REMEDIAL ACTION PLAN
Moen Incorporated 2609 Cox Mill Road Sanford, NC
Prepared for:
Moen Incorporated 2609 Cox Mill Road Sanford, NC
Prepared by:
GROUNDWATER & ENVIRONMENTAL SERVICES, INC. Exchange Alley Building 23 South 13th Street, Suite 103 Richmond, Virginia 23219
July 2011
TABLE OF CONTENTS
1.0 INTRODUCTION...... 1 2.0 SUMMARY OF REMEDIAL INVESTIGATION RESULTS...... 3 2.1 PHASE I REMEDIAL INVESTIGATION...... 3 2.1.1 Methodology ...... 4 2.1.2 Results...... 4 2.2 PHASE II REMEDIAL INVESTIGATION ...... 5 2.2.1 Methodology ...... 5 2.2.2 Results...... 7 3.0 REMEDIAL ACTION OBJECTIVES ...... 11 3.1 SOIL REMEDIATION...... 11 3.1.1 Constituents of Concern...... 11 3.1.2 Soil Remediation Goals...... 13 3.2 GROUNDWATER REMEDIATION...... 13 3.2.1 Constituents of Concern...... 14 3.2.2 Groundwater Remediation Goals ...... 15 4.0 FEASIBILITY STUDY ...... 16 4.1 POTENTIALLY APPLICABLE SOIL TECHNOLOGIES – VOCS ...... 16 4.1.1 Chemical Oxidation ...... 17 4.1.2 Soil Excavation ...... 18 4.1.3 Soil Vapor Extraction ...... 19 4.1.4 No Active Remediation...... 21 4.2 POTENTIALLY APPLICABLE SOIL TECHNOLOGIES – METALS ...... 21 4.2.1 Institutional Controls...... 21 4.2.2 Adjustment of Health-Based Soil Remediation Goals ...... 23 4.2.3 No Remedial Action ...... 24 4.3 POTENTIALLY APPLICABLE GROUNDWATER TECHNOLOGIES - VOCS ...... 25 4.3.1 In Situ Chemical Oxidation...... 25 4.3.2 Enhanced Bioremediation...... 27 4.3.3 Monitored Natural Attenuation...... 29 4.3.4 No Active Remediation...... 30 4.4 POTENTIALLY APPLICABLE GROUNDWATER TECHNOLOGIES - METALS...... 30 5.0 PROPOSED REMEDY...... 33 5.1 CHEMICAL OXIDATION IN SOIL...... 33 5.1.1 Principle of Operation ...... 33 5.1.2 Waste Determination ...... 34 5.1.3 Conceptual Design...... 34 5.1.4 Justification of Proposed Remedy...... 36 5.2 CHEMICAL OXIDATION IN GROUNDWATER ...... 37 5.2.1 Principle of Operation ...... 37 5.2.2 Conceptual Design...... 37
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5.2.3 Justification of Proposed Remedy...... 38 5.2.4 Institutional Controls...... 38 6.0 DESCRIPTION OF ACTIVITIES AND PROCEDURES ...... 39 6.1 REMEDIAL DESIGN SOIL BORING INSTALLATION, AND SOIL SAMPLE COLLECTION AND ANALYSIS ...... 39 6.1.1 Soil Boring Installation...... 39 6.1.2 Soil Sample Collection and Analysis ...... 40 6.2 REMEDIAL PERFORMANCE MONITORING WELL INSTALLATION, AND GROUNDWATER SAMPLE COLLECTION AND ANALYSIS...... 41 6.2.1 Well Installation, Construction, and Development...... 41 6.2.2 Groundwater Sample Collection and Analysis...... 42 6.3 CONFIRMATION SOIL BORING INSTALLATION, AND SOIL SAMPLE COLLECTION AND ANALYSIS ...... 44 6.4 MANAGEMENT OF REMEDIAL ACTION-DERIVED WASTES ...... 44 6.5 EQUIPMENT AND PERSONNEL DECONTAMINATION PROCEDURES ...... 45 7.0 DESCRIPTION OF PROPOSED TREATABILITY STUDIES...... 47 7.1 FIELD PILOT/TREATABILITY TESTS...... 47 7.2 LABORATORY TREATABILITY TESTS...... 47 8.0 PROPOSED CRITERIA FOR REMEDIAL ACTION COMPLETION ...... 50 8.1 POST-REMEDIATION CONFIRMATION SOIL SAMPLING ...... 50 8.2 BASELINE GROUNDWATER MONITORING...... 50 8.3 POST-REMEDIATION GROUNDWATER MONITORING ...... 50 8.4 EVALUATION OF REMEDY PERFORMANCE ...... 51 8.5 REPORTING OF PERFORMANCE EVALUATION RESULTS...... 51 8.5.1 Pre-Construction Reports ...... 52 8.5.2 Construction Completion Report ...... 53 8.5.3 Remedial Action Completion Report ...... 53 8.5.4 Periodic Progress Reports...... 54 9.0 SCHEDULE...... 55
LIST OF TABLES
Table 1 – Soil Remedial Technology Evaluation Table Table 2 – Groundwater Remedial Technology Evaluation Table Table 3 – Remedial Design Soil Sample Collection and Analytical Matrix Table 4 – Baseline Groundwater Sample Collection Matrix Table 5 – Quarterly Groundwater Sample Collection Matrix Table 6 – Semi-Annual Groundwater Sample Collection Matrix Table 7 – Annual Groundwater Sample Collection Matrix Table 8 – Remedial Confirmation Soil Sample Collection and Analytical Matrix
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LIST OF FIGURES
Figure 1 – Local Area Map Figure 2 – Proposed Soil and Groundwater Injection Plan – AOC-16C Figure 3 – Proposed Soil and Groundwater Injection Plan – AOC-13 Figure 4 – Proposed Remedial Design Soil Boring Location Map Figure 5 – Proposed Performance Monitoring Well Location Map
LIST OF ATTACHMENTS
Attachment A – Certification Statements Attachment B – Site-Specific Health and Safety Plan Attachment C – Belfor Environmental Constructability Report Attachment D – NCDENR Electronic Mail dated 24 May 2011 Attachment E – In Situ Chemical Oxidation Health and Safety Plan Addendum Attachment F – Tentative Remedial Action Schedule
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1.0 INTRODUCTION
This Remedial Action Plan (RAP) is herein submitted to the North Carolina Department of Environment and Natural Resources (NCDENR) – Registered Environmental Consultant (REC) Program for the Moen Incorporated (Moen) facility located at 2609 Cox Mill Road in Sanford, North Carolina. The Moen facility, which is referred to interchangeably as “the site” within this RAP, is approximately 38.3-acres in size, located along Cox Mill Road, and is situated in a mixed commercial, industrial, and residential area (see Figure 1).
As detailed in Section .0306(l) of the Registered Environmental Consultant Program Implementation Guidance, this RAP is required to: ensure that the Registered Site Manager (RSM) prepares a feasibility study to evaluate remedial alternatives; confirm that the selected remedy is supported by the feasibility study; and provide a statute-required opportunity for public comment on the proposed remedy. Moen contracted Groundwater & Environmental Services, Inc. (GES) as the REC to prepare the RAP, which is written in a style that is understandable to the general public. The RAP, which is focused on remediation of soil and groundwater impacts underlying the three (3) primary volatile organic compound (VOC) source areas, includes the following:
A summary of Remedial Investigation (RI) results for soil and groundwater, as reported in the Phase I Remedial Investigation Report dated January 2010 and the Final Remedial Investigation Report dated June 2011;
A description of Remedial Action objectives, which includes a summary of areas of concern (AOCs) to be remediated, affected media, identified contaminants of concern (COCs), and remedial design goals (including preliminary remediation goals);
A Feasibility Study, which identifies/screens at least three (3) potentially applicable technologies (or combinations of technologies) for soil and groundwater, and presents a detailed, comparative, ranked (in order of preference) analysis of each remedial alternative;
A preliminary design of the proposed remedy(ies), which includes a description of the principle of operation of the technology (or combination of technologies), pre-design schematic drawings of all major components of the remedy, and off-site treatment/disposal details (as applicable);
Justification for the proposed remedy(ies) using the eight (8) feasibility study criteria provided in Section .0306(l)(3)(A) through (H) of the Registered Environmental Consultant Program Implementation Guidance;
A description of all activities and procedures necessary to implement the proposed Remedial Action in compliance with applicable laws and regulations, and in a manner that cleanup standards are met;
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A description of proposed field pilot/treatability tests and laboratory treatability studies, and additional site characterization needed to support the final design;
A work plan for post-remediation confirmation monitoring to evaluate remedial performance, which shall be reported in periodic remedial progress reports and in a Remedial Action Completion Report(s);
A tentative Remedial Action schedule; and
A health and safety plan (HASP), which aims to ensure the health and safety of all persons on- and off-site (including surrounding community) from exposure to site COCs and the Remedial Action itself.
Where appropriate, the RAP has also been prepared in accordance with Section 5.2 of the Inactive Hazardous Sites Branch Guidelines for Assessment and Cleanup dated August 2010.
As required in 15A NCAC 13C .0306(b), this RAP has been properly certified. Specifically, the Remediating Party Certification Statement (.0306(b)(2)) and Registered Site Manager Certification Statement (.0306(b)(1)) are included in Attachment A as required by Section .0306(b)(5) of the Registered Environmental Consultant Program Implementation Guidance. The Work Phase Completion Form No. WPC-III will be submitted at the conclusion of the RAP public notice period and after receiving authorization from REC Program staff.
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2.0 SUMMARY OF REMEDIAL INVESTIGATION RESULTS
Twenty-four (24) AOCs were identified at the site based upon historical analytical results from previous environmental assessments conducted at the site (see Attachment O to the Phase I Remedial Investigation Work Plan) and site inspection results (see Attachment G of the Phase I Remedial Investigation Work Plan). Of these, the number of AOCs was reduced by five (5) within the Phase I Remedial Investigation Work Plan given review of historical documentation and no reported releases. The AOCs were defined within Section 5.2 and Table 9 of the Phase I Remedial Investigation Work Plan. Suspected COCs, as defined within Section 5.1 of the Phase I Remedial Investigation Work Plan, included historically-used solvents (e.g., chlorinated ethanes, chlorinated ethenes, and methylene chloride), brass components (e.g., copper, lead, and zinc), electroplating compounds (e.g., cyanide and chromium), non-UST petroleum constituents, and polychlorinated biphenyls (PCBs).
Field activities associated with implementation of the Phase I Remedial Investigation Work Plan were conducted from March to July 2009, and reported within the Phase I Remedial Investigation Report. Based on Phase I RI results, a Phase II Remedial Investigation Work Plan was submitted to the REC Program in February 2010. During the Phase II RI, four (4) Addenda to the Phase II Remedial Investigation Work Plan were submitted. Phase II RI field activities were conducted at the site from February 2010 to April 2011, and reported within the Final Remedial Investigation Report. Further details regarding the RI at the site are included in the following subsections.
Note that this document focuses on soil and groundwater impacts; sediment/surface water data and the need for remediation of these media are not discussed herein. In the areas to be remediated, sub-slab vapor and indoor air concentrations of target COCs are expected to decrease accordingly. Sediment and surface water analytical results are not discussed herein and will be detailed in a separate RAP.
2.1 Phase I Remedial Investigation
As detailed in Section 1.0 of the Phase I Remedial Investigation Work Plan, the objectives of the Phase I RI were to:
Identify releases of hazardous substances to the environment;
Identify potential exposure pathways;
Characterize the chemical nature of releases; and
Collect sufficient sampling data to support a cleanup-level determination.
Further information is provided within the following subsections regarding the methods of investigation and results for soil and groundwater during the Phase I RI.
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2.1.1 Methodology
The following methods of investigation were utilized as part of the Phase I RI:
A soil sample collection event was conducted at the site from March to April 2009 for the purpose of identifying potential impacts above preliminary soil remediation goals (PSRGs) at the nineteen (19) AOCs outlined in Section 5.2 of the Phase I Remedial Investigation Work Plan. Boring locations were biased based on soil analytical results obtained from historical environmental investigation reports (see Attachment O of the Phase I Remedial Investigation Work Plan). Soil samples were collected from potential surface and subsurface releases, and shipped on ice to Pace Analytical Laboratories, Inc. of Huntersville, North Carolina (Certification no. 12) for analysis in accordance with Appendix A to the Registered Environmental Consultant Program Implementation Guidance.
Eight (8) new well nests (i.e., MW-22 through MW-29) were installed from 06 to 26 May 2009 within the facility to provide a detailed characterization of the subsurface lithology inside the facility and to facilitate the monitoring of individual hydrostratigraphic units. Subsequently, a groundwater sample collection event was conducted (for both new and existing wells) from 01 to 07 June 2009 for the purpose of providing a comprehensive and synoptic snapshot of groundwater impacts at the site. Groundwater samples were collected with a Grundfos® RediFlo2® electronic submersible pump, a peristaltic pump, or polypropylene-high-density polyethylene (PP-HDPE) bailer, and shipped to Pace Analytical Laboratories, Inc. for analysis in accordance with Appendix A of the Registered Environmental Consultant Program Implementation Guidance.
Data validation was conducted on subsets of soil and groundwater analytical results.
2.1.2 Results
The following summarizes the primary areas where COCs were detected above preliminary soil and groundwater remediation goals.
Three (3) primary chlorinated solvent source areas were identified within the unsaturated soil zone underlying the Facility at AOC-13 (Former Brite Dip Pit), AOC-16C (Former Parts Degreaser) within the former Tool Room (Cafeteria), and AOC-21 (Former Cast Bar Department). AOC-13 was characterized by exceedances of the Protection of Groundwater PSRGs for 1,1-dichloroethene (DCE), 1,1-dichloroethane (DCA), and methylene chloride. Similarly, AOC-16C was characterized by 1,1-DCE, 1,2-DCA, and 1,4-dioxane in excess of Protection of Groundwater PSRGs.
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Conversely, AOC-21 was impacted by trichloroethene (TCE) and vinyl chloride in excess of Protection of Groundwater PSRGs.
Four (4) metals (e.g., arsenic, cadmium, mercury, and manganese) were detected in soil at concentrations above their average background concentration, and exceeding either the Preliminary Health-Based PSRG or Protection of Groundwater PSRGs (see Section 8.1.3 of the Phase I Remedial Investigation Report).
Groundwater analytical results from wells installed underlying the facility indicated that the greatest groundwater impacts existed within the sand channel unit directly beneath the three (3) primary source areas indentified within the unsaturated soil zone, and did not extend into the deeper quartz gravel or saprolitic hydrostratigraphic units. Downgradient, groundwater analytical results indicated that the downgradient contaminant plume, which consisted primarily of chlorinated solvents (e.g., 1,1-DCE and TCE), was primarily confined to shallow alluvial hydrostratigraphic units (e.g., sand channel) underlying the site. In addition, based upon hydraulic heads gauged, the potential existed for all groundwater impacts to discharge ultimately into the unnamed stream, which runs along the eastern property boundary.
2.2 Phase II Remedial Investigation
As detailed in Section 8.1 of the Phase I Remedial Investigation Report, the number of AOCs was further reduced by six (6). As detailed in Section 1.3 of the Phase II Remedial Investigation Work Plan, the objectives of the Phase II RI were to:
Delineate the areal and vertical extent of soil impacts (within the primary VOC source areas) and groundwater impacts to below preliminary remediation goals;
Collect sufficient soil and groundwater data to support a cleanup-level determination; and
Sufficiently characterize the site conditions in order to conduct a feasibility study of applicable remedial alternatives and to support a proposed remedy(ies).
Addenda Nos. 001 to 003 to the Phase II Remedial Investigation Work Plan were submitted to address data gaps observed in soil and groundwater analytical data collected to date. Further information is provided within the following subsections regarding the methods of investigation and results for soil and groundwater during the Phase II RI.
2.2.1 Methodology
The following methods of investigation were utilized as part of the Phase II RI:
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In accordance with Section A.2.2 of Appendix A of the Registered Environmental Consultant Implementation Guidance, a membrane interface probe (MIP) investigation (i.e., a semi-quantitative field screening method) was conducted from 15 to 23 February 2010 to pinpoint the locations of the three (3) primary source areas and evaluate the lateral and vertical extent of VOC impacts. MIP profiling was conducted at thirty-eight (38) boring locations including twelve (12) within AOC-13, nine (9) within AOC-21, and seventeen (17) in AOC- 16C.
Following the MIP investigation, confirmation soil borings were installed in February 2009 within the three (3) MIP survey grids, and focused on areas exhibiting the greatest electron capture detector (ECD) and flame ionization detector (FID) responses, and at the periphery of the impacts. A total of eighty-seven (87) soil samples were collected from twenty-five (25) soil borings installed, and shipped to TestAmerica Laboratories, Inc. of Nashville, Tennessee (Certification no. 387) for analyses in accordance with Appendix A to the Registered Environmental Consultant Program Implementation Guidance. Soil samples were also collected from select Phase I RI soil borings to evaluate the leachability of isolated exceedances of Protection of Groundwater SRGs.
In accordance with Section A.2.2 of Appendix A to the Registered Environmental Consultant Program Implementation Guidance and the Phase II Remedial Investigation Work Plan – Addendum No. 002, a soil gas survey was conducted from 19 to 21 February 2011 to identify the potential TCE source in soil in or around AOC-21 (Former Cast Bar Department). A total of fifty-four (54) soil gas samples were collected from points installed and screened under the concrete slab. Subsequently, from 24 to 28 January 2011, nine (9) soil borings were installed within and along the periphery of the soil gas survey grid, and a soil sample collection event was conducted to confirm soil gas survey results. Additional soil samples were collected from borings installed within AOC-13 (Former Brite Dip Pit) and AOC-16C (Former Parts Degreaser) to further delineate 1,4-dioxane impacts in soil, in AOC-24 (Former Bag House Fire) to identify potential metal impacts, and at various locations to speciate prior detections of total chromium above the average background concentration.
Nine (9) new monitoring wells (i.e., MW-30 through MW-38) were installed at the site from 02 to 21 March 2010, which included three (3) locations inside the Main facility and six (6) locations outside of the Facility. Subsequently, groundwater samples were collected from 29 March to 08 April 2010 at the nine (9) new nested wells, two (2) existing wells within the Main Facility (i.e., MW-22D and MW-24D), and well MW-18 along the southern site boundary. Groundwater samples were shipped on ice to TestAmerica Laboratories, Inc. for analyses in
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accordance with Appendix A of the Registered Environmental Consultant Program Implementation Guidance. The purpose of the groundwater sample collection event, which was combined with Phase I RI groundwater analytical results, was to provide a comprehensive and synoptic snapshot of groundwater impacts at the site, facilitate a detailed characterization of the subsurface lithology inside and outside of the facility, and to facilitate monitoring of individual hydrostratigraphic units. In accordance with the Phase II Remedial Investigation Work Plan – Addendum No. 002, from 18 to 19 January 2011, groundwater samples were collected from select wells along the property line to confirm the absence of 1,4-dioxane and/or metals at concentrations exceeding groundwater remediation goals. Additional groundwater samples were collected within and surrounding the Facility to speciate chromium. Further groundwater samples were collected on 17 March 2011 from wells MW-22I and MW-36S to confirm conflicting analytical results for total and hexavalent chromium in accordance with the Phase II Remedial Investigation Work Plan – Addendum No. 003.
Off-site activities were conducted in accordance with the Phase II Remedial Investigation Work Plan – Addendum No. 001 dated 24 June 2010, which included potable well and/or tap sample collection activities at four (4) off-site parcels, proper abandonment of five (5) off-site potential water-supply wells located on parcels adjacent to the site from 30 June to 01 July 2010 in accordance with 15A NCAC 02C .0113, installation/construction of two (2) off-site sentinel wells (i.e., MW-39 and MW-40) from 28 to 30 June 2010 in accordance with 15A NCAC 02C .0108, off-site groundwater sample collection to confirm the absence of VOC concentrations above groundwater remediation goals downgradient of the site, and connection of two (2) properties to municipal water provided by the City of Sanford Public Works Department. All aqueous samples were collected, shipped on ice to Pace Analytical Services, Inc. of Huntersville, NC (Certification no. 12), and analyzed for VOCs via US EPA SW846 method 8260B.
2.2.2 Results
The following summarizes the delineation of soil and groundwater impacts.
As detailed in Section 3.6 of the Final Remedial Investigation Report, the following results were obtained in the three (3) primary VOC source areas.
o In AOC-13 (Former Brite Dip Pit), during the MIP investigation, FID results were observed to be greatest near the location of the former brite dip pit and AOC-16B (former Parts Degreaser), and extended from 5- to 15-feet beneath land surface (bls). Combined with the Phase I RI data, the Phase II RI data identified that
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chlorinated ethane daughter product impacts were greatest at the location of the former Brite Dip pit. 1,1-DCE impacts were greatest in soil borings AOC13-SB01 (0.27 milligrams per kilogram (mg/kg) from 5- to 6-feet bls) and AOC13-SB07 (0.18 mg/kg from 6.5- to 7.5-feet bls), were distributed from approximately 5- to 7.5 feet bls above the water table, and extended to soil boring AOC21-SB03 to the south. Exceedances for chlorinated ethane daughter products 1,1-DCA and 1,2-DCA were consistent with those of 1,1-DCE. In AOC21-SB03, 1,4- dioxane was detected at a maximum concentration of 4.45 mg/kg. Chlorinated ethane daughter product and 1,4-dioxane exceedances in AOC-13 (Former Brite Dip Pit) were volumetrically delineated. o In AOC-16C (Former Parts Degreaser), during the MIP investigation, the greatest ECD responses in AOC-16C extended spatially from the northwest corner (at a depth of 5 feet bls) to the eastern corner of the cafeteria (between 10- to 20-feet bls). During the Phase II RI, a maximum concentration of 1,1,1-TCA of 1.89 mg/kg was detected in soil boring AOC16C-SB07 positioned in the northeastern corner of the former Tool Room (Cafeteria). Similarly, within the same boring, 1,4-dioxane was detected at a maximum concentration of 9.16 mg/kg. Combined with the Phase I RI data, the Phase II RI dated identified that chlorinated ethane daughter product impacts extended to the east towards boring AOC19-SB01, and were greatest in soil borings AOC16C-SB01 and AOC16C-SB05. Chlorinated ethane and 1,4-dioxane impacts in AOC-16C (Former Parts Degreaser) were delineated. o During the MIP investigation near AOC-21 (Former Cast Bar Department), the greatest ECD responses were observed at MIP point B29, which is located northwest of soil boring AOC21-SB01 installed during the Phase I RI, and distributed between 10- to 15- feet bls (within the fluctuation range of the water table). Results of the MIP investigation and subsequent confirmation soil sample collection event indicated that a potential source of TCE existed around MIP point B29 and was distributed at depths greater than 10 feet bls. Combined with Phase I RI data, Phase II RI soil analytical results yielded maximum TCE concentrations ranging from 0.0545- to 0.0756-mg/kg in soil borings AOC21-SB01, AOC21-SB05, and AOC21-SB06. These TCE concentrations were located at or near the water table, and were believed to be responsible for the magnitude of TCE detected within downgradient well MW-28S. The subsequent soil gas survey revealed that the largest TCE concentrations (in soil gas) were detected upgradient and to the northwest of AOC-21. Confirmation soil analytical results confirmed that TCE impacts
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(maximum concentration of 0.94 mg/kg) existed in soil near soil gas point SG-55, which was characterized by TCE at 200,500 micrograms per cubic meter (µg/m3), and were distributed from 8- to 11-feet bls. TCE concentrations in this area were the greatest detected to date at the site, and more than an order of magnitude greater than that observed in and around AOC-21. However, the location of major equipment (e.g., screw machines, an electroplater) within the area prohibited further delineation of the identified TCE source area. Further installation of remedial design soil borings to refine the spatial distribution of TCE is proposed for this area in Section 5.1.3 below.
As detailed in Section 4.4 of the Final Remedial Investigation Report, Phase II RI analytical data for metals was combined with that obtained during the Phase I RI, and the following metals were identified at concentrations exceeding soil remediation goals.
o Arsenic was detected in twenty (20) soil borings at concentrations exceeding the Preliminary Health Based PSRG and average background concentration. Lesser number of locations exhibited mercury, manganese, and hexavalent chromium concentrations above their respective Preliminary Health-Based PSRGS and/or average background concentrations. No further delineation as part of the RI was recommended.
o Arsenic was detected in six (6) soil borings at concentrations exceeding the Protection of Groundwater PSRG, the Preliminary Health-Based PSRG, and average background concentration. Similarly, manganese was detected in nine (9) soil borings at concentrations exceeding the Protection of Groundwater PSRG and average background concentration. A localized Protection of Groundwater exceedance was observed in AOC-16C for cadmium. No further delineation as part of the RI was recommended.
Groundwater analytical results from the Phase II RI, in combination with the Phase I RI data, identified the following.
o New wells MW-33 confirmed the groundwater and contaminant migration pathway from nested well MW-22 in the Cafeteria (former Tool Room) to downgradient wells MW-9, MW-9I, and MW-21D in AOC-9A (Loading Docks). Similarly, well MW-34 confirmed the groundwater and contaminant migration pathway from well MW-28 (in the Molding Department) to downgradient wells MW-9, MW-9I, and MW-21D in AOC-9A. At AOC-9A, contaminant plumes comingle and are transported within the shallow hydrostratigraphic units towards the unnamed creek.
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o Along the southwestern property line, metal concentrations (beryllium, chromium, lead, manganese, and/or nickel) in exceedance of groundwater remediation goals and the average background concentration were detected in new wells MW-31S, MW-31D, MW-32S, and MW-32D. Additional collection of filtered samples from MW-31D and MW-32D indicated that exceedances for lead and chromium were due to turbidity. Tetrachloroethene (PCE) was also detected in well MW-32S at a concentration slightly greater than the groundwater remediation goal. As part of the Phase II Remedial Investigation Work Plan – Addendum No. 002, confirmation samples were collected from wells MW-31S (for nickel), MW-31D (for beryllium, total and hexavalent chromium, lead, and manganese), and MW-32S and MW-32D (for total and hexavalent chromium, and manganese). Only manganese, which was believed to be a result of intrinsic redox conditions, was observed to exceed the groundwater remediation goal. Within the property boundaries, localized exceedances of groundwater remediation goals were observed for arsenic, beryllium, cadmium, total and hexavalent chromium, copper, lead, manganese, nickel, and zinc. No further delineation was recommended as part of the RI. o In existing well MW-18, which is located along the southern property line, 1,1-DCE was detected at a concentration of 78 µg/L exceeding the groundwater remediation goal. 1,4-dioxane was detected in well MW-18 at a concentration less than the groundwater remediation goal. No VOCs were detected further downgradient, in off-site wells MW-39 and MW-40, at concentrations exceeding their groundwater remediation goals.
Validated tentatively-identified compounds (TICs) observed in soil and groundwater during the RI, as described in Section 10.3 of the Final Remedial Investigation Report, were determined to be innocuous and/or co-located with COCs that will be remediated. As such, validated TICs will be addressed in conjunction with the proposed remedial approach herein. No additional remediation of TICs is necessary as part of the RAP.
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3.0 REMEDIAL ACTION OBJECTIVES
The affected media to be remediated includes soil and groundwater. Further details are provided in the following subsections regarding AOCs to be remediated, COCs detected, and remedial design goals.
All remediation detailed below will be conducted in accordance with a site-specific HASP, which is included herein as Attachment B. Implementation of the HASP during Remedial Action will help ensure that:
The Health and Safety of all persons on- and off-site will not be adversely affected by the proposed remedial activities;
The surrounding community is protected from exposure to site-specific COCs; and
All Local, State, and Federal regulations regarding Health and Safety are conformed/adhered to.
3.1 Soil Remediation
The primary objective of proposed soil remediation is abatement of chlorinated solvent mass located within the vadose zone. The areas targeted for remediation have the greatest potential for COCs (e.g., chlorinated ethenes, chlorinated ethanes, and 1,4- dioxane) to leach and contribute to groundwater remediation goal exceedances. No volatile COCs were observed to exceed their respective Preliminary Health-Based PSRGs. Thus, the long-term goal for VOC impacts in the vadose zone is treatment to concentrations that are less than Protection of Groundwater PSRGs, and that minimize leach-based migration between the vadose zone and the underlying hydrostratigraphic units.
In the following subsections, further details are provided regarding COCs to be remediated in AOC-13 (Former Brite Dip Pit), AOC-16C (Former Parts Degreaser) in the former Tool Room (current cafeteria), and upgradient of AOC-21 (Former Cast Bar Department), and their respective remedial design goals. For metals detected during the RI across the site, and in exceedance of Preliminary Health-Based PSRGs (i.e., arsenic, mercury, hexavalent chromium, and manganese) and/or Protection of Groundwater PSRGs (i.e., arsenic, cadmium, and manganese); further discussion is included in Section 4.2.
3.1.1 Constituents of Concern
The following subsections summarize COCs to be remediated in soil, which were delineated as part of the RI.
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3.1.1.1 AOC-13 (Former Brite Dip Pit)
COCs to be remediated within AOC-13 (Former Brite Dip Pit) include the following:
Chlorinated ethane daughter products, 1,1-dichloroethane (DCA) and 1,1-dichloroethene (DCE), which were detected at maximum concentrations of 0.57- and 0.27-mg/kg in soil boring AOC13- SB01 from 5- to 6-feet bls, and at 0.365- and 0.118-mg/kg in soil boring AOC13-SB07 from 6.5- to 7.5-feet bls, respectively;
1,4-dioxane, which was detected at maximum concentrations of 4.45- and 0.183-mg/kg in soil borings AOC13-SB01 and AOC21- SB03, respectively; and
COCs including 1,2-DCA, TCE, and vinyl chloride detected in soil boring AOC13-SB07 at maximum concentrations of 0.00721-, 0.0636-, and 0.00275-mg/kg, respectively.
3.1.1.2 AOC-16C (Former Parts Degreaser)
COCs to be remediated within AOC-16C (Former Parts Degreaser) within the former Tool Room (current cafeteria) include the following:
Chlorinated ethane parent compound, 1,1,1-trichloroethane (TCA), which was detected at a maximum concentration of 1.89-mg/kg in soil boring AOC16C-SB07 advanced within the northwest corner of the cafeteria;
Chlorinated ethane daughter products (i.e., 1,1-DCA, 1,2-DCA, and 1,1-DCE), which were detected at maximum concentrations within soil borings AOC16C-SB01 and AOC16C-SB05; and
1,4-dioxane, which was detected in soil boring AOC16C-SB07 at a maximum concentration of 9.16 mg/kg.
3.1.1.3 Upgradient of AOC-21 (Former Cast Bar Department)
COCs to be remediated upgradient of AOC-21 (Former Cast Bar Department) include:
Maximum TCE concentrations detected in soil borings SGS-SB01 (0.19 mg/kg), SGS-SB03 (0.34 mg/kg), and SGS-SB01-B (0.94 mg/kg);
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Low concentrations of PCE detected at maximum concentrations of 0.013- and 0.023-mg/kg in soil borings SGS-SB02 and SGS- SB07, respectively; and
Maximum detections of 1,4-dioxane within soil borings AOC21- SB05 (0.0387 mg/kg), SGS-SB01 (0.035 mg/kg), SGS-SB01B (0.049 mg/kg), and SGS-SB04 (0.065 mg/kg).
No remediation is proposed for boring TCE and vinyl chloride Protection of Groundwater exceedances in borings AOC21-SB01, AOC21-SB05, and AOC21-SB06, which were detected at the water table (around 10 feet bls). These exceedances were likely a result of groundwater fluctuation.
3.1.2 Soil Remediation Goals
Remedial design goals for each of the above VOCs are derived from Inactive Hazardous Sites Branch Soil Remediation Goals (SRG) February 2011 and include:
Preliminary Health-Based Soil PSRGs in accordance with Section D.2.1.1.1 of the Registered Environmental Consultant Program Implementation Guidance; and
Protection of Groundwater SRGs in accordance with Section D.2.1.2 of the Registered Environmental Consultant Program Implementation Guidance.
The Preliminary Health-Based PSRGs assume an unrestricted land use for each environmental medium.
3.2 Groundwater Remediation
The three (3) primary objectives of proposed groundwater remediation include the following:
Reduction of contaminant mass within the dissolved and adsorbed phases (and free phase if present);
Reduction/elimination of mass flux in groundwater to concentrations below the natural assimilative capacity of the aquifer; and
Production of safe end products including carbon dioxide and water (from VOC degradation).
In the following subsections, further details are provided regarding COCs to be remediated in groundwater underlying AOC-13 (Former Brite Dip Pit), AOC-16C
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(Former Parts Degreaser) in the former Tool Room (current cafeteria), and AOC-21 (Former Cast Bar Department), and their respective remedial design goals.
3.2.1 Constituents of Concern
The following subsections summarize COCs to be remediated in groundwater, which were delineated as part of RI.
3.2.1.1 AOC-13 (Former Brite Dip Pit)
Target COCs to be remediated in sand channel (Zone 1B) underlying AOC-13 (Former Brite Dip Pit) include the following:
1,1,2-TCA and daughter products 1,1-DCE, 1,1-DCA, and 1,2- DCA;
1,4-dioxane; and
Lesser concentrations of chlorinated ethenes (TCE and daughter products cis 1,2-DCE and vinyl chloride).
Localized metals including beryllium, cadmium, total and hexavalent chromium, copper, lead, manganese, nickel, and zinc were detected in wells IW-2 and MW-26S at concentrations above their groundwater remediation goals and average background concentrations. These impacts will be evaluated for Remedial Action following completion of VOC Remedial Action.
3.2.1.2 AOC-16C (Former Parts Degreaser)
Target COCs to be remediated in the sand channel (Zone 1B) underlying AOC-16C (Former Parts Degreaser) include the following:
1,1,1- and 1,1,2-TCA, and daughter products 1,1-DCE, 1,1-DCA, and 1,2-DCA;
1,4-dioxane; and
Lesser concentrations of chlorinated ethenes (PCE, TCE, and daughter product vinyl chloride).
3.2.1.3 Upgradient of AOC-21 (Former Cast Bar Department)
Based upon soil analytical results, and groundwater analytical results from nested wells MW-23 and MW-37, target COCs to be remediated in the sand channel (Zone 1B) upgradient of AOC-21 (Former Cast Bar
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Department) include primarily TCE, cis 1,2-DCE, and vinyl chloride. Co- mingled impacts at lesser concentrations include PCE and 1,4-dioxane. Chlorinated ethene impacts upgradient of AOC-21 are believed to lay upon mottled clay (Zone 2), and based upon downgradient groundwater monitoring, are not believed to have entered deeper hydrostratigraphic units (Zones 3 and 4).
3.2.1.4 Near AOC-24 (Former Bag House Fire)
Target COCs within the sand channel (Zone 1B) underlying and near AOC-24 (Former Bag House Fire) include elevated concentrations of metals (i.e., arsenic, beryllium, cadmium, and lead). These impacts will be evaluated for Remedial Action following completion of VOC Remedial Action.
3.2.2 Groundwater Remediation Goals
All groundwater analytical results will be evaluated against the following groundwater remediation goals:
Permanent NCDENR 2L groundwater quality standards as provided in paragraphs (g) and (h) within the North Carolina Administrative Code (NCAC) Title 15A Subchapter 2L dated 01 January 2010; and
Interim NCDENR 2L groundwater Interim Maximum Allowable Concentrations (IMAC) established in 2010.
Metals will also be evaluated against their respective average background concentrations (see Table 5 of the Final Remedial Investigation Report) and calculated US Environmental Protection Agency (EPA) site-specific soil screening levels (SSLs) (see Attachment G of the Final Remedial Investigation Report).
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4.0 FEASIBILITY STUDY
This section details the screening of potentially-applicable remedial technologies for VOCs in soil and groundwater. While sub-slab vapor impacts have been observed, the risk to human health is acceptable and the proposed Remedial Action will address the source of these vapors. In addition, VOCs detected in the surface water body to the east of the Main Facility building are a result of groundwater discharge. These impacts are below the relevant standards and will be addressed through the proposed source area remedial approach. Sediment impacts will be addressed under a separate cover.
A minimum of three (3) technologies (or combinations thereof) have been provided for each media. In accordance with Section .0306(l)(3) of the Registered Environmental Consultant Program Implementation Guidance, the following eight (8) evaluation criteria have been used to provide a detailed analysis of each remedial alternative and to justify the selected remedial alternative:
Protection of human health and the environment, including attainment of cleanup levels;
Compliance with applicable federal, state and local regulations;
Long-term effectiveness and permanence;
Reduction of toxicity, mobility and volume;
Short-term effectiveness (i.e., effectiveness at minimizing the impact of the site Remedial Action on the environment and the local community);
Implementability (i.e., technical and logistical feasibility, including an estimate of time required for completion);
Cost; and
Community acceptance.
The following subsections provide a comparative analysis of the remedial alternatives for soil and groundwater. Discussion is also included regarding potential Remedial Action technologies for metals in soil and groundwater.
4.1 Potentially Applicable Soil Technologies – VOCs
Potentially-applicable soil technologies to remediate VOC impacts in the vadose zone were evaluated and included in situ chemical oxidation (ISCO), soil excavation, soil vapor extraction (SVE), and no Remedial Action. Further details are provided in Table 1 and the subsections below for the selected alternatives.
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4.1.1 Chemical Oxidation
Traditionally, ISCO has been applied widely as a groundwater remediation technology for destruction of volatile COCs (e.g., chlorinated solvents, petroleum constituents, etc.). ISCO is conducted via the injection of a single chemical oxidant (e.g., hydrogen peroxide, ozone, persulfate, and permanganate) or suite thereof into the subsurface, and upon contact with sorbed-phase COCs, the oxidants promote rapid COC decomposition reactions. Most ISCO strategies rely on the production of strong oxidants (e.g., hydroxyl and sulfate-free radicals), which are highly-reactive and non-specific.
Although generally accepted by Federal and State regulators, few case studies were identified that describe the application of ISCO to vadose zone impacts. In vadose zone soils, the porosity is primarily filled by subsurface vapors, which limit liquid oxidant migration horizontally (in comparison to groundwater-filled voids). As a result, the radius of influence (ROI) of ISCO injection within the vadose zone is limited and the majority of the injectant is expected to migrate downward.
Given contact with subsurface COCs, rapid destruction can be realized in short periods of time. Given vadose zone injection and the presence of subsurface heterogeneities, oxidant selection may significantly affect remedial effectiveness. The hydroxyl radical, which is generated via hydrogen peroxide (H2O2) and/or ozone injection, has low stability and persistence in the subsurface. As such, should subsurface heterogeneities not facilitate full contact with COCs, remedial effectiveness will be decreased. Other oxidants have longer persistence within the subsurface. For example, the persulfate anion may persist up to two (2) months within the subsurface and continue to generate sulfate-free radicals.
Methods for implementation of ISCO within the vadose zone may include injection via direct-push technology, dedicated injection wells, or slow drip (via a horizontal well system). Given the localized nature of the source areas at the site, focused injection is best achieved via direct-push technology. Injection enhancements can be used to increase the ROI and vertical distribution of oxidants including atomization (direct-push technology only), co-injection of inert gases, and/or pressure-pulse technology.
Initial capital costs will be incurred regardless of injection methodology for procurement of chemical oxidants. Injection via dedicated injection wells incurs initial capital costs associated with well installation. Similarly, injection via slow drip incurs capital costs associated with installation of a horizontal well system, associated operation and maintenance (O&M), and sub-slab depressurization (if necessary). Less capital costs are associated with temporary injection points installed via direct-push technology. Given subsurface heterogeneities, multiple ISCO injections (and increased costs) may be required to achieve COC concentrations below Protection of Groundwater PSRGs.
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4.1.2 Soil Excavation
Soil excavation is a remedial technology in which contaminated media is physically removed from the subsurface, and properly transported off-site and disposed at a permitted facility. Under optimal conditions, complete removal of impacted soil may be realized which reduces source area impacts below applicable Protection of Groundwater standards and decreases COC leaching into underlying groundwater. Excavation can be conducted within a short time frame, and have both short- and long-term effectiveness (at a high probability of success). However, little to no reduction in toxicity is realized for the contaminated media transferred to a permitted facility, and liability still remains with the waste generator.
The practicability of excavation as a viable remediation technology for the three (3) primary VOC areas was evaluated by GES along with representatives of Belfor Environmental and Triad Geotechnical Consulting. The evaluation was performed to evaluate if the contaminated media located beneath the Moen facility could safely be removed and to identify potential challenges. A copy of the Constructability Report conducted by Belfor is presented in Attachment C. In general, excavation within the Main Facility Building was technically practical from an engineering perspective. However, the following challenges and disadvantages were identified.
Due to the location of the three (3) VOC impacted areas, the potential challenges for using excavation as a remediation technology include maintaining structural integrity of the building, relocation of operating manufacturing equipment, exposure to plant workers during excavation activities, ability to completely remove the contaminated media, and economic impacts due to loss production. Structural integrity concerns exist due to the impacted soil being located adjacent to and under existing building footers, sidewalls, and column supports. Conducting excavation activities near or under existing footers, sidewalls, and columns will require the use of shoring, bracing, and special excavation techniques (to ensure the integrity of the building structure during excavation). However, implementing these costly excavation techniques will present challenges to make sure all the contaminated soil can be completely removed.
The following excavation logistics represent a challenge to implement: ingress and egress of excavation equipment and materials into and out of the Main Facility Building; egress of excavated contaminated media out of the Main Facility Building and off-site; dust, vapor, and vehicular exhaust management; preparation of the work area to minimize exposures to plant workers; limitation of production operations and business interruptions; and maintenance of existing monitoring wells.
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The greatest disadvantage to implementing excavation as a remedial technology is the necessity for relocating the cafeteria and removing production equipment, specifically an electroplater (Plater 6) and screw machines overlying the identified TCE source area upgradient of AOC-21 (Former Cast Bar Department). In order to access the contaminated soil in these areas, a temporary cafeteria would need to be provided by Moen, and the production equipment would need to be placed out of service and relocated until excavation is completed. It is estimated that it would take approximately 3- to 4-weeks to disconnect and relocate Plater 6 and the screw machines at the site. The excavation activities in this area were estimated to take an additional 30- to 45-days with an approximate 3- to 4- weeks to move equipment back and place into service. Overall, this process could take up to three (3) months to complete. Plater 6 is an integral part of the manufacturing operation, and significant production and business losses would be realized if this unit was not in operation. Therefore, excavation activities in this area would cause the facility to completely shut down operation for potentially up to three (3) months. Although relocating the cafeteria would not cause the operations to shut down, additional expenses would occur as a result of relocation activities and additional business interruptions to plant operations.
The economic costs would be cost prohibitive and infeasible to implement. It was estimated that utilizing excavation as the technology of choice would cost approximately $3.3 million (see Attachment C). However, this cost estimate is a likely minimum as it does not factor in the costs associated with disconnecting and reassembling of the manufacturing equipment, the cost to relocate the cafeteria, and the cost associated with the complete shutdown of the plant manufacturing operations for up to 3 months.
4.1.3 Soil Vapor Extraction
SVE is a well-documented, field-tested, commonly-used remediation technology that is generally accepted by Federal and State regulatory agencies, and is used to remove subsurface vapors from the vadose zone, and in the process, enhance COC mass transfer from the sorbed and aqueous phases into the gaseous phase. A vacuum is applied to one (1) or more extraction wells screened across the vadose zone, which creates vapor flow pathways through the subsurface and through contaminated media. VOCs are collected from and/or desorbed from the soil, transported via vapor flow pathways into the extraction wells, and ultimately to ex-situ vapor treatment. To remove VOCs from SVE vapors, ex-situ treatment typically consists of physical methods (e.g., absorption onto granular activated carbon) or destructive methods (e.g., incineration) prior to emission to the atmosphere.
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Advantages of SVE over other vadose-zone-treatment technologies include the following:
No physical (e.g., excavation and disposal of impacted soil) or chemical methods (e.g., chemical oxidation) are necessary to remove contaminant mass from the vadose zone; and
SVE may be capable, depending on ROI within the subsurface, to address VOCs immobilized underneath existing building structures or manufacturing equipment, which negates the need for demolition or removal.
However, factors that limit the effectiveness and implementability of SVE at the subject site include the following:
Interbedded, fine-grained silts and clays with low conductivity of air (or low permeability in general) and potential for greater presence of soil water underlie the site, which may prohibit contaminant removal and create preferential vapor flow paths in more-permeable, less-impacted media;
Chlorinated ethenes (TCE, 1,1-DCE, and vinyl chloride) are characterized by vapor pressures ranging from 75- to 2600-millimeters of mercury (mmHg), and chlorinated ethanes (1,1,1-TCA, 1,1-DCA, and 1,2-DCA) have volatilities ranging from 82.1- to 124.6-mmHg; however, 1,1,2-TCA and 1,4-dioxane, which are target COCs at the site, are characterized by low volatilities 24.4- and 30-mmHg, respectively, which result in less effective removal via SVE;
Recovery of volatile chlorinated solvents will be limited by the relatively- high ground water level (between 8- to 10-feet bls);
Vacuum application may result in localized groundwater upwelling, which further limits the recovery of COCs from unsaturated soil;
Intrusive activities (e.g., drilling and trenching) will be necessary to install the SVE wells and associated treatment system piping within the main building and around existing equipment, and valuable manufacturing space, which is currently used for production, may be necessary to house SVE treatment equipment; and
Moderate to high costs as a result of installation of closely-spaced wells, a piping network, and ex-situ treatment system components, periodic O&M, permitting, and compliance monitoring.
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4.1.4 No Active Remediation
No active remediation is neither protective of human health and the environment nor amenable to Regulatory or community acceptance. The Registered Environmental Consultant Program Implementation Guidance states that “all proposed remedies must include removal and/or treatment of source areas with contamination exceeding health-based remedial goals and contamination leaching to groundwater.” Although the soil and groundwater impacts are not considered to be a risk to human health according to the Registered Environmental Consultant Program Implementation Guidance, no source area removal will only be considered “if the REC can demonstrate that source removal is technically impracticable from an engineering perspective.” All active remediation technologies detailed above are practical from an engineering perspective, but some less preferable to a business/production perspective for Moen.
Should no active soil remediation be conducted, leaching of chlorinated solvent and 1,4-dioxane impacts from the VOC source areas is expected to continue in both short- and long-term, with minimal removal in soil by natural attenuation processes.
4.2 Potentially Applicable Soil Technologies – Metals
Potentially-applicable soil technologies to address metal impacts in the vadose zone, which were detected in exceedance of their Preliminary Health-Based PSRGs and Average Background Concentrations, were evaluated and included institutional controls, adjustment of Health-Based Soil Remediation Goals, and no Remedial Action. Further details are provided below for the selected alternatives, or combinations thereof, which are ranked in order by preference.
4.2.1 Institutional Controls
As detailed in Section 3.1 above, four (4) metals were detected at concentrations exceeding their Preliminary Health-Based PSRGs and average background concentrations, including arsenic, mercury, hexavalent chromium, and manganese. In accordance with Appendix F of the Registered Environmental Consultant Program Implementation Guidance, cleanup levels for the standard Commercial/Industrial exposure scenario were obtained from the branch given written request (see Attachment D). Of the four (4) metals, only arsenic concentrations exceeded the Commercial/Industrial cleanup level of 4.6 mg/kg in the following borings:
AOC2-SB04, which contained arsenic at a concentration of 4.7 mg/kg from 0.0- to 0.5-feet bls;
AOC5-SB01, which contained arsenic at a concentration of 5.1 mg/kg from 5- to 6-feet bls;
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AOC13-SB03, which contained arsenic at a concentration of 6.68 mg/kg from 0.0- to 0.5-feet bls;
AOC16C-SB01, which contained arsenic at a concentration of 8.40 mg/kg from 0- to 1-foot bls;
AOC16C-SB02, which contained arsenic at a concentration of 5.2 mg/kg from 0- to 1-foot bls;
AOC16C-SB04, which contained arsenic at concentrations of 4.69- and 5.42-mg/kg from 0.0- to 0.5-foot bls and 3- to 4-foot bls, respectively;
AOC16C-SB06, which contained arsenic at a concentration of 6.42 mg/kg from 0.0- to 0.5-foot bls;
AOC16C-SB07, which contained arsenic at 5.81 mg/kg from 2- to 4-feet bls;
AOC18-SB01, which contained arsenic at 5.3 mg/kg from 0.0- to 0.5-foot bls;
AOC21-SB04, which contained arsenic at 6.86 mg/kg from 0.0- to 0.5- foot bls;
AOC23-SB01, which contained arsenic at concentrations of 6.6- and 8.4- mg/kg from 0.0- to 0.5-foot bls and 2- to 4-feet bls, respectively.
For select metal exceedances (excluding those arsenic exceedances above), institutional controls (i.e., land use restrictions) may be proposed and utilized at the site to restrict current and future land use to Commercial/Industrial. As a result, in accordance with Appendix F of the Registered Environmental Consultant Program Implementation Guidance, no further Remedial Action may be required. However, the guidance further states that “leaving contaminants in place above unrestricted use remediation goals with appropriate land use restrictions is a form of on-site containment.” A notification will be required that:
Proposes a containment remedy with land use restrictions at the site;
Provides descriptions of the current site and surrounding property use, the proposed site use, and current and proposed zoning of the site and surrounding properties;
Includes a statement confirming that all soil remedial goals will be met at the site; and
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Includes a land use restriction proposal including a description of activities and uses restricted at the site, the deed book and page numbers for the property where the restrictions will apply, proposed remediation goals for restricted land use, written consent by the owner of the site, a proposed annual inspection plan.
Use restrictions at the site may include maintenance of the existing pavement caps and prevention of contact (e.g., unpermitted subsurface excavation) with direct- contact exceedances unless special precautions are taken to mitigate risks. The institutional controls will be transferable with the property and recorded in the appropriate Register of Deeds office. The institutional control shall be in place for the period of time necessary to comply with applicable standards.
Disadvantages associated with use of land use restrictions include the following:
Several arsenic exceedances of Commercial/Industrial cleanup goals remain at the site and are not addressed;
In Appendix F of the Registered Environmental Consultant Program Implementation Guidance, the Branch states “…that the use of physical barriers as a remedy for contaminated soils is the least favored option”;
Future land use associated with the property is limited to Commercial/Industrial;
The Branch may review the proposal and reject the proposed containment remedy; and
Public notice requirements of the RAP in accordance with G.S. 130A- 310.4(c)(2) and 15A NCAC 13C .0306(j), and associated potential for public comments that must be addressed prior to RAP implementation.
For these reasons, calculation of adjusted Final Health-Based Soil Remediation Goals for unrestricted land use are preferred and detailed within the following section.
4.2.2 Adjustment of Health-Based Soil Remediation Goals
In accordance with Appendix E of the Registered Environmental Consultant Program Implementation Guidance, adjusted Final Health-Based Soil Remediation Goals may be calculated for COCs with only carcinogenic effects, only non-carcinogenic effects, or both carcinogenic and non-carcinogenic effects. The advantages of calculating these standards include the following:
The land use remains unrestricted and thus can be developed as residential (if desired by the owner); and
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Health-Based Soil Remediation Goals can be calculated nearer the upper limit of the acceptable carcinogenic risk range (i.e., cancer risk of 10-4) and acceptable non-carcinogenic risk range (i.e., hazard index of 1.0).
This is recommended herein for the four (4) metals (i.e., arsenic, mercury, hexavalent chromium, and manganese) exceeding their respective Preliminary Health-Based PSRGs and average background concentrations.
4.2.3 No Remedial Action
As detailed in Section 3.1 above, three (3) metals were detected at concentrations exceeding their Protection of Groundwater PSRGs and average background concentrations, including arsenic, cadmium, and manganese. No action is recommended for these metals for the following reasons.
A leaching evaluation was conduced on arsenic exceedances of 6.6- and 8.4- mg/kg detected in soil boring AOC23-SB01 at depths of 0- to 0.5-feet bls and 2- to 4-feet bls, respectively. The SPLP samples collected from the equivalent depths in an adjacent boring yielded non-detect results (with a method detection limit less than the groundwater remediation standard). These results indicate that arsenic detections at or near 8.4 mg/kg, although greater than the Protection of Groundwater PSRG (5.8 mg/kg) and calculated U.S. EPA site-specific SSL (2.92 mg/kg), do not have the potential to leach at concentrations above groundwater remediation goal of 10 µg/L.
A leaching evaluation was conducted on a cadmium concentration of 3.0 mg/kg detected in soil boring AOC23-SB01 from 10- to 11-feet bls. The SPLP sample collected from the equivalent depth in an adjacent boring yielded non-detect results (with a method detection limit less than the 2L standard). These results indicate that cadmium detections at or near 3.0 mg/kg do not have the potential to leach at concentrations above the 2L standard of 2 µg/L. In addition, all cadmium detections were less than the calculated U.S. EPA site-specific SSL of 31.6 mg/kg, which was based upon site-specific geotechnical parameters and a realistic dilution attenuation factor (DAF) of 10 (see Attachment G of Final Remedial Investigation Report).
All manganese detections were less than the calculated U.S. EPA site- specific SSL of 571 mg/kg, which was based upon site-specific geotechnical parameters and a realistic DAF of 10 (see Attachment G of Final Remedial Investigation Report).
As such, no soil remediation is required for Protection of Groundwater exceedances detected in soil during the RI.
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4.3 Potentially Applicable Groundwater Technologies - VOCs
Potentially-applicable groundwater remediation technologies evaluated for VOCs included ISCO, enhanced bioremediation, monitored natural attenuation (MNA), and no active remediation. Further details are provided below for the selected alternatives, or combinations thereof.
4.3.1 In Situ Chemical Oxidation
As described in Section 4.1.1, ISCO is an established, well-documented, field- tested remedial technology, which has been applied widely in groundwater for destruction of various contaminants of concern (e.g., chlorinated solvents, petroleum constituents, etc.) and is accepted by Federal and State regulators. Given contact with subsurface COCs, rapid destruction can be realized in short periods of time. However, the presence of subsurface heterogeneities and oxidant selection may significantly affect remedial effectiveness.
Methods for implementation of ISCO within groundwater may include injection via direct-push technology or dedicated injection wells. Injection enhancements can be used to increase the ROI and vertical distribution of oxidants including atomization (direct-push technology only), co-injection of inert gases, and/or pressure-pulse technology. Prior to injection, notification and authorization from the U.S. EPA Region IV – UIC Program will be necessary. Initial capital costs will include procurement of chemical oxidants and dedicated injection well installation (if selected over direct-push technology). Less capital costs are associated with temporary injection points installed via direct-push technology.
Advantages of ISCO over other groundwater treatment technologies include the following:
Persulfate, upon activation with H2O2 or naturally-occurring ferrous iron, rapidly produces persulfate anions and sulfate-free radicals (a strong oxidant), which are very reactive and moderately stable in the subsurface. The persulfate anion can persist within the subsurface from weeks to months, in comparison to H2O2 and hydroxyl radicals that do not have prolonged stability / persistence within the subsurface. Due to the unspecific nature of persulfate anions and sulfate-free radicals, these oxidants are best suited to remediate volatile COCs at concentrations above groundwater remediation goals including chlorinated ethenes, chlorinated ethanes, and 1,4-dioxane.
Average pH values are around 5.00 standard units (s.u.) within hydrostratigraphic zone 1B (i.e., sand channel sands) underlying the primary VOC source areas. Persulfate oxidation is less dependent upon pH values and documented to be effective in acidic conditions.
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ISCO can be applied within the primary VOC source areas quickly and unobtrusively using direct push or injection well methodology. In addition, injection can be conducted during 2nd shift to minimize disruption(s) to production at the Moen facility.
ISCO has the potential to reduce COC impacts underlying the source areas and resultantly reduce impacts within the downgradient dissolved-phase plume. No receptors are located on-site or immediately downgradient of the site. As such, no remediation within the dissolved phase-plume is recommended.
Capital costs for direct-push application or injection well installation are expected to incur moderate cost. However, no permanent piping infrastructure or ex-situ treatment system is required, or O&M following application. All remediation occurs within the subsurface in and around the treatment zone(s). In addition, the amounts of remediation wastes are reduced.
Immediately following chemical oxidation, subsurface conditions in the injection area are expected to turn oxic in the short-term. In the short term, this may be disruptive and potentially toxic to intrinsic chlororespiring microorganisms (where present). However, in the long- term (i.e., months following injection), subsurface conditions are expected to return to pre-injection conditions. Subsequently, natural attenuation processes (e.g., physical, chemical, or biological processes in groundwater that act without human intervention) are expected to continue to reduce toxicity, mobility, volume, or concentrations of contaminants.
Factors that may limit the effectiveness and implementability of chemical oxidation include the following:
With standard injection techniques, the chemical oxidant injectant has the potential to be transported along preferential pathways or preferentially into high-permeability zones, which may not contain the greatest impacts. Injection enhancements described above are recommended to better distribute the injectant across the injection screen (or point), and to enhance the ROI of the injectant.
Given subsurface heterogeneities, multiple ISCO injections may be required to achieve COC concentrations below groundwater remediation goals. Should multiple ISCO injections be necessary; injection via direct- push techniques, in comparison to dedicated injection wells, may result in a greater number of injection points advanced within the source area.
Immediately following injection, contaminant desorption may occur, which may result in short-term mobilization of dissolved phase
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contaminants away from the treatment zone. In addition, ISCO may also temporarily mobilize metals already present in soil. However, the dissolved impacts can be addressed with subsequent inspections and the metal concentrations are expected to return to pre-injection values in the long term.
ISCO is considered a viable method to remediate groundwater impacts underlying the three (3) primary VOC source areas. However, further treatability studies are recommended to evaluate the effect of subsurface media, contaminant levels, and natural organic matter on the soil oxidant demand, and to calculate appropriate volumes of persulfate and H2O2 to add (see Section 7.0).
4.3.2 Enhanced Bioremediation
Enhanced bioremediation of chlorinated solvents is a well-documented and field- tested remedial technology, which utilizes intrinsic or augmented anaerobic microorganisms to catalyze in situ reductive dechlorination of chlorinated solvents to benign end products. Select subsurface microorganisms have been identified that reductively dechlorinate parent compounds PCE and TCE, under anaerobic conditions, to lesser chlorinated ethenes (cis 1,2- DCE, trans 1,2-DCE, and vinyl chloride) and to benign organic compound ethene. Laboratory and field studies have revealed that Dehalococcoides (Dhc.) species are the only microorganisms capable of complete TCE biotransformation beyond 1,2-DCE to the benign products ethene and inorganic chloride. Several different microorganisms have been identified that reductively dechlorinated chlorinated ethanes under anaerobic conditions (e.g., Desulfobacteria, Clostridium species, Dehalobacter species, and methanogenic consortia).
Biostimulation is utilized to create an optimal subsurface environment for chlororespiring microorganisms when present; however, suboptimal conditions prevail for intrinsic bioremediation (e.g., lack of sufficient nutrients, vitamins, and/or organic carbon). More specifically, biostimulation refers to the injection of commercially-available, field tested nutrients and/or electron donors to:
Establish reducing conditions in environments characterized by elevated dissolved oxygen concentrations and positive oxidation-reduction potential (ORP) values;
Provide fermentable substrates for intrinsic fermenting microorganisms, which then stimulates anaerobic microbial processes including chlororespiration; and/or
Enhance the rate of biodegradation of a select contaminant (or mixture thereof) by indigenous chlororespirers.
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For this technique to yield satisfactory results, the appropriate microbial species must be present at the site. If not present, bioaugmentation can be conducted to emplace the chlororespiring population within the subsurface.
Advantages of enhanced bioremediation over other groundwater treatment technologies include the following.
As evidenced by the formation of anaerobic reductive dechlorination daughter products vinyl chloride (from parent compounds PCE, TCE, and 1,1-DCE) and chloromethane (from parent compound TCA), reductive dechlorination potential already exists at the site.
Chlororespiring microorganisms, where present, are capable of transport into non-preferential contaminant pathways and against concentration gradients, can move along with groundwater/plume flow, and can treat both sorbed- and dissolved-phase contaminant mass.
Capital costs for direct-push application or injection well installation are expected to incur moderate cost. However, no permanent piping infrastructure or ex-situ treatment system is required, or O&M following application. All remediation occurs within the subsurface in and around the treatment zones. In addition, the amounts of remediation wastes are reduced.
However, factors that limit the effectiveness and implementability of enhanced bioremediation at the site include the following:
1,4-dioxane impacts are less amenable to removal via anaerobic enhanced bioremediation.
Repeated injections of biostimulants may be necessary to treat continued loading and back-diffusion from fine-grained material (silts and clays) interbedded within the alluvial deposits underlying the site. This results in recurrent costs for re-amendment with electron donor, etc.
Microbially-mediated reductive dechlorination of chlorinated solvents is not an instantaneous process, and may take several months to a year to see positive effects. In addition, the toxicity of daughter products including vinyl chloride (from parent compounds PCE, TCE, and 1,1-DCE) and 1,2- DCA (from parent compound TCA) may exceed that of the parent compounds. From review of historical groundwater analytical data collected at the site, it is unknown whether benign products ethene (from chlorinated ethenes) or ethane (from chlorinated ethanes) are being formed, or whether incomplete dechlorination (e.g., stall at vinyl chloride or chloromethane) is occurring.
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Short- and long-term effectiveness is dependent upon subsurface biogeochemical conditions (e.g., nutrient balance, pH, dominant terminal electron accepting processes (TEAPs)), which are difficult to regulate. Minimal information regarding the biogeochemistry of the site has been collected in the past. However, the low pH values (~ 5.0 standard units), variable dissolved oxygen concentrations, and positive ORP values detected are not optimal for microorganisms responsible for anaerobic chlororespiration.
4.3.3 Monitored Natural Attenuation
Natural attenuation processes (i.e., physical, chemical, and/or biological processes that act without human intervention) have been observed to reduce contaminant toxicity and mobility at the site, which occur both in short-term and long-term periods. MNA is a passive approach that relies solely on these processes for reducing contamination toxicity.
Advantages of MNA over other groundwater treatment technologies include the following:
MNA is considered by the Branch to be a potential remedial alternative for attaining remediation goals;
TCE dechlorination to vinyl chloride and TCA degradation to chloromethane are currently occurring throughout the plume;
Approach with minimal site disturbance and waste generation, no technical requirements required for implementation, and no design, capital, and equipment O&M costs to be spent.
Disadvantages of MNA, which may limit effectiveness, include the following:
Groundwater conditions downgradient of the Main Facility building and near the unnamed stream are characterized by oxic conditions and low pH values, which are not optimal for anaerobic chlororespiration;
Vinyl chloride and chloromethane have been detected, which are products of chlorinated ethene and chlorinated ethane reductive dechlorination, respectively; however, the extent of their production and that of ethene and ethane may be limited;
MNA provides minimal control on target COC concentrations, which may increase with time (success of MNA based on assumption that COC concentrations collected to date are likely maxima);
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Long-term monitoring will be necessary to confirm compliance with groundwater remedial goals along the property line and off-site; and
Community acceptance is questionable.
MNA will be better realized should active remediation be conducted near the VOC source areas as rates and extent of chlororespiration would be expected to increase with decreased mass loading.
4.3.4 No Active Remediation
No further active remediation for groundwater was considered as:
No VOC impacts were confirmed above groundwater remediation goals within point of compliance wells MW-6, MW-17, MW-31, and MW-32 located along the property boundary;
No VOC impacts were detected above groundwater remediation standards downgradient (and off-site) of well MW-18; and
Former potable wells were abandoned surrounding and off-site of the facility, and no receptors are immediately downgradient of the site.
The VOC source areas identified within the facility are relatively old (no ongoing source), finite, and of limited volume, and natural attenuation processes have been observed to occur. As such, COC concentrations observed along the primary flow paths, along the property line, and off-site are not expected to increase in either short- or long-term, and the concentrations are expected to decrease with time. Given no active remediation, these processes are solely responsible for reducing contamination toxicity.
Advantages of no active remediation include the following:
No technical requirements for implementation; and
No design, capital, and equipment O&M costs to be incurred.
However, acceptance by the Branch and surrounding community is questionable.
4.4 Potentially Applicable Groundwater Technologies - Metals
As detailed in Section 3.2.1 above, the following metals were detected within groundwater at concentrations greater than groundwater remediation goals and are believed to be related to historical manufacturing processes at the site:
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Cadmium, total and hexavalent chromium, copper, lead, nickel, and zinc within well IW-2, and beryllium and manganese in underlying well MW- 26S near AOC-13 (Former Brite Dip Pit).
Arsenic, beryllium, cadmium, and lead in shallow well MW-36S near AOC-24 (Former Bag House Fire).
Following VOC remediation in groundwater, as proposed in Section 5.2 below, the above metal exceedances (and those detected across the site at concentrations slightly exceeding groundwater remediation goals during the RI) will be further evaluated and an Addendum to the RAP will be prepared (as necessary). As currently envisioned, metal remediation technologies in groundwater underlying AOC-13 and AOC-24 may include, but are not limited to, the following.
Soil flushing. This remedial technology removes metals via in situ injection of an appropriate washing solution (targeted to metals detected) into the impacted subsurface, leaching of metals from soil, and subsequent extraction of the impacted elutriate. The washing solution, while in the subsurface, removes metal contaminants via solubilization, emulsion formation, and/or chemical reactions. Ex situ, the elutriate is collected at land surface, treated to remove dissolved metals, and separated for reinjection. Once the metals are removed, the surfactant may be recovered and re-used (to an extent practical). Washing solutions may include additives (e.g., acids, bases, chelating agents, oxidizing/reducing agents, and/or surfactants/co-solvents), which may require a UIC permit to inject.
Chemical treatment (redox and pH manipulation). This remedial technology reduces the toxicity and/or affects mobility (via precipitation or solubilization) of target metals in situ via chemical reactions. For example, oxidants may be used to convert metal ions to their most- oxidized form (i.e., removes electrons). Conversely, reducing agents (e.g., alkali metals, ferrous sulfate, sulfur dioxide, sulfite salts) may be used to convert metal ions to their most reduced state (i.e., adding electrons). Neutralization agents may be used to adjust pH. Chemical selection will be based upon the redox nature of the target metals, and designed not to mobilize existing metals or making them more toxic. A UIC permit may be required to inject.
Electrokinetic treatment. This remedial technology mobilizes charged metal ions via application of a low-density electrical current (via electrodes) to the subsurface, and is best-suited to low-permeability, saturated media. The intrinsic conductivity of the groundwater is used to move positively-charged metal ions (cations) to negatively-charged electrodes and negatively-charged metal ions (anions) to positively- charged electrodes. The metal-impacted solution around the electrodes is removed via electroplating, precipitation, complexation with an ion
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exchange resin, and/or pump and treat. Chemical solutions may be injected to enhance metal recovery and may require a UIC permit.
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5.0 PROPOSED REMEDY
This section provides a preliminary, conceptual design for the proposed remedies in soil and groundwater, and justification based upon results of the feasibility study. More specifically, a description of the principle of operation is provided for each technology, and pre-design schematics for the major remedy components are referenced (where applicable). In accordance with Section .0306(l)(4)(Note**) of the Registered Environmental Consultant Program Implementation Guidance, a waste determination has been included for contaminated media to be transported off-site for disposal.
As required under 15A NCAC 13C .0306(m), final design plans and equipment specifications, drawings, and permits and approvals will be provided within forthcoming Pre-Construction Reports (submitted under separate cover).
5.1 Chemical Oxidation in Soil
ISCO is proposed to remediate impacts in the vadose zone at AOC-13 (Former Brite Dip Pit), AOC-16C (Former Parts Degreaser) in the cafeteria (Former Tool Room), and the TCE source area identified upgradient of AOC-21 (Former Cast Bar Department). Given access limitations in AOC-13 and the TCE source area, injection will be conducted in a phased approach commencing at AOC-16C. Soil remediation at each area will be conducted prior to or concurrently with groundwater remediation as detailed in Section 5.2.
Further details are provided in the following subsections.
5.1.1 Principle of Operation
Combined injection of sodium persulfate and H2O2 is proposed for remediation of COC impacts within the vadose zone underlying the three (3) primary VOC source areas. Co-injection will facilitate both short-term and long-term chemical oxidation. Further details are provided regarding principles of operation as follows.
Upon contact with water, injected sodium persulfate dissociates into sodium and the persulfate anion. The persulfate anion in solution is a strong, kinetically-slow oxidant (standard oxidation potential of 2.0 volts), which upon activation, produces the sulfate-free radical (a stronger, faster oxidant with standard oxidation potential of 2.5 volts). Although the sulfate-free radical is short-lived in the subsurface, the persulfate anion may exist for weeks to months. Following reaction, the persulfate anion decomposes to the bisulfate anion and H2O2.
H2O2 will be injected with persulfate as an activation agent, which along with naturally-occurring ferrous iron, promotes the formation of the sulfate-free radical from the persulfate anion. In addition, H2O2 is an oxidant (with standard
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oxidation potential of 1.8 volts), which may also react with naturally-occurring ferrous iron to produce the strong, kinetically-fast hydroxyl radical (standard oxidation potential of 2.8 volts). Both radicals can be regenerated via chain- propagating reactions with COCs, or terminated via reaction with naturally- occurring iron. The sulfate-free radical may be scavenged by carbonate and bicarbonate ions, or chloride.
Reactions of site COCs with persulfate anion/sulfate-free radical and hydrogen peroxide/hydroxyl radical are expected to generate carbon dioxide and water via mineralization. The sulfate-free and hydroxyl radicals are uncharged, and upon contact with COCs, remove an electron resulting in destabilization of the COC and subsequent mineralization.
5.1.2 Waste Determination
In comparison to other soil remediation technologies, ISCO is not expected to generate a large amount of waste. As detailed in Section 5.1.3 below, direct-push technology is recommended for injection and does not generate a substantial volume of soil cuttings.
As detailed within the waste determination dated 20 July 2009 (see Attachment Q of the Phase I RI Report), which was based on a review of historical manufacturing operations and generator knowledge, knowledge of the processes that created the source of contamination, contaminant, or waste near the remaining AOCs is inconclusive. As such, in accordance with the Section titled “Determination of When Contamination is Caused by Listed Hazardous Waste” on page 5 of US EPA’s document titled “Management of Remediation Waste under RCRA”; the US EPA states that in the absence of documentation, “one may assume that the source, contaminant, or waste is not listed hazardous waste”. Consequently, waste previously generated as part of the RI and waste to be generated as part of Remedial Action will not be considered listed hazardous waste. Waste characterization, management, and proper transportation and disposal methods to be used are detailed in Section 6.4.
5.1.3 Conceptual Design
The soil impacts within AOC-13 (Former Brite Dip Pit) and AOC-16C (Former Parts Degreaser) are of limited volumetric extent. More specifically, in and around AOC-13, chlorinated ethene daughter product (i.e., 1,1-DCE, 1,1-DCA, and 1,2-DCA) exceedances were localized at soil borings AOC13-SB01 (from 5- to 6-feet bls), AOC13-SB07 (from 2- to 7.5-feet bls), and AOC21-SB03 (4- to 9.5-feet bls). 1,4-dioxane exceedances in AOC-13 were also limited in extent to boring AOC21-SB03. Similarly in AOC-16C, chlorinated ethane exceedances (including parent compounds 1,1,1- and 1,1,2-TCA) were greatest and localized in soil boring AOC16C-SB07 from 1- to 6-feet bls. 1,4-dioxane and chlorinated ethane daughter product exceedances observed downgradient were derived from
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impacts at AOC16C-SB07. As such, a focused ISCO application is recommended to address localized source areas within AOC-13 and AOC-16C.
As detailed in Section 5.1.1, the selected chemical oxidant suite will include persulfate with H2O2 as an activating agent. Persulfate is more easily atomized and injected in comparison to other injectants (e.g., Fenton’s reagent), and presents less health and safety concerns. In addition, persulfate has been documented to effectively destroy intermingled COCs at the site including chlorinated ethenes (TCE and daughter products), chlorinated ethanes (TCA and daughter products), and 1,4-dioxane. Sodium persulfate will be procured from FMC Corporation in crystalline form and stored within a proper location identified by Moen. Further details regarding chemical storage, management, and handling are provided in the ISCO HASP Addendum (see Attachment E).
Different ISCO injection techniques were researched within the vadose zone. The injection methodology favored given the localized distribution of the source areas is direct push technology. A direct-push rig will be utilized to advance a small diameter probe (between ¾- to 2-inches in diameter) downward via a percussion hammer to terminal depth. Terminal depth will be defined during field application as either the underlying confining unit (e.g., hydrostratigraphic zone 2) or the water table, whichever is shallower. Via direct-push, injection is conducted as the probe is retrieved from terminal depth to around 2 feet bls A casing will be advanced to terminal depth, and used to prohibit injections from migrating along the probe hole and daylighting at land surface. Permanent injection points may be used for injection instead of, or in conjunction with, direct-push injection points.
Sodium persulfate will be mixed with tap water on-site, and injected into the vadose zone at a concentration between 10 to 30% (by mass). H2O2, as an activation agent, will be added as an 8% solution to the persulfate solution at a concentration between 1 to 10 moles of H2O2 per mole of persulfate. The final molar ratio will be selected from this range. Further information regarding mixing of persulfate and hydrogen peroxide, injection requirements, and appropriate PPE is included in Attachment E. Given the use of direct-push technology, certain injection enhancements may be employed including a directional injection nozzle (to best direct chemical oxidant into areas with limited access), atomization (to push the chemical oxidant into the vadose zone with compressed gas), co-injection of inert gases, and/or pressure-pulse technology.
As currently envisioned, ISCO will be conducted in a phased approach. Specifically, the initial phase of ISCO injection will be conducted in AOC-16C (Former Parts Degreaser) within a grid-like fashion (see Figure 2). In the vadose zone, ISCO will be focused on 1,1,1-TCA and 1,4-dioxane impacts at and near soil boring AOC16C-SB07, and 1,1-DCE impacts downgradient and to the east (see Figure 2). As initially envisioned, near this location, injection points will be closely spaced (in a 2-foot by 2-foot grid). Further away from the source zone,
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injection will be conducted in a 5-foot by 5-foot grid. During the initial phase, the spacing of injection points may be increased in the field based on observed ROI. If determined necessary, temporary vadose zone monitoring wells may be installed to evaluate the ROI.
The second phase of ISCO will be focused on the remaining two (2) VOC source areas as follows.
In AOC-13 (Former Brite Dip Pit), in the vadose zone, ISCO will be focused on chlorinated ethane, chlorinated ethene, and 1,4-dioxane impacts at and near soil borings AOC13-SB01 and AOC13-SB07 (see Figure 3). This area, which includes the former brite dip pit and the majority of the former brite dip trench, is accessible for direct-push technology. Near borings AOC13-SB01 and –SB07, injection points will be spaced on 2-foot by 2-foot grids. Further away from the source zone, injection will be conducted on 5-foot by 5-foot grids.
In the TCE source area upgradient of AOC-21 (Former Cast Bar Department), installation of remedial design soil borings are proposed to further delineate the area to be remediated (see proposed boring locations in Figure 4). Just upgradient of AOC-21, near boring locations AOC21- SB01, AOC21-SB05, and AOC21-SB06, chlorinated ethene impacts were detected at the depth of groundwater and will not be addressed as part of soil remediation. The additional remedial design borings will be installed surrounding borings SGS-SB01 and SGS-SB03, in which chlorinated ethene and/or 1,-4 dioxane impacts were detected throughout the vertical thickness of the boring, and location will be determined in the field, and sampled for analysis of VOCs (see Table 3). The remedial methodology in this area will be based upon findings from the remedial design borings and may include, but is not limited to, co-injection of persulfate with H2O2 via horizontal well installation (as the source area is located underlying permanent equipment (e.g., screw machines, an electroplater)) and slow drip methodology.
The chemical oxidant suite and injection methodology may be modified based upon performance within the initial phase of ISCO at AOC-16C (Former Parts Degreaser), and upon performance within subsequent ISCO applications in AOC- 13 (Former Brite Dip Pit) and the TCE source area.
5.1.4 Justification of Proposed Remedy
In comparison to other technologies (e.g., SVE, excavation), ISCO via direct-push technology is less intrusive and can be conducted within a faster timeframe. Also, regarding production at the Moen facility, ISCO can be conducted during less- populated work shifts (i.e., 2nd shift from 15:00 to midnight) with minimal production disturbance. Although potentially less effective than excavation,
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ISCO has the ability to remediate the target COCs and is more cost-effective even if multiple injection events are required.
5.2 Chemical Oxidation in Groundwater
ISCO is proposed to remediate VOC impacts in shallow groundwater (within sand channel sands) underlying AOC-13 (Former Brite Dip Pit), AOC-16C (Former Parts Degreaser) in the cafeteria (Former Tool Room), and the TCE source area identified upgradient of AOC-21 (Former Cast Bar Department). Although low COC concentrations were detected above groundwater remediation goals in deeper groundwater within the quartz gravel and saprolite; these concentrations are expected to decrease given remediation in the overlying shallow groundwater and no active remediation is recommended.
Given access limitations in AOC-13 and the TCE source area, ISCO will be conducted in a phased approach commencing at AOC-16C. Groundwater remediation at each area will be conducted concurrently with or directly following soil remediation detailed in Section 5.1. Further details are provided in the following subsections.
5.2.1 Principle of Operation
Similar to soil remediation, ISCO will be conducted in groundwater using sodium persulfate and H2O2. Further details regarding the principles of operation are provided in Section 5.1.1. Delivery, management and handling, storage, mixing, injection, and appropriate PPE are detailed in Attachment E.
Field pilot/treatability tests and/or laboratory treatability studies shall be conducted to determine the optimal molar ratios of persulfate and H2O2 for groundwater injection, to confirm removal of target COCs, and/or to evaluate metal sensitivity (as practical) to oxidation (see Section 7.0).
5.2.2 Conceptual Design
On a location per location basis, groundwater remediation will be conducted concurrently with or directly following soil remediation.
In AOC-16C (Former Parts Degreaser), the greatest groundwater impacts are dispersed underlying soil boring AOC16C-SB01. ISCO injection will be conducted via direct-push technology in a grid-like fashion (assuming an effective ROI of 10 feet) (see Figure 2). The probe will be advanced via the percussion hammer to the terminal depth of the sand channel (as determined from review of well MW-22 well construction diagram) and injection will be conducted through the probe during probe advancement.
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Temporary wells may be installed to measure injectant ROI via oxidant observation, water level changes, and/or pressure changes. The proposed injection point spacing may be increased in the field should increased ROIs be observed. Enhancements (e.g., pressure-pulse technology, atomization, co- injection with inert gases) may be used to increase distribution across the injection point and to enhance the ROI.
Following the initial phase of ISCO in AOC-16C; ISCO injection will be conducted in a 10-foot by 10-foot grid within AOC-13 (Former Brite Dip Pit) (as proposed in Figure 3) and the TCE source area upgradient of AOC-21 (Former Cast Bar Department). However, the chemical oxidant suite and injection methodology may be modified based upon performance within AOC-16C (Former Parts Degreaser).
As part of ISCO injection, five (5) additional shallow monitoring wells (i.e., MW- 39 through MW-43) will be installed near the primary VOC source areas to evaluate remedial performance and/or further refine the spatial extent of COC impacts in groundwater (see Figure 5). The locations of these wells will be determined in the field and documented within a Pre-Construction Report along with groundwater analytical results. Also, groundwater samples may be collected within the injection area via direct-push technology to focus future injections.
5.2.3 Justification of Proposed Remedy
In comparison to other technologies (e.g., enhanced bioremediation, MNA), ISCO via direct-push technology is more-suited to the existing geochemical conditions (e.g., average pH of 5.00 s.u. within the sand channel), can be conducted and evaluated within a faster timeframe, and is more specific to target COCs (e.g., 1,4-dioxane). Also, regarding production at the Moen facility, ISCO can be conducted during less-populated work shifts (i.e., 2nd shift from 15:00 to midnight) with minimal production disturbance.
5.2.4 Institutional Controls
Institutional controls (i.e., land use restrictions) will be utilized at the site to prevent future groundwater usage on-site for potable, irrigational, or manufacturing purposes. This institutional control will be transferable with the property and recorded with the appropriate Register of Deeds office. The institutional control shall be in place for the period of time necessary to comply with applicable standards.
In addition, as detailed within Section 6.0 of the Final Remedial Investigation Report, all potable wells adjacent to the site were abandoned and adjacent properties using potable water were connected to municipal water. As such, no groundwater receptors exist immediately downgradient and adjacent to the site.
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6.0 DESCRIPTION OF ACTIVITIES AND PROCEDURES
This section, in accordance with 15A NCAC 13C .0306(l)(6), summarizes all activities necessary to implement the proposed methods of Remedial Action in compliance with applicable laws and regulations, and in a manner that soil and groundwater remediation goals are met. In addition, it includes procedures to be utilized in accordance with 15A NCAC 13C .0306(l)(8). Further details are provided within the following sections.
6.1 Remedial Design Soil Boring Installation, and Soil Sample Collection and Analysis
As proposed in Section 5.1.3, prior to the second phase of ISCO, remedial design soil borings will be installed in and around the TCE source area upgradient of AOC-21 (Former Cast Bar Department) to further delineate the area to be remediated (see Figure 4). The following subsections describe methodologies to be utilized for soil boring installation, and soil sample collection and analysis.
6.1.1 Soil Boring Installation
All proposed remedial design soil boring locations will first be cleared of utilities via ground penetration radar (GPR) and electromagnetic tracing prior to installation. Boring locations will be moved should underground utilities be identified at the proposed location. Next, the cleared remedial design soil boring locations will be concrete-cored to an appropriate diameter to facilitate boring advancement. Following utility clearance and concrete coring; soil borings shall be advanced to a depth of 5 feet bls via a 4-inch diameter, stainless steel hand auger or direct-push technology. The soil boring(s) will be advanced via direct- push technology from 5 feet bls to terminal depth, which shall be representative of the water table (“free” water surface).
In accordance with the US EPA Region 4 Logbooks Operating Procedure (SESDPROC-010-R3), the date and time of observation, soil boring identification, advancement depth, and soil description will be recorded within dedicated, bound logbooks for continuous soil samples collected during boring advancement. From each boring, soil cores will be collected via Macro-Core® sleeves. The physical description of the soil within each soil boring will be conducted visually in accordance with the Modified Unified Soil Classification System (USCS) for Field Classification of Soil. Also, a hand-held photo-ionization detector (PID) will be used to qualitatively screen the soil samples for VOCs. Each soil sample will be visually described within the dedicated logbook(s) as follows:
The main soil type’s name; Gradation (coarse-grained soils) and plasticity (fine-grained soils); Density or Consistency; Water content or depth at which saturated soils are encountered; Color description;
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Minor soil type; Structure; Presence of inclusions (if observed); Geological name (if known); Appropriate USCS group name and symbol; and Results of PID screening.
Following soil boring installation and sampling, each soil boring shall be properly abandoned in accordance with the US EPA Region 4 Design and Installation of Monitoring Wells Guidance (SESDGUID-101-R0) and sealed at the surface to match the surrounding flooring. A stake or flag will be placed at the soil boring location until surveying by a North Carolina-registered land surveyor is conducted.
Soil cuttings, decontamination water, and other IDW generated during soil boring installation will be managed in accordance with Section 6.4.
6.1.2 Soil Sample Collection and Analysis
During boring advancement, soil samples will be collected from within the 0- to 1- foot interval and at 5-foot intervals to the water table in accordance with US EPA Region 4 Soil Sampling Operating Procedure (SESDPROC-300-R1) and Appendix A of the Registered Environmental Consultant Program Implementation Guidance. However, should elevated PID responses be observed at a different depth, soil sample collection may be re-directed to that vertical location.
In accordance with analytical reporting requirements provided in Appendix A of the Registered Environmental Consultant Program Implementation Guidance; soil samples shall be collected and analyzed as follows (see Table 3):
Samples for US EPA Target Compound List (TCL) VOCs shall be collected within a method 5035 compatible container (e.g., Terra-Core kit) and analyzed via US EPA SW846 method 8260B;
Samples for 1,4-dioxane shall be collected within a method 5035 compatible container (e.g., Terra-Core kit) and analyzed via US EPA SW846 method 8260B – selective ion mode (SIM);
Samples for total hazardous substance list metals shall be collected within 4-oz glass jars, prepared by EPA 3050B, and analyzed with US EPA SW846 method 6020/7471;
Samples for total organic carbon (TOC) shall be collected within 4-oz jars and analyzed via US EPA SW846 methods 9060; and
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Samples for hexavalent chromium shall be collected within 4-oz glass jars and analyzed via US EPA SW846 method 3060A (or equivalent).
The following QA/QC samples will be collected (see Table 3) during the proposed soil sample collection activities:
One (1) field duplicate to be analyzed for VOCs, 1,4-dioxane, metals, and hexavalent chromium via the above methods;
One (1) equipment rinsate blank to be analyzed for US EPA TCL VOCs and total hazardous substance list metals via US EPA SW846 methods 8260B and 6020/7470A, respectively; and
A trip blank will be submitted with each cooler containing bottleware for VOC analysis and analyzed for US EPA TCL VOCs via US EPA SW846 method 8260B.
TICs will not be identified during 8260B analysis, as they are believed to be innocuous and are co-located with target soil COCs to be remediated as proposed herein.
6.2 Remedial Performance Monitoring Well Installation, and Groundwater Sample Collection and Analysis
As proposed in Section 5.2.2, five (5) additional shallow monitoring wells will be installed near the primary VOC source areas to evaluate remedial performance and refine the extent of groundwater impacts (see Figure 5). These wells will be incorporated into periodic performance monitoring as described in Section 8.2. If determined necessary, additional shallow monitoring wells may be installed to further evaluate remedial performance.
The following subsections describe methodologies to be utilized for well installation, construction, and development, and groundwater sample collection and analysis.
6.2.1 Well Installation, Construction, and Development
Each monitoring well will be designed and installed in accordance with the US EPA Region 4 Design and Installation of Monitoring Wells Guidance (SESDQUID-101-R0). A North Carolina-certified well driller and -certified well Contractor shall be on-site at all times during well installation.
Each well will be installed within a single boring via direct-push technology or hollow stem auger/air rotary, and the boring will be advanced to the terminal depth of the shallow-most hydrostratigraphic unit (i.e., channel sand (Zone 1A) or mottled clay (Zone 2)). Continuous soil samples will be collected during advancement for geologic characterization and PID screening.
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Monitoring wells to be installed within the Facility shall have a diameter of 2- inches or less (if installed via direct-push technology). The well screen will consist of 5- to 10-feet of Sch40 PVC 10-slot screen, and will extend across the shallow-most hydrostratigraphic unit. The sand pack will be filled with commercially-available washed siliceous Morie no.0 (DSI no.1) sand (or equivalent). A minimum 2-foot thick bentonite seal (i.e., untreated, high-yielding Wyoming bentonite pellets) will be placed above each sand filter pack. Bentonite-cement grout will be placed above the uppermost bentonite seal to around 1- to 2-feet bls. The riser extending from the screen to land surface will consist of Sch40 PVC.
All wells will be constructed flush-mount and completed with watertight lockable caps. Well vaults for flush mount construction will be equipped with a water- resistant cast-iron flange and lid with Buna N gaskets. Well pads shall be completed such that they are flush with the surrounding facility floor. Following completion, well construction diagrams will be completed for the new wells.
Following well construction, each installed well will be developed in accordance with the US EPA Region 4 Design and Installation of Monitoring Wells Guidance. Drill cuttings, decontamination water, and other IDW generated during well installation will be managed in accordance with Section 6.4.
6.2.2 Groundwater Sample Collection and Analysis
Prior to groundwater sample collection, the “free” water surface (i.e., potentiometric surface) will be measured within each well using an electronic water level indicator in accordance with the US EPA Region 4 Groundwater level and Well Depth Measurement Operating Procedure (SESDPROC-105-R1). Specifically, for each new well, the following information will be entered into the bound logbook:
The water level to the nearest 0.01 foot relative to a surveyed reference point on the well casing; and
The serial number of the electronic water level indicator.
During periodic performance monitoring, as described in Sections 8.2 and 8.3, groundwater samples will be collected from well locations described in Tables 4 through 7 via an environmental pump (e.g., peristaltic or electronic submersible pump) using the general low-flow/low-stress methodology in accordance with the US EPA Region 4 Groundwater Sampling Operating Procedure (SESDPROC- 301-R1). Should isolated zones not yield enough groundwater for low-flow sampling, a clean bailer or Hydrosleeve sampler will be utilized to purge and collect the groundwater sample. Effort will be made to reduce the turbidity within each of the above wells to the lowest value practical. General water quality
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parameters (pH, temperature, dissolved oxygen, specific conductance, and ORP) will be monitored for equilibrium and recorded prior to sample collection.
In accordance with analytical reporting requirements specified in Appendix A to the Registered Environmental Consultant Program Implementation Guidance, groundwater samples shall be collected from all wells identified within Tables 4 through 7, and shipped to a NCDENR – Division of Water Quality – certified laboratory for analyses as follows:
Samples for US EPA TCL VOCs shall be collected within three (3) 40- mL, HCl-preserved VOA glass vials with Teflon® septa and analyzed via US EPA SW846 method 8260B;
Samples for 1,4-dioxane shall be collected within three (3) 40-mL, HCL- preserved VOA glass vials with Teflon® septa and analyzed via US EPA SW846 method 8260B – SIM;
Samples for total hazardous substances list metals will be collected within HNO3-preserved, 250-mL polyethylene or glass bottles, prepared by SM 3030C, and analyzed via US EPA method 6200/6010B/7470A;
Samples for hexavalent chromium will be collected in unpreserved, 250- mL polyethylene or glass bottles, and analyzed via US EPA method 7196 (or equivalent);
Samples for TOC will be collected in 100-mL glass bottles and analyzed via US EPA SW846 method 9060;
Samples for chemical oxygen demand (COD) will be collected in 250-mL polyethylene or glass bottles, and analyzed via standard method 410.4; and/or
Samples for ferrous iron will be collected in unpreserved, 100-mL glass bottles and analyzed via method SM18 3500-FE D.
The following QA/QC samples will be collected during performance monitoring (see Tables 4 through 7):
One (1) field duplicate will be collected per medium and container type, and each day of field activities;
One (1) equipment rinsate blanks will be collected per twenty (20) field samples, and analyzed for US EPA TCL VOCs and total hazardous substance list metals via US EPA SW846 methods 8260B and 6020/6010B/7470A, respectively; and
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A trip blank will be submitted with each cooler containing bottleware for VOC analysis and analyzed for US EPA TCL VOCs via US EPA SW846 method 8260B.
TICs will not be identified during 8260B analysis, as they are believed to be innocuous and are co-located with target groundwater COCs to be remediated as proposed herein.
6.3 Confirmation Soil Boring Installation, and Soil Sample Collection and Analysis
As described in Section 8.1, the effectiveness and success of ISCO in soil will be evaluated based upon post-remedial confirmation soil sampling. Within each of the three (3) primary source areas, three (3) post-remediation confirmation soil borings will be installed via direct-push technology within the injection grid in accordance with the methodology provided in Section 6.1.1 above. Boring locations will be determined in the field and located in close proximity to locations of soil borings installed during the RI, which will serve as baseline for comparative purposes. From each boring, soil cores will be collected via Macro-Core® sleeves, screened with a PID, and visually inspected for soil characterization. Soil and QA/QC samples will be collected and analyzed for target COCs in accordance with the methodology provided in Section 6.1.2, as detailed in Table 8. TICs will not be identified during 8260B analysis, as they are believed to be innocuous and are co-located with target soil COCs to be remediated as proposed herein.
Soil cuttings, decontamination water, and other IDW generated during soil sampling will managed in accordance with Section 6.4.
6.4 Management of Remedial Action-Derived Wastes
Remedial Action-derived wastes generated shall be managed in accordance with Section A.6.2.g. of Appendix A to the Registered Environmental Consultant Implementation Guidance and the U.S. EPA Region 4 Management of Investigation Derived Waste Operating Procedure (SESDPROC-202-R1). More specifically, DOT-approved fifty- five (55)-gallon steel drums will be utilized to containerize all investigation-derived waste (IDW) including:
Coring water generated during concrete coring;
Soil cuttings generated from probe advancement via direct-push technology;
Decontamination fluids generated during decontamination of drilling equipment; and
Disposable equipment and personal protective equipment (PPE) containerized with the appropriate waste.
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Containerized waste accumulated will be stored within a proper storage area as identified by Moen. Once containerized, each individual waste stream listed above will be sampled for characterization and profiling purposes in accordance with Section 4.3 of the US EPA Region 4 Waste Sampling Operating Procedure (SESDPROC-302-R1). Specifically:
Representative liquid samples will be collected from each individual liquid waste stream and analyzed for RCRA VOCs and metals via US EPA methods 8260B and 6020/7470A; and
A discrete, representative, grab soil sample will be collected from soil cuttings, prepped via US EPA method 1311 (the Toxicity Characteristic Leaching Procedure (TCLP)), and analyzed for RCRA VOCs and metals via US EPA methods 8260B and 6020/7471, respectively.
Waste analytical results will be directly compared against Maximum Concentrations of Contaminants for the Toxicity Characteristic as provided in Table 1 of 40 CFR §261.24. Based upon this evaluation, in accordance with the Waste Determination dated 20 July 2009 (see Attachment Q of the Phase I RI Report), the wastes will be profiled as either non-hazardous or RCRA characteristic hazardous waste. PPE will be disposed of in accordance with the characterization of the source material.
Trash generated during Remedial Action shall be containerized and properly disposed of off-site in accordance with Federal, State, and Local permits, rules, and regulations.
6.5 Equipment and Personnel Decontamination Procedures
Decontamination activities will be conducted in accordance with the US EPA Region 4 Field Equipment Cleaning and Decontamination Operating Procedure (SESDPROC-205-R1). A decontamination area will be established outside of the work area, in a surface-contamination-free area designated by Moen, for any equipment coming in contact with subsurface materials, including:
Down-hole drilling equipment (e.g., geoprobe rods, hollow stem augers, etc.);
Soil sample collection equipment (e.g., hand augers, etc.);
Groundwater sample collection equipment (e.g., peristaltic pumps, Redi-Flo2® pumps, etc.);
Electronic water level indicators; and
Tools exposed to contaminated media.
The decontamination area shall be constructed on a level surface of impervious and compatible materials, and shall be free of cracks and other potential leakage routes. The
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decontamination area shall be designed, through size or other means, to collect all liquid and semi-liquid material generated or collected during decontamination activities.
All equipment utilized during RAP implementation shall be decontaminated prior to and between usage. In addition, all sampling equipment will be decontaminated between soil and groundwater sample collection events. Further equipment-specific requirements are provided in the US EPA Region 4 Field Equipment Cleaning and Decontamination Operating Procedure (SESDPROC-205-R1). All wash waters and residues will be collected, containerized, and characterized for proper disposition.
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7.0 DESCRIPTION OF PROPOSED TREATABILITY STUDIES
This section, in accordance with 15A NCAC 13C .0306(l)(7), provides a description of proposed pilot/treatability tests and/or laboratory treatability studies to support the final remedial design. Additional soil and groundwater site characterization efforts to support Remedial Action were summarized previously in Sections 6.1 and 6.2, respectively. Further details are provided in the sections below.
7.1 Field Pilot/Treatability Tests
During the initial phase of ISCO, field pilot/treatability tests are proposed to be conducted within AOC-16C (Former Parts Degreaser). The objective will be to determine in the field:
The optimal concentration, molar ratio, and volume of sodium persulfate (activated with hydrogen peroxide) required to completely oxidize target COCs (i.e., chlorinated ethanes and 1,4-dioxane) and naturally-occurring soil oxidant demand; and
The optimal injection methodology.
In addition, the pilot/treatability test will be used to evaluate the ability of the formation to accept and distribute the oxidant, and to determine safeguards necessary (e.g., sub-slab vapor depressurization). A detailed scope of work will be provided within a forthcoming Pre-Construction Report specific to the initial phase of ISCO. Field pilot/treatability test results will be applied to the second phase of ISCO injection within AOC-13 (Former Brite Dip Pit) and upgradient of AOC-21 (Former Cast Bar Department).
7.2 Laboratory Treatability Tests
The objectives of proposed laboratory treatability studies, which will be conducted prior to the second phase of ISCO in AOC-13 (Former Brite Dip Pit) and the TCE source area, are to:
Determine the optimal concentration, molar ratio, and volume of sodium persulfate (activated with hydrogen peroxide) required to completely oxidize all target COCs (i.e., chlorinated ethenes, chlorinated ethanes, and 1,4-dioxane) and naturally-occurring soil oxidant demand in site-specific soil and groundwater;
Evaluate the sensitivity of redox-sensitive metals (i.e., arsenic, chromium, lead, manganese, etc.) detected within AOC-13 (Former Brite Dip Pit) to persulfate oxidation; and/or
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Determine whether off-gassing will occur and the extent thereof, and whether sub-slab vapor depressurization or additional measures will be necessary during and following ISCO application.
Representative soil and groundwater samples will be collected concurrent with the installation of remedial design soil borings in the TCE source area upgradient of AOC-21 (Former Cast Bar Department) (see Sections 5.1.3 and 6.1), and will be focused on the area of greatest impacts:
Near boring AOC13-SB01 in AOC-13 (Former Brite Dip Pit); and
Near boring SGS-SB01 upgradient of AOC-21 (Former Cast Bar Department).
Soil samples will be collected via direct-push technology within the shallow-most hydrostratigraphic unit (i.e., sand channel (Zone 1B) or mottled clay (Zone 2)). Groundwater will be collected from nearby monitoring wells:
Well IW-2 within AOC-13 (Former Brite Dip Pit); and
The proposed new performance monitoring well upgradient of AOC-21 (Former Cast Bar Department).
Soil and groundwater samples will be shipped directly to a commercial bench testing laboratory (e.g., Prima Environmental, Inc.) for setup. Also, soil samples will be shipped to a commercial geotechnical laboratory (e.g., PTS labs) for analysis of porosity, bulk density, volumetric water content, and fraction of organic carbon.
Once received at the bench testing laboratory, a bench test will be prepared using material from each of the two (2) source areas. Each bench test will consist of a control slurry and three (3) test slurries. The test slurries will be composed of source area- specific soil mixed with groundwater. Samples will be collected from soil and water to determine the concentration of target COCs within each of the bench tests prior to chemical oxidant injection.
Various concentrations of activated sodium persulfate will be added to the test slurries. The activation agent will be selected based upon the results from the initial phase of ISCO in AOC-16C. The lab shall collect initial samples after the groundwater and soil are mixed, and amend them with additional COC concentration if determined necessary.
Including the initial sampling event, aqueous samples will be collected from the slurries and analyzed for target COCs, pH, ORP, dissolved oxygen, total organic carbon and/or metals three (3) times during each bench test. Off gas produced by the control and test slurries will be trapped within Tedlar® bags and analyzed for VOCs at the end of the test. This data will be used to support a complete mass balance, and to evaluate the objectives listed above.
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The scope herein is subject to change based upon results from the first phase of ISCO, and may include additional oxidant evaluation (e.g., alkali-activated sodium persulfate) or composite preparation of bench tests (e.g., combining soil and groundwater from source areas with similar COCs into one (1) bench test).
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8.0 PROPOSED CRITERIA FOR REMEDIAL ACTION COMPLETION
This section, in accordance with 15A NCAC 13C .0306(l)(9), outlines a scope for post- remediation confirmation sample collection and groundwater monitoring, which will be used to evaluate the performance of the selected remedies proposed in Section 5.0. In addition, this section details the content and timetable for submittal of Pre-Construction Reports and the Construction Completion Report, and the reporting of performance evaluation results within periodic Remedial Action Progress Reports and the Remedial Action Completion Report.
8.1 Post-Remediation Confirmation Soil Sampling
The effectiveness and success of ISCO in soil will be evaluated based upon post-remedial confirmation soil sampling. As discussed in Section 6.3, a confirmation soil sample collection event will be conducted approximately six (6) months following ISCO completion to assess reductions in soil-phase COC concentrations and to evaluate remaining in-place mass. Further details regarding methodologies for soil boring installation, and soil sample collection and analysis are provided in Section 6.3. A proposed soil sample collection matrix is included in Table 8.
8.2 Baseline Groundwater Monitoring
Baseline groundwater samples will be collected prior to Remedial Action implementation from select wells in or just downgradient of the three (3) primary VOC source areas, and new wells proposed in Sections 5.2 and 6.2. These analytical data will be used as a “time zero” measurement to gauge the effectiveness of both soil and groundwater remediation. Further details are as follows.
Prior to groundwater sample collection, the “free” water surface (i.e., potentiometric surface) will be measured within each well in accordance with Section 6.2. Groundwater samples will be collected from select wells underlying the Main Facility Building, and analyzed in accordance with methodologies provided in Section 6.2. A baseline groundwater sample collection matrix is included as Table 4. Select wells directly underlying the three (3) primary VOC source areas will be analyzed for ferrous iron, total organic carbon (TOC), and chemical oxygen demand (COD) (see Table 4). These data will be utilized to determine natural oxidant demand, evaluate the potential for naturally- occurring ferrous iron to promote Fenton’s Reagent and activate persulfate, and assist with estimation of volumes of persulfate and hydrogen peroxide to be co-injected at each source area.
8.3 Post-Remediation Groundwater Monitoring
The effectiveness and success of ISCO in groundwater underlying and downgradient of the three (3) primary VOC source areas will be based upon the following performance monitoring conducted following completion of both phases of ISCO implementation:
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Two (2) quarterly monitoring events within the 1st year to assess concentration decreases of target VOCs in monitoring wells positioned within or just downgradient of the three (3) primary VOC source areas (see Table 5);
Three (3) years of semiannual monitoring to assess target VOC trends within monitoring wells in and just downgradient of the three (3) primary VOC source areas, and select wells immediately downgradient of the Main Facility Building (see Table 6); and
Three (3) years of annual monitoring to further assess target VOC trends within monitoring wells across the site, and along the groundwater and contaminant migration pathways (see Table 7).
The methodology to be used for groundwater sample collection and well gauging, and analyses to be conducted by a NCDENR – Division of Water Quality-certified laboratory, were detailed in Section 6.2 above. On a semi-annual and annual basis, as described in Table 6 and 7, groundwater samples will be collected from select wells for analysis of total hazardous substance list metals and hexavalent chromium. The purpose will be to evaluate potential metal mobilization and/or increases in metal concentrations as a result of ISCO. Samples will also be collected for analysis of ferrous iron directly underlying the three (3) primary VOC source areas to evaluate the potential for ferrous iron to promote Fenton’s Reagent and activate persulfate (should additional injections be necessary).
8.4 Evaluation of Remedy Performance
In order to gauge remedial performance:
COC concentrations observed in confirmation soil borings will be evaluated against soil remediation goals as defined in Section 3.1.2; and
Detected VOCs in groundwater will be evaluated against groundwater remediation goals (see Section 3.2.2).
Further chemical oxidation may be necessary dependant upon the results of post- remediation confirmation soil and/or groundwater sampling.
8.5 Reporting of Performance Evaluation Results
In accordance with Section .0306(l) of the Registered Environmental Consultant Program Implementation Guidance, the following reports will be prepared and submitted to document performance evaluation. All reports will be submitted to the Branch within thirty (30) days of certification by the RSM (Montgomery S. Bennett of GES).
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8.5.1 Pre-Construction Reports
In accordance with Section .0306(m) of the Registered Environmental Consultant Program Implementation Guidance, Pre-Construction Reports will be prepared and submitted, which documents the following.
Treatability studies. As discussed in Section 7.0 above, treatability studies will be conducted with site-specific soil and groundwater to determine optimal molar ratios of persulfate and hydrogen peroxide, assess removal of target COCs, and evaluate metal sensitivity to oxidation. Treatability study reports will be summarized and included as an appendix to the Pre-Construction Report.
Remedial design soil and groundwater results. As discussed in Sections 5.1.3 and 6.1 above, additional remedial design soil borings will be installed upgradient of AOC-21 (Former Cast Bar Department) to further delineate the spatial extent of chlorinated ethene and 1,4-dioxane impacts near soil borings SGS-SB01 and SGS-SB03. Also, as detailed in Sections 5.2.2 and 6.2, further monitoring wells will be installed near the three (3) primary VOC source areas, and groundwater samples will be collected to evaluate remedial performance and further refine groundwater impacts. Results of additional site characterization will be summarized within the Pre-Construction Report.
Final Engineering Design Report. This report shall include final plans and equipment specifications for construction of the remedy, a narrative description of the final design, and a summary of changes from the conceptual design provided herein;
A plan for performance monitoring and evaluation.
An updated project schedule for construction, O&M, performance monitoring and evaluation, report submittal (i.e., Construction Completion Report and Remedial Action Completion report), and progress reporting.
Permits and Approvals. Copies of all permits and approvals, and registrations will be incorporated as appendices.
Waste management and disposal. Generation, treatment, handling, and ultimate disposition of wastes produced will be described.
As currently anticipated, two (2) Pre-Construction Reports will be submitted. The first Pre-Construction Report will be submitted prior to the first phase of ISCO within AOC-16C (Former Parts Degreaser), and in addition to the final ISCO design, will include a plan for proposed field pilot/treatability tests to be conducted. The second Pre-Construction Report will be submitted prior to ISCO
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implementation at AOC-13 (Former Brite Dip Pit) and the TCE source area upgradient of AOC-21 (Former Cast Bar Department). A tentative schedule is provided in Section 9.0. The required Work Phase Completion Form No. WPC- IV will be submitted with each Pre-Construction Report.
8.5.2 Construction Completion Report
In accordance with Section .0306(n) of the Registered Environmental Consultant Program Implementation Guidance, a Construction Completion Report will be submitted to the Branch following completion of both phases of ISCO implementation and shall include: “As built" plans and specifications;
A summary of major variances from the final design plans;
A summary of any problems encountered during construction; and
A description of waste generation, treatment, handling, and ultimate disposition.
The required Work Phase Completion Form No. WPC-V will be submitted with the Construction Completion Report.
8.5.3 Remedial Action Completion Report
Once confirmation data has been received that indicates soil and/or groundwater remediation goals have been achieved, a Remedial Action Completion Report will be submitted to the Branch with the associated Work Phase Completion Form No. WPC-VI. In accordance with Section .0306(p) of the Registered Environmental Consultant Program Implementation Guidance, the Remedial Action Completion Report will:
Present the results of remediation and confirmation sampling outlined herein;
Demonstrate that site cleanup has been completed, and that applicable soil and/or groundwater remedial goals have been achieved; and
Provide a summary of Remedial Action operating experience in meeting design goals;
Report the present worth of the total capital and O&M costs to implement the RAP.
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In accordance with the Administrative Agreement dated 22 January 2009, “operation of the remedial action system for groundwater shall be considered to have begun only upon the submission to the Division of the groundwater remedial action construction completion report, certified in accordance with 15A NCAC 13C .0306(b) by the REC and the Remediator, and upon commencement of the actual operation of the remedial system”.
8.5.4 Periodic Progress Reports
In accordance with Section .0306(o) of the Registered Environmental Consultant Program Implementation Guidance, Remedial Action Progress Reports will be prepared and submitted to the Branch quarterly, and shall include the following:
O&M results, which shall include summaries of Remedial Action O&M requirements and a discussion of major problems encountered;
Performance evaluation results, which shall include tabulated and graphical presentations of monitoring data, and a comparison of Remedial Action performance to design goals;
A description of all field and laboratory QA/QC procedures followed during any sampling and analysis;
Tabulation of analytical results for all sampling and copies of all laboratory reports including the laboratory summary sheet, laboratory results, QA/QC documentation and results, and chain of custody documentation; and
A map, drawn to scale, which shows all soil sample and monitoring well locations.
The first Progress Report will be submitted to the Branch within ninety (90) days of receipt of the Construction Completion Report and work phase completion certification. After the first full year of Remedial Action and the completion of four (4) quarterly monitoring events, groundwater Remedial Action progress reports will be prepared and submitted on an annual basis.
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9.0 SCHEDULE
This section provides a tentative schedule for additional site characterization, conduct of treatability studies, final Remedial Action design and construction, operation and maintenance, performance monitoring and evaluation, and progress reporting.
August 2011: o Submittal of RAP to REC Program including certifications by Remediation Party and RSM; o REC Program drafts public notice, and provides copy of the notice and copy of facility mailing list to RSM; and o RSM adds additional parties to mailing list (if necessary) and distributes public notice.
September 2011: o Public notice periods ends and any public comments are satisfactorily addressed; o REC Program informs RSM that the RAP work phase completion statement can be certified and submitted; o Work Phase Completion Form No. WPC-III submitted, and includes Document Certification Forms from Remediating Party and RSM; and o RAP implemented.
Winter 2011: o Five (5) additional performance monitoring wells installed within Facility; o Baseline performance monitoring event conducted; o Pre-Construction Report specific to ISCO implementation in AOC-16C (Former Parts Degreaser) in Cafeteria submitted to Branch, which includes final plans for field pilot/treatability tests, and any pertinent permits and certifications; and o Field pilot/treatability test conducted in AOC-16C (Former Parts Degreaser).
Winter 2012: o Remedial design borings installed and sampled in TCE source upgradient of AOC-21 (Former Cast Bar Department); o Soil and groundwater samples collected from AOC-13 (Former Brite Dip Pit) and TCE source area for laboratory treatability studies, and shipped to commercial bench test laboratory; and o Laboratory treatability studies conducted.
Summer 2012: o Second Pre-Construction Report submitted to REC Program, which documents results of laboratory treatability studies and additional characterization results, provides final remedial plans for AOC-13C and the TCE source area, and includes any pertinent permits and certifications.
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Fall/Winter 2012: o Lessons learned from ISCO application at AOC-16C applied to ISCO applications at VOC source areas underlying AOC-13 (Former Brite Dip Pit) and upgradient of AOC-21 (Former Cast Bar Department).
2013: o Construction Completion Report submitted to REC Program with necessary certifications; o Confirmation soil samples installed within three (3) primary VOC source areas; o Post-remediation performance monitoring commences in groundwater; o Quarterly progress reporting commences.
2014: o Semi-annual and annual performance monitoring continues; and o Quarterly progress reporting continues.
2015: o Final year of semi-annual and annual performance monitoring; and o Quarterly progress reporting continues.
2016: o Final quarterly progress report submitted; o Submittal of Remedial Action Completion Report to REC Program with necessary certifications; o Completion of Remedial Action; and o Termination of Agreement.
Further details are provided in the tentative Remedial Action schedule included as Attachment F.
56 Remedial Action Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC July 2011
TABLES
Remedial Action Plan Table 1 Soil Remedial Technology Evaluation Table Moen Incorporated Sanford, North Carolina
Protection of Human Effectiveness Remedial Compliance with Reduction of Toxicity, Community Description Health and Implementability Cost Technology Regulations Short-Term Long-Term Mobility, and Volume Acceptance Environment
Persulfate and H2O2 can Although generally Selected chemical be injected via Geoprobe Phased injection of chemical Persulfate anion Initial capital costs for Positive message to Chlorinated solvent and accepted by Federal and oxidants (persulfate, within small, well- oxidants (e.g., persulfate, hydrogen expected to persist for procurement of chemical provide to surrounding 1,4-dioxane impacts in State regulators in Given contact, COC H2O2, and/or ozone) defined source area peroxide, and/or ozone) into vadose up to 2 months within oxidants, and injection Community (i.e., source areas do not groundwater, lesser destruction expected to able to destroy all (atomization or pressure- zone source area(s) to destroy sorbed- subsurface, with via geoprobe or consumers), plant exceed Preliminary applications be rapid volatile COCs (including pulse technology phase COCs and those trapped potential to produce dedicated horizontal personnel, and other Health-Based PSRGs implemented in vadose 1,4-dioxane) and reduce recommended to within pore spaces sulfate-free radicals well system stakeholders zone their volume increase contact and distribution)
Moderate costs associate ISCO intended to Hydroxyl radicals Further soil boring Alternative injection In Situ with installation of Relies on production of strong decrease source area Underground Injection produced via H2O2 installation, and soil methodology for Chemical dedicated ozone points, Shows dedication to oxidants (e.g., sulfate-free radicals impacts to Control (UIC) and/or ozone injection sample collection and persulfate/H O includes Oxidation 2 2 ozone generation, solving COC issues at and hydroxyl radicals), which are concentrations below notification and have low stability / analysis necessary to slow drip into vadose (ISCO) associated equipment site highly reactive and non-specific Protection of authorization necessary persistence within confirm long-term zone via horizontal well and O&M, and sub-slab Groundwater PSRGs subsurface effectiveness system depressurization system
Dedicated injection Subsurface points, an injection heterogeneities in system (with associated Multiple injections may vadose zone may result O&M), and sub-slab be necessary within in preferential flow paths system to capture vadose zone and that affect contact with fugitive emissions increase costs COCs and remedial required for long-term effectiveness ozone injection
GES - July 2011 Page 1 of 3 Moen - Sanford, NC Table 1 Soil Remedial Technology Evaluation Table Moen Incorporated Sanford, North Carolina
Protection of Human Effectiveness Remedial Compliance with Reduction of Toxicity, Community Description Health and Implementability Cost Technology Regulations Short-Term Long-Term Mobility, and Volume Acceptance Environment
High costs for excavation of Positive message to Chlorinated solvent and Removal of COCs Excavation within Main contaminated media, Commonly used and Near complete removal provide to surrounding 1,4-dioxane impacts in Capable of quickly within the vadose zone, Facility building is maintenance of generally accepted by of impacted soil above Community (i.e., source areas do not removing portions of reducing source area technically practical structural supports, Federal and State Protection of consumers), plant exceed Preliminary leaching source area(s). COCs impacting from an engineering subcontractor oversight, regulatory agencies. Groundwater PSRGs. personnel, and other Health-Based PSRGs groundwater. perspective sampling, monitoring, & stakeholders building restoration. (see attached report)
High costs for off-site Complete removal of Transfer of Applicable to both disposal of contaminated impacted soil may be contaminated media to vadose zone soils and Highly effective Reduction of source area media as RCRA non- Shows dedication to realized, reducing source High probability of RCRA landfill with little upper portion of technology for removal COCs impacting hazardous or hazardous solving COC issues at Physical removal of impacted soils area impacts below success to no reduction in saturated soils (that can of COCs. groundwater. waste (depending on site Excavation to depth of groundwater within Protection of toxicity, but liability still be dewatered or waste characterization primary source area(s) Groundwater PSRGs remains with Moen stabilized) results) Process equipment Natural attenuation within manufacturing High costs for processes expected to building and potential dismantling, relocating, High probability of increase in effectiveness production losses limit & re-installing process success given lessening of ability to excavate equipment, and lost source area COC entirety of source production time. concentrations area(s). May be combined with Replacement of any use of other technologies monitoring wells located for remediation of in source area(s) inaccessible areas and required saturated zone
GES - July 2011 Page 2 of 3 Moen - Sanford, NC Table 1 Soil Remedial Technology Evaluation Table Moen Incorporated Sanford, North Carolina
Protection of Human Effectiveness Remedial Compliance with Reduction of Toxicity, Community Description Health and Implementability Cost Technology Regulations Short-Term Long-Term Mobility, and Volume Acceptance Environment Commonly used Moderate to high to Positive message to Chlorinated solvent and technology, which is Effective at removing Expected to reduce Preferential vapor flow operate and maintain provide to surrounding Removal of soil vapor from vadose 1,4-dioxane impacts in generally accepted by SVE typically takes volatile chlorinated volume of more volatile pathway may develop, SVE treatment Community (i.e., zone via induced vacuum on source areas do not Federal and State months to years to see solvents (TCE, TCA, site COCs, but less which may circumvent equipment, and to consumers), plant extraction wells exceed Preliminary regulatory agencies and positive results and daughter products), volatile COCs (e.g., 1,4- the targeted treatment conduct compliance personnel, and other Health-Based PSRGs has been used for but not 1,4-dioxane dioxane) to remain area monitoring. stakeholders decades Can be implemented to Interbedded silts and Reduces toxicity of Moderate to high due to intended to decrease remove vapors from clays in vadose zone chlorinated ethenes by installation of closely- Ex-situ treatment of recovered volatile impacts to May require Federal vadose zone beneath may not be conducive to Shows dedication to Soil Vapor preferentially removing spaced wells, a piping vapors via GAC prior to emission to concentrations below and/or State permit to building structures or vapor extraction as solving COC issues at Extraction COCs with greatest network, and the atmosphere Protection of construct and operate large equipment, effectiveness decreases site (SVE) volatilities (e.g., vinyl treatment system Groundwater PSRGs depending on ROI as permeability of soil chloride) components. within soils decreases Drilling and trenching necessary to install SVE A relatively-high ground wells and piping water level (between 8- network, and to 10-feet bls), which manufacturing space limits the amount of may be necessary to subsurface from which house treatment vapors can be removed equipment No remedial action for No remedial action is Not protective against Protection of Leaching of chlorinated solvents and 1,4-dioxane Little to none other than No technical not a positive message to No Active No further remedial action to be Protection of Groundwater PSRG expected to continue in short- and long-term, with minimal natural requirements for Little to no cost provide to Community Remediation taken. Groundwater PSRG exceedances does not minimal removal by natural attenuation processes attenuation processes implementation adjacent to and exceedances meet REC Program downgradient of site requirements
GES - July 2011 Page 3 of 3 Moen - Sanford, NC Table 2 Groundwater Remedial Technology Evaluation Table Moen Incorporated Sanford, North Carolina
Protection of Human Effectiveness Remedial Compliance with Reduction of Toxicity, Community Description Health and Implementability Cost Technology Regulations Short-Term Long-Term Mobility, and Volume Acceptance Environment Chlorinated and 1,4- In-situ injection of persulfate and/or Given contact, Persulfate has some dioxane solvent impacts Addition of an oxidizer Initial capital costs for Positive message to hydrogen peroxide to destroy Generally accepted by contaminant destruction stability within in groundwater at could temporarily No O&M following injection wells and provide to surrounding organic contaminants within Federal and State is rapid within subsurface, but activator concentrations greater mobilize some metals application moderate costs for Community (i.e., groundwater underlying source regulatory agencies immediate treatment H2O2 has low stability / than groundwater already present in soil H2O2 consumers) area(s) area persistence remediation goals In Situ Reactive sulfate-free radical, a strong Subsurface conditions Existing subsurface Given contact, persulfate Can be applied quickly Chemical oxidizer, created by reaction of No receptors on-site or Underground Injection expected to return to pre- Multiple injections may Shows dedication to conditions in injection and H2O2 able to and unobtrusively using Oxidation persulfate anion with naturally- immediately Control (UIC) permit injection conditions be necessary and solving COC issues at area expected to turn destroy both chlorinated direct push or injection (ISCO) occurring ferrous iron or hydrogen downgradient of site required months following increase costs site oxic in short-term solvents and 1,4-dioxane well methodology peroxide injection Has potential to reduce Injection enhancements Average pH values of ~ source area mass and in recommended to 5.00 in sand channel will turn reduce impacts increase contact and not adversely affect within dissolved-phase distribution within sand chemical oxidation plume channel
GES - July 2011 Page 1 of 3 Moen - Sanford, NC Table 2 Groundwater Remedial Technology Evaluation Table Moen Incorporated Sanford, North Carolina
Protection of Human Effectiveness Remedial Compliance with Reduction of Toxicity, Community Description Health and Implementability Cost Technology Regulations Short-Term Long-Term Mobility, and Volume Acceptance Environment Chlororespiring Chlorinated and 1,4- If able to maintain In situ injection of an electron donor Microbially-mediated microorganisms active at dioxane solvent impacts reducing conditions, Initial capital costs for Positive message to suite to promote reducing conditions Generally accepted by reductive dechlorination site by production of in groundwater at treatment zone is No O&M following injection wells and provide to surrounding and stimulate anaerobic reductive Federal and State is not instantaneous, and vinyl chloride from TCE concentrations greater expected to remain application moderate costs for Community (i.e., dechlorination of chlorinated regulatory agencies may take months to a and 1,1-DCE, and than groundwater effective longer than electron donor consumers) solvents year to see effects chloromethane from remediation goals ISCO process TCA Can be applied quickly No receptors on-site or Short- and long-term effectiveness dependent upon No reduction of 1,4- Multiple injections may Shows dedication to and unobtrusively using immediately UIC permit required nutrient balance, pH, and geochemical conditions, dioxane toxicity and be necessary and solving COC issues at direct push or injection downgradient of site which are difficult to regulate mobility expected increase costs site well methodology In Situ Enhanced Injection enhancements Anaerobic Has potential to reduce recommended to Reductive Microorganisms able to source area mass and in increase contact and Dechlorination migrate (outside of turn reduce impacts distribution within sand injection area) to within dissolved-phase channel, however impacted areas plume microorganisms may migrate on their own.
Low pH values, variable Multiple applications DO concentrations, and may be required to positive ORP values not establish reducing optimal for Enhanced conditions and stimulate Bioremediation chlororespirers
GES - July 2011 Page 2 of 3 Moen - Sanford, NC Table 2 Groundwater Remedial Technology Evaluation Table Moen Incorporated Sanford, North Carolina
Protection of Human Effectiveness Remedial Compliance with Reduction of Toxicity, Community Description Health and Implementability Cost Technology Regulations Short-Term Long-Term Mobility, and Volume Acceptance Environment Should active Groundwater conditions Relies on natural physical, chemical, Rates and extent of remediation be near stream or biological processes in Intrinsic reductive Considered by branch to anaerobic reductive Oxic conditions along conducted, oxic characterized by oxic Avoids substantial groundwater that act without human dechlorination currently be a potential remedial dechlorination not groundwater migration conditions expected to conditions and low pH design, capital, and intervention to reduce toxicity, occurring for chlorinated alternative for attaining expected to increase pathway may inhibit be re-established just not optimal for equipment O&M costs mobility, volume, or concentrations solvent impacts remediation goals given no active intrinsic bioremediation downgradient of chlororespiring of contaminants remediation Monitored building/source areas microorganisms Will require community Natural Long-term monitoring outreach to detail overall Attenuation program to be remedial strategy Must include removal Daughter products vinyl Volume of plume implemented to Passive, in situ approach with No receptors and/or treatment of chloride and expected to decrease demonstrate minimal site disturbance and waste immediately source areas of chloromethane currently with time via dispersion effectiveness of generation downgradient of the site groundwater observed along plume, and sorption. attenuation process, contamination in soil but may be limited. which may continue indefinitely 1,1-DCE at well MW-18 along property line, but Acceptance of no active No reduction in toxicity impacts not above Contaminant concentrations along property line No technical Avoids substantial May be seen remediation in expected other than groundwater remediation and off-site not expected to increase in short- or requirements for design, capital, and unfavorably by groundwater by REC natural attenuation goal off-site (and long-term implementation equipment O&M costs community near site Program is questionable processes downgradient) or along No Active No active remediation to be taken in property line Remediation groundwater Minimal control on concentrations. Success No receptors Natural attenuation processes occurring in short- based upon assumption immediately term and expected to continue in long-term that historical downgradient of the site concentrations are maxima
GES - July 2011 Page 3 of 3 Moen - Sanford, NC Table 3 Remedial Design Soil Sample Collection and Analytical Matrix Moen Incorporated Sanford, North Carolina
Number 2Sampling Depth 3Required Laboratory Analyses Area of 1Descriptive Type of Soil of Soil Soil Sample ID 0 - 1 feet 5 - 6 feet Depth of 51,4- 8Hexavalent Concern Name Release Boring ID 4VOCs 6Metals 7TOC Borings bls bls Water Table Dioxane Chromium Remedial Design Soil Samples RD-SB01 (0-1) X - - 1 1 1 1 RD-SB01 RD-SB01 (5-6) - X - 1 1 11 1 RD-SB01 (Depth) - - X 1 1 1 1 RD-SB02 (0-1) X - - 1 1 1 1 RD-SB02 RD-SB02 (5-6) - X - 1 1 11 1 RD-SB02 (Depth) - - X 1 1 1 1 RD-SB03 (0-1) X - - 1 1 1 1 RD-SB03 RD-SB03 (5-6) - X - 1 1 11 1 Remedial RD-SB03 (Depth) - - X 1 1 1 1 NA Unknown 6 Design RD-SB04 (0-1) X - - 1 1 1 1 RD-SB04 RD-SB04 (5-6) - X - 1 1 11 1 RD-SB04 (Depth) - - X 1 1 1 1 RD-SB05 (0-1) X - - 1 1 1 1 RD-SB05 RD-SB05 (5-6) - X - 1 1 11 1 RD-SB05 (Depth) - - X 1 1 1 1 RD-SB06 (0-1) X - - 1 1 1 1 RD-SB06 RD-SB06 (5-6) - X - 1 1 11 1 RD-SB06 (Depth) - - X 1 1 1 1 Quality Assurance/Quality Control (QA/QC) Field Duplicate - - - 1111 1 QA/QC NA NA NA NA Equipment Blank - - 1 - 1 - - Samples Trip Blank - - - 1 - - - - Totals 6 NANANANANA2119207 19
Notes: ID, identification; bls, beneath land surface; NA, not applicable; QA/QC, Quality Assurance/Quality Control 1 - See Section 6.1 of the Remedial Action Plan for further details. 2 - Soil boring shall be advanced to terminal depth of water table and sampled at 5-foot intervals from 1 feet bls to the water table, and at the water table. 3 - Analytical method requirements provided in Appendix A to the Registered Environmental Consultant Program Implementation Guidance 4 - US EPA Target Compound List (TCL) volatile organic compounds (VOCs) to be prepped and analyzed via US EPA SW846 methods 5035 and 8260B, respectively. 5 - 1,4-dioxane to be analyzed via US EPA SW846 method 8260B - selective ion mode (SIM). 6 - Total hazardous substance list metals to be prepared by EPA 3050B or 3051, and analyzed via US EPA SW846 method 6020/7471. 7 - Total organic carbon (TOC) to be analyzed via US EPA SW846 method 9060 (or equivalent) 8 - Hexavalent chromium to be analyzed via US EPA SW846 method 7196A (or equivalent)
GES - July 2011 Page 1 of 1 Moen - Sanford, NC Table 4 Baseline Groundwater Sample Collection Matrix Moen Incorporated Sanford, North Carolina
1Laboratory Analyses Interval Well ID 3 1,4- 5Ferrous 6Hexavalent ID 2VOCs 4Metals 7TOC 8COD Dioxane Iron Chromium Existing Monitoring Wells IW-2 - 1111 1 11 S1111 1 11 MW-22 I 11111 11 MW-23 S 1111 1 11 MW-26 S 1111 1 11 MW-28 S 1 1 1 - - - - MW-33 S 1 1 1 - - - - MW-37 S 1111 1 11 Proposed New Shallow Performance Monitoring Wells MW-39 - 1111 1 11 MW-40 - 1111 1 11 MW-41 - 1 1 1 - - - - MW-42 - 1 1 1 - - - - MW-43 - 1 1 1 - - - - Quality Assurance/Quality Control (QA/QC) Field Duplicate 1111 1 11 Equipment Blank 1-1- - -- 8Trip Blank 2------Total Sample Count 17 14 15 9 9 9 9
Notes:
1 - Groundwater samples to be collected and analyzed in accordance with Appendix A to the Registered Environmental Consultant Program Implementation Guidance . 2 - Volatile organic compounds (VOCs) to be analyzed via US EPA SW846 method 8260B. 3 - 1,4-dioxane to be analyzed via US EPA SW846 method 8260B - selective ion mode (SIM). 4 - Metals to be prepared via SM 3030C and analyzed via US EPA method 6020/7471. 5 - Ferrous Iron to be analyzed via method SM18 3500-FE D. 6 - Hexavalent chromium to be analyzed via method SM 3500 CR D (or equivalent). 7 - Total organic carbon (TOC) to be analyzed via US EPA method 9060 (or equivalent). 8 - Chemical oxygen demand (COD) to be analyzed via method 410.4.
GES - July 2011 Page 1 of 1 Moen - Sanford, NC Table 5 Quarterly Groundwater Sample Collection Matrix Moen Incorporated Sanford, North Carolina
Interval 1Laboratory Analyses Well ID ID 2VOCs 3 1,4-Dioxane Existing Monitoring Wells IW-2 - 1 1 S1 1 MW-22 I 1 1 MW-23 S 1 1 MW-26 S 1 1 MW-28 S 1 1 MW-33 S 1 1 MW-37 S 1 1 Proposed New Shallow Performance Monitoring Wells MW-39 - 1 1 MW-40 - 1 1 MW-41 - 1 1 MW-42 - 1 1 MW-43 - 1 1 Quality Assurance/Quality Control (QA/QC) Field Duplicate 11 Equipment Blank 1- 8Trip Blank 2- Total Sample Count 17 14
Notes:
1 - Groundwater samples to be collected and analyzed in accordance with analytical method requirements provided in Appendix A to the Registered Environmental Consultant Program Implementation Guidance . 2 - Volatile organic compounds (VOCs) to be analyzed via US EPA SW846 method 8260B. 3 - 1,4-dioxane to be analyzed via US EPA SW846 method 8260B - selective ion mode (SIM).
GES - July 2011 Page 1 of 1 Moen - Sanford, NC Table 6 Semi-Annual Groundwater Sample Collection Matrix Moen Incorporated Sanford, North Carolina
1Laboratory Analyses Interval Well ID 5Ferrous 6Hexavalent ID 2VOCs 3 1,4-Dioxane 4Metals Iron Chromium Existing Monitoring Wells IW-2 - 1111 1 -111- 1 MW-9 I111- 1 MW-21 D 1 1 1 - 1 S11111 MW-22 I 11111 MW-23 S 1 1 1 - 1 MW-25 S 1 1 - - - MW-26 S 1111 1 MW-28 S 1 1 1 - 1 MW-30 S 1 1 - - - MW-31 S 1 1 1 - 1 MW-33 S 1 1 1 - 1 MW-34 S 1 1 1 - 1 MW-37 S 1111 1 Proposed New Shallow Performance Monitoring Wells MW-39 - 1111 1 MW-40 - 1111 1 MW-41 - 1 1 1 - 1 MW-42 - 1 1 1 - 1 MW-43 - 1 1 1 - 1 Quality Assurance/Quality Control (QA/QC) Field Duplicate 1111 1 Equipment Blank 1-1- - 8Trip Blank 3--- - Total Sample 25 21 20 8 19
Notes:
1 - Groundwater samples to be collected and analyzed in accordance with Appendix A to the Registered Environmental Consultant Program Implementation Guidance . 2 - Volatile organic compounds (VOCs) to be analyzed via US EPA SW846 method 8260B. 3 - 1,4-dioxane to be analyzed via US EPA SW846 method 8260B - selective ion mode (SIM). 4 - Metals to be prepared via SM 3030C and analyzed via US EPA method 6020/7471. 5 - Ferrous Iron to be analyzed via method SM18 3500-FE D. 6 - Hexavalent chromium to be analyzed via US EPA SW846 method 3060 (or equivalent).
GES - July 2011 Page 1 of 1 Moen - Sanford, NC Table 7 Annual Groundwater Sample Collection Matrix Moen Incorporated Sanford, North Carolina
1Laboratory Analyses Interval Well ID 5Ferrous 6Hexavalent ID 2VOCs 3 1,4-Dioxane 4Metals Iron Chromium Existing Monitoring Wells MW-1 - 1 1 - - - IW-2 - 1111 1 -1 1 - - - MW-4 D1 1 - - - MW-7 S 1 1 - - - -111- 1 MW-9 I111- 1 MW-10 - 1 1 - - - MW-11 - 1 1 - - - S1 1 - - - MW-13 I1 1 - - - MW-17 S 1 1 - - - MW-18 - 1 1 - - - MW-20 I 1 1 - - - MW-21 D 1 1 1 - 1 S11111 MW-22 I 11111 D1 1 - - - MW-23 S 1111 1 MW-25 S 1 1 - - - S11111 MW-26 I1 1 - - - MW-28 S 1 1 1 - 1 MW-30 S 1 1 - - - MW-31 S 1 1 1 - 1 MW-32 S 1 1 - - - MW-33 S 1 1 1 - 1 MW-34 S 1 1 1 - 1 MW-37 S 1111 1
GES - July 2011 Page 1 of 2 Moen - Sanford, NC Table 7 Annual Groundwater Sample Collection Matrix Moen Incorporated Sanford, North Carolina
1Laboratory Analyses Interval Well ID 5Ferrous 6Hexavalent ID 2VOCs 3 1,4-Dioxane 4Metals Iron Chromium Proposed New Shallow Performance Monitoring Wells MW-39 - 1111 1 MW-40 - 1111 1 MW-41 - 1 1 1 - 1 MW-42 - 1 1 1 - 1 MW-43 - 1 1 1 - 1 Quality Assurance/Quality Control (QA/QC) Field Duplicate 2211 1 Equipment Blank 2-1- 1 8Trip Blank 5--- - Total Sample Count 43 36 20 9 20
Notes:
1 - Groundwater samples to be collected and analyzed in accordance with Appendix A to the Registered Environmental Consultant Program Implementation Guidance . 2 - Volatile organic compounds (VOCs) to be analyzed via US EPA SW846 method 8260B. 3 - 1,4-dioxane to be analyzed via US EPA SW846 method 8260B - selective ion mode (SIM). 4 - Metals to be prepared via SM 3030C and analyzed via US EPA method 6020/7471. 5 - Ferrous Iron to be analyzed via method SM18 3500-FE D. 6 - Hexavalent chromium to be analyzed via US EPA SW846 method 3060 (or equivalent).
GES - July 2011 Page 2 of 2 Moen - Sanford, NC Table 8 Remedial Confirmation Soil Sample Collection and Analytical Matrix Moen Incorporated Sanford, North Carolina
Number 2Sampling Depth 3Required Laboratory Analyses Area of 1Descriptive Type of of Soil Soil Boring ID Soil Sample ID 0 - 1 5 - 6 Depth of 51,4- 7Hexavalent Concern Name Release 4VOCs 6Metals Borings feet bls feet bls Water Table Dioxane Chromium Remedial Confirmation Soil Samples AOC13-SB10 (0-1) X - - 1 1 1 1 AOC13-SB10 AOC13-SB10 (5-6) - X - 1 1 1 1 AOC13-SB10 (Depth) - - X 1 1 1 1 AOC13-SB11 (0-1) X - - 1 1 1 1 Former Brite AOC-13 Subsurface 3 AOC13-SB11 AOC13-SB11 (5-6) - X - 1 1 1 1 Dip Pit AOC13-SB11 (Depth) - - X 1 1 1 1 AOC13-SB12 (0-1) X - - 1 1 1 1 AOC13-SB12 AOC13-SB12 (5-6) - X - 1 1 1 1 AOC13-SB12 (Depth) - - X 1 1 1 1 AOC16C-SB12 (0-1) X - - 1 1 1 1 AOC16C-SB12 AOC16C-SB12 (5-6) - X - 1 1 1 1 Former Parts AOC16C-SB12 (Depth) - - X 1 1 1 1 Degreaser in AOC16C-SB13 (0-1) X - - 1 1 1 1 AOC-16C Former Tool Subsurface 3 AOC16C-SB13 AOC16C-SB13 (5-6) - X - 1 1 1 1 Room AOC16C-SB13 (Depth) - - X 1 1 1 1 (Cafeteria) AOC16C-SB14 (0-1) X - - 1 1 1 1 AOC16C-SB14 AOC16C-SB14 (5-6) - X - 1 1 1 1 AOC16C-SB14 (Depth) - - X 1 1 1 1 AOC21-SB11 (0-1) X - - 1 1 1 1 AOC21-SB11 AOC21-SB11 (5-6) - X - 1 1 1 1 AOC21-SB11 (Depth) - - X 1 1 1 1 Former Cast AOC21-SB12 (0-1) X - - 1 1 1 1 AOC-21 Bar Surface 3 AOC21-SB12 AOC21-SB12 (5-6) - X - 1 1 1 1 Department AOC21-SB12 (Depth) - - X 1 1 1 1 AOC21-SB13 (0-1) X - - 1 1 1 1 AOC21-SB13 AOC21-SB13 (5-6) - X - 1 1 1 1 AOC21-SB13 (Depth) - - X 1 1 1 1
GES - July 2011 Page 1 of 2 Moen - Sanford, NC Table 8 Remedial Confirmation Soil Sample Collection and Analytical Matrix Moen Incorporated Sanford, North Carolina
Number 2Sampling Depth 3Required Laboratory Analyses Area of 1Descriptive Type of of Soil Soil Boring ID Soil Sample ID 0 - 1 5 - 6 Depth of 51,4- 7Hexavalent Concern Name Release 4VOCs 6Metals Borings feet bls feet bls Water Table Dioxane Chromium Quality Assurance/Quality Control (QA/QC) Field Duplicate - - - 1 1 1 1 QA/QC NA NA NA NA Equipment Blank - - 1 1 1 1 Samples Trip Blank - - - 1 - - - Totals 9 NA NANANANA30292929
Notes:
ID, identification; bls, beneath land surface; NA, not applicable; QA/QC, quality assurance/quality control 1 - See Table 9 of Phase I Remedial Investigation Work Plan for description of Areas of Concern (AOCs). 2 - Soil boring shall be advanced to terminal depth of water table and sampled at 5-foot intervals from 1 feet bls to the water table, and at the water table. 3 - Analytical method requirements provided in Appendix A to the Registered Environmental Consultant Program Implementation Guidance . 4 - U.S. EPA Target Compound List (TCL) volatile organic compounds (VOCs) to be prepped and analyzed via US EPA SW846 methods 5035 and 8260B, respectively. 5 - 1,4-dioxane to be analyzed via US EPA SW846 method 8260B - selective ion mode (SIM). 6 - Total hazardous substance list metals to be prepared by EPA 3050B or 3051, and analyzed via US EPA SW846 method 6020/7471. 7 - Hexavalent chromium to be analyzed via US EPA SW846 method 3060A (or equivalent)
GES - July 2011 Page 2 of 2 Moen - Sanford, NC Moen Incorporated 2609 Cox Mill Road, Sanford, NC July 2011
FIGURES
Remedial Action Plan
Moen Incorporated 2609 Cox Mill Road, Sanford, NC July 2011
ATTACHMENTS
Remedial Action Plan Moen Incorporated 2609 Cox Mill Road, Sanford, NC July 2011
ATTACHMENT A – CERTIFICATION STATEMENTS
Remedial Action Plan
Moen Incorporated 2609 Cox Mill Road, Sanford, NC July 2011
ATTACHMENT B – SITE-SPECIFIC HEALTH AND SAFETEY PLAN
Remedial Action Plan GROUNDWATER & ENVIRONMENTAL SERVICES, INC.
SITE-SPECIFIC HEALTH AND SAFETY PLAN FOR Moen Incorporated 2609 Cox Mill Road Sanford, NC 27330 EMERGENCY PHONE NUMBERS
Local Police 911
Local Fire 911
Local Rescue 911
Local Hospital Name, Number & Address Central Carolina Hospital - Phone: 919-774-2100 1135 Carthage Street Sanford, NC 27330 Directions to Hospital (map attached) Start NW on Cox Mill Road 0.9 miles Continue on Broadway Road 1.1 miles Continue on E. Main Street 0.4 miles Turn right on S. Horner Blvd. 1.8 miles Turn left at Fields Drive 1.0 miles Turn right at Carthage Street 0.1 miles End at 1135 Carthage Street National Response Center (NRC): 1-800-424-8802 The NRC should be contacted in the event of a significant chemical release. Once notified, the NRC will activate a federal response to the spill. Please confirm with the client and project manager to determine if the spill should be reported.
Poison Control Center: 1-800-222-1222 The Poison Control Center should be contacted in the event of accidental poisoning. They will provide information on immediate treatment for the poisoning.
Nearest Telephone: On-site GES Floater Cell Phone Groundwater & Environmental Services, Inc.
Jonathan Waddell Telephone: 866-222-7786 x4245 Site Supervisor Cell Phone: 804-614-2602
Thomas M. Baylis Telephone: 800-458-1077 x124 Director of Corporate Health and Safety Cell Phone: 610-587-1124
Client Representative Samantha Ezell Telephone Number 919-258-4237
State Agency Representative NCDNR Telephone Number 919-791-4200
DO NOT TRANSPORT SERIOUSLY INJURED CALL LOCAL RESCUE
Updated: July 2011 1
ATTACHMENT I
HOSPITAL ROUTE MAPS
Updated: July 2011 2 2609 Cox Mill Rd, Sanford, NC 27332 to 1135 Carthage St, Sanford, NC 27330 - Google... Page 1 of 2
Directions to 1135 Carthage St, Sanford, NC 27330 5.3 mi – about 13 mins Central Carolina Hospital - Phone: 919-774-2100 Loading...
©2011 Google - Map data ©2011 Google -
http://maps.google.com/maps?f=d&source=s_d&saddr=2609+Cox+Mill+Rd,+Sanford,+N... 4/18/2011 2609 Cox Mill Rd, Sanford, NC 27332 to 1135 Carthage St, Sanford, NC 27330 - Google... Page 2 of 2
2609 Cox Mill Rd, Sanford, NC 27332
1. Head northwest on Cox Mill Rd/US-421 Bypass N toward Mt Pisgah Church Rd go 0.9 mi Continue to follow US-421 Bypass N total 0.9 mi About 2 mins 2. Continue onto Broadway Rd go 1.1 mi About 2 mins total 2.0 mi 3. Continue onto E Main St go 0.4 mi total 2.4 mi 4. Turn right at S Horner Blvd go 1.8 mi About 4 mins total 4.2 mi 5. Turn left at Fields Dr go 1.0 mi About 4 mins total 5.2 mi 6. Turn right at Carthage St go 0.1 mi Destination will be on the right total 5.3 mi 1135 Carthage St, Sanford, NC 27330
These directions are for planning purposes only. You may find that construction projects, traffic, weather, or other events may cause conditions to differ from the map results, and you should plan your route accordingly. You must obey all signs or notices regarding your route. Map data ©2011 Google Directions weren't right? Please find your route on maps.google.com and click "Report a problem" at the bottom left.
http://maps.google.com/maps?f=d&source=s_d&saddr=2609+Cox+Mill+Rd,+Sanford,+N... 4/18/2011
TABLE OF CONTENTS
Section Page No. EMERGENCY PHONE NUMBERS...... 1
1.0 INTRODUCTION ...... 6 1.1 APPROVALS ...... 6 1.2 SITE BACKGROUND...... 6 1.3 SCOPE OF WORK...... 6
2.0 PROJECT ORGANIZATION AND RESPONSIBILITIES ...... 7
3.0 OSHA TRAINING REQUIREMENTS ...... 8 3.1 GENERAL TRAINING REQUIREMENTS...... 8 3.2 PRE-ENTRY MEETING...... 8 3.3 FIRST AID/CPR TRAINING ...... 8
4.0 MEDICAL SURVEILLANCE REQUIREMENTS ...... 9 4.1 GENERAL MEDICAL SURVEILLANCE REQUIREMENTS...... 9 4.2 DRUG AND ALCOHOL COMPLIANCE ...... 9 4.3 ACCIDENT / INCIDENT MEDICAL SURVEILLANCE...... 9
5.0 HAZARD ASSESSMENT...... 10 5.1 CHEMICAL HAZARDS...... 10 5.1.1 Contaminant Characterization and Potential Routes of Exposure...... 10 5.1.2 General Chemical Data...... 10 5.2 PHYSICAL HAZARDS...... 10 5.2.1 Slip/Trip/Fall/Cuts ...... 11 5.2.2 Excessive Noise ...... 11 5.2.3 Airborne Particulate (ears, eyes, nose, mouth, inhalation) ...... 11 5.2.4 On-site Traffic...... 11 5.2.5 Ladder Safety...... 11 5.2.6 Air Compressor...... 12 5.2.7 Electrical ...... 12 5.2.8 Power Tools...... 12 5.2.9 Back Strain...... 12 5.2.10 Site Security...... 12 5.2.11 Biological Hazards (insects, snakes, poisonous plants and animals)...... 13 5.2.12 Heat Stress...... 13 5.2.13 Cold Stress...... 14 5.2.14 Confined Space (CS) Entry...... 14
Updated: July 2011 3 5.2.15 Fall Hazards...... 14 5.2.16 Hot Work ...... 14 5.3 RADIOLOGICAL HAZARDS...... 15
6.0 SITE CONTROL MEASURES...... 16 6.1 SITE ZONES...... 16 6.2 COMMUNICATIONS ...... 16
7.0 PERSONAL PROTECTIVE EQUIPMENT ...... 17 7.1 GENERAL...... 17 7.2 LEVEL D PROTECTION...... 17 7.3 MODIFIED LEVEL C PROTECTION...... 17 7.4 LEVEL C PROTECTION...... 17 7.5 LEVEL A AND B PROTECTION...... 18
8.0 DECONTAMINATION ...... 19 8.1 GENERAL...... 19
9.0 EMERGENCY ACTION PLAN ...... 20 9.1 PERSONAL INJURY WITHIN THE EXCLUSION ZONE...... 20 9.2 PERSONAL INJURY WITHIN THE DECONTAMINATION ZONE ...... 20 9.3 PERSONAL INJURY WITHIN THE SUPPORT ZONE...... 21 9.4 FIRE/EXPLOSION...... 21 9.5 PERSONAL PROTECTIVE EQUIPMENT FAILURE ...... 22 9.6 EQUIPMENT FAILURE...... 22
10.0 STANDARD OPERATING SAFETY PROCEDURES, ENGINEERING CONTROLS, AND WORK PRACTICES...... 23 10.1 WORK PERMITS...... 23 10.2 GENERAL SITE RULES...... 23 10.3 ADDITIONAL STANDARD OPERATING SAFETY PROCEDURES ...... 24
EXPOSURE MONITORING PROGRAM ...... 27 REAL-TIME MONITORING ...... 27 ACTION LEVELS...... 27
Updated: July 2011 4
FIGURES
Figure 1 Route to Local Hospital Map
LIST OF ATTACHMENTS
Attachment A Site Maps
Attachment B Exposure Monitoring Program for the Contaminants of Concern
Attachment C Material Safety Data Sheets
Attachment D Job Safety Analysis Sheets and Daily Site Safety Checklists
Attachment E Pre-entry Meeting Notes
Attachment F Sign-off Sheet
Attachment G Incident/Injury Case Management
Updated: July 2011 5 1.0 INTRODUCTION
1.1 APPROVALS
Prepared By: Date: (Benjamin Snyder – Junior Engineer)
Reviewed by: Date: (Jonathan P. Waddell - Project Manager)
Approved By: Date: (Melissa L. Orndorff - Local Health and Safety Officer)
1.2 SITE BACKGROUND Project Name: Moen Incorporated Site Address: 2609 Cox Mill Road, Sanford, North Carolina Nearest Intersection: Cox Mill Road and Broadway Road Township/Municipality: Sanford County: Lee Additional Site Information: Must sign in as a visitor at the Guardhouse and at Main Facility prior to entry.
1.3 SCOPE OF WORK
Task 1 - Utility Markout
Task 2 - Surveying
Task 3 - Remedial Design Soil boring installation and sampling
Task 4 - Performance monitoring well installation and groundwater sample collection
Task 5 - Sediment/ surface water sampling
Task 6 - Vapor implant installation and sampling
Task 7 - Soil and groundwater remediation via in situ chemical oxidation (see HASP Addendum in RAP)
Task 8 -
Task 9 -
Task 10 -
Updated: July 2011 6 2.0 PROJECT ORGANIZATION AND RESPONSIBILITIES
Responsibility Name Task Description
Project Manager Jonathan Waddell Oversee and coordinate all budget and technical aspects for the project
Local Health & Safety Melissa Orndorff Coordinate all Officer health and safety operations for the project site
Site Supervisor GES Personnel Oversee and coordinate all health and safety aspects from the project site
Updated: July 2011 7 3.0 OSHA TRAINING REQUIREMENTS
3.1 GENERAL TRAINING REQUIREMENTS
All personnel performing activities covered by this plan must be trained in accordance with the requirements of 29 CFR 1910.120(e). The Project Manager will verify and document that all GES personnel meet the applicable training requirements prior to the start of site work, including:
OSHA 1910.120 initial 40-hour training OSHA annual eight-hour refresher training within the last year OSHA eight-hour supervisory training for on-site managers and supervisors and GES requirements At least one GES personnel will have American Red Cross (or equivalent) first aid and CPR training, and will be present on-site at all times
Documentation for training certification will be maintained by the Local HSO.
Subcontractors chosen to perform well drilling, excavation, materials disposal, utility installation in trenches, and any other site activities where the potential exists for contact with contaminants must provide written documentation of HAZWOPER training, for each of his employees who will be involved in activities at this site, before the start of work.
3.2 PRE-ENTRY MEETING
A Pre-entry meeting reviewing the Site Specific Health and Safety Plan for all proposed work location personnel shall be held and documented in this HASP and in the site log. This meeting shall be prior to the commencement of any on-site work activities.
3.3 FIRST AID/CPR TRAINING
At least one member of the GES staff assigned to the project will have American Red Cross (or equivalent) first aid and cardiopulmonary resuscitation (CPR) training. At least one trained individual will be present on-site at all times. The Local HSO will maintain all training documentation.
Updated: July 2011 8 4.0 MEDICAL SURVEILLANCE REQUIREMENTS
4.1 GENERAL MEDICAL SURVEILLANCE REQUIREMENTS
All personnel performing activities covered by this plan must be active participants in an ongoing medical monitoring program in accordance with the requirements of 29 CFR 1910.120(f). Subcontractors chosen to perform selected site activities must provide written documentation of such, for each employee who will be involved in activities at this site, before the start of work.
4.2 DRUG AND ALCOHOL COMPLIANCE
All personnel performing activities covered by this plan must have had a negative drug and alcohol screen performed within the last 12 months.
4.3 ACCIDENT / INCIDENT MEDICAL SURVEILLANCE
As a follow-up to a work-related injury, all employees are entitled and encouraged to seek medical attention. All accidents and potential exposures must be reported immediately to the Local HSO, who will coordinate with the CHS to arrange for appropriate medical attention. Depending on the type of incident, it may be critical to perform tests within 24 to 48 hours. Failure to report an injury or incident immediately will result in disciplinary action.
Events surrounding near-miss accidents/injuries will be recorded in the daily log and documented in accordance with the GES Incident Reporting Procedures.
Updated: July 2011 9 5.0 HAZARD ASSESSMENT
5.1 CHEMICAL HAZARDS
5.1.1 Contaminant Characterization and Potential Routes of Exposure
The main routes of exposure for field personnel include:
. Inhalation of contaminant vapors; . Inhalation of contaminated particulate matter; . Ingestion of contaminated material; or . Dermal absorption of contaminated material. . Injection of contaminated material
Site personnel can reduce their exposure potential by:
. Using the proper PPE; . Practicing contamination avoidance; . Following proper decontamination procedures; and . Observing good personnel hygiene.
5.1.2 General Chemical Data
In order to protect site personnel from the hazards associated with site contaminants of concern typically found during projects at Retail Sites, and Exposure Monitoring Program will be implemented to control potential chemical exposures. Attachment B contains this program along with data tables on the contaminants of concern. These tables provide information on each contaminant’s characteristics, such as routes of exposure, health hazards, ionization potentials, exposure limits, etc. All hazardous chemicals brought on-site by GES personnel or its subcontractors will be managed in accordance with 29 CFR 1910.1200 and the GES Hazard Communication Program. This will include: proper labeling, an inventory list of all hazardous materials brought onsite, and a copy of each chemical’s Material Safety Data Sheet (MSDS) will be maintained on-site. Attachment C contains MSDSs of hazardous substances generally used by GES personnel.
5.2 PHYSICAL HAZARDS
A variety of physical hazards may be present, but these hazards are similar to those associated with any field project.
Updated: July 2011 10 5.2.1 Slip/Trip/Fall/Cuts
* Utilize proper housekeeping practices, such as removal of debris and tools from the work area to keep the area clear of trip hazards. * Use caution tape or barricade fencing, where warranted, to keep unauthorized personnel from entering the work area. * Replace manhole covers securely to prevent tripping and vehicle accidents. * Use hose cutters when cutting piping. * Walkways and work spaces will be kept clear of cords, hoses, pipes, etc. that cause trip hazards. * If trip hazards cannot be removed from the work area, they shall be taped down and cones shall be placed to identify the hazard.
5.2.2 Excessive Noise
* Use hearing protection during loud mechanical operations such as drilling, Geoprobing and excavating operations. * Use hearing protection inside a remedial shed when equipment is operating loudly.
5.2.3 Airborne Particulate (ears, eyes, nose, mouth, inhalation)
* Eye protection is to be worn at all times on site. * Respiratory protection is to be worn when site activities cause excessive particulates, such as performing carbon change outs.
5.2.4 On-site Traffic
* Safety vest shall be worn and safety cones placed around the work site as specified in the "GES Traffic Control Procedures.” * Use caution tape or barricade fencing, where warranted, to keep unauthorized personnel from entering the work area.
5.2.5 Ladder Safety
* Ladders must be inspected prior to use. Any damaged ladder will be discarded immediately. * Painted ladders are forbidden. * Never stand on the top step of the ladder. * Extension ladders must extend 36" beyond work area. * Pitch ladders at a 4:1 ratio. * Extension and straight ladders must be tied off. * Fall protection must be worn when working at heights six (6) feet or more above ground.
Updated: July 2011 11 5.2.6 Air Compressor
* Eye protection is to be worn at all times on site. * Hot steam will burn skin upon contact. * Use proper pressure relief valves before performing O&M on an air compressor.
5.2.7 Electrical
* Inspect all electrical equipment and extension cords prior to use. * All electrical circuits and equipment must be grounded in accordance with the NEC regulations. * Equipment producing sparks are not to be used in operating remedial system sheds. * Lockout/Tagout procedures will be in effect if equipment is to be repaired. * Use three-pronged plugs and heavy-duty extension cords. * A GFCI is required when using an extension cord. * Workers must not have wet hands or be standing in water while plugging/unplugging energized equipment. * Plugs and receptacles will be kept out of water (unless they are approved for submersion).
5.2.8 Power Tools
* Equipment will be inspected for defects prior to use. * Eye protection is to be worn at all times on site. * Employees using tools that may subject their hands to an injury, such as cuts, abrasions, punctures, or burns will wear protective gloves. * Loose or frayed clothing, dangling jewelry, or loose long hair will not be worn when working with power tools. * A GFCI will be used with all power tool operations. * Shielding or guarding will be in effect if applicable.
5.2.9 Back Strain
* Utilize proper lifting procedures when loading and unloading heavy equipment. * Bend down at the knees rather than bending the back. * Use a mechanical lifting device or a lifting aid such as hand carts, drum dollies or lift gates when lifting heavy objects.
5.2.10 Site Security
* Do not permit anyone who is not properly trained and outfitted with the appropriate PPE to enter the Exclusion or Contamination Reduction Zones (this includes GES personnel, clients, etc.) * Use caution tape or barricade fencing, where warranted, to keep unauthorized personnel from entering the work area.
Updated: July 2011 12 * On sites where it is believed that security is an issue, two employees will be used for all field work. The “buddy-system” will be in place and the two employees will be in constant communication and within each others line of sight. There will be a cellular phone available to call 911 if a violent condition presents itself. * When acts of violence occur or when an employee(s) feels that they are being placed in a threatening position they must immediately leave the site. * All potential acts of violence or threats by non-GES personnel must be immediately reported to the Site Operations Manager and the Local Health and Safety Officer. The situation will be discussed to determine future action on the site in question. * If any GES employee notices suspicious persons or activities in a GES office or in the vicinity of a work area, he or she should immediately report the observation to his or her supervisor or site operations manager.
5.2.11 Biological Hazards (insects, snakes, poisonous plants and animals)
* Do not touch or contact poisonous plants, such as poison ivy and poison oak. * If available, apply an over-the-counter barrier cream, such as Ivy Block® to prevent contact with plant oils. * Wash hands and arms immediately with soap and water if skin contacts the plants. * Wear long pants with socks pulled over legs to prevent skin contact with plants and insects. * Inspect yourself carefully for insects or ticks after being outdoors. * Spray any wasp/hornet nests with an insect repellant from a safe distance recommended by the product’s manufacturer. * Do not antagonize snakes or wild animals.
5.2.12 Heat Stress
Know and recognize the signs and symptoms of heat-related illnesses, as follows: Heat cramps Heat exhaustion: Cool, moist, pale, or flushed skin Headache Nausea Dizziness, weakness and exhaustion Heat stroke: Red, hot, dry, skin Changes in consciousness Rapid, weak pulse Rapid, shallow breathing * Adjust work schedules to provide time intervals for intake of juices, juice products and water in an area free from contamination.
Updated: July 2011 13 5.2.13 Cold Stress
* Know and recognize the signs and symptoms of cold-related illnesses, as follows: Frostbite: Lack of feeling in the affected area Skin that appears waxy, is cold to the touch or is discolored (flushed, white, yellow or blue) Hypothermia: Shivering Numbness Glassy stare Apathy Loss of consciousness * Have appropriate clothing available and dress in layers to protect against cold weather. * Adjust work schedules to provide sufficient rest periods in a heated area for warming up during operations conducted in cold weather.
5.2.14 Confined Space (CS) Entry
* Confined space entry is prohibited unless authorized by the project manager or local health and safety officer. * All Confined Space Entry procedures must be followed, including and not limited to air monitoring, presence of attendant and permit completion.
5.2.15 Fall Hazards
* OSHA-approved man-lifts and ladders will be used for access to elevated locations. * Employees must wear a safety belt with a lanyard attached to the boom or basket when working from a man-lift. * If the elevated location is inaccessible by a man-lift, CHSSE shall be contacted to determine the appropriate fall protection.
5.2.16 Hot Work
* A hot work permit will be completed prior to the start of the work. * The Site Supervisor will conduct a safety briefing on hot work rules and procedures, and all hot work participants will sign the permit. * Hot work will not be performed if there is a possibility of an explosive atmosphere or an oxygen-enriched atmosphere. * The Site Supervisor will designate a person for fire watch duty, who will have access to a properly rated fire extinguisher and will remain on-duty for one-half hour after the hot work is complete.
Updated: July 2011 14 * All hot work equipment will be inspected daily, prior to use. If the equipment is found to be defective, it will be removed from the site, or tagged with a "Do Not Use" sign until it is repaired. * All welding and cutting personnel will be trained in the safe operation of their equipment.
5.3 RADIOLOGICAL HAZARDS
Based on available site historical information, there are no radiological contaminants of concern at this site. If site-specific potential radiological information becomes available, the hazards will be addressed in an addendum to the HASP.
Updated: July 2011 15 6.0 SITE CONTROL MEASURES
6.1 SITE ZONES
A controlled work area should be established in the immediate vicinity of the site activities covered by this plan. Only those persons who can comply with the requirements of this plan should be allowed into this area during any work activities, which may result in exposure to the hazards associated with the specific task being performed. The work site should be marked off with at least the following items from the GES Traffic Control Procedures: Four (4) traffic cones with flags 50 inches high, caution tape, two (2) work area signs or barricades at the site entrances and a flashing amber light on the company vehicle.
When activities involve invasive activities on sites in which the Project Manager, Local HSO or the CHS have determined the area to be highly-contaminated, a three-zone system will be used to control the potential spread of contamination. For the purpose of this plan, the following definition of terms is provided:
Exclusion Zone - The immediate area of the work activity to be performed or an area fully enclosing the hazards present.
Contamination Reduction Zone - The transition area between the contaminated and uncontaminated area. Decon procedures take place within this zone.
Support Zone - The uncontaminated area where exposure to hazardous conditions, is not anticipated.
6.2 COMMUNICATIONS
Emergency numbers are listed on cover of this HASP. Work will not be conducted on-site without access to a telephone, and site personnel will be informed of its location. If a telephone is not available on site, a cell phone will be made available for emergency use.
Updated: July 2011 16 7.0 PERSONAL PROTECTIVE EQUIPMENT
7.1 GENERAL
The level of protection worn by site personnel will be enforced by the Site Supervisor. Levels of protection may be upgraded or downgraded at the discretion of the Local HSO, or CHS, based on real-time air monitoring data and prior site experience. Any changes in the level of protection will be documented. Levels of protection less than those designated in this HASP must first be approved by the CHS.
7.2 LEVEL D PROTECTION
Level D PPE provides minimal protection against chemical hazards. A respirator is not required. Level D PPE includes:
. Cotton coveralls or long pants and a shirt with sleeves . Reflective safety vest . Safety glasses . Steel-toe/steel-shank work boots . Work gloves . Hearing protection (as required by task) . Hard Hat (as required by task) . Chemical resistant gloves (as required by task)
7.3 MODIFIED LEVEL C PROTECTION
Modified Level C PPE includes the items listed in Section 7.2 above, and the following items:
. Full-face APR or Half-face APR respirator equipped with the appropriate chemical cartridges
7.4 LEVEL C PROTECTION
Level C PPE provides a higher level of respiratory and skin protection against chemical hazards than Level D. Level C PPE includes the items listed in Section 7.2 above, and the following items:
. Poly-coated Tyvek (yellow) or Saranax (shiny white) . Steel-toe/steel-shank work boots and chemical resistant over-boots, or chemical resistant steel-toe/steel shank boots . Inner chemical resistant gloves . Chemical resistant outer gloves
Updated: July 2011 17 . Seal arm, leg, and zipper joints with tape, as required . Half-face or full-face, air-purifying respirator equipped with appropriate cartridges
7.5 LEVEL A AND B PROTECTION
Level A PPE should be worn when the highest level of respiratory and skin protection is needed, or if the contaminants of concern are unknown. Level B PPE should be worn when the highest level of respiratory protection is required, but a lesser level of skin protection is needed. The tasks covered under this HASP do not require the use of Level A or B PPE.
Separate Health and Safety Plans will be developed for Level A/Level B investigations and for Emergency Responses, which may involve the use of Level A and/or Level B health and safety measures.
Updated: July 2011 18 8.0 DECONTAMINATION
8.1 GENERAL
At a minimum, the procedures outlined below shall be followed for decontamination:
. Remove gross contamination from tools, respirator, monitoring equipment, boots, etc., prior to leaving the “exclusion zone”, using paper towels, handi-wipes, etc. . Completely decontaminate soiled equipment in the Contamination Reduction Zone using detergent and water and dispose of all cleaning materials as follows.
1. Due to the small quantity of waste generated during decontamination, it is allowable in most states to dispose of lightly contaminated materials in the site dumpster. It is important, however, to ensure that there is no chance of vapor generation or fluid leaking from the dumpster. At no time are materials containing free product to be disposed of in this manner. In this case, arrangements must be made for use of labeled drums and proper disposal.
2. All decontamination materials including protective sheeting, rags, sorbents, disposable personal protective equipment, and decontamination fluids should be carefully screened with a Photo-ionization Detector (PID) prior to disposal to determine relative levels of contamination.
3. Lightly contaminated decontamination fluids should either be treated via the site treatment system prior to discharge or disposed of via the sanitary sewer system. Highly contaminated decontamination fluids must be stored in labeled drums and proper disposal arrangements must be made.
Dispose of contaminated gloves, Tyvek suits, used cartridges, paper towels, etc., by placing in a plastic bag and discarding in accordance with applicable standards. WASH HANDS AND FACE THOROUGHLY WITH SOAP AND WATER BEFORE LUNCH OR COFFEE BREAKS, AND AS SOON AS PRACTICAL AFTER FINISHING WORK FOR THE DAY. Particular care should be taken to protect any skin injuries. If open wounds exist on hands or forearms, handling chemicals should be restricted or eliminated. SHOWER AS SOON AS POSSIBLE.
Updated: July 2011 19 9.0 EMERGENCY ACTION PLAN
9.1 PERSONAL INJURY WITHIN THE EXCLUSION ZONE
Site operations shall be temporarily halted and all site personnel shall assemble in the Contamination Reduction Zone. The Site Supervisor shall evaluate the nature of the injury and, if indicated by the hazards present on site, the injured person shall be decontaminated to the extent possible prior to movement to the Support Zone.
Contact shall be made for an ambulance and with the designated medical facility (if required). An individual certified in Standard First Aid and Adult CPR may choose to initiate the appropriate first aid. No persons shall reenter the Exclusion Zone until:
a. The conditions resulting in the emergency have been corrected; a. The hazards have been reassessed; b. The Site Safety Plan has been reviewed; and d. Site personnel have been briefed on any changes in the Site Safety Plan.
9.2 PERSONAL INJURY WITHIN THE DECONTAMINATION ZONE
The Site Supervisor shall evaluate the nature of the injury and, if indicated by the hazards present on site, the injured person shall be decontaminated to the extent possible prior to movement to the Support Zone.
Contact shall be made for an ambulance and with the designated medical facility (if required). An individual certified in Standard First Aid and Adult CPR may choose to initiate the appropriate first aid.
If the injury increases risk to other site workers, all site personnel shall move to the Contamination Reduction Zone and site activities will stop until the risks can be assessed and either removed or minimized.
Updated: July 2011 20 9.3 PERSONAL INJURY WITHIN THE SUPPORT ZONE
The Site Supervisor will assess the nature of the injury and determine if the cause of injury or loss of the injured person will affect continuation of site operations. If the injury will not affect the safety or performance of other site workers, operations may continue, with the person certified in first aid initiating the appropriate first aid and necessary follow up as stated above.
If the injury increases risk to other site workers, all site personnel shall move to the Contamination Reduction Zone and site activities will stop until the risks can be assessed and either removed or minimized.
9.4 FIRE/EXPLOSION
If a fire is observed in the incipient phase (i.e., when it begins) and if the site personnel witnessing the fire feel secure in attempting to control the fire, the individual can attempt to extinguish the fire by using the onsite fire extinguisher. The fire extinguisher should be a 10 or 20 pound (lb) dry chemical, Class A, B, and C extinguisher and is adequate for paper and wood based products (A), flammable and combustible liquids (B), and electrical (C) type fires.
If there is no fire extinguisher available or if site personnel do not feel secure in attempting to extinguish the fire, site personnel shall perform the following:
Secure the site, if possible. Evacuate the area using the nearest safe pathway from the area. Proceed to the nearest phone and call 911 and provide the emergency operator all required information. This will activate the emergency response system.
If more than one individual is on the site team, the individual activating the evacuation plan shall verbally communicate to the other site personnel that there is an emergency condition and that they should evacuate from the work area. If contact cannot be made verbally with the other site personnel, any of the following systems can be used as long as the system is audible above background noise. The system can be the site vehicle horn, a whistle, an air horn, or other acceptable device. The system used for initiating an evacuation from the site shall be
Updated: July 2011 21 discussed during the tailgate meeting with the other site personnel prior to beginning the workday. The system that is decided upon shall be documented in the site logbook.
If an explosion or other unsafe condition occurs that the site supervisor had determined will place the other site personnel at risk, then the evacuation system described above should be activated immediately.
9.5 PERSONAL PROTECTIVE EQUIPMENT FAILURE
If any site worker experiences a failure or alteration of protective equipment that affects the protection factor that person and his/her buddy, if applicable, shall immediately leave the Exclusion Zone. Reentry shall not be permitted until the equipment has been repaired or replaced.
9.6 EQUIPMENT FAILURE
If any other equipment on site fails to operate properly, the Site Supervisor shall be notified and then determine the effect of this failure on continuing operations. If the failure will affect the safety of personnel, all personnel shall leave the Exclusion Zone until the situation is evaluated and appropriate actions are taken.
Updated: July 2011 22 10.0 STANDARD OPERATING SAFETY PROCEDURES, ENGINEERING CONTROLS, AND WORK PRACTICES
10.1 WORK PERMITS
Work permits will be required for confined space entry, and hot work. These permits must be obtained from the Local Health and Safety Officer prior to site work.
10.2 GENERAL SITE RULES
The following general site rules apply to all personnel while on the site:
Before daily site operation begins, the daily site safety checklist will be completed, the subcontractor’s training documentation will be reviewed (as required by section 3 of this plan), and a pre-entry briefing will be held to review the site's health and safety plan concerns and emergency procedures. This meeting will be registered in this health and safety plan. Attendance will be documented.
One site worker will be assigned to keep the daily log for all health and safety- specific site activities, unless otherwise specified.
• All personnel will wear Steel-toe safety boots. Hard hats will be worn when working near heavy equipment (drill rigs, excavating equipment, etc.), when individuals are working overhead, or when required by the client.
Eye protection and reflective safety vests will be worn at all times while on site.
Possession of alcohol or illegal substances on the job site or consumption during hours of site operation is strictly prohibited.
Food and/or beverages are not permitted in the site's Exclusion or Contamination Reduction Zones. Food and/or beverages will be permitted in the Support Zone, if proper decontamination procedures are being followed.
Smoking is not permitted on site. Chewing tobacco, snuff, application of cosmetics and/or lip balm is not permitted in the site's Exclusion or Contamination Reduction Zones.
Updated: July 2011 23 A change in level of protection will be based on air monitoring equipment readings taken in the breathing zone.
Field personnel will use air monitoring equipment and not their nose to determine site contamination (i.e., sniffing sampled soils or water in jars, confined spaces, open bore holes or trenches, etc.). Odors detected during the course of standard operating procedures, however, should be noted in the daily log.
Field personnel should not stand with their head directly over a well when it is being opened. First aid kit(s) and a fire extinguisher(s) will be available in all company vehicles and/or within 50 feet of the working area.
Note: Hotwork activities require that a person onsite shall act as a fire watch with a Class A, B, C dry chemical extinguisher within 10 feet of the activity, and all required Hotwork requirements are satisfied.
Any revisions to the final Site-Specific Health and Safety Plan must be reviewed by the Project/Case Manager and approved by the Local Health and Safety Officer or a Principal Hydro-geologist, at a minimum.
10.3 ADDITIONAL STANDARD OPERATING SAFETY PROCEDURES
See Attachments.
Updated: July 2011 24
ATTACHMENT A
SITE MAPS
Updated: July 2011
ATTACHMENT B
EXPOSURE MONITORING PROGRAM FOR THE CONTAMINANTS OF CONCERN
Updated: July 2011
EXPOSURE MONITORING PROGRAM
REAL-TIME MONITORING Photo-ionization Detector (PID): Real-time monitoring for volatile organic compounds (VOCs) will be conducted using a photo-ionization detector (PID). The PID will be used to monitor employee breathing zones during all invasive activities. Table 1 lists PID action levels and response requirements
Combustible Gas Indicator/Oxygen Level Meter: Real-time monitoring for combustible gases and oxygen levels will be conducted using a Combustible Gas Indicator (CGI)/Oxygen Level Meter. The CGI will test for the presence of combustible gases by continuously monitoring the lower explosive limit (LEL) of organic vapors. The CGI will be used to monitor the LEL prior to, and during, Confined Space (CS) entries and during work near an excavation in contaminated soil. The Oxygen Level Meter will detect an oxygen-deficient or oxygen-enriched atmosphere, and will be used prior to, and during, all CS entry activities. Table 2 lists CGI and Oxygen Level Meter action levels and response requirements.
. Calibration of Real-Time Monitoring Equipment: Monitoring and calibration protocols will be performed in accordance with the manufacturer's guidelines. Calibration will be performed, at a minimum, prior to each day's use.
. Calibration logs will be maintained by the Local HSO.
ACTION LEVELS
Tables 1 and 2 list the action levels and response requirements for a PID and CGI/Oxygen Level Meter. Changing levels of protection, upgrading respiratory protection, or changing work practices is based on maintaining the upper limit of the action level for approximately 10 minutes sustained in the breathing zone (i.e., a non-transient reading) or at the discretion of the Site Supervisor. If changes in protection levels are required, the HSO will notify the Local HSO or the CHS.
Updated: July 2011 TABLE 1 OVM ACTION LEVELS Meter Response Action Required PID response <5 units above No respiratory protection required (i.e., Level D) background PID response >5 units above If medically qualified, fit tested and trained to wear background (Bkgd) and < 50 respiratory protection, then upgrade to Modified units above Bkgd. Level C, half-face respiratory protection; investigate the cause of elevated VOC measurements. If not medically qualified to wear respiratory protection, leave work zone and contact office PID response >50 units and < If medically qualified, fit tested and trained to wear 250 units above Bkgd. respiratory protection, then upgrade to Level C, full- face respiratory protection; investigate the cause of elevated VOC measurements. If not medically qualified to wear respiratory protection, leave work zone and contact office. PID response > 250 above Retreat from site* Bdgd. *Note 1: If a retreat becomes necessary, the Local HSO or CHS will be consulted in regard to adding mechanical ventilation or possible changes in work practices. Work will not resume until appropriate corrective measures are implemented. *Note 2: Because direct reading instruments can not indicate or are not compound specific, concentrations shown on the instruments shall be related to units above background and not parts per million (ppm).
TABLE 2 CGI/OXYGEN LEVEL METER ACTION LEVELS Meter Response Action
CGI response < 10 % LEL Continue normal operations.
CGI response > 10 % and Eliminate all sources of ignition from the <20 % LEL work area; implement continuous monitoring. However if work is being done in a confined space, retreat from work area.* CGI response > 20 % LEL Discontinue operations; allow to vent; retreat from work area.* Oxygen level < 19.5% Retreat from work area.* Oxygen level > 23.5% Retreat from work area.*
Updated: July 2011
TABLE 3 MATERIALS OF CONCERN OSHA TWA ACGIH TLV IP Contaminant (ppm) (ppm) Hazards Entry Routes (eV) Inhalation, ingestion, 1,1,1-TCA 350 350 1,2,3,4,6,7,10 eye or skin contact. +11 1,1,2-TCA 10 10 1,2,3,4,5,6,7,10 Skin contact. +11 Inhalation, ingestion, 1,1-DCA 100 100 1,2,3,5,6,7,10 eye or skin contact. +11.06 1,2-DCA 50 10 1,2,3,4,5,6,7,8,10 +11.04 PCE 100 25 1,2,3,4,5,6,7,8,9,10 +9.32 TCE 100 50 1,2,4,5,6,7,10 Inhalation. +9.47 Inhalation, ingestion, Cis 1,2-DCE 200 200 1,2,3,6,8,10 eye or skin contact. +9.66 Trans 1,2-DCE 200 200 1,2,3 Inhalation. +9.65 1,1-DCE 5 5 1,2,3,4,5,6,7,10 +9.79 Vinyl chloride 1 1 1,2,3,4,5,7,8,9,10 +9.99 Inhalation, ingestion, 1,4-dioxane 100 25 2,6,7 eye or skin contact. +9.19
TWA = Time Weighted Average in parts per million (ppm) C = Ceiling IP = Ionization Potential TLV = Threshold Limit Values 1 = irritant to skin 6 = may cause nausea and vomiting 2 = irritant to eyes 7 = may cause liver and kidney damage 3 = irritant to respiratory system 8 = irritant to GI tract 4 = may cause headache 9 = carcinogen/possible carcinogen 5 = may cause dizziness, lightheadedness 10 = may cause damage to CNS
*Note: If a retreat becomes necessary, the Local HSO or CHS will be consulted about adding mechanical ventilation, or possible changes in work practices.
Updated: July 2011
ATTACHMENT C
SITE MATERIAL SAFETY DATA SHEETS (MSDS)
Updated: July 2011 Material Safety Data Sheet 1,1-Dichloroethane MSDS
Section 1: Chemical Product and Company Identification Product Name: 1,1-Dichloroethane Contact Information:
Catalog Codes: SLD3280 Sciencelab.com, Inc. 14025 Smith Rd. CAS#: 75-34-3 Houston, Texas 77396 US Sales: 1-800-901-7247 RTECS: KI0175000 International Sales: 1-281-441-4400 TSCA: TSCA 8(b) inventory: 1,1-Dichloroethane Order Online: ScienceLab.com
CI#: Not available. CHEMTREC (24HR Emergency Telephone), call: 1-800-424-9300 Synonym: International CHEMTREC, call: 1-703-527-3887 Chemical Name: 1,1-Dichloroethane For non-emergency assistance, call: 1-281-441-4400 Chemical Formula: C2-H4-Cl2
Section 2: Composition and Information on Ingredients Composition: Name CAS # % by Weight {1,1-}Dichloroethane 75-34-3 100
Toxicological Data on Ingredients: 1,1-Dichloroethane: ORAL (LD50): Acute: 725 mg/kg [Rat].
Section 3: Hazards Identification Potential Acute Health Effects: Hazardous in case of skin contact (irritant), of eye contact (irritant), of ingestion, of inhalation.
Potential Chronic Health Effects: CARCINOGENIC EFFECTS: Classified 2 (Reasonably anticipated.) by NTP. A4 (Not classifiable for human or animal.) by ACGIH. MUTAGENIC EFFECTS: Not available. TERATOGENIC EFFECTS: Not available. DEVELOPMENTAL TOXICITY: Classified Development toxin [POSSIBLE]. The substance is toxic to kidneys, lungs, liver, central nervous system (CNS). Repeated or prolonged exposure to the substance can produce target organs damage.
Section 4: First Aid Measures Eye Contact: Check for and remove any contact lenses. Do not use an eye ointment. Seek medical attention.
p. 1 Skin Contact: After contact with skin, wash immediately with plenty of water. Gently and thoroughly wash the contaminated skin with running water and non-abrasive soap. Be particularly careful to clean folds, crevices, creases and groin. Cover the irritated skin with an emollient. If irritation persists, seek medical attention. Wash contaminated clothing before reusing.
Serious Skin Contact: Wash with a disinfectant soap and cover the contaminated skin with an anti-bacterial cream. Seek immediate medical attention.
Inhalation: Allow the victim to rest in a well ventilated area. Seek immediate medical attention.
Serious Inhalation: Evacuate the victim to a safe area as soon as possible. Loosen tight clothing such as a collar, tie, belt or waistband. If breathing is difficult, administer oxygen. If the victim is not breathing, perform mouth-to-mouth resuscitation. Seek medical attention.
Ingestion: Do not induce vomiting. Examine the lips and mouth to ascertain whether the tissues are damaged, a possible indication that the toxic material was ingested; the absence of such signs, however, is not conclusive. Loosen tight clothing such as a collar, tie, belt or waistband. If the victim is not breathing, perform mouth-to-mouth resuscitation. Seek immediate medical attention.
Serious Ingestion: Not available.
Section 5: Fire and Explosion Data Flammability of the Product: Flammable.
Auto-Ignition Temperature: 458°C (856.4°F)
Flash Points: CLOSED CUP: -17°C (1.4°F). OPEN CUP: -6°C (21.2°F).
Flammable Limits: LOWER: 5.6% UPPER: 11.4%
Products of Combustion: These products are carbon oxides (CO, CO2), halogenated compounds.
Fire Hazards in Presence of Various Substances: Not available.
Explosion Hazards in Presence of Various Substances: Risks of explosion of the product in presence of mechanical impact: Not available. Risks of explosion of the product in presence of static discharge: Not available.
Fire Fighting Media and Instructions: Flammable liquid. SMALL FIRE: Use DRY chemical powder. LARGE FIRE: Use alcohol foam, water spray or fog.
Special Remarks on Fire Hazards: Not available.
Special Remarks on Explosion Hazards: Not available.
Section 6: Accidental Release Measures Small Spill: Absorb with an inert material and put the spilled material in an appropriate waste disposal.
Large Spill: Flammable liquid. Keep away from heat. Keep away from sources of ignition. Stop leak if without risk. Absorb with DRY earth,
p. 2 sand or other non-combustible material. Do not touch spilled material. Prevent entry into sewers, basements or confined areas; dike if needed. Eliminate all ignition sources. Be careful that the product is not present at a concentration level above TLV. Check TLV on the MSDS and with local authorities.
Section 7: Handling and Storage Precautions: Keep locked up Keep away from heat. Keep away from sources of ignition. Ground all equipment containing material. Do not ingest. Do not breathe gas/fumes/ vapour/spray. Wear suitable protective clothing In case of insufficient ventilation, wear suitable respiratory equipment If ingested, seek medical advice immediately and show the container or the label. Avoid contact with skin and eyes Keep away from incompatibles such as oxidizing agents, alkalis.
Storage: Flammable materials should be stored in a separate safety storage cabinet or room. Keep away from heat. Keep away from sources of ignition. Keep container tightly closed. Keep in a cool, well-ventilated place. Ground all equipment containing material. A refrigerated room would be preferable for materials with a flash point lower than 37.8°C (100°F).
Section 8: Exposure Controls/Personal Protection Engineering Controls: Provide exhaust ventilation or other engineering controls to keep the airborne concentrations of vapors below their respective threshold limit value. Ensure that eyewash stations and safety showers are proximal to the work-station location.
Personal Protection: Splash goggles. Lab coat. Vapor respirator. Be sure to use an approved/certified respirator or equivalent. Gloves.
Personal Protection in Case of a Large Spill: Splash goggles. Full suit. Vapor respirator. Boots. Gloves. A self contained breathing apparatus should be used to avoid inhalation of the product. Suggested protective clothing might not be sufficient; consult a specialist BEFORE handling this product.
Exposure Limits: TWA: 100 STEL: 250 (ppm) from ACGIH (TLV) [1999] TWA: 100 (ppm) from OSHA (PEL) Australia: TWA: 200 (ppm) Consult local authorities for acceptable exposure limits.
Section 9: Physical and Chemical Properties Physical state and appearance: Liquid. (Oily liquid.)
Odor: Chloroform like odor (Slight.)
Taste: Not available.
Molecular Weight: 98.96 g/mole
Color: Colorless. pH (1% soln/water): Not available.
Boiling Point: 57.3°C (135.1°F)
Melting Point: -96.9°C (-142.4°F)
p. 3 Critical Temperature: 261.5°C (502.7°F)
Specific Gravity: 1.175 (Water = 1)
Vapor Pressure: 180 mm of Hg (@ 20°C)
Vapor Density: 3.44 (Air = 1)
Volatility: Not available.
Odor Threshold: 120 ppm
Water/Oil Dist. Coeff.: Not available.
Ionicity (in Water): Not available.
Dispersion Properties: Partially dispersed in diethyl ether. See solubility in water, diethyl ether.
Solubility: Partially soluble in diethyl ether.
Section 10: Stability and Reactivity Data Stability: The product is stable.
Instability Temperature: Not available.
Conditions of Instability: Not available.
Incompatibility with various substances: Reactive with oxidizing agents, alkalis.
Corrosivity: Corrosive in presence of aluminum.
Special Remarks on Reactivity: Not available.
Special Remarks on Corrosivity: Will attack some forms of plastic and rubber
Polymerization: No.
Section 11: Toxicological Information Routes of Entry: Absorbed through skin. Eye contact. Inhalation. Ingestion.
Toxicity to Animals: Acute oral toxicity (LD50): 725 mg/kg [Rat].
Chronic Effects on Humans: CARCINOGENIC EFFECTS: Classified 2 (Reasonably anticipated.) by NTP. A4 (Not classifiable for human or animal.) by ACGIH. DEVELOPMENTAL TOXICITY: Classified Development toxin [POSSIBLE]. The substance is toxic to kidneys, lungs, liver, central nervous system (CNS).
Other Toxic Effects on Humans: Hazardous in case of skin contact (irritant), of ingestion, of inhalation.
Special Remarks on Toxicity to Animals: Not available.
Special Remarks on Chronic Effects on Humans: Not available.
Special Remarks on other Toxic Effects on Humans: Not available.
p. 4 Section 12: Ecological Information Ecotoxicity: Not available.
BOD5 and COD: Not available.
Products of Biodegradation: Possibly hazardous short term degradation products are not likely. However, long term degradation products may arise.
Toxicity of the Products of Biodegradation: The products of degradation are as toxic as the product itself.
Special Remarks on the Products of Biodegradation: Not available.
Section 13: Disposal Considerations Waste Disposal:
Section 14: Transport Information DOT Classification: CLASS 3: Combustible liquid with a flash point greater than 37.8C (100F). Marine pollutant
Identification: : 1,1-Dichloroethane : UN2362 PG: II
Special Provisions for Transport: Not available.
Section 15: Other Regulatory Information Federal and State Regulations: California prop. 65 (no significant risk level): 1,1-Dichloroethane California prop. 65: This product contains the following ingredients for which the State of California has found to cause cancer which would require a warning under the statute: 1,1-Dichloroethane Rhode Island RTK hazardous substances: 1,1-Dichloroethane Pennsylvania RTK: 1,1-Dichloroethane Florida: 1,1-Dichloroethane Minnesota: 1,1-Dichloroethane Massachusetts RTK: 1,1-Dichloroethane New Jersey: 1,1-Dichloroethane New Jersey spill list: 1,1-Dichloroethane TSCA 8(b) inventory: 1,1-Dichloroethane TSCA 8(a) PAIR: 1,1-Dichloroethane TSCA 8(d) H and S data reporting: 1,1-Dichloroethane: June 1999 TSCA 12(b) one time export: 1,1-Dichloroethane SARA 313 toxic chemical notification and release reporting: 1,1-Dichloroethane: 1% CERCLA: Hazardous substances.: 1,1-Dichloroethane: 1000 lbs. (453.6 kg)
Other Regulations: OSHA: Hazardous by definition of Hazard Communication Standard (29 CFR 1910.1200). EINECS: This product is on the European Inventory of Existing Commercial Chemical Substances.
Other Classifications:
WHMIS (Canada): CLASS B-2: Flammable liquid with a flash point lower than 37.8°C (100°F). CLASS D-2B: Material causing other toxic effects (TOXIC).
DSCL (EEC):
p. 5 R11- Highly flammable. R22- Harmful if swallowed. R37/38- Irritating to respiratory system and skin. R41- Risk of serious damage to eyes. R52- Harmful to aquatic organisms.
HMIS (U.S.A.):
Health Hazard: 2
Fire Hazard: 3
Reactivity: 0
Personal Protection: h
National Fire Protection Association (U.S.A.):
Health: 2
Flammability: 3
Reactivity: 0
Specific hazard:
Protective Equipment: Gloves. Lab coat. Vapor respirator. Be sure to use an approved/certified respirator or equivalent. Wear appropriate respirator when ventilation is inadequate. Splash goggles.
Section 16: Other Information References: Not available.
Other Special Considerations: Not available.
Created: 10/09/2005 05:07 PM
Last Updated: 11/06/2008 12:00 PM
The information above is believed to be accurate and represents the best information currently available to us. However, we make no warranty of merchantability or any other warranty, express or implied, with respect to such information, and we assume no liability resulting from its use. Users should make their own investigations to determine the suitability of the information for their particular purposes. In no event shall ScienceLab.com be liable for any claims, losses, or damages of any third party or for lost profits or any special, indirect, incidental, consequential or exemplary damages, howsoever arising, even if ScienceLab.com has been advised of the possibility of such damages.
p. 6 Page 1 of 8 MATERIAL SAFETY DATA SHEET
1. CHEMICAL PRODUCT AND COMPANY IDENTIFICATION
MATHESON TRI-GAS, INC. Emergency Contact: 150 Allen Road Suite 302 CHEMTREC 1-800-424-9300 Basking Ridge, New Jersey 07920 Calls Originating Outside the US: Information: 1-800-416-2505 703-527-3887 (Collect Calls Accepted)
SUBSTANCE: VINYLIDENE CHLORIDE
TRADE NAMES/SYNONYMS: MTG MSDS 239; 1,1-DICHLOROETHENE; 1,1-DICHLOROETHYLENE; VDC; VINYLIDENE CHLORIDE MONOMER; VINYLIDENE DICHLORIDE; VINYLIDENE CHLORIDE, INHIBITED; RCRA U078; UN 1303; C2H2CL2; MAT25070; RTECS KV9275000
CHEMICAL FAMILY: halogens
CREATION DATE: Jan 24 1989 REVISION DATE: Dec 11 2008
2. COMPOSITION, INFORMATION ON INGREDIENTS
COMPONENT: VINYLIDENE CHLORIDE CAS NUMBER: 75-35-4 PERCENTAGE: >99.9
COMPONENT: 4-METHOXYPHENOL CAS NUMBER: 150-76-5 PERCENTAGE: 0.02000
3. HAZARDS IDENTIFICATION
NFPA RATINGS (SCALE 0-4): HEALTH=2 FIRE=4 REACTIVITY=2
EMERGENCY OVERVIEW: COLOR: colorless PHYSICAL FORM: volatile liquid ODOR: faint odor, sweet odor MAJOR HEALTH HAZARDS: harmful if swallowed, respiratory tract irritation, skin irritation, eye irritation, central nervous system depression Page 2 of 8 PHYSICAL HAZARDS: Flammable liquid and vapor. Vapor may cause flash fire. May polymerize. Containers may rupture or explode. May form peroxides during prolonged storage.
POTENTIAL HEALTH EFFECTS: INHALATION: SHORT TERM EXPOSURE: irritation, symptoms of drunkenness, lung congestion, liver damage, convulsions LONG TERM EXPOSURE: kidney damage, tumors SKIN CONTACT: SHORT TERM EXPOSURE: irritation (possibly severe) LONG TERM EXPOSURE: same as effects reported in short term exposure EYE CONTACT: SHORT TERM EXPOSURE: irritation (possibly severe), eye damage LONG TERM EXPOSURE: same as effects reported in short term exposure INGESTION: SHORT TERM EXPOSURE: symptoms of drunkenness, liver damage LONG TERM EXPOSURE: same as effects reported in short term exposure
4. FIRST AID MEASURES
INHALATION: If adverse effects occur, remove to uncontaminated area. Give artificial respiration if not breathing. Get immediate medical attention.
SKIN CONTACT: Wash skin with soap and water for at least 15 minutes while removing contaminated clothing and shoes. Get medical attention, if needed. Thoroughly clean and dry contaminated clothing and shoes before reuse.
EYE CONTACT: Flush eyes with plenty of water for at least 15 minutes. Then get immediate medical attention.
INGESTION: If a large amount is swallowed, get medical attention.
5. FIRE FIGHTING MEASURES
FIRE AND EXPLOSION HAZARDS: Severe fire hazard. The vapor is heavier than air. Vapors or gases may ignite at distant ignition sources and flash back. Vapor/air mixtures are explosive above flash point. Containers may rupture or explode if exposed to heat.
EXTINGUISHING MEDIA: alcohol-resistant foam, carbon dioxide, regular dry chemical, water
Large fires: Use alcohol-resistant foam or flood with fine water spray.
FIRE FIGHTING: Move container from fire area if it can be done without risk. Cool containers with water spray until well after the fire is out. Stay away from the ends of tanks. For fires in cargo or storage area: Cool Page 3 of 8 containers with water from unmanned hose holder or monitor nozzles until well after fire is out. If this is impossible then take the following precautions: Keep unnecessary people away, isolate hazard area and deny entry. Let the fire burn. Withdraw immediately in case of rising sound from venting safety device or any discoloration of tanks due to fire. For tank, rail car or tank truck: Evacuation radius: 800 meters (1/2 mile). Do not attempt to extinguish fire unless flow of material can be stopped first. Flood with fine water spray. Do not scatter spilled material with high-pressure water streams. Cool containers with water spray until well after the fire is out. Apply water from a protected location or from a safe distance. Avoid inhalation of material or combustion by-products. Stay upwind and keep out of low areas. Water may be ineffective.
FLASH POINT: 14 F (-10 C) LOWER FLAMMABLE LIMIT: 5.6% UPPER FLAMMABLE LIMIT: 11.4% AUTOIGNITION: 855 F (457 C) FLAMMABILITY CLASS (OSHA): IA
6. ACCIDENTAL RELEASE MEASURES
AIR RELEASE: Reduce vapors with water spray. Stay upwind and keep out of low areas.
SOIL RELEASE: Dig holding area such as lagoon, pond or pit for containment. Dike for later disposal. Absorb with sand or other non-combustible material.
WATER RELEASE: Collect with absorbent into suitable container. Collect spilled material using mechanical equipment.
OCCUPATIONAL RELEASE: Avoid heat, flames, sparks and other sources of ignition. Remove sources of ignition. Stop leak if possible without personal risk. Reduce vapors with water spray. Small spills: Absorb with sand or other non- combustible material. Collect spilled material in appropriate container for disposal. Large spills: Dike for later disposal. Keep unnecessary people away, isolate hazard area and deny entry. Stay upwind and keep out of low areas. Notify Local Emergency Planning Committee and State Emergency Response Commission for release greater than or equal to RQ (U.S. SARA Section 304). If release occurs in the U.S. and is reportable under CERCLA Section 103, notify the National Response Center at (800)424-8802 (USA) or (202)426- 2675 (USA).
7. HANDLING AND STORAGE
STORAGE: Store and handle in accordance with all current regulations and standards. Subject to storage regulations: U.S. OSHA 29 CFR 1910.106. Grounding and bonding required. Store in a cool, dry place. Store in a well-ventilated area. Keep in the dark. Keep separated from incompatible substances. Store outside or in a detached building. Store with flammable liquids. Store in a tightly closed container. Containers must have overpressure release device. Avoid heat, flames, sparks and other sources of ignition. Keep separated Page 4 of 8 from incompatible substances. Monitor inhibitor content. Avoid exposure to low temperatures or freezing. May form explosive peroxides. Store in a tightly closed container. Avoid contact with light. Store in a cool, dry place. Monitor inhibitor content. Do not evaporate or distill to dryness. Keep separated from incompatible substances.
8. EXPOSURE CONTROLS, PERSONAL PROTECTION
EXPOSURE LIMITS: VINYLIDENE CHLORIDE: 1 ppm (4 mg/m3) OSHA TWA (vacated by 58 FR 35338, June 30, 1993) 5 ppm ACGIH TWA NIOSH TWA (lowest feasible concentration)
VENTILATION: Provide local exhaust ventilation system. Ventilation equipment should be explosion- resistant if explosive concentrations of material are present. Ensure compliance with applicable exposure limits.
EYE PROTECTION: Wear splash resistant safety goggles. Provide an emergency eye wash fountain and quick drench shower in the immediate work area.
CLOTHING: Wear appropriate chemical resistant clothing.
GLOVES: Wear appropriate chemical resistant gloves.
RESPIRATOR: The following respirators and maximum use concentrations are drawn from NIOSH and/or OSHA. At any detectable concentration - Any self-contained breathing apparatus that has a full facepiece and is operated in a pressure-demand or other positive-pressure mode. Any supplied-air respirator with a full facepiece that is operated in a pressure-demand or other positive- pressure mode in combination with an auxiliary self-contained breathing apparatus operated in pressure- demand or other positive-pressure mode. Escape - Any air-purifying full-facepiece respirator (gas mask) with a chin-style, front-mounted or back-mounted organic vapor canister. Any appropriate escape-type, self-contained breathing apparatus. For Unknown Concentrations or Immediately Dangerous to Life or Health - Any supplied-air respirator with a full facepiece that is operated in a pressure-demand or other positive- pressure mode in combination with an auxiliary self-contained breathing apparatus operated in pressure- demand or other positive-pressure mode. Any self-contained breathing apparatus that has a full facepiece and is operated in a pressure-demand or other positive-pressure mode. Page 5 of 8
9. PHYSICAL AND CHEMICAL PROPERTIES
PHYSICAL STATE: liquid COLOR: colorless PHYSICAL FORM: volatile liquid ODOR: faint odor, sweet odor MOLECULAR WEIGHT: 96.64 MOLECULAR FORMULA: C2-H2-CL2 BOILING POINT: 86-90 F (30-32 C) FREEZING POINT: -188 F (-122 C) VAPOR PRESSURE: 400 mmHg @ 14.8 C VAPOR DENSITY (air=1): 3.4 SPECIFIC GRAVITY (water=1): 1.213 WATER SOLUBILITY: 0.04% @ 20 C PH: Not available VOLATILITY: Not available ODOR THRESHOLD: 500 ppm EVAPORATION RATE: Not available COEFFICIENT OF WATER/OIL DISTRIBUTION: Not available SOLVENT SOLUBILITY: Soluble: organic solvents
10. STABILITY AND REACTIVITY
REACTIVITY: May form explosive peroxides. Avoid contact with temperatures above -40 C. Avoid contact with heat, air, light or moisture and monitor inhibitor content. May polymerize. Closed containers may rupture violently.
CONDITIONS TO AVOID: Avoid heat, flames, sparks and other sources of ignition. Containers may rupture or explode if exposed to heat.
INCOMPATIBILITIES: metals, acids, oxidizing materials
HAZARDOUS DECOMPOSITION: Thermal decomposition products: phosgene, halogenated compounds, oxides of carbon
POLYMERIZATION: May polymerize. Avoid contact with heat or light and monitor inhibitor content.
11. TOXICOLOGICAL INFORMATION
VINYLIDENE CHLORIDE: TOXICITY DATA: 10000 mg/m3 inhalation-rat LC50; 200 mg/kg oral-rat LD50 CARCINOGEN STATUS: IARC: Human Inadequate Evidence, Animal Limited Evidence, Group 3; Page 6 of 8 ACGIH: A4 -Not Classifiable as a Human Carcinogen LOCAL EFFECTS: Irritant: inhalation, skin, eye ACUTE TOXICITY LEVEL: Toxic: inhalation, ingestion TARGET ORGANS: central nervous system, liver TUMORIGENIC DATA: Available. MUTAGENIC DATA: Available. REPRODUCTIVE EFFECTS DATA: Available.
12. ECOLOGICAL INFORMATION
ECOTOXICITY DATA: FISH TOXICITY: 74000 ug/L 96 hour(s) LC50 (Mortality) Bluegill (Lepomis macrochirus)
INVERTEBRATE TOXICITY: 224000 ug/L 96 hour(s) LC50 (Mortality) Opossum shrimp (Mysidopsis bahia)
ALGAL TOXICITY: >712000 ug/L 96 hour(s) EC50 (Photosynthesis) Diatom (Skeletonema costatum)
ENVIRONMENTAL SUMMARY: Moderately toxic to aquatic life.
13. DISPOSAL CONSIDERATIONS
Subject to disposal regulations: U.S. EPA 40 CFR 262. Hazardous Waste Number(s): U078. Hazardous Waste Number(s): D029. Dispose of in accordance with U.S. EPA 40 CFR 262 for concentrations at or above the Regulatory level. Regulatory level- 0.7 mg/L. Dispose in accordance with all applicable regulations.
14. TRANSPORT INFORMATION
U.S. DOT 49 CFR 172.101: PROPER SHIPPING NAME: Vinylidene chloride, stabilized ID NUMBER: UN1303 HAZARD CLASS OR DIVISION: 3 PACKING GROUP: I LABELING REQUIREMENTS: 3
CANADIAN TRANSPORTATION OF DANGEROUS GOODS: SHIPPING NAME: Vinylidene chloride, stabilized UN NUMBER: UN1303 CLASS: 3 PACKING GROUP/CATEGORY: I Page 7 of 8
15. REGULATORY INFORMATION
U.S. REGULATIONS: CERCLA SECTIONS 102a/103 HAZARDOUS SUBSTANCES (40 CFR 302.4): VINYLIDINE CHLORIDE: 100 LBS RQ
SARA TITLE III SECTION 302 EXTREMELY HAZARDOUS SUBSTANCES (40 CFR 355 Subpart B): Not regulated.
SARA TITLE III SECTION 304 EXTREMELY HAZARDOUS SUBSTANCES (40 CFR 355 Subpart C): Not regulated.
SARA TITLE III SARA SECTIONS 311/312 HAZARDOUS CATEGORIES (40 CFR 370 Subparts B and C): ACUTE: Yes CHRONIC: Yes FIRE: Yes REACTIVE: Yes SUDDEN RELEASE: Yes
SARA TITLE III SECTION 313 (40 CFR 372.65): VINYLIDINE CHLORIDE
OSHA PROCESS SAFETY (29 CFR 1910.119): Not regulated.
STATE REGULATIONS: California Proposition 65: Not regulated.
CANADIAN REGULATIONS: WHMIS CLASSIFICATION: BD2
NATIONAL INVENTORY STATUS: U.S. INVENTORY (TSCA): Listed on inventory.
TSCA 12(b) EXPORT NOTIFICATION: VINYLIDENE CHLORIDE CAS NUMBER: 75-35-4 SECTION 4
CANADA INVENTORY (DSL/NDSL): Not determined.
16. OTHER INFORMATION
Page 8 of 8 MSDS SUMMARY OF CHANGES 5. FIRE FIGHTING MEASURES 15. REGULATORY INFORMATION
“RTECS®” is a United States trademark owned and licensed under authority of the U.S. Government, by and through Symyx Software, Inc. Portions ©Copyright 2001, U.S. Government. All rights reserved.
©Copyright 1984-2008 ChemADVISOR, Inc. All rights reserved.
MATHESON TRI-GAS, INC. MAKES NO EXPRESS OR IMPLIED WARRANTIES, GUARANTEES OR REPRESENTATIONS REGARDING THE PRODUCT OR THE INFORMATION HEREIN, INCLUDING BUT NOT LIMITED TO ANY IMPLIED WARRANTY OF MERCHANTABILITY OR FITNESS FOR USE. MATHESON TRI-GAS, INC. SHALL NOT BE LIABLE FOR ANY PERSONAL INJURY, PROPERTY OR OTHER DAMAGES OF ANY NATURE, WHETHER COMPENSATORY, CONSEQUENTIAL, EXEMPLARY, OR OTHERWISE, RESULTING FROM ANY PUBLICATION, USE OR RELIANCE UPON THE INFORMATION HEREIN.
Material Safety Data Sheet 1,2-Dichloroethane MSDS
Section 1: Chemical Product and Company Identification Product Name: 1,2-Dichloroethane Contact Information:
Catalog Codes: SLD2521, SLD3721 Sciencelab.com, Inc. 14025 Smith Rd. CAS#: 107-06-2 Houston, Texas 77396 US Sales: 1-800-901-7247 RTECS: KH9800000 International Sales: 1-281-441-4400 TSCA: TSCA 8(b) inventory: 1,2-Dichloroethane Order Online: ScienceLab.com
CI#: Not available. CHEMTREC (24HR Emergency Telephone), call: 1-800-424-9300 Synonym: Ethylene dichloride International CHEMTREC, call: 1-703-527-3887 Chemical Formula: C2H4CL2 For non-emergency assistance, call: 1-281-441-4400
Section 2: Composition and Information on Ingredients Composition: Name CAS # % by Weight {1,2-}Dichloroethane 107-06-2 100
Toxicological Data on Ingredients: 1,2-Dichloroethane: ORAL (LD50): Acute: 670 mg/kg [Rat]. 413 mg/kg [Mouse]. DERMAL (LD50): Acute: 2800 mg/kg [Rabbit]. VAPOR (LC50): Acute: 1414.2 ppm 4 hour(s) [Rat].
Section 3: Hazards Identification Potential Acute Health Effects: Extremely hazardous in case of ingestion. Very hazardous in case of eye contact (irritant), of inhalation. Hazardous in case of skin contact (irritant). Corrosive to skin and eyes on contact. Liquid or spray mist may produce tissue damage particularly on mucous membranes of eyes, mouth and respiratory tract. Skin contact may produce burns. Inhalation of the spray mist may produce severe irritation of respiratory tract, characterized by coughing, choking, or shortness of breath. Inflammation of the eye is characterized by redness, watering, and itching.
Potential Chronic Health Effects: Very hazardous in case of ingestion, of inhalation. CARCINOGENIC EFFECTS: Classified + (PROVEN) by OSHA. Classified 2B (Possible for human.) by IARC. Classified 2 (Reasonably anticipated.) by NTP. MUTAGENIC EFFECTS: Not available. TERATOGENIC EFFECTS: Not available. DEVELOPMENTAL TOXICITY: Not available.
p. 1 The substance is toxic to lungs, the nervous system, liver, mucous membranes. Repeated or prolonged exposure to the substance can produce target organs damage. Repeated or prolonged contact with spray mist may produce chronic eye irritation and severe skin irritation. Repeated or prolonged exposure to spray mist may produce respiratory tract irritation leading to frequent attacks of bronchial infection.
Section 4: First Aid Measures Eye Contact: Check for and remove any contact lenses. Immediately flush eyes with running water for at least 15 minutes, keeping eyelids open. Cold water may be used. Do not use an eye ointment. Seek medical attention.
Skin Contact: If the chemical got onto the clothed portion of the body, remove the contaminated clothes as quickly as possible, protecting your own hands and body. Place the victim under a deluge shower. If the chemical got on the victim's exposed skin, such as the hands : Gently and thoroughly wash the contaminated skin with running water and non-abrasive soap. Be particularly careful to clean folds, crevices, creases and groin. If irritation persists, seek medical attention. Wash contaminated clothing before reusing.
Serious Skin Contact: Wash with a disinfectant soap and cover the contaminated skin with an anti-bacterial cream. Seek immediate medical attention.
Inhalation: Allow the victim to rest in a well ventilated area. Seek immediate medical attention.
Serious Inhalation: Evacuate the victim to a safe area as soon as possible. Loosen tight clothing such as a collar, tie, belt or waistband. If breathing is difficult, administer oxygen. If the victim is not breathing, perform mouth-to-mouth resuscitation. WARNING: It may be hazardous to the person providing aid to give mouth-to-mouth resuscitation when the inhaled material is toxic, infectious or corrosive. Seek immediate medical attention.
Ingestion: Do not induce vomiting. Examine the lips and mouth to ascertain whether the tissues are damaged, a possible indication that the toxic material was ingested; the absence of such signs, however, is not conclusive. Loosen tight clothing such as a collar, tie, belt or waistband. If the victim is not breathing, perform mouth-to-mouth resuscitation. Seek immediate medical attention.
Serious Ingestion: Not available.
Section 5: Fire and Explosion Data Flammability of the Product: Flammable.
Auto-Ignition Temperature: 413°C (775.4°F)
Flash Points: CLOSED CUP: 13°C (55.4°F). OPEN CUP: 18°C (64.4°F).
Flammable Limits: LOWER: 6.2% UPPER: 15.6%
Products of Combustion: These products are carbon oxides (CO, CO2).
Fire Hazards in Presence of Various Substances: Flammable in presence of open flames and sparks. Slightly flammable to flammable in presence of oxidizing materials.
Explosion Hazards in Presence of Various Substances: Risks of explosion of the product in presence of mechanical impact: Not available. Risks of explosion of the product in presence of static discharge: Not available. Slightly explosive to explosive in presence of oxidizing materials.
Fire Fighting Media and Instructions:
p. 2 Flammable liquid, soluble or dispersed in water. SMALL FIRE: Use DRY chemical powder. LARGE FIRE: Use alcohol foam, water spray or fog.
Special Remarks on Fire Hazards: Not available.
Special Remarks on Explosion Hazards: Not available.
Section 6: Accidental Release Measures Small Spill: Absorb with an inert material and put the spilled material in an appropriate waste disposal.
Large Spill: Flammable liquid. Corrosive liquid. Keep away from heat. Keep away from sources of ignition. Stop leak if without risk. Absorb with DRY earth, sand or other non-combustible material. Do not get water inside container. Do not touch spilled material. Use water spray curtain to divert vapor drift. Prevent entry into sewers, basements or confined areas; dike if needed. Eliminate all ignition sources. Call for assistance on disposal. Be careful that the product is not present at a concentration level above TLV. Check TLV on the MSDS and with local authorities.
Section 7: Handling and Storage Precautions: Keep locked up Keep container dry. Keep away from heat. Keep away from sources of ignition. Ground all equipment containing material. Do not ingest. Do not breathe gas/fumes/ vapour/spray. Never add water to this product In case of insufficient ventilation, wear suitable respiratory equipment If ingested, seek medical advice immediately and show the container or the label. Avoid contact with skin and eyes
Storage: Flammable materials should be stored in a separate safety storage cabinet or room. Keep away from heat. Keep away from sources of ignition. Keep container tightly closed. Keep in a cool, well-ventilated place. Ground all equipment containing material. A refrigerated room would be preferable for materials with a flash point lower than 37.8°C (100°F).
Section 8: Exposure Controls/Personal Protection Engineering Controls: Provide exhaust ventilation or other engineering controls to keep the airborne concentrations of vapors below their respective threshold limit value. Ensure that eyewash stations and safety showers are proximal to the work-station location.
Personal Protection: Splash goggles. Lab coat. Vapor respirator. Be sure to use an approved/certified respirator or equivalent. Gloves.
Personal Protection in Case of a Large Spill: Splash goggles. Full suit. Vapor respirator. Boots. Gloves. A self contained breathing apparatus should be used to avoid inhalation of the product. Suggested protective clothing might not be sufficient; consult a specialist BEFORE handling this product.
Exposure Limits: TWA: 10 CEIL: 75 (ppm) from ACGIH (TLV) TWA: 40 CEIL: 300 (mg/m3) from ACGIHConsult local authorities for acceptable exposure limits.
Section 9: Physical and Chemical Properties Physical state and appearance: Liquid.
p. 3 Odor: Not available.
Taste: Not available.
Molecular Weight: 98.96 g/mole
Color: Not available. pH (1% soln/water): Not available.
Boiling Point: 83.5°C (182.3°F)
Melting Point: -35.3°C (-31.5°F)
Critical Temperature: Not available.
Specific Gravity: 1.2351 (Water = 1)
Vapor Pressure: 61 mm of Hg (@ 20°C)
Vapor Density: 3.42 (Air = 1)
Volatility: Not available.
Odor Threshold: 26 ppm
Water/Oil Dist. Coeff.: The product is equally soluble in oil and water; log(oil/water) = 0
Ionicity (in Water): Not available.
Dispersion Properties: See solubility in water, methanol, diethyl ether, n-octanol, acetone.
Solubility: Easily soluble in methanol, diethyl ether, n-octanol, acetone. Very slightly soluble in cold water.
Section 10: Stability and Reactivity Data Stability: The product is stable.
Instability Temperature: Not available.
Conditions of Instability: Not available.
Incompatibility with various substances: Not available.
Corrosivity: Non-corrosive in presence of glass.
Special Remarks on Reactivity: Not available.
Special Remarks on Corrosivity: Not available.
Polymerization: No.
Section 11: Toxicological Information Routes of Entry: Eye contact. Inhalation. Ingestion.
Toxicity to Animals:
p. 4 WARNING: THE LC50 VALUES HEREUNDER ARE ESTIMATED ON THE BASIS OF A 4-HOUR EXPOSURE. Acute oral toxicity (LD50): 413 mg/kg [Mouse]. Acute dermal toxicity (LD50): 2800 mg/kg [Rabbit]. Acute toxicity of the vapor (LC50): 1414.2 ppm 4 hour(s) [Rat].
Chronic Effects on Humans: CARCINOGENIC EFFECTS: Classified + (PROVEN) by OSHA. Classified 2B (Possible for human.) by IARC. Classified 2 (Reasonably anticipated.) by NTP. The substance is toxic to lungs, the nervous system, liver, mucous membranes.
Other Toxic Effects on Humans: Extremely hazardous in case of ingestion. Very hazardous in case of inhalation. Hazardous in case of skin contact (irritant).
Special Remarks on Toxicity to Animals: Not available.
Special Remarks on Chronic Effects on Humans: Passes through the placental barrier in animal. Excreted in maternal milk in human.
Special Remarks on other Toxic Effects on Humans: Not available.
Section 12: Ecological Information Ecotoxicity: Not available.
BOD5 and COD: Not available.
Products of Biodegradation: Possibly hazardous short term degradation products are not likely. However, long term degradation products may arise.
Toxicity of the Products of Biodegradation: The products of degradation are more toxic.
Special Remarks on the Products of Biodegradation: Not available.
Section 13: Disposal Considerations Waste Disposal:
Section 14: Transport Information DOT Classification: Class 3: Flammable liquid.
Identification: : Ethylene dichloride : UN1184 PG: II
Special Provisions for Transport: Marine Pollutant
Section 15: Other Regulatory Information Federal and State Regulations: California prop. 65: This product contains the following ingredients for which the State of California has found to cause cancer, birth defects or other reproductive harm, which would require a warning under the statute: 1,2-Dichloroethane California prop. 65: This product contains the following ingredients for which the State of California has found to cause cancer which would require a warning under the statute: 1,2-Dichloroethane Pennsylvania RTK: 1,2-Dichloroethane
p. 5 Massachusetts RTK: 1,2-Dichloroethane TSCA 8(b) inventory: 1,2-Dichloroethane CERCLA: Hazardous substances.: 1,2-Dichloroethane
Other Regulations: OSHA: Hazardous by definition of Hazard Communication Standard (29 CFR 1910.1200).
Other Classifications:
WHMIS (Canada): CLASS B-2: Flammable liquid with a flash point lower than 37.8°C (100°F). CLASS D-1A: Material causing immediate and serious toxic effects (VERY TOXIC). CLASS D-2A: Material causing other toxic effects (VERY TOXIC). CLASS E: Corrosive liquid.
DSCL (EEC): R11- Highly flammable. R20/22- Harmful by inhalation and if swallowed. R38- Irritating to skin. R41- Risk of serious damage to eyes. R45- May cause cancer.
HMIS (U.S.A.):
Health Hazard: 2
Fire Hazard: 3
Reactivity: 0
Personal Protection: h
National Fire Protection Association (U.S.A.):
Health: 2
Flammability: 3
Reactivity: 0
Specific hazard:
Protective Equipment: Gloves. Lab coat. Vapor respirator. Be sure to use an approved/certified respirator or equivalent. Wear appropriate respirator when ventilation is inadequate. Splash goggles.
Section 16: Other Information References: Not available.
Other Special Considerations: Not available.
Created: 10/10/2005 08:17 PM
Last Updated: 11/06/2008 12:00 PM
p. 6 The information above is believed to be accurate and represents the best information currently available to us. However, we make no warranty of merchantability or any other warranty, express or implied, with respect to such information, and we assume no liability resulting from its use. Users should make their own investigations to determine the suitability of the information for their particular purposes. In no event shall ScienceLab.com be liable for any claims, losses, or damages of any third party or for lost profits or any special, indirect, incidental, consequential or exemplary damages, howsoever arising, even if ScienceLab.com has been advised of the possibility of such damages.
p. 7 MATERIAL SAFETY DATA SHEETS
MSDS No: 156-59-2 Date: 03/09/2001 SUPPLIER 6141 Easton Road, Bldg. 1 EMERGENCY PHONE (215) 766-8861 ADDRESS: PO Box 310 NUMBER: Plumsteadville, PA 18949-0310 1. CHEMICAL PRODUCT PRODUCT 1,2-DICHLOROETHYLENE SYNONYMS:cis-Dichloroethylene NAME: (CIS) 2. COMPOSITION, INFORMATION ON INGREDIENTS Exposure Limits (PPM) ACGIH OSHA Other Ingredient Name Formula CAS # Concentration MAC TLV PEL STEL 1,2- C2H2CL2 156- 99+% 200 NE NE NE DICHLOROETHYLENE (CIS) 59-2
Note: NE = NONE ESTABLISHED S/A = SIMPLE ASPHYXIANT 3. HAZARD INDENTIFICATION * * * EMERGENCY OVERVIEW * * * Flammable liquid and vapor. Can form explosive mixtures with air. Can cause irritation to eyes, skin and respiratory tract.
POTENTIAL HEALTH EFFECTS
ROUTES OF ENTRY: Inhalation , Ingestion
ACUTE EFFECTS: Vapor or mist is irritating to the eyes, skin, mucous membrane, and upper respiratory tract. Skin and eye irritation may occur. High concentrations may have a narcotic effect.
CHRONIC EFFECTS: Kidney and liver damage.
MEDICAL CONDITIONS AGGRAVATED BY OVEREXPOSURE: None known
OTHER EFFECTS OF OVEREXPORSURE: None
CARCINOGENICITY (US ONLY): NTP - No IARC MONOGRAPHS - No OSHA REGULATED - No 4. FIRST AID MEASURES
INHALATION: Immediately remove victim to fresh air. If breathing has stopped, give artificial respiration. If breathing is difficult, give oxygen.
EYE CONTACT: Immediately flush with copious amounts of water for at least 15 minutes.
SKIN CONTACT: Immediately flush with copious amounts of water for at least 15 minutes while removing contaminated clothing.
INGESTION: Never give anything by mouth to an unconscious person. Have conscious and alert person drink 1 to 2 glasses of water. Induce vomiting after victim drinks water.
IN EVENT OF EXPOSURE, CONSULT A PHYSICIAN
NOTE TO PHYSICIAN: None
5. FIRE FIGHTING MEASURES
FLASH POINT: 2 deg.C
AUTOIGNITION TEMPERATURE: 460 deg. C
FLAMMABLE LIMITS: Vol.% LOWER: 5.6 UPPER: 12.80
EXTINGUISHING MEDIA: Carbon dioxide, foam, or dry chemical.
SPECIAL FIRE FIGHTING INSTRUCTION AND EQUIPMENT: Wear self-contained breathing apparatus and full protective clothing. Keep fire exposed cylinders cool with water spray.
HAZARDOUS COMBUSTION PRODUCTS: Toxic carbon monoxide, hydrogen chloride and phosgene.
UNUSUAL FIRE AND EXPLOSION HAZARDS: Cylinder rupture may occur under fire conditions. Emits toxic fumes under fire conditions. Vapors may travel a considerable distance to the source of ignition and flash back.
6. ACCIDENTAL RELEASE MEASURES
CLEAN UP PROCEDURES: Evacuate and ventilate area. Remove leaking cylinder to exhaust hood or safe outdoor area. Shut off source if possible and remove source of heat. Absorb with sand or vermiculite and place in closed containers for disposal.
SPECIALIZED EQUIPMENT: None
7. HANDLING AND STORAGE
PRECAUTIONS TO BE TAKEN IN HANDLING: Secure cylinder when using to protect from falling. Use suitable hand truck to move cylinders. Use only in a well-ventilated area.
PRECAUTIONS TO BE TAKEN IN STORAGE: Store in well ventilated areas. Keep valve protection cap on cylinders when not in use. Store away from oxidizers, combustible materials, and source of ignition or heat.
8. EXPOSURE CONTROLS / PERSONAL PROTECTION
ENGINEERING CONTROLS: Provide adequate general and local exhaust ventilation to maintain concentrations below exposure and flammable limits.
EYE / FACE PROTECTION: Goggles. A safety shower and eyewash station should be readily available.
SKIN PROTECTION: Wear suitable protective clothing.
RESPIRATORY PROTECTION: Use a self-contained breathing apparatus in case of emergency or non-routine use.
OTHER PROTECTIVE EQUIPMENT: Safety shoes when handling cylinders.
9. PHYSICAL AND CHEMICAL PROPERTIES
APPEARANCE: Colorless
ODOR: Pleasant aromatic odor
PHYSICAL PRESSURE: Liquid
VAPOR PRESSURE: @41 deg.C: 400 mm Hg
VAPOR DENSITY (AIR=1): 3.34
BOILING POINT (C): 59
SOLUBILITY IN WATER: Insoluble
SPECIFIC GRAVITY (H2O=1): @20 deg.C: 1.284
EVAPORATION RATE: N/Av
ODOR THRESHOLD: N/Av
10. STABILITY AND REACTIVITY
STABILITY: Stable under normal storage conditions.
CONDITIONS TO AVOID: Storage in poorly ventilated areas. Storage near a heat source.
MATERIALS TO AVOID: Oxidizing agents, air and moisture. Nitrogen dioxide, sodium, potassium hydroxide.
HAZARDOUS POLYMERIZATION: Will not occur.
HAZARDOUS DECOMPOSITION: HCl gas, phosgene gas, CO and oxides of chlorine.
11. TOXICOLOGICAL INFORMATION
LETHAL CONCENTRATION (LC50): None established
LETHAL DOSE 50 (LD50): N/Ap
TERATOGENICITY: N/Ap
REPRODUCTIVE EFFECTS: N/Ap
MUTAGENICITY: N/Ap
12. ECOLOGICAL INFORMATION No adverse ecological effects are expected.
13. DISPOSAL CONSIDERATIONS
WASTE DISPOSAL METHOD: Dispose of non-refillable cylinders in accordance with federal, state and local regulations. Allow gas to vent slowly to atmosphere in an unconfined area or exhaust hood. If the cylinders are the refillable type, return cylinders to supplier with any valve outlet plugs or caps secured and valve protection caps in place. Waste can be burned in an approved incinerator equipped with an afterburner and scrubber.
14. TRANSPORT INFORMATION
CONCENTRATION: 99+%
DOT DESCRIPTION (US ONLY):
PROPER SHIPPING NAME: Flammable liquids, n.o.s. HAZARD CLASS: 3 (flammable), Packing Group I INDENTIFICATION NUMBER: UN1993 REPORTABLE QUANTITIES: 1000 lb. LABELING: FLAMMABLE LIQUID
ADR / RID (EU Only): Class 3, 3(b)
SPECIAL PRECAUTIONS: Cylinders should be transported in a secure upright position in a well ventilated truck.
15. REGULATORY INFORMATION
OSHA: Process Safety Management: Material is not listed in appendix A of 29 CFR 1910.119 as highly hazardous chemical.
TSCA: Material is listed in TSCA inventory.
SARA: The threshold planning quantity for material is 10,000 lbs.
EU NUMBER: N/Av
NUMBER IN ANNEX 1 OF DIR 67/548: Material is listed in annex 1.
EU CLASSIFICATION: N/Av
R: 22-33-35-64
S: 15-22-23-27-36-65-71-76-104
16. OTHER INFORMATION
OTHER PRECAUTIONS: Protect containers from physical damage. Do not deface cylinders or labels. Cylinders should be refilled by qualified producers of compressed gas. Shipment of a compressed gas cylinder which has not been filled by the owner or with his written consent is a violation of federal law (49 CFR).
ABBREVIATIONS: N/Ap - Not Applicable N/Av - Not Available SA - Simple Asphyxiant NE - None Established
DISCLAIMER: Information included in this document is given to the best of our knowledge, however, no warranty is made that the information is accurate or complete. We do not accept any responsibility for damages by the use of the document. He a lt h 2 3 Fire 3 2 1 Re a c t iv it y 1 Pe rs o n a l Pro t e c t io n J Material Safety Data Sheet p-Dioxane MSDS
Section 1: Chemical Product and Company Identification
Product Name: p-Dioxane Contact Information: Catalog Codes: SLD3919 Sciencelab.com, Inc. 14025 Smith Rd. CAS#: 123-91-1 Houston, Texas 77396 RTECS: JG8225000 US Sales: 1-800-901-7247 International Sales: 1-281-441-4400 TSCA: TSCA 8(b) inventory: 1,4-Dioxane Order Online: ScienceLab.com CI#: Not applicable. CHEMTREC (24HR Emergency Telephone), call: Synonym: p-Dioxane; Diethylene dioxide; 1,4-Dioxane 1-800-424-9300 Chemical Name: 1,4-Dioxacyclohexane International CHEMTREC, call: 1-703-527-3887 Chemical Formula: C4H8O2 For non-emergency assistance, call: 1-281-441-4400
Section 2: Composition and Information on Ingredients
Composition:
Name CAS # % by Weight {1,4-}Dioxane 123-91-1 100
Toxicological Data on Ingredients: 1,4-Dioxane: ORAL (LD50): Acute: 4200 mg/kg [Rat.]. 5300 mg/kg [Mouse]. 2000 mg/kg [Rabbit]. VAPOR (LC50): Acute: 37000 mg/m 2 hours [Mouse].
Section 3: Hazards Identification
Potential Acute Health Effects: Hazardous in case of eye contact (irritant), of ingestion, of inhalation. Slightly hazardous in case of skin contact (irritant, permeator). Potential Chronic Health Effects: Hazardous in case of inhalation. CARCINOGENIC EFFECTS: Classified A3 (Proven for animal.) by ACGIH, 2B (Possible for human.) by IARC. Classified 2 (Some evidence.) by NTP. MUTAGENIC EFFECTS: Mutagenic for mammalian somatic cells. TERATOGENIC EFFECTS: Not available. DEVELOPMENTAL TOXICITY: Not available. The substance may be toxic to blood, kidneys, liver, skin, central nervous system (CNS). Repeated or prolonged exposure to the substance can produce target organs damage.
Section 4: First Aid Measures
p. 1 Eye Contact: Check for and remove any contact lenses. Immediately flush eyes with running water for at least 15 minutes, keeping eyelids open. Cold water may be used. Get medical attention. Skin Contact: Wash with soap and water. Cover the irritated skin with an emollient. Get medical attention if irritation develops. Cold water may be used. Serious Skin Contact: Not available. Inhalation: If inhaled, remove to fresh air. If not breathing, give artificial respiration. If breathing is difficult, give oxygen. Get medical attention if symptoms appear. Serious Inhalation: Evacuate the victim to a safe area as soon as possible. Loosen tight clothing such as a collar, tie, belt or waistband. If breathing is difficult, administer oxygen. If the victim is not breathing, perform mouth-to-mouth resuscitation. Seek medical attention. Ingestion: Do NOT induce vomiting unless directed to do so by medical personnel. Never give anything by mouth to an unconscious person. Loosen tight clothing such as a collar, tie, belt or waistband. Get medical attention if symptoms appear. Serious Ingestion: Not available.
Section 5: Fire and Explosion Data
Flammability of the Product: Flammable. Auto-Ignition Temperature: 180°C (356°F) Flash Points: CLOSED CUP: 12°C (53.6°F). OPEN CUP: 18.3°C (64.9°F) (Cleveland). Flammable Limits: LOWER: 2% UPPER: 22% Products of Combustion: These products are carbon oxides (CO, CO2). Fire Hazards in Presence of Various Substances: Highly flammable in presence of open flames and sparks, of heat. Non-flammable in presence of shocks. Explosion Hazards in Presence of Various Substances: Risks of explosion of the product in presence of mechanical impact: Not available. Risks of explosion of the product in presence of static discharge: Not available. Fire Fighting Media and Instructions: Flammable liquid, soluble or dispersed in water. SMALL FIRE: Use DRY chemical powder. LARGE FIRE: Use alcohol foam, water spray or fog. Special Remarks on Fire Hazards: Vapor is heavier than air and may travel considerable distance to source of ignition and flash back. When heated to decomposition, it emits acrid smoke and irritating fumes. Special Remarks on Explosion Hazards: Vapor forms explosive mixtures with air over a wide range. Dioxane is capable of forming explosive peroxides under certain conditions, and unless proper precautions are taken, it can explode when redistilled. In the reaction with triethynylaluminum, the residue from the sublimation of the complex with Dioxane is explosive. The complex should not be dried by heating.
Section 6: Accidental Release Measures
Small Spill: Dilute with water and mop up, or absorb with an inert dry material and place in an appropriate waste disposal container.
p. 2 Large Spill: Flammable liquid. Keep away from heat. Keep away from sources of ignition. Stop leak if without risk. Absorb with DRY earth, sand or other non-combustible material. Do not touch spilled material. Prevent entry into sewers, basements or confined areas; dike if needed. Be careful that the product is not present at a concentration level above TLV. Check TLV on the MSDS and with local authorities.
Section 7: Handling and Storage
Precautions: Keep locked up.. Keep away from heat. Keep away from sources of ignition. Ground all equipment containing material. Do not ingest. Do not breathe gas/fumes/ vapor/spray. Avoid contact with eyes. Wear suitable protective clothing. In case of insufficient ventilation, wear suitable respiratory equipment. If ingested, seek medical advice immediately and show the container or the label. Keep away from incompatibles such as oxidizing agents. Storage: Store in a segregated and approved area. Keep container in a cool, well-ventilated area. Keep container tightly closed and sealed until ready for use. Avoid all possible sources of ignition (spark or flame).
Section 8: Exposure Controls/Personal Protection
Engineering Controls: Provide exhaust ventilation or other engineering controls to keep the airborne concentrations of vapors below their respective threshold limit value. Ensure that eyewash stations and safety showers are proximal to the work-station location. Personal Protection: Splash goggles. Lab coat. Vapor respirator. Be sure to use an approved/certified respirator or equivalent. Gloves (impervious). Personal Protection in Case of a Large Spill: Splash goggles. Full suit. Vapor respirator. Boots. Gloves. A self contained breathing apparatus should be used to avoid inhalation of the product. Suggested protective clothing might not be sufficient; consult a specialist BEFORE handling this product. Exposure Limits: TWA: 72 (mg/m3) from ACGIH (TLV) [United States] TWA: 20 (ppm) from ACGIH (TLV) [United States] CEIL: 3.6 (mg/m3) from NIOSH CEIL: 1 (ppm) from NIOSH TWA: 25 (ppm) from OSHA (PEL) [United States] TWA: 90 (mg/m3) from OSHA (PEL) [United States] TWA: 25 STEL: 100 (ppm) [United Kingdom (UK)] TWA: 91 STEL: 366 (mg/m3) [United Kingdom (UK)] CEIL: 100 (ppm) from OSHA (PEL) [United States] CEIL: 360 (mg/m3) from OSHA (PEL) [United States]Consult local authorities for acceptable exposure limits.
Section 9: Physical and Chemical Properties
Physical state and appearance: Liquid. (Liquid.) Odor: Ethereal. Pleasant. (Slight.) Taste: Not available. Molecular Weight: 88.11 g/mole Color: Colorless. pH (1% soln/water): Not available. Boiling Point: 101.1°C (214°F) Melting Point: 11.8°C (53.2°F) Critical Temperature: 312°C (593.6°F) Specific Gravity: 1.0337 (Water = 1)
p. 3 Vapor Pressure: 3.9 kPa (@ 20°C) Vapor Density: 3.03 (Air = 1) Volatility: Not available. Odor Threshold: Not available. Water/Oil Dist. Coeff.: The product is more soluble in water; log(oil/water) = -0.3 Ionicity (in Water): Not available. Dispersion Properties: See solubility in water. Solubility: Soluble in cold water, hot water.
Section 10: Stability and Reactivity Data
Stability: The product is stable. Instability Temperature: Not available. Conditions of Instability: Heat, ignition sources, incompatible materials, air, sunlight. Incompatibility with various substances: Reactive with oxidizing agents. Corrosivity: Non-corrosive in presence of glass. Special Remarks on Reactivity: Hydroperoxide-free Dioxane rapidly forms hydroperoxide on contact with air. Exposure to sunlight accelerates this formation. Decomposes to carbon monoxide. Incompatible with silver perchlorate, oxidizing agents, sulfur trioxide, decaborane, triethynyl aluminum, boron trifluoride. Dioxane may react with hydrogen in the presence of Rainey nickel above 210C (410F). Special Remarks on Corrosivity: Not available. Polymerization: Will not occur.
Section 11: Toxicological Information
Routes of Entry: Absorbed through skin. Eye contact. Inhalation. Toxicity to Animals: WARNING: THE LC50 VALUES HEREUNDER ARE ESTIMATED ON THE BASIS OF A 4-HOUR EXPOSURE. Acute oral toxicity (LD50): 2000 mg/kg [Rabbit]. Acute toxicity of the vapor (LC50): 37000 mg/m3 2 hours [Mouse]. Chronic Effects on Humans: CARCINOGENIC EFFECTS: Classified A3 (Proven for animal.) by ACGIH, 2B (Possible for human.) by IARC. Classified 2 (Some evidence.) by NTP. MUTAGENIC EFFECTS: Mutagenic for mammalian somatic cells. May cause damage to the following organs: blood, kidneys, liver, skin, central nervous system (CNS). Other Toxic Effects on Humans: Hazardous in case of ingestion, of inhalation. Slightly hazardous in case of skin contact (irritant, permeator). Special Remarks on Toxicity to Animals: LD50 [Rabbit] - Route: Skin; Dose: 7600 ul/kg LCL [Human] - Route: Inhalation; Dose: 470 ppm/72 hrs. Special Remarks on Chronic Effects on Humans: May cause adverse reproductive effects (fetotoxicity) based on animal data. May affect genetic material (mutagenic) based on animal data. May cause cancer (tumorgenic). Special Remarks on other Toxic Effects on Humans: Acute Potential Health Effects: Skin: Causes skin irritation. May be absorbed through skin with possible system effects. Eyes: Vapors cause eye irritation. Splashes cause severe irritation, possible corneal burns and eye damage. Inhalation: Highly toxic by inhalation. Easily absorbed through lungs. Causes irritation of the respiratory tract. May affect respiration (coughing),
p. 4 behavior and brain (headache, dizziness, narcosis, irritability, drowsiness, altered sleep time, physcophpysical changes), cardiovascular system (increased blood pressure), sense organs, gastrointestinal tract (nausea, vomiting), liver, and kidneys. metabolism Ingestion: Causes gastrointestinal (digestive) tract irritation with nausea, vomiting, sore throat, abdominal pain. May also affect behavior, sense organs, urinary system. Chronic Potential Health Effects: Prolonged exposure may cause central nervous system depression, loss of appetite, nausea, abdominal tenderness, and liver or kidney damage. Prolonged skin contact may cause dermatitis. Suspected human carcinogen based on animal data.
Section 12: Ecological Information
Ecotoxicity: Not available. BOD5 and COD: Not available. Products of Biodegradation: Possibly hazardous short term degradation products are not likely. However, long term degradation products may arise. Toxicity of the Products of Biodegradation: The product itself and its products of degradation are not toxic. Special Remarks on the Products of Biodegradation: Not available.
Section 13: Disposal Considerations
Waste Disposal: Waste must be disposed of in accordance with federal, state and local environmental control regulations.
Section 14: Transport Information
DOT Classification: CLASS 3: Flammable liquid. Identification: : Dioxane UNNA: 1165 PG: II Special Provisions for Transport: Not available.
Section 15: Other Regulatory Information
Federal and State Regulations: California prop. 65: This product contains the following ingredients for which the State of California has found to cause cancer, birth defects or other reproductive harm, which would require a warning under the statute: 1,4-Dioxane California prop. 65 (no significant risk level): 1,4-Dioxane California prop. 65: This product contains the following ingredients for which the State of California has found to cause cancer which would require a warning under the statute: 1,4-Dioxane Connecticut hazardous material survey.: 1,4-Dioxane Illinois toxic substances disclosure to employee act: 1,4-Dioxane Illinois chemical safety act: 1,4- Dioxane New York release reporting list: 1,4-Dioxane Rhode Island RTK hazardous substances: 1,4-Dioxane Pennsylvania RTK: 1,4-Dioxane Minnesota: 1,4-Dioxane Massachusetts RTK: 1,4-Dioxane Massachusetts spill list: 1,4-Dioxane New Jersey: 1,4-Dioxane New Jersey spill list: 1,4-Dioxane Louisiana spill reporting: 1,4-Dioxane California Director's list of Hazardous Substances: 1,4-Dioxane TSCA 8(b) inventory: 1,4-Dioxane SARA 313 toxic chemical notification and release reporting: 1,4-Dioxane CERCLA: Hazardous substances.: 1,4-Dioxane: 100 lbs. (45.36 kg) Other Classifications: WHMIS (Canada): CLASS B-2: Flammable liquid with a flash point lower than 37.8°C (100°F). CLASS D-2B: Material causing other toxic effects (TOXIC). DSCL (EEC): R11- Highly flammable. R36- Irritating to eyes. R45- May cause cancer. S2- Keep out of the reach of children. S46- If swallowed, seek medical advice immediately and show this container or label. S53- Avoid exposure - obtain special instructions before use.
p. 5 HMIS (U.S.A.): Health Hazard: 2 Fire Hazard: 3 Reactivity: 1 Personal Protection: j National Fire Protection Association (U.S.A.): Health: 2 Flammability: 3 Reactivity: 1 Specific hazard: Protective Equipment: Gloves (impervious). Lab coat. Vapor respirator. Be sure to use an approved/certified respirator or equivalent. Wear appropriate respirator when ventilation is inadequate. Splash goggles.
Section 16: Other Information
References: -SAX, N.I. Dangerous Properties of Indutrial Materials. Toronto, Van Nostrand Reinold, 6e ed. 1984. -Material safety data sheet emitted by: la Commission de la Santé et de la Sécurité du Travail du Québec. -Hawley, G.G.. The Condensed Chemical Dictionary, 11e ed., New York N.Y., Van Nostrand Reinold, 1987. -The Sigma-Aldrich Library of Chemical Safety Data, Edition II. RTECS, and HSDB databases Other Special Considerations: Not available. Created: 10/09/2005 05:14 PM Last Updated: 11/01/2010 12:00 PM
The information above is believed to be accurate and represents the best information currently available to us. However, we make no warranty of merchantability or any other warranty, express or implied, with respect to such information, and we assume no liability resulting from its use. Users should make their own investigations to determine the suitability of the information for their particular purposes. In no event shall ScienceLab.com be liable for any claims, losses, or damages of any third party or for lost profits or any special, indirect, incidental, consequential or exemplary damages, howsoever arising, even if ScienceLab.com has been advised of the possibility of such damages.
p. 6 MATERIAL SAFETY DATA SHEET Hydrogen Peroxide (8 to 20%)
MSDS Ref. No.: 7722-84-1-2 Date Approved: 04/05/2005 Revision No.: 6
This document has been prepared to meet the requirements of the U.S. OSHA Hazard Communication Standard, 29 CFR 1910.1200; the Canada's Workplace Hazardous Materials Information System (WHMIS) and, the EC Directive, 2001/58/EC.
1. PRODUCT AND COMPANY IDENTIFICATION
PRODUCT NAME: Hydrogen Peroxide (8 to 20%) GENERAL USE: Standard 8% is formulated with an inorganic tin-based stabilizer for high stability and long term storage. Suitable for industrial bleaching, processing, pollution abatement and general oxidation reactions. Technical grade contains an organic based stabilizer. It is particularly useful in chemical synthesis where the presence of inorganic residues is objectionable.
MANUFACTURER EMERGENCY TELEPHONE NUMBERS FMC CORPORATION (800) 424-9300 (CHEMTREC - U.S.) Hydrogen Peroxide Division (613) 996-6666 (CANUTEC) 1735 Market Street (303) 595-9048 (Medical - U.S. - Call Collect) Philadelphia, PA 19103 (215) 299-6000 (General Information) (281) 474-8750 (Plant: Pasadena, TX, US - Call Collect) (250) 561-4221 (Plant: Prince George, BC, Canada - Call FMC of Canada Ltd. Collect) Hydrogen Peroxide Division PG Pulp Mill Road Prince George, BC V2N2S6 (250) 561-4200 (General Information)
2. HAZARDS IDENTIFICATION EMERGENCY OVERVIEW: • Clear, colorless, odorless liquid • Oxidizer. • Contact with combustibles may cause fire. • Decomposes yielding oxygen that supports combustion of organic matters and can cause overpressure if confined. • Extremely irritating to eyes, nose, throat and lungs.
Page 1 of 10
Hydrogen Peroxide (8 to 20%) (7722-84-1-2) Date: 04/05/2005
POTENTIAL HEALTH EFFECTS: Extremely irritating to eyes, nose, throat and lungs. May cause skin irritation.
3. COMPOSITION / INFORMATION ON INGREDIENTS
Chemical Name CAS# Wt.% EC No. EC Class Hydrogen Peroxide 7722-84-1 8 - 20 231-765-0 Xn, R22-41 Water 7732-18-5 80 - 92 231-791-2 Not classified
4. FIRST AID MEASURES EYES: Immediately flush with water for at least 15 minutes, lifting the upper and lower eyelids intermittently. See a medical doctor or ophthalmologist immediately.
SKIN: Wash with plenty of soap and water. Get medical attention if irritation occurs and persists.
INGESTION: Rinse mouth with water. Dilute by giving 1 or 2 glasses of water. Do not induce vomiting. Never give anything by mouth to an unconscious person. See a medical doctor immediately.
INHALATION: Remove to fresh air. If breathing difficulty or discomfort occurs and persists, contact a medical doctor.
NOTES TO MEDICAL DOCTOR: Hydrogen peroxide at 8 to 20% concentration is an oxidant. Skin contact may be irritating; eye contact may be severely irritating. Treatment is by dilution and is symptomatic and supportive.
5. FIRE FIGHTING MEASURES
EXTINGUISHING MEDIA: Flood with water.
FIRE / EXPLOSION HAZARDS: Product is non-combustible. On decomposition releases oxygen which may intensify fire.
FIRE FIGHTING PROCEDURES: Any tank or container surrounded by fire should be flooded with water for cooling. Wear full protective clothing and self-contained breathing apparatus.
Page 2 of 10 Hydrogen Peroxide (8 to 20%) (7722-84-1-2) Date: 04/05/2005
FLAMMABLE LIMITS: Non-combustible
SENSITIVITY TO IMPACT: No data available
SENSITIVITY TO STATIC DISCHARGE: No data available
6. ACCIDENTAL RELEASE MEASURES
RELEASE NOTES: Dilute with a large volume of water and hold in a pond or diked area until hydrogen peroxide decomposes. Dispose according to methods outlined for waste disposal. Combustible materials exposed to hydrogen peroxide should be immediately submerged in or rinsed with large amounts of water to ensure that all hydrogen peroxide is removed. Residual hydrogen peroxide that is allowed to dry (upon evaporation hydrogen peroxide can concentrate) on organic materials such as paper, fabrics, cotton, leather, wood or other combustibles can cause the material to ignite and result in a fire.
7. HANDLING AND STORAGE HANDLING: Wear chemical splash-type monogoggles and full-face shield, impervious clothing, such as rubber, PVC, etc., and rubber or neoprene gloves and shoes. Avoid cotton, wool and leather. Avoid excessive heat and contamination. Contamination may cause decomposition and generation of oxygen gas which could result in high pressures and possible container rupture. Hydrogen peroxide should be stored only in vented containers and transferred only in a prescribed manner (see FMC Technical Bulletins). Never return unused hydrogen peroxide to original container, empty drums should be triple rinsed with water before discarding. Utensils used for handling hydrogen peroxide should only be made of glass, stainless steel, aluminum or plastic.
STORAGE: Store drums in cool areas out of direct sunlight and away from combustibles. For bulk storage refer to FMC Technical Bulletins.
COMMENTS: VENTILATION: Provide mechanical general and/or local exhaust ventilation to prevent release of vapor or mist into the work environment.
8. EXPOSURE CONTROLS / PERSONAL PROTECTION EXPOSURE LIMITS
Chemical Name ACGIH OSHA Supplier
Hydrogen Peroxide 1 ppm (TWA) 1 ppm (PEL)
Page 3 of 10 Hydrogen Peroxide (8 to 20%) (7722-84-1-2) Date: 04/05/2005
ENGINEERING CONTROLS: Ventilation should be provided to minimize the release of hydrogen peroxide vapors and mists into the work environment. Spills should be minimized or confined immediately to prevent release into the work area. Remove contaminated clothing immediately and wash before reuse.
PERSONAL PROTECTIVE EQUIPMENT EYES AND FACE: Use chemical splash-type monogoggles and a full-face shield made of polycarbonate, acetate, polycarbonate/acetate, PETG or thermoplastic.
RESPIRATORY: If concentrations in excess of 10 ppm are expected, use NIOSH/DHHS approved self-contained breathing apparatus (SCBA), or other approved atmospheric-supplied respirator (ASR) equipment (e.g., a full-face airline respirator (ALR)). DO NOT use any form of air-purifying respirator (APR) or filtering facepiece (AKA dust mask), especially those containing oxidizable sorbants such as activated carbon.
PROTECTIVE CLOTHING: Rubber or neoprene footwear (avoid leather). Impervious clothing materials such as rubber, neoprene, nitrile or polyvinyl chloride (avoid cotton, wool and leather). Completely submerge hydrogen peroxide contaminated clothing or other materials in water prior to drying. Residual hydrogen peroxide, if allowed to dry on materials such as paper, fabrics, cotton, leather, wood or other combustibles can cause the material to ignite and result in a fire.
GLOVES: Liquid proof rubber or neoprene gloves. Thoroughly rinse the outside of gloves with water prior to removal. Inspect regularly for leaks.
9. PHYSICAL AND CHEMICAL PROPERTIES ODOR: Odorless APPEARANCE: Clear, colorless liquid AUTOIGNITION TEMPERATURE: Non-combustible BOILING POINT: 102°C (216°F) (8% and 10%) COEFFICIENT OF OIL / WATER: Not available DENSITY / WEIGHT PER VOLUME: Not available EVAPORATION RATE: Above 1 (Butyl Acetate = 1) FLASH POINT: Non-combustible FREEZING POINT: -5°C (23°F) (8%); -6°C (21°F) (10%) ODOR THRESHOLD: Not available OXIDIZING PROPERTIES: Oxidizer PERCENT VOLATILE: 100% pH: (as is) approx. 2.5 to 3.5
SOLUBILITY IN WATER: (in H20 % by wt) Above 1
Page 4 of 10 Hydrogen Peroxide (8 to 20%) (7722-84-1-2) Date: 04/05/2005
SPECIFIC GRAVITY: (H2O=1) 1.06 @ 20°C/4°C (8%); 1.03 @ 20°C/4°C (10%) VAPOR DENSITY: (Air = 1): Not available VAPOR PRESSURE: 31 mmHg @ 30°C (8%); 30 mmHg @ 30°C (10%)
COMMENTS: pH (1% solution): 5.0 - 6.0
10. STABILITY AND REACTIVITY
CONDITIONS TO AVOID: Excessive heat or contamination could cause product to become unstable. STABILITY: Stable (heat and contamination could cause decomposition) POLYMERIZATION: Will not occur INCOMPATIBLE MATERIALS: Reducing agents, wood, paper and other combustibles, iron and other heavy metals, copper alloys and caustic. HAZARDOUS DECOMPOSITION PRODUCTS: Oxygen which supports combustion.
COMMENTS: Materials to Avoid : Dirt, organics, cyanides and combustibles such as wood, paper, oils, etc.
11. TOXICOLOGICAL INFORMATION EYE EFFECTS: 8% hydrogen peroxide: Extremely irritating (washed) (rabbit) 8% hydrogen peroxide: Moderately irritating (unwashed) (rabbit) 10% hydrogen peroxide: Extremely irritating (rabbit) [FMC Study Number: I84-851]
SKIN EFFECTS: 10% hydrogen peroxide: Slightly irritating after 4 hr. exposure (rabbit) [FMC Study Number: I89-1078]
DERMAL LD50: 35% hydrogen peroxide: > 2,000 mg/kg (rabbit) [FMC Study Number: I83-746]
ORAL LD50: 10% hydrogen peroxide: > 5,000 mg/kg (rat) [FMC Study Number: I89-1077]
INHALATION LC50: 50% hydrogen peroxide: > 0.17 mg/l (rat) [FMC Study Number: I89-1080]
TARGET ORGANS: Eyes, nose, throat and lungs
Page 5 of 10 Hydrogen Peroxide (8 to 20%) (7722-84-1-2) Date: 04/05/2005
ACUTE EFFECTS FROM OVEREXPOSURE: Extremely irritating to eyes, nose, throat and lungs. May cause skin irritation.
CHRONIC EFFECTS FROM OVEREXPOSURE: The International Agency for Research on Cancer (IARC) has concluded that there is inadequate evidence for carcinogenicity of hydrogen peroxide in humans, but limited evidence in experimental animals (Group 3 - not classifiable as to its carcinogenicity to humans). The American Conference of Governmental Industrial Hygienists (ACGIH) has concluded that hydrogen peroxide is a 'Confirmed Animal Carcinogen with Unknown Relevance to Humans' (A3).
CARCINOGENICITY: Chemical Name IARC NTP OSHA Other Hydrogen Peroxide Listed Not listed Not listed (ACGIH) Listed (A3, Animal Carcinogen)
12. ECOLOGICAL INFORMATION
ECOTOXICOLOGICAL INFORMATION: Channel catfish 96-hour LC50 = 37.4 mg/L Fathead minnow 96-hour LC50 = 16.4 mg/L Daphnia magna 24-hour EC50 = 7.7 mg/L Daphnia pulex 48-hour LC50 = 2.4 mg/L Freshwater snail 96-hour LC50 = 17.7 mg/L For more information refer to ECETOC "Joint Assessment of Commodity Chemicals No. 22, Hydrogen Peroxide." ISSN-0773-6339, January 1993
CHEMICAL FATE INFORMATION: Hydrogen peroxide in the aquatic environment is subject to various reduction or oxidation processes and decomposes into water and oxygen. Hydrogen peroxide half-life in freshwater ranged from 8 hours to 20 days, in air from 10-20 hrs. and in soils from minutes to hours depending upon microbiological activity and metal contaminants.
13. DISPOSAL CONSIDERATIONS DISPOSAL METHOD: An acceptable method of disposal is to dilute with a large amount of water and allow the hydrogen peroxide to decompose followed by discharge into a suitable treatment system in accordance with all regulatory agencies. The appropriate regulatory agencies should be contacted prior to disposal.
14. TRANSPORT INFORMATION
U.S. DEPARTMENT OF TRANSPORTATION (DOT)
PROPER SHIPPING NAME: Hydrogen Peroxide, aqueous solutions with
Page 6 of 10 Hydrogen Peroxide (8 to 20%) (7722-84-1-2) Date: 04/05/2005
not less than 8%, but less than 20% hydrogen peroxide UN/NA NUMBER: UN 2984 PACKING GROUP: III LABEL(S): Oxidizer PLACARD(S): 5.1 (Oxidizer)
ADDITIONAL INFORMATION: DOT Marking: Hydrogen Peroxide, aqueous solution with not less than 8%, but less than 20% Hydrogen Peroxide, UN 2984
Hazardous Substance/RQ: Not applicable
49 STCC Number: 4918689
DOT Spec: stainless steel/high purity aluminum cargo tanks and rail cars. UN Spec: HDPE drums. Contact FMC for specific details.
INTERNATIONAL MARITIME DANGEROUS GOODS (IMDG)
PROPER SHIPPING NAME: Hydrogen peroxide, aqueous solution with not less than 8%, but less than 20% peroxide.
INTERNATIONAL CIVIL AVIATION ORGANIZATION (ICAO) / INTERNATIONAL AIR TRANSPORT ASSOCIATION (IATA)
PROPER SHIPPING NAME: Hydrogen peroxide, aqueous solution with not less than 8%, but less than 20% peroxide(*).
OTHER INFORMATION: (*) Air regulations permit shipment of Hydrogen Peroxide (8 - 20%) in non-vented containers for Air Cargo Only aircraft, as well as for Passenger and Cargo aircraft. HOWEVER, all FMC Hydrogen Peroxide containers are vented and therefore, air shipments of FMC H202 is not permitted. IATA air regulations state that venting of packages containing oxidizing substances is not permitted for air transport.
Protect from physical damage. Keep drums in upright position. Drums should not be stacked in transit. Do not store drum on wooden pallets.
15. REGULATORY INFORMATION
Page 7 of 10 Hydrogen Peroxide (8 to 20%) (7722-84-1-2) Date: 04/05/2005
UNITED STATES
SARA TITLE III (SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT) SECTION 302 EXTREMELY HAZARDOUS SUBSTANCES (40 CFR 355, APPENDIX A): Not listed
SECTION 311 HAZARD CATEGORIES (40 CFR 370): Fire Hazard, Immediate (Acute) Health Hazard
SECTION 312 THRESHOLD PLANNING QUANTITY (40 CFR 370): The Threshold Planning Quantity (TPQ) for this product, if treated as a mixture, is 10,000 lbs; however, this product contains the following ingredients with a TPQ of less than 10,000 lbs.: None, (conc. <52%)
CERCLA (COMPREHENSIVE ENVIRONMENTAL RESPONSE COMPENSATION AND LIABILITY ACT)
CERCLA DESIGNATION & REPORTABLE QUANTITIES (RQ) (40 CFR 302.4): Unlisted (Hydrogen Peroxide 8-20%); RQ = 100 lbs.; Ignitability
TSCA (TOXIC SUBSTANCE CONTROL ACT) TSCA INVENTORY STATUS (40 CFR 710): Listed
RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) RCRA IDENTIFICATION OF HAZARDOUS WASTE (40 CFR 261): Waste Number: D001
CANADA WHMIS (WORKPLACE HAZARDOUS MATERIALS INFORMATION SYSTEM): Chemical Name: Hydrogen peroxide Hazard Classification / Division: Class C (Oxidizer), Class D, Div. 2, Subdiv. B Ingredient Disclosure List: Listed
INTERNATIONAL LISTINGS Hydrogen peroxide: China: Listed Japan (ENCS): (1)-419 Korea: KE-20204 Philippines (PICCS): Listed
HAZARD, RISK AND SAFETY PHRASE DESCRIPTIONS:
Hydrogen Peroxide, (Index #008-003-00-9):
EC Symbols: Xn (Harmful)
Page 8 of 10 Hydrogen Peroxide (8 to 20%) (7722-84-1-2) Date: 04/05/2005
EC Risk Phrases: R22 (Harmful if swallowed.) R41 (Risk of serious damage to eyes.)
EC Safety Phrases: S1/2 (Keep locked up and out of reach of children.) S3 (Keep in a cool place.) S17 (Keep away from combustible material.) S26 (In case of contact with eyes, rinse immediately with plenty of water and seek medical advice) S28 (After contact with skin, wash immediately with plenty of water and soap.) S36/37/39 (Wear suitable protective clothing, gloves and eye/face protection.) S45 (In case of accident or if you feel unwell, seek medical advice immediately - show the label where possible.)
16. OTHER INFORMATION
HMIS
Health 1 Flammability 0 Physical Hazard 1 Personal Protection (PPE) H Protection = H (Safety goggles, gloves, apron, the use of a supplied air or SCBA respirator is required in lieu of a vapor cartridge respirator)
HMIS = Hazardous Materials Identification System
Degree of Hazard Code: 4 = Severe 3 = Serious 2 = Moderate 1 = Slight 0 = Minimal
NFPA
Health 1 Flammability 0 Reactivity 1 Special OX SPECIAL = OX (Oxidizer)
NFPA = National Fire Protection Association
Degree of Hazard Code: 4 = Extreme
Page 9 of 10 Hydrogen Peroxide (8 to 20%) (7722-84-1-2) Date: 04/05/2005
3 = High 2 = Moderate 1 = Slight 0 = Insignificant
REVISION SUMMARY: This MSDS replaces Revision #5, dated February 02, 2004. Changes in information are as follows: Section 3 (Composition / Information on Ingredients) Section 15 (Regulatory Information) Section 16 (Other Information)
FMC Logo - FMC Corporation Trademark
© 2005 FMC Corporation. All Rights Reserved.
FMC Corporation believes that the information and recommendations contained herein (including data and statements) are accurate as of the date hereof. NO WARRANTY OF FITNESS FOR ANY PARTICULAR PURPOSE, WARRANTY OF MERCHANTABILITY, OR ANY OTHER WARRANTY, EXPRESSED OR IMPLIED, IS MADE CONCERNING THE INFORMATION PROVIDED HEREIN. The information provided herein relates only to the specific product designated and may not be applicable where such product is used in combination with any other materials or in any process. It is a violation of Federal law to use this product in a manner inconsistent with its labeling. Further, since the conditions and methods of use are beyond the control of FMC Corporation, FMC Corporation expressly disclaims any and all liability as to any results obtained or arising from any use of the product or reliance on such information.
Page 10 of 10 MATERIAL SAFETY DATA SHEET Hydrogen Peroxide (20 to 40%)
MSDS Ref. No.: 7722-84-1-3 Date Approved: 04/05/2005 Revision No.: 9
This document has been prepared to meet the requirements of the U.S. OSHA Hazard Communication Standard, 29 CFR 1910.1200; the Canada's Workplace Hazardous Materials Information System (WHMIS) and, the EC Directive, 2001/58/EC.
1. PRODUCT AND COMPANY IDENTIFICATION
PRODUCT NAME: Hydrogen Peroxide (20 to 40%) ALTERNATE PRODUCT NAME(S): Durox® Reg. & LR 35%, Oxypure® 35%, Standard 27.5 & 35%, Super D® 25 & 35, Technical 35%, Chlorate Grade, 20%, Semiconductor Reg, Seg, RGS, RGS 2, RGS 3, 31% GENERAL USE: Durox® 35% Reg. & LR - meets the Food Chemical Codex requirements for aseptic packaging and other food related applications.
Oxypure® 35% - certified by NSF to meet NSF/ANSI Standard 60 requirements for drinking water treatment.
Standard 27.5 and 35% - most suitable grade for industrial bleaching, processing, pollution abatement and general oxidation reactions.
Semiconductor Reg, Seg, RGS, RGS 2, RGS 3, 31% - conform to ACS and Semi Specs. for wafer etching and cleaning, and applications requiring low residues.
Super D® 25 and 35% - meets US Pharmacopoeia specifications for 3% topical solutions when diluted with proper quality water. While manufactured to the USP standards for purity and to FMC's demanding ISO 9002 quality standards, FMC does not claim that it's Hydrogen Peroxide is manufactured in accordance with all pharmaceutical cGMP conditions.
Technical 35% - essentially free of inorganic metals suitable for chemical synthesis.
Chlorate Grade 20% - specially formulated for use in chlorate manufacture or processing.
Page 1 of 11
Hydrogen Peroxide (20 to 40%) (7722-84-1-3) Date: 04/05/2005
MANUFACTURER EMERGENCY TELEPHONE NUMBERS FMC CORPORATION (800) 424-9300 (CHEMTREC - U.S.) Hydrogen Peroxide Division (613) 996-6666 (CANUTEC) 1735 Market Street (303) 595-9048 (Medical - U.S. - Call Collect) Philadelphia, PA 19103 (215) 299-6000 (General Information) (281) 474-8750 (Plant: Pasadena, TX, US - Call Collect) (250) 561-4221 (Plant: Prince George, BC, Canada - Call FMC of Canada Ltd. Collect) Hydrogen Peroxide Division PG Pulp Mill Road Prince George, BC V2N2S6 (250) 561-4200 (General Information)
2. HAZARDS IDENTIFICATION EMERGENCY OVERVIEW: • Clear, colorless, odorless liquid • Oxidizer. • Contact with combustibles may cause fire. • Decomposes yielding oxygen that supports combustion of organic matters and can cause overpressure if confined. • Corrosive to eyes, nose, throat, lungs and gastrointestinal tract.
POTENTIAL HEALTH EFFECTS: Corrosive to eyes, nose, throat and lungs. May cause irreversible tissue damage to the eyes including blindness. May cause skin irritation.
3. COMPOSITION / INFORMATION ON INGREDIENTS
Chemical Name CAS# Wt.% EC No. EC Class Hydrogen Peroxide 7722-84-1 20 - 40 231-765-0 Xn, R22-37/38-41 Water 7732-18-5 60 - 80 231-791-2 Not classified
Page 2 of 11 Hydrogen Peroxide (20 to 40%) (7722-84-1-3) Date: 04/05/2005
4. FIRST AID MEASURES EYES: Immediately flush with water for at least 15 minutes, lifting the upper and lower eyelids intermittently. See a medical doctor or ophthalmologist immediately.
SKIN: Wash with plenty of soap and water. Get medical attention if irritation occurs and persists.
INGESTION: Rinse mouth with water. Dilute by giving 1 or 2 glasses of water. Do not induce vomiting. Never give anything by mouth to an unconscious person. See a medical doctor immediately.
INHALATION: Remove to fresh air. If breathing difficulty or discomfort occurs and persists, contact a medical doctor.
NOTES TO MEDICAL DOCTOR: Hydrogen peroxide at these concentrations is a strong oxidant. Direct contact with the eye is likely to cause corneal damage especially if not washed immediately. Careful ophthalmologic evaluation is recommended and the possibility of local corticosteroid therapy should be considered. Because of the likelihood of corrosive effects on the gastrointestinal tract after ingestion, and the unlikelihood of systemic effects, attempts at evacuating the stomach via emesis induction or gastric lavage should be avoided. There is a remote possibility, however, that a nasogastric or orogastric tube may be required for the reduction of severe distension due to gas formation.
5. FIRE FIGHTING MEASURES
EXTINGUISHING MEDIA: Flood with water.
FIRE / EXPLOSION HAZARDS: Product is non-combustible. On decomposition releases oxygen which may intensify fire.
FIRE FIGHTING PROCEDURES: Any tank or container surrounded by fire should be flooded with water for cooling. Wear full protective clothing and self-contained breathing apparatus.
FLAMMABLE LIMITS: Non-combustible
SENSITIVITY TO IMPACT: No data available
SENSITIVITY TO STATIC DISCHARGE: No data available
6. ACCIDENTAL RELEASE MEASURES
RELEASE NOTES: Dilute with a large volume of water and hold in a pond or diked area until hydrogen peroxide decomposes. Hydrogen peroxide may be decomposed by adding sodium metabisulfite or sodium sulfite after diluting to about 5%. Dispose according to methods outlined for waste disposal.
Page 3 of 11 Hydrogen Peroxide (20 to 40%) (7722-84-1-3) Date: 04/05/2005
Combustible materials exposed to hydrogen peroxide should be immediately submerged in or rinsed with large amounts of water to ensure that all hydrogen peroxide is removed. Residual hydrogen peroxide that is allowed to dry (upon evaporation hydrogen peroxide can concentrate) on organic materials such as paper, fabrics, cotton, leather, wood or other combustibles can cause the material to ignite and result in a fire.
7. HANDLING AND STORAGE HANDLING: Wear chemical splash-type monogoggles and full-face shield, impervious clothing, such as rubber, PVC, etc., and rubber or neoprene gloves and shoes. Avoid cotton, wool and leather. Avoid excessive heat and contamination. Contamination may cause decomposition and generation of oxygen gas which could result in high pressures and possible container rupture. Hydrogen peroxide should be stored only in vented containers and transferred only in a prescribed manner (see FMC Technical Bulletins). Never return unused hydrogen peroxide to original container, empty drums should be triple rinsed with water before discarding. Utensils used for handling hydrogen peroxide should only be made of glass, stainless steel, aluminum or plastic.
STORAGE: Store drums in cool areas out of direct sunlight and away from combustibles. For bulk storage refer to FMC Technical Bulletins.
COMMENTS: VENTILATION: Provide mechanical general and/or local exhaust ventilation to prevent release of vapor or mist into the work environment.
8. EXPOSURE CONTROLS / PERSONAL PROTECTION EXPOSURE LIMITS
Chemical Name ACGIH OSHA Supplier
Hydrogen Peroxide 1 ppm (TWA) 1 ppm (PEL)
ENGINEERING CONTROLS: Ventilation should be provided to minimize the release of hydrogen peroxide vapors and mists into the work environment. Spills should be minimized or confined immediately to prevent release into the work area. Remove contaminated clothing immediately and wash before reuse.
PERSONAL PROTECTIVE EQUIPMENT EYES AND FACE: Use chemical splash-type monogoggles and a full-face shield made of polycarbonate, acetate, polycarbonate/acetate, PETG or thermoplastic.
RESPIRATORY: If concentrations in excess of 10 ppm are expected, use NIOSH/DHHS approved self-contained breathing apparatus (SCBA), or other approved atmospheric-supplied respirator (ASR) equipment (e.g., a full-face airline respirator (ALR)). DO NOT use any form of air-purifying respirator (APR) or filtering facepiece (AKA dust mask), especially those containing oxidizable sorbants such as activated carbon.
Page 4 of 11 Hydrogen Peroxide (20 to 40%) (7722-84-1-3) Date: 04/05/2005
PROTECTIVE CLOTHING: For body protection wear impervious clothing such as an approved splash protective suit made of SBR Rubber, PVC (PVC Outershell w/Polyester Substrate), Gore-Tex (Polyester trilaminate w/Gore-Tex), or a specialized HAZMAT Splash or Protective Suite (Level A, B, or C). For foot protection, wear approved boots made of NBR, PVC, Polyurethane, or neoprene. Overboots made of Latex or PVC, as well as firefighter boots or specialized HAZMAT boots are also permitted. DO NOT wear any form of boot or overboots made of nylon or nylon blends. DO NOT use cotton, wool or leather, as these materials react RAPIDLY with higher concentrations of hydrogen peroxide. Completely submerge hydrogen peroxide contaminated clothing or other materials in water prior to drying. Residual hydrogen peroxide, if allowed to dry on materials such as paper, fabrics, cotton, leather, wood or other combustibles can cause the material to ignite and result in a fire.
GLOVES: For hand protection, wear approved gloves made of nitrile, PVC, or neoprene. DO NOT use cotton, wool or leather for these materials react RAPIDLY with higher concentrations of hydrogen peroxide. Thoroughly rinse the outside of gloves with water prior to removal. Inspect regularly for leaks.
9. PHYSICAL AND CHEMICAL PROPERTIES ODOR: Odorless APPEARANCE: Clear, colorless liquid AUTOIGNITION TEMPERATURE: Non-combustible BOILING POINT: 103ºC/218ºF (20%); 107ºC/225ºF (31%); 108ºC/226ºF (35%) COEFFICIENT OF OIL / WATER: Not available DENSITY / WEIGHT PER VOLUME: Not available EVAPORATION RATE: Above 1 (Butyl Acetate = 1) FLASH POINT: Non-combustible FREEZING POINT: -15ºC/6ºF (20%); -26ºC/-15ºF (31%); -33ºC/-27ºF (35%) ODOR THRESHOLD: Not available OXIDIZING PROPERTIES: Strong oxidizer PERCENT VOLATILE: 100% pH: (as is) < / = 3.7
SOLUBILITY IN WATER: (in H2O % by wt) 100% SPECIFIC GRAVITY: 1.07 @ 20ºC/4ºC (20%); 1.11 @ 20ºC/4ºC (31%); 1.13 @ 20ºC/4ºC (35%) VAPOR DENSITY: (Air = 1): Not available VAPOR PRESSURE: 28 mmHg @ 30ºC (20%); 24 mmHg @ 30ºC (31%); 23 mmHg @ 30ºC (35%)
COMMENTS: pH (1% solution) @ 25ºC: 5.0 - 6.0
Page 5 of 11 Hydrogen Peroxide (20 to 40%) (7722-84-1-3) Date: 04/05/2005
10. STABILITY AND REACTIVITY
CONDITIONS TO AVOID: Excessive heat or contamination could cause product to become unstable. STABILITY: Stable (heat and contamination could cause decomposition) POLYMERIZATION: Will not occur INCOMPATIBLE MATERIALS: Reducing agents, wood, paper and other combustibles, iron and other heavy metals, copper alloys and caustic. HAZARDOUS DECOMPOSITION PRODUCTS: Oxygen which supports combustion.
COMMENTS: Materials to Avoid : Dirt, organics, cyanides and combustibles such as wood, paper, oils, etc.
11. TOXICOLOGICAL INFORMATION EYE EFFECTS: 35% hydrogen peroxide: Extremely irritating/corrosive (rabbit) [FMC Study Number: I83-748]
SKIN EFFECTS: 35% hydrogen peroxide: Mildly irritating after 4-hour exposure (rabbit) [FMC Study Number: I83-747]
DERMAL LD50: 35% hydrogen peroxide: > 2,000 mg/kg (rabbit) [FMC Study Number: I83-746]
ORAL LD50: 35% hydrogen peroxide: 1,193 mg/kg (rat) [FMC Study Number: I83-745]
INHALATION LC50: 50% hydrogen peroxide: > 0.17 mg/l (rat) [FMC Study Number: I89-1080]
TARGET ORGANS: Eyes, nose, throat and lungs
ACUTE EFFECTS FROM OVEREXPOSURE: Extremely irritating/corrosive to eyes and gastrointestinal tract. May cause irreversible tissue damage to the eyes including blindness. Inhalation of mist or vapors may be severely irritating to nose, throat and lungs. May cause skin irritation.
CHRONIC EFFECTS FROM OVEREXPOSURE: The International Agency for Research on Cancer (IARC) has concluded that there is inadequate evidence for carcinogenicity of hydrogen peroxide in humans, but limited evidence in experimental animals (Group 3 - not classifiable as to its carcinogenicity to humans). The American Conference of Governmental Industrial Hygienists (ACGIH) has concluded that hydrogen peroxide is a 'Confirmed Animal Carcinogen with Unknown Relevance to Humans' (A3).
Page 6 of 11 Hydrogen Peroxide (20 to 40%) (7722-84-1-3) Date: 04/05/2005
CARCINOGENICITY: Chemical Name IARC NTP OSHA Other Hydrogen Peroxide Listed Not listed Not listed (ACGIH) Listed (A3, Animal Carcinogen)
12. ECOLOGICAL INFORMATION
ECOTOXICOLOGICAL INFORMATION: Channel catfish 96-hour LC50 = 37.4 mg/L Fathead minnow 96-hour LC50 = 16.4 mg/L Daphnia magna 24-hour EC50 = 7.7 mg/L Daphnia pulex 48-hour LC50 = 2.4 mg/L Freshwater snail 96-hour LC50 = 17.7 mg/L For more information refer to ECETOC "Joint Assessment of Commodity Chemicals No. 22, Hydrogen Peroxide." ISSN-0773-6339, January 1993
CHEMICAL FATE INFORMATION: Hydrogen peroxide in the aquatic environment is subject to various reduction or oxidation processes and decomposes into water and oxygen. Hydrogen peroxide half-life in freshwater ranged from 8 hours to 20 days, in air from 10-20 hrs. and in soils from minutes to hours depending upon microbiological activity and metal contaminants.
13. DISPOSAL CONSIDERATIONS DISPOSAL METHOD: An acceptable method of disposal is to dilute with a large amount of water and allow the hydrogen peroxide to decompose followed by discharge into a suitable treatment system in accordance with all regulatory agencies. The appropriate regulatory agencies should be contacted prior to disposal.
14. TRANSPORT INFORMATION
U.S. DEPARTMENT OF TRANSPORTATION (DOT)
PROPER SHIPPING NAME: Hydrogen peroxide, aqueous solutions with not less than 20% but not more than 40% hydrogen peroxide PRIMARY HAZARD CLASS / DIVISION: 5.1 (Oxidizer) UN/NA NUMBER: UN 2014 PACKING GROUP: II LABEL(S): Oxidizer, Corrosive PLACARD(S): 5.1 (Oxidizer)
Page 7 of 11 Hydrogen Peroxide (20 to 40%) (7722-84-1-3) Date: 04/05/2005
ADDITIONAL INFORMATION: DOT Marking: Hydrogen Peroxide, aqueous solution with not less than 20%, but not more than 40% Hydrogen Peroxide, UN 2014
Hazardous Substance/RQ: Not applicable
49 STCC Number: 4918775
DOT Spec: stainless steel/high purity aluminum cargo tanks and rail cars. UN Spec: HDPE drums. Contact FMC for specific details.
INTERNATIONAL MARITIME DANGEROUS GOODS (IMDG)
PROPER SHIPPING NAME: Hydrogen peroxide, aqueous solutions with not less than 20%, but not more than 60% hydrogen peroxide.
INTERNATIONAL CIVIL AVIATION ORGANIZATION (ICAO) / INTERNATIONAL AIR TRANSPORT ASSOCIATION (IATA)
PROPER SHIPPING NAME: Hydrogen peroxide, aqueous solutions with not less than 20%, but not more than 40% hydrogen peroxide (*).
OTHER INFORMATION: (*) Air regulations permit shipment of Hydrogen Peroxide (20 - 40%) in non-vented containers for Air Cargo Only aircraft, as well as for Passenger and Cargo aircraft. HOWEVER, all FMC Hydrogen Peroxide containers are vented and therefore, air shipments of FMC H202 is not permitted. IATA air regulations state that venting of packages containing oxidizing substances is not permitted for air transport.
Protect from physical damage. Keep drums in upright position. Drums should not be stacked in transit. Do not store drum on wooden pallets.
15. REGULATORY INFORMATION UNITED STATES
SARA TITLE III (SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT) SECTION 302 EXTREMELY HAZARDOUS SUBSTANCES (40 CFR 355, APPENDIX A): Not listed
SECTION 311 HAZARD CATEGORIES (40 CFR 370): Fire Hazard, Immediate (Acute) Health Hazard
Page 8 of 11 Hydrogen Peroxide (20 to 40%) (7722-84-1-3) Date: 04/05/2005
SECTION 312 THRESHOLD PLANNING QUANTITY (40 CFR 370): The Threshold Planning Quantity (TPQ) for this product, if treated as a mixture, is 10,000 lbs; however, this product contains the following ingredients with a TPQ of less than 10,000 lbs.: None, (conc. <52%)
SECTION 313 REPORTABLE INGREDIENTS (40 CFR 372): Not listed
CERCLA (COMPREHENSIVE ENVIRONMENTAL RESPONSE COMPENSATION AND LIABILITY ACT)
CERCLA DESIGNATION & REPORTABLE QUANTITIES (RQ) (40 CFR 302.4): Unlisted (Hydrogen Peroxide 20-40%); RQ = 100 lbs.; Ignitability, Corrosivity
TSCA (TOXIC SUBSTANCE CONTROL ACT) TSCA INVENTORY STATUS (40 CFR 710): Listed
RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) RCRA IDENTIFICATION OF HAZARDOUS WASTE (40 CFR 261): Waste Number: D001, D002
CANADA WHMIS (WORKPLACE HAZARDOUS MATERIALS INFORMATION SYSTEM): Product Identification Number: 2014 Hazard Classification / Division: Class C (Oxidizer), Class D, Div. 2, Subdiv. B. (Toxic), Class E (Corrosive) Ingredient Disclosure List: Listed
INTERNATIONAL LISTINGS Hydrogen peroxide:
China: Listed Japan (ENCS): (1)-419 Korea: KE-20204 Philippines (PICCS): Listed
HAZARD, RISK AND SAFETY PHRASE DESCRIPTIONS:
Hydrogen Peroxide, (Index #008-003-00-9):
EC Symbols: Xn (Harmful)
Page 9 of 11 Hydrogen Peroxide (20 to 40%) (7722-84-1-3) Date: 04/05/2005
EC Risk Phrases: R22 (Harmful if swallowed.) R37/38 (Irritating to respiratory system and to skin.) R41 (Risk of serious damage to eyes.)
EC Safety Phrases: S1/2 (Keep locked up and out of reach of children.) S3 (Keep in a cool place.) S17 (Keep away from combustible material.) S26 (In case of contact with eyes, rinse immediately with plenty of water and seek medical advice) S28 (After contact with skin, wash immediately with plenty of water and soap.) S36/37/39 (Wear suitable protective clothing, gloves and eye/face protection.) S45 (In case of accident or if you feel unwell, seek medical advice immediately - show the label where possible.)
16. OTHER INFORMATION
HMIS
Health 3 Flammability 0 Physical Hazard 1 Personal Protection (PPE) H Protection = H (Safety goggles, gloves, apron, the use of a supplied air or SCBA respirator is required in lieu of a vapor cartridge respirator)
HMIS = Hazardous Materials Identification System
Degree of Hazard Code: 4 = Severe 3 = Serious 2 = Moderate 1 = Slight 0 = Minimal
NFPA
Health 3 Flammability 0 Reactivity 1 Special OX SPECIAL = OX (Oxidizer)
NFPA = National Fire Protection Association
Degree of Hazard Code:
Page 10 of 11 Hydrogen Peroxide (20 to 40%) (7722-84-1-3) Date: 04/05/2005
4 = Extreme 3 = High 2 = Moderate 1 = Slight 0 = Insignificant
REVISION SUMMARY: This MSDS replaces Revision #8, dated November 04, 2004. Changes in information are as follows: Section 3 (Composition / Information on Ingredients) Section 15 (Regulatory Information) Section 16 (Other Information)
Durox, Oxypure, Super D and FMC Logo - FMC Trademarks
© 2005 FMC Corporation. All Rights Reserved.
FMC Corporation believes that the information and recommendations contained herein (including data and statements) are accurate as of the date hereof. NO WARRANTY OF FITNESS FOR ANY PARTICULAR PURPOSE, WARRANTY OF MERCHANTABILITY, OR ANY OTHER WARRANTY, EXPRESSED OR IMPLIED, IS MADE CONCERNING THE INFORMATION PROVIDED HEREIN. The information provided herein relates only to the specific product designated and may not be applicable where such product is used in combination with any other materials or in any process. It is a violation of Federal law to use this product in a manner inconsistent with its labeling. Further, since the conditions and methods of use are beyond the control of FMC Corporation, FMC Corporation expressly disclaims any and all liability as to any results obtained or arising from any use of the product or reliance on such information.
Page 11 of 11 HCl MSDS
HYDROCHLORIC ACID (10%-33%)
MSDS Number: H3886 --- Effective Date: 11/17/99
1. Product Identification
Synonyms: This MSDS applies to the concentrated standard used to make laboratory solutions and any solution that contains more than 10% but less than 33% Hydrochloric acid. For diluted product, see MSDS for Hydrochloric Acid (less than 10%). For saturated solution CAS No.: 7647-01-0 Molecular Weight: 36.46 Chemical Formula: HCl in H2O Product Codes: J.T. Baker: 0323, 0327, 4654, 4657, 4658, 5618, 5619 Mallinckrodt: 2608, 2609, 2625, H151, H168, V024, V035, V328
2. Composition/Information on Ingredients
http://cheville.okstate.edu/photonicslab/Safety/safety/MSDS/hcl_msds.htm (1 of 9)7/2/2007 11:44:58 AM HCl MSDS
Ingredient CAS No Percent Hazardous ------
Hydrogen Chloride 7647-01-0 10 - 33% Yes Water 7732-18-5 67 - 90% No
3. Hazards Identification
Emergency Overview ------POISON! DANGER! CORROSIVE. LIQUID AND MIST CAUSE SEVERE BURNS TO ALL BODY TISSUE. MAY BE FATAL IF SWALLOWED OR INHALED.
J.T. Baker SAF-T-DATA(tm) Ratings (Provided here for your convenience) ------Health Rating: 3 - Severe (Poison) Flammability Rating: 0 - None Reactivity Rating: 2 - Moderate Contact Rating: 3 - Severe (Corrosive) Lab Protective Equip: GOGGLES & SHIELD; LAB COAT & APRON; VENT HOOD; PROPER GLOVES Storage Color Code: White (Corrosive) ------
Potential Health Effects ------
Inhalation: Corrosive! Inhalation of vapors can cause coughing, choking, inflammation of the nose, throat, and upper respiratory tract, and in severe cases, pulmonary edema, circulatory failure, and death. Ingestion: Corrosive! Swallowing hydrochloric acid can cause immediate pain and burns of the mouth, throat, esophagus and gastrointestinal tract. May cause nausea, vomiting, and diarrhea, and in severe cases, death. Skin Contact: Corrosive! Can cause redness, pain, and severe skin burns. Concentrated solutions cause deep ulcers and discolor skin. Eye Contact: Corrosive! Vapors are irritating and may cause damage to the eyes. Contact may cause severe burns and permanent eye damage.
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Chronic Exposure: Long-term exposure to concentrated vapors may cause erosion of teeth. Long term exposures seldom occur due to the corrosive properties of the acid. Aggravation of Pre-existing Conditions: Persons with pre-existing skin disorders or eye disease may be more susceptible to the effects of this substance.
4. First Aid Measures
Inhalation: Remove to fresh air. If not breathing, give artificial respiration. If breathing is difficult, give oxygen. Get medical attention immediately. Ingestion: DO NOT INDUCE VOMITING! Give large quantities of water or milk if available. Never give anything by mouth to an unconscious person. Get medical attention immediately. Skin Contact: In case of contact, immediately flush skin with plenty of water for at least 15 minutes while removing contaminated clothing and shoes. Wash clothing before reuse. Thoroughly clean shoes before reuse. Get medical attention immediately. Eye Contact: Immediately flush eyes with plenty of water for at least 15 minutes, lifting lower and upper eyelids occasionally. Get medical attention immediately.
5. Fire Fighting Measures
Fire: Not considered to be a fire hazard. May react with metals or heat to release flammable hydrogen gas. Explosion: Not considered to be an explosion hazard. Fire Extinguishing Media: Water or water spray. Neutralize with soda ash or slaked lime. Special Information: In the event of a fire, wear full protective clothing and NIOSH-approved self-contained breathing apparatus with full facepiece operated in the pressure demand or other positive pressure mode. Structural firefighter's protective clothing is ineffective for fires involving hydrochloric acid. Stay away from ends of tanks. Cool tanks with water spray until well after fire is out.
6. Accidental Release Measures
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Ventilate area of leak or spill. Wear appropriate personal protective equipment as specified in Section 8. Isolate hazard area. Keep unnecessary and unprotected personnel from entering. Contain and recover liquid when possible. Neutralize with alkaline material (soda ash, lime), then absorb with an inert material (e. g., vermiculite, dry sand, earth), and place in a chemical waste container. Do not use combustible materials, such as saw dust. Do not flush to sewer! US Regulations (CERCLA) require reporting spills and releases to soil, water and air in excess of reportable quantities. The toll free number for the US Coast Guard National Response Center is (800) 424-8802.
J. T. Baker NEUTRASORB(R) or TEAM(R) 'Low Na+' acid neutralizers are recommended for spills of this product.
7. Handling and Storage
Store in a cool, dry, ventilated storage area with acid resistant floors and good drainage. Protect from physical damage. Keep out of direct sunlight and away from heat, water, and incompatible materials. Do not wash out container and use it for other purposes. When diluting, the acid should always be added slowly to water and in small amounts. Never use hot water and never add water to the acid. Water added to acid can cause uncontrolled boiling and splashing. When opening metal containers, use non-sparking tools because of the possibility of hydrogen gas being present. Containers of this material may be hazardous when empty since they retain product residues (vapors, liquid); observe all warnings and precautions listed for the product.
8. Exposure Controls/Personal Protection
Airborne Exposure Limits: For Hydrochloric acid: - OSHA Permissible Exposure Limit (PEL): 5 ppm (Ceiling) - ACGIH Threshold Limit Value (TLV): 5 ppm (STEL/Ceiling)
Ventilation System: A system of local and/or general exhaust is recommended to keep employee exposures below the Airborne Exposure Limits. Local exhaust ventilation is generally preferred because it can control the emissions of the contaminant at its source, preventing dispersion of it into the general work area. Please refer to the ACGIH document, Industrial Ventilation, A Manual of Recommended Practices, most recent edition, for details. Personal Respirators (NIOSH Approved): If the exposure limit is exceeded, a full facepiece respirator with an acid gas cartridge may be worn up to 50 times the exposure limit or the maximum use concentration specified by the appropriate regulatory agency or respirator supplier, whichever is lowest. For emergencies or
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instances where the exposure levels are not known, use a full-facepiece positive-pressure, air-supplied respirator. WARNING: Air purifying respirators do not protect workers in oxygen- deficient atmospheres. Skin Protection: Rubber or neoprene gloves and additional protection including impervious boots, apron, or coveralls, as needed in areas of unusual exposure to prevent skin contact. Eye Protection: Use chemical safety goggles and/or a full face shield where splashing is possible. Maintain eye wash fountain and quick-drench facilities in work area.
9. Physical and Chemical Properties
Appearance: Clear, colorless liquid. Odor: Pungent odor. Solubility: Infinitely soluble. Density: 1.05 @ 15C (59F) pH: For HCL solutions: 0.1 (1.0 N), 1.1 (0.1 N), 2.02 (0.01 N) % Volatiles by volume @ 21C (70F): 100 Boiling Point: 101 - 103C (214 - 217F) Melting Point: No information found. Vapor Density (Air=1): No information found. Vapor Pressure (mm Hg): No information found. Evaporation Rate (BuAc=1): No information found.
10. Stability and Reactivity
Stability: Stable under ordinary conditions of use and storage. Hazardous Decomposition Products: When heated to decomposition, emits toxic hydrogen chloride fumes and will react with water or steam to produce heat and toxic and corrosive fumes. Thermal oxidative decomposition produces toxic chlorine fumes and explosive hydrogen gas. Hazardous Polymerization:
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Will not occur. Incompatibilities: A strong mineral acid, concentrated hydrochloric acid is highly reactive with strong bases, metals, metal oxides, hydroxides, amines, carbonates and other alkaline materials. Incompatible with materials such as cyanides, sulfides, sulfites, and formaldehyde. Conditions to Avoid: Heat, direct sunlight.
11. Toxicological Information
Hydrochloric acid: Inhalation rat LC50: 3124 ppm/1H; Oral rabbit LD50: 900 mg/kg. Investigated as a tumorigen, mutagen, reproductive effector.
------\Cancer Lists\------NTP Carcinogen--- Ingredient Known Anticipated IARC Category ------Hydrogen Chloride (7647-01-0) No No 3 Water (7732-18-5) No No None
12. Ecological Information
Environmental Fate: When released into the soil, this material is not expected to biodegrade. When released into the soil, this material may leach into groundwater. Environmental Toxicity: This material is expected to be toxic to aquatic life.
13. Disposal Considerations
Whatever cannot be saved for recovery or recycling should be handled as hazardous waste and sent to a RCRA approved waste facility. Processing, use or contamination of this product may change the waste management options. State and local disposal regulations may differ from federal disposal regulations. Dispose of container and unused contents in accordance with federal, state and local requirements.
14. Transport Information
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Domestic (Land, D.O.T.) ------Proper Shipping Name: HYDROCHLORIC ACID Hazard Class: 8 UN/NA: UN1789 Packing Group: II Information reported for product/size: 200L
International (Water, I.M.O.) ------Proper Shipping Name: HYDROCHLORIC ACID Hazard Class: 8 UN/NA: UN1789 Packing Group: II Information reported for product/size: 200L
15. Regulatory Information
------\Chemical Inventory Status - Part 1\------Ingredient TSCA EC Japan Australia ------Hydrogen Chloride (7647-01-0) Yes Yes Yes Yes Water (7732-18-5) Yes Yes Yes Yes
------\Chemical Inventory Status - Part 2\------Canada-- Ingredient Korea DSL NDSL Phil. ------Hydrogen Chloride (7647-01-0) Yes Yes No Yes Water (7732-18-5) Yes Yes No Yes
------\Federal, State & International Regulations - Part 1\------SARA 302------SARA 313------Ingredient RQ TPQ List Chemical Catg. ------Hydrogen Chloride (7647-01-0) 5000 500* Yes No Water (7732-18-5) No No No No
------\Federal, State & International Regulations - Part 2\------RCRA- -TSCA- Ingredient CERCLA 261.33 8(d) ------
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Hydrogen Chloride (7647-01-0) 5000 No No Water (7732-18-5) No No No
Chemical Weapons Convention: No TSCA 12(b): No CDTA: Yes SARA 311/312: Acute: Yes Chronic: Yes Fire: No Pressure: No Reactivity: No (Mixture / Liquid)
Australian Hazchem Code: 2R Poison Schedule: No information found. WHMIS: This MSDS has been prepared according to the hazard criteria of the Controlled Products Regulations (CPR) and the MSDS contains all of the information required by the CPR.
16. Other Information
NFPA Ratings: Health: 3 Flammability: 0 Reactivity: 0 Label Hazard Warning: POISON! DANGER! CORROSIVE. LIQUID AND MIST CAUSE SEVERE BURNS TO ALL BODY TISSUE. MAY BE FATAL IF SWALLOWED OR INHALED. Label Precautions: Do not get in eyes, on skin, or on clothing. Avoid breathing vapor or mist. Keep container closed. Use with adequate ventilation. Wash thoroughly after handling. Label First Aid: If swallowed, DO NOT INDUCE VOMITING. Give large quantities of water. Never give anything by mouth to an unconscious person. If inhaled, remove to fresh air. If not breathing, give artificial respiration. If breathing is difficult, give oxygen. In case of contact, immediately flush eyes or skin with plenty of water for at least 15 minutes. Remove contaminated clothing and shoes. Wash clothing before reuse. In all cases call a physician. Product Use: Laboratory Reagent. Revision Information: No changes. Disclaimer: ************************************************************************************************ Mallinckrodt Baker, Inc. provides the information contained herein in good faith but makes no representation as to its comprehensiveness or accuracy. This document is intended only as a guide to the appropriate precautionary handling of the material by a properly trained person using this product. Individuals receiving the information must
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exercise their independent judgment in determining its appropriateness for a particular purpose. MALLINCKRODT BAKER, INC. MAKES NO REPRESENTATIONS OR WARRANTIES, EITHER EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION ANY WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE WITH RESPECT TO THE INFORMATION SET FORTH HEREIN OR THE PRODUCT TO WHICH THE INFORMATION REFERS. ACCORDINGLY, MALLINCKRODT BAKER, INC. WILL NOT BE RESPONSIBLE FOR DAMAGES RESULTING FROM USE OF OR RELIANCE UPON THIS INFORMATION. ************************************************************************************************ Prepared by: Strategic Services Division Phone Number: (314) 539-1600 (U.S.A.)
The Oklahoma State University Photonics Laboratory is supported through a National Science Foundation Course Curriculum and Laboratory Improvement Award. The information on this page may be distributed freely.
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MSDS Number: N3660 * * * * * Effective Date: 05/06/05 * * * * * Supercedes: 07/02/02
NITRIC ACID, 50-70%
1. Product Identification
Synonyms: Aqua Fortis; Azotic Acid; Nitric Acid 50%; Nitric Acid 65%; nitric acid 69-70% CAS No.: 7697-37-2 Molecular Weight: 63.01 Chemical Formula: HNO3 Product Codes: J.T. Baker: 411D, 412D, 5371, 5796, 5801, 5826, 5856, 5876, 5896, 9597, 9598, 9600, 9601, 9602, 9603, 9604, 9606, 9607, 9608, 9610, 9616, 9617, 9670 Mallinckrodt: 1409, 2704, 2705, 2716, 6623, H862, H988, H993, H998, V077, V650
2. Composition/Information on Ingredients
Ingredient CAS No Percent Hazardous ------
Nitric Acid 7697-37-2 50 - 70% Yes Water 7732-18-5 30 - 50% No
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3. Hazards Identification
Emergency Overview ------POISON! DANGER! STRONG OXIDIZER. CONTACT WITH OTHER MATERIAL MAY CAUSE FIRE. CORROSIVE. LIQUID AND MIST CAUSE SEVERE BURNS TO ALL BODY TISSUE. MAY BE FATAL IF SWALLOWED OR INHALED. INHALATION MAY CAUSE LUNG AND TOOTH DAMAGE.
SAF-T-DATA(tm) Ratings (Provided here for your convenience) ------Health Rating: 4 - Extreme (Poison) Flammability Rating: 0 - None Reactivity Rating: 3 - Severe (Oxidizer) Contact Rating: 4 - Extreme (Corrosive) Lab Protective Equip: GOGGLES & SHIELD; LAB COAT & APRON; VENT HOOD; PROPER GLOVES Storage Color Code: White (Corrosive) ------
Potential Health Effects ------
Nitric acid is extremely hazardous; it is corrosive, reactive, an oxidizer, and a poison.
Inhalation: Corrosive! Inhalation of vapors can cause breathing difficulties and lead to pneumonia and pulmonary edema, which may be fatal. Other symptoms may include coughing, choking, and irritation of the nose, throat, and respiratory tract. Ingestion: Corrosive! Swallowing nitric acid can cause immediate pain and burns of the mouth, throat, esophagus and gastrointestinal tract. Skin Contact: Corrosive! Can cause redness, pain, and severe skin burns. Concentrated solutions cause deep ulcers and stain skin a yellow or yellow-brown color. Eye Contact: Corrosive! Vapors are irritating and may cause damage to the eyes. Contact may cause severe burns and permanent eye damage. Chronic Exposure: Long-term exposure to concentrated vapors may cause erosion of teeth and lung damage. Long-term exposures seldom occur due to the corrosive properties of the acid. Aggravation of Pre-existing Conditions: Persons with pre-existing skin disorders, eye disease, or cardiopulmonary diseases may be more susceptible to the effects of this substance.
4. First Aid Measures
Immediate first aid treatment reduces the health effects of this substance.
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Inhalation: Remove to fresh air. If not breathing, give artificial respiration. If breathing is difficult, give oxygen. Call a physician. Ingestion: DO NOT INDUCE VOMITING! Give large quantities of water or milk if available. Never give anything by mouth to an unconscious person. Get medical attention immediately. Skin Contact: In case of contact, immediately flush skin with plenty of water for at least 15 minutes while removing contaminated clothing and shoes. Wash clothing before reuse. Thoroughly clean shoes before reuse. Get medical attention immediately. Eye Contact: Immediately flush eyes with plenty of water for at least 15 minutes, lifting lower and upper eyelids occasionally. Get medical attention immediately.
5. Fire Fighting Measures
Fire: Not combustible, but substance is a strong oxidizer and its heat of reaction with reducing agents or combustibles may cause ignition. Can react with metals to release flammable hydrogen gas. Explosion: Reacts explosively with combustible organic or readily oxidizable materials such as: alcohols, turpentine, charcoal, organic refuse, metal powder, hydrogen sulfide, etc. Reacts with most metals to release hydrogen gas which can form explosive mixtures with air. Fire Extinguishing Media: Water spray may be used to keep fire exposed containers cool. Do not get water inside container. Special Information: Increases the flammability of combustible, organic and readily oxidizable materials. In the event of a fire, wear full protective clothing and NIOSH-approved self-contained breathing apparatus with full facepiece operated in the pressure demand or other positive pressure mode.
6. Accidental Release Measures
Ventilate area of leak or spill. Wear appropriate personal protective equipment as specified in Section 8. Isolate hazard area. Keep unnecessary and unprotected personnel from entering. Contain and recover liquid when possible. Neutralize with alkaline material (soda ash, lime), then absorb with an inert material (e. g., vermiculite, dry sand, earth), and place in a chemical waste container. Do not use combustible materials, such as saw dust. Do not flush to sewer! US Regulations (CERCLA) require reporting spills and releases to soil, water and air in excess of reportable quantities. The toll free number for the US Coast Guard National Response Center is (800) 424-8802.
J. T. Baker NEUTRASORB® acid neutralizers are recommended for spills of this product.
7. Handling and Storage
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Store in a cool, dry, ventilated storage area with acid resistant floors and good drainage. Protect from physical damage. Keep out of direct sunlight and away from heat, water, and incompatible materials. Do not wash out container and use it for other purposes. When diluting, the acid should always be added slowly to water and in small amounts. Never use hot water and never add water to the acid. Water added to acid can cause uncontrolled boiling and splashing. Containers of this material may be hazardous when empty since they retain product residues (vapors, liquid); observe all warnings and precautions listed for the product.
8. Exposure Controls/Personal Protection
Airborne Exposure Limits: -OSHA Permissible Exposure Limit (PEL): 2 ppm (TWA), 4 ppm (STEL) -ACGIH Threshold Limit Value (TLV): 2 ppm (TWA); 4 ppm (STEL)
Ventilation System: A system of local and/or general exhaust is recommended to keep employee exposures below the Airborne Exposure Limits. Local exhaust ventilation is generally preferred because it can control the emissions of the contaminant at its source, preventing dispersion of it into the general work area. Please refer to the ACGIH document, Industrial Ventilation, A Manual of Recommended Practices, most recent edition, for details. Personal Respirators (NIOSH Approved): If the exposure limit is exceeded, wear a supplied air, full-facepiece respirator, airlined hood, or full-facepiece self-contained breathing apparatus. Nitric acid is an oxidizer and should not come in contact with cartridges and canisters that contain oxidizable materials, such as activated charcoal. Canister-type respirators using sorbents are ineffective. Skin Protection: Wear impervious protective clothing, including boots, gloves, lab coat, apron or coveralls, as appropriate, to prevent skin contact. Eye Protection: Use chemical safety goggles and/or a full face shield where splashing is possible. Maintain eye wash fountain and quick-drench facilities in work area.
9. Physical and Chemical Properties
Appearance: Colorless to yellowish liquid. Odor: Suffocating, acrid. Solubility: Infinitely soluble. Specific Gravity: 1.41 pH: 1.0 (0.1M solution) % Volatiles by volume @ 21C (70F): 100 (as water and acid)
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Boiling Point: 122C (252F) Melting Point: -42C (-44F) Vapor Density (Air=1): 2-3 Vapor Pressure (mm Hg): 48 @ 20C (68F) Evaporation Rate (BuAc=1): No information found.
10. Stability and Reactivity
Stability: Stable under ordinary conditions of use and storage. Containers may burst when heated. Hazardous Decomposition Products: When heated to decomposition, emits toxic nitrogen oxides fumes and hydrogen nitrate. Will react with water or steam to produce heat and toxic and corrosive fumes. Hazardous Polymerization: Will not occur. Incompatibilities: A dangerously powerful oxidizing agent, concentrated nitric acid is incompatible with most substances, especially strong bases, metallic powders, carbides, hydrogen sulfide, turpentine, and combustible organics. Conditions to Avoid: Light and heat.
11. Toxicological Information
Nitric acid: Inhalation rat LC50: 244 ppm (NO2)/30M; Investigated as a mutagen, reproductive effector. Oral (human) LDLo: 430 mg/kg.
------\Cancer Lists\------NTP Carcinogen--- Ingredient Known Anticipated IARC Category ------Nitric Acid (7697-37-2) No No None Water (7732-18-5) No No None
12. Ecological Information
Environmental Fate: No information found. Environmental Toxicity:
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No information found.
13. Disposal Considerations
Whatever cannot be saved for recovery or recycling should be managed in an appropriate and approved waste facility. Although not a listed RCRA hazardous waste, this material may exhibit one or more characteristics of a hazardous waste and require appropriate analysis to determine specific disposal requirements. Processing, use or contamination of this product may change the waste management options. State and local disposal regulations may differ from federal disposal regulations. Dispose of container and unused contents in accordance with federal, state and local requirements.
14. Transport Information
Domestic (Land, D.O.T.) ------Proper Shipping Name: NITRIC ACID Hazard Class: 8 UN/NA: UN2031 Packing Group: II Information reported for product/size: 6.5GL
International (Water, I.M.O.) ------Proper Shipping Name: NITRIC ACID (WITH NOT MORE THAN 70% NITRIC ACID) Hazard Class: 8 UN/NA: UN2031 Packing Group: II Information reported for product/size: 6.5GL
15. Regulatory Information
------\Chemical Inventory Status - Part 1\------Ingredient TSCA EC Japan Australia ------Nitric Acid (7697-37-2) Yes Yes Yes Yes Water (7732-18-5) Yes Yes Yes Yes
------\Chemical Inventory Status - Part 2\------Canada-- Ingredient Korea DSL NDSL Phil. ------Nitric Acid (7697-37-2) Yes Yes No Yes
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Water (7732-18-5) Yes Yes No Yes
------\Federal, State & International Regulations - Part 1\------SARA 302------SARA 313------Ingredient RQ TPQ List Chemical Catg. ------Nitric Acid (7697-37-2) 1000 1000 Yes No Water (7732-18-5) No No No No
------\Federal, State & International Regulations - Part 2\------RCRA- -TSCA- Ingredient CERCLA 261.33 8(d) ------Nitric Acid (7697-37-2) 1000 No No Water (7732-18-5) No No No
Chemical Weapons Convention: No TSCA 12(b): No CDTA: No SARA 311/312: Acute: Yes Chronic: Yes Fire: Yes Pressure: No Reactivity: No (Mixture / Liquid)
Australian Hazchem Code: 2PE Poison Schedule: S6 WHMIS: This MSDS has been prepared according to the hazard criteria of the Controlled Products Regulations (CPR) and the MSDS contains all of the information required by the CPR.
16. Other Information
NFPA Ratings: Health: 3 Flammability: 0 Reactivity: 0 Other: Oxidizer Label Hazard Warning: POISON! DANGER! STRONG OXIDIZER. CONTACT WITH OTHER MATERIAL MAY CAUSE FIRE. CORROSIVE. LIQUID AND MIST CAUSE SEVERE BURNS TO ALL BODY TISSUE. MAY BE FATAL IF SWALLOWED OR INHALED. INHALATION MAY CAUSE LUNG AND TOOTH DAMAGE. Label Precautions: Do not get in eyes, on skin, or on clothing. Do not breathe vapor or mist. Use only with adequate ventilation. Wash thoroughly after handling. Keep from contact with clothing and other combustible materials. Do not store near combustible materials. Store in a tightly closed container. Remove and wash contaminated clothing promptly. Label First Aid: In case of contact, immediately flush eyes or skin with plenty of water for at least 15 minutes while removing contaminated clothing and shoes. Wash clothing before reuse. If swallowed, DO NOT INDUCE VOMITING.
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Give large quantities of water. Never give anything by mouth to an unconscious person. If inhaled, remove to fresh air. If not breathing, give artificial respiration. If breathing is difficult, give oxygen. In all cases get medical attention immediately. Product Use: Laboratory Reagent. Revision Information: No Changes. Disclaimer: ************************************************************************************************ Mallinckrodt Baker, Inc. provides the information contained herein in good faith but makes no representation as to its comprehensiveness or accuracy. This document is intended only as a guide to the appropriate precautionary handling of the material by a properly trained person using this product. Individuals receiving the information must exercise their independent judgment in determining its appropriateness for a particular purpose. MALLINCKRODT BAKER, INC. MAKES NO REPRESENTATIONS OR WARRANTIES, EITHER EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION ANY WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE WITH RESPECT TO THE INFORMATION SET FORTH HEREIN OR THE PRODUCT TO WHICH THE INFORMATION REFERS. ACCORDINGLY, MALLINCKRODT BAKER, INC. WILL NOT BE RESPONSIBLE FOR DAMAGES RESULTING FROM USE OF OR RELIANCE UPON THIS INFORMATION. ************************************************************************************************ Prepared by: Environmental Health & Safety Phone Number: (314) 654-1600 (U.S.A.)
http://www.jtbaker.com/msds/englishhtml/N3660.htm (8 of 8)7/2/2007 11:46:12 AM Material Safety Data Sheet 1,1,1-Trichloroethane
ACC# 14370 Section 1 - Chemical Product and Company Identification
MSDS Name: 1,1,1-Trichloroethane Catalog Numbers: AC294930000, AC294930250, AC294932500, AC327940000, AC327940010, AC327942500, S80231, T391-20, T391-4, T398-4 Synonyms: Methyl chloroform; Methyltrichloromethane; Trichloroethane; Trichloromethylmethane; 1,1,1-TCE. Company Identification: Fisher Scientific 1 Reagent Lane Fair Lawn, NJ 07410 For information, call: 201-796-7100 Emergency Number: 201-796-7100 For CHEMTREC assistance, call: 800-424-9300 For International CHEMTREC assistance, call: 703-527-3887
Section 2 - Composition, Information on Ingredients
CAS# Chemical Name Percent EINECS/ELINCS 71-55-6 1,1,1-Trichloroethane >96 200-756-3 123-91-1 1,4-Dioxane 2.5 204-661-8 106-88-7 1,2-Butylene oxide 0.47 203-438-2 75-52-5 Nitromethane 0.34 200-876-6
Section 3 - Hazards Identification
EMERGENCY OVERVIEW
Appearance: colorless liquid. Warning! Causes eye, skin, and respiratory tract irritation. May be harmful if inhaled. May cause central nervous system depression. This is a CFC substance which destroys ozone in the upper atmosphere. Destruction of the ozone layer can lead to increased ultraviolet radiation which, with excess exposure to sunlight, can lead to an increase in skin cancer and eye cataracts. Target Organs: Central nervous system, respiratory system, eyes, skin.
Potential Health Effects Eye: Causes mild eye irritation. Vapors may cause eye irritation. Skin: Causes skin irritation. Prolonged or repeated contact may dry/defat the skin and cause irritation. 1,4-Dioxane may cause an allergic skin reaction, and absorption of this substance may cause systemic toxicty. Methyl chloroform is an acknowledged skin irritant in guinea pigs, where a single topical application of 1 ml or repeated contact over 3 days causes edema, erythema, inflammation, and cellular degeneration. There is one case report of allergic contact dermatitis in a worker exposed to 1,1,1-trichloroethane. It is not possible to draw any conclusions from this single report. Ingestion: Causes gastrointestinal irritation with nausea, vomiting and diarrhea. Low hazard for usual industrial handling. Although there are no case reports of aspiration, it was induced in rats in one study. In addition, based on its physical properties (viscosity and surface tension), it seems likely that 1,1,1-trichloroethane can be aspirated. Inhalation: Inhalation of high concentrations may cause central nervous system effects characterized by nausea, headache, dizziness, unconsciousness and coma. May cause narcotic effects in high concentration. Causes irritation of the mucous membrane and upper respiratory tract. Numerous deaths due to depression of CNS control of respiration and fatal cardiac arrhythmia have been reported from methyl chloroform inhalation (accidental or intentional) in poorly ventilated rooms, pits, tanks, and other small areas (Documentation of the TLV). Cases of intentional abuse of 1,1,1-trichloroethane in substances such as typewriter correction fluid for euphoric symptoms have been documented. Chronic: Prolonged or repeated skin contact may cause defatting and dermatitis. Exposure to high concentrations may cause central nervous system depression. Studies with solvent abusers have established that severe cardiac arrhythmias may result from cardiac sensitization, where the heart has an increased response to circulating epinephrine. In these cases, exposures by far exceeded occupational relevant levels. Liver effects have been observed in some animal studies at high
Section 4 - First Aid Measures
Eyes: In case of contact, immediately flush eyes with plenty of water for a t least 15 minutes. Get medical aid. Skin: In case of contact, flush skin with plenty of water. Remove contaminated clothing and shoes. Get medical aid if irritation develops and persists. Wash clothing before reuse. Ingestion: Potential for aspiration if swallowed. Get medical aid immediately. Do not induce vomiting unless directed to do so by medical personnel. Never give anything by mouth to an unconscious person. If vomiting occurs naturally, have victim lean forward. Inhalation: If inhaled, remove to fresh air. If not breathing, give artificial respiration. If breathing is difficult, give oxygen. Get medical aid. Notes to Physician: Alcoholic beverage consumption may enhance the toxic effects of this substance.
Section 5 - Fire Fighting Measures
General Information: As in any fire, wear a self-contained breathing apparatus in pressure- demand, MSHA/NIOSH (approved or equivalent), and full protective gear. During a fire, irritating and highly toxic gases may be generated by thermal decomposition or combustion. Use water spray to keep fire-exposed containers cool. Substance is nonflammable. Vapors may accumulate in confined spaces Methyl chloroform burns only in excess oxygen or in air if a strong source of ignition is present. No flash point in conventional closed tester; however, vapors in containers can explode if subjected to high energy source. Extinguishing Media: Use extinguishing media most appropriate for the surrounding fire. Flash Point: Not applicable. Autoignition Temperature: 500 deg C ( 932.00 deg F) Explosion Limits, Lower:7.0 vol % Upper: 16 vol % NFPA Rating: (estimated) Health: 2; Flammability: 1; Instability: 0 Section 6 - Accidental Release Measures
General Information: Use proper personal protective equipment as indicated in Section 8. Spills/Leaks: Absorb spill with inert material (e.g. vermiculite, sand or earth), then place in suitable container. Clean up spills immediately, observing precautions in the Protective Equipment section. Provide ventilation. Approach spill from upwind.
Section 7 - Handling and Storage
Handling: Wash thoroughly after handling. Remove contaminated clothing and wash before reuse. Use with adequate ventilation. Avoid contact with eyes, skin, and clothing. Keep container tightly closed. Avoid breathing vapor. Storage: Store in a cool, dry, well-ventilated area away from incompatible substances. Do not store in aluminum containers.
Section 8 - Exposure Controls, Personal Protection
Engineering Controls: Facilities storing or utilizing this material should be equipped with an eyewash facility and a safety shower. Use adequate general or local exhaust ventilation to keep airborne concentrations below the permissible exposure limits. Exposure Limits Chemical Name ACGIH NIOSH OSHA - Final PELs 350 ppm TWA; 450 ppm 350 ppm TWA; 1900 1,1,1-Trichloroethane 700 ppm IDLH STEL mg/m3 TWA 20 ppm TWA; Skin - potential significant 100 ppm TWA; 360 1,4-Dioxane contribution to overall 500 ppm IDLH mg/m3 TWA exposure by the cutaneous r oute 1,2-Butylene oxide none listed none listed none listed 100 ppm TWA; 250 Nitromethane 20 ppm TWA 750 ppm IDLH mg/m3 TWA
OSHA Vacated PELs: 1,1,1-Trichloroethane: 350 ppm TWA; 1900 mg/m3 TWA 1,4-Dioxane: 25 ppm TWA; 90 mg/m3 TWA 1,2-Butylene oxide: No OSHA Vacated PELs are listed for this chemical. Nitromethane: 100 ppm TWA; 250 mg/m3 TWA Personal Protective Equipment Eyes: Wear chemical splash goggles. Skin: Wear appropriate protective gloves to prevent skin exposure. Clothing: Wear appropriate protective clothing to minimize contact with skin. Respirators: A respiratory protection program that meets OSHA's 29 CFR 1910.134 and ANSI Z88.2 requirements or European Standard EN 149 must be followed whenever workplace conditions warrant respirator use.
Section 9 - Physical and Chemical Properties
Physical State: Liquid Appearance: colorless Odor: Sweet, mild chloroform-like. pH: Not applicable. Vapor Pressure: 100 mm Hg @ 20 deg C Vapor Density: 4.55 (air=1) Evaporation Rate:1.0 (carbon tetrachloride=1) Viscosity: 0.86 cP @ 20 deg C Boiling Point: 74 deg C Freezing/Melting Point:-33 deg C Decomposition Temperature:> 260 deg C Solubility: Insoluble. Specific Gravity/Density:1.338 (water=1) Molecular Formula:C2H3Cl3 Molecular Weight:133.38
Section 10 - Stability and Reactivity
Chemical Stability: Because of 1,1,1-TCE's reactivity with magnesium, aluminum, & their alloys, inhibitors (like 1,4-dioxane, 1,3-dioxolane, isobutyl alcohol, or nitroethane) are often added to increase the stability of the solvent & prevent corrosion of metal parts. 1,1,1-Trichloroethane reacts slowly with water to produce hydrochloric acid. Conditions to Avoid: High temperatures, ignition sources, moisture, confined spaces. Incompatibilities with Other Materials: Strong oxidizing agents, strong bases, aluminum, magnesium, chemically active metals. Hazardous Decomposition Products: Hydrogen chloride, chlorine, phosgene, carbon monoxide, carbon dioxide. Hazardous Polymerization: Will not occur.
Section 11 - Toxicological Information
RTECS#: CAS# 71-55-6: KJ2975000 CAS# 123-91-1: JG8225000 CAS# 106-88-7: EK3675000 CAS# 75-52-5: PA9800000 LD50/LC50: CAS# 71-55-6: Draize test, rabbit, eye: 100 mg Mild; Draize test, rabbit, eye: 2 mg/24H Severe; Draize test, rabbit, skin: 5 gm/12D (Intermittent) Mild; Draize test, rabbit, skin: 20 mg/24H Moderate; Inhalation, mouse: LC50 = 3911 ppm/2H; Inhalation, mouse: LC50 = 29492 ppm/10M; Inhalation, rat: LC50 = 17000 ppm/4H; Inhalation, rat: LC50 = 14250 ppm/7H; Inhalation, rat: LC50 = 20000 ppm/2H; Oral, mouse: LD50 = 6 gm/kg; Oral, rabbit: LD50 = 5660 mg/kg; Oral, rat: LD50 = 9600 CAS# 123-91-1: Draize test, rabbit, eye: 100 mg Severe; Draize test, rabbit, eye: 100 mg/24H Moderate; Inhalation, mouse: LC50 = 37 gm/m3/2H; Inhalation, rat: LC50 = 46 gm/m3/2H; Oral, mouse: LD50 = 5300 mg/kg; Oral, rabbit: LD50 = 2 gm/kg; Oral, rat: LD50 = 4200 mg/kg; Skin, rabbit: LD50 = 7600 uL/kg; .
CAS# 106-88-7: Draize test, rabbit, eye: 100 mg/24H Moderate; Draize test, rabbit, skin: 500 mg/24H Mild; Inhalation, rat: LC50 = 6300 mg/m3/4H; Oral, rat: LD50 = 500 mg/kg; Skin, rabbit: LD50 = 2100 uL/kg; .
CAS# 75-52-5: Oral, mouse: LD50 = 950 mg/kg; Oral, rat: LD50 = 940 mg/kg; .
Carcinogenicity: CAS# 71-55-6: Not listed by ACGIH, IARC, NTP, or CA Prop 65. CAS# 123-91-1:
z ACGIH: A3 - Confirmed animal carcinogen with unknown relevance to humans z California: carcinogen, initial date 1/1/88 z NTP: Suspect carcinogen z IARC: Group 2B carcinogen
CAS# 106-88-7:
z ACGIH: Not listed. z California: Not listed. z NTP: Not listed. z IARC: Group 2B carcinogen
CAS# 75-52-5:
z ACGIH: A3 - Confirmed animal carcinogen with unknown relevance to humans z California: carcinogen, initial date 5/1/97 z NTP: Suspect carcinogen z IARC: Group 2B carcinogen
Epidemiology: No information found Teratogenicity: Animal evidence suggests that 1,1,1-TCE is not teratogenic at exposures which are not maternally toxic. Slight fetotoxicity (for example, reduced fetal weight) has been reported at doses which were not maternally toxic. Reproductive Effects: Animal evidence suggests that 1,1,1-TCE does not cause reproductive effects. Mutagenicity: Evidence from studies using live animals suggests that 1,1,1-trichloroethane is not mutagenic. Neurotoxicity: Some studies using sensitive neurobehavioural tests have shown altered scores for exposed workers. However, whether or not these results indicate nervous system damage is not clear. Other studies with 1,1,1-TCE have not shown any changes. Other Studies:
Section 12 - Ecological Information
Ecotoxicity: Fish: Fathead Minnow: EC50 = 52.9 mg/L; 96 Hr; Flow-through at 25.5°CFish: Bluegill/Sunfish: LC50 = 72 mg/L; 96 Hr; Static bioassayFish: Fathead Minnow: LC50 = 52.9 mg/L; 96 Hr; Flow-through at 25.5°CFish: Sheepshead minnow: LC50 = 53-72 mg/L; 96 Hr; UnspecifiedWater flea Daphnia: EC50 > 530 mg/L; 48 Hr; Unspecified Releases to surface water will decrease in concn almost entirely due to evaporation. Spills on land will decrease in concentration almost entirely due to volatilization and leaching. Environmental: Releases to air may be transported long distances and partially return to earth in rain. In the troposphere, 1,1,1-trichloroethane will degrade very slowly by photooxidation and also slowly diffuse to the stratosphere where photodegradation will be rapid. This substance has a high potential for oxone depletion. Physical: No information available. Other: No information available.
Section 13 - Disposal Considerations
Chemical waste generators must determine whether a discarded chemical is classified as a hazardous waste. US EPA guidelines for the classification determination are listed in 40 CFR Parts 261.3. Additionally, waste generators must consult state and local hazardous waste regulations to ensure complete and accurate classification. RCRA P-Series: None listed. RCRA U-Series: CAS# 71-55-6: waste number U226. CAS# 123-91-1: waste number U108.
Section 14 - Transport Information
US DOT Canada TDG Shipping Name: 1,1,1-TRICHLOROETHANE 1,1,1-TRICHLOROETHANE Hazard Class: 6.1 6.1 UN Number: UN2831 UN2831 Packing Group: III III
Section 15 - Regulatory Information
US FEDERAL
TSCA CAS# 71-55-6 is listed on the TSCA inventory. CAS# 123-91-1 is listed on the TSCA inventory. CAS# 106-88-7 is listed on the TSCA inventory. CAS# 75-52-5 is listed on the TSCA inventory. Health & Safety Reporting List CAS# 71-55-6: Effective 10/4/82, Sunset 10/4/92 CAS# 106-88-7: Effective 10/4/82, Sunset 10/4/92 CAS# 75-52-5: Effective 4/13/89, Sunset 12/19/95 Chemical Test Rules CAS# 71-55-6: 40 CFR 799.5000 Section 12b None of the chemicals are listed under TSCA Section 12b. TSCA Significant New Use Rule None of the chemicals in this material have a SNUR under TSCA. CERCLA Hazardous Substances and corresponding RQs CAS# 71-55-6: 1000 lb final RQ; 454 kg final RQ CAS# 123-91-1: 100 lb final RQ; 45.4 kg final RQ CAS# 106-88-7: 100 lb final RQ; 45.4 kg final RQ SARA Section 302 Extremely Hazardous Substances None of the chemicals in this product have a TPQ. SARA Codes CAS # 71-55-6: immediate. CAS # 123-91-1: delayed, fire. CAS # 106-88-7: immediate. CAS # 75-52-5: immediate, delayed, fire, reactive. Section 313 This material contains 1,1,1-Trichloroethane (CAS# 71-55-6, >96%),which is subject to the reporting requirements of Section 313 of SARA Title III and 40 CFR This material contains 1,4-Dioxane (CAS# 123-91-1, 2.5%),which is subject to the reporting requirements of Section 313 of SARA Title III and 40 CFR Part 373. This material contains 1,2-Butylene oxide (CAS# 106-88-7, 0.47%),which is subject to the reporting requirements of Section 313 of SARA Title III and 40 CFR Part 373. Clean Air Act: CAS# 71-55-6 is listed as a hazardous air pollutant (HAP). CAS# 123-91-1 is listed as a hazardous air pollutant (HAP). CAS# 106-88-7 is listed as a hazardous air pollutant (HAP). CAS# 71-55-6 is listed as a Class 1 ozone depletor with an 0.1 ODP; 110 GWP This material does not contain any Class 2 Ozone depletors. Clean Water Act: None of the chemicals in this product are listed as Hazardous Substances under the CWA. CAS# 71-55-6 is listed as a Priority Pollutant under the Clean Water Act. CAS# 71-55-6 is listed as a Toxic Pollutant under the Clean Water Act. OSHA: CAS# 75-52-5 is considered highly hazardous by OSHA. STATE CAS# 71-55-6 can be found on the following state right to know lists: California, New Jersey, Pennsylvania, Minnesota, Massachusetts. CAS# 123-91-1 can be found on the following state right to know lists: California, New Jersey, Pennsylvania, Minnesota, Massachusetts. CAS# 106-88-7 can be found on the following state right to know lists: New Jersey, Pennsylvania, Minnesota, Massachusetts. CAS# 75-52-5 can be found on the following state right to know lists: California, New Jersey, Pennsylvania, Minnesota, Massachusetts.
California Prop 65 WARNING: This product contains 1,4-Dioxane, a chemical known to the state of California to cause cancer. WARNING: This product contains Nitromethane, a chemical known to the state of California to cause cancer. California No Significant Risk Level: CAS# 123-91-1: 30 æg/day NSRL
European/International Regulations European Labeling in Accordance with EC Directives Hazard Symbols: XN N Risk Phrases: R 20 Harmful by inhalation. R 59 Dangerous for the ozone layer.
Safety Phrases: S 24/25 Avoid contact with skin and eyes. S 59 Refer to manufacturer/supplier for information on recovery/recy cling. S 61 Avoid release to the environment. Refer to special instructions /safety data sheets.
WGK (Water Danger/Protection) CAS# 71-55-6: 3 CAS# 123-91-1: 2 CAS# 106-88-7: 3 CAS# 75-52-5: 2 Canada - DSL/NDSL CAS# 71-55-6 is listed on Canada's DSL List. CAS# 123-91-1 is listed on Canada's DSL List. CAS# 106-88-7 is listed on Canada's DSL List. CAS# 75-52-5 is listed on Canada's DSL List. Canada - WHMIS This product has a WHMIS classification of D1B, D2B. This product has been classified in accordance with the hazard criteria of the Controlled Products Regulations and the MSDS contains all of the information required by those regulations. Canadian Ingredient Disclosure List CAS# 71-55-6 is listed on the Canadian Ingredient Disclosure List. CAS# 123-91-1 is listed on the Canadian Ingredient Disclosure List. CAS# 75-52-5 is listed on the Canadian Ingredient Disclosure List.
Section 16 - Additional Information
MSDS Creation Date: 6/11/1999 Revision #5 Date: 3/16/2007
The information above is believed to be accurate and represents the best information currently available to us. However, we make no warranty of merchantability or any other warranty, express or implied, with respect to such information, and we assume no liability resulting from its use. Users should make their own investigations to determine the suitability of the information for their particular purposes. In no event shall Fisher be liable for any claims, losses, or damages of any third party or for lost profits or any special, indirect, incidental, consequential or exemplary damages, howsoever arising, even if Fisher has been advised of the possibility of such damages. MATERIAL SAFETY DATA SHEET Klozür™
MSDS Ref. No.: 7775-27-1-12 Date Approved: 02/22/2005 Revision No.: 1
This document has been prepared to meet the requirements of the U.S. OSHA Hazard Communication Standard, 29 CFR 1910.1200; the Canada's Workplace Hazardous Materials Information System (WHMIS) and, the EC Directive, 2001/58/EC.
1. PRODUCT AND COMPANY IDENTIFICATION
PRODUCT NAME: Klozür™ SYNONYMS: Sodium Persulfate, Sodium Peroxydisulfate; Disodium Peroxydisulfate GENERAL USE: In situ and ex situ chemical oxidation of contaminants and compounds of concern for environmental remediation applications.
MANUFACTURER EMERGENCY TELEPHONE NUMBERS FMC CORPORATION (800) 424-9300 (CHEMTREC - U.S.) Active Oxidants Division (303) 595-9048 (Medical - Call Collect) 1735 Market Street Philadelphia, PA 19103 (215) 299-6000 (General Information)
2. HAZARDS IDENTIFICATION EMERGENCY OVERVIEW: • White, odorless, crystals • Oxidizer. • Decomposes in storage under conditions of moisture (water/water vapor) and/or excessive heat causing release of oxides of sulfur and oxygen that supports combustion. Decomposition could form a high temperature melt. See Section 10 ("Stability and Reactivity").
POTENTIAL HEALTH EFFECTS: Airborne persulfate dust may be irritating to eyes, nose, lungs, throat and skin upon contact. Exposure to high levels of persulfate dust may cause difficulty in breathing in sensitive persons.
Page 1 of 9
Klozür™ (7775-27-1-12) Date: 02/22/2005
3. COMPOSITION / INFORMATION ON INGREDIENTS
Chemical Name CAS# Wt.% EC No. EC Class Sodium Persulfate 7775-27-1 >99 231-892-1 Not classified as hazardous
4. FIRST AID MEASURES EYES: Flush with plenty of water. Get medical attention if irritation occurs and persists.
SKIN: Wash with plenty of soap and water. Get medical attention if irritation occurs and persists.
INGESTION: Rinse mouth with water. Dilute by giving 1 or 2 glasses of water. Do not induce vomiting. Never give anything by mouth to an unconscious person. See a medical doctor immediately.
INHALATION: Remove to fresh air. If breathing difficulty or discomfort occurs and persists, contact a medical doctor.
NOTES TO MEDICAL DOCTOR: This product has low oral toxicity and is not irritating to the eyes and skin. Flooding of exposed areas with water is suggested, but gastric lavage or emesis induction for ingestions must consider possible aggravation of esophageal injury and the expected absence of system effects. Treatment is controlled removal of exposure followed by symptomatic and supportive care.
5. FIRE FIGHTING MEASURES
EXTINGUISHING MEDIA: Deluge with water.
FIRE / EXPLOSION HAZARDS: Product is non-combustible. On decomposition releases oxygen which may intensify fire. Presence of water accelerates decomposition.
FIRE FIGHTING PROCEDURES: Do not use carbon dioxide or other gas filled fire extinguishers; they will have no effect on decomposing persulfates. Wear full protective clothing and self- contained breathing apparatus.
FLAMMABLE LIMITS: Non-combustible
SENSITIVITY TO IMPACT: No data available
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SENSITIVITY TO STATIC DISCHARGE: Not available
6. ACCIDENTAL RELEASE MEASURES
RELEASE NOTES: Spilled material should be collected and put in approved DOT container and isolated for disposal. Isolated material should be monitored for signs of decomposition (fuming/smoking). If spilled material is wet, dissolve with large quantity of water and dispose as a hazardous waste. All disposals should be carried out according to regulatory agencies procedures.
7. HANDLING AND STORAGE HANDLING: Use adequate ventilation when transferring product from bags or drums. Wear respiratory protection if ventilation is inadequate or not available. Use eye and skin protection. Use clean plastic or stainless steel scoops only.
STORAGE: Store (unopened) in a cool, clean, dry place away from point sources of heat, e.g. radiant heaters or steam pipes. Use first in, first out storage system. Avoid contamination of opened product. In case of fire or decomposition (fuming/smoking) deluge with plenty of water to control decomposition. For storage, refer to NFPA Bulletin 430 on storage of liquid and solid oxidizing materials.
COMMENTS: VENTILATION: Provide mechanical general and/or local exhaust ventilation to prevent release of dust into work environment. Spills should be collected into suitable containers to prevent dispersion into the air.
8. EXPOSURE CONTROLS / PERSONAL PROTECTION EXPOSURE LIMITS
Chemical Name ACGIH OSHA Supplier
3 Sodium Persulfate 0.1 mg/m (TWA)
ENGINEERING CONTROLS: Provide mechanical local general room ventilation to prevent release of dust into the work environment. Remove contaminated clothing immediately and wash before reuse.
PERSONAL PROTECTIVE EQUIPMENT EYES AND FACE: Use cup type chemical goggles. Full face shield may be used.
RESPIRATORY: Use approved dust respirator when airborne dust is expected.
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PROTECTIVE CLOTHING: Normal work clothes. Rubber or neoprene footwear.
GLOVES: Rubber or neoprene gloves. Thoroughly wash the outside of gloves with soap and water prior to removal. Inspect regularly for leaks.
9. PHYSICAL AND CHEMICAL PROPERTIES ODOR: None APPEARANCE: White crystals AUTOIGNITION TEMPERATURE: Not applicable. No evidence of combustion up to 800°C. Decomposition will occur upon heating. BOILING POINT: Not applicable COEFFICIENT OF OIL / WATER: Not applicable DENSITY / WEIGHT PER VOLUME: Not available EVAPORATION RATE: Not applicable (Butyl Acetate = 1) FLASH POINT: Non-combustible MELTING POINT: Decomposes ODOR THRESHOLD: Not applicable OXIDIZING PROPERTIES: Oxidizer PERCENT VOLATILE: Not applicable pH: typically 5.0 - 7.0 @ 25 °C (1% solution) SOLUBILITY IN WATER: 73 % @ 25 °C (by wt.)
SPECIFIC GRAVITY: 2.6 (H2O=1) VAPOR DENSITY: Not applicable (Air = 1) VAPOR PRESSURE: Not applicable
10. STABILITY AND REACTIVITY
CONDITIONS TO AVOID: Heat, moisture and contamination. STABILITY: Stable (becomes unstable in presence of heat, moisture and/or contamination). POLYMERIZATION: Will not occur INCOMPATIBLE MATERIALS: Acids, alkalis, halides (fluorides, chlorides, bromides and iodides), combustible materials, most metals and heavy metals, oxidizable materials, other oxidizers, reducing agents, cleaners, and organic or carbon containing compounds. Contact
Page 4 of 9 Klozür™ (7775-27-1-12) Date: 02/22/2005
with incompatible materials can result in a material decomposition or other uncontrolled reactions. HAZARDOUS DECOMPOSITION PRODUCTS: Oxygen that supports combustion and oxides of sulfur.
COMMENTS: PRECAUTIONARY STATEMENT: Pumping and transport of Klozür persulfate requires appropriate precautions and design considerations for pressure and thermal relief. Decomposing persulfates will evolve large volumes of gas and/or vapor, can accelerate exponentially with heat generation, and create significant and hazardous pressures if contained and not properly controlled or mitigated. Use with alcohols in the presence of water has been demonstrated to generate conditions that require rigorous adherence to process safety methods and standards to prevent escalation to an uncontrolled reaction.
11. TOXICOLOGICAL INFORMATION EYE EFFECTS: Non-irritating (rabbit) [FMC Study Number: ICG/T-79.029]
SKIN EFFECTS: Non-irritating (rabbit) [FMC Study Number: ICG/T-79.029]
DERMAL LD50: > 10 g/kg [FMC Study Number: ICG/T-79.029]
ORAL LD50: 895 mg/kg (rat) [FMC Study Number: ICG/T-79.029]
INHALATION LC50: 5.1 mg/l (rat) [FMC I95-2017]
SENSITIZATION: May be sensitizing to allergic persons. [FMC Study Number: ICG/T-79.029]
TARGET ORGANS: Eyes, skin, respiratory passages
ACUTE EFFECTS FROM OVEREXPOSURE: Dust may be harmful and irritating. May be harmful if swallowed.
CHRONIC EFFECTS FROM OVEREXPOSURE: Sensitive persons may develop dermatitis and asthma [Respiration 38:144, 1979]. Groups of male and female rats were fed 0, 300 or 3000 ppm sodium persulfate in the diet for 13 weeks, followed by 5000 ppm for 5 weeks. Microscopic examination of tissues revealed some injury to the gastrointestinal tract at the high dose (3000 ppm) only. This effect is not unexpected for an oxidizer at high concentrations. [Ref. FMC I90-1151, Toxicologist 1:149, 1981].
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CARCINOGENICITY: NTP: Not listed IARC: Not listed OSHA: Not listed OTHER: ACGIH: Not listed
12. ECOLOGICAL INFORMATION ECOTOXICOLOGICAL INFORMATION:
Bluegill sunfish, 96-hour LC50 = 771 mg/L [FMC Study I92-1250] Rainbow trout, 96-hour LC50 = 163 mg/L [FMC Study I92-1251] Daphnia, 48-hour LC50 = 133 mg/L [FMC Study I92-1252] Grass shrimp, 96-hour LC50 = 519 mg/L [FMC Study I92-1253]
CHEMICAL FATE INFORMATION: Biodegradability does not apply to inorganic substances.
13. DISPOSAL CONSIDERATIONS DISPOSAL METHOD: Dispose as a hazardous waste in accordance with local, state and federal regulatory agencies.
14. TRANSPORT INFORMATION
U.S. DEPARTMENT OF TRANSPORTATION (DOT)
PROPER SHIPPING NAME: Sodium Persulfate PRIMARY HAZARD CLASS / DIVISION: 5.1 (Oxidizer) UN/NA NUMBER: UN 1505 PACKING GROUP: III LABEL(S): 5.1 (Oxidizer) PLACARD(S): 5.1 (Oxidizer) MARKING(S): Sodium Persulfate, UN 1505
ADDITIONAL INFORMATION: Hazardous Substance/RQ: Not applicable
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49 STCC Number: 4918733
This material is shipped in 225 lb. fiber drums, 55 lb. poly bags and 1000 - 2200 lb. IBC's (supersacks).
INTERNATIONAL MARITIME DANGEROUS GOODS (IMDG)
PROPER SHIPPING NAME: Sodium Persulfate
INTERNATIONAL CIVIL AVIATION ORGANIZATION (ICAO) / INTERNATIONAL AIR TRANSPORT ASSOCIATION (IATA)
PROPER SHIPPING NAME: Sodium Persulfate
OTHER INFORMATION: Protect from physical damage. Do not store near acids, moisture or heat.
15. REGULATORY INFORMATION UNITED STATES
SARA TITLE III (SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT) SECTION 302 EXTREMELY HAZARDOUS SUBSTANCES (40 CFR 355, APPENDIX A): Not applicable
SECTION 311 HAZARD CATEGORIES (40 CFR 370): Fire Hazard, Immediate (Acute) Health Hazard
SECTION 312 THRESHOLD PLANNING QUANTITY (40 CFR 370): The Threshold Planning Quantity (TPQ) for this product, if treated as a mixture, is 10,000 lbs; however, this product contains the following ingredients with a TPQ of less than 10,000 lbs.: None
SECTION 313 REPORTABLE INGREDIENTS (40 CFR 372): Not listed
CERCLA (COMPREHENSIVE ENVIRONMENTAL RESPONSE COMPENSATION AND LIABILITY ACT)
CERCLA DESIGNATION & REPORTABLE QUANTITIES (RQ) (40 CFR 302.4): Unlisted, RQ = 100 lbs., Ignitability
TSCA (TOXIC SUBSTANCE CONTROL ACT) TSCA INVENTORY STATUS (40 CFR 710):
Page 7 of 9 Klozür™ (7775-27-1-12) Date: 02/22/2005
Listed
RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) RCRA IDENTIFICATION OF HAZARDOUS WASTE (40 CFR 261): Waste Number: D001
CANADA WHMIS (WORKPLACE HAZARDOUS MATERIALS INFORMATION SYSTEM): Product Identification Number: 1505 Hazard Classification / Division: Class C (Oxidizer), Class D, Div. 2, Subdiv. B. (Toxic) Ingredient Disclosure List: Listed
INTERNATIONAL LISTINGS Sodium persulfate: Australia (AICS): Listed China: Listed Japan (ENCS): (1)-1131 Korea: KE-12369 Philippines (PICCS): Listed
HAZARD, RISK AND SAFETY PHRASE DESCRIPTIONS:
EC Symbols: (Not classified as hazardous)
EC Risk Phrases: (Not classified as hazardous)
EC Safety Phrases: (Not classified as hazardous)
16. OTHER INFORMATION
HMIS
Health 1 Flammability 0 Physical Hazard 1 Personal Protection (PPE) J Protection = J (Safety goggles, gloves, apron & combination dust & vapor respirator)
HMIS = Hazardous Materials Identification System
Degree of Hazard Code: 4 = Severe
Page 8 of 9 Klozür™ (7775-27-1-12) Date: 02/22/2005
3 = Serious 2 = Moderate 1 = Slight 0 = Minimal
NFPA
Health 1 Flammability 0 Reactivity 1 Special OX SPECIAL = OX (Oxidizer)
NFPA = National Fire Protection Association
Degree of Hazard Code: 4 = Extreme 3 = High 2 = Moderate 1 = Slight 0 = Insignificant
REVISION SUMMARY: New MSDS
Klozür and FMC Logo - FMC Trademarks
© 2005 FMC Corporation. All Rights Reserved.
FMC Corporation believes that the information and recommendations contained herein (including data and statements) are accurate as of the date hereof. NO WARRANTY OF FITNESS FOR ANY PARTICULAR PURPOSE, WARRANTY OF MERCHANTABILITY, OR ANY OTHER WARRANTY, EXPRESSED OR IMPLIED, IS MADE CONCERNING THE INFORMATION PROVIDED HEREIN. The information provided herein relates only to the specific product designated and may not be applicable where such product is used in combination with any other materials or in any process. It is a violation of Federal law to use this product in a manner inconsistent with its labeling. Further, since the conditions and methods of use are beyond the control of FMC Corporation, FMC Corporation expressly disclaims any and all liability as to any results obtained or arising from any use of the product or reliance on such information.
Page 9 of 9 Liqui-nox® Material Safety Data Sheet Alconox, Inc. 30 Glenn Street, Suite 309 White Plains, NY 10603 Get a PDF version of this document 24 Hour Emergency Number - Chem-Tel (800) 255-3924
I. Identification National Fire Protection Product Name (shown on label): LIQUI-NOX Association 704 Labeling: CAS Registry Number: Not Applicable Effective Date: January 1, 2001 Chemical Family: Anionic Liquid Detergent Mfr. Catalog #s for Sizes: 1232, 1201, 1215, 1255
II. Hazardous Ingredients/Identity Information
There are no hazardous ingredients in LIQUI-NOX¨ as defined by the OSHA Standard and Hazardous Substance List 29 CFR 1910 Subpart Z.
NJTSRN: 1200 III. Physical/Chemical Characteristics Boiling Point (F): 214°F Vapor Pressure (mm Hg): No Data Vapor Density (AIR=1): No Data Specific Gravity (Water=1): 1.075 Evaporation Rate (Butyl Acetate=1): Slower Melting Point: No Data Solubility in Water: Completely soluble in all proportions Appearance: Yellow liquid, nearly odorless pH: 8.5 (1%)
IV. Fire and Explosion Data
Flash Point (Method Used): None (Cleveland Open Cup) Flammable Limits: LEL: No Data UEL: No Data Extinguishing Media: Water, dry chemical, CO2, foam Special Fire fighting Procedures: Self-contained positive pressure breathing apparatus and protective clothing should be worn when fighting fires involving chemicals. Unusual Fire and Explosion Hazards: None V. Reactivity Data
Stability: Stable Hazardous Polymerization: Will not occur. Incompatibility (Materials to Avoid): Oxidizing agents. Hazardous Decomposition or Byproducts: May release SO2 on burning.
VI. Health Hazard Data
Route(s) of Entry: Inhalation? No Skin? Yes Ingestion? Yes Health Hazards (Acute and Chronic): Skin contact may prove locally irritating, causing drying and/or chapping. Ingestion may cause discomfort and/or diarrhea. Carcinogenicity: NTP? No IARC Monographs? No OSHA Regulated? No Signs and Symptoms of Exposure: Prolonged skin contact may cause drying and/or chapping. Medical Conditions Generally Aggravated by Not established. Unnecessary exposure to this Exposure: product or any industrial chemical should be avoided. Emergency and First Aid Procedures: Eyes: Immediately flush eyes with water for at least 15 minutes. Call a physician. Skin: Flush with plenty of water. Ingestion: Drink large quantities of water or milk. Do not induce vomiting. If vomiting occurs administer fluids. See a physician for discomfort.
VII. Precautions for Safe Handling and Use
Steps to be Taken if Material is Released or Material foams profusely. For small spills Spilled: recover as much as possible with absorbent material and flush remainder to sewer. Material is biodegradable. Waste Disposal Method: Small quantities may be disposed of in sewer. Large quantities should be disposed of in accordance with local ordinances for detergent products. Precautions to be Taken in Storing and No special precautions in storing. Use Handling: protective equipment when handling undiluted material. Other Precautions: No special requirements other than the good industrial hygiene and safety practices employed with any industrial chemical. VII. Control Measures
Respiratory Protection (Specify Type): None Required Ventilation: Local Exhaust-Normal Special-Not Required Mechanical-Not Required Other-Not Required Protective Gloves: Impervious gloves are recommended. Eye Protection: Goggles and/or splash shields are recommended. Other Protective Clothing or Equipment: Not required Work/Hygienic Practices: No special practices required.
Material Safety Data Sheet Trichloroethylene ACC# 23850 Section 1 - Chemical Product and Company Identification
MSDS Name: Trichloroethylene Catalog Numbers: AC158310000, AC158310025, AC421520000, AC421520040, AC421520200, AC421525000, 15831-0010, S80327ACS-1, S80327ACS-2, T340-4, T341-20, T341-4, T341-500, T341J4, T403-4 Synonyms: Ethylene trichloride; 1,1,2-Trichloroethylene; TCE. Company Identification: Fisher Scientific 1 Reagent Lane Fair Lawn, NJ 07410 For information, call: 201-796-7100 Emergency Number: 201-796-7100 For CHEMTREC assistance, call: 800-424-9300 For International CHEMTREC assistance, call: 703-527-3887
Section 2 - Composition, Information on Ingredients
CAS# Chemical Name Percent EINECS/ELINCS 79-01-6 Trichloroethylene 99+ 201-167-4
Section 3 - Hazards Identification
EMERGENCY OVERVIEW
Appearance: APHA: 15 max liquid. Warning! Harmful to aquatic organisms; may cause long-term adverse effects in the aquatic environment. Breathing vapors may cause drowsiness and dizziness. Possible risks of irreversible effects. Cancer hazard. Causes eye and skin irritation. May cause respiratory tract irritation. May cause liver and kidney damage. May cause central nervous system effects. Target Organs: Kidneys, central nervous system, liver, spleen, respiratory system, eyes, skin.
Potential Health Effects Eye: Causes eye irritation. Contact with trichloroethylene causes pain but no permanent injury to the eyes. (Doc of TLV) Skin: Causes skin irritation. May be harmful if absorbed through the skin. Ingestion: May cause irritation of the digestive tract. May be harmful if swallowed. May cause central nervous system effects. Inhalation: May cause respiratory tract irritation. May cause liver and kidney damage. May be harmful if inhaled. May cause central nervous system effects. The chief symptoms of TCE exposure were found to be abnormal fatigue, irritability, headache, gastric disturbances, and intolerance to alcohol. (Doc to TLV) Chronic: Prolonged or repeated skin contact may cause defatting and dermatitis. May cause liver and kidney damage. May cause cancer in humans. Repeated exposure may cause damage to the spleen. Adverse reproductive effects have been reported in animals. Laboratory experiments have resulted in mutagenic effects. Possible risk of irreversible effects.
Section 4 - First Aid Measures
Eyes: Immediately flush eyes with plenty of water for at least 15 minutes, occasionally lifting the upper and lower eyelids. Get medical aid. Skin: Get medical aid. Immediately flush skin with plenty of water for at least 15 minutes while removing contaminated clothing and shoes. Ingestion: Do not induce vomiting. Get medical aid. Inhalation: Remove from exposure and move to fresh air immediately. If not breathing, give artificial respiration. If breathing is difficult, give oxygen. Get medical aid. Notes to Physician: Treat symptomatically and supportively.
Section 5 - Fire Fighting Measures
General Information: As in any fire, wear a self-contained breathing apparatus in pressure-demand, MSHA/NIOSH (approved or equivalent), and full protective gear. Extinguishing Media: Use water spray, dry chemical, carbon dioxide, or chemical foam. Flash Point: Not applicable. Autoignition Temperature: 410 deg C ( 770.00 deg F) Explosion Limits, Lower:7.9 Vol % Upper: 90 Vol % NFPA Rating: (estimated) Health: 2; Flammability: 1; Instability: 1
Section 6 - Accidental Release Measures
General Information: Use proper personal protective equipment as indicated in Section 8. Spills/Leaks: Absorb spill with inert material (e.g. vermiculite, sand or earth), then place in suitable container. Wear a self contained breathing apparatus and appropriate personal protection. (See Exposure Controls, Personal Protection section). Remove all sources of ignition. Use a spark-proof tool. Do not let this chemical enter the environment.
Section 7 - Handling and Storage
Handling: Do not get in eyes, on skin, or on clothing. Keep away from heat, sparks and flame. Do not ingest or inhale. Use only in a chemical fume hood. Storage: Keep away from sources of ignition. Store in a cool, dry place. Store in a tightly closed container. Store protected from light.
Section 8 - Exposure Controls, Personal Protection
Engineering Controls: Facilities storing or utilizing this material should be equipped with an eyewash facility and a safety shower. Use only under a chemical fume hood. Exposure Limits
Chemical Name ACGIH NIOSH OSHA - Final PELs 10 ppm TWA; 25 ppm 100 ppm TWA; 200 Trichloroethylene 1000 ppm IDLH STEL ppm Ceiling
OSHA Vacated PELs: Trichloroethylene: 50 ppm TWA; 270 mg/m3 TWA Personal Protective Equipment Eyes: Wear appropriate protective eyeglasses or chemical safety goggles as described by OSHA's eye and face protection regulations in 29 CFR 1910.133 or European Standard EN166. Skin: Wear appropriate protective gloves to prevent skin exposure. Clothing: Wear appropriate protective clothing to prevent skin exposure. Respirators: Follow the OSHA respirator regulations found in 29 CFR 1910.134 or European Standard EN 149. Use a NIOSH/MSHA or European Standard EN 149 approved respirator if exposure limits are exceeded or if irritation or other symptoms are experienced.
Section 9 - Physical and Chemical Properties
Physical State: Liquid Appearance: clear, colorless - APHA: 15 max Odor: chloroform-like pH: Not available. Vapor Pressure: 77.3 mbar @ 20 deg C Vapor Density: 4.5 (air=1) Evaporation Rate:Not available. Viscosity: Not available. Boiling Point: 87 deg C @ 760 mmHg Freezing/Melting Point:-86 deg C Decomposition Temperature:Not available. Solubility: Insoluble. Specific Gravity/Density:1.460 Molecular Formula:C2HCl3 Molecular Weight:131.39
Section 10 - Stability and Reactivity
Chemical Stability: Moisture sensitive. Light sensitive. Conditions to Avoid: Incompatible materials, light, ignition sources, excess heat, exposure to moist air or water. Incompatibilities with Other Materials: Strong oxidizing agents, strong reducing agents, bases, active metals, metals and metal compounds (toxic, e.g. beryllium, lead acetate, nickel carbonyl, tetraethyl lead). Hazardous Decomposition Products: Hydrogen chloride, carbon monoxide, carbon dioxide. Hazardous Polymerization: Will not occur.
Section 11 - Toxicological Information
RTECS#: CAS# 79-01-6: KX4550000 LD50/LC50: CAS# 79-01-6: Draize test, rabbit, eye: 20 mg/24H Moderate; Draize test, rabbit, skin: 2 mg/24H Severe; Inhalation, mouse: LC50 = 8450 ppm/4H; Inhalation, mouse: LC50 = 220000 mg/m3/20M; Inhalation, mouse: LC50 = 262000 mg/m3/30M; Inhalation, mouse: LC50 = 40000 mg/m3/4H; Inhalation, rat: LC50 = 140700 mg/m3/1H; Oral, mouse: LD50 = 2402 mg/kg; Oral, mouse: LD50 = 2400 mg/kg; Oral, rat: LD50 = 4920 mg/kg; Skin, rabbit: LD50 = >20 gm/kg; Skin, rabbit: LD50 = 20 mL/kg; .
Carcinogenicity: CAS# 79-01-6:
• ACGIH: A2 - Suspected Human Carcinogen • California: carcinogen, initial date 4/1/88 • NTP: Suspect carcinogen • IARC: Group 2A carcinogen
Epidemiology: Tumorigenic effects have been reported in experimental animals. Teratogenicity: Teratogenic effects have occurred in experimental animals. Reproductive Effects: Adverse reproductive effects have occurred in experimental animals. Mutagenicity: Mutagenic effects have occurred in humans. Neurotoxicity: No information available. Other Studies: Section 12 - Ecological Information
Ecotoxicity: Fish: Fathead Minnow: 41-67 mg/L; 96 hrs.; LC50Daphnia: Daphnia: 2.2-100 mg/L; 48 hrs.; LC50Mollusk Shrimp: 2 mg/L; 96 hrs.; LC50 Bluegill sunfish, LD50= 44,700 ug/L/96Hr. Fathead minnow, LC50=40.7 mg/L/96Hr. Environmental: In air, substance is photooxidized and is reported to form phosgene, dichloroacetyl chloride, and formyl chloride. In water, it evaporates rapidly. Potential for mobility in soil is high. Physical: No information available. Other: Bioconcentration potential is low (BCF less than 100).
Section 13 - Disposal Considerations
Chemical waste generators must determine whether a discarded chemical is classified as a hazardous waste. US EPA guidelines for the classification determination are listed in 40 CFR Parts 261.3. Additionally, waste generators must consult state and local hazardous waste regulations to ensure complete and accurate classification. RCRA P-Series: None listed. RCRA U-Series: CAS# 79-01-6: waste number U228.
Section 14 - Transport Information
US DOT Canada TDG Shipping Name: TRICHLOROETHYLENE TRICHLOROETHYLENE Hazard Class: 6.1 6.1 UN Number: UN1710 UN1710 Packing Group: III III
Section 15 - Regulatory Information
US FEDERAL
TSCA CAS# 79-01-6 is listed on the TSCA inventory. Health & Safety Reporting List None of the chemicals are on the Health & Safety Reporting List. Chemical Test Rules None of the chemicals in this product are under a Chemical Test Rule. Section 12b None of the chemicals are listed under TSCA Section 12b. TSCA Significant New Use Rule None of the chemicals in this material have a SNUR under TSCA. CERCLA Hazardous Substances and corresponding RQs CAS# 79-01-6: 100 lb final RQ; 45.4 kg final RQ SARA Section 302 Extremely Hazardous Substances None of the chemicals in this product have a TPQ. SARA Codes CAS # 79-01-6: immediate, delayed, reactive. Section 313 This material contains Trichloroethylene (CAS# 79-01-6, 99+%),which is subject to the reporting requirements of Section 313 of SARA Title III and 40 CFR Clean Air Act: CAS# 79-01-6 is listed as a hazardous air pollutant (HAP). This material does not contain any Class 1 Ozone depletors. This material does not contain any Class 2 Ozone depletors. Clean Water Act: CAS# 79-01-6 is listed as a Hazardous Substance under the CWA. CAS# 79-01-6 is listed as a Priority Pollutant under the Clean Water Act. CAS# 79-01-6 is listed as a Toxic Pollutant under the Clean Water Act. OSHA: None of the chemicals in this product are considered highly hazardous by OSHA. STATE CAS# 79-01-6 can be found on the following state right to know lists: California, New Jersey, Pennsylvania, Minnesota, Massachusetts.
California Prop 65 The following statement(s) is(are) made in order to comply with the California Safe Drinking Water Act: WARNING: This product contains Trichloroethylene, a chemical known to the state of California to cause cancer. California No Significant Risk Level: CAS# 79-01-6: 50 æg/day NSRL (oral); 80 æg/day NSRL (inhalation)
European/International Regulations European Labeling in Accordance with EC Directives Hazard Symbols: T Risk Phrases: R 36/38 Irritating to eyes and skin. R 45 May cause cancer. R 52/53 Harmful to aquatic organisms, may cause long-term adverse effects in the aquatic environment. R 67 Vapours may cause drowsiness and dizziness. R 68 Possible risk of irreversible effects.
Safety Phrases: S 45 In case of accident or if you feel unwell, seek medical advice immediately (show the label where possible). S 53 Avoid exposure - obtain special instructions before use. S 61 Avoid release to the environment. Refer to special instructions /safety data sheets.
WGK (Water Danger/Protection) CAS# 79-01-6: 3 Canada - DSL/NDSL CAS# 79-01-6 is listed on Canada's DSL List. Canada - WHMIS This product has a WHMIS classification of D1B, D2B. This product has been classified in accordance with the hazard criteria of the Controlled Products Regulations and the MSDS contains all of the information required by those regulations. Canadian Ingredient Disclosure List CAS# 79-01-6 is listed on the Canadian Ingredient Disclosure List.
Section 16 - Additional Information
MSDS Creation Date: 2/01/1999 Revision #9 Date: 6/03/2008
The information above is believed to be accurate and represents the best information currently available to us. However, we make no warranty of merchantability or any other warranty, express or implied, with respect to such information, and we assume no liability resulting from its use. Users should make their own investigations to determine the suitability of the information for their particular purposes. In no event shall Fisher be liable for any claims, losses, or damages of any third party or for lost profits or any special, indirect, incidental, consequential or exemplary damages, howsoever arising, even if Fisher has been advised of the possibility of such damages.
Page 1 of 8 MATERIAL SAFETY DATA SHEET
1. CHEMICAL PRODUCT AND COMPANY IDENTIFICATION
MATHESON TRI-GAS, INC. Emergency Contact: 150 Allen Road Suite 302 CHEMTREC 1-800-424-9300 Basking Ridge, New Jersey 07920 Calls Originating Outside the US: Information: 1-800-416-2505 703-527-3887 (Collect Calls Accepted)
SUBSTANCE: VINYL CHLORIDE
TRADE NAMES/SYNONYMS: MTG MSDS 97; 1-CHLOROETHYLENE; 1-CHLOROETHENE; CHLOROETHYLENE; CHLOROETHENE; CHLORETHENE; CHLORETHYLENE; ETHYLENE MONOCHLORIDE; MONOCHLOROETHYLENE; MONOCHLORO ETHENE; MONOCHLOROETHENE; VINYL CHLORIDE MONOMER; VINYL CHLORIDE, INHIBITED; VINYL C MONOMER; RCRA U043; UN 1086; C2H3Cl; MAT24940; RTECS KU9625000
CHEMICAL FAMILY: halogenated, aliphatic
CREATION DATE: Jan 24 1989 REVISION DATE: Dec 11 2008
2. COMPOSITION, INFORMATION ON INGREDIENTS
COMPONENT: VINYL CHLORIDE CAS NUMBER: 75-01-4 PERCENTAGE: >99.9
COMPONENT: PHENOL CAS NUMBER: 108-95-2 PERCENTAGE: <0.1
COMPONENT: INHIBITORS CAS NUMBER: Not assigned. PERCENTAGE: <0.1
3. HAZARDS IDENTIFICATION
NFPA RATINGS (SCALE 0-4): HEALTH=2 FIRE=4 REACTIVITY=1
Page 2 of 8 EMERGENCY OVERVIEW: COLOR: colorless PHYSICAL FORM: gas ODOR: faint odor, sweet odor MAJOR HEALTH HAZARDS: harmful if swallowed, skin irritation, eye irritation, central nervous system depression, cancer hazard (in humans) PHYSICAL HAZARDS: Flammable gas. May cause flash fire. May polymerize. Containers may rupture or explode.
POTENTIAL HEALTH EFFECTS: INHALATION: SHORT TERM EXPOSURE: irritation, nausea, difficulty breathing, irregular heartbeat, headache, drowsiness, dizziness, disorientation, joint pain, loss of coordination, hearing loss, lung congestion LONG TERM EXPOSURE: impotence, bluish skin color, blood disorders, liver damage, cancer SKIN CONTACT: SHORT TERM EXPOSURE: irritation, blisters LONG TERM EXPOSURE: irritation, blisters EYE CONTACT: SHORT TERM EXPOSURE: irritation, eye damage LONG TERM EXPOSURE: irritation, eye damage INGESTION: SHORT TERM EXPOSURE: frostbite LONG TERM EXPOSURE: cancer
4. FIRST AID MEASURES
INHALATION: If adverse effects occur, remove to uncontaminated area. Give artificial respiration if not breathing. If breathing is difficult, oxygen should be administered by qualified personnel. Get immediate medical attention.
SKIN CONTACT: If frostbite or freezing occur, immediately flush with plenty of lukewarm water (105- 115 F; 41-46 C). DO NOT USE HOT WATER. If warm water is not available, gently wrap affected parts in blankets. Get immediate medical attention.
EYE CONTACT: Wash eyes immediately with large amounts of water, occasionally lifting upper and lower lids, until no evidence of chemical remains. Get medical attention immediately.
INGESTION: If a large amount is swallowed, get medical attention.
NOTE TO PHYSICIAN: For inhalation, consider oxygen.
5. FIRE FIGHTING MEASURES
Page 3 of 8 FIRE AND EXPLOSION HAZARDS: Severe fire hazard. Severe explosion hazard. The vapor is heavier than air. Vapors or gases may ignite at distant ignition sources and flash back. Vapor/air mixtures are explosive. Electrostatic discharges may be generated by flow or agitation resulting in ignition or explosion.
EXTINGUISHING MEDIA: carbon dioxide, regular dry chemical
Large fires: Use regular foam or flood with fine water spray.
FIRE FIGHTING: Move container from fire area if it can be done without risk. For fires in cargo or storage area: Cool containers with water from unmanned hose holder or monitor nozzles until well after fire is out. If this is impossible then take the following precautions: Keep unnecessary people away, isolate hazard area and deny entry. Let the fire burn. Withdraw immediately in case of rising sound from venting safety device or any discoloration of tanks due to fire. For tank, rail car or tank truck: Stop leak if possible without personal risk. Let burn unless leak can be stopped immediately. For smaller tanks or cylinders, extinguish and isolate from other flammables. Evacuation radius: 800 meters (1/2 mile). Do not attempt to extinguish fire unless flow of material can be stopped first. Flood with fine water spray. Cool containers with water spray until well after the fire is out. Apply water from a protected location or from a safe distance. Avoid inhalation of material or combustion by-products. Stay upwind and keep out of low areas. Evacuate if fire gets out of control or containers are directly exposed to fire. Evacuation radius: 500 meters (1/3 mile). Consider downwind evacuation if material is leaking.
FLASH POINT: -108 F (-78 C) (CC) LOWER FLAMMABLE LIMIT: 3.6% UPPER FLAMMABLE LIMIT: 33% AUTOIGNITION: 882 F (472 C)
6. ACCIDENTAL RELEASE MEASURES
WATER RELEASE: Subject to California Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65). Keep out of water supplies and sewers.
OCCUPATIONAL RELEASE: Avoid heat, flames, sparks and other sources of ignition. Stop leak if possible without personal risk. Reduce vapors with water spray. Keep unnecessary people away, isolate hazard area and deny entry. Remove sources of ignition. Ventilate closed spaces before entering. Notify Local Emergency Planning Committee and State Emergency Response Commission for release greater than or equal to RQ (U.S. SARA Section 304). If release occurs in the U.S. and is reportable under CERCLA Section 103, notify the National Response Center at (800)424-8802 (USA) or (202)426-2675 (USA).
7. HANDLING AND STORAGE
STORAGE: Store and handle in accordance with all current regulations and standards. Protect from physical damage. Store outside or in a detached building. Inside storage: Store in a cool, dry place. Store in a Page 4 of 8 well-ventilated area. Avoid heat, flames, sparks and other sources of ignition. Grounding and bonding required. Subject to storage regulations: U.S. OSHA 29 CFR 1910.101. See original container for storage recommendations. Keep separated from incompatible substances.
8. EXPOSURE CONTROLS, PERSONAL PROTECTION
EXPOSURE LIMITS: VINYL CHLORIDE: 1.0 ppm OSHA TWA 5 ppm OSHA STEL 15 minute(s) 0.5 ppm OSHA action level 8 hour(s) 1 ppm ACGIH TWA NIOSH TWA (lowest feasible concentration)
VENTILATION: Ventilation equipment should be explosion-resistant if explosive concentrations of material are present. Provide local exhaust or process enclosure ventilation system. Ensure compliance with applicable exposure limits.
EYE PROTECTION: Wear splash resistant safety goggles with a faceshield. Provide an emergency eye wash fountain and quick drench shower in the immediate work area.
CLOTHING: Wear appropriate chemical resistant clothing.
GLOVES: For the gas: Wear appropriate chemical resistant gloves. For the liquid: Wear insulated gloves. OSHA REGULATED SUBSTANCES: U.S. OSHA 29 CFR 1910.1017.
RESPIRATOR: The following respirators and maximum use concentrations are drawn from NIOSH and/or OSHA. OSHA Standard: Respirator selection should comply with 29 CFR 1910.134, 29 CFR 1910.1017, and the final rule published in the Federal Register on August 24, 2006. NIOSH Recommendations: At any detectable concentration - Any self-contained breathing apparatus that has a full facepiece and is operated in a pressure-demand or other positive-pressure mode. Any supplied-air respirator with a full facepiece that is operated in a pressure-demand or other positive- pressure mode in combination with an auxiliary self-contained breathing apparatus operated in pressure- demand or other positive-pressure mode. Escape - Any air-purifying full-facepiece respirator (gas mask) with a chin-style, front-mounted or back-mounted canister providing protection against the compound of concern. Any appropriate escape-type, self-contained breathing apparatus. Page 5 of 8
9. PHYSICAL AND CHEMICAL PROPERTIES
PHYSICAL STATE: gas COLOR: colorless ODOR: faint odor, sweet odor MOLECULAR WEIGHT: 62.50 MOLECULAR FORMULA: C-H2-C-H-Cl BOILING POINT: 9 F (-13 C) FREEZING POINT: -245 F (-154 C) VAPOR PRESSURE: 2515.6 mmHg @ 21.1 C VAPOR DENSITY (air=1): 2.2 SPECIFIC GRAVITY (water=1): 0.9106 WATER SOLUBILITY: 0.25% PH: Not applicable VOLATILITY: Not applicable ODOR THRESHOLD: 260 ppm EVAPORATION RATE: Not applicable VISCOSITY: 0.01072 cP @ 20 C COEFFICIENT OF WATER/OIL DISTRIBUTION: Not applicable SOLVENT SOLUBILITY: Soluble: alcohol, ether, carbon tetrachloride, benzene
10. STABILITY AND REACTIVITY
REACTIVITY: May polymerize. Avoid contact with light or storage and use above room temperature.
CONDITIONS TO AVOID: Avoid heat, flames, sparks and other sources of ignition. Containers may rupture or explode if exposed to heat.
INCOMPATIBILITIES: metal carbide, metals, oxidizing materials, peroxides
HAZARDOUS DECOMPOSITION: Thermal decomposition products: halogenated compounds, oxides of carbon, phosgene
POLYMERIZATION: May polymerize. Avoid contact with heat, light, air, water or incompatible materials. Closed containers may rupture violently.
11. TOXICOLOGICAL INFORMATION
VINYL CHLORIDE: TOXICITY DATA: 18 pph/15 minute(s) inhalation-rat LC50; 500 mg/kg oral-rat LD50 CARCINOGEN STATUS: OSHA: Carcinogen; NTP: Known Human Carcinogen; IARC: Human Sufficient Evidence, Animal Sufficient Evidence, Group 1; ACGIH: A1 -Confirmed Human Carcinogen; Page 6 of 8 EC: Category 1 LOCAL EFFECTS: Irritant: skin, eye ACUTE TOXICITY LEVEL: Toxic: ingestion Relatively Non-toxic: inhalation TARGET ORGANS: central nervous system TUMORIGENIC DATA: Available. MUTAGENIC DATA: Available. REPRODUCTIVE EFFECTS DATA: Available. ADDITIONAL DATA: Stimulants such as epinephrine may induce ventricular fibrillation. May cause birth defects.
12. ECOLOGICAL INFORMATION
ECOTOXICITY DATA: FISH TOXICITY: 388000 ug/L 10 month(s) LETH (Mortality) Northern pike (Esox lucius)
INVERTEBRATE TOXICITY: 41.74 ug/L 72 day(s) (Residue) Mosquito (Culex pipiens quinquefasciata)
ALGAL TOXICITY: 41.74 ug/L 72 day(s) (Residue) Green algae (Oedogonium cardiacum)
13. DISPOSAL CONSIDERATIONS
Dispose in accordance with all applicable regulations. Hazardous Waste Number(s): D043. Dispose of in accordance with U.S. EPA 40 CFR 262 for concentrations at or above the Regulatory level. Regulatory level- 0.2 mg/L. U043.
14. TRANSPORT INFORMATION
U.S. DOT 49 CFR 172.101: PROPER SHIPPING NAME: Vinyl chloride, stabilized ID NUMBER: UN1086 HAZARD CLASS OR DIVISION: 2.1 LABELING REQUIREMENTS: 2.1 QUANTITY LIMITATIONS: PASSENGER AIRCRAFT OR RAILCAR: Forbidden CARGO AIRCRAFT ONLY: 150 kg
CANADIAN TRANSPORTATION OF DANGEROUS GOODS: SHIPPING NAME: Vinyl chloride, stabilized UN NUMBER: UN1086 CLASS: 2.1 Page 7 of 8
15. REGULATORY INFORMATION
U.S. REGULATIONS: CERCLA SECTIONS 102a/103 HAZARDOUS SUBSTANCES (40 CFR 302.4): Vinyl chloride: 1 LBS RQ PHENOL: 1000 LBS RQ
SARA TITLE III SECTION 302 EXTREMELY HAZARDOUS SUBSTANCES (40 CFR 355 Subpart B): Not regulated.
SARA TITLE III SECTION 304 EXTREMELY HAZARDOUS SUBSTANCES (40 CFR 355 Subpart C): Not regulated.
SARA TITLE III SARA SECTIONS 311/312 HAZARDOUS CATEGORIES (40 CFR 370 Subparts B and C): ACUTE: Yes CHRONIC: Yes FIRE: Yes REACTIVE: Yes SUDDEN RELEASE: Yes
SARA TITLE III SECTION 313 (40 CFR 372.65): Vinyl chloride
OSHA PROCESS SAFETY (29 CFR 1910.119): Not regulated.
STATE REGULATIONS: California Proposition 65: Known to the state of California to cause the following: Vinyl chloride Cancer (Feb 27, 1987)
CANADIAN REGULATIONS: WHMIS CLASSIFICATION: ABD2
NATIONAL INVENTORY STATUS: U.S. INVENTORY (TSCA): Listed on inventory.
TSCA 12(b) EXPORT NOTIFICATION: Not listed.
CANADA INVENTORY (DSL/NDSL): Not determined.
16. OTHER INFORMATION
Page 8 of 8 MSDS SUMMARY OF CHANGES 15. REGULATORY INFORMATION
“RTECS®” is a United States trademark owned and licensed under authority of the U.S. Government, by and through Symyx Software, Inc. Portions ©Copyright 2001, U.S. Government. All rights reserved.
©Copyright 1984-2008 ChemADVISOR, Inc. All rights reserved.
MATHESON TRI-GAS, INC. MAKES NO EXPRESS OR IMPLIED WARRANTIES, GUARANTEES OR REPRESENTATIONS REGARDING THE PRODUCT OR THE INFORMATION HEREIN, INCLUDING BUT NOT LIMITED TO ANY IMPLIED WARRANTY OF MERCHANTABILITY OR FITNESS FOR USE. MATHESON TRI-GAS, INC. SHALL NOT BE LIABLE FOR ANY PERSONAL INJURY, PROPERTY OR OTHER DAMAGES OF ANY NATURE, WHETHER COMPENSATORY, CONSEQUENTIAL, EXEMPLARY, OR OTHERWISE, RESULTING FROM ANY PUBLICATION, USE OR RELIANCE UPON THE INFORMATION HEREIN.
ATTACHMENT D
JOB SAFETY ANALYSIS SHEETS AND DAILY SITE SAFETY CHECKLISTS
Updated: July 2011 Job Safety Analysis (JSA) Page 1 of 4
JSA Title: General Site Activities (Health & Safety Contingency Plan) JSA Control #: 028 Date Developed: 11/1/04 Please complete the below if this JSA is being modified for SITE-SPECIFIC reasons. Latest Revised Date: 6/21/10 Date Form Completed: Work Location: Initiated/Changed by: Julius Pachy This JSA has been fully reviewed with all staff members and all activity job steps, hazards, work practices, and PPE are clearly understood and have been implemented. All necessary revisions have been written on this JSA. Approved by: Thomas Baylis, CIH
REQUIRED PPE: Air Purifying Respirator; Gloves: nitrile, Kevlar, leather; Hard Hat: if working in an area with low overhead clearance; Hearing Protection: if site activities raise the noise level to 85 dB; PPE Clothing: highly visible clothing such as orange coveralls or reflective safety vest; Safety Glasses; Safety Shoes: steel-toed REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT: Insect repellent with DEET (recommended); Sunscreen; Wheel chocks
Activity/Sequence of Job Tasks Energy or Biological What would be the result of Energy/Biological/Waste Management Plan List all tasks required to perform a Sources exposure to a biological or Eliminate – Control – Protect job in the sequence they are (Check all that apply) energy source? (e.g., slip, Risk Control Measures carried out. trip, fall, exposure, List control measures required to eliminate, control or protect against unwanted contact with an uncontrolled electrocution, injury, death, biological or energy source to minimize the risk of injury or environmental impact. Include identification of etc.). How, where, or ‘Stop Work’ triggers. when could an uncontrolled release or unwanted contact with a biological or energy source occur? Please ensure that all necessary JSAs associated with your work scope have been identified and reviewed. A. Travel To and Arrive Onsite X Motion X Gravity 1a. Workers being struck/ 1a. Park in a secure area where vehicle is out of traffic pattern so that tailgate safety meeting can be 1. Complete JSA/HASP/safety X Chemical Radiation injured and work vehicles/ performed safely. Be extra cautious when parked near active roadways do to flying debris or other checklist/tailgate meeting Electrical Heat/Cold property damage being material flying off of roadway. Biological Pressure caused by traffic
Note: Please remember to 1b. Potential to cause a fire/ 1b. All personal electronic devices (e.g., cell phones) are not to be used in the vicinity of tank explosion by use of cell systems, remediation systems, vehicular traffic areas, or any area where the potential for an explosive complete each applicable client phones and other electronic environment exists or where cell phone use can distract from. Ensure that a 10 lb fire extinguisher is required checklist prior to equipment brought to and made available to site personnel surrounding hazards. performing on site activities. 1c. Overhead hazards 1c. Inspect work area for any overhead hazards including overhead utilities and overhead trees and Note: Identify and locate the vegetation. Emergency Stop switch for the A visual inspection of overhead tree branches and vegetation should be conducted prior to starting a fuel delivery system at all active job task. retail sites. Suspicious or dead braches will need to be removed prior to performing the job task. Working in a wooded area during high winds should be avoided and re-evaluate conditions after a storm. On-site edits:
2. Establish/set up site control X Motion Gravity 2a. Personal injury from 2a. Wear highly visible clothing such as orange reflective traffic vests or clothing. (traffic control) Chemical Radiation contact with vehicles; Utilize cones/barricades/safety fence to establish work zones as indicated in the “Traffic Control X Electrical Heat/Cold property damage caused by Program” posted in the HASP. Biological Pressure being hit with a vehicle Cone/flag height must be at least 50” tall. 2b. Personal injury to 2b. Establish access points in the work zone to keep pedestrians and unintentional traffic out. pedestrians if hit by (contact Inform facility personnel of work (restricted) area and do not permit unauthorized individuals (i.e., by) vehicles those not properly trained or wearing appropriate PPE) access to the exclusion zone. 2c. Electrocution and/ or 2c. A spotter must be utilized when vehicles, including construction vehicles, are backing or moving JSA Control #: 028 Page 2 of 4
property damage by onsite to ensure a safe pathway. Prior to any vehicle movement, a discussion must be held with each contacting overhead wires designated spotter so that they are aware of their responsibilities, hand signals that must be used for or structures directing equipment operators, and ensure that they are aware of any unique site conditions or concerns. Note: If electrical utilities Prior to moving any vehicle, all racks, doors, and toolboxes must be closed to prevent contact with must be de-energized and objects and to prevent items from falling out in transport. locked and tagged out of If there is no spotter, the driver must get out and walk around the vehicle prior to backing. service, a thorough Spotters must look up to ensure that there are no overhead wires or structures such as canopies that evaluation must be can be struck and ensure that they can be safely cleared by the operating equipment. conducted of the work area Look down to identify unusual depressions, holes, or debris that may interfere with backing. to ensure that all electrical Observe fixed objects or parked, unoccupied vehicles. service that is required to be Back slowly using rear view mirrors frequently. de-energized has been de- If backing vision is obscured, stop the vehicle every few feet to exit and recheck the backing route. energized and that no one Remain constantly alert at all times while backing a vehicle for the potential for other vehicles or remains exposed to pedestrians to appear unexpectedly in the path of travel. hazardous electrical energy. Vehicle tailgate must be in up/closed position when vehicle is in motion. 2d. Parked vehicles/ 2d. When parked and unhooked from a vehicle, trailers must have a wheel chock placed in front of and equipment may roll and behind each rear wheel. cause injury and/or property Wheel chocks must be used for large vehicles when parked/positioned on uneven surfaces (terrain). damage Wheel chocks must be used for vehicles or machinery that include but are not limited to all IRSP trucks (e.g., DAPL, HypeAir #1, #2, trailer, skid mounted F-250, F-350, dewatering truck, and PRSP trailers), aerial manlifts (e.g., cherrypickers), geoprobes as appropriate, airknife units, VR units, construction vehicles or equipment (gravel haulers, gravel trains), support vehicles (box trucks), support trailers, compressors units on wheels, and all vehicles with manual transmissions when parked on sloped surfaces. On-site edits:
3. Remove/load equipment from X Motion X Gravity 3a. Personal injury due to 3a. Utilize proper lifting procedure (keep your back straight) when loading coolers and/or equipment back vehicle Chemical Radiation back or other strains into truck; bend down at the knees and lift with your legs rather than bending and/or lifting with your back. Electrical Heat/Cold To avoid lifting heavy/awkward coolers, leave cooler on tailgate to load samples and ice into. Note: If equipment is to be placed Biological Pressure Utilize material handling devices when possible to move equipment (e.g., lift gates, pallet jacks, within an area that has an dollies, etc.). overhead/garage door which has If necessary, utilize a ramp for loading and unloading wheeled devices, ensuring the ramp is properly not been in use or appears to be supported prior to use. in poor or suspect condition, the Use mechanical means or assistance for items weighing >50 lbs. door and operating system 3b. Personal injury due to 3b. Maintain three points of contact when exiting vehicle cab or when exiting truck beds. (springs/ pulleys and wires) must falls while exiting vehicles Position cooler/equipment in a location that is nearest to exit point of vehicle (e.g., cab door, truck bed be inspected by a qualified tailgate) to eliminate the need to carry items while exiting vehicle. overhead/garage door repair 3c. Personal injury due to 3c. Ensure all equipment is properly secured and stored (e.g., tie downs, adjustable straps, tool box, tool service. The qualified individual equipment shift cabinet, etc.) during non- use and transportation. must ensure that the door can be Don appropriate gloves (leather) when securing or removing equipment. operated safely and that the door During removal of equipment be cautious of pinch points that may have been created due to shifting and its operating system do not equipment or equipment that may be secured or stored together. present any hazards to the individuals occupying the area.
On-site edits:
Form Revised 06/10/10 JSA Control #: 028 Page 3 of 4
4. Exposure Motion Gravity 4a. Weather related issues 4a. Staff should understand and be able to recognize the signs and/or symptoms of cold and hot weather X Chemical X Radiation related illnesses. Electrical X Heat/Cold Personnel should dress appropriately for ambient temperatures which would include but not be limited Biological Pressure to dry layered clothing. Applying sunscreen to exposed skin is strongly recommended during sunny weather conditions (all seasons) to mitigate sun exposure. 4b. Cold stress related 4b. For cold weather, work schedules should be adjusted to provide sufficient break periods in a heated injury area. 4c. Heat stress related 4c. For hot weather, work schedules may need to be adjusted to provide time intervals for replenishing injury fluids and which is free of contamination. 4d. Severe weather 4d. Avoid exposure to severe weather. Pay attention to severe weather alerts and take appropriate precautions to secure life and property when severe weather occurs in work area. Take precautions with approaching thunderstorms and lighting. Discontinue all work until 30 minutes after severe weather has passed. In case severe weather such as tornados, hailstorms, or strong winds, take cover and make every effort to protect life. Note: When operating equipment or machinery indoors that is fueled by gasoline, propane, or other hydrocarbon fuels, the emissions must be exhausted to the outside and carbon monoxide (CO) levels must be monitored during indoor activities. Levels of CO that exceeds 35 ppm will require operations to cease and staff to evacuate from the work area. 4e. Personal injury or illness 4e. Review and understand action levels noted in the HASP. due to exposure to site Monitor (evaluate) breathing zone of workers with PID. contaminants Monitor (evaluate) any enclosure with a PID. Ensure that Level C PPE is available for potential upgrade. Note: GES and/or subcontractor personnel are required to wear fire retardant clothing or protection when operating cutting tools that may generate sparks or generate conditions that act as ignition sources. On-site edits:
B. Biological Hazards Motion Gravity 1a. Injury or illness caused 1a. Wear appropriate PPE (e.g., eye protection, long pants, nitrile sampling gloves, shirt with sleeves, 1. Exposure Chemical Radiation by exposure to bio-hazards steel-toed boots). Electrical Heat/Cold 1b. Personal injury or illness 1b. Do not touch or contact poisonous plants, such as poison ivy and poison oak. X Biological Pressure caused by exposure to Apply an over-the-counter barrier cream such as Ivy Block® to prevent contact with plant oils. poisonous plants Wash hands and arms immediately with soap and water if skin contacts the plants. Wear long pants with socks pulled over legs to prevent skin contact with plants and insects. 1c. Personal injury or illness 1c. Spray any wasp/hornet nests with an insect repellent from a safe distance recommended by the due to exposure to insects product’s manufacturer. Ensure that long sleeve shirts and pants are worn at all times to prevent contact with ticks. Using insect repellent with DEET is strongly recommended. Do not spray your skin directly. If conditions warrant, don a Tyvek suit. Visually inspect and carefully open any outside enclosures that insects and small animals could potentially enter. 1d. Personal injury or illness 1d. Do not antagonize snakes or wild animals. due to encounters with animals On-site edits:
C. Traverse Site X Motion X Gravity 1a. Personal injury due to 1a. Maintain all equipment and tools in designated areas and out of pathways. 1. Walking service Chemical Radiation slips, trips, and falls Look for changes in elevation and grade when walking on uneven terrain.
Form Revised 06/10/10 JSA Control #: 028 Page 4 of 4
Electrical Heat/Cold Scan your walking path for obstructions, debris, slip, trip, and fall hazards. Biological Pressure If applicable, replace manhole covers securely to prevent tripping and vehicle accidents. If ice and slick conditions are present, use salt or sand to add traction to prevent slips. Do not traverse through standing water/puddles. Snow can be moved away from walkways if it poses a slip hazard. Place temporary ramps over hoses or cords leading from water source or power source to designated work zone. On-site edits:
Form Revised 06/10/10 Job Safety Analysis (JSA) Page 1 of 4
JSA Title: General Site Activities (Dusk and Night Work) JSA Control #: 029 Date Developed: 4/11/05 Please complete the below if this JSA is being modified for SITE-SPECIFIC reasons. Latest Revised Date: 4/12/10 Date Form Completed: Work Location: Initiated/Changed by: Lisa Leclair This JSA has been fully reviewed with all staff members and all activity job steps, hazards, work practices, and PPE are clearly understood and have been implemented. All necessary revisions have been written on this JSA. Approved by: Thomas Baylis, CIH
REQUIRED PPE: Gloves: nitrile, Kevlar, leather; Hard Hat: if working in an area with low overhead clearance; Hearing Protection: if site activities raise the noise level to 85 dB; PPE Clothing: highly visible clothing such as orange coveralls or reflective safety vest; Safety Glasses; Safety Shoes: steel-toed REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT:
Activity/Sequence of Job Tasks Energy or Biological What would be the result of Energy/Biological/Waste Management Plan List all tasks required to perform a Sources exposure to a biological or Eliminate – Control – Protect job in the sequence they are (Check all that apply) energy source? (e.g., slip, Risk Control Measures carried out. trip, fall, exposure, List control measures required to eliminate, control or protect against unwanted contact with an uncontrolled electrocution, injury, death, biological or energy source to minimize the risk of injury or environmental impact. Include identification of etc.). How, where, or ‘Stop Work’ triggers. when could an uncontrolled release or unwanted contact with a biological or energy source occur? Please ensure that all necessary JSAs associated with your work scope have been identified and reviewed. A. Travel To and Arrive Onsite X Motion Gravity 1a. Workers being struck/ 1a. Park in a secure area where vehicle is out of traffic pattern so that tailgate safety meeting can be 1. Complete JSA/HASP/safety X Chemical Radiation injured and work vehicles/ performed safely. checklist/tailgate meeting X Electrical Heat/Cold property damage being Be extra cautious when parked near active roadways do to flying debris or other material flying off of X Biological Pressure caused by traffic roadway.
Note: Two individuals will be 1b. Potential to cause a fire/ 1b. All personal electronic devices (i.e., cell phones) are not to be used in the vicinity of tank systems, explosion by use of cell remediation systems, vehicular traffic areas, or any area where the potential for an explosive environment required to be onsite for all phones and other electronic exists or where cell phone use can distract from surrounding hazards. Ensure that 10 lb fire extinguisher activities that occur during the equipment is brought to and available for site personnel. night unless an alternative 1c. Overhead hazards 1c. Inspect work area for any overhead hazards including overhead utilities and overhead trees and approach is implemented that is vegetation. approved by the director HSSE A visual inspection of overhead tree branches and vegetation should be conducted prior to starting a and the regional operations job task. manager. Suspicious or dead braches will need to be removed prior to performing the job task. Note: Please remember to Working in a wooded area during high winds should be avoided and re-evaluate conditions after a complete each applicable client storm. required checklist prior to performing on site activities. Note: Identify and locate the Emergency Stop switch for the fuel delivery system at all active retail sites.
On-site edits: JSA Control #: 029 Page 2 of 4
2. Establish/set up site control X Motion Gravity 2a. Personal injury from 2a. Wear highly visible clothing and REFLECTIVE traffic vests must be worn. (traffic control) Chemical Radiation contact with vehicles; Utilize cones/barricades/safety fence to establish work zones as indicated in the “Traffic Control X Electrical Heat/Cold property damage caused by Program” posted in the HASP. Flashing traffic barricades shall be placed around the work area Biological Pressure being hit with a vehicle perimeter. Cone/flag height must be at least 50” tall. 2b. Personal injury to 2b. Establish access points in the work zone to keep pedestrians and unintentional traffic out. pedestrians if hit by (contact Inform facility personnel of work (restricted) area and do not permit unauthorized individuals (those not by) vehicles properly trained or wearing appropriate PPE) access to the exclusion zone. 2c. Electrocution and/or 2c. A spotter must be utilized when vehicles, including construction vehicles, are backing or moving onsite property damage by to ensure a safe pathway. Prior to any vehicle movement, a discussion must be held with each contacting overhead wires designated spotter so that they are aware of their responsibilities, hand signals that must be used for or structures. directing equipment operators and ensure that they are aware of any unique site conditions or concerns. Note: If electrical utilities Prior to moving any vehicle, all racks, doors, and toolboxes must be closed to prevent contact with must be de-energized and objects and to prevent items from falling out in transport. locked and tagged out of If there is no spotter, the driver must get out and walk around the vehicle prior to backing. service, a thorough Spotters must look up to ensure that there are no overhead wires or structures such as canopies that evaluation must be can be struck and ensure that they can be safely cleared by the operating equipment. conducted of the work area Look down to identify unusual depressions, holes, or debris that may interfere with backing. to ensure that all electrical Observe fixed objects or parked, unoccupied vehicles. service that is required to be Back slowly using rear view mirrors frequently. de-energized has been de- If backing vision is obscured, stop the vehicle every few feet to exit and recheck the backing route. energized and that no one Remain constantly alert at all times while backing a vehicle for the potential for other vehicles or remains exposed to pedestrians to appear unexpectedly in the path of travel. hazardous electrical energy. Vehicle tail gate must be in up/closed position when vehicle is in motion. 2d. Parked vehicles/ 2d. When parked and unhooked from a vehicle, trailers must have a wheel chock placed in front of and equipment may roll and behind each rear wheel. cause injury and/or property Wheel chocks must also be used for large vehicles when parked or positioned on uneven surfaces damage (terrain). In addition, wheel chocks must be used for vehicles or machinery that include but are not limited to all IRSP trucks (DAPL, HypeAir#1, #2, trailer, skid mounted F-250, F-350, dewatering truck, and PRSP trailers), aerial manlifts (cherrypickers), geoprobes as appropriate, airknife units, VR units, construction vehicles or equipment (gravel haulers, gravel trains), support vehicles (box trucks), support trailers, compressors units on wheels, and all vehicles with manual transmissions when parked on sloped surfaces. 2e. Personal injury due to 2e. One or more flood lights (at least 4 feet high) with an output of 500 watt minimum shall be positioned working at dusk work and so sufficient lighting is maintained over the work area. The lighting should be sufficient to perform work limited lighting within the safely and that personnel and machinery is visible by all motorist. vicinity of the area covered A flashing beacon light shall be used and placed on the top of GES vehicle, parked in the vicinity of the by operating permanent working area. lights (i.e., service station) The GES vehicle should have the warning lights on. The beacon light and working sign should be placed so that the most visibility can be provided to motorists or other traffic. 2f. Personal injury due to 2f. A tower light (30 feet in height) with an output of 50,000 lumens shall be positioned so that an average night work/improper lighting illuminance of 20 footcandles is maintained over the work area. The lighting should be sufficient so that and work area visibility personnel and machinery is visible by all motorists. Machine lights shall be operated throughout the work period. Two illuminated work area signs shall be used and placed at the entrance to and exit from the work area. The signs should be placed so that the most visibility can be provided to motorists or other traffic. On-site edits:
Form Revised 06/10/10 JSA Control #: 029 Page 3 of 4
3. Remove/load equipment from X Motion X Gravity 3a. Personal injury due to 3a. Utilize proper lifting procedure (keep your back straight) when loading coolers and/or equipment back vehicle Chemical Radiation back or other strains into truck. Bend down at the knees and lift with your legs rather than bending and/or lifting with your back. Electrical Heat/Cold To avoid lifting heavy/awkward coolers, leave cooler on tailgate to load samples and ice into. Note: If equipment is to be placed Biological Pressure Utilize material handling devices when possible to move equipment (i.e., lift gates, pallet jacks, dollies, within an area that has an etc.). overhead/garage door which has If necessary, utilize a ramp for loading and unloading wheeled devices, ensuring the ramp is properly not been in use or appears to be supported prior to use. in poor or suspect condition, the Use mechanical means or assistance for items weighing >50 lbs. door and operating system 3b. Personal injury due to 3b. Maintain three points of contact when exiting vehicle cab or when exiting truck beds. (springs/ pulleys and wires) must falls while exiting vehicles Position cooler/equipment in a location that is nearest to exit point of vehicle (i.e., cab door, truck bed be inspected by a qualified tailgate) to eliminate the need to carry items while exiting vehicle. overhead/garage door repair 3c. Personal injury due 3c. Ensure all equipment is properly secured and stored (i.e., tie downs, adjustable straps, tool box, tool service. The qualified individual equipment shift cabinet, etc.) during non- use and transportation. must ensure that the door can be Don appropriate gloves (leather) when securing or removing equipment. operated safely and that the door During removal of equipment be cautious of pinch points that may have been created due to shifting and its operating system do not equipment or equipment that may be secured or stored together. present any hazards to the individuals occupying the area.
On-site edits:
4. Exposure Motion Gravity 4a. Weather related issues 4a. Staff should understand and be able to recognize the signs and/or symptoms of cold and hot weather Chemical X Radiation related illnesses. Electrical X Heat/Cold Personnel should dress appropriately for ambient temperatures which would include the use of dry Biological Pressure layered clothing. 4b. Cold stress related 4b. For cold weather, work schedules should be adjusted to provide sufficient break periods in a heated injury area. 4c. Heat stress related 4c. For hot weather, work schedules may need to be adjusted to provide time intervals for replenishing injury fluids and which is free of contamination. 4d. Severe weather 4d. Avoid exposure to severe weather. Pay attention to severe weather alerts and take appropriate precautions to secure life and property when severe weather occurs in work area. Take precautions with approaching thunderstorms and lighting. Discontinue all work until 30 minutes after severe weather has passed. In case severe weather such as tornados, hailstorms, or strong winds, take cover and make every effort to protect life. Note: When operating equipment or machinery indoors that is fueled by gasoline, propane, or other hydrocarbon fuels, the emissions must be exhausted to the outside and carbon monoxide (CO) levels must be monitored during indoor activities. Levels of CO that exceeds 35 ppm will require operations to cease and staff to evacuate from the work area. 4e. Personal injury or illness 4e. Review and understand action levels noted in the HASP. due to exposure to site Monitor (evaluate) breathing zone of workers with PID. contaminants Monitor (evaluate) any enclosure with a PID. Ensure that Level C PPE is available for potential upgrade. Note: GES and/or subcontractor personnel are required to wear fire retardant clothing or protection when operating cutting tools that may generate sparks or generate conditions that act as ignition sources. On-site edits:
Form Revised 06/10/10 JSA Control #: 029 Page 4 of 4
B. Biological Hazards Motion Gravity 1a. Injury or illness caused 1a. Wear appropriate PPE (i.e., eye protection, long pants, nitrile sampling gloves, shirt with sleeves, 1. Exposure Chemical Radiation by exposure to bio-hazards steel-toed shoes). Electrical Heat/Cold 1b. Personal injury or illness 1b. Do not touch or contact poisonous plants, such as poison ivy and poison oak. X Biological Pressure caused by exposure to If available, apply an over-the-counter barrier cream, such as Ivy Block® to prevent contact with plant poisonous plants oils. Wash hands and arms immediately with soap and water if skin contacts the plants. Wear long pants with socks pulled over legs to prevent skin contact with plants and insects. 1c. Personal injury or illness 1c. Spray any wasp/hornet nests with an insect repellant from a safe distance recommended by the due to exposure to insects product’s manufacturer. Inspect yourself carefully for insects or ticks after being outdoors. Visually inspect and carefully open any outside enclosures that insects and small animals could potentially enter. 1d. Personal injury or illness 1d. Do not antagonize snakes or wild animals. due to encounters with animals On-site edits:
C. Traverse Site X Motion X Gravity 1a. Personal injury due to 1a. Maintain all equipment and tools in designated areas and out of pathways. 1. Traversing site Chemical Radiation slips, trips, and falls Look for changes in elevation and grade when walking on uneven terrain. Electrical Heat/Cold Scan your walking path for obstructions, debris, slip, trip, and fall hazards. Biological Pressure If applicable, replace manhole covers securely to prevent tripping and vehicle accidents. If ice and slick conditions are present, use salt or sand to add traction to prevent slips. Do not traverse through standing water/puddles. Snow can be moved away from walk ways if it poses a slip hazard. Place temporary ramps over hoses or cords leading from water source or power source to designated work zone. On-site edits:
Form Revised 06/10/10 Job Safety Analysis (JSA) Page 1 of 2
JSA Title: Air Sparging/Vapor Extraction JSA Control #: 005 Date Developed: 2/23/05 Please complete the below if this JSA is being modified for SITE-SPECIFIC reasons. Latest Revised Date: 9/16/09 Date Form Completed: Work Location: Initiated/Changed by: Thomas Baylis, CIH This JSA has been fully reviewed with all staff members and all activity job steps, hazards, work practices, and PPE are clearly understood and have been implemented. All necessary revisions have been written on this JSA. Approved by: Julius Pachy
REQUIRED PPE: Air Purifying Respirator: required when PID action levels exceed HASP requirements; Gloves: nitrile, leather; Hard Hat: if working in an area with low overhead clearance; Hearing Protection: if site activities raise the noise level to 85 dB; PPE Clothing: highly visible clothing such as orange coveralls or reflective safety vest, Tyvek; Safety Glasses; Safety Shoes: steel-toed REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT: Lockout/tagout kit; J-Hooks to open well covers
Activity/Sequence of Job Tasks Energy or Biological What would be the result of Energy/Biological/Waste Management Plan List all tasks required to perform a Sources exposure to a biological or Eliminate – Control – Protect job in the sequence they are (Check all that apply) energy source? (e.g., slip, Risk Control Measures carried out. trip, fall, exposure, List control measures required to eliminate, control or protect against unwanted contact with an uncontrolled electrocution, injury, death, biological or energy source to minimize the risk of injury or environmental impact. Include identification of etc.). How, where, or ‘Stop Work’ triggers. when could an uncontrolled release or unwanted contact with a biological or energy source occur? Please ensure that all necessary JSAs associated with your work scope have been identified and reviewed. A. Begin Air Sparging X Motion X Gravity 1a. Contact with traffic 1a. Set up traffic controls per GES traffic control procedures (e.g., cones, flags, caution tape, work signs). 1. Set up truck/blower/air sparge X Chemical Radiation Upgrade traffic controls (e.g., snow fencing or barricades) to better protect workers from heavy traffic equipment X Electrical X Heat/Cold and/or pedestrians. X Biological X Pressure 1b. Pinch point/contact 1b. Check all the components of the equipment (e.g., air compressor, motor, etc.). Note: Be aware of pressure valve during equipment set up Make sure lines are securely connected. readings throughout the air sparge Make sure all belt guards are in place. process. If high levels are Make sure all fitting and gauges are secure. observed, stop operation Make sure all cam lock fittings have a safety pin in place. immediately. All hoses under pressure must be secured by a whip check device. Note: Inspect all hoses for damage, remove damaged hoses from service. 1c. Contact/exposure to 1c. Wear appropriate PPE (e.g., eye protection, long pants, nitrile or rubber gloves and leather work contaminates gloves as outer layer, hard hat, shirt with sleeves, and steel-toed boots). Monitor action levels per HASP, upgrade to Air Purifying Respirator if action level, due to vapors, exceeds HASP requirements. 1d. Noise 1d. Wear hearing protection during activity. 1e. Pinch point/contact 1e. Keep fingers from in between manway lid and ground. during well lid opening When opening well with J-Hook watch for bees, spiders, etc.; spray if insects are present. Secure all hose connections and well lids/seals. 1f. Contact overhead 1f. Make sure area is clear of overhead hazards before lowering drop tubes into well. obstacles Note: Some components may be hot. Wear protective gloves and long sleeves if contact is anticipated. Note: Some components may be under pressure. On-site edits: JSA Control #: 005 Page 2 of 2
2. If service or repairs are needed X Motion Gravity 2a. Electrical hazards 2a. Follow all LO/TO procedures if servicing or repairs must be made. Chemical Radiation Complete LO/TO permit. X Electrical Heat/Cold 2b. High pressure and 2b. Check pressure/vacuum and assure that the pressure/vacuum has been released prior to Biological X Pressure vacuum (stored in system) opening/removing any fittings, drains, etc. Wear proper PPE listed in section A.1b and 1c. Make sure guards are replaced, no one is near equipment, and all tools are removed prior to re- starting system. On-site edits:
B. Complete Air Sparging X Motion X Gravity 1a. Back strain 1a. Utilize proper lifting procedure when loading equipment back into truck. 1. Pick up all equipment, hoses, Chemical Radiation Bend down at the knees and lift with your legs rather than bending and lifting with your back. secure wells, and load truck Electrical Heat/Cold Do not lift any items over 50 lbs without help or mechanical means. Biological Pressure 1b. Pinch points 1b. Wear leather gloves and keep fingers out of the way of the manway lid and the ground to avoid pinching. On-site edits:
Form Revised 06/10/10 Job Safety Analysis (JSA) Page 1 of 3
JSA Title: Drilling (Core Drill) JSA Control #: 094 Date Developed: 3/1/07 Please complete the below if this JSA is being modified for SITE-SPECIFIC reasons. Latest Revised Date: 1/21/08 Date Form Completed: Work Location: Initiated/Changed by: Patrick Monterio This JSA has been fully reviewed with all staff members and all activity job steps, hazards, work practices, and PPE are clearly understood and have been implemented. All necessary revisions have been written on this JSA. Approved by: Thomas Baylis, CIH
REQUIRED PPE: Gloves: nitrile, leather; Hard Hat: if working in an area with low overhead clearance; Hearing Protection: if site activities raise the noise level to 85 dB; PPE Clothing: highly visible clothing such as orange coveralls or reflective safety vest; Safety Glasses; Safety Shoes: steel-toed REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT: Cutting tools; Hotwork Permit
Activity/Sequence of Job Tasks Energy or Biological What would be the result of Energy/Biological/Waste Management Plan List all tasks required to perform a Sources exposure to a biological or Eliminate – Control – Protect job in the sequence they are (Check all that apply) energy source? (e.g., slip, Risk Control Measures carried out. trip, fall, exposure, List control measures required to eliminate, control or protect against unwanted contact with an uncontrolled electrocution, injury, death, biological or energy source to minimize the risk of injury or environmental impact. Include identification of etc.). How, where, or ‘Stop Work’ triggers. when could an uncontrolled release or unwanted contact with a biological or energy source occur? Please ensure that all necessary JSAs associated with your work scope have been identified and reviewed. A. Premobilization X Motion Gravity 1a. Equipment maintenance 1a. Ensure that PM or person responsible for scheduling rental equipment requests that the vendor 1. Equipment inspection Chemical Radiation inspects the equipment prior to site delivery. Electrical Heat/Cold Biological X Pressure
On-site edits:
B. Power Equipment X Motion X Gravity 1a. Proper equipment 1a. Prior to acceptance of equipment from the vendor (if rented equipment), review the operating 1. Use of core drill Chemical Radiation maintenance/operation procedures and maintenance logs with the vendor representative (if applicable). X Electrical Heat/Cold 1b. Contact with cutting 1b. Wear appropriate PPE (i.e., eye protection, long pants, nitrile sampling gloves (inner), leather gloves Note: Only trained operators are Biological X Pressure tools (outer), hard hat, hearing protection, shirt with sleeves, steel-toed boots.) No loose sleeves – may get permitted to perform this task. caught in rotating drill. 1c. Noise 1c. Wear hearing protection 1d. Electric machinery 1d. Make sure you are using GFI protected outlet Use appropriate gauge extension cord. Make sure cord is in good shape. Watch distance from outlet; amperage issues from electric motor could trip breaker. Watch water used in coring doesn’t affect electric; it is a potential shock hazard. If using a generator be careful of hot exhaust, exhaust fumes. Make sure area is well ventilated. Be careful when using gas to fuel generator. 1e. Rotating machinery 1e. Inspect the cutting equipment prior to start of work. Make sure blade/bit is sharp and guards are in place. Cut away from your body; keep feet out of the path of cutting tools. Place the core drill on a debris-free level surface before cutting. Make sure base is level, adjust if needed; typically has adjustment screws for leveling. Use vacuum pump if on machine to stabilize. JSA Control #: 094 Page 2 of 3
Use concrete anchors that are attached to the drill to stabilize the base when there is no vacuum. Stand on the back of base to stabilize it only if ABSOLUTELY necessary. 1f. Flying/shattering objects 1f. Have bystanders maintain a 5 foot distance from the operation at all times. 1g. Bend knees to lift out of back of truck. Use two people to prevent back strain. Once on ground you 1g. Back strain should have wheels (i.e., dolly); item is heavy and awkward. Note: If any drums are filled with soil or any material, the drum can only be filled a maximum of two-thirds (2/3) full. 1h. Manual transportation 1h. Ensure that the drill body lock is engaged and functioning properly prior to transport. 1i. Hand positioning/pinch 1i. If feasible, move drill body down the drill pole and place your hand at the top of the drill pole away from points the drill body to stabilize the rig during transport. While moving core drill, keep hands away from the top of the drill body where the vertical rollers move the body of the drill up and down on the mast. On-site edits:
2. Starting the core drill X Motion Gravity 2a. Wrist strain 2a. Make sure water is on to hose bib fitting to ensure lubrication of cutting area (i.e., asphalt, concrete, Chemical Radiation etc.) Electrical Heat/Cold Water also displaces cutting debris from core hole. Biological X Pressure Concrete is much more difficult to core; be careful of rebar and aggregate in concrete. Gently and slowly apply force to penetrate the surface of the asphalt. DO NOT FORCE. This is not good for drill bit and may cause machine to bind up. Potential to spin and throw you. If you force bit into concrete it may cause breakage of shaft-safety pin which is a sacrificial break point to alleviate too much force on machine (can be replaced, there usually is a spare on the machine) Never start the Core Drill while holding it off the ground or by "drop starting" it. Be careful if restarting in borehole. Make sure the bit is not bound up or it could send the machine into a spin. 2b. Pinch points 2b. Make sure fingers are clear of drill head adjustment teeth. Turn adjustment pin to tighten or loosen drill head to move up and down with crank wheel. On-site edits:
3. Preparing to cut X Motion Gravity 3a. Flying debris/caught by 3a. Clear away anything that has a chance of interfering with the operation. Chemical Radiation /contact Remove debris that could cause you to slip or lose your balance or accidentally contact the drill Electrical Heat/Cold blade/bit. Biological X Pressure Keep both hands away from the rotating drill blade/bit. Make sure that all kill switches are functioning properly. If necessary, perform wet cut when possible to reduce amount of dust and sparks generated during the cutting process. 3b. Removal of core 3b. If core gets stuck in borehole, use thin stiff wire w/90 degree bend on end to slide down and beneath the core and lift out; be careful not to bang bit to hard (can be damaged). Watch you do not pinch fingers in between core and side of cored hole. Make sure water is on in bit; may push out a stuck core. On-site edits:
4. Hotwork Permit Motion Gravity 4a. Fire/explosion 4a. Complete a Hotwork Permit when completing cuts within 35 feet of a vapor source. X Chemical Radiation Note: Air monitoring must take place throughout the cutting procedure if the possibility of flammable Electrical Heat/Cold vapors exists. Biological X Pressure
Form Revised 06/10/10 JSA Control #: 094 Page 3 of 3
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Form Revised 06/10/10 Job Safety Analysis (JSA) Page 1 of 5
JSA Title: Drilling/Soil Boring/Monitoring Well Installation JSA Control #: 019 Date Developed: 2/23/05 Please complete the below if this JSA is being modified for SITE-SPECIFIC reasons. Latest Revised Date: 2/15/11 Date Form Completed: Work Location: Initiated/Changed by: Maurice Baron This JSA has been fully reviewed with all staff members and all activity job steps, hazards, work practices, and PPE are clearly understood and have been implemented. All necessary revisions have been written on this JSA. Approved by: Thomas Baylis, CIH
REQUIRED PPE: Air Respirator: respirators may be required if conditions or work area air quality exceeds applicable HASP action levels; don a DUST MASK for comfort if inhalation of concrete dust is unavoidable. Face Shield: if flying particles are generated. Gloves: nitrile, Kevlar, leather. Hard Hat. Hearing Protection: if site activities raise the noise level to 85 dB. PPE Clothing: highly visible clothing such as orange coveralls or reflective safety vest. Safety Glasses/ Safety Shoes: steel-toed, non-slip soles REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT: PID, GCI/O2 or LEL meter; Sample bottles/jars; Lockout/tagout kit; Spill response kit/spill pad - used under hydraulic equipment when work activities occur on a permeable surface such as grass or gravel; Hotwork Permit; Driller's tools - inspect condition of; Samd and or salt for ice; PVC casing (6-10")
Activity/Sequence of Job Tasks Energy or Biological What would be the result of Energy/Biological/Waste Management Plan List all tasks required to perform a Sources exposure to a biological or Eliminate – Control – Protect job in the sequence they are (Check all that apply) energy source? (e.g., slip, Risk Control Measures carried out. trip, fall, exposure, List control measures required to eliminate, control or protect against unwanted contact with an uncontrolled electrocution, injury, death, biological or energy source to minimize the risk of injury or environmental impact. Include identification of etc.). How, where, or ‘Stop Work’ triggers. when could an uncontrolled release or unwanted contact with a biological or energy source occur? Please ensure that all necessary JSAs associated with your work scope have been identified and reviewed. A. Prepare for Soil Boring and X Motion X Gravity 1a. Drill rig maintenance, 1a. Evaluate subcontractor rig maintenance verification form for completeness. Well Installation Chemical Radiation operational safety Accompany subcontractor during a visual inspection of the drill rig prior to start up. 1. Review, inspect and locate Electrical Heat/Cold Complete GES’ Drilling Site Safety Checklist. safety equipment including fire Biological Pressure 1b. Trip, slips, falls 1b. Maintain all equipment and tools in designated areas and out of pathways. extinguisher, first aid kit, insect Identify and protect all air lines, water lines, electrical cords, and cables. repellant, ice melt, PPE, etc. Inspect work area for uneven ground and terrain. Watch for the formation of snow covered ice during cold weather. Note: Show subcontractors 1c. Exertion 1c. Use proper lifting techniques; bend at the legs and keep back straight. location of first aid kit and eye Hold item close to body. wash; check fire extinguisher on Items heavier than 50 lbs or items that are awkward to handle, use mechanical devices or ask for drill rig. help.
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2. Ensure that appropriate Motion X Gravity 2a. Contact 2a. Identify appropriate safety equipment and PPE. equipment and materials are X Chemical Radiation Time savings to reduce trips for forgotten items. available for sampling Electrical Heat/Cold Ensure proper gloves are worn for the appropriate task and client-specific protocols. Biological Pressure . Leather gloves shall be worn at all times while operating the drill rig, handling augers, operating equipment, handling heavy loads, and whenever else deemed appropriate. . Kevlar gloves shall be worn while handling cutting tools or any other sharp objects. . Nitrile gloves shall be worn over Kevlar gloves when there is a potential to contact any contaminated solids or fluids. Ensure the appropriate layering of gloves (i.e., nitrile gloves are worn under leather gloves while handling augers). JSA Control #: 019 Page 2 of 5
2b. Cuts, burns, acid 2b. Watch for broken bottles (i.e., when removing from cooler, be careful while filling sample vials/jars, contact and when placing on ice in cooler). On-site edits:
3. Load required equipment on X Motion X Gravity 3a. Exertion 3a. Use proper lifting techniques; this consists of bending your knees and lifting with your back straight. support truck and drill rig Chemical Radiation While carrying, hold objects close to your body. Electrical Heat/Cold Items heavier than 50 lbs or items that are awkward to handle, use mechanical devices or ask for Biological X Pressure help. 3b. Slips, trips, falls 3b. Continuously check ground for uneven and slippery terrain. 3c. Caught, pinch points 3c. Position hands 6 inches away from pinch points on lift gate latches and utility boxes. Use established handles and/or latches while opening and closing. On-site edits:
4. Drill rig positioning at drilling X Motion Gravity 4a. Contact with rig 4a. All staff except those individuals who are responsible for positioning and leveling the rig must remain location Chemical Radiation supports/ levelers at least 20 feet away from the rig. X Electrical Heat/Cold Note: If the rig is positioned on soft ground or there is any evidence of the levelers or jacks sinking into Biological Pressure the soil or other surfaces, all activities must stop and all site staff alerted. The GES oversight person must call into the office, the client notified, and a near loss report must be completed regarding the issue. Prior to restarting activities, approved cribbing and other supports must be placed under each leveler (jack). If there is still evidence of sinking or if the rig appears to be unstable in any way, all work must stop, site staff alerted, and the local GES office and corporate HSSE notified. Work should not begin until all issues have been resolved. 4b. Electrocution contact 4b. Locate all sources of electricity to site features. with underground energized To the extent possible, LO/TO all sources of electricity in the vicinity of the drilling location. electrical lines Position boom a minimum of 10 feet from overhead power lines. Have an observer watch the raising of mast. Notify all affected employees on-site of the de-energized condition. Note If the mark out locations are not visible (i.e. covered by snow, debris, vehicles, washed away/faded, etc.) stop work and contact the project manager or senior office manager. On-site edits:
5. Drilling area containment X Motion X Gravity 5a. Exertion 5a. See A.3a for guidance when carrying and placing bails of straw or other material for containment. construction Chemical Radiation 5b. Pinch points with tools 5b. Use appropriate PPE including safety glasses and nitrile coated or regular work gloves. Electrical Heat/Cold (hammer) and equipment Note: Containment construction must comply with the guidance provided in Attachment 3 of GES’ Biological X Pressure (stakes or other material “Drilling Protocol”.
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B. Drilling X Motion X Gravity 1a. Clearing 1a. Ensure that the use of soft dig protocol creates a borehole clearance that is at least 2 inches wider 1. Begin drilling soil boring/ X Chemical Radiation than the widest drilling tool. monitor well Electrical X Heat/Cold Always clear to at least 5 feet depth outside the exclusion zone and to 8’ depth in the exclusion zone. Biological X Pressure If soils are collapsing during the soft dig process, insert the appropriate sized PVC casing to keep the Note: When using an air rotary to hole open to at least 2 inches wider than the widest drilling tool. drill the borehole ensure that the Note: If any evidence of peastone is observed during handclearing, drilling, excavation, or any protective skirt is firmly secured to subsurface activity, all subsurface work must stop and the project manager and/or the senior office manager must be contacted immediately. Form Revised 06/10/10 JSA Control #: 019 Page 3 of 5 the drill rig in order to prevent 1b. Contact and caught 1b. Ensure locations have been cleared. sudden expulsions of potentially Stay 2 feet away from moving rotating parts (e.g., augers, drill drive shaft, etc.). impacted groundwater/mud from Recommended to keep at least 10 feet away from borehole while drilling is in progress. the open borehole, rapid Confer with drillers to make sure you are in a good spot (i.e., safe distance and out of their work zone) propulsion of the skirt, and/or Note: If a jackhammer is used to break concrete or asphalt, wear leather or vibration-absorbing gloves, potential exposures to on-site eye protection, hearing protection, and a hard hat. personnel. Use shovels to push debris out of way. Follow manufacturer’s operating procedures for equipment. Have a stable stance; feet shoulder width apart, hold jackhammer lightly and balanced. Do not wear excessively loose, baggy clothing, or jewelry. Take breaks (a 10 minute break every hour of operation) during operation of equipment (e.g., jack hammer) to prevent vibration/repetitive motion injuries. 1c. Exertion 1c. Bend down at the knees and lift with your legs rather than bending and lifting with your back. Drink plenty of water and Gatorade. 1d. Exposure 1d. Use nitrile gloves while handling soil samples. Scan with PID. Monitor air in work area for elevated vapors during drilling activities. 1e. Noise 1e. Wear hearing protection (i.e., ear muffs or foam inserts). Note: If any drums are filled with soil or any material, the drum can only be filled a maximum of two-thirds (2/3) full. On-site edits:
2. Collecting soil samples if Motion X Gravity 2a. Exposure 2a. Proper PPE nitrile gloves for handling soil samples (e.g., safety glasses, hard hat, nitrile gloves, Level necessary X Chemical Radiation D clothing). Electrical X Heat/Cold Handle sample jars safely, if a jar is broken make sure leather work gloves are used during clean up. Biological Pressure 2b. Contact 2b. While logging soil samples, continuously observe all drilling activities and maintain a safe distance from the active drilling. 2c. Slips, trips, falls 2c. Maintain work area, keep walk ways clean, pick up tools, and soil in drums. Watch for ice formation while drilling in winter. On-site edits:
3. Auger removal X Motion X Gravity 3a. Contact and caught 3a. Use proper auger removal tools; NO J-hooks. Chemical Radiation Leather work gloves must be used while handling winch cables. Electrical Heat/Cold Only Shackles properly secured to the auger flight should be used for lift augers; shackles should be Biological Pressure certified by the manufacturer and appropriately labeled/stamped with model number or other documentation confirming load rating. The augers should be lifted hydraulically with the drive cap bolted on the auger string; if permitted, the use of a clevace or chain wrap device should be wrapped around the augers so that the augers can be lifted and placed in the proper location safely. 3b. Exertion 3b. Utilize proper lifting procedures. See A.3a. On-site edits:
4. Install well (riser, screen, sand X Motion X Gravity 4a. Exertion 4a. Utilize proper lifting procedures while carrying bentonite and sand bags. pack, and bentonite) X Chemical Radiation 4b. Slips, trips, falls 4b. Make sure work area is clean, pick up all tools, sweep up all soil, and maintain walk ways. Electrical Heat/Cold Fall protection is required whenever individuals are working 6 feet or more above ground level. Biological X Pressure 4c. Exposure, inhalation 4c. Monitor vapor levels in work area and wear nitrile gloves when cleaning up soil. hazard from nuisance dust Position yourself up wind from concrete dust generated while mixing.
Form Revised 06/10/10 JSA Control #: 019 Page 4 of 5
4d. Striking and laceration Don a dust mask for comfort if inhalation is unavoidable. from saw or cutting device 4d. Wear cut resistant (Kevlar or similar) gloves during this activity and the appropriate cutting tool plastic while cutting PVC well to pipe cutter or similar tool must be used. finished length.
Note: Do not use a die grinder tool or similar device to cut casing. An internal plastic pipe cutter, or a tool that could not result in a hand injury is acceptable On-site edits:
5. Pressure grout the steel casing X Motion X Gravity 5a. Back injury that can 5a. Utilize proper lifting procedures to add materials to the mixer and while installing or removing the (if open rock well) or PVC riser in X Chemical Radiation result from exertion tremie pipe; see A.3a. place using a tremie pipe Electrical Heat/Cold 5b. Respiratory irritation 5b. Avoid breathing dust generated when opening bags or mixing the grout. Biological X Pressure from nuisance dust, Stay upwind of the dust or wear a dust mask for comfort. inhalation hazard 5c. Injury from the contact 5c. Wear appropriate PPE (e.g., eye protection, long pants, nitrile gloves or nitrile coated work gloves, with materials or equipment shirt with sleeves, steel-toed boots). 5d. Skin irritation from the 5d. Avoid contact with grout; grout may cause skin irritation and burns. exposure to grout 5e. Injury from exposure to 5e. Do not reach into the mixer while operating. pinch points Make sure all guards are in place on the mixer prior to operating. 5f. Potential hearing loss 5f. Wear proper hearing protection (e.g., ear muffs or foam inserts) if noise levels exceed 85 dB. from exposure to elevated noise levels. On-site edits:
6. Install manway and concrete X Motion X Gravity 6a. Exertion 6a. Utilize proper lifting procedures while carrying concrete bags. pad X Chemical Radiation While mixing concrete use a balanced stance and mix slowly to avoid splashing concrete. Electrical Heat/Cold 6b. Slips, trips, falls 6b. Make sure work area is clean, pick up all tools, sweep up all soil, and maintain walk ways. Biological X Pressure 6c. Spark/dust reduction 6c. When possible, perform wet cuts to reduce the explosion and dust hazard. 6d. Fire/explosion 6d. If sparks are generated within 35 feet of a vapor source (i.e., an operating pump island) a Hotwork Permit must be furnished and air monitoring must take place. 6e. Personal injury from 6e. A "spotter" should be used when manually hauling or moving any loads such as using a wheel barrow contact with vehicles that could deviate their attention from surrounding hazards. On-site edits:
C. Decontamination X Motion X Gravity 1a. Contact 1a. Proper PPE safety glasses, hard hat, ear muffs, work gloves, Level D clothing. Procedures X Chemical Radiation 1b. Exertion 1b. Utilize proper lifting procedures 1. Decontamination of augers and Electrical Heat/Cold See A.3a if augers need to be carried to decon area or manually loaded into a truck; use 2 people. drilling tools (use for guideline Biological Pressure 1c. Slips, trips, falls 1c. Make sure work area is clean, pick up all tools, sweep up all soil, and maintain walk ways. while drilling and decontaminating split spoons)
Form Revised 06/10/10 JSA Control #: 019 Page 5 of 5
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2. Soak/spray durable equipment X Motion X Gravity 2a. Contact 2a. Wear appropriate PPE (e.g., eye protection, long pants, nitrile sampling gloves, shirt with sleeves, to prevent cross-contamination X Chemical Radiation hard hat, steel-toed boots, rain suit or coated Saranex). between multiple well locations; Electrical Heat/Cold Comply with monitoring and action level requirements in HASP. properly store disposable Biological Pressure 2b. Exposure 2b. Avoid contact with all decontamination chemicals including Liquinox and any other soaps or solvents equipment used on drilling equipment. Use of face shield during high pressure washing to avoid splashing face. 2c. Exertion 2c. Utilize proper lifting procedures; see A.3a. On-site edits:
E. Mobilization X Motion X Gravity 1a. Contact and caught 1a. Ensure an observer is watching the raising and lowering of the drill rig mast so no lines or overhead 1. Preparation to mob to next Chemical Radiation obstacles are contacted. drilling location or leave site Electrical Heat/Cold Use proper PPE (e.g., hard hat, safety glasses, hearing protection (while rig is operational), steel-toed Biological Pressure boots, and leather work gloves. Prior to lowering rig off of outriggers make sure all tools and personnel are clear of the drill rig. Prior to driving to next location make sure auger racks are in. While rig is moving on site have spotters verify clearance so no overhead obstacles are contacted and no obstacles are hit while backing up. 1b. Exertion 1b. Utilize proper lifting procedures. See A.3a and drink plenty of water and Gatorade. On-site edits:
Form Revised 06/10/10
JOB SAFETY ANALYSIS DATE 2/23/05, 3/31/06, 8/17/07, 6/9/08, 4/24/09 NEW PAGE 1 of 2 X REVISED JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) JSA # All Work Locations Assessment and Drum Sampling/Evaluation 022 Remediation DEVELOPMENT TEAM POSITION / TITLE REVIEWED BY POSITION / TITLE Thomas Baylis, CIH Dir, HSSE Eric Munz, CSP Reg HSSE Spec - NE Eric Munz, CSP Reg HSSE Spec - NE
REQUIRED (use an “X”) & RECOMMENDED (use an “&”) PERSONAL PROTECTIVE EQUIPMENT – Place appropriate symbol on corresponding line(s) X AIR PURIFYING RESPIRATOR X HEARING PROTECTION X SAFETY SHOES steel-toed and booties FACE SHIELD LIFELINE / HARNESS SUPPLIED RESPIRATOR X GLOVES nitrile exam gloves, nitirile 11-mil X PPE CLOTHING highly visible clothing such OTHER outer gloves, leather as orange coveralls, Tyvek, reflective safety X GOGGLES vest X HARD HAT X SAFETY GLASSES REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT 1. PID 2. LEL 3. Eyewash kit 4. Flashlight 5.
¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS A. Review “General Site Activities” JSA #028 B. Protective Equipment 1. Don proper PPE 1a. Exposure to contaminants 1a. Wear appropriate PPE (eye protection-goggles, long pants, nitrile exam gloves, nitrile over-gloves (11-mil, long wrist), Tyvek Note: This JSA is only coveralls, shirt with sleeves, steel-toed shoes with boot covers, intended for sampling drums half-face air purifying respirator fitted with an organic vapor, that contain waste oil or similar acid, HEPA filter combination cartridge). material. Drums that contain Evaluate (monitor work area with a CGI/O2 (LEL). If levels an unknown material are not to exceed 10% LEL, leave the area and contact GES Corporate be opened and may only be H&S. handled and sampled under Review action levels noted in the HASP. the direct supervision of When approaching or sampling drum(s), monitor breathing Corporate H&S. zone with a PID. If levels exceed 50 ppm in breathing zone, leave area and contact GES Corporate H&S. Restrict any contact with bailed/recovered waste samples. C. Inspect the Drum 1. Drum(s) condition 1a. Spill prevention and 1a. Evaluate drum(s) condition, if drums are distended or containment bulging, leave the area and contact GES Corporate H&S. To prevent contamination of clean or non-impacted surfaces, place absorbent material (i.e., pads, absorbent pillows, etc.) around the perimeter of the drum(s) and parts cleaner. Note: If any drums are filled with soil or any material, the drum can only be filled a maximum of two-thirds (2/3) full. 1b. Slips/trips/falls 1b. Keep all equipment and tools in designated areas within working (exclusion) zone. Secure and protect all air lines, water lines, electrical cords, and cables. 1c. Cuts to the skin/PPE 1c. Handle all sample collection containers and tools with protective gloves (e.g., nitrile knit or leather) to prevent cuts. Be cautious of your surroundings; do not kneel on broken glass or sharp objects. 1d. Fire, explosion 1d. Use the proper tool for the job. Use non-sparking tools for opening and sampling drums. 1e. Inadequate lighting 1e. Ensure that there is enough light to complete the necessary activities. If sufficient lighting can not be obtained, two GES personnel must be onsite to complete the necessary task. 2. Release pressure in the 2a. Pressurized vessel 2a. Loosen the vent port slowly to release any pressure that drum might have built up in the container. 3. Open the drum or securing 3a. Pinch point 3a. Use the proper type of gloves – thick enough to prevent the drum collar pinch points and cuts (i.e., leather, nitrile coated knit, etc.). 4. Moving/relocating drums 4a. Back strain 4a. If drums must be moved utilize a drum dolly. DO NOT ATTEMPT TO “WALK” or “ROCK” DRUMS TO
JOB SAFETY ANALYSIS Page 2 of 2
¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS MOVE THEM. Drums can become unstable and easily tip- over causing possible damage and personal injury as well as releasing the material contained.
WORK ACTIVITY (Description) — Drum Handling - #022
Job Safety Analysis (JSA) Page 1 of 2
JSA Title: Gauging Liquid Levels in Groundwater Monitoring Wells JSA Control #: 027 Date Developed: 2/28/05 Please complete the below if this JSA is being modified for SITE-SPECIFIC reasons. Latest Revised Date: 2/15/11 Date Form Completed: Work Location: Initiated/Changed by: Deb Tierney This JSA has been fully reviewed with all staff members and all activity job steps, hazards, work practices, and PPE are clearly understood and have been implemented. All necessary revisions have been written on this JSA. Approved by: Thomas Baylis, CIH
REQUIRED PPE: Gloves: nitrile, leather. Hearing Protection: if site activities raise the noise level to 85 dB. PPE Clothing: highly visible clothing such as orange coveralls or reflective safety vest. Safety Glasses. Safety Shoes: steel-toed. Respirator: may be required if conditions or work area air quality exceeds applicable HASP action levels. REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT:
Activity/Sequence of Job Tasks Energy or Biological What would be the result of Energy/Biological/Waste Management Plan List all tasks required to perform a Sources exposure to a biological or Eliminate – Control – Protect job in the sequence they are (Check all that apply) energy source? (e.g., slip, Risk Control Measures carried out. trip, fall, exposure, List control measures required to eliminate, control or protect against unwanted contact with an uncontrolled electrocution, injury, death, biological or energy source to minimize the risk of injury or environmental impact. Include identification of etc.). How, where, or ‘Stop Work’ triggers. when could an uncontrolled release or unwanted contact with a biological or energy source occur? Please ensure that all necessary JSAs associated with your work scope have been identified and reviewed. A. Locate and Open Onsite Motion X Gravity 1a. Slips, trips, and falls 1a. Maintain all equipment and tools in designated areas and out of pathways. Wells Chemical Radiation Be alert for uneven terrain. 1. Traverse site to wells Electrical Heat/Cold Biological Pressure
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2. Inspect and open wells, replace X Motion Gravity 2a. Pinch points/abrasion 2a. Remove and replace manhole covers so that they do not pinch fingers. well cap, and cover Chemical Radiation Wear leather work gloves to protect your fingers and hand. Electrical Heat/Cold Use kneeling pads when kneeling on hard surfaces. Biological X Pressure 2b. Contact with, struck by 2b. Release any stored air pressure in the well casing by slowly removing well cap. well cap On-site edits:
B. Conduct Liquid Gauging Motion Gravity 1a. Exposure to site 1a. Wear appropriate PPE (i.e., eye protection [goggles when exposed to contaminants], long pants, 1. Insert interface probe into well X Chemical Radiation contaminants nitrile sampling gloves, shirt with sleeves, steel-toed shoes). X Electrical Heat/Cold Note: All wells need to be screened with a PID to determine the presence of vapors. Comply with action Biological Pressure levels stated within site specific HASP. 1b. Exposure to 1b. Avoid skin/eye/mouth contact with contamination chemicals and decon waste water. decontamination chemicals Wear nitrile gloves and eye protection. 1c. Electrical shock or 1c. If there is an electrical powered pump installed in the well, the pump must be de-energized and locked electrocution and tagged out prior to inserting the interface probe into the well. JSA Control #: 027 Page 2 of 2
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Form Revised 06/10/10 Job Safety Analysis (JSA) Page 1 of 3
JSA Title: Groundwater Sampling JSA Control #: 032 Date Developed: 2/8/05 Please complete the below if this JSA is being modified for SITE-SPECIFIC reasons. Latest Revised Date: 4/16/10 Date Form Completed: Work Location: Initiated/Changed by: Scott Martin, Project Env Sci This JSA has been fully reviewed with all staff members and all activity job steps, hazards, work practices, and PPE are clearly understood and have been implemented. All necessary revisions have been written on this JSA. Approved by: Julius Pachy and Thomas Baylis, CIH
REQUIRED PPE: Gloves: nitrile, Kevlar, leather; Hard Hat: if working in an area with low overhead clearance; Hearing Protection: if site activities raise the noise level to 85 dB; PPE Clothing: highly visible clothing such as orange coveralls or reflective safety vest; Safety Glasses; Safety Shoes: steel-toed REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT: LEL (to be used if within 35 feet of an ignition source); PID (if organic vapors are probable)
Activity/Sequence of Job Tasks Energy or Biological What would be the result of Energy/Biological/Waste Management Plan List all tasks required to perform a Sources exposure to a biological or Eliminate – Control – Protect job in the sequence they are (Check all that apply) energy source? (e.g., slip, Risk Control Measures carried out. trip, fall, exposure, List control measures required to eliminate, control or protect against unwanted contact with an uncontrolled electrocution, injury, death, biological or energy source to minimize the risk of injury or environmental impact. Include identification of etc.). How, where, or ‘Stop Work’ triggers. when could an uncontrolled release or unwanted contact with a biological or energy source occur?
A. Locate and Open Onsite X Motion Gravity 1a. Pinch points/abrasion 1a. Remove and replace manhole covers so that they do not pinch fingers. Wells X Chemical Radiation Use a screwdriver or crowbar as appropriate and wear work gloves to prevent injuries to hands. 1. Inspect and open wells Electrical Heat/Cold Use kneeling pads when kneeling on hard surfaces. Biological Pressure 1b. Back strain 1b. Utilize proper lifting procedure when removing covers. Bend down at the knees and lift with your legs The GES SOP for “Groundwater rather than bending and/or lifting with your back. Sampling” must be reviewed. 1c. Shoulder strain resulting 1c. Always keep your wrist straight when using a wrench. Please note that it is important that from using a socket wrench Be sure that the opening of the socket is in full contact with the bolt before you apply pressure. the GES vehicle is shut-off or the to loosen and remove bolts Pull, don't push, and use a slow, steady motion. If the bolt can not be loosened with normal force, use vehicle positioned so that the from the lid the correct breaking bar and do not place a piece of pipe on the end of the wrench to improve vehicle exhaust does not present leverage. an exposure concern for staff Protect yourself from losing your balance if the wrench slips or a bolt breaks. Kneel on a solid surface members or impact sample with one foot planted firmly on the floor and don't lean into the work. integrity Note: Never use hand sockets with power or impact wrenches. Replace sockets showing cracks or wear. On-site edits:
B. Conduct Liquid Gauging X Motion Gravity 1a. Exposure to site 1a. Wear appropriate PPE (i.e., eye protection, long pants, nitrile sampling gloves, shirt with sleeves, 1. Insert interface probe into well X Chemical Radiation contaminants steel-toed boots). and record liquid level reading in Electrical Heat/Cold 1b. Inhalation of organic 1b. If organic vapors are present, replace the well cap and do not proceed until a PID is obtained to scan site log book Biological Pressure vapors the atmosphere ensuring that concentrations are below 5 ppm. Note: Be aware that there may be elevated levels of gasoline or product vapors in the wells. On-site edits:
C. Purge Monitoring Well X Motion X Gravity 1a. Exposure to site 1a. Refer to PPE required for B.1a. 1. Set up of equipment; insert X Chemical Radiation contaminants Do not splash purged water on clothing or skin. bailer/pump into monitoring well X Electrical Heat/Cold 1b. Exposure to acid from 1b. Prior to lifting and carrying battery from GES vehicle to sample location, inspect the battery to ensure and purge water into appropriate Biological Pressure battery that is used to power that there is no visible sign of leaking acid. purge pump It is recommended that the battery is placed and carried to location in a carrying container that would JSA Control #: 032 Page 2 of 3 container at surface prevent acid from contacting sampling personnel and equipment. 1c. Cuts, pinch points 1c. Don leather gloves during the connection of the battery converter to the car battery. 1d. Hand injuries from 1d. Use cut resistant gloves when cutting polyethylene tubing to prevent hand injuries. Note: When using non- cutting polyethylene tubing Use a proper tool, a tubing cutter. intrinsically safe pumps within 35 and bailing string When cutting bailing string to attach to bailer, cut away from the body, not towards. feet of a vapor source, within the Wear Kevlar or similar cut resistant gloves. critical zone as defined by client- Use appropriate cutting tool, i.e. scissors, safety knife, etc. specific protocols, or when there 1e. Repetitive motion injury 1e. Take frequent breaks as needed to prevent fatigue to shoulder and arm muscles caused by bailing are noticeable gasoline vapor from bailing purge water water. odors, the atmosphere must be Be aware of the signs and symptoms of repetitive stress injuries and report all symptoms immediately. tested with a combustible gas 1f. Spill or release of 1f. Take care to minimize the splash/release of purged water. indicator so that it can be impacted water prior to If purging activity causes splashing, slow the bailing process to prevent the loss of water. determined if the atmosphere treatment (if required by contains less than 10% of the LEL. local regulations) 1g. Electrical shock hazard 1g. If using an energy source to power and electric pump, refer to the owner’s manual for correct setup procedures. When using a battery, make sure that the polarity is correct (i.e., positive to positive contact, etc.). If the connection is loose, repair or replace the cord. 1h. Slip, trip, fall on 1h. Set up the work area so that all of the cords and piping are in one area. This will help to minimize the cords/piping possibility of tripping. 1i. Back injuries 1i. Utilize proper lifting procedure (i.e., keep your back straight) when loading coolers and/or equipment back into truck. Bend down at the knees and lift with your legs rather than bending and lifting with your back. To avoid lifting heavy/awkward coolers, leave cooler on tailgate to load samples and ice into. Utilize material handling devices when possible to move equipment (i.e., lift gates, pallet jacks, dollies, etc.). If necessary, utilize a ramp for loading and unloading wheeled devices, ensuring the ramp is properly supported prior to use. Note: Tie a rope or line to the pump that can be used to raise and lower pump from the well. Do not lower or raise the pump by pulling on the electrical feeds. Note: No one should ever attempt to lift an object that weighs greater than 50 lbs. On-site edits:
D. Conduct Groundwater X Motion Gravity 1a. Exposure to site 1a. Refer to PPE required for B.1a. Sampling X Chemical Radiation contaminants 1. Insert disposable X Electrical Heat/Cold bailer/peristaltic pump into Biological Pressure monitoring well to collect water for sampling On-site edits:
2. Collect groundwater in sampling X Motion Gravity 2a. Pull out bailer/tubing 2a. Refer to PPE required for B.1a. container X Chemical Radiation from monitoring well Do not splash purged water on clothing or skin. Electrical Heat/Cold Pull out tubing carefully to avoid hitting the body or face. Biological Pressure 2b. Burns to the skin/eyes 2b. Avoid contact with preservatives. These are commonly corrosive and can burn the skin/eyes on contact. Kevlar and nitrile surgical gloves should be worn when opening a cooler and retrieving sample collection containers; sample preservative may have leaked from a container or multiple containers; sample preservatives consist of various types of acids that include HCL, HNO3, and H2SO4 – hand and skin protection is necessary. Flush skin/eyes with water if contact is made. Refer to the MSDS for more information.
Please ensure that all necessary JSAs associated with your work scope have been identified and reviewed. Form Revised 05/18/10 JSA Control #: 032 Page 3 of 3
2c. Cuts to the skin 2c. Wear Kevlar gloves under nitrile-surgical gloves when sampling and especially when handling broken glassware. Wear Kevlar gloves when using a blade to cut bailer twine. Cut away from the body, not towards. 2d. Contact with skin or 2d. Place bailer back into well when filling multiple collection containers. clothing Do not hold bailer under arm or between knees when switching to a new container. On-site edits:
E. Decontamination X Motion Gravity 1a. Exposure to 1a. Refer to PPE required for B.1a. 1. Soak/spray durable equipment X Chemical Radiation decontamination chemicals Avoid contact with all decontamination chemicals including Liquinox, Simple Green, Methanol, and to prevent cross-contamination Electrical Heat/Cold any other solvents used on sampling equipment. between multiple well locations; Biological Pressure properly store disposable equipment On-site edits:
F. Replace Well Cap and Cover X Motion Gravity 1a. Pinch points 1a. Refer to A.1a above. 1. Replace well cap and cover Chemical Radiation Electrical Heat/Cold Biological Pressure
On-site edits:
Please ensure that all necessary JSAs associated with your work scope have been identified and reviewed. Form Revised 05/18/10
JOB SAFETY ANALYSIS DATE 2/8/05, 3/8/05, 11/1/05, 8/14/06, 8/23/06, NEW PAGE 1 of 2 6/8/07, 9/15/08, 10/15/08, 7/7/09, X REVISED 12/18/09 JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) JSA # All Work Locations Sampling Hand Auger Use (Soil Sampling) 035
INITIATED / CHANGED BY POSITION / TITLE APPROVED BY POSITION / TITLE Michael Berzinsky Project Environmental Scientist Thomas Baylis, CIH Dir, HSSE
REQUIRED PERSONAL PROTECTIVE EQUIPMENT – Place an “X” next to the appropriate line item and expand on requirement as necessary. AIR PURIFYING RESPIRATOR HEARING PROTECTION X SAFETY SHOES steel-toed FACE SHIELD LIFELINE / HARNESS SUPPLIED RESPIRATOR X GLOVES nitrile; Kevlar; or nitrile coated knit X PPE CLOTHING highly visible clothing such OTHER GOGGLES as orange coveralls, reflective safety vest HARD HAT X SAFETY GLASSES REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT 1. Cones and flags 2. PID 3. 4. 5.
¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS A. Review “General Site Activities” JSA #028 B. Review Site Information 1a. Damage to underground 1a. Review any available site plans including as-builts, public Pertaining to Underground improvements and private mark outs. Improvements C. Use Hand Auger to Collect/Clear Soil 1. Hand clear surface soil with 1a. Subsurface utilities 1a. Ensure that the use of soft dig protocol creates a borehole spade shovel clearance that is at least 2 inches wider than the widest drilling tool. Always clear to at least 5’ depth outside the exclusion zone and to 8’ depth in the exclusion zone. 1b. Cuts to skin, eye injury 1b. Wear appropriate PPE (i.e., safety glasses, leather gloves, steel-toe shoes, highly visible clothing, and Level D attire). 1c. Back strain/overexertion 1c. When performing any type of physical labor be sure not to strain/stress your body. Take plenty of breaks to rest muscles and take in fluids. Note: If any evidence of peastone is observed during handclearing, drilling, excavation, or any subsurface activity, all subsurface work must stop and the project manager and/or the senior office manager must be contacted immediately. 2. Use hand auger to collect 2a. Contact with contaminants 2a. Wear appropriate PPE, whenever handling contaminated soil samples soils. This includes nitrile sampling gloves to prevent contact with the skin. Note: This tool can cause 2b. Back strain/overexertion 2b. While operating the hand auger, be aware that it is easy to damage to underground overexert yourself. structures so it should never Note: Be sure not to twist your upper body at the waist while be advanced with excessive using the auger. This motion can cause injury to your back. force! Use the strength in your upper arms to turn the hand auger. Add handle extensions as needed so that your back can If you cannot turn the hand remain straight and there is no need to bend your waist. auger easily, stop and move to Keep your feet shoulder width apart for stability. a new location. Keep your head away from the handle of the auger. Should this tool break loose during use you will avoid injury. Individuals who are not involved in the work activity should remain clear of the auger handle length plus 1 foot away from where the augering is occurring. 2c. Soil spills out of the bottom 2c. If this condition occurs, stop advancing the hand auger of the hand auger immediately! This may be a sign of fill material, indicating that an underground structure exists. 2d. Tripping on open 2d. Set up cones and flags to identify trip hazards associated boreholes and associated soil with boreholes/stockpile inside the work zone. stockpiles Complete or backfill an open borehole ASAP.
JOB SAFETY ANALYSIS JSA # - 035 Page 2 of 2
¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS Note: Prior to leaving the site, ensure all trip hazards associated with boreholes have been eliminated. 3. Sample and classify 3a. Contact with contaminated 3a. Scan soil samples with PID (NOT NOSE!!). impacted soil soils Bend down at the knees and lift with your legs rather than bending and lifting with your back; avoid twisting. Wear appropriate PPE to prevent contact with the skin including nitrile gloves and safety glasses. 3b. Cut/puncture from fill 3b. Wear cut-resistant gloves (i.e., nitrile coated knit gloves or material/soil Kevlar beneath nitrile exam gloves) when sampling soil and/or handling sampling glassware. A small shovel can be used to loosen compacted soil containing sharp debris. 3c. Cut/puncture from broken 3c. Wear cut-resistant gloves (i.e., nitrile coated knit gloves or glass Kevlar beneath nitrile exam gloves) when handling sampling glassware (especially OVA mason jars).
JOB SAFETY ANALYSIS DATE 2/11/10 X NEW PAGE 1 of 2 REVISED JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) JSA # All Work Locations Remediation Hydrogen Peroxide Test Kit Use (CHEMetrics) 125
INITIATED / CHANGED BY POSITION / TITLE APPROVED BY POSITION / TITLE Rich Evans, PE Reg Engrg Mgr - Mid-Atlantic Thomas Baylis, CIH Dir, HSSE
REQUIRED PERSONAL PROTECTIVE EQUIPMENT – Place an “X” next to the appropriate line item and expand on requirement as necessary. AIR PURIFYING RESPIRATOR X HEARING PROTECTION X SAFETY SHOES steel-toed FACE SHIELD LIFELINE / HARNESS SUPPLIED RESPIRATOR X GLOVES Kevlar; nitrile X PPE CLOTHING highly visible clothing such OTHER X GOGGLES if conducting injection event or if as orange coveralls, reflective safety vest well is anticipated to be under pressure X SAFETY GLASSES HARD HAT REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT 1. PID 2. Kneeling pads 3. Crowbar 4. 5.
¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS A. Review “General Site Activities” JSA #028 B. Review “Manhole Cover Removal/Vault Observation (Petroleum Products)” JSA #099 C. Locate and Open Onsite wells 1. Inspect and open wells 1a. Pinch points/abrasion 1a. Remove and replace manhole covers so that they do not pinch fingers. Use a crowbar as appropriate and wear Kevlar cut resistant gloves to prevent injuries to hands. Use kneeling pads when kneeling on hard surfaces. 1b. Back strain 1b. Utilize proper lifting procedure when removing covers. Bend down at the knees and lift with your legs rather than bending and/or lifting with your back. 1c. Shoulder strain resulting 1c. Always keep your wrist straight when using a wrench. from using a socket wrench to Be sure that the opening of the socket is in full contact with loosen and remove bolts from the bolt before you apply pressure. the lid Pull, don't push, and use a slow, steady motion. . If the bolt can not be loosened with normal force, use the correct breaking bar and do not place a piece of pipe on the end of the wrench to improve leverage. Protect yourself from losing your balance if the wrench slips or a bolt breaks. . Kneel on a solid surface with one foot planted firmly on the floor and don't lean into the work. Note: Never use hand sockets with power or impact wrenches. Replace sockets showing cracks or wear. D. Collect Groundwater Sample 1. Insert disposable bailer into 1a. Exposure to site 1a. Wear appropriate PPE (e.g., eye protection, long pants, injection/monitoring well to contaminants Kevalr cut resistant gloves under nitrile sampling gloves, shirt collect water for sampling with sleeves, steel-toed boots). 1b. Inhalation of organic 1b. If organic vapors are present, replace the well cap and do not vapors proceed until a PID is obtained to scan the atmosphere ensuring that concentrations are below 5 ppm. Note: Be aware that there may be elevated levels of gasoline or product vapors in the wells. 1c. Spill or release of impacted 1c. Take care to minimize the splash/release of water by slowly water prior to treatment (if bailing and maintaining the bailer in a vertical position; this required by local regulations) approach will prevent the loss of water. 2. Collect groundwater in 2a. Pull out bailer from 2a. Refer to PPE required for D.1a.
JOB SAFETY ANALYSIS JSA # - 125 Page 2 of 2
¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS sampling container monitoring well Do not splash purged water on clothing or skin. 2b. Cuts to the skin 2b. Wear Kevlar gloves when using a blade to cut bailer twine. The cutting tool that is used to cut the twine must have a self- retracting blade or a blade that is protected by a guard. NO pocket knives or utility knives are permitted. E. Hydrogen Peroxide Test Kit Use 1. Transfer sample from 1a. Exposure to site 1a. Refer to PPE required for D.1a. disposable bailer to epidorf contaminants (small plastic vial) 1b. Inhalation of organic 1b. If organic vapors are present, replace the well cap and do not vapors proceed until a PID is obtained to scan the atmosphere ensuring that concentrations are below 5 ppm. Note: Be aware that there may be elevated levels of gasoline or product vapors in the wells. 1c. Spill or release of impacted 1c. Take care to minimize the splash/release of water by tilting water prior to treatment (if the bailer only enough to initiate flow into the epidorf. required by local regulations) Since only a small amount of water is required, use a slow controlled pour by minimally tilting the bailer; this approach will prevent the loss of water. 2. Transfer sample from 2a. Exposure to site 2a. Refer to PPE required for D.1a. epidorf (small plastic vial) to contaminants glass ampule 2b. Cuts to the skin 2b. Wear Kevlar gloves under nitrile surgical gloves when handling glass ampule 3. Snap ampule in channel in 3a. Cuts to the skin 3a. Refer to PPE required for D.1a. plastic cylinder of deionized water
Job Safety Analysis (JSA) Page 1 of 2
JSA Title: Monitoring Well Development (Utilizing Waterra Pump or Submersible Pump (e.g., Whale Pump)) JSA Control #: 078 Date Developed: 2/1//05 Please complete the below if this JSA is being modified for SITE-SPECIFIC reasons. Latest Revised Date: 3/23/11 Date Form Completed: Work Location: Initiated/Changed by: Cris Altman This JSA has been fully reviewed with all staff members and all activity job steps, hazards, work practices, and PPE are clearly understood and have been implemented. All necessary revisions have been written on this JSA. Approved by: Thomas Baylis, CIH
REQUIRED PPE: Face Shield: if flying particles strike the operator in the face. Gloves: nitrile, leather. Hard Hat: if working in an area with low overhead clearance. Hearing Protection: if site activities raise the noise level to 85 dB. PPE Clothing: highly visible clothing such as orange coveralls or reflective safety vest; Tyvek suit if whole body contact is unavoidable. Safety Glasses. Safety Shoes: steel-toed. REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT: Sorbent sock or pillow; LEL meter; Hotwork Permit
Activity/Sequence of Job Tasks Energy or Biological What would be the result of Energy/Biological/Waste Management Plan List all tasks required to perform a Sources exposure to a biological or Eliminate – Control – Protect job in the sequence they are (Check all that apply) energy source? (e.g., slip, Risk Control Measures carried out. trip, fall, exposure, List control measures required to eliminate, control or protect against unwanted contact with an uncontrolled electrocution, injury, death, biological or energy source to minimize the risk of injury or environmental impact. Include identification of etc.). How, where, or ‘Stop Work’ triggers. when could an uncontrolled release or unwanted contact with a biological or energy source occur? Please ensure that all necessary JSAs associated with your work scope have been identified and reviewed. A. Locate and Open Onsite X Motion X Gravity 1a. Pinch points, 1a. Remove and replace manhole covers so that they do not pinch fingers. Wells X Chemical Radiation abrasion Wear leather gloves for this task. 1. Inspect and open wells Electrical Heat/Cold 1b. Back strain 1b. Utilize proper lifting procedure when removing covers. X Biological Pressure Bend down at the knees and lift with your legs rather than bending and lifting with your back.
On-site edits:
B. Well Development X Motion X Gravity 1a. Exposure to site 1a. Wear appropriate PPE (e.g., eye protection, long pants, leather palm gloves, shirt with sleeves, steel- 1. Setup pump and check valve, X Chemical Radiation contaminants toed boots). tubing, ring, and generator X Electrical Heat/Cold 1b. Slip, trip, fall 1b. Setup work area to minimize the amount of hoses and equipment positioned in walk ways. Biological 1c. Exposure to acid from 1c. Prior to lifting and carrying battery from GES vehicle to sample location, inspect the battery to ensure Pressure battery that is used to power that there is no visible sign of leaking acid. Note: When using non- purge pump It is recommended that the battery is placed and carried to location in a carrying container that would intrinsically safe pumps within prevent acid from contacting sampling personnel and equipment. 35 feet of a vapor source (i.e. 1d. Cuts, pinch points 1d. Don leather gloves during the connection of the battery converter to the car battery. whale pump for well 1e. Electrical shock hazard 1e. If using an energy source to power an electric pump, refer to the owner’s manual for correct setup development), within the procedures. critical zone as defined by The potential for spark generation should be considered when using alligator clips and powering off of client-specific protocols, or a battery. when there are noticeable Ensure that there is no LEL or harmful vapors in the area, prior to attaching the leads. gasoline vapor odors, the Hotwork Permit should be filled out as well. atmosphere must be tested Note: Tie a rope or line to the pump that can be used to raise and lower pump from the well. Do not with a combustible gas lower or raise the pump by pulling on the electrical feeds. When raising pump, raise by line and tubing at indicator so that it can be the same tine to ensure the tubing does not “kink” inside of the well and become stuck. determined if the atmosphere contains less than 10% of the JSA Control #: 078 Page 2 of 2
LEL.
On-site edits:
2. Operate generator, pump, and X Motion Gravity 2a. Repetitive motion 2a. Take frequent breaks as needed to prevent fatigue to shoulder and arm muscles caused by bailing flush well screen X Chemical Radiation operating pump water. X Electrical Heat/Cold Be aware of the signs and symptoms of repetitive stress injuries and report all symptoms immediately. Biological X Pressure 2b. Exposure from 2b. Wear additional PPE (e.g., Tyvek) and pace bailing actions. splashes during bailing activities 2c. Spill or release of 2c. Have spill pillows or socks available to contain any release or impacted water spill. impacted water On-site edits:
3. Remove piping from well X Motion X Gravity 3a. Exposure to 3a. Refer to B.1a. X Chemical Radiation contaminants Electrical Heat/Cold 3b. Back/muscle strain 3b. Refer to A.1b. Biological Pressure
On-site edits:
C. Decontamination Motion Gravity 1a. Exposure to 1a. Wear appropriate PPE (e.g., eye protection, long pants, nitrile sampling gloves, shirt with sleeves, 1. Soak/spray durable equipment X Chemical Radiation decontamination steel-toed boots). to prevent cross-contamination Electrical Heat/Cold chemicals Avoid contact with all decontamination chemicals including Liquinox, Simple Green, Methanol and any between multiple well locations; Biological Pressure other solvents used on sampling equipment. properly store disposable equipment On-site edits:
2. Replace well cap and cover X Motion X Gravity 2a. Pinch points 2a. Refer to A.1a. Chemical Radiation Electrical Heat/Cold Biological Pressure On-site edits:
Form Revised 06/10/10 Job Safety Analysis (JSA) Page 1 of 3
JSA Title: Operation and Maintenance (O&M) JSA Control #: 038 Date Developed: 3/8/05 Please complete the below if this JSA is being modified for SITE-SPECIFIC reasons. Latest Revised Date: 6/21/10 Date Form Completed: Work Location: Initiated/Changed by: Richard Evans, PE This JSA has been fully reviewed with all staff members and all activity job steps, hazards, work practices, and PPE are clearly understood and have been implemented. All necessary revisions have been written on this JSA. Approved by: Thomas Baylis, CIH
REQUIRED PPE: Gloves: leather, nitrile; Hard Hat: when overhead hazards are present or in areas of low overhead clearance; Hearing Protection: if any system components are operating because the sound levels inside the system enclosure will be above 85 dB; PPE Clothing: highly visible clothing such as orange coveralls or reflective safety vest; Safety Glasses; Safety Shoes: steel-toed REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT: Lockout/tagout kit; PID; CGI/O2 or LEL meter
Activity/Sequence of Job Tasks Energy or Biological What would be the result of Energy/Biological/Waste Management Plan List all tasks required to perform a Sources exposure to a biological or Eliminate – Control – Protect job in the sequence they are (Check all that apply) energy source? (e.g., slip, Risk Control Measures carried out. trip, fall, exposure, List control measures required to eliminate, control or protect against unwanted contact with an uncontrolled electrocution, injury, death, biological or energy source to minimize the risk of injury or environmental impact. Include identification of etc.). How, where, or ‘Stop Work’ triggers. when could an uncontrolled release or unwanted contact with a biological or energy source occur?
A. Unlock and Open System Motion Gravity 1a. Elevated levels of 1a. Perform atmospheric testing prior to entering the system enclosure. Enclosure/Compound X Chemical Radiation organic vapors and oxygen Notify the LHSO or CHSO if levels are outside of the limits listed below: 1. Sample atmosphere of Electrical Heat/Cold deficient/ enriched . Organic vapor limit for entry is <5 ppm (taken with a PID). enclosure Biological Pressure atmospheres . Oxygen level limits for entry are >19.5% and <23.5% (taken with a CGI/O2 or LEL meter). . Lower explosive limit is <10% (taken with LEL meter) Note: Visually inspect the exterior of system sheds for any potential hazardous conditions upon arrival and departure. On-site edits:
B. Perform O&M Activities X Motion Gravity 1a. Electrocution/contact 1a. Follow LO/TO procedures. 1. Lockout/tagout system Chemical Radiation with energized equipment Complete a LO/TO permit. components as needed X Electrical Heat/Cold Notify all affected personnel of the deenergized condition. Biological Pressure Use lock/tag combination or a tag alone if the energy source can not be physically locked out. Look for multiple switches which may return power to the component; lock each switch separately. On-site edits:
2. Review P&ID – look for Motion Gravity 2a. Equipment failure/ 2a. Check the P&ID for accuracy including CSDs, components, and piping. missing/mislabeled Critical Safety X Chemical Radiation potential release NOTE ANY DEFICIENCIES. Devices (CSDs) Electrical Heat/Cold Biological X Pressure JSA Control #: 038 Page 2 of 3
On-site edits:
3. Perform O&M activities X Motion X Gravity 3a. Exposure to site 3a. Wear appropriate PPE (eye protection, long pants, nitrile sampling gloves, hard hat, shirt with X Chemical Radiation contaminants sleeves, steel–toed boots.) Electrical Heat/Cold Comply with action levels stated in HASP Biological X Pressure Note: Be aware that there may be elevated levels of gasoline or product vapors in oil/water separators and other related system equipment. 3b. Air compressor 3b. Check all the components of the air compressor system. Make sure lines are securely connected. (pressurized lines) Make sure all belt guards are in place. Note: Be aware of elevated temperatures in piping and surfaces of compressed air systems, heed warning labels, and do not contact elevated temperature system elements without heat-resistant PPE (e.g., gloves rated for the temperature present). 3c. Back injury 3c. Utilize proper lifting procedure (keep your back straight) when loading coolers and/or equipment back into truck. Bend down at the knees and lift with your legs rather than bending and lifting with your back. Utilize material handling devices when possible to move equipment (i.e., lift gates, pallet jacks, dollies, etc.). If necessary, utilize a ramp for loading and unloading wheeled devices, ensuring the ramp is properly supported prior to use. Note: No one should ever attempt to lift an object that weighs greater than 50 lbs. 3d. Trips falls entering 3d. Use 3 point stance when entering or exiting raised equipment trailers, buildings, or field vehicles. remediation enclosures and Place items in elevated area first so hands are free for 3 point mount/dismount. vehicles 3e. Falls from improperly 3e. Comply with GES’ fall protection document (HSSE Policy #0015) (also discusses ladder safety) which using ladders includes but is not limited to the following. If using a ladder to access any elevated components, inspect the ladder prior to use ensuring the steps are free of debris, water, ice, etc. Inspect ladder components (e.g., rungs, rails, supports) to ensure they are secure and free of defect. Place ladder on level ground. Fall protection must be used at heights greater than 6 feet above ground when two handed work is needed. Maintain 3 points of contact. Extension and straight ladders must be tied off. Pitch ladder at a 4 to 1 ratio. Note: Never stand on top rung of ladder. On-site edits:
C. System Start-up X Motion Gravity 1a. Pinch points, cuts 1a. Never operate equipment without guards in place to prevent contact with moving parts. 1. Replace equipment guards, Chemical Radiation Wear work gloves (e.g., leather) while handling tools and sharp objects to prevent cuts to the skin. secure hose fittings Electrical Heat/Cold Biological X Pressure
On-site edits:
Please ensure that all necessary JSAs associated with your work scope have been identified and reviewed. Form Revised 05/18/10 JSA Control #: 038 Page 3 of 3
2. Remove lockout/tagout X Motion Gravity 2a. Electrocution/contact 2a. Follow LO/TO procedures. Chemical Radiation with energized equipment Notify all affected personnel of the energized condition. X Electrical Heat/Cold Ensure that all fail-safe devices are working properly prior to leaving site. Biological X Pressure 2b. Elevated noise 2b. Hearing protection should be worn if noise levels exceed 85 dBA as per this policy or if noise level is unknown (e.g., measurement device is not available or has not been pre-determined) that the use of hearing protection is recommended/required. On-site edits:
Please ensure that all necessary JSAs associated with your work scope have been identified and reviewed. Form Revised 05/18/10
JOB SAFETY ANALYSIS DATE 2/9/05, 3/9/05, 7/5/05, 9/14/05, 11/1/05, NEW PAGE 1 of 3 3/3/06, 5/8/07, 5/12/08, 10/24/08, X REVISED 12/18/08, 12/23/08; 2/13/09, 3/13/09, 6/23/09 JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) JSA # All Work Locations Assessment and Peroxide and Ozone Injection 044 Remediation DEVELOPMENT TEAM POSITION / TITLE REVIEWED BY POSITION / TITLE Eric Munz, CSP Regional HSSE Spec - NE Thomas Baylis, CIH Dir, HSSE Dan Germann Local HSO - NJ-C Keith Graver Hype Air Manager Dan Hughes IRSP Operator/Jr. Engineer Dave Kendall Corporate Jr. Engineer REQUIRED (use an “X”) & RECOMMENDED (use an “&”) PERSONAL PROTECTIVE EQUIPMENT – Place appropriate symbol on corresponding line(s) & AIR PURIFYING RESPIRATOR with acid & HEARING PROTECTION when noise levels X SAFETY SHOES steel-toed; protective mist cartridges exceed 85 dB overboots for spill clean-up & FACE SHIELD When mixing chemicals, LIFELINE / HARNESS SUPPLIED RESPIRATOR moving chemicals or service/repair to well X PPE CLOTHING highly visible clothing such & OTHER IMPERVIOUS CLOTHING - if spill heads & fittings that contain chemicals. as orange coveralls; reflective safety vest occurs, gloves and boots must be rubber, PVC, X GLOVES 11-mil nitrile X SAFETY GLASSES when not wearing or 11-mil nitrile gloves. In addition, have either X GOGGLES MANDATORY during all activities goggles or engaging in site operations a chemical resistant apron, chemical resistant conducted on site. oversleeves, rainsuit or a poly-coated Tyvek & HARD HAT suit REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT 1. Lockout/tagout kit 2. CGI/O2 meter 3. Ozone Meter 4. 5.
¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS A. Review “General Site Activities” JSA - #028 B. Set Up Note: No peroxide and ozone injection program is permitted until the “GES General Guidelines and Information for Performing Hype Air Events” Protocol is reviewed and understood by all project staff. NOTE: Before starting any set The GES regional engineer should be contacted immediately if there are any questions or issues up, everyone on site must regarding the injection event. inspect each well to be used for injection to verify well WARNING: If injecting ozone, peroxide, persulfate, or any combination of chemicals into a construction. well constructed of PVC, a plexiglass well head restraining system MUST be used to add another level of safety as an added precaution during the injection event. Corporate Engineering MUST also be notified. 1. Set up injection system on 1a. Back strains 1a. Bend down at the knees and lift with your legs rather than hypeair platforms/well head bending and lifting with your back. assemblies including any with 1b. Pinch point hazard 1b. Wear 11-mil nitrile gloves for this activity. Keep fingers out engineering controls/peroxide- from under manways to avoid pinching. ozone-persulfate lines/mixing 1c. Slips, trips & falls 1c. Make sure all hoses and lines are positioned about the work and/or holding tanks area to avoid tripping hazards. Keep work area clean and tools picked up. 1d. Well head/Injection line/air 1d. Make sure all injection lines and well head assemblies have or ozone line failure during whip checks in place and that all available engineering controls event have been utilized. 2. Transfer of hydrogen 2a. Back injury from improper 2a. When moving hydrogen peroxide drums from one location to peroxide drums from one lifting and possible spills another, ensure that the proper drum cart is utilized. location to another Prior to moving/opening hydrogen peroxide drums, check for bulging of drum to assure drum is not under pressure. WARNING: Avoid contact to Drums MUST have at least one self-venting bung. cotton, wool, and leather with Inspect drum cart prior to moving any drums. hydrogen peroxide. Wear face shield while moving drums. 2b. Site-Specific Hazards 2b. Ensure the forks are positioned under the drum and that any other connections are secure. Use rachet straps if terrain is uneven. Utilize two people when terrain is uneven (grass, mud, snow, gravel, etc.). Utilize plywood to even out terrain. Evaluate the use of safer pathways. 3. Inject high pressure air to 3a. Air compressor (vehicle 3a. Check all the components of the air compressor system. open well screen and sand mounted air compressor) Make sure lines are securely connected and whip checks are
JOB SAFETY ANALYSIS Page 2 of 3
¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS pack (pressurized lines) in place. Make sure all belt guards are in place. If using a Vehicle Mounted Air Compressor, make sure the truck hood is down. Truck hood can be popped open to allow for better air circulation and cooling of engine compartment. 3b. Elevated noise (generator Make sure all fittings are secure. and/or VMAC compressor) 3b. Wear hearing protection while the air compressor is operating if working near this equipment creates noise levels above 85 dB. 4. Transfer water and/or 4a. Exposure to hydrogen 4a. Wear appropriate PPE (i.e., eye protection [goggles], steel- hydrogen peroxide, from peroxide toed boots, long pants, 11-mil nitrile gloves, hard hat [if holding tank or other source overhead obstacles are present]). If upgrade is necessary, into HypeAir platform chemical resistant apron/oversleeves, rainsuit, or poly-coated mixing/injection tank; mix Tyvek suit is required. hydrogen peroxide for injection Wear face shield while transferring chemicals. and/or start ozone generator 4b. Exposure to spilled 4b. Rubber booties or rubber over boots, chemical resistant material during a spill clean-up apron/oversleeves, rainsuit, or poly-coated Tyvek suit are WARNING: When working necessary for spill clean-up. All hydrogen peroxide handling with pressurized lines, must be completed in accordance with the Material Safety Data manifolds or well head Sheet (MSDS). assemblies, make sure the 4c. Leaking pipe/fittings; 4c. Check lines for leaks during transfer of peroxide into pressure has been released contact with hydrogen peroxide holding/ mixing tank. If any leaks are detected stop and make prior to performing any work the necessary repairs prior to continuing. on them. If the formation is If service or repair is needed, verify pressure has been tight and the pressure is slow released prior to working on particular piece of equipment. to release, allow sufficient time Never isolate chemicals between two closed valves, thus for the pressure to drop. preventing pressure build up. Wear face shield while making necessary repairs. WARNING: If onsite and staff 4d. Hydrogen peroxide release 4d. Before transferring hydrogen peroxide drums to holding notice a pungent odor, the to ground tanks that have bottom mounted drains, have a 5-gallon bucket ozone generator must be shut filled half way with water and place under holding tank gravity down and the area properly drain line (located under truck) to capture peroxide in case of an ventilated. If these activities open valve or leak. occur, the generator and lines Note: If using skid-mounted HypeAir units or trucks in must be re-inspected. In conjunction with drop trailers, close water and hydrogen addition, if any eye or peroxide fill port valves to prevent gravity feed of chemical into respiratory system irritation tank and possible overfill and/or overflow. occurs, GES’ regional engineer 4e Leaking pipe/fittings; 4e. Make sure all guards are on ozone generator prior to and director of engineering release of ozone starting. must be contacted to Wear 11-mil nitrile gloves for this activity. determine if other actions are All ozone lines must be checked for leaks during the initial warranted. start-up of the ozone generator. This can be accomplished safely without using ozone. After starting the ozone generator, select oxygen only and begin to inject with compressed air. Listen for severe leaks or spray soapy 4f. Property damage overhead water on fittings and check for the presence of air bubbles. 4f. During install of drop tube and packers, watch for overhead 4g. Pinch points obstacles and wear a hard hat. 4g. Keep fingers out from under man ways to avoid pinching and wear gloves while opening wells. 5. Injection of hydrogen 5a. Exposure to chemicals 5a. Only employees trained to operate the injection system peroxide and/or ozone are permitted to operate the equipment. Wear required PPE while on site or near injection lines. REVIEW the MSDS and all action levels in the HASP for hydrogen peroxide and ozone with all staff on site. Have proper PPE available for upgrade to Level C for hydrogen peroxide. 5b. Oxygen enriched/deficient 5b. Monitor breathing zone during operation of equipment and atmospheres, flammable the injection with an oxygen or ozone meter if applicable. atmosphere Oxygen levels are required to be >19.5% and <23.5%. LEL levels measured by a calibrated combustible gas
JOB SAFETY ANALYSIS Page 3 of 3
¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS indicator are <25% of the LEL. If oxygen levels outside the well casings exceed 23.5% and/ or LEL levels exceed 25%, the system should be shut down. The GES regional engineer must be contacted so that the appropriate action is taken. Post no smoking signs and keep all sources of ignition away from oxidizing agents/chemicals. 5c. High pressured lines during 5c. Prior to initiating injection make sure all fittings and lines are injection secure and tight and whip checks are in place. Wear 11-mil nitrile for this activity. Monitor pressure of lines during operation/injection. If service or repair is needed, verify pressure has been released prior to working on particular piece of equipment. Never isolate chemicals between two closed valves, thus preventing pressure build up. 5d. Slips, trips, falls 5d. Make sure all hose and lines are positioned about the work area to avoid tripping hazards. Keep work area clean and tools picked up. 6. If service or repairs are 6a. Electrocution 6a. Follow all LO/TO procedures if servicing or repairs must be needed made. 6b. Exposure to chemicals 6b. When repairing feed lines that contain process chemicals, wear appropriate PPE. Refer to B.4a above for specific PPE needed. If upgrade is necessary, refer to B.4b above for specific PPE needed. Upgrade to face shield while making necessary repairs. 6c. High pressure (stored in 6c. Check pressure and ensure that the pressure has been system) released prior to opening/removing any fittings, lines, wellheads, drains, etc. Never isolate chemicals between two closed valves, thus preventing pressure build up. 6d. Pinch point hazard 6d. Wear 11-mil nitrile for this activity since item to be repaired could contain chemicals. C. Complete Injection 1. Thoroughly rinse injection 1a. Slips, trips, falls, cuts 1a. Keep area clean, tools picked up, and pay attention to areas lines, pumps, well packers, in the work space where lines will be temporarily stored during mixing tank, and any equipment pick up. miscellaneous equipment 1b. Back strains 1b. Bend down at the knees and lift with your legs rather than bending and lifting with your back when pulling equipment from well. 1c. Hand contact with H2O2 1c. Wear 11-mil nitrile for this activity. Note: It is recommended that a minimum of 200 to 500 gallons of additional water should be available onsite for rinse or emergency use. The water would be used whenever there is a hydrogen peroxide release or whenever peroxide contacts unprotected surfaces. 1d. Eye contact with H2O2 1d. As required, wear chemical splash goggles for this activity. 1e. Release of chemicals to 1e. Use emergency rinse water on site to fully dilute the surface surface via preferential release. pathways (i.e., including but not limited to cracks in concrete, asphalt, well pack, vaults, etc.)
WORK ACTIVITY (Description) — Peroxide and Ozone Injection JSA - #044
Job Safety Analysis (JSA) Page 1 of 2
JSA Title: Portable Generator Use JSA Control #: 053 Date Developed: 2/9/05 Please complete the below if this JSA is being modified for SITE-SPECIFIC reasons. Latest Revised Date: 6/30/10 Date Form Completed: Work Location: Initiated/Changed by: Steven Mendez This JSA has been fully reviewed with all staff members and all activity job steps, hazards, work practices, and PPE are clearly understood and have been implemented. All necessary revisions have been written on this JSA. Approved by: Thomas Baylis, CIH
REQUIRED PPE: Gloves: nitrile, leather; Hard Hat: if working in an area with low overhead clearance; Hearing Protection: if site activities raise the noise level to 85 dB; PPE Clothing: highly visible clothing such as orange coveralls or reflective safety vest; Safety Glasses; Safety Shoes: steel-toed REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT: Sorbent pads; Funnel; Ground falult circuit interruptor (GFCI)
Activity/Sequence of Job Tasks Energy or Biological What would be the result of Energy/Biological/Waste Management Plan List all tasks required to perform a Sources exposure to a biological or Eliminate – Control – Protect job in the sequence they are (Check all that apply) energy source? (e.g., slip, Risk Control Measures carried out. trip, fall, exposure, List control measures required to eliminate, control or protect against unwanted contact with an uncontrolled electrocution, injury, death, biological or energy source to minimize the risk of injury or environmental impact. Include identification of etc.). How, where, or ‘Stop Work’ triggers. when could an uncontrolled release or unwanted contact with a biological or energy source occur? Please ensure that all necessary JSAs associated with your work scope have been identified and reviewed. A. Transporting Generator X Motion X Gravity 1a. Damage to the 1a. Ensure that individuals read and understand the manufacturer’s specifications and operations manual 1. Place the generator into vehicle Chemical Radiation generator which could result and understand the requirements for proper transportation and handling. Electrical Heat/Cold in improper operation Never transport the generator in the passenger area of a vehicle. Biological Pressure 1b. Muscle/back strain 1b. Lift with your legs and not your back while handling the equipment. Wear PPE including leather gloves when handling the generator. 1c. Slip/trip/tall 1c. Look for changes in elevation, grade, and surface cover when manually transporting generator. Use two people when necessary to manually transport generator. On-site edits:
B. Using the Generator Motion X Gravity 1a. Muscle/back strain 1a. Lift with your legs and not your back while handling the equipment. 1. Remove the generator from the Chemical Radiation Wear PPE including leather gloves when handling the generator. vehicle Electrical Heat/Cold Biological Pressure
On-site edits:
2. Set up generator Motion Gravity 2a. Shock/electrocution 2a. Insure the portable generator is located on the ground. Chemical Radiation Verify that the grounding wire has been attached and is secured to either the generator frame (if Note: Always refer to the X Electrical Heat/Cold applicable) or the vehicle frame if not removing generator from the truck. generator manufacturer and local Biological Pressure Place the generator in a well vented area away from flammable objects. requirements for proper operation Place generator away from areas where exhaust vapors can accumulate (i.e. in a pickup truck bed or and use including grounding and cargo van compartment). bonding. Have a fire extinguisher readily available within 10 feet of the portable generator. Note: Portable generator can not stay or be mounted within the truck unless proper grounding and JSA Control #: 053 Page 2 of 2
bonding are performed. On-site edits:
3. Plugging tools/equipment into Motion Gravity 3a. Shock/electrocution 3a. Start the generator and allow it to warm up. the generator Chemical Radiation When using hand operated tools and using the 120 volt, 15 or 20 amp receptacles, a GFCI is required X Electrical Heat/Cold to be in line. Note: Always refer to the Biological Pressure Other electric operated equipment using greater than 120 volt receptacles do not require GFCI, but generator manufacturer and local need to be grounded. requirements for proper operation and use. On-site edits:
D. Fueling Generator Motion Gravity 1a. Fire/explosion 1a. Keep operation area well-vented (i.e., outdoors). 1. Prepare area for fueling process X Chemical Radiation Keep generator at least 3 feet away from any object. Electrical Heat/Cold Do not place flammable objects near generator. Biological X Pressure Do not use generator in an environment where flammable vapors are present. Note: Check location/inspect all fire extinguishers. Have fire extinguisher readily available within 10 feet. On-site edits:
2. Remove gas tank cap on the Motion Gravity 2a. Exposure to fuel and 2a. Don appropriate PPE (i.e., nitrile gloves). generator; carry refueling X Chemical Radiation vapors Store fuel in approved container (i.e., metal can with self-closing spring lid). container to refueling area Electrical Heat/Cold Store fuel in a well vented area free of open flames or sparks. Biological Pressure
On-site edits:
3. Fill generator fuel tank X Motion X Gravity 3a. Exposure to fuel and 3a. Don appropriate PPE (nitrile gloves). X Chemical Radiation vapors Use a funnel to minimize the chance of spilling fuel. Electrical Heat/Cold Fill fuel tank in well ventilated areas. Biological Pressure 3b. Exertion from lifting 3b. Lift with your legs not your back while refueling the generator. refueling container 3c. Fire/explosion 3c. Ensure all ignition sources are removed form the refueling area. Never refuel a “hot” generator; let it cool first. Refuel in a well vented area (i.e., outdoors). Do not refuel while engine is running. Unhook all electrical loads. Do not overfill tank. Fuel can overflow causing a release of product onto the ground and increase the chance of a fire or explosion. If fuel spills, use sorbent pads to wipe the area and make sure area is dry before starting engine. On-site edits:
Form Revised 06/10/10
JOB SAFETY ANALYSIS DATE 2/9/05, 3/10/05, 6/16/06 NEW PAGE 1 of 1 X REVISED JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) JSA # All Work Locations Assessment and Pressure Washer Use 048 Remediation DEVELOPMENT TEAM POSITION / TITLE REVIEWED BY POSITION / TITLE Thomas Baylis, CIH Dir, HSSE Eric Munz, ASP NE Corp H&S Spec Dan Germann Local HSO - NJ
REQUIRED (use an “X”) & RECOMMENDED (use an “&”) PERSONAL PROTECTIVE EQUIPMENT – Place appropriate symbol on corresponding line(s) AIR PURIFYING RESPIRATOR X HEARING PROTECTION X SAFETY SHOES steel-toed X FACE SHIELD LIFELINE / HARNESS SUPPLIED RESPIRATOR X GLOVES nitrile/leather X PPE CLOTHING highly visible clothing such & OTHER RESPIRATOR - may be required if GOGGLES as orange coveralls, reflective safety vest conditions or work area air quality exceeds & HARD HAT X SAFETY GLASSES applicable HASP action levels; BOOTIES; GLOVES - thermal protective REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT 1. 2. 3. 4. 5.
¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS A. Review “General Site Activities” JSA - #028 B. Use Pressure Washer 1. Operation 1a. Pinch points, abrasion 1a. Comply with manufacturer requirements for operation. Wear leather or other work gloves to prevent hand injuries. 1b. High pressure/elevated 1b. Keep hands and clothing arms length away from rotating noise machinery, inlet, and discharge openings to the washer. Wear hearing protection. Avoid contact with compressor casing and associated piping; may cause major skin burns on contact. Do not reach into any opening in the compressor while it is operating; ensure guards are in place on external moving parts prior to start-up. All hoses and fittings should be inspected prior to use – Defective equipment must be repaired or replaced prior to use. Test any emergency cut-off switches for operation. 1c. Hot surfaces - burns to 1c. Do not sit on or touch the pressure washer during operation. the skin Thermal protective gloves must be worn if there is a need to contact hot machinery parts. Do not hold equipment being cleaned. Always work so steam and high pressure spray is directed away from the body. High pressure spray can also cause bruises and other skin injuries. 1d. Splash concerns/ 1d. Wear appropriate PPE (i.e., eye protection/glasses and a exposure to site face shield, hearing protection, long pants, leather work gloves contaminants with a nitrile outer layer, shirt with sleeves, steel-toed shoes). Review and understand action levels noted in the HASP. Note: Wear outer boot covers if water is splashed during the pressure washer use. Note: A face shield must be worn in addition to safety glasses to prevent water from splashing onto the face of the operator. Note: When “de-pressurizing” wand, be sure to maintain control, using both hands and face nozzle away from workers. 1e. Overhead lines 1e. Maintain a working distance of at least 10 feet from an energized overhead power line. For other overhead lines such as telephone or cable lines, if there is a potential of contacting and/or damaging the lines, the appropriate service company should be contacted so that the lines can be relocated or protected.
JOB SAFETY ANALYSIS DATE 9/30/05, 3/24/06, 4/14/06, 8/13/07, NEW PAGE 1 of 2 3/4/08, 10/24/08, 2/11/10 X REVISED JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) JSA # All Work Locations Various Private Markout/Site Survey 049
INITIATED / CHANGED BY POSITION / TITLE APPROVED BY POSITION / TITLE Julius Pachy Reg HSSE Spec - MW Thomas Baylis, CIH Dir, HSSE
REQUIRED PERSONAL PROTECTIVE EQUIPMENT – Place an “X” next to the appropriate line item and expand on requirement as necessary. AIR PURIFYING RESPIRATOR HEARING PROTECTION X SAFETY SHOES steel-toed FACE SHIELD LIFELINE / HARNESS SUPPLIED RESPIRATOR X GLOVES leather; nitrile; or equivalent X PPE CLOTHING highly visible clothing such OTHER GOGGLES as orange coveralls, reflective safety vest X HARD HAT when overhead hazards are X SAFETY GLASSES present REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT 1. Flagging tape 2. Traffic control 3. Lockout/tagout kit 4. Paint spray and wand 5. (barricades, cones, flags, caution tape)
¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS A. Review “General Site Activities” JSA #028 B. Markout/Survey 1. Drive to site and park 1a. Contact with traffic, 1a. Drive defensively following GES safe driving policy; obey all vehicle. pedestrians, and obstacles traffic laws. 1b. Contact, parking vehicles, 1b. Park in designated parking area. traffic flow/ control 2. Check in with property 2a. Contact with site traffic 2a. Don traffic safety gear immediately. owner/station manager and Inform property owner/station manager of your presence on conduct tailgate safety meeting site. 3. Site walk and evaluation of 3a. Contact with site traffic 3a. Don PPE (listed above). conditions/site features, locate points to be marked out 4. Set up site control and 4a. Contact with traffic while 4a. Set up traffic control (e.g., cones/barricades) as needed. control points setting up control points 4b. Exertion carrying 4b. Utilize proper lifting techniques when loading and unloading equipment vehicle. Bend down at the knees and lift with your legs rather than bending and lifting with your back. 4c Pinch point when placing 4c. Wear leather or equivalent gloves when handling barricades barricades and avoid pinch point area 4d. Exposure to the elements 4d. Dress appropriately for ambient temperatures, drink plenty of fluids. Note: Do not twist while lifting. This can cause a severe back injury. 5. Open roadbox to prepare for 5a. Skin abrasion 5a. Don leather (or similar) gloves to prevent a skin injury while TOC reading handling tools and opening the roadbox. Use J-hook to remove lid. Keep fingers and body parts from “line of fire” pinch points. 5b. Strains from opening/ 5b. Use proper body positioning when removing roadbox or removing roadbox or manway manway covers. covers Do not lift manway covers; they can weigh over 50 lbs. Kneel down, back straight, firm grip, pull lid towards you. 6. Markout points 6a. Contact with traffic 6a. Constantly scan for vehicles. Set up traffic control (e.g., cones, barricades) as needed. Limit time spent in areas where lines of sight for oncoming traffic are limited. Use a spotter in high traffic areas. 6b. Slip, trip, and fall when 6b. Check thick vegetation for tripping hazards and debris. moving through thick Look for the safest route to a point before proceeding and vegetation proceed with caution.
JOB SAFETY ANALYSIS JSA # - 049 Page 2 of 2
¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS 7. Direct connect method or 7a. Electrocution 7a. Locate source of electricity of line being located and de- induction method using clamp; contact with energized lines energize lines by using lockout/tagout procedures. induction method using drop 7b. Traffic which includes 7b. Wear highly visible clothing such as orange reflective traffic box technique; tracing utilities; being struck by pedestrian or vests or clothing. marking lines on ground to other vehicles indicate utilities 7c. Paint overspray 7c. Use paint wand to apply paint.
8. If needed, expose metal 8a. Electrocution 8a. Comply with requirements indicated in 7a above. wiring. 8b. Potential cut or abrasion 8b. Leather or equivalent work gloves must be worn to provide from the tool used to expose hand protection. wire Sand paper or similar tool should be used. If a cutting tool is used, the “Cutting Tool Use” JSA # 015 must be reviewed. NOTE: The use of utility knives and pocket knives (e.g., stanley knives, box cutters) are STRICTLY PROHIBITED.
JOB SAFETY ANALYSIS DATE 7/6/05, 9/23/05, 6/16/06, 9/26/06, NEW PAGE 1 of 3 11/16/09, 1/18/10 X REVISED JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) JSA # All Work Locations Assessment and Remediation Remediation System Installation and System 054 Piping Leak Check
INITIATED / CHANGED BY POSITION / TITLE APPROVED BY POSITION / TITLE Lydia Ross Associate Engineer Thomas Baylis, CIH Dir, HSSE
REQUIRED PERSONAL PROTECTIVE EQUIPMENT – Place an “X” next to the appropriate line item and expand on requirement as necessary. AIR PURIFYING RESPIRATOR X HEARING PROTECTION X SAFETY SHOES steel-toed X FACE SHIELD within 10' of pressurized lines LIFELINE / HARNESS SUPPLIED RESPIRATOR during leak check activities X PPE CLOTHING highly visible clothing such X OTHER RESPIRATORS - may be required if X GLOVES leather; nitrile; Kevlar (cutting as orange coveralls, reflective safety vest conditions or work area air quality exceeds activities) X SAFETY GLASSES applicable HASP action levels GOGGLES X HARD HAT REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT 1. Lockout/tagout kit 2. PID 3. LEL meter 4. Hotwork Permit 5. Small shovel 6. System piping
¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS A. Review “General Site Activities” JSA #028 B. Review “Excavation Activities” JSA - #024 When Performing System Installation 1. Mobilize to trench/ 1a. Contact, caught, fall by 1a. Check excavation locations for underground and overhead excavation location uneven surfaces, pinch points, utilities. Follow GES’ Excavation Protocol or client-specific and contact with objects on protocol. site Observe equipment set up, ensuring no contact with overhead obstacles. Proper equipment set up and leveling. Remind everyone never to leave hand tools on/near equipment. C. Working in a Trench/ Excavation 1. Activities involving workers 1a. Engulfment, entrapment, 1a. Access to the trench/excavation shall be restricted if deeper in or in the vicinity of open falls into excavation than 4 feet. trenches If workscope requires personnel to enter a trench/excavation greater than 4 feet, specific approval must be obtained from corporate H&S prior to initiating field activities. Corporate H&S will verify that appropriate protective equipment will be installed (i.e., trench box, appropriate benching/sloping angles, etc.) to prevent a collapse of soil and to meet OSHA requirements. Under no circumstances will a GES employee and/or subcontractor be allowed to enter an excavation greater than 4 feet in depth without prior corporate H&S approval. Keep all tools, equipment, and personnel at least 2 feet from the edge of an open trench/excavation. Ladders shall be placed in the trench/excavation if the trench/excavation is 4 feet deep. These shall be arranged so that no point in the excavation is greater than 25 feet away from one ladder. Ladders shall be pitched at a 4:1 ratio. 1b. Trench collapse 1b. No personnel shall be permitted to enter a trench/ excavation with the presence of standing water/product at the bottom. Constantly monitor for the signs of weakening sidewalls. Evacuate the area if an unstable condition develops. D. Installing Remediation Equipment
JOB SAFETY ANALYSIS JSA # - 054 Page 2 of 3
¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS 1. Installation of remediation 1a. Exposure to site 1a. Monitor (evaluate) breathing zone of workers with PID. equipment (pipe install) contaminants Monitor (evaluate) any enclosure with a PID as specified in the HASP. Ensure that Level C PPE is available for potential upgrade or evacuate/ventilate the space if concentrations exceed those posted in the HASP. Note: Be aware that there may be elevated levels of gasoline or product vapors when impacted soil and groundwater is encountered or when the work space is located down-wind from a vapor source (i.e., an operating pump island). Be aware of other vapors associated with chemicals used during equipment install. Note: Monitor the deepest points in the trench/excavation for the presence of hazardous vapors. Refer to C.1 above for site control requirements. 1b. Exertion (back injury) from 1b. Use proper techniques when lifting piping; bend at your lifting knees, keep your back straight, and lift with your legs. When carrying an object, hold it close to your body. Never attempt to lift or carry an equipment or material heavier than 45 lbs. Obtain assistance or use a mechanical lifting device. 1c. Cuts to skin 1c. While cutting pipe use a stable surface (i.e., work bench, vice, etc.) DO NOT STEADY THE PIPE AGAINST ANY PART OF YOUR BODY! Wear cut resistant gloves. 2. Place and glue piping and 2a. Exposure to adhesives 2a. Have MSDS available and comply with MSDS requirements fittings together for any chemical used during pipe install (i.e., adhesive and glue used to connect pipes and fittings). Wear appropriate cut and chemical resistant gloves. 2b. Exposure to organic 2b. Monitor breathing zone as specified in D1a. vapors 3. System (remediation system 3a. System component failure 3a. Check applicable testing SOP. piping) leak check (system For PVC, maximum pressure is 5 psi. For other types of pressurized to no more than 5 high pressure pipes (i.e., ABS/Chemair) check pipe psi) manufactures maximum pressure rating. Ensure that all system connections and caps are connected and glued together and the minimum drying time is met. Use pressure rated seals and couplings. All hose connections are secured. Test emergency cut-off switches and develop mechanism for depressurizing lines. Evaluate potential use of other protective temporary shielding (i.e., plywood, tarps, other materials) of in-trench or aboveground. 3b. Contact pipe failure from 3b. Level D PPE and a face shield must be worn when within 10 high pressure feet of any pressurized lines during leak check activities. Never place any body part in a position that could be contacted by system components if a failure occurs. E. Wire System Components 1. Working with electrical 1a. Contact with energized 1a. Always use LO/TO when working on electrical components. components lines Deenergize the system whenever possible. 1b. Contact with overhead 1b. If an overhead hazard exists, don a hard hat (i.e., when Note: Consult a licensed obstructions working above your head). electrician for a detailed Note: If power tools are used refer to the “Cutting Tool Use” hazard assessment. JSA #015. F. Ladders and Boom Trucks 1. Using ladders and boom 1a. Falls from improperly using 1a. Comply with GES’ Fall Protection document (also discusses trucks ladders ladder safety) which includes but is not limited to the following. If using a ladder to access any elevated components inspect Note: Review GES’ “Fall the ladder prior to use ensuring steps are free of debris, Protection” document prior to water, ice, etc. using a ladder for any task. Inspect rungs to ensure they are secure and free of cracks.
JOB SAFETY ANALYSIS JSA # - 054 Page 3 of 3
¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS Place ladder on level ground. Fall protection must be used at heights greater than 6 feet above ground when two handed work is needed. Maintain 3 points of contact. Extension and straight ladders must be tied off. Pitch ladder at a 4 to 1 ratio. Note: Never stand on top rung of ladder. 1b. Falls, when using a cherry 1b. If using a boom truck with a cage guard, you must use a picker/boom truck body harness. Make sure cage is free of debris, sediment, water, ice, etc. 1c. Head injuries from 1c. Wear hard hats when performing this activity. potential overhead hazards
Job Safety Analysis (JSA) Page 1 of 3
JSA Title: Remediation System Equipment and Removal and Installation JSA Control #: 055 Date Developed: 1/12/06 Please complete the below if this JSA is being modified for SITE-SPECIFIC reasons. Latest Revised Date: 5/11/10 Date Form Completed: Work Location: Initiated/Changed by: Darrell Interess This JSA has been fully reviewed with all staff members and all activity job steps, hazards, work practices, and PPE are clearly understood and have been implemented. All necessary revisions have been written on this JSA. Approved by: Thomas Baylis, CIH
REQUIRED PPE: Gloves: nitrile, Kevlar, leather; Hard Hat: if working in an area with low overhead clearance; Hearing Protection: if site activities raise the noise level to 85 dB; PPE Clothing: highly visible clothing such as orange coveralls or reflective safety vest; Safety Glasses; Safety Shoes: steel-toed REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT: Lockout/tagout kit
Activity/Sequence of Job Tasks Energy or Biological What would be the result of Energy/Biological/Waste Management Plan List all tasks required to perform a Sources exposure to a biological or Eliminate – Control – Protect job in the sequence they are (Check all that apply) energy source? (e.g., slip, Risk Control Measures carried out. trip, fall, exposure, List control measures required to eliminate, control or protect against unwanted contact with an uncontrolled electrocution, injury, death, biological or energy source to minimize the risk of injury or environmental impact. Include identification of etc.). How, where, or ‘Stop Work’ triggers. when could an uncontrolled release or unwanted contact with a biological or energy source occur? Please ensure that all necessary JSAs associated with your work scope have been identified and reviewed. A. Load Materials for Work X Motion X Gravity 1a. Exertion/back strain 1a. Utilize proper lifting technique (i.e., bend at your knees and keep your back straight and carry the Activity Chemical Radiation object close to your body) use 2 people to lift/move over 45 lbs. 1. Loading materials Electrical Heat/Cold 1b. Loose equipment/ 1b. Secure all equipment and materials in bed of truck prior to departure using tie down straps. Biological Pressure materials
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B. Mobilize to Site Motion X Gravity 1a. Driving 1a. Follow GES safe driving program; plan route to and from site location prior to departure. 1. Proceeding to site Chemical Radiation 1b. Weather conditions 1b. Allow sufficient travel time when adverse weather conditions are a factor. Electrical Heat/Cold Biological Pressure
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C. Assess Area and Equipment Motion X Gravity 1a. Contact with energized 1a. Ensure all electric power lines have been de-energized and LO/TO out prior to start of to be Removed or Installed X Chemical Radiation lines removal/breakdown and/or installation of equipment. 1. Assessing area and equipment X Electrical X Heat/Cold 1b. Slips, trips, and falls 1b. Walk path of travel prior to starting removal of equipment for uneven terrain and trip hazards. Biological X Pressure Clear path of snow, ice, debris, etc. Keep equipment and tools in designated area out of path of travel. 1c. Exposure to weather 1c. Recognize signs/symptoms of heat/cold stress. and insects Dress appropriately. Take breaks as needed. Understand action levels in site-specific HASP. JSA Control #: 055 Page 2 of 3
Inspect shed for bees’ nests; have spray available if needed.
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D. Load/Unload Equipment X Motion X Gravity 1a. Contact with/pinch 1a. Wear appropriate PPE (e.g., leather gloves). 1. Load and unload equipment Chemical Radiation points Electrical Heat/Cold 1b. Back strain 1b. Utilize proper bending and lifting technique, bend at your knees and keep or hug the load close to Biological Pressure body. Use 2 people to lift/move equipment over 45 lbs. 1c. Slip, trip, and fall 1c. Have vehicle as close to remedial shed as possible to minimize travel while carrying equipment. On-site edits:
E. Wire System Components Motion X Gravity 1a. Contact with energized 1a. Always use LO/TO when working on electrical components. 1. Working with electrical Chemical Radiation lines De-energize the system whenever possible. components X Electrical Heat/Cold 1b. Head injury 1b. If an overhead hazard exists, don a hard hat (i.e. when working above your head). X Pressure Biological Note: Consult a licensed electrician for a detailed hazard assessment. Note: Be aware of overhead utilities. Maintain a minimum of 10 foot distance.
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2. Connecting and energizing X Motion Gravity 2a. Personal injury due to 2a. De-energize the system whenever possible. equipment and electrical Chemical Radiation contact with energized Prior to energizing circuit, determine the level of personal protection equipment needed and approach components X Electrical Heat/Cold components or arcing/ distances for arc flash safety, and don necessary PPE. Biological Pressure sparking Verify electrical connections are tightened per manufacturer's specifications. 2b. Equipment damage 2b. Verify with a multi-meter that control devices, circuit breakers, overload relays, etc. are installed at Note: See also Electrical Safety due to improper voltage, proper voltage and over-current protection according to manufacturer’s specifications. Program. phase, current, or motor Prior to energizing circuit, review and verify proper phase, voltage, and over-current protection rating rotation direction with respect to installed equipment nameplates and/or manufacturer’s specifications. Proceed with start-up of circuit/equipment in an incremental manner Verifying proper operation during each step (for motors verify proper rotation) against manufacturers’ specifications. Verify all required control interlocks. On-site edits:
Form Revised 06/10/10 JSA Control #: 055 Page 3 of 3
F. Ladders and Boom Trucks X Motion X Gravity 1a. Falls from improperly 1a. Comply with GES’ fall protection document (HSSE Policy #0015) (also discusses ladder safety) which 1. Using ladders and boom trucks Chemical Radiation using ladders includes but is not limited to the following. Electrical Heat/Cold If using a ladder to access any elevated components, inspect the ladder prior to use ensuring steps are Biological Pressure free of debris, water, ice, etc. Inspect rungs to ensure they are secure and free of cracks. Place ladder on level ground. Fall protection must be used at heights greater than 6 feet above ground when two handed work is needed. Maintain 3 points of contact. Extension and straight ladders must be tied off. Pitch ladder at a 4 to 1 ratio. Note: Never stand on top rung of ladder. 1b. Falls, when using a 1b. If using a boom truck with a cage guard, you must use a body harness. cherry picker/boom truck Make sure cage is free of debris, sediment, water, ice, etc. 1c. Head injuries from 1c. Wear hard hats when performing this activity potential overhead hazards On-site edits:
Form Revised 06/10/10
JOB SAFETY ANALYSIS DATE 9/22/04, 5/18/06, 8/8/07, 4/8/09, 7/29/09 NEW PAGE 1 of 1 X REVISED JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) JSA # All Work Locations Investigation and Site Survey 057 Remediation DEVELOPMENT TEAM POSITION / TITLE REVIEWED BY POSITION / TITLE Edwin Fox Case Mgr/LHSO Julius Pachy Reg HSSE Spec - MW J. Kohnen & J. Gould Surveyors (Gateway) J. Brethauer Asst Dir of Surveyors (Gateway) REQUIRED (use an “X”) & RECOMMENDED (use an “&”) PERSONAL PROTECTIVE EQUIPMENT – Place appropriate symbol on corresponding line(s) AIR PURIFYING RESPIRATOR HEARING PROTECTION X SAFETY SHOES steel-toed FACE SHIELD LIFELINE / HARNESS SUPPLIED RESPIRATOR X GLOVES nitrile; leather X PPE CLOTHING highly visible clothing such OTHER GOGGLES as orange reflective safety vest HARD HAT X SAFETY GLASSES REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT 1. Transit 2. Stadia rod 3. Plumb-bob 4. Flagging tape 5. Traffic control 6. Hammer and nails 7. Socket wrench 8. Screw driver (barricades, cones, flags, caution tape) ¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS A. Review “General Site Activities” JSA - #028 B. Review “Groundwater Sampling” JSA - #032 C. Mobilize to Site 1. Drive to site and park vehicle 1a. Contact with traffic, 1a. Drive defensively following GES safe driving policy. Obey all pedestrians, and obstacles traffic laws. 1b. Contact with parking 1b. Park in designated parking area. vehicles, traffic flow/control D. Arrive On-site 1. Check in with property 1a. Contact with site traffic 1a. Don traffic safety gear immediately. owner/station manager Inform property owner/station manager of your presence on site. Don PPE (listed above). Determine location(s) for transit where the maximum number of points can be surveyed with out moving the transit. Select locations outside of main traffic patterns. 2. Set up control points 2a. Contact with traffic while 2a. Set up traffic control (cones/barricades) work zone, per GES’ setting up control points Traffic Control Program. 2b. Contact while driving nails 2b. Check hand tools for wear and tear. for the control points 2c. Exertion carrying equipment 2c. Utilize proper lifting techniques when loading and unloading vehicle. Bend down at the knees and lift with your legs. Note: Do not twist while lifting. This can cause a severe back injury. 2d. Exposure to the elements 2d. Dress appropriately for ambient temperatures; drink plenty of fluids. E. Roadbox 1. Open roadbox to prepare for 1a. Skin abrasion 1a. Don leather gloves to prevent a skin injury while handling tools TOC reading and opening the roadbox. F. Survey Points 1. Surveying 1a. Contact with traffic 1a. Constantly scan for vehicles. Set up traffic control (i.e., cones/barricades) work zone. Limit time spent in areas where lines of sight for oncoming traffic are limited. 1b. Fall, slip/trip when moving 1b. Check thick vegetation for tripping hazards and debris. through thick vegetation Look for the safest route to a point before proceeding; then proceed with caution. Consult “Offsite and Onsite Clearing of Overgrowth (Vegetation)” JSA #111. 1c. Exposure to poisonous 1c. Don leather gloves before accessing monitor wells. plants, insects, animals 1d. Injurious contact (i.e., pinch 1d. Consult Job step B.1 of “Groundwater Sampling” JSA #032 if points or strains) accessing monitoring wells to survey casing elevations.
JOB SAFETY ANALYSIS DATE 11/15/06, 10/24/08, 6/23/09, 8/26/09, NEW PAGE 1 of 3 11/16/09 X REVISED JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) JSA # All Work Locations Chemical Injection Sodium Persulfate Injection 092
INITIATED / CHANGED BY POSITION / TITLE APPROVED BY POSITION / TITLE Glenn Iosue, PE Corporate Engineer Thomas Baylis, CIH Dir, HSSE
REQUIRED PERSONAL PROTECTIVE EQUIPMENT – Place an “X” next to the appropriate line item and expand on requirement as necessary. X AIR PURIFYING RESPIRATOR with acid X HEARING PROTECTION when noise levels X SAFETY SHOES steel-toed mist cartridges exceed 85 dB SUPPLIED RESPIRATOR X FACE SHIELD LIFELINE / HARNESS X OTHER DUST MASK; IMPERVIOUS X GLOVES 11 mil nitrile X PPE CLOTHING highly visible clothing such CLOTHING - if mixing liquid and a spill occurs, X GOGGLES as orange coveralls, reflective safety vest neoprene gloves and either rubber or PVC X HARD HAT X SAFETY GLASSES boots must be worn in addition to poly-coated Tyvek suit REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT 1. Lockout/tagout kit 2. CGI/O2 meter 3. 4. 5.
¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS A. Review “General Site Note: Review and modify as to current weather, humidity, and heat index conditions Job Step #4 Activities” JSA #028 - Exposure, Potential Hazards 4a through 4d of the “General Site Activities” JSA. B. Set Up Injection System/ Note: No peroxide, persulfate, or ozone injection program is permitted until the “GES General Trailer/Truck/Pumps/Drop Guidelines and Information for Performing HypeAir Events” protocol is reviewed and understood Tubes and Perform Injection by all project staff. GES’ regional engineer should be contacted immediately if there are any questions or issues regarding the injection event. GES’ HypeAir manager must be contacted if there are any losses/near losses or issues. 1. Inject high pressure air to 1a. Air compressor (vehicle 1a. Check all the components of the air compressor system. open well screen and sand mounted air compressor) Make sure lines are securely connected. pack (pressurized lines) Make sure all belt guards are in place. Make sure all fittings are secure. 1b. Elevated noise (generator 1b. Wear hearing protection while the air compressor is and/or VMAC compressor) operating (if working near). This equipment creates noise levels above 85 dB. 2. Transfer water from holding 2a. Exposure to persulfate 2a. Wear appropriate PPE: (eye protection [goggles or tank or other source to mixing faceshield], dust mask, long pants, nitrile gloves, hard hat [if tank (this must be a separate overhead obstacles are present], shirt with sleeves, steel–toed tank from the hydrogen boots.) peroxide mixing/injection tank); Prior to moving or opening persulfate bags, check for rips or mix sodium persulfate for tears in bags that could cause persulfate to spill from bags. injection. Always use proper lifting techniques to lift bags of persulfate. Bags typically weigh 55 lbs. Due to the weight of the bags, WARNING: Only generate the two people or mechanical means will be required to lift and quantity of persulfate solution transport bags from one work location to another. that will be injected during a 2b. Special provisions are to be made during chemical mixing in workshift. NEVER store any 2b. Exposure to added heat hot weather conditions where heat and humidity will play a persulfate solution oversight. and humidity while wearing factor when wearing chemical protective clothing. upgraded chemical protective Modify delivery schedule to ensure chemical arrives on site WARNING: Avoid contact to clothing early. cotton, wool, and leather with Review SOW and accommodate modifications to prevent persulfate. unnecessary work in heat or otherwise undesirable conditions. WARNING: If onsite Identify tasks on SOW that may require cooler conditions. personnel have any skin, eye, Identify work scope modifications that can enable these or respiratory system irritation, tasks to be performed in cooler conditions (i.e., scheduling the injection system must be earlier work start times). shut down and the area Communicate to site personnel, especially person(s) wearing properly ventilated. Skin and upgraded chemical protective clothing the importance of eye irritation must be flushed taking the time to perform tasks safely. with copius amounts of water Take breaks as needed or as implemented; have remaining and a physician should be site personnel monitor as well. contacted if irritation persists. Ensure measures are in place to provide added relief from In addition, GES’ vice the elements, such as an air conditioned environment, pop- president of engineering must up shade tents, coolers with water, hydrating drinks, etc.; wet
JOB SAFETY ANALYSIS JSA # - 092 Page 2 of 3
¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS be contacted to determine if towels can be wrapped around the neck or head to provide other action is warranted. additional cooling effects. 2c. Rubber booties or rubber over boots, hearing protection, 2c. Exposure to spilled and poly-coated Tyvek suit or apron and arm sleeves are material during a spill clean-up required for spill clean-up. All persulfate handling must be completed in accordance with the Material Safety Data Sheet (MSDS). 2d. Before transferring persulfate from bags to mixing tank, 2d Persulfate release to have a source of water readily available to dissolve and dilute ground any crystals that may be spilled on ground or other surfaces. 2e. Make sure all lines and fittings are properly sealed. 2e. Leaking pipe/fittings, Check for leaks. If there is a leak in any of the components release of persulfate/water shut off pumps, close valves, and flush leak with plenty of solution water. Once pressure has been relieved from the line make repairs to leaking component. Copper, brass, galvanized, and iron pipe, fittings, equipment should not be used with persulfate. NEVER STORE persulfate solution overnight in a holding tank. 2f. During installation of drop tube and packers watch for 2f. Property damage overhead overhead obstacles and wear a hard hat if they are present. 2g. Keep fingers out from under man ways to avoid pinching 2g. Pinch points and wear leather gloves while opening wells. 3. Injection of persulfate 3a. Exposure to chemicals 3a. Only employees trained to operate the injection system are permitted to operate the equipment. Wear required PPE while in trailer or near injection lines. Review the MSDS and all action levels in the HASP with all staff on site. Have proper PPE available for upgrade to Level C. 3b. Oxygen enriched/deficient 3b. Monitor breathing zone during operation of equipment and atmospheres; flammable the injection with an oxygen or ozone meter. atmosphere Oxygen levels are required to be >19.5% and <23.5%. LEL levels measured by a calibrated combustible gas indicator are <25 % of the LEL. If oxygen levels outside the well casings exceed 23.5% and/ or LEL levels exceed 20%, the system should be shut down. GES’ regional engineer and the IRSP manager must be contacted so that the appropriate action is taken. Post no smoking signs and keep all sources of ignition away from oxidizing agents/chemicals. 3c. High pressured lines during 3c. Prior to initiating injection make sure all fittings and lines are injection secure and tight. Wear 11 mil nitrile gloves for this activity. Monitor pressure of lines during operation/injection. 3d. Slips, trips, falls 3d. Make sure all hoses and lines are positioned about the work area to avoid tripping hazards. Keep work area clean and tools picked up. 4. If service or repairs are 4a. Electrocution 4a. Follow all LO/TO procedures if servicing or repairs must be needed made. 4b. Exposure to chemicals 4b. When repairing feed lines that contain process chemicals, wear appropriate PPE. Refer to B.2a above for specific PPE needed. 4c. High pressure (stored in 4c. Check pressure and ensure that the pressure has been system) released prior to opening/removing any fittings, drains, etc. 4d. Pinch point hazard 4d. Wear 11 mil nitrile for this activity. Make sure guards are replaced, no one is within an arms length of any equipment, and all tools are removed prior to re-starting system. C. Complete Injection 1. Thoroughly rinse injection 1a. Slips, trips, falls, cuts 1a. Keep area clean, tools picked up, and pay attention to areas lines, pumps, well packers, in the work space where lines will be temporarily stored during mixing tank, and any equipment pick up. miscellaneous equipment 1b. Back strains 1b. Bend down at the knees and lift with your legs rather than bending and lifting with your back when pulling equipment from
JOB SAFETY ANALYSIS JSA # - 092 Page 3 of 3
¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS well. 1c. Hand contact with 1c. Wear 11 mil nitrile for this activity. persulfate Note: It is recommended that a minimum of 200 to 500 gallons of additional water should be available onsite for rinse or emergency use. 1d. Release of chemicals to 1d. Use emergency rinse water on site to fully dilute the surface surface via preferential release. pathways (i.e., including but not limited to cracks in concrete, asphalt, well pack, vaults, etc.)
JOB SAFETY ANALYSIS DATE 09/13/07, 10/24/08, 8/26/09, 11/16/09 NEW PAGE 1 of 3 X REVISED JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) JSA # All Work Locations Chemical Injection Sodium Persulfate/Hydrogen Peroxide 100 Combined Injection
INITIATED / CHANGED BY POSITION / TITLE APPROVED BY POSITION / TITLE Keith Graver HypeAir Mgr Thomas Baylis, CIH Dir, HSSE
REQUIRED PERSONAL PROTECTIVE EQUIPMENT – Place an “X” next to the appropriate line item and expand on requirement as necessary. X AIR PURIFYING RESPIRATOR with acid X HEARING PROTECTION when noise levels X SAFETY SHOES steel-toed mist cartridges exceed 85 dB SUPPLIED RESPIRATOR X FACE SHIELD LIFELINE / HARNESS X OTHER DUST MASK; IMPERVIOUS X GLOVES 11 mil nitrile X PPE CLOTHING highly visible clothing such CLOTHING - if mixing liquid and a spill occurs, X GOGGLES as orange coveralls, reflective safety vest neoprene gloves and either rubber or PVC X HARD HAT X SAFETY GLASSES boots must be worn in addition to poly-coated Tyvek suit REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT 1. Lockout/tagout kit 2. CGI/O2 meter 3. Ozone meter 4. 5.
¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS A. Review “General Site Note: Review and modify as to current weather, humidity, and heat index conditions Job Step #4 Activities” JSA #028 - Exposure, Potential Hazards 4a through 4d of the “General Site Activities” JSA. B. Review “Peroxide and Ozone Injection” JSA - #044 C. Review “Sodium Persulfate Injection” JSA - #092 D. Review GES’ HypeAir Guidance E. Set Up Injection System/ Note: No peroxide, persulfate, or ozone injection program is permitted until the “GES General Trailer/Truck/Pumps/Drop Guidelines and Information for Performing HypeAir Events” protocol is reviewed and understood Tubes/Wellhead Assemblies by all project staff. GES’ regional engineer should be contacted immediately if there are any and Perform Injection questions or issues regarding the injection event. GES’ HypeAir manager must be contacted if there are any losses/near losses or issues. 1. Inject high pressure air to 1a. Contact by or injury from 1a. Check all the components of the air compressor system. open well screen and sand high pressure (vehicle Make sure lines are securely connected. pack mounted air compressor) Make sure all belt guards are in place. (pressurized lines) Make sure all fittings are secure. 1b. Elevated noise (generator 1b. Wear hearing protection while the air compressor is and/or VMAC compressor) operating (if working near). This equipment creates noise levels above 85 dB. 2. Transfer water from holding 2a. Exposure to persulfate/ 2a. Wear appropriate PPE: (eye protection [goggles or face tank or other source into peroxide mixture shield], dust mask, long pants, nitrile gloves, hard hat [if vehicle mixing/injection tank; overhead obstacles are present], shirt with sleeves, steel–toed mix persulfate/peroxide and boots.) water Prior to moving or opening persulfate bags, check for rips or tears in bags that could cause persulfate to spill from bags. WARNING: Only generate the Always use proper lifting techniques to lift bags of persulfate. quantity of persulfate/peroxide Bags typically weigh 55 lbs. Due to the weight of the bags, solution that will be injected two people or mechanical means will be required to lift and during a workshift. NEVER transport bags from one work location to another. store any persulfate/peroxide Prior to mixing, check for bulging hydrogen peroxide drums. solution overnight. (Drums MUST have at least one self-venting bung.) 2b. Special provisions are to be made during chemical mixing in WARNING: Avoid contact to 2b. Exposure to added heat hot weather conditions where heat and humidity will play a cotton, wool, and leather with and humidity while wearing factor when wearing chemical protective clothing. persulfate/peroxide. upgraded chemical protective Modify delivery schedule to ensure chemical arrives on site clothing early. WARNING: If onsite Review SOW and accommodate modifications to prevent personnel have any skin, eye, unnecessary work in heat or otherwise undesirable or respiratory system irritation, conditions. the injection system must be Identify tasks on SOW that may require cooler conditions.
JOB SAFETY ANALYSIS JSA # - 100 Page 2 of 3
¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS shut down and the area Identify work scope modifications that can enable these properly ventilated. Skin and tasks to be performed in cooler conditions (i.e., scheduling eye irritation must be flushed earlier work start times). with copious amounts of water Communicate to site personnel, especially person(s) wearing and a physician should be upgraded chemical protective clothing the importance of contacted if irritation persists. taking the time to perform tasks safely. In addition, GES’ vice Take breaks as needed or as implemented; have remaining president of engineering must site personnel monitor as well. be contacted to determine if Ensure measures are in place to provide added relief from other action is warranted. the elements, such as an air conditioned environment, pop- up shade tents, coolers with water, hydrating drinks, etc.; wet towels can be wrapped around the neck or head to provide additional cooling effects. 2c. Rubber booties or rubber over boots, hearing protection, 2c. Exposure to spilled and poly-coated Tyvek suit or apron, and arm sleeves are material during a spill clean-up required for spill clean-up. All persulfate/peroxide handling must be completed in accordance with the Material Safety Data Sheet (MSDS). 2d. Before transferring persulfate from bags to mixing tank, 2d Persulfate/peroxide release have a source of water readily available to dissolve and dilute to ground any crystals that may be spilled on ground or other surfaces. 2e. Make sure all lines and fittings are properly sealed. 2e. Leaking pipe/fittings, Check for leaks. If there is a leak in any of the components release of persulfate/peroxide shut off pumps, close valves, and flush leak with plenty of solution water. Once pressure has been relieved from the line make repairs to leaking component. Copper, brass, galvanized, and iron pipe, fittings, equipment should not be used with persulfate. NEVER STORE persulfate/peroxide solution overnight in a holding tank. 2f. During installation of drop tube and packers watch for 2f. Property damage overhead overhead obstacles and wear a hard hat if they are present. 2g. Keep fingers out from under man ways to avoid pinching 2g. Pinch points and wear leather gloves while opening wells. 3. Injection of 3a. Exposure to chemicals 3a. Only employees trained to operate the injection system are persulfate/peroxide permitted to operate the equipment. Wear required PPE while in trailer or near injection lines. Review the MSDS and all action levels in the HASP with all staff on site. Have proper PPE available for upgrade to Level C. 3b. Oxygen enriched/deficient 3b. Monitor breathing zone during operation of equipment and atmospheres; flammable the injection with an oxygen or ozone meter. atmosphere Oxygen levels are required to be >19.5% and <23.5%. LEL levels measured by a calibrated combustible gas indicator are <25 % of the LEL. If oxygen levels outside the well casings exceed 23.5% and/ or LEL levels exceed 20%, the system should be shut down. GES’ regional engineer and the IRSP manager must be contacted so that the appropriate action is taken. Post no smoking signs and keep all sources of ignition away from oxidizing agents/chemicals. WARNING: NEVER isolate 3c. High pressured lines during 3c. Prior to initiating injection make sure all fittings and lines are the persulfate/peroxide injection secure and tight. Wear 11 mil nitrile gloves for this activity. solution between two valves as Monitor pressure of lines during operation/injection. possible increased line 3d. Slips, trips, falls 3d. Make sure all hoses and lines are positioned about the work pressures may exist. area to avoid tripping hazards. Keep work area clean and tools picked up. 4. If service or repairs are 4a. Electrocution 4a. Follow all LO/TO procedures if servicing or repairs must be needed made. 4b. Exposure to chemicals 4b. When repairing feed lines that contain process chemicals, wear appropriate PPE. Refer to E.2a above for specific PPE needed. 4c. High pressure (stored in 4c. Check pressure and ensure that the pressure has been
JOB SAFETY ANALYSIS JSA # - 100 Page 3 of 3
¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS system) released prior to opening/removing any fittings, drains, etc. 4d. Pinch point hazard 4d. Wear 11 mil nitrile for this activity. Make sure guards are replaced, no one is within an arms length of any equipment, and all tools are removed prior to re-starting system. F. Complete Injection 1. Thoroughly rinse injection 1a. Slips, trips, falls, cuts 1a. Keep area clean, tools picked up, and pay attention to areas lines, pumps, well packers, in the work space where lines will be temporarily stored during mixing tank, and any equipment pick up. miscellaneous equipment 1b. Back strains 1b. Bend down at the knees and lift with your legs rather than bending and lifting with your back when pulling equipment from well. 1c. Hand contact with 1c. Wear 11 mil nitrile for this activity. persulfate Note: It is recommended that a minimum of 200 to 500 gallons of additional water should be available onsite for rinse or emergency use. 1d. Release of chemicals to 1d. Use emergency rinse water on site to fully dilute the surface surface via preferential release. pathways (i.e., including but not limited to cracks in concrete, asphalt, well pack, vaults, etc.)
Job Safety Analysis (JSA) Page 1 of 2
JSA Title: Soil Drumming JSA Control #: 060 Date Developed: 5/18/05 Please complete the below if this JSA is being modified for SITE-SPECIFIC reasons. Latest Revised Date: 6/21/10 Date Form Completed: Work Location: Initiated/Changed by: Lisa Leclair This JSA has been fully reviewed with all staff members and all activity job steps, hazards, work practices, and PPE are clearly understood and have been implemented. All necessary revisions have been written on this JSA. Approved by: Thomas Baylis. CIH
REQUIRED PPE: Air Purifying Respirators: may be required if conditions or work area air quality exceeds applicable HASP action levels; Face Shield: if flying particles are generated; Gloves: nitrile, Kevlar, leather; Hard Hat: if working in an area with low overhead clearance; Hearing Protection: if site activities raise the noise level to 85 dB; PPE Clothing: highly visible clothing such as orange coveralls or reflective safety vest; Safety Glasses; Safety Shoes: steel-toed REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT: PID; CGI/O2 or LEL meter; shovel; Adjustable wrench or socket wrench
Activity/Sequence of Job Tasks Energy or Biological What would be the result of Energy/Biological/Waste Management Plan List all tasks required to perform a Sources exposure to a biological or Eliminate – Control – Protect job in the sequence they are (Check all that apply) energy source? (e.g., slip, Risk Control Measures carried out. trip, fall, exposure, List control measures required to eliminate, control or protect against unwanted contact with an uncontrolled electrocution, injury, death, biological or energy source to minimize the risk of injury or environmental impact. Include identification of etc.). How, where, or ‘Stop Work’ triggers. when could an uncontrolled release or unwanted contact with a biological or energy source occur? Please ensure that all necessary JSAs associated with your work scope have been identified and reviewed. A. Traffic Awareness X Motion Gravity 1a. Traffic (struck by) 1a. Wear required highly visible clothing. 1. Secure work area from traffic Chemical Radiation Establish work area so that each site vehicle used for activity are in close proximity of each other; this Electrical Heat/Cold would prevent unnecessary trips outside of work zone and into potential traffic area. Biological Pressure
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B. Prepare for Drum Filling X Motion X Gravity 1a. Trip, slips, and falls 1a. Maintain all equipment and tools in designated areas and out of pathways. 1. Review, inspect, and locate Chemical Radiation Identify and protect all air lines, water lines, electrical cords, and cables. safety equipment including fire Electrical Heat/Cold Watch for the formation of snow covered ice during cold weather. extinguisher, first aid kit, insect Biological X Pressure 1b. Exertion 1b. Use proper lifting techniques; bend at the legs and keep back straight. repellant, ice melt, PPE, etc. Hold item close to body. Items heavier than 50 lbs or shovel loads that are awkward to handle use mechanical devices or ask Note: Know location of first aid kit for help. and eye wash.
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2. Locate the appropriate Motion Gravity 2a. Contact 2a. Identify appropriate safety equipment and don PPE. equipment and materials are Chemical Radiation Time savings to reduce trips for forgotten items. available for filling drums Electrical Heat/Cold 2b. Exposure to site 2b. Watch for broken bottles or other debris that could cause cuts or abrasions. Biological X Pressure materials JSA Control #: 060 Page 2 of 2
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3. Remove drum lid X Motion Gravity 3a. Pinch point 3a. Use the proper type of gloves - thick enough to prevent pinch points and cuts (i.e., leather, Nitrile Chemical Radiation coated knit, etc.). Electrical Heat/Cold Use the proper sized socket or adjustable wrench for lid removal. Biological Pressure
On-site edits:
4. Load soil into drums X Motion X Gravity 4a, Exertion 4a. Use proper lifting techniques; this consists of bending your knees and lifting with your back straight. X Chemical Radiation Shovel loads heavier than 50 lbs or awkward to handle use a mechanical loading device or ask for Note: If any drums are filled with Electrical Heat/Cold help. soil or any material, the drums Biological X Pressure Grasp shovel handle properly : Position one hand at base of shovel handle and your other hand near may only be filled two-thirds (2/3rd) the top of the handle. full. 4b. Fall 4b. Be alert for uneven and slippery terrain. 4c. Exposure to 4c. Wear appropriate PPE (e.g., eye protection-goggles, long pants, Nitrile exam gloves, Nitrile over- contaminants gloves (11-mil), long wrist) Tyvek coveralls, shirt with sleeves, steel-toed shoes with boot covers, half- face air purifying respirator fitted with an organic vapor, acid, HEPA filter combination cartridge). Evaluate (monitor work area with a CGI/O2 (LEL); if levels exceed 10% LEL leave the area and contact GES corporate HSSE. Review action levels noted in the HASP. When approaching or sampling drum(s), monitor breathing zone with a PID; if levels exceed 50 ppm in breathing zone leave area and contact GES corporate HSSE. On-site edits:
5. Moving/relocating drums X Motion X Gravity 5a. Back strain 5a. If drums must be moved utilize a drum dolly. Chemical Radiation DO NOT ATTEMPT TO "WALK" or "ROCK" DRUMS TO MOVE THEM. Electrical Heat/Cold Drums can become unstable and easily tip-over causing possible damage and personal injury as well Biological Pressure as releasing the material contained. Scan your walking path for obstructions, debris, slip, trip and fall hazards. On-site edits:
Form Revised 06/10/10
JOB SAFETY ANALYSIS DATE 2/23/05, 2/5/10 NEW PAGE 1 of 2 X REVISED JSA TYPE CATEGORY WORK TYPE WORK ACTIVITY (Description) JSA # All Work Locations Various Deliveries and Pick-ups 016
INITIATED / CHANGED BY POSITION / TITLE APPROVED BY POSITION / TITLE Julius Pachy Reg HSSE Spec - MW Thomas Baylis, CIH Dir, HSSE
REQUIRED PERSONAL PROTECTIVE EQUIPMENT – Place an “X” next to the appropriate line item and expand on requirement as necessary. AIR PURIFYING RESPIRATOR HEARING PROTECTION X SAFETY SHOES steel-toed FACE SHIELD LIFELINE / HARNESS SUPPLIED RESPIRATOR X GLOVES leather; nitrile X PPE CLOTHING highly visible clothing such OTHER GOGGLES as orange coveralls, reflective safety vest X HARD HAT client-specific when overhead X SAFETY GLASSES hazards are present/heavy equip is in use REQUIRED AND/OR RECOMMENDED TOOLS AND EQUIPMENT 1. Material handling device 2. 3. 4. 5. (i.e., hand truck)
¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS A. Review “General Site Activities” JSA #028 B. Delivery of Materials/ Equipment 1. Delivery or pick-up of 1a. Improper lifting technique, 1a. Utilize proper lifting procedure when loading and unloading supplies or materials to the site back strain, exertion, muscle vehicle. by an outside source (manual injuries Determine that object is within safe weight limit. lifting heavy objects) Do not lift any object weighting more then 50Lbs Note: Recommended safe Use 2 people if packages are heavy, large, or awkward. lifting weights for an average Check that there is ample room to squat, lift, turn or man or woman are 50 and 35 maneuver without twisting the back or other muscles or pounds respectively. joints. Bend down at the knees and lift with your legs rather than Note: Mechanical equipment bending and lifting with your back. or assistance such as dollies, Place one foot slightly in front of the other. carts, come-alongs, or rollers Squat as close to the object as possible. are to be used whenever Grasp one of the top corners away from the body and the possible. opposite bottom corner closest to the body. Tilt the object slightly away from the body, tilt forward at the Note: Stop immediately if you hips, keep the back straight and tuck in the chin. feel any pain, muscle pulls, or Pull the object into the body and stand up slowly and evenly limited range of motion. without jerking or twisting. Contact LHSO, project To set an object down, reverse the sequence, being sure not manager, and/or site to trap the bottom hand between the object and the surface operations manager. on which the object is set. Do not carry objects in a manner that obstruct vision in line of travel. When 2 or more persons are lifting, have a plan and a set of signals so lifting occurs simultaneously. 1b. Cuts, pinching, and 1b. Check each object before lifting for presence of splinters, crushing slivers, sharp edges, and loose joints; signs of biological hazards; or chemical contamination. Check for pinch points (i.e., other objects close by). 1c. Slips, trips, falls 1c. Check route to be traveled if lifting involves carrying. Check walking and working surfaces for slip/trip/fall hazards. Note ramps, changes on level of elevation, and ladders or stairways than need to be negotiated. 2. Deliveries of remediation 2a. Contact with heavy 2a. Make sure all operators have seat belts and safety bars in equipment requiring heavy equipment use. equipment to unload or move All equipment should be inspected prior to use by the operator for hydraulic leaks, broken glass, safety devices, NOTE: If moving remediation etc. equipment with heavy 2b. Pinch points 2b. Never stand in equipment pinch points (i.e., between tracks
JOB SAFETY ANALYSIS JSA # - 016 Page 2 of 2
¹JOB STEPS ²POTENTIAL HAZARDS ³CRITICAL ACTIONS equipment make sure the load and counter weight of excavators, between back of backhoe is balanced and secured. and bucket arm, etc.). 2c. Blind spots 2c. Never let anyone stand in the swing radius. Never assume operator can see you. Never approach equipment in a blind spot. Always approach equipment from the front where the operator can see you and stop the activities. 2d. Caught or stuck by 2d. Never let anyone stand under an elevated load. Never let anyone ride on the side or in a bucket of equipment. Make sure cabs are clean and no loose objects are on the floor that could block control pedals.
GES DAILY SITE SAFETY CHECKLIST
Site Name: Moen, Incorporated Address: 2609 Cox Mill Road Sanford, North Carolina 27330
Individual’s Name: Date:______
Task and date of entry:
This checklist is to be completed on a daily basis. The date should be noted in the space provided. The employee completing the checklist should verify that each item is correct and initial in the last space provided.
Date:
1. Proper training certificates have been obtained from subcontractors. 2. The site-specific HASP has been reviewed and signed by GES employees and GES-hired subcontractors. 3. The daily site-safety meeting has been conducted. 4. Applicable JSAs are onsite, reviewed by Staff to ensure all tasks/jobs are covered, and site specific JSA modifications occur when needed. 5. Fire extinguishers are available for use and are fully charged. 6. A fully-stocked first aid kit and eye wash bottle are readily available. 7. Any potential tripping hazards have been removed from site. 8. All vessels containing flammable or corrosive material are properly labeled. 9. Proper personal protective equipment is being used for present conditions. 10. Equipment on-site is checked and in safe working order. 11. Safety cones and flags or barricades have been utilized to mark out work area. 12. No person on-site has the appearance of being under the influence of motor skill altering substances. 13. All workers on-site are clothed in an appropriate manner (highly visible clothing, no tank tops, muscle shirts or shorts). 14. Electrical power operated tools shall be properly grounded and used with a Ground-Fault Circuit Interrupter (GFCI). 15. All required Permits (GES and/or client) are completed by an authorized individual.
16. When working alone, has a phone call been placed to the PM to discuss site conditions, review the Scope of Work, LPS requirements, and coordinate communications for the day. Note: The frequency/ amount of additional calls from the field should be established during the PM’s discussion with the individual. A call must always occur prior to leaving the site.
17. Prior to leaving the site for the day, the GES site supervisor has conducted a meeting with onsite staff to review worker condition (possible injuries), JSA revisions, discuss possible Near Losses/ Losses, and activities scheduled for the next day.
18. All health and safety concerns have been communicated to the Local Health and Safety Officer and Project Manager
I verify and initial that the above information is correct by initialing in the boxes to the right: Additional Notes:
Re444444 4/10
ATTACHMENT E
PRE-ENTRY MEETING NOTES
Updated: July 2011 PRE-ENTRY MEETING NOTES/ATTENDANCE (Include date, length of meeting, names of personnel in attendance, topics of discussion, comments and concerns, etc.)
Updated: July 2011
ATTACHMENT F
SIGN OFF SHEET
Updated: July 2011 SITE SAFETY AND HEALTH PLAN COMPLIANCE AGREEMENT
All project personnel, including visitors, must follow the requirements of this Site Safety Plan. In order to document individual agreement with this requirement, all personnel must complete this “Site Safety and Health Plan Compliance Agreement.” These agreements will be kept in this Site Safety Plan and will become part of the permanent project record upon completion of site activities.
By signing below, I have read the Site Health and Safety Plan (HASP), or I have been verbally advised of its contents. I understand, and I agree to comply with all of its provisions. I understand that I could be prohibited from working on the project, and I may be subject to disciplinary actions for violating any of the health and safety requirements specified in the HASP.
NAME SIGNATURE DATE (TIME IN/OUT) 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. 22.
Updated: July 2011
ATTACHMENT G
INCIDENT/INJURY CASE MANAGEMENT
Updated: July 2011 ALL accidents, injuries, property damage, or releases (Loss or Near Loss) shall be reported to GES’ on-site supervisor ASAP but no later than the end of the shift.
Injury Case Management is a collaborative process which: Helps ensure prompt, adequate, and appropriate medical care is provided Assesses, plans, implements, coordinates, monitors, and evaluates options Can minimize the impact of an impairment (resulting from potentially work-related injury or illness) Preserves as much as practicable the individual’s functional capacity.
Medical injuries or emergencies within each field location will be managed by the following method: If an injury or medical condition occurs that cannot be treated by providing basic first aid to the individual, the GES PM and Site Operations Manager are notified by the GES Oversight person. Onsite, individuals who are certified in cardiopulmonary resuscitation (CPR)/First Aid will be requested to respond to the individual’s location. Following this evaluation the GES Director, HSSE and client program manager, must be contacted regarding the individual’s condition and injury management approach onsite and offsite.
Following an assessment of the individual’s condition, if responding GES personnel feel that outside medical response personnel (emergency care) are necessary: The 911 emergency response system will be activated, if necessary. Provide the 911 emergency operator all of the information that is requested. It should be noted that in some GES offices the number 8 must be dialed prior to dialing 911. The injured individual (GES or subcontractor employee) will be accompanied by other GES staff (i.e., PM, local HSO, site supervisor) so that desired injury management information will be communicated to the attending physician.
If an individual requires medical treatment beyond basic first aid, but the initial assessment determines that the individual does not require emergency care, then: The PM, Site Operations Manager, and CHSSE will be contacted PRIOR to leaving the site. The individual will be scheduled for an appointment at the occupational clinic near each office. If the injured individual is a subcontractor, then the individual will be directed to visit an occupational clinic established by the subcontracting company. If there is no clinic established, the individual will be scheduled at a GES clinic.
The individual will be accompanied to their examination by the GES local HSO or other GES or subcontractor management staff. Desired injury management information will be communicated to the attending physician that would include but will not be limited to: Any required or alternative medication (over the counter medication) Any work place restrictions versus lost time are discussed with the attending physician. The GES director, HSSE will also contact the attending physician regarding the examination, diagnosis and the GES injury management approach.
Updated: July 2011 Moen Incorporated 2609 Cox Mill Road, Sanford, NC July 2011
ATTACHMENT C – BELFOR ENVIRONMENTAL CONSTRUCTABILITY REPORT
Remedial Action Plan
CONSTRUCTABILITY REPORT
For
MOEN Manufacturing Facility Remediation of Contaminated Soils
PROJECT LOCATION 2609 Cox Mill Road Sanford, NC
BELFOR PROJECT #2530-1-10096 REPORT DATE: March 11th, 2011
Report Created By: Joel Miller, Belfor Environmental Report Contributor: Scott Harshman, Triad Geotechnical Consulting
Constructability Report March 11th, 2011 MOEN Manufacturing Facility Remediation of Contaminated Soils
Table of Contents
1.0 INTRODUCTION...... 3 2.0 PROJECT DESCRIPTION...... 3 3.0 RECOMMENDED REMEDIAL ACTIVITIES...... 3 3.1 SITE PREPERATION...... 3 3.2 EQUIPMENT & MATERIAL HAUL ROUTES...... 3 3.3 REMOVAL OF EQUIPMENT & OBSTRUCTIONS...... 4 3.4 INSTALLATION OF AN AIR CONTAINMENT SYSTEM...... 4 3.5 FOOTER, SIDEWALL, AND COLUMN SUPPORT...... 5 3.6 CONCRETE REMOVAL & REPLACEMENT ...... 5 3.7 EXCAVATION & BACKFILLING...... 5 3.7 BUILDING RESTORATION ...... 6
4.0 BUDGETARY COST ESTIMATE...... 6 4.1 COST ESTIMATE SUMMARY ...... 6 4.2 ESTIMATE FOR CAFATERIA AREAS 1&2 ...... 7 4.3 ESTIMATE FOR PLANT AREA 3A...... 8 4.4 ESTIMATE FOR PLANT AREA 3B...... 9 4.5 ESTIMATE FOR PLANT AREA 4...... 10
5.0 PROJECT DURATION...... 10
6.0 ATTACHMENTS 5.1 ATTACHMENT A - EXCAVATION AREA DESIGNATION DRAWING 5.2 ATTACHMENT B - FOUNDATION, COLUMN, AND SIDEWALL SUPPORT DRAWINGS 5.3 ATTACHMENT C - PROJECT DURATION SCHEDULES
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1.0 INTRODUCTION
Belfor Environmental is pleased to provide this constructability report for remedial activities at the MOEN manufacturing facility located at 2609 Cox Mill Road, Sanford, NC. Belfor Environmental developed this constructability report through experience with similar projects, site walks, plan review, and collaboration with Groundwater and Environmental Services (GES) and Triad Geotechnical Consulting (TGC). The purpose of this report is to describe the recommended remedial activities to safely remove contaminated soil beneath the floor, identify potential problems, provide budgetary cost estimates, and determine project task durations. This report is not a proposal, and the pricing and processes discussed herein may change during proposal development due to estimating variances, actual field measurements, and/or scope of work alterations. In order to provide an official proposal, Belfor would need to collect on-site measurements, photographs, and conduct a site visit with various specialty subcontractors.
2.0 PROJECT DESCRIPTION
There are five main remedial areas in the facility, two are in the cafeteria/break room, and the other three are in the main plant (building additions 1&3). For identification purposes, the following designations have been made for each of these areas; Cafeteria Area 1, Cafeteria Area 2, Plant Area 3a, Plant Area 3b, and Plant Area 4. Please see the attached remedial area maps to identify each of these areas (Attachment A). The ultimate goal of this project is to safely remove the contaminated soils beneath the floor slab and footers, and return the facility to pre-project conditions.
3.0 RECOMMENDED REMEDIAL ACTIVITIES
3.1 Site Preparation In order to prepare the work areas for excavation, four main tasks would need to be performed. First, equipment and material haul routes would need to be established. Second, equipment and obstructions would need to be removed. Third, a containment system for the air would need to be created to prevent volatile emissions inside the building and to ensure adequate clean air supply in the work areas. Last, internal walls, sidewalls, columns, and footer supports would need to be installed.
3.2 Equipment and Material Haul Routes In the cafeteria/break room areas, the main haul route would be established through the double doors. The doors themselves and middle door stop would need to be removed to create enough space for entry/exit. Equipment and materials would be brought into and removed from the facility using this portal. A mini excavator and fork lifts would be the primary equipment utilizing this portal.
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In the Plant, the main haul route would be established down the existing travel corridor out to the loading dock through the loading dock hanger door. As with the cafeteria area, a mini excavator and fork lifts would be the primary equipment utilizing this route. Other small equipment will also be brought in and removed using this route.
3.3 Removal of Equipment and Obstructions In the cafeteria/break room areas, primary aboveground obstructions consist of tables and vending machines (Internal walls are discussed in section 3.5). These materials can be removed using standard powered and non-powered fork lifts coupled with manpower and simple rigging equipment. Miscellaneous stationary structures and objects would need to be removed and reinstalled or replaced, depending on the item. Adequate lay down areas would need to be established outside or within the undisturbed areas of the cafeteria for temporary item storage during remediation.
In plant area 3a, obstructions primarily consist of the electroplating machine and auxiliary electroplating equipment. Plant area 3b contains manufacturing machines, and plant area 4 contains miscellaneous equipment. For the purposes of this report, Belfor anticipates relocating these operations to a location inside the plant very close to the existing area. Belfor has assumed this equipment can be moved utilizing standard or industrial fork lifts. The process tanks and other miscellaneous piping and parts would need to be drained and possibly decontaminated prior to relocation.
3.4 Installation of an Air Containment System In order to ensure volatile emissions from the contaminated soils and equipment are not released into the building, air containments will need to be installed around each work area. Belfor anticipates that one air containment can be installed around both cafeteria areas. In the plant, Belfor recommends installation of separate air containments for both plant area 3a, 3b, and plant Area 4. The air containment would consist of reinforced poly sheeting connected to the ceiling support rafters at the top and connected to wood supports on the floor. The containment would be installed around the exterior of the excavation areas. Three air fans would be used to bring fresh air, and three HEPA filtered fans would be used to exhaust the air to the outside. This will provide a minimum of four complete air changes per hour. In addition to air containment, vapors would need to be suppressed utilizing Rusmar Foam Suppression Technology, or equivalent. Rusmar Foam protection would be applied to the surfaces of the soil at a minimum of once every 24 hours during active operations. In order to ensure carbon monoxide and other gases do not build up in the containment areas, all equipment would need to be fitted with air scrubbers. Air scrubbers reduce emission up to 80%. Constant work area monitoring will need to be performed to ensure these engineered controls are effective.
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3.5 Footer, Sidewall, and Column Support In order to excavate near or under the existing footers and columns; shoring, bracing, and special excavation techniques will need to be utilized for this project. Please refer to Attachment B for drawings of the different support methods.
For the external wall footers, Belfor recommends excavation using the “piano key” method. This method consists of undermining the footers in 3-4 foot sections, leaving 6-8 feet of undisturbed earth between each section, for the entire length of the footer. Once the soils from these piano key sections are removed, flowable fill would be installed and allowed to set-up prior to moving on to the next section or “piano key”. This process would be repeated until all the soil was removed and replaced with flowable fill concrete. Internal non-load bearing walls will need to be completely removed and replaced.
Internal Columns would need to be supported using a helical pier support method. Although timber cribbing/beam support is another method that could be used, the limited space and additional time to install would cost more and be obstructive. Please see Attachment B for details on these methods.
The excavation sidewalls will be secured using sheet piling to a depth of approximately 20ft. The proposed sheet piling would be installed using a backhoe with hydraulic hammer. Sheet piling would not be required where piano-keying methods were used. The other option for sidewall safety is to excavate safe slopes. After review of the additional concrete, excavating, and backfill costs associated with creating 1.5H to 1V slopes, the sheet piling method is the better value and recommended option for this project.
3.6 Concrete Removal & Replacement In order to minimize disturbance and vibration, concrete would be removed by saw cutting a grid like pattern over the entire surface area. Each grid would be approximately 5ft x 5ft, allowing removal with a standard fork lift. Each 5ft x 5ft section would be further processed outside the building using a hydraulic breaker, and then sent to a concrete recycler. Saw cutting creates large volumes of slurry, and this slurry would need to be collected using drum vacuums or similar wet vacuuming equipment.
After backfilling the excavation, new concrete would be installed using concrete pump equipment. The concrete would be doweled to the existing concrete and reinforced with wire mesh or rebar. Belfor has included costs to install a standard gloss sealant on all newly installed concrete surfaces.
3.7 Excavation & Backfilling Excavation equipment would consist of a mini-excavator, off-road fork lift, and three propane powered fork lifts with fork lift bins. The contaminated soils would be placed
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into the hopper and taken to a fully contained load out area (on the edge of the main containment area) using the off-road fork lift. The propane powered fork lifts would then pick up each bin and haul it outside through the fully contained load out area. This will help to ensure soils/dust from the excavation areas are not tracked outside of the excavation areas. Each area would be excavated to a depth of 8ft, with the soils around the column footers left for last. Contaminated soils would be placed on poly sheeting and covered at the end of each day. After characterization, the soils would be loaded and transported to a subtitle D Landfill for disposal as a non-hazardous waste.
After successful removal of the contaminated soils, clean compactable fill soil would be brought on-site, transported to the excavation areas using the fork lift bins, and then placed and compacted using a small loader and 52inch sheep’s foot compactor. For this report, Belfor has included costs for standard compaction testing during backfilling operations.
3.8 Building Restoration After all the concrete has been restored, all previously removed aboveground equipment, walls, and other obstructions would be restored to pre-project conditions. If possible, materials will be re-used for the restoration.
4.0 Budgetary Cost Estimate
Based on the proposed scope of work discussed in this constructability report, the tables below are an estimate of costs for this project.
4.1 Budgetary Cost Estimate Summary
Area Subtotal Overhead Costs* New Total Cafeteria 1&2 $895,185 $19,850 $915,035 Plant 3a $636,780 $17,650 $654,430 Plant 3b $498,040 $15,000 $513,040 Plant 4 $866,735 $19,700 $886,435 PROJECT $2,896,740 $72,200 $2,968,940 TOTAL *Please note that the overhead costs are not included in sections 4.2, 4.3, and 4.4. These costs are for project management, administration, and foundation support design.
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4.2 Cafeteria Areas 1&2 Item Description Quantity Unit Unit Price Total 1 Mobilization 1 EA $9,600 $9,600 2 Site Prep - Move Equipment 3 Day $3,850 $11,550 3 Site Prep - Building Access 1 Day $3,920 $3,920 4 Site Prep - Air Containment 3 Day $8,200 $24,600 5 Remove Concrete – 0.5ft thick 3015 SF $9 $27,135 6 Sheet Piling 20ft deep sheets 5640 SF $26 $146,640 Internal Column Supports - 7 Helical Piers - EA 7 EA $25,000 $175,000 Piano Key - External Footings - 8 Includes Flowable Fill 250 CY $331 $82,750 Excavate & Stockpile Soils 9 Outside 1340 TON $63 $84,420 10 Backfill & Compact Excavation 895 CY $150 $134,250 11 Restore Concrete – 0.5ft thick 56 SY $545 $30,520 Restore Building/Reinstall 12 Equipment 6 Day $9,350 $56,100 Load, Transport & Recycle 13 Concrete 56 CY $105 $5,880 Load, Transport, and Dispose of 14 Non-Hazardous Soil 1340 TON $67 $89,780 15 Cleanup and Demobilization 2 Day $6,520 $13,040 TOTAL $895,185
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4.3 Plant Area 3a
Item Description Quantity Unit Unit Price Total 1 Mobilization 1 EA $9,600 $9,600 2 Site Prep - Move Equipment 6 Day $3,850 $23,100 3 Site Prep - Building Access 1 Day $3,920 $3,920 4 Site Prep - Air Containment 5 Day $8,200 $41,000 5 Remove Concrete – 0.5ft thick 2340 SF $9 $21,060 6 Sheet Piling 20ft deep sheets 3560 SF $26 $92,560 Internal Column Supports - 7 Helical Piers - EA 5.5 EA $25,000 $137,500 Excavate & Stockpile Soils 8 Outside 1040 TON $63 $65,520 9 Backfill & Compact Excavation 695 CY $150 $104,250 10 Restore Concrete – 0.5ft thick 44 Y $545 $23,980 Restore Building/Reinstall 11 Equipment 7 Day $3,850 $26,950 Load, Transport & Recycle 12 Concrete 44 CY $105 $4,620 Load, Transport, and Dispose of 13 Non-Hazardous Soil 1040 TON $67 $69,680 14 Cleanup and Demobilization 2 Day $6,520 $13,040 TOTAL $636,780
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4.4 Plant Area 3b Item Description Quantity Unit Unit Price Total 1 Mobilization 1 EA $9,600 $9,600 2 Site Prep - Move Equipment 4 Day $3,850 $15,400 3 Site Prep - Building Access 1 Day $3,920 $3,920 4 Site Prep - Air Containment 4 Day $8,200 $32,800 5 Remove Concrete – 0.5ft thick 2030 SF $9 $18,270 6 Sheet Piling 20ft deep sheets 2560 SF $26 $66,560 Internal Column Supports - 7 Helical Piers - EA 3.5 EA $25,000 $87,500 Excavate & Stockpile Soils 8 Outside 900 TON $63 $56,700 9 Backfill & Compact Excavation 600 CY $150 $90,000 10 Restore Concrete – 0.5ft thick 38 SY $545 $20,710 Restore Building/Reinstall 11 Equipment 5 Day $3,850 $19,250 Load, Transport & Recycle 12 Concrete 38 CY $105 $3,990 Load, Transport, and Dispose of 13 Non-Hazardous Soil 900 TON $67 $60,300 14 Cleanup and Demobilization 2 Day $6,520 $13,040 TOTAL $498,040
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4.5 Plant Area 4 Item Description Quantity Unit Unit Price Total 1 Mobilization 1 EA $9,600 $9,600 2 Site Prep - Move Equipment 3 Day $3,850 $11,550 3 Site Prep - Building Access 1 Day $3,920 $3,920 4 Site Prep - Air Containment 5 Day $8,200 $41,000 5 Remove Concrete – 0.5ft thick 3625 SF $9 $32,625 6 Sheet Piling 20ft deep sheets 5100 SF $26 $132,600 Internal Column Supports - 7 Helical Piers - EA 6 EA $25,000 $150,000 Piano Key - External Footings - 8 Includes Flowable Fill 60 CY $331 $19,860 Excavate & Stockpile Soils 9 Outside 1613 TON $63 $101,619 10 Backfill & Compact Excavation 1075 CY $150 $161,250 11 Restore Concrete – 0.5ft thick 68 CY $545 $37,060 Restore Building/Reinstall 12 Equipment 4 Day $9,350 $37,400 Load, Transport & Recycle 13 Concrete 68 CY $105 $7,140 Load, Transport, and Dispose of 14 Non-Hazardous Soil 1613 TON $67 $108,071 15 Cleanup and Demobilization 2 Day $6,520 $13,040 TOTAL $866,735
5.0 Project Duration Please see attachment C for a schedule of project durations
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ID Task Name Duration Start Finish y 1, '11 May 8, '11 May 15, '11 May 22, '11 May 29, '11 Jun 5, '11 Jun 12, '11 Jun 19, '11 Jun 26, '11 Jul 3, '11 Jul 10, '11 M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T 1 Cafeteria Areas 1&2 54 days Mon 5/2/11 Thu 7/14/11
2 Mobilization 1 day Mon 5/2/11 Mon 5/2/11
3 Site Prep - Move Equipment 3 days Tue 5/3/11 Thu 5/5/11
4 Site Prep - Building Access 1 day Tue 5/3/11 Tue 5/3/11
5 Site Prep - Air Containment 3 days Fri 5/6/11 Tue 5/10/11
6 Remove Concrete 4 days Wed 5/11/11 Mon 5/16/11
7 Sheet Piling 20ft deep sheets 7 days Wed 5/11/11 Thu 5/19/11
8 Internal Column Supports - Helical Piers 11 days Wed 5/11/11 Wed 5/25/11
9 Piano Key - External Footingsl 6 days Thu 5/26/11 Thu 6/2/11
10 Excavate & Stockpile Soils Outside 9 days Fri 6/3/11 Wed 6/15/11
11 Backfill & Compact Excavation 10 days Thu 6/16/11 Wed 6/29/11
12 Restore Concrete 3 days Thu 6/30/11 Mon 7/4/11
13 Restore Building/Reinstall Equipment 6 days Tue 7/5/11 Tue 7/12/11
14 Load, Recycle Concrete 1 day Tue 5/17/11 Tue 5/17/11
15 Load, T&D Non-Haz Waste 3 days Thu 6/16/11 Mon 6/20/11
16 Cleanup and Demobilization 2 days Wed 7/13/11 Thu 7/14/11
Task Progress Summary External Tasks Deadline Project: Task Durations - Caf 1&2 Date: Fri 3/11/11 Split Milestone Project Summary External Milestone
Page 1 ID Task Name Duration Start Finish y 1, '11 May 8, '11 May 15, '11 May 22, '11 May 29, '11 Jun 5, '11 Jun 12, '11 Jun 19, '11 Jun 26, '11 Jul 3, '1 M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T 1 Plant 3a 46.2 days Mon 5/2/11 Tue 7/5/11
2 Mobilization 1 day Mon 5/2/11 Mon 5/2/11
3 Site Prep - Move Equipment 6 days Tue 5/3/11 Tue 5/10/11
4 Site Prep - Building Access 1 day Tue 5/3/11 Tue 5/3/11
5 Site Prep - Air Containment 5 days Wed 5/11/11 Tue 5/17/11
6 Remove Concrete 3 days Wed 5/18/11 Fri 5/20/11
7 Sheet Piling 20ft deep sheets 5 days Wed 5/18/11 Tue 5/24/11
8 Internal Column Supports - Helical Piers 8 days Wed 5/18/11 Fri 5/27/11
9 Excavate & Stockpile Soils Outside 7 days Mon 5/30/11 Tue 6/7/11
10 Backfill & Compact Excavation 8 days Wed 6/8/11 Fri 6/17/11
11 Restore Concrete 2.2 days Mon 6/20/11 Wed 6/22/11
12 Restore Building/Reinstall Equipment 7 days Wed 6/22/11 Fri 7/1/11
13 Load, Recycle Concrete 1 day Mon 5/23/11 Mon 5/23/11
14 Load, T&D Non-Haz Waste 2 days Wed 6/8/11 Thu 6/9/11
15 Cleanup and Demobilization 2 days Fri 7/1/11 Tue 7/5/11
Task Progress Summary External Tasks Deadline Project: Task Durations - Plant 3a Date: Fri 3/11/11 Split Milestone Project Summary External Milestone
Page 1 ID Task Name Duration Start Finish 1, '11 May 8, '11 May 15, '11 May 22, '11 May 29, '11 Jun 5, '11 Jun 12, '11 Jun 19, '11 M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T 1 Plant 3a 36.5 days Mon 5/2/11 Tue 6/21/11
2 Mobilization 1 day Mon 5/2/11 Mon 5/2/11
3 Site Prep - Move Equipment 4 days Tue 5/3/11 Fri 5/6/11
4 Site Prep - Building Access 1 day Tue 5/3/11 Tue 5/3/11
5 Site Prep - Air Containment 4 days Mon 5/9/11 Thu 5/12/11
6 Remove Concrete 3 days Fri 5/13/11 Tue 5/17/11
7 Sheet Piling 20ft deep sheets 3.5 days Fri 5/13/11 Wed 5/18/11
8 Internal Column Supports - Helical Piers 5.5 days Fri 5/13/11 Fri 5/20/11
9 Excavate & Stockpile Soils Outside 6 days Fri 5/20/11 Mon 5/30/11
10 Backfill & Compact Excavation 7 days Mon 5/30/11 Wed 6/8/11
11 Restore Concrete 2 days Wed 6/8/11 Fri 6/10/11
12 Restore Building/Reinstall Equipment 5 days Fri 6/10/11 Fri 6/17/11
13 Load, Recycle Concrete 1 day Wed 5/18/11 Wed 5/18/11
14 Load, T&D Non-Haz Waste 2 days Mon 5/30/11 Wed 6/1/11
15 Cleanup and Demobilization 2 days Fri 6/17/11 Tue 6/21/11
Task Progress Summary External Tasks Deadline Project: Task Durations - Plant 3b Date: Fri 3/11/11 Split Milestone Project Summary External Milestone
Page 1 ID Task Name Duration Start Finish y 1, '11 May 8, '11 May 15, '11 May 22, '11 May 29, '11 Jun 5, '11 Jun 12, '11 Jun 19, '11 Jun 26, '11 Jul 3, '11 Jul 10, '11 M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T F S S M T W T 1 Cafeteria Areas 1&2 53.5 days Mon 5/2/11 Thu 7/14/11
2 Mobilization 1 day Mon 5/2/11 Mon 5/2/11
3 Site Prep - Move Equipment 3 days Tue 5/3/11 Thu 5/5/11
4 Site Prep - Building Access 1 day Tue 5/3/11 Tue 5/3/11
5 Site Prep - Air Containment 5 days Fri 5/6/11 Thu 5/12/11
6 Remove Concrete 5 days Fri 5/13/11 Thu 5/19/11
7 Sheet Piling 20ft deep sheets 6.5 days Fri 5/13/11 Mon 5/23/11
8 Internal Column Supports - Helical Piers 9 days Fri 5/13/11 Wed 5/25/11
9 Piano Key - External Footingsl 3 days Thu 5/26/11 Mon 5/30/11
10 Excavate & Stockpile Soils Outside 11 days Tue 5/31/11 Tue 6/14/11
11 Backfill & Compact Excavation 12 days Wed 6/15/11 Thu 6/30/11
12 Restore Concrete 3.5 days Fri 7/1/11 Wed 7/6/11
13 Restore Building/Reinstall Equipment 4 days Wed 7/6/11 Tue 7/12/11
14 Load, Recycle Concrete 1 day Fri 5/20/11 Fri 5/20/11
15 Load, T&D Non-Haz Waste 3.5 days Wed 6/15/11 Mon 6/20/11
16 Cleanup and Demobilization 2 days Tue 7/12/11 Thu 7/14/11
Task Progress Summary External Tasks Deadline Project: Task Durations - Plant 4 Date: Fri 3/11/11 Split Milestone Project Summary External Milestone
Page 1 Moen Incorporated 2609 Cox Mill Road, Sanford, NC July 2011
ATTACHMENT D – NCDENR ELECTRONIC MAIL DATED 24 MAY 2011
Remedial Action Plan From: Assefa, Hanna [mailto:[email protected]] Sent: Tuesday, May 24, 2011 03:19 PM To: Macdonald, Janet K
Janet, the industrial commercial preliminary remediation goals are Mercury 6.8 (N ), Manganese 4.6 E+03(N ), Hexavalent Chromium 5.6 (C ). For arsenic the PRG is 1.6 ppm(C ), However, since we allow 4.6 ppm for residential based on background concentrations we also allow the 4.6(N) for arsenic. The REC guidance describes adjustments possible in the appendix.
From: Macdonald, Janet K Sent: Thursday, May 19, 2011 8:27 AM To: Assefa, Hanna Cc: Montgomery Bennett Subject: RE: Moen Sanford, NC
Thanks so much, Hanna.
They still need Commercial/Industrial direct‐contact standards for arsenic, mercury, manganese, and hexavalent chromium in soil.
Janet
Janet Macdonald Phone: (919) 508-8446
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Assefa, Hanna Sent: Wednesday, May 18, 2011 3:43 PM To: Macdonald, Janet K Cc: Caulk, Kim Subject: RE: Moen Sanford, NC
Janet if numbers are currently or in the future unavailable they should look at the chemical similarities of the other constituents in groundwater at the site that have standards. If they are similar the remediation system that they implement is going to be the same so they can proceed till a standard is calculated. If let us say all the chemicals with standards do not exceed standards and the chemicals without standards are the only drivers for groundwater issue at the site – I would suggest comparing concentrations to reporting limits (pql) if concentrations are lower‐ request standards be calculated with the annual group. If higher mark them as urgent explaining why they are urgent. There will be times I will not be able to calculate a standard due to lack of tox data or other criteria. In that situation the standard becomes the pql.
From: Macdonald, Janet K Sent: Wednesday, May 18, 2011 1:47 PM To: Assefa, Hanna Cc: Montgomery Bennett Subject: FW: Moen Sanford, NC
A request for soil industrial health‐based goals and a few groundwater goals (see below). I understand that groundwater standards (IMACs) are only calculated once per year. If numbers are currently unavailable can you advise on what they should use in the meantime?
Thanks,
Janet
Janet Macdonald Phone: (919) 508-8446
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Montgomery Bennett [mailto:[email protected]] Sent: Tuesday, May 17, 2011 3:41 PM To: Macdonald, Janet K Cc: Jonathan Waddell Subject: Moen Sanford, NC
Janet:
As we discussed today, I would like the REC program to provide appropriate remediation goals for the following media and constituents:
SOIL - Commercial/Industrial direct-contact standards for arsenic, mercury, manganese, and hexavalent chromium; and GROUNDWATER remediation goals for 1,2,3-trichlorobenzene, 2-ethyl-1-hexanol, 2-ethyl- hexanal, 2-octanone, bromochloromethane, chlorodibromomethane, cyclohexane, methyl acetate, and methylcyclohexane.
Again, thank you for your time and consideration regarding the other issues we discussed.
Monty
Montgomery S. Bennett, P.G. Senior Project Manager Groundwater & Environmental Services, Inc. 23 South 13th Street, Suite 201 Richmond, Virginia 23219 Phone 866-222-7786 , Ext. 3771 Fax (804) 343-0770 Cell (804) 467-8572 [email protected]
Confidentiality Notice: This transmission (including any attachments) may contain confidential information belonging to Groundwater & Environmental Services, Inc. and is intended only for the use of the party or entity to which it is addressed. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, retention or the taking of action in reliance on the contents of this transmission is strictly prohibited. If you have received this transmission in error, please immediately notify the sender and erase all information and attachments. Thank You. Moen Incorporated 2609 Cox Mill Road, Sanford, NC July 2011
ATTACHMENT E – IN SITU CHEMICAL OXIDATION HEALTH AND SAFETY PLAN ADDENDUM
Remedial Action Plan
IN SITU CHEMICAL OXIDATION HEALTH & SAFETY PLAN ADDENDUM
Prepared for:
Moen Incorporated 2609 Cox Mill Road Sanford, North Carolina
Prepared by: Groundwater & Environmental Services, Inc. 23 South 13th Street, Suite 201 Richmond, VA
JULY 2011 HASP Addendum Moen Incorporated July 2011
TABLE OF CONTENTS
1.0 INTRODUCTION ...... 1
1.1 OBJECTIVES ...... 1 1.2 SCOPE OF WORK...... 1
2.0 ROLES AND RESPONSIBILITIES...... 2
2.1 PROJECT MANAGER...... 2 2.2 HEALTH AND SAFETY DIRECTOR...... 2 2.3 SITE SAFETY OFFICER ...... 3 2.4 FIELD PERSONNEL ...... 3 2.5 INCIDENT AND ACCIDENT INVESTIGATION ...... 4
3.0 HAZARD COMMUNICATION ...... 5
3.1 MATERIAL SAFETY DATA SHEETS...... 5 3.2 TRAINING REQUIREMENTS...... 5 3.2.1 Daily Tailgate Safety Meetings ...... 5 3.2.2 Pre-entry Briefing ...... 6
4.0 PROJECT HAZARD ANALYSIS ...... 7
4.1 JOB SAFETY ANALYSIS AND ACTIVITY HAZARD ANALYSIS ...... 7 4.2 CHEMICAL HAZARDS...... 8 4.2.1 Contaminants of Concern ...... 8 4.2.2 Sodium Persulfate ...... 9
4.2.3 Hydrogen Peroxide (H2O2) ...... 9 4.3 COMPRESSED FLUIDS ...... 10
5.0 PERSONAL PROTECTIVE EQUIPMENT...... 11
5.1 LEVEL D...... 11 5.2 MODIFIED LEVEL C ...... 11 5.3 LEVEL C ...... 12
6.0 HAZARD CONTROLS ...... 13
6.1 CHEMICAL OXIDANT SOLUTIONS ...... 13 6.2 NEUTRALIZATION SOLUTIONS ...... 13 6.3 LOCK OUT/TAG OUT PROGRAM ...... 13 6.4 TRAFFIC CONTROL ...... 14 6.5 MOVING EQUIPMENT AND VEHICLES ...... 14 6.6 PREFERENTIAL PATHWAY MONITORING...... 14 6.7 NIGHT AND DUSK OPERATIONS ...... 15 6.8 HEAT STRESS...... 15 6.9 BUDDY SYSTEM...... 15
7.0 SPILL PREVENTION PLAN ...... 16
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TABLES Table 4-1 Chemical Hazard Summary Table 5-1 Activity-Specific PPE Requirements
APPENDICES Appendix A Activity Hazard Analyses (AHAs) Appendix B Near Loss Incident / Loss Incident Investigation Report Form Appendix C Klozur Documentation Appendix D Lock-Out Tag-Out Policy and Permit
ACRONYMS AND ABBREVIATIONS AHA Activity Hazard Analysis ANSI American National Standards Institute APR Air Purifying Respirator COCs Contaminants of Concern DOT Department of Transportation GES Groundwater and Environmental Services, Inc. HASP Health and Safety Plan HASPA Health and Safety Plan Addendum H2O2 Hydrogen Peroxide HSD Health and Safety Director ISCO In-Situ Chemical Oxidation JSA Job Safety Analysis MSDS Material Safety Data Sheet NIOSH National Institute for Occupational Safety and Health PM Project Manager PPE Personal Protective Equipment SPP Spill Prevention Plan SSO Project Site Safety Officer Wt Weight
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1.0 Introduction
This Health and Safety Plan Addendum (HASPA) contains protocols for field activities to be completed during the in-situ chemical oxidation (ISCO) treatment of soil and groundwater using sodium persulfate and hydrogen peroxide (H2O2) at the Moen Incorporated facility (the site) located at 2609 Cox Mill Road in Sanford, NC. The ISCO treatment at the facility entails the co-injection of sodium persulfate and H2O2 (as an activation agent) to destroy site contaminants of concern (COCs) within the vadose zone and the underlying shallow groundwater hydrostratigraphic unit (i.e., sand channel).
The activities and procedures associated with ISCO are described in further detail within Section 5.0 of the Remedial Action Plan (RAP). This HASPA supplements the Health and Safety Plan for the site, as provided in Attachment B to the RAP.
1.1 Objectives
The purpose of this HASPA is to establish safe working conditions and protocols to be followed when undertaking activities related to ISCO at the site. The health and safety procedures presented in this HASPA have been established based on Job Safety Analyses (JSAs) (see Attachment B of RAP) and Activity Hazard Analyses (AHAs) of the activities to be performed during mixing and subsurface injection activities (see Appendix A).
This HASPA establishes personal protective equipment (PPE) requirements, summarizes safe operating procedures, and outlines response procedures for activities associated specifically with the mixing and subsurface injection of persulfate and H2O2. This HASPA will be available on site for use by field workers, supervisors, and any regulatory representatives.
All project personnel will be required to review and follow the procedures and protocols as specified in this addendum. All project personnel will also be required to sign an acknowledgement of compliance prior to beginning work on site.
1.2 Scope of Work
The scope of work is detailed in Section 5.0 of the RAP. The injection events will be phased, with the first phase commencing in the cafeteria (former Tool Room). The first phase of ISCO is anticipated to last for approximately 2- to 3-weeks, followed by several months of performance monitoring. ISCO within the remaining areas will be conducted as part of the second phase and is expected to last 4- to 6-weeks.
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2.0 Roles and Responsibilities
The implementation of health and safety at the site will be the shared responsibility of the Project Manager (PM), the Health and Safety Director (HSD), the Project Site Safety Officer (SSO), and all other on-site field personnel. The roles and responsibilities of site personnel regarding health and safety are described below.
2.1 Project Manager
The PM is, by designation, the individual who has the primary responsibility for ensuring the overall health and safety of the project. The PM therefore has the primary responsibility for ensuring the implementation of the requirements of this HASPA. Specific responsibilities of the PM include:
Providing the HSD with updated data regarding the types and extent of activities at the Site;
Assuring that all personnel to whom this HASPA applies have received a copy and have submitted a completed copy of the HASPA sign-off form;
Assuring that all personnel submit documentation of the medical surveillance and training requirements specified in the project HASPA;
Assuring that all personnel to whom this HASPA applies have attended a pre- entry briefing prior to entering an exclusion zone;
Maintaining a high level of health and safety consciousness among employees at the work site; and
Maintaining regular communications with the SSO and, if necessary, the HSD.
2.2 Health and Safety Director
The HSD is the individual responsible for the overall preparation, interpretation and where appropriate, modification of this HASPA. Modifications to this HASPA which may result in less stringent precautions cannot be undertaken by the PM or the SSO without the approval of the HSD. Specific responsibilities of the HSD include:
Reviewing, approving and amending this HASPA;
Advising the PM and SSO on matters relating to health and safety on this site;
Recommending appropriate PPE;
Conducting accident investigations; and
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Maintaining regular contact with the PM and SSO to evaluate site conditions and new information which might require modifications to the HASPA.
2.3 Site Safety Officer
The SSO, appointed by the PM, will be on-site during the ISCO activities covered by this HASPA. The SSO is responsible for enforcing the requirements of this HASPA once on- site work begins. By design, the SSO has the authority, and the responsibility, to immediately correct all situations where noncompliance with this HASPA is noted and to instantaneously stop work in cases where an immediate danger is perceived. Specific responsibilities of the SSO include:
Procuring and distributing the PPE appropriate for ISCO activities;
Verifying that all PPE and health and safety equipment is in good working order;
Setting up and maintaining the contamination reduction zone within the exclusion areas, and assuring proper decontamination of all site personnel and equipment;
Notifying the PM and HSD of all noncompliance situations, and stopping work in the event that an immediate danger situation is perceived;
Assisting with accident/incident investigations and preparing accident/incident investigation reports;
Conducting the exclusion zone pre-entry briefing;
Conducting the daily Tailgate Safety Meetings (TSMs); and
Initiating emergency response procedures.
2.4 Field Personnel
The field personnel, regardless of affiliation, have the responsibility, and the authority, to immediately stop work in cases where an immediate danger is perceived. Field personnel have the responsibility, and the authority, to immediately identify and communicate to the SSO all situations where noncompliance with this HASPA is noted.
All field personnel are covered by this HASPA, and are responsible for following the health and safety procedures specified in this HASPA, and for performing their work in a safe and responsible manner. Some of the specific responsibilities of the field personnel are as follows:
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Reading the GES site-specific HASP and this HASPA in their entirety prior to the start of on-site work;
Signing the HASPA Acknowledgement Form, and providing documentation of medical surveillance and training to the PM prior to the start of work;
Attending the required exclusion zone pre-entry briefing prior to beginning on- site work;
Bringing forth any questions or concerns regarding the content of the HASPA to the PM or the SSO prior to the start of work;
Reporting all accidents, injuries and illnesses, regardless of their severity, to the SSO; and
Complying with the requirements of this HASPA and the requests of the SSO.
2.5 Incident and Accident Investigation
In the event of any injury or accident, emergency medical services (dial 911) will be called to assess injured parties and provide medical assistance (if necessary). All incidents will be investigated. An incident is defined as per the Loss Prevention System (LPS). The SSO is to complete the initial portion of LPS Near Loss Incident (NLI) / Loss Incident (LI) Investigation Report form (see Appendix B) and either the PM or the HSD as soon as practical or by the end of the work shift.
The report will be reviewed by the PM and the HSD to evaluate the root cause of the accident. Activity hazard analyses and job safety analyses will be reviewed and updated to reflect any changed conditions or improved procedures. The PM, HSD, and SSO will report to the site prior to restarting work.
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3.0 Hazard Communication
The objective of the hazard communication program is to:
Effectively disseminate pertinent information on the safe handling of hazardous chemicals in the work place and on the job site; and
Inform all personnel of their rights and responsibilities under the OSHA Hazard Communication Standard.
The HAZCOM program is administered by the HSD and complies with the requirements of the OSHA Hazard Communication (HAZCOM) Standards in 29 CFR 1910.120 and 1926.59.
3.1 Material Safety Data Sheets
Copies of example material safety data sheets (MSDS) for hazardous substances that may be encountered by field personnel were obtained from the manufacturer. All site workers will review the MSDS prior to working at the site. Example MSDSs for these compounds are provided in Attachment C of the HASP (see Attachment B of the RAP).
The SSO will review the MSDS for all incoming shipments and review for consistency with the AHA. The example MSDSs (see Attachment C of the HASP) will be updated with the MSDSs supplied with chemicals as they are delivered at the site and filed in the HASP.
All affected employees will be briefed on the hazards and allowed to review the MSDS.
3.2 Training Requirements
All site personnel working on the project will have:
Met the OSHA (29 CFR 1910.120) initial classroom training requirements of 40 hours of instruction and annual 8-hour refresher training; and
Completed at least 3 days of on-the-job training for their job under a trained and experienced supervisor.
3.2.1 Daily Tailgate Safety Meetings
Daily safety meetings will be conducted and documented by the SSO at the beginning of each shift, or whenever new employees arrive at the job site once the project work commences. Health and safety considerations for the day’s activities will be discussed, and the PPE necessary will be outlined. These meetings will be documented in the
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project files using the Pre Entry Meeting Notes and the Site Safety Checklist included in the HASP (see Attachment B to the RAP).
3.2.2 Pre-entry Briefing
All staff working within the work zone shall attend a pre-entry briefing given by the SSO. The briefing shall review PPE, chemical hazards, operational procedures and limits, site control, and emergency response procedures.
This briefing does not replace review and comprehension of Section 5.0 of the RAP, the HASP (see Attachment B of the RAP), and the HASPA. The pre-entry briefing will be documented on the form included in the HASP. All on-site personnel, including subcontractors, will read and become familiar with the site-specific HASP and HASPA. Agreement to abide by the elements of the plan is indicated by each person’s signature on the Health and Safety Plan Approval/Sign Off.
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4.0 Project Hazard Analysis
This section describes the project hazard analysis for specific tasks related to ISCO at the Site. The project hazard analysis entails JSAs, AHAs, chemical hazards summary, and PPE summary. The project hazard analysis presented in this HASP should be reviewed by GES field personnel prior to undertaking any field task.
4.1 Job Safety Analysis and Activity Hazard Analysis
The JSA/AHA process is used to identify potential safety, health, and environmental hazards that may be encountered by field personnel when undertaking a particular task. The JSA/AHA is employed to protect personnel, the community, and the environment through description of the work involved, the specific hazards that will be potentially encountered, and the control measures that will be utilized to minimize or eliminate each hazard. The JSAs are located in Attachment D of the HASP (see Attachment B of the RAP) and include the following:
General Site Activities (JSA #028); General Site Activities (Dusk and Night Work) (JSA #029); Air Sparging – Vapor Extraction (JSA #005); Drilling (Core Drill) (JSA #094); Drilling – Soil Boring – Monitoring Well Installation (JSA #019); Drum Sampling – Evaluation (JSA #022); Gauging Liquid Levels in GW Monitoring Wells (JSA #027); Groundwater Sampling (JSA # 032); Hand Auger Use (Soil Sampling) (JSA #035); Hydrogen Peroxide Test Kit Use (JSA #125); Monitoring well development (Utilizing Waterra Pump) (JSA #078); O&M (JSA #038); Peroxide and Ozone Injection (JSA #044); Portable generator use (JSA #053); Pressure Washer (JSA #048); Private markout – Site Survey (JSA #049); Remediation System Installation and System Piping Leak Check (JSA #054); Remediation System Equipment Removal and Installation (JSA #055); Site Survey (JSA #057); Sodium persulfate injection (JSA #092); Sodium persulfate – Hydrogen peroxide combined injection (JSA #100); Soil drumming (JSA #060); and Deliveries and Pick-ups (JSA #016).
AHAs are located in Appendix A and include the following:
Task 1 - Mix Equipment Set Up;
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Task 3 - Set-up: Connection to Wells; Task 4 – Chemical Oxidant Injection and Process Monitoring; Task 5 - Equipment Demobilization and Decontamination; and Task 6 - Emergency Response Procedures.
All field personnel have the right and duty to immediately stop work when conditions are unsafe, when established safety procedures are being disregarded, or whenever work conditions present an immediate uncontrolled risk of injury or illness.
4.2 Chemical Hazards
In addition to COCs found in soil and groundwater, several chemical compounds will be utilized on site during ISCO. The primary chemical compounds that will be encountered by field personnel during the injection are:
Sodium persulfate; H2O2; and Neutralization compounds.
Example MSDSs for these compounds can be found in Attachment C of the HASP (See Attachment B of the RAP). Final MSDSs will be obtained from the chemical suppliers on receipt of the chemicals at the job-site.
4.2.1 Contaminants of Concern
At the site, field personnel may encounter COCs when handling site groundwater. The COCs identified within the vadose zone and shallow groundwater include:
o Chlorinated ethanes including parent compounds 1,1,1-trichloroethane (TCA) and 1,1,2-TCA, and reductive dechlorination daughter products 1,1-dichloroethane (DCA), 1,2-DCA, 1,1-dichloroethene (DCE), and chloroethane;
o Chlorinated ethenes including parent compounds tetrachloroethene (PCE) and trichloroethene (TCE), and reductive dechlorination daughter products cis 1,2- DCE, trans 1,2-DCE, and vinyl chloride;
o Solvent stabilizer 1,4-dioxane; and
o Low concentrations of additional VOCs (methylene chloride, benzene) and metals (beryllium, cadmium, chromium, lead, manganese, and nickel).
Procedures for handling impacted groundwater and the required PPE are found in the site-specific HASP (see Attachment B to the RAP).
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4.2.2 Sodium Persulfate
Upon injection, sodium persulfate dissociates into sodium and the persulfate anion. The persulfate anion is a strong, moderate-stable, non-selective oxidizer but is kinetically- slow. Skin and eye protection should be worn at all times when handling this oxidant, which is highly corrosive at a pH of around 2.0 standard units. Upon activation (via naturally-occurring ferrous iron or H2O2), highly-reactive, kinetically-fast sulfate-free radicals may be produced.
Prior to injection, sodium persulfate will be delivered by FMC Corporation as a white, crystalline powder to the site in 55-pound bags, drums, or supersacks. Powdered sodium persulfate will be stored in a cool, dry storage area. No persulfate will be stored in a closed, sealed container as over pressurization (due to oxygen generation) may occur. Also, persulfate is not to be stored near heat, moisture, direct sunlight, or incompatible materials including reducing agents (e.g., sawdust, powdered metals, and alcohols), acids, bases, ammonia-containing solutions, or alkaline cleaners. Further detail is provided in Appendix C.
Diluted persulfate solutions (between 5- to 50-grams per liter) will be prepared on-site using powdered persulfate and tap water, and used on the day of preparation. Plastic or stainless steel scoops will be used to remove persulfate from its container. All persulfate handling and transfer equipment should be constructed of compatible materials (e.g., 304 and 316 SS, PVC, polyethylene, Teflon® resin, or Plexiglas®). Metals other than 304 and 316 SS may cause decomposition of persulfate solutions or may be corroded by them, particularly aluminum, carbon steel, galvanized steel, nitrile, brass, copper, iron, Monel, or nickel. Following injection, any remaining persulfate will be diluted and injected into the subsurface. No persulfate will be disposed of improperly in trash cans.
The appropriate PPE to be used when working with this material is summarized in the JSAs (see Attachment D to the HASP), AHAs (see Appendix A), and Section 5.0. Some characteristic properties of persulfate and possible symptoms of exposure are summarized in Table 4-1. The example MSDS for sodium persulfate is located in Attachment C of the HASP.
4.2.3 Hydrogen Peroxide (H2O2)
H2O2 is a stable, moderate-strength oxidizer, which is kinetically-slow and an eye/skin irritant. H2O2 solutions are clear with a slight, characteristic odor. During the H2O2 injection event, H2O2 will be present on-site as an 18% (maximum) solution. During ISCO, H2O2 will be co-injected simultaneously with persulfate as an 8% (wt) liquid solution. This concentration of H2O2 should prevent excessive heat and gas generation in the subsurface. Temperature and back pressure is to be monitored during H2O2 injection to prevent excessive heat.
H2O2 is not compatible with other oxidizers, select metals (silver, lead, chromium, copper, mercury, and iron), or nitrates, and should never be stored in close proximity with
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sodium persulfate. H2O2 will be stored in a cool, ventilated area away from sunlight and combustibles.
The appropriate PPE to be used when working with this material is summarized in the JSAs/AHAs. Eye protection (chemical splash-type monogoggles and full-face shield) and skin protection (rubber or neoprene footwear, impervious clothing materials) should be worn when handling this material. Some characteristic properties of H2O2 and possible symptoms of exposure are summarized in Table 4-1. The preliminary MSDS for H2O2 solutions are located in Attachment C of the HASP.
4.3 Compressed Fluids
Sodium persulfate and H2O2 will be co-injected simultaneously into the subsurface (via direct-push technology or dedicated injection wells) as a compressed solution. Compressed fluids contained stored physical energy. Therefore, connection and disconnection of process lines has the potential to release the stored energy. Control of stored energy is performed using Lock Out/Tag Out (LO/TO) procedures discussed in Section 6.0. The control of stored energy is regulated by 29 CFR 1910.147.
Stored physical energy can be converted to kinetic energy, which causes hoses to whip or contents of to be sprayed. Whip potential will be controlled by using tie-downs for chemical hose connections. The size and weight of hose and maximum pressure of 40 pounds per square inch (PSIG) limit the potential for whip. The lock out/tag out procedures includes an energy control plan that addresses pressure measurement, pressure relief, and verification prior to opening process lines.
TABLE 4-1 – CHEMICAL HAZARD SUMMARY Chemical Compound Form Appearance Irritant Eye: May cause irritation Skin: May cause irritation Liquid Ingestion: low oral toxicity, may Sodium Persulfate Clear to milky color Solution cause irritation Inhalation: Dust may cause breathing difficulty or discomfort Eye: Extreme irritation Skin: May cause irritation Hydrogen Peroxide Liquid Clear, colorless Ingestion: gastrointestinal (H2O2) Solution distress Inhalation: Extreme irritant to nose, throat, and lungs
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5.0 Personal Protective Equipment
The required level of PPE to be utilized during the injection is specific to the activity being conducted. All activities completed will require at least Level D PPE. Additional details concerning task-specific PPE requirements can be found in the corresponding JSAs (see Attachment D of the HASP) and AHAs (see Appendix A). The PPE requirements are also summarized in Table 5-1 for general injection activities.
The PPE requirements established in this HASPA are subject to modification based on progress/results of site activities. Upgrades or downgrades in PPE levels are customarily verbally communicated between site personnel.
5.1 Level D
Standard Level D PPE includes:
Standard work uniform or coveralls; ANSI-approved, steel-toed work boots; ANSI-approved safety glasses with side shields; ANSI-approved hard hat; Leather-palmed gloves; Nitrile gloves, if liquids are encountered; Hearing protection (if necessary) providing 25 dBA or greater protection; and Reflective traffic vests.
Tasks to be undertaken during ISCO that require Level D PPE include mix equipment set up, and equipment decontamination and demobilization.
5.2 Modified Level C
Modified Level C PPE includes:
Chemical splash-rated coveralls in addition to standard work uniform or coveralls; ANSI-approved, steel-toed work boots; ANSI-approved, steel-toed PVC work boots, if liquids are encountered; Leather-palmed gloves; Nitrile gloves (11 mil), if liquids are encountered; Goggles and a face shield; A dust mask when transferring water from holding tanks into mixing tanks, mixing persulfate, and while managing persulfate in powdered form; Hearing protection (if necessary) providing 25 dBA or greater protection; ANSI-approved safety glasses with side shields and splash shield (if necessary), or goggles; ANSI-approved hard-hat; and Reflective traffic vests.
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Tasks to be undertaken during ISCO that require modified Level D PPE include mixing of the sodium persulfate and H2O2 solutions, during pressurized injection, and during any neutralization or spill response activities.
5.3 Level C
Respiratory protection will include an air-purifying respiratory with acid mist cartridge and will be available as necessary. However, respiratory protection is not expected to be used during this project. Engineering controls are not feasible for the work since it is temporary in nature. The respiratory protection requirements found in 29 CFR 1910.134 and the GES Health and Safety Policies shall be followed. If the use of a respirator is deemed necessary, all site personnel will evacuate the work area until air quality within the work area returns to acceptable levels.
TABLE 5-1 – ACTIVITY-SPECIFIC PPE REQUIREMENTS Task Activity Initial PPE Required Mobilization/Demobilization All Level D Delivery and Storage of All Modified Level C Hazardous Chemicals Chemical All Modified Level C Handling/Mixing/Injection Spill response in chemical storage Modified Level C Spill/Emergency Response area Spill response in injection area Modified Level C Decontamination of Equipment All Modified Level C Waste Management All Modified Level C
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6.0 Hazard Controls
This portion of the HASPA addresses health and safety requirements for activities related to handling each chemical that will be used during ISCO. All field activities involving chemical handling will be conducted by authorized personnel only. This portion of the HASPA also addresses additional pertinent hazards associated with the field activities such as LOTO, moving equipment hazards, and traffic safety.
6.1 Chemical Oxidant Solutions
Field personnel will encounter various concentrations of sodium persulfate and H2O2 solutions during injection activities. All solutions should be assumed to be concentrated, unless testing indicates otherwise. Modified Level C PPE, as described in Section 5.0, is required when handling solutions of sodium persulfate and H2O2.
6.2 Neutralization Solutions
Should a spill occur, in addition to neutralization solutions detailed below, personnel should wear neoprene gloves, and either rubber or PVC boots in addition to the poly- coated Tyvek suit. If a spill of persulfate crystals, water should be used to dissolve and dilute the crystals. Rinse water should also be used to fully dilute any surface releases of sodium persulfate combined with hydrogen peroxide. Between 200- to 500-gallons of rinse water is recommended to be stored on-site for this purpose.
6.3 Lock out/Tag out Program
Sodium persulfate and H2O2 will be co-injected into the subsurface as compressed fluids via direct-push technology or dedicated injection wells. Compressed fluids contain stored physical energy. Therefore, connection and disconnection of process lines has the potential to release the stored energy. Control of stored energy is performed using Lock Out/Tag Out (LO/TO) procedures. The control of stored energy is regulated by 29 CFR 1910.147 and the GES LO/TO Program.
The energy control procedures are as follows. Energized systems are defined as those systems that contain residual or stored energy, or are connected to an energy source that may cause a hazardous release. When stored energy may be encountered by site personnel, the SSO will ensure the appropriate application of lockout/tag out (LO/TO) procedures. Appendix D contains the LO/TO Permit to be completed by trained personnel prior to placing a lock or tag.
The LO/TO Permit will be used to confirm that the following steps are followed:
Preparation for shut-down, which includes preparing a sketch or diagram, and identifying all potential employees affected; Shutdown of equipment,
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Equipment isolation; Lock out or tag out device application; The means of relieving the stored energy; Verification of isolation and a zero energy state procedure; and Release of lockout or tag out.
The SSO and employee placing a lock or tag, and all potentially affected employees, will have completed LO/TO training prior to placing a lock or tag and will comply with all requirements of the HASP. Of special importance are, pre-planning, notification, and the authority to place a lock or tag. All locked or tagged out systems will be tested and challenged prior to allowing personnel to work in the area.
6.4 Traffic Control
Exclusion zones established in these work areas will, at minimum, consist of traffic delineators (yellow rope), barricades, cones, and caution signs.
6.5 Moving Equipment and Vehicles
Field activities will consist of ISCO within an active manufacturing facility. Field personnel will be working in close proximity to each other, and must coordinate and communicate effectively (internal and with Moen) to ensure safe work operations.
Drilling equipment movement will be conducted within or in close proximity to the work areas. All field personnel will be notified when drilling equipment movement is planned. A spotter will be established for each equipment move. The spotter and equipment mover will establish hand signals prior to movement. A walk around will be performed by the driver and spotter prior to the equipment move. Eye contact will always be maintained between field personnel in close proximity to equipment movement and the driver.
6.6 Preferential Pathway Monitoring
As sodium persulfate and H2O2 are co-injected into the subsurface, they will move away from the injection probe. During injection activities, the movement of these solutions can be influenced by natural heterogeneities in the subsurface, bedding and backfill materials associated with buried utilities, and compromised buried utility conduits (i.e., leaking storm sewers, etc.).
A preferential pathway monitoring program will be implemented to expeditiously identify potential preferential pathways that could influence the movement of chemical oxidant solutions during injection activities. Specifically, a preferential pathway evaluation will be conducted at the Site prior to injection. The evaluation shall consist of identifying and mapping features where chemical oxidant solutions could surface (i.e.
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manholes, storm drains, etc.). During injection activities, preferential pathways in close proximity to the injection locations will be monitored periodically.
6.7 Night and Dusk Operations
All work is anticipated to be conducted within an active manufacturing facility with adequate lighting. However, should night and dusk operations be necessary outside of the facility, the following lighting equipment will be in use:
A light tower greater than 50,000 lumens; Flashing strobes on vehicles; Hazard lights on vehicles; and One (1) or more 500W floodlight(s) will be utilized.
Pedestrian ramps over process piping will be minimal. The criteria for adequate lighting are 20 foot-candles.
6.8 Heat Stress
Heat stress will be minimized using the following work procedures:
Use the buddy system and monitor for signs of heat stress (headache, dizziness, weakness, irritability, confusion, vomiting); Drink lots of water, at least one (1) cup an hour; Avoid heavy meals and caffeinated drinks; Use of cotton undergarments; Use of cooling devices designed for hard hats; and Rest cycles as follows: o 5 minutes every 90 minutes; o 10 minutes every 60 minutes when above 75 °F; and o Re-evaluate conditions if above 85 °F with review by PM, SSO, and HSD.
6.9 Buddy System
An important element in controlling personnel exposure to site hazards is the implementation of buddy system procedures. These procedures ensure that no site personnel are allowed to work without another qualified worker present to provide assistance.
At all times, buddies should:
Observe their buddy for signs of exposure site hazards or stresses; Observe the site area in which they are working for hazards; Remain within verbal or visual contact with their buddy at all times; and Notify the team leader and or field office if emergency assistance is needed.
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7.0 Spill Prevention Plan
This Spill Prevention Plan (SPP) is intended to minimize the likelihood of an uncontrolled release of chemicals and associated risk of chemical exposure to field personnel. The general components of this plan are training, engineering controls, and procedural controls.
The following training elements contribute to minimize the potential for a spill:
Hazard communication briefing and orientation session; HASPA orientation; Operational procedures training; and Spill response training.
The following engineering controls will be implemented to minimize the potential for a spill:
Hydrostatic testing of process equipment prior to use; Check valves to minimize the potential for backflow of process fluids; Cam lock tie downs to prevent an accidental disconnection release; Plugs for process hoses and manifolds outside of secondary containment zone; Secondary containment for sodium persulfate and H2O2 mix systems; Storage of between 200- to 500-gallons of rinse water to fully dilute any mixed persulfate and H2O2, or to dissolve and dilute any persulfate crystals.
The following procedural controls will be implemented to reduce the likelihood of a spill:
Buddy system for operations and chemical transportation; Identification of a clear travel path for chemical transportation; Site controls in both chemical storage area and mix/injection area; Tag out procedures during system repairs and disassembly; Depressurization of piping prior to system repair, maintenance, or disassembly; and Dilution of spill via rinse water to eliminate potential for mixtures to react violently.
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APPENDICES HASP Addendum Former Wilson Jones Co. Facility July 2011
APPENDIX A Activity Hazard Analyses (AHAs)
ACTIVITY HAZARD ANALYSIS
Task 1: Equipment Set Up PRINCIPAL STEPS POTENTIAL HAZARDS RECOMMENDED CONTROLS -Use proper lifting techniques (flex at the knees and use legs when lifting). -Obey sensible lifting limits (50 pounds individual Heavy lifting lifting maximum). -Use mechanical lifting equipment to move large, awkward loads.
-Clear walkways of equipment, vegetation, and excavated material. Slips, trips and falls -Maintain good housekeeping. -Avoid using boot covers.
-Keep hands, fingers, and feet clear of Pinch-points/Cut Hazards moving/suspended materials and equipment. -Wear adequate hand protection.
Mix Equipment Set Up -Work area will be barricaded / demarcated. -Spotter for all vehicle and equipment moves. Contact with moving Perform a walk-around and review hand signals prior -PPE – Safety glasses, equipment/vehicles to each move. safety shoes, hard hats, reflective vest, and leather -All other workers within 50 feet will be notified prior gloves. to move.
-Maintain clear and marked egress pathways away from work area and exclusion zones. Secure hoses and cam-lock ears. -Demark work areas with yellow polyethylene rope Work area control and signage. Establish set-back of 10 feet or greater at all times. -Shut-down all powered equipment if unauthorized personnel enter the exclusion zone.
-Train workers to recognize symptoms of hot and cold stress. Instruct workers using impermeable clothing to have extra dry clothes to change into. Hot/Cold Stress -Buddy system to monitor for signs (headache, dizziness, weakness, irritability, confusion, vomiting). -Scheduled rest periods (5 min/90 min and 10 min/ 60 min >75 °F and re-evaluate conditions >85 °F).
ACTIVITY HAZARD ANALYSIS
Task 2: Connection to Wells PRINCIPAL STEPS POTENTIAL HAZARDS RECOMMENDED CONTROLS -Train workers on the hazards associated with site chemicals. Applicable MSDS sheets will be review by all employees working with chemicals. -Perform visual inspection of containers for contents and sign of contamination prior to use. Chemical exposure -Add water to the container before chemicals. -Transfer materials slowly to prevent splashing. -Label tanks to identify the chemical contents, and the Set up: Connections to associated hazards. Wells -Use LO/TO Checklist and Energy Control
Procedures -Allow time for pressure to dissipate. -PPE – Goggles or safety Release of stored energy -Use redundant pressure gauges on system manifold. glasses, face shield, chemical resistant -Tie-down all cam locks ears to prevent accidental clothing, hard-toed shoes release. with rubber covers, rubber gloves, hard hats and -Spill containment measures shall be readily available Reflective vest. Spills/leaks to contain spill, and prevent chemical mixing and/or migration off-site.
-Train workers to recognize symptoms of hot and cold stress. Instruct workers using impermeable clothing to have extra dry clothes to change into. Hot/Cold Stress -Buddy system to monitor for signs (headache, dizziness, weakness, irritability, confusion, vomiting). -Scheduled rest periods (5 min/90 min and 10 min/ 60 min >75 °F and re-evaluate conditions >85 °F).
ACTIVITY HAZARD ANALYSIS
Task 3: Chemical Oxidant Injection & Process Monitoring PRINCIPAL STEPS POTENTIAL HAZARDS RECOMMENDED CONTROLS -Work area will be barricaded / demarcated. -Spotter for all vehicle and equipment moves. Contact with moving Perform a walk-around and review hand signals prior equipment/vehicles to each move. -All other workers within 50 feet will be notified prior to move.
-Maintain clear and marked egress pathways away from work area and exclusion zones. Secure hoses and cam-lock ears. Work area control -Demark work areas with yellow polyethylene rope and signage. Establish set-back of 10 feet or greater at all times. Shut-down all powered equipment if unauthorized personnel enter the exclusion zone.
-Task lights will be provided in the 20 to 30 lumen Chemical Oxidant per square foot range of performance. Injection and Process -Workers will each have additional task lights and/or Night-time (dark and Monitoring head lamps. dusk) work -PPE – Goggles or safety -Work will be conducted inside site control area that glasses, face shield, is illuminated by others to a minimum of 20 lumens chemical resistant per square foot. clothing, hard-toed shoes with chemical resistant -Use LO/TO Checklist and Energy Control covers, nitrile gloves, hard Procedures -Allow time for pressure to dissipate. hats and reflective vest. Release of stored energy -Use redundant pressure gauges on system manifold. -Tie-down all cam locks ears to prevent accidental release.
-Train workers on the hazards associated with site chemicals. All employees working with chemicals will review the MSDS sheets prior to beginning work. Verify site controls. -Chemical mixing and injection equipment-specific training is required for all operators. Chemical exposure -Clean water rinse all components three (3) times before disassembly. Water rinse is preferable to chemical neutralization. -Triple rinse with clean water rinse and materials subjected to chemical neutralization. -Secure injection hose to well.
ACTIVITY HAZARD ANALYSIS
Task 3: Chemical Oxidant Injection & Process Monitoring (continued) PRINCIPAL STEPS POTENTIAL HAZARDS RECOMMENDED CONTROLS -Label piping to identify chemical contents and the Chemical exposure associated hazards. Identify flow directions on piping. (continued) -Use tag out procedures to modify plumbing.
Chemical Oxidant -Clear work area of equipment. Maintain good Injection and Process housekeeping. Monitoring Slips, trips and falls -Mark hose path with safety cones (Continued) -PPE – Goggles or safety -Keep hands, fingers, and feet clear of glasses, face shield, Pinch-points/Cut Hazards moving/suspended materials and equipment. chemical resistant -Wear adequate hand protection. clothing, hard-toed shoes with chemical resistant -Train workers to recognize symptoms of hot and cold covers, nitrile gloves, hard stress. Instruct workers using impermeable clothing to hats and reflective vest. have extra dry clothes to change into. Hot/Cold Stress -Buddy system to monitor for signs (headache, dizziness, weakness, irritability, confusion, vomiting). -Scheduled rest periods (5 min/90 min and 10 min/ 60 min >75 °F and re-evaluate conditions >85 °F).
ACTIVITY HAZARD ANALYSIS
Task 4: Demobilization and Decontamination PRINCIPAL STEPS POTENTIAL HAZARDS RECOMMENDED CONTROLS -Train workers on the hazards associated with site chemicals. All employees working with chemicals will review the MSDS sheets prior to beginning work. Verify site controls. -Chemical mixing and injection equipment-specific training is required for all operators. Chemical exposure -Clean water rinse all components three (3) times before disassembly. Water rinse is preferable to chemical neutralization. -Triple rinse with clean water rinse and materials subjected to chemical neutralization. Demobilization and -Secure injection hose to well. Decontamination -PPE – Goggles or safety -Spill containment measures shall be readily available glasses, face shield, to contain spill, and prevent chemical mixing and/or chemical resistant migration off-site. Spills/Leaks clothing, hard-toed shoes -Plan and prepare work area prior to transferring with chemical resistant chemicals to minimize the potential for slip, trip, and covers, nitrile gloves, hard fall during transfer. hats and reflective vest. -Keep hands, fingers, and feet clear of Pinch-points/Cut Hazards moving/suspended materials and equipment. -Wear adequate hand protection.
-Train workers to recognize symptoms of hot and cold stress. Instruct workers using impermeable clothing to have extra dry clothes to change into. Hot/Cold Stress -Buddy system to monitor for signs (headache, dizziness, weakness, irritability, confusion, vomiting). -Scheduled rest periods (5 min/90 min and 10 min/ 60 min >75 °F and re-evaluate conditions >85 °F).
ACTIVITY HAZARD ANALYSIS
Task 5: Emergency Response Procedures PRINCIPAL STEPS POTENTIAL HAZARDS RECOMMENDED CONTROLS -Train workers on the hazards associated with site chemicals. All employees working with chemicals will review the MSDS sheets prior to beginning work. Verify site controls. -Chemical mixing and injection equipment-specific training is required for all operators. Chemical exposure -Clean water rinse all components three (3) times before disassembly. Water rinse is preferable to chemical neutralization. -Triple rinse with clean water rinse and materials subjected to chemical neutralization. -Secure injection hose to well.
-Ensure that containers are clear of other chemicals Emergency Response and/or debris prior to transferring chemicals. Procedures -Fire extinguishers (water media) shall be suitably -PPE – Goggles or safety placed, distinctly marked, readily accessible, and glasses, face shield, Fire/Explosion maintained in a fully charged and operable condition. chemical resistant -Use 6% sodium thiosulfate for KMnO clothing, hard-toed shoes 4 neutralization. DO NOT USE HIGHER with chemical resistant CONCENTRATIONS OR MAKE covers, nitrile gloves, hard SUBSTITUTIONS. hats and reflective vest. -Spill containment measures shall be readily available to contain spill and prevent chemical mixing and/or migration off-site. Spills/Leaks -Plan and prepare work area prior to transferring chemicals to minimize the potential for slip, trip, and fall during transfer.
-Train workers to recognize symptoms of hot and cold stress. Instruct workers using impermeable clothing to have extra dry clothes to change into. Hot/Cold Stress -Buddy system to monitor for signs (headache, dizziness, weakness, irritability, confusion, vomiting). -Scheduled rest periods (5 min/90 min and 10 min/ 60 min >75 °F and re-evaluate conditions >85 °F).
HASP Addendum Former Wilson Jones Co. Facility July 2011
APPENDIX B Near Loss Incident / Loss Incident Investigation Report Form + Project Manager : Groundwater and Environmental Services LOSS/NEAR LOSS Report
Location: CLIENT: (Include City / Country) Site/Business Line (tick before): REPORT STATUS: Initial (24 hours) Date: Integrated oil sites IPM/ c-stores Terminal Pipeline/ Final (5 /10 days) Date: refineries All Solutions Completed E&P/ Legacy Industrial Government All V&V Completed
Near Loss LOSS Time:
Event type: Fire/Explosion Injury/Illness Security Environmental Transportation of Personnel Property/Equipment Damage
Sub-Contractor (Company & Experience) GES Experience Job Task: Equipment involved: Incident Description (Include Who - What - When - Where):
Immediate Corrective Actions Taken:
Investigation Results; Q/A (Causal/Contributing Factors = Why did it happen? There must be at least one Causal Factor): Q1 A1
Q2 A2
Q3 A3 PERSONAL FACTORS: JOB FACTORS: (1) Lack of Skill or Knowledge (5) Lack of, or Inadequate Procedure(s) (2) Doing the Job According to Procedures/Acceptable Practices Takes More Time/Effort ("Shortcut") (6) Inadequate Communication of Expectations (3) Shortcutting Procedures or Acceptable Practices is Positively Reinforced or Tolerated Regarding Procedures or Acceptable Practices (4) In Past, didn’t Follow Procedures/Acceptable Practices & No Incident Occurred. ("Routine") (7) Inadequate Tools or Equipment (8) EXTERNAL FACTOR(S)
ROOT CAUSE(S) AND SOLUTION(S): HOW TO PREVENT INCIDENT FROM RECURRING
Causal Root Solutions Due Person Completion Date Date Factor Cause (Actions to prevent recurrence) Date Responsible Date Verified Validated _ _ /_ _ / _ _ /_ _ / _ _ /_ _ / _ _ /_ _ /
______1
_ _ /_ _ / _ _ /_ _ / _ _ /_ _ / _ _ /_ _ / 2 ______
_ _ /_ _ / _ _ /_ _ / _ _ /_ _ / _ _ /_ _ /
______3
_ _ /_ _ / _ _ /_ _ / _ _ /_ _ / _ _ /_ _ / _ _ _ _ 4 ______
Prepared by: Date of Investigation _ _ /_ _ /_ _ _ _
Feb. 2011 HASP Addendum Former Wilson Jones Co. Facility July 2011
APPENDIX C Klozur Documentation Hydrogen Peroxide Technical Bulletin
Quality
Reliability
Service Table of Contents
Introduction 1
Chemistry 2
Hydrogen Peroxide Applications 4
Technical Data 9
Analysis 10
Safety 12
Product Quality & Grades 14
Supply Reliability 16
Technical Services 17
Engineering Services 19
Distribution Services 23
Sales and Customer Services 26
Summary 27 Introduction
Hydrogen peroxide is one of the most versatile, FMC offers the full range of concentrations and dependable and environmentally desirable grades of hydrogen peroxide. Most industrial chemicals available today. The safety and efficiency applications call for the use of 31%, 35%, 50% of its operations have led to the development of or 70% concentrations. All grades are manufactured numerous applications. For example, hydrogen to the highest standards of quality and are readily peroxide is an oxidizing agent for organic and available in bulk or drum quantities from inorganic chemical processing, a bleach for textiles inventories stocked at strategic distribution and pulp, and a treatment for municipal sewage points worldwide. and industrial waste. Because of hydrogen peroxide's favorable properties, numerous FMC also provides Technical Service Engineers applications have been developed. who are prepared to assist in the application of hydrogen peroxide as well as the safe handling As the leading supplier of hydrogen peroxide, and storage of the chemical. FMC Corporation has made major contributions to the field of peroxygen technology for over This brochure explains the properties, capabilities, 60 years. FMC continues to pioneer new uses and recommended methods for handling applications for this widely used chemical at hydrogen peroxide safely under varying conditions. the company's extensive research facilities in It also describes the comprehensive research, Princeton, New Jersey. manufacturing, technical service, engineering, distribution and sales support services which As a worldwide producer of hydrogen peroxide, are responsible for making FMC hydrogen FMC has seven manufacturing facilities around peroxide the market standard. the world and is the only producer with four plants and five operating cycles in North America.
1 Chemistry
Physical and Chemical Properties
Versatility
Hydrogen peroxide is a chemical capable of reacting via several mechanisms. Depending on the environment, it can function as an oxidizing or reducing agent, oxygen source, or complexing agent. This versatility enables hydrogen peroxide to be used in a wide variety of manufacturing and industrial applications.
Oxidation
+ → H2O2 + 2H + 2e- 2H2O E=1.77
This characteristic of hydrogen peroxide is the basis for its use as a reactant in chemical synthe- sis, a bleaching agent for pulp and paper, textiles, minerals, clays, etc., and for destroying organic and inorganic contaminants in a variety of environmental applications.
Reduction
→ + H2O2 O2 + 2H + 2e- E=0.68V
Not often thought of as a reducing agent, hydrogen peroxide is capable of reducing several inorganic species. For example:
❑ 4+ → 3+ + 2Ce + H2O2 2Ce + 2H + O2
❑ + → 2+ MnO2 + H2O2 + 2H Mn + O2 + 2H2O
This capability finds use in analytical determinations, dechlorination and a number of other areas.
2 Oxygen Sources
Catalyst → 2H2O2 2H2O + O2
Oxygen can be generated by the addition of decomposition catalysts such as silver, iron and copper to hydrogen peroxide. The oxygen produced can be used in a variety of applications including the forming of materials such as plastics, latex, gypsum products, etc. The oxygen generated by this reaction is often used in environmental dissolved oxygen. This oxygen helps keep the aqueous system from becoming anaerobic.
Complexing Agents
Hydrogen peroxide, has extensive use in byproduct and secondary metal recovery to control the solubility of metals. It can be used to effectively separate metals such as uranium from vanadium or cobalt from nickel through selective oxidation and/or the formation of peroxy-metal complexes.
Peroxygens form complexes with various metals. This changes the relative solubility of the metal being complexed. The effect can either make the metal more soluble, precipitate the metal, or modify extraction Peroxide Derivatives coefficients. The relative solubility of peroxy complexes can be used to separate otherwise similar metals, giving Molecular addition of hydrogen peroxide to certain increased purification compared to simple separation compounds results in the formation of perhydrates. processes. When urea is dissolved in a hydrogen peroxide solution and then cooled or evaporated, it forms the crystalline compound urea peroxide. Similar compounds are formed in this way from hydrogen peroxide with tetrasodium pyrophosphate, sodium carbonate, sodium metaborate, and others.
3 Hydrogen Peroxide Applications
Worldwide Usage CHEMICAL PULPS Hydrogen peroxide is an environmentally safe oxidizing
Hydrogen peroxide (H2O2) is used in a variety of agent which does not generate chlorine derivatives. applications throughout the world. This versatile Historically, peroxide has been used in chemical pulp chemical has widespread applications in pulp and bleaching as a cost-effective replacement or supplement paper, textile, waste treatment, mining, oil, food and for chlorine dioxide, and as a means of achieving higher chemical processing, cosmetic and pharmaceutical brightness and improving brightness stability. A major industries. It is also one of the most environmentally use today is in minimizing or replacing chlorine, chlorine desirable chemicals since its primary decomposition dioxide, and hypochlorite in the bleach sequence. Its by-products are water and oxygen. use lowers bleaching costs when producing Elementally Chlorine-Free (ECF) grades and increasingly it is the Pulp and Paper key delignification and brightening agent for today's low-AOX and Totally Chlorine-Free (TCF) grades. Typical applications are:
❑ Chemical Pulps —Enhance delignification to decrease the use of chlorine-based chemicals and improve environmental quality —Increase brightness and improve brightness stability —Peroxide can be used in the following stages: ■ Oxygen delignification, (EOP) - or (OP) - stages ■ Reinforced extraction, (EP) - or (EOP) - stages ■ Terminal P and high density storage ■ Hot P-stages (TCF) Hydrogen peroxide plays a major role in the bleaching of all types of pulps: SECONDARY FIBER Mechanical, kraft, and deinked Peroxide assists the deinking and bleaching of recycled recycle fiber. groundwood fibers to reduce alkali reversion and increase brightness. Peroxide is also used in woodfree secondary MECHANICAL PULPS fiber bleaching to minimize or replace hypochlorite to H2O2 is the preferred bleaching agent for developing high improve environmental quality and increase substitution brightness in mechanical and other high yield pulps. The of wood containing grades. Applications include: brightness is more stable with hydrogen peroxide than with any other commercial agent. The following are some pulp ❑ Secondary Fiber applications: —Pulper —Soaking Tower ❑ Mechanical Pulps —Bleaching Tower —Bleaching pulps in-refiner, in-grinder, single and multi-stage towers —Treatment to improve physical properties, decrease capital or product costs . ■ Alkaline peroxide treatment prior to refining to develop strength ■ Interstage washing to reduce resins, improve strength and absorbency
4 Detergents and Textiles Environmental Applications
Hydrogen peroxide and its derivatives are widely used as effective color-safe bleaches and processing aids in the textile and detergent industries.
Hydrogen peroxide can be used for the treatment of a variety of inorganic and organic pollutants.
Hydrogen peroxide is used successfully in the detoxification of industrial waste waters. Since its primary decomposition products are water Valued for its versatility, hydrogen peroxide offers and oxygen, it is not itself a source of pollution. textile manufacturers the advantage of ease of Depending on the pollutant, hydrogen peroxide application, reduction of processing times, minimization can be used alone or activated with catalysts such of effluent problems, preservation of textile fiber quality, as iron (Fenton's reaction), ultraviolet light, ozone, high and very stable degree of whiteness, and primary etc. It is used routinely in many industries such decomposition products, water and oxygen. as petroleum refining and chemical operations.
Hydrogen peroxide can be used to bleach natural cellulose, Hydrogen peroxide is effective in treating: animal and synthetic fibers. Some examples of textile processing applications as well as hydrogen peroxide ❑ Inorganic pollutants based bleaches are as follows: 2- —Reduced sulfur compounds (H2S, SOx, S2O3 ) —Cyanides (simple and complex) ❑ Textile processing - —Active chlorine compounds (Cl2+ OC1 ) —Bleaching of woven and knit fabrics —NOx —Desizing (CMC, starch, PVA) —Metals removal (Fe, As, Cr) —Denim processing —Antichlorination —Dye fixation
❑ Bleaching agents —Perborates —Percarbonates
—Liquid H2O2 bleach —Thickened/gelled peroxides —Peracids
5 ❑ Organic Pollutants Hydrogen peroxide is an attractive reagent in metallurgy —Phenolics since its primary decomposition products are only water —Aromatic hydrocarbons and oxygen. Examples of its uses include the extraction —Organosulfur compounds (mercaptans, sulfides) of uranium, the separation of cobalt and manganese, and —Chlorinated hydrocarbons (vinyl chloride, the oxidation of many metal ions. trichloroethylene, tetrachloroethylene, etc.) —Pesticides Common mining applications include: —Aldehydes ❑ Gold and silver processing As a potential source of oxygen, hydrogen peroxide —Heap and agitated cyanide leaching enhancement is used in biological treatment. This oxygenation is —Cyanide detoxification especially helpful at times of overload, for the treatment of filamentous bulking sludges, and for the prevention ❑ Uranium of denitrification in settling tanks. Examples of these —Yellowcake purlfication (V, Mo, Na removal) applications are: —In-situ leaching —Oxidant in acid or alkaline leaching ❑ General —Recovery of uranium from wet process phosphoric —Bioreclamation of aquifiers & groundwater acid —BOD/COD control —Bulking control/sludge dens)fication ❑ Copperlmolybdenum Flotation Separation —Slime removal —Process water recycling ❑ Copper leaching
Mining Applications ❑ Acid mine drainage (heavy metal removal)
❑ Phosphate rock purification Mining applications take advantage of hydrogen peroxide’s prpperties of oxidation, reduction, Chemical Manufacturing Applications complexation and oxygen generation. Hydrogen peroxide is used to produce a wide range of organic chemicals. This includes epoxides, organic peroxides and organosulfur compounds. Organic peroxides are used as initiators in the production of polystyrene, polyvinylchloride, polyethylene and other polymers, as well as curing agents for polyester resins. Organic synthesis of peracids using hydrogen peroxide is another common application.
Hydrogen peroxide is also used to produce inorganic chemicals of high purity. These include such diverse products as ferric sulphate, hydrazine, sodium chlorite, potassium hydrogen peroxymonosulfate and arsenic acid.
6 Chemical processing applications such as product ❑ Inorganic peroxygens purlfication and bleaching are other important uses —CaO2, ZnO2, perborates, percarbonates for hydrogen peroxide. ❑ Arsenic acid
❑ Chemical processing
—H2SO4 decolorization —Mineral bleaching —Starch modification —Oil bleaching
Industrial Applications
Because of hydrogen peroxide's unique properties, it has found uses in many industries. Some examples include:
The selective oxidizing properties ❑ Oilfield of hydrogen peroxide are used in a —Gel/polymer formation and breaking number of processes for manufacturing —Slime removal in injection wells chemicals and intermediates. —Emulsion breaking —Stimulation and permeability enhancement Examples of typical chemical manufacturing applications —Natural gas sweetening include: —H2S removal in brines ❑ ❑ Epoxides of: Geothermal H2S abatement —Oils —Well drilling —Intermediates (Steroids) —Power plants —Stacking ❑ Organic peroxygens —Peracids, MEK Peroxides Solutions of hydrogen peroxide and sulfuric acid are used in the etching of printed circuit boards. They ❑ Specialty organics are also used in other cleaning and etching processes —Lactones throughout the industry. Some of hydrogen peroxide's —Alcohols common electronics and metal finishing applications —Polysulfide curing agents include: ❑ ❑ Initiator for polymers Electronics —Emulsion Solution polymerization —Silicon wafer cleaning —Semiconductor processing ❑ Oxides of sulfur and nitrogen —Photo resist removal (stripping) —Sulfoxides —Copper etching —Sulfones —Cupric chloride regeneration —Amine oxides
7 ❑ Metal Finishing ❑ Cosmetics —Pickling Al, Fe, Cu —Hair bleaching —Chemical milling —Perm waves —Hair dye setting through oxidation
❑ Pharmaceutical —Contact lens cleaner —Denture cleaner —Topical antiseptic
Hydrogen peroxide is an effective environmentally clean reagent in numerous industrial applications.
Hydrogen peroxide is an effective cleaning agent with the advantage of the harmless residues formed when it decomposes. Food processors use H2O2 in the following applications: Versatile hydrogen peroxide ❑ Food processing is used in the cosmetics and —Packaging of milk, fruit juices, etc. pharmaceutical industries. —Sugar decolorization —Food preservative (milk, whey) These are just some of the many ways hydrogen —Bleaching agent peroxide is used effectively and economically —Cleaning solutions for equipment and lines throughout the world. With over 60 years of Miscellaneous Applications experience, FMC has the technical expertise to assist with all applications and systems technology. A trained applications specialist will provide the One of Hydrogen Peroxide's earliest applications was technical assistance you need to put hydrogen its use in dilute solutions as an antiseptic. Today, peroxide to work. (Please see the Technical Service hydrogen peroxide is used in a variety of cosmetic section for more details) and pharmaceutical applications such as: FMC is a leading supplier of hydrogen peroxide. For help with your specific applications needs, contact FMC today at: 215-299-6000
8 Technical Data
Terminology Physical Properties
FMC hydrogen peroxide (H2O2) is sold as an aqueous FMC hydrogen peroxide has a molecular weight of solution. The amount of H2O2 present is expressed as 34.02, is clear, colorless and waterlike in appearance, a percent of the solution's weight. Thus, a 35% solution and has a slightly acidic odor. It is miscible with water is one which contains 35% hydrogen peroxide and 65% in all proportions and is nonflammable. Other physical water by weight. properties are listed in Table 1.
Formerly, the concentration of the chemical was Stability expressed in terms of ‘volume’ strength. This referred to the volume of oxygen released during decomposition. FMC hydrogen peroxide is very stable under normal Thus, ‘hydrogen peroxide 130 volume’ meant that, conditions, when properly stored. The rate of active under standard conditions 130 volumes of oxygen oxygen loss in large containers, such as bulk storage would be released by one volume of solution. tanks, is less than 1% per year at normal ambient temperatures. In small containers, such as drums, the A list of the concentrations of hydrogen peroxide rate of loss is less than 2% per year. In general, the available from FMC Corporation follows showing larger the ratio of the surface area to the volume of weight percentages with equivalent ‘volume’ strength the hydrogen peroxide, the greater the rate of oxygen along with other important properties. loss.
The decomposition rate of hydrogen peroxide is increased by contamination, alkalinity, increasing temperatures and contact with certain metals.
(H2O2) concentrations, weight % 31 35 50 70 ‘Volume strength’ @ 0°C & 1 atm 116 130 197 300 Active oxygen content, weight % 14.6 16.5 23.5 32.9
(H2O2) g/l 346 396 600 903 Specific gravity @ 20°C/4°C 1.11 1.13 1.19 1.29 Lbs/gal @ 20°C 9.25 9.42 9.92 10.75 Boiling point, °C 106 108 114 126 Freezing point, °C –27 –33 –52 –40 Viscosity @ 25°C (centipoise) 0.98 1.0 1.06 1.12 Refractive index @ 25°C 1.353 1.355 1.366 1.381 Dielectric constant @ 20°C 82 83 83 82 Total vapor pressure @ 30°C (mm Hg) 24.0 23.3 18.3 10.1 Partial pressure @ 30°C (mm Hg) 0.24 0.28 0.56 1.17 Heat of dilution, cal/g mole @ 25°C & 1 atm –66 –84 –178 –381 Surface tension, dynes/cm at 20°C 74.4 74.6 75.6 77.3
Table 1. Chemical and Physical Properties
9 Technical Data continued
❑ To provide some protection against accidental ❑ Hydrogen peroxide remains a liquid until temperatures contamination during shipment, storage or handling, drop substantially below 0 °C. Crystals begin to appear low levels of special stabilizers are added to FMC in 35% and 50% solutions at -33 °C, and -52 °C, hydrogen peroxide. However, since no additive will respectively. Thus, outside storage is a common practice. prevent decomposition if excessive contamination occurs, the best practice is to prevent contamination ❑ Metals, such as copper and iron, and other through proper handling techniques. contaminants act as catalysts for the decomposition of hydrogen peroxide. Using materials of construction ❑ Alkaline hydrogen peroxide solutions are much less in storage and handling systems that are not compatible stable than acidic solutions of comparable purity. For with hydrogen peroxide can cause catalytic decomposi- that reason, hydrogen peroxide is shipped and stored tion of the hydrogen peroxide. To avoid this danger, at an acidic pH level. refer to the Materials of Construction section of this bulletin. ❑ Rising temperatures markedly increase the decomposition rate. The rate increases approximately Information on safe storage and use of hydrogen 2.2 times for each 10 °C rise in temperature in the peroxide is available from your FMC Technical Service range from 20 °C to 100 °C. The rate increases 1.5 Specialist. times for each 10 °F rise from 68 °F to 212 °F. Analysis Qualitative Analysis
A number of color reactions are known which will detect hydrogen peroxide in very small amounts. One of these reactions recommended for practical work is based on the distinct yellow color produced by hydrogen peroxide when a few drops of acid titanium sulfate solution are added to a small amount of the material to be tested. Another very sensitive test is based on the liberation of iodine from an acid solution of potassium iodide containing a few drops of soluble starch solution. Addition of the sample to be tested will produce a distinct blue color if hydrogen peroxide is present.
10 Quantitative Analysis—Potassium Approximate Sample Size Permanganate Method Percent H2O2 Grams Sample 35 1.0 Principle 50 0.7 Hydrogen peroxide is oxidized by potassium 65 0.6 permanganate in the presence of sulfuric acid. 70 0.5 Organic or inorganic reducing substances which are capable of reacting with permanganate interfere The weighed sample should be transferred quantitatively with the method. to a 250 mL Erlenmeyer flask containing 50 to 100 mL of C.P. 25% sulfuric acid. Add, with a vigorous stirring, Chemical Reaction 0.5N KMnO4 at the rate of 10 to 30 mL/minute. The end point is reached when a faint pink color lasting for 5H2O2 + 2KMnO4 + 3H2SO4—> K2SO4+ 2MnSO4 one minute is obtained. If, during the titration, the + 8H O + 5O 2 2 solution in the beaker turns brown, discard the sample and begin the analysis again. Brown coloration only indicates deficiency of acid, or too rapid addition of Apparatus KMnO . Titrations should be made on at least two ❑ Analytical balance—accuracy of plus or minus 4 samples to test the accuracy. 0.1 mg Calculation of Results ❑ 5 mL beaker or small weighing bottle The concentration of H2O2 in the analyzed sample is calculated as follows: ❑ 250 mL Erlenmeyer flask
weight % H O = mL KMnO X Normality of KMnO X 1.701 ❑ 50 mL buret—Class A 2 2 4 4 Sample weight in grams ❑ Medicine dropper Other Methods You can also obtain an accurate volumetric analysis of Reagents hydrogen peroxide by reducing ceric salts to cerous salts; 0.5 N Potassium permanganate titrating solution sulfuric or by liberating iodine from an iodide, followed by acid — approximately 25% by weight titration with a thiosulfate solution. Safety For more information about analytical methods please Observe standard safety laboratory procedures in the consult with FMC's technical specialists. handling of H2O2 and H2SO4.
Procedure To accurately measure the weight percent of hydrogen peroxide in a strong solution, it is important to weigh the sample for analysis. This can be done by using a dropper to transfer the solution to a small tared beaker on the pan of the analytical balance. The sample chosen should contain about 0.35 grams of hydrogen peroxide.
11 Safety
General Considerations of lungs, throat and nose that usually subsides after exposure ceases. Swallowing may produce corrosion A basic understanding of the properties of hydrogen (burning) of the gastrointestinal tract that may be peroxide is the first step in the safe handling of this life-threatening. If spilled on the skin, wash off chemical. Decomposition caused by contamination immediately with large amounts of water. If the releases oxygen and heat. In dilute solutions, the heat chemical has come into contact with the eyes follow evolved is normally absorbed by the water present. appropriate first-aid procedures and consult a physician In more concentrated solutions, the heat raises the promptly. temperature of the solution and accelerates the decomposition rate. Therefore, all handling procedures Hydrogen peroxide and its primary decomposition must insure product integrity by preventing any products, oxygen and water, are not systemic poisons. contamination. However, hydrogen peroxide vapors can cause irritation and inflammation of the respiratory tract. If inhalation Hydrogen peroxide should be stored only in original has been prolonged, seek fresh air at once and consult containers or in containers of compatible materials a physician immediately. that have been properly designed, thoroughly passivated, and dedicated for this use. To prevent contamination,
H2O2 should never be returned to its storage container. Dispose of any excess by dilution with purified water.
Hydrogen peroxide is not considered to be an explosive. However, when it is mixed with organic substances, hazardous, impact-sensitive compounds may result. Even small amounts of materials containing catalysts such as silver, lead, copper, chromium, mercury and iron can cause immediate decomposition and explosive rupture of the containing vessel, even if the vessel is properly vented.
Fires caused by hydrogen peroxide are best controlled by using large quantities of water. The chemical itself Although 3% hydrogen peroxide solutions are often does not burn, but its decomposition liberates oxygen used as a gargle or mouthwash, more concentrated which supports combustion. solutions should never be allowed to come into contact with the mouth. If hydrogen peroxide is swallowed, Personnel Safety ingest lukewarm water freely and call a physician.
Always wear safety goggles, neoprene rubber gloves If clothing comes into contact with hydrogen peroxide, and shoes, and suitable protective clothing when wash it thoroughly in water. Any H2O2 left to dry on handling hydrogen peroxide. Concentrated solutions the fabric, particularly if it is soiled, may cause fire. are corrosive to the eye and skin and direct eye contact may cause irreversible tissue damage including blindness. Inhalation of mist or vapor will cause severe irritation
12 FMC Customer Safety Assistance ❑ Safety and Handling Programs available on slides or video cassette for customer training. To help instruct customer operating personnel, FMC offers a safety wall chart, "Safe Handling of Hydrogen ❑ Product Safety Seminars conducted at customer Peroxide," which should be prominently displayed in plant locations. areas where the chemical is stored, handled and used. This chart is available upon request. FMC also provides: FMC is committed to the safe delivery, handling and use of our hydrogen peroxide. As an FMC customer, ❑ Material Safety Data Sheets maintained you will receive safety information, materials and through a comprehensive computer system. training to help you use our product effectively and safely.
A FMC Safety Instructor presents a hydrogen peroxide safety seminar to customer personnel.
IN CASE OF EMERGENCY For Transportation Emergencies contact: CHEM TREC at 1-800-424-9300 FMC Emergency Response Center 1-609-924-6677 For Medical Emergencies Contact: Rocky Mountain Poison Control at 1-303-595-9048
13 Product Quality and Grades
Consistent product quality is vitally Product Grades important in many hydrogen peroxide FMC manufactures several grades of hydrogen peroxide applications. In addition, quality tailored to different end-use applications, as shown in product helps provide safety and Table 2. reliability to our customers. Each grade is available in different concentrations to maximize economy and convenience. The grades differ FMC Commitment to the Highest Standards from one another in the types and amounts of stabilizing additives contained. FMC manufactures each grade to Product quality is of critical importance at FMC. best meet our customers' specific needs. Excellent quality reflects the teamwork and good communications with our customers and throughout Stabilizer levels for special grades are chosen to ensure the FMC organization. that products comply with requirements of the Food Chemical Codex, the U.S. Pharmacopeia and technical There are many behind-the-scenes activities and organizations such as S.E.M. I. and the American programs carried out by FMC plant and technical Chemical Society. staffs which have made our product quality second to none. Here are some highlights of this ongoing commitment to excellence. Statistical Process Control (SPC)
H2O2 FMC hydrogen peroxide is consistently within set Statistical specifications. Process upsets are spotted early and Process corrected at once. Data is thoroughly analyzed and quickly communicated to plant operators so that Control process improvements are recognized and maintained.
Designed initially to meet the special needs of the semiconductor industry, SPC is now routinely used at all FMC plants to control the manufacture of all product grades. FMC has stringent specifications tailored to each grade of hydrogen peroxide. Our goal is, and will continue to be, to produce hydrogen peroxide that meets those rigid criteria 100% of the time. SPC enables us to minimize the cost of reworking products, improve timeliness on deliveries, and reduce customers' expenses and worries about analytical results. An FMC sales representative can provide you with complete details on our Statistical Process Control Program.
14 Grades (concentration) Main Applications Stabilizer/Specs Dilution Water Standard ■ Textile/pulp bleaching Tin type and other Deionized water or (70,50,35) ■ Waste treatment continuous monitored ■ General uses tap water of suitable purity. (FMC will assist in analyzing tap water) Technical ■ Chemical synthesis Organic. Essentially Deionized only (70,50,35) free of metal ions Chlorate ■ Hypochlorite destruction Tin type and other Deionized only (5o) during sodium chlorate low phosphate manufacture Super D ■ Hair bleach Tin type and other. Deionized only (65,5O,35) ■ Topical antiseptic Meets US Pharmacopeia requirements for 3% topical antiseptic Durox, Durox LR ■ US Food and Drug Tin type and other. Deionized only (50,35) Administration Meets Food Chemical approved food uses Codex specifications. Residue <60 ppm
Electronic Grades Main Applications Stabilizer/Specs Dilution Water Semiconductor ■ Contact lens applications Minimal amount of Deionized only (70,31 ) ■ Semiconductor stabilizer, <20 ppm. processing Conforms to SEMI and ACS specifications. SEG/RGS ■ Contact lens applications Stabilizer free Dilution for storage (31) ■ Semiconductor Purity to <1 PPB not recommended processing contaminents
Table 2. H2O2 Product Grades
15 Supply Reliability
Reliability of hydrogen peroxide supply is paramount in all industrial applications. Excessive costs occur without the right product, at the right place, at the right time.
FMC is a leading producer of hydrogen peroxide, with seven worldwide manufacturing plants. Our plants in Mexico, Japan, Thailand and Europe supply the international market. In North America, FMC operates hydrogen peroxide manufacturing plants in Spring Hill, West Virginia and Bayport, Texas. A third plant was recently added to the system in Prince George, British Columbia, which will further enhance our supply reliability. FMC also maintains a strategic network of hydrogen peroxide distribution centers.
FMC's multiple facilities, extensive distribution system, computerized quality control, and industry leadership all add up to one thing: unsurpassed reliability in meeting our customers' hydrogen peroxide needs.
FMC plant personnel use state of the art process control technology.
16 Technical Services
Technical expertise and assistance Personalized Service in the use of hydrogen peroxide in FMC personnel understand your needs and will all applications is a valuable service work closely with you to solve any hydrogen peroxide application problems. FMC capabilities range from provided by FMC. laboratory evaluation to on-site assistance for plant trials and commercial start-up. Laboratory and field Full Technical Support trials can include feasibility studies or statistical optimization studies, depending on your needs. All When you buy FMC hydrogen peroxide you also of these laboratory and onsite services include detailed receive our full technical support for all your applications follow-up reports and personal presentations of data needs. FMC Technical Service Specialists are ready to and recommendations. Some of these services are assist you in the following areas: listed below:
❑ Pulp and Paper ❑ Textiles ❑ Electronics ❑ Detergent ❑ Mining ❑ New Technology ❑ Environmental ❑ Industrial
Laboratory services provided at FMC’s Princeton laboratory help ensure quality results.
17 Technical Services continued
❑ Training in safety and handling FMC is committed to advancing hydrogen peroxide ❑ Plant audits applications technology. We are responsive to the needs of our customers by developing new applications and ❑ Plant problem solving optimizing existing applications. We are continuously ❑ Analytical procedures developing new applications at our Princeton research facility, and sponsoring additional studies at leading ❑ Product and application literature academic and research centers. FMC is on the front ❑ Phone consultation line of hydrogen peroxide application development ❑ Laboratory evaluation worldwide through technology transfers with our partners in Europe, Asia and Latin America. ❑ Plant trials ❑ Commericial start-up assistance FMC is committed to keeping customers informed of all emerging technology through customer seminars, ❑ Feasibility studies presentations at industry conferences, and technical ❑ Statistical optimization studies publications.
FMC Technical Service Specialist provides on-site applications assistance utilizing a hydrogen peroxide skid delivery unit.
18 Engineering Services
Expertise in the storage and handling Storage System Design of hydrogen peroxide is an important Hydrogen peroxide solutions should be stored in value for providing safe and efficient accordance with National Fire Protection Association Code 43A. This code lists hydrogen peroxide solutions systems. higher than 52% as Class 3 oxidizers and solutions between 27.5% and 52% as Class 2 oxidizers. With hydrogen peroxide, proper handling and storage is vital to safe operation. FMC Engineering Services Hydrogen peroxide should only be stored in original Group has designed and installed approximately three containers or in tanks built from compatible materials out of every four hydrogen peroxide storage facilities which have been properly designed and thoroughly in North America, and has the expertise to assist in passivated. all hydrogen peroxide storage needs. Selection of a drum or bulk storage system depends on the needs of the user and is often a function of economics and safety. The drum storage system requires a minimal capital investment; but the product cost is higher and there are labor costs for drum handling. These costs are avoided in bulk systems.
When designing a storage and handling system for hydrogen peroxide, it is important to eliminate the danger of catalytic decomposition. Hydrogen peroxide will decompose into oxygen and water when catalyzed by a variety of materials. Because of this danger,
19 Engineering Services continued
all systems must be designed with the following basic Since the freezing points of hydrogen peroxide guidelines: solutions are low and the boiling points high (see Technical Data section), storage tanks can usually ❑ Contamination Prevention be located outdoors in both hot and cold climates.
Use only materials compatible with H2O2. Design to prevent contaminants from entering the system. Like any liquid, hydrogen peroxide can be transferred Clean and passivate the system prior to first use. from one point to another by gravity flow or pumping. Train operating personnel in the proper use and All equipment used in a transfer must be made of maintenance of the system. High-purity Aluminum material compatible with hydrogen peroxide and Alloy 5254 is recommended for permanent storage should have adequate pressure relief (venting) systems. tanks. Care must be taken during fabrication to prevent undesirable substances from becoming Materials of Construction embedded in the aluminum surface. Proper welding techniques are absolutely mandatory. Since hydrogen peroxide is a powerful oxidizing agent, compatible materials must be used in the ❑ Decomposition Effect Minimization construction of any system. The most practical The design should eliminate the consequence of material is high purity aluminum. FMC recommends Aluminum Alloy 5254 for the construction of hydrogen H2O2 decomposition by providing proper ventilation in all parts of the system. This will eliminate pressure peroxide bulk storage tanks. Aluminum alloys such as build-up which could result in system ruptures. 1060 are used in the hydrogen peroxide transfer Storage tanks must be properly vented and located piping. Type 316 stainless steel is a satisfactory away from sources of direct heat and combustible material for H2O2 transfer pumps. Materials materials. compatible with hydrogen peroxide are listed
Class 1 materials These materials can be used for unlimited-time contact with hydrogen peroxide. ■ Aluminum alloys, type 5254, 1060 and B-356 (cast) for storage tank, transfer piping, pumps and valves. ■ White chemical porcelain ■ Some grades of polyethylene may be used under certain carefully selected conditions of temperature, interconnecting materials, physical location, H2O2 concentration and hydraulics. Consultation with FMC is advised prior to storing peroxide in polyethylene. ■ Pyrex®1 laboratory glassware ■ Kel-F® 812 resin ■ Fluorocarbon resin Class 2 materials These materials may be used for limited-time contact with hydrogen peroxide. ■ Stainless steel type 304, 316 for transfer pumps and tank trucks conveying peroxide on a short residence-time basis only. Consultation with FMC is advised. ■ Koroseal®3 700 molded polyvinyl chloride
Table 3. Suggested materials for use with Hydrogen Peroxide 1Trademark of Corning Glass Works 2Trademark of Minnesota Mining and Manufacturing Company 3Trademark of The B.F. Goodrich Company
20 in Table 3. Under certain circumstances other materials used in handling hydrogen peroxide solutions must be can be used. (Please contact a FMC specialist for more thoroughly cleaned and passivated before being placed information) in service. Aluminum alloys and stainless steels should be passivated by the following procedure: System Maintenance (Inspection and Passivation) 1. Detergent wash to remove all oil, grease, loose contaminants, etc. To ensure maximum, peroxide stability, all equipment
Part Material Identification/miscellaneous Storage tank 5254 aluminum Section VIII ASME code for unfired 316 Stainless Steel vessels under 14.7 psi (101.4 kPa). Piping 1060 aluminum alloy, 316 stainless steel; Schedule 40 or 80. Butt welded joints. Koroseal® 700 gaskets Van Stone flanged connections. Valves: B356 aluminum Model—Ball flanged P515114436T with Manual or 110 volt, 60 cycle electric operators. electrical Type EL 20 operation
Check 304/316 stainless steel Pumps: Centrifugal Class 1 or 2 e.g. 356.A 2" (5.08 cm) 10W self-priming Metering 304/316 stainless steel fluorocarbon diaphragm, hydraulically activated Water meter Cadmium plated galvanized iron case, Model DV 1¹⁄₂" (3.81 cm) with batch bronze working parts register and totalizer 50 GPM max. 1¹⁄₄" (3.18 cm) water meter union connections Water filter 304/316 stainless steel Model VCS 1003-EG 16 3-30 micron disposable filter cartridges for water service Temperature Aluminum or stainless steel Vapor actuated capillary 6" (15.24 cm) monitoring dial type with high alarm contact. For device 110 volt, 60 cycle service, audio/visual alarm. Hoses 304/316 stainless steel 2" (5.08 cm) ID stainless steel flexible metal hose (2.4" [6.1 cm] OD). Male and female stainless steel quick connectors end fittings. Mechanical 316 stainless steel, ceramic and Type 9, code QVICI 316 (for service with seals flourocarbon resin or equivalent hydrogen peroxide transfer pumps).
Table 4. Suggested Specifications for an H2O2 System
21 Engineering Services continued
2. Thoroughly rinse with clean, purlfied water and drain to remove all contaminants and washing solution.
3. Treat all surfaces with a 35% nitric acid solution. Rinse thoroughly and drain several times to remove all acid and water-soluble con taminants.
The size and type of the facility will determine the passivation procedures used. In some cases, tanks, piping and other items may be passivated separately before they are installed in the storage and handling system.
FMC provides customers with detailed instructions for proper passivation procedures. For field passivation, FMC will provide special equipment to customers who wish to perform system passivation after installation. For more information, contact your FMC sales representative. All FMC customers have access to our full range of engineering services. FMC Technicians complete installation passivation and inspection of a hydrogen peroxide storage system at customer site.
22 Distribution Services
Moving all grades of hydrogen Shipping drums used for storage must always be stored head up, preferably on a concrete floor, in a peroxide through the most extensive clean, cool, fireproof area away from combustible peroxide distribution network in materials. Wherever hydrogen peroxide is stored, you must have adequate ventilation and ample water for North America is a key component washing away accidental spills. of reliability, safety and quality. Tank Trailers Shipping Methods 4000-gallon (approximately 15m3), 5000-gallon (approximately l9m3) and 6000-gallon (approximately There are three common types of hydrogen peroxide 23m3) tank trailers deliver into customerowned bulk shipping containers: drums, tank trailers, and tank cars. storage tanks. These trailers can carry 70% hydrogen peroxide by weight for dilution on delivery. Or they Drums can carry 50%, 35% and 31% concentrations for 55-gallon polyethylene drum is the most typical drum delivery without dilution. Many tank trailers are size. Polyethylene drums are also available in 6-, 15- and equipped with on-board deionization units to improve 30-gallon (23-, 57- and 114-liter) sizes. Concentrations the local water quality when used for dilutions. They of up to 50% are available in drums. All are equipped are also equipped with pumps, hoses and fittings for with a venting device in the drum head and should never attachment to bulk storage systems. Unloading and be palletized or stacked in a way that would damage or dilution are performed by FMC Driver/Technicians. block the vent. Hydrogen peroxide drums should be A minimum delivery of 1500 gallons (5.7m3) is stored on metal or plastic pallets. Since H2O2 is a rapid generally required. oxidizer, drums should never be stored on wooden pallets. Drums should be handled and emptied using dedicated special drum rockers, bung wrenches and unloading equipment.
23 Distribution Services continued
Tank Cars A computer sourcing model is used to analyze all Special aluminum railroad tank cars—from 4,000 customer shipments of hydrogen peroxide. This to 20,000-gallon (approximately 15 to 76m3) ensures minimum delivery times, provides back-up capacities—normally deliver hydrogen peroxide up locations, and helps us maintain adequate fleet size to 70% concentration. Customers perform unloading and inventory levels to meet our customers' requirements. and dilution, with instructions and training from FMC. Special tracking systems are utilized at FMC to provide Before a customer decides to dilute hydrogen peroxide up to date information on the location of Rail and shipments to 35% or 50% from 70%, FMC will assist Tr uck shipments. Please contact your sales representative in the sampling and analysis of the water supply to for additional information regarding this service. determine its suitability for use. If the water is not suitable for use either ‘as is,’ or after deionization, Rail Shipments and Deliveries straight 35% or 50% hydrogen peroxide must be specified when ordering. A fleet of 20,000-gallon jumbo rail cars stocks our North American distribution centers with hydrogen peroxide from FMC plants in Spring Hill, West Virginia, Bayport, Texas and Prince George, British Columbia. FMC also provides direct rail shipments to customers. The fleet includes 4,000, 6,000, 8,000 and 10,000 gallon cars for specialized customer needs. Tank Truck Deliveries with FMC Driver/Technicians
FMC Driver/Technicians deliver hydrogen peroxide in a modern fleet of tank trucks, the largest fleet in North America. FMC tank trailers are totally dedicated to hydrogen peroxide service. This eliminates the possibility of contamination with other products. Distribution Network and Fleet Many of the tankers are equipped with deionization units to improve water quality. Some tank trailers are FMC operates an extensive distribution network lined with polyethylene for use in transporting throughout North America and worldwide to provide semiconductor grade peroxide. customers with fast, dependable service. ‘Becoming our customer's most valued supplier’ is not just a Specially trained Driver/Technicians operate FMC's slogan, but our day-to-day commitment. Throughout tank truck fleet. These skilled FMC employees have the United States and Canada, our strategically located have been recognized nationally in DISTRIBUTION and distribution centers have extensive storage capabilities. MODERN BULK TRANSPORTER magazines for providing Most customers are within hours of an FMC the highest quality of delivery service. distribution center.
FMC also supplies many chemical distributors throughout North America to further provide a reliable local source of product.
24 FMC Driver/Technicians understand hydrogen peroxide and inspect customer storage tanks for FMC Driver/Technician possible contamination or leakage. They take samples performs analysis during of the peroxide in the customer storage tanks before delivery to a customer and after delivery and test the samples for pH, plant. concentration and stability. They also check water conductivity during dilution deliveries.
Driver/Technicians are carefully trained and routinely deliver 70% hydrogen peroxide and dilute it to lower concentrations required by the customer. This can result in sign)ficant freight savings to our customers.
For hydrogen peroxide delivery, dilution and tank inspections, an experienced Driver/Technician is your front line contact.
25 Sales and Customer Service
Sales Services
Field Sales Representatives FMC's field sales representatives are your point of contact for all FMC services. Our advanced field communication networks assure ready access to our representatives. These individuals are highly trained professionals with extensive experience serving hydrogen peroxide consuming industries. They can help meet your hydrogen peroxide requirements and assist you with technical, engineering, safety and application services. Customer Service
Customer Service Representatives Our customer service representatives are experienced professionals prepared to handle your hydrogen peroxide orders and sample requests, and provide up-to-date information about product availability, delivery status, freight costs, quality and safety. They utilize FMC's customer service system (CSS), which is one of the most advanced computer order entry and transportation management systems in the chemical industry. The CSS network instantaneously transmits information about your order to sales, manufacturing and distribution operations, ensuring that your order is handled quickly and efficiently.
26 The FMC Commitment
Reliability Service Quality Safety
FMC strives to become your most valued supplier. Our advanced engineering service provides safe and Our commitment to uncompromised Reliability, efficient storage and handling systems. Finally, our Quality, Service and Safety ensures every customer distribution services, with our FMCemployed driver/ the most complete value package in the industry. technicians, provides the safe and reliable delivery of a quality product. Reliability Quality FMCis the only producer of hydrogen peroxide in North America operating four plants on five separate FMC offers all commercial grades of hydrogen cycles which are backed up by sister plants throughout peroxide which are specially stabilized for our the world. FMC also provides the most extensive customer's applications. Implementation of SPC hydrogen peroxide distribution network in the (Statistical Process Control) programs at all our industry. With FMC reliability, you get the right hydrogen peroxide plants enables FMC to supply product, at the right place, at the right time. product of the highest quality with every shipment. Service Safety
As a leading supplier of hydrogen peroxide for over Overriding our Reliability, Service and Quality 60 years, FMC provides expert technical service for programs is our utmost concern- Safety. You can every application of hydrogen peroxide. rely on FMC's technicians who are trained to provide expert advice and assistance in the safe handling of all applications.
Becoming your most valued supplier for every hydrogen peroxide need.
27 FMC Corporation Hydrogen Peroxide Division 1735 Market Street Philadelphia Pennsylvania 19103
Questions on hydrogen peroxide?
Call 215-299-6000
in Eastern Canada call Estern region Sales Offices at 1-800-668-5166
in Western Canada call Vancouver Sales Office collect at 1-800-567-5700
and Super D are registered trademarks of FMC Corporation. © 2002 FMC Corporation. All rights reserved. 105ICG0302.RS FMC Corporation Hydrogen Peroxide Division 1735 Market Street Philadelphia, PA 19103 Phone: 1-800-442-6236 URL at: http://www.fmcchemicals.com
Hydrogen Peroxide - Standard Grade
CAS NO 7722-84-1
Introduction
Standard Grade hydrogen peroxide is formulated with an inorganic tin-based stabilizer system for high stability and long-term storage. The 70% concentration can be diluted to 35% or 50% concentration with most ordinary tap water found in North America. This permits a customer to achieve maximum economy by purchasing hydrogen peroxide at 70% concentration and diluting it to 35% or 50% for storage. This hydrogen peroxide product is suitable for storage at 70% concentration if desired. Product diluted and drummed at FMC locations meets the stringent assay and stability specifications below.
Standard Grade Hydrogen Peroxide is used extensively for pulp, textile, and environmental applications. It is the most suitable grade available for industrial purposes and should be used whenever possible. ______
Specifications 35% 50% 70% H2O2 content, % by weight Product diluted at FMC sites 35.0-35.8 50.0-50.8 70.0-70.8 Stability, 24 hours @ 100° C >96.0% >96.0% >96.0%
35% 50% 70% Typical Properties Loss in % assay, 1 yr, 25° C <0.7 <1.0 <1.4 Apparent pH <3.7 <3.0 0-1.0 Sn, ppm 25-35 36-50 50-70 Active oxygen content, % 16.5 23.5 32.9 Specific gravity (20° C/4° C) 1.13 1.20 1.29 Lbs/gal (kg/M3 or g/L) @ 20° C 9.4(1126) 10.0(1198) 10.8(1294) Boiling point, ° C (° F) 108(226) 114(237) 126(259) Freezing point, ° C (° F) -33(-27) -52(-62) -40(-40) ______
Standard Containers Polyethylene drums: 15 gallon (56.8 liter), 30 gallon (113.6 liter), 55 gallon (208.2 liter). Bulk shipments are available in tank trucks and tank cars. Hydrogen peroxide above 8% concentration is classified as an "Oxidizer" by the Department of Transportation and all containers must carry the yellow DOT label. ______
The information contained herein is, to our knowledge, true and accurate. However, we make know warranty or representation, expressed or implied, and nothing contained herein should be construed as permission or recommendation to infringe any patent. All intellectual property rights to this material is retained by FMC Corporation. Last Revised 06/23/03.
Environmental Solutions
Procedure for Activating Klozur® Persulfate with an 8% Hydrogen Peroxide Solution
Background
Klozur Persulfate can be activated with hydrogen peroxide to generate sulfate radicals, which are capable of destroying a wide range of organic contaminants. In general, hydrogen peroxide is dosed in conjunction with Klozur persulfate in a ratio of 1 mole hydrogen peroxide to 1 mole persulfate up to 10 moles hydrogen peroxide to 1 mole persulfate. Typically, a mole ratio of 5 : 1 hydrogen peroxide to persulfate is sufficient to treat most contaminants under a wide range of site conditions.
Safety and Handling
Hydrogen peroxide is a strong oxidant, capable of generating significant heat and gasses when applied in the subsurface.
Review the MSDS with all workers prior to handling this chemical.
Hydrogen peroxide is sold commercially in a variety of concentrations. Common concentrations include 70%, 50%, 17.5%, and 8%. Highly concentrated forms of hydrogen peroxide may generate extreme exothermic reactions upon injection into the subsurface or when contacting high levels of contamination, potentially liberating significant quantities of gas. Care must be taken to avoid excessive heat and gas evolution as this may cause damage to utilities, buildings and represents a safety hazard if not properly controlled.
FMC recommends hydrogen peroxide solutions of no more than 8% by weight be used to activate Klozur persulfate.
This will help to minimize the generation of heat and gas upon injection of hydrogen peroxide into the subsurface.
Use of hydrogen peroxide solutions in excess of 8 wt% may increase the risk of injury, loss of product containment and equipment damage.
Activation Procedures
1. Determine the quantity of Klozur Persulfate in lbs to be injected into the treatment area at the contaminated site.
2. Determine the number of moles of Klozur persulfate:
FMC and Klozur are trademarks of the FMC Corporation. Copyright 2008 FMC Corporation. All rights reserved. Document: 02-01-EIT-DH. This document is for guidance purposes only and does not guarantee freedom from injury or damage. Review all relevant MSDS’s. For questions, please contact the Environmental Industry Team (EIT) at 866-860- 4760.
Environmental Solutions
moles Klozur persulfate = lbs of Klozur persulfate / 238
3. Determine the number of moles of hydrogen peroxide needed;
moles of hydrogen peroxide = moles of Klozur persulfate x 5
4. Determine the lbs of hydrogen peroxide needed:
lbs of hydrogen peroxide = moles hydrogen peroxide x 34
5. Determine the gallons of 8% hydrogen peroxide needed:
Gallons of hydrogen peroxide = lbs of hydrogen peroxide / 0.684
Applying Klozur solution and hydrogen peroxide activator to a contaminated site
1. Hydrogen peroxide can be injected after injecting Klozur Persulfate
2. It is recommended that if the Klozur persulfate and 8 wt% hydrogen peroxide solution are added simultaneously
No more than 5 gallons of 8% hydrogen peroxide should be added per gallon of 30% Klozur solution
No more than 3 gallons of 8% hydrogen peroxide should be added per gallon of 20% Klozur solution
No more than 2 gallons of 8% hydrogen peroxide should be added per gallon o 10% Klozur solution
It is always safer to inject the materials sequentially. If mixing hydrogen peroxide and Klozur persulfate above ground, insure safe conditions. Use clean water and clean mixing and handling equipment. Transition metals in the supply water, such as iron, can result in rapid decomposition of the hydrogen peroxide. It is recommended that oxidant solutions be injected promptly into the subsurface and avoid delays resulting in the solutions remaining in mix tanks for extended periods of time. Also use vented tanks and piping when using oxidizing solutions. Always drain lines to empty and avoid trapping solution between valves for extended periods of time. Do not “dead head” pumps. When injecting hydrogen peroxide solutions, it is recommended that temperature and back-pressure be monitored and controlled to prevent highly exothermic, subsurface reactions.
FMC and Klozur are trademarks of the FMC Corporation. Copyright 2008 FMC Corporation. All rights reserved. Document: 02-01-EIT-DH. This document is for guidance purposes only and does not guarantee freedom from injury or damage. Review all relevant MSDS’s. For questions, please contact the Environmental Industry Team (EIT) at 866-860- 4760.
Technical data KlozurTM Environmental grade persulfate CAS No. 7775-27-1
Typical formula by weight percent Na2S2O8 99% MW 238.1 g/mol
Active oxygen content 6.7% pH of solution strength wt% pH 20% 5.9 Note: pH of solution will decrease over time.
Typical properties Odor none Appearance white crystals Melting point decomposes
Solubility @ 25°C 73 grms/100 grms H2O Loose bulk density, lb/ft3 69.9 Crystal density, g/cc 2.59
Typical metallic impurity concentrations (ppm) Iron 2 Copper <0.2 Chromium <0.15 Lead <0.2
Uses Chemical oxidation of organic contaminants in conjunction with FMC Activation Chemistries
Shipment/container information: DOT Classification: 5.1 (Oxidizer), yellow Oxidizer label. 55 lb (25 kg) polyethylene bag; 225 lb (102.3 kg) fiber drum with polyethylene liner; 2,200 lb (1,000 kg) woven polypropylene sack with polyethylene liner
HMIS classification: Health 1 Flammability 0 Physical hazard 1 Personal protection J
The information contained herein is, to our knowledge, true and accurate. Because conditions of use are beyond our control, we make no warranty or representation, expressed or implied, except that the products discussed herein conform to the chemical descriptions shown on their labels. Nothing contained herein should be construed as permission or recommendation to infringe any patent. No agent, representative, or employee of this company is authorized to vary any of the terms of this notice. FMC logo and Klozur are trademarks of FMC Corporation. © 2006 FMC Corporation. All rights reserved. Document No. 01-01-EIT-DF. 01/03/06.RS
FMC Corporation Active Oxidants Division 1735 Market Street Philadelphia, Pennsylvania 19103 215-299-6000 Environmental Solutions
Safe Handling, Use and Storage Technical Bulletin
Background First Aid Klozur ® sodium persulfate is a stable, Eye Contact – flush with water for at highly soluble, crystalline material, least 15 minutes. If irritation occurs and which upon activation is capable of persists, obtain medical attention. oxidizing a broad range of recalcitrant Skin Contact – wash with plenty of compounds. When properly handled soap and water. If irritation occurs and and stored, sodium persulfate does not persists, obtain medical attention. Wash present a serious health hazard. clothing before reuse. However, as with all oxidizing chemicals, Klozur ® sodium persulfate Inhalation – get fresh air. If breathing requires careful attention to all aspects difficulty or discomfort occurs, call a of handling and use. This bulletin physician. covers the basic safe handling, use and Ingestion – drink one to two glasses of storage practices for Klozur ® sodium water. Do not induce vomiting. Call a persulfate. For more information, physic ian immediately. please refer to the Material Safety Data Sheet (MSDS), which is available from FMC. Flammability 0 Personal Protective Health Equipment Eye protection – wear chemical 1 1 goggles or a face shield whenever splashing, spraying or eye contact is Reactivity possible. OXY Respir atory – use dust respirator approved by NIOSH/MSA whenever Disposal exposure may exceed the established Klozur ® persulfate crystals should never standard listed in the MSDS. be discarded in trash bins. Contact with Hands – wear general purpose moisture, contaminants, and / or neoprene gloves reducing agents can initiate a chemical reaction or persulfate decomposition. Clothing – wear ordinary work clothes Persulfate crystals that become waste with long sleeves and full -length pants. material are classified as hazardous waste, because they are oxidizers. Footw ear – wear shoes with chemical Persulfate that is spilled on the floor, or resistant soles (neoprene) otherwise contaminated, is best dissolved in copious amounts of water. Do not return spilled persulfate back to the original contain er.
FMC and Klozur are trademarks of the FMC Corporation. Copyright 2004 FMC Corporation. All rights reserved. Document: 01 -03 -AOD -DD. For questions, please contact the Environmental Industry Team (EIT) at 866 -860 -4760. Environmental Solutions
An acceptable disposal method for spent Decomposition Hazard of Klozur ® Klozur ® persulfate solutions is to dilute Persulfate Crystals with large quantities of water and dispose Overheating or contamination of via a treatment system. Any disposal persulfate can lead to a self -accelerating method must be in full accordance with all decomposition. Persulfate decomposes to local, state and federal agencies. form solid sulfate salts and emit noxious ® Neutrali zation of Klozur persulfate fumes of SO x. Oxygen and heat released solutions may be performed, but must be from persulfate decomposition may induce done slowly with mild alkali (example: combustion in flammable materials. bicarbonate) with ample heat sink or The only way to halt a decomposition cooling to prevent rapid temperature event is to apply large quantities of water. increases and gas release. One gallon of water per pound of decomposing material is recommended. Materials Compatibility Do not use less than a quart of water per pound of material, as this may intensify 304 and 316 stainless steel are the decomposition. recommended for mixing, conveyance and storage equipment (tanks, pipes, etc.) Other compatible materials include: Observe the following polyvinyl chloride, polyethylene, precautions to prevent ® ® Plexiglas , Teflon , chemical stoneware decomposition: and glass. ® Metals other than 304 and 316 stainless Do not expose Klozur persulfa te or their ste el may cause persulfate containers to moisture. Moisture reduces decomposition, and in turn may be the decomposition temperature. corroded by the persulfate. This is ® particularly true of Monel, copper, brass Do not store Klozur persulfate near and iron. The pH of Klozur ® persulfate incompatible materials: reducing agents, solutions will decrease over time, and may acids, bases, ammoniacal solutions, or drop below a pH of 2. alkaline cleaners. Do not store near point sources o f heat Storage (steam pipes, electrical appliances, Kloz ur ® persulfate should be kept in a heating vents, gas flames radiant heaters, cool, dry storage area. If stored in bulk, etc). Do no store in ambient temperatures NFPA 430 guidelines should be followed. above 113 ºF or 45 ºC ® Do not store or process Klozur persulfate Do not return spilled or unused portions to solutions in sealed or closed containers or the original container. vessels. Normal solution decomposition will rele ase oxygen gas, which may over - Do not use on hydrocarbon free pro duct. pressurize a sealed container and cause rupture. Environmental Solutio ns
Corrosion and Material Compatibility Technical Bulletin
Background
Klozur ® Persulfate solutions are used to treat contaminated soil and groundwater and can remediate a wide range of organic contaminants. However, Klozur ® Persulfate is a very strong oxidant, and its solutions may be very acidic (pH ≤ 2) under many conditions, resulting in a corrosive environment for many metals and materials. In this bulletin, results from corrosion studies using un -activated and activated persulfate solutions are pre sented and recommendations regarding materials of compatibility are made. For additional information regarding the safety of Klozur ® Persulfate, please refer to the Material Safety Data Sheet (MSDS), which is available from FMC.
Corrosion
Laboratory tes ts were conducted to evaluate the performance of commonly -used engineering materials exposed to Klozur ® Persulfate solutions (both activated and un -act ivated). The tests were performed at two different persulfa te solution concentrations : 20 wt% represent ing typical make -up sol utions being injected, and 40 g / L representing typical in situ ground water concentrations. These tests were conducted per the guidelines outlined in ASTM G31 -72 . Corrosio n rates for metallic coupons were calculated based on chan ges in weight over the exposure time. Non -metallic coupons were observed for visual changes and changes in physical properties. Structural properties of concrete and non -metallics were not measured.
Results
For un -activated Klozur ® Persulfate solution s, n o observable corrosion on stainless steel (304L and 316L) was observed during the testing. However, for carbon steel , copper and brass, severe corrosion was observed shortly after the testing was initiated, for both the concentrated (20 wt%) and dilut ed persulfate solutions. The corrosion rates for carbon steel and brass were observed to decrease when evaluated after one and two months as compared to the one week exposure. However, the rates were sufficiently high to indicate that general corrosion w as on -going throughout the two month period, indicating that there was no formation of a protective corrosion - product layer. Kynar ® and FRP demonstrated satis factory performance over the one month exposure with no noticeable weight gain or softening observ ed. Concrete, natural rubber and synthetic rubber showed indications of degradation with long -term exposure to the concentrated persulfate solution.
In general, the impact of the Fe -EDTA activated persulfate solution was similar to the un - activated per sulfate solution. No significant increases in corrosion were observed due to the presence of the activator system or subsequent formation of sulfate radicals.
For high pH act ivated persulfate solutions , sodium hydroxide was added to raise the pH to above 10 and to neutralize sulfuric acid formed upon persulfate decomposition. S ignificant decreases in corrosion rates were observed for high pH activated persulfate in contact with copper, brass and carbon steel. Negligible corrosion was observed for these metals after one month exposure, even at the 20% persulfate concentration. In addition, no noticeable corrosion was observed for stainless steel. Significant reaction with concrete was observed, however. Significant weight gain (5 – 10%) and bleaching w ere observed for the concrete after one month exposure to the
FMC and Klozur are trademarks of the FMC Corporation. Copyright © 2006 FMC Corporation. All rights reserved. Document 04 -02 -EIT -DF. For questions, please contact the Environmental Industry Team at 866 -860 -4760. Environmental Solutions high pH activated persulfate solution, and some dissolution of the concrete was noted during the test.
Table 1: Results for Un -Activated Klozur ® Persulfate Solutions (20 wt%) at room tempera ture after 1 week and 1 months exposure time mpy – milli -inches per year; - compatible material , - non -compatible material Material 1 week 1 month Comments Stainless steels < 1 mpy. No noticeable corrosion over (304L, 316L) 2 months
Copper > 100 mpy 20 – 50 m py Severe general corrosion , corrosion Bras s rate decreases with time.
Severe general corrosion, etching at > 200 mpy 50 – 100 mpy Carbon steel welds , corrosion rate decreases with time. No noticeable changes aft er 2 months Kynar ® (PVDF) exposure FRP No noticeable changes after 2 months (fiber -reinforced plastic ) exposure
Weight gain, Weight gain ( 5 – Increasing weight gain over time. Concrete bleached 10%) , bleached Some dissolution observed as r esidue appearance appearance in test chamber.
Crack s and blisters observed after 1 Natural Rubber Slight weight gain Slight weight gain month exposure. Synthetic rubber Crac ks and blisters observed after 1 Slight weight gain Slight weight gain (neoprene) mo nth exposure
Tab le 2: Results for Un -Activa ted Klozur ® Persulfate Solution ( 40 g / L) at room temperature after 1 week and 2 months exposure time mpy – milli -inches per year; - compatible material , - non -compatible material Material 1 week 1 month Comments Stainle ss steels < 1 mpy. No noticeable corrosion over (304L, 316L) 2 months
Copper > 5 0 mpy < 20 mpy Severe general corrosion , corrosion Brass rate decreases with time.
Several general corrosion, etching at > 5 0 mpy < 20 mpy Carbon steel welds , cor rosion rate decreases with time. No noticeable changes after 1 month Kynar ® (PVDF) exposure FRP No noticeable changes after 1 month (fiber -reinforced plastic ) exposure
Weight gain, Weight gain ( 5 – Increasing weight gain over time. Concrete bleached 10%), bleached Some dissolution observed as residue appearance appearance in test chamber.
Although the above information accurately reflects the results of the tests performed, FMC makes no warranty or representation, expressed or inferred, and nothing herein sh ould be construed as to guaranteeing actual results in field use, or permission or recommendation to infringe any patent. No agent, representative or employee of this company is authorized to vary any of the terms of this notice. Environmental Solutions
Natural Rubber Slight weight gain Slight weight gain
Synthetic rubber Slight weight gain Slight weight gain (neoprene)
Table 3: Results for Fe -EDTA Klozur ® Persul fate Solutions, 20 wt% and 40 g / L at room temperature after 1 month exposure time mpy – milli -inches per year; - compatible material , - non -compatible material 20 wt% Material 40 g / L Comments concentration Stainless steels < 1 mpy. No noticeable corrosion over (304L, 3 16L) 1 month
Copper 20 – 50 mpy < 20 mpy Severe general corrosion , corrosion Brass rate decreases with time.
> 50 mpy 20 - 50 mpy Several general corrosion, etching at Carbon steel welds .
No noticeable changes after 1 month Kynar ® (PVDF) exposure
FRP No noticeable changes after 1 month (fiber -reinforced plastic ) exposure
Weight gain, Weight gain ( 5 – Increasing weight gain over time. Concrete bleached 10%), bleached Som e dissolution observed as residue appearance appearance in test chamber.
Natural Rubber Slight weight gain Slight weight gain
Synthetic rubber Slight weight gain Slight weight gain (neoprene)
Table 4: Results for high pH activate Klozur ® Persulfate Solutions, 20 wt% and 40 g / L at room temperature after 1 month exposure time mpy – milli -inches per year; - compatible material , - non -compatible material 20 wt% Material 40 g / L Comments concentration Stainless steels < 1 mpy. No noticeable corrosio n over (304L, 316L) 1 month
Copper Negligible general corrosion (< 2 mpy). Brass Black film formation observed.
Negligible general corrosion (< 2 mpy). Carbon steel Isolated rust spots observed
Bleached appearance, increasing Weight gain, Weight gain ( 5 – weight gain over time, some Concrete bleached 10% ), bleached dissolution observed as residue in test appearance appearance container.
Although the above information accurately reflects the results of the tests performed, FMC makes no warranty or representation, expressed or inferred, and nothing herein sh ould be construed as to guaranteeing actual results in field use, or permission or recommendation to infringe any patent. No agent, representative or employee of this company is authorized to vary any of the terms of this notice. Environmental Solutions
Material Compatibility
Recommend and Compatible Materials:
• Butyl rubber • EPDM • FRP (fiber reinforced plastic) • Glass • Neoprene • Plexiglas ® • Polyethylene • PVC • Stainless steel (304L and 316L) for all mixing, conveyance and storage equipment • Teflon ® • Viton
Incompatible Materials
• Aluminum Brass • Carbon steel Copper • Galvanized pipe Iron • Monel Nickel • Nitrile rubbers
Well Construction • Use compatible materia ls, such as PVC or Stainless Stee l (304L, 316 L)
Pumps • Check compatibility of all seals, gaskets, tubing and hoses
Geoprobe ® Rods • Threaded joints of rods are very susceptible to corrosion. To help reduce corrosion, several practical measures can be taken, such as applying a barrier layer like Loctite ® or Teflon ® grease to the threads, or utilizing the High pH activation system to reduce acidic corrosion.
Subsurface Utilities • Always check for location and compatibility of subsurface utilities.
Hosing
• Klozur ® persulfate solutions: 20 – 40%, neutral to mildly acidic conditions, moderate to low pressure
Master -Flex 300 EPDM or Equivalent
Specs Max Allowable Working Pressure (diameter) (PS I)
1″ 80 2″ 60 3″ 50 4″ 45 6″ 35
Although the above information accurately reflects the results of the tests performed, FMC makes no warranty or representation, expressed or inferred, and nothing herein sh ould be construed as to guaranteeing actual results in field use, or permission or recommendation to infringe any patent. No agent, representative or employee of this company is authorized to vary any of the terms of this notice. Environmental Solutions
o – 30 F to +140 F o EPDM black inner liner of hosing with polyethylene helix o Reinforced and a Type G (PVC) cover o Medium oil resistance
• Klozur ® persulfate solutions: 20 – 40%, mildly acidic conditions, high pressure
Alfagomma (Italian Company) o Model T 505 4 -4 SP o 6 BAF (240 PSI) o XLPE chemical S&D
Transporter Ultrachem (brand name) o 250 PSI water pressure
• Fittings
304 Stainless – Schedule 40 CPVC – Schedule 80 preferred (could lose strength when heated) PVC (may become embrittled with continued use)
Although the above information accurately reflects the results of the tests performed, FMC makes no warranty or representation, expressed or inferred, and nothing herein sh ould be construed as to guaranteeing actual results in field use, or permission or recommendation to infringe any patent. No agent, representative or employee of this company is authorized to vary any of the terms of this notice. HASP Addendum Former Wilson Jones Co. Facility July 2011
APPENDIX D Lock-Out Tag-Out Policy and Permit Groundwater & Environmental Services, Inc. (GES) Lockout/ Tag out Checklist (Permit)
Name of individual completing the permit: ______Client / Location: Date: ______
Pre-work Guidelines (check if completed)
__ Energy Control procedures have been identified for the equipment or machine. __ Employees have been trained on the Energy Control and lockout/Tag out Procedures. __ Individuals have been trained in the GES Lockout/ Tag out Program.
Lockout/ Tag out Equipment (check if completed)
__ Lockout/ Tag out devices are designed to prevent removal without the use of excessive force or unusual techniques. __ Lockout/ Tag out devices identify the employee applying the device(s). __ Individual locks and keys are supplied to each employee working on the equipment. __ Blocks are used whenever possible injury could result from mechanical movement or gravity. __ Chains or cables are used whenever locking out valves and where locking provisions are not available. __ Tag out devices warn of hazardous conditions if the machine or equipment is energized and include the following: “Danger – Do not Operate”. __ Tag out devices are securely attached to energy isolating devices so that they cannot be inadvertently or accidentally removed.
Lockout/ Tag out Requirements (check if completed)
__ Affected personnel are notified of the machine or equipment to be locked and tagged out. __ Lockout and Tag out devices are used together, when feasible, and are placed directly on the energy isolating devices (i.e. switch, valve, blocking device, etc.). __ “Zero” Energy state has been achieved for all potential sources of energy including, but not limited to: __ - Electrical __ - Chemical __ - Pneumatic __ - Mechanical __ - Thermal __ - Hydraulic __ - Other __ Lockout devices are affixed in a manner that will hold the energy isolating devices in a “safe” or “off” position. __ Each employee working on the machine or equipment has affixed his/her own lock to the isolating device. __ Prior to starting service and maintenance work, the machine or equipment is checked to verify that isolation and/ or de- energizing techniques have been done correctly by attempting to activate or “turn on” the machine or equipment, and checking electrical circuits and sources using a voltmeter or other appropriate test equipment.
Re-energizing Requirements (check if completed)
__ After maintenance or service is complete, the work area is inspected to ensure that nonessential items (i.e. tools, debris, etc.) have been removed from the machine or equipment. __ The machine or equipment components are checked to ensure they are operationally intact. __ Affected employees have been notified that the machinery or equipment will be put back in service. __ Each Lockout device is removed by the employee who applied the device. __ In the event that an employee has left the site and forgot to remove his/her lock, the Supervisor in charge of the operation removes the lock only after ensuring that the employee has left the work site, and he has made a reasonable effort to contact the employee to let him know his lock is going to be or has been removed. __ The equipment or machine is re-energized using manufacturer’s start-up procedures.
Please note reason(s) for not completing: ______Moen Incorporated 2609 Cox Mill Road, Sanford, NC July 2011
ATTACHMENT F – TENTATIVE REMEDIAL ACTION SCHEDULE
Remedial Action Plan Tentative Remedial Action Schedule Moen Incorporated Sanford, North Carolina ID Task Name Duration Start Finish Predec 2011 2012 2013 2014 2015 2016 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 1 Remedial Action 1287 days Thu 4/28/11 Fri 4/1/16 2 Completion of Remedial Investigation 0 days Thu 7/7/11 Thu 7/7/11 7/7 3 Development of Remedial Action Plan 68 days Thu 4/28/11 Mon 8/1/11 4 Public Notice Period 30 days Mon 8/8/11 Fri 9/16/11 3FS+4 5 Remedial Action Plan Implementation 64 days Tue 8/2/11 Fri 10/28/11 6 Procurement of Quotes and Remedial Permits 50 days Tue 8/2/11 Mon 10/10/11 3 7 Remedial Performance Well Installation 10 days Mon 9/26/11 Fri 10/7/11 4FS+5 8 Baseline Groundwater Monitoring 5 days Mon 10/10/11 Fri 10/14/11 7 9 Preparation of Pre-Construction Report (AOC-16C) 64 days Tue 8/2/11 Fri 10/28/11 3 10 Pre-Construction Report (AOC-16C) Implementation 160 days Mon 10/31/11 Fri 6/8/12 11 In Situ Chemical Oxidation (AOC-16C) 40 days Mon 10/31/11 Fri 12/23/11 9 12 Remedial Design Boring Installation 5 days Mon 1/9/12 Fri 1/13/12 11FS+ 13 Treatability Studies 70 days Mon 1/16/12 Fri 4/20/12 12 14 Preparation of Pre-Construction Report (AOC-13/AOC-21) 120 days Mon 12/26/11 Fri 6/8/12 11 15 Pre-Construction Report (AOC-13/AOC-21) Implementation 110 days Mon 4/23/12 Fri 9/21/12 16 Procurement of Quotes and Remedial Permits 50 days Mon 4/23/12 Fri 6/29/12 13 17 In Situ Chemical Oxidation (AOC-13/AOC-21) 60 days Mon 7/2/12 Fri 9/21/12 16 18 Preparation of Construction Completion Report 100 days Mon 9/24/12 Fri 2/8/13 17 19 Preparation of Remedial Action Completion Report 130 days Mon 9/7/15 Fri 3/4/16 20 Completion of Remedial Action, Termination of Agreement 0 days Fri 4/1/16 Fri 4/1/16 45FS+ 4/1 21 22 Performance Monitoring 725 days Mon 3/11/13 Fri 12/18/15 23 Confirmation Soil Sample Collection Event 5 days Mon 3/11/13 Fri 3/15/13 18FS+ 24 1st Quarterly Groundwater Sample Collection Event 5 days Mon 3/11/13 Fri 3/15/13 25 Semi-Annual Groundwater Sample Collection Event 530 days Mon 6/10/13 Fri 6/19/15 29 2nd Quarterly Groundwater Sample Collection Event 5 days Mon 9/16/13 Fri 9/20/13 30 Annual Groundwater Sample Collection Event 535 days Mon 12/2/13 Fri 12/18/15 34 35 Major Submittals 1154 days Mon 10/3/11 Fri 3/4/16 36 Remedial Action Plan 0 days Mon 10/3/11 Mon 10/3/11 3 37 Work Phase Completion Form No. WPC-III 0 days Mon 10/3/11 Mon 10/3/11 4FS+1 10/3 38 Pre-Construction Report (AOC-16C) 0 days Fri 10/28/11 Fri 10/28/11 9 39 Work Phase Completion Form No. WPC-IV 0 days Fri 10/28/11 Fri 10/28/11 10/28 40 Pre-Construction Report (AOC-13/AOC-21) 0 days Fri 6/8/12 Fri 6/8/12 14 41 Work Phase Completion Form No. WPC-IV 0 days Fri 6/8/12 Fri 6/8/12 6/8 42 Construction Completion Report 0 days Fri 2/8/13 Fri 2/8/13 18 43 Work Phase Completion Form No. WPC-V 0 days Fri 2/8/13 Fri 2/8/13 2/8 44 Remedial Action Completion Report 0 days Fri 3/4/16 Fri 3/4/16 19 45 Work Phase Completion Form No. WPC-VI 0 days Fri 3/4/16 Fri 3/4/16 3/4 46 47 Progress Reporting 1240 days Fri 4/15/11 Fri 1/15/16 48 Quarterly Letter Status Reports 457 days Fri 4/15/11 Tue 1/15/13 57 Quarterly Remedial Action Progress Reports 719 days Mon 4/15/13 Fri 1/15/16
Project: 20101217.Moen-Sanford.RI S Task Progress Summary External Tasks Deadline Date: Fri 7/22/11 Split Milestone Project Summary External Milestone
GES - July 2011 Page 1 of 1 Moen - Sanford, NC