BASEWIDE SITE SAFETY AND HEALTH PLAN FORMER FORT ORD, CALIFORNIA
TOTAL ENVIRONMENTAL RESTORATION CONTRACT CONTRACT NO. DACW05-96-D-0011 TASK ORDER NO. 011
Submitted to: U.S. Department of the Army Corps of Engineers, Sacramento 1325 "J" Street Sacramento, California 95814-2922
Submitted by: Shaw Environmental, Inc. #4 All Pro Lane Marina, California 95045
December 2004
Revision 8
Issued to:______Date:______
Copy #:______Controlled Uncontrolled BASEWIDE SITE SAFETY AND HEALTH PLAN FORMER FORT ORD, CALIFORNIA
TOTAL ENVIRONMENTAL RESTORATION CONTRACT CONTRACT NO. DACW05-96-D-0011 TASK ORDER NO. 011
December 2004
Revision 8
Approved by: Date: Peter Kelsall Project Manager
Approved by: Date: Tom Ghigliotto Contractor Quality Control System Manager
Approved by: Date: Charles Luckie Site Safety and Health Officer
Approved by: Date: Rudy VonBurg, C.I.H. Program Certified Industrial Hygienist CONTRACT NO. DACW05-96-D-0011 SITE SAFETY AND HEALTH PLAN ACKNOWLEDGMENT FORM
The contract for the above project requires that you be provided with complete formal and site- specific training; that you be supplied with proper personal protective equipment, including respirators; that you be trained in its use; and that you receive a medical examination to evaluate your physical capacity to perform your assigned work tasks under the environmental conditions expected while wearing the required personal protective equipment. These provisions are to be done at no cost to you. By signing this certification, you are acknowledging that your employer has met these obligations to you.
I HAVE REVIEWED, UNDERSTAND, AND AGREE TO FOLLOW THE SITE SAFETY AND HEALTH PLAN FOR THE FORT ORD REMEDIAL ACTION SITE.
PRINTED NAME SIGNATURE REPRESENTING DATE
CONTRACT NO. DACW05-96-D-0011 TRAINING ACKNOWLEDGMENT FORM
By signing this certificate, you are acknowledging that you have completed the following formal training courses that meet Occupational Health and Safety Administration (OSHA) requirements:
SITE-SPECIFIC TRAINING: I have been provided and have completed the site-specific training required by this Contract. The Site Safety and Health Officer conducted the training. ______Employee/Visitor Initials
RESPIRATORY PROTECTION: I have been trained in accordance with the criteria in Shaw Environmental’s/my Employer's Respiratory Protection Program. I have been trained in the proper work procedures and use the limitations of the respirator(s) I will potentially wear. I have been trained in and will abide by the facial hair policy.
______Employee/Visitor Initials
RESPIRATOR FIT-TEST TRAINING: I have been trained in the proper selection, fit, use, care, cleaning, maintenance, and storage of the respirator(s) that I will potentially wear. I have been fit-tested in accordance with the criteria in Shaw Environmental’s /my Employer's Respiratory Protection Program and have received a satisfactory fit. I have been assigned my individual respirator. I have been taught how to properly perform positive and negative pressure fit-check upon donning negative pressure respirators each time. ______Employee/Visitor Initials
MEDICAL EXAMINATION: I have had a medical examination within the last 12 months, which was paid for by my employer. The examination included health history and pulmonary function tests and may have included an evaluation of a chest x-ray. A physician made a determination regarding my physical capacity to perform work tasks on the project while wearing protective equipment, including a respirator. I was personally provided a copy and informed of the results of that examination. My employer's Site Safety and Health Officer evaluated the medical certification provided by the physician and signed the appropriate blank below. The physician determined that there were: no limitations to performing the required work tasks: ______Employee/Visitor Initials identified physical limitations to performing the required work tasks: ______Employee/Visitor Initials
[Employee's] [Visitor's] Signature ______Date ______Printed Name ______Social Security Number ______Employer's Site Safety and Health Officer Signature ______Date ______Printed Name ______Social Security Number ______
Table of Contents______
List of Tables ...... v List of Figures ...... vi List of Forms...... viii List of Appendices ...... ix Acronyms and Abbreviations...... x 1.0 Introduction...... 1-1 1.1 Document Organization...... 1-2 1.2 Site Description ...... 1-4 1.2.1 Operable Unit 1 Groundwater Treatment System...... 1-6 1.2.2 Operable Unit 2 Groundwater Treatment System...... 1-6 1.2.3 Sites 2/12 Groundwater Treatment System...... 1-7 1.2.4 Operable Unit 2 Landfills ...... 1-7 1.2.5 Site 39 Impact Area...... 1-8 1.2.6 Site 39A East Garrison Area ...... 1-8 1.2.7 Munitions Response Sites...... 1-9 1.2.8 Operable Unit Carbon Tetrachloride Plume...... 1-9 1.2.9 Aboveground and Underground Storage Tank Sites...... 1-9 1.3 Site-Specific Work Plans ...... 1-10 1.4 Regulatory Guidance...... 1-10 2.0 Organization, Qualifications, and Responsibilities ...... 2-1 2.1 All Personnel ...... 2-1 2.2 Occupational Physician ...... 2-1 2.3 Certified Industrial Hygienist...... 2-1 2.4 Site Safety and Health Officer ...... 2-2 2.5 Health and Safety Technicians...... 2-3 2.6 Unexploded Ordnance Safety Officer...... 2-4 2.7 Senior Unexploded Ordnance Supervisor ...... 2-4 2.8 Unexploded Ordnance Avoidance/Escort Personnel...... 2-4 2.9 Project Manager ...... 2-5 2.10 Superintendent...... 2-5 2.11 Independent Certified Industrial Hygienist...... 2-5 2.12 Subcontractors ...... 2-6 3.0 Hazard Analysis and Risk Assessment...... 3-1 3.1 Activity Hazard Analysis ...... 3-1 3.2 Job Safety Analysis ...... 3-2 3.3 Safety Observation Program ...... 3-2 3.4 Chemical Hazards ...... 3-3 3.4.1 Health-Significant Contaminants ...... 3-3 3.4.2 Other Potential Contaminants ...... 3-5 3.5 Biological Hazards...... 3-6 3.6 Exposure Standards...... 3-15 4.0 Training Requirements...... 4-1 4.1 General Training...... 4-1
Revision 8 i Basewide Site Safety and Health Plan Former Fort Ord, California
Table of Contents (continued) ______
4.2 Hazardous Waste Operations Training...... 4-1 4.2.1 40-Hour Training ...... 4-1 4.2.2 Supervisory Training...... 4-2 4.2.3 Refresher Training...... 4-2 4.2.4 Supervised Field Experience...... 4-2 4.3 Visitor Training ...... 4-2 4.4 Tailgate Safety Meetings...... 4-3 4.5 Site-Specific Training...... 4-3 4.6 Hazard Communication...... 4-3 4.7 First Aid and Cardiopulmonary Resuscitation...... 4-4 4.8 Bloodborne Pathogen Training...... 4-4 4.9 Lead Awareness...... 4-4 4.10 Asbestos Awareness...... 4-4 4.11 Military Munitions Recognition Training...... 4-4 5.0 Personal Protective Equipment...... 5-1 5.1 Respiratory Protection...... 5-1 5.2 Hearing Conservation...... 5-1 5.3 Levels of Protection...... 5-2 5.3.1 Level A Protection ...... 5-2 5.3.2 Level B Protection ...... 5-2 5.3.3 Level C Protection...... 5-2 5.3.4 Level D Protection...... 5-3 5.4 Activity-Specific Levels of Protection...... 5-4 5.5 Donning/Doffing Personal Protective Equipment...... 5-4 6.0 Medical Surveillance...... 6-1 6.1 Medical Examination ...... 6-1 6.1.1 Preplacement Examination...... 6-1 6.1.2 Annual Examination ...... 6-2 6.1.3 Exit Examination...... 6-2 6.2 Lead Standard Monitoring ...... 6-2 6.3 Subcontractor Requirements...... 6-3 6.4 Medical Records...... 6-3 6.5 Medical Restrictions ...... 6-3 7.0 Exposure Monitoring and Air Sampling Program ...... 7-1 7.1 Routine Monitoring Requirements ...... 7-1 7.2 Volatile Organic Compounds Monitoring ...... 7-1 7.3 Dust Emission Monitoring...... 7-2 7.4 Personal Air Monitoring ...... 7-3 7.5 Meteorological Monitoring ...... 7-3 7.6 Oxygen and Combustible Gas Monitoring...... 7-3 7.7 Calibration of Air Monitoring Equipment ...... 7-3 7.8 Other Hazardous Conditions ...... 7-4 7.9 Record Keeping...... 7-4
Revision 8 ii Basewide Site Safety and Health Plan Former Fort Ord, California
Table of Contents (continued) ______
8.0 Heat/Cold Stress Monitoring ...... 8-1 8.1 Heat Stress...... 8-1 8.1.1 Signs and Symptoms of Heat Stress...... 8-2 8.1.2 Heat Stress Prevention...... 8-2 8.1.3 Acclimatization ...... 8-3 8.1.4 Physiological Monitoring...... 8-3 8.1.5 Training ...... 8-4 8.2 Cold Stress...... 8-4 9.0 Standard Operating Procedures, Engineering Controls, and Work Practices ...... 9-1 9.1 General Practices...... 9-1 9.2 Visitors to Field Activities...... 9-2 9.3 Buddy System ...... 9-3 9.4 Excavation Procedures...... 9-3 9.5 Hot Work ...... 9-5 9.6 Confined Space Entry...... 9-5 9.7 Sanitation ...... 9-5 9.7.1 Drinking Water...... 9-5 9.7.2 Hand-Washing Facilities...... 9-5 9.7.3 Toilets...... 9-6 9.7.4 Trash Collection ...... 9-6 9.8 Fire Prevention and Protection ...... 9-6 9.9 Electrical Power...... 9-8 9.10 High or Elevated Work...... 9-8 9.11 Manual Lifting...... 9-9 9.12 Clearing and Grubbing ...... 9-10 9.13 Military Munitions...... 9-10 9.13.1 General Unexploded Ordnance Avoidance Procedures...... 9-10 9.13.2 Unexploded Ordnance Personnel Assignments...... 9-11 9.13.3 Excavation Technical Approach ...... 9-12 9.14 Dust Control ...... 9-12 9.15 Radiation Monitoring...... 9-13 9.16 Equipment and Vehicle Inspections...... 9-13 9.17 Ropes, Cables, and Slings ...... 9-13 9.17.1 Visual Inspection ...... 9-13 9.17.2 Detailed Inspection...... 9-14 9.17.3 Disposition of Damaged Wire Rope...... 9-14 9.17.4 Sling Inspection...... 9-15 9.17.5 Wire Rope ...... 9-15 9.17.5.1 Wire Rope Inspection and Replacement Criteria ...... 9-16 9.17.5.2 Inspection Requirements for Reuse of Wire Rope,Primary Suspension 9-16 9.17.5.3 Inspection Procedure ...... 9-16 9.17.5.4 Inspection Requirements for Reuse of Wire Rope for Tieback...... 9-17 9.17.5.5 Manila Rope...... 9-17
Revision 8 iii Basewide Site Safety and Health Plan Former Fort Ord, California
Table of Contents (continued) ______
9.18 Underground and Aboveground Storage Tanks ...... 9-17 9.18.1 Preliminary Requirements ...... 9-17 9.18.2 Operation Requirements − Hazard Assessment ...... 9-18 9.18.3 Fire Safety...... 9-19 9.18.4 Underground Storage Tank Decontamination ...... 9-19 9.18.5 Underground Storage Tank Removal...... 9-20 9.18.6 Air Monitoring ...... 9-21 9.19 Drilling Operations...... 9-21 9.20 Groundwater Treatment System Operation and Maintenance...... 9-23 9.21 Operable Unit 2 Landfills Operations and Maintenance ...... 9-23 10.0 Site Control...... 10-1 10.1.1 Support Zone...... 10-1 10.1.2 Contamination Reduction Zone...... 10-1 10.1.3 Exclusion Zone...... 10-2 10.1.4 Emergency Entry and Exit...... 10-2 10.1.5 Entry Requirements...... 10-2 10.1.6 Communications...... 10-2 10.2 Perimeter Postings ...... 10-2 10.3 Security ...... 10-3 10.3.1 Security Operations...... 10-3 10.3.2 General Security...... 10-4 10.3.3 Site-Specific Areas ...... 10-4 11.0 Personnel and Equipment Decontamination...... 11-1 11.1 Personnel Decontamination ...... 11-1 11.2 Equipment Decontamination ...... 11-2 12.0 Emergency Response Plan and Contingency Procedures...... 12-1 12.1 Pre-Emergency Planning...... 12-1 12.2 Personnel Roles/Lines of Authority...... 12-2 12.3 List of Emergency Contacts and Notifications ...... 12-3 12.4 Advance Notifications...... 12-4 12.5 Emergency Recognition and Prevention ...... 12-4 12.6 Site Topography, Layout, and Prevailing Weather Conditions...... 12-4 12.7 Medical Emergency Response...... 12-5 12.8 Personal Exposure or Injury ...... 12-5 12.9 Chemical Warfare Agents...... 12-6 12.10 Fire Control...... 12-6 12.11 Spills or Leaks...... 12-7 12.12 Safety Signals ...... 12-9 12.13 Site Evacuation Procedures ...... 12-9 12.14 Emergency Equipment ...... 12-10 12.15 Emergency Decontamination Procedures ...... 12-10 12.16 Adverse Weather Conditions...... 12-11 12.17 Earthquakes ...... 12-12
Revision 8 iv Basewide Site Safety and Health Plan Former Fort Ord, California
Table of Contents (continued) ______
12.18 Community Alert...... 12-12 13.0 Record Keeping and Data Management...... 13-1 13.1 Logs ...... 13-1 13.2 Safety Inspections ...... 13-1 13.3 Accident Reporting, Investigation, and Review...... 13-2 14.0 References ...... 14-1
Revision 8 v Basewide Site Safety and Health Plan Former Fort Ord, California
List of Tables ______
Table 1-1 Policies and Procedures - Health and Safety Table 3-1 Maximum Concentrations of Health-Significant Contaminants Detected in Soil and Water Samples at Ford Ord Remedial Action Areas Table 3-2 Proposition 65 Warning and Notification Table 3-3 Hazardous and Toxic Materials Table 3-4 Stinging Insects Table 3-5 Exposure Guidelines for Identified Site Contaminants Table 7-1 Action Levels Table 7-2 Air Monitoring Frequency and Location Table 9-1 Minimum Clearance from Energized Overhead Electric Lines Table 9-2 Standard Operating Procedures for Discoveries of Munitions and Explosives of Concern Table 9-3 Unexploded Ordnance/Military Munitions Waste Notification List Table 12-1 Emergency Phone Numbers Table 12-2 Emergency Equipment
Revision 8 vi Basewide Site Safety and Health Plan Former Fort Ord, California
List of Figures ______
Figure 1-1 Location Map Figure 1-2 Operable Unit 1 Groundwater Treatment Plant Layout Figure 1-3 Operable Unit 2 Groundwater Treatment Plant Layout Figure 1-4 Sites 2/12 Groundwater Treatment Plant Layout Figure 1-5 Operable Unit 2 Landfill Site Plan Figure 1-6 Landfill Gas Monitoring Probe Locations Figure 1-7 Process Flow Diagram Landfill Gas Treatment System Figure 1-8 Sites 39, and Potential Military Munitions Sites Figure 2-1 Project Organization Chart Figure 3-1 Personal Protection Requirements for Poison Oak Figure 11-1 Vehicle Decontamination Station Plan Figure 12-1 Hospital Route
Revision 8 vii Basewide Site Safety and Health Plan Former Fort Ord, California
List of Forms ______
Form 3-1 Activity Hazard Analysis Form 3-2 Job Safety Analysis Form 3-3 Safety Observation Program Form 9-1 Safety Inspection Check List for Construction Equipment Form 9-2 Equipment Inspection Form 13-1 Project Safety Inspection Report Form 13-2 Project Safety and Health Assessment Summary/Deficiency Tracking Report
Revision 8 viii Basewide Site Safety and Health Plan Former Fort Ord, California
List of Appendices______
Appendix A Lead Hazard Compliance and Management Plan Appendix B Accident and Injury Reporting Forms Appendix C Activity Hazard Analyses Appendix D Material Safety Data Sheets Appendix E Asbestos Hazard Management Plan Appendix F Bloodborne Pathogen Exposure Control Plan
Revision 8 ix Basewide Site Safety and Health Plan Former Fort Ord, California
Acronyms and Abbreviations______
°F degrees Fahrenheit ACGIH American Conference of Governmental Industrial Hygiene AHA activity hazard analysis AHERA Asbestos Hazard Emergency Response Act APR air-purifying respirator Army U.S. Department of the Army AST aboveground storage tank BOEWP Basewide Ordnance and Explosives Work Plan CAC Certified Asbestos Contractor Cal/OSHA California Division of Occupational Safety and Health Administration CCR California Code of Regulations CFR Code of Federal Regulations CIH certified industrial hygienist CPR cardiopulmonary resuscitation CRC contamination reduction corridor CRZ contamination reduction zone CWM chemical warfare material dB(A) A-weighted decibels EOD explosive ordnance disposal EPA U.S. Environmental Protection Agency EZ exclusion zone FAAF Fritzsche Army Air Field FFA Federal Facility Agreement ft foot/feet GAC granular activated carbon gal gallon(s) H2S hydrogen sulfide HAZMAT hazardous material(s) HIV human immunodeficiency virus HS health and safety HTRW hazardous, toxic, and radiologic waste HST Health and Safety Technician in. inch(es) IT IT Corporation JSA job safety analysis KMnO4 potassium permanganate LBP lead-based paint LEL lower explosive limit LFG landfill gas MCDH Monterey County Department of Health mg/kg milligram(s) per kilogram mg/m3 milligram(s) per cubic meter
Revision 8 x Basewide Site Safety and Health Plan Former Fort Ord, California
Acronyms and Abbreviations (continued) ______
MMR military munitions response MRS munitions response site MSDS Material Safety Data Sheet NIOSH National Institute for Occupational Safety and Health OU operable unit OSHA Occupational Safety and Health Administration PEL permissible exposure limit PPE personal protective equipment PVC polyvinyl chloride RI remedial investigation RMSF Rocky Mountain Spotted Fever RWQCB Regional Water Quality Control Board-Central Coast Region Shaw Shaw Environmental, Inc. SSHO Site Safety and Health Officer SSHP Site Safety and Health Plan STEL short-term exposure limit SZ support zone SUXOS Senior Unexploded Ordnance Supervisor TERC Total Environmental Restoration Contract TLV threshold limit value TWA time-weighted average USACE U.S. Army Corps of Engineers UST underground storage tank UXO unexploded ordnance UXOSO Unexploded Ordnance Safety Officer VOC volatile organic compound WNV West Nile Virus
Revision 8 xi Basewide Site Safety and Health Plan Former Fort Ord, California
1.0 Introduction
This Site Safety and Health Plan (SSHP) has been prepared by Shaw Environmental, Inc. (Shaw), (formerly IT Corporation) for the U.S. Department of the Army (Army) under the Total Environmental Restoration Contract (TERC) II Contract No. DACW05-96-D-0011. This SSHP describes the safety and health guidelines developed to protect on-site personnel, the environment, and potential off-site receptors from chemical, physical, radiological, and biological hazards at the former Fort Ord, California. In no case may work be performed in a manner that conflicts with the intent of this SSHP or the inherent safety and environmental cautions outlined in this SSHP.
Some sites at former Fort Ord may have mixed military munitions and hazardous, toxic, and radiologic waste (HTRW) that require cleanup. In these cases, it is important to plan a cleanup strategy to address both types of contaminants in a manner that provides safety to the site workers while maximizing the efficiency of cleanup. Sites containing both military munitions and HTRW waste will be remediated using a phased approach, unless an alternate plan is developed and approved. The first phase, performed by the military munition response (MMR) team (Shaw or other contractor), will be to remove the explosive hazards. The MMR team will use appropriate personal protective equipment (PPE) and/or engineering controls, as specified in site-specific work plans, to prevent unacceptable exposure to HTRW contaminants. Military munitions removal will be planned and performed in a manner that will minimize movement and disturbance of HTRW contaminated soil as much as possible. The goal is to safely and effectively remove the military munition hazard without making it more difficult or more expensive to remediate the HTRW contamination.
The second phase, performed by the HTRW cleanup team after the military munitions hazard has been removed, will be to perform the HTRW remediation. Even though the military munitions have been removed, unexploded ordnance (UXO) support, most likely, will be required to protect HTRW workers from potential residual military munition hazards. The level of UXO support required will be based on the remaining level of military munition risk and will be determined on a site-specific basis.
The MMR team will implement the requirements presented in the Basewide Ordnance and Explosives Work Plan (BOEWP) (IT, 2001) to address military munition response actions including removal of potential UXO, construction support, and anomaly avoidance. The BOEWP will be used unless it is superseded by a later revision or a site-specific work plan. It is intended to be used primarily for military munition investigations and removal actions, but also to support HTRW activities.
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This SSHP in combination with the Shaw Corporate Health and Safety Policies and Procedures (HS Manual) and the SSHP presented in the BOEWP meets the health and safety program requirements of California Division of Occupational Safety and Health Administration (Cal/OSHA), Title 8, California Code of Regulations (CCR) Section 5192 and Occupational Safety and Health Administration’s (OSHA) Title 29 Code of Federal Regulations (CFR) 1926.65. These documents also serve as the company’s Injury and Illness Prevention Plan as presented in Health and Safety Policy (HS) 019. Table 1-1 provides a list of the Shaw health and safety policies and procedures.
This SSHP incorporates an update to the project organization and scope of work and replaces the Revision 7 (Shaw, 2003). For background information on historical work completed reference should be made to Revision 5 (IT, 1998).
Shaw fully acknowledges its responsibility to provide a safe and healthful work place for its employees, clients, and the general public. Shaw's mission is to provide our clients with safe and economical solutions. Shaw's health and safety program has been carefully designed to thoroughly address health and safety issues arising from all phases of operations.
Authorized U.S. Army Corps of Engineers (USACE) representatives have the right to notify Shaw of any condition that poses a serious or imminent danger to health and safety. Upon such notification, Shaw shall immediately take corrective action. Furthermore, any authorized USACE representative may issue an order stopping all or part of the work until satisfactory corrective action has been taken.
Specific requirements may be revised if new information is received or site conditions change. Any amendments to this plan will be made with the knowledge and concurrence of both Shaw and the Army.
1.1 Document Organization This SSHP is composed of 14 sections and is organized as follows:
Section 1.0 - Introduction, includes general information regarding the project, the corporate health and safety program, and lists applicable guidance documents
Section 2.0 – Organization, Qualifications, and Responsibilities, identifies and describes the qualifications and responsibilities of key project personnel as they relate to safety and health.
Section 3.0 – Hazard Analysis and Risk Assessment, defines the activities to be performed, the specific hazards anticipated, and the control measures to be implemented.
Revision 8 1-2 Basewide Site Safety and Health Plan Former Fort Ord, California
Section 4.0 – Training Requirements, identifies general and specific training requirements for personnel that may be exposed to work-related hazards.
Section 5.0 – Personal Protective Equipment, provides guidelines for selection of proper PPE requirements.
Section 6.0 – Medical Surveillance, presents medical examination requirements, frequency, and record keeping requirements.
Section 7.0 – Exposure Monitoring and Air Sampling Program, identifies environmental and personal monitoring that will be conducted to identify health hazards and appropriate level of protection required.
Section 8.0 – Heat/Cold Stress Monitoring, identifies symptoms, prevention, and physiological monitoring during execution of tasks.
Section 9.0 – Standard Operating Procedures, Engineering Controls, and Work Practices, presents the health and safety policies and procedures that apply to this project.
Section 10.0 – Site Control, presents control measures to prevent entry of unauthorized personnel into potentially dangerous or hazardous working areas within the site.
Section 11.0 – Personnel and Equipment Decontamination, identifies the procedures that will be implemented to minimize the possibility of exposure to chemical hazards.
Section 12.0 – Emergency Response Plan and Contingency Procedures, identifies emergency preparedness and procedures to protect site workers and the surrounding environment.
Section 13.0 – Record Keeping and Data Management, identifies forms associated with record keeping and data management requirements.
Section 14.0 – References, presents a list of documents referenced in this SSHP.
In addition to the main text of this SSHP, important additional information is provided in the following appendices.
Appendix A – presents the Lead Hazard Compliance and Management Plan.
Appendix B – Accident and Injury Reporting Forms, presents the different types of forms available to report accidents and injuries.
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Appendix C - Activity Hazard Analyses, identifies potential safety, health, and environmental hazards associated with specific tasks. New activity hazard analyses (AHAs) will be developed as necessary and added to Appendix C.
Appendix D - Material Safety Data Sheets, presents information on chemicals used at the site.
Appendix E – presents the Asbestos Hazard Management Plan
Appendix F – presents the Bloodborne Pathogen Exposure Control Plan
1.2 Site Description Fort Ord is located near Monterey Bay in northwestern Monterey County, California, approximately 80 miles south of San Francisco. The installation comprises approximately 28,000 acres adjacent to the cities of Seaside, Sand City, Monterey, and Del Rey Oaks to the south and Marina to the north. Railroad tracks from the now defunct Southern Pacific Railroad and Highway 1 pass through the western portion of the former Fort Ord, separating the beachfront from the rest of the installation. A location map is presented as Figure 1-1.
Beginning with its founding in 1917, the former Fort Ord served primarily as a training and staging facility for infantry troops. From 1947 to 1975, the former Fort Ord was a basic training center. After 1975, the 7th Infantry Division (Light) occupied the former Fort Ord. Light infantry troops operate without heavy tanks, armor, or artillery. The former Fort Ord was selected in 1991 for decommissioning, and troop reallocation was completed in 1993. No active Army division is stationed at the former Fort Ord.
In 1917, the Army bought the present-day East Garrison and nearby lands on the east side of the former Fort Ord to use as a maneuver and training ground for field artillery and cavalry troops stationed at the Presidio of Monterey. Before the Army's use of the property, the area was agricultural, as is much of the surrounding land today. No permanent improvements were made until the late 1930s, when administrative buildings, barracks, mess halls, tent pads, and a sewage treatment plant were constructed.
In 1938, additional agricultural property was purchased for the development of the Main Garrison. At the same time, the beachfront property was donated to the Army. The Main Garrison was constructed between 1940 and the 1960s, starting in the northwest corner of the base and expanding southward and eastward. During the 1940s and 1950s, a small airfield within the Main Garrison was present in what is now the South Parade Ground. In the early 1960s, Fritzsche Army Air Field (FAAF) was completed. The Main Garrison airfield was then decommissioned and its facilities were redeveloped as motor pools and other facilities.
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The former Fort Ord consists of both developed and undeveloped land. The three principal developed areas are the East Garrison, the FAAF, and the Main Garrison; these areas collectively comprise approximately 8,000 acres. The remaining 20,000 acres are largely undeveloped areas.
The two principal undeveloped areas, the Coastal Zone and the Inland Areas or Impact Area, were primarily left in their natural state, without the development of facilities. These undeveloped areas are briefly described below.
• Coastal Zone: A system of sand dunes lies between Highway 1 and the shoreline. The western edge of the dunes has an abrupt drop of 40 to 70 feet (ft), and the dunes reach an elevation of 140 ft above mean sea level on the gentler, eastern slopes. Stillwell Hall (a former recreation center), Beach Trainfire Ranges, ammunition storage facilities, and two inactive sewage treatment facilities lie east of the dunes. The dunes provide a buffer zone that isolates the Beach Trainfire Ranges from the shoreline to the west. Remedial activities have been completed at the Beach Trainfire Ranges, and the property will be transferred to the California State Parks and Recreation. Because of the presence of rare and/or endangered species and because of its visual attributes, Monterey County has designated the former Fort Ord's coastal zone an environmentally sensitive area.
• Inland Ranges: Undeveloped land in the inland portions of the former Fort Ord includes infantry training areas and open areas used for livestock grazing and recreational activities such as hunting, fishing, and camping. The Impact Area occupies a large portion of this undeveloped land; this area was used for advanced military training operations.
Environmental investigations began at Fort Ord in 1984 at FAAF under the Regional Water Quality Control Board-Central Coast Region (RWQCB) cleanup or abatement orders 84-92, 86-86, and 86-315. Investigations indicated the presence of residual organic compounds from fire drill burning practices at the Fire Drill Burn Pit (Operable Unit [OU] 1). The subsequent remedial investigation (RI) and feasibility study for OU1 was completed in 1988, and cleanup of soil and groundwater began under RWQCB cleanup or abatement orders 86-87, 86-317, and 88- 139. In 1986, further investigations began at the OU2 Landfill, and the preliminary site characterization was completed in 1988. In 1990, Fort Ord was placed on the U.S. Environmental Protection Agency’s (EPA) National Priorities List primarily because of volatile organic compounds (VOCs) found in groundwater beneath OU2.
A Federal Facility Agreement (FFA) was signed by the Army, EPA, California Environmental Protection Agency’s Department of Toxic Substances Control (formerly the Toxic Substances Control Program of the Department of Health Services), and RWQCB. The FFA established schedules for performing RIs and feasibility studies and requires that remedial actions be completed as expeditiously as possible. In 1991, the basewide RI began, and Fort Ord was placed on the Base Realignment and Closure list.
Revision 8 1-5 Basewide Site Safety and Health Plan Former Fort Ord, California
The final draft of the Basewide Remedial Investigation/Feasibility Study, Fort Ord, California (HLA, 1995) was submitted in October 1995. On May 7, 1996, the Army presented the proposed plan for the RI sites, surface water outfalls, and Sites 25 and 33 at Fort Ord to the public for review and comment. The responses to public comments are included in the Record of Decision, Basewide Remedial Investigation Sites, Fort Ord, California (Army, 1997) that was signed in January 1997.
The final draft of the Final Remedial Investigation Report, Fort Ord Landfills, Fort Ord, California (D&M, 1993) was submitted in October 1993. On October 12, 1993, the Army presented the proposed closure plan for the OU2 Landfill to the public for review and comment. The responses to public comments are included in the Record of Decision, Operable Unit 2 Landfills, Fort Ord, California (Army, 1994).
The following sections present brief discussions of investigations, remedial action, and operations and maintenance activities ongoing at the former Fort Ord.
1.2.1 Operable Unit 1 Groundwater Treatment System Operable Unit 1 is the site of a groundwater treatment system and monitoring well network near the former FAAF (now Marina Municipal Airport) located at the northwestern portion of the former Fort Ord (Figure 1-1). Historical training activities conducted by the Army in this area included discharge of off-specification fuel and solvents into an unlined burn pit where they were ignited and extinguished and resulted in the need for active groundwater remediation.
The current components of the groundwater remediation system include two extraction wells, and two 250-gallon (gal) (1,000 pound) granular activated carbon (GAC) vessels connected in series. Groundwater is pumped from the extraction wells through the GAC and is then discharged to the ground surface. The plant layout is shown in Figure 1-2.
Project activities will include, but not limited to, additional investigations, system expansion, operation and maintenance of the groundwater treatment system, and sampling activities.
1.2.2 Operable Unit 2 Groundwater Treatment System Operable Unit 2 is the site of a groundwater treatment system and monitoring well network located at the northeastern portion of the former Fort Ord (Figure 1-1). Operable Unit 2 groundwater treatment system addresses the remediation of groundwater contamination from the former OU2 Landfill operated from 1956 to 1987. The landfill possibly received a small amount of chemical waste along with household and commercial refuse.
The current groundwater treatment system consists of 15 extraction wells, the groundwater treatment plant, 3 injection wells, and 5 infiltration galleries. The groundwater treatment plant
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consists of GAC adsorption vessels operated in series. Treated water flows to two effluent equalization tanks prior to re-injection. The plant layout is shown in Figure 1-3.
In addition to the groundwater treatment system, 91 monitoring wells are used to collect water level and/or groundwater chemistry data (under separate contract) in support of the OU2 groundwater remedy.
Project activities will include, but not limited to, system expansion, operation and maintenance of the groundwater treatment system, and sampling activities.
1.2.3 Sites 2/12 Groundwater Treatment System Sites 2/12 groundwater treatment system addresses the remediation of groundwater contamination at the former Sites 2 and 12 located in the west central portion of the former Fort Ord (Figure 1-1). Site 2 was the former Main Garrison Sewage Treatment Plant, and Site 12 was comprised of a former disposal site, an automotive repair yard, and an equipment dismantling area.
The current groundwater treatment system consists of eight extraction wells, the groundwater treatment plant, 2 injection wells, and 3 infiltration galleries. The groundwater treatment plant consists of two GAC adsorption vessels operated in series. Treated groundwater from the OU2 system is piped to the Sites 2/12 system where the water from both systems is combined before groundwater injection/infiltration. The plant layout is shown in Figure 1-4.
In addition to the groundwater treatment system, 45 monitoring wells and piezometers are used to collect water level and/or groundwater chemistry data (under separate contract) in support of the Sites 2/12 groundwater remedy.
Project activities will include, but not limited to, system expansion, operation and maintenance of the groundwater treatment system, and sampling activities.
1.2.4 Operable Unit 2 Landfills Operable Unit 2 Landfills formerly included six landfill cells, one cell north (Area A) and five cells south of Imjin Road (Areas B through F) (Figures 1-1 and 1-5). As part of the remedial action, refuse and impacted soil from Area A was excavated and placed as part of the general fill in Areas B, C, D, and F. There are no remedial systems at Area A that requires post-closure operation or maintenance.
The landfill south of Imjin Road (Areas B through F) encompassing approximately 120 acres of land has been closed by placement of an engineered cover system, or cap. The engineered cover consists of a 2-ft foundation layer placed over the general fill, a low-hydraulic conductivity barrier layer, composed of a low linear density polyethylene geomembrane, and a 2-ft vegetative
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top layer designed to protect the geomembrane and support the growth of native vegetation. Vents are installed through the cover at 22 locations along the center ridge of each cell. Sixty- three monitoring probes are installed at 40 locations along the perimeter of the landfill. Figure 1-6 shows the location of vents and monitoring probes.
A landfill gas (LFG) extraction and treatment system addresses the migration of LFG including VOCs along the eastern perimeter of Area F by a line of 11 extraction wells (Figure 1-6). The
LFG is treated with GAC to remove VOCs and potassium permanganate (KMnO4) to remove vinyl chloride. The final design stage of the LFG mitigation system is ongoing. Consideration is being given to expanding the number of extraction wells and replacing the existing treatment system. Figure 1-7 shows a process flow diagram of the LFG treatment system.
Future project activities will include, but not be limited to operation and maintenance, LFG monitoring, operation of a LFG collection and treatment system, and expansion of the LFG collection and treatment system.
1.2.5 Site 39 Impact Area The Site 39 Impact Area is approximately 8,000 acres, bounded by Eucalyptus Road to the north, Barloy Canyon Road to the east, South Boundary Road to the south, and North-South Road to the west (Figure 1-1). The Impact Area was reportedly used since the early 1900s for ordnance training exercises. The Impact Area includes a large number of separate small arms firing and military munition ranges that have varied history, characteristics, and proposed land use. Over the years various types of ordnance have been used during training activities, including hand grenades, mortars, rockets, mines, artillery rounds, and small arms rounds. Some training activities using petroleum hydrocarbons were also conducted. Some of the ranges were used for small arms training activities only, while other ranges were used for a variety of training activities. Figure 1-8 shows a site location map.
Project activities may include, but not be limited to, site inspection, surveying, sampling, excavation and hauling of excavated material, treatment of excavated material, and site restoration.
1.2.6 Site 39A East Garrison Area Site 39A is located in the northeastern portion of the former Fort Ord, on the southwestern side of the East Garrison Area (Figure 1-1). Site characterization and remedial activities at three small-bore shooting ranges, skeet range and three target bunkers was conducted from 1994 through 1998. Figure 1-8 presents a site location map.
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Additional investigation and remediation at the East Garrison Ranges may be required based on the results of recent literature reviews. Project activities may include, but not be limited to, site inspection, surveying, sampling, and excavation and site restoration.
1.2.7 Munitions Response Sites Recent literature reviews, as part of the additional soil characterization for the Impact Area and reviews of reports and data from military munition investigations at the former Fort Ord, were conducted to evaluate the potential for small arms training to have occurred outside the Impact Area, the East Garrison Ranges, and the Beach Ranges. Remediation at the Beach Ranges (Site 3) was completed in 1998. Potential munitions response sites (MRSs) are shown on Figure 1-8.
Additional investigation and remediation is anticipated at some of these sites based on the results of the review and evaluation. Project activities may include, but not be limited to, site inspection, surveying, sampling, excavation, hauling of excavated material, and site restoration.
1.2.8 Operable Unit Carbon Tetrachloride Plume The Army has been investigating the presence of carbon tetrachloride (CT) in groundwater since 1997 in response to its detection in two monitoring wells during the basewide quarterly monitoring program. Analytical results from additional soil gas and groundwater samples collected in what is now the Preston Park housing area, in the vicinity of Lexington Court and Ready Court, suggest that a CT source may be present in the vadose zone soils in this area. The CT in the soils is suspected to be a continuing source of groundwater contamination and has the potential for vapor intrusion into nearby residential housing.
The Army has implemented a soil vapor extraction and treatment system (SVE) to remove CT and other VOCs from the extracted soil vapor. The results of the pilot SVE system will provide data for the OU CTP Remedial Investigation/ Feasibility Study (RI/FS) on the effectiveness of this remedial technology for source control of the CT groundwater plume and mitigation of potential vapor intrusion into the nearby housing area.
Project activities will include, but not limited to, additional investigations and extraction and treatment, drilling, sampling, and construction.
1.2.9 Aboveground and Underground Storage Tank Sites Investigation is ongoing to identify and locate aboveground storage tanks (ASTs) and underground storage tanks (USTs) that need to be removed and/or demolished.
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Project activities may include, but not be limited to, excavation, removal of residual liquid, cleaning, sampling, demolition of all associated pipelines and structures, transport of demolition debris, residual liquid, and rinse water, and confined space entry.
1.3 Site-Specific Work Plans Site-specific work plans are available for active sites and will be prepared for each new scope of work/task identified. Each plan will be prepared in sufficient detail to describe the background site conditions and identify work procedures and potential safety hazards. In the event that site- specific conditions/activities produce significant changes to the work plan, the work plan will be modified under the supervision of the Project Manager and forwarded to the Site Safety and Health Officer (SSHO) so appropriate modifications (if necessary) can also be made to the SSHP.
1.4 Regulatory Guidance This SSHP has been written in accordance with the following guidance documents:
Total Environmental Restoration Contract II, DACW05-96-D-0011 (USACE, 1996)
Engineer Regulation 385-1-92, Safety and Occupational Health Requirements for hazardous, Toxic, and Radioactive Waste (HTRW) Activities (USACE, 2003)
Engineer Manual (EM) 385-1-1, Safety and Health Requirements Manual (USACE, 2003)
Engineer Pamphlet (EP) 75-1-2, Munitions and Explosives of Concern (MEC) Support During Hazardous, Toxic, and Radioactive Waste (HTRW) and Construction Activities (USACE, 2004) Shaw Corporate Health and Safety Procedures Manual
NIOSH-Pocket Guide to Chemical Hazards (NPG). 2004 Database http://www.cdc.gov/niosh/npg/npg.html
Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices (TLVs and BEIs). (American Conference of Governmental Industrial Hygiene [ACGIH], 2003)
Guide to Occupational Exposure Values (ACGIH, 2003)
California Code of Regulations, Title 8, California Occupational Safety and Health Administration Construction and General Industry Safety Orders and Section 5192, Hazardous Waste Operations and Emergency Response
Code of Federal Regulations, Title 10, Part 20, Standards for Protection Against Radiation
Code of Federal Regulations, Title 29, Occupational Safety and Health Administration
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Code of Federal Regulations, Title 40, U.S. Environmental Protection Agency Hazardous Waste Requirements
Specific documents cited as references in the text are listed in Section 14.0.
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2.0 Organization, Qualifications, and Responsibilities
The current project organization is shown in Figure 2-1. This section describes the qualifications and responsibilities of key project personnel as they relate to health and safety.
2.1 All Personnel All site personnel will be responsible for continuous adherence to safety and health procedures during the performance of assigned work. In no case may work be performed in a manner that conflicts with the intent of this plan or the inherent safety and environmental cautions outlined in this plan. After due warnings personnel violating safety procedures will be dismissed from the site and possibly terminated from further work.
Any person who observes unsafe acts or conditions or other safety problems should immediately report observations and concerns to appropriate supervisory personnel or to the SSHO. If there is any dispute with regard to health and safety, on-site staff will attempt to resolve the issue on- site and if the issue cannot be resolved, they will consult off-site technical staff and supervisors for assistance. The specific task or operation in question shall be discontinued until the issue is resolved.
2.2 Occupational Physician The Occupational Physician is responsible for developing and implementing a medical monitoring program in compliance with 8 CCR 5192.
The physician shall have the following qualifications:
• The physician shall have certification in occupational medicine from the American Board of Preventative Medicine, or who, by necessary training and experience, is Board eligible to manage the medical surveillance program.
• The physician shall have extensive experience in the occupational health area and be familiar with the site’s hazards and the scope of the project.
2.3 Certified Industrial Hygienist The CIH is responsible for the development, implementation, and oversight of the health and safety program.
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The CIH shall be available for on-site consultation and emergencies. The CIH shall have the following qualifications:
• The CIH shall be an Industrial Hygienist certified by the American Board of Industrial Hygiene.
• A minimum of three years’ experience in developing and implementing safety and health programs at hazardous waste sites, in the hazardous waste disposal industry, or in the chemical or petroleum processing industry.
• Documented experience in supervising professional and technician-level personnel.
• Documented experience in developing worker exposure assessment programs and air monitoring programs and techniques.
• Documented experience in the development of PPE programs, including programs for working in and around potentially toxic, flammable, combustible atmospheres, and confined spaces.
• Working knowledge of State and Federal occupational safety and health regulations.
• The appropriate management and supervisor training identified in Title 29 CFR 1926.65.
• For asbestos work, two years specialized experience in the asbestos abatement industry and demonstrable expertise in asbestos air monitoring techniques, and Asbestos Hazard Emergency Response Act (AHERA)-certified contractor/supervisory training.
• For lead-based paint (LBP) work, one year specialized experience in LBP abatement industry, demonstrable expertise in LBP air monitoring techniques, and EPA- accredited supervisory training.
2.4 Site Safety and Health Officer The SSHO is responsible for implementation of this SSHP, as well as recommendations and revisions for the program CIH's approval. The SSHO will conduct daily inspections to determine if operations are being conducted in accordance with this SSHP, the Army contract requirements, and OSHA regulations. The SSHO is assigned to the Project Manager for the duration of the project but reports directly to the CIH with operational issues. An open dialogue is kept between the SSHO, CIH, and supervisory personnel of the project to ensure that safety issues are quickly addressed and corrective action taken. The SSHO has the authority to take immediate steps to correct unsafe or unhealthful conditions, including the stoppage of all field work when deemed necessary. The SSHO also has the authority to initiate disciplinary actions per Shaw Human Resources procedure. The SSHO will maintain an open dialogue with subcontractor supervisory personnel to expedite the correction of any safety deficiencies. In
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addition, the SSHO may communicate at any time with site visitors or workers to correct hazardous conditions or to assess potential unsafe conditions and implement the requirements established in this SSHP.
The SSHO shall have the following qualifications:
• A minimum of two years experience in implementing health and safety programs at hazardous waste sites, in the hazardous waste disposal industry, AST/UST removal projects, or in the chemical industry where Level C and Level B PPE were required.
• Documented experience in construction techniques and construction safety procedures.
• Working knowledge of Federal and State occupational health and safety regulations.
• Specific training in personal and respiratory protective equipment program implementation, confined space program oversight, and in the proper use of air monitoring instruments and air sampling methods.
• Trained in First Aid and cardiopulmonary resuscitation (CPR) by a recognized organization such as the American Red Cross and meet the requirements specified by the Bloodborne Pathogen Standard, 29 CFR 1910.1030.
• For asbestos work; shall be AHERA-certified as a Contractor Supervisor; have a minimum of one year working experience in the asbestos abatement industry, have demonstrable experience in asbestos air monitoring techniques;including successful completion of National Institute for Occupational Safety and Health (NIOSH)-582: sampling and evaluating airborne asbestos dust.
• For LBP work, shall have EPA-accredited LBP Supervisor training, a minimum of six months working experience in the LBP abatement industry, demonstrable experience in LBP air monitoring techniques, and knowledge of engineering and work practice controls that reduce lead exposure.
The requirements for an alternate will be the same as for the designated SSHO. Replacement of this function can only be made after verification of qualification and prior written consent from the Army.
2.5 Health and Safety Technicians As necessary, one or more Health and Safety Technicians (HST) will be appointed to assist the SSHO in the implementation and enforcement of this SSHP. The HST duties may include conducting air monitoring and sampling as specified in this SSHP, maintaining decontamination facilities, documenting calibrations and daily safety activities, and observing and correcting unsafe conditions when they exist.
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Also, in addition to the SSHO, at least one HST will be trained in First Aid and CPR by a recognized organization such as the American Red Cross and meet the requirements specified by the Bloodborne Pathogen Standard, 29 CFR 1910.1030.
2.6 Unexploded Ordnance Safety Officer The UXO Safety Officer (UXOSO) will serve as an advisor to the SSHO in evaluating health and safety concerns with respect to military munition issues. The UXOSO may be asked to provide information and help develop specific guidance to ensure safe work practices on combination military munitions/HTRW sites.
2.7 Senior Unexploded Ordnance Supervisor The Senior UXO Supervisor (SUXOS) will be responsible for overseeing and implementing UXO avoidance operations on an HTRW project. The SUXOS in charge of the UXO avoidance operation has the following responsibilities:
• Assist in the development of site-specific work plans
• Evaluate the sites to determine the level of support that is required to safely conduct the given operation
• Oversee UXO personnel that provide explosive ordnance recognition, escort, location, and safety functions during anomaly avoidance activities
• Make arrangements through the USACE for military munitions removal or disposal actions in the event that the work area is too contaminated with UXO to safely allow non-UXO personnel to work in the area
• Ensure that exact location of any military munition related items encountered are accurately captured, with the aid of a digital global positioning system, and that those coordinates are properly reported and recorded in the geographical information system
• Ensure that suspect MRSs are clearly marked or delineated prior to HTRW crews entering the area
• Ensure that UXO safety briefings are given to all site personnel and visitors
• Take operational control of a site until properly relieved, in the event hazardous UXO is encountered
2.8 Unexploded Ordnance Avoidance/Escort Personnel Unexploded ordnance personnel that are assigned to provide UXO avoidance and escort during HTRW-related activities will have the following responsibilities:
• Search the work area for the presence of surface UXO, and mark suspected UXO with red flagging
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• Immediately report any suspect UXO or conditions that have not been previously discussed to the SUXOS
• Check the specific locations to be drilled, sampled, or remediated for the presence of subsurface anomalies with the aid of a hand-held magnetometer or appropriate instrument
• Identify safe anomaly free locations for any intrusive sampling, drilling or HTRW remediation activities
• Ensure that all non-UXO assets stay within the boundaries of the established work area
2.9 Project Manager The Project Manager has the overall responsibility for implementation of this SSHP. Specific responsibilities will include:
• Promoting safety awareness in all aspects of the project • Conducting monthly safety council meetings • Conducting management safety inspections at least monthly • Investigating accidents and incidents.
2.10 Superintendent The Superintendent is responsible for implementation of this SSHP for field activities on a day- to-day basis.
The Superintendent will have a minimum of six years project superintendent experience, with a minimum of three years field and supervisory experience on hazardous and toxic waste projects, and shall meet the requirements of a competent person as defined in Titles 29 CFR 1926.32(f) and 29 CFR 1926.65. The Superintendent will be experienced and knowledgeable in the field of hazardous and toxic waste cleanup and in the specific activities anticipated during this project. The Superintendent will also be responsible for coordinating site activities with other contractors working in any immediate or adjacent area.
2.11 Independent Certified Industrial Hygienist In accordance with the TERC II, an independent CIH will be employed if required to perform asbestos and LBP work, as described below.
The independent CIH will prepare a site-specific LBP Hazard Management Plan, perform training, direct air monitoring, and assist the contractor’s competent person in implementing and ensuring that health and safety requirements are complied with during the performance of all LBP-required work. The CIH shall be completely independent from the contractor and shall not
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be an employee of the contractor or be an employee or principal of a firm recognized by Federal, State, or local regulations that would constitute a business relationship that would not be considered independent. The CIH shall have a minimum of one year of comprehensive experience in planning and overseeing LBP abatement activities and successfully completed the EPA-accredited LBP supervisor training. The CIH should also have certification from the California Department of Health Services as an Inspector and Project Monitor or Project Designer for lead work.
The independent CIH will prepare the Asbestos Hazard Management Plan (Appendix E), prepare and perform training, direct air monitoring, and assist the contractor’s competent person in implementing and ensuring health and safety requirements are complied with during the performance of all asbestos-required work. The CIH shall be completely independent from the contractor and shall not be an employee of the contractor or be an employee or principal of a firm recognized by Federal, State, or local regulations that would constitute a business relationship that would not be independent. The CIH shall have a minimum of two years comprehensive experience in planning and overseeing asbestos abatement activities and have successfully completed the AHERA-certified contractor/supervisor training. The CIH should also have certification from Cal/OSHA as a Certified Asbestos Contractor (CAC).
2.12 Subcontractors Subcontractors are responsible for the health and safety of their employees and for complying with the standards established in this SSHP and Shaw HS 011, which provides for health and safety rules for contractors. All subcontract personnel working on site must complete a site orientation training conducted by the SSHO or his designee and must sign an acknowledgment that they are aware of the site history, the general safety hazards, and Shaw HS 011. All subcontractor personnel will provide to the SSHO prior to starting fieldwork documentation of appropriate training and medical surveillance.
Subcontractors will report daily to the Superintendent, unless otherwise directed by the Project Manager, and will attend the tailgate safety meeting appropriate to their activity. The SSHO will monitor subcontractor activities and maintain an open dialogue with the Superintendent and subcontractor supervisory personnel to ensure that safety deficiencies are immediately corrected. This responsibility would include communication to subcontractor employees in situations that are immediately hazardous due to exposure potential or unsafe conditions.
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3.0 Hazard Analysis and Risk Assessment
Shaw will be performing construction and removal activities at various areas located in the former Fort Ord, California. These may include the following tasks:
• Mobilization/demobilization • Site preparation • Grubbing and clearing • Excavation of contaminated materials • Soil/debris separation • Groundwater/soil gas well drilling, installation, and monitoring • Pumping liquids from water wells or impoundments to a water treatment facility • Groundwater treatment plant operation, maintenance, and repair • Soil/water/soil gas sampling • Soil screening • Habitat management • Structure demolition • Ambient air monitoring • Asbestos hazard management • Lead hazard management • Utility relocation • Landfill capping • Backfilling and site restoration • Equipment decontamination • UST removal • AST removal.
3.1 Activity Hazard Analysis Personnel and visitors will be familiar with site hazards and strictly adhere to the appropriate safety procedures prescribed in this SSHP including the AHAs developed for specific tasks. Each AHA identifies potential safety, health, biological, and environmental hazards associated with specific tasks, and provides for the protection of personnel, the community, and the environment.
The AHAs will be prepared in accordance with EM 385-1-1, Safety and Health Requirements Manual (USACE, 2003). It is the joint responsibility of the SSHO and Superintendent to ensure that an appropriate AHA is developed for each task. Appendix C contains AHAs developed to date for each major task associated with this project. Additional AHAs will be developed for
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new tasks and added to this SSHP. The SSHO and a representative from the USACE will approve AHAs.
Because of the complexity and constant change of projects, sites must be continually inspected to identify new hazards. Changes to the hazard analysis may be originated by the SSHO but must be approved by the CIH. Form 3-1 presents the format for AHAs.
3.2 Job Safety Analysis The job safety analysis (JSA) is an effective management technique for identifying hazardous conditions and unsafe acts in the workplace. A JSA is intended to analyze the individual steps or activities, which together create a job or specific work duty, and to detect any actual or potential hazards that may be present. This process can identify less obvious potential hazards that may go undetected during routine management observations or audits. A new JSA will be prepared for each new activity. If required, to reflect new conditions in the task being performed or new hazards not identified previously, the JSA will be reviewed and updated before commencement of field activity. Shaw HS 045 contains a discussion of procedures and requirements for conducting a JSA. Form 3-2 will be used for JSA.
3.3 Safety Observation Program Employees engaged in work activities are often the most knowledgeable about the hazards of their work and can provide valuable feedback on unsafe conditions and unsafe practices that require corrective action.
Employees are encouraged to provide information on actual or potential safety hazards observed in the workplace, which if left unreported might result in an accident or injury to a Shaw employee, subcontractor, client or public and to provide recommendations to correct the hazards.
A good Safety Observation Program will:
• Pinpoint practices that could cause accidents, injuries, damage, inefficiency and waste. • Determine specific needs for coaching and training. • Check the adequacy of existing job/task methods and procedures. • Follow-up on the effectiveness of training. • Give appropriate on-the-spot constructive correction.
The SSHO or an employee, if the SSHO is not familiar with the hazards associated with the task, will conduct safety observations when new tasks commence. Form 3-3 will be used to document safety observations. Safety inspection will also be conducted to identify safety and health issues (Section 13.2).
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3.4 Chemical Hazards This section discusses the hazards associated with materials that are likely to be encountered during construction, removal activities, and operation and maintenance. Health effects, along with routes of exposure for chemicals of concern, are listed in the Material Safety Data Sheets (MSDSs) for the specific chemical, located in Appendix D of this document.
3.4.1 Health-Significant Contaminants These hazards include, but not limited to, lead, explosive compounds (such as cyclotrimethylene trinitramine, cyclotetramethylenetetranitramine and trinitrotoluene), petroleum distillates (total petroleum hydrocarbons), and LFG that include methane and other VOCs. The routes of exposure are primarily through inhalation of vapors and dusts and by direct contact with contaminated media. The action levels for total dust and VOCs (see Section 7.0) were developed to ensure that exposure above one-half of each compound's permissible exposure limit (PEL) will not be reached. Table 3-1 contains the maximum concentrations of health significant contaminants detected in soil samples at the former Fort Ord.
Health effects along with routes of exposure for significant site contaminants are detailed in the following paragraphs.
Lead Lead has no local toxic effects. Systemic poisoning symptoms are nonspecific: fatigue, headache, poor sleeping, aching bones and muscles, constipation, abdominal pains, and decreased appetite. All these symptoms are reversible with time away from exposure. Continued exposure results in anemia, pallor, "lead line" on the gums, and decreased hand-grip strength. Lead also has central nervous system effects and was implicated in producing learning deficiencies in exposed children. Lead compounds display a variety of toxic effects that are more specific to the compound than to the lead. Some of these compounds were found to be carcinogenic in experimental animals. For example, the effects of lead's toxicity may be compounded when it takes the form of lead chromate, which is a suspected human carcinogen.
Explosive Compounds Explosive compounds can affect the body if inhaled or swallowed, or by contact with the eyes or skin. Exposure to explosive compounds can cause liver damage with yellow jaundice and anemia that may be fatal. Exposure may also cause irritation of the eyes, nose, and throat with sneezing, coughing and sore throat. It may cause a skin rash and stain the skin, hair, and nails a yellowish color. It may affect the ability of the blood to carry oxygen. This lack of oxygen may result in a bluish discoloration of the skin, weakness, drowsiness, shortness of breath, and unconsciousness. In addition, it may cause muscular pains, heart irregularities, kidney irritation, cataracts of the eyes, menstrual irregularities, and nerve damage.
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Petroleum Distillates (TPH) Petroleum distillates can affect the body if they are inhaled, come in contact with the eyes or skin, or are swallowed. Overexposure to petroleum distillates may cause dizziness, drowsiness, headache, and nausea. They may also cause irritation of the eyes, throat, and skin.
Landfill Gas Anaerobic bacteria that consume organic matter in landfill refuse produce landfill gas. Landfill gas is chiefly composed of methane and carbon dioxide. In addition, other major gases (also called fixed gases), including oxygen, nitrogen, and water vapor, could be present. Landfill gas may also contain traces of hydrogen, ethane, and other gases. The oxygen and nitrogen component of LFG are introduced as air during placement of refuse, the result of atmospheric weather effects, LFG system operations, or the diffusion of air into the landfill.
The most significant characteristics of LFG are as follows:
• LFG consists primarily of methane (about 55%) and carbon dioxide (about 45%.). LFG is wet; cooling almost always results in the formation of condensate water.
• LFG is flammable (i.e. potentially explosive)
• LFG can migrate through surrounding soil, within open conduits, and through permeable trench backfill material.
• LFG can accumulate in confined spaces.
• The weight (specific density) of LFG is typically close to the weight of air.
• Typical temperature range is 16 to 52°C (60 to 125°F) within a landfill.
• Component gases (methane, carbon dioxide, water vapor, and others) tend to stay together but can separate through soil and liquid contact.
Pure methane is a colorless and odorless gas. It has practically no toxic effects below the flammable limits. While methane has no noticeable toxic effects, high concentrations can displace oxygen and serve as a simple asphyxiant.
Hydrogen sulfide (H2S) is a colorless, toxic gas that is identified by its odor, similar to that of rotten eggs. It is heavier than air, flammable, and is generally a component of LFG. Hydrogen sulfide can cause irritation of eyes, nose and throat. Long-term exposure (30 minutes or longer) to elevated concentrations can cause drowsiness, staggering, and nausea that can lead to death, due to respiratory system failure.
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3.4.2 Other Potential Contaminants Other contaminants present a minimal health risk at a low concentration. Chemical hazards may include:
• Benzene (in groundwater) • Carbon tetrachloride (in groundwater and soil vapor) • Chlorinated pesticides • Chloroform (in groundwater) • Dioxins/Furans • Ethylene dibromide (in groundwater) • Ethylene dichloride (in groundwater) • Methane • Methylene chloride (in groundwater) • Methyl chloroform (in groundwater) • PCE (in groundwater) • TCE (in groundwater) • Vinyl chloride (in groundwater) • Diesel exhaust • Gasoline exhaust • Fecal coliform • Mercury • PCBs • Cadmium • Beryllium • Crystalline silica.
In addition to chemical compounds, other types of waste or reactive substances that might be encountered include:
• Chemical agent test kits • Medical waste • Dry sewage • Radioactive materials • Poison oak as a skin and inhalation hazard.
The presence of medical waste was identified in the OU2 Landfill and Sites 16 and 17. Employees will not manually handle, contact, remove, or inspect the contents of any biohazard container, bag, or device. In the event suspect material should pose an exposure hazard (e.g., puncture wound by used syringe) the SSHO will be notified immediately.
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None of the above-mentioned contaminants are anticipated during field activities; however, if encountered the full complement of air monitoring devices listed in Section 7.2 will be used to assess the presence of airborne contaminants.
It must be kept in mind that even though previous site analytical data do not reveal any other significant chemical hazards to site personnel, the potential still exists for "hot spots" not previously identified. Both the action levels and initial levels of PPE were developed to account for these potential hazards.
Table 3-2 contains the list of contaminants detected at each of the sites and satisfies requirements of the State of California Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65). Table 3-3 contains additional information on hazardous and toxic materials that may be encountered during the execution of this project.
3.5 Biological Hazards Biological hazards include ticks, poisonous plants, snakes, bird excrement, hantavirus, fecal coliform, stinging insects, spiders, wild animals, and bloodborne pathogens.
Ticks. Ticks are vectors of many different diseases, including Rocky Mountain Spotted Fever (RMSF), Q Fever, Tularemia, Colorado Tick Fever, and Lyme Disease. They attach to their host's skin and intravenously feed on its blood creating an opportunity for disease transmission. The first symptoms of either disease are flu like chills, fever, headache, dizziness, fatigue, stiff neck, and bone pain. If immediately treated by a physician, most individuals recover fully in a short period of time. If not treated, more serious symptoms can occur. Recently, lyme disease has been the most prevalent type of disease transmitted by ticks in the United States.
If a site employee believes a tick has bitten them, or if any of the signs and symptoms appear, the employee will contact the SSHO, who will authorize the employee to visit a physician for an examination and possible treatment.
The following precautions should be taken when working in areas that might be infested with ticks:
• Cover your body as much as possible. Wear long pants and long-sleeved shirts. Light color clothing makes spotting of ticks easier.
• Try to eliminate possible paths by which the tick may reach unprotected skin. For example, tuck bottoms of pants into socks or boots and sleeves into gloves. (Duct tape may be used to help seal cuffs and ankles.) If heavy concentrations of ticks or insects are anticipated or encountered, Tyvek® coveralls may be used for added protection.
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• Conduct periodic and frequent (e.g., hourly) surveys of your clothing for the presence of ticks. Remove any ticks and insects that become attached to clothing.
• Spray outer clothing, particularly your pant legs and socks, but not your skin, with an insect repellent that contains permethrin or permanone, or use a repellent with N,N-diethyl-m-toluamide, which can be applied to the skin.
• When walking in wooded areas, avoid contact with bushes, tall grass, or brush as much as possible.
• Tuck pant legs into boot tops or tape pants to boot tops to prevent ticks from crawling up the pant leg (this may not be an option at sites where extreme heat stress is anticipated).
• If dressed in Level D or Modified Level D and no other head protection is required, wear a hat to prevent ticks from getting into the hair.
If a tick is discovered, the following procedure should be used to remove it:
• Do not detach a tick with your bare fingers; bacteria from a crushed tick may be able to penetrate even unbroken skin. Fine-tipped tweezers should be used.
• Grip the tick as close to your skin as possible and gently pull it straight away from you until it releases its hold.
• Do not twist the tick as you pull and do not squeeze its bloated body. That may actually inject bacteria into your skin.
• If the tick resists, cover the tick with salad oil for about 15 minutes to asphyxiate it, then remove it with tweezers.
• Do not use matches, a lit cigarette, nail polish or any other type of chemical to “coax” the tick out.
• Be sure to remove all parts of the tick’s body, thoroughly wash your hands and the bite area with soap and water, and disinfect the area with alcohol or a similar antiseptic after removal.
• For several days to several weeks after removal of the tick, look for the signs of the onset of Lyme Disease, such as a rash that looks like a bulls-eye or an expanding red circle surrounding a light area.
• Look for the signs of the onset of RMSF, such as a rash-like inflammation consisting of red spots under the skin that appear 3 to 10 days after the tick bite.
• Notify the SSHO of any tick bites as soon as possible.
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Mosquitos. Mosquitos are vectors for the West Nile Virus (WNV) infection, a condition that can vary in presentation in different individuals. Most persons who become infected with WVN develop no clinical illness or symptoms. Below is a list of WVN infections:
West Nile Fever - Of the approximately 20 percent of infected people who develop symptoms, most develop what has been termed West Nile fever. Fever, headache, fatigue, skin rash on the trunk of the body (occasionally), swollen lymph glands (occasionally) and eye pain (occasionally). The incubation period for the development of these symptoms is between 2 to 14 days.
West Nile Meningitis/Encephalitis - Severe infections involve the Central Nervous system resulting in aseptic meningitis and encephalitis. Characteristic symptoms for meningitis include fever, headache, stiff neck, and changes in the white cells of the spinal fluids (Pleocytosis) with a predominance of lymphocytes. Characteristic symptoms for encephalitis include fever, headache, alteration of consciousness, lethargy, confusion, coma, limb paralysis, cranial nerve palsies and tremors.
West Nile Poliomyelitis is a flaccid paralysis syndrome associated with WNV infection and is less common than meningitis or encephalitis. This syndrome is generally characterized by the acute onset of asymmetric limb weakness or paralysis in the absence of sensory loss. The paralysis can occur in the absence of fever, headache or other common symptoms associated with WNV. Paralysis of the respiratory muscles leading to respiratory failure can sometimes occur (fatal).
The WNV infection can be suspected in a person based on geographical location, clinical symptoms and patient history but laboratory testing is required for a confirmed diagnosis. The most efficient diagnostic method is the detection of specific antibodies to WNV in serum collected within 8-14 days of illness onset or CSF collected within 8 days of illness onset.
WNV Treatment – There is no specific treatment for WNV infection. The more severe infections may require hospitalization and supportive care to prevent secondary infections
Poisonous Plants. Poison oak (Rhus diversiloba), and poison sumac (Rhus vernex) have three or five leaves radiating from a stem. The plant tissues have an oleoresin, which is active in live, dead, and dried parts and produces a delayed allergic hypersensitivity. The oleoresin may be carried through smoke, dust, contaminated articles, and the hair of animals. The best antidote for poisonous plants is recognition and avoidance.
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The allergic reaction associated with exposure to these plants will generally cause the following signs and symptoms:
• Blistering at the site of contact, usually occurring within 12 to 48 hours after contact
• Reddening, swelling, itching, and burning at the site of contact
• Pain, if the reaction is severe
• Conjunctivitis, asthma, and other allergic reactions if the person is extremely sensitive to the poisonous plant toxin.
Crusting and scaling occurs within a few days. Symptoms usually disappear in 1 to 2 weeks in cases of mild exposure and up to 3 weeks when exposure is severe.
Reaction to poisonous plants can be prevented if the exposed skin is washed with mild soap and water within 10 minutes of contact. Site workers wearing appropriate clothing can prevent contact. Preventive measures that can prove effective for most site personnel are:
• Avoid contact with any poisonous plants on site and keep a steady watch to identify, report, and mark poisonous plants found outside.
• Wash hands, face, or other exposed areas at the beginning of each break period and at the end of each workday.
• Avoid contact with, and wash on a daily basis, contaminated tools, equipment, and clothing.
• Barrier creams, detoxification/wash solutions, and orally administered desensitization may prove effective and should be tried to find the best preventive solution.
• Avoid spreading oils from these plants to hands and other parts of the body.
Figure 3-1, which presents the personal protection requirements for poison oak, will be posted at work sites.
Snakes. There are various types of poisonous snakes indigenous to California. The degree of toxicity resulting from snakebites depends on the potency of the venom, the amount of venom injected, and the size of the person bitten. Poisoning may occur from injection or absorption of venom through cuts or scratches.
The most effective way to prevent snakebites is to avoid snakes in the first place. To minimize the threat of snake bites, all personnel will be aware of the potential for encountering snakes and will avoid actions that increase the likelihood of encounters (e.g., turning over logs). Personnel should avoid walking at night or in high grass and underbrush. Visual inspection of work areas
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should be performed prior to activities taking place. The use of leather boots and long pants will be required since more than half of all bites are on the lower part of the leg. No attempt at killing snakes should be made; many people are bitten in such an attempt.
If a potentially poisonous snake bites someone, the following treatment should be initiated:
• Keep the patient calm
• Notify emergency medical services
• Transport to closest medical facility
• Wash the wound and keep the affected body part still, if time permits
• Apply direct pressure to the site of the bite if bleeding is extreme
• Keep the affected area lower than the heart
• Carry or have him/her walk slowly to the nearest vehicle and immediately transport to the nearest hospital.
Note: The medical profession no longer recommends the use of tourniquet and “slash and suck” treatment for snakebite. Instead, make every effort to transport to the nearest hospital as quickly as possible.
Bird Excrement. Accumulation of bird excrement can pose a biological threat to site workers and visitors. There is a group of pulmonary disease and disorders that result from exposure to infected bird droppings. The inhalation of dust from infected droppings can result in one of these pulmonary infections. All site activities that deal with the disturbance of accumulated bird excrement will be performed in Level C PPE using high-efficiency particulate-air respirator filters at a minimum.
Hantavirus. Rodents, such as deer mice, can potentially carry hantavirus. Deer mice usually live at higher elevations, like mesas, and can be distinguished from other rodents by their small size (2 4/5 inches [in.] to 4 in. long) and by their biocolored tail. However, the Center for Disease Control believes that other rodents also have the potential to carry the virus, so precautions must be taken when dealing with any species of rodent. It is not possible to distinguish by observation whether a rodent carries the hantavirus.
Hantavirus affects the respiratory system in humans. The first symptoms of infection can occur at any time up to 45 days after exposure and include one or more of the following: fever, muscle aches, headache, or coughing. These symptoms progress rapidly into a severe lung disease that often requires intensive-care treatment. Hantavirus can be transferred to humans, primarily from breathing infected rodent excreta particles that have become airborne or ingesting excreta
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particles that have clung to hands or clothing. It can also be contacted from rodent bites or transferred through broken skin. Though the illness caused by hantavirus is severe, it is a relatively rare illness that can be prevented by simple precautions and common sense.
The best way to avoid contact with hantavirus is to avoid contact with rodents and their excreta. Do not leave food or garbage where rodents have access to them; this includes leaving food items and wrappers in vehicles. When possible, seal any opening greater than 1/4-in. diameter in vehicles or structure with steel wool to prevent rodent access.
Fecal Coliform. The basic precautionary procedures while working around material suspected to be contaminated by coliform bacteria are the same as those outlined under Hantavirus. Remediation of old latrines will be conducted in Level C respiratory protection unless otherwise designated by the SSHO.
Stinging Insects. Contact with stinging insects like bees, hornets, and wasps may result in site personnel experiencing adverse health affects that range from being mild discomfort to life threatening. Therefore, stinging insects present a serious hazard to site personnel, and extreme caution must be exercised whenever site and weather conditions increase the risk of encountering stinging insects. Table 3-4 presents the description, habitat, problem, symptoms, and protection against common stinging insects.
Nests and hives for bees, wasps, hornets, and yellow jackets often occur in ground, trees, and brush. The area will be checked for obvious nests and hives before it is cleared. If a nest or hive is found, the SSHO will be contacted before the nest is disturbed or removed. Bites and stings can be painful and may elicit an allergic reaction.
Individuals with life threatening allergies will not work in areas where there is a great potential for insect stings. If simple first-aid measures do not alleviate the symptoms, the victim will be taken to the nearest medical center. An attempt will be made to kill the offending insect and take it to the emergency room with the victim if this can be done quickly and without endangering personnel.
Some of the factors that increase the degree of risk associated with accidental contact to stinging insects are as follows:
• The nests for these insects are frequently found in remote, wooded, and grassy areas.
• The nests can be situated in trees, rocks, bushes, or in the ground, and are usually difficult to see.
• Accidental contact with these insects is highly probable, especially during warm weather conditions when the insects are most active.
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• If a site worker accidentally disturbs a nest, the worker may be inflicted with multiple stings, causing extreme pain and swelling which can leave the worker incapacitated and in need of medical attention.
• Some people are hypersensitive to the toxins injected by a sting, and when stung, experience a violent and immediate allergic reaction resulting in a life-threatening condition known as anaphylactic shock.
• Anaphylactic shock manifests itself very rapidly and is characterized by extreme swelling of the body, eyes, face, mouth, and respiratory passages.
The hypersensitivity needed to cause anaphylactic shock, can in some people, accumulate over time and exposure; therefore, even if someone has been stung previously, and has not experienced an allergic reaction, there is no guarantee that they will not have an allergic reaction upon receipt of another sting.
With these things in mind and with the high probability of contact with stinging insects, all site personnel shall comply with the following safe work practices:
• If a worker knows that he is hypersensitive to bee, wasp, or hornet stings, they must inform the SSHO of this condition prior to participation in site activities. The SSHO will question all site personnel concerning allergies or sensitivities prior to initiating work on site.
• All site personnel will be watchful for the presence of stinging insects and their nests, and shall advise the SSHO if a stinging insect nest is located or suspected in the area.
• Any nests located on site shall be flagged off and site personnel shall be notified of its presence.
• If stung, site personnel shall immediately notify the SSHO to obtain treatment and allow the SSHO to observe them for signs of allergic reaction.
• Site personnel with a known hypersensitivity to stinging insects shall keep required emergency medication on or near their person at all times.
Stings of these insects are responsible for more deaths in the U.S. than bites and stings of all venomous creatures. This is due to the sensitization by the victim to the venom from repeated stings, which can result in anaphylactic reactions. The stinger may remain in the skin and should be removed by teasing or scraping rather than pulling. An ice cube placed over the sting will reduce pain. An analgesic-corticosteroid lotion is often used. People with known hypersensitivity to such stings should carry a kit containing antihistamine and epinephrine.
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Spiders. The biting insects of greatest concern are spiders, especially the black widow and the brown recluse. These spiders are of special concern due to the significant adverse health effects that can be caused by their bite.
Black Widow – The black widow is a coal-black, bulbous spider 3/4 to 1-1/2 in. in length, with a bright red hourglass on the underside of the abdomen. The black widow is usually found in dark moist locations, especially under rocks and rotting logs and may even be found in outdoor toilets where they inhabit the underside of the seat. Victims of a black widow bite may exhibit the following signs or symptoms:
• Sensation of pinprick or minor burning at the time of the bite
• Appearance of small punctures (sometimes none are visible)
• After 15 to 60 minutes, intense pain is felt at the site of the bite which spreads quickly and is followed by profuse sweating, rigid abdominal muscles, muscle spasms, breathing difficulty, slurred speech, poor coordination, dilated pupils, and generalized swelling of face and extremities.
Brown Recluse – The brown recluse is brownish to tan in color, rather flat, 1/2 to 5/8 in. long with a dark brown “violin” shape on the underside. It may be found in trees or in dark locations. Victims of a brown recluse bite may exhibit the following signs or symptoms:
• Blistering at the site of the bite, followed by a local burning at the site 30 to 60 minutes after the bite;
• Formation of a large, red, swollen, postulating lesion with a bull’s-eye appearance;
• Systemic effects may include a generalized rash, joint pain, chills, fever, nausea, and vomiting; and
• Pain may become severe after 8 hours with the onset of tissue necrosis.
There is no effective first aid treatment for either of these bites. Except for very young, very old, or weak victims, these spider bites are not considered to be life threatening; however, medical treatment must be sought to reduce the extent of damage caused by the injected toxins. If either of these spiders are confirmed to be on site, the SSHO shall brief the site personnel as to the identification and avoidance of the spiders. Site personnel should notify the SSHO if they locate either of these spiders.
Wild Animals. Normally animals avoid people and areas where activities are ongoing. Small animals, such as raccoons, infected with rabies or when cornered, may become aggressive.
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When working, remain alert for likely locations that animals inhabit. Avoid nests, dens, and holes in the ground that may be the animal’s home.
The only effective measure to preclude animal bites is avoidance. Contact with all wild animals will be avoided at all times. Persons bitten by an animal should seek medical assistance immediately, especially if it is suspected that the animal is rabid. Aggressive or disoriented behavior, as well as foaming of the mouth can be signs of rabid animals. Until medical assistance can be reached, persons should watch for symptoms of severe swelling, nausea, and shock.
Bloodborne Pathogens. In July of 1992, OSHA issued a final Standard for Protection of Workers Potentially Exposed to Bloodborne Pathogens (29 CFR 1910.1030). This primarily involves medical and research personnel or employees designated as responsible for rendering first aid or medical assistance. Bloodborne pathogens are pathogenic microorganisms that may be present in human blood and can cause disease in humans. These pathogens include, but are not limited to hepatitis B virus and human immunodeficiency virus (HIV).
Potential exposure during site activities may occur from workers who are infected. The OSHA Standard specifically includes first aid providers and is enforceable on site subject to the Hazardous Waste Site Work and Emergency Response Standard (29 CFR 1910.120). The basic concept of this standard is that medical care workers and first aid providers must be instructed in the sources, hazards and avoidance of bloodborne pathogens. They must take the "Universal Precaution" and assume that any blood containing fluid or person bleeding or contaminated with blood containing fluid is positive (infected) with both viruses. Such personnel must be provided with and specifically trained in the basic understanding of the health hazards and the use of personal protection such as, gloves, gowns, masks, eye shields, and CPR barriers or one-way valve rescue breather devices. . The Bloodborne Pathogen Exposure Control Plan is provided in Appendix F.
Military Munition Hazards
This section discusses the military munition hazards that may be encountered during remedial activities at the former Fort Ord. If an item is suspected to be military munitions, all work will cease and the SSHO will be notified, who in turn will notify the UXOSO. At this point, the UXOSO will take over and implement the requirements presented in the BOEWP (IT, 2001). Military munition related hazards are as follows:
• Military Munitions. Military munitions are defined as ammunition, ammunition components, chemical or biological warfare materiel, or explosives that have been abandoned, expelled from demolition pits or burning pads, lost, discarded, buried or fired.
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• Explosive Soil. Explosive soil refers to a mixture of explosives in soil, sand clay or other solid media at concentrations such that the mixture itself is explosive.
• Unexploded Ordnance. Unexploded ordnance is defined as military munitions that have been primed, fused, armed, or otherwise prepared for action and have been fired, dropped, launched, projected, or placed in such a manner as to constitute a hazard and remain unexploded either by malfunction, design, or any other cause.
3.6 Exposure Standards Exposure guidelines presented in Title 29 CFR 1926.65 or Title 8 CCR 5192 will be implemented. The more stringent value will be utilized.
Threshold limit values (TLVs) refer to airborne concentrations of substances that represent conditions that nearly all employees may be repeatedly exposed to day after day without adverse effect. These TLVs are recommended by the ACGIH and are based upon the best available information obtained through industrial experience and animal or human studies. Because of the wide variation in individual susceptibility, a small percentage of workers may experience discomfort from some substances at concentrations below the recommended values. It has been policy to use these guidelines for good hygienic practices; however, whenever applicable, stricter guidelines may be utilized.
The PEL is based on the time-weighted average (TWA) concentration for a normal 8-hour workday and a 40-hour workweek. Several chemical substances have short-term exposure limits (STEL) or ceiling values that do not cause irritation, chronic or irreversible tissue damage, narcosis of a sufficient degree to result in accidental injury, impaired self-rescue abilities, or substantially reduced work efficiency.
The STEL is defined by the ACGIH as a 15-minute TWA exposure that should not be exceeded at any time during a workday even if the 8-hour TWA is within the TLV-TWA. Exposures above the TLV-TWA up to the STEL should not be longer than 15 minutes and should not occur more than four times per day. There should be at least 60 minutes between successive exposures in this range. An averaging period other than 15 minutes may be recommended when observed biological effects warrant this.
In the event that the TLV and PEL for a compound are different, the lower value will apply. Exposure guidelines for identified site contaminants are shown in Table 3-5.
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4.0 Training Requirements
Most field activities at the former Fort Ord require 40-hour training in accordance with Title 29 CFR 1926.65 or Title 8 CCR 5192, as well as other training described in this section. The SSHO may determine that specific defined activities are exempt from training requirements or subject to reduced requirements.
4.1 General Training The SSHO will be responsible for informing all personnel performing on-site activities and all visitors of the contents of this SSHP and ensuring that each person signs the SSHP Acknowledgment Form before entering an exclusion zone (EZ). By signing this form, individuals recognize the hazards present on the site and the policies and procedures required to minimize exposure to hazards or adverse effects caused by hazards. Documentation of certification of training requirements and the training acknowledgment form will be reviewed by the SSHO, provided to the Superintendent, and filed on-site. Untrained employees may be restricted from sites where the potential for exposure exists as determined by the SSHO. Shaw HS 050 contains a discussion of training requirements.
4.2 Hazardous Waste Operations Training Shaw trains all field personnel according to Title 29 CFR 1926.65 and Title 8 CCR 5192 before their initial assignment to any project.
4.2.1 40-Hour Training The following is a general list of topics covered in the 40-hour course:
• General site safety
• Physical hazards (fall protection, noise, heat stress, and cold stress)
• Key management positions responsible for site health and safety
• Safety, health, and other hazards
• Use of PPE
• Work practices by which employees can minimize risks from hazards
• Safe use of engineering controls and equipment on site
• Medical surveillance requirements, including recognition of symptoms and signs that might indicate over exposure to hazards
• Worker Right-to-Know (Hazard Communication)
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• Engineering controls and safe work practices
• Components of the site health and safety program
• Decontamination practices for personnel and equipment
• Confined space entry procedures
• Emergency Response Procedures
• As low as reasonably achievable.
4.2.2 Supervisory Training Site supervisory personnel shall receive eight additional hours of specialized training on program supervision. The following topics are discussed:
• Overall health and safety program • PPE program • Spill containment program • Air-monitoring techniques.
4.2.3 Refresher Training Personnel covered by Section 4.2.1 are required to complete eight hours of refresher training annually on the following topics:
• Safe work practices • Chemical hazard awareness • Hearing conservation • Hazard communication • Respirator refresher • Confined-space entry procedures update • Military munitions awareness.
4.2.4 Supervised Field Experience Personnel covered by Section 4.2.1 will receive a minimum of three days actual field experience under the direct supervision of a trained, experienced supervisor. This supervised field experience will be documented on the Shaw On-the-Job Training Record.
4.3 Visitor Training Site access by personnel making deliveries or performing repairs to utilities, public or government officials, visitors, or local residents will be limited to support areas only. These persons will not be required to comply with the medical and training requirements as previously defined. Support zone access will be limited to designated work, delivery, or observation areas
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to minimize any potential exposure to site contaminants. Site observation areas will be located upwind from predominant wind directions. Weather conditions or site activities may restrict access to observation areas. Authorization for limited site access will be determined on a case- by-case basis by the SSHO in consultation with the CIH and Project Manager. Site access for such personnel will be limited to areas with no potential for exposure during routine operations. These personnel will be escorted on-site and will be strictly prohibited from entering the contamination reduction zone (CRZ) or EZ.
4.4 Tailgate Safety Meetings Tailgate safety meetings will be conducted in accordance with the requirements of Shaw HS 051. Tailgate safety meetings are required to fulfill regulatory provisions for employee training and indoctrination on work place hazards and as a means to minimize work place incurred injuries and illnesses.
The SSHO will conduct tailgate safety meetings for all personnel at the beginning of each work shift or whenever new employees arrive at the job site once the job commences. The topics discussed at the tailgate safety meeting include health and safety considerations for the day's activities, necessary PPE, problems encountered, and new operations. Attendance records and meeting notes will be maintained with the project files. At the conclusion of each shift, a debriefing for site employees will be held, if necessary.
4.5 Site-Specific Training Shaw provides site-specific training for all personnel assigned to projects falling within the scope and application of Title 29 CFR 1926.65. The content of the training will be derived from information contained within this SSHP. All workers must also read and sign the SSHP acknowledging acceptance of site rules and understanding of site hazards before being permitted to enter an EZ. Emergency procedures contained within Section 12.0 will be rehearsed during this training.
4.6 Hazard Communication The hazard communication program is presented in Shaw HS 060. All personnel performing field activities shall receive basic hazard communication training, which involves a review of Shaw HS 060, MSDSs, container labeling, and chemical health hazards. Personnel shall be trained on the hazards of chemicals handled or used on site by reviewing site-specific work plans and the MSDSs in Appendix D. Material Safety Data Sheets will be obtained for all materials purchased for sites that require them.
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4.7 First Aid and Cardiopulmonary Resuscitation At least two persons trained in a minimum of both American Red Cross first-aid techniques and CPR will be on-site whenever activities occur. Refresher training in CPR is required every two years and every three years for first aid. These two employees will meet both the training and vaccination requirements of Shaw’s Bloodborne Pathogen Exposure Control Plan.
4.8 Bloodborne Pathogen Training All employees assigned to jobs with occupational exposure to potentially infectious material shall receive specialized training prior to commencement of work and at least annually thereafter according to 29 CFR 1910.1030, Shaw’s Bloodborne Pathogen Exposure Control Plan (Appendix F) and the Shaw Policy and Procedure HS 512.
The training will include:
• An explanation of the epidemiology and symptoms of bloodborne pathogen diseases such as Hepatitis A, Hepatitis B, Hepatitis C and HIV.
• An explanation of the modes of transmission of bloodborne pathogens.
• A discussion of appropriate safety practices and PPE.
• An explanation of the procedures to follow if an exposure incident occurs and
• The availability of Hepatitis B vaccinations.
4.9 Lead Awareness
All employees subject to exposure to lead at or above the action level will follow the training and compliance program for lead construction projects (Title 8 CCR 1532.1) as presented in the Lead Hazard Compliance and Management Plan, Appendix A.
4.10 Asbestos Awareness If OSHA Class 4 asbestos-related work is required, then asbestos awareness training will be provided to employees performing the work. The asbestos awareness training will be conducted by a CAC. Asbestos awareness training of 2, 4 or 8 hours will be provided to the laborers as appropriate and will depend on the nature of the asbestos task undertaken. Only AHERA trained laborers under the supervision of a CAC will undertake full-scale asbestos abatement. The Asbestos Hazard Management Plan is presented in Appendix E.
4.11 Military Munitions Recognition Training UXO specialists will provide military munitions recognition training. All personnel working at known or suspected MRSs will undergo site-specific UXO training covering the known and
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suspected ordnance present at the site. Topics covered will include general UXO hazards, identification, and general safety precautions. Personnel performing hands-on UXO operations, such as avoidance, construction support, identification, or clearance and disposal, will be qualified UXO specialists.
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5.0 Personal Protective Equipment
This section provides guidelines for selection of appropriate PPE in accordance with Title 8 CCR 5192 and Title 29 CFR 1910.120 (g) (5), 1910.134, and 1910.132. Specific requirements for PPE will be defined in the site-specific work plan. Shaw HS 600 will be adhered to at all times. Environmental and personal monitoring will be conducted to identify health hazards to determine appropriate level of employee protection needed. Environmental and personal monitoring requirements are presented in Section 7.0.
5.1 Respiratory Protection Respiratory protective equipment shall be NIOSH-approved, and respirator use shall conform to American National Standards Institute Z88.2, Title 29 CFR 1910.134 and Title 8 CCR 5144 requirements. Standard operating procedure Shaw HS 601 further defines the respiratory protection program that details the selection, use, inspection, cleaning, maintenance, storage, and fit testing of respiratory-protective equipment.
All personnel (including visitors) performing on-site activities and using air-purifying respirator (APR) must have successfully passed a qualitative respirators fit test in accordance with Title 29 CFR 1926.103 and Title 8 CCR 5144 within the last 12 months. Documentation of fit testing is the responsibility of each employer. Fit testing and any training related to respiratory protection for Shaw personnel will be documented on the Training Acknowledgement Form.
5.2 Hearing Conservation A hearing conservation program will be implemented at the site when exposures equal or exceed an 8-hour TWA of 85 A-weighted decibels [dB(A)]. Hearing loss caused by high sound levels is a problem that can be prevented. As part of the criteria for the medical surveillance program established for this site, audiometric testing is conducted to monitor each worker's ability to hear. Sound-level measuring will be conducted initially on-site and whenever new tasks are started or additional equipment is brought onto the site that has not previously had its sound level quantified.
Caution should be taken at or around loud locations. Engineering controls, such as mufflers and baffles, should be utilized when feasible to reduce noise. Personnel working with or around heavy equipment and as sound-level monitoring dictates should wear hearing protection, such as E-A-R™ plugs (Noise Reduction Rating of 29). All sound levels above 85 dB(A) will require the use of hearing protection. Shaw HS 402 will be adhered to.
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5.3 Levels of Protection The following is a brief description of the PPE that will be required during various phases of the project. The EPA terminology for protective equipment will be used: Levels A, B, C, and D. At a minimum, four sets of appropriate PPE will be maintained at the site for Army visitor usage. Where foot traffic and proximity to earth moving equipment is required, all personnel will be required to wear reflective traffic vests or as specified by the SSHO. The SSHO may upgrade PPE based on actual field conditions. The CIH is solely responsible for downgrading from the initial level of PPE identified in the project-specific work plan or AHA.
5.3.1 Level A Protection Level A protection use is not anticipated during this project.
5.3.2 Level B Protection Level B protection is not anticipated during this project. However, Level B protection will be required when airborne concentrations of hazardous materials (HAZMAT) exceed or are expected to exceed twice the OSHA PEL. Level B PPE will be the initial level of protection used if the preliminary site evaluation does not produce sufficient information to identify the hazards or suspected hazards of the site. The following equipment will be used for Level B protection:
• Full-face, positive-pressure demand, supplied-air respirator, either self-contained or airline with a 5-minute egress bottle.
• Surgical scrubs or equivalent
• Steel-toed heavy-duty, polyvinyl chloride (PVC) boots
• Polyethylene-coated Tyvek™ coveralls with hoods and elastic wrists and ankles
• Latex gloves (inner)
• Nitrile gloves (outer)
• Hearing protection (if necessary)
• Hard hat
• Duct tape openings (ankles, wrists, and respirator).
5.3.3 Level C Protection Level C protection shall be used when:
• The types of air contaminants were identified, concentrations were measured, and an APR is available that can remove the contaminants.
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• The substance has adequate warning properties and all criteria for the use of an APR have been met.
Level C protective equipment at a minimum shall consist of:
• Full-face APR with NIOSH-approved cartridges
• Combination filter/cartridge providing protection against – Not more than 1,000 parts per million of known organic vapors or chlorine, chlorine dioxide, hydrogen chloride, sulfur dioxide, and escape only from H2S. – Dusts, fumes, and mists having a TWA less than 0.05 milligram per cubic meter (mg/m3) – Radionuclides
• Surgical scrubs or equivalent
• Steel-toed heavy-duty, PVC boots
• Tyvek™ coveralls with hoods and elastic wrists and ankles
• Latex gloves (inner and if necessary cotton liners)
• Nitrile gloves (outer)
• Hearing protection (if necessary)
• Hard hat
• Duct tape openings (ankles, wrists, and respirator)
• High visibility safety vests (as appropriate).
5.3.4 Level D Protection Level D PPE shall be used when:
• Work functions preclude significant splashes and immersions, or the potential for unexpected inhalation of, or contact with, hazardous concentrations of harmful chemicals
• Atmospheric concentrations of contaminants are less than half the TLV/PEL.
Level D PPE at a minimum shall consist of:
• Street clothes or coveralls • Steel-toed work boots • Safety glasses
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• Hearing protection (if necessary) • Splash shield (if necessary) • Hardhat • Leather palm gloves (if necessary) • High visibility safety vests.
Level D-modified PPE at a minimum shall consist of:
• Tyvek™ coveralls with elastic wrists and ankles • Steel-toed PVC boots • Latex gloves (inner) • Nitrile gloves (outer) • Hearing protection (if necessary) • Splash shield (if necessary) • Hardhat • Safety glasses • Duct tape openings (ankles, wrists). • High visibility safety vests.
5.4 Activity-Specific Levels of Protection The required level of protection is specific to the activity being conducted. For each project site, the initial levels of PPE will be identified in the project-specific work plan approved by the SSHO and CIH.
5.5 Donning/Doffing Personal Protective Equipment All persons entering an EZ shall put on the required PPE in accordance with the requirements of this SSHP. When leaving the EZ, PPE will be removed in accordance with the procedures listed in Section 11.1 in order to minimize the spread of contamination.
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6.0 Medical Surveillance
Shaw will utilize the services of a Board-Certified Occupational Medicine physician (Section 2.2) for the medical surveillance requirements of this project. Dr. Jerry Berke will review all medical examinations and will be available for medical consultation on an as-needed basis.
Dr. Jerry Berke, M.D., M.P.H. Health Resources 600 West Cummings Park, Suite 3400 Woburn, MA 01801 (800) 350-4511
6.1 Medical Examination As required by Shaw HS 100, all personnel on site working within a CRZ or EZ will have successfully completed a pre-placement or periodic/updated physical examination. Management of exposure and medical records will be in accordance with Shaw HS 102. The occupational physician determined the content of this examination. The site CIH may consult with the physician and recommend additional testing of employees or subcontractors.
6.1.1 Preplacement Examination This examination was designed to meet Title 29 CFR 1926.65 or in Title 8 CCR 5192 requirements for hazardous-waste site operations.
The Shaw medical surveillance program examination, at a minimum, consists of:
• Medical and occupational history questionnaire that includes information on past gastrointestinal, hematologic, renal cardiovascular, reproductive, immunological, and neurologic problems
• Physical examination
• Blood pressure measurements
• Complete blood count and differential to include hemoglobin and hematocrit determinations, red cell indices, and smear of peripheral morphology
• Blood urea nitrogen and serum creatinine
• Sequential Multiple Analyzer Computer
• Pulmonary function test
• Audiogram
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• Electrocardiogram for employees over 35 years old or when other complications indicate the necessity
• Drug and alcohol screening
• Visual acuity.
The following information is, or has been, provided to the examining physician:
• Copy of Title 29 CFR 1926.65 and their appendices • Description of employee's duties • Contaminants potentially exposed to • Description of the PPE to be used • Information from previous medical examinations.
The medical surveillance provided to the employee includes a judgement by the medical examiner of the employee’s ability to use either positive- or negative-pressure respiratory equipment. Any employee found to have a medical condition that could directly or indirectly be aggravated by exposure to these chemical substances or by the use of respiratory equipment will not be employed for the project. A copy of the medical examination is provided at the employee's request.
The employee will be informed of any medical conditions that would result in work restriction or that would prevent them from working at hazardous waste sites.
6.1.2 Annual Examination All Shaw employees receive an annual update examination meeting the requirements of Title 29 CFR 1926.65. The results of these examinations are compared to previous results and the baseline physical to determine if any effects due to exposure have occurred. Appropriate actions are taken as recommended by the physician should the results indicate an exposure; otherwise, employees are cleared for continued work.
6.1.3 Exit Examination Shaw offers exit physical examinations for all employees involved in the medical surveillance program who are leaving the company for any reason to ensure they are in good health.
6.2 Lead Standard Monitoring Biological monitoring for blood lead and zinc protoporphyrin levels will be performed according to the requirements established in the Lead Hazard Compliance and Management Plan in Appendix A.
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6.3 Subcontractor Requirements Subcontractors will certify that all their employees have successfully completed a physical examination by a qualified physician on the Training Acknowledgment Form. The physical examinations will meet the requirements of Title 29 CFR 1926.65, 1926.62 and 1926.103. Subcontractors will also supply copies of the medical examination certificate for each employee they have on site.
6.4 Medical Records Medical and personal exposure monitoring records will be maintained according to the requirements of Title 29 CFR 1926.65 and will be kept for the duration of employment plus 30 years. Confidentiality of employee medical records will be maintained. The written medical opinion from the occupational physician will be made available upon request to the Army representative for any site worker.
6.5 Medical Restrictions When a medical care provider identifies a need to restrict work activity, the employee's home office will communicate the restriction to the employee, the Superintendent, the SSHO, and the CIH. The terms of the restriction will be discussed with the employee and the Superintendent. Every attempt will be made to keep the employee working while not violating the terms of the medical restriction.
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7.0 Exposure Monitoring and Air Sampling Program
Environmental and personal monitoring will be conducted to identify health hazards in order to determine the appropriate level of employee protection needed on-site. The following sections apply, unless the CIH and SSHO deem that monitoring for a specific activity may be discontinued or modified. Specific monitoring requirements will be identified in the site-specific work plan and AHA.
7.1 Routine Monitoring Requirements Routine air-monitoring requirements are applicable for the following conditions:
• Upon initial entry to rule out immediately-dangerous-to-life-and-health conditions
• When the possibility of an immediately-dangerous-to-life-and-health condition or flammable/explosive atmosphere has developed
• When work begins on a different portion of the site
• When contaminants other than those previously identified are being handled
• When a different type of operation is initiated
• When employees are handling leaking drums or containers or working in areas with obvious liquid contamination
• During confined-space work
• When respiratory protection is being used
• When an OSHA-specific standard requires monitoring, e.g., for lead.
Specific monitoring requirements will be identified in the task-specific Work Plan and AHA. Air monitoring results will be used to determine the effectiveness and/or need for dust control methods and to trigger action levels as specified in Table 7-1. The frequency and location of air- monitoring activities can be found in Table 7-2.
7.2 Volatile Organic Compounds Monitoring As determined by site conditions, real-time monitoring will be conducted during activities when there is a potential for emissions of VOCs. Measurements of airborne VOCs will be conducted in the work area by using a photoionization detector or flame ionization detector. The VOCs will be monitored in the breathing zones of employees.
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Integrated air sampling may occur if the action levels in Table 7-1 are reached or exceeded. Contact with the program CIH must be made to initiate this sampling (see Footnotes 1 and 2 to Table 7-1). This decision will be based on analytical results of soil/water samples and integrated air sampling.
Table 7-1 outlines the action levels and PPE that are required when the airborne concentrations of specific contaminants of concern are exceeded. For the purposes of this plan, perimeter exposure monitoring will not be required during nonintrusive work in Level D or Modified Level-D PPE. Any excursion of air contaminants above the STEL or the action levels as specified in Table 7-1 that require Level-C PPE to be worn will require perimeter monitoring to be initiated.
7.3 Dust Emission Monitoring Dust emission monitoring will be conducted during intrusive activities to ensure that field personnel are adequately protected from airborne contaminants. The expected contaminant and the instruments to measure it are:
• Dust emissions: Dust Tracks, Mini-Rams, or Real-time PM10 Monitors
The action level criterion (Level D to Level C) for dust/particulate is 0.5 mg/m3, as determined 3 by a Mini-Ram, or 0.15 mg/m , as determined by a real-time PM10 readout. This dust-action level provides a five-fold safety factor to the OSHA PEL of 0.05 mg/m3 for a lead content in the soil of 20,000 milligrams per kilogram (mg/kg), or fifty-fold for 2,000 mg/kg lead. If the action level is exceeded, the Program CIH may specify integrated sampling and if so, the action level for lead will apply. Table 7-1 shows the project action levels.
For intrusive activities, perimeter monitoring will be conducted in the zone or area immediately adjacent to the EZ boundary, as well as the support zone (SZ) up to a distance of 100 ft from the barrier tape or other system used to identify the limits of the EZ. One or more dust monitors will be established downwind at the edge of the EZ to provide data to confirm that unacceptable dust is not leaving the EZ. One dust monitor will be established upwind at the edge of the EZ to provide background dust levels. If action levels are exceeded, engineering controls will be instituted or personnel will upgrade to Level C.
Action levels that prompt Level C PPE use will be evaluated in the perimeter air monitoring zone no less frequently than hourly and more frequently if determined necessary by the SSHO. Because of the varied locations at which work will be conducted, the SSHO will need to consider wind direction, speed and proximity of on-site personnel (e.g., residences or recreational activities). The meteorological monitoring station will provide supporting information on these parameters and will be in use during all hours of project operations.
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If dust emissions exceed the action levels for Level-C PPE as defined in Table 7-1, perimeter air monitoring, will be conducted continuously; and dust control measures will be supplemented.
7.4 Personal Air Monitoring Personal air monitoring may be required by the CIH based on site conditions. Personal air monitoring will be conducted on at least two representative field personnel using integrated sampling pumps in accordance with NIOSH Method 7082 [inorganic lead]. Additional lead sampling may occur in accordance with the Lead Hazard Compliance and Management Plan found in Appendix A. NIOSH method 7300 will be utilized for arsenic and chromium. Other NIOSH methods may be utilized at the discretion of the SSHO in consultation with the CIH to quantify other site contaminants. This decision will be based on analytical results of soil/water samples and integrated air sampling. Duration of sampling will be done to enable each field personnel’s exposure level to be reasonably represented by at least one full shift (at least 7 hours). A laboratory accredited by the American Industrial Hygiene Association will analyze the samples.
7.5 Meteorological Monitoring Wind speed and direction will be monitored. Wind direction will be used to determine the
appropriate location for the Dust Tracks, Mini-Rams, or real-time PM10 monitors. Wind speed will be monitored and used to determine, in conjunction with visual assessment and results from dust monitoring, whether the operation should be halted.
7.6 Oxygen and Combustible Gas Monitoring Measurements of oxygen and combustible gas will be made using a combination
oxygen/combustible gas monitor. Areas with suspected H2S contamination will have real time
H2S monitoring.
7.7 Calibration of Air Monitoring Equipment All air monitoring equipment will be maintained and calibrated according to the manufacturer's recommendations, which will be available in the SSHO's site office. Calibration will be done before and after each use and under the approximate environmental conditions the instrument will be used. Equipment calibrations will be documented on the equipment calibration log.
If an instrument is found to be inoperative or suspected of giving erroneous readings, the SSHO shall be responsible for immediately removing the instrument from service and obtaining a replacement unit. The specific Shaw or subcontractor operation for which this equipment is essential shall cease until an appropriate replacement unit is obtained. The SSHO will be responsible for ensuring a replacement unit is obtained and/or repairs are initiated on the defective equipment.
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When applicable, only manufacturer-trained and/or authorized Shaw personnel will be allowed to perform instrument repairs or preventive maintenance.
7.8 Other Hazardous Conditions The SSHO will take affirmative action to limit exposures. If elevated levels of unknown chemicals or contaminants are encountered, operations will cease until the situation is evaluated by the SSHO. If necessary the SSHO will contact the CIH to further discuss any potentially hazardous situations. Operations will only be resumed if they can be accomplished in a safe manner.
7.9 Record Keeping The SSHO or his designee will be responsible for establishing and maintaining records of all required monitoring as described below:
• Date, time, location, pertinent task, and exposure information • Description of the analytical methods, equipment used and calibration data • Type of PPE worn • Engineering controls used to reduce exposure • Sampling location • Work operations taking place during monitoring • Meteorological data • Signature of analyst/sample collector
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8.0 Heat/Cold Stress Monitoring
Heat and cold stress monitoring will be performed in accordance with Shaw HS 400 and HS 401.
8.1 Heat Stress Heat stress (HS 400) may be of concern during the execution of tasks associated with this project. Heat stress is caused by a number of interacting factors, including environmental conditions, clothing, workload, and individual characteristics. Extremely hot weather can cause physical discomfort, loss of efficiency, or personal injury.
Individuals vary in their susceptibility to heat stress. Factors that may predispose individuals to heat stress include:
• Lack of physical fitness
• Insufficient acclimation
• Age
• Dehydration
• Obesity
• Alcohol and/or drug use
• Medical conditions
• Infection
• Sunburn
• Diarrhea
• Chronic disease
• Reacclimation (especially after days off in a cool environment or in air-conditioned areas).
Reduced work tolerance and the increased risk of heat stress are directly influenced by the amount and type of PPE worn. The PPE adds weight and bulk and severely reduces the body's access to normal heat exchange mechanisms (evaporation, convection, and radiation) and increases energy expenditure. Standard operating procedure HS 400 will be adhered to at all times.
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8.1.1 Signs and Symptoms of Heat Stress If the body's physiological processes fail to maintain a normal body temperature because of excessive heat, a number of physical reactions can occur ranging from mild to fatal.
Heat related problems include the following:
• Heat Rash - Caused by continuous exposure to heat and humidity and aggravated by chafing clothes. Heat rash decreases the body's ability to tolerate heat as well as being a nuisance.
• Heat Cramps - Caused by profuse perspiration with inadequate electrolytic fluid replacement. Heat cramps cause painful muscle spasms and pain in the extremities and abdomen.
• Heat exhaustion - Caused by increased stress on various organs to meet increased demand to cool the body. Heat exhaustion causes shallow breathing; pale, cool, moist skin; profuse sweating; and dizziness. Heat exhaustion can be alleviated by promptly moving the affected individual to a cool place to lie down and by providing cool fluids to drink.
• Heat Stroke - The most severe form of heat stress. Heat stroke symptoms include hot, dry skin; no perspiration; nausea; dizziness; confusion; strong, rapid pulse; and coma. The body must be cooled immediately to prevent severe injury or death.
8.1.2 Heat Stress Prevention One or more of the following practices will help reduce the probability of succumbing to heat stress:
• Acclimate workers to heat conditions when field operations are conducted during hot weather.
• Provide plenty of liquids to replace the body fluids lost by perspiration. Fluid intake must be forced because, under conditions of heat stress, the normal thirst mechanism is not adequate to bring about a voluntary replacement of lost fluids.
• Provide cooling devices to aid natural body ventilation. However, these devices add weight and should be balanced against worker comfort.
• If possible, install mobile showers or hose-down facilities to reduce body temperature and cool protective clothing.
• If possible, conduct field operations in the early morning.
• Train personnel to recognize the signs and symptoms of heat stress and its treatment.
• Rotate personnel to various job duties if possible.
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• Provide shade or shelter to relieve personnel of exposure to the sun during rest periods.
Individuals succumbing to the symptoms of heat stress will notify the SSHO or Superintendent immediately. The onset of heat stress will preempt any of the aforementioned, halt activities, and initiate treatment. Early detection and treatment of heat stress will prevent further serious illness or injury and lost work time. Proper and effective heat stress treatment can prevent the onset of more serious heat stroke or exhaustion conditions. Individuals that have succumbed to any heat- related illness become more sensitive and predisposed to additional heat stress situations.
8.1.3 Acclimatization The degree to which an employee's body has physiologically adjusted or acclimatized to working under hot conditions is extremely important. The NIOSH recommends a progressive six-day acclimatization period for unacclimatized workers before allowing them to work at their full capacity. Under this regimen, the first day of work on site is begun using only 50% of the anticipated workload and exposure time, and 10% is added each day through day six. Six days should be considered the average time needed for worker acclimatization due to each individual's physical condition and the ability to adjust to hot and humid environments. It is important to note that employees can lose acclimatization in a matter of days and they may require a short acclimatization period when returning from trips to cooler environments.
8.1.4 Physiological Monitoring Ambient temperature and other environmental factors provide basic guidelines to implement work/rest periods. However, since individuals vary in their susceptibility to heat stress, Shaw will also utilize physiological monitoring to regulate each individual's response to heat stress when the temperature exceeds 75 degrees Fahrenheit (°F). The two physiological parameters that each individual will monitor are as follows:
• Heart Rate - Each individual will count his/her radial (wrist) pulse as early as possible in the first rest period. If any individual’s heart rate exceeds 100 beats per minute at the beginning of the rest period, then reduce the work cycle by one-third. The rest period will remain the same.
• Aural and Oral Body Core Temperature - Each individual will measure his/her temperature with a suitable thermometer for one minute as early as possible in the first rest period. If the temperature exceeds 99.6 °F at the beginning of the rest period, then reduce the work cycle by one-third. The rest period will remain the same.
An individual is not permitted to return to work if his/her temperature exceeds 100.6 °F.
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Physiological monitoring information will be recorded on the Employee Record for Heat Stress. All monitoring will be performed by persons with a minimum of current Red Cross first-aid certification and individualized training to recognize the symptoms of heat stress.
8.1.5 Training Personnel (including subcontractor employees) potentially exposed to heat stress conditions will have the following training during the site-specific training session:
Employees:
• Sources of heat stress, influence of protective clothing, and importance of acclimation • How the body handles heat • Heat-related illnesses • Preventive/corrective measures • First-aid procedures.
Shaw Superintendents:
• Physiological monitoring • Establishing work-rest regimes based upon information supplied in Shaw HS 400.
8.2 Cold Stress It is not anticipated that cold stress will be encountered during the execution of this delivery order. If cooler conditions than expected are encountered (e.g., 45°F) during work hours, the requirements established in HS 401 will be followed.
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9.0 Standard Operating Procedures, Engineering Controls, and Work Practices
All of Shaw corporate health and safety policies and procedures presented in the HS Manual apply to this project. The following sections are intended to supplement these procedures and clarify specific work practices.
9.1 General Practices The following general practices shall be followed at the work site:
• Whenever possible, avoid contact with contaminated (or potentially contaminated) surfaces. Walk around (not through) puddles and discolored surfaces. Do not kneel or set equipment on potentially contaminated ground.
• All CRZs and EZs, as established on the site, shall be observed. Entry into a CRZ and EZ shall be by prior notification and authorization of the Superintendent. All required PPE shall be worn before entering these zones.
• Contaminated equipment and PPE, such as respirators, gloves, and boots, (if not discarded) shall not be removed from the CRZ until they have been properly cleaned.
• Legible and understandable precautionary labels shall be affixed prominently to containers of contaminated scrap, waste, debris, and clothing.
• No food or beverages shall be present or consumed in a CRZ or EZ. These are only allowed in designated areas of the SZ.
• No tobacco products shall be present or used, and cosmetics shall not be applied in a CRZ or EZ. These are only allowed in designated areas of the SZ if areas have been designated.
• Field personnel must observe each other for signs of toxic exposure. Indications of adverse effects include, but are not limited to – Changes in complexion and skin discoloration – Changes in coordination – Changes in demeanor – Excessive salivation and pupillary response – Changes in speech pattern – Irritability or mood swing.
• Field personnel shall be cautioned to inform each other of nonvisual effects of toxic exposure such as – Headaches
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– Dizziness – Nausea – Blurred vision – Cramps – Irritation of eyes, skin, or respiratory tract.
• The general guidelines to be adhered during earthquakes are presented in Section 12.17.
• Any detected effects of toxic exposure shall be reported to the SSHO immediately.
• An emergency eyewash unit shall be located immediately adjacent to employees who handle hazardous or corrosive materials, including decontamination fluids. All operations involving the potential for eye injury and splash must have approved eyewash units locally available that are capable of delivering at least 0.4 gallon (1.5 liters) per minute for 15 minutes or more. The emergency eye wash equipment must irrigate and flush both eyes simultaneously while the operator hold both eyes open. Personal eyewash units that deliver less than 15 minutes of flushing may be used to supplement emergency-washing facilities; however, they may not be used as a substitute.
• If any on-site activities, including decontamination, continue later than dusk, adequate lighting must be provided. Work areas must have adequate lighting for employees to work and to identify hazards (5-ft candles minimum). Personnel should carry flashlights in all normally dark areas for use in the event of a power failure.
• Hazardous work, such as handling HAZMAT and heavy loads, and equipment operation should not be conducted during severe storms.
• Operations involving the potential for fire hazards shall be conducted to minimize the risk of fire. Nonsparking tools and fire extinguishers shall be used or available as appropriate. Sources of ignition shall be removed. When necessary, explosion-proof instruments and/or bonding and grounding techniques will be used to prevent fire or explosion.
• A fire extinguisher will be located on all vehicles and heavy equipment or in the work area (Section 9.8).
• Safety glasses will be worn during any work on-site where potential for eye damages exists, e.g., maintenance of equipment, operations in dust or contaminated areas, sampling, visitors on site, and debris removal.
• Emergency equipment will be provided as specified in Section 12.14.
9.2 Visitors to Field Activities All visitors to field activities must report immediately to the responsible person at the work site who is maintaining the Visitors’ Log (usually the decontamination technician). All visitors must
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complete a site orientation, including site history and potential physical and chemical hazards. All visitors will sign the entry log and tailgate safety acknowledgment.
The only personnel allowed to enter the CRZ or EZ shall be Shaw or Army employees, approved Shaw subcontractors, or regulatory personnel. Visitors will not be allowed to enter the CRZ or EZ unless they have provided evidence of appropriate training and medical surveillance and have been approved by the SSHO.
9.3 Buddy System All personnel will employ the buddy system during operations. This system requires that a partner, or buddy, accompany each worker. The buddy provides the co-worker/partner with assistance, observes the partner for signs of exposure, periodically checks the integrity of the partner’s PPE, and notifies the SSHO if help is needed. The buddy must be in a line of sight or hearing of the partner and be prepared to enter any area the partner enters. The buddy must be fully certified to work in the level of protection that the employee is working in, and must have the appropriate PPE available.
The "buddy system" will be used at all times by all field personnel in the EZ. No one is to perform fieldwork alone. Visual, voice, or radio communication will be maintained at all times.
9.4 Excavation Procedures Excavation and trenching activities will be conducted in accordance with Shaw HS 307. Due to the high probability of sandy soils, it may be necessary to utilize protective systems for workers who may enter excavations (e.g., for sampling). All excavations 4 ft deep or greater, into which persons will enter and perform work, must be made safe for entry by benching, sloping, or shoring, as approved by a Professional Engineer. Excavations less than 4 ft in depth that are determined by a competent person to have no potential for cave-in do not require protective systems. Note: A permit by the Cal/OSHA is required before starting work on excavations 5 ft deep or greater that workers are required to enter.
For all excavations or intrusive work, the guidance provided in Section 9.13 pertaining to military munitions operations will be strictly adhered to. Shaw requires pre-excavation clearance by a qualified UXO specialist at all locations in Site 39 and at other locations that have not been cleared for military munitions by the Army.
All excavations shall be performed from a stable ground position. A competent person, one who has received training in excavation safety, shall make daily inspections of the excavation. The inspector shall determine the likelihood of a cave-in, and remedial action, such as sloping or shoring, shall be taken if the walls appear to be unstable.
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All soil shall be located at least 4 ft from the edge of the excavation to prevent it from falling back into the excavation. Perimeter protection will be used for all excavation activities at the site. The perimeter protection shall consist of warning barricades or fencing placed at a distance not closer than 6 ft from the edge of the excavation and shall display adequate warning at an elevation of 3-to-4 ft aboveground.
All project personnel shall participate in the site-specific training session and be instructed on the following requirements:
• Excavations over 4 ft in depth that personnel are required to enter must have sufficient stairs, ramps, or ladders provided to require no more than 25 ft of lateral travel.
• Before excavating, the existence and location of underground pipe, electrical equipment, and gas lines will be determined and documented. If the locations of any lines are in question, a cable-avoiding tool will be used to positively locate them. Workers who are hand digging must have PPE or tools that are nonconductive to electricity, e.g., rubber gloves and boots or fiberglass-handled tools.
• Combustible gas readings of the general work area will be made regularly.
• No ignition sources are permitted if the ambient airborne concentration of flammable vapors exceeds 10% of the lower explosive limit (LEL) during the excavation. A combustible gas indicator will be used to make this determination.
• Operations must be suspended and the area vented if the airborne flammable concentration reaches 10% of the LEL in the area of an ignition source (e.g., sparks from bucket of excavator).
• If excavating equipment is located in the vicinity of overhead power lines, Table 9-1 will be used to determine safe working distances.
• Ladders will be provided and placed at an angle not more than 30 degrees from vertical and will be secured as necessary. Ladder side rails shall extend at least 3 ft above the ground surface.
• Excavations occurring within 2 ft of communication cables will be performed by hand digging until the cable is exposed.
• In excavations a competent person shall determine presence of toxics.
• Any container that may be encountered during excavation such as, cylinders, drums, sealed bottles, or similar items with contents is to be avoided and not removed until a hazard assessment is made by the SSHO.
If asbestos or asbestos-like materials are encountered, operations will cease and the SSHO will be notified prior to any resumption of work or removal of the material.
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9.5 Hot Work Welding, cutting, and other hot work conducted on-site must comply with the guidelines established in Shaw HS 314, base fire department requirements, or both. A qualified person will prepare a Hot Work Permit each day for which hot work will be performed.
9.6 Confined Space Entry Shaw HS 300 for confined-space entry will be followed if such an activity is needed during the execution of this project. A confined-space is defined as a space large enough and so configured that a person can bodily enter and perform assigned work, has limited means for entry or exit, and is not designed for continuous employee occupancy. Contaminated soil excavations, storage vessel entries, and other confined space work may pose additional hazards such as air contamination, flammable or explosive atmosphere, and oxygen deficiency. Excavation entry may pose the possibility of engulfment. Shaw has detailed training for confined-space entry, and only personnel properly trained shall supervise and participate in confined-space entry procedures or serve as standby attendants.
All confined-spaces are initially considered permit required. Under certain conditions, a space may be reclassified as a nonpermit-confined space provided the SSHO approves the reclassification and the space meets the criteria outlined in Shaw HS 300.
9.7 Sanitation A break area will be designated and provided in an area in the SZ (outside of contaminated zones). Outdoor and indoor areas may be designated. The designated areas will be clean and will facilitate the number of workers using it. Eating, drinking, and tobacco may be permitted in break areas. Smoking will only be permitted if it is done in an area that is approved by the SSHO.
9.7.1 Drinking Water Shaw will provide an adequate supply of drinking water. These drinks will be dispensed in an approved potable water system and in a manner that prevents contamination between the consumer and dispenser. All outlets dispensing nonpotable water will be posted "Caution - Water Unfit for Drinking, Washing, or Cooking." Systems furnishing nonpotable water and systems furnishing potable water will be constructed and remain completely independent of each other.
9.7.2 Hand-Washing Facilities Facilities for washing hands will be provided at each break area. Adequate water supply, antibacterial soap and disposable towels will be provided.
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9.7.3 Toilets If permanent toilet facilities are not available (within 500 ft) Shaw will provide, at a minimum, two chemical toilets for the personnel on-site. Arrangements will be made for the routine servicing and cleaning of these units. The number of toilets provided will be consistent with the requirements of EM 385-1-1 (USACE, 2003).
9.7.4 Trash Collection Adequate trash receptacles will be placed around the job site for trash collection. Contaminated trash must be segregated from sanitary trash. Sanitary trash receptacles will be labeled "Sanitary Trash," and hazardous waste will be labeled according to applicable regulations.
High housekeeping standards must be maintained. Trash receptacles shall be emptied on an as- needed basis.
9.8 Fire Prevention and Protection Clothes, cotton waste, and other combustible materials that might constitute a fire hazard will be placed in closed metal containers and placed outside or destroyed at the end of each day.
Shaw will provide and maintain portable fire extinguishers in the following manner:
• Portable fire extinguishers will be provided, where needed, and inspected on a monthly basis. A visual inspection will be made to ensure that extinguishers are fully charged and in an operable condition. Hoses, nozzles, brackets, and supports will be inspected for deficiencies and corrected. Gauge pressure will be checked on pressurized units on a monthly basis to ensure units are fully charged and nonpressurized units will have their cartridges weighed on an annual basis. The chemical within dry chemical extinguishers will be inspected on an annual basis to ensure that it is powdery and in a free-running condition. An inspection tag will be attached to all extinguishers to designate that they have received an annual inspection.
• Fire extinguishers will be suitably placed, distinctly marked, and readily accessible.
• A fire extinguisher with a rating of not less than 10-B will be located within 50 ft or wherever more than 5 gal of flammable gas are being used on the work site (this does not apply to integral fuel tanks of motor vehicles).
• A fire extinguisher with a rating of not less than 20-B will be located outside and within 10 ft of the door opening into any room, building, or trailer used for storage of more than 60 gal of flammable or combustible liquids.
• If flammable liquids are being stored in an outside location, at least one portable fire extinguisher with a rating of not less than 20-B will be located at least 25 ft from the storage area, but not more than 75 ft away.
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• All tank trucks or vehicles used for transporting and/or dispensing flammable or combustible liquids will have a portable fire extinguisher with not less than a 20-BC rating.
• A portable fire extinguisher with a rating of not less than 20-BC will be placed within 50 ft of each service or fueling area.
• Fire extinguishers will be placed in storage areas so they are capable of extinguishing materials being stored.
• A nationally recognized testing laboratory will approve all fire extinguishers.
• A fire extinguisher with a rating of not less than 2-A will be provided where torches or open flames are in use.
• At least one dry-chemical or carbon-dioxide fire extinguisher, with a 5-BC rating minimum, will be available for placement on each unit of heavy equipment.
Refueling of the mechanical equipment also poses fire hazards. All refueling and fuel handling equipment must be Underwriters Laboratories listed and Factory Mutual approved. The refueling must be done in a designated area to prevent contamination from minor spills and to reduce the risk of fires. The following guidelines must be followed whenever personnel are dispensing flammable and combustible liquids:
• Flammable liquid dispensing systems will be electrically bonded and grounded. All tanks, hoses, and containers of 5 gal or less will be kept in metallic contact while flammable liquids are being transferred; transferring of flammable liquids in containers in excess of 5 gal will be done only when the containers are electrically bonded.
• Flammable or combustible liquids will be drawn from, or transferred into, vessels, containers, or tanks within a building or outside only through a closed piping system, from safety cans, by means of a device drawing through the top, or from a container, or from portable tanks, by gravity or pump, through an approved self- closing valve. Transferring by means of air pressure on the container or portable tanks is prohibited.
• Areas in which flammable or combustible liquids are transferred in quantities greater than 5 gals from one tank or container to another will be separated from other operations by at least 25 ft or a barrier having a fire resistance of at least 1 hour. Drainage or other means will be provided to control spills.
• Natural or mechanical ventilation will be provided to maintain the concentration of flammable vapor below 10% of the LEL.
• Dispensing units will be protected against collision damage.
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• Dispensing nozzles and devices for flammable liquids will be of an approved type. A listed emergency breakaway device designed to retain liquid on both sides of the breakaway point, shall be installed on each hose dispensing Class I liquids
• Dispensing devices shall be at least 20 feet from any activity involving fixed ignition sources.
• A barrier having a fire resistance rating of at least one hour shall segregate DOT identified noncompatible materials that may create a fire hazard.
• Lamps, lanterns, heating devices, and similar equipment will not be filled while hot; these devices will be filled only in well-ventilated rooms free of open flames or in open air and shall not be filled in storage buildings
• Measures will be taken to control growth of tall grass, brush and weeds adjacent to facilities. A break of at least 3 feet shall be maintained around all facilities.
9.9 Electrical Power All electrical equipment must have a ground fault circuit interrupter as part of the circuit. All equipment must be suitable and approved for the class of hazard. Temporary wiring conductors installed for operation of construction tools and equipment will be either Type TW or THW contained in metal raceways or will be hard-usage or extra-hard-usage multiconductor cord. Temporary wiring will be secured above the ground or floor and will not present an obstacle to persons or equipment. Applicable OSHA standards for electrical power, Title 29 CFR Part 1926(k), shall apply. When power is needed outside job trailers, an outside receptacle shall be installed. No extension cords shall be run through doorways. Only OSHA-approved outside- rated wiring shall be used.
Standard operating procedure Shaw HS 315 presents the control of hazardous energy and HAZMAT sources (lockout/tagout). This establishes the minimum requirements to ensure that all machinery, equipment, or confined spaces are isolated from all potential hazard sources (mechanical, electrical, chemical hazards, etc.) and are locked out and tagged out prior to employees performing any servicing, maintenance, or entry activities.
9.10 High or Elevated Work Elevated work, where a fall potential exists, will be performed using appropriate ladders and/or fall protection (i.e., body harness and lifeline). The requirements for inspection, setup, and proper use of portable step, straight and extension ladders are presented in Shaw HS 302. Guidance on the methods and techniques to minimize fall hazards and training for workers on the use, inspection, and limitations of fall arresting equipment, and the rescue of fallen workers suspended from their equipment is presented in Shaw HS 1101. No employee may be exposed to a fall of over 6 ft without being adequately protected.
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9.11 Manual Lifting Many different types of objects may be handled manually during site operations. Care should be taken when lifting and handling heavy or bulky items because they are the cause of many back injuries. The following fundamentals address the proper lifting techniques that are essential in preventing back injuries:
• The size, shape, and weight of the object to be lifted must first be considered. No individual employee is permitted to lift any object that weights over 60 lbs. Multiple employees or the use of mechanical lifting devices are required for objects over the 60-lb. limit.
• The anticipated path to be taken by the lifter should be inspected for the presence of slip, trip, and fall hazards.
• The feet shall be placed far enough apart for good balance and stability (typically shoulder width). THE FOOTING SHALL BE SOLID.
• The worker shall get as close to the load as possible. The legs shall be bent at the knees.
• The back shall be kept as straight as possible, and abdominal muscles should be tightened.
• To lift the object, the legs are straightened from their bending position.
• A worker shall never carry a load that cannot be seen over or around.
• When placing an object down, the stance and position are identical to that for lifting. The legs are bent at the knees and the object lowered.
When two or more workers are required to handle the same object, coordination is essential to ensure that the load is lifted uniformly and that the weight is equally divided between the individuals carrying the load. When carrying the object, each worker, if possible, shall face the direction in which the object is being carried. In handling bulky or heavy items, the following guidelines shall be followed to avoid injury to the hands and fingers:
• A firm grip on the object is essential; leather gloves shall be used if necessary.
• The hands and object shall be free of oil, grease, and water which might prevent a firm grip, and the fingers shall be kept away from any points that could cause them to be pinched or crushed, especially when setting the object down.
• The item shall be inspected for metal slivers, jagged edges, burrs, and rough or slippery surfaces before being lifted.
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9.12 Clearing and Grubbing When trees are being felled, the following rules must be adhered to:
• Before beginning the operation, alert all personnel in the area that the operation is about to commence. Then, check that the area around the landing point of the tree is clear.
• Use a spotter to make sure that area remains clear.
• Check that there are no overhead power lines or obstructions that may catch or deflect the tree as it falls.
• Never turn your back on the tree while it is being felled.
• Watch for kickback from the saw and do not force the saw if it becomes stuck in the tree.
• Make use of wedges to prevent saw binding.
• When using a chain saw, wear the appropriate PPE, including hardhat, leather palm gloves, chaps, face shield, safety glasses, steel-toed boots, and hearing protection.
• All chain saws will be equipped with a spark suppressor.
• A 5-AB fire extinguisher will be located within 50 ft of the chainsaw cutting location
An AHA will be prepared for any mechanical brush-removal device that is proposed.
Machetes will not be used for any work at the former Fort Ord.
9.13 Military Munitions Intrusive activities at the former Fort Ord are inherently dangerous because of the potential presence of military munitions. This potential requires the strictest adherence to safety precautions, a planned approach, and intensive supervision in order to be completed in a safe and successful manner. MMR operations will be conducted in accordance with the BOEWP (IT, 2001). Unexploded ordnance and construction support activities will be conducted in accordance with EP-75-1-2 (USACE, 2004).
9.13.1 General Unexploded Ordnance Avoidance Procedures Shaw’s UXO specialists will provide UXO safety support during all intrusive activities. Their mission is to ensure the safety of onsite workers and prevent adverse impacts on the project schedule and overall project efficiency in the event that UXO is encountered during remediation work.
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When conducting intrusive activities (drilling, sampling, surveying, etc.), consideration will be given to possible military munitions contamination that may be found on the surface and/or subsurface in various areas of former Fort Ord. If the activities are conducted within areas with known or suspected military munitions contamination, the UXO team will conduct a surface access survey and a subsurface survey of UXO before any type of activities commence, including foot and vehicular traffic. Results of this surface survey will determine if the area is safe for non-UXO personnel. During excavation work, UXO specialists will carefully observe the excavation sites and examine the excavated materials for the presence of UXO and UXO- related material. An area that is considered too dangerous for entry will require further investigation, and or clearance.
All UXO-related material will be identified, and those that are deemed “safe to move” by the USACE Military Munitions Safety Specialist will be moved to a nearby designated safe holding area. Those items that cannot be positively identified or are not safe to be moved will be avoided, left in place, and clearly marked for handling and disposal by the on-site UXO contractor at the direction of the USACE Military Munitions Safety Specialist. In the event that a UXO item is not safe to be moved, project excavation activities may resume in another area of the remediation site that is outside of the fragmentation hazard area presented by the UXO. Excavation will stop in the event that unexpectedly large amounts of buried UXO are encountered, and the project plans will be reassessed.
Standard operating procedures for discoveries of UXO items are summarized in Table 9-2. A notification list is provided in Table 9-3.
9.13.2 Unexploded Ordnance Personnel Assignments A UXO specialist will support intrusive activities such as drilling, sampling, and surveying. A minimum of two UXO-qualified personnel will be on-site during excavation operations, and one of the UXO-qualified personnel will be a UXO supervisor. During loading and hauling operations, one UXO specialist will be positioned at the laydown area, and one UXO specialist will be located at the receiving point on the Landfill.
Shaw’s UXO personnel are all former U.S. military explosive ordnance disposal (EOD) technicians and graduates of the U.S. Naval School of EOD in Indian Head, Maryland. Additionally, they are all trained HAZMAT technicians and have completed the required OSHA 40-hour training in accordance with Title 29 CFR 1910.120. For this project, the UXO organization will be as described below:
• UXO Supervisor – The UXO Supervisor reports to the Project Manager and is responsible for the safety and operations of UXO specialists assigned to him.
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• UXO Specialists – UXO Specialists will be responsible for safety conducting field operations as assigned by and under the supervision of the UXO Supervisor.
A team of UXO personnel will be assigned to the project after mobilization dates are determined. The resumes of these individuals provide information on training, experience, and certificates of EOD school graduation, 40-hour and 8-hour refresher OSHA training, and medical fitness. These certifications will be provided for review and maintained in the Shaw project office.
9.13.3 Excavation Technical Approach Excavation support activities will consist of the following UXO operations:
• SAFETY OBSERVATION – Excavation activities will be observed by UXO specialists to identify and segregate UXO-related material and UXO for the purposes of minimizing the handling by and exposure to UXO of untrained workers and preventing UXO from being inadvertently transferred from the remediation site to another area.
• SUBSURFACE GEOPHYSICAL SURVEY – As needed, magnetometers will be used to examine the surface area in a nonintrusive manner. This technique will be used to investigate the surrounding area in the event that UXO is uncovered during excavation and detected by visual safety observation.
• UXO HANDLING AND REMOVAL – UXO located as the result of safety observation will be identified and, at the discretion of the USACE Military Munitions Safety Specialist, either moved to a designated holding area, or left in place and conspicuously marked to ensure the safety of site workers until the UXO is handled and disposed of by the cognizant UXO contractor.
More specific procedures will be included as necessary in site-specific work plans.
9.14 Dust Control The most effective way to control dust is to minimize its initial generation. Preventive measures will be implemented by project personnel to maintain fugitive dust emissions at levels below action levels established in Section 7.0. The following list details methods and measures to be applied.
• Speed limits on haul roads.
• Use dust suppressants during loading and hauling operations. Suppressants may include the following: – Place gravel on haul roads – Spray water on haul roads, stockpile(s), and loading equipment.
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• Use manufactured dust suppressants that are environmentally acceptable.
• Install enclosures and dust collectors on fixed equipment.
• Schedule and stage operations to take advantage of prevailing winds.
• Schedule hauling operations to minimize trips on dirt haul roads.
• Utilize tarpaulin on trucks while transporting material.
• Limit drop heights from material loading equipment to dump-point impact. This applies to truck loading and stockpiling.
• Operations where crystalline silica may be present (e.g., soil/debris separation); evaluation of exposure based upon Mini-Ram data will be conducted, as well as personal respirable dust sampling as determined by the SSHO.
9.15 Radiation Monitoring Radiation monitoring is not anticipated at this time, however, where there is a concern for ionizing radiation exposure, the work area will be initially screened with a radiation survey meter. A Ludlum™ 2221 or equivalent will be used as a general screening instrument to identify the presence of gamma radiation. If gamma sources are identified, a quantitative instrument such as the Ludlum™ L-1000, will be used to measure alpha particles. A Ludlum L-2200 or equivalent will be used to quantitatively measure beta and gamma radiation..
9.16 Equipment and Vehicle Inspections Mechanized equipment will be inspected in accordance with the requirements of EM 385-1-1 (USACE, 2003). Before any piece of mechanized equipment is placed into service, a thorough inspection will be performed and documented on Form 9-1. Thereafter, the operator will check equipment each day in use, and a detailed weekly inspection will be documented using the standard form included as Form 9-2.
Vehicles will be inspected weekly, in accordance with Shaw HS 810.
9.17 Ropes, Cables, and Slings This section provides inspection procedures for ropes, cables, and slings.
9.17.1 Visual Inspection A competent person must perform a visual inspection of ropes, cables, and slings before use on each shift. The visual inspection is performed to identify the following:
• Kinking, crushing, birdcaging, or severe twists • Nicks and breaks and frayed or unraveled edges
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• Deformed, worn, or flattened surfaces • Corroded or pitted surfaces • Shortened or lengthened rope lays • Evidence or heat damage • End attachments that are cracked, deformed, or worn • Appearance of indicator thread.
9.17.2 Detailed Inspection The following, more detailed inspection must be performed by a competent person at least monthly or at more frequent intervals depending on operating conditions and use:
• Run out rope completely and note conditions, such as number of broken strands, broken wires in one lay, reduction in rope diameter, corrosion, shorting of the lay, or fraying
• Run a soft cloth, preferably cotton, over the entire length of wire rope and examine any rope lays that pick up threads of the cloth
• Determine the extent of damage due to broken wires, nicks, cuts and frayed or unraveled edges
• Assure that wire rope is properly lubricated
• When any of the above conditions exist and show evidence of abnormal deterioration, the item must be watched and reinspected daily. If this condition continues to worsen, the item must be condemned and replaced.
9.17.3 Disposition of Damaged Wire Rope Any wire rope or cable removed from service due to a damaged condition must be removed from service and destroyed to prevent reuse. The length and type of service, as well as the severity of operation, must be taken into consideration before determining the disposition of ropes or cables that show signs of damage. When failure of the rope or cable might endanger life or equipment, the rope or cable must be destroyed immediately. In all cases, the rope or cable must be destroyed if any of the following conditions are found to exist:
• Broken Wires − Six or more wires broken in any one wire lay. Three or more wires broken in any one strand of one rope lay.
• Work Outside Wires − Wearing of one-third or more of the original diameter of any of the outside individual wires.
• Broken Strand − One or more broken strands.
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• Kinking, Crushing, Unstranding, or other Damage − Rope severely kinked, crushed, cut frayed, birdcaged, unstranded, or unraveled, or any other damage resulting in distortion of the rope structure.
• Heat or Weld Damage − Any evidence of heat damage or weld splatter.
• Corrosion − Considerable corrosion (rust) in the valleys between strands or corroded or broken wires at end connections.
• Reduction in Diameter − Noticeable reduction from normal rope diameter.
9.17.4 Sling Inspection Slings are generally used in conjunction with other material-handling equipment for the movement of material by hoisting. Slings are made of alloy steel chain, wire rope, metal mesh, natural or synthetic fiber, or fibers woven into a web. Many manufacturers of slings will produce their slings with a safety mark already on them. An example would be a sling with a red colored strand woven right into the material. If the sling has been cut or nicked to the point where the red colored strand is visible, the sling should be replaced immediately. However, since not all manufacturers make this safety mark, it is up to the competent person to determine when the sling should be replaced.
Each day and prior to each shift, before use, the sling and all fastenings and attachments must be visually inspected for damage or defects by a competent person. Additional inspections should be performed during use, and when service conditions warrant. Damaged or defective slings must be immediately removed from service, tagged, and destroyed.
In the case of alloy steel chain slings or hoists, the inspection shall include a thorough check for wear; defective welds deformation of the links, and an increase in length. When such defects or deterioration is present, the chain sling must be immediately removed from use, tagged and replaced until it can be repaired or destroyed.
9.17.5 Wire Rope Fixtures are usually attached to wire rope by means of wire rope clips, commonly referred to as either “U” clips or “U” bolts. These wire rope clips are also used when making a loop at the end of a wire rope. There is a right way and a wrong way to use a wire rope clip. The correct method for installing a wire rope clip is to attach the clip with the base or saddle of the clip against the live, or long end of the rope, and the rounded “U” portion of the bolt over the short or dead end of the wire rope. This will allow the clip to develop 80% to 90% efficiency and is the only correct method to attach wire rope clips. The saying, “Never saddle a dead horse,” will remind users of the correct mounting of wire rope clips.
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9.17.5.1 Wire Rope Inspection and Replacement Criteria Due to the variable factors involved, there is no precise rule for when to replace wire rope. Continued use of wire rope depends on the remaining strength as judged by the competent person using the inspection criteria.
9.17.5.2 Inspection Requirements for Reuse of Wire Rope for Primary Suspension Wire rope must be removed from service when any of the following conditions exist:
• Any broken wire
• Kinks that cannot be removed by hand without the use of tools
• Crushing, birdcaging, or any other damage that results in distortion of the rope structure or reduces the diameter of any single wire by one-third or more of its diameter
• Evidence of heat exposure
• Noticeable rusting, corrosion, or pitting
• Any sign of core failure as evidenced by a lengthening of rope lay and a reduction in the diameter of the rope. The minimum acceptable diameter of a used 5/16 in. wire rope is 0.300. A new 5/16 in. wire rope must have a minimum measurement of 0.3125
• Any build-up of foreign matter.
9.17.5.3 Inspection Procedure To perform the inspection, stretch the wire rope out on the ground. Inspect for kinks at this time. Cut out any kinked areas that cannot be straightened by hand without the use of tools. Continue the inspection process with any remaining lengths that are usable as primary or tieback ropes.
Coil wire rope with a winder. Pass the full length of the rope through your hand using a glove and a rag squeezed on the rope. Measure length of rope while winding. This procedure coupled with visual inspection should detect any broken wires. Check the bullet on both ends for damage.
Visually inspect the entire length of the wire rope for birdcaging, corrosion, pitting, heat exposure, and foreign matter. Check for any reduction in individual wire diameter caused by abrasion or wear. Measure the wire rope diameter at a distance of 20 ft from the J-clamped end. The minimum acceptable diameter without load on a used 5/16-in. rope is 0.300. New 5/16-in. rope should measure 0.3125 + 1/32 in. - 0.000. Mark the inspected coil as “Ready for Use” and place in the storage area.
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9.17.5.4 Inspection Requirements for Reuse of Wire Rope for Tieback The inspection procedure will be the same as inspection for the primary wire rope, with the following allowances or exceptions:
• Four randomly distributed broken wires in three lays or two broken wires per strand in no more than three lays is acceptable.
• No broken wires are allowed in the valley between strands since this indicates an abnormal condition where other wires not visible could be broken.
• A nut must be welded on each end of the tieback to ensure that it cannot be used for primary suspension.
• Tiebacks must be tagged “Do Not Use” until they are inspected and tagged “Ready for Use: Tie Back Only,” before using.
9.17.5.5 Manila Rope Only industrial-grade manila rope identified by a single-colored shard with the weave shall be used. All manila rope shall be inspected before each use.
9.18 Underground and Aboveground Storage Tanks Removal of USTs will be conducted in accordance with Shaw HS 309 and requirements of the Monterey County Department of Health (MCDH) as presented in Monterey County Ordinance 3040, Underground Storage Tank Closure Procedure. A permit and fee is required by the MCDH for the closure and removal of a UST. The MCDH does not have permit requirements or closure procedures for AST removal. However, applicable requirements presented in Monterey County Ordinance 3040 and Shaw HS 309 will be implemented.
Other policys directly related to UST and AST removal are, but not limited to, the following:
• Shaw HS 300 (Section 9.6) – Confined Space Entry • Shaw HS 307 (Section 9.4) – Excavation and Trenching • Shaw HS 314 (Section 9.5) - Welding, Cutting, and Other Hot Work in Hazardous Locations • Shaw HS 315 (Section 9.9) – Lockout/Tagout
9.18.1 Preliminary Requirements A site reconnaissance will be conducted prior to start of field activities to confirm locations of tank and all associated piping using site records and physical inspection. USA Alert will be contacted prior to fieldwork and the Underground/Overhead Utility Checklist included in HS309 will be completed.
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Trees, boulders, poles and other surface encumbrances located at the work site shall be made safe or removed prior to initiation of the tank closure project.
The site shall be arranged to assure that construction equipment (not in transit) and personnel do not come closer than authorized to any energized overhead high voltage conductor such as electric utility lines.
9.18.2 Operation Requirements − Hazard Assessment At the beginning of the project, each work shift, and as often as necessary to ensure safety, a competent person shall conduct an area survey to locate work place hazards and determine appropriate safety control measures.
Only experienced, demonstrably proficient equipment operators will be used to operate heavy equipment such as backhoes, front-end loaders, cranes, etc. Where certification or licensing requirements exist, such personnel shall possess appropriate certification and/or licensing for operating specified heavy equipment.
The following practices shall be followed when using heavy equipment:
• Equipment should be inspected daily by the operator to ensure that there are no operational problems.
• Materials, such as pipe, rebar, etc., shall be kept out of traffic lanes and access ways. and stored so as not to endanger personnel at any time.
• The equipment operator shall maintain communication with a designated signalman through either direct voice contact or approved, standard hand signals. In addition, all site personnel in the immediate work area shall be made aware of the equipment operations.
• When not in use, hydraulic and pneumatic components should be left in down or "dead" position.
• Roll-over protection shall be provided on hilly sites.
• No riding on vehicles or equipment except in fixed seats.
• Foot traffic shall be restricted while heavy equipment is in operation. Workers remaining around any heavy equipment shall be kept to a minimum.
• A flagman with roadwork vest, signs, cones, and high-level warning signs shall be provided when it is necessary to control normal vehicular traffic due to vehicles, such as end-dumps, entering or leaving the site.
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9.18.3 Fire Safety Hot work shall not be conducted unless all requirements of Shaw HS 314 have been met.
Cold cutting of USTs to facilitate cleaning shall only be performed under direct supervision of a qualified person.
Equipment on-site shall be bonded and grounded, spark-proof, and explosion resistant, as appropriate. Particular attention to bonding/grounding shall be made during transfer of flammable/combustible liquids into vacuum trucks and when ventilation equipment is utilized.
A fire extinguisher with a minimum rating of 10-BC shall be strategically located in the area of active work.
No smoking shall be allowed in the work area.
9.18.4 Underground Storage Tank Decontamination Underground storage tanks that have been removed, but not cleaned, are considered hazardous waste. These tanks must be transported in accordance with Department of Transportation HAZMAT packaging and shipping requirements, including manifesting, and taken to a permitted hazardous waste disposal site.
Minimum decontamination procedures that shall be performed to allow transportation of removed tanks under a bill of lading, disposal at a nonhazardous waste facility, or tank demolition for scrap include:
• Removal of all residual liquid material, followed by triple rinsing with an appropriate cleaning solution to remove remaining sludge and/or scale from the interior surfaces of the tank.
• Routine tank testing to determine the effectiveness of the cleansing, flushing and rinsing procedure. Tanks that have contained flammable or combustible liquids shall be checked with a combustible gas indicator. Readings shall not exceed 10% LEL.
• A physical examination of the tank interior to confirm that the rinsing process has removed all residual material. When triple rinsing is not sufficient to remove all sludge or scale, tanks shall be entered per Shaw HS 300 so that personnel can physically scrape or effectively pressure-wash interior surfaces.
• The proper handling and disposal of all rinsate or residual material which is considered to be hazardous waste, unless an analysis of the material's hazardous constituents does not warrant this action.
• An awareness that tank cleaning may not remove all flammable substances in the tank, such as those that have absorbed to or penetrated walls of a container, or those that are retained in seams located at the junction of walls and ends of tanks.
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Low readings on a combustible gas indicator do not assure that explosive conditions will not occur later under conditions that promote vaporization of such residues.
The purging of flammable vapors within the tank, prior to transportation from a site, to levels that preclude potential explosive atmospheres, or such lower levels as may be required by the local agency. A standard method of tank purging, once all liquids have been removed, is placement of one and one-half (1½) pounds of dry ice (carbon dioxide) per one hundred (100) gal of tank liquid capacity while simultaneously sealing all tank openings except the vent(s). Nitrogen gas or other methods listed in the American Petroleum Institute 1604, Removal and Disposal of Used Underground Petroleum Storage Tanks, may also be used to purge tanks.
9.18.5 Underground Storage Tank Removal After the tank has been freed of vapors and before it is removed from the excavation, plug or cap all accessible holes. One plug should have a 1/8-in. vent hole to prevent the tank from being subjected to excessive differential pressure caused by temperature changes. The tank should always be positioned with this vent plug on top of the tank during subsequent transport and storage.
Tank removal will proceed as follows:
• Excavate around the tank to uncover it for removal
• Remove the tank from the excavation and place it on a level surface
• Use wood blocks to prevent movement of the tank after removal and prior to loading on a truck for transportation
• Use screwed (boiler) plugs to plug any corrosion holes in the tank shell.
Tank closure projects involving trenching or excavating 4 ft or greater are subject to the requirements of Shaw HS 307.
Tanks should be removed from the site as promptly as possible after vapor-freeing procedures have been completed, preferably on the day of tank removal from the excavation. If a tank remains at the site overnight or longer, additional vapor may be released from any liquid absorbed in the tank walls or residues remaining in the tank. Before the tank is removed from the site, the tank atmosphere should be checked with a combustible gas indicator to ensure that it does not exceed 10% of the lower flammable limit.
The tank should be secured on a truck for transportation to the storage or disposal site with the 1/8-in. vent hole located at the uppermost point on the tank. Tanks should be transported in accordance with all applicable local, state, and federal regulations.
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9.18.6 Air Monitoring Should chemical contaminants be present in a UST or surrounding soil, a qualified person shall conduct air monitoring for combustible or oxygen deficient environments, or specific toxic constituents. Operations associated with UST closure that may require air monitoring includes:
• Excavation of soil
• Hot work or cold cutting
• Storage tank cleaning and purging
• Confined space entry
• Tank certification prior to removal from site.
Additional tests shall be selected and performed to the satisfaction of the qualified person based on the recommendations of the SSHO. All tests shall be repeated as often as necessary to assure safety since changing conditions may result in varying atmospheric contaminant concentrations.
All work activity is prohibited in atmospheres where tests indicate that the concentration of flammable vapors is greater than 10% of the LEL, or the concentration of oxygen is less than 20% or greater than 23.5%. Positive steps, such as ventilation, shall be taken to establish acceptable atmospheric conditions prior to resumption of operations.
If tests indicate the presence of toxic contaminants in concentrations at or above the permissible explosive, work in such an atmosphere will proceed only when PPE appropriate for the specific contaminants is provided to all affected personnel, based on recommendations of the SSHO.
9.19 Drilling Operations Standard operating procedure Shaw HS 316 establishes the general requirements for the operation of mobile drilling equipment.
A brief summary is provided below:
• Equipment should be inspected daily to ensure that there are no operational problems.
• Before leaving the controls, shift the transmission controlling the rotary drive into neutral and place the feed level in neutral. Before leaving the vicinity of the drill, shut down the drill engine.
• Do not drive the drill rig from hole with the mast in the raised position.
• Before raising the mast, look up to check for overhead obstructions.
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• Before the mast of a drill rig is raised and drilling is begun, the drill rig must first be leveled and stabilized with leveling jacks and/or cribbing. Re-level the drill rig if it settles after initial set up. Lower the mast only when the leveling jacks are down, and do not raise the leveling jack pads until the mast is lowered completely.
• Employees involved in the operation shall not wear any loose fitting clothing that could get caught in any exposed moving machinery.
• Use a long handled shovel to clear cuttings from the auger. Do not remove soil cuttings from the drill auger while the auger is rotating.
• Means (augur guard, barricade or electronic brake activated by a presence sensing device) shall be provided to guard against employee contact with the auger (USACE, 2004).
• Throwing or dropping tools is not permitted. Carefully pass tools by hand between personnel or use a hoist line.
• During freezing weather, do not touch any metal parts of the drill rig with exposed flesh. Freezing of moist skin to metal can occur almost instantaneously.
• Adequately cover or protect (i.e., grate) all boreholes during the placement of PVC casing to prevent drill rig personnel from stepping or falling into the hole. Cover, protect, or backfill all open boreholes according to engineering specifications upon completion of the well.
• Never allow "horsing around" within the vicinity of the drill rig and tool and supply storage areas – even when the drill rig is shut down.
• Due to splash potential, safety glasses shall also be worn during drilling and well installation.
• While drilling, all nonessential personnel shall remain at a distance which is past the radius of the boom, whenever possible. Workers (drillers, hydrogeologists, etc.) remaining around the drill rig shall be kept to a minimum.
• The area shall be roped off, marked or posted, to keep the area clear of pedestrian traffic or spectators.
• All personnel should be instructed in the use of the emergency kill switch on the drill rig.
• Personnel working in close proximity to the drill rig shall wear steel-toed shoes, hearing protection, and hard hats.
• Elevated superstructures (e.g., drill rigs, cranes) shall remain a distance of 10 ft away from utility lines and 20 ft away from power lines.
• A copy of the manufacturer’s operating manual shall be available at the job site.
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9.20 Groundwater Treatment System Operation and Maintenance Operation of the OU1, OU2, and 2/12 groundwater treatment systems includes various activities that will provide continuous system operations at designed capacities. Some of these activities include electrical and mechanical inspections of systems and components, filter cleaning or replacement, flow monitoring, carbon replacement, periodic component repair, completion of appropriate maintenance and monitoring documentation, and system sampling. Detailed operation and maintenance procedures and health and safety are presented in the Work Plan, Operable Unit 1, Operable Unit 2, Sites 2/12 Groundwater Treatment System, Former Fort Ord, California (IT, 2000a).
9.21 Operable Unit 2 Landfills Operations and Maintenance Operation and maintenance of the LFG extraction and treatment system includes activities that will ensure continuous system operations at designed capacities. Some of these activities include electrical and mechanical inspections of systems and components, GAC/ KMnO4 replacement, flow monitoring, periodic component repair, completion of appropriate maintenance and monitoring documentation, and system sampling.
Post-closure activities associated with the OU2 Landfills include inspection and maintenance of the final landfill cover, drainage and erosion control, survey monuments, and settlement plates.
Detailed operation and maintenance procedures and health and safety are presented in the Post- Closure Operations and Maintenance Plan, Areas B through F, Operable Unit 2 Landfills Remedial Action, Fort Ord, California (IT, 2000b).
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10.0 Site Control
This section presents site control measures to prevent entry of unauthorized personnel into potentially dangerous or hazardous working areas within the site. Only authorized personnel will be allowed access to the site.
Contamination control zones will also be established around the hazardous-area perimeter, to reduce migration of contaminants into clean areas, to prevent access or exposure to hazardous conditions by unauthorized persons, and to prevent authorized project personnel from entering areas that have not been cleared for military munitions.
Site security will also be provided to prevent the entry of unauthorized personnel into the site.
10.1 Contamination Control Zones
The primary purposes for contamination control zones are to establish the hazardous-area perimeter, to reduce migration of contaminants into clean areas, and to prevent access or exposure to hazardous conditions by unauthorized persons. At the end of each workday, the entire site will be secured to prevent unauthorized entry. Site work zones will include the SZ, CRZ, EZ and emergency entry and exit.
10.1.1 Support Zone The uncontaminated SZ, or clean zone, will be the area outside the EZ and CRZ and within the geographic perimeters of the site. The area is used for staging of materials, parking of vehicles, office facilities, sanitation facilities, and receipt of deliveries. Personnel entering this zone may include delivery personnel, visitors, security guards, etc., who will not necessarily be permitted in the EZ. All personnel arriving in the SZ will, upon arrival, report to the site office and sign the site visitor log.
10.1.2 Contamination Reduction Zone Personnel and equipment decontamination will be performed in the CRZ that is adjacent to the EZ. This is the contamination reduction corridor (CRC) and decontamination. All personnel entering or leaving the EZ will pass through this area in order to prevent any cross-contamination and for the purpose of accountability. Personal protective outer garments and respiratory protection will be removed in the CRZ and properly labeled. All water generated from equipment and personal decontamination will be contained on site and disposed of in an appropriate manner.
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10.1.3 Exclusion Zone The EZ is the area where contamination does or could occur during site activities. This zone has the highest potential for exposure to contamination by contact, ingestion, or inhalation. All employees will use proper PPE when working in these areas. The location of the EZ will be identified by fencing or other appropriate means. An entry log is kept daily which records the time of entry and exit from the EZ for each person.
10.1.4 Emergency Entry and Exit Contamination control zones, evacuation routes, and emergency equipment locations will be included on a site map prior to the initiation of on-site activities. During an emergency, the evacuation routes noted on the site map should be followed. If conditions such as wind direction or physical hazards do not allow access to the prescribed evacuation routes, evacuate by the safest means available and decontaminate to the greatest extent possible. Additional emergency procedures can be found in Section 12.0.
10.1.5 Entry Requirements In order to allow an individual into potentially contaminated areas of the site, the (CRZ and EZ), the following requirements must be met:
• Documentation of completing training requirements as described in Section 4.0 (including review of this SSHP and signing off as such)
• Documentation of completing medical-surveillance requirements as described in Section 6.0
• Respiratory fit testing as necessary (Section 5.1)
• A hazard briefing that includes current operations at the site, hazards that exist, and control measures to follow
• Signing the site entry log, upon both entry and exit from a CRZ.
10.1.6 Communications Two-way radios will be provided to on-site field personnel during this project. Cellular telephones will also be available.
10.2 Perimeter Postings Appropriate warning signs will be strategically placed where people enter the EZ and CRZ.
"DANGER – AUTHORIZED PERSONNEL ONLY. PERSONAL PROTECTIVE EQUIPMENT REQUIRED BEYOND THIS POINT."
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Signs may be more hazard-specific as necessary. Additional signs may be posted at the perimeter of the site to alert passersby of potential dangers.
An OSHA 2203 Job Safety and Health Protection poster along with all other California OSHA, Department of Labor and Proposition 65 warning and notification posters will be clearly displayed in both the Shaw administration and employee break trailers. In addition, each site where an employee is potentially exposed to lead above the PEL will be posted per the requirements of the Lead Hazard Compliance and Management Plan (Appendix A). Details regarding CRZs and decontamination will be detailed in the appropriate compliance program for that task and contaminant.
10.3 Security This section describes the procedures for controlling access by personnel and vehicles into potentially dangerous or hazardous working areas within the site. Security fencing, lighting, and warning signs will control access to each area. Entrance to each area will be restricted to specific points that will be controlled and monitored by project personnel. Only project personnel, subcontractor personnel, and authorized visitors with proper identification will be allowed access to the site. A UXO escort will always accompany non-UXO personnel.
Security measures described in the following sections include:
• Security operations • General security • Site-specific areas
10.3.1 Security Operations The primary mission of security operations is the control of personnel and vehicles entering and leaving the sites. Control will be provided by security fencing or barricade tape installed around each site, depending on site-specific conditions, with specific points established to gain access to the sites. As work progresses, portable fencing will be relocated, as required. Access gates (when applicable) will be locked when unattended.
The integrity of the fencing will be checked on a regular basis. Necessary repairs will be noted in the safety log and immediately reported to the Superintendent, who will assign repair responsibilities.
Project personnel will conduct periodic patrols around and through the sites. Personnel on patrol will remain in radio contact with the administration trailer.
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10.3.2 General Security Security operations will include:
• Maintaining a visitor log at the project reception desk and work sites.
• Escorting visitors to the site(s) by project personnel. Visitors will receive an abbreviated site orientation briefing in accordance with this SSHP.
• Contracting with a security service to patrol the sites during off work hours and weekends.
• Notifying local law enforcement in the event of vandalism, trespassing, or breaking and entering. It is not intended that project personnel assume a confrontational role.
• Site facilities containing items of value, or which are subject to vandalism will remain locked when unoccupied.
A key cabinet will be located at the project offices and will contain master keys (and spares) for on-site locks. A key log identifying personnel and the keys specifically issued will be implemented and maintained. Key control will be the responsibility of the Project Administrator.
10.3.3 Site-Specific Areas The site security for the removal sites will consist of one or all of the following measures:
• Fencing (chainlink, safety, or barbed wire) will be installed to prevent public access to the sites.
• Materials and supplies will be placed in locked boxes within a fenced yard.
• Plastic barrier fence, steel posts, or fencing will be installed to segregate areas of work activity.
• Signs stating "Authorized Personnel Only" will be installed around areas of work activity.
• Warning signs will be erected at specific areas to provide warning of hazardous conditions in accordance with the requirements of this SSHP.
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11.0 Personnel and Equipment Decontamination
In general, everything that enters an EZ at a site must be either decontaminated or properly discarded upon exit from an EZ. All personnel must enter and exit an EZ through a CRZ. Before moving an EZ, heavy equipment will be decontaminated and inspected before it is moved into the SZ. This inspection shall be noted in the daily log.
11.1 Personnel Decontamination Shaw will establish personnel decontamination facilities on site to ensure that personnel maintain a high degree of personal hygiene and minimize the possibility of exposure to chemical hazards. These personnel hygiene facilities will conform to the requirements specified in Title 29 CFR 1926.65. A personnel decontamination area will be established immediately outside the EZ at the CRC, in the CRZ to facilitate contamination and PPE removal. All personnel exiting the EZ will pass through the decontamination area to remove gross contamination. Standard decontamination procedures are as follows.
Decontamination Procedures Level D-Modified The following decontamination procedures shall be followed for Level-D Modified PPE:
• Step into first washtub and wash PVC boots with soap solution and scrub brush. • Step into second washtub and rinse boots with clean water and scrub brush. • Remove outer work gloves. • Remove outer Tyvek™ coveralls and dispose in the proper receptacle. • Remove PVC boots and place in boot rack. • Remove inner (nitrile) gloves and dispose in the proper receptacle. • Wash hands and face before eating, drinking, or smoking (break or end of shift). • Redress in street clothes and leave site.
Decontamination Procedures Level C/B PPE The following decontamination procedures shall be followed for Level-C/B PPE:
• Step into first washtub and wash PVC boots with soap solution and scrub brush.
• Step into second washtub, rinse boots with clean water, and scrub brush.
• Untape boots, gloves, and respirator.
• Remove PVC boots and place in the boot rack.
• Remove outer work gloves.
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• Remove Level-B PPE airline/self-contained breathing apparatus ensemble (if applicable)
• Remove Tyvek™ coveralls and dispose in the proper receptacle.
• Remove APR, if applicable, and place on hanger if on break, or on the table at the end of the shift.
• Remove inner latex/nitrile gloves and dispose in the proper receptacle.
• Wash hands and face before eating, drinking, or smoking (break).
• Remove underclothing and socks (end of shift).
• Proceed to shower (end of shift).
• Redress in street clothes and leave site.
Personnel utilizing Level-C and -B PPE are required to shower completely (including washing of hair) before changing into street clothes at the end of the work shift and before leaving the site. The SSHO will also determine if personnel wearing Level-D Modified PPE will be required to shower. This decision will be based on the potential for PPE breakthrough to have occurred and other subjective information. Personnel are required to wash hands, face, and other exposed skin areas before leaving the CRZ for breaks or lunch. Towels, washcloths, soap, and shampoo will be provided to personnel. Work clothes will be left in the shower/change facility. With the exception of work within the SZ, no work clothing, shoes, or boots will be worn off or carried out of the project area. Nondisposable soiled work clothes will be laundered on site or taken to an appropriate laundry service. Inner protective clothing and towels will be laundered utilizing soap and chlorine bleach. Boots, gloves, and respirators will be decontaminated before entering the SZ.
11.2 Equipment Decontamination Assume that any item or vehicle taken into an EZ must be contaminated thus carefully inspected and/or decontaminated before leaving that particular EZ. A visual inspection of the frame and tires of all vehicles and equipment leaving an EZ will be completed. In order for a vehicle or equipment to pass inspection, it must be in a broom-clean condition, water washed, and free of loose dirt or sludge material on tailgates, axles, wheels and bucket.
The equipment decontamination area will be used to remove soil from all equipment leaving the work area. Decontamination procedures will consist of washing equipment to remove mud and/or dirt. Personnel who must come in contact with equipment during vehicle maintenance and repair will utilize a special “clean area”. All equipment requiring maintenance or repair will be staged in a CRZ before servicing. A typical decontamination plan is shown in Figure 11-1.
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Personnel assigned to vehicle decontamination will wear the protective equipment, clothing, and respiratory protection consistent with this SSHP. Seats and flooring in equipment and vehicles that are to be used in the EZ will be covered to the greatest extent possible with disposable polyethylene.
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12.0 Emergency Response Plan and Contingency Procedures
Site personnel must be prepared to respond and act quickly in the event of an emergency or accidental contaminant release. Emergency preparedness and response procedures will aid in protecting site workers and the surrounding environment.
This Emergency Response Plan, as required by Title 29 CFR 1910.120, addresses the following elements:
• Pre-emergency planning and procedures for reporting incidents to appropriate government agencies for potential chemical exposure, personal injuries, fire/explosions, environmental spills and releases, discovery of radioactive materials
• Personnel roles, lines of authority, communications
• Posted instructions and list of emergency contacts: physician, notified nearby medical facility, fire and police departments, ambulance service, state/local/federal agencies, CIH, and Contracting Officer
• Emergency recognition and prevention
• Site topography, layout and prevailing weather conditions
• Criteria and procedures for site evacuation, emergency alerting procedures/employee alarm system, emergency PPE and equipment, safe distance, place of refuge, evacuation routes, site security and control
• Specific procedures for decontamination and medical treatment of injured personnel
• Route maps to nearest pre-notified medical facility
• Criteria for initiating community alert program, contacts and follow-up
12.1 Pre-Emergency Planning During the development of the AHAs included in this SSHP, potential health and safety hazards associated with the conduct of site activities were identified. Once identified, these hazards were assessed to determine the risk that these hazards could result in an emergency situation. Contingency plans for responding to the potential emergency situations have been developed and are included in this SSHP.
Shaw has gathered information/phone numbers of the local and site emergency response authorities. The authorities will be contacted and informed of the nature of the site activities to be performed under this SSHP, and the potential hazards that the conduct of these activities pose to investigation personnel, the environment and the general public.
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Preplanning measures include employee training, fire and explosion prevention and protection, chemical spill and discharge prevention and protection, and safe work practices to avoid personal injury or exposure. The following sections provide general procedures to be followed. Specific procedures will be identified in the site-specific work plan.
12.2 Personnel Roles/Lines of Authority The roles and responsibilities of Shaw personnel for response to emergencies at the former Fort Ord will be clearly defined and coordinated with Shaw subcontractors, Army project personnel, and a Fire Department emergency response team. The responding Fire Department (911) will evaluate the emergency situation and make the determination whether to involve the HAZMAT Unit in the response. The responsibilities of specific project individuals and the coordination of the responding Fire Department are defined as follows.
Superintendent. At all times during scheduled work activities, the Superintendent or alternate shall be present on site. This individual will be responsible for implementing emergency procedures and determining appropriate response actions. Depending on the circumstances and time permitting, the Superintendent will review proposed response actions with the SSHO and the Army site representative. Specific responsibilities for the Superintendent include:
• Evaluating and assessing emergency incidents or situations
• Assigning personnel and coordinating response activities on site
• Assuring that field personnel are aware of the potential hazards associated with the site
• Summoning a Fire Department emergency response team
• Notifying the Project Manager or, in his absence, the Program Manager of an emergency situation
• Coordinating response to an incident with the Army site representative
• Assuring that all Shaw emergency equipment is routinely inspected and functional
• Working with the SSHO regarding the correction of any work practices or conditions that may result in injury to personnel or exposure to hazardous substances
• Assuring that appropriate emergency response agencies are aware of the provisions made herein
• Evaluating the safety of site personnel in the event of an emergency, and providing evacuation coordination if necessary
• Maintaining site facilities and assisting site personnel in accessing those facilities.
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The Superintendent will direct all emergency response activities conducted or managed by Shaw and is responsible for field implementation and enforcement of health and safety policies and procedures. The Superintendent will be fully trained in health and safety procedures and maintain current certification in standard first aid and CPR. Other responsibilities include overall supervision and management of field activities.
Site Safety and Health Officer. The SSHO is responsible for implementing, communicating, and enforcing health and safety policies and procedures during the course of the project and shall be present on site during scheduled work. The SSHO will review the fitness and training records of all field personnel for compliance with the established requirements and will assist in arranging proper training and medical examinations. He will also assist in evaluating health and safety concerns with respect to environmental releases and emergency response actions and has authority to take action providing a safe work place to employees and subcontractors during such events.
SUXOS. The SUXOS will direct all MMR emergency actions including HTRW sites.
UXO Safety Officer. The UXOSO will assist the SUXOS and SSHO in evaluating heath and safety concerns with respect to MMR emergency actions including HTRW sites.
Project Manager. The Project Manager will provide support to emergency responders and dedicate appropriate project resources to the response effort. If required, the Project Manager will mobilize additional personnel and equipment to the site. The Project Manager will notify and provide the Army site representative with recommendations concerning any additional action(s) to be taken.
12.3 List of Emergency Contacts and Notifications The Superintendent, Project Manager, and SSHO will be notified immediately in the event of an emergency. The Superintendent will immediately evaluate the incident and, if necessary, notify a Fire Department (911) emergency support service. If not previously notified, the Project Manager, Army site representative, and designated environmental contact will be advised of the situation. Telephone numbers for emergency contact personnel are listed in Table 12-1. The list will be maintained with current contacts, and telephone numbers will be posted along with other emergency phone numbers at all telephone locations at the site.
The information provided to the notified person should include the nature of the incident and the exact location and the suspected contaminants or material involved. Information regarding the incident that should be reported to the emergency operator includes the following:
• Name and telephone number of the individual reporting the incident
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• Location and type of incident • Nature of the incident (fire, explosion, spill, or release) and substances involved • Number and nature of medical injuries • Movement or direction of spill/vapor/smoke • Response actions currently in progress • Estimate of quantity of any released materials • Status of incident • Other pertinent information.
A complete incident report shall be completed by the SSHO and provided to the Army representative once the urgency of the emergency incident has been resolved.
12.4 Advance Notifications Advance notifications will be made before any extraordinary activity, such as chemical handling or shipment, deep excavations, road closures, or hauling of contaminated materials on public roads. These notifications include:
• Notification to the TERC Community Relations Manager, who will determine the need for notification to the general public.
• Notification to the former Fort Ord Fire Department for any activity where there is a potential need for rescue personnel.
• Notification to agencies and organizations potentially affected by road closures or detours. The list of notifications will be identified in the site-specific work plan.
Attention will be paid to the potential impacts of activities on nearby residences, businesses, and especially schools. To the extent possible, traffic will be routed to avoid schools. As necessary, work may be conducted when schools or other businesses are closed.
12.5 Emergency Recognition and Prevention All site employees will be trained on the potential sources of emergencies for the site, and how to recognize emergency conditions. This training will include recognition of signs of an unplanned release (i.e., odors, visual indications, instrument readings, etc.).
12.6 Site Topography, Layout, and Prevailing Weather Conditions Generally, the site topography and layout will not affect emergency response actions except at Site 39, which is highly vegetated and may affect access in the event of an emergency.
The area's climate is characterized by warm, dry summers and cool, rainy winters. The Pacific Ocean is the principal influence on the climate at former Fort Ord, causing fog and onshore winds that moderate temperature extreme. Daily ambient air temperatures typically range from
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40 to 70ºF, but temperatures in the low 100 °F have occurred. Thick fog is common in the morning throughout the year. Winds are generally from the west.
The average annual rainfall of 14 in. occurs almost entirely between November and April. Because the predominant soil is permeable sand, runoff is limited and stream flow only occurs intermittently and within the very steep canyons in the eastern portion of former Fort Ord.
12.7 Medical Emergency Response In the event of severe physical or chemical injury, local Fire Department emergency response personnel shall be summoned for emergency medical treatment and ambulance service. Their response time is estimated to be less than 10 minutes upon initial notification.
Be prepared to provide the following information to the operator:
• Caller’s name • Injured persons name • What happened? • What s the problem? • Current treatment being given • Location of accident • Location and name of person meeting the ambulance • Phone number of contact person
The responding Fire Department emergency medical responders will be utilized to provide care to severely injured personnel. Once the emergency medical technicians make an initial assessment, the decision on using ground or air transportation for the victims will be made. Qualified first-aid/CPR providers will treat minor injuries on site and if additional treatment beyond first aid is required, the injured personnel will be transported to the Monterey Bay Urgent Care or Community Hospital of Monterey Peninsula. The Community Hospital of Monterey Peninsula can provide 24-hour emergency medical care along with the services of a critical care center. Transportation routes and maps shall be posted in the project office and in each site vehicle prior to the initiation of on-site activities. A copy of this map is provided as Figure 12-1.
12.8 Personal Exposure or Injury Every precaution will be taken to aid in the prevention of injuries and/or exposure to contaminants. These precautions are detailed in this SSHP and generally consist of the following measures:
• Personnel will be properly trained for their work duties
• Site personnel will wear appropriate PPE for each specific task or work assignment
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• Site personnel will follow the proper field safety protocols as defined
• Site controls will be enforced so that only authorized personnel are able to access the work zones
• Site personnel will be made aware of potential environmental and chemical hazards
• Real-time air monitoring will be performed to evaluate the effectiveness of engineering controls and levels of personal protection
• Proper decontamination procedures will be followed for personnel and equipment.
In the event of personal exposure to contaminants, the following general guidelines will be adhered to:
• Contact/Absorption − Copious amounts of potable water will be used to flush, for at least 15 minutes, contaminants from the skin. This activity will occur in the on-site shower trailer. Start flushing while removing contaminated clothing. If irritation persists, repeat flushing. The condition of the individual will be assessed and transport to a medical center arranged if necessary. Do not transport victim unless the recommended flushing period is completed or flushing can be continued during transport.
• Inhalation − The victim will be moved immediately to an area providing fresh air. Decontamination of the victim and artificial respiration will be provided if necessary. The condition of the individual will be assessed and transport to a medical center arranged if necessary.
• Ingestion − Immediately contact local poison control center. The victim will be decontaminated, if necessary, and transported to a medical facility.
12.9 Chemical Warfare Agents Chemical Agent Identification Sets have been found at the former Fort Ord. It is not anticipated that any chemical warfare material (CWM) will be encountered at future work sites. If there is suspect CWM, all personnel will immediately move upwind and away from the presumed source. The discoverer will immediately notify the SSHO who will in turn notify the UXOSO. At this point, the UXOSO will take over and implement the requirements for CWM presented in the BOEWP (IT, 2001).
12.10 Fire Control In the event or imminent danger of a fire or explosion, all activities shall halt, and a local Fire Department (911) shall be notified immediately. If it is safe to do so, site personnel may use fire-fighting equipment available on site to remove and isolate flammable or other HAZMAT that may contribute to the fire.
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Upon arrival of the local Fire Department emergency responders, the Superintendent and/or SSHO will advise the fire chief or lead representative of the location, nature, and identification of the HAZMAT on site, as well as any other specific hazards inherent to the site.
The following measures will be implemented during site-field activities to minimize the risk of fire and/or explosion:
• Smoking is permitted onsite only in the designated smoke area.
• Good housekeeping procedures will be required on site.
• Material storage methods will be in accordance with manufacturers' recommendations.
• Flammable liquids will be stored in approved containers and cabinets only.
• Trained personnel shall conduct all storage, handling, or use of flammable and combustible materials.
• Entry and exit pathways shall be kept clear of debris or obstacles.
• Work areas will be cleared of excess vegetation and obstructions.
Any base-specific guidelines established by the Army will be strictly enforced. Any fire, no matter how small, must be reported to the former Fort Ord Fire Department chief or designated official.
12.11 Spills or Leaks Shaw will maintain the following equipment and materials in the SZ for use during spill response activities:
• Overpacks for drums • Absorbent pads • Granular absorbent material (noncombustible) • Polyethylene sheeting • 55-gal drums • Shovels and assorted hand tools • Drum liners • Citrikleen™ (or equivalent) • Air horn • Appropriate PPE for chemicals in use or likely to be encountered.
If a hazardous waste spill or material release to the air, soil, or water at the site is observed, Shaw will immediately notify the Army site representative and the former Fort Ord Fire Department. An assessment will be made of the magnitude and potential impact of the release. If it is safe to
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do so, site personnel will attempt to locate the source of the release, prevent further release, and contain the spilled and/or affected materials as follows:
• The spill or release area will be approached cautiously. Real-time air monitoring will be continuously performed in the spill vicinity.
• Hazards will be identified based on available information from witnesses or material identification documents (placards, MSDSs and logs). The potential hazards will be evaluated to determine the proper personal protection levels, methods, and equipment necessary for response.
• If necessary, the release area will be evacuated, isolated, and secured.
• If possible, spill containment will initially be made without entering the immediate hazard area.
• Entry to the release area will be made with the PPE, personnel, methods, and equipment necessary to perform the work. Hazardous spill containment and collection will be performed in four steps as follows: – Contain the spill with absorbent socks, booms, granules, or construction of temporary dikes. – Control the spill at the source by plugging leaks, uprighting containers, overpacking containers, or transferring contents of a leaking container. – Collect the spilled material with shovels or heavy equipment as necessary. – Store the spilled material for further treatment or disposal. Treatment and/or disposal options of the material will depend on the amount and type of material.
If site personnel cannot safely and sufficiently respond to an environmental release, evacuation of the area may be warranted. The decision to evacuate will depend on the risk of exposure to SZ personnel and the severity of the release. The responding Fire Department will be notified in the event of a significant spill. Upon their arrival at the site, the Superintendent will brief them on the current situation at hand and any potential hazards the team may be faced with.
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12.12 Safety Signals While working in the EZ, the following hand signals will be used for communication when necessary.
Hand Signal Meaning Arms crossed over head Shut-off equipment Hand gripping throat Out of air/can not breath Wave hand over head Need assistance Thumbs up OK, I’m all right, I understand Thumbs down No, negative
Vehicle or portable air horns will be used for alarm signals as follows:
• One long blast: Emergency evacuation of EZ • Two short blasts: Clear working area around powered or moving equipment.
12.13 Site Evacuation Procedures The authority to order personnel to evacuate the area rests with the Superintendent or SSHO who would advise the other as soon as possible. In the event that site evacuation is required, a continuous, uninterrupted air horn will be sounded for approximately ten seconds. Air horns will be located in the site administration office, shower trailer, and active work area. Radio communication may also be used to alert site workers and provide special instructions. Evacuations may or may not be limited to specific EZ or site area.
Personnel working in the EZ or CRZ will immediately make their way to the administrative trailer for a "head count." Depending on the severity of the event and allowable time, personnel exiting the EZ and CRZ may be instructed to forgo or modify decontamination procedures.
Personnel in the SZ will immediately report to the designate assembly point for a "head count" and further instructions. The Superintendent and the SSHO will remain in contact to ensure that evacuation procedures are properly executed. If the administration support trailer is inaccessible, personnel shall evacuate to an upwind location as determined by the windsock and perform a "head count."
Situations requiring evacuation may include unusually severe weather conditions, fires, or significant chemical spills or releases. In the event of project evacuation, the Army site representative, Fire Department (911), and Police Department (911) will be notified immediately. A site emergency map that delineates evacuation routes, emergency air horn
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locations, first-aid kit locations, rally point, and site-contamination control-zone perimeters will be developed once an on-site evaluation of conditions and topography is complete.
12.14 Emergency Equipment The team support vehicle is designated as an emergency vehicle. All emergency equipment will be maintained in proper working order and inspected by the UXOSO to ensure completeness and proper working order. The results of the inspection will be documented in the safety log. In the event that any of the disposable items are used, the UXOSO will ensure they are replaced immediately. The emergency equipment listed in Table 12-2 will be available on-site.
12.15 Emergency Decontamination Procedures Treatment of illnesses or injuries to personnel working within the contaminated areas of the site may be more difficult because of protective clothing requirements and the potential for exposure to the contaminants. The SSHO or Emergency Medical Care Provider must quickly assess the extent of the injury or illness of the victim. A determination will be made if lifesaving medical treatment is critical and if personal decontamination procedures will create additional injuries or aggravate the existing condition. Life-threatening injuries must receive immediate medical attention. Decontamination procedures may be modified, simplified, or eliminated completely under such circumstances.
The following guidelines are established for responding to minor emergencies when an individual may have been injured or overcome by exposure to a hazardous substance at the site. If a truly serious injury exists, only portions of these guidelines may be appropriate to ensure prompt medical treatment.
• Notify supervisory and safety personnel, and verify that the area is safe to remain.
• Select an emergency decontamination location upwind and/or uphill from any spills, and determine the most effective pathway to emergency vehicles.
• Field decontamination should be performed in two stages: washing with soapy water, followed by a clear water rinse.
• Upon arrival at the injured party, stabilize any life-threatening problems, such as spills or fires, and remove (i.e., brush or blot with absorbency pads) visible, gross contamination. If possible, prevent coming in contact with any contamination present at the scene. However, do not delay with this task, and be prepared to transport immediately to the decontamination area.
• Have support personnel perform real-time air monitoring.
• Determine type, nature, and extent of exposure or injury based on mechanism.
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• Quickly cut or tear first layer of protective clothing (outer suit) off the injured party and discard. If cutting, always cut away from the body toward the extremities to avoid inflicting further injury.
• Without delay, efficiently move the injured away from the accident scene, possible contamination, or any hazardous substances. Relocate to a nearby "clean" area to expedite removal of respiratory protection and establish communication.
• If the individual is unconscious, evaluate if an adequate airway exists and breathing and circulation are present. If absent, commence rescue breathing or CPR without delay.
• Move the injured to the decontamination area and transfer responsibilities to support personnel.
• Using soapy solution, support personnel should carefully wash outer garments as needed and rinse.
• Spray outer protective clothing with clear water.
• Quickly remove tape from the injured’s wrists and ankles; assume the individual is injured until an assessment indicates otherwise.
• Carefully, but quickly, cut the second layer of protective clothing (inner suit, boots, and gloves) off the injured party. Always cut away from the body toward the extremities to avoid inflicting further injury.
• Be prepared to turn emergency care over to Emergency Medical Service personnel. Otherwise, administer appropriate standard first aid to injuries.
• Following stabilization of any injuries, monitor and be on the alert for shock, wrap the injured in a warm blanket or other items to conserve body heat, and be prepared for vomiting.
• Cover any contact surfaces of transport equipment with a protective sheet or plastic.
• Inform all arriving personnel and transport crew of nature and extent of injuries and any potential hazards present.
12.16 Adverse Weather Conditions Adverse weather can take many forms. Thunder and lightning storms, earthquakes, hail, high winds, and tornados are a few examples. Sudden changes in the weather, extreme weather conditions, and natural disasters can create a number of subsequent hazards. Generally, poor working conditions arise, and slip, trip, and fall hazards exist. Natural disasters can create many secondary hazards, such as release of HAZMAT to the environment, structure failure, and fires.
Routinely monitoring weather conditions and reports may help reduce the impact of severe weather and natural disasters. It may be necessary to halt certain hazardous operations or stop
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work altogether to allow the situation to pass. The SSHO must decide what operations, if any, are safe to perform based on existing conditions and anticipated conditions.
The best protection against most severe weather episodes is to avoid potential exposure. This avoidance means seeking shelter before the storm hits. Stay away from pipes and electrical equipment should lightning be a threat, and watch for damage caused by lightning strikes nearby.
12.17 Earthquakes The following general guidelines will be adhered to in the event of an earthquake:
• If you are indoors duck or drop down to the floor. Take cover under a sturdy desk, table, or other furniture. Hold on to it and be prepared to move with it. Hold the position until the ground stops shaking and it is safe to move. Stay clear of windows, fireplaces, and heavy furniture or appliances. Do not rush outside. Falling glass or building parts may injure you. Do not try using the stairs or elevators while the building is shaking or while there is danger of being hit by falling glass or debris.
• If you are outside, get into the open, away from buildings and power lines.
• If you are driving; stop if it is safe, but stay inside. Do not stop on or under a bridge, overpass, or tunnel. Move your car as far out of the normal traffic pattern as possible. Do not stop under trees, light posts, electrical power lines, or signs.
12.18 Community Alert In the event of an emergency that would require evacuation of the local community, the USACE and the Base Realignment and Closure Transition Office will coordinate notifications as necessary.
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13.0 Record Keeping and Data Management
Proper record keeping and data management are essential in the implementation of this SSHP. The forms associated with the record keeping and data management requirements must be completed in an accurate, timely fashion and filed with the appropriate entities. It is the responsibility of the SSHO to ensure that the forms are properly completed. Completed forms will be kept and maintained by Shaw. These records shall be maintained for a 5-year period. Subcontractors will also be responsible for keeping a copy of the forms pertaining to their personnel.
13.1 Logs The SSHO will maintain and complete a daily log for each day's work. The daily log will document chronologically each day's health and safety activities in sufficient detail for future reference as needed. Other relevant data and field information will be recorded on separate log forms for air monitoring, sampling, equipment calibration inspections, and incident reporting.
An EZ sign-in log will be maintained that will provide a project record of the following information for each work shift's activities:
• Worker's name • Work area • Duties performed • Level of protection • Time in/time out.
All personnel will be required to log in and out of the EZ.
A visitors’ sign-in log will be maintained in the project office and administration area. Visitors requesting access to hazardous field activities must have appropriate project approval, be medically qualified, and have the health and safety training prerequisites for hazardous waste operations.
An OSHA 2203 Job Safety and Health Protection poster will be clearly displayed in the site administration trailer.
13.2 Safety Inspections Shaw HS 021 establishes the requirements for safety inspections. These inspections are an integral part of the overall accident prevention program and help demonstrate management’s commitment to safety.
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Safety reviews and inspections are conducted by all tiers of the management structure and are documented. A list of all corrective action items will be maintained showing the corrective action, responsible person, and the date action is to be completed. Health and safety personnel will conduct follow-up inspections to ensure that corrective actions or measures were implemented.
The Superintendent and Project Manager will both inspect the site at least monthly and interview one or two site workers regarding areas of safety concerns or ideas for safety improvement. Site supervisory personnel will inspect site conditions and activities daily to identify changing conditions or potential hazards. Identified safety and health issues and deficiencies, and the actions, timetable, and responsibility for correcting the deficiencies, shall be recorded in inspection reports (Form 13-1). Identified safety and occupational health deficiencies and suggested corrective measures will be brought to the attention of the Superintendent and SSHO. Safety review inspections will be recorded and filed for reference by project management and Army personnel. A safety and health deficiency tracking log will be posted on the project safety bulletin board to monitor the status of safety and health deficiencies (Form 13-2).
13.3 Accident Reporting, Investigation, and Review Shaw HS 020 that prescribes the requirements for incident reporting, investigation, and review is presented in Appendix B. All project personnel are required to immediately report to their direct supervisor all occupational injuries, illnesses, accidents and near miss incidents having the potential for injury. Any supervisor (but preferably the supervisor directly responsible for the involved employees) with first-hand knowledge of an incident is required to:
• Immediately arrange for appropriate medical attention and notify the responsible health and safety representative.
• Inform Health Resources of all incidents requiring medical attention by calling (800) 350-4511, and provide the following information: – Company Name – Employee Name – Name of treating medical facility and phone number – Brief description of incident.
• Health Resource’s role is to interface with the treating physician to ensure that appropriate care is provided to the injured employee.
• Complete required forms for all cases requiring medical attention.
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All injuries, illnesses, accidents, and near miss incidents will be investigated. Once arrangement for medical care have been made, the employee’s direct supervisor, with assistance from the health and safety representative and/or business line HS staff will:
• Reconstruct (NEVER RE-ENACT) the condition that led to the incident (collect facts)
• Describe and document (include sketch, photos, etc.) how the incident occurred
• List witnesses and collect written statements when possible
• Identify and discuss the causative factors
• Identify the unsafe act or unsafe condition that contributed to the incident
• Identify possible systematic/management deficiencies
• List the corrective actions, which are to be taken to prevent re-occurrence of the incident, the person responsible for the corrective action, and the date by which action is to be completed.
The investigation will be started as soon as possible after the incident and a written report submitted to the appropriate health and safety representative within 72 hours. In addition to the previous information, reports from external sources (police, insurance carriers, testing laboratories, etc.) are to be obtained as soon as they become available and forwarded to the recipients of the investigation report.
Each manager whose project/location experiences an OSHA recordable or a chargeable vehicle accident is required to convene an Accident Review Board within 10 days of the accident. The purpose of the Accident Review Board is to review the information gathered for each incident and takes appropriate action to prevent its recurrence. The Accident Review Board shall be composed of the project/location manager, the employee’s direct supervisor, a health and safety representative, and the employee(s) involved in the incident. When appropriate, a representative of other internal sources of expertise should be involved.
If all relevant facts about the incident are not available (e.g., police reports, investigations by clients), and the Accident Review Board will not be held within 10 days, the Accident Review Board may be delayed until necessary information becomes available.
The health and safety representative will serve as the chair of the Accident Review Board, and will distribute supporting information to all members of the Board before or at the time the Board is convened.
It is generally not acceptable to discipline an employee for having an accident. However, if the Accident Review Board determines that the accident resulted from an unsafe act or violation of
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company procedure on the employee’s part, the employee should be subject to disciplinary action in accordance with company’s progressive disciplinary action system (see Human Resources Procedure HR207).
The employee’s supervisor (at the time of the incident) and the responsible project or location manager will implement the corrective actions specified by the Accident Review Board. The Review Board’s action will be documented on the Accident Review Board report.
Detailed requirements, instructions and forms are included in Appendix B.
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14.0 References
U.S. Department of the Army (Army), 1994, Record of Decision, Operable Unit 2 Landfills, Fort Ord, California, Fort Ord, CA
Army, 1997, Record of Decision, Basewide Remedial Investigation Sites, Fort Ord, California, Fort Ord, CA
Dames & Moore, 1993, Final Remedial Investigation Report, Fort Ord Landfills, Fort Ord, California. [Prepared for U.S. Army Corps of Engineers, Fort Ord, CA.]
Harding Lawson Associates, 1995, Basewide Remedial Investigation/Feasibility Study, Fort Ord, California, Novato, CA. [Prepared for U.S. Army Corps of Engineers, Fort Ord, CA.]
IT Corporation (IT), 1998, Site Safety and Health Plan Fort Ord Remedial Action, Former Fort Ord, California, Fort Ord, California, Revision 5
IT, 2000a, Work Plan, Operable Unit 1, Operable Unit 2, Sites 2/12 Groundwater Treatment System, Former Fort Ord, California)
IT, 2000b, Post-Closure Operations and Maintenance Plan, Areas B through F, Operable Unit 2 Landfills Remedial Action, Fort Ord, California
IT, 2001, Basewide Ordnance and Explosives Work Plan, Former Fort Ord, California, Concord, California
Shaw, 2003, Site Safety and Health Plan Fort Ord Remedial Action, Former Fort Ord, California, Fort Ord, California, Revision 7
U.S. Army Corps of Engineers (USACE, 2003), Engineer Manual 385-1-1, Safety and Health Requirements Manual
USACE, 2004, Engineer Pamphlet 75-1-2, Munitions and Explosives of Concern (MEC) Support During Hazardous, Toxic, and Radioactive Waste (HTRW) and Construction Activities
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