • Recycle containers if possible, or dispose of in an authorized landfill.


Shipping Name: NITROPHENOLS Hazard Class: 6.1 ID No.: 1663 Packing Group: III Label: Harmful[6]


RCRA 40 CFR: Listed U170 Toxic Waste CERCLA 40 CFR 302.4: Listed per CWA Section 311(b)(4), per RCRA Section 3001, per CWA Section 307(a) 100

lb (45.35 kg) SARA 40 CFR 372.65: Listed SARA EHS 40 CFR 355: Not listed TSCA: Listed



Attachment F

Incident/Near-Miss Investigation Report

05/27/04 Page 1 of 3 Attach D Near Miss Form.doc


Incident / Near-Miss Investigation Report

OSHA Recordable Lost Workday Injury Restricted Duty Injury

First Aid Injury Vehicle Accident Equipment Damage

Fire Spill / Leak Near Miss

Date of Incident: Incident Number:

Every employee injury, accident, and near miss must be reported within 24 hours of the injury. If the incident results in hospitalization, an immediate report must be made by telephone to the OU RI/FS Manager and the Health and Safety Officer.

Project Information

Project Name: Project #

Location of Incident:

Employee

Name: Employee Number:

Employment Status: Regular Part Time How long in present job?

Injury or Illness Information

Where did the incident / near miss occur? (number, street, city, state, zip):

Employee’s specific activity at the time of the incident / near miss:

Equipment, materials, or chemicals the employee was using when the incident / near miss occurred (e.g., the equipment employee struck against or that struck the employee; the vapor inhaled or material swallowed; what the employee was lifting, pulling, etc.):

Describe the specific injury or illness (e.g., cut, strain, fracture, etc.):

Body part(s) affected (e.g., back, left wrist, right eye, etc.):

Name and address of treatment provider (e.g., physician or clinic): Phone No.:

If hospitalized, name and address of hospital: Phone No.:

Date of injury or onset of illness: / / Time of event or exposure: AM PM

Did employee miss at least one full shift’s work? No Yes, 1st date absent (MM/DD/YYYY) / /

Has employee returned to work? Regular work Restricted work No Yes, date returned (MM/DD/YYYY) / /

To whom reported: Other workers injured / made ill in this event? Yes No

Description of Incident / Near Miss: (Describe what happened and how it happened.)




Motor Vehicle Accident (MVA) Company Vehicle?

Yes No

Accident Location (street, city, state)

Vehicle Towed?

Yes No

Other Vehicle?

Yes No

# Vehicles Towed:

# of Injuries:

Spill Material Spilled: Quantity: Source: Agency Notifications:

Cost of Incident $

Third Party Incidents Name of Owner:

Address:

Telephone:

Description of Damage:

Witness Name:

Address:

Telephone:

Witness Name:

Address:

Telephone:

# Root Cause and Contributing Factors: Conclusion (Describe in Detail Why Incident / Near Miss Occurred) 1 2 3 4 5 Root Cause(s) Analysis (RCA): 1. Lack of skill or knowledge. 5. Correct way takes more time and / or requires more

effort. 2. Lack of or inadequate operational procedures or work

standards. 6. Short-cutting standard procedures is positively

reinforced or tolerated. 3. Inadequate communication of expectations regarding

procedures or work standards. 7. Person thinks there is no personal benefit to always

doing the job according to standards. 4. Inadequate tools or equipment. 8. Uncontrollable.

# RCA #

Solution(s): How to Prevent Incident / Near Miss From Reoccurring

Person Responsible Due Date Closure

Date

Investigation Team Members Name Job Title Date




Results of Solution Verification and Validation

Reviewed By Name Job Title Date OU RI/FS Manager

OU Health and Safety Officer

Attachment G

Safe Work Observation Form

` Anniston PCB Site Anniston, Alabama

Safe Work Observation Form


Observer Name Observer Title Project/Project Number

Date _ Project Type / Task Observed Time ____ AM PM

Background Information

List Critical Work Procedures

List Issue/Items Requiring Corrective Action

Root Cause Analysis 1. Employee lacks the skill or knowledge to carry out duties 5. Employee chose not to take the time or put forth the effort to do the job

properly 2. Procedures, work standards, or expectations were not communicated 6. Supervisor did not require the employee to follow the standard procedure 3. Procedures or work standards were not developed or were inadequate 7. Employee doesn’t see any advantage to doing the job to standard. 4. Equipment, systems, or tools were inadequate 8. Uncontrollable.

Criterion # RCA # Corrective Action Identified

Responsible Individual

Due Date

Closure Date

Results of Corrective Action

Reviewed by Date Reviewed by Date

` Anniston PCB Site Anniston, Alabama

Environmental Operations

PRE-TASK PREPARATION Correct Questionable Comments

1. Health and Safety Plan / MSDSs on site 2. Employee familiar / trained on task 3. OSHA-required training/medical surveillance 4. Utility mark out / check performed 5. Traffic hazard addressed / work area marked 6. Walking / working surfaces free of hazards 7. Tailgate safety meeting performed 8. Impact on nearby residence/business evaluated 9. Communicates intentions to other personnel 10. Knowledge of emergency procedures 11. Distance between equipment and power lines 12. Personal protective equipment 13. Air monitoring equipment on site, calibrated 14. First aid kit / fire extinguisher on site 15. One person trained in first aid / CPR 16. Work zones established and marked PERFORMING TASK 17. Employee trained in task to be performed 18. Correct body positioning 19. Proper lifting / pushing / pulling techniques 20. Keep hands / body away from pinch points 21. Walking / working surfaces kept clear of debris 22. Faces traffic as appropriate 23. Vehicles/ barricades to protect against traffic 24. Drill rig located properly, blocked / chocked 25. Drill rig moved only with derrick lowered 26. Excavator located on stable ground 27. Eye contact made with equipment operator 28. Spoil at least 2 feet back from edge of excavation 29. Excavation shored/sloped/benched 30. Excavation entry controlled 31. Equipment/tools used properly 32. Electrical equipment connected through GFCI 33. Power tools handled properly 34. Electrical cords inspected / in good condition 35. Follows lockout / tagout procedures 36. Air monitoring conducted/action levels understood 37. Equipment decontaminated properly 38. Personnel decon prior to eating/drinking/smoking 39. Decontamination effective POST – TASK 40. Procedures / AHA adequate 41. Equipment / tools stored properly 42. Proper storage of soil / water / waste material 43. Work area secured 44. Other

Attachment H

Air Monitoring Form

05/27/04 Attach F Air Form.doc


Air Monitoring Log

Project: Monitoring Instruments:

Date:

Air Monitor: Level of Protection:

Activity:

Time

Location

Instrument Reading

Comments

Attachment I

Health and Safety Inspection Form

05/27/04 Page 1 of 3 Attach G H&S Insp Form.doc



Project Name: Date:


Prepared By: Site Safety Officer:

Auditor: Health & Safety

Coordinator On Site:

YES NO N/A COMMENTS

GENERAL

Is the HASP on site?

Is the HASP finalized and approved?

Is the OSHA poster displayed?

Are emergency telephone numbers posted?

Is emergency eyewash immediately available?

Is an emergency shower immediately available?

Are emergency notification means available (radio, telephone)?

Is a first-aid kit immediately available?

Is the first-aid kit adequately stocked?

Is there a proper sanitation facility on site?

DOCUMENTATION AND RECORDKEEPING Are only personnel listed and approved in the HASP on site?

Are all personnel properly trained? (Check company-issued wallet cards.)

Is the daily field log kept by the Site Safety Officer?

Are levels of PPE recorded?

Are contaminant levels recorded?

Are site surveillance records kept by HSC?

Is a copy of current fit test records on site?

Are calibration records maintained for air monitoring equipment?

Are accident / incident forms on site?

Are field team review sheets signed?

Are additional hospital route directions available?

Is the visitors’ logbook being accurately maintained?

Are MSDSs available for all chemicals on site?

Are HASP revisions recorded?

Is the first-aid kit inspected weekly?

Are daily safety meetings held?

Are emergency procedures discussed during safety meetings?




YES NO N/A COMMENTS

EMERGENCY RESPONSES Is a vehicle available on site for transportation to the hospital?

Are fire extinguishers on site and immediately available at designated work areas?

Is at least one person trained in CPR and first aid on site at all times during work activities?

Do all personnel know who is trained in CPR / first aid?

PERSONAL PROTECTIVE EQUIPMENT (PPE)

Is proper PPE being worn as specified in HASP?

Level of PPE being worn.

Is PPE adequate for work conditions?

If not, give reason.

Upgrade/downgrade to PPE level.

Does any employee have facial hair that would interfere with respirator fit?

If yes, willing to shave, as necessary?

Fit-tested within the last year? (Documentation present)

If Level B, is a back-up / emergency person suited up (except for air)?

Does the HSC periodically inspect PPE and equipment?

Is the PPE not in use properly stored?

Is all equipment required in the HASP on site?

Properly calibrated?

In good condition?

Used properly?

Other equipment needed?

List.

Is monitoring equipment covered with plastic to minimize contamination?

PERSONNEL AND EQUIPMENT DECONTAMINATION

Is the decontamination area properly designated?

Is appropriate cleaning fluid used for known or suspected contaminants?

Are appropriate decontamination procedures used?

Are decontamination personnel wearing proper PPE?

Is the equipment decontaminated?




YES NO N/A COMMENTS

PERSONNEL AND EQUIPMENT DECONTAMINATION (continued)

Are sample containers decontaminated?

Are disposable items replaced as required?

WORK PRACTICES

Was proper collection and disposal of potentially contaminated PPE performed?

Was proper collection and disposal of decontamination fluid performed?

Is water available for decontamination?

Is the buddy system used?

Is equipment kept off drums and the ground?

Is kneeling or sitting on drums or the ground prohibited?

Do personnel avoid standing or walking through puddles or stained soil?

Are work zones established?

If night work is conducted, is there adequate illumination?

Is smoking, eating, or drinking in the exclusion or CRZ prohibited?

To the extent feasible, are contaminated materials handled remotely?

Are contact lenses not allowed on site?

Is entry into excavations not allowed unless properly shored or sloped?

Is a competent person on site during excavation?

Are all unusual situations on site listed in HASP?

If not, when?

Action taken?

HASP revised?

CONFINED SPACE ENTRY

Are employees trained according to 1910.146 – Confined Space Entry?

Are all confined spaces identified? If not, list:

Is all appropriate equipment available and in good working order?

Is equipment properly calibrated?

Are confined space permits used?

Are confined space permits completely and correctly filled out?

*N/A = Not Applicable

Attachment J

Safety Meeting Log

05/27/04 Attach H Safety Mtg Log.doc


Safety Meeting Log

Project: Location: Date / Time: Activity: 1. Work Summary 2. Physical Chemical Hazards 3. Protective Equipment/Procedures 4. Emergency Procedures Is there anyone with any medical conditions that they would like the team to know about? For example: Medic Alert, allergic to bee stings, nitro for chest pains, etc. Location of medical equipment: fire extinguishers, first aid kit, route to hospital, auto-injectors, etc. 5. Signatures of Attendees

Attachment K

Hot Work Permit

05/27/04 Attach I Hot Work Permit.doc


Site Hot Work Permit

Permit #:

Project:

ALL COPIES OF PERMIT MUST REMAIN AT

JOB SITE UNTIL THE WORK IS COMPLETE

Location and Description of Hot Work:

Checklist YES NO N/A COMMENT

Is there any alternate procedure to use instead of hot work?

Is it possible to move the hot work to a designated hot work area?

Is it possible to move all fire hazards at least 35 feet away? If all fire hazards cannot be removed, can guards, barriers, or screens be used to confine any heat, sparks, or slag, and to protect the immovable fire hazards?

Are there any flammable or combustible liquid storage areas within 50 feet? Is the area where the work is to be performed free of combustible material to heat, sparks, flying sparks, or slag?

Are combustible materials adjacent to the opposite side of partitions, walls, or ceilings protected by guards or moved 35 feet away from the surface?

Is everything moved or protected that could be damaged by sparks or water?

Is suitable fire extinguishing equipment on hand and ready for immediate use?

Is the sprinkler system in the area operational? Are the surrounding employees in an area where flying sparks and slag may injure them?

Have precautions been implemented to prevent injury to employees?

Has the area supervisor been notified?

Is a fire watch in place?

Is hot work to be conducted in a confined space? Is appropriate personal protective equipment and respiratory protection being used?

The area where hot work is being conducted must remain attended for at least 30 minutes after completion of the work. Monitoring Frequency: Continuous Every 30 min. Other

Monitor’s Name: _________________________________

Hot Work Air Monitoring Parameters Time of Reading

% Oxygen>19.5% % LEL <10% Other

Air Monitor ________________________________________________________________ Print Name _______________________________________________________________________________________________________ Signature Date Time

Attachment L

Confined Space Entry Checklist

06/02/04 Attach L CSE Checklist.doc


Confined Space Entry Checklist

Permit #:

Project:

ALL COPIES OF PERMIT MUST REMAIN AT

JOB SITE UNTIL THE ENTRY IS COMPLETE

Location and Description of Confined Space:

Checklist YES NO N/A COMMENT Are all lines to and from confined space blanked, capped, or isolated? Electrical service locked out (entrant with key)? Are mechanical devices / systems restrained and locked out? Is explosion-proof electrical equipment in use? Are ladders secured at top? Is the ground fault circuit interrupter checked and functioning? Are all ignition sources identified and isolated? Are respirators and air supply equipment in proper condition? Are safety harnesses and lifelines in proper condition? Is required PPE being used? Is monitoring equipment calibrated and functioning properly? Is atmospheric testing completed? Is a trained attendant on standby? Is emergency equipment ready for use? Are rescue provisions in place? Are warning signs posted? Is ventilation equipment functioning properly? Is the retrieval system functioning properly? Communication device for entrance and attendants? Is the area secured to eliminate unauthorized entry? Are entry personnel trained for confined space entry? Is the confined space entry permit completed and posted? Are the permanent ladder rungs in safe condition? Monitoring Frequency: Continuous 5 min. 10 min. 30 min.

Monitor’s Name: _________________________________

Confined Space Air Monitoring Parameters Time of Reading % Oxygen>19.5% % LEL <10% CO <20 ppm Other

Pre-Entry

Entry Supervisor ________________________________________________________________ Print Name _______________________________________________________________________________________________________ Signature Date Time Air Monitor ________________________________________________________________ Print Name _______________________________________________________________________________________________________ Signature Date Time

Attachment M

Confined Space Entry Permit

06/03/04 Attach M CSE Permit.doc


Confined Space Entry Permit

Project Name: Date / Time:


Prepared By: Health and Safety Coordinator:

Location and Description of Confined Space:

Rescue Contact and Phone Number:

Entry Objectives:

Equipment / Materials Required for Entry:

Time of Entry: Expiration of Entry:

Required Respirator for Entry:

Required Protective Clothing for Entry:

Monitoring Interval: Continuous 5 minutes 10 minutes 15 minutes 30 minutes

Air Monitoring Requirements

Calibrated Monitor For Monitoring Equipment

Date / Time By

% O2

% of LEL

H2S

CO

Other:

Other:

Entrants and Attendants

Number of Entrants: Number of Attendants:

Names of Entrants Names of Attendants

Entry Supervisor Authorizing Confined Space Entry Permit

Print: Date: Time:

Signature: Date: Time:

Entry Supervisor Canceling Confined Space Entry Permit

Print: Date: Time:

Signature: Date: Time:

Appendix 1

NTC Removal Action Supplemental Sampling Health

and Safety Plan

NTC Removal Action Supplemental Sampling

Health & Safety Plan

Anniston PCB Site, Anniston Alabama

September 2003 Revision 0

September 2003

Report on

NTC REMOVAL ACTION SUPPLEMENTAL SAMPLING HEALTH AND SAFETY PLAN

FOR THE

ANNISTON PCB SITE

(Docket No. CV-02-PT-0749-E)

Prepared for:

United States Environmental Protection Agency Waste Management Division

Atlanta Federal Center 61 Forsyth Street, S.W.

Atlanta, GA 30303

Prepared by:

Solutia Inc. 702 Clydesdale Avenue

Anniston, Alabama 36201

September 2003 Anniston PCB Site Revision 0 Supplemental Sampling Health and Safety Plan Solutia Inc. Page 1 of 1

TITLES AND APPROVALS

The undersigned certify that this Solutia Inc. (Solutia) NTC Removal Action Supplemental

Sampling Health and Safety Plan is approved and will be utilized for the Anniston PCB Site

(Site) activities in Anniston, Alabama defined by the United States Environmental Protection

Agency (EPA) Non-Time Critical Removal Agreement.

____________________________________ ______________________________ Craig Branchfield Date Solutia Project Manager

____________________________________ ______________________________ John Loper Date

CERCLA Manager

____________________________________ ______________________________ Gayle Macolly Date NTC Removal Action Manager

____________________________________ ______________________________ Charles Haury, CIH Date Health and Safety Officer

____________________________________ ______________________________ Gina Monroy Date Health and Safety Coordinator

____________________________________ ______________________________ Michael Price Date Site Safety Officer

September 2003 Anniston PCB Revision 0 Supplemental Sampling Health and Safety Plan Solutia Inc. Page i of iii

TABLE OF CONTENTS

Titles and Approvals Table of Contents SECTION PAGE

1.0 INTRODUCTION ....................................................................................................1

2.0 SITE DESCRIPTION...............................................................................................2 2.1 General Information........................................................................................2 2.2 Site and Work Description ..............................................................................2

3.0 HEALTH AND SAFETY ORGANIZATION AND COORDINATION....................3 3.1 Solutia Project Manager..................................................................................3 3.2 CERCLA Manager.........................................................................................3 3.3 NTC Removal Action Manager .......................................................................3 3.4 Sampling Health and Safety Officer.................................................................3 3.5 Sampling Health and Safety Coordinator ..........................................................4 3.6 Sampling Site Safety Officer...........................................................................4 3.7 Project Personnel............................................................................................5

4.0 HAZARD EVALUATION........................................................................................6 4.1 General..........................................................................................................6 4.2 Field Activities...............................................................................................6 4.3 Activity-Specific Hazards ...............................................................................6 4.4 Chemical Hazards...........................................................................................7

4.4.1 Exposure Via Ingestion.......................................................................7 4.4.2 Exposure Via Dermal Contact.............................................................8 4.4.3 Exposure Via Inhalation ......................................................................8

4.5 Physical Hazards ............................................................................................8 4.5.1 Operation of Drilling Equipment .........................................................9 4.5.2 Confined Space Entry.........................................................................9 4.5.3 Heat Stress .........................................................................................9

4.5.3.1 Operational Guidance.................................................................................. 10 4.5.4 Cold Stress....................................................................................... 12 4.5.5 Noise ............................................................................................... 13 4.5.6 Manual Lifting ................................................................................. 13 4.5.7 Slip, Trip and Fall Hazards................................................................ 14 4.5.8 Electrical Equipment......................................................................... 14

4.6 Biological Hazard......................................................................................... 14 4.6.1 Insect Bites and Stings ...................................................................... 14 4.6.2 Tick Bites ........................................................................................ 14 4.6.3 Snake Bites ...................................................................................... 16 4.6.4 Dogs................................................................................................ 16

September 2003 Anniston PCB Revision 0 Supplemental Sampling Health and Safety Plan Solutia Inc. Page ii of iii

TABLE OF CONTENTS (Continued)

4.6.5 Plants............................................................................................... 16

5.0 TRAINING REQUIREMENTS..............................................................................18 5.1 Basic Training.............................................................................................. 18 5.2 Pre-Work Briefing ........................................................................................ 18 5.3 Daily Briefings ............................................................................................. 18 5.4 First Aid and CPR........................................................................................ 19 5.5 Documentation ............................................................................................. 19 5.6 Hazard Communication ................................................................................ 19

6.0 SITE CONTROL....................................................................................................20 6.1 General........................................................................................................ 20 6.2 Daily Start Up.............................................................................................. 20

7.0 AIR MONITORING...............................................................................................21

8.0 WORK TASKS AND PERSONAL PROTECTIVE EQUIPMENT REQUIREMENTS .................................................................................................22 8.1 General........................................................................................................ 22 8.2 Respiratory Protection Program..................................................................... 22 8.3 PPE Protection Summary .............................................................................. 23

8.3.1 Level D Equipment........................................................................... 23 8.3.2 Level C Equipment ........................................................................... 23

9.0 DECONTAMINATION PROCEDURES................................................................25 9.1 General........................................................................................................ 25 9.2 Contamination Prevention ............................................................................. 25 9.3 Decontamination Equipment ......................................................................... 26 9.4 Personnel Decontamination........................................................................... 26 9.5 Equipment Decontamination ......................................................................... 27

9.5.1 Respiratory Protective Equipment...................................................... 27 9.5.2 Drilling and Sampling Equipment ...................................................... 27

10.0 EMERGENCY RESPONSE PROCEDURES.........................................................29 10.1 General........................................................................................................ 29 10.2 Emergency Notifications ............................................................................... 29 10.3 Evacuation Routes ........................................................................................ 29 10.4 Emergency Equipment and First Aid Requirements ........................................ 29

10.4.1 Emergency Equipment and First Aid Supplies .................................... 29 10.4.2 Fire Extinguishers............................................................................. 29

September 2003 Anniston PCB Revision 0 Supplemental Sampling Health and Safety Plan Solutia Inc. Page iii of iii

TABLE OF CONTENTS (Continued)

11.0 MEDICAL SURVEILLANCE PROGRAM............................................................30

12.0 RECORD KEEPING AND REPORTS...................................................................31 12.1 General Record Keeping ............................................................................... 31 12.2 Training Records .......................................................................................... 31 12.3 Daily Field Information................................................................................. 31 12.4 Accident Reporting ....................................................................................... 32 12.5 Project Completion Activities........................................................................ 32

13.0 REFERENCES.......................................................................................................33

In Order Following

Page 33

TABLES TABLE 1 Regulatory and Recommended Exposure Limits for Selected Chemicals for

the Individual Properties TABLE 2 Heat Stress: Basis for Work Schedule TABLE 3 NTC Removal Action Sampling PPE Requirements TABLE 4 Emergency Phone Numbers Anniston PCB Site

FIGURES

FIGURE 1 General Work Area FIGURE 2 Outline for Level C Decontamination FIGURE 3 Outline for Level D Decontamination FIGURE 4 Site and Hospital Location

APPENDICES APPENDIX A Health and Safety Plan Addendum/Revision Form APPENDIX B Toxicological Data for Selected Chemicals APPENDIX C OSHA 101 Form for Occupational Injuries and Illnesses APPENDIX D Health and Safety Plan Signature Form APPENDIX E “Tailgate” Safety Meeting Form


1.0 INTRODUCTION

This Supplemental Sampling Health and Safety Plan (Sampling HSP) has been prepared in

accordance with the requirements of the Non-Time Critical Removal Agreement (NTC Removal

Agreement) included as Appendix G to the Partial Consent Decree (Docket No. CV-02-PT-0749-

E) between the United States Environmental Protection Agency (EPA) and Solutia Inc. (Solutia).

The Partial Consent Decree was entered by the United States District Court for the Northern

District of Alabama on August 4, 2003 (EPA, 2002). The NTC Removal Agreement provides for

the performance of a removal action in connection with residential properties that may contain

soil with polychlorinated biphenyls (PCBs) located in and around Anniston, Calhoun County,

Alabama. These residential properties are included within the Anniston PCB Site (Site) as

defined by the Partial Consent Decree.

This Sampling HSP has been developed for the protection of the project team and other persons

that may be exposed to hazards associated with sampling activities at the Site. The purpose of

this Sampling HSP is to assign responsibilities, establish personnel protection standards, specify

and establish safe operating procedures and practices, and provide for contingencies that may

arise while conducting sampling activities at the Site.

This Sampling HSP has been prepared based upon the requirements pertaining to hazardous

waste activities outlined in the following regulations, guidelines, and manuals:

• Code of Federal Regulations (CFR), Title 29, part 1910 (29 CFR 1910);

• Guidelines prepared by National Institute for Occupational Health and Safety (NIOSH), Occupational Safety and Health Administration (OSHA), U.S. Coast Guard (USCG), and the U.S. Environmental Protection Agency (USEPA); and

• Manual entitled “Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities (1985).”

This Sampling HSP is based on the information available concerning the possible chemical and

physical hazards found on the Site. As additional site-specific information becomes available,

this Sampling HSP may be modified accordingly. The form for completing the Sampling HSP

Addendum/Revision is presented in Appendix A.


2.0 SITE DESCRIPTION

2.1 General Information

The removal action activities are being conducted in accordance with the NTC Removal

Agreement between the EPA and Solutia. EPA has designated Ms. Pam Scully, as EPA’s

Remedial Project Manager. Solutia has designated Mr. Craig Branchfield as its Project Manager.

Mr. Branchfield is located at Solutia’s Anniston facility at:

Solutia Inc.


Anniston, Alabama 36201

(256) 236-8404

2.2 Site and Work Description

The Site consists of residential properties located in and around Anniston, Calhoun County,

Alabama. Work tasks may include the following:

• sampling surface soils in residential yards;

• sampling soils in residential yards at depth by hand and/or mechanical boring advancement methods; and

• sampling dust in residences.


3.0 HEALTH AND SAFETY ORGANIZATION AND COORDINATION

The key personnel listed below will be responsible for the supervision and implementation of the

requirements outlined in the Sampling HSP for the Site.

• Solutia Project Manager: Craig Branchfield (Solutia Inc.)

• CERCLA Manager: John Loper (The Loper Group, Inc.)

• NTC Removal Action Manager: Gayle Macolly (Golder Associates, Inc.)

• Sampling Health and Safety Officer: Charles Haury (Golder Associates, Inc.)

• Sampling Health and Safety Coordinator: Gina Monroy (Golder Associates, Inc.)

• Site Safety Officer: Michael Price (Genesis Project, Inc.)

3.1 Solutia Project Manager

The Solutia Project Manager has overall responsibility for projects associated with the Solutia,

Anniston, Alabama facility. The Solutia Project Manager has final authority for decisions made

by the response team associated with the Anniston PCB Site removal actions.

3.2 CERCLA Manager

The Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)

Manager has overall responsibility for the management and technical oversight of the Anniston

PCB Site CERCLA project. The CERCLA Manager offers technical and management support to

the Solutia Project Manager.

3.3 NTC Removal Action Manager

The NTC Removal Action Manager has overall responsibility for the management and technical

oversight of the Anniston PCB Site Removal Action project. The NTC Removal Action Manager

is a liaison between the Solutia Project Manager and/or CERCLA Manager and the Site Sampling

Manager. The NTC Removal Action Manager assesses final data and reports findings to the

CERCLA Manager and Solutia Project Manager.

3.4 Sampling Health and Safety Officer

The Health and Safety Officer (HSO) is the primary reviewer of the Sampling HSP and is

responsible for health and safety technical support.


3.5 Sampling Health and Safety Coordinator

The Health and Safety Coordinator (HSC) is responsible for the implementation of the Sampling

HSP at the Site. The responsibilities of the HSC include:

• functioning as the communications liaison between project team and HSO and as such reports directly to the HSO and Site Sampling Manager;

• informing personnel of potential hazards associated with the Site;

• maintaining current documentation of the Site personnel’s health and safety training;

• working closely with the SSO regarding health and safety issues; and

• approving changes in the Sampling HSP.

3.6 Sampling Site Safety Officer

The Site Safety Officer (SSO) is the sampling contractor’s representative responsible for the on-

Site enforcement of the policies and provisions contained in the Sampling HSP. The

responsibilities of the SSO include:

• ensuring that each member of the investigative team is up to date on safety training (e.g., OSHA 40-hour Hazardous Waste Operations and Emergency Response (HAZWOPER), OSHA 8-hour refresher, cardiopulmonary resuscitation (CPR), and first aid, as necessary);

• meeting with the HSC to evaluate sampling operations and understand sampling strategies;

• assisting the HSC in enforcing the Sampling HSP;

• functioning as the communications liaison on safety issues between the project field team and the HSC and the Site Sampling Manager;

• ensuring that the necessary safety equipment is available and operational, including both personal protective equipment and monitoring equipment;

• calibrating monitoring equipment on a daily basis and recording results in field logs;

• ensuring that monitoring equipment is operating correctly, and providing maintenance when required;

• making recommendations to change protection levels of personal protective equipment (PPE);

• implementing proper decontamination and emergency procedures;

• defining work zones;

• conducting on-Site health and safety meetings before on-Site activities begin;

• ensuring that workers have read the Sampling HSP and signed the acknowledgement form;


• authorizing stop-work, which will be executed upon determination of an imminent safety hazard emergency situation or other potentially dangerous situations; and

• initiating and implementing changes to the Sampling HSP.

3.7 Project Personnel

Personnel of the sampling contractor involved in on-Site sampling will be responsible for:

• reading the Sampling HSP and signing the acknowledgement form;

• following the Sampling HSP requirements;

• following the recommendations of the SSO;

• reporting any health and safety issues or hazards they feel are not addressed in the Sampling HSP;

• taking precautions to prevent accident and injury to themselves and to other personnel;

• immediately notifying the SSO of any accidents or medical problems; and

• reporting any unsafe conditions.


4.0 HAZARD EVALUATION

4.1 General

This section presents chemical and physical hazard information to be used for the development of

health and safety protocols for on-Site activities. The goals of the hazard evaluation are twofold:

1) to summarize available chemical information and the corresponding impacts on worker health

and safety; and 2) to adequately describe the physical hazards associated with the Site. This

information is important in the development of action levels to be used for the determination of

levels of respiratory and dermal protection. The judgment of the SSO will provide the basis for

upgrading or downgrading levels of protection. The main constituents of concern at the Site are

PCBs, which may be present in the soils at the Site.

4.2 Field Activities

Field activities that may be performed during the sampling event include:

• site reconnaissance;

• surface and subsurface soil sampling; and

• dust sampling.

Each of these activities involves different potential hazards and requires different levels of

protection.

4.3 Activity-Specific Hazards

The potential health and safety hazards associated with the types of activities to be performed at

the Site are described below:

• Site Reconnaissance

These are non-intrusive tasks and will typically be performed prior to sampling.

Therefore, the potential hazards to personnel performing these tasks are anticipated to be

low.

• Surface and Subsurface Soil Sampling

The potential hazards associated with this activity include inhalation or dermal contact

with potentially impacted soils and physical hazards, such as slips, falls, or sprains.


When sampling is conducted using mechanical means such as a drilling rig, the following

steps are typically involved:

• positioning the rig over the sample location;

• retrieving subsurface soil boring; and

• sampling solids and abandoning the borehole.

Three types of potential hazards are associated with these steps. The primary hazard is

dermal contact with potentially impacted materials, water, and/or equipment. The second

hazard is contact with underground and overhead utilities. The third and less likely

hazard is potential exposure to dust during soil boring retrieval and sampling activities.

• Dust Sampling

This is a non-intrusive task and will typically be performed within a residence.

Therefore, the potential hazards to personnel performing these tasks are anticipated to be

low. However, the potential hazards associated with this activity include inhalation or

dermal contact with potentially impacted dust.

4.4 Chemical Hazards

There is a potential for the sampling workers to be exposed to chemical hazards. The primary

pathway for exposure to occur is dermal contact with chemicals of concern potentially associated

with the soil samples. Secondary pathways for exposure include inhalation of particulate

materials, and possible ingestion if personal hygiene is inadequate. Table 1 lists known exposure

limits for chemicals that may be encountered during sampling of residential properties. Appendix

B presents additional information on health effects from exposure to these chemicals.

4.4.1 Exposure Via Ingestion

Exposure via ingestion can be prevented through the use of the following guidelines:

• prohibiting eating, drinking, smoking, and the application of cosmetics in the work area; and

• requiring workers to wash hands and face prior to consuming food, beverages, or smoking.


4.4.2 Exposure Via Dermal Contact

Exposure via dermal contact can be prevented through the use of PPE and caution taken in

handling liquids and solids in the work zone. The level of PPE required is described in Section

8.3. It is important that a common sense approach be taken in preventing dermal contact.

Precautions should be taken to prevent touching unprotected portions of the skin (particularly

eyes, nose or mouth) when handling liquids or solids in the work zone.

4.4.3 Exposure Via Inhalation

Practices to be employed to minimize potential airborne exposure when performing these

activities should include:

• standing upwind of the field activity;

• recognizing potential warning properties of chemicals and of dust that may be present during field activities (e.g., odor, irritation, nausea, etc.); and

• wearing appropriate PPE including respiratory protection if directed by the SSO.

The SSO will be responsible for assessing the sampling work areas for dust that could possibly

present exposure via inhalation. In the unlikely event that excessive dust is generated during

sampling, personnel will be required to wear NIOSH approved respiratory protection equipped

with P-100 Particulate filter cartridge. Dust control techniques, such as low volume water

spraying or fogging, may be used to minimize the potential for inhalation of particulates.

4.5 Physical Hazards

The following physical hazards must be recognized and controlled during field activities:

• operation of heavy equipment;

• heat stress;

• cold stress;

• noise;

• manual lifting;

• slip, trip and fall; and

• electrical equipment.


4.5.1 Operation of Drilling Equipment

Precautions must be taken when working around drilling equipment. The moving of the

equipment from location to location within the Site is of particular concern. Drilling equipment

operators must obey Site-specific safety requirements, and traffic control must be strictly

followed.

Except where electrical distribution and transmission lines have been de-energized and visibly

grounded, drilling equipment will be operated near power lines in accordance with the guidelines

specified in 29 CFR 1926.

4.5.2 Confined Space Entry

Workplaces that are not intended for human occupancy are defined as confined spaces. Limited

openings hinder proper ventilation, escape, and rescue; therefore, creating a potentially life

threatening situation for a worker.

Confined space entry is not anticipated for Site operations. However, if confined space entry is

required, it will not be undertaken without prior approval from the Site Sampling Manager, HSC

and SSO. Any confined space entry will be governed by OSHA regulation, 29 CFR 1910.146.

4.5.3 Heat Stress

High ambient temperature can result in health effects ranging from transient heat fatigue, physical

discomfort, reduced efficiency, personal injury, increased accident probability, to serious illness

or death. Heat stress is of particular concern when chemical protective clothing1 is worn, since

these garments prevent evaporative body cooling. Wearing personal protective equipment puts a

worker at considerable risk of developing heat stress.

Heat stress is caused by a number of interacting factors, including environmental conditions,

clothing, workload, and the individual characteristics of the worker. Because heat stress is

probably one of the most common (and potentia lly serious) illnesses at sites, regular monitoring

and other preventive measures are vital.

1 Note: Chemical protective clothing is defined as, but not limited to: Clothing constructed of Tyvek, or

coated-Tyvek, PVC rain suits or coveralls, and CPF Series Coveralls.


Heat stress manifests in progressive stages, increasing in severity. The initial stage is commonly

termed heat fatigue, which is usually transient, and subsides with rest and replenishment of fluids.

Heat fatigue is characterized by discomfort, and reduced mental awareness, with a greater effect

in unacclimated workers. Medical treatment is usually not needed.

Heat exhaustion can result from sustained exertion in heat, combined with failure to replace water

and salts lost in sweat. Symptoms include fatigue; nausea; headache; clammy, moist skin, which

may be flushed or pale; and skin eruptions (red face or rash). If any of these signs are observed,

the personnel should stop work immediately and seek medical attention. Replacement of water

and salts is required for recovery; victims may faint upon standing. Electrolyte replacement

fluids should be taken until urine volume increases.

Heat syncope results in fainting, and is caused by standing immobile in heat. It is caused by

pooling of venous blood in the dilated vessels of the skin and lower body. Recovery is complete

and rapid following rest in a recumbent position at a cool location.

The most serious heat illness is heat stroke. Heat stroke is a MEDICAL EMERGENCY,

treatment must be immediate, and professional medical attention must be obtained. Heat stroke is

caused by a combination of factors including heavy exertion in heat, inadequate replacement of

fluids, poor physical condition, and individual susceptibility. Failure of the sweat response

occurs, leading to a rapidly accelerated increase in core temperature. The victim usually has hot,

dry red skin, and if conscious, is confused; convulsions may be present. The victim must be

cooled immediately. Heat stroke is fatal if treatment is incomplete or delayed.

As with any illness, the best cure is prevention. Heat stress is most likely early in the summer,

prior to acclimatization. Full acclimatization takes from 5 to 7 consecutive days of controlled

exertion in heat.

4.5.3.1 Operational Guidance

A work/rest schedule should be developed prior to initiating field activities, whenever ambient

temperatures are greater than 70º F and chemical protective clothing is used; and when

temperatures are greater than 85º F without chemical protective garments. The schedule must be


constantly assessed to ensure effectiveness, and may need to be modified during the workday.

Table 2 presents the heat stress-monitoring basis. Note that personnel performing physically

more demanding work may need a more restrictive schedule.

Increasing Work Rate

1. If a worker's heart rate does not increase, or increases only slightly (l0% or less for the heart rate) from the baseline readings after the first work cycle, the work period (according to the established work-rest regimen) can be increased by 20%.

2. The worker will be monitored closely after the next work cycle period and if there are still no significant increases in heart rate, the work period can be increased by an additional 10% and the rest period remains the same.

3. Increases in the work period can be made throughout the shift if there are no significant increases in the physiological monitoring indices.

4. Note that the increases to the work period are made based on the work-rest regimen established prior to initiation of work activities.

Decreasing Work Rate

1. Count the radial pulse as early as possible in the rest period.

2. If a worker's heart rate exceeds 110 beats per minute immediately after a work period, shorten the next work cycle by 30% and keep the rest period the same.

3. If the heart rate still exceeds the 110 beats per minute after the next work period, shorten the following work cycle by 30%.

4. Continue to shorten the employee's work cycle until the heartbeat is below 110 beats per minute.

Adequate liquids must be provided to replace lost body fluids. Personnel must replace water and

salt lost from sweating. Personnel must be encouraged to drink more than the amount required to

satisfy thirst. Thirst satisfaction is not an accurate indicator of adequate salt and fluid

replacement.

Replacement fluids can be a 0.1% salt-water solution, a commercial mix, such as Gatorade,

Poweraide, Quik Kick or equivalent, or a combination of these with fresh water. Personnel

should be encouraged to salt their foods more heavily. Salt pills are prohibited.

The replacement fluid temperature should be kept cool. Cooling devices such as vortex tubes or

cooling vests can be worn beneath protective garments. Breaks are to be taken in a cool, shaded

rest area (<80° F). Personnel shall remove chemical protective garments during rest periods.


Personnel shall not be assigned other tasks during rest periods. Personnel shall be informed of

the importance of adequate rest and proper diet in the prevention of heat stress. Personnel shall

be informed of the harmful effects of excessive alcohol consumption in the prevention of heat

stress.

Individuals with pre-existing medical conditions or restrictions contraindicating exposure to

elevated environmental heat are precluded from assignments that involve exposure to high

temperatures. Healthy individuals will vary significantly in their tolerance to heat, and heat

tolerance can be affected by minor illnesses (cold, flu) and by prescription and over-the-counter

medications. The heart rate measure is only a part of the overall situation to be considered; other

objective, and subjective symptoms of heat stress, such as: extreme fatigue, nausea,

disorientation, light-headedness, and breathlessness must be fully considered when evaluating the

adequacy of control measures. The heart rate measure will provide guidance that can be

significantly different for each member of a field team based on their acclimatization, physical

fitness and heat tolerance. If it is critical that team members use the same work/break schedule,

the schedule that accommodates the least heat-tolerant team member will be observed.

Training

Those personnel (including workers, supervisors, and contractor personnel) potentially exposed to

heat stress conditions shall have been trained in the following:

1. Sources of heat stress, influence of protective clothing, and importance of acclimatization;

2. How the body handles heat;

3. Heat related illnesses;

4. Preventative/corrective measures; and

5. First aid procedures.

4.5.4 Cold Stress

Critical factors in preventing cold stress disorders are adequate clothing and staying dry. The SSO

and Sampling Team Manager will ensure the capability to quickly move individua ls who become

wet to a sheltered, warm area. The following specific steps will be taken [adapted from the

ACGIH TLV booklet (ACGIH 2002)].


• If ambient temperatures are 40º F or below, site training will include prevention of cold injury, cold-injury symptoms, and cold-injury first aid.

• If ambient temperatures are 40º F or below, and there is a potential for workers to become significantly wet (splashed or soaked), the SSO will ensure that at least one of the following controls is in place:

° a sufficient supply of dry, warm clothing is immediately available;

° personnel wear clothing appropriate for water contact (e.g., immersion-survival suits, neoprene chest waders, wet suit,); or

° a heated break area is immediately available.

• A heated break area will be provided if ambient temperatures are below 32º F.

• At a minimum, breaks will be taken in a warm area every 120 minutes if ambient temperatures are below 32º F.

• Workers will be allowed to take unscheduled breaks, if needed, in a warm area.

• If the equivalent chill temperature (temperature combined with the effect of wind) is less than −29° F, outdoor work will be discontinued or effective engineering controls such as windscreens, temporary shelters, or portable heating units will be used.

4.5.5 Noise

Hearing protection may be required during drilling operations. Training on the proper use of

hearing protection will be conducted as a part of the health and safety briefing conducted by the

SSO prior to on-Site work.

4.5.6 Manual Lifting

Activities may require personnel to move large, heavy objects by hand. The human body is

subject to severe damage in the forms of back injury and hernia if caution is not observed when

handling, lifting, or moving these large, heavy objects.

General Rules

• Get a good footing.

• Place feet about one shoulder width apart.

• Bend at knees to grasp weight.

• Keep the back straight.

• Get a firm hold.


4.5.7 Slip, Trip and Fall Hazards

Ground survey should be made at the site to identify any holes or possible trip hazards.

Walkways should be maintained clear of debris and in a dry condition. Tools and clothing should

be stored when not in use and should not be left on the ground.

4.5.8 Electrical Equipment

Extension cords used with portable electric tools and appliances shall be three-wire and grounded.

Plugs shall conform to the type and configuration required by the OSHA Construction Standards.

4.6 Biological Hazard

4.6.1 Insect Bites and Stings

Insects may be present at this site. Although they can be painful, they rarely cause death.

However, some people have a severe allergic reaction to an insect bite or sting that can result in a

life threatening condition. The following is a list of preventive measures:

• Apply insect repellent prior to fieldwork and or as often as needed throughout the work

shift.

• Wear proper protective clothing (work boots, sock and light colored pants).

• When walking in wooded areas, avoid contact with bushes, tall grass, or brush as much as possible.

• Field personnel who may have insect allergies should provide this information to the HSO prior to commencing work.

• Mark and avoid fire ant mounds.

4.6.2 Tick Bites

The Center for Disease Control (CDC) has noted the increase of Lyme Disease and Rocky

Mountain Spotted Fever (RMSF) resulting from bites from infected ticks that live in and near

wooded areas, tall grass, and brush. Ticks are small, ranging in size up to about one quarter inch.

They are sometimes difficult to see. The tick season extends from spring through summer. When

embedded in the skin, they may look like a freckle. Lyme disease has occurred in 43 states, with

the heaviest concentrations in the Northeast (Connecticut, Massachusetts, New Jersey, New York,

Pennsylvania), the upper Midwest (Minnesota and Wisconsin), and along the northern California

coast. It is caused by deer ticks and lone star ticks which have become infected with spirochetes.


Deer ticks may range in size from one-eighth inch in size up to one-quarter inch in size and can

be black or brick red in color. Lone star ticks are larger and chestnut brown in color.

RMSF has occurred in 36 states, with the heaviest concentrations in Oklahoma, North Carolina,

South Carolina, and Virginia. It is caused by Rocky Mountain wood ticks, and dog ticks which

have become infected with rickettsia. Both types of ticks are black in color.

Standard field gear (work boots, socks and light-colored coveralls) provides good protection

against tick bites, particularly if the joints are taped. However, even when wearing field gear, the

following precautions should be taken when working in areas that might be infested with ticks:

• When in the field, check yourself often for ticks, particularly on your lower legs and

areas covered with hair. Look for "a freckle that moves".

• Spray outer clothing, particularly your pant legs and socks, BUT NOT YOUR SKIN, with an insect repellent.

• When walking in wooded areas, avoid contact with bushes, tall grass, or brush as much as possible.

• If you suspect that a tick is present, remove it with tweezers only, and not with matches or a lit cigarette. Grasp the tick with the tweezers and pull gently. If it resists, cover the tick with salad oil for about 15 minutes to asphyxiate it, then remove it with tweezers. Do not use nail polish or any other type of chemical. Be sure and remove all parts of the tick's body. Once removed, disinfect the area with alcohol, or a similar antiseptic.

• Look for signs of the onset of Lyme disease, such as a rash that looks like a bulls-eye or an expanding red circle surrounding a light area on the skin, frequently with a small welt in the center. This rash can appear from several days to several weeks after the tick bite.

• Also look for signs of the onset of RMSF, an inflammation or rash comprising many red spots under the skin, which appears 3 to 10 days after the tick bite. The rash frequently occurs on the ankles and wrists.

The first symptoms of either disease are flu-like chills, headache, dizziness, fatigue, stiff neck,

and bone pain. If immediately treated by a physician, most individuals recover fully in a short

period of time. If not treated, more serious symptoms can occur.

If you believe you have been bitten by a tick, or if any of the signs and symptoms noted above

appears, contact the SSO. The SSO has the authority to authorize a physician visit for an

examination and possible treatment.


4.6.3 Snake Bites

There are poisonous snakes in Calhoun County, Alabama. If bitten by a snake, remain calm, keep

the affected area below the level of the heart and walk, do not run, to the nearest aid station for

assistance. The SSO will designate someone to immediately transport the victim to the closest

medical facility for treatment or send for appropriate medical assistance, whichever is faster. The

following precautions should be used when working in areas with snakes:

• Wear appropriate protective equipment (work boots, snake chaps).

• Be alert and aware of surroundings.

• Avoid walking in wooded areas and through bushes, tall grass or brush as much as possible.

4.6.4 Dogs

Sampling is to take place on residential property. In some instances residents may have dogs,

which may be unfriendly to samplers. The sampling team will not sample properties where dogs

are loose in the yard without the presence of the dog owner on-hand. In most cases, the samplers

should not proceed to conduct sampling unless the dog is restrained. Additionally, the sampling

team should be aware that wild or unleashed dogs might be present in the residential

neighborhoods. If such dogs are encountered, the sampling team should not approach or provoke

the animals. Mace may be used as a deterrent, if attacked.

4.6.5 Plants

The potential for contact with poisonous plants exists when performing fieldwork in Alabama.

Poison ivy, sumac, and oak may be present on site. Poison ivy can be found as vines on tree

trunks or as upright bushes. Poison ivy consists of three leaflets with notched edges. Two-

leaflets form a pair on opposite sides of the stalk, and the third leaflet stands by itself at the tip.

Poison ivy is red in the early spring and turns shiny green later in the spring. Poison sumac can

be present in the form of a flat-topped shrub or tree. It has fern-like leaves, which are velvety

dark green on top and pale underneath. The branches of immature trees have a velvety "down."

Poison sumac has white, "hairy" berry clusters. Contact with poison ivy, sumac or oak may lead

to a skin rash, characterized by reddened, itchy, blistering skin which needs first aid treatment.


Poison ivy barrier cream and cleanser will be used at the discretion of the SSO. Site workers will

apply the barrier cream prior to working in areas where exposure to the poisonous plants exists.

Subsequently, the cleanser will be used at the end of the work shift to remove oils, which remain

on the skin from exposure to the plants.


5.0 TRAINING REQUIREMENTS

5.1 Basic Training

Consistent with 29 CFR 1910.120, OSHA Hazardous Waste Operations, personnel performing

fieldwork associated with the NTC Removal Action activities must have received formal off-Site

hazardous waste training (with three days on-the-job training) prior to on-Site work. This

consists of 40 hours of initial training and 8 hours of annual refresher training for field staff.

Managers and supervisors must receive an additional 8 hours of specialized off-Site training

geared toward their supervisory responsibilities. Excluded from this responsibility are workers

who will not have the opportunity to contact Site hazards such as truck drivers. Personnel

responsible for field activities must be familiar with and have access to this Sampling HSP.

5.2 Pre-Work Briefing

A health and safety meeting will be conducted by the SSO prior to commencing field activities.

The meeting will address the following topics;

• contents of the approved Sampling HSP;

• discussion of work tasks and potential hazards;

• identification of evacuation routes and routes to the hospital;

• locations of site emergency equipment and supplies;

• discussion of personal protective equipment (PPE) requirements and action levels;

• review of the OSHA 101 form (Appendix C) to be filled out in the event of an injury or illness caused by work at the site; and

• reminder that unsafe work practices or conditions should be reported to the SSO.

The health and safety site-specific training described above will also be conducted for new

personnel assigned to the Site. Following the briefing, personnel will be required to signify that

they have read and understood the contents of this Sampling HSP by signing the Health and

Safety Plan Review Signature Form (Appendix D).

5.3 Daily Briefings

At the beginning of each day, the SSO (or designee) will review on-Site work activities and

outline Site conditions with respect to modifications of work plans and health and safety plans.

Personnel will be briefed and updated on any changes in safety procedures and sign a “Tailgate”

Safety Meeting Form found in Appendix E.


5.4 First Aid and CPR

The SSO will identify those individuals having First Aid and CPR training. At least one

individual in the sampling team will have current First Aid and CPR training. Training will be

consistent with the requirements of the American Red Cross.

5.5 Documentation

Documentation of training requirements is the responsibility of each employer. Written

documentation verifying compliance with 29 CFR 1910.120 must be submitted to the SSO.

Documentation of workers current training credentials (40-Hour Training, 8-Hour Refreshers, 8-

hour Supervisory Training, and medical respirator clearance) will be kept on-Site and submitted

to the Solutia representative on request. No one will be allowed to work on-Site without the

appropriate training and medical clearances.

5.6 Hazard Communication

In accordance with the OSHA Hazard Communication Standard (29 CFR 1910.1200 and 29 CFR

1926.59), copies of material safety data sheets (MSDS) for chemical materials brought on-Site

will be available in the field office or from the SSO. The MSDS training will be conducted by

the SSO in accordance with 29 CFR 1910.1200 and 29 CFR 1926.59 and the sampling

contractor’s hazard communication program. The training will be conducted in conjunction with

the pre-work briefing. Training will include, but may not be limited to all hazards or potential

hazards associated with any chemical materials on-Site. Appendix B contains the MSDSs for on-

Site Hazardous Materials.


6.0 SITE CONTROL

6.1 General

Site control measures will be implemented by members of the field sampling team to control

access and minimize the potential for the spread of impacted materials to non-impacted areas.

The work area will be divided into three different zones as determined by the HSC:

• The Exclusion (or Work) Zone: Consists of those areas, which are considered, affected or potentially affected by chemical constituents. Only the necessary number of workers with proper protective equipment will be allowed in this area.

• The Contamination Reduction Zone (CRZ): In this area personal decontamination procedures will be implemented.

• The Support (or Clean) Zone: This area will be used primarily for field command operations.

6.2 Daily Start Up

The following procedures will be followed prior to daily Site start up:

• The SSO (or designee) will review on-Site work activities with respect to modifications of the work plans and health and safety plans, and brief and update personnel;

• Safety and monitoring equipment will be checked for proper function; and

• The SSO will visually assess dust conditions in the work area.

Start-up activities shall be documented in the Site logbook.


7.0 AIR MONITORING

Air monitoring for volatile organic compounds (VOCs) is not anticipated during field sampling

activities because the chemicals listed in Table 1 are not volatile under normal outdoor

conditions. Air monitoring for particulates is not anticipated during field sampling activities

because the field activities do not create dusty conditions. However, the SSO will be responsible

for visually assessing for dust and will be responsible for recommendations to upgrade PPE

requirements.


8.0 WORK TASKS AND PERSONAL PROTECTIVE EQUIPMENT REQUIREMENTS

8.1 General

The level of protection required for each area of the sampling involving field activities will be

based on the recognized hazards of the chemicals of potential concern, most likely routes of

exposure (e.g., dermal, ingestion and possibly inhalation) and on observations for dust. The

purpose of PPE is to ensure that the individual is protected from the hazards encountered in the

course of the project. The elements involved in PPE include protective clothing, eye and face

protection, and respiratory protection that may be used by individuals involved in sampling field

activities.

8.2 Respiratory Protection Program

No respirators are currently anticipated to be required for this project. Personnel required to wear

a respirator must comply with the requirements outlined in this program. Personnel who will be

involved with sampling activities must first be cleared by the HSO. These personnel must also

have been trained in the selection, operation, and maintenance of air purifying respirators in

accordance with OSHA Standard 29 CFR 1910.134. Respiratory protection will be upgraded to

Level C at the judgment of the HSC and/or SSO. The NIOSH Respirator Decision Logic will be

used to determine appropriate respiratory protection.

Prior to using a respirator, personnel must be properly fit tested. The fit test will be conducted by

the HSC if proof of a previous fit test has not been documented within the last year. The fit test

will be performed using the appropriate challenge aerosol for the type of respirator selected (e.g.,

irritant smoke, isoamyl acetate (e.g., banana oil), or saccharin aerosol). Records of fit tests will

be maintained in project files and with the HSC.

Special lens holders, glasses, or both may be required for full-face respirators. Persons requiring

corrective lenses and a full-face respirator shall have a specific respirator fitted with the

corrective lens prescription prior to the initiation of field activities. Contact lenses shall not be

worn while performing fieldwork. Beards, long sideburns, and mustaches that interfere with the

proper fit of a respirator are prohibited.


A respirator will be assigned to each person who may have to use one during field activities. It is

the individual’s responsibility to properly operate and maintain the respirator. Personnel will be

responsible for cleaning, disinfecting, inspecting, and storing their respirator before and after each

use. Personnel will report any problems with respirators to the HSC.

8.3 PPE Protection Summary

A description of minimum requirements for Level C and Level D protection is summarized

below. When using Level C criteria, the buddy system must be used; at least two persons must

conduct the work. Planned field activities will be initiated at Level D protection. The HSC will

decide if an upgrade to Level C is necessary due to airborne dust. If PPE above Level C is

deemed necessary, then field activities will cease pending assessment by the SSO, HSC and HSO.

8.3.1 Level D Equipment

• boots with steel toes and shank;

• Neoprene or Nitrile chemical resistant outer gloves (optional);

• disposable latex inner gloves;

• boot covers (disposable - at the determination of the SSO);

• safety glasses (face shield and/or goggles when needed for chemical splash protection such as in the plant area);

• hard hat (optional - at the determination of the SSO, when required by Solutia or when over-head hazards exist);

• thermal/weather protection (coat, overalls, sweater, hat, rain gear, cool vest, heat stress monitors, optional - at the determination of the SSO or by personal choice);

• ear protection to be worn when working around drill rigs and other loud equipment; and

• long sleeve shirt (optional – at the determination of the SSO or when required by Solutia) and long pants.

8.3.2 Level C Equipment

• minimum half-face air purifying respirator (NIOSH approved) equipped with a compatible cartridge combination of HEPA filter for dust as determined by the SSO;

• Tyvek coveralls;

• safety boots with steel toe & shank;

• Nitrile or Neoprene chemical resistant outer gloves (optional);


• disposable latex inner gloves;

• boot covers (optiona l - at the determination of the SSO);

• hard hat (optional - at the determination of the SSO or when required by Solutia);

• face shield and/or goggles when needed for chemical splash protection (optional - at the determination of the SSO);

• thermal/weather protection (optional - at the determination of the SSO);

• ear protection to be worn when working around drill rigs and other loud equipment; and

• long sleeve shirt and long pants.

A summary of PPE requirements for the project specific tasks is provided in Table 3.

Modifications in the personal protective equipment requirements outlined in this document may

be necessary as new conditions and/or tasks warrant. Addenda and revisions to this HSP will be

made only by the SSO, the HSC or the HSO, and shall be documented using the

Addendum/Revision Record found in Appendix A.


9.0 DECONTAMINATION PROCEDURES

9.1 General

Decontamination procedures reduce the potential for transport of chemicals of concern outside of

the work area. Decontamination procedures also protect workers from potential exposure that

may occur during removal of personal protective equipment. It is important that decontamination

is handled in an organized, step-wise manner. If decontamination is conducted improperly,

inhalation or dermal contact with constituents of concern may occur.

Decontamination consists of thoroughly decontaminating reusable PPE and general equipment,

and washing face and hands before leaving the Site. Disposal of wastes generated from

decontamination procedures will be the responsibility of Solutia.

9.2 Contamination Prevention

The prevention of contamination is the first step towards providing a clean and safe work place.

Contamination prevention should minimize worker exposure and help ensure valid sample results

by precluding cross-contamination. Procedures for contamination avoidance include:

Personnel

• Do not walk through areas of obvious or known contamination; walking through puddles or mud, and kneeling on the ground shall be avoided.

• Make sure personal protective equipment has no cuts or tears prior to wearing.

• Fasten closures on suits.

• Particular care should be taken to protect any skin injuries.

• Stay upwind of dust.

Equipment and Samples

• Monitoring equipment shall not be placed on potentially contaminated surfaces.

• Limit the amount of contamination that comes in contact with heavy equipment and vehicles.

• If contaminated tools are to be placed on non-contaminated equipment/vehicles for transport to the decontamination area, use plastic wrap or sheeting to keep the equipment clean.


9.3 Decontamination Equipment

The following materials will be available for decontamination as needed:

• galvanized wash tub;

• tap water;

• plastic sheeting;

• alkaline soap solution (Alconox, or other heavy-duty detergent);

• long handle scrub brushes;

• disposable plastic to cover the station area;

• disinfectant wipes to clean inside of respirator; and

• distilled water in a squeeze bottle for rinsing.

9.4 Personnel Decontamination

Diagrams of general work areas and outlines for Level C and Level D decontamination are

presented on Figures 1 through 3. The following minimum procedures for Level C

decontamination will be followed prior to leaving the work area:

Exiting Exclusion Zone

Equipment drop 1. Upon exiting the exclusion or work zone, workers will deposit their equipment on a plastic drop cloth in the designated area. Soil and sediment sampling equipment will be wiped clean with a damp cloth, as required. During hot weather, a cool-down station may be set up in this area.

Contamination Reduction Zone

Outer Garment, Boots, and Gloves Wash and Rinse

2. Workers will scrub outer boots, outer gloves, and coveralls with a long handled brush and soap and water. Workers will then rinse with plenty of water.

Outer Boot and Glove Removal 3. Once completed with rinsing, workers will remove outer gloves and outer boots and discard them.

Air Purifying Respirator 4. Workers will receive a new respirator cartridge (or mask), outer gloves, and outer boots for return to the work/exclusion zone.

Outer Garment Removal 5. If workers are not returning to the work/exclusion zone, they will remove their coveralls and deposit them in separate containers.


Respirator Removal 6. Once coveralls are deposited, respirators may be removed. Respirators will be washed in soap solution and rinsed in water. The inside of the respirators will be cleaned with an alcohol wipe. Inner gloves will be removed and discarded.

Support Zone

Field Wash 7. Thoroughly wash hands and face. Shower as soon as possible.

During this procedure, methods for properly disposing of contaminated personal protective

clothing or equipment must be followed to reduce the possibility of contacting potentially

contaminated media. Decontaminated PPE and trash will be placed in DOT-approved drums or

roll-offs for disposal.

9.5 Equipment Decontamination

9.5.1 Respiratory Protective Equipment

When respiratory protective equipment is required, there is a high potential for these units to

become contaminated. At the end of each workday, respirators will be thoroughly

decontaminated. During decontamination, this equipment will be properly disassembled

(according to manufacturer specifications), washed with soap and water, rinsed in water, cleaned

with an alcohol wipe and allowed to dry before reassembly. Disassembly and reassembly shall be

performed by personnel trained in this task.

9.5.2 Drilling and Sampling Equipment

At the discretion of the SSO, decontamination procedures may be used on a daily basis to address

potential contamination or equipment that will move between clean and contaminated areas

without leaving the work area. Brushes and other similar tools will be used to manually remove

gross materials from tires, tracks, and other portions of the equipment.

A steam cleaner may be used to decontaminate equipment at the completion of the project and for

any equipment leaving the Site from a contaminated work area. Personnel should exercise caution

when using a steam cleaner. The high-pressure steam can cause severe burns. Protective gloves,

safety glasses with side shields or face shield, hard hats, steel-toed boots, and Tyvek suit or rain

gear will be worn when using the steam cleaners. Small equipment will be decontaminated as per


procedures referenced in Section 9.5.1. Water from the decontamination process will be captured

for appropriate disposal.


10.0 EMERGENCY RESPONSE PROCEDURES

10.1 General

The following procedures should be implemented in the event of an emergency. The SSO will

act as the field sampling Emergency Coordinator. The SSO is responsible for investigating

emergency situations arising from the sampling work and has the authority to modify or stop

sampling activities in order to reduce potential hazards until the hazards have been identified and

corrective actions taken. If the emergency situation requires fire, police, or medical personnel,

the telephone numbers listed in Table 4 should be used to contact the appropriate emergency

personnel.

10.2 Emergency Notifications

Telephone numbers for fire department, ambulance, police, and medical facilities are listed in

Table 4. In the event of an emergency, the EPA RPM, Solutia Project Manager, and Sampling

Team Leader should also be notified as soon as possible.

10.3 Evacuation Routes

In the event of an emergency, evacuation routes must be followed by Site personnel. Figure 4

identifies the location of the hospital. During an evacuation, the HSC will be responsible for

conducting a head count to ensure that sampling personnel have safely exited the Site.

10.4 Emergency Equipment and First Aid Requirements

10.4.1 Emergency Equipment and First Aid Supplies

A fully equipped first aid kit will be maintained at the Site. The kit will contain a minimum of

two pairs of latex gloves to be worn by first aid providers, and a CPR barrier mask to be used

during CPR. Portable eye wash containers, filled with sterile rinse solutions, will be located in

each field-sampling vehicle.

10.4.2 Fire Extinguishers

A portable fire extinguisher with combination Class ABC rating will be maintained on each drill

rig.


11.0 MEDICAL SURVEILLANCE PROGRAM

A medical surveillance program will be in compliance with 29 CFR 1910.120 and implemented

for field personnel. This medical program assures that personnel are physically able to perform

the assigned work. The program also monitors the personnel’s health and provides medical care

for occupational injury or illness. Contractors and subcontractors shall certify that their own

personnel are medically fit for the intended work.

Specialized blood chemistry programs are not required unless exposure to a particular chemical

of concern is suspected. Should this situation occur, the site HSO should be consulted. The HSO

and HSC will make a determination of any requirement for special monitoring.


12.0 RECORD KEEPING AND REPORTS

12.1 General Record Keeping

The SSO will maintain logs covering the implementation of the sampling activities. Copies of

logs and reports will be kept by the SSO. Medical clearance records of field personnel will be

maintained by the SSO. Certification of employee training and field experience will also be

maintained by the SSO. Copies of respirator fit test records will be kept at the Site and/or in

personnel medical files.

Sampling personnel will be required to read and understand this Sampling HSP. Signed

statements will be maintained at the Site.

12.2 Training Records

Training records will be prepared by the SSO for personnel involved in field activities. At a

minimum, these records will include:

• employee’s name;

• verification of pre-work physical examination (e.g., medical clearance);

• Sampling HSP training verification (Pre-Work Briefing);

• “tailgate” safety meeting roster with topics;

• MSDS training verification; and

• respirator fit test records.

12.3 Daily Field Information

The daily field information will be noted on the Field Sampling Logs and/or the Daily Summary

Logs by the SSO or their designee. The information will contain:

• date;

• area (site-specific) checked;

• personnel in specific area;

• equipment being utilized by personnel;

• PPE being used by site personnel in sampling work areas; and

• PPE maintenance records.


The HSC and/or SSO will note items that pose potential health and safety risks or inconsistencies

with the Sampling HSP, and the actions taken to address the situation.

A separate sign-in log will be maintained for visitors to the Site and will include name, date, time

in-out, company name, and signature. Visitors to Site areas other than the support zone require

training and medical monitoring consistent with 29 CFR 1910.120.

12.4 Accident Reporting

Field personnel shall report any job-related accident or injury immedia tely to the SSO or

Sampling Team Leader. Upon receiving appropriate medical attention, an accident report will be

filled out by the SSO and injured employee using an OSHA Form 101 (Appendix C).

Photographs shall be taken of the accident location if it involved an identifiable physical hazard

(e.g., fall hazard, unguarded machinery, etc.). One copy of this report will go to the field

log/files, and one copy will go to the HSO with distribution to the Solutia Project Manager. This

report will be filed and forwarded within 24 hours.

12.5 Project Completion Activities

At the completion of sampling, the SSO will provide documentation of the project Sampling HSP

implementation, including the following:

1. The SSO will provide decontamination records for equipment to be removed from the Site at the completion of this phase of activities. These records will be maintained in the permanent project file.

2. The medical records for any personnel involved in a work-related accident or illness will be updated by the SSO. These updates will be sent for inclusion in the personnel medical files. Exposure and medical monitoring records will be maintained as per 29 CFR 1910.120.

3. An OSHA 300 log will be kept for recording lost workdays, restricted duties, and OSHA-recordable injuries or fatalities. The log will be prepared by the SSO and kept on Site until completion of the sampling. At that time, it will be forwarded to the sampling contractor’s office to be retained for five years.

4. If no work-related accidents or illnesses occurred during sampling, a statement to this effect will be placed in the file.


13.0 REFERENCES Code of Federal Regulations, Title 29, Part 1910, Subsections 120, 134 and 1200. Agency for Toxic Substances and Disease Registry (ATSDR). Toxicological profile for (certain

chemicals). American Conference of Government Industrial Hygienists (ACGIH), “Threshold Limit Values

for Chemical Substances and Physical Agents and Biological Exposure Indices”, 2002 and TLV Documentation Guide.

National Institute of Occupational Health and Safety (NIOSH), “Pocket Guide to Chemical

Hazards”, Latest Edition. NIOSH/OSHA/USCG/EPA “Occupational Safety and Health Guidance Manual for Hazardous

Waste Site Activities,” 1985. NIOSH, “NIOSH Respirator Decision Logic,” May 1987. United States Environmental Protection Agency, 2002. Partial Consent Decree, United States of

America v. Pharmacia Corporation (p/k/a/Monsanto Company) and Solutia Inc. Civil Action No. CV-02-PT-0749-E. October 2002. Effective date August 4, 2003.

TABLES


TABLE 1

REGULATORY AND RECOMMENDED EXPOSURE LIMITS

FOR SELECTED CHEMICALS FOR THE INDIVIDUAL PROPERTIES

Compound OSHA

PEL

ACGIH TLV

STEL

Chlorinated Biphenyls (42% chlorine)

1 mg/m3 (skin) 1 mg/m3 (skin) --

Chlorinated Biphenyls (54% chlorine)

0.5 mg/m3 (skin) 0.5 mg/m3 (skin) --

Lead 0.05 mg/m3 0.05 mg/m3 -- ACGIH TLV - American Conference of Governmental Industrial Hygienists’ Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices 2002 PEL - Permissible Exposure Limit STEL - Short Term Exposure Limit -- - No value established.


TABLE 2

HEAT STRESS: BASIS FOR WORK SCHEDULE

FREQUENCY OF MEASUREMENT

AMBIENT TEMPERATURE (°F)

NORMAL WORK

CLOTHING1

IMPERMEABLE WORK

CLOTHING

70° – 80°

N/A

90 MIN

80° -85°

120 MIN

60 MIN

85° -90°

90 MIN

30 MIN

> 90°

60 MIN

15 MIN

1Normal work clothing is cotton coveralls, or other cotton clothing with long sleeves and pants.


TABLE 3

NTC REMOVAL ACTION SAMPLING PPE REQUIREMENTS

Task Respiratory Clothing Gloves Boots Other *

Soil Sampling NA Level D L, N (optional)

B SG (HH/HP with

drill rig) Decontamination NA Level D L, N

(optional) B SG

Borehole Backfilling

NA Level D L, N (optional)

B SG

NOTES:

B = Steel-toe work boots C = Cotton overalls F = Steel-toe fireman’s boots HH = Hard hat HP = Hearing Protection L = Latex N = Nitrile NA = Not Anticipated S = Surgical SG = Safety glasses T = Tyvek W = Work Gloves * = Depending on Area


TABLE 4

EMERGENCY PHONE NUMBERS – ANNISTON PCB SITE

Emergency Services Telephone Numbers

Police 911

Fire 911

Hospital 256-236-2210

Poison Control 911

Solutia Inc. personnel to be notified in case of emergency:

Craig Branchfield 256-231-8404

EPA personnel to be notified in case of emergency:

Pam Scully 404-562-4300

FIGURES

CHECKEDDRAWN REVIEWED DATE SCALE FILE NO. JOB NO. DWG NO./REV NO. FIGURE

TITLECLIENT/PROJECT

Atlanta, Georgia

SDP September 2003 N/A 943-3680.CER HASP.cdr

Anniston PCB SiteNTC Removal Action Supplemental Sampling


1

General Work Area

Hot Line

ContaminationControl Line

WIND DIRECTION

Command Post

SUPPORT ZONE

CONTAMINATIONREDUCTION ZONE

EXCLUSION ZONE

CONTAMINATIONAREA

AccesControlPoints

CONTAMINATIONREDUCTIONCORRIDOR

The size of each work zone will depend onsite specific conditions; e.g., extent ofcontamination, drilling requirements, etc.

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GM

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TITLECLIENT/PROJECT

Atlanta, Georgia

SDP N/A 943-3680048 HASP.cdr 2

Outline for Level C Decontamination

SegregatedEquipment Drop

Outer Garment,Boots, and GlovesWash and Rinse

Boots, Gloves,and Outer GarmentRemoval

RespiratoryProtectionRemoval

Field Wash

Outer Boot andGlove Removal

CartridgeChange

Hot Line


EXCLUSION ZONE


SUPPORT ZONE

MinimumDecontamination Layout

LEVEL CPROTECTION

The decontamination corridoris approximately 5 ft by 10 ft.

September 2003



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GM

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TITLECLIENT/PROJECT

Atlanta, Georgia

SDP N/A 943-3680.CER HASP.cdrSeptember 2003



3

Outline for Level D Decontamination

SegregatedEquipment Drop

Outer Garment,Boots, and GlovesWash and Rinse

Boots, Gloves,and Outer GarmentRemoval

Field Wash

Hot Line


EXCLUSION ZONE


SUPPORT ZONE

MinimumDecontamination Layout

LEVEL DPROTECTION

The decontamination corridoris approximately 5 ft by 10 ft.

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APPENDIX A

Health and Safety Plan Addendum/Revision Form

HEALTH AND SAFETY PLAN ADDENDUM/REVISION Date:____________________________________________________________________

Site Designation/Location:____________________________________________________

Subject:__________________________________________________________________

Addendum: _______________________________________________________________

Affected Health and Safety Plan Section: _________________________________________

Revision: ________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

Requested by: Signature: ____________________________________________________

Printed Name:_________________________________________________

Title:________________________________________________________

Effective Date: ____________________________________________________________

Approved By: Signature: ____________________________________________________

Printed Name:_________________________________________________

Title:________________________________________________________

CONCURRENCE (by Project Manager and Health and Safety Officer or Health and Safety

Coordinator):

Effective Date: ____________________________________________________________

Approved By: Signature: ____________________________________________________

Printed Name:_________________________________________________

Title:________________________________________________________

NOTES/REMARKS:

________________________________________________________________________

________________________________________________________________________

APPENDIX B

Toxicological Data for Selected Chemicals

APPENDIX C

OSHA 101 Form for Occupational Injuries and Illnesses

APPENDIX D

Health and Safety Plan Signature Form

HEALTH AND SAFETY PLAN SIGNATURE FORM Each field team member shall sign this section after site-specific training is completed and before

being permitted to work on site.

I have read, understand and agree to comply with the provisions of the above-referenced

Supplemental Sampling Health and Safety Plan for work activities at this Site.

Date:____________________________________________________________________

Trainer’s Printed Name:______________________________________________________

Trainer’s Signature:_________________________________________________________

Trainer’s Title: ____________________________________________________________

Name Printed Signature Date

APPENDIX E

"Tailgate" Safety Meeting Form

“TAILGATE” SAFETY MEETING FORM The following personnel were present at the “tailgate” (daily pre-job) safety briefing

conducted at (time):___________________________________________________

on (date): __________________________________________________________

at (location): ________________________________________________________

by (printed name):__________________________________________________

(signature):_____________________________________________________

(title): ________________________________________________________

and have read the above plan, are familiar with its provisions and the following discussed topics:

________________________________________________________________________

________________________________________________________________________

Name Printed Signature Date