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HEALTH & SAFETY PLANWORK PLAN APPENDIX II DOCUMENT III
TEST TRENCH EXCAVATIONPUROLATOR PRODUCTS COMPANY RI
ERM- Northeast
1301036
HEALTH & SAFETY PLANWORK PLAN APPENDIX II DOCUMENT III
TEST TRENCH EXCAVATIONPUROLATOR PRODUCTS COMPANY RI
AUGUST 27, 1991
PREPARED FOR:
PUROLATOR PRODUCTS COMPANYMOTOR COMPONENTS DIVISION
P.O. BOX 1502ELMIRA, NEW YORK 14902-1502
PREPARED BY:
ERM-NORTHEAST6700 KIRKVILLE ROAD
EAST SYRACUSE, NY 13057
OJ
ERM- NortheastTABLE OF CONTENTS
Section No. Page No.
I.0 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1- 1
2.0 Test Trench Excavation and Sampling Procedures . . . . . . . . . . . . . . . . . . . . . 2 - 12.1 Trench Excavation and Entry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 - 2
2.1.1 Excavation Stabilization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 - 32.1.2 Excavation Entry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 - 5
2.2 Container Handling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 - 72.2.1 Container Handling Mechanics . . . . . . . . . . . . . . . . . . . . . . . . 2 - 92.2.2 Opening of Containers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 - 92.2.3 Container Sampling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 - 1 1
2.3 Soil Sampling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 -13
3.0 Project Personnel Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 - 1
4.0 Personnel Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 - 1
5.0 Medical Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 - 1
6.0 Health and Safety Hazards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 - 1
7.0 Site Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 - 1
8.0 Action Levels/Protective Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 - 18.1 Respiratory Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 - 18.2 Contact Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 - 3
9.0 Decontamination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 - 19.1 Site Operation Areas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 - 19.2 Decontamination Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 - 2
10.0 Site Access and Site Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 - 1
II.0 Emergency Response . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 - 1
12.0 Incident Reporting Procedure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 - 1
13.0 Special Precautions and Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 - 1
ERM-northeastLIST OF FIGURES
Figure No. Page No.
1 - 1 Investigative Areas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-2
2 - 1 Confined Space Entry/Work Permit . . . . . . . . . . . . . . . . . . . . . . . . . 2-4
2 - 2 Container Handling Decision Process . . . . . . . . . . . . . . . . . . . . . . . . 2-8
9 - 1 Decontamination Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 - 5
LIST OF EXHIBITS
Exhibit No. Page No.
12 - 1 Incident Report Form . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 -2
LIST OF TABLES
Table No. Page No.
4 - 1 Subcontractor Occupational Safety and Health Certificate . . . . . . . . . 4-3
6 - 1 Potential Site Compounds and AssociatedExposure Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-3
6 - 2 Health and Safety Hazards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-5
8 - 1 Personnel Protective Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-4
ATTACHMENTS
ATTACHMENT 1: Body MechanicsATTACHMENT 2: Emergency Procedures
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1.0 INTRODUCTION
This Health and Safety Plan (HASP) has been developed for the test trench excavationportion of the Remedial Investigation (RI) and is designated Document ffl of Addendumn of the 1990 RI Work Plan submission. This HASP provides recommended health andsafety procedures for those employees participating in the associated field operations. Theprocedures set forth in this plan are designed to reduce the risk of exposure to chemicalsubstances that may be present in the soil, containers, and air and to other hazardsassociated with any activities conducted during the test trench excavation procedure. Theprocedures set forth herein are developed in accordance with the provisions of 29 CFR1910.120 (Hazardous Waste Operations and Emergency Response), OSHA 29 CFR1926.650-652 (Excavations) the EPA document, "Standard Operating Safety Guides," andERM experience in similar field operations.
The procedures in this plan have been developed for use during those on-site activitiesinvolving ERM personnel. ERM shall be solely responsible for compliance with theprovisions of this Health and Safety Plan by ERM employees and subcontractors of ERMonly. The recommended health and safety guidelines set forth within this document maybe modified as further information is made available through sample analysis and on-sitecharacterization.
The 1990 Remedial Investigation identified several areas at the Purolator Facility thatmay contain buried metal debris. These areas were identified as magnetic anomalies duringthe magnetometer geophysical survey. Some of these areas may contain buried containers.The three areas suspected to contain buried containers are shown on Figure 1-1. In orderto identify the material burjed in these areas, test trench excavations will be conducted.This HASP presents the specific health and safety protocols to be followed during the trenchexcavation container handling, and soil and waste sampling procedures.
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LEGEND
18th Street
GRID AREA LOCATION
TEST TRENCH EXCAVATION AREAS
TEST TRENCH EXCAVATIONS AREAS V2&3
PUROLATOR PRODUCTS COMPANY
ELMIRA. NEW YORK
PUROLATOR PRODUCTS COMPANY
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Anticipated field activities include:
• excavating six test trenches in Areas 3 and three trenches in Area 1;• perform shallow excavation in Area 4;• logging materials encountered in the test trenches;• removing any buried containers (drums, etc.) from the excavations;• securing and staging containers and sampling contents (if any); and• soil sampling as required to characterize soils underlying containers.
Section 2.0 of this document briefly describes the site setting and the work to beperformed under the provisions of the HASP. This subject is presented in more detail inthe project Field Sampling Plan (Document 1 of this submittal). The remainder of theHASP presents the health and safety protocols to be followed during the implementationof the Work Plan, the specific responsibilities of project team members entering the site,and the project contingency plan to be followed in case of emergency.
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2.0 TEST TRENCH EXCAVATION AND SAMPLING PROCEDURES
The results of the magnetometer survey conducted during the 1990 RemedialInvestigation indicated possible buried metal in several areas. Buried metal containers maybe present in one or more of the suspect areas. A test trench excavation program will beconducted to determine the presence of buried containers in the three areas as discussedin the FSP (Document I of this Work Plan). The following tasks will be performed in eachof these areas (detailed descriptions of field work protocol is presented in the FSP):
• Trenches will be dug with an excavator at strategically placed intervals untilnatural material or metal debris is encountered.
• If a container is encountered, excavation will cease and the container will bephysically uncovered and inspected.
• If the container is in good condition or empty, it will be removed with theexcavator and placed in a temporary staging area.
• If the container is in poor condition and not empty, it will be overpacked in thetrench and then placed in the temporary staging area.
• If fluid is present in a container, efforts will be made to eliminate the potentialfor spillage; these efforts may include absorbing small amounts of fluid withpads or "speedy - dry" or pumping fluids into a new sound container.
Representative samples will be obtained from the containers. ^o
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• When all containers are removed, soil samples will be obtained from beneaththe former container locations.
• The trench or excavation will be backfilled after completion of all the abovetasks.
As described in Section 7.0, ambient air monitoring will be performed continuouslyduring all excavation and sampling activities.
2.1 Trench Excavation and Entry
Nine test trenches will be excavated; six in Area 3 and three in Area 1. Additionally,some shallow digging will be conducted in Area 4 (Area 4 excavation depth will not exceedfive feet). Before excavation, ERM will determine if there are any underground utilities inthe area. If there are, they will be located and protected. Sufficient clearance will also bemaintained for any overhead utilities.
Test trench activities will include excavation, trench inspection logging, soil samplingand trench backfilling. Trenching will continue horizontally and vertically until materialsunaffected by past waste disposal are encountered. Excavation depths are not expected toexceed 12 feet.
Every effort will be made to avoid the need for personnel to enter a test excavation.However, if sampling and drum handling requirements necessitate the need to enter andexcavation more than five feet deep, appropriate safety precautions in accordance withOSHA 29 CFR 1926.650-652 (excavations) and Standard Practices for Confined Space Entry ^(ASTM D4276-84) will be used. *
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Test pits and excavation greater than five feet deep will be considered confined spacesand will not be entered unless absolutely necessary. However, if entry is required, thefollowing precautions will be implemented:
• the need for trench entry will be evaluated;
• excavation stability will be assured (see Section 2.1.1);
• initial atmospheric testing will be performed by the site safety officer (SSO);
• upon complete evaluation of the space to be entered, the SSO will issue apermit for confined space entry (see Figure 2-1);
• if entry is required for any reason besides short duration sampling, continuousair monitoring will be performed to assure proper respiratory protection (thiswill not be required if Level B protection is utilized).
2.1.1 Excavation Stabilization
If a worker must enter a trench over five feet deep, the excavation faces will beguarded by a shoring system, sloping of the ground, or some other equivalent means,for example, trench boxes (movable enclosures for workers) or trench shields (movableshoring systems). Trenches less than five feet deep where a hazardous groundmovement may occur will also require protection. Since the area where containers areburied has been previously excavated and/or has been covered with
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FIGURE 2-1
CONFINED SPACE. ENTRY/WORK PERMIT
Permit Date: _________ Time: ______ to ____
Location: __________________________.___________
Work to be performed:
Permit granted to: _
Permit granted by: _
PrecautionsNot
Performed Required
Purging _______ _______Ventilation _______ _______Isolation ________ _______Disconnection ________ _______Lockout ________ _______Tagout ________ _______
Air Testing
OxygenLELVapors(specify]
Test Measured Continuous MonitoringPerformed Level Required Not Required
Personnel Protective Equipment
Specify:
Rescue
Standby Person:
Equipment:
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loose soil, the soil has been disturbed and must be considered unstable. Therefore,care will be taken to inspect each trench before entry and stabilize the trench isaccordance applicable OSHA regulations or presented in Section 3.2 and AppendixA of the FSP.
Tools, equipment, and excavated material will be kept two feet or more from theedge of the trench to prevent their falling into or damaging the trench.
ERM will make daily inspections of trenches and excavations to ensure there areadequate slopes, shoring, and bracing and to check for evidence of possible slides orcave-ins. More frequent inspections may be necessary as work progresses or after rainor snowfall.
2.12 Excavation Entry
Absolutely no trench entry without use of appropriate supplied-air respirators anddermal protection is to be initiated until appropriate initial testing has been conductedto assure the atmosphere is safe. Monitoring shall be conducted for oxygen content,combustible gases/vapors, toxic contaminants, and any other tests specified by theSSO. Entry into the trench shall not be permitted without use of appropriate supplied-air respirators under the following conditions:
• Oxygen concentrations less than 19.5% or greater than 23.5%.
• Flammability measurements greater than 8% of the lower explosive limits(LEL). , >
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• Toxicity measurements indicating an IDLH atmosphere's existence in thetrench.
Initial atmospheric samples shall be drawn while outside the trench at least at thefollowing locations:
• outside the entry point;• immediately inside the entry point;• at least every four feet in depth to the excavation floor.
All initial monitoring results will be recorded on the entry permit.
The entry permit will specify the level of protection to be used for the trench entry.When the nature of the air contamination present is unknown, supplied-air respiratorprotection will be required.
Additional safety equipment in the form of safety belts, body harness, or wrist typeharnesses with life lines shall be provided and used for all entries. Lifelines shall beattached to extraction devices outside the trench so that non-entry rescues may beeffected. Standby personnel shall be equipped with at least the same level ofprotection as the entry team as well as supplied respirators suitable for IDLHatmospheres.
As part of the pre-entry procedure, the SSO shall review the entry permit with allmembers of entry team and standby team personnel and shall be present during theoperation. He will maintain communications and have ready access to emergency andsupport services and facilities.
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i2.2 Container Handling
i' If buried containers (i.e., drums) are encountered during trenching activities, these
containers will be removed, sampled and staged on-site in accordance with the decisionprocess shown on Figure 2-2. Any soil removed in order to access buried containers will bestockpiled or placed in "roll-off containers according to procedures described in Section 3.0.
Once a container is exposed, the following procedures will be performed anddocumented by ERM personnel in the project field log book:
• Describe drum type (steel, plastic, bunged, open-top, etc.);• Describe the condition of container including corrosion, leaks bulging, etc.;• Identify markings such as tags and/or labels;• Determine the physical nature of any drum contents, if possible;• Describe the soils surrounding the container; and• Monitor the air around the container for VOCs.
This evaluation will be performed before moving the drum whenever practical.
A decision will then be made as to the need to move the container to the temporaryor permanent staging area for logging and sampling or implement other drum handlingprocedures. In general, if the drum is sound and there is no threat of spillage, the drum willbe moved to the staging area.
If the potential for spillage or breakage exists, the drum may be overpacked in place.Pumping of fluids from the drum (if present) may also be necessary. Drum handling 5procedures are described in detail in Section 4.0 of the FSP and are summarized on Figure o2-2. °
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FIGURE 2-2CONTAINER HANDLING DECISION PROCESS
• EXPOSE CONTAINER'LOCK .̂ OR LABELS & IDENTIFYING FEATURES
•PHOTOGRAPH & DESCRIBE•ARE THERE LIQUID OR SOLID CON'ENTS?
YESf
•MONI~OR CONTENTS-OR VOCs
•DETERMINE RISK OFS= —AGE. BREAKAGEOR C~r£R RELEASES
NO
•REMOVE ic S'OCKPILECONTAINER
IN "ROLLOFF"
1• -ABE. TOP If SIDE
OF CONTAINER• SAMPLE CONTNTS
• OVERPACK IN TRENCH• LASEI. -OP & SIDE
OF OVtRPACX•REMOVE TO STAGING AREA
VE FROM EXCAVATIONTO THE EZ
DtTSMINE IF CONTAINERSrOLO BE OVERPACKED NO
•SAMPLE CONTENTS• LABEL TOP ic SIDE
OF CONTAINER••REMOVE TOSTAGING AREA
-YES• LABEL TOP It SIDE
Of CONTAINER• SAMPLE CONTENTS
• OVERPACK IN THE EZ• LABEL TOP k SOE
OF OVERPACK••REMOVE TO STAGING AREA
*NOTE: REMOVE CONTAINER WITH BACKHOE BUCKET,SUNG AND/OR OTHER APPROPRIATE HANDLING
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22.1 Container Handling Mechanrcs
The container handling procedures described above will require some degree ofmanual drum handling as well as movement of drums with equipment. Manualhandling of drums and other heavy objects will be performed according to proper bodymechanics procedures to reduce the potential for injury (see HASP Attachment 1).Drums and other containers will be handled with the excavator. Drums will be movedin the CRZ using a rubber - tired backhoe. Both pieces of equipment will beappropriately sized to handle these loads. ERM's field operations coordinator willverify equipment load capabilities.
2.2.2 Opening of Containers
Generally, containers will be moved to the staging area for opening and sampling.However, site conditions may require a separate container opening area. Proceduresfor opening containers are the same, regardless of where the containers are opened.To enhance the efficiency and safety of container-opening personnel, the followingprocedures will be considered:
• Supplied-air respiratory protection systems via airlines and escape Self-Contained Breathing Apparatus (SCBAs) will be used to enable workers tooperate in relative comfort for extended periods of time if the action levelsdiscussed in Section 8.1 of this Health and Safety Plan (HASP) requiresupplied air.
• Personnel will remain a safe distance from the containers being opened.Explosion-resisfant plastic shields between personnel and container-openingequipment will be utilized if personnel must be located near drums.
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• The breathing space of on-site personnel will be monitored continuously withan OVA during container opening. Sensors of monitoring equipment will beplaced as close as possible to the container opening.
• One or more of the following devices will be used for opening containers:
- Hand-held, bronze, non-sparking bung wrench;
- pneumatically operated impact wrench to remove container bungs;
- hydrauiically or pneumatically operated container piercers; or
- backhoes equipped with bronze spikes for penetrating container tops inlarge-scale operations.
• Picks or chisels will not be used to open containers.
• Container opening equipment will be hung or balanced to minimize workerexertion.
• All steps will be performed slowly if the container shows signs of swelling orbulging. Excess pressure will be relieved prior to opening and, if possible, froma remote location, using such devices as a pneumatic impact wrench orhydraulic penetration device. If pressure must be relieved manually, a barriersuch as explosion-resistant plastic sheeting will be placed between the workerand bung to deflect any gas, liquid or solids which may be expelled as the bung 5is loosened.
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• Exotic metal containers and polyethylene or polyvinyl chloride-lined (PVClined) containers will be opened through the bung by removal or drilling.Extreme caution will be exercised when manipulating these containers.
• Open bungs and drill openings will be resealed as soon as possible with newbungs or plugs to avoid explosions and/or vapor generation. Container will beplaced into an overpack if an open container cannot be resealed. Openingsin pressurized containers will be plugged with pressure-venting caps set to a 5-psi (pounds per square inch) release to allow venting of vapor pressure.
• Equipment will be decontaminated after each use to avoid mixing incompatiblewastes.
2.2.3 Container Sampling
Before collecting any sample, ERM's Field team will develop a site-specific samplingstrategy which includes the following considerations:
• Research background information about the wastes.
• Determine which containers should be sampled.
• Select the appropriate sampling device (s) and container (s).
• Develop a site-specific sampling strategy which includes the number, volumeand locations of samples to be taken.
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• Develop Standard Operating Procedures for opening containers, sampling, andsample packaging and transportation.
• Have a trained health and safety professional determine, based on availableinformation about the wastes and site conditions, the appropriate personalprotection to be used during sampling, decontamination, and packaging of thesample. The selection of respiratory and dermal protection required will bebased on air monitoring and initial characterization of materials being sampled.At a minimum, modified Level D protection including tyvek coveralls,protective gloves and boots, chemical-resistant aprons, and safety goggles willbe worn during container opening and sampling.
When manually sampling from a container, ERM will use the following techniques:
• Keep sampling personnel at a safe distance while containers are being opened.Sample only after opening operations are complete.
• Do not lean over other containers to reach the container being sampled, unlessabsolutely necessary.
• Cover container tops with plastic sheeting or other suitable uncontam-inated materials to avoid excessive contact with the container tops.
• Never stand on containers. Use mobile steps or another platform to reach theheight necessary to safely sample from the containers.
* l~*%• Obtain samples with either glass rods or vacuum pumps. Vacuum pumps will >
not be used for collection of samples to be submitted for VOC analysis. UseoM
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dedicated samplers to obtain each sampler or decontaminate sampling toolsbetween uses.
2.3 Soil Sampling
As described in Section 5.1 and 5.2 of the FSP, samples will be collected of soilsdirectly underlying any removed drums or containers. These soil samples will be collectedto determine the effects, if any, that drum burial has had on underlying soils. Soil sampleswill be collected manually in open excavations less than five feet deep. If the excavationarea meets the definition of a "confined space", samples will be collected using the bucketof the excavator or other remote techniques. If trench entry is required, the precautionspresented in Section 2.1.2 will be followed.
Soil samples will be collected using a stainless steel hand auger or trowel. A handauger will be used at accessible locations. If the sample is collected from soil obtained withthe excavator, the sample will be collected from the center of the bucket contents at alocation that has not come in contact with the bucket. In either case, proper dermal andrespiratory protection will be used during sample collection. All sampling tools will beproperly decontaminated between uses (see QAPP Section 4.1).
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3.0 PROJECT PERSONNEL RESPONSIBILITIES
All tasks related to the trench excavation procedures will be performed by ERMemployees and subcontractors experienced in this type of investigation. It is theresponsibility of all project personnel to be aware of the potential health and safety hazardsat the site. Furthermore, key project personnel will be assigned specific health and safetyresponsibilities as follows:
Project Director - is responsible for the overall administration and quality assuranceof the investigation. Working with the Project Manager, the Project Director providesoverall review of all project tasks.
Project Manager - is the person duly appointed to act in a supervisory capacity overdesignated employees and activities. The Project Manager is responsible for the dayto day management of the project and overall compliance with all Work Plandocuments.
Field Operations Coordinator - is the person duly appointed to conduct field andrelated activities under the supervision of the Project Manager. The Field OperationsCoordinator is responsible for coordinating site activities and subcontractors consistentwith health and safety requirements.
ERM Site Safety Officer - a Site Safety Officer will be designated to monitor all siteactivities to ensure the Health and Safety Plan is properly implemented. The SiteSafety Officer may assume:
• Responsibility for the field implementation, evaluation, and any necessary field ^modifications of this Health and Safety Plan.
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• Responsibility for maintaining adequate supplies of all personal protectiveequipment as well as calibration and maintenance of all monitoring instru-ments.
• Responsibility for performing and evaluating perimeter ambient air monitoring.
• Authority to suspend operations at the site due to any ineffectiveness of or non-conformance to the Health and Safety Plan.
It is the responsibility of all on-site personnel to monitor the health and safety of theirco-workers. Therefore, each member of the project team will be experienced in hazardouswaste site characterizations, trained in accordance with OSHA 1910.120, and familiar withthis HASP. The project team will consist of (at a minimum) three ERM staff and fiveremedial contractor staff. All site activities will be performed by team members workingin pairs at a minimum (i.e., the "buddy system" will be utilized).
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4.0 PERSONNEL TRAINING
ERM personnel and ERM's subcontractors associated with those field activities inwhich the potential for exposure to hazardous substances above the Permissible ExposureLimit (PEL) exists have participated in a health and safety training program that complieswith criteria set forth by ERM and OSHA as per 29 CFR 1910.120. As such, employeeshave been instructed on general health and safety principles and procedures, properoperation of monitoring instruments, and use of personal protective equipment.
In addition, site employees will undergo site-specific training prior to the start-up ofany given project task. As activities change, related on-site instruction will address potentialhazards and associated risks, site operating procedures, emergency response, and site controlmethods to be employed. The Site Safety Officer will be responsible for the properadministration of this training.
This Health and Safety Plan will be distributed to all subcontractors prior to the startof field activities. A pre-operation meeting will be held to discuss the contents of the Plan.Specialty training will be provided as determined by task and responsibility. All training ofpersonnel will be conducted under direct supervision of a trained Health and Safety Officer.At a minimum, all on-site project personnel must have an understanding of the following:
1. Site-Specific Health and Safety Hazards - personnel must be informed ofspecific hazards related to the site, site operations and site conditions(including weather and biological hazards).
2. Personal Protective Equipment (PPE) - personnel must be trained in properuse of personal protective equipment.
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3. Safe Work Practices/Engineering Controls - personnel must be informed ofappropriate work practices and engineering controls that will reduce the riskof exposure to site hazards.
4. Safety Equipment Use - personnel must understand the use of monitoringinstruments and other safety equipment.
5. Medical Surveillance Program - personnel must be informed of requirementsfor medical surveillance of hazardous waste site employees.
6. Site Control Methods - personnel must understand site methods used to reduceexposure to on-site and off-site personnel.
7. Decontamination Procedures - personnel must be trained in proper decontam-ination operations and procedures.
8. Emergency Response - personnel must be trained in proper emergencyresponse operations and procedures.
ERM contractors and subcontractors must acknowledge their compliance to thesetraining requirements by completing the form shown in Table 4-1.
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TABLE 4-1SUBCONTRACTOR OCCUPATIONAL SAFETY
AND HEALTH CERTIFICATION
PROJECT:
SUBCONTRACTORS:
1. Contractor certifies that the following personnel to be employed during the PurolatorSite Remedial Action have met the following requirements of the OSHA HazardousWaste Operations Standard (29 CFR 1910.120) and other applicable OSHA standards,as required by ERM.
Subcontractor RespiratorPersonnel Training Certification Medical Exam
2. Subcontractor certifies that it has received a copy of the Site Health and Safety Planand will ensure that its employees are informed and will comply with its requirements.
3. Subcontractor further certifies that is has read and understands and will comply withall provisions of its contractual agreement.
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5.0 MEDICAL MONITORING
The Occupational Safety and Health Administration (OSHA) has establishedrequirements for a medical surveillance program designed to monitor and reduce healthrisks for employees potentially exposed to hazardous materials (29 CFR 1910.120). Thisprogram has been designed to provide baseline medical data for each employee involvedin hazardous waste operations including field activities, and to determine his/her ability towear personal protective equipment, such as chemical-resistant clothing and respirators.Project personnel who may wear respiratory protection must be provided respirators asregulated by 29 CFR 1910.134. This standard requires that an individual's ability to wearrespiratory protection be medically certified before he/she performs designated duties.Where medical requirements of 29 CFR 1910.120 and of 29 CFR 1910.134 overlap, the moststringent of the two will be enforced.
All project field personnel have been administered medical examinations on a pre-employment and annual basis and as warranted by symptoms of exposure or specializedactivities. For the purposes of this Health and Safety Plan, all subcontractors shall assumethe employer's responsibility in obtaining the necessary medical monitoring and training fortheir employees pursuant to section 29 CFR 1910.120.
The examining physician is required to make a report to the employer of any medicalcondition which would place such employees at increased risk of wearing a respirator orother personal protective equipment. Each employer engaged in site work shall assume theresponsibility of maintaining site personnel medical records as regulated by 29 CFR1910.120 where applicable. Exemption from the medical surveillance program may beallowed by the ERM Health and Safety Manager or his designee. These exemptions will
^be based on his interpretation of the requirements of 29 CFR 1910.120 relative to each Qindividual exemption request. 0
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6.0 HEALTH AND SAFETY HAZARDS
The results of the 1990 Remedial Investigation give a good understanding of thepotential environmental hazards which may be encountered during the trench excavationfield work. Table 6-1 lists chemical compounds and metals which may be present duringtrench excavation activities. The compounds and metals listed have been chosen fromsample analysis obtained during the 1990 Remedial Investigation to provide a frameworkfor the development of this Health and Safety Plan.
In addition to hazards associated with on-site chemicals, other safety considerationsinherent to the investigation process must be considered. These hazards relate to the useof heavy equipment in an industrial setting, the nature of an intrusive investigation of thesubsurface, and the elements. Table 6-2 lists potential health and safety hazards that maybe encountered based on the tasks to be performed. This list has been compiled based onscheduled activities and potential site conditions.
One potential hazard listed on Table 6-2 is heat stress. Heat stress will be avoided byimplementing work/rest periods dependent on weather conditions. Using the "buddysystem", co-workers will monitor each other for signs of heat stress which are as follows:fatigue, headache, dizziness when erect, loss of appetite, nausea, abdominal distress,vomiting, shortness of breath, flushing of face and neck, pulse rate above 150 beats/min.,glazed eyes, and mental disturbances, such as apathy, poor judgement, and irritability.Persons showing indications of heat stress will be removed to a cool place and permitted tolie down for a time.
The Occupational Safety and Health Administration (OSHA) has established a seriesof regulations pertaining to e'xcavations (29 CFR 1926.650 through 1926.652). All applicable ^
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regulations will be adhered to during this investigation, and a copy of the regulations isincluded as Appendix A in the Field Sampling Plan (Document I of this submittal).
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TABLE 6-1POTENTIAL SITE COMPOUNDS AND ASSOCIATED EXPOSURE INFORMATION
3•
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Compound
Acetone
PEL
750 ppm1780 mg/m3
2-Butanone 200 ppm(methyl ethyl ketone) 590 mg/m3
Chlorodlphenyl(54% chlorine)(Arochlor1254)
Chromium metal
Copper dusts
0.5 mg/m3
0.5 mg/m3
1 mg/m3
Characteristics
colorless liquid with a fragrant, mint-like odor
dear, colorless liquid with a fragrant, mini-like, moderately sharp odor
Cadmium dusts 0.05 mg/m3 appearance and odor vary
1.2-Dlchloroethylene 200 ppm793 mg/m3
pate yePow. viscous liquid with a mild hydro-carbon odor
appearance and odor vary
odorless solids
colorless liquid with an ether-like slightlyacrid odor
Route ofExposure
InhalationIngeslioncontact
Inhalationingestioncontact
Inhalationingeslion
InhalationabsorptionIngestioncontact
InhalationIngestion
inhalationIngestioncontact
inhalationingestioncontact
Symptoms of Overexposure
irritation of eyes, nose, and throat;headache, dizziness, dermatitis
irritation of eyes and nose, headache, dizzi-ness, vomiting
pulmonary edema, dyspnea, cough, tightchest, subslemal pain, headache, chills,muscle aches, nausea, diarrhea, anosmia,emphysema, protelnurla. anemia, carcinoma
Irritation of eyes and skin, acne-form derma-titis, jaundice, dark urine, carcinoma
hlstologlcfibrosls of lungs
Irritation of mucous membranes and phar-ynx, nasal perforation, eye Irritation, metaltaste, dermatitis
Irritation of eyes and respiratory system,central nervous system depression
Target Organs
respiratory system, skin
central nervous system,kings
respiratory system, kidneys,prostate, blood
skin, eyes, Iver
respiratory system
respiratory system, skin,liver, kidneys
respiratory system, eyes,central nervous system
6S£I TOO
TABLE 6-1 (cont'd)
Ethyl benzene
Toluene
Trtchkxoethylene
100 ppm434mg/m3
100 ppm377mg/nr
SO ppm260mg/m3
colorless liquid with an aromatic odor
colorless liquid with an aromatic odor
colorless Hquld with a sweet odor
inhalationIngeslioncontact
InhalationabsorptionIngestioncontact
Inhalationingestioncontact
Irritation ol eyes and mucous membranes,headache, dermatitis, narcosis, coma
lallgue, weakness, confusion, euphoria, diz-ziness, headache, dilated pupils, lacrimation.nervousness, muscle fatigue, Insomnia, par-esthesta, dermatitis, photobla
headache, vertigo, visual disturbance, trem-ors, somnolence, nausea, vomiting, irritationol eyes, dermatitis, cardiac arrhythmias, paresthesla, carcinoma
2eyes, upper respiratory**,system, skin, centralnervous system
central nervous system,liver, kidneys, skin
respiratory system, heart,liver, kidneys, centralnervous system, skin
O>I
Xytene 100 ppm434mg/m3
colorless liquid with aromatic odors Inhalation dizziness, excitement, drowsiness, Incoordlabsorption nation, staggering gall, Irritation ol eyes,Ingestion nose and throat, comeal vacuolizallon, ancontact orexla, nausea, vomiting, abdominal pain,
dermatitis
central nervous system,eyes, gastrointestinal tract,blood, liver, kidneys, skin
TABLE 62HEALTH AND SAFETY HAZARDS
IPROCEDURE USED TO
HAZARD DESCRIPTION MONITOR/REDUCE HAZARD
Heavy Equipment/ ConstrucUonAcUvNy
Underground Material
Machinery(e.g. excavator)
Excavation Trenches
Personnel maintain eye contact with operators; hardhats. saletyshoes, and eye protection worn (as appropriate) during equipmentoperation.
Maintain the slopes ol the sides ol trenches at a low angle toavoid cave Ins.
CTiIUi
Chemical Exposure
Refuse and Materials
Heat Stress
Snake Bite
Vapor Inhalation or direct contact with variouscompounds assodatedwilh trench excavationand container removal
Constructlonrefuse and construction materi-als.
Adverse response to long termexposure lo warm temperatures.
Potential Poisonous Venom
Follow guidelines In thlsHASP. Be tamMiar with slgnsand symplorns ol exposure. Report suspected over- exposure to site Hearth& Salety officer immediately
Maintain clean work areas; dlsposeof reluselmmediately; do notblock access routes with materials.
Employ buddy system. Each worker Is responsible for visuallymonitoring his/her partner lor signs ol heat stress. Site salolypersonnel will also monitor worker's conditions and establishwork/rest regimens.
Employ buddy system. Each worker Is responsible lor visuallymonitoring the work area for presence ol snakes. Snake bllu kitwill be Included In flrslald kit. ERM salety otlicer will discusswithpersonnel procedures to follow In case of snake bile.
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7.0 SITE MONITORING
Field activities associated with the trench excavation procedures may createpotentially hazardous conditions, such as the release of hazardous substances into thebreathing space or contact with contaminated soils and chemicals. Monitoring of airbornevapors will be continuously performed during on-site operations where chemical wastescould potentially be encountered. ERM will monitor the ambient air with an organic vaporanalyzer (such as an OVA- Model 128GC flame ionization organic vapor analyzer fromFoxboro). Monitoring results will be continuously evaluated to ensure that appropriaterespiratory protective measures are employed during site activities. In addition, theexcavation contractor will supply equipment to detect the percentage of oxygen in the trenchand to measure the lower explosive limit (LEL) in the trench. If the oxygen level is lessthan 19.5% or greater than 23.5% and/or the LEL is greater than 8%, no access to thetrench excavation will be allowed.
Air monitoring results will be evaluated by comparing sustained on-site concentra-tions of total organic vapors in the ambient air to established action levels (Section 8.0).If the action level is exceeded, ERM's site safety officer will temporarily suspend work. Thefield crew will proceed to the CRZ area to don the appropriate respiratory protective gear.Work will continue until a change in ambient air quality indicates that a change inrespiratory protection is warranted.
Though off-site movement of volatile organic compound vapors is not expected, workarea perimeter monitoring will be performed with the OVA twice daily to determine iforganic vapors are moving off-site. Furthermore, when the presence of significantconcentrations (greater than 5 ppm) of organic vapors are detected in the work area, theSite Safety Officer will monitor air quality changes with respect to increasing distance from
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the work area. The distance from the work area at which VOC concentrations in ambientair approximate background will be documented in the field notebook.
If elevated concentrations of organic vapors are sustained at a significant distancefrom the work area, work will be suspended and mitigating measures will be implemented.Mitigation measures may include covering the excavation area with plastic and/or soil.Excavation procedures will then be re-evaluated to assure that mitigation measures (e.g.application of vapor-suppressing foam) are utilized during subsequent excavation. Perimetermonitoring results will be recorded in the project field notebook. Purolator's FacilityCoordinator will be notified immediately if perimeter monitoring detects organic vaporconcentrations significantly above background levels. The Purolator Facility Coordinatorwill notify the proper local authorities if fugitive organic vapor concentrations are detectedmigrating off-site. The local authorities (specifically, the Chemung County Local EmergencyPlanning Committee) will be responsible for contacting any affected local residents.
Due to the presence of cadmium and chromium in soils near the proposed excavationareas, paniculate monitoring of ambient air in the work area will be conducted. AMiniRAM paniculate dust monitor by MIE, Inc. will be used to monitor airborneparticulates. Monitoring will be continuously performed in the work area and, if the actionlevel is exceeded, the site safety officer will monitor air quality changes with respect todistance from the excavation (as described above for VOC monitoring). Action levels asdescribed in Section 8.0 will be followed.
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8.0 ACTION LEVELS/PROTECTIVE EQUIPMENT
Certain field activities to be conducted as pan of the trench excavation procedurehave associated exposure risk for inhalation and direct contact with hazardous materials.ERM will constantly monitor field conditions to ensure that the appropriate protectiveequipment is being utilized. Levels of protection will be selected based on establishedaction levels and site observations.
8.1 Respiratory Protection
Field personnel may be exposed to respiratory hazards during trench excavation.Therefore, all intrusive work in these areas will include constant monitoring of ambient airquality. Trichloroethene (TCE) is the compound most likely to be encountered duringtrench excavation activities. TCE has a Permissible Exposure Limit (PEL) of 50 ppm.Therefore, ERM will conservatively assume that all detected organic vapors are due to TCEand will set action levels for respiratory protection as follows:
Background VOC concentration to Level D with full-face respirator and organic5 ppm or total particulates less vapor/paniculate vapor cartridges available. Allthan 1 mg/m3 in the breathing personnel with the excavating contractor andzone ERM's field team will have respirator and car-
tridges available in the Support Zone (see Sec-tion 9.0 of this document)
5 ppm to 50 ppm VOC concentra- Level C full-face respirator with organic va-tion or greater than 1 mg/m3 total por/particulate cartridges. Level B Self-Con-particulates in the breathing zone tained Breathing Apparatus (SCBA) or supplied
air available in the Support Zone for all person-nel.
over 50 ppm (or O2 less than Level B - SCBA or supplied air.19.5%) >
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Furthermore, paniculate monitoring will be conducted as described in Section 7.0.Level C protection (full-face respirator will organic vapor/paniculate filters) will be requiredif the action level of 1 mg/m3 total airborne particulates is exceeded.
SCBA will include supply tank and escape tank. Supplied air will include full-facehose mask, escape tank, sufficient supply hose and sufficient air supply in accordance withapplicable federal regulations for compressed air for breathing purposes.
The field team (the excavating contractor and ERM personnel) will be prepared toupgrade to Level B protection attire as needed according to the above referenced actionlevels. The field team and associated equipment which will be present at the site are asfollows:
Full-Face Respirator SCBA or Supplied AirExcavation Contractor -
Project Supervisor X X
Equipment Operator X X
Field Technical X X
ERM Field Team -Field Operations Coordinator X X
Health/Safety Officer X X
Geologist X X
This equipment will be available on-site throughout the duration of field activitiesand will be stored and maintained in the support zone. All respiratory equipment will be ^N1OSH/MSHA approved and properly maintained. All persons will have been fit-tested <">
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on the appropriate respirator prior to initiation of field work. All persons which may berequired to wear a respirator will be clean shaven.
8.2 Contact Protection
Contact with hazardous chemicals is possible during trench excavation procedures.In general, TCE is the substance of concern. Therefore, all on-site soil and containersampling activities will be performed in Tyvek coveralls and chemical-resistant boots andgloves. All areas of potential skin exposure (e.g. sleeves and glove cuffs) will be sealed withduct tape.
Full face respirators will be readily available during all on-site investigative activities.Respirators will be equipped with combination organic vapor/particulate filters. Levels ofprotection are further described on Table 8-1.
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Table 8-1PERSONAL PROTECTIVE EQUIPMENT
Level Required Equipment Optional Equipment
D
B
Shirt and long pants with tyvek coveralls.Inner latex surgical gloves with outer vitonor nitrile gloves. Hard hat, steel toedboots with rubber overboots or steel toedrubber boots, and safety glasses. Level Cprotection readily available.
Level D requirements plus full-face airpurifying respirator equipped with appro-priate canister or cartridges. Chemical-resistant clothing such as Tyvek or Sara-nex with one piece hoods, booties andelastic wrist bands.
Level C requirements except pressuredemand self-contained breathing appara-tus or supplied air with full-face hosemask in place of respirator. Water-resis-tant tape over protective clothing as need-ed.
Disposable outer boots maybe worn in lieu of rubberoverboots; hearing protec-tion will be worn by equip-ment operator. Face shieldand apron for drum open-ing.
As per Level D.
As per Level C.
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9.0 DECONTAMINATION
Decontamination of protective equipment involves scrubbing with an Alconox/watersolution followed by clean water rinses. All disposable items shall be disposed of in a drycontainer. Rubber components of respirators will be soaked in Alconox and water andscrubbed with a brush. In addition to being decontaminated, all respirators and personalanicles must be sanitized before they can be used again if they become soiled from exhala-tion, body oils, and perspiration. The manufacturer's instructions should be followed insanitizing the respirator masks. Sampling and monitoring equipment will be decontaminatedas described in the Quality Assurance Project Plan (Document II).
9.1 Site Operation Areas
Equipment and personnel cleaning will be conducted in decontamination areasremoved from areas of potential contamination. Ideally, the decontamination areas will beeasily accessible to and in visual contact with the work areas. Guidelines for establishingwork areas and support zones are as follows:
Exclusion Zone (EZ): All areas of potential contamination as indicated by the 1990Remedial Investigation and background information will be considered the ExclusionZone. Appropriate personal protective equipment must be worn in this zone. Thiszone will be separated from the contaminant reduction zone by a hotline or barrierto prevent personnel from entering the exclusion zone boundary without protectiveequipment. Primary exclusion zones will be established around the excavator whiletrench excavation operations are in progress. At a minimum, this zone will radiateto a distance of 25 feet from the point of operations.
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Contaminant Reduction Zone fCRZ'): The decontamination process will take placein this zone. Personnel and equipment must be adequately decontaminated beforeleaving this zone for the support zone.
Support Z ie CSZ): The support zone is considered to be uncontaminated; as such,protective clothing and equipment are not required but should be available for usein emergencies. All equipment and materials are stored and maintained within thiszone. Protective clothing is put on in the support zone before entering thecontaminant reduction zone.
92 Decontamination Guidelines
All personnel must exit the EZ through an established CRZ. Personnel leaving thepoint of operations should wash outer gloves and boots. The outer boots shall be properlywashed and removed first and either stored in an appropriate area or disposed of properly.Personnel shall then remove and dispose of the Tyvek coveralls with care so that innerclothing does not come in contact with any contaminated surfaces. After Tyvek removal,personnel shall remove and clean outer nitrile gloves, inspect the gloves, and discard ifdamaged. Personnel shall then remove the respirator, where applicable. Respirators shallbe disinfected between uses with towelettes or other sanitizing methods. Potable water, ata minimum, will be present so that site personnel can thoroughly wash hands and face afterleaving the point of operations.
Portable wash stations will be utilized for easy and efficient access. The wash stationshall consist of a potable water supply, hand soap and clean towels. Portable sprayer unitsfilled with Alconox solution and potable water will also be available to wash and rinse off
* . 'TJgrossly contaminated boots, gloves and equipment. The Site Safety Officer will monitor >
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decontamination procedures to ensure their effectiveness. Modifications of the decontami-nation procedure may be necessary as determined by the Site Safety Officer's observations.
Figure 9-1 summarizes the personnel decontamination procedures which may berequired during site operations depending on the appropriate level of protection.
Decontamination of all field investigation and sampling equipment will followguidelines established in the USEPA Region n Environmental Services division, MonitoringManagement Branch, CERCLA QAPP (Review Guidance, April 27, 1987). As such, thedecontamination procedure for the test trench excavation will be as follows:
1. Heavy Equipment (excavator, etc.) - All heavy equipment will be steam-cleaned before entering the work area. Equipment will be scrubbed manuallyto remove heavy soils prior to steam cleaning. Equipment will also be steam-cleaned upon completion of work in each excavation area and at the end ofeach work day.
2. Sampling Equipment (trowels, hand-augers, bowls, spatulas') - All samplingequipment will be cleaned before each use by washing with solutions in thefollowing order:
- phosphate-free laboratory detergent solution;- tap water rinse;- nitric acid solution rinse;- methanol rinse;- Hexane rinse; and
* 3*- deionized water (triple rinse). oooM
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After the final rinse with deionized water, equipment will be wrapped inaluminum foil (shiny side out) and stored in a clean area until use.
3. Meters and Probes - All meters and probes that are used in the field will bedecontaminated between uses by triple-rinsing with deionized water.
Personnel involved in the decontamination process will, at a minimum, wear coverallsand latex gloves.
All decontamination water will be containerized as described in the FSP. Protectiveclothing will be "double-bagged" in plastic bags, labeled and secured in the staging area.
n
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Outer GlovtRemoval
EXCLUSIONZONE
TapeRemoval
Boot Cover&
Glove Wash
Boot CoverRemoval
Boot Coyer &Glove Rinse
SegregatedEquipment
Drop
HOTUNE^Suit/Safety Soot
Wash
Tank Changeand Redress • Soot Coyer/
Outer Gloves
CONTAMINATIONREDUCTION
ZONE
Safety 3aotRemoval
'SC3A SaefcoacJcRemoval
Sol ash SuitRemoval
Inner GloveWa*h
Inner GioveRinse
Pace Piece / R E S P I R A T O RRemoval
Inner GloveRemoval
Inner ClamingRemoval
FieldWash M9] Redress
CONTAMINATIONCONTROL LINE
+ IF USING LEVEL B PROTECTION«
IF USING LEVEL C PROTECTION
DECONTAMINATION PROCEDURES
PUROLATOR PRODUCTS COMPANY
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ERM-Northeast
10.0 SITE ACCESS A.VD SITE CONTROL
Access inside the specific worksite location at the Purolator facility will be limitedto trained, authorized personnel. Access into the established exclusion zone or work areawill be limited to those authorized personnel wearing appropriate personal protectiveequipment. The exclusion zones will be cordoned off with flagging tape or other suitableindicators designating the exclusion zone boundary. The zones will also be monitored bythe Site Safety Officer to ensure personnel do not enter without proper personal protection.
Sign-in procedures may be implemented to ensure that only authorized personnel willparticipate in the investigative activities. The Field Operations Coordinator will coordinatethis effort and maintain the generated documentation accordingly.
Certain procedures must be followed to ensure suitable site control and limitationof access so that those persons who may be unaware of site conditions are not exposed toinherent hazards. All heavy machinery and equipment shall be stored in a secured areaupon completion of daily activities.
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11.0 EMERGENCY RESPONSE
Arnot Ogden Memorial Hospital is the emergency care facility closest to thePurolator site. Medical personnel at the Arnot Ogden Memorial Hospital will be informedof site hazards and activities prior to project initiation so that emergency situations can behandled most efficiently. All on-site personnel will be issued directions to the hospital priorto initiation of field work.
The Chemung County Sheriffs Department and the Local Emergency PlanningCommittee will be notified of any events that could impact the health and safety of thesurrounding community. Should any fires or similar occurrences provide such a threat, theSite Safety Officer will assist the police in notifying the various businesses and homes in thearea.
All on-site tasks will be performed by a team of at least two people. In case ofemergency, all site personnel will report to the nearest CRZ for immediate exit from thework area. All facility buildings are equipped with telephones and a cellular telephone willbe maintained in the Support Zone; if emergency assistance is required the nearesttelephone will be used to call for help. In the event of a facility-wide emergency,instructions will be broadcast over the public address system which can be heard throughoutthe site. All site workers will be informed of Purolator's emergency evacuation plan.
The Site Safety Officer will be responsible for responding to all emergencies. TheSite Safety Officer will:
1. Notify appropriate individuals, authorities and/or health care facilities of the'activities and hazards of the investigation;
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2. Ensure that the following safety equipment is available at the site: eyewashstation, first aid supplies, and fire extinguisher;
3. Have working knowledge of all safety equipment available at the site; and
4. Ensure that emergency phone numbers and a map which details the mostdirect route to the nearest hospital are prominently posted.
In the event of a safety or health emergency at the site, appropriate emergencymeasures will immediately be taken to assist those who have been injured or exposed andto protect others from hazards. The Site Safety Officer will be immediately notified and willrespond according to the seriousness of the injury. Personnel trained in first-aid will bepresent during site activities to provide administrative first-aid as appropriate for injuries orillness incurred during operations. The ERM Project Manager and Purolator FacilityCoordinator will be immediately informed of any serious injuries.
Emergency contacts and telephone numbers and directions to the hospital arepresented as Attachment 1 of this document. Attachment 1 will be removed and posted inthe CRZ or other appropriate on-site location for the duration of field activities.
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12.0 INCIDENT REPORTING PROCEDURE
Adherence to this site-specific Health and Safety Plan and any additional facilitysafety rules and regulations will significantly reduce the likelihood of personnel beingexposed to toxic substances above permissible exposure limits. However, in the event anincident does occur, it is imperative that specific reporting procedures be followed so thatappropriate corrective action can be taken by the Health and Safety (H&S) Officer and theProject Manager. Upon notification of an incident, the H&S Officer will contact theappropriate technical personnel for recommended medical diagnosis and, if necessary,treatment. The Project Manager and the Purolator H&S Officer will investigate facility/siteconditions to determine: (1) whether and at what levels the incident actually occurred, (2)the cause of the incident, and (3) the means to prevent the incident from recurring.
An incident reporting form (Exhibit 12-1) has been developed so that consistent andappropriate information is obtained regarding employee exposures. The form will becompleted by the ERM H&S Officer and the exposed individual. New York Stateemployer's report of injury/illness (Form C-Z) will also be completed. These forms will beSled with the employee's medical and safety records and the appropriate agency to serveas documentation of the incident and the actions taken.
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EXHIBIT 12-1INCIDENT REPORT FORM
PROJECT NAME:
EMPLOYEE NAME: LOCATION OF INCIDENT:
DATE:
EMPLOYEE JOB TITLE: TYPE OF INCIDENT:
SPECIFIC JOB AT TIME OF INCIDENT:
LEVEL OF PROTECTION WORN AT TIME OF EXPOSURE:
SUMMARY OF WHAT OCCURRED:
ACTIONS TAKEN TO CORRECT SITUATION (ENGINEERING, P.P.E. ETC.):
EMPLOYEE SIGNATURE:
SITE SAFETY OFFICER:
ERM H&S COORDINATOR :«
TIME & DATE OF REPORT:
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13.0 SPECIAL PRECAUTIONS AND PROCEDURES
The Purolator test trench investigation poses potential exposure risks from bothchemical and physical hazards. The chemical risks have been explained in detail in theprevious sections. The potential for chemical exposure to hazardous substances issignificantly reduced through the use of personal protective clothing, engineering controlsand implementation of safe work practices.
Other potential hazards that are associated with the site activities include injury fromheavy equipment and site refuse. Precautionary measures have been established to reducethese risks to a minimum during site activities. These procedures area as follows:
Heavy Machinery/Equipment. - All site employees must remain aware of activities thatinvolve the use of heavy equipment and machinery. Respiratory protection and protectiveeye wear may be worn frequently during site activities. This protective equipmentsignificantly reduces peripheral vision of the wearer. Therefore, it is essential that allemployees at the site exercise extreme caution during operation of equipment andmachinery to avoid physical injury to themselves or others.
Construction Materials and Site Refuse - All construction materials and site refuse shouldbe contained in appropriate areas or facilities. Site personnel should make certain thatnails, lumber, cement, etc., are not scattered throughout the area of activity and that alltrash and scrap materials are immediately disposed of properly.
Additional Safety Features - The following are important safety precautions which will beenforced during this investigation:
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1. Eating, drinking, chewing gum or tobacco, smoking, or any practice that increasesprobability of hand-to-mouth transfer and ingestion of material is prohibited in anyarea designated as contaminated.
2. Hands and face must be thoroughly washed upon leaving the work area and beforeeating, drinking, or any other activity.
3. Whenever decontamination procedures for outer garments are in effect, the entirebody should be thoroughly washed as soon as possible after the protective garmentis removed.
4. No facial hair which interferes with the face seal of a respirator will be permitted onpersonnel required to wear respiratory protection equipment. The respirator mustseal against the face so that the wearer receives air only through the air purifyingcartridges attached to the respirator. Fit testing shall be performed prior torespirator use to ensure a proper seal is obtained by the wearer.
5. Contact lenses will not be worn on-site. Persons requiring protective eye wear willwear glasses or, in conjunction with respirators, prescription optical inserts.
6. Contact with potentially contaminated surfaces should be avoided whenever possible.One should not walk through puddles, mud, or other discolored surfaces; kneel onground; lean, sit or place equipment on containers, vehicles, or the ground.
7. Medicine and alcohol can potentiate the effect from exposure to certain compounds.Prescribed drugs and alcoholic beverages should not be consumed by personnel« i-qinvolved in the project during or immediately before performance of on-site activities. >
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8. Personnel and equipment in the work areas should be minimized, consistent witheffective site operations.
9. Procedures for leaving the work area must be planned and implemented prior togoing to the site. Work areas and decontamination procedures must be establishedon the basis of prevailing site conditions.
10. Respirators will be issued for the exclusive use of one worker and will be cleanedand disinfected after each use.
11. Safety gloves and boots shall be taped to the disposable, chemical-protective suits asnecessary.
12. All unsafe equipment left unattended will be identified by a "DANGER, DO NOTOPERATE" tag.
13. Noise mufflers or ear plugs may be required for all site personnel working aroundheavy equipment. This requirement will be at the discretion of the Site SafetyOfficer. Disposable, form-fitting plugs are preferred.
14. Cartridges for air-purifying respirators in use will be changed daily at a minimum.
15. The buddy system will be used at all times during the investigation.
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ATTACHMENT 1DOCUMENT III
BODY MECHANICS
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ERM-NorthcastBODY MECHANICS
I. Definition
The most efficient, effective way to move and use the body to reduce stress and strain onthe musculoskeletal structures.
A. Five Principals of Proper Body Mechanics
1) Maintain Posture - maintain natural curves of the spine by positioning the pelvisin a neutral position.
Lordosis - sway backKyposis - forward head and rounded shoulders
2) Face the Object -
Avoid simultaneous twisting and bending
3) Object Close to Body
Improved stability and spinal alignment when elbows are positioned at thesides of the body to hold object in the center of gravity.
4) Wide Base of Support
Provides adequate balance and stability
5) Symmetry
Use both arms when reaching, lifting, and carrying
B. Application to Task
1) Standing
a) Relax pelvis in neutral position to maintain natural spinal alignment.
b) Alternately rest right, then left foot on an elevated foot rest.
c) Occasionally shift weight from side to side.>
d) Lean against wall in a pelvic tilt by placing your back against the wall and °distributing weight evenly over both feet. 0
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' ERM-Northeast2) Sitting
a) Maintain natural spinal alignment by selecting a chair that will support yourlumbar spine.
b) Use a lumbar support when necessary. This may be improvised with a rolledtowel, a rolled piece of clothing, a handbag, or by placing your arm behindyou.
3) Bending to Lift
a) Assessment (how much does the object weigh?)
b) Face your object to avoid twisting (pivot)
c) Position feet to allow a wide base of support
d) Assume a squatting or half kneeling position while maintaining a straight backwith pelvis in neutral
e) Grasp object with both hands and raise it to your center of gravity
f) Lift object with your legs while you maintain a straight back with your pelvisin neutral.
4) Carrying
a) Hold object close to you at your center of gravity
b) Maintain natural curves of the back
c) Maintain a clear visual field
5) Reaching
a) Use a foot stool when objects are higher than shoulder height as raising armsover head puts stress on the lumbar curve
b) Use both arms
c) Distribute weight evenly over both feet with a wide base of support« >TJ
d) Raise up on tip toes to shorten the distance of the reach ooo
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ERM-Northeast6) Push
a) Push as opposed to pull when able
b) Face object to avoid twisting
c) Position body close to object and push with the arms and legs
d) Back should remain straight
7) Pull
a) Face object with one foot behind the other with weight evenly distributed overboth feet
b) Pull should come from both arms and both legs
c) Back should remain straight
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ERM-Northeast 0301039
ATTACHMENT 2DOCUMENT III
EMERGENCY PROCEDURES
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ERM-Morth«a$t
ATTACHMENT 2PUROLATOR HASP (WORK PLAN DOCUMENT III)
Emergency Procedures:
In the event of injury or exposure in the work area, ALL affected persons shouldproceed directly to the CRZ. The Site Safety Officer will assess the situation to determineif emergency response support is needed. The site safety officer will:
notify the appropriate emergency response contact (Note: EmergencyResponse contact telephone numbers are attached);
administer first aid as needed;
control the event to remove the possibility of additional injury or exposure;and
proceed to the hospital (or contact ambulance service) if necessary.
Hospital Route
Bear right onto Route 14 from the facility.
Turn right onto Oakwood Avenue (Note: Oakwood Avenue becomes DavisStreet).
Turn right onto Roe Avenue (there is a church on the corner of Davis andRoe). ' g
ooA hospital route map is attached. i-1
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ROUTE TO HOSPITAL
PUROLATOR PRODUCTS COMPANY- - ^3
FAC 001 1381
ERM- NortheastEMERGENCY RESPONSE TELEPHONE NUMBERS
ERM Project Director:
ERM Project Manager:
ERM Health/Safety Officer:(alternate)
Facility Coordinator:
Facility Coordinator:(alternate)
Facility Health/Safety Officer:
Facility Health/Safety Officer(alternate)
Purolator Guard House
Corporate Coordinator:
Ambulance:
Hospital:
Poison Control Center:
Chemung County Sheriffs Dept.:
Elmira Heights Fire Dept and Rescue:
Electrical and Gas Emergencies (NYSEG):«
Chemung County Local EmergencyPlanning Committee (LEPC):
Brian J. Jacot(518) 452-4291
James F. Blasting(315) 437-0677
James F. Blasting(315) 437-0677
Reeve B. Howland(607) 737-8011
Russ MacDowall(607) 737-8011
Pat Foster(607) 737-8011
Paula Casselbury(607) 737-8011
(607) 737-8011 or0 if in plant
James Skaggs(918) 481-2565
(607) 734-9141
(607) 737-4180
(607) 737-4357
(607) 737-2930
(607) 733-6589
(607) 796-0222
(607) 737-2096 so
Co0303
