DRAFT FOR REVIEW VOLUME 3 HEALTH AND SAFETY PLAN SITE WIDE GROUNDWATER (OPERABLE UNIT 03) WEST LAKE LANDFILL SITE BRIDGETON, MISSOURI June 5, 2019 Project #: 63N-001-001 SUBMITTED BY: Trihydro Corporation 1252 Commerce Drive, Laramie, WY 82070 DRAFT memorandum To: West Lake OU-3 Project-Team Members From: Mr. Stephen L Lombardo, P.G. Date: June 5, 2019 Re: Health and Safety Plan (HASP) Orientation The purpose of this memorandum is to provide project-team members (specifically field team employees) with a Health and Safety Plan (HASP) orientation, including a summary of the project, its common hazards, minimum personal protective equipment (PPE) required, other relevant safety concerns, plus policies and practices unique to the site. Since project history affects information presented to project team members, this orientation is an evergreen document and should be updated as the project progresses. Lessons learned and hazards identified will be documented during daily tailgate safety meetings, recorded on Job Safety Analyses (JSAs) and memorialized in the HASP. This memo must be read in conjunction with the site-specific HASP, which contains detailed site hazard and response information. INTRODUCTION The Site was added to the Superfund National Priorities List (NPL) in 1990 and consists of three Operable Units (OUs) including former industrial and municipal waste cells and groundwater. Operable Unit 1 (OU-1) includes former waste disposal areas Radiological Area 1 (Area 1) and Radiological Area 2 (Area 2) where radiological impacted materials (RIM) exist (EPA ID#MOD079900932). Operable Unit 2 (OU-2) has no areas impacted with RIM and includes the closed construction and demolition (C&D) cell, inactive sanitary landfill, and the North and South Quarry Portions of the Bridgeton Landfill. OU-2 is managed by the Missouri Department of Natural Resources (MDNR). OU-3 includes groundwater beneath the entire 212-acre Site and is the focus of this Remedial Investigation/Feasibility Study (RI/FS). The RI/FS portion of the project is anticipated to begin in 2019 and go through 2023. Currently, the Exclusion Zone atDRAFT the Site is controlled by Feezor Engineering and Ameriphysics, LLC for OU-1 related activities and routine groundwater and air monitoring. Trihydro will defer to and adhere to the existing health and safety policies/procedures regarding working within the OU-1 Exclusion Zone. PROJECT/SITE HISTORY For ease of discussion, the Site is divided into five units: . Area 1 . Area 2 . Closed Demolition Landfill . Inactive Sanitary Landfill . The Bridgeton Landfill Project-Team Members Health and Safety Plan Orientation June 5, 2019 Page 2 OU-1 comprises Area 1, Area 2, the Buffer Zone, and Crossroads Properties LLC Lot 2A2. The Bridgeton Landfill, the Closed Demolition Landfill, and the Inactive Sanitary Landfill are all part of OU-2. The West Lake Landfill contains multiple areas of differing past operations. The landfill property was used agriculturally until a limestone quarrying and crushing operation began in 1939. The quarrying operation continued until 1988 and resulted in shallow excavation areas and two quarry pits, the North Quarry Pit and the South Quarry Pit. The South Quarry Pit was excavated to a maximum depth of 240 feet below ground surface (ft bgs) and had a bottom elevation of approximately 240 feet (ft) above mean sea level (msl). The Site contains several areas where solid wastes have been disposed. The date on which landfilling activities started at the West Lake Landfill is not known with certainty and has been variously cited as beginning in or around the early 1950s, or as starting in 1952 or possibly 1962. The landfill was not officially permitted for use as a sanitary landfill until 1952. EPA has reported that “from 1941 through 1953 it appeared that limestone extraction was the prime activity at the facility; however, as time passed the focus of the activity appeared to shift to waste disposal”. EPA has reported that historical aerial photography from 1953 indicates use of a landfill had commenced. Mine spoils from quarrying operations were deposited on adjacent land immediately to the west of the quarry. Portions of the quarried areas and adjacent areas were subsequently used for landfilling municipal refuse, industrial solid wastes, and C&D debris. EPA has reported that liquid wastes and sludges were also disposed of at the landfill. These operations, which predated state and federal laws and regulations governing such operations, occurred in areas that subsequently have been identified as Area 1, Area 2, the Closed Demolition Landfill, and the Inactive Sanitary Landfill. Due in part to the fact that the disposal of solid and liquid waste at the Site predated state and federal regulations for landfills, there is DRAFTuncertainty regarding the specific site activities and disposal practices conducted on-site. Specifically, based upon a review of historical aerial photographs as documented in the Aerial Photographic Analysis of the West Lake Landfill Site, “deep” pits, lagoons, and other Site features related to past on-site disposal practices have been identified on several historical aerial photographs for years pre-dating the arrival of radionuclides from the Latty Avenue Site. This project HASP is specifically geared towards the OU-3 RI/FS field scope of work. WORK SCOPE The OU-3 RI/FS is designed to document the nature and extent of releases of any hazardous substance from the Site in groundwater and determine the potential risk posed to human health and the environment. The objective of the RI/FS is to refine the current understanding of the hydrogeologic system, evaluate background water quality near the Site, determine the extent of groundwater impacts occurring at and Project-Team Members Health and Safety Plan Orientation June 5, 2019 Page 3 near the Site, provide predictive tools/models to evaluate potential future impacts, and based on the information collected, identify potential groundwater remedies that may be implemented at the Site. The primary hydrogeologic investigation and groundwater characterization tasks will include: 1. Well inventory and repair. 2. Surveying and mapping the existing groundwater monitoring network. 3. Advancing soil borings for geologic logging investigation. 4. Downhole geophysics. 5. New monitoring well installation on-site and off-site. 6. New and existing well development. 7. Groundwater sampling. 8. Install surface water gauges on and off site. Tasks included in the field investigation may include, but are not limited to, surficial and subsurface geologic investigations and sampling, monitoring well/soil boring drilling and installation, fluid level gauging, aquifer testing, groundwater sampling, surface water sampling, storm water sampling, sediment sampling, surface soil sampling, leachate sampling, methane gas sampling/monitoring, surveying/global positioning system (GPS), vapor intrusion investigations, ecological assessments, and routine site visits. MINIMUM/ANTICIPATED PERSONAL PROTECTIVE EQUIPMENT (PPE) The minimum PPE to enter the Site is listed below. However, refer to the HASP and task-specific Job Safety Analysis (JSA) forms for additional anticipated PPE. There are also additional requirements as outlined in the Radiation Safety DRAFTPlan included with this HASP as Appendix J. Safety-toed boots . Safety glasses . Hard hat . Work gloves . Tyvek (as needed) . Chemical resistant gloves (as needed) . Half-face APR (as needed) . Nitrile gloves, 4-gas meter (as needed) Project-Team Members Health and Safety Plan Orientation June 5, 2019 Page 4 . H2S monitor (as needed), photo-ionization detector (PID) (as needed) . Geiger counter (as needed) . Hearing protection (as needed) . Pocket dosimeter (as needed) . High-visibility vest TRAINING/DRUG SCREENING REQUIREMENTS . Occupational Safety and Health Administration Hazardous Waste Operations and Emergency Response (OSHA HAZWOPER) 40-Hour Training . Generalized Employee Radiological Training (GERT) Training (as needed) . Bridgeton Landfill On-Site Orientation The drug consortium applies to project team members who must be enrolled and screened before site entry. In accordance with the Trihydro Drug and Alcohol Policy described in the HASP Reference Manual, at no time while on duty may employees use or be under the influence of alcohol, narcotics, intoxicants, or similar mind-altering substances to include prescription medications. Employees found under the influence or consumption of substances are to be immediately removed from the jobsite. Trihydro reserves the right to test for substance abuse. As part of implementing Trihydro’s program to deter alcohol, drug, and substance abuse, each employee may be requested to submit to urine, blood, or other medical tests at any time, with or without notice. Employees are further subject to “for cause” drug, alcohol, or substances testing. “Cause” is determined if the company has reason to believe that the covered worker has used alcohol or illegal drugs or has misused prescription medication or over-the- counter drugs. Key reasons for testing may include the following: accidents, injuries, near misses, excessive absences, tardiness, altercations,DRAFT lengthy absences, possession of drugs, or thefts. This policy applies to Trihydro employees and subcontractors. Drug Testing Facilities Concentra Medical Center 83 Progress Pkwy Maryland Heights, MO (314) 434-8174 Mercy Urgent Care - St Peters 637 Dunn Road Suite 101 Hazelwood, MO (314) 817-2000 MOBILE PHONE AND