KAISER ENVIRONMENT AND FACILITIES MANAGEMENT GROUP IGF Kaiser Engineers, Inc. Gateway View Plaza 1600 West Carson St. Pittsburgh, PA 152 19 412/497-2000 Fax 412/497-2212 http://www.icfkaiser.com November 30, 1998 Mr. John Osolin Geologist / Project Manager US EPA - Region U 290 Broadway -19th Floor New York, NY 10007-1866 Subject: Response to Comments - Pulverizing Services Site Health and Safety Plan Pulverizing Services Site, Moorestown, New Jersey Dear Mr. Osolin: The following responses are provided to comments received from you on November 19, 1998. In addition, an addendum to the Pulverizing Services Site Health and Safety Plan dated, October 29, 1998, is attached to add comment information to the Health and Safety Plan. COMMENT 1; Does OSC agree with sampling in Level D? Response: The following equation was used to calculate real-time action levels for Level D and to upgrade to Level C. This equation conservatively assumes all aerosol detected by real-time instrumentation are contaminated. ( 106 me / kg) (PEL in me / m3) (Soil concentration in mg/ kg) COMMENT 2; No separate spill containment program. Response: Section 9.8 of the HASP has been added to provide the following information: SPILLS If a spill of hazardous material occurs, the following actions will be taken: Notify the field operations leader immediately. Take immediate measures to control and contain the spill within site boundaries. Isolate the hazardous area, and keep unnecessary personnel away. • Stay upwind and keep out of low-lying areas. Allow no flares, smoking, or flames in hazard area. For liquids, keep combustibles away from the spilled materials. 80443-19-B 2D0388 ;F KAISER Mr. John Osolin November 30, 1998 Page! Small Dry Spills Shovel contaminated materials into dry containers and cover. Use care not to make material airborne. Label the containers as to contents and remove to a secure area. Small Liquid Spills Absorb the liquid with sand, clean fill, or other noncombustible absorbent material. Place contaminated material in a container, cover and label it, and remove it to a secure area. COMMENT 3; Site map should show where zones are located. Response: Work zones are established in section 5.3 of the health and safety plan. The site safety and health officer shall identify contaminated areas using flagging and the specific location for the contamination reduction zone prior to the initiation of work. COMMENT 4: Did not see any standing orders for the zones, such as no smoking, eating, etc. in the hot zone; buddy system. Response: Attachment B, Employee Health and Safety Rules, establishes standing orders for site activities. The following section will be added to the health and safety plan: 2.4 BUDDY SYSTEM/SITE COMMUNICATIONS If the size or topography of the site is such that operations will be conducted out of continuous visual contact with support zone personnel, a buddy system, or means of immediate voice communication (two- way radio) shall be instituted. COMMENT S; Site communication information not found. Response: Refer to response to Comment No. 4. COMMENT 6: Routes of exposure are not identified for each contaminant of concern. Response: Table 4-1, Constituents of Concern, has been updated to incorporate routes of potential exposure. In general, the compounds of concern present an exposure hazard through direct contact, but absorption, inhalation and accidental ingestion are also potential routes of exposure. COMMENT 7: Recommend use of a FID instead of a FED as a direct reading instrument for contaminants. Response: Table 4-1, Constituents of Concern, has been updated to incorporate ionization potentials for volatile organic compounds. All the ionization potentials for volatile organic compounds are below 11.7 eV. A PID equipped with an 11.7 eV lamp will be used. 80443-19-B 200389 KAISER Mr. John Osolin November 30, 1998 Page 3 COMMENT 8: The emergency response plan needs to include the following information: 1. Pre-emergency planning. 2. Personnel roles. 3. Emergency recognition and control. 4. Safe distances and places of refuge. 5. Site security and control. 6. Evacuation procedures. 7. Emergency decontamination. Response: Section 9.1 of the HASP shall be revised to include the following information: In the event of an emergency requiring notification of off-site personnel, the field operations leader is responsible for immediately contacting the appropriate agencies. If the field operations leader is unavailable, the site safety officer will perform this function. A list of phone numbers for emergency agencies and utilities will be posted near each phone in the field office. Each day or as often as necessary, the field operation leader shall designate an assembly point in case of emergency (i.e. main gate). Whenever an employee reports, or becomes aware of an emergency conditions, the employee shall immediately contact the field operations leader via two-way radio and proceed to the designated assembly point. The field operation leader shall account for all personnel on site, and shall provide instructions on further actions to be taken, including declaration of "all clear". Upon arrival of emergency response personnel, the field leader will relinquish control of the emergency to response personnel. The field leader will control access of unauthorized visitors to the site and provide safe egress for emergency vehicles. In the event of injury occurring to an individual while contaminated, the designated first aid personnel shall conduct decontamination procedures on the injured party donning the appropriate level of PPE. If the severity of injury does not permit decontamination prior to removal from the site, the field operations leader shall inform emergency rescue personnel of possible contaminates and wrap the victim in a blanket or similar barrier creating devices to prevent cross contamination. Should you have any questions regarding the responses to these comments, please feel free to contact Dan Welshons at 412/497-2329 or myself at 412/497-2265. A. Douglas Weeks, Jr. -Daniel J. Welshons, CSP Project Manager Safety and Health Manager Am Attachment cc: Patrick J. Kelly, P.P.G. 80443-19-B 2003,10 HEALTH AND SAFETY PLAN ADDENDUM Section: 2.4.4.0.9.1.9.8 Addendum: SITE DESIGNATION / LOCATION; Effective Date: November 30. 1998 Pulverizing Services Site Approved By: Moorestown, New Jersey Project Health and Safety Officer: ___________ Date: SUBJECT; • Buddy System/Site Communication Concurrence: • Hazard Evaluation Project Manager: ____ • Emergency Procedures - General Date: ____ • Spills Sheet: 1 of__5 2.4 BUDDY SYSTEM/SITE COMMUNICATIONS If the size or topography of the site is such that operations will be conducted out of continuous visual contact with support zone personnel, a buddy system, or means of immediate voice communication (two- way radio) shall be instituted. 4.0 Hazard Evaluation (Revised Table 4-1 Attached) 9.1 Emergency Procedures - General In the event of an emergency requiring notification of off-site personnel, the field operations leader is responsible for immediately contacting the appropriate agencies. If the field operations leader is unavailable, the site safety officer will perform this function. A list of phone numbers for emergency agencies and utilities will be posted near each phone in the field office. Each day or as often as necessary, the field operation leader shall designate an assembly point in case of emergency (i.e. main gate). Whenever an employee reports, or becomes aware of an emergency conditions, the employee shall immediately contact the field operations leader via two-way radio and proceed to the designated assembly point. The field operation leader shall account for all personnel on site, and shall provide instructions on further actions to be taken, including declaration of "all clear". 80443-19-B Health and Safety Plan Addendum Pulverizing Services Site November 30,1998 200391 Upon arrival of emergency response personnel, the field leader will relinquish control of the emergency to response personnel. The field leader will control access of unauthorized visitors to the site and provide safe egress for emergency vehicles. In the event of injury occurring to an individual while contaminated, the designated first aid personnel shall conduct decontamination procedures on the injured party donning the appropriate level of PPE. If the severity of injury does not permit decontamination prior to removal from the site, the field operations leader shall inform emergency rescue personnel of possible contaminates and wrap the victim in a blanket or similar barrier creating devices to prevent cross contamination. 9.8 SPILLS If a spill of hazardous material occurs, the following actions will be taken: • Notify the field operations leader immediately. • Take immediate measures to control and contain the spill within site boundaries. • Isolate the hazardous area and keep unnecessary personnel away. • Stay upwind and keep out of low-lying areas. • Allow no flares, smoking, or flames in hazard area. • For liquids, keep combustibles away from the spilled materials. Small Dry Spills Shovel contaminated materials into dry containers and cover. Use care not to make material airborne. Label the containers as to contents and remove to a secure area. Small Liquid Spills Absorb the liquid with sand, clean fill, or other noncombustible absorbent material. Place contaminated material in a container, cover and label it, and remove it to a secure area. 80443-19-B Health and Safety Plan Addendum Pulverizing