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Bennett's Quarry
HEALTH AND SAFETY PLAN

Monroe County, Indiana
August 6, 1999


Introduction | 2.0 Site Description And Scope Of Work |Key Personnel | Hazard Assessment | Schedule

1.0 INTRODUCTION

 This site-specific Health and Safety Plan (HASP) describes the health and safety procedures to be implemented during remediation of the Bennett's Quarry site in Monroe County, Indiana. The purpose of the plan is to communicate the known and suspected hazards associated with the project and to establish appropriate safety procedures for all companies, agencies, and personnel working at the site.

This HASP has been developed through the cooperation of key employees of CBS and PSARA Technologies, Inc. Prior to the start of work, each contractor will be required either to adopt this HASP for their personnel or to submit a company-specific HASP to the site Health and Safety Coordinator (HSC) for review and comment. Any company-specific HASP, however, must be at least as protective of site personnel as this site-specific HASP.

Should additional contractors or subcontractors become involved in potentially hazardous work at the site, they will be required to adopt the site-specific HASP for their personnel. In this event, the new contractor will be given the opportunity to review this HASP and request any modifications appropriate to the natureof their work. Any request for site-specific HASP modification must be reviewed and approved by theHSC and the CBS Project Manager as described in the HASP.

The term "site" as used throughout this document refers to that portion of the Bennett's Quarry site that willbe secured and used for project operations during the excavation, loading, and transfer of contaminated materials. This includes all exclusion zone and support zone areas.

The procedures contained herein are based upon the best available information at the time of the plan's preparation. As new information becomes available, the HASP will be revised accordingly to ensure protection of site personnel. To make a revision to the HASP document, the revision must be described in a Memorandum of HASP Modification, approved by the HSC and the CBS Project Manager, andprovided to the HSC from each contractor on site for review and comment. In addition, copies of anyMemorandum(s) of HASP Modification will be promptly sent to all of the Consent Decree Parties. The Memorandum must then be affixed to the HASP and communicated to site personnel.

2.0 SITE DESCRIPTION AND SCOPE OF WORK


2.1 SITE DESCRIPTION

Bennett's Quarry is located approximately 2.5 miles northwest of Bloomington, Indiana, in the NE 1/4 of Section 30, T9N, R1W. Figure 1 shows the general location of the site. The site consists of two areas. The main area is approximately 3.5 acres in size and is bordered by the quarry access road to the east and south and by Stout Creek to the west. The second area (hereafter referred to as the satellite area) comprises approximately 0.5 acre and is located approximately 100 ft east of the main area across the quarry access road. Both areas are secured at the perimeter by a 6-ft-high chain-link fence with barbedwire around the top.

The abandoned Monon Railroad track is located between the main site and Stout Creek. The former railline is generally overgrown with low brush and trees. The main site is covered by a clay cap believed to be approximately 16 to 22 in. thick. CBS maintains the cap, as well as the security fences. There is a large pile of old quarry rock located along the eastern edge of the site. Large quarry blocks are also present on the cap in two places to serve as cable anchors for quarry operations just west of the site. Within the perimeter of the main area are some large trees, particularly along the north and east ends of the site. Limited site clearing was performed in the wooded areas in December 1998 to facilitate a geophysics investigation.

The smaller satellite area is approximately 230 ft by 160 ft and is located some 50 ft south of a deep quarryexcavation. The area is characterized by large piles of old quarry rubble and some large trees. Two large pieces of rusted quarry equipment are present in the northwestern and southwestern portions of the site.

2.2 SCOPE OF WORK

This HASP has been prepared in conjunction with the development of the Remedial Action Work Planfor Bennett's Quarry dated June 1999. The provisions of this HASP are based upon the detailed scope ofwork described in that plan. A brief description of the nature of the work is provided below.

2.2.1 Site Preparation/Site Setup

Prior to the start of excavation, the following site preparation activities will take place:

2.2.2 Remediation Activities for Bennett's Quarry

The material contained in Bennett's Quarry will be removed using conventional excavation equipment. Based on existing data, the material will be excavated and transported to a Toxic Substances ControlAct (TSCA) landfill. The following major steps will be used to remove TSCA materials as presented in the Remedial Work Plan:


3.0 KEY PERSONNEL



The following individuals have been identified as key personnel for this project. Their roles and responsibilities are described in this section.

CBS Project Manager: Mr. Jim Patrick
CBS Project Engineer Mr. Ray Taylor
Remediation Contractor Project Manager: Mr. Dave Delaney
Site Health & Safety Coordinator: Mr. Brad Brees


3.1 CBS PROJECT
MANAGER

The CBS Project Manager will have overall responsibility for all aspects of the project. He will be on site as necessary to ensure that the project is being conducted in accordance with the Work Plans. The Project Manager will be responsible for approving (on behalf of CBS) any modifications to the technical approach or any alternates or equivalents that may be suggested by the contractor or other Consent Decree Parties. The CBS Project Manager will also be responsible for submitting weekly safety and air monitoring reportsto the Consent Decree Parties during remediation activities.

3.2 CBS PROJECT ENGINEER

The CBS Project Engineer or his designee will be responsible for overseeing daily project activities and forcoordinating the various contractors involved in the project. He will be responsible for documenting andreporting daily progress and resolving issues related to safety, air monitoring, and project operations. He wealso be responsible for tracking all costs from all contractors involved.

3.3 REMEDIATION CONTRACTOR PROJECT
MANAGER

The Remediation Contractor Project Manager will be responsible for implementing the remediationactivities described in the Work Plan and other contract documents and for supervising contractoremployees. The Remediation Contractor Project Manager will be responsible for overseeing all operationsrelated to the transportation of TSCA and non-TSCA material from the site, including scheduling,manifesting, placarding, and all other applicable Department of Transportation (DOT) rules and regulations.In addition, he will be responsible for ensuring that all remediation personnel meet applicable regulatoryrequirements (i.e., training and medical monitoring) and conduct work operations in accordance with therequirements of this HASP.

3.4 SITE HEALTH AND SAFETY COORDINATOR

The site HSC will have primary responsibility for the daily implementation of the HASP at the site. This person will be responsible for all health and safety activities, including safety training, air monitoring, site inspections, and decontamination of personnel, equipment, and materials leaving the site. The HSC will also be charged with the responsibility of enforcing the use of personal protective equipment (PPE) and training site personnel as outlined in Section 9.0 of this HASP. The HSC will have experience in field operations with air monitoring instruments, PPE, decontamination procedures, and emergency equipment and procedures. In addition, the HSC will conduct an onsite chemical inventory and will provide Material Safety Data Sheets (MSDSs) for each chemical identified at the site to the CBS Project Manager and Remediation Contractor Project Manager. Copies of the MSDSs will also be posted at the HSC's office trailer.

4.0 HAZARD ASSESSMENT

 This section addresses the identified health and safety hazards associated with the activities covered by thisWork Plan. Specific hazards associated with each task to be performed are outlined in the Health andSafety Requirements Matrix presented in Appendix A.

Additional job hazard analyses will be performed by the HSC and the Remediation Contractor Project Manager on an as-needed basis. These task-specific hazard analyses will address the hazards and safety procedures associated with individual operations or tasks, such as permitting a confined space entry or developing a lifting plan for crane operations.

4.1 CHEMICAL HAZARDS



Polychlorinated biphenyls (PCBs) have been determined to be the primary constituents of concern on site.Waste materials containing PCBs >50 ppm will be disposed of at a TSCA-perrnitted facility. An MSDS for PCBs is presented in Appendix B. The MSDS provides a summary of toxicological data information, chemical properties, and proper handling procedures for the materials.

Activities involving a potential for exposure to PCBs include but are not limited to:

Some potential for exposure to PCBs is associated with the loading of impacted material for transportation offsite. The PPE and procedures specified for these specific activities will reflect the level of protection needed. Activities may be reclassified as more environmental data are evaluated (e.g., air monitoring).

Some project activities may have the potential to result in offsite exposure to the public. The potential for public exposure is greatest through the inhalation route because of the possibility of fugitive dust emissions. Air monitoring will be performed around the perimeter of the site to assess the migration of constituents from impacted areas, if any. Perimeter and personnel exposure monitoring are presented inthe Air Monitoring Plan (AMP) for the Bennett's Quarry site (PSARA, June 8, 1999), which is included in Appendix D of the Remedial Action Work Plan.

The dust release potential will be mitigated by dust suppression and material handling procedures designed to minimize the generation of dust. These procedures will include minimizing the extent of open excavation and consolidation areas to help reduce the total amount of dust released. Once materials have been placed, they will be covered to prevent erosion, as needed.

Capacitors containing PCB fluids will be removed from the site. Although these materials will be primarily handled using heavy equipment, there is still a potential for dermal contact from fluid that may leak or spill from damaged capacitors. Handling oily or oil-filled waste will require stringent PPE adherence, which is addressed in Section 6.0 of this HASP.

In addition to PCB exposure, the excavation of material from a former dump site presents the potential for exposure to a range of other potentially hazardous substances. These could include asbestos, lead, solvents, hazardous residential wastes, or drums of industrial waste placed prior to the implementation of the RCRA regulations. Based on the period of operation of the dump, however, only minimal amounts of asbestos-containing materials should be present. Continuous organic vapor monitoring, including personnelmonitoring, will be used along with ongoing inspection of the excavation areas to identify any potentiallyhazardous conditions. The HSC and contractor health and safety officer will be responsible for determining safety precautions, changes to the PPE program, or other modifications to this HASP that would be appropriate in response to unanticipated chemical hazards.

Every hazardous chemical that is brought on site by any of the contractors must be reported to the HSC in accordance with the Occupational Safety and Health Administration's (OSHA's) Hazard CommunicationStandard, 29 CFR 1910.1200. Any hazardous material that is present on site must be addressed in the site-specific Hazard Communication Program, which will be available at the command post. A chemical inventory will be kept to track all chemicals that are brought on site. The written Hazard Communication Program will address all hazards associated with the chemicals in use. The hazards associated with these materials will be conveyed by the HSC to personnel involved in their use prior to beginning work activities.

4.2 BIOLOGICAL HAZARDS



Biological hazards include plants, animals, bacteria, or viruses that may cause disease in humans. A wide variety of biological hazards are present in and around the Bennett's Quarry site work area. These include, but are not limited to, ticks (Lyme disease and Rocky Mountain spotted fever), poison ivy and oak, chiggers, rodents, bees, wasps, snakes, and bloodborne pathogens. Workers should avoid contact and adopt appropriate controls. Allergic reactions caused by contact with plants, insect bites, and other biological hazards should be reported to the HSC.

All first aid activities involving potential exposure of personnel to blood or blood-tainted (contaminated) body fluids shall be conducted in accordance with the requirements of the Bloodborne Pathogen Standard 29 CFR 1910.1030. Personnel involved in first aid procedures shall don the proper PPE and dispose ofblood-contaminated materials as required. Responding personnel will don surgical gloves and other PPE deemed necessary by the HSC at the time of the incident. An adequate inventory of such PPE will be maintained with the first aid kit located at the first aid station near the decontamination area and in the HSC's office trailer. Contact with blood or blood-tainted body fluids during first aid procedures should be reported immediately to the HSC.

4.3 PHYSICAL AND ENVIRONMENTAL HAZARDS



Physical and environmental hazards may be encountered during work activities. The HSC will be responsible for maintaining written procedures or Safety Standard Operating Procedures (SSOPs) for manyof these activities. Contractors or subcontractors preferring to use their own procedures may do so, where applicable, provided they are at least as protective of site personnel as this sitespecific HASP. Prior to usingan alternate procedure, however, the contractor will be required to submit the company's written program to the HSC for approval. Work activities will be performed in accordance with applicable OSHA regulations.Specific emphasis will be placed on the anticipated physical and environmental hazards described in the paragraphs that follow.

4.3.1 Slips, Trips, and Falls

All work paths and work areas must be kept clear of slip and trip hazards. To control material spills, plastic sheeting will be placed on the ground between the material being loaded and the truck (see Section 11.6). Workers should be aware of the slip hazard associated with the plastic sheeting. Applicable OSHA standards for walkways, stairways, etc. (29 CFR 1926.500) will apply.

Landfills and dump areas are often characterized by pits, voids, or areas of unstable ground caused by settling or erosion. Strict adherence to foot protection will be required. Workers should go out of their way to walk on compacted roads where sure footing is more available.

Due to the slip and trip hazards described above, compounded by the nature of trash to contain sharp objects, there is a high hazard potential for puncture wounds at this site. Tetanus, an acute spasmodic disease, is commonly caused when the skin is punctured or cut by an object that can carry infection, sucha rusty nail. All persons working on the site must have had a tetanus or booster shot within the last 5 years.

4.3.2 Heavy Equipment

Only experienced equipment operators shall be permitted to operate heavy equipment. All machines will be supplied with a fire extinguisher and a backup horn. Equipment should be inspected by the operator each morning prior to use to ensure that all safety equipment and devices (e.g., backup alarms, brakes) are fully operational.

The number of ground personnel working around heavy equipment shall be kept to a minimum. Workers should maintain eye contact with operators. In addition, all ground personnel shall wear orange safetyvests for easy identification. Should heavy equipment operations continue after daylight work hours, all persons working on site will be required to wear reflective safety vests and to put reflectors on all sides of their hard hats.

4.3.3 Fuel Storage

A storage area will be established in the support zone for all fuels and other flammable liquids. The area will be clearly marked with "Caution - Flammables" and "No Smoking" signs. The area also will include a secondary containment berm to control spills. Site personnel will strictly adhere to applicable provisions of29 CFR 1926, Subpart F. Fire Protection and Prevention, when handling, using, and storing flammable and combustible materials. The fuel storage area will be inspected daily by the HSC for signs of leakage, spillage, containment integrity, and improper storage.

4.3.4 Electrical Power



All electrical power must have a ground fault circuit interrupter as part of the circuit. All equipment must be suitable and approved for the class of hazard. Applicable OSHA standards for electrical equipment (29CFR 1926, Subpart K) shall apply.

4.3.5 Equipment Decontamination - Pressure Washer Operations

Personnel participating in equipment decontamination activities and processing of large items removed during excavation activities shall be properly trained in the operation of the pressure washer prior to beginning decontamination activities. Equipment shall be inspected each day prior to use. All personnel shall don the proper PPE as defined in Section 6.0. The area will be clearly marked, and all employees not directly involved in these activities shall remain outside the work area.

4.3.6 Heat Stress

When the temperature exceeds 70_F and personnel are wearing protective clothing, a heat stressmonitoring program will be implemented, as appropriate. The HSC will be responsible for implementingthis program and for monitoring site personnel for the signs and symptoms of heat stress.

Adequate drinking water will be made available by the contractor at work stations.

4.3.7 Cold Stress

Potential exposure to extreme cold coupled with the presence of moisture may result in cold stress related disorders. The HSC will be responsible for monitoring site personnel for the signs and symptoms of coldstress (e.g., skin condition and color, sluggishness). If the signs and symptoms of cold exposure are discovered, the HSC will be responsible for implementing appropriate first aid procedures. An enclosed heated environment will be made available at the site during the duration of the project.

4.3.8 Flame, Heat, or Spark-producing Operations

< Utilization of flame, heat, and/or spark-producing equipment (e.g., cutting, welding torches, or abrasive saws) may be necessary during the course of this project. When the use of such equipment isnecessary, the employee will obtain a Hot Work Permit from the HSC, and the operation will be carefully monitored to ensure compliance with the provisions stated in 29 CFR 1926.353 for flame, heat, or spark-producing operations.

4.3.9 Noise

Those employees working around heavy equipment or in other noisy areas are subject to possible exposure to noise above the OSHA Permissible Exposure Limit (PEL) of 90 decibels (dBA). All heavy equipment operators will be required to use hearing protection unless sound level measurements clearly demonstrate that protection is not required. Other employees will utilize hearing protection when working around heavy equipment or in areas where sound level measurements in excess of 85 dBA are encountered.

4.3. 10 Lifting

All personnel should know their lifting limits and the proper way(s) to lift an object. Lifting should be limited by factors such as: the route and distance to be traveled, the amount of time required, and the centerof gravity necessary to handle the load safely. A worker shall not lift more than 50 lb without assistance from another person or mechanical help. This includes handling and sorting of capacitors.

4.3.11 Hand Tools/Power Tools

Proper eye, face, and hearing protection shall be provided and worn while using all power tools. All tools shall be inspected by the user prior to beginning work operations. Defective tools will not be used and will be tagged out. Only tools designed for the application in mind will be used. The proper strength tool will be used as specified for each job. For hand tools, the use of handle extensions and cheater bars is prohibited.

Power tools and machines will be disconnected from their power source before making adjustments or attachment changes. Guards or safety devices will not be removed. All fuel powered tools will be shut off before refueling. Blade guards must be in place and working properly. Air-powered tools must have safety clips or retainers on all hose connections. Manufacturers' safe operating pressures will not be exceeded for any fittings.

4.3. 12 Excavations



During excavation activities, appropriate monitoring will be conducted. If personnel enter an excavation 4 ft deep or greater, hazardous atmosphere monitoring will be conducted. Further, if the excavation is 5 ft deep or greater or the potential for cave-in exists, actions will be taken to address the stability of the excavation in accordance with 29 CFR 1926.650, Subpart P. Excavations.

Daily inspections shall be made by the HSC or another competent person for evidence of a situation that could result in possible cave-ins, indications of failure of protection systems, hazardous atmospheres, or other hazardous conditions. Excavations shall be inspected either daily or prior to entry and shall also be inspected after every rain storm.

Open excavations that are to be left open shall be barricaded with safety fence.

4.3.13 Confined Space Entries



No person on this site is permitted to enter a confined space, as defined by the HSC, until a confined space entry permit has been completed. This permit verifies that the confined space is safe for entry and that it has been tested for oxygen level, flammable vapors, and toxic gases. Monitoring of the confined space and completion of the permit is the responsibility of the HSC. All persons on this site are equired to comply with the requirements of 29 CFR 1910.146.

5.0 SITE CONTROL AND STANDARD OPERATING PROCEDURES

5.1 WORK ZONES

The objectives for establishing work zones at this site are to delineate clearly the hazardous area perimeter, prevent migration of hazardous materials into clean areas, and prevent access or exposure to hazardous areas by unauthorized persons. Figure 2 shows the approximate locations of key work zone boundaries and identifies the anticipated locations for personnel and equipment decontamination facilities and field offices at the Bennett's Quarry site. Truck staging areas and turnarounds are presented on Figure 6 of the Work Plan. Fuel and flammable liquids storage, site access, parking, and sanitary facilities will be established upon mobilization.

In the event that modifications to this work zone plan become necessary during either mobilization or siteoperations, a revised drawing(s) will be prepared, approved, and distributed as a modification to this HASP as described in Section 1.0.

5.1.1 Exclusion Zone

The exclusion zone boundaries will be clearly identified with caution tape or safety fence, and signs will beposted. Access to the exclusion zone will be limited to the access corridor, where personnel are required to don personal protective clothing as described in Section 6.0 of this HASP. All personnel entering the exclusion zone will be required to meet the training and medical monitoring requirements defined inSections 9.0 and 10.0 of this HASP.

5.1.2 Contamination Reduction Zone



The contamination reduction zone/decontamination zone is the area where all personnel and equipment decontamination will take place. This area will be clearly identified, and access will be restricted. Separate facilities are anticipated for personnel and equipment decontamination, as discussed in Section 7.0 of this HASP.

In addition to decontamination facilities, each contamination reduction zone will include the site access corridor and an emergency station. The access corridor provides a single point of entry for personnel entering and exiting the exclusion zone and facilitates accurate tracking of personnel in that zone. This corridor includes a storage area for PPE and an area to dress out prior to entering the exclusion zone. The emergency station in the personnel decontamination area will be accessible from both the exclusion zone and the support zone and will include, as a minimum, an emergency shower, an emergency eye wash, a fire extinguisher, and a first aid kit (Figure 2). Emergency equipment is further discussed in Section 11.0.

5.1.3 Support Zone

The support zone includes all areas for support operations, including office facilities, equipment storage,a break area, sanitary facilities, emergency vehicle access, fuel and flammable liquids storage, and designated parking. No PCB-impacted material will be placed in this zone.

5.1.4 Project Control Zone

The project control zone identifies es the entire area that is under secured project control and is restricted from access by the general public. This zone is delineated for the purpose of clarifying the boundary for perimeter air monitoring and for the prevention of accidental entry into the project work areas by the general public.

5.2 SITE SECURITY

Security for the Bennett's Quarry site will be provided during working hours. The access gate will be located on the site access road near the Hunter Valley Road intersection where the old bar gate had been. This gate will be locked during non-working hours.

5.3 VISITORS

All visitors to the project site will be required to report immediately to the guard shack and sign in.Visitors' vehicles should be parked in designated locations to avoid interfering with project operations.

In general, visitor access to the site will be limited to the office trailer and adjacent parking area. In the event that it becomes necessary for a site visitor to proceed beyond this point, he/she must be escorted at all times by the CBS Project Engineer, the HSC, or their designee. Visitors intending to enter the restricted areas must first participate in a site orientation training session as described in Section 9.2. No access into exclusion zones will be permitted during site operations without providing documentation of HAZWOPER training and medical monitoring to the HSC prior to entry. The site HSC will be responsible for authorizing entry into restricted areas and for determining which areas are appropriate for site visitors based upon his/her current knowledge of hazards and ongoing site operations.

5.4 GENERAL FIEED SAFETY AND STANDARD OPERATING ROCEDURES

The following is a list of policies and procedures to be implemented during work operations at this site:

The "buddy system" will be used by all field personnel in the exclusion zone. Visual, voice, orradio communication must be maintained at all times.

Eating, drinking, and smoking are permitted only in designated areas in the support zone.No smoking will be permitted except in the designated area.

Hands and face must be thoroughly washed immediately upon leaving the decontamination zone and prior to eating, drinking, smoking, or applying cosmetics.

5.1.4 Project Control Zone

The project control zone identifies the entire area that is under secured project control and is restrictedfrom access by the general public. This zone is delineated for the purpose of clarifying the boundary for perimeter air monitoring and for the prevention of accidental entry into the project work areas by thegeneral public.

5.2 SITE
SECURITY

Security for the Bennett's Quarry site will be provided during working hours. The access gate will be located on the site access road near the Hunter Valley Road intersection where the old bar gate had been. This gate will be locked during non-working hours.

5.3 VISITORS

All visitors to the project site will be required to report immediately to the guard shack and sign in.Visitors' vehicles should be parked in designated locations to avoid interfering with project operations.

In general, visitor access to the site will be limited to the office trailer and adjacent parking area. In the event that it becomes necessary for a site visitor to proceed beyond this point, he/she must be escorted at all times by the CBS Project Engineer, the HSC, or their designee. Visitors intending to enter the restricted areas must first participate in a site orientation training session as described in Section 9.2. No access into exclusion zones will be permitted during site operations without providing documentation of HAZWOPER training and medical monitoring to the HSC prior to entry. The site HSC will be responsible for authorizing entry into restricted areas and for determining which areas are appropriate for site visitors based upon his/her current knowledge of hazards and ongoing site operations.

5.4 GENERAL FIELD SAFETY AND STANDARD OPERATING PROCEDURES

The following is a list of policies and procedures to be implemented during work operations at this site:

The "buddy system" will be used by all field personnel in the exclusion zone. Visual, voice, or radio communication must be maintained at all times.

Eating, drinking, and smoking are permitted only in designated areas in the support zone.No smoking will be permitted except in the designated area.

Hands and face must be thoroughly washed immediately upon leaving the decontamination zone and prior to eating, drinking, smoking, or applying cosmetics.

6.0 PERSONAL PROTECTIVE EQUIPMENT

6.1 GENERAL

The following subsections describe the minimum PPE to be used by all personnel involved in project operations at this site. The PPE described here has been selected based on the anticipated chemical and physical hazards associated with each work zone and job function included in the Remedial Work Plan. This plan may be modified if project hazards or air monitoring results identify higher-than-anticipated levels of PCB exposure.

6.2 PERSONAL PROTECTION MATRIX

Table 1 provides a list of job functions and work zones and identifies the PPE required for each scenario. As additional work tasks are identified during the course of the project, the HSC will be responsible for identifying the appropriate regimen of PPE and for adding the new scenario to this table.

Table 1. Personal Protection Requirements for Specific Activities

Bennett's Quarry Site, Monroe County, Indiana

Activity Location Level of Protection
Site preparation Entire site Level D
Excavation and loading Exclusion zone Modified Level D (upgrade to Level Cbased on personnel air monitoringresults)
Capacitor handling Exclusion zone
Processing of large items via spray washing Exclusion zone Modified Level D with splash gear
Wastewater treatment Water Treatment area Modified Level D
Post-excavation sampling Exclusion zone Modified Level D
Equipment decontamination (including pressure washing) Contamination reduction zone Modified Level D with splash gear
Support zone operations Support zone Level D

6.3 LEVELS OF PERSONAL PROTECTIVE EQUIPMENT

The following are brief descriptions of the levels of PPE that will be required for site activities.

Level "D" Protection

This is the minimum level of protection for all personnel on site and is generally required for all support zoneoperations.


Modified Level "D" Protection

This is the level of protection that is initially anticipated for material handling operations inside the exclusion zone.



Modified Level "D" Splash Gear:

This dress-out regimen is intended primarily for all "wet" work involving contact with PCB-impacted decontamination or runoff water, as during equipment decontamination operations.

Level "C" Protection

This is the level of protection that will be implemented if personnel exposure exceeds the action levels identified in Section 8.0 and detailed in the AMP.

7.0 DECONTAMINA TION

In general, everything that enters the exclusion zone must either be properly decontaminated or properly disposed of upon exit from the exclusion zone. All personnel must enter and exit the exclusion zone through the decontamination zone. Any material that is generated by decontamination procedures will bestored in a designated area in the exclusion zone until disposal arrangements are made. All wash/rinse water generated during decontamination activities will be collected and transferred to the wastewater treatment process for treatment and disposal.

7.1 PERSONNEL DECONTAMINATION

At a minimum, the personnel decontamination facilities will include the following stations:



All personnel who enter the exclusion zone will be required to wash hands and face with soap and water prior to eating, drinking, smoking, or applying cosmetics.

Personnel decontamination operations will be conducted atop plastic sheeting with bermed sides to contain liquids and other materials that may be generated in the process.

7.2 EQUIPMENT DECONTAMINATION



Prior to demobilization, equipment will be decontaminated and inspected by the HSC or his designee before it is moved into the support zone. These inspections will be recorded by the HSC in the daily site log book.

Any vehicle working in an exclusion zone will be decontaminated before leaving the site. The vehicle will be cleaned by sweeping excess soil and debris off the wheels. A high-pressure sprayer will then beused to wash the wheels, if necessary. Each piece of equipment will be inspected after cleaning for anysoil remaining on the tires or elsewhere. A wipe sample may be collected on heavy equipment to verify compliance with OSHA occupational exposure levels. All vehicles will be cleaned to the satisfaction ofthe HSC or his designated assistant prior to entering the support zone or leaving the site.

8.0 AIR MONITORING AND ACTION LEVELS



Elevated airborne PCB concentrations represent the primary worker exposure concern at the site. To ensure an effective program of sampling and monitoring air quality, both in the work zones and at the site perimeter, an AMP has been developed for the Bennett's Quarry site (PSARA 1999), which is included in Appendix D of the Remedial Action Work Plan. This AMP details the perimeter, area, and personnel monitoring to be conducted during site activities to identify the potential for worker exposure and the migration of contaminants during work operations.

Briefly, the air monitoring program will include the collection of personnel and perimeter air samples and the use of real-time monitoring equipment. Methods, frequencies, action levels, and record keeping requirements for this site are summarized in Table 2 and detailed in the AMP.

Results of the daily air monitoring activities will be recorded and evaluated by the HSC. All data will be maintained with the project records and available for review. A weekly report summarizing the air monitoring activities of the prior week for the Bennett's Quarry site will be prepared and submitted to the Consent Decree Parties.

Table 2. Site-specific Air Monitoring Requirements
Bennett's Quarry Site, Monroe County, Indiana



Instrument Location/Frequency Hazard Action Level Action
Perimeter PUF sampler Daily for minimum of 20 hr during remedial activities. PCBs greater than or equal to ug/m3 above background Implement engineering controls for dust suppression.
Personnel sampling pumpInitially, daily from personnel selected by HSC. Subsequent frequency to be determined by HSC. PCBs >0.125 mg/m3

<0.01 mg/m3		 Identify source and upgrade to Level C (Sec. 6.0).

Decrease frequency of sampling as defined in the AMP.
MiniRAM Periodically during dust generating activities (e.g., excavation, truck loading) Total dust >10 mg/m3 above background (5-min TWA) Implement engineering controls for dust suppression. Increase frequency of monitoring.
Photoionization detector (PID) Continuous monitoring in solid waste excavation areas. Organic vapors (unknowns) 5 ppm Evacuate immediate work area. Notify HSC
.

9. 0 TRAINING REQUIREM EN TS



9.1 HAZWOPER TRA INING



All personnel (including visitors) entering the exclusion zone or decontamination zone must have completed all applicable training requirements for hazardous waste site and emergency response work in accordance with OSHA 29 CFR 1910.120. Copies of the current training certificates for all personnel must be provided to the HSC before beginning work. In the event that any worker's annual training will expire during the course of the project, he must complete the required refresher training prior to the expiration date.

Personnel required to supervise or manage site investigation/cleanup personnel must have an dditional 8 hours of supervisory safety training as required under OSHA 29 CFR 1910.120.

9.2 SITE-SPECIFIC TRAINING

The HSC will design and implement a site-specific training program for all site employees. The program will present all aspects of this HASP and will provide site employees an opportunity to ask questions regarding the HASP. The HSC will instruct employees in proper material handling techniques; propermethods for the use, storage, and disposal of decontamination fluids; preventive maintenance of safety equipment; personal hygiene practices; PPE; and appropriate responses to emergencies.

The training program will provide site employees instruction on responding effectively to an emergency. The appropriate response to fires, explosions, and the shutdown of operations will be reviewed, as wellas the proper response to an unacceptable level of dust resulting from site activities. Emergency procedures, areas of the site that have restricted access, methods used for project decontamination, and general safety will also be covered in the training.

At a minimum, the site-specific orientation training program will cover the following topics:

Prior to working on site, replacement employees must report to the HSC and will be required toreceive the initial training given by the HSC. In addition, each person will be required to sign the Safety Plan Acknowledgment Form, which is included in Appendix C. By signing this form, individuals recognize the hazards present on site and agree to comply with the policies and procedures set forth in this HASP.

9.3 DAILY TAILGATE SAFETY MEETINGS

Daily safety meetings will be held by the HSC or his designee for all personnel at the site. During these meetings, the HSC will discuss any safety concerns, changes in site conditions, monitoring results, orother safety-related topics for the Bennett's Quarry site remediation activities. Periodic retraining onimportant site-specific safety issues may also be addressed. Attendance lists, including signatures and topics discussed for all safety meetings, will be maintained as part of the project safety records.

10.0 MEDICAL MON/TOR/NG REQUIREMENTS

Medical screening provides a method for identifying those employees whose medical history indicates potentially increased health risk when exposed to contaminants present within a working environment. The medical screening directly and indirectly measures the functional activity of organs potentially affected by chemical exposure during work and assesses the employee's ability to utilize protective equipment safely.

All CBS and contractor employees engaged in hazardous waste work will be required to participate in their respective company-sponsored medical monitoring programs, have a medical examination by a qualified physician, and be in good health prior to starting site work. An annual physical will serve as an exit examination for full-time CBS and contractor employees. At a minimum, the examination must be in accordance with OSHA Standards 29 CFR 1910.120 and 29 CFR 1910.134.

The medical examination must include a judgment by the examiner of the ability of the person to use negative- or positive-pressure respirators and whether he is medically able to perform his job. An individual determined to have a medical condition that could be aggravated directly or indirectly by exposure to those chemical substances or special conditions within the work environment will not be allowed to participate in any activity that could result in such exposure. Some typical conditions that might require such measures include reduced lung function (which would be a problem for respirator wearers), back conditions (which would limit one's ability to lift heavy objects), and liver conditions (which might be aggravated by exposure to lower levels of contaminants).

Any employee who suffers a lost-time illness or sustains a lost-time injury during the project must be reexamined by a physician before returning to the work site. The physician must certify that the employee is fit to return to work before his employment on site can continue. A written copy of this certification willbe maintained at the site and included in the employee's records.

No one other than personnel authorized by the HSC will be permitted to enter the exclusion areas. Before a site exclusion zone can be entered, a statement signed by a doctor indicating that a medical examination (encompassing the tests described previously) has been successfully completed will be required of everyone except emergency medical personnel. Copies of these physician statements will be maintained by the HSC as part of the project safety records.

11.0 CONTINGENCY PLAN

The following response procedures have been developed in an effort to prepare project site personnel to respond effectively in the event of an emergency.

Several types of emergencies are outlined in the following subsections. These are not intended to cover all potential situations, and the corresponding response procedures should not be followed blindly. Every accident is a unique event that must be dealt with by trained personnel working in a calm, controlled manner. In the event of an accident/unusual event, the prime consideration is to provide the appropriate initial response to assist those in jeopardy without placing additional personnel at an unnecessary risk.

11.1 GENERAL RESPONSE CONSIDERATIONS

Emergencies must be dealt with in a manner that minimizes the health and safety risks to site personnel and the public. The following procedures will be implemented in the event of an emergency:

To respond to emergencies, at least one person at the site in addition to the HSC will be certified in first aidand cardio-pulmonary resuscitation (CPR) by the American Red Cross or other approved agency. Theseindividuals will be available to provide emergency first aid in the event of an injury.

1 1.2 RESPONSIBILITIES

The HSC or a designated substitute will have the responsibility for directing response activities in the event of an emergency. The HSC will:


In the event that outside emergency response agencies are mobilized, the HSC will coordinate response activities with those of public agencies.

1 1 .3 EMERGENCY CONTACTS



Figure 3 presents a list of response agencies, organizations, and personnel who may, depending on the nature of the situation, need to be contacted in the event of a site emergency. All primary response agencies will be notified prior to commencement of work as to the nature of activities at the site.

In addition, all of these phone numbers will be verified from the project site during the initial site setup phase of the project.

11.4 EMERGENCY RESPONSE EQUIPMENT

During the site preparation phase of the project, the remediation contractor will mobilize the appropriate emergency response equipment and facilities. At a minimum, prior to the start of waste handling operations, the following equipment will be provided and tested to verify that it is in working order:


Other equipment used for the routine implementation of the worker health and safety protection andmonitoring programs (i.e., air monitoring equipment, confined space entry equipment) will be available asneeded to support any emergency response activity.

11.5 ACCIDENTS AND INJURIES



The vast majority of worker injuries on hazardous waste sites are not chemical in nature. The injuries tend to be sprains, rashes, and lacerations, which must be treated promptly. Follow-up care is extremely important to ensure that a minor injury or illness does not become aggravated by site conditions or continued work in chemical protective clothing. All site personnel are instructed to report any and allinjuries and illnesses to the HSC.

If a person working In an exclusion zone is physically injured, Red Cross first aid procedures will befollowed. Depending on the severity of the injury, emergency medical response may be sought. If the employee can be moved, he will be taken to the edge of the work area (on a stretcher, if needed), where contaminated clothing will be removed, emergency first aid administered, and transportation to a loca lemergency medical facility awaited. Directions and a map to the nearest hospital are presented in Figure 4. This figure will be posted at each site telephone and will be placed in each site vehicle.

If it is necessary for outside emergency medical personnel to enter the exclusion zone to treat or move an injured worker, the HSC will brief these personnel on the nature of the hazards present and will determine what protective equipment they must wear. Extra PPE will be available for emergencies.

If the injury to the worker is chemical in nature (e.g., overexposure), first aid procedures will be implemented as described in the MSDS for the chemical(s) involved. Material Safety Data Sheets for all hazardous substances that are present or will be used on the site will be compiled in the field and made available to all employees at the HSC's office trailer. Material Safety Data Sheets for known hazardous substances at the site are presented in Appendix B.

Personnel will conduct first aid procedures and dispose of all blood-contaminated materials in accordance with the requirements of the bloodborne pathogens standard, 29 CFR 1910.1030. All personnel shall be required to don safety glasses and latex gloves (at a minimum) when conducting firstaid procedures and cleanup operations where blood or blood-tainted body fluids are involved. They shall also be required to wash hands, face, and neck thoroughly following cleanup activities. Potential exposures should be reported to the HSC immediately.

1 1.6 SPILLS

Potential spills can occur from handling of damaged or leaking capacitors, improper fuel handling,overloading or improperly loading trucks, leakage or breakage of wastewater lines, and many other scenarios. The following procedures have been established to minimize the potential for accidental spillsand to maximize site preparedness in the event that a spill does occur. In addition to these measures, daily inspections of the site will be conducted by the HSC to evaluate the effectiveness of these measures and to identify and address any previously unanticipated spill scenarios.

Excavation will proceed so as to minimize the handling of capacitors over previously confirmed areas. Capacitors will be placed directly into DOT-approved containers as they are removed from the excavation area. The containers will be sealed as they are filled and staged in the loading area pending transport offsite.

All fuels, oils, and other flammable or combustible liquids will be stored in one designated spot on the site. This location will be equipped with secondary containment adequate to contain a release of 110 percent of the largest container plus additional freeboard to contain accumulated rainwater. The area willbe barricaded in a manner that allows effective refueling but prevents accidents from vehicular traffic. Signs will be posted identifying the area and prohibiting smoking.

To minimize spillage during the loading process, plastic sheeting will be placed on the ground between the material being loaded and the truck, and the truck liner will be draped over the side of the truck. Any spillage, whether from the truck or from the excavator bucket, will be cleaned up regularly and at least at the end of each work day. During rainy conditions, any needed spill cleanup will be accomplished immediately to avoid impacting stormwater. After loading, each truck will have aminimum of 6 inches of freeboard on all sides. Tires on loaded trucks will be washed prior to the truck leaving the site.

Wastewater will be contained in tanks that are located or barricaded to prevent accidents. Pumps and hoses will be drained and handled in a manner that minimizes leakage or spillage. Any spillage of PCB-impacted wastewater will be promptly cleaned up.

1.1.7 FIRES



Although a fire is unlikely, the office trailer will maintain effective communication to summon assistance inthe event of a fire. If a fire breaks out, the HSC will be notified immediately. The HSC will evaluate the extent of the fire and make a decision whether to call the local fire department or have site personnela ttempt to operate fire fighting equipment. Site personnel will only become involved in the fire fighting actions when the fire is clearly within the capability of the fire extinguishers on site. All personnel shall be trained in the use, capabilities, and limitations of the available fire extinguishers.

11.8 SITE EVACUATION PLAN

Procedures for evacuation have been established for this project even though the materials being handled and the procedures being used make an actual evacuation extremely unlikely. The evacuation routes from all areas of the site, to the rendezvous point, are presented in Figure 2.

Two types of evacuation procedures are in place for this project: emergency evacuation procedures and non-emergency evacuation procedures. An emergency evacuation is warranted only if the nature of thesituation is so extreme that implementation of a more controlled and orderly non emergency procedure could endanger the health or safety of site personnel.

In the event that an employee identifies a situation on the site that he believes warrants an evacuation ,he should immediately notify the HSC, the remediation contractor supervisor, or his immediate supervisor. Generally, the HSC or remediation contractor supervisor will be responsible for evaluating the situation and initiating an evacuation. Under extreme or obvious evacuation circumstances, however, any site worker can initiate an evacuation.

The primary means of initiating an evacuation will be an audible signal. A combination of air horns, truck horns, and site radios will be utilized to ensure that all site personnel are notified of the intent to evacuate the site. The audible signals will be as follows:

Single long blast (repeated as necessary):       

Double brief blasts:       
Non-emergency evacuation signal

In an emergency evacuation scenario, all site personnel will be directed to discontinue what they're doing immediately, notify their buddy and any other nearby workers, and quickly leave the site via the most accessible route as illustrated in Figure 2. Personnel should then proceed to the emergency evacuation rendezvous point located at the site entrance and remain there until directed by their supervisor. Emergency evacuation scenarios typically include toxic gas releases or major fires that have the potential to release toxic vapors or cut off escape routes. No such scenarios are anticipated on this project.

In a non-emergency evacuation scenario, personnel should discontinue their work, making sure all equipment is turned off and secure, and proceed with their buddy to the office trailer for further instructions. Non-emergency evacuation scenarios may include imminent severe thunderstorms tornado warnings, or airborne concentrations of contaminants that have reached evacuation action levels.

The HSC or designated representative will be responsible for coordinating evacuation procedures and for conducting a head count at the rendezvous point located at the site entrance. Missing personnelshould be reported immediately to the HSC, CBS Project Engineer, or outside response agency's representative.

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