ohm remediation services corp.ohm remediation services corp. (ohm) is pleased to present this health...

OHM Remediation Services Corp. A Subsidiary of OHM Corporation

SDMS Document

113185

OHM Remediation Services Corp. A Subsidiary of OHM Corporation

SITE-SPECIFIC HEALTH AND SAFETY PLAN FOR

DREDGING AND DEWATERING PILOT PROJECT

THE GRASSE RIVER STUDY AREA

NoN'TiME CRITICAL REMOVAL ACTION

MASSENA, NEW YORK

Prepared for:

ALUMINUM COMPANY OF AMERICA MASSENA, NEW YORK

Prepared by:

OHM Remediation Services Corp. Trenton, New Jersey

d a ^ ^^ - v iL. 2 .^0^ , C.l4^

Paul A. Lawless, CIH Industrial Hygienist

April 17, 1995 OHM Project 15946HS

TABLE OF CONTENTS

1.0 INTRODUCTION 1-1

1.1 SITE HISTORY 1-1

1.2 SCOPE OF WORK 1-1

FIGURE 1.1 SITEMAP 1-2

2.0 KEY PERSONNEL 2-1

2.1 PROJECT MANAGER 2-1 2.2 SITE SUPERVISOR 2-1 2.3 SITE SAFETY OFFICER 2-1 2.4 CERTIFIED INDUSTRIAL HYGIENIST 2-1 2.5 EMPLOYEE SAFETY RESPONSIBILITY 2-1 2.6 OSHA RECORDS 2-2 2.7 KEY SAFETY PERSONNEL 2-2

FIGURE 2.1 ORGANIZATION CHART 2-3

3.0 JOB HAZARD ANALYSIS 3-1

3.1 CHEMICAL HAZARDS 3-1 3.2 PHYSICAL HAZARDS 3-1 3.3 ENVIRONMENTAL HAZARDS 3-1 3.4 TASK-SPECIFIC ASSESSMENT 3-6

4.0 WORK AND SUPPORT AREAS 4-1

4.1 EXCLUSION ZONE 4-1 4.2 CONTAMINATION-REDUCTION ZONE 4-1 4.3 SUPPORT ZONE 4-1 4.4 GENERAL 4-1 4.5 SITE SECURITY 4-2

FIGURE 4.1 SITE WORK ZONE LAYOUT 4-3

5.0 PROTECTIVE EQUIPMENT 5-1

5.1 ANTICIPATED PROTECTION LEVELS 5-1 5.2 PROTECTION LEVEL DESCRIPTIONS 5-1 5.3 SUPPLIED-AIR RESPIRATORS 5-3 5.4 BREATHING-AIR QUALITY 5-3 5.5 AIR-PURIFYING RESPIRATORS 5-3 5.6 RESPIRATOR CARTRIDGES 5-3 5.7 CARTRIDGE CHANGES 5-3 5.8 INSPECTION AND CLEANING 5-3 5.9 FIT TESTING 5-4 5.10 FACIAL HAIR 5-4 5.11 CORRECTIVE LENSES 5-4 5.12 CONTACT LENSES 5-4 5.13 MEDICAL CERTIFICATION 5-4 5.14 SITE-SPECIFIC RESPIRATORY PROTECTION PROGRAM 5-4

TABLE OF CONTENTS (CONTINUATION)

6.0 DECONTAMINATION PROCEDURES 6-1

6.1 PERSONNEL DECONTAMINATION 6-1 6.2 EQUIPMENT DECONTAMINATION 6-1 6.3 DISPOSAL 6-2

7.0 AIR MONITORING 7-1

7.1 LOWER EXPLOSIVE LIMIT/OXYGEN METER (LEL/Oj) 7-1 7.2 PHOTOIONIZATION DETECTOR (PID) 7-1 7.3 PORTABLE TOTAL DUST MONITOR)) 7-2 7.4 AIR MONITORING LOG 7-2 7.5 CALIBRATION REQUIREMENTS 7-2 7.6 AIR MONITORING RESULTS 7-3 7.7 INTEGRATED AIR MONITORING PROGRAM 7-3

8.0 EMERGENCY RESPONSE AND CONTINGENCY PLAN 8-1

8.1 PRE-EMERGENCY PLANNING 8-1

8.2 EMERGENCY RECOGNITION AND PREVENTION 8-2

TABLE 8.1 EMERGENCY TELEPHONE NUMBERS 8-3

8.3 PERSONNEL ROLES, LINES OF AUTHORITY, AND COMMUNICATIONS 8-3 8.4 SAFE DISTANCES AND PLACES OF REFUGE 8-5 8.5 EVACUATION ROUTES AND PROCEDURES 8-6 8.6 EMERGENCY SPILL RESPONSE PROCEDURE 8-7 8.7 EMERGENCY CONTINGENCY PLAN 8-11 8.8 MEDICAL EMERGENCY CONTINGENCY MEASURES 8-11 8.9 FIRE CONTINGENCY MEASURES 8-12 8.10 HAZARDOUS WEATHER CONTINGENCY MEASURES 8-13 8.11 SPILL/RELEASE CONTINGENCY MEASURES 8-14

9.0 TRAINING REQUIREMENTS 9-1

10.0 MEDICAL SURVEILLANCE PROGRAM 10-1

TABLE 10.1 WORKER MEDICAL PROFILES 10-1

10.1 EXAMINATION SCHEDULE 10-1

APPENDICES APPENDIX A - HEALTH AND SAFETY PLAN CERTIHCATION APPENDIX B - OHM HAZARD COMMUNICATION PROGRAM APPENDIX C - MSDS LIST APPENDIX D - PIPELINE ENTRY PROCEDURES APPENDIX E - HOT WORK PROCEDURES APPENDIX F - LOCK OUT/TAG OUT PROCEDURES APPENDIX G - HIGH PRESSURE WASHERS APPENDIX H - MUDCAT AND DEWATERING PROCEDURES APPENDIX I - ELECTRICAL SAFETY PROCEDURES APPENDIX J - PPE PROGRAM

11

1.0 INTRODUCTION

OHM Remediation Services Corp. (OHM) is pleased to present this Health and Safety Plan (HASP) which has been developed for the Aluminum Company of America (ALCOA).

This HASP documents the policies and procedures which protect workers and the public from potential hazards posed by work at this site. OHM considers safety the highest priority during work at a site containing potentially hazardous materials and has established a goal of zero accidents for all projects. All projects will be conducted in a manner which minimizes the probability of injury, accident, or incident occurrence. This HASP is a key element in the proper planning of project work which is necessary to assure the goal of zero accidents. The HASP Certification (Appendix A) will be signed by all who actively participate at this project.

Although this plan focuses on the specific work activities planned for this site, it must remain flexible because of the nature of this work. Conditions may change and unforeseen situations may arise that require deviations from the original plan. This flexibility allows modification by the OHM supervisors and health and safety officials with approval from the project CIH.

LI SITK HISTORY

A section of the Grasse River bottom adjacent to the ALCOA Massena, New York facility contains elevated concentrations of polychlorinated biphenyls (PCBs). These river sediments are to be removed by dredging/dewatering for proper disposal and the effluent will be treated and returned to the Grasse River.

L2 SCOPE OF WORK

• Mobilization and site setup • Dredging/dewatering of river sediments • Water treatment operations • Equipment decontamination • Demobilization

OHM Project I5946HS Aluminum Company of America February 23, 1995 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp.

1-1

REFERENCE:

7.5 MIN U.S.G.S. TOPOGRAPHIC MAP. CINCINNATI, OHIO, QUADRANGLE. DATED: 1961, PHOTOREVISED 1981. SCALE: 1:24000.

S C A L E

2000 4000 FEET

OHM Remedia t ion Services Corp.

OHM Project No. 1-5946

o 1/5

o Q.

Drawn By:

A. Smith Dote:

^

4/17/95

Chocked By;

E. Medlin Scole:

AS SHOWN

Approved By:

Drowing No.

1 5 9 4 6 - A 1 4

FIGURE 1 SITE LOCATION MAP

GRASSE RIVER STUDY AREA NON-TIME-CRITICAL REMOVAL ACTION

PREPARED FOR

ALUMINUM COMPANY OF AMERICA MASSENA, NEW YORK

• i ^

2.0 KEY PERSONNEL

The Project Manager (PM), Site Supervisor (SS), Certified Industrial Hygienist (CM) and Site Safety Officer (SSO) are responsible for formulating and enforcing health and safety requirements, and implementing the HASP. Reporting relationships are shown in Figure 2.1

2.1 PROTECT MANAGER

The PM has the overall responsibility for the project and to assure that the goals of the construction remedial action are attained in a manner consistent with the HASP requirements. The PM will coordinate with the SS and the SSO to assure that the remedial action goals are completed in a manner consistent with the HASP. The PM will conduct a monthly health and safety audit of the project using the Management Health and Safety Report Form. The PM reports to the Director of Operations.

2.2 SITE SUPERVISOR

The SS is responsible for field implementation of the HASP. The SS will be the main contact in any on-site emergency situation. The SS will conduct periodic inspection of the work site to confirm compliance with all health and safety requirements. The SS is also responsible for coordinating remedial actions for all deficiencies and for enforcing the OHM "Cardinal Safety Rules". The SS reports to the Project Manager.

2.3 SITE SAFETY OFFICER

The SSO has responsibility for administering the HASP relative to site activities, and will be in the field full-time while site activities are in progress. The SSO's primary operational responsibiUties include personal and environmental monitoring, coordination of job safety analyses, personal protective equipment maintenance, and assignment of protection levels. The SSO will direct all field activities involved with safety and is authorized to stop work when an imminent health or safety risk exists. The SSO is responsible for assuring that all on-site personnel understand all safety requirements. The SSO reports jointly to the CIH and the Project Manager.

2.4 CERTIFIED INDUSTRIAL HYGIENIST

The CIH is responsible for the contents of the HASP and ensures that the HASP complies with all federal, state and local health and safety requirements. If necessary, the CIH can modify specific aspects of the HASP to adjust for on-site changes that affect safety. The CIH will coordinate with the SSO on all modifications to the HASP and will be available for consultation when required. The CIH will not necessarily be on site during OHM activities; however, he may perform site safety audits to confirm field compliance with the HASP. The CIH reports to the Regional Vice President / General Manager.

2.5 EMPLOYEE SAFETY RESPONSIBILITY

Each employee is responsible for personal safety as well as the safety of others in the area. The employee will use all equipment provided in a safe and responsible manner as directed by the SS. All OHM personnel will follow the policies set forth in OHM's Employee Safety Guide and the OHM Health and Safety Procedures Manual, with particular emphasis on the OHM "Cardinal Safety Rules."

OHM Project 15946HS Aluminum Company of America February 23,1995 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp.

2-1

^-=^=^ OilM Ueinediation

X" ^ ^ ^ Services Corp. ^ AantataUarr of OHM CoreonU & Si) tal iUu7 of OHM CorponUos KEY PERSONNEL

2.6 OSHA RECORDS

Required records including the OSHA 200 log are maintained at the OHM Divisional offices.

2.7 KEY SAFETY PERSONNEL

The following individuals share responsibility for health and safety at the site.

Site Supervisor Bob Hart 609-421-7571 (site phone)

TBD (site phone)

Eric Medlin 412-963-2300 (office) 800-317-3878 (pager)

Michael Zustra, IHIT 508-435-9561 (office) 609-869-8968 (pager)

Kevin McMahon, M.S., CIH 609-588-6375 (office) 609-421-7523 (pager)

Fred Halvorsen, Ph.D., PE, CIH 800-231-7031

Site Safety Officer

Project Manager

Northern District H&S Manager

ER Health and Safety Director

Vice President, Health and Safety

OHM Project 15946HS Aluminum Company of America February 23, 1995 Information herein is proprietary and confidential and to be u.ted or released to others only with explicit written permission of OHM Remediation Services Corp.

2-2

VICE PRESIDENT fic GENERAL MANAGER

Gjry Gardner

rrr

PROJECT MANAGER £ Med/m

:^:îi^^kiir:iiiPMiiiii^Mm^ffM^^Si 'i^îiî^MiiMW^Si

SITE SUPERVISOR B. H3rt

™ , ^ ™ ^ ^ , ^ ™ ~ ™ ~ .

PROGRAM CIH Kevin McMahon

SITE SAFETY OFFICER TBD

TBD = To Be Determined

FIGURE 2.1

HEALTH S SAFETY ORGANIZATION Dredging and Dewatering Pilot Project

The Grasse River Study Area Non-Time Critical Removal Action

Massena, New York OHM Project 15946

Prepared for ALUMINUM COMPANY OF AMERICA

MASSENA, NEW YORK

2-3

^'^^=- OHM Remediation ^ j ^ ^ Services Corp.

ICorporatioA

3.0 JOB HAZARD ANALYSIS

This section outlines the potential chemical and physical hazards which workers may be exposed to during work on this project. Section 3.1 reviews hazards associated with chemicals/contaminants identified at the site. An MSDS list is included in Appendix C.

3.1 CHEMICAL HAZARDS

3.1 CHEMICAL HAZARDS

CHEMICAL

Polychlorinated Biphenyls

Skin, eye, inhalation, ingestion

l|ii|a|il

0.5 mg/m'

HEALTH HAZARDS/ PHYSICAL HAZARDS

Irritation of eyes, skin; acne-form dermatitis; probable human carcinogen; fever, vomiting, diarrhea, can be absorbed through intact skin; chronic exposure causes liver damage

Reacts with strong oxidizers, sodium and potassium; produces toxic gases from thermal deonmnnsirinn

Personnel will be removed from the work site and placed under observation immediately if the following symptoms occur:

Dizziness or stupor Nausea, headaches, or cramps Irritation of the eyes, nose, or throat Euphoria Chest pains and coughing Rashes or bums

3.2 PHYSICAL HAZARDS

To minimize physical hazards, OHM has developed standard safety protocols which will be followed at all times. Failure to follow safety protocols will result in expulsion of an employee from the site and appropriate disciplinary actions.

The SS and SSO will observe the general work practices of each crew member and equipment operator, and enforce safe procedures to minimize physical hazards. Hard hats, safety glasses, and steel-toe safety boots are required in all areas of the site. Site-specific hazards and all necessary precautions will be discussed at the daily safety meetings. The Health and Safety Procedures Manual will be maintained at the project site as a reference document.

3.3 ENVIRONMENTAL HAZARDS

Environmental factors such as weather, wild animals, insects, and irritant plants pose a hazard when performing outdoor work. The SSO and SS will take all necessary measures to alleviate these hazards should they arise.

OHM Project 15946HS Aluminum Company of America Febmary 23, 1995 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp.

3-1

J - ^ ^ _ OIliM Hcmediaiion V~ ^ ^ Scniccs Corp.

— • ASubildlvrofOBMCoriMnUw JOB HAZARD ANALYSIS

3.3.1 Heat Stress

The combination of warm ambient temperature and protective clothing result in the potential for heat stress. Heat stress disorders include:

• Heat rash • Heat cramps • Heat exhaustion • Heat stroke

Heat stress prevention is outlined in procedure No. 22 of the OHM Corp. Health and Safety Procedures manual. This information will be reviewed during safety meetings. Workers will be encouraged to increase consumption of water and electrolyte-containing beverages (eg, Gatorade).

It is recommended that workers break at least every two hours for 10 to 15 minute rest periods when temperatures rise above 72.5 degrees F and protective clothing is worn. In addition, workers are encouraged to take rests whenever they feel any adverse effects that may be heat-related. The frequency of breaks may need to be increased upon worker recommendation to the SSO and SS.

Heat stress can be prevented by assuring an adequate work/rest schedule; guidelines are printed below.

AMBIENT TEMPERATURE

90" F or above

87.5 F-90 F

82.5-87.5 F

77.5-82.5 F

72.5-77.5 F

NO CHEMICAL PROTECTIVE CLOTHING

Level D

After 45 minutes of work





PROTECTION LEVELS C/B/A






The work/rest schedule can be calculated based on heat stress monitoring results. Monitoring consists of taking the radial pulse of a worker for 30 seconds immediately after exiting the work area. If the heart rate exceeds 110 beats per minute at the beginning of the rest period, shorten the next work cycle by 1/3 and keep the rest period the same. If the heart rate still exceeds 110 beats per minute at the next rest period, increase the following rest period by 1/3. The initial rest period should be at least 10 minutes.

Monitoring for heat stress will begin when the ambient temperature reaches or exceeds 70 degrees Fahrenheit when wearing Level C PPE, or 80 degrees Fahrenheit for site activities performed in Level D. Monitoring will include pulse rate,weight loss, oral temperature and signs and symptoms of heat stress. See Procedure 22 Health and Safety Procedures Manual.

3.3.2 Exposure to Cold

With outdoor work in the winter months, the potential exists for hypothermia and frostbite.

OHM Project 15946HS Aluminum Company of America February 23, 1995 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp.

3-2

_ ^ - ^ ^ ^ OHM Remedia t ion

V^ —...— ncrviccs Corn ^ . . . ^ .^c j^ J O B HAZARD ANALYSIS

Protective clothing greatly reduces the possibility of hypothermia in workers. However, personnel will be instructed to wear warm clothing and to stop work to obtain more clothing if they become too cold. Employees will also be advised to change into dry clothes if their clothing becomes wet from perspiration or from exposure to precipitation.

In cold weather, the potential for frostbite exists, especially in body extremities. Personnel will be instructed to pay particular attention to hands, feet, and any exposed skin when dressing. Personnel will be advised to obtain more clothing if they begin to experience loss of sensation due to cold exposure.

Employees will be encouraged to use the heated shelters on site at regular intervals depending upon the severity of ambient temperatures. Symptoms of cold stress, including heavy shivering, excessive fatigue, drowsiness, irritability, or euphoria necessitate immediate return to the shelter.

3.3.3 Biological Hazards

• POISON IVY (Rhus Radicans)

Poison Ivy may be found at the site. It is highly recommended that all personnel entering into an area with poison ivy wear a minimum of a ty vek coverall, to avoid skin contact.

The majority of skin reactions following contact with offending plants are allergic in nature and characterized by:

• General symptoms of headache and fever • Itching • Redness • A rash

Some of the most common and most severe allergic reactions result from contact with plants of the poison ivy group, including poison oak and poison sumac. Such plants produce severe rash characterized by redness, blisters, swelling, and intense burning and itching. The victim may develop a high fever and feel very ill. Ordinarily, the rash begins within a few hours after exposure, but may be delayed 24 to 48 hours.

Distinguishing Features of Poison Ivy Group Plants

The most distinctive features of poison ivy and poison oak are their leaves, which are composed of three leaflets each. Both plants have greenish-white flowers and berries that grow in clusters.

First Aid

a. Remove contaminated clothing; wash all exposed areas thoroughly with soap and water, followed by rubbing alcohol.

b. Apply calamine or other soothing lotion if rash is mild.

c. Seek medical advice if a severe reaction occurs, or if there is a known history of previous sensitivity.


3-3

_-=-^^^ OIliM Kemedialion

\ ^ PfZ^ oH^ Z... JOB HAZARD ANALYSIS

• TICKS

Heavily vegetated areas of a site may have ticks. It is highly recommended that all personnel walking through such areas wear a tyvek coverall and latex boot covers taped at all joints. The ticks will stand out against the light colors. A tick or insect repellent containing DEET is recommended.

Ticks can transmit several diseases, including Rocky Mountain spotted fever, a disease that occurs in the eastern portion of the United States as well as the westem portion, and Lyme disease. Ticks adhere tenaciously to the skin or scalp. There is some evidence that the longer an infected tick remains attached, the greater is the chance that it will transmit disease.

First Aid

a. Carefully (slowly and gently) remove the tick with tweezers, taking care that all parts are removed.

b. With soap and water, thoroughly, but gently, scrab the area from which the tick has been removed, because disease germs may be present on the skin; also wipe the bite area with an antiseptic.

c. If you have been bitten, place the tick in a jar labeled with the date, location of the bite, and the location acquired. If any symptom appears, such as an expanding red rash, contact a physician immediately.

• LYME DISEASE

Lyme disease may cause a number of medical conditions, including arthritis, that can be treated if you recognize the symptoms early and see your doctor. Early signs may include a flu-like illness, an expanding skin rash and joint pain. If left untreated, Lyme disease can cause serious nerve and heart problems as well as a disabling type of arthritis.

You are more likely to spot early signs of Lyme disease rather than see the tick or its bite. This is because the tick is so small (about the size of the head of a common pin or a period on this page and a little larger after they fill with blood), you may miss it or signs of a bite. However, it is also easy to miss the early symptoms of Lyme disease.

In its early stage, Lyme disease may be a mild illness with symptoms like the flu. It can include a stiff neck, chills, fever, sore throat, headache, fatigue, and joint pain. But this flu-like illness is usually out of season, commonly happening between May and October when ticks bite.

Most people develop a large, expanding skin rash around the area of the bite. Some people may get more than one rash. The rash may feel hot to the touch and may be painful. Rashes vary in size, shape, and color, but often look like a red ring with a clear center. The outer edges expand in size. Its easy to miss the rash and the connection between the rash and the tick bite. The rash develops from three days to as long as a month after the rick bite. Almost one third of those with Lyme disease never get the rash.


3-4

_^"=^=^ OIIM Kemedialion

\ ^ i" ,L^^a. 3:,„ JOB HAZARD ANALYSIS

Joint or muscle pain may be another early sign of Lyme disease. These aches and pains may be easy to confuse with the pain that comes from other types of arthritis. However, unlike many other types of arthritis, this pain seems to move or travel from joint to joint.

In later stages, Lyme disease may be confused with other medical problems. These problems can develop months to years after the first tick bite.

Early treatment of Lyme disease symptoms with antibiotics can prevent the more serious medical problems of later stages. If you suspect that you have symptoms of Lyme disease, notify the SS or SSO; or if you have demobilized from the porject site, contact your doctor.

Lyme disease can cause problems with the nervous system that look like other diseases. These include symptoms of stiff neck, severe headache, and fatigue usually linked to meningitis. They may also include pain and drooping of the muscles on the face, called Bell's Palsy. Lyme disease can also mimic symptoms of multiple sclerosis or other types of paralysis.

Lyme disease can cause serious but reversible heart problems, such as irregular heart beat. Finally, Lyme disease can result in a disabling, chronic type of arthritis that most often affects the knees. Treatment is more difficult and less successful in later stages. Researchers think these more serious problems may be linked to how the body's defense or immune system responds to the infection.

3.3.4 Noise

Hearing protection is required for workers operating or working near heavy equipment, where the noise level is greater than 85 dbA (Time Weighted Average) as well as personnel working around heavy equipment. The SSO will determine the need and appropriate testing procedures, (i.e., sound level meter and/or dosimeter) for noise measurement.


3-5

J^-=^^ OHM Remediation

X~ _ j=F=" Services Corp. — ASubaidiirrofOHllCorpontioii

JOB HAZARD ANALYSIS

3.4 TASK-SPECIFIC RISK ASSESSMENT

3.4.1 ACTIVITY HAZARD ANALYSIS FOR SITE PREPARATION

TASK BREAKDOWN

Equipment/ Facility/ Fence Set-up

POTENTIAL HAZARDS

Struck By/ Against Heavy Equipment

Slips, Trips, Falls

Handling Heavy Objects

Sharp Objects

Insect/ Snake Bites

Contact Dermatitis

High Noise Levels

High/Low Ambient Temperature

HAZARD CONTROL MEASURES

• Use reflective warning vests worn when exposed to vehicular traffic • Avoid equipment swing areas • Make eye contact with operators before approaching equipment • Understand and review hand signals

• Clear, walkways of equipment, tools, vegetation, excavated material, and debris • Mark, identify, or barricade other obstructions

• Observe proper lifting techniques • Obey sensible lifting limits • Use mechanical lifting equipment (hand carts, trucks) to move large, awkward loads

• Wear cut resistant work gloves when the possibility of lacerations or other injury may be caused by sharp edges or objects

• Maintain all hand and power tools in a safe condition • Keep guards in place during use

• Review injury potential and types of snakes with workers • Avoid insect nests areas, likely habitats of snakes outside work areas • Emphasize The Buddy System where such injury potential exists • Use insect repellant, wear PPE to protect against sting/bite injuries

• Wear PPE to avoid skin contact with contaminated soil, plants, or other skin irritants • Identify and review poisonous plants with workers

• Use hearing protection when exposed to excessive noise levels (greater than 85 dBA over an 8-hour work period)

• Monitor for Heat/Cold stress in accordance with OHM Health and Safety Procedures Manual

OHM Project 15946HS Aluminum Company of America Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp.

3-6

February 23, 1995

^-= ;=-.. OHM Remediation

V~ ^ ^ Services Corp. — ASabsidiurofOHHCorporatioii JOB HAZARD ANALYSIS


TASK BREAKDOWN

Road Construction, Grading

Install Silt Fence

POTENTIAL HAZARDS

Struck By/ Against Heavy Equipment

Sharp Objects

Insect/ Snake Bites

Contact Dermatitis

High Noise Levels


Drowning

Slips, Trips, Falls

HAZARD CON I'ROL MEASURES

• Use reflective warning vests worn when exposed to vehicular traffic • Avoid equipment swing areas • Make eye contact with operators before approaching equipment • Understand and review hand signals



• Review injury potential and types of snakes with workers • Avoid insect nests areas, likely habitats of snakes outside work areas • Emphasize The Buddy System where such injury potential exists • Use insect repellant, wear PPE to protect against sting/bite injuries.

• Wear PPE to avoid skin contact with contaminated soil, plants, or other skin irritants • Identify and review poisonous plants with workers



• Wear USCG Approved personal flotation devices for work activities on or near water • Provide a floating ring buoy with at least 90 feet in the immediate boat launch/land areas • Place ring buoys not more than 200 feet apart • Maintain two tender boats (minimum) during on water activities

• Clear walkways and fixed or portable ladders of equipment, extension cords, air-lines, tools, or other debris

• Mark, identify, or barricade other obstructions


3-7

February 23, 1995

j^^^=^ OHM Remediation

V~ y^=^ Services Corp. — A9ubsldUrjofOH)IC«Mir>tlan

JOB HAZARD ANALYSIS


TASK BREAKDOWN

Install Silt Fence (continued)

POTEN riAL HAZARDS

Caught In/ Between Moving Parts

Struck by. Against Heavy Equipment, Protruding Objects


• Provide and use proper work gloves when the possibility of crush, pinch, or other injury may be caused by moving/stationary edges or objects

• Maintain all equipment in a safe condition • Keep all guards in place during use • De-energize and locked-out machinery before maintenance or service

• Use reflective warning vests when exposed to vehicular traffic • Avoid equipment swing areas • Make eye contact with operators before approaching equipment • Barricade or enclose the work areas • Restrict entry to the work area to authorized personnel • Wear hard hats, safety glasses with side shields, and steel-toe safety boots • Understand and review posted hand signals


3-8

February 23, 1995

J=-^^^ OHM Remediation

X~ ^ ^ ^ Services Corp. — A9alaldiurofOHIICorr«niUo ICoryoraUon

JOB HAZARD ANALYSIS

^A.l ACTIVIIY HAZARD ANALYSIS FOR RIVER DREDGING/DEWATERING

TASK BREAKDOWN

Sediment Dredging

POTENTIAL HAZARDS

Drowning

Electrical Shock

SHps, Trips, Falls



• Wear USCG Approved personal flotation devices for work activities on or near water • Provide a floating ring buoy with at least 90 feet in the immediate boat launch/land areas • Place ring buoys not more than 200 feet apart • Maintain two tender boats (minimum) during on water activities

• De-energize or shut off utility lines at their source before work begins • Use double insulated or properly grounded electric power-operated tools • Maintain tools in a safe condition • Provide an equipment-grounding conductor program or employ ground-fault circuit

interrupters • Use qualified electricians to hook up electrical circuits • Inspect all extension cords daily for structural integrity, ground continuity, and damaged

insulation • Cover or elevate electric wire or flexible cord passing through work areas to protect from

damage • Keep all plugs and receptacles out of water • Use approved water-proof, weather-proof type if exposure to moisture is likely • Inspect all electrical power circuits prior to commencing work • Follow Lockout-Tagout procedures in accordance with OHM Health and Safety Procedures

Manual

• Clear walkways and fixed or portable ladders of equipment, extension cords, air-lines, tools, or other debris

• Mark, identify, or guard other obstructions


• Maintain all equipment in a safe condition • Keep all guards in place during use • De-energize and locked-out machinery before maintenance or service


3-9

February 23, 1995

^ ^ s s ^ OHM Remediation

X~ _ ^ ^ Services Corp. — A 8aWiliiii7 of OHM Corporation

JOB HAZARD ANALYSIS

ZA.l ACTIVITY HAZARD ANALYSIS FOR RIVER DREDGING/DEWATERING

TASK BREAKDOWN

Sediment Dredging (continued)

Sediment Dewatering

POTENTIAL HAZARDS

Struck by. Against Protruding Objects, Boats/Wakes, Operating equipment

Explosion, Fires

Inhalation and Contact with Hazardous Substances

ElecU-ical Shock



• Identify location of underground/river gas pipelines • Mark line of piping with buoy, shore marker • Inform dredge operators of pipe depth and other operational precautions • Notify gas pipeline company of dredging operation location

• Provide workers proper skin, eye and respiratory protection based on the exposure hazards present

• Review contaminant chemical MSDSs with workers before operations begin


interrupters • Use qualified electricians to hook up electrical circuits • Inspect all extension cords daily for structural integrity, ground continuity, and damaged



Manual


3-10

February 23, 1995

_^-=^^ OHM Remediation ^ _ ^ ^ Services Corp.

A SoMdiir J of OHH Corporktion JOB HAZARD ANALYSIS

3.4.2 ACTIVITY HAZARD ANALYSIS FOR RIVER DREDGING/DEWATERING

TASK BREAKDOWN

Sediment Dewatering (continued)

POTENTIAL HAZARDS

Slips, Trips, Falls



Struck by, against Heavy Equipment, Protruding objects. Flying, Falling debris


• Clear walkways, work areas, fixed or portable ladders of equipment, extension cords, airlines, tools, or other debris

• Secure/inspect all hand, guard rails and toe boards before operations begin • Mark, identify, or barricade other obstructions


• Maintain all equipment in a safe condition • Avoid reaching between press plates while plate shifter is in motion • Keep all guards in place during use • De-energize and locked-out machinery before maintenance or service





3-11

February 23, 1995

OHM Remediation Services Corp. A SuboMlvr of OHU Corporation

JOB HAZARD ANALYSIS

3.4.3 ACTIVITY HAZARD ANALYSIS FOR WATER TREATMENT OPERATIONS

TASK BREAKDOWN

System Set-up

System Operation & Maintenance

POTENTIAL HAZARDS


Sharp Objects

High Noise Levels


Struck By/Against Vehicles & Equipment

Slips, Trips, & Falls


Inhalation & Contact with Hazardous Substances


• Observe proper lifting techniques • Obey sensible lifting limits • Use mechanical lifting equipment (hand cart, truck) to move large awkward loads


• maintain all hand and power tools in a safe condition • Keep guards in place during use


• Provide and use proper work gloves when the possibility of cmsh, pinch, or other injury may be caused by moving/stationary edges or objects

• Maintain all equipment in a safe condition • Keep all guards in place during use • De-energize and lock-out machinery before maintenance or service

• Avoid equipment swing areas • Make eye contact with operators before approaching equipment • Understand and review hand signals • Avoid areas under suspended loads

• Clear walkways, work areas of equipment, ground debris, tools, and other materials • Mark, identify, or barricade other obstructions

• Monitor for heat/cold stress in accordance with OHM Health & Safety Procedures Manual

• Provide workers proper skin, eye, respiratory & splash protection based on the exposure hazards present

• Review water treatment chemical MSDSs with workers before treatment operations begin


3-12

February 23, 1995

^ ^ s s ^ OHM Remediation

V~ _.^=^ Services Corp. "" A Suboidiarj of OHM Corpomtion

JOB HAZARD ANALYSIS

3.4.3 ACTIVITY HAZARD ANALYSIS FOR WAlER TREATMENT OPERATIONS

TASK BREAKDOWN

System Operation & Maintenance (continued)

POTENTIAL HAZARDS

Electrical Shock


Fires



interrupters. All power tools will be run on GFCIS No. 440V extension cords are allowed, only hard wired circuits as per Alcoa policy

• Use qualified electricians to hook up electrical circuits • Inspect all extension cords daily for structural integrity, ground continuity, and damaged



Manual



• Eliminate sources of ignition from the work area • Smoking is prohibited • Provide ABC (or equivalent) fire extinguishers for all work and flammable storage areas,

fuel powered generators and compressors • Store flammable liquids in well ventilated areas • Post "NO SMOKING" signs • Store combustible materials away from flammables • Store all compressed gas cylinders upright, secure, caps in place when not in use • Separate Flammables and Oxidizers by 20 feet

OHM Project I5946HS Aluminum Company of America Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp.

3-13

February 23, 1995

^ ^ ^ OHM Remediation

X~ -^^^ Services Corp. —" A Subddlirj of OHM Corporation

JOB HAZARD ANALYSIS

\ 3 A 3 ACTIVITY HAZARD ANALYSIS FOR WATER TREATMENT OPERATIONS

TASK BREAKDOWN

System Operation & Maintenance (continued)

Treatment Chemical Handling

POTENTIAL HAZARDS

Flammable, Toxic, Oxygen deficient Atmospheres

Slips, Trips, & Falls




Fires


• Test vessel atmosphere for flammable/toxic vapors, and oxygen deficiency • Review contaminant MSDS before starting work • Wear proper level of PPE for the type of atmospheric contaminants • Use body harness, safety belt with tripod wench for possible rescue • Obtain Confined Space Entry Permit signed by Supervisor/Safety Officer • De-energize, lock-out and tag all energized equipment • Provide safety observer outside vessel • Provide written rescue plan • Review emergency procedures before work commences

• Clear walkways of equipment, ground debris, tools, and other materials • Mark, identify, or barricade other obstructions



• Review water treatment chemical MSDSs with workers before U-eatment operations begin


• Eliminate sources of ignition from the work area • Prohibit smoking in work areas • Provide ABC (or equivalent) fire extinguishers in all work and flammable storage areas, fuel

powered generators and compressors • Store flammable liquids in well ventilated areas • Post "NO SMOKING" signs • Store combustible materials away from flammables • Store all compressed gas cylinders upright, caps in place when not in use • Separate Flammables and Oxidizers by 20 feet


3-14

February 23, 1995

^'=^=^ OHM Remediation

V~ ^ ^ Services Corp. — A Snteidlnrr of OHH Corporatloa

JOB HAZARD ANALYSIS

3 A 3 ACTIVITY HAZARD ANALYSIS FOR WATER TREATMENT OPERATIONS

TASK BREAKDOWN

Treatment Chemical Handling (continued)

System Breakdown & Decontamination

POTENTIAL HAZARDS


Sharp Objects


Sharp Objects


Struck By/ Against Vehicles & Equipment


HAZARD CONIROL MEASURES










• Avoid equipment swing areas • Make eye contact with operators before approaching equipment • Understand and review hand signals • Avoid areas under suspended loads


• Review contaminant MSDS before starting work


3-15

February 23, 1995

_^^^s^ OHM Remediation

V~ ^ ^ ^ Services Corp. ^ " ASabotdliryofaHlIOorporatl • Corporation

JOB HAZARD ANALYSIS

3.4.3 ACTIVITY HAZARD ANALYSIS FOR WATER TREATMENT OPERATIONS

TASK BREAKDOWN

System Breakdown & Decontamination (cont'd)

POTENTIAL HAZARDS


High Noise Levels



• Test vessel atmosphere for flammable/toxic vapors, and oxygen deficiency • Review contaminant MSDS before work begins • Wear proper level of PPE for the type of atmospheric contaminants • Use body harness, safety belt, life line and retrieval system for possible rescue • Obtain Confined Space Entry Permit signed by Supervisor/Safety Officer • De-energize, lock-out and tag all energized equipment • Provide safety observer outside vessel • Provide written rescue plan • Review emergency procedures before work commences

• Use hearing protection when exposed to excessive noise levels (greater than 85 dBA over an 8-hour work period



3-16

February 23, 1995

^ ^ ^ ^ OHM Remediation ^ s = ^ Services Corp.

^ . ^ ASnboldlurotOHllCorpordlon JOB HAZARD ANALYSIS

3.4.4 ACTIVITY HAZARD ANALYSIS FOR EQUIPMENT DECONTAMINATION

TASK BREAKDOWN

Heavy Equipment, Vehicles, Pumps, Piping, Hoses

Roll-offs & Containers

POTENTIAL HAZARDS

Slips, Trips, Falls

Struck by. Against Heavy Equipment, Protruding Objects, & Splashes


Bums


Sharp Objects

High Noise Levels


Slips, Trips, Falls


• Clear, walkways of equipment, vegetation, tools, excavated material, and debris • Mark, identify, or barricade other obstructions

• Use reflective warning vests when exposed to vehicular traffic • Avoid equipment swing areas • Make eye contact with operators before approaching equipment • Wear hard hats, safety glasses with side shields, or goggles with splash shields and steel-

toe safety boots • Understand and review hand signals



• Use proper gloves, face shield/safety goggles, shin and toe guards, and splash suits to protect workers from skin burns and injury when operating laser (high pressure washers)

• Observe proper lifting techniques • Obey sensible lifting limits • Use mechanical lifting equipment (hand carts, trucks) to move large, awkward loads





• Clear, walkways of equipment, vegetation, tools, excavated material, and debris • Mark, identify, or barricade other obstructions


3-17

February 23, 1995

_^^^=^ OHM Remediation

V~ .^=" Services Corp. • = ' A SolaidivT of OHH Corporation

JOB HAZARD ANALYSIS

1 3.4.4 ACTIVITY HAZARD ANALYSIS FOR EQUIPMENT.DECONTAMINATION

TASK BREAKDOWN

Roll-offs & Containers (continued)

POTENTIAL HAZARDS

Struck by. Against Heavy Equipment, Protruding Objects, & Splashes



Burns


Sharp Objects

High Noise Levels

High/Low Ambient Teniperature


• Use reflective warning vests when exposed to vehicular traffic • Avoid equipment swing areas • Make eye contact with operators before approaching equipment • Wear hard hats, safety glasses with side shields, or goggles with splash shields and steel-

toe safety boots • Understand and review hand signals

• Test vessel atmosphere for flammable/toxic vapors, and oxygen deficiency • Review contaminant MSDS with workers and observer before starting work • Wear proper level of PPE for the type of atmospheric contaminants • Use body harness, safety belt with tripod wench for possible rescue • Obtain Confined Space Entry Permit signed by Supervisor/Safety Officer


• Review MSDS information before starting work

• Use proper gloves, face shield/safety goggles, shin and toe guards, and splash suits to protect workers from skin burns and injury when operating laser (high pressure washers)

• Observe proper lifting techniques • Obey sensible lifting limits • Use mechanical lifting equipment (hand carts, ti-ucks) to move large, awkward loads






3-18

February 23, 1995

4.0 WORK AND SUPPORT AREAS

To prevent migration of contamination caused through tracking by personnel or equipment, work areas and personal protective equipment will be clearly specified prior to beginning operations. OHM has designated work areas or zones as suggested by the NIOSH/OSHA/USCG/EPA'S document titled, "Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities." Each work area (see Figure 4.1) will be divided into three zones as follows:

• An Exclusion or "hot" Zone (EZ) • A Contamination-Reduction Zone (CRZ) • A Support Zone (SZ)

4.1 EXCLUSION ZONE

The EZ is the area suspected of contamination and presents the greatest potential for worker exposure. Personnel entering the area must wear the mandated level of protection for that area. In certain instances, different levels of protection will be required depending on the tasks and monitoring performed within that zone. The EZ for this project will include all the environments in direct contact with contaminated sediments or effluent. This includes: discharge areas of the shaker screen, chemical mix tanks, water treatment vessels and holding pools and accessways and catwalks around exposed contaminated surfaces, also roll-off/dump boxes where solidified cake is staged prior to disposal.

4.2 CONTAMINATION-REDUCTION ZONE

The CRZ or transition zone will be established between the EZ and SZ. In this area, personnel will begin the sequential decontamination process required to exit the EZ. To prevent off-site migration of contamination and for personnel accountability, all personnel will enter and exit the EZ through the CRZ. The CRZ for this project will include the burmed area containing water treatment and dewatering press operations, also the decontamination areas for equipment and personnel and the truck scale.

4.3 SUPPORT ZONE

The SZ serves as a clean, control area. Operational support facilities are located within the SZ. Normal work clothing and support equipment are appropriate in this zone. Contaminated equipment, or clothing will not be allowed in the SZ. The support facilities should be located upwind of site activities. There will be a clearly marked controlled access point from the SZ into the CRZ and EZ that is monitored closely by the SSO and the SS to ensure proper safety protocols are followed. The SZ for this project will include the office and crew facility trailers parking lots and site access roads. The site will be surrounded by a security fence and twenty-four hour security will be maintained during the project (see Appendix J).

4.4 GENERAL

The following items are requirements to protect the health and safety of workers and will be discussed in the safety briefing prior to initiating work on the site.

• Eating, drinking, chewing gum or tobacco, smoking, or any practice that increases the probability of hand to mouth transfer and ingestion of contamination is prohibited in the EZ and CRZs.


4-1

^ ^ ^ ^ - OIIM Remediation

V^^!:"±Z... y oRKAND SUPPORT AREAS

• Hands and face must be washed upon leaving the EZ and before eating, drinking, chewing gum or tobacco and smoking or other activities which may result in ingestion of contamination.

• A buddy system will be used. Hand signals will be established to maintain communication.

• During site operations, each worker will consider himself as a safety backup to his partner. Off-site personnel provide emergency assistance. All personnel will be aware of dangerous situations that may develop.

• Visual contact will be maintained between buddies on site when performing hazardous duties.

• No personnel will be admitted to the site without the proper safety equipment, training, and medical surveillance certification.

• All personnel must comply with established safety procedures. Any staff member who does not comply with safety policy, as established by the SSO or the SS, will be immediately dismissed from the site.

• Proper decontamination procedures must be followed before leaving the site.

• All employees and visitors must sign in and out of the site.

4.5 SITE SECURITY

OHM personnel will work 24 hours per day, 7 days per week. This will insure 24 hour security.


4-2

tXCWSlON Z(JNE

CONTAMINATION REDUOTl0N--Z0NE

-SUPPdRT ZONE

--- ^ ^ ^ ' • r ^ -• :'• X X X X X X X \ -•--' ^ - ^ ' . ^A -""'X X X ;'.,/< X/^^^xX X XV

^ . , ^ ^ r y < A. >v. >y <,;-.,-</y'yX^,XJX;,S:^

f •^^'v'>5lK^x'yX•'vV>•*•Ac>2'>^>!^

V'.•'•'• .X/'vl^-X^x X^X_;< ' ;K_ ;< ;X_ ; ' ' ,X^ ,X^ . - : . . :< ,X . , ; ' . , ,X , , : \> ;^ ; ' ' . ' : , , \ ,X^XJ

V X X X V V X X X :• /, :•. x >-. •• X W " \ K X X. X X X > 0 * X '••' ;••. .-, X. \ ^W-*r

REMOVAL AREA-*a' (OUTFALL 001)

COBBLE AREA 'A'

BOULDER ZONE 'B'

^

mm m --m^}^

General Notes and Legend

EXCLUSION ZONE

CO^f^AMINATION REDUCTION ZONE

SUPPORT ZONE

/ •

No. V

R e v i s i o n

• \

Date

OHM Remedia t ion Services Corp.

Drawn By:

A. Snnith

Dote:

. 4 /17 /95

Chocked By:

E. Medlin

Scale:

AS SHOWN

Approved By:

Drawing No.

15946-B5 ,

FIGURE 4 - 1

WORK ZONES GRASSE RIVER STUDY AREA

NON-TIME-CRITICAL REMOVAL ACTION

PREPARED FOR

ALUMINUM COMPANY OF AMERICA MASSENA. NEW YORK

i

5.0 PROTECTIVE EQUIPMENT

This section addresses the various levels of personal protective equipment (PPE) which are or may be required at this job site. OHM personnel are trained in the use of all PPE utilized.

5.1 ANTICIPATED PROTECTION LEVELS

TASK

Site Preparation/ Construction

Dredging Sediments

Dewatering Operations

Water Treatment Operations

Equipment Decontamination

Demobilization

CRZ Workers

1 SZ Workers

PROTECTION LEVEL

Level D

Level D

Level D/C

Level D/C

Level C

Level D

Level D

Level D

COMMENTS/MODIFICATIONS

USCG approved floatation devices

USCG approved floatation devices

Upgrade to Level C if PID readings exceed "action levels" listed in Section 7 of this HASP

Upgrade to Level C if PID readings exceed "action levels" listed in Section 7 of this HASP

Splash suits/Surans, shin and toe guards, boots and gloves, when operating High Pressure Washers

5.2 PROTECTION LEVEL DESCRIPTIONS

This section lists the minimum requirements for each protection level. Modification to these requirements will be noted above.

5.2.1 Level D

Level D consists of the following:

Safety glasses with side shields Hard hat Steel-toed work boots Work clothing as prescribed by weather Hearing protection >85 dB A

OHM Project I5946HS Aluminum Company of Almerica February 23, 1995 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp.

5-1

_ -=s=^ OHM Remediation

V~ ^ ^ Services Corp. — A Subsidlarj of OHM Corporation PROTECTIVE EQUIPMENT

5.2.2 Modified Level D

Modified Level D consists of the following:

Safety glasses with side shields

Hard hat

Steel-toed work boots

Nitrile, neoprene, latex or PVC overboots

Outer nitrile, neoprene, or PVC gloves over latex sample gloves

Face shield (when projectiles or splashes pose a hazard)

Tyvek coverall [Polyethylene-coated Tyveks required when workers have a potential to be exposed to contaminated liquids or sludges.]

Hearing protection >85 dB A

5.2.3 Level C

Level C consists of the following:

Full-face, air-purifying respirator with appropriate cartridges

Hooded Tyvek Coveralls [Polyethylene-coated Tyveks required when workers have a potential to be exposed to contaminated liquids or sludges].

Hard hat

Steel-toed work boots

Nitrile, neoprene, latex or PVC overboots

Nitrile, neoprene, or PVC gloves over latex sample gloves

Face shield (when projectiles or splashes pose a hazard)

Hearing protection >85 dB A

5.2.4 Level B

Level B protection consists of the items required for Level C protection with the exception that an air-supplied respirator is used in place of the air-purifying respirator.

OHM Project 15946HS Aluminum Company of Almerica Febmary 23, 1995 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp.

5-2

^ ^ ^ 0II.V1 Heniediation •X. , ^ = Services Corp. _ - .__ > ^ ,..>..,..,o,oH,cor,.r.,oo PROTECTIVE EQUIPMENT

5.2.5 Level A

Level A protection consists of the items required for Level B protection with the addition of a fully-encapsulating, vapor-proof suit capable of maintaining positive pressure.

5.3 SUPPLIED-AIR RESPIRATORS

If air monitoring shows that Level B protection is needed, OHM personnel will wear Survivair 9881-02 Hippack Airline respirators with 5-minute egress bottles. Personnel requiring Level "B" protection and high mobility will wear Survivair Mark 2 SCBA units.

5.4 BREATHING-AIR OUALITY

Code of Federal Regulations 29 CFR 1910.134 states breathing air will meet the requirement of the specification for Grade D breathing air as described in the ANSI/CGA Specification G-7.1-1989. OHM requires a certificate of analysis from vendors of breathing air in order to show that the air meets this standard. Breathing air will be obtained in cylinders exclusively and will be stationed in the exclusion zone (EZ).

5.5 AIR-PURIFYING RESPIRATORS

A NIOSH-approved full-face respirator with appropriate air-purifying cartridges will be used for Level C work.

5.6 RESPIRATOR CARTRIDGES

The crew members working in Level C will wear respirators equipped with air-purifying cartridges approved for the following contaminants.

Organic vapors < 1,000 ppm Chlorine gas <10 ppm Hydrogen chloride <50 ppm Sulfur dioxide <50 ppm Dusts, fumes and mists with a TWA <0.05 mg/m' Asbestos-containing dusts and mists Radionuclides Pesticides

5.7 CARTRIDGE CHANGES

All cartridges will be changed a minimum of once weekly, or more frequently if personnel begin to experience increased inhalation resistance or breakthrough of a chemical warning property. Cartridges will be labeled with the date service began.

5.8 INSPECTION AND CLEANING

Respirators are checked periodically by a qualified individual and inspected before each use by the wearer. All respirators and associated equipment will be decontaminated and hygienically cleaned after each use.


5-3

_ ^ ^ ^ _ OIl.M Remediation •X. . ^=^ Services Corp. _- __, > ^ "°>--'-"""^"'-- PROTECTIVE EQUIPMENT

5.9 FIT TESTING

Annual respirator fit tests are required of all personnel wearing negative-pressure respirators. The test will use isoamyl acetate or irritant smoke. The fit test must be for the style and size of the respirator to be used.

5.10 FACIAL HAIR

Personnel who have facial hair which interferes with the respirator's sealing surface will not be permitted to wear a respirator and will not be permitted to work in areas requiring respirator use.

5.11 CORRECTIVE LENSES

Normal eyeglasses cannot be worn under full-face respirators because the temple bars interfere with the respirator's sealing surfaces. For workers requiring corrective lenses, special spectacles designed for use with respirators will be provided.

5.12 CONTACT LENSES

Contact lenses will not be worn with any type of respirator.

5.13 MEDICAL CERTIFICATION

Only workers who have been certified by a physician as being physically capable of respirator usage will be issued a respirator. Personnel unable to pass a respiratory fit test or without medical clearance for respirator use will not be permitted to enter or work in areas on site that require respiratory protection. Employees receive a written physicians opinion that they are fit for general hazardous waste operations as per 29 CFR 1910.120(f)(7).

5.14 SITE SPECIFIC PERSONAL PROTECTIVE EOUIPMENT fPPE^ PROGRAM

The primary objective of the PPE program is to ensure employee protection and to prevent employee exposure to site contaminants during site operations. Engineering controls are not feasible for many tasks and, therefore, require the use of PPE.

The RM will be responsible for implementing all aspects of the PPE program. This includes donning and doffing, temperature related stress monitoring, inspection, and decontamination (see Section 6.0). PPE selection is identified in Table 5.1 for each specified task. The RM in consultation with the PSO, if assigned. District Health and Safety Manager, project CIH and the OSC will direct changes in PPE based on changing conditions. The site specific HASP will served as written certification that the workplace was evaluated concerning PPE requirements. OHM Corporation's comprehensive PPE Program is described in Appendix J.

5.14.1 SITE-SPECIFIC RESPIRATORY PROTECTION PROGRAM

The primary objective of respiratory protection is to prevent employee exposure to atmospheric contamination. When engineering measures to control contamination are not feasible, or while they are being implemented, personal respiratory protective devices will be used.

The criteria for determining respirator need have been evaluated based on the site contaminants; expected levels of protection are outlined in Section 5.1. Air monitoring will be conducted to confirm that respiratory protection levels are adequate (Section 7.0). All respirator users are OSHA trained in proper


5-4

OIIM Remediation V , ^ = Services Corp. —» _^

^ . . .. . ^ PROTECTIVE EQUIPMENT respirator use and maintenance. The SS and SSO will observe workers during respirator use for signs of stress. The SS, CM, and SSO will also evaluate this HASP periodically to determine its continued effectiveness with regard to respiratory protection. All persons assigned to use respirators will have medical clearance to do so.


5-5

6.0 DECONTAMINATION PROCEDURES

This section describes the procedures necessary to ensure that both personnel and equipment are free from contamination when they leave the work site.

6.1 PERSONNEL DECONTAMINATION

Decontamination procedures will ensure that material which workers may have contacted in the EZ does not result in personal exposure and is not spread to clean areas of the site. This sequence describes the general decontamination procedure. The specific stages will vary depending on the site, the task, the protection level, etc.

1. Go to end of EZ 2. Wash outer boots and gloves in detergent solution 3. Rinse outer boots and gloves in water 4. Remove outer boots and let dry 5. Remove outer gloves and let dry 6. Cross into CRZ 7. Wash splash suit 8. Rinse splash suit 9. Remove splash suit and let dry 10. Remove and wash respirator 11. Rinse respirator and hang to dry 12. Remove sample gloves and discard 13. Remove Tyvek and discard 14. Remove booties and discard 15. Remove sample gloves and discard

6.1.1 Suspected Contamination

Any employee suspected of sustaining skin contact with chemical materials will first use the emergency shower. Following a thorough drenching, the worker will proceed to the decontamination facility. Here the worker will remove clothing, shower, don clean clothing, and immediately be taken to the first-aid station. Medical attention will be provided as determined by the degree of injury.

6.1.2 Personal Hygiene

Following decontamination and before any eating, smoking, or drinking, personnel will wash hands, arms, neck and face.

6.2 EOUIPMENT DECONTAMINATION

All contaminated equipment will be decontaminated before leaving the site. Decontamination procedures will vary depending upon the contaminant involved, but may include sweeping, wiping, scraping, hosing, or steaming the exterior of the equipment. Personnel performing this task will wear the proper PPE as prescribed by the SSO.


6-1

J ' '=s^ OIIM Remediation

^ \.^..^.s^ DECONTAMINATION PROCEDURES

6.3 DISPOSAL

All decontamination liquids and disposable clothing will be treated as contaminated waste unless determined otherwise by accepted testing methods. Wastes will be disposed of according to state and federal regulations.


6-2

J^^ss^ OHM Remediation

\ ^ E^2;' Soi 3:,.. AIR MONITORING

If levels exceed background at any time in the support zone, work in the exclusion zone will cease and corrective actions will be taken, e.g., cover soil with polyethylene sheeting. Work will not resume until levels reach background in the support zone.

7.3 PORTABLE TOTAL DUST MONITOR

A mini-ram will be used to monitor the general respirable dust levels on this site. The air sampling will be performed at designated locations at the site perimeter, upwind and downwind of the active work areas in the (EZ). Site conditions will determine the frequency and duration of dust monitoring. Mini-ram readings will trigger dust abatement actions and PPE upgrades.

7.3.1 Type and Operational Aspects

• Real-Time Aerosol Monitor (Mini Ram Model PDM-3)

Principle of Operation

• Detection of light in the near infrared region back-scattered to a sensor (photovoltaic detector) by airborne particulate in a sensing volume

• The higher the dust concentration the more back-scattering of light to the sensor, resulting in increased readings

• Device calibrated at the factory against an air sampling filter/gravimetric analysis reference method

7.3.2 Calibration Methods/Frequencies

There is no calibration method or procedure for calibrating the mini-ram monitor. However, it is recommended that the mini-ram monitor be re-zeroed once a week. During a zero check, the sampled air passes through the purge air filter and dryer to effect a self-cleaning of the optical chamber.

7.3.3 Preventative Maintenance

Maintenance of the mini-ran consists of replacement of filters and desiccant; battery replacement; and cleaning of the optical detection assembly.

7.4 AIR MONITORING LOG

The SSO will ensure that all air-monitoring data is logged into a monitoring notebook. Data will include instrument used, wind direction, work process, etc. The Regional and Corporate OHM CIH will periodically review this data.

7.5 CALIBRATION REQUIREMENTS

The PID, LEL/O2 meter and sampling pumps required with fixed-media air sampling will be calibrated daily before and after use. A separate log will be kept detailing date, time, span gas, or other standard, and name of person performing the calibration.

OHM Project I5946HS Aluminum Company of America Febmary 23, 1995 Information herein is proprietary and confidential and to be used or released to others only with explicit written permission of OHM Remediation Services Corp.

7-2

^ - ^ = ^ OHM Remediat ion

N ^ F ^ L7., fo. °x.. A//g MONITORING

7.6 AIR MONITORING RESULTS

Air monitoring results will be posted for personnel inspection, and will be discussed during morning safety meetings.

7.7 INTEGRATED AIR MONITORING PROGRAM

Air samples may be collected at all active work zones in the exclusion zone. Monitoring will be performed to determine if the level of protection is adequate for employees and to document that off-site migration of contaminants will not occur. The concentration will be evaluated based on ACGIH threshold limit values.

TWA sampling will be performed at each active work location. At least one (1) TWA sample will be taken at each location. One (1) sample will be obtained from a personal sampling pump carried by the most "at-risk" individual.

7.7.1 Type and Operational Aspects

• Gilian Air Sampling Pump (or equivalent)

Principle of Operation

• Air sampling pump is calibrated to draw a specified air flow rate (liters per minute) for a designated period of time (usually 8 hours).

• Volume of air sampled is then calculated as follows:

Flow rate (liter/min.) x sample time (min.) = sample volume (liters)

• Use a bubble meter to calibrate air sampling pump; pump equipped with a rotameter that shows the flow rate during the sampling period.

• Equipped with a rechargeable battery for 8-hour sampling times; must be recharged for at least 16 hours.

Collection Media

Filter cassettes-heavy metal dust

• Connect collection media/holder to air sampling pump using Tygon tubing; comprises the sampling train that must be assembled to calibrate the pump.

7.7.2 Calibration Methods/Frequencies

Flow rate calibration can be accomplished by using primary standard soap and the Gilibrator Calibrator (or equivalent). The Gilibrator calibrator allows rapid flow rate determination with direct read-out on the built-in display.

Simply connect the sampler to the calibrator, press the ON push button, and then push the plunger to start a bubble up the flow cell. The flow rate is automatically calculated and shown on the display.


7-3

_ ^ ^ = - OHM Remediation

V~ . ^ s ^ Ser\'ices Corp. ^ •. -•

^ .».>.. . . . ,O,O„CO„OVM,.. A/i? MONITORING

Subsequent readings are averaged with the previous readings. It is recommended that calibration of the sampler be checked prior to the start of and after each sampling period.

7.7.3 Preventative Maintenance

The Gilian air sampling pump was designed for both mechanical and electronic reliability. The sampling pump should not require special maintenance or adjustments under normal conditions. However, as with all instruments, the sampling pump does require some basic care. Basic maintenance of the consists of filter replacement, installing and removing battery packs, storage conditions, and electronic control assembly.


7-4

8.0 EMERGENCY RESPONSE AND CONTINGENCY PLAN

8.1 PRE-EMERGENCY PLANNING

Prior to engaging in construction/remediation activities at the site, OHM will plan for possible emergency situations and have available adequate supplies and manpower to respond. In addition site personnel will receive training during the site orientation concerning proper emergency response procedures.

The following situations would warrant implementation of the ERCP:

Fire/Explosion

Spill or Release of Hazardous Materials

Natural Disaster

Medical Emergency

• The potential for human injury exists. • Toxic fumes or vapors are released. • The fire could spread on site or off site and possibly ignite other

flammable materials or cause heat-induced explosions. • The use of water and/or chemical fire suppressants could result

in contaminated run-off. • An imminent danger of explosion exists.

• The spill could result in the release of flammable liquids or vapors, thus causing a fire or gas explosion.

• The spill could cause the release of toxic liquids or fumes in sufficient quantities or in a manner that is hazardous to or could endanger human health.

• A rain storm exceeds the flash flood level. • The facility is in a projected tornado path or a tornado has

damaged facility property. • Severe wind gusts are forecasted or have occurred and have

caused damage to the facility.

• Overexposure to hazardous materials. • Trauma injuries (broken bones, severe lacerations/bleeding,

burns). • Eye/skin contact with hazardous materials. • Loss of consciousness. • Heat stress (Heat stroke). • Cold stress (Hypothermia). • Heart attack. • Respiratory failure. • Allergic reaction.

The following measures will be taken to assure the availability of adequate equipment and manpower resources:

• Sufficient equipment and materials will be kept on site and dedicated for emergencies only. The inventory will be replenished after each use.

• On-site emergency responders will be current in regards to training and medical surveillance programs. Copies of all applicable certificates will be kept on file for on-site personnel required to respond.


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^ • ^ ^ OIIM Remediation

X~ ^ ^ Services Corp. ^ — A SnbtUlor j of OHJI Corporolioa

EMERGENCY RESPONSE AND CONTINGENCY PLAN

• It will be the responsibility of the emergency coordinator to brief the on-site response team on anticipated hazards at the site. The emergency coordinator shall also be responsible for anticipating and requesting equipment that will be needed for response activities.

• Emergency response activities will be coordinated with the Local Emergency Planning Committee (LEPC) in compliance with SARA Title III requirements.

Communications will be established prior to commencement of any activities at the remediation site. Communication will be established so that all responders on site have availability to all pertinent information to allow them to conduct their activities in a safe and healthful manner. The primary communication device will be two-way radios. Air horns may be used to alert personnel of emergency conditions.

Primary communication with local responders in the event of an emergency will be accomplished using commercial telephone lines.

8.2 EMERGENCY RECOGNITION AND PREVENTION

Because unrecognized hazards may result in emergency incidents, it will be the responsibility of the Site Supervisor and Site Safety Officer (SSO), through daily site inspections and employee feedback (Safety Observation Program, daily safety meetings, and activity hazard analyses) to recognize and identify all hazards that are found at the site. These may include:

Chemical Hazards

Physical Hazards

Mechanical Hazards

Environmental Hazards

• Materials at the site • Materials brought to the site

• Fire/explosion • Slip/trip/fall • Electrocution • Confined space • IDLH atmospheres • Excessive noise

• Heavy equipment • Stored energy system • Pinch points • Electrical equipment • Vehicle traffic

• Electrical Storms • High winds • Heavy Rain/Snow • Temperature Extremes (Heat/Cold Stress) • Poisonous Plants/Animals

Once a hazard has been recognized, the Site Supervisor and/or the SSO will take immediate action to prevent the hazard from becoming an emergency. This may be accomplished by the following:

• Daily safety meeting • Task-specific training prior to commencement of activity • Lock-out/tag-out • Personal Protective Equipment (PPE) selection/use


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^ ^ ^ ^ OlliVI Remediation

X~ ^^==" Services Corp. ! = ' •• A SabcUivT of OHH Coraontle A SabcUivT of OHH Corpontlen


Written and approved permits for hot work, confined space Trenching/shoring procedure Air monitoring Following all OHM standard operating procedures Practice drills for fire, medical emergency, and hazardous substances spills

TABLE 8.1

1 EMERGENCY TELEPHONE NUMBERS j

Local Agencies Alcoa Fire Department, Massena, NY Fire Department - Massena, NY Police - Massena, NY Massena Rescue Squad, Massena, NY

Hospital - Massena Memorial

From: Alcoa plant site, main gate, go west on Park Ave., 1/5 mile, then south on Alcoa Road across the Massena Power canal approximately 1/2 mile, turn right at the stop light onto Center Street and proceed about 1/2 mile, cross Main Street, and continue west on Maple Street for about 2/3 mile, go right onto Hospital Drive, Hospital on left.

Regional Poison Control Center

State Agencies New York State Department of Environmental Conservation

Federal Agencies EPA Region Branch Response Center Edison, NJ National Response Center

Project Manager Eric Medlin Director, Health and Safety Kevin McMahon

OHM Corporation (24 hour)

1 Additional Phone #'s in Section 2 this HASP

315-764-4128 (located at Clockhouse #1) 315-769-2464 Ext 4500 315-769-3577 315-764-0313

315-764-1711

800-252-5655

315-769-8401

908-548-8730

800-424-8802

412-963-2300

800-537-9540

8.3 PERSONNEL ROLES. LINES OF AUTHORITY. AND COMMUNICATIONS

This section of the ERCP describes the various roles, responsibilities, and communication procedures that will be followed by personnel involved in emergency responses.

The primary emergency coordinator for this site is the Site Supervisor. In the event an emergency occurs and the emergency coordinator is not on site, the Site Safety Officer or the highest ranking employee on site will serve as the emergency coordinator until he arrives. The emergency coordinator will determine the nature of the emergency and take appropriate action as defined by this ERCP.


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< ^ selJlercolp^"*'" EMERGENCY RESPONSE AND • ' A SoMiUvJ of OHH Carporatioo ^ ^ — ^

CONTINGENCY PLAN

The emergency coordinator will implement the ERCP immediately as required. The decision to implement the plan will depend upon whether the actual incident threatens human health or the environment. Immediately after being notified of an emergency incident, the emergency coordinator or his designee will evaluate the situation to determine the appropriate action.

8.3.1 Responsibilities and Duties

This section describes the responsibilities and duties assigned to the emergency coordinator.

It is recognized that the structure of the "Incident Command System" will change as additional response organizations are added. OHM will follow procedures as directed by the fire department, LEPC, State and Federal Agencies as required. OHM will defer to the local Fire Department chief to assume the role of Incident Commander upon arriving on site. Additional on-site personnel may be added to the Site Emergency Response Team as required to respond effectively.

8.3.2 On-site Emergency Coordinator Duties

The on-site emergency coordinator is responsible for implementing and directing the emergency procedures. All emergency personnel and their communications will be coordinated through the emergency coordinator. Specific duties are as follows:

• Identify the source and character of the incident, type and quantity of any release. Assess possible hazards to human health or the environment that may result directly from the problem or its control.

• Discontinue operations in the vicinity of the incident if necessEuy to ensure that fires, explosions, or spills do not recur or spread to other parts of the site. While operations are dormant, monitor for leaks, pressure build-up, gas generation, or ruptures in valves, pipes, or other equipment, where appropriate.

• Notify The Client Representative. The Client Representative will determine what additional help is necessary to control the incident.

• Direct on-site personnel to control the incident until, if necessary, outside help arrives. Specifically:

• Ensure that the building or area where the incident occurred and the surrounding area are evacuated and shut off possible ignition sources, if appropriate. The Emergency Response Team is responsible for directing site personnel such that they avoid the area of the incident and leave emergency control procedures unobstructed.

• If fire or explosion is involved, notify local Fire Department.

• Have protected personnel, in appropriate PPE, on standby for rescue.

If the incident may threaten human health or the environment outside of the site, the emergency coordinator should immediately determine whether evacuation of area outside of the site may be necessary and, if so, notify the Police Department and the Office of Emergency Management.


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< m Se"'"°" EMERGENCY RESPONSE AND ^ — ABDbsliUujofOHHCorponrtloD ^ - f — ^

CONTINGENCY PLAN

When required, notify the National Response Center. The following information should be provided to the National Response Center:

Name and telephone number Name and address of facility Time and type of incident Name and quantity of materials involved, if known Extent of injuries Possible hazards to human health or the environment outside of the facility.

The emergency telephone number for the National Response Center is 800-424-8802.

If hazardous waste has been released or produced through control of the incident, ensure that:

• Waste is collected and contained.

• Containers of waste are removed or isolated from the immediate site of the emergency.

• Treatment or storage of the recovered waste, contaminated soil or surface water, or any other material that results from the incident or its control is provided.

• Ensure that no waste that is incompatible with released material is treated or stored in the facility until cleanup procedures are completed.

• Ensure that all emergency equipment used is decontaminated, recharged, and fit for its intended use before operations are resumed.

• Notify the USEPA Regional Administrator that cleanup procedures have been completed and that all emergency equipment is fit for its intended use before resuming operations in the affected area of the facility. The USEPA Regional Administrator's telephone number is included in the Emergency Contacts.

• Record time, date, and details of the incident, and submit a written report to the USEPA Regional Administrator. Report is due to USEPA within 15 days of the incident.

8.4 SAFE DISTANCES AND PLACES OF REFUGE

The emergency coordinator for all activities will be the Response Manager. No single recommendation can be made for evacuation or safe distances because of the wide variety of emergencies which could occur. Safe distances can only be determined at the time of an emergency based on a combination of site and incident-specific criteria. However, the following measures are established to serve as general guidelines.

In the event of minor hazardous materials releases (small spills of low toxicity), workers in the affected area will report initially to the contamination reduction zone. Small spills or leaks (generally less than 55 gallons) will require initial evacuation of at least 50 feet in all directions to allow for cleanup and to prevent exposure. After initial assessment of the extent of the release and potential hazards, the emergency coordinator or his designee will determine the specific boundaries for evacuation. Appropriate steps such as caution tape, rope, traffic cones, barricades, or personal monitors will be used to secure the boundaries.


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^ m SeUles coiT?""" EMERGENCY RESPONSE AND ^ ^ ^ ^ A Bnbftdivj of OHH Corpor^len ^ ->f — ^

CONTINGENCY PLAN In the event of a major hazardous material release (large spills of high toxicity/greater than 55 gallons),

workers will be evacuated from the building/site. Workers will assemble at the entrance to the site for a head count by their foremen and to await further instruction.

If an incident may threaten the health or safety of the surrounding community, the public will be informed and, if necessary, evacuated from the area. The emergency coordinator, or his designee will inform the proper agencies in the event that this is necessary. Telephone numbers are listed in Table 8.1.

Places of refuge will be established prior to the commencement of activities. These areas must be identified for the following incidents:

Chemical release Fire/explosion Power loss Medical emergency Hazardous weather

In general, evacuation will be made to the crew trailers, unless the emergency coordinator determines otherwise. It is the responsibility of the emergency coordinator to determine when it is necessary to evacuate personnel to off-site locations.

In the event of an emergency evacuation, all the employees will gather at the entrance to the site until a head count establishes that all are present and accounted for. No one is to leave the site without notifying the emergency coordinator.

8.5 EVACUATION ROUTES AND PROCEDURES

All emergencies require prompt and deliberate action. In the event of an emergency, it will be necessary to follow an established set of procedures. Such established procedures will be followed as closely as possible. However, in specific emergency situations, the emergency coordinator may deviate from the procedures to provide a more effective plan for bringing the situation under control. The emergency coordinator is responsible for determining which situations require site evacuation.

8.5.1 Evacuation Signals and Routes

Two-way radio communication and an air horn will be used to notify employees of the necessity to evacuate an area or building involved in a release/spill of a hazardous material. Each crew supervisor will have a two way radio. A base station will be installed in the OHM office trailer to monitor for emergencies. Total site evacuation will be initiated only by the emergency coordinator, however, in his absence, decision to preserve the health and safety of employees will take precedence. Evacuation routes will be posted in each outside work area. Signs inside buildings will be posted on walls or other structural element of a building. Periodic drills will be conducted to familiarize each employee with the proper routes and procedures.

8.5.2 Evacuation Procedures

In the event evacuation is necessary, the following actions will be taken:

• The emergency signal will be activated.


8-6

< m sirvlceXl """ EMERGENCY RESPONSE AND • • ^ " ' ASaMdiarrofOHHCorporktlen ,^-« .—^

CONTINGENCY PLAN • No further entry of visitors, contractors, or trucks will be permitted. Vehicle traffic within the site

will cease in order to allow safe exit of personnel and movement of emergency equipment.

• Shut off all machinery if safe to do so.

• ALL on-site personnel, visitors, and contractors in the support zone will assemble at the entrance to the site for a head count and await further instruction from the emergency coordinator.

• ALL persons in the exclusion zone and contamination reduction zone will be accounted for by their immediate crew leaders (e.g., foreman). Leaders will determine the safest exits for employees and will also choose an alternate exit if the first choice is inaccessible.

• During exit, the crew leader should try to keep the group together. Immediately upon exit, the crew leader will account for all employees in his crew.

• Upon completion of the head count, the crew leader will provide the information to the emergency coordinator.

• Contract personnel and visitors will also be accounted for.

• The names of emergency response team members involved will be reported to the emergency spill control coordinator.

• A final tally of persons will be made by the emergency coordinator or designee. No attempt to find persons not accounted for will involve endangering lives of OHM or other employees by re-entry into emergency areas.

• In all questions of accountability, immediate crew leaders will be held responsible for those persons reporting to them. Visitors will be the responsibility of those employees they are seeing. Contractors and truck drivers are the responsibility of the Site Supervisor. The security guard will aid in accounting for visitors, contractors, and truckers by reference to sign-in sheets available from the guard shack.

• Personnel will be assigned by the emergency coordinator to be available at the main gate to direct and brief emergency responders.

• Re-entry into the site will be made only after clearance is given by the emergency coordinator. At his direction, a signal or other notification will be given for re-entry into the facility.

• Drills will be held periodically to practice all of these procedures and will be treated with the same seriousness as an actual emergency.

8.6 EMERGENCY SPILL RESPONSE PROCEDURES AND EOUIPMENT

In the event of an emergency involving a hazardous material spill or release, the following general procedures will be used for rapid and safe response and control of the situation. Emergency contacts found in Table 8.1 provide a quick reference guide to follow in the event of a major spill.


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^ m servleerco?"" EMERGENCY RESPONSE AND ^ — ASakflUivjofOHHCorporatlBB ^ ^ . ^

CONTINGENCY PLAN

8.6.1 Notification Procedures

If an employee discovers a chemical spill or process upset resulting in a vapor or material release, he or she will immediately notify the on-site emergency coordinator.

On-site Emergency Coordinator will obtain information pertaining to the following:

The material spilled or released. Location of the release or spillage of hazardous material. An estimate of quantity released and the rate at which it is being released. The direction in which the spill, vapor or smoke release is heading. Any injuries involved. Fire and/or explosion or possibility of these events. The area and materials involved and the intensity of the fire or explosion.

This information will help the on-site emergency coordinator to assess the magnitude and potential seriousness of the spill or release.

8.6.2 Procedure for Containing/Collecting Spills

The initial response to any spill or discharge will be to protect human health and safety, and then the environment. Identification, containment, treatment, and disposal assessment will be the secondary response. The Client representative will be notified of any releases of sediment from the silt-screened area or liquids from the land based operation into the Grasse River.

If for some reason a chemical spill is not contained within a dike or sump area, an area of isolation will be established around the spill. The size of the area will generally depend on the size of the spill and the materials involved. If the spill is large (greater than 55 gallons) and involves a tank or a pipeline rupture, an initial isolation of at least 100 ft. in all directions will be used. Small spills (less than or equal to 55 gallons) or leaks from a tank or pipe will require evacuation of at least 50 ft. in all directions to allow cleanup and repair and to prevent exposure. When any spill occurs, only those persons involved in overseeing or performing emergency operations will be allowed within the designated hazard area. If possible the area will be roped or otherwise blocked off

If the spill results in the formation of a toxic vapor cloud (by reaction with surrounding materials or by outbreak of fire) and its release (due to high vapor pressures under ambient conditions), further evacuation will be enforced. In general an area at least 500 feet wide and 1,000 feet long will be evacuated downwind if volatile materials are spilled. (Consult the DOT Emergency Response Guide for isolation distances for listed hazardous materials.)

If an incident may threaten the health or safety of the surrounding community, the public will be informed and possibly evacuated from the area. The on-site emergency coordinator will inform the proper agencies in the event this is necessary. (Refer to Table 8.1)

As called for in regulations developed under the Comprehensive Environmental Response Compensation Liability Act of 1980 (Superfund), OHM's practice is to report a spill of a pound or more of any hazardous material for which a reportable quantity has not been established and which is listed under the Solid Waste Disposal Act, Clean Air Act, Clean Water Act, or TSCA. OHM also follows the same practice for any substances not listed in the Acts noted above but which can be classified as a hazardous waste under RCRA.


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_ ^ ^ s ^ ^ OIIM I{emediation

X~ ^ = ' Services Corp. ^ = ^ A S o M d l v ; of OHH Corporation


Clean up personnel will take the following measures:

Make sure all unnecessary persons are removed from the hazard area.

Put on protective clothing and equipment.

If a flammable material is involved, remove all ignition sources, and use spark and explosion proof equipment for recovery of material.

Remove all surrounding materials that could be especially reactive with materials in the waste. Determine the major components in the waste at the time of the spill.

If wastes reach a storm sewer, try to dam the outfall by using sand, earth, sandbags, etc. If this is done, pump this material out into a temporary holding tank or drums as soon as possible.

Place all small quantities of recovered liquid wastes (55 gallons or less) and contaminated soil into drums for incineration or removal to an approved disposal site.

Spray the spill area with foam, if available, if volatile emissions may occur.

Apply appropriate spill control media (e.g. clay, sand, lime, etc.) to absorb discharged liquids.

For large spills, establish diking around leading edge of spill using booms, sand, clay or other appropriate material. If possible, use diaphragm pump to transfer discharged liquid to drums or holding tank.

8.6.3 Emergency Response Equipment

The following equipment will be staged in the support zone and throughout the site, as needed, to provide for safety and first aid during emergency responses.

ABC-type fire extinguisher First-aid kit, industrial size Eyewash/safety shower Emergency oxygen unit Emergency signal horn Self contained breathing apparatus (two) Stretcher/backboard

In addition to the equipment listed above, OHM maintains direct reading instrumentation that may be used in emergency situations to assess the degree of environmental hazard. This equipment will only be used by the Site Safety Officer or other specially trained personnel. This equipment will be stored, charged and ready for immediate use in evaluating hazardous chemical concentrations. The equipment will be located at the OHM office trailer.


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_ ^ - ^ ^ OILM Remediation

X~ ^ ^ Services Coip. — K S u b t t d l u ; ofOHMCorporttiOB


EQUIPMENT NAME

Portable H-NU Photoionization Meter

MSA Oxygen and Combustible Gas Meter

Draeger Detector Tubes

APPLICATION

Measures selected inorganic and organic chemical concentrations

Measures oxygen and combustible gas levels

Assorted detector tubes to measure specific chemical concentrations

8.6.4 Personal Protective Equipment

A supply of two (minimum) SCBAs will be located in the support zone for use in emergency response to hazardous materials releases. They will be inspected at least monthly, according to OSHA requirements. In addition, all emergency response personnel will have respirators available for use with cartridge selection determined by the Site Safety Officer based on the results of direct reading instruments. Emergency response personnel will also be provided with protective clothing as warranted by the nature of the hazardous material and as directed by the Site Safety Officer.

8.6.5 Emergency Spill Response Clean-Up Materials and Equipment

A sufficient supply of appropriate emergency response clean-up and personal protective equipment will be inventoried and inspected, visually, on a weekly basis.

The materials listed below will be kept on site for spill control, depending on the types of hazardous materials present on site. The majority of this material will be located in the support zone, in a supply trailer or storage area. Small amounts will be placed on pallets and located in the active work areas.

• Sand or clay to solidify/absorb liquid spills.

• Lime (calcium oxide), soda ash (sodium carbonate), or baking soda (sodium bicarbonate) for neutralizing acid (pH <7) spills.

• Activated charcoal (carbon) to adsorb organic solvents (hydrocarbons) and to reduce flammable vapors.

• Citric acid for neutralizing caustic (pH >7) spills.

• Vapor-suppressing foam, if required by the Client, for controlling the release of volatile organic compounds.

• Appropriate solvents e.g. CITRIKLEEN, for decontamination of structures or equipment.

The following equipment will be kept on site and dedicated for spill cleanup:

Plastic shovels for recovering corrosive and flammable materials. Sausage-shaped absorbent booms for diking liquid spills, drains, or sewers. Sorbent sheets (diapers) for absorbing liquid spills. Overpack drums for containerizing leaking drums. 55-gallon open-top drums for containerization of waste materials.


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< ^ See" ' " " " EMERGENCY RESPONSE AND ^ ^ ^ r . . . ^ ASaMdUryofOHHCorpontloB ^^— . ^

CONTINGENCY PLAN

*NOTE: All contaminated soils, absorbent materials, solvents and other materials resulting from the clean-up of spilled or discharged substances shall be properly stored, labelled, and disposed of off-site.

8.7 EMERGENCY CONTINGENCY PLAN

This section of the ERCP details the contingency measures OHM will take to prepare for and respond to fires, explosions, spills and releases of hazardous materials, hazardous weather, and medical emergencies.

8.8 MEDICAL EMERGENCY CONTINGENCY MEASURES

The procedures listed below will be used to respond to medical emergencies.

8.8.1 Response

The nearest workers will immediately assist a person who shows signs of medical distress or who is involved in an accident. The work crew supervisor will be summoned.

The work crew supervisor will immediately make radio contact with the on-site emergency coordinator to alert him of a medical emergency situation. The supervisor will advise the following information:

• Location of the victim at the work site • Nature of the emergency • Whether the victim is conscious • Specific conditions contributing to the emergency, if known

The Emergency Coordinator will notify the Site Safety Officer. The following actions will then be taken depending on the severity of the incident:

• Life-Threatening Incident ~ If an apparent life-threatening condition exists, the crew supervisor will inform the emergency coordinator by radio, and the local Emergency Response Services (EMS) will be immediately called. An on-site person will be appointed who will meet the EMS and have him/her quickly taken to the victim.

• Non Life-Threatening Incident ~ If it is determined that no threat to life is present, the Site Safety Officer will direct the injured person through decontamination procedures (see below) appropriate to the nature of the illness or accident. Appropriate first aid or medical attention will then be administered.

*NOTE: The area surtounding an accident site must not be disturbed until the scene has been cleared by the Site Safety Officer.

Any personnel requiring emergency medical attention will be evacuated from exclusion and contamination reduction zones if doing so would not endanger the life of the injured person or otherwise aggravate the injury. Personnel will not enter the area to attempt a rescue if their own lives would be threatened. The decision whether or not to decontaminate a victim prior to evacuation is based on the type and severity of the illness or injury and the nature of the contaminant. For some emergency victims, immediate decontamination may be an essential part of life-saving first aid. For others, decontamination may aggravate


8-11

< ^ s e S col ''"" EMERGENCY RESPONSE AND ^ • ^ ' — ASobi ld l i /yofOHHCorpor tUoi i ^ ^ ^ . ^

CONTINGENCY PLAN the injury or delay life-saving first aid. Decontamination will be performed if it does not interfere with essential treatment.

If decontamination can be performed, observe the following procedures:

• Wash external clothing and cut it away.

If decontamination cannot be performed, observe the following procedures:

• Wrap the victim in blankets or plastic to reduce contamination of other personnel.

• Alert emergency and off-site medical personnel to potential contamination, instruct them about specific decontamination procedures.

• Send site personnel familiar with the incident and chemical safety information, e.g. MSDS, with the affected person.

All injuries, no matter how small, will be reported to the SSO or the Site Supervisor. An accident/injury/illness report will be completely and properly filled out and submitted to the Regional Health and Safety Director/Project CIH, in accordance with OHM's reporting procedures.

A list of emergency telephone numbers is given in Table 8.1.

8.8.2 Notification

The following personnel/agencies will be notified in the event of a medical emergency:

• Alcoa Fire Department, Local Fire Department or EMS

• On-site Emergency Coordinator • Workers in the affected areas • Client Representative

8.8.3 Directions To Hospital

Written directions to the hospital and a map will be posted in all trailers in the staging area. Directions to the hospital are as follows:

From: Alcoa plant site, main gate, go west on Park Ave., 1/5 mile, then south on Alcoa Road across the Massena Power canal approximately 1/2 mile, turn right at the stop light onto Center Street and proceed about 1/2 mile, cross Main Street, and continue west on Maple Street for about 2/3 mile, go right onto Hospital Drive, Hospital on left.

8.9 FIRE CONTINGENCY MEASURES

Because flammable/combustible materials are present at this site, fire is an ever-present hazard. OHM personnel and subcontractors are not trained professional firefighters. Therefore, if there is any doubt that a fire can be quickly contained and extinguished, personnel will notify the emergency coordinator by radio and vacate the structure or area. The emergency coordinator will immediately notify the Alcoa Fire Department.


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c m s e S coS '"" EMERGENCY RESPONSE AND ^ ^ • ^ - • A BulMfaUuT of OHH Corporation ^ ^ ^ — ^

CONTINGENCY PLAN

The following procedures will be used to prevent the possibility of fires and resulting injuries:

• Sources of ignition will be kept away from where flammable materials are handled or stored.

• The air will be monitored for explosivity before and during hot work and periodically where flammable materials are present. Hot work permits will be required for all such work.

• "No smoking" signs will be conspicuously posted in areas where flammable materials are present.

• Fire extinguishers will be placed in all areas where a fire hazard may exist.

• Before workers begin operations in an area the foreman will give instruction on egress procedures and assembly points. Egress routes will be posted in work areas and exit points clearly marked.

8.9.1 Response

The following procedures will be used in the event of a fire:

• Anyone who sees a fire will notify their supervisor who will then contact the Emergency Coordinator by radio. The emergency coordinator will activate the emergency air horns and contact the Alcoa Fire Department.

• When the emergency siren sounds, workers will disconnect electrical equipment in use (if possible) and proceed to the nearest fire exit.

• Work crews will be comprised of pairs of workers (buddy system) who join each other immediately after hearing the fire alarm and remain together throughout the emergency. Workers will assemble at a predetermined rally point for a head count.

• When a small fire has been extinguished by a worker, the emergency coordinator will be notified.

8.10 HAZARDOUS WEATHER CONTINGENCY MEASURES

Operations will not be started or continued when the following hazardous weather conditions are present:

• Lightning • Heavy Rains/Snow • High Winds

8.10.1 Response

• Excavation/soil stock piles will be covered with plastic liner.

• All equipment will be shut down and secured to prevent damage.

• Personnel will be moved to safe refuge, initially crew trailers. The emergency coordinator will determine when it is necessary to evacuate personnel to off-site locations and will coordinate efforts with fire, police and other agencies.


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< ^ seJvLercor?""" EMERGENCY RESPONSE AND ^ — ASaMdiu-jofOHHCerporotloB ^ ^ ^ . ^

CONTINGENCY PLAN 8.10.2 Notification

The emergency coordinator will be responsible for assessing hazardous weather conditions and notifying personnel of specific contingency measures. Notifications will include:

• OHM employees and subcontractors • Client Representative • Local Civil Defense Organization

8.11 SPILL/RELEASE CONTINGENCY MEASURES

In the event of release or spill of a hazardous material the following measures will be taken:

8.11.1 Response

Any person observing a spill or release will act to remove and/or protect injured/contaminated persons from any life-threatening situation. First aid and/or decontamination procedures will be implemented as appropriate. First aid will be administered to injured/contaminated personnel. Unsuspecting persons/vehicles will be warned of the hazard. All personnel will act to prevent any unsuspecting persons from coming in contact with spilled materials by alerting other nearby persons. Attempt to stop the spill at the source, if possible. Without taking unnecessary risks, personnel will attempt to stop the spill at the source. This may involve activities such as uprighting a drum, closing a valve or temporarily sealing a hole with a plug.

Utilizing radio communications, the emergency coordinator will be notified of the spill/release, including information on material spilled, quantity, personnel injuries and immediate life threatening hazards. Air monitoring will be implemented by the emergency coordinator and SSO to determine the potential impact on the surrounding community. Notification procedures will be followed to inform on-site personnel and off-site agencies. The emergency coordinator will make a rapid assessment of the spill/release and direct confinement, containment and control measures. Depending upon the nature of the spill, measures may include:

• construction of a temporary containment berm utilizing on-site clay absorbent earth

• digging a sump, installing a polyethylene liner and

• diverting the spill material into the sump placing drums under the leak to collect the spilling material before it flows over the ground

• transferring the material from its original container to another container

The emergency coordinator will notify the Client Representative of the spill and steps taken to institute clean-up. Emergency response personnel will clean-up all spills following the spill clean-up plan developed by the emergency coordinator. Supplies necessary to clean up a spill will be immediately available on-site. Such items may include, but are not limited to:

• Shovel, rake • Clay absorbent • Polyethylene liner


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c m S K coJ """" EMERGENCY RESPONSE AND ^ — A SabiUlvj of OHH CorporttlM -— _ ^

CONTINGENCY PLAN

• Personal safety equipment • Steel drums • Pumps and miscellaneous hand tools

The major supply of material and equipment will be located in the Support Zone. Smaller supplies will kept at active work locations. The emergency coordinator will inspect the spill site to determine that the spill has been cleaned up to the satisfaction of the Client. If necessary, soil, water or air samples may be taken and analyzed to demonstrate the effectiveness of the spill clean-up effort. The emergency coordinator will determine the cause of the spill and determine remedial steps to ensure that recurrence is prevented. The emergency coordinator will review the cause with the Client Representative and obtain his concurrence with the remedial action plan.


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9.0 TRAINING REQUIREMENTS

As a prerequisite to employment at OHM, all field employees are required to take a 40-hour training class and pass a written examination. This training covers all forms of personal protective equipment, toxicological effects of various chemicals, hazard communication, bloodbome pathogens, handling of unknown tanks and drums, confined-space entry procedures, and electrical safety. This course is in full compliance with OSHA requirements in 29 CFR 1910.120. In addition, all employees receive annual 8-hour refresher training and three day on-site training under a trained experienced supervisor. Supervisory personnel receive an additional 8-hour training in handling hazardous waste operations.

All personnel entering the exclusion zone will be trained in the provisions of this site safety plan and be required to sign the Health and Safety Plan Certification in Appendix A.

Site-specific training for the ALCOA, Massena, New York Grasse River Study Area site, which will include potential site contaminants, site physical and environmental hazards, emergency response and evacuation procedures, and emergency telephone numbers and will be held at the site location by the SS and SSO before any site work activities begin.

OHM Project 15946HS Aluminum Company of America Febmary 23, 1995 Information herein is proprietary and confidential and to be used or relecLsed to others only with explicit written permission of OHM Remediation Services Corp.

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10.0 MEDICAL SURVEILLANCE PROGRAM

All OHM personnel participate in a medical and health monitoring program. This program is initiated when the employee starts work with a complete physical and medical history and is continued on a regular basis. A listing of OHM's worker medical profile is shown below. This program was developed in conjunction with a consultant toxicologist. Other medical consultants are retained when additional expertise is required.

The medical surveillance program meets the requirements of the OSHA Standard 29 CFR 1910.120 (f).

TABLE 10.1

WORKER MEDICAL PROFILE

Item

Medical History

Work History

Visual Acuity and Tonometry

Pulmonary Function Tests

Physical Examination

Audiometry Tests

Chest X-Ray

Complete Blood Counts

Blood Chem. (SSAC-23 or equivalent)

Urinalysis

Dermatology Examination

Electrocardiogram/Stress Test

Initial

X

X

X

X

X

X

X

X

X

X

X

X

Annual

X

X

X

X

X

X

X

X

X

X

X

X (based on age)

Specific Tests (as required): (PCB blood or fat, urine mercury, urine arsenic, urine phenol, urine halomethanes, blood cyanide,

cholinesterase-pseudo-cholesterase, nerve conduction velocity tests, blood lead, urine lead.)

10.1 EXAMINATION SCHEDULE

Employees are examined initially upon start of employment, annually thereafter, and may be examined upon termination of employment. Unscheduled medical examinations are conducted:

• At employee request after known or suspected exposure to toxic or hazardous materials


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• At the discretion of the client, the CIH, SSO, or OHM occupational physician after known or suspected exposure to toxic or hazardous materials

• At the discretion of the OHM occupational physician

All nonscheduled medical examinations will include, as a minimum, all items specified above for periodic surveillance examination, with the exception of the chest X-ray, which will be conducted at the discretion of the occupational physician performing the examination.

OHM Project 15946HS Aluminum Company of America Febmary 23, 1995 Information herein is proprietary and confidential and to be used or released to others only with explicit written permis.sion of OHM Remediation Services Corp.

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APPENDIX A

HEALTH AND SAFETY PLAN CERTIFICATION

HEALTH-AND-SAFETY PLAN CERTIFICATION

By signing this document, I am stating that I have read and understand the site health-and-safety plan for OHM Remediation Services Corp. personnel and visitors entering the Grasse River site.

REPRESENTING NAME (PRINT) SIGNATURE DATE

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APPENDIX B OHM HAZARD COMMUNICATION PROGRAM

APPENDIX B OHM HAZARD COMMUNICATION PROGRAM

OB.TECTIVE

A Hazard Communication (Employee Right-To-Know) Program will be instituted at all OHM Remediation Services Corp. (OHM) facilities and job-sites. A copy of the written Hazard Communication Program contained in this procedure will be present at all OHM job-sites, shops, and facilities.

PURPOSE

The purpose of Hazard Communication (Employee Right-to-Know) is to ensure that the hazards of all chemicals located at field project sites, shops, and facilities are transmitted (communicated), according to 29 CFR 1910.1200 and 29 CFR 1926.59 to all OHM personnel and OHM subcontractors.

GENERAL REQUIREMENTS

3.1 It is the responsibility of site supervisors, shop supervisors, and facilities managers to ensure that the Hazard Communication Program for the area under their supervision is updated as necessary.

3.2 Container Labeling-OHM personnel will ensure that all drums and containers are labeled according to contents. These drums and containers will include those from manufacturers and those produced by on site operations. All incoming and outgoing labels shall be checked for identity, hazard warning, and name and address of responsible party.

3.3 Material Safety Data Sheets (MSDSs)-There will be an MSDS located on site for each hazardous chemical known to exist or which is being used on site. All MSDSs will be located in the site health and safety plan which can be found in the office trailer. MSDS's for products in use may be stored in a separate binder.

3.4 Employee Information and Training—Training employees on chemical hazards is accomplished through an ongoing corporate and regional training program. Additionally, chemical hazards will be communicated to employees through daily safety meetings held at OHM field projects and by an initial site orientation program.

3.5 OHM employees will be instructed on the following:

Chemicals and their hazards in the work area How to prevent exposure to these hazardous chemicals What the company has done to prevent workers' exposure to these chemicals Procedures to follow if they are exposed to these chemicals How to read and interpret labels and MSDSs for hazardous substances Emergency spill procedures Proper storage and labeling

3.6 Before any new hazardous chemical is introduced on site, each employee will be given information in the same manner as during the initial safety class. The site supervisor will be responsible for seeing that the MSDS on the new chemical is available. During the mandatory morning safety briefing, information on each new chemical will be presented.

Should any new chemical be brought on site, the appropriate MSDSs will be added and reviewed with the employees.


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^ "°""'-'°"'"' OHM HAZARD COMMUNICATION PROGRAM

1.0 GENERAL

The following written hazard communication program has been established for OHM Corporation. The purpose of this program is to transmit information about the various Chemical hazards in the work place to the workers using various media. The transmittal of information will be accomplished by means of a comprehensive hazard communication program, which will include container labeling and other forms of warning, material safety data sheets, and employee training in accordance with 29 CFR 1910.1200 and 29 CFR 1926.59.

The program will be available in corporate and regional Health and Safety Departments for reviews by all employees. It will also be available in the corporate library and clearly marked "Employee Right-to-Know" stations located within each individual shop and on each job site. OHM Corporation will accomplish the hazard communication requirements through formal safety training, departmental safety meetings, and job site safety meetings.

2.0 RESPONSIBILITIES

Purpose: Overall responsibility rests with all corporate officers of OHM Corporation. A brief outiine of responsibilities for those persons directiy involved with the program will follow. These responsibilities are not all inclusive, but are designed to give guidance in initial and long-term program development since each area is different. These responsibilities may vary.

Scope: This program is intended to cover those employees who are directly involved with the handling of hazardous materials or supervision of those activities.

2.1 Health and Safety Department Responsibilities

1. Review operations with supervisors to determine what tasks require hazard communication training.

2. Advise supervisory people as to which materials may need to be considered hazardous initially and eventually to ensure that hazard task determination is being done according to the written policy.

3. Follow up through safety meetings and safety audits to ensure that supervisors are carrying out prescribed company policy.

4. Notify supervisors of any operating changes affecting the hazardous materials being used.

5. Periodically audit the Hazard Communication Program's progress. Initially, this should be done biweekly, but later the audit may be done on a monthly or quarterly basis.

2.2 Training Department Responsibilities

1. Ensure that up-to-date records are maintained on training of all employees required to handle hazardous materials. The supervisor should keep copies of these records and should also send copies of the initial training to the corporate training secretary for the training file.

2. Educate personnel upon initial training to the requirements of the Hazard Communication Standard.

2.3 Supervisor Responsibilities

1. Identify jobs requiring the use of hazardous chemicals and provide lists of those jobs and chemicals to the Health and Safety Department.

2. Provide the training required by the Hazard Communication Standard and document training of employees in the safe handling of hazardous materials.


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> ^ >. .,o.o,,c...r... OHM HAZARD COMMUNICATION PROGRAM

3. Inspect engineering controls and personal protective equipment before each use. Health and Safety can help determine a suitable inspection plan for each application as needed.

4. Make daily surveys of the work area to ensure that safe practices are being followed. Advise employees of unsafe work practices on the first occasion and consider further violations as disciplinary violations.

5. Ensure required labeling practices are being followed. Labeling should be affixed to the container when it arrives. If the contents are transferred to another container, then all label information (manufacturer, product name, and product number) must also be affixed to the new container, so that all containers of the material, regardless of size, are labeled.

6. Enforce all applicable safety and health standards through periodic audits.

7. Before ordering a material, determine if a Material Safety Data Sheet exist on file. Request an MSDS for any material without one.

8. Send all new MSDSs to the Health and Safety Department after making a copy for the Employee Right-to-Know file.

2.4 Employee Responsibilities

1. Obey established safety rules and regulations

2. Use all safety procedures and personnel protective equipment as required by company procedures

3. Notify supervisor of the following:

a. Any symptoms or unusual effects that may be related to the use of hazardous chemicals. b. Any missing or unreadable labels on containers.

c. Missing, damaged, or malfunctioning safety equipment.

4. Use approved labels on containers; do not remove labels (labels will be located in the warehouse).

5. Do not use unapproved containers for hazardous materials. (Is material and container compatible?) 6. Know where emergency equipment and first-aid supplies are located before considering a possibly

dangerous task.

7. Know location of Material Safety Data Sheets (MSDS). These will be located in the "Employee Right-to-know" station for the respective shop/job site.

8. Know what you are expected to do in case of an emergency. Before the commencement of any task, emergency considerations shall be made.

2.5 Shipping/Receiving Personnel Responsibilities

1. Ensure MSDS are received with initial shipment of a hazardous material; if not, contact purchasing to request the appropriate MSDS and also call the Health and Safety Department to determine if there is an MSDS available until the requested MSDS arrives.

2. Ensure labels are affixed to all containers.

3. Store hazardous materials in designated locations.


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> _ .. ..,o,o™„. OHM HAZARD COMMUNICATION PROGRAM

4. Use proper personal protective equipment when handling hazardous materials.

5. Report damaged containers or spills to the appropriate Health and Safely Department immediately.

6. Request an MSDS from the manufacturer for any hazardous material that arrives in Findlay from a job. Also, a MSDS shall accompany any hazardous material that is sent to a job.

3.0 HAZARD DETERMINATION

OHM Corporation will rely on Material Safety Data Sheets from hazardous chemical supplies to meet hazard determination requirements. Other relevant data from laboratory analyses, chemical reference materials, and chemical manufacturers', written evaluation procedures will be utilized when warranted. No other method shall be used to determine chemical hazard unless approved by the Health and Safety.

4.0 LABELING

The shipping and receiving supervisors will be responsible for seeing that all containers arriving at OHM Corporation are properly and clearly labeled. Shipping and receiving supervisors shall also check all labels for chemical identity and appropriate hazard warnings. If the hazardous chemical is regulated by OSHA in a substance specific health standard, the supervisor or department manager shall ensure that the labels or other forms of warning used are in accordance with the requirements of that standard. Any container that is not labeled shall be immediately labeled correctiy after initial discovery.

Each supervisor or department manager shall be responsible for seeing that all portable containers used in their work area are properly labeled with chemical identity and hazard warning.

Supervisors or department managers shall also ensure that labels on hazardous chemical containers are not removed or defaced unless the container is immediately marked with the required information and that all labels are legible in English and prominentiy displayed on the container or readily available in the work area throughout each shift.

If any container is found and the contents cannot be identified, the supervisor or manager shall be contacted immediately. When proper identification is made, a label shall be affixed to the container immediately. If it is discovered that no MSDS is available, the manufacturer and the Health and Safety Department shall be contacted to assist in locating the proper MSDS. If there is no way to identify the material in the container, the container should be set aside, away from all personnel until it can be tested by the Health and Safety Department or laboratory personnel. Supervisors and managers shall communicate their findings or awareness of such containers to all personnel in the area and to those who enter later.

5.0 MATERIAL SAFETY DATA SHEETS (MSDS)

Each supervisor or department manager at OHM Corporation will be responsible for maintaining a current MSDS relevant to the hazardous chemicals used in their area. The Health and Safety Department will be responsible for compiling the master MSDS file for the facility and aiding all shops/job sites with the completion and maintenance of their respective MSDS files.

All MSDS will be readily available for review by all employees during each work shift. Each shop/job site will designate a clearly marked "Employee Right-to-know" station where employees can immediately obtain a MSDS and the required information in an emergency.

Although manufacturers are required to provide employers with MSDSs on an initial chemical shipment, OHM Corporation purchasing agents (and supervisors purchasing their own material) shall request MSDSs and updates to MSDS on all purchase orders. Supervisors and department managers that are without proper MSDSs shall be


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responsible for requesting this information from manufacturers for chemicals. A file of followup letters shall be maintained for all hazardous chemical shipments received without MSDSs.

6.0 EMPLOYEE INFORMATION AND TRAINING

It is the responsibility of the supervisor in charge of each employee to ensure that the employee is properly trained. Training employees on chemical hazards and chemical handling is accomplished at the time of initial employment at OHM Corporation, whenever a new chemical (or physical) hazard is introduced into the work area, and through ongoing formal and informal training programs. Additionally, chemical hazards are communicated to employees through daily, morning, shop specific safety meetings, which shall be documented according to topic, major points discussed, and names of those attending (attendance is mandatory). Also, biweekly hazardous chemical safety meetings will be prepared by the Health and Safety Department using similar documentation for shop areas. Attendance is mandatory for these meetings also. Documentation for shop safety meetings will be available in the respective Employee Right-to-know stations and biweekly safety meeting documentation will be available in the Health and Safety Department to all employees for these meetings also. Documentation for shop safety meetings will be available in the respective Employee Right-to know stations and biweekly safety meeting documentation will be available in the Health and Safety Department to all employees for further referencing and questioning. Records of all formal training conducted at OHM Corporation is coordinated and maintained by the Training Department secretary.

At a minimum, OHM Corporation will inform employees on the following:

• The requirements of 29 CFR 1910.1200—Hazard Communication—Evaluating the potential hazards of chemicals and communication information concerning hazards and appropriate protective measures to employees. This is accomplished in several different ways including, but no limited to 40-hour OSHA Hazardous Waste Worker Training (29 CFR 1910.120), Shop safety meetings, job site safety meetings. Health and Safety Department safety meetings, and formal and informal training about specific chemical hazards.

• The location and availability of the written hazard communication program, list of hazardous chemicals, and MSDS sheets-Notices will be periodically posted on the employee bulletin boards providing the location of the above material.

• Any operations in their work area where hazardous chemicals are present.

• What the company has done to lessen or prevent workers' exposure to these chemicals.

Employee training shall include at least:

• Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area, (monitoring instruments, visual appearance or odor), and acute and chronic health effects.

• The physical and health hazards of the chemicals in the work area (accomplished through periodic physical and chemical hazard awareness sessions developed by the Health and Safety Department). These sessions shall serve as chemical hazards refreshers.

• The methods of preventing exposure to hazardous chemicals including the measures OHM Corporation has taken to protect the employees.

• Procedures to follow if OHM Corporation employees are exposed to hazardous chemicals (location of nearest phone, emergency eyewash, and shower will be included). These discussions shall include proper operating procedures for all emergency equipment.


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• The details of the hazard communication program developed by OHM Corporation, including an explanation of the labeling system and the Material Safety Data Sheets, and how employees can obtain and use the appropriate hazard information.

• Standard operating procedures within each respective shop. OHM Corporation company policy determines what is considered standard operating procedures.

• Procedures for workers involved in non-routine tasks.

Each supervisor or department manager shall ensure that the above training is emphasized to OHM Corporation employees. The Health and Safety Department will ensure that each shop, department, and Job site is properly informing and training all employees through daily group meeting and individual discussions. Whenever a new hazardous chemical is placed into use, the supervisor or department manager shall inform the employees of the hazards said chemical may pose. The supervisor or manager shall also be responsible for obtaining and making available a MSDS for the new chemical.

7.0 HAZARDOUS NON-ROUTINE TASKS

Occasionally, employees at OHM Corporation are required to perform tasks which are considered to be non-routine. All tasks considered to be non-routine shall be carefully discussed among the supervisor and those performing the task. This safety briefing shall include all possible hazards that may be encountered while completing the task, including:

• Hazard recognition

• Chemicals involved and their hazardous properties

• Physical hazards

• Methods of avoiding all hazards (technical instruments, proper personal protective equipment, etc.)

The following is list of some of the non-routine tasks which may occur at OHM Corporation together with some information needed to complete the tasks safely.

• Confined Space Entry

Obtain confined space entry procedure/permit from Health and Safety Department and follow all protocol before beginning task, compete and have supervisor sign permit before any work begins.

Monitor atmosphere with explosimeter, oxygen meter, and any toxic gas meter as may be appropriate.

Discuss specific chemical hazards.

Discuss protective/safety measures the employee can take (e.g.. Personal protective equipment and engineering controls) use of life lines, lock-out/tagout procedures, etc.

Measures the company has taken to lessen the hazards including ventilation, respirator, presence of another employee, and emergency procedures.

• Excavation, Trenching, and Shoring

Obtain guidelines from Health and Safety Department before beginning task.


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Comply with all requirements set forth for this activity in 29 CFR Subpart P(excavating, trenching, shoring).

Discuss specific chemical hazards.

Follow confined space entry procedure above if trench is above shoulder height.

Discuss protective/safety measures the employee can take.

Review appropriate accident prevention steps.

• Decontamination of Equipment

Determine possible contaminants and the hazards associated with them.

Determine personal protection needed by contacting the Health and Safety Department.

Alert all personnel in areas of contamination and decontamination

Contain and secure all contaminated materials and decontamination materials.

Contact the Health and Safety Department for proper disposal.

It is company policy that no OHM Corporation employee will begin work on any non-routine task without first receiving a safety briefing from their supervisor or a Health and Safety Department representative.

8.0 INFORMING CONTRACTORS

• Hazardous chemicals to which they may be exposed while performing a task including the following:

Chemical properties Physical properties Acute/Chronic health effects

• Location of "Employee Right-to Know" station which includes the following:

MSDS for work area Hazard Communication Program Other relevant safety material

• Precautionary measures to be taken to protect employees from chemical and physical hazards.

• Location of nearest emergency equipment (fire extinguisher, eyewash, shower, phone, first-aid kit, etc.)

• Procedures to follow in the event of employee exposure.

• Steps OHM Corporation has taken to reduce the risk of exposure to physical and chemical hazards including the following:

Safety meetings Hazard Communication Program Proper storage and labeling of hazardous chemicals Health and Safety Department shop audits


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^ — — OHM HAZARD COMMUNICATION PROGRAM

• The methods used to label all hazardous chemicals.

The Health and Safety Department shall offer assistance in providing the above information to contractors working at OHM Corporation. On initial visit by a contractor to OHM Corporation, a "Contractor Right-to-Know" release form shall be completed. This form will state that the above information has been communicated to the perspective contractor.


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APPENDIX C MSDS LIST

Material Safety Data Sheet from Genium's Reference Collection

Genium Publishing COTporation 1145 Catalyn Street

Schenectady, NY I2303-I836 USA (518)377-8855 CENIUU PUBUSHINa CORP.

No. 683

POLYCHLORINATED BIPHENYLS (PCBs)

Issued: November 1988

SECTION 1. MATERIAL IDENTIFICATION 27 Material Name: POLYCHLORINATED BIPHENYLS (PCBs)

Description (Origin/Uses): Commercial PCBs are mixtures that were once widely manufactured by combioing chlorine gas, iron filings^ and biphenyls. Their high stability contributes to their intended commercial applications and their accidental, long-term adverse environmental and health effects. PCBs are useful as insulators in electrical equipment because they Genium are electrically nonconductive. Their distribution has been limited since 1976. The Aroclor PCB codes identify PCBs by type. The first two digits of a code indicate whether the PCB contains chlorinated biphenyls (12), chlorinated terphenyls, (54), or both (25,44); the last two digits indicate the approximate percentage of chlorine. Found in insulating liquid, synthetic rubber, plasticizers, flame retardants, floor tile, printer's ink, paper and fabric coatings, brake linings, paints, automobile body sealants, asphalt, adhesives, electrical capacitors, electrical transformers, vacuum pumps, gas-transmission turbines, heat-transfer fluids, hydraulic fluids, lubricating and cutting oil, copying paper, carbonless copying paper, and fluorescent light ballasts. Synonym: Chlorodiphenyls

Other Designations (Producer, Trade Name, Nation): Monsanto, Arocloi* (USA, Great Britain); Bayer, Clophen* (German Democratic Republic); Prodelec, Phenocloi*. Pyralene* (France); Kanegafuchi, Kanechlor*; Mitsubishi, Santotherm* (Japan); Caffaro, Fenclor* (Italy).

Trade Name CAS No. RTECSKo. Trade Name CAS No. RTECSSo. Aroclors Aroclor 1016 Aroclor 1221 Aroclor 1232

01336-36-3 12674-11-2 11104-28-2 11141-16-5

TQI350000 TQ1351000 TQ1352000 TQI35400O

Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260

53469-21-9 12672-29-6 11097-69-1 11096-82-5

TQ1356000 TQ1358000 TQ1360000 TQ1362000

HMIS H 1 F 1 R 0 PPG*

R 1 1 3 S 1 K 1

SECTION 2. INGREDIENTS AND HAZARDS/EXPOSURE LIMITS PCB-42% Chlorine/Aroclor 1242 CAS No. 53469-21-9 OSHA PEL (Skin*) 8-Hr TWA: 1 mg/m' ACGIH TLV (Skin*), 1988-89 TLV-TWA: 1 mg/m'

PCB-S4% Chlorine/Aroclor 1254 CAS No. 11097-69-1 OSHA PEL (Skin*) 8-Hr TWA: 0.5 mg/m' ACGIH TLV (Skin*), 1988-89 TLV-TWA: 0.5 mg/m'

AU PCBs/Aroclors CAS No. 1336-36-3 NIOSH REL 1977 10-Hour TWA: O.OOlmg/m' Toxicity Data** Mouse, Oral, LDjg: 1900mg/kg

*This material can be absorbed through intact skin, which contributes to overall exposure. **Sec NIOSH, RTECS (Genium ref. 90), at the locations specified in section 1 for additional data with references to tumorigenic, reproductive, mutagenic, and irritative effects.

SECTION 3. PHYSICAL DATA BoUing Point: Ranges from 527"F (275"C) to 725"F (385"C) Solubility In Water (%): Insoluble Pour Point: Ranges from -Sl'F (-35'C) to 87.8'F (31*0

% Volatile by Volume: Ranges from 1.2 to 1.6 Molecular Weight (Average): Aroclor 1242: 258 Grams/Mole

Aroclor 1254:326 Grams/Mole

Appearance and Odor: Clear to light yellow mobile oil to a sticky resin; a sweet "aromatic" odor. As the percentage of chlorine increases, the PCB becomes thicker and heavier; e.g., Aroclor 1254 is more viscous than Aroclor 1242.

SECTION 4. FIRE AND EXPLOSION DATA I LEL: Not Found | DEL: Not Found Flash Point* Autoignition Temperature: Not Found

Extinguishing Media: Use water spray/fog, carbon dioxide (CO,), dry chemical, or "alcohol" foam to extinguish fires that involve polychlorinated biphenyls. Although it is very difficult to ignite PCBs, they are often mixed with more flammable materials (oils, solvents, etc.) Unusual Fire or Explosion Hazards: If a transformer containing PCBs is involved in a fire, its owner may be required to report the incident to appropriate authorities. Consult and follow all pertinent Federal, state, and local regulations. Special Fire-flghtlng Procedures: Wear a self-contained breathing apparatus (SCBA) with a full facepiece operated in the pressure-demand or positive-pressure mode; fire fighters must also wear a complete set of protective clothing. Comments: The hazards of PCB fires are associated with the possibility of their being released into the environment where they and their products of degeneration can pose serious long-term health risks. These potential problems are heightened by the PCBs' resistance to biological and chemical degradation and by the possibility that they will contaminate underground water systems (see sect. 5)

•Ranges from 284'F (140"C) to 392T (200'C).

SECTION 5. REACTIVITY DATA Stability/Polymerization: Polychlorinated biphenyls are very stable materials. Hazardous polymerization cannot occur. Chemical Incompatibilities: PCBs can react dangerously with sodium or potassium. These reactions are part of an industrial process used to destroy PCBs; however, people have been killed by explosions at PCB treatment, storage, and disposal sites. Conditions to Avoid: Limit human exposure to PCBs to the lowest possible level; especially avoid contact with skin. Hazardous Products of Decom-poslton: Thermal-oxidative degradation of PCBs can produce toxic gases such as carbon monoxide, chlorine, chlorinated aromatic fragments, phenolics, aldehydes, and hydrogen chloride. Incomplete combustion of PCBs produces toxic compounds such as polychlorinated dibenzofuran (PCDF, the major product of combustion), and polychlorinated dibcnzo-/>-dioxin (PCDD or dioxin).

CotWTicht C !QR» ^v r . ^ i ! ' " ^ D>.Wi,v.;-. ^ - .

No. 683 POLYCHLORINATED BIPHENYLS (PCBs) 11/88

SECTION 6. HEALTH HAZARD INFORMATION Carcinogenicity: The EPA lists PCBs as carcinogens, and the lARC classifies them as probable human carcinogens (group 2B). Summary of Risks: Effects of accidental exposure to PCBs include acneform eruptions; eye discharge; swelling of the upper eyelids tol hyperemia of the conjunctiva; hyperpigmentation of skin, nails, and mucous membrane; chloroacnc; distmcuve hat rolliclss; fever; hearing difficulties; limb spasms; headache; vomiting; and diarrhea. PCBs are potent liver toxins that can be absorbed through unbroken skin in hazardous amounts without immediately discernible pain or discomfort Severe health effects can develop later. In experimental animals, prolonged or repeated exposure to PCBs by any route results in liver damage at levels that are less than those reported to have caused cancer in rodents. Medical Conditions Aggravated by Long-Term Exposure: None reported. Target Organs: Skin, eyes, eyelids, blood, liver. Primary Entry: Inhalation, skin contacfabsorption. Acute Effects: Skin and eye irritation, acneform dermatitis, nausea, vomiting, abdominal pain, jaundice, liver damage. Chronic Effects: Possible cancer (evidence of this is inconclusive); reproductive effects (jaundice, -xcessive secretion of tears, dermal chromopexy); and hepatitis. FIRST AID: Eyes. Immediately flush eyes, including under the eyelids, gently but thoroughly with flooding amounts of running water for 15 minutes. Skin. Rinse exposed skin with flooding amounts of water; wash with soap and water. Inhalation. Remove the exposed person to fresh air; restore and/or support breathing as needed. Have qualified medical personnel administer oxygen as required. Ingestion. Induce vomiting by sticking your finger to the back of the exposed person's throat. Have him or her drink 1 to 2 glasses of milk or water. Get medical help (in plant, paramedic, community) for all exposures. Seek prompt medical assistance for further treatment, observation, and support after first aid. Note to Physician: PCBs are poorly metabolized, soluble in lipids, and they accumulate in tissues or organs rich in lipids. Liver function tests can help to determine the extent of body damage in exposed persons. If electrical equipment containing PCBs arcs over, the PCBs or other hydrocarbon dielectric fluids may decompose and give off hydrochloric acid (HCl), a potent respiratory irritant

SECTION 7. SPILL, LEAK, AND DISPOSAL PROCEDURES Spill/Leak: Treat any accidental release of PCBs as an emergency. An SPCCP (spill-prevention control and countermeasure plan) must be formulated before spills or leaks occur. PCBs are resistant to biodegradation, soluble in lipids, and chemically stable; as such they have become significant contaminants of global ecosystems. Releases of PCBs require immediate, competent, professional response from trained personnel. Each release situation is unique and requires a specifically designed cleanup response. General recommendations include adhering to Federal regulations (40 CFR Part 761). Notify safety personnel, evacuate nonessential personnel, ventilate the spill area, and contain the PCBs. AU wastes, residues, and contaminated cleanup equipment from the incident are subject to EPA requirements (40 CFR 761). Consult your attorney or appropriate regulatory officials for information about reporting requirements and disposal procedures. Waste Disposal: Contact your hazardous waste disposal firm or a licensed contractor for detailed recommendations, especially when PCBs are unexpectedly discovered. Follow Federal, sute, and local regulations. PCBs are biomagnified in the food chain; i.e., their concentration increases at each link. The disposal of PCBs or of PCB-contaminated materials is strictly regulated; violations of applicable laws can result in fines, lawsuits, and negative publicity. Warning: Accidental spills of PCBs that may affect water supplies must be reported to Coast Guard personnel at the National Response Center, telephone (202) 426-2675. OSHA Designations Listed as an Air Contaminant (29 CFR 1910.1000 Subpart Z). EPA Designations (40 CFR 302.4) CERCLA Hazardous Substance, Reportable Quantity: 10 lbs (4.54 kg), per the Clean Water Act (CWA), §§311 (b) (4) and 307 (a).

SECTION 8. SPECIAL PROTECTION INFORMATION Goggles: Always wear protective eyeglasses or chemical safety goggles. Where splashing of PCBs is possible, wear a full face shield. Follow OSHA eye- and face-protections regulations (29 CFR 1910.133). Respirator: Wear a NIOSH-approved respirator per Genium reference 88 for the maximum-use concentrations and/or exposure limits cited in section 2. Follow OSHA respirator regulations (29 CFR 1910.134). For emergency or nonroutine operations (leaks or cleaning reactor vessels and storage tanks), wear an SCBA. Warning: Air-purifying respirators will not protect workers in oxygen-deficient atmospheres. Other: Wear impervious gloves, boots, aprons, and gauntlets, etc., to prevent any contact of PCBs with your skin. Ventilation: Install and operate general and local maximum, explosion-proof ventilation systems powerful enough to maintain airborne levels of this material below the OSHA PEL standards cited in section 2. Local exhaust ventilation is preferred because it prevents dispersion of the contamination into the general work area by eliminating it at its source. Consult the latest edition of Genium reference 103 for detailed recommendations. Safety Stations: Make emergency eyewash stations, safety/quick-drench showers, and washing facilities available in work areas. Contaminated Equipment: Contact lenses pose a special hazard; soft lenses may absorb irritants, and all lenses concentrate them. Do not wear contact lenses in any wo± area. Remove contaminated clothing and launder it before wearing it again; clean this material from your shoes and equipment. Heavily soiled clothing must be properly discarded in a manner consistent with applicable regulations. Comments: Practice good personal hygiene; always wash thoroughly after using this material and before eating, drinking, smoking, using the toilet, or applying cosmetics. Keep it off your clothing and equipment Avoid transferring it from your hands to your mouth while eating, drinking, or smoking. Do not eat, drink, or smoke in work areas.

SECTION 9. SPECIAL PRECAUTIONS AND COMMENTS Storage Segregation: Store PCBs in closed containers in a cool, diy, well-ventilated area. Protect containers from physical damage. Special Handling/Storage: All storage facilities must have adequate containment systems (dikes; elevated, nonporous holding platforms; retaining walls) to prevent any major release of PCBs into the environment Carefully design and implement these extra precautions now; do not wait until you have to respond to an accidental release of this material. Transportation Data (49 CFR 172.101-2; PCBs were the first materials to be direcay regulated by Congress by way of TSCA in 1976.)

DOT Shipping Name: Polychlorinated Biphenyls IMO Shipping Name: Polychlorinated Biphenyls DOT Hazard Class: ORM-E IMO Hazard Class: 9 ID No. UN 23115 IMDG Packaghig Group: D DOT Packaging Requirements: 49 CFR 173.510

References: 1, 6,26, 38, 84-94, 100,101,116.117,120,122.

Prepared by PJ Igoe, BS; Industrial Hygiene Review: DJ Wilson, C M ; Medical Review: W Silverman, MP

Technical Review: Northeast Analytical, Inc. (PCB and VOC Specialists), Schenectady, New York, Telephone: (518) 346-4592 Copyright 0 1988 by Genium Publishing Cotpotitioo. Any cooumciil use or leproductioa wilhout Ibe publisher'l penaiision is pioliibileil. Judiments u to the luiubilily of informicioii herein for Che p u e h u a ' l

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APPENDIX D PIPELINE ENTRY PROCEDURES

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OHM Corporaticai

2

HEALTH & SAFETY PROCEDURES PIPELINE ENTRY

PROCEDURE NUMBER 25 Page 1 of 3

LAST REVISED 12/92 APPROVED BY: JFK/FHH

OBJECTIVE

OHM Remediation Services Corp. (OHM) personnel shall not break into a pipeline until a line entry permit has been completed. The line entry permit is vzdid for a single work shift only.

PURPOSE

This procedure provides requirements for breaking into lines which contain or may contain hazardous materials in order to prevent explosion, pressure related injury, or chemical contact.

PROCEDURE -- PRE-ENTRY

3.1 Prior to beginning operations at a site, the potential hazards associated with line entry will be recognized and addressed.

3.2 Each line should be regarded as potentially full and pressurized with a toxic or flammable product until it is proven otherwise. Safe line entry requires investigation and pre-planning before work begins.

33 It is critical to determine the line contents in order to assess the products' toxic and flammable properties.

• Trace line to each end. For example, identify the pipe run between tanks or reactors.

• Check for color coding. Many plants designate line contents by their own color-coding system.

• Do not assume one plant's code is the same as another or is consistent within each plant.

• If necessary, sample line contents.

3.4 Scaffolding or manlifts used for elevated piping must be used according to manufacturer's specifications. Guardrails and tie-of65 must be used.

35 Portable lighting must be provided if area is not sufficiently illuminated.

PIPELINE ENTRY Procedure Number 25 Page 2 of 3

3.6 Any electrical lines near the work area must be de-energized prior to beginning operations. All electrical circuits are to be locked out.

3.7 The level of personal protective equipment (PPE) needed for the job, as well as any decontamination, secondary containment or spiU response procedures should be determined before line entry is attempted.

PROCEDURE - LINE BREAKING

4.1 Alert all employees in the work area to the hazard.

4.2 Make available an emergency drench shower and an eye wash station.

4.3 Isolate the line by closing, locking, and tagging all valves entering the line.

4.4 Lock and tag all electrical systems for pumps and automatic valves contained in the pipe run to be entered.

4.5 Remove all free product by pumping or draining. Inert or purge if applicable.

4.6 Blank or Discoimect line ~ Install some physical barrier to prevent additional product from entering the system.

4.6.1 Insert a blank or blind in a line to block it completely. This is important since valves should not be considered trustworthy. Valves have been known to leak even when fully closed.

4.6.2 Make use of double block and bleed (two closed valves within close proximity of each other with an open drain line between), if available.

4.7 Prepare for Line Entry

4.7.1 Establish exclusion zone. Zone should be sufficiently large to prevent unprotected people from contacting line material from liquid splash or vapor/gas emission.

4.7.2 Stage appropriate spill-control media at site.

4.73 Establish fire watch if necessary.

4.7.4 Review level of personal protective equipment (i.e., respirator, clothing, gloves, and eye protection).

1 PIPELINE ENTRY | Procedure Number 25 Page 3 of 3 |

4.7.5 Conduct air monitoring, including perimeter monitoring, for possible releases and explosive atmosphere survey or work area.

4.7.6 Stage appropriate working surface (i.e., ladder, scaffold, manlift, etc.)

4.8 Enter the Line

4.8.1 The best place to enter a line is at a flange.

4.8.2 Use non-sparking tools, such as brass, to loosen flange bolts if dealing with a flammable material.

4.8.3 Slowly loosen top flange bolts first. If pressurized, this will relieve it. If the line still contains fluid, the material will be noted as dripping or welling around the flange. If these conditions are noted, retighten and recheck purge procedures.

4.8.4 Because of possible leaks, no one will stand adjacent to or under a flange when opening.

4.9 The site supervisor is responsible for evaluating all safety hazards and assuring that the line entry permit is properly completed.

4.10 Line entry permits will be maintained in the project file.

4.11 A copy of the line entry permit follows this procedure.

CHM Corporatirai

Date

Project Name.

Project Number,

Potential Chemical Hazards.

LINE BREAKING PERMIT (Good for One Work Shift Only)

ajn. lunc . To_

.Location

ajn. ..PiP.

Safety Precautions

1. All emergency equipment in position? (Eyewash and safety shower, sorbent material, fire extinguishers, etc.)

2. Lines drained, purged and/or washed clean of materials?

3. All valves checked for positioning and tagged?

4. All electrical equipment locked out and tagged?

5. Fire watch designated?

6. Exculsion zone roped o£r and signs posted?

7. Persoimel wearing adequate personal protective equipment for expected hazard (consult site safety plan)?

8. LEL Survey completed?

9. Air monitoring equipment for poisonous/toxic substance available?

10. Decontamination, spill response equipment and procedure established, in place, and ready for response?

11. All personnel briefed on procedures?

Yes_

Yes_

Yes.

Ycs_

Ycs_

Yes_

Ycs_

Yes_

Yes_

Ycs_

No_

Not Necessary.

Not Necessary_

Not Necessary_

Not Necessary.

Not Necessary_

Not Necessary.

Not Necessary.

Not Necessary.

Not Necessary.

Yes_ Not Necessary.

I Certify that all necessary precautions have been taken in accordance to the line breaking procedures.

Supervisor ,

Foreman

Site-Safety OfScer

Line Breaking Crew.

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APPENDIX E HOT WORK PROCEDURES

OHM CorporaticMi

i

HEALTH & SAFETY PROCEDURES HOT WORK



1. OBJECnVE

OHM Remediation Services Corp. (OHM) personnel performing hot work outside of rooms specifically designed for spark producing operations such as welding are required to obtain a hot work permit and comply with all provisions described in the permit.

2. PURPOSE

This procedure establishes requirements for cutting or burning operations performed at OHM Remediation Services Corp. (OHM) project sites in accordance with 29 CFR 1910.252 (d)(2)(iv) and .252 (d)(xiii)(b).

3. REQUIREMENTS

3.1 The site safety officer (SSO) or other qualified person will issue the hot work permit for any flame or spark producing operation that requires such a permit. This procedure is to be repeated for each shift when such operations occur.

3.2.1 Conduct a visual inspection of area. Remove any combustible material surrounding the work area for a minimum of 50 feet. Special attention will be paid to areas where hot slag can fall or spatter. Any combustible material which caimot be readily removed will be covered or otherwise protected from the hot materials. For example, covering a combustible surface with one inch of soil or wetting it may be sufficient.

3.2.2 Designate a fire watch. This person's ( or persons') sole responsibility will be to monitor the welding or burning operation and have immediate access to a fire extinguisher or sufficient size and type for the potential combustible material. In addition, this person(s) shall be trained in the proper use of the appropriate fire extinguisher and be knowledgeable of the emergency signal and evacuation procedures as well as emergency shutdown procedures.

HOT WORK Procedure Number 26 Page 2 of 5

3.2.3 A qualified person must test the atmosphere. Do not begin until all spaces, pipes, and sumps affected have been opened and tested for the presence of flammables. If any flammable or combustible vapors exceed 10 percent lower explosive limit (LEL), no work will begin until levels are reduced. As a rule, no hot work will begin when any combustible vapor is present. All sewers in the vicinity of the hot work must be covered.

3.2.4 Notify personnel. Persormel working in the area of the hot work will be alerted to the fact that hot work is taking place.

3.2.5 Complete a hot work permit A hot work permit will be completed and posted. The OHM Hot Work Permit follows this procedure.

4. BURNING OPERATION SAFETY RULES

4.1 Wear adequate flame and heat resistant clothing and appropriate eye protection. This includes chipping operations.

4.2 Ensure that the area below is roped off and posted if work is overhead.

4.3 Protect persoimel and equipment in near vicinity against exposure from arc or sparks.

4.4 Observe good housekeeping practices; keep excess hoses, cables, and equipment out of aisle ways, stairways, and your work statioiL

4.5 Never use oil, grease, or pipe fitting compounds to make up connections on o;^-acetylene welding equipment.

4.6 Store torch fittings in a manner to prevent contaminatioiL

4.7 Do not interchange ojcygen and acetylene hoses; oxygen is coded green and acetylene is coded red.

4.8 Do not force connections or strike or force valve wheels.

4.8.1 Before connecting cylinders, read the label to ensure that the proper gas is being used.

4.8.2 cylinders must not be placed where they might form part of an electrical circuit. Keep cylinders away form grating, layout tables and piping systems that may be used for the grounding or electrical welding circuits.


4.9 Open oxygen valves momentarily to remove dust or dirt; stand on one side of the v^ve and avoid contact of gas with any combustible material.

4.9.1 Pressure-adjusting screws on regulators will be fully released before the regulator is attached to a cylinder and flie cylinder valve opened. Open the cylinder valve slowly; stand to one side, not in ftont of pressure regulator gauge faces when opening cylinder valves.

4.9.2 Do not use adjustable wrenches on acetylene cylinders; use the T-wrench provided. Keep it in place at the cylinder.

4.9.3 Never open an acetylene cylinder valve more than one and one half turns.

4.10 Do not store tools or equipment in the recessed top of an acetylene cylinder, and do not allow water to accumulate there.

4.11 Inspect the welding hose for defects before each use. Keep hoses clear of equipment and hot slag.

4.12 Do not use oxygen for cleaning, pressurization, or for ventilation.

4.13 Do not relight the flame on hot work when in an enclosed space. Allow time for gases to escape and then use a friction lighter.

4.14 A metal part which is suspiciously light probably has a void inside and an opening should be drilled before heating. Electrical boxes at the end of a conduit should be opened prior to cutting the conduit. Valves on both ends of piping should be opened.

4.15 Never lay work that is to be heated or welded on a concrete floor because when sufficiently heated, concrete may spall and fly with danger of injury.

4.16 Do not cut material in such a position that severed parts will fall striking legs or feet of the operator or assistant, or damage gas lines.

4.17 When a flashback occurs, both gases should be shut off - first ojygen, then acetylene. Before ligihting the torch again, see that it is cool and that no damage has been done to the torch, hose, or regulator.

4.18 Mark work "HOT" if left unattended or where others may come in contact with hot surfaces.

HOT WORK H Procedure Number 26 Page 4 of 5

4.19 When burning operations are to be stopped for a few minutes during the course of the work, it is permitted to close torch valves only. When work is stopped for a longer period, (5 minutes) or is left unattended, the following steps must be taken:

4.19.1 Qose ojtygen and acetylene cylinder valves

4.19.2 Open torch valves to relieve pressure, then close again

4.193 Release regulator pressure adjusting screws

4.20 Before regulator is removed fi-om a cylinder, the cylinder valve will be closed and the gas released from the regulator.

4.21 Back flow protection shall be provided by an approved device that will protect O2 from flowing into the fuel-gas system or fuel-gas from flowing into the O2 systems.

5. PERSONAL PROTECTIVE EOUIPMENT

The normal personal protective equipment worn when working generally provides inadequate protection from flames or heat. The person performing the work shall supplement the existing equipment with the following:

5.1 Welding gloves fa.<!hioned from leather or other fire-resistant material

5.2 Apron or jacket fashioned from leather or other fire-resistant material

5.3 Chaps, if necessary, for leg protection

5.4 Eye protection and face protection with appropriate ANSI approved darkened lenses

5.5 If necessary, flash-fire protection.

5.6 Respiratory protection must be used during hot work that will produce fumes and gases hazardous to health. Such gases and fumes may be caused by the filling agent or material being worked on.

6. TRAINING

6.1 Employees designated to operate welding equipment shall have been properly instructed and judged competent to operate such equipment.


7. OHM HOT WORK PERMIT

7.1 No employee or subcontractor of OHM is to begin hot work unless an OHM Hot Work Permit has been requested and provided. It is the responsibility of the supervisor to make the determination if a permit is required. Tie permit shall be signed by the Site Supervisor or SSO and explained to each affected employee.

7.2 It is the responsibility of the Site Supervisor to see that workers comply with all safety practices of the OHM Hot Work Permit.

7.3 The permit will be valid for a single work shift only. For work requiring more than a single work shift, a new permit shall be completed at the start of each shift. The permit shall be displayed at the work site.

7.4 At the conclusion of the work, permits will be placed in the project file.

OHM Corporatioi

HOT WORK PERMIT

Date: Time:

Project Name: Project Number:.

Location:

Issued to:_

Site Safety Officer:.

Supervisor:

Do not cut or use other open-flame or spark producing equipment until the following precautions have been been taken.

Protective Equipment used:.

(Initial Each Item)

The location where the work is to be done has been personally examined.

Any available fire protection systems are in service.

There are no flammable dusts, vapors, liquids, or unpurged tanks (empty) in the area.

Explosimeter reading < 10% LEL

All combustibles have been moved away from the operation, or otherwise protected with fire curtains or equivalent

Ample portable fire extinguishing equipment has been provided.

Arrangements have been made to patrol the area for a least V hour after the work has been completed.

The phone number for the local Fire Department is:

This form must be filled out daily whenever HOT WORK is being conducted and posted at the job site.

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11

APPENDIX F LOCK OUT/TAG OUT PROCEDURES

OHM Corporation

HEALTH & SAFETY PROCEDURES LOCKOUT/TAGOUT



1. OBJECTIVE

This procedure shall be used by OHM Remediation Services Corp. (OHM) persoimel to ensure that the machine or equipment being worked on is isolated from all potential hazardous energy sources, and locked out or. tagged out before an employee performs any servicing or maintenance activity where that unexpected energization, start-up or release of energy could cause an injury. Energy sources can be electrical, mechanical, hydrauUc, pneumatic, chemiczd, thermal, or other energy.

2. PURPOSE

This procedure establishes the minimum safety requirements to ensure the proper deactivation of movable, electrically energized, pressurized equipment and systems, and systems containing hazardous materials prior to repairing, cleaning, oiling, adjusting, or similar work. This procedure complies with the requirements in 29 CFR 1910.147.

3. REQUIREMENTS

This procedure applies to all equipment that receives energy from electrical power, hydraulic fluid under pressure, compressed air, steam, energy stored in springs, potential energy from suspended parts, or any other source that may cause unexpected movement when it is necessary to perform work on that system. It also applies to similar functions performed on systems containing hazardous materials.

4. DEFINirrONS

4.1 Lockout - The placement of a lockout device on an energy isolating device, in accordance with this procedure, ensuring that the energy isolating device and the equipment being controlled caimot be operated until the lockout device is removed. The lockout device can be key operated or a combination device.

4.2 Tagout - The placement of a tagout device on an energy isolating Jevice, in accordance with this procedure, to indicate that the energy isolating device and the equipment being confrolled may not be operated until the tagout device is removed by the authorized person who originally placed the tagout device in position.

1 LOCKOUT/TAGOUT Procedure Number 27 Page 2 of 3 |

4.3 Authorized employee. A person who locks or implements a tagout system procedure on machines or equipment to perform the servicing or maintenance on that machine or equipment.

PROGRAM ELEMENTS

Prior to initiating any repairs, modifications and/or adjustments to operating equipment, these steps will be followed.

5.1 The immediate supervisor with jurisdiction over the equipment and all affected employees will be notified that the energy sources are to be deactivated.

5.2 All sources of power that must be locked out, blocked or released will be identified by the immediate Supervisor and the employee who will work on the equipment.

5.3 In order to ensure that the equipment caimot be re-energized while maintenance activities are performed, the employee will lockout / blank out all potential energy sources. (The employees will be assigned padlocks with their names or identification numbers affixed to the locks. The locks will be individually keyed to prevent another employee from removing the lock inadvertently.) If more than one employee is assigned to work on the equipment, a multi-lockout hasp will be used so that all employees working on the equipment can apply their locks and ensure their safety.

5.4 A tagout device will be affixed to all components or systems de-energized to indicate that lockout has been performed.

Prior to performing any work activities, the employee will operate the start and .stop controls on the equipment to ensure that the equipment has been properly deactivated. After the test, the equipment must be in neutral or off.

5.5 After the servicing and/or maintenance is complete and the equipment is ready for normal operations, check the area around the machine or equipment. After all tools have been removed from the machine or equipment, guards have been reinstalled, remove all lockout or tagout devices. Operate the energy isolating devices to restore energy to the machine or equipment

LOCKOUT/TAGOUT Procedure Number 27 Page 3 of 3

6. SPECIAL CONDITIONS

During certain operations it may be necessary to energize the equipment for a short period of time. Employees in the immediate area will be notified and directed to stay clear of the equipment If the operation is to be deactivated again, the employee should repeat steps 5.3 to 5.6 of this procedure before work resumes.

In some instances work will carry over to another shift. The maintenance supervisor shall affix a department lock to the equipment to ensure that it is not energized during the transition. During subsequent slight operations, employees will ensure that steps 5.2 to 5.6 are complete before work resumes on the equipment

If the work is completed and a lock remains on the equipment, it shall not be removed imtil the employee responsible for the lock is found or the supervisor of the employee investigates and ascertains that the equipment is safe to operate. Unauthorized removal of a lock will subject the violator to disciplinary action up to dismissal.

7. TRAINING

Initial and annual training will be given to all employees to ensure that the purpose and function of this energy and control program are understood.

8. PERIODIC INSPECnON

Corporate health and safety will conduct an annual audit of the energy control program to ensure that the requirements of their procedures are being followed. A record of annual audits wiU be kept to comply with the certification requirement of periodic inspections.

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APPENDIX G HIGH PRESSURE WASHERS

OHM Corporation

HEALTH & SAFETY PROCEDURES HIGH PRESSURE WASHERS



1. QBTECnVE

OHM Remediation Services Corp. (OHM) personnel who have been trained in the proper set-up, use, and care of high pressure washers wiU be authorized to operate this equipment

2. PURPOSE

This procedure describes requirements for the safe operation of the high-pressure washer.

3. PERSONAL PROTECTIVE EOUIPMENT

The following equipment will be worn by operators and assistants:

Safety shoes or boots

Metal foot and shin guards

Eye protection (goggles and face shield)

Hard hat

Heavy duty PVC rain suit or equivalent

Heavy chemical resistant gloves

QPERATTON PROCEDURE

Only frained, authorized persoimel will operate the high-pressure washer.

The lance must always be pointed at the work area.

The operator must maintain good footing.

The operator must have an assistant to aid in moving the hose to different areas and backing up the operator. The assistant must remain in back of the operator.

HIGH PRESSURE WASHERS Procedure Number 30 Page 2 of 2

Non-operators must remain a safe distance from the operator. The distance must be a minimum of 25 feet.

The operating pressure should never exceed that which is necessary to complete the job.

No unauthorized attachment may be made to the unit (The trigger should never be tied down.)

The operator should be changed at frequent intervals to avoid fatigue (at least hourly).

Equipment should be cleaned often to avoid oil or dirt build-up, especially around the trigger and guard area.

An assistant should always be standing by at the pressure generator to shut down the equipment and monitor the pressure.

All users must be trained in emergency shut down procedures and general equipment maintenance.

All lances must be made of seamless stainless steel. Do not use carbon steel which can corrode and result in weakening of the lance.

DO NOT MODIFY THE LANCE. The lance barrel, from trigger block to the tip, should not be less than 48 inches as recommended by manufacturers of hydroblasting equipment

Always increase pressure slowly to inspect for leaks. All leaks or malfunctioning equipment must be repaired immediately or the unit taken out-of-service. Never exceed the operating pressure necessary to do the job.

Attach a cable which connects the water supply hose to the laser wand to prevent whipping should they accidentally disconnect.

A serious risk of infection and further complications is possible from a hydroblasting laceration. If an injection injury is suspected, the freating physician should be informed so he/she can request a surgeon who specializes in iiyection injuries. The specialist may have to perform surgery on the affected body part in order to remove the material (oil, particles) that was injected directiy through the skin.

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APPENDIX H MUDCATAND DEWATERING PROCEDURES

1 - OHM Corporation

HEALTH & SAFETY PROCEDURES MUDCATAND DEWATERING

PROCiEDURE NUMBER 36 Page 1 of 3


QBJECnVE

All OHM Remediation Services Corp, (OHM) personnel who will be operating the Mudcat Dredge (Mudcat) will be trained in the safety, operation, and maintenance of this equipment. Only properly trained and authorized personnel will be allowed to operate the Mudcat

PURPOSE

This procedure describes the requirements for the safe operation of the Mudcat

REQUIREMENTS - PERSONAL PROTECTIVE EQUIPMENT

The following equipment will be worn by Mudcat operators and assistants:

3.1 United States Coast Guard (USCG) approved life vest or life jacket.

3.2 Hearing protection.

3.3 Eye protection.

3.4 Hard hat

3.5 Safety shoes or boots.

3.6 Heavy gloves, such as monkey grips.

3.7 Tyvek Suit (minimum).

3.8 Refer to site specific health and safety plan for any additional requirements.

MUDCAT SAFETY PROCEDURE

4.1 Only trained, authorized personnel will operate the Mudcat

4.2 The operator must have an assistant to aid in moving the guide cables. This assistant will maintain constant two-way radio contact with the Mudcat operator.

MUDCAT AND DEWATERING Procedure Number 36 Page 2 of 3 |

4.3 The operator and assistant must maintain a secure footing on the Mudcat deck and the pond perimeters.

4.4 A floating ring buoy with at least 90 feet of line must be kept in close proximity to the pond. Distance between ring buoys shall not exceed 200 feet.

4.5 Two tender boats will be available on-site, one for shuttling the operator between the Mudcat and the shore and the other in case of an emergency.

4.6 All chains, cables, and rigging will be inspected weekly and this inspection will be documented.

4.7 Two 20 lb. ABC fire extinguishers will be available on board the Mudcat and will be inspected daily.

4.8 All pumps and systems will be de-energized and locked out and the diesel motor stopped before removing obstructions from the pump impeller or auger-cutter assembly.

4.9 The Mudcat will not be operated if the safety guard for the auger-cutter blades is non-functional.

4.10 The Mudcat will not be operated in high winds, waves in excess of 12-inches or swift currents.

5. DEWATERING PRESS SAFETY PROCEDURE

5.1 Only trained, authorized personnel will operate the dewatering press.

5.2 All wiring and electrical hook-ups will be properly grounded and shielded. Qear access will be maintained to all electrical panels.

5.3 The operator will verify that all personnel are clear before the press plates are opened or closed.

5.4 Personnel will not attempt repairs until all systems (electrical, hydraulic, etc., are locked out and tagged.

6. SPECIFIC PROCEDURES FOR OIL-BASED SLUDGES

6.1 Monitoring for hydrogen sulfide (HjS) will be conducted.

6.2 If HjS is present, ferric chloride may be injected into the sludge as it is pumped to reduce HjS emissions.

MUDCAT AND DEWATERING Procedure Number 36 Page 3 of 3

6.3 Waterless hand cleaner or detergent will be provided for hand-washing. Diesel fuel will not be used for persormel decontamination.

6.4 A canvas shroud over the shaker/mix tank with negative air drawn through carbon filters may be required to reduce H2S emissions.

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APPENDIX I ELECTRICAL SAFETY PROCEDURES

OHM CorporaticMi

HEALTH & SAFETY PROCEDURES ELECTRICAL SAFETY



1. OBJECTIVE

OHM Remediation Services Corp. (OHM) personnel performing work on electrical systems and equipment will follow standards set by the National Electrical Code (NEC) and OSHA in selection of materials and methods of installation and maintenance. Only qualified personnel will work on electrical systems and equipment

2. PLFRPOSE

This procedure specifies the requirements for electrical equipment and methods and is an overview of the requirements of 29 CFR 1910, Subpart S-Electrical. If work is to be performed on any electrical circuit, lockout/tagout may be required. Refer to the Lockout/Tagout procedure.

3. GENERAL REQUIREMENTS

3.1 No electrical work should be done on an energized circuit

3.2 Only approved electricians will be permitted to work on electrical equipment or permanent electrical wiring.

33 Use proper clearance and grounding procedures. All electrical circuits and equipment shall be de-energized and lockout/tagout accomplished before maintenance or repair work is started.

3.4 Single-phase electric hand tools and other single-phase portable electrical equipment must be approved by a recognized testing agency, and all exposed non-current-canying metal parts must be grounded, or be double insulated.

3.5 Before each use, portable electrical appliances are to be examined for obvious deficieirdes in the appliance, cord, and plug. If any deficient is noted, the appliance is not to be used.

1 ELECTRICAL SAFETY Procedure Number 38 Page 2 of 5 |

3,6. Extension cords are to be kept clean, dry, free of kinks, and protected from oil, hot or sharp surfaces, and chemicals. Extension cords used outdoors shall be Ground Fault Circuit Interrupter (GFCI) protected. All extension cords shall be free from damage and are not to be placed across aisles, through doors, through holes in a wall, or in areas where the cord may be damaged or become a tripping hazard. Extension cords must not be placed in walkways, or on stairs or steps where the cords may pose a tripping hazard,

4, PORTABLE ELECTRICAL EQUIPMENT

4.1 Double insulated portable industrial type electric tools meeting the requirements of the Underwriters Laboratory are authorized for use (ground wire not required). Where such a system is employed, the equipment must be distinctly marked.

4.2 Portable electrical tools not provided with special insulating or grounding protection are not intended for use in damp, wet or conductive location (persons standing on the ground or on metal floors).

4.3 All portable electrical appliances and equipment where the non-current carrying metal parts are exposed to contact by personnel shall be grounded by continuous conductor of adequate capacity from the device to a grounded receptacle. The site safety officer shall resolve any question which arises as to whether or not a particular appliance should be grounded.

4.4 Grounding of receptacles shall be accomplished in one of two ways:

• A built-in ground wire of green color may be attached to the ground pole of the receptacle.

• The conduit system, if installed in an approved manner, may be relied upon for grounding of a receptacle serving single phase appliances with ratings up to 230 volts.

4.5 At outside locations all single-phase 15 and 20 ampere receptacle outiets operating at 230 volts or less which are not a part of the permanent wiring of the building or structure must have GFQ for persoimel protection. The GFCI should be located a,, the power source so that all extension cords and tools are protected by the GFCI.

The outlet box for portable extension cords for outdoor use shall be of weatherproof type maintained in good conditioiL

ELECTRICAL SAFETY Procedure Number 38 Page 3 of 5 |

5. ELECTRICAL GUARDING

5.1 Suitable access and working space shall be provided and maintained about all electric equipment to permit ready and safe operation and maintenance of such equipment

5.2 The dimension of the working space is the direction of access to energized parts in switchboards, control panels, fused switches, circuit breakers, panel boards, motor controllers, and similar equipment which require examination, adjustment, servicing, or maintenance while energized, shall not be less that 36" in depth (30" for installations built prior to 1981) and the side being 30" or the width of the equipment, whichever is greater.

5.3 The working space shall not be used for storage purposes. The "keep clear" area may be identified with suitable floor markings and/or posting of signs or decals on the equipment.

5.4 Energized parts of electrical equipment operating at 50 volts or more shall be guarded against accidental contact by the use of approved cabinets or enclosures.

5.5 Entrance to rooms and other guarded location containing exposed energized parts shall be marked with a conspicuous warning sign forbidding unqualified persons to enter.

5.6 Temporary covers, warning signs, and/or barricades are to be used when it is necessary to remove covers of electrical panels during construction, major refurbishment, or for the purpose of providing temporary power to an area.

5.7 All openings in boxes, enclosures, or fittings shall be effectively guarded or closed to afford protection substantially equivalent to that of the wall of the box, enclosure, or fitting.

5.8 All electrical components over 230 volts shall have signs stating "High Voltage" 240 volts.

6. EXTENSION CORD REQUIREMENTS

6.1 Extension cords are designed for and will be used for TEMPORARY USE ONLY! All other electrical coimections will be made permanent by proper construction methods.

ELECTRICAL SAFETY 1 Procedure Number 38 Page 4 of 5 |

62 Use of indoor extension cords greater then 50 feet in length is to be discouraged. All extension cords shall include a grounding conductor within the cable jacket and shall be equipped at each end with either explosion-proof or non-e3q)losion-proof three-wire, grounded receptacles and plugs (but not with one of each), depending on the location and intended use. (No "hybrid", ungrounded or external ground wire extension cords are allowed.)

6.3 If a cord is damaged, it shall be shortened or replaced by an electrician -never patched with electrical tape.

6.4 Cords shall be protected against contact with oil, hot surfaces and chemicals.

6.5 Cords must not be hung over nails or other sharp edges or placed where vehicles may run over them.

7. ELECTRICAL FUSE REQUIREMENTS

7.1 Circuits must be de-energized by lockout and tagout procedures before attempting to replace fuses.

7.2 Bridging of fuses or circumventing the normal operation of drcuit breakers is prohibited.

7.3 Blown fuses shall not be replaced with fuses having a higher amperage or voltage rating. Fuses should be replaced in kind to maintain proper circuit protection.

7.4 Use a fuse puller to remove fuses.

8. ASSURED ELECmiCAL GROUNDING REQUIREMENTS

8.1 This program provides the minimum requirements for an assured equipment grounding conductor program and reflects the requirements of 29 CFR 1910.304. It also applies to circuits and equipment not attached to a permanent building or structure.

8.2 OHM and its contractors will implement either a wiitten assured equipment grounding conductor program or use GFCFs when using temporary wiring (cords and plugs) in field work using any temporary electrical power source.

8.3 Cords and equipment will be inspected prior to each use for damage or missing parts. Equipment which is found to be defective will be taken out of service and repaired.

ELECTRICAL SAFETY Procedure Number 38 Page 5 of 5

8,4 The Assured Equipment Grounding Conductor Program will include the following:

• This written program,

• Designation of a competent person(s) to implement the program,

• Visual inspection of cords on a daily basis for deformed and missing pins, insulation damage, and indications of possible internal damage. Equipment found damaged or defective will be removed from service and repaired or expended.

• Cords and electrical circuits will be tested for the following:

Electrical grounding continuity

Correct attachment of grounding conductor

• Tests outlined above shall be performed before the first use, before being returned to use after repair, after possible damage (such as being run over by a vehicle), and at least every three mouths.

• The tests outlined above must be recorded and cords which have been tested identified.

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APPENDIX J PPE PROGRAM

II

S— OHM Corporation

HEALTH & SAFETY PROCEDURES PERSONAL PROTECTIVE EQUIPMENT PROGRAM


LAST REVISED 1/95 APPROVED BY: DLM/FHH

OBJECTIVE iS^IF? OHM Remediation Services Corp. (OHM) personnel will be protected for chemical, physical, and environmental hazards by the appropriate personal protective equipment (PPE) when engineering and administrative controls are not effective in controlling job hazards.

2. PURPOSE

The purpose of this procedure is to address the elements of the PPE program. This PPE program conforms to the requirements found in 29 CFR 1910.120 (g) Engineering controls, work practices, and personal protective equipment for employee protection; 29 CFR 1910'Subpart I - Personal Protective Equipment -.132 General Requirements, .133 Eye and Face Protection, .135 Head Protection, .136 Foot Protection, .138 Hand Protection; and 29 CFR 1910.1200 Hazard Communication.

3. RESPONSIBILITY AND AUTHORITY

The responsibility and authority for the selection, use, and maintenance of personal protective equipment is shared between management, supervisory, health and safety, and employee personnel.

3.1 Management - Management has the responsibility to provide PPB appropriate for the hazard/s associated with e:q)ected work tasks.

3.2 Supervisors - Supervisors have the responsibility conduct hazard assessments and ensure personnel utilizing PPE in compliance with this SOP. Supervisors may request assistance from or designate authority to health and safety personnel for hazard assessment, selection, inspection, and decontamination of PPE. The use of PPE by employees is the supervisors responsibility.

3.3 Health and Safety Persoimel - Health and safety personnel have responsibility to assist supervisors in hazard assessment, selection, inspection, and decontamination of PPE. In event of conflict, health and safety personnel have the authority implement the necessary measures.

3.4 Employees - Employees have the responsibility to use, inspect, and decontaminate PPE as directed by supervisors.

PERSONAL PROl'LCriVE EQUIPMENT ^-PROGRAM

Procedure Number 17 Page 2 of 10

4, PROGRAM ELEMENTS U llj [ ^ U [J

Program elements define the regulatory requirements of a PPE program,

4.1 Hazard assessment - All tasks undertaken by OHM personnel will be assessed for chemical, physical, and environmental hazards present or likely to be present which necessitate the use of PPE to ensure adequate protection. This assessment shall take place prior to commencement of work.

4.2 Hazard Reassessment - The level of protection or type of personal protective eqiupment shall be increased when additional information on site conditions indicates that increased protection is necessary to reduce employee exposures below permissible exposure limits, published exposure levels for hazardous substances and health hazards or other physical and environmental hazards.

4.3 PPE Selection - The regional health and safety director/manager or his/her designee will initially select the level and types of PPE that will protect the affected employee from the hazards identified in the initial hazard assessment

4.4 Written Certification - The site spedfic Healtii and Safety Plan (HASP) will serve as the written certification that identifies the workplace was evaluated. The HASP shall be dated. The signature line shall designate the person certifying that the evaluation has been performed.

4.5 Communication of Selection - Employees will be informed of the PPE selection decisions through reading or verbally reviewing the HASP, pre-project safety briefings, job safety analysis (JSA) review, safety meetings and/or some combinations.

4.6 PPE Use and Fit - The supervisor will be responsible for the proper use and fit of PPE by workers under his/her direction and will monitor the effectiveness of these items. Heath and safety personnel will advise and assist the supervisor in these areas.

4.7 Work Mission Duration - The supervisor will be responsible for the establishment of the duration of specific work missions. The duration will be determined by the complexity of the assignment, PPE involved, physical factors, temperature, humidity, weather conditions, elevation of work, and acclimation of the worker to the demands of the task assigned. The supervisor will consider the recommendations of the health and safety personnel.

A sufficient amount of rest breaks will be allowed in order to avoid

•ERSONAL PROTECTIVE EQUIPMENT T R O G R A M


j¥¥n overexertion or thermal stress by the employees while maintaining productive work practices. Further guidance is offered in OHM Health and Safety Procedure No. 22 Heat Stress and No. 23 Cold Stress.

4.8 PPE Maintenance and Storage - Each employee is responsible for the proper maintenance and storage of the standard issue equipment (e.g., hard hat, full-face piece negative pressure respirator, safety glasses). The supervisor will assure that proper maintenance is carried out.

4.9 PPE Decontamination - Each employee is responsible for daily cleaning and decontamination of reusable PPE such as outer gloves, outer boots, reusable chemically resistant clothing, and standard issue PPE such as hard hats and respirators.

OHM will provide an area/s for decontamination operations, necessary cleaning agents, tools eg. brushes and wash basins, and a method to dispose of materials generated durihg decontamination activities.

OHM will attempt to reduce decontamination requirements through the use of disposable protective clothing and gloves as feasible.

4.10 PPE Training - All employees will receive training in the proper use of PPE prior to wearing the equipment in a work situation. This training will be administered upon commencement of employment during HAZWOPER training. PPE refresher training will be reviewed annually during the HAZWOPER refresher training. Project specific training will be provided as required.

4.11 PPE Donning and Doffing Procedures - All employees wiU receive training upon commencement of employment and during annual refresher training concerning the donning and doffing of PPE. Periodic ttaining will be provided as required.

4.12 PPE Inspection - Each employee shall inspect PPE for defects and proper function prior to each use. Defective or damaged PPE shall not be used. Any PPE found to be defective or have missing parts will be replaced prior to use.

4.13 PPE In Use Monitoring - The supervisor is responsible for monitoring the effectiveness of selected PPE, If at any time level of PPE is to be downgraded, it is mandatory that the change be approved by the regional health and safety director/manager or his/her designee,

4.14 Evaluation of PPE Program - Health and safety personnel will compile data on PPE in the field to determine that the PPE performs to OHM needs. Periodically, this information should be reviewed by the corporate director

'ERSONAL PROTECTIVE EQUIPMENT -PROGRAM


ttirrf of health and safety to ensure that PPE is providing the necessary level of protection, quality, and is appropriate for the work performed.

If at any time the failure of PPE causes injury to an employee or fails to perform as expected, the supervisor will tadce the unit or item out of service and investigate the incident. The incident shall be immediately reported to the regional health and safety director/manager. If after scrutiny, the unit or item is determined to have a manufacturing defect, all identical units will be removed from use until corrective actions are taken.

4.15 Limitations During Temperature Extremes • Extreme temperatures exert stress on personnel and may alter the performance characteristics of PPE. During periods of extreme temperature, work assignments will be adjusted to protect the employee from overexertion or exposure. The supervisor will evaluate if temperature extremes are effecting performance characteristics of PPE and report these findings to the regional health and safety director/manager and/or his/her designee.

4.16 Unserviceable PPE - Any PPE which is no longer functioning properly or is no longer serviceable shall be removed from use and either repaired or destroyed.

5. SAFETY EQUIPMENT POLICY

OHM will provide, maintain, and replace personal protective equipment as detailed below.

5.1 Standard issue safety equipment - Standard issue safety equipment will be provided at no cost to field employees. These items consist of:

• Hard hat

• Safety glasses with clear arid shaded lenses

• Full-face respirator with nose cup

5.2 Company provided equipment - OHM will provide at no cost to the employee the following items on a task specific or project specific basis:

• Chemical protective equipment such as gloves, boots, and clothing

• Specialty glasses or goggles

• Face shields

• Flame resistant clothing

PERSONAL PROTECTIVE EQUIPMENT pPROGRAM


Hearing protection

Fall protection i i s ^n 5.3 Employee provided equipment - The employee shall provide the following

equipment:

• ANSI approved steel toed and shank boots/shoes (Note: Further guidance is provided in Section 7 Safety footwear)

• Outerwear for cold weather

5.4 Equipment replacement - OHM will replace worn out or work damaged equipment detailed in 5.1 and 5.2. OHM reserves the right to charge employees for the replacement cost of equipment which is lost or damaged though neglect or abuse.

5.5 Additional PPE - The regional health and safety director/manager and/or his/her designee or the supervisor may require additional company provided PPE on a task specific basis.

6. WORK CLOTHES

OHM employees, subcontractors, and visitors will observe the requirements for proper work clothing when on OHM project sites, facilities, and shops.

6.1 Pants - Long pants are required at all times. These pants must be in good repair.

6.2 Shirts - Shirts will be worn on the job. Shirts will be buttoned up the front and at the cuff unless rolled up. Shirt tails must be kept in the trousers. Sleeveless shirts are prohibited at all work locations. Supervisory personnel are expected to wear a shirt with a collar. T-shirts are permitted for personnel who wear protective clothing most of the day.

6.3 Clothing - Loose or ragged clothing will not be worn,

6.4 Modifications - Regional health and safety director/manager may modify work clothing requirements on a project specific basis.

6.5 Contaminated Clothing - Clothing (including shoes) saturated with petroleum products or chemicals will be removed immediately to prevent irritation and possible dermal exposure.

6.6 Jewelry - Rings and other jewelry (except watches) must be removed when working in areas where they could catch on moving objects, sharp

PERSONAL PROTECTIVE EQUIPMENT PROGRAM


D O protrusions, come in contact with electrical circuits or chemical agents, or compromise PPE ie, rings capable of cutting gloves. Additionally, the supervisor may deem other types of jewelry inappropriate for the work task.

6.7 Hair Length - Hair long enough to constitute a hazard while working around moving machinery or rotating tools and equipment must be secured by a net or tied back. Hair styles must not interfere with the ability to properly wear safety headgear, safety spectacles, and respiratory protection.

7. EYE/FACE PROTECTION

All OHM employees, subcontractors, and visitors shall wear eye and face protection meeting the requirements of ANSI document Z87.1 - 1989 titied "Practice of Occupational and Educational Eye and Face Protection" during the tasks posing exposure to eye or face injury.

7.1 Requirements - To protect' the face and eyes against injuries from flying objects, splashing liquids, and harmful rays, safety spectacles with side shields, goggles, face shields, cutting goggles, and welding helmets will be used. The supervisor will be responsible to identify the need for eye/face protection and specify the eye/face protection required for each operation. A selection guide is attached in Table 1.

7.2 Safety spectacles - Safety spectacles are protective devices intended to shield the wearer's eyes from a variety of hazards. While they are primary protectors and may be used alone, they may also be used in conjunction with other protective devices such as goggles and face shields.

73 Goggles - Goggles are protective devices intended to fit the face immediately surrounding the eyes in order to shield the eyes from a variety of hazards. While they are primary protectors and may be used alone, they also may be used in conjunction with other protectors.

7.4 Face shields - Face shields are protective devices intended to shield the wearer's face, or portions thereof, in addition to the eyes, from certain hazards. Face shields are secondary protectors and shall be used with primary protectors,

7.5 Cutting goggles - Cutting goggles are protective devices designed to protect the eyes from radiation and impact. Goggles are primary protectors and in some situations must be supplemented with face shields. See Table 3 for selection guidelines.

7.6 Welding helmets - Welding helmets are protective devices intended to shield the eyes and face from optical radiation and impact. Welding helmets are secondary protectors and shall be used only in conjunction with

PERSONAL PROTECTIVE EQUIPMENT I PROGRAM


MMl primary protectors such as safety spectacles or goggles. See Tab selection guidelines,

7.7 Prescription Spectacles - For personnel that wear prescription spectacles, OHM provides prescription safety spectacles with side shields. It is mandatory that prescription safety spectacles not be altered by the employee and be worn at all times when safety spectacles are required.

7.8 Contact lenses - Contact lenses are not permitted to be worn where accidental eye contact with chemical agents or physical materials is possible. OHM provides prescription spectacles and other protective devices for use in these situations.

7.9 Shaded lenses - Shaded lenses eg. sun glasses are not to be worn indoors or under low light conditions.

8. SAFETY HEADGEAR

All OHM employees, subcontractors, and visitors shall wear safety headgear meeting the requirements of ANSI document Z89.1-1986 titied "Protective Headwear for Industrial Workers - Requirements" when exposed to overhead hazards.

8.1 Requirement - Safety headgear shall be worn by all personnel while engaged in work where there is a hazard of falling objects, low overhead restrictions, and other overhead hazards exist. Safety headgear may also be required to be worn by contractual requirements.

8.2 Use - Safety headgear must be worn as prescribed by the manufacturer in the bill front position unless the headgear was approved to be worn in another position.

83 Modifications - Safety headgear shall not be painted, drilled or modified in any manner. Use of safety related headgear stickers are permitted.

8.4 Life Expectancy - No maximum mandatory service life is specffied by regulation for safety headgear. However, a hardhat should be removed from service if chemical corrosion, cracks, deformities, worn suspension, or discoloration is noted with the unit

9. SAFETY FOOTWEAR

All OHM employees, subcontractors, and visitors that enter OHM project sites and are exposed to foot hazards shall wear footwear meeting the ANSI document 241 -1991 titled "Protective Footwear" during operations posing foot injury.

ERSONAL PROTECTIVE EQUIPMENT TROGRAM


f l l 9.1 Project Sites - Steel toe and shank leather work boots shall be^onroifjdi

OHM project sites. High top or low top sneakers, westem style boots, or other footwear even though ANSI approved are not appropriate for the activities encountered at hazardous waste and emergency response sites and shall not be worn.

9.2 OHM Facilities and Shops - Personnel working at OHM shops and facilities have the option of wearing other types of ANSI approved safety work shoes and boots provided they are appropriate for the tasks being performed. The supervisor of the work area is responsible to decide what type footwear is appropriate.

10. HAND PROTECTION/GLOVES

OHM employees, subcontractors, and visitors will don appropriate gloves when engaged in any operation that presents a hazard to the hands.

10.1 Use - Appropriate work gloves shall be available for hand protection against heat and flame, cold, chemicals, petroleum products, corrosive materials, moisture, mechanical abrasion, electricity, and sharp and rough surfaces.

10.2 Selection - Glove selection of the appropriate hand protection shall be based on an evaluation of the performance characteristic of the hand protection relative to the task(s) to be performed, chemical concentration and properties, physical conditions present, duration of use, and the hazards and potential hazards identified. The type of work gloves used must be approved by the regional health and safety director/manager and his/her designee and specified in the HASP for the particular task.

103 Electrical - When working on high voltage (480 volts and above) electrical equipment, electrically tested high voltage ^oves will be worn. Leather protection wiU be worn over these gloves. (NOTE: Only authorized personnel are permitted to work on High Voltage electrical equipment).

IL PROTECTIVE CLOTHING

OHM employees, subcontractors, and visitors will don appropriate protective clothing when engaged in any operation that presents a hazard to the body.

11.1 Use - Appropriate clothing shaU be available for body protection against heat and flame, cold, chemicals, petroleum products, corrosive materials, moisture, mechanical abrasion, electricity, and sharp and rough surfaces,

11.2 Selection - Clothing selection of the appropriate body protection shaU be based on an evaluation of the performance characteristic of the body protection relative to the task(s) to be performed, chemical concentration

PERSONAL PROTECrrVE EQUIPMENT hPROGRAM


and properties, physical conditions present, duration of use, and the hazards and potential hazards identified. The type of protective clothing used must be approved by the regional health and safety director/manager and his/her designee and specified in the HASP for the particular task.

12. TOTALLY-ENCAPSULATING CHEMICAL PROTECHVE SUFFS

Totally-encapsulating chemical protective suits (Level A) shaU be used in conditions where skin absorption of a hazardous substance may result in a substantial possibiUty of immediate death, immediate serious illness or injury, or impair the ability to escape.

12.1 Use - OHM wiU only use Level A protection when aU other reasonable efforts of controlling employee exposure through engineering or administrative means are not possible.

12.2 Authorization - Level A protection may only be used after authorization of the regional health and safety director/manager has been granted.

12.3 Health and Safety Persoimel - An appropriately experienced health and safety employee must be assigned to the project site where Level A is to be used. They must evaluate that the foUowing items are ready:

• Communications

• Decontamination

• Emergency rescue procedures and personnel

• Emergency medical attention

12.4 OHM wiU discard and properly dispose of any Level A suit which has come in contact with chemical contaminants or sustained physical damage at least at the end of the project

13. LOANING PERSONAL PROTECTIVE EOUIPMENT

OHM personnel should not loan OHM personal protective equipment to any cUent, subcontractor, or visitor personnel. If there are urgent circumstances, such as an emergency response where the equipment cannot be obtained elsewhere and chemical exposure is possible, OHM personnel can loan personal protective equipment such as respirators, protective clothing and other safety equipment to client personnel or personnel from other organizations. However because of the potential liability involved, approval of senior OHM management is required as well as the requirement that a representative of the company and the individual using the equipment execute an OHM Indemnification and Release Agreement

, _ _ r T _ j _ .

•ERSONAL PROTECTIVE EQUIPMENT TROGRAM


following wiU be required BEFORE the personal protective equipment may be loaned:

• The OHM Regional Vice President (or his/her designee) must spedficaUy authorize the loaning of personal protective equipment on the particular project

• An authorized representative of the company whose personnel wiU use the equipment must sign the Indemnification and Release Agreement

• The individual who wiU use the equipment musl also sign the Indemnification and Release Agreement attesting to the fact that the individual is either experienced in the use of the equipment or has been given instruction on the safe use of the equipment and is medicaUy qualified to wear the equipment

• An OHM representative must also sign the form as a witness to the above.

Contractual Requirement - An indemnification and release agreement is not required if providing personal protective equipment to clients or regulatory persoimel is a contractual requirement

Exemptions - Hard hats, safety glasses, hearing protection, and protective clothing provided for cleanliness is exempted for the indemnification requirement. Instruction should be provided to the individual prior to wearing.

13.2

133

OHM Remediation Services Corp.

®!S!^n

TABLE 1 FACE PROTECTION SELECHON GTHDELINES

Hazard

Flying fragments, objects, large chips, particles, sand, and dirt from chipping, grinding, machining, masonry work, riveting, and sanding

Chemical splash from corrosive and chemical handling, pressure washing operations

Nuisance dust from woodworking, buffing, and general dusty conditions

Hot sparks from grinding operations

Molten metal from torch cutting operations

Welding operations

Protection

Safety spectacles or goggles Supplement with face shield for severe exposure

Goggles Supplement with face shield for severe e;qposure

Safety spectacles or goggles

Safety spectacles or goggles Supplement with face shield for severe exposure

Shaded cutting goggles (see Table 3) and face shield

Safety spectacles and shaded welding hood (see Tables 2)

OHM Remediation Services Corp. A SakaUlvr iTOHM CW»M«UMI i][^/^n

TABLE 2

GUIDE FOR WELDING SHADE NUMBERS

Operation

Shielding metal arc welding

Gas metal arc welding and flux cored arc welding

Air carbon Air cutting

Plasma arc welding

Plasma arc cutting

Torch brazing

Torch soldering

Carbon arc welding

Electrode Size Un inch

Less than 3 3-5 5-8 More than 8

'

(Light) (Heavy)

(Light) (Medium) (Heavy)

Arc Current (A)

Less than 60 60-160 160-250 250-550

Less than 60 60-160 160-250 250-500

150-500 Less than 500 500-1000

Less than 20 20-100 100-400 400-800

less tiian 300 300-400 400-800

. . .

_

Minimum Protective

Shad<?

7 8 10 11

7 10 10 10

10 10 11

6 8 10 11

8 9 10

.~

—

Suggested" Shade No. (Cgmfprt)

10 12 14

11 12 14

14 12 14

6 to 8 10 12 14

9 12 14 3 o r 4

2

14

•As a rule of thumb, start with a shade that is too dark to see the weld zone. Then go to a lighter shade which gives sufficient view of the weld zone without going below the minimum. In ojq^el gas welding or cutting where the torch produces a high yellow light it is desirable to use a filter lens that absorbs the yellow or sodium line in the visible light of the (spectrum) operation.

n.*-«-» ^ o t » i

Dlîn

TABLED

.xnBBôRCirrnt^^ S H A D B I ^ ^ ^ ^

ligjit

Heavy

oxygen catting

light êdinjn Heavy

Under 1/8 1/8 to 1/2 over \ l^

Under 1 l to6^ Over 6

Mininwni

4 or 5 5 or 6 6or8

3 or 4 4 or 5 5 or 6

J H M Corporation £

INDEMNIFICATION AND RELEASE AGREEMENT

FOR A>TD IN CONSEDERAHON OF the use by the undersigned of property belonging to OHM Remediation Services Corp. (hereinafter referred to as "OHM") and which may include full-face mask respirators, self-contained breathing apparatus, and other equipment and supplies, and other good and valuable consideration, the undersigned , for himself and his successors, and assigns, does herel^ release and discharge OHM, its officers, employees, agents, and subcontractors from any and all daims, actions, demands, damages, costs, loss of services, expenses, compensation, third-party actions, or suits, including attorneys fees, arising and resulting from the aforementioned use of property, equipment, or supplies belonging to OHM

In addition, the undersigned, on behalf of his employer, principal, himself, and his successors, and assigns, agrees to release, save, and hold harmless, protect indemnify, and defend OHM, and its officers, employees, agents, and subcontractors against any and all claims, actions, and expenses as above described, whether for bodily injury, property damage or destruction, or both, arising or resulting in anyway from the use by the undersigned of property of OHM and agrees to save, hold harmless, protect, indemnify, and defend OHM against any such claims, actions, or expenses, referenced above, that might be brought against OHM by any third persons or the heirs, successors, executors or assigns of the undersigned.

The undersigned acknowledges by signing that he has carefully read this Agreement understands —the contents thereof, and has freely and voluntarily signed the same,

EXECUTED on , 19 .

1. OHM Regional Vice President (or designee) authorizing use of equipment:

2. CLTENT OR SUBCONTRACTOR REPRESENTATIVE AUTHORIZING EOUIPMENT USE;

I authorize the individual(s) in 3, below to use OHM provided personal protective equipment

Company Name

Sign Name

Print Name •,

Title

INDIVIDUAL USING EOUIPMENT: I certify that I am familiar with the equipment and medically qualified to wear the equipment

Company Name_ '

Sign Name

Print Name

NOTE: A continuation sheet can be used if more than one individual is to be certified to use equipment

OHM Representative Acknowledging Signatures:

Sign Name

levised 11/19/92 OHM Health and Safety Department

ohm remediation services corp.ohm remediation services corp. (ohm) is pleased to present this health...

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