it tetra tech nus, inc. · 'it tetra tech nus, inc. 0 600 clark avenue, suite 3 king of prussia. pa...

TETRA TECH NUS, INC. 'It 600 Clark Avenue, Suite 3 King of Prussia. PA 19406- I433 0 Tel 6 10.49 1.9688 Fax 6 10.49 1.9645 w . t e t r a t e c h corn PHIL-I9226

June 10,2005

Project Number 7673

Mr. Robert Prince United States Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, Pennsylvania 19406-1415

Reference: RAC 3 Program EPA Contract No. 68-S6-3003

Subject: Health and Safety Plan (HASP) EPA Work Assignment No. 059-RICO-03DG Safety Light Corporation (SLC) Site Remedial Investigation/Feasibility Study (RVFS)

Dear Mr. Prince:

Enclosed please find one copy of the HASP for the subject site. The HASP was prepared by Tetra Tech NUS, Incorporated (TtNUS) under contract to the United States Environmental Protection Agency (EPA). Linda Dietz, EPAs remedial project manager for this site, has directed TtNUS to provide this plan to you.

If you have any questions, please do not hesitate to contact me at 610-491-9688.

Sincprely,

;kndrew /e- bowitz l L 1 I . Project dfanager

C: Linda Dietz (EPA Region 3) File 6.3

NMSSIRGNl MATERIALSOOZ

HEALTH AND SAFETY PLAN

REMEDIAL INVESTIGATION / FEASIBILITY

STUDY

SAFETY LIGHT CORPORATION

BLOOMSBURG, COLUMBIA COUNTY, PENNSYLVANIA

EPA WORK ASSIGNMENT NUMBER 059-RICO-03DG

TETRA TECH NUS PROJECT NUMBER 7673

RAC 3 PROGRAM

CONTRACT NUMBER 68-S6-3003

MAY 2005

TETRA TECH NUS, INC.



STUDY





RAC 3 PROGRAM

CONTRACT NUMBER 68-S6-3003

MAY 2005



STUDY





RAC 3 PROGRAM

CONTRACT NUMBER 6866-3003

MAY 2005



STUDY





RAC 3 PROGRAM

CONTRACT NUMBER 6846-3003

MAY 2005


REMDIAL INVESTIGATION/FEASIBlLlTY STUDY

SAFETY LIGHT CORPORATION BLOOMSBURG, COLUMBIA COUNTY, PENNSYLVANIA

EPA WORK ASSIGNMENT NUMBER 059-RICO-03DG EPA CONTRACT NUMBER 6846-3003


Tetra Tech NUS, Incorporated 600 Clark Avenue, Suite 3

King of Prussia, Pennsylvania

MAY 2005

SUBMITTED BY: APPROVED gY:

TETRA TECH NUS, INC. PITTSBURGH, PENNSYLVANIA

TETRA TECH NUS, INC. KING OF PRUSSIA, PENNSYLVANIA

TABLE OF CONTENTS

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SECTION PAGE

1 . 0 INTRODUCTION ........................................................................................................................... 1.1 SITE HISTORY AND BACKGROUND ............................................................................. 1-2 1.1

1.2 KNOWN WASTE/DISPOSAL ........................................................................................... 1-2 1.2 SUMMARY OF PREVIOUS INVESTIGATIONS .............................................................. 1-4

2.0 SCOPE OF WORK ........................................................................................................................ 2-1

3.0 PROJECT TEAM ORGANIZATION .............................................................................................. 3-1 3.1 3.1 . 1 TtNUS Project Manager 3-1 3.1.2 3.1.3 3.1.4 3.1.5

KEY PROJECT PERSONNEL AND ORGANIZATION .................................................... 3-1

TtNUS RAC 3 Health and Safety Manager ...................................................................... 3-1 TtNUS Field Operations Leader ....................................................................................... 3-2 Site Safety Officer ............................................................................................................. 3.2

...................................................................................................

TtNUS and Subcontractor Personnel ............................................................................... 3-3

4.0 TRAININGMEDICAL SURVEILLANCE REQUIREMENTS ......................................................... 4-1 4.1 INTRODUCTORY/REFRESHER/SUPERVISORY TRAINING ........................................ 4-1

4.2 SUBCONTRACTOR EXCEPTIONS ................................................................................ 4-1 4.3 SITE-SPECIFIC TRAINING .............................................................................................. 4-2 4.4 OTHER TRAINING ........................................................................................................... 4-2 4.5 MEDICAL SURVEILLANCE ............................................................................................. 4-2

4.1.1 4.1.2

Requirements for Tetra Tech NUS Personnel .................................................................. 4-1 Requirements for Subcontractors ..................................................................................... 4-1

4.6 MEDICAL DATA SHEETS ................................................................................................ 4-3

5.0 HAZARD ASSESSMENT .............................................................................................................. 5-1 5.1 5.1.1 5.1.2 5.2 5.2.1 5.2.2 5.2.3 5.2.4 5.2.5 5.2.6 5.2.7 5.2.8 5.2.9 5.3 5.3.1

CHEMICAL HAZARDS ..................................................................................................... 5-1 Site Contaminants ............................................................................................................ 5-1

Heavy Equipment Hazards .............................................................................................. 5-2

Slips, Trips, and Falls ....................................................................................................... 5-3

Drum Handling .................................................................................................................. 5-5

Severe Weather ............................................................................................................... 5-7 Heat and Cold Stress ....................................................................................................... 5-7

Fauna ............................................................................................................................... 5-9

Chemical Used On Site .................................................................................................... 5-2 PHYSICAL HAZARDS ...................................................................................................... 5-2

Energized Systems ........................................................................................................... 5-2

Heavy or Awkward Lifting ................................................................................................. 5-3 Portable Power Hand Tools .............................................................................................. 5-3

Compressed Gases .......................................................................................................... 5-6

BIOLOGICAL HAZARDS .................................................................................................. 5-9

5.3.1.1 Venomous Snakes .......................................................................................................... 5-9 5.3.1.2 Insects and Spiders ........................................................................................................ 5-10 5.3.1.3 Other Animals ................................................................................................................. 5-11 5.3.2 Flora ............................................................................................................................... 5-12

ii

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. TABLE OF CONTENTS CONTINUED

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SECTION PAGE

6.0 AIR MONITORING ........................................................................................................................ 6-1 INSTRUMENTS AND USE ........................................................................................... 6-1

HAZARD MONITORING FREQUENCY ....................................................................... 6-1 INSTRUMENT MAINTENANCE AND CALIBRATION ................................................. 6-1

6.1

6.2 6.3

6.1.1 Photoionization Detector ............................................................................................... 6-1

7.0 PERSONAL PROTECTIVE EQUIPMENT .................................................................................... 7-1 7.1 LEVELS OF PROTECTION ......................................................................................... 7-1 7.2 SELECTION OF LEVELS OF PROTECTION .............................................................. 7-1 7.3 RESPIRATORY PROTECTION PROGRAM ................................................................ 7-2 7.4 DECONTAMINATION .................................................................................................. 7-2

8.0 SITE CONTROL MEASURES ...................................................................................................... 8-1 8.1 EXCLUSION ZONE .......................................................................................................... 8-1

8.2 CONTAMINATION REDUCTION ZONE .......................................................................... 8-1 8.3 SUPPORT ZONE ............................................................................................................. 8-2 8.4 SITE VISITORS ................................................................................................................ 8-2 8.5 SITE SECURITY AND ACCESS ...................................................................................... 8-3 8.6 SITE MAP ......................................................................................................................... 8-3 8.7 BUDDY SYSTEM ............................................................................................................. 8-3 8.8 MATERIAL SAFETY DATA SHEET (MSDS) REQUIREMENTS ..................................... 8-4 8.9 COMMUNICATION .......................................................................................................... 8-4 8.10 SAFE WORK PERMITS ................................................................................................... 8-4

8.1.1 Exclusion Zone Clearance ................................................................................................ 8-1

9.0 SITE HEALTH AND SAFETY STANDARD OPERATING PROCEDURES ................................. 9-1 9.1 GENERAL SAFE WORK PRACTICES ............................................................................ 9-1 9.2 DRILLING OPERATIONS - SAFE WORK PRACTICES ................................................. 9-3 9.2.1 Before Drilling Operations ............................................................................................... 9-3 9.2.2 During Drilling Operations ................................................................................................ 9-3 9.2.3 After Drilling Operations ................................................................................................... 9-4

10.0 EMERGENCY RESPONSE / CONTINGENCY PLAN ................................................................ 10-1 10.1 INTRODUCTION ............................................................................................................ 10-1 10.2 EMERGENCY PLANNING ............................................................................................. 10-1 10.3 EMERGENCY RECOGNITION AND PREVENTION ..................................................... 10-2 10.3.1 Recognition ..................................................................................................................... 10-2 10.3.2 Prevention ....................................................................................................................... 10-3 10.4 EVACUATION ROUTES, PROCEDURES, AND PLACES OF REFUGE ...................... 10-3 10.5 DECONTAMINATION PROCEDURES / EMERGENCY MEDICAL TREATMENT ....... .1 0-4 10.6 EMERGENCY CONTACTS ............................................................................................ 10-4 10.7 EMERGENCY ALERTING AND ACTION/RESPONSE PROCEDURES ....................... 10-8 10.8 PPE AND EMERGENCY EQUIPMENT ......................................................................... 10-8 10.9 INJURY/ILLNESS REPORTING .................................................................................... 10-9

iii

TABLE OF CONTENTS CONTINUED

SECTION PAGE

11 .O SPILL CONTAINMENT PROGRAM ........................................................................................... 11-1 11.1 SCOPE AND APPLICATION .......................................................................................... 11 -1 1 1.2 POTENTIAL SPILL AREAS ............................................................................................ 11-1 1 1.3 CONTAINMENT AREAS ................................................................................................ 11 -1 11.3.1 IDW ................................................................................................................................ 11-2 11.3.2 Flammable/POL Storage ................................................................................................ 11-2 1 1.4 MATERIALS HANDLING ................................................................................................ 11-2 1 1.5 LEAK AND SPILL DETECTION ..................................................................................... 11-3 11.6 PERSONNEL TRAINING AND SPILL PREVENTION ................................................... 11-3 1 1.7 SPILL PREVENTION AND CONTAINMENT EQUIPMENT ........................................... 11 -3 1 1.8 SPILL CONTAINMENT/CONTROL RESPONSE PLAN ................................................ 11 -4

12.0 CONFINED SPACE ENTRY ....................................................................................................... 12-1 13.0 HAZARD COMMUNICATION ..................................................................................................... 13-1 14.0 MATERIALS AND DOCUMENTS ............................................................................................... 14-1

14.1 MATERIALS TO BE POSTED AT THE SITE ................................................................. 14-1

15.0 GLOSSARY ................................................................................................................................. 15-1

ATTACHMENTS

ATTACHMENT I - INJURYALLNESS PROCEDURE AND REPORT FORM ATTACHMENT I1 - MEDICAL DATA SHEET ATTACHMENT 111 -TICK CONTROL AND LYME’S DISEASE INFORMATION ATTACHMENT IV -TASK HAZARD ASSESSMENT SUMMARY TABLE ATTACHMENT V - CHEMICALS/RADIONUCLIDES OF CONCERN TABLE ATTACHMENT VI -SAFE WORK PERMITS ATTACHMENT VI1 - EQUIPMENT INSPECTION CHECKLIST ATTACHMENT Vlll - SOP FOR UTILITY CLEARANCE ATTACHMENT IX - SOPS FOR RADIOLOGICAL INSTRUMENT USE

TABLES

NUMBER PAGE

10-1 Emergency Contacts ................................................................................................................... 10-7

iv

TABLE OF CONTENTS CONTINUED

FIGURES

NUMBER PAGE

4-1

6-1

8-1

10-1

10-2

Site-Specific Training Documentation ......................................................................................... ..4-4

Safe Work Permit .......................................................................................................................... 8-5 Emergency Response Protocol ................................................................................................... 10-5 Bloomsburg Hospital ................................................................................................................. 10-1 0

Documentation of Field Calibration ............................................................................................... 6-3

V

1 .O INTRODUCTION

This Health and Safety Plan (HASP) has been developed to provide practices and procedures for Tetra

Tech NUS, Inc. (TtNUS) personnel and subcontractors engaged in site activities related to the Remedial

Investigation / Feasibility Study at the Safety Light Corporation (SLC) Site in Btoomsburg, Columbia

County, Pennsylvania. This HASP has been developed to comply with Title 29 Code of Federal

Regulations (CFR), Part 1910.120 (29 CFR 1910.120) and 29 CFR 1926.65.

This HASP contains the following general information:

Identification of tasks and potential hazards associated with soil, groundwater, surface water and

sediment, ecological and air investigation activities as well as site reconnaissance, topography

surveying, ecological characterization, and multimedia sampling tasks;

Listing of contaminants of concern and the associated hazards;

Required personal protective equipment (PPE), depending on the activity being performed and the

nature of the identified contaminants and physical hazards;

Employee health and safety training requirements;

Emergency response information;

Medical surveillance requirements;

Site control measures;

Confined space entry requirements;

Spill containment requirements;

Frequency and types of air monitoring and exposure monitoring, and;

Decontamination procedures.

This HASP has been developed using the latest available information regarding known or suspected

chemical contaminants and potential physical hazards associated with the proposed work at the Safety

Light Corporation Site. Modifications or updates may be deemed necessary based on expanded scope

or work, updated chemical contaminant information, TtNUS policy or procedural changes, revised

emergency contact information or emergency response procedures, or other conditions that justify

modification of this document. Changes to the HASP will be made with the approval of the TtNUS Project

Manager (PM) and RAC 3 Health and Safety Manager (HSM). Any requests for modifications of this plan

based on field observations will be directed to the HSM, who will determine if the changes are necessary.

1-1

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x

As a supplement to the HASP, the Tetra Tech NUS, Inc. Health and Safety Guidance Manual provides

additional information on many health and safety related topics and provides various company-specific

Standard Operating Procedures (SOPS). This document is referenced throughout this HASP, and will be

available for use by field personnel performing work at the site.

1.1 SITE HISTORY AND BACKGROUND

The SLC facility is located at 4150-A Old Berwick Road, Bloomsburg, Pennsylvania, within the South

Centre Township of Columbia County in central Pennsylvania, about 6 miles east of Bloomsburg and 6

miles west of Berwick. The north site boundary is the Old Berwick Road and the south site boundary is

the Susquehanna River. The site is completely fenced on all sides. SLC owns the Vance-Walton property

located along the southeast corner of the site. Other residential tracts of land are adjacent to the east and

west boundaries of the site. The site is about 10-acres in extent and contains numerous structures and

contaminated areas, including lagoons, dumps, an abandoned canal, and buildings. SLC utilizes a 2-acre

area of the site for its current manufacturing operations. In the 8-acres not under NRC license, third party

companies, USR Metals, Inc. and Multimetals Products Corporation, conduct nonradiological

manufacturing processes that include metal finishing and plating.

Activities at the site have varied over time and involved a number of different radionuclides including, but

not limited to, radium-226 (=Ra), tritium (3H), strontium-90 (%r), americium-241 (241Am), and cesium-

137 (137Cs). Fuel oil, solvents, and heavy metals were also used at the site. During site operations,

buildings, soils, and groundwater at the site have become contaminated with radionuclides. There is also

evidence of vinyl chloride contamination in groundwater. A detailed site history including results of

previous investigations may be found in the Site-Wide RI/FS Work Plan (TtNUS, 2005).

1.2 KNOWN WASTE/DISPOSAL

Wastes generated at the SLC facility include solid and liquid waste streams contaminated with radioactive

materials, including =%A, %r, 137Cs, 241Am, and 3H. Contaminated laboratory glassware was buried on the

property. Contaminated solids were placed inside two old silos buried in the ground (refer to building number 14 on Figure 1-2). According to groundwater analytical data collected by Foster Wheeler in 2000 and

Monserco in 1995, the old silo shows a wSr and '37Cs plume going towards the Susquehanna River.

Concentrated liquid wastes were allowed to evaporate, and the dry residuals were transferred to the

Radiological Services Company. Additionally, plant effluent was discharged into the abandoned canal,

located adjacent to the Susquehanna River. These canals were a series of about five individual

impoundments that were all part of the former river bed. The canals were filled with river water, allowing the

wastes in them to be diluted prior to discharge into the Susquehanna River.

1-2

From 1948 to 1954, the east lagoon was used for the disposal of sewage and process wastewater from the

radium laboratory in the main building. In 1960, the contents of the east lagoon were pumped into the west

lagoon. During the May 2001 NRC site visit, an oily spot was observed in the middle of the base of the east

lagoon. Also, an 8 or 10-inch diameter outfall was observed in the east lagoon; origin unknown.

The west lagoon was used for the disposal of liquid waste including silver plating wastes and anodizing

solutions from USR (before 1982) and SLC (after 1982) operations (Figure 1-2). Low-level radioactive waste

reportedly was buried in the west lagoon. Also as noted above, in 1960 the east lagoon was pumped into the

west lagoon.

The east and west lagoons are located in the 100-year floodplain and were reportedly flooded in 1972, mixing

with flood waters. Contents of the lagoons were dispersed on the site property and in the Susquehanna

River.

Three disposal areas are located on the facility; the abandoned canal, and two disposal pits (east and west

plant dumps) (Figure 1-2). The abandoned canal was used for the disposal of =RA contaminated ductwork

and liquid waste from radiological production activities. The east plant dump encompasses areas between

the east and west lagoons, and was identified in 1972 during a storm sewer installation. The west plant

dump is adjacent to the western property line and fence. During a May 2001 NRC site visit, the east plant

dump contained piles of pallets, old chain-link fences, old pipes, windows, cinder blocks, and sheet metal. In

1948 and 1949, the west plant dump was used for the disposal of solid waste. The west plant dump also

was used for the disposal of =RA dials and wSr deck markers.

_-

Four 2,400-gallon aboveground storage tanks (ASTs) housed in the Liquid Waste Building contain 3H

contaminated wastewater from the Tritium or Nuclear Building (refer to building number 11 on Figure 1-2).

The wastewater is transported through a below-grade drain line and enters a concrete sump that is about 7

feet deep. The wastewater is then pumped into one of the 2,400-gallon ASTs for dilution. The 3H

contaminated wastewater is diluted to a concentration of 3 x l o 3 pCi/mL, then is released to the North Branch of the Susquehanna River. According to groundwater analytical data collected by Monserco in 1995,

a VOC plume containing vinyl chloride, 1,1,1 -trichlorethane, 1,l -dichloroethane, and cis-l,2-dichloroethane

emanates from the area of the Liquid Waste Building and flows toward the Susquehanna River.

Another potential source for onsite contamination is an underground storage tank (UST) formerly used to

store 3H contaminated wastewater. Prior to 1972, 3H contaminated wastewater was previously contained in

below-ground tanks in a vault in the basement of the Liquid Waste Building. In 1972, the North Branch of the

Susquehanna River flooded the building and a tank containing 3H contaminated wastewater was uprooted

1-3

from its location and dispersed in the flood water. Before the flood, the tank contained about 500-gallons of

H contaminated wastewater. The flood water was sampled and detected 3H contamination. The remaining

tank was subsequently filled and the vault was capped. The remainder of the building was filled with soil and

covered with a concrete slab.

1.3 SUMMARY OF PREVIOUS INVESTIGATIONS

3

Since the 1960 time frame, the company has undertaken various clean-up efforts including decontamination

of buildings, backfilling of on-site lagoons and removal of soils contaminated with =RA. These clean-up

efforts are not well documented.

According to site documents, eight environmental investigations of the SLC site have been conducted since

1978. Six environmental summary reviews were also prepared from available data. These investigations

and environmental reviews are further described below.

1978 Giles Drilling Corporation, on behalf of USRC, initiated groundwater monitoring with the installation of

monitoring wells 1, 2, and 3 located in the southern portion of the facility south of the underground silo area. Soil and groundwater from these wells provided initial data on contamination levels and

suggested that additional monitoring was required. No investigational report or initial groundwater

monitoring data is available from this investigation; however boring logs for these wells are included

in the Meiser & Earl Report discussed below.

1979 Meiser & Earl Hydrogeologists, on behalf of USRC, conducted a hydrogeological investigation, including installation of thirteen monitoring wells and three wells for background (wells 4 through 19).

The thirteen monitoring wells were located around the abandoned canal, the east and west lagoons,

and the disposal pits. Investigation activities commenced on January 29, 1979, and were completed

in March 1979. Objectives of the investigation were to determine the depths to groundwater, water-

table gradients and flow directions, existing water quality, extent of any radiological contamination

from abandoned disposal areas, and to propose appropriate pollution abatement techniques.

Investigation activities included the collection of interval soil samples for textural classification and

radioactivity analysis and the construction of screened or cased wells from which water samples

could be collected. The investigation activities revealed hydrogeological information at the site; the

site is underlain by fluvio-glacial deposits and static water levels revealed that water flow across the

site is essentially from the north to the south (towards the Susquehanna River), except during limited

periods when flooding occurs and flow is temporarily blocked locally by a groundwater mound.

1979 Radiation Management Corporation (RMC) conducted a radiological investigation in conjunction

with the Meiser & Earl Investigation. RMC reportedly used soil and groundwater collected both

by Meiser & Earl and by themselves for radiological analysis. This report concluded that

1-4

although Contamination was evident, no significant public health hazard was present and

remediation was neither appropriate nor justified at that time. However, continued and additional

environmental monitoring was suggested.

1981 Oak Ridge Associated Universities (ORAU) performed an environmental survey under contract

to the NRC. ORAU conducted survey activities at the SLC site in June and August, 1981. This

survey reviewed the SLC’s program for controlling and monitoring radiation and radioactivity

levels. Data were collected to confirm measurements performed by the licensee, to evaluate the

adequacy and accuracy of environmental controls and monitoring procedures, and to determine

if environmental contamination was occurring. Survey activities include the measurement of

direct radiation levels in unrestricted areas around the entire property, monitoring routine

releases of tritium in stack air and liquid effluents from SLC activities and measurement of

radionuclide concentrations in the environment as a result of present and previous operations of

SLC and USRC. Boreholes were drilled for the collection of subsurface soils; however no

monitoring wells were installed. Media sampled were surface and subsurface soil, groundwater,

vegetation, surface water, and aquatic organisms, both on and off -site.

The main conclusions of this study were that direct radiation levels were above the regional

background levels at the site, but were below federal guidelines for unrestricted use. However,

on-site soil sampling indicated elevated levels of =%A, wSr, and 13’Cs and groundwater

sampling showed levels of 3H and ?3r exceeding NRC and EPA guidelines for unrestricted use.

The study concluded that contaminants were migrating into soil and groundwater, but did not

appear at that time to be accumulating off-site although ORAU indicated this to be a potential

future concern.

1988 NRC performed an environmental evaluation of the site using available monitoring data. The

objective of this evaluation was to compile information about on-site contamination, to assess

the hazards to nearby residents, and to make recommendations about further remediation

actions. The NRC concluded that the disposal of radioactive wastes at the SLC site had caused

extensive contamination of groundwater on and off-site, and of soil on-site. The study identified

areas where decontamination work should be focused. Decontamination efforts should focus on

cleanup and control of the disposal silos, open dumps, and contaminated soils in order to

minimize further contamination spread. The NRC evaluation also identified that further

characterization work was necessary, covering both radiological and non-radiological hazardous

constituents.

1990 Chemical Nuclear Systems, Inc. (CNSI) conducted a hydrogeological and radiological evaluation

of the SLC facillty in June and July 1990. This study was a response to a Partial Interim

1-5

Settlement Agreement between USR Industries and the NRC. This settlement required partial

studies of the nature, scope, location, and movement of radioactive contamination at the SLC

facility. This evaluation was also intended to provide characterization data required to be

collected by the NRC according to the settlement agreement. The evaluation was not

considered comprehensive in scope. The primary objectives of this study were to assess the

hydrogeologic flow regime and the potential for off-site radiological migration from the site.

Activities conducted include soil coring, installation of 9 monitoring wells (wells A through I) and

groundwater and rainwater sampling.

The study indicated that groundwater flow is in a southerly direction toward the Susquehanna

River, and confirmed the presence of radioactive contamination within the soil and groundwater.

Off-site wells showed evidence of 3H and the highest level was measured at the Vance-Walton

well. Groundwater samples also showed evidence of %3r from adjacent properties to the east

and west of the SLC site. Levels of radionuclides detected were below drinking water standards.

The study recommended further environmental monitoring and site characterization work.

1991 NUS Corporation Superfund Division prepared Preliminary Assessment (PA) for EPA using all existing SLC reports. This document concluded that the soil and groundwater remained

contaminated primarily with =RA, ?3r, 13’Cs, and 3H as a result of waste disposal practices

employed during the history of the site.

1993 In 1993 and 1994, Roy F. Weston Technical Assistance Team (TAT), tasked by EPA Region 3, conducted soil and groundwater sampling at the SLC property and vicinity. The TAT

recommended the following upon completing the sampling activities: clean out a tub full of blue-

colored residue with standing liquid, pH equal to 0, in the Metal Etching Building, remove empty,

rusting drums scattered along the west lagoon edge, check state regulations for applicable laws

regarding tank removal due to a tank overfill located east of MW11, and recommended that a filterkcreen be placed at the outlet of a compressor exhaust in the Carpenter shop. The soil

samples detected some contaminants, however none met or exceeded EPA action levels.

1994 Ecology and Environment, Inc. (E&E), tasked by the NRC Region I office, conducted a file

review in support of the Hazard Ranking System (HRS) Package which was being prepared by

E&E. The file review found that several inspection reports, two in 1980 and one in 1986,

prepared by NRC indicate elevated 3H concentrations in the neighboring residential wells,

including the Vance Walton and Murphy wells; however, levels detected were below drinking

water standards. It was also noted that NRC inspection reports reveal that 3H, nsRA, and %r

have been detected consistently in on-site groundwater at concentrations exceeding NRC

guidelines for unrestricted area.

1-6

1994 In 1994, Monserco Limited prepared a Characterization Plan for SLC to quantify the physical and

radiochemical characteristics of radiological contamination and it's distribution, assess non-

radiological constituents and their effect on radiological constituents, evaluate environmental

impacts, assess associated hazards from existing and potential future radiological contamination

under the conditions of unrestricted use, and finally to provide sufficient information to develop a

closure plan for the site. This plan outlined the methods and technologies to be used as part of

the site survey and detailed each survey location in regards to area to be sampled and quantity

of samples to be taken.

1995 SLC commissioned Monserco Limited to conduct a site characterization. These activities were

conducted between May 1995 and December 1995. Objectives of the site characterization were

to determine the extent of radiological contamination on ground surfaces, determine whether radioactive contaminated items are buried under the SLC grounds, gain access to the two

underground silos and obtain information on their contents, drill new boreholes and wells (wells

M1 through M13), sample and analyze the subsurface soils and waters, and determine the extent of radiological contamination inside the buildings.

Monserco conducted electromagnetic surveys at the site. Four anomalies indicating large

metallic objects were detected using the survey: two underground silos, an anomaly located east

of the Well House indicative of an underground storage tank, and linear anomalies located in the

same vicinity that may be buried pipes associated with the underground storage tank. Two

anomalies representing large metallic objects were located south of the Etching Building and

west of the Pipe shop. Numerous anomalies associated with isolated buried objects were

detected. The highest density of these anomalies was located south of the Solid Waste Building

and Liquid Waste Building in the abandoned canal. A number of linear anomalies identified

across the property may indicate buried pipes or cables.

Eight trenches were excavated revealing the canal bottom, metal debris, and glass. Thirteen

boreholes were drilled at various locations on the SLC site to assess the radiological and non-

radiological condition of the subsurface soils and to install additional groundwater monitoring

wells. Cored material was monitored every two feet for radiation using a contamination probe.

Positive radiation readings were recorded for soils from boreholes M2, M3, M4, M5, M6, M7, M9, M10, M11, M12, and M13. Hydrocarbon odors were reported by field crew during drilling at

boreholes M1, M8, M9, and M13. Organic vapors were monitored using a photo ionization

detector (PID). Positive results were obtained from boreholes M1 and M7.

1-7

... .

Results from monitoring well sampling showed elevated levels of radionuclides, most notably

Cs, in groundwater near the buried silos (M9, M13) and in a southerly (downgradient) direction

at wells M4 and M5. Vinyl chloride (up to 30 ug/l) was also detected in monitoring wells in the

vicinlty of the Liquid Waste Building in wells Mi, M8, and M1 1 .

137

2000 A Health Consultation Report documenting past sampling data was issued by the Agency for

Toxic Substances and Disease Registry (ATSDR) in April 2000. The report concluded that

radioactive materials, specifically %A, %r, 13Cs, 3H and 241Am, have been used and

disposed in silos, lagoons, and holding tanks associated with the SLC. From these disposal

practices, radioactive material has contaminated the on-site areas of the SLC and perhaps

nearby off-site residential wells (3H only). The contaminants in the residential wells are not at

levels of public health concern. The amount of land contaminated has been exacerbated by a

flood of the Susquehanna River in 1972.

ATSDR reviewed environmental sampling data collected during three characterization events

from 1980 until 1996. The results indicated that surface soils are contaminated with and

Cs and that the contamination has apparently seeped from the soils to the groundwater. Soil

contamination is mostly to the south and southeast of the main buildings. Although the

contamination has not yet reached the river, data strongly suggest the contamination is migrating

in that direction. Additional contamination associated with the site is predominately between the

main site buildings and the river but external exposure to ionizing radiation is localized along the

outside of the buildings.

1 37

2000-

2001 The Pennsylvania Department of Environmental Protection (PADEP) implemented a Hazardous

Sites Cleanup Act (HSCA) funded assessment of the SLC property. Foster Wheeler

Environmental Corporation was contracted to conduct the site assessment activities, which were

completed in August 2000. The primary objectives of this assessment were to perform sample

collection and analysis of surface water and groundwater in and around the site. Activities

included collection of groundwater from monitoring wells, collection of surface water from the

adjacent Susquehanna River, and collection of water from nearby residential wells. Sample

results indicate that the groundwater and potentially the surface water at the SLC site are

impacted by previous site activities.

Analytical results indicate that groundwater is impacted by radionuclides and some inorganic

analyies. The majority of groundwater sample results confirm the presence of radionuclides

above non-detect levels. Comparison of the groundwater analytical results indicated that many

samples exceeded the EPA drinking water maximum contaminant levels (MCLs) for gross

1-8

alpha, gross beta, %A, 228RA, and %3r. The highest concentrations of radionuclides were

found in the groundwater collected from the monitoring wells closest to the location of the

underground waste disposal silos, wells M9 and M10. None of the residential well sample

results were found to exceed the EPA MCLs for radionuclides. There were inorganic analytes

detected above the PADEP Act 2 Medium-Specific Concentration (MSCs). Some of these

exceedences may be attributed to the elevated level of suspended solids in the groundwater

samples. Lead and copper exceeded the PADEP Act 2 MSCs in one of the residential well

water samples. As copper was not detected in other groundwater samples, the elevated copper

levels may be attributed to the residential plumbing system.

Low-level organic contaminants were detected in the groundwater samples collected from the

site. Vinyl chloride and bis(2-ethylhexy1)phthalate were the only organic contaminants to exceed

the PADEP Act 2 MSCs, and were detected in samples from only one monitoring well, M9.

None of the residential well samples exceeded the PADEP Act 2 MSCs for VOCs or SVOCs.

Analyses for radionuclides in surface water collected from the Susquehanna River show that low

concentrations are present. Standards for radionuclide concentrations in surface water were not

used for data comparison, as none were determined applicable for this event by PADEP. All

surface water sample results were below the inorganics Water Quality Criteria for Toxic

Substances and surface water samples were not analyzed for VOCs or SVOCs.

2001 ICF Consulting submitted a Review and Evaluation of Characterization Data for SLC in October

2001. This report was prepared under contract to the NRC. The report presented prior

characterization data, an evaluation of the completeness of the data, and suggested where

additional data could increase the current understanding of the site and refine future cost estimates. The ICF report concluded that operations have resulted in the radiological

contamination of every building (except for the Old Radium Vault) at the site. It should be noted that, although it is believed that radioactive sources have been removed from the Old Radium

Vault, access to the building was not possible due to a collapsed roof. Due to structural damage

at some buildings, remediation is most likely not possible due to entry restrictions. Many

buildings still contain contaminated waste, equipment, and source material. The majority of the

surface soils at the site are contaminated with at least one radionuclide at levels exceeding the

Derived Concentration Guidance Levels (DCGLs) as reported as either actually detected

concentrations or presumed by analytical detection limits in excess of the DCGLs. The DCGLs

were calculated in the Monserco report using guidelines in effect at that time. The DCGLs were

considered remediation goals to achieve acceptable levels of radiological levels to return the

property to unrestricted The primary radioactive isotopes of concern in surface and subsurface

soils are 226RA, 13’Cs, 241Am, and ?3r. The primary radioactive isotopes of concern in

1-9

1

groundwater are 3H, =RA, 13’Cs, 241Am, and ?3r. Daughter isotopes of 226RA, such as 214Pb

and 214Bi, have also been found in the surface and subsurface soils and groundwater.

2002- 2004 A 1994 settlement by NRC with SLC required SLC to remove and dispose radioactive wastes

stored in the underground silos. By June 2000, SLC had removed the waste and placed it in 176

55-gallon drums and 26 containers each containing approximately 3.55 cubic yards of material.

These waste drums and containers; however, were placed in the floodplain of the Susquehanna

River approximately 200 feet from the river. In 2002 EPA conducted a removal assessment of

these materials and entered into an administrative order of consent with SLC to relocate the

waste in a secure area on the property outside the floodplain and arrange for disposal at an

NRC-licensed facility. SLC did not comply with the consent order and EPA commenced

implementation of a RA. The drums and containers were moved to a secure location outside

the floodplain in December 2004 and are waiting for transport and disposal at a licensed facility.

2004 Lockheed Martin Services, under contract to EPA, submitted an Aerial Photographic Analysis of

SLC in December 2004, showing site conditions from 1938 until 1999. Significant site features,

including lagoons and dump areas are shown, although resolution of several of the photographs

is poor.

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2.0 SCOPE OF WORK

This HASP addresses health and safety issues associated with field activities related to the RI at the SLC

Site. Detailed information on planned site activities is provided in the Field Sampling Plan (FSP). Site

activities addressed within this plan include:

0 Mobilization/Demobilization and Site Reconnaissance including topographic surveying and

residential well inventory

Groundwater Investigation including refurbishment of existing and installation of new groundwater

monitoring wells, groundwater and effluent water sampling.

0

0 Equipment Cleaning/Decontamination

0 Investigation-derived wastes (IDW) Management

This HASP will be modified if additional site activities are to be performed by TtNUS personnel, or if other

site conditions change (new information on contaminants of concern, changes in how work is going to be

performed, personnel changes, etc.). or this his HASP discusses many of the hazards associated with

these site activities as well as safe work practices that will be used to mitigate the hazards and to protect

site personnel, the environment, and site property.

.- .

2-1

3.0 PROJECT TEAM ORGANIZATION

3.1 KEY PROJECT PERSONNEL AND ORGANIZATION

This section defines responsibility for site safety and health for TtNUS employees engaged in onsite

activities. Personnel assigned to these positions will exercise the primary responsibility for onsite health

and safety. These persons will be the primary point of contact for any questions regarding the safety and

health procedures and the selected control measures that are to be implemented for onsite activities.

3.1.1 TtNUS Proiect Manaqer (PM)

The TtNUS PM is responsible for the overall direction of health and safety for this project including the

following functions:

I.

II.

II.

iii.

iv.

V.

vi.

3.1.2

Providing pertinent site information (scope of work, available analytical data, personnel

assignments, etc.) to facilitate preparation of the HASP.

Approving the HASP.

Monitoring field documents to ensure adequate health and safety practices are employed.

Coordinating with the project personnel to implement necessary emergency response procedures.

Verifying corrective actions are implemented.

Ensure that project personnel receive this HASP and that provisions for conveying information

contained within the HASP and other site documents to site workers are provided.

Providing for appropriate monitoring, personal protective equipment, decontamination materials,

and other project necessities.

TtNUS RAC 3 Health and Safetv Manaqer (HSM)

The HSM or authorized designee is responsible for developing this HASP in accordance with applicable

OSHA regulations. Specific responsibilities include:

i. Developing the implementing project health and safety documents including the HASP.

ii. Reviewing information regarding site contaminants and physical hazards associated with the site.

ii. Establishing air monitoring and decontamination procedures.

1 1 1 . Assigning personal protective equipment based on task and potential hazards.

iv. Determining emergency response procedures and emergency contacts.

...

3-1

v. Stipulating training requirements and reviewing appropriate training and medical surveillance

certificates.

vi. Providing standard work practices to minimize potential injuries and exposures associated with

hazardous waste work.

vii. Modifying this HASP, as it becomes necessary.

viii. Auditing project sites to ensure compliance with this HASP and other applicable OSHA

regulations or TtNUS H&S

3.1.3 TtNUS Field Operations Leader (FOL]

The TtNUS FOL is responsible for implementation of the HASP with the assistance of an appointed Site

Safety Officer (SSO). The FOL manages field activities, executes the work pian, and enforces safety procedures as applicable to the work plan. Additional duties include:

i.

I I .

Ensuring and enforcing compliance with the HASP.

Coordinating site activities such that they may be performed in an effective and safe manner

consistent with the HASP.

Enforcing the buddy system on-site.

Controlling site entry of unauthorized personnel.

Assuring availability of all safety equipment.

Inspecting the site for safety hazards and proper posting

iii.

iv.

V.

vi.

3.1.4 Site Safetv Officer (SSO)

The SSO supports site activities by advising the FOL on the aspects of health and safety on site. These

duties may include:

I.

II.

Coordinating health and safety activities with the FOL through implementation of this HASP.

Selecting, applying, inspecting, and maintaining personal protective equipment, air monitoring

instruments, and other site equipment and materials.

Confirm that site personnel meet appropriate training and medial requirements.

Conducting site-specific training, daily safety meetings, and weekly inspections.

Verification of decontamination procedures are being implemented.

iii.

iv.

V.

vi. Implementation of Hazard Communication, Respiratory Protection Programs, and other

associated health and safety programs as they may apply to site activities.

Conducting site inspections to identify potential hazard and to implement corrective actions vii.

3-2

viii.

ix.

Coordination of emergency response procedures and follow-up.

Notification of appropriate contract representatives and TtNUS Project Manager in the event

of an emergency.

Investigation of accidents and injuries (see Attachment I - Illness/lnjury Reporting Procedure

and Form).

Providing input to the HSM regarding the need to modify, this HASP, or applicable health and

safety associated documents as per site-specific requirements.

Observing field team members for symptoms of exposure or stress.

X.

xi.

xii.

Compliance with the requirements stipulated in this HASP is monitored by the SSO and coordinated

through the TtNUS HSM and the TtNUS Corporate Health and Safety Manager.

Note: In some cases one person may be designated responsibilities for more than one position. For

example, at the site, the FOL may also be responsible for SSO duties. This action will be performed only

as credentials, experience, and availability permits.

3.1.5 TtNUS and Subcontractor Personnel

TtNUS and subcontractor employees are responsible for:

1. Understanding and following direction provided in this HASP, and other project plans and as

provided under the direction of the SSO and/or FOL.

Reporting unsafe conditions or incidents to the FOL and/or SSO.

Providing necessary training and medical surveillance information to SSO.

Attending site-specific training and daily safety meetings.

ii.

111.

iv.

...

3-3

4.0 TRAINING/MEDICAL SURVEILLANCE REQUIREMENTS

4.1 INTRODUCTORY/REFRESHER/SUPERVlSORY TRAINING

4.1.1 Requirements for Tetra Tech NUS Personnel _--

Prior to performing site activities at SLC, TtNUS field personnel must complete 40 hours of introductory

hazardous waste site training. Additionally, TtNUS personnel who have had introductory training more

than 12 months prior to site work must have completed 8 hours of refresher training within the past 12

months before being cleared for site work. In addition, 8-hour supervisory training in accordance with 29

CFR 191 0.120(e)(4) will be required for site supervisory personnel. Documentation of TtNUS introductory,

supervisory, and refresher training as well as site-specific training will be maintained at the project site.

TtNUS will conduct a site-specific training session prior to initiating site work. Additionally, a brief safety

meeting will be held daily to discuss operations planned for that day and to review applicable Safe Work

Permits. These daily meetings may also be used to discuss completed operations, scope of work

variances, and any problems that were encountered.

4.1.2 Requirements for Subcontractors

TtNUS subcontractor personnel will have completed introductory hazardous waste site training or

equivalent work experience as defined in OSHA Standard 29 CFR 1910.120 (e). Additionally, personnel

who have had the introductory training more than 12 months ago, are required to have 8 hours of

refresher training meeting the requirements of 29 CFR 1910.120 (e)(4) prior to performing field work if

required. TtNUS subcontractors will certify that each employee has had such training by sending TtNUS a

letter, on company letterhead, containing the necessary training information and by providing copies of

certificates for subcontractor personnel participating in site activities.

4.2 SUBCONTRACTOR EXCEPTIONS

Subcontractors who will not enter the exclusion zone during operation, and whose activities involve no

potential for exposure to site contaminants, will not be required to meet the requirements for

training/medical surveillance other than site-specific training as stipulated in Section 4.3. Exceptions to

the training and medical surveillance requirements stipulated in Sections 4.1 and 4.5, respectively, will

only be granted through prior approval by the RAC 3 HSM.

4-1

.-

4.3 SITE-SPECIFIC TRAINING

TtNUS will provide site-specific training to site personnel who will perform work on this project. Site-

specific training will also be provided to personnel [EPA, DEP, etc.] who may enter the site to perform

functions that may or may not be directly related to site operations. Site-specific training will include:

Names and roles of designated personnel and alternates responsible for site safety and health

Site activities and operations planned at the site

Safety, health, and other hazards present on site

Use of personal protective equipment

Work practices to minimize risks from hazards

Medical surveillance requirements

Signs and symptoms of overexposure

Contents of the Health and Safety Plan

Emergency response procedures (evacuation and assembly points)

Spill response procedures

Review of the use of Safe Work Permits

Site-specific documentation will be established through the use of the Site-Specific Training

Documentation Form (Figure 4-1). Site personnel and visitors must sign this document upon receiving

site-specific training.

4.4 OTHER TRAINING

TtNUS incorporates other OSHA required training as part of annual 8-hour refresher training. This

additional training includes but is not limited to hearing conservation and protection (29 CFR 1910.95),

hazard communication (29 CFR 191 0.1 200), and personal protective equipment (29 CFR 191 0.1 32).

Training provided as part of site-specific training or daily safety meetings on project work sites

supplements this training. It should be noted that in some situations, additional training for TtNUS or

subcontractor personnel will be necessary (confined space operations, use of respiratory protection, fall

protection, energy control, etc.).

4.5 MEDICAL SURVEILLANCE

Tetra Tech NUS and subcontractor personnel participating in project field activities will have had a

physical examination. Physical examinations shall meet the minimum requirements of paragraph (f) of

OSHA 29 CFR 1910.120. The physical examinations will be performed to ensure all personnel are

medically qualified to perform hazardous waste site work using respiratory protection.

4-2

Documentation for medical clearances will be maintained at the job site and made available, as necessary. Subcontractor personnel may use the "Subcontractor Medical Approval Form" to satisfy this

requirement, or a letter on letterhead stationary from an officer of the company. The letter should state

that the persons listed in the letter participate in a medical surveillance program that meets the

requirements contained in paragraph (f) of Title 29 of the Code of Federal Regulations (CFR), Part

1910.120, entitled "Hazardous Waste Operations and Emergency Response." The letter should further

state the following:

0 The individuals listed have had physical examinations under this program within the frequency as

determined sufficient by their occupational health care provider

Date of the exam

The individuals identified have been cleared, by a licensed physician, to perform hazardous waste site

work and to wear positive- and negative- pressure respiratory protection.

A sample Subcontractor Medical Approval Form and form letter is provided to eligible subcontractors in

the Bid Specification package.

4.6 MEDICAL DATA SHEETS

Each field team member (including visitors entering the exclusion zone) shall be required to complete and

submit a copy of the Medical Data Sheet found Attachment I1 of this HASP. This shall be provided to the

SSO prior to participating in site activities. The purpose of this document is to provide site personnel and

emergency responders with additional information that may be necessary in order to administer medical

attention.

4-3

FIGURE 4-1

satisfaction, and that the dates of my training and medical surveillance Site- 40-Hour &Hour

(Printed and Signature) Training (Date) Training Name Specific Training Refresher

Date (Date)

SITE-SPECIFIC TRAINING DOCUMENTATION

indicated below are accurate. 4-Hour

SUperViSOry Medical Training Exam (Date)

My signature below indicates that I am aware of the potential hazardous nature of performing investigation activities at Safety Light Corporation, and that I have received site-specific training which included the elements presented below:

Names of designated personnel and alternates responsible for site safety and health Site activities and operations planned at the site Safety, health, and other hazards present on site Use of personal protective equipment Work practices to minimize risks from hazards Medical surveillance requirements Signs and symptoms of overexposure Contents of the Health and Safety Plan Emergency response procedures (evacuation and assembly points) Spill response procedures Review of contents of relevant Material Safety Data Sheets Review of the use of Safe Work Permits

4-4

5.0 HAZARD ASSESSMENT

Site-specific hazards are identified through hazard analysis to determine the appropriate safety and health

procedures needed to protect workers from the identified chemical, physical, and biological hazards. This

section provides information on most commonly encountered hazards associated with planned field

activities at SLC and lists generally practiced mitigation procedures. Tasks, hazards and associated

control measures are identified in detail in Attachment IV.

5.1 CHEMICAL AND RADIOLOGICAL HAZARDS

Site activities associated with hazardous waste sites bring field personnel into possible contact with

hazardous chemicals in the form of site contaminants, cleaning/decontamination fluids, sample

preservatives, calibration gasses, and products used to operate or maintain site equipment. This section

of the HASP serves to identify those chemical hazards and provide guidance to prevent or minimize

potential for exposures or contact with these chemicals. A list of chemical and radiological contaminant

properties can be found in Attachment V

5.1.1 Site Contaminants

The site consists of locations where radioactive materials and chemicals were used in manufacturing

processes. Numerous sampling and remedial activities have been performed over a period of years that

provide a good characterization profile of site contaminants. The primary radioactive isotopes of concern

associated with subsurface soils are Ra-226, Cs-137, Sr-90, H-3 and Am-241. These contaminants would most likely be encountered during direct push sampling and monitoring well installation/construction and

testing activities. The possibility also exists for the presence of vinyl chloride in subsurface soils. These

same radionuclides, as well as vinyl chloride, represent contaminants of concern for associated

groundwater processing activities. These contaminants could be encountered during monitoring well

redevelopment, monitoring well sampling, water level measurements, and pipe discharge sampling. There

is a minimal potential that these contaminants may be observed during residential well sampling.

It is not expected that these contaminants will pose an inhalation hazard. However, safe work practices

such as avoiding the generation of site dusts, avoidance and collection of potentially contaminated soils,

and exposure monitoring to evaluate potential exposure (vinyl chloride) to site personnel will be

implemented during the performance of site activities. Periodic monitoring of equipment, work areas and

personnel using portable radiation detection instruments will be performed to verify radiological conditions.

5- 1

5.1.2 Chemicals Use on Site

Site investigations may require the use of chemicals (sample preservatives, decontamination solvents,

fuels, etc.). Manufacturer Material Safety Data Sheets (MSDS) will be maintained and be available for

review by site personnel to determine potential hazards, protective measures, and other information

regarding the potential hazard of the chemical. Safe work practices and the use of protective equipment

to prevent exposure to potential site contaminants will also be used to prevent exposure to chemicals that

may be used or encountered during site operations.

5.2 PHYSICAL HAZARDS

Potential physical hazards associated with fieldwork are described below, along with TtNUS policy and

general procedural guidelines to minimize these hazards.

5.2.1 Heavv Equipment Hazards (Pinchkompression points. rotatinq equipment. etc.)

Often the hazards associated with drilling operations are the most dangerous to be encountered during

site activities. The SSO will discuss safe drilling procedures as part of site-specific training and/or during

daily safety meetings. The following rules will apply to drilling operations:

- -

Site personnel will be aware of the location and operation of this equipment. Each drill rig must be equipped with emergency stop devices which will be tested daily to ensure

that they are operational.

Long handled shovels or equivalent shall be used to clear cuttings from the borehole and rotating

equipment.

-

0 Additional requirements during drilling activities are discussed in Attachment IV. The SSO will

thoroughly discuss safe drilling procedures during the pre-activities training session and all equipment

(drill rigs, excavators, backhoe, etc.) will be inspected using the Equipment Inspection Form

(Attachment VII).

5.2.2 Eneraized Svstems (Contact with Underaround or Overhead Utilities)

Underground utilities such as pressurized lines, water lines, telephone lines, buried utility lines, and high

voltage power lines may be present throughout the facility. Therefore, subsurface activities must be

conducted following the requirements of the Tetra Tech NUS SOP for “Utility Locating and

Excavation Clearance (HS-1.0)”. A copy of this SOP is provided as Attachment VIII. Drilling operations will

5-2

be conducted at a safe distance from overhead power lines as discussed in Attachment VIII. In certain

cases, utility personnel may need to de-energize electrical cables using facillty lockouthagout procedures to

insure electrical hazards are eliminated.

5.2.3 Slips, Trips, and Falls

All work sites contain potential slip, trip, and fall hazards, such as:

0 holes, pits, or ditches;

0 open manholes to sewers

0 slippery surfaces;

steep grades;

0 uneven grades; and

0 sharp objects, such as nails, metal shards and broken glass.

Personnel will be instructed to look for potential safety hazards and to immediately inform the SSO or the

FOL about the hazards. If the hazard cannot be immediately removed, action such as marking or

barricading the hazard will be taken to warn site workers.

The SSO will determine the severity of any injury incurred during a slip, trip, or fall. If a person becomes

contaminated because of a slip, trip, or fall, the victim should obtain prompt medical attention.

Decontamination shall be provided to the extent necessary.

5.2.4 Heavv or Awkward Lifting

Precaution shall be exercised when lifting heavy or awkward objects (sample coolers, sampling

equipment, IDW containers, augers and other drilling equipment, etc.). Personnel should know and

practice proper lifting techniques and not lift more weight than can be handled comfortably, regardless of

load weight. Help should be obtained for lifting loads greater than 50 pounds. Mechanical equipment

should be used for lifting heavy materials when possible.

5.2.5 Portable Power Hand Tools

Environmental site activities occasionally require the use of portable hand tools. Any such equipment

(e.g., wrenches, wedges, chisels, hammers, pneumatic tolls, drills, welding equipment, etc.) used in the

work area must have appropriate guarding, interlocks, or controls to ensure safe operation, in accordance

5-3

with 29 CFR 1926.301 through 302. Machinery and equipment must be inspected for defects in the

guarding and operation before each use.

The following specific precautions will be used to help prevent injuries and accidents:

Never remove, make inoperative, or reduce the effectiveness of any equipment or machine guard.

Never override any safety interlock or attempt to operate any piece of equipment or machinery

without guards or other required safety devices in place and fully functional.

Never operate any piece of equipment or machinery when it is functioning improperly or at any

time when operation would constitute a hazard. Any piece of equipment that does not meet this

requirement must be repaired immediately or will be removed from the premises.

Occasionally, during installation of equipment or demolition of an existing area, there may be

times when a piece of equipment must be left in an incomplete state. It may be potentially

hazardous to operate the equipment or to enter the area during this time. When such situations

occur, the equipment must be locked out or the area must be identified with yellow tape that reads

"Caution - Do Not Enter".

In addition, the following general precautions should be considered:

Do not use electrically powered tools near flammable materials or within an explosive atmosphere, unless they are of the explosion-proof type meeting the National Electrical Code

(NEC) for explosive areas. Employees operating the equipment should be aware of sparks and/or

metal fragments when using this equipment.

At no time will electrical power equipment be operated without proper grounding. All electrical

cords and cables, including extension cords, shall include a third wire ground.

Prohibit operations of electrical tools in wet or damp areas except in unusual emergency

circumstances.

Limit use of tools to the purpose for which the tool is intended (e.g., wrenches will not be used as

hammers). Defective tools (e.g., with mushroomed heads or split or defective handles) shall not

be used.

Do not use conducting (Le., metal) tools around electrical facilities. Insulated tools, approved for

electrical work, shall be tested frequently for proper insulation.

Select the correct size and type of wrench for each job. Wrench handles shall not be extended

with a pipe or cheater because the jaws will spread.

Repair mushroomed punch, drift, and chisel heads. Mushroomed heads represent

fractured/stressed/crystallized metal that will break and fly off when struck.

5-4

Wear eye protection at all times.

Wear leather or heavy cotton work gloves when using tools to protect against blisters, cuts, or

other hand injuries.

Wear eye protection (safety glasses with side shields) to protect the eyes from twigs, sticks, or

flying debris.

Wear long pants and long-sleeved shirts to protect against abrasions.

Wear hard hats if work will involve areas with overhead hazards (e.g., overhanging branches).

Wear sturdy work boots.

Inspect all hand tools [i.e., shovel handles (cracks, splinters, etc.), brush hook handles and blade

attachment points, etc.)

Use the proper tool for the intended purpose. This to will avoid potential injury possibly created

through improper use.

Drum Handling

The following general guidelines shall be followed:

Use only drums and containers that meet the appropriate U.S. Department of Transportation

(DOT), OSHA, and United States Environmental Protection Agency (USEPA) regulations.

Be aware of the potential hazards of the contents of drums or containers before handling. Only

trained personnel should open drums containing unknown materials.

Bulging drums or containers are an indication of pressure buildup. Open all drums or bungs

extremely slowly to determine the presence of vapors or pressure inside the drum. If the

possibility of fire or explosion exists, a protective shield and/or remote opening devices should be

used.

Consider any unlabeled drum or container as containing a hazardous substance and leave it

alone until contents are properly identified and labeled. Do not assume that exterior labeling

properly identifies the contents or potential hazards of drums and containers.

Label and identify drums and containers when moved to the staging areas to safely identify and

classify their contents. Segregate incompatible drums.

Staging areas shall be provided with adequate ingress and egress routes. Use secondary

containment at staging area for all moved drums.

Inspect the integrity of the drum or container before moving. Any drum or container lacking

integrity shall be overpacked.

5-5

0

0

0

0

0

0

5.2.7

When

Organize site operations to minimize the amount of drum or container movement. Have a clear

view of the available pathway when moving drums. If needed, an additional person should be

available to provide guidance.

Utilize drum container handling equipment whenever possible. The equipment utilized should

have a sufficiently rated load capacity, and should be able to operate smoothly on the available

surface.

Use proper lifting and moving techniques to prevent back injuries, if handling equipment is not

available.

Never stand on drums or containers.

Use non-sparking tools.

Cease site operations immediately if site activities uncover buried drums or containers. The SSHS

must be notified. The SSHS will evacuate the area. All unknown situations must be evaluated

before site activities are resumed. The services of a specialized contractor trained in handling

unknown contaminants may be needed. If, after evaluating the situation, only a portion of the site

is affected, that area shall be barricaded and work may continue at other portions of the site.

working with compressed gases (e.g., calibration gases for monitoring instruments,

oxygen/acetylene cylinders for welding), the following general precautions should be taken:

Chain or secure cylinders in an upright position at all times whether in storage or use.

Move cylinders only when they are chained to a handcart; never drop, role or slide them across

the ground or floor.

Keep the protective cap in place at all times when the cylinder is not in actual use. Cylinder must

be properly labeled with contents and hazard warnings.

Always use the proper regulator for each cylinder. Don’t use an adaptor or other connections to

attach a regulator to a gas cylinder. If it is the correct regulator, it will fit easily on the existing

connection.

Store and properly secure cylinders in a well ventilated location. The use and storage of

flammable or combustible gases is restricted in the facility.

All cylinders utilized onsite shall be free of corrosion and inspectedhested per DOT requirements.

Any cylinder that does not meet DOT inspection requirements must be tagged “Do Not Use” and

removed from site property.

Keep oxidizing gases separate from fuel gases.

5-6

I

e Cylinders should be tagged and capped when empty. It is recommended that full and empty

cylinders be stored separately

5.2.8 Severe Weather

Project tasks under this Scope of Work will be performed outdoors. As a result, inclement weather may

be encountered. In the event that adverse weather conditions arise (electrical storms, heavy winds,

hurricanes, etc.), the FOL and/or the SSO will be responsible for temporarily suspending or terminating activities until hazardous conditions no longer exist.

5.2.9 Heat and Cold Stress

The most severe heat-induced illnesses are heat exhaustion and heat stroke. If left untreated, heat

exhaustion could progress to heat stroke and possible death.

The symptoms of heat exhaustion include:

headaches;

dizziness or lightheadedness;

weakness;

mood changes such as irritability, confusion, or the inability to think straight;

upset stomach;

vomiting ;

decreased or dark-colored urine;

fainting or passing out; and

pale, clammy skin.

In the event that these symptoms are observed, the following actions should be taken:

0

Act immediately. If not treated, heat exhaustion may advance to heat stroke or death.

Move the victim to a cool, shaded area to rest. Don’t leave the person alone. If symptoms include

dizziness or lightheadedness, lay the victim on his or her back and raise the legs 6 to 4 inches. If

symptoms include nausea or upset stomach, lay the victim on his or her side.

Loosen and remove any heavy clothing.

Have the person drink cool water (about a cup every 15 minutes) unless sick to the stomach.

5-7

--

0 Cool the person’s body by fanning and spraying with a cool mist of water or applying a wet cloth to

the person’s skin.

Call 91 1 for emergency help if the person does not feel better in a few minutes. 0

The symptoms of heat stroke include:

0

0

0

0 seizures or fits; and

0 unconsciousness with no response.

dry, pale skin with no sweating;

hot, red skin that looks sunburned;

mood changes such as irritability, confusion, or the inability to think straight;

If these symptoms are observed, call 91 1 for emergency help immediately and follow same actions listed

above.

If the SSO requires personnel to wear chemically impervious clothing, heat stress monitoring will be

required. The safe duration of workhest periods will be determined based on the suggested schedules in

the current American Conference of Governmental Industrial Hygienist (ACGIH) Threshold Limit Values

for heat stress. These workhest periods will be adjusted based on the:

0 anticipated work rate;

0

0

0

ambient temperature and other environmental factors;

types of personal protective equipment; and

individual worker characteristics and fitness.

The workhest periods may be further adjusted when the temperature reaches 70 degrees Fahrenheit or

above.

Heart rate will be measured for 30 seconds using the radial pulse method, and as early as possible in the

rest period. If the heart rate exceeds 11 0 beats per minute, the work period will be shortened by one third.

If at the beginning of the next rest period, the heart rate is still greater than 110 beats per minute, the work

period will again be shortened by one third.

Temperatures may be taken orally at the end of the work period. If the body temperature is greater than

99.6 degrees Fahrenheit, the next work period will be shortened by one third. If oral temperature still

exceeds 99.6 degrees Fahrenheit at the end of the shortened work period, it will be shortened again by

one third. A worker will not be allowed to wear a semi-permeable or impermeable garment if hisher oral

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. .

temperature is greater than 100.6 degrees Fahrenheit. If deemed necessary by the SSO, heat stress

monitoring will be performed.

Cold stress is also an important factor in employee health and safety. On days with low temperatures, high

winds, and low humidity, anyone can suffer from the extreme cold. Severe cold temperatures can be life

threatening. Several factors increase the harmful effects of cold: age (being very young or very old), wet

clothing, wounds or fractures, smoking, fatigue, emotional stress, and certain diseases and medications.

Cold weather injuries may be either local or systemic. Local cold weather injuries include chilblains

(chronic injury of the skin and peripheral capillary circulation) and frostbite. Frostbite occurs in three

progressive stages: frostnip, superficial frostbite, and deep frostbite. Systemic cold injuries, due to

hypothermia, are these that affect the entire body system. Hypothermia is caused by exposure to cold and

is aggravated by moisture, cold winds, fatigue, hunger, and inadequate clothing or shelter. The objective is

to prevent the deep body temperature from falling below 96.4"F (36°C) and to prevent cold injury to body

extremities.

5.3 BIOLOGICAL HAZARDS

Many environmental investigation activities bring site personnel into areas that are natural habitats for

many indigenous plants and animals, including snakes, rodents, and insects. When working in the field,

TtNUS personnel and subcontractors must be aware of their surroundings and recognize the hazards

associated with the wildlife around them. Field workers must remember that these animals are wild and

should be left alone.

Fauna - 5.3.1 5.3.1.1 Venomous Snakes

Although not considered a significant concern at most sites, venomous snakes may be present. Field

workers must maintain awareness of their surroundings. In most instances, these animals, when left

alone, will eventually retreat to preferred habitats away from people, Site personnel must be made aware

of the potential presence of these animals.

Venomous snakes which may be found in Pennsylvania include:

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0 Eastern Diamondback Rattlesnake - 7-4 feet in length; found in almost any habitat, but most commonly in pine woods, abandoned fields or brushy/grassy areas; aggressive.

0 Cottonmouth (Water Moccasin) - Exceeds 5 feet in length; variable color pattern; characteristic

whitish mouth lining shown when in a defensive posture; found along stream banks, in swamps

and margins of lakes; unpredictable disposition.

If a venomous snake is observed, the following protocol should be followed:

0 Move!

0

0

Notify the SSO or Field Manager.

Notify others in the area.

If bitten by a snake, the patient should be transported immediately to the nearest medical dispensary,

which, depending on the severity and nature of the bite, may transfer the patient to an offsite medical

facility. The absorption of venom should be retarded by placing the victim at rest and splinting the

extremity that was the site of the bite. The affected limb should be kept below heart level. If possible, place

a wide constriction band above the bite. This should be just firm enough to allow a finger to be placed

between the band and the skin. The goal is to impede lymph flow, not venomous return. As the area

begins to swell, the band should be loosened and re-applied away from the swelling. Never attempt to

suck the venom out of the patient.

5.3.1.2 Insects and Spiders

Caution should be used when opening the casings around monitoring wells as these areas are excellent

habitats for spiders. Any personnel with known allergic conditions to specific insects should notify the SSO

so that appropriate precautions can be taken. Notification of allergic conditions can be through the use of

a Medical Data Sheet as presented in Attachment II.

Ticks are small, round-shaped, dark colored insects that are the size of small seeds. Several diseases

(e.g., Lyme disease from deer ticks) may be transmitted from ticks. Therefore, bites from both wood and

deer ticks may present potential hazards to human health. Lightly colored clothing should be worn so that

any ticks present are more easily seen. In addition, site personnel should thoroughly inspect themselves at

the end of the day and remove any ticks that are beneath clothing and/or attached to skin. Additionally,

site personnel should tape pant legs to work boots and if necessary wear protective coveralls to minimize

the potential for tick to become attached. Commercially available insect repellents containing DEET may

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be used according to manufacturer recommendations. Ticks can be removed with tweezers, taking care

to remove the head, then the affected area should be washed with soap and water, and an antiseptic

ointment should be applied. If the tick’s head cannot be removed or if a rash persists, medical attention

should be sought. A tetanus immunization may be recommended. Additional information of Lymes

disease and tick bite prevention is provided in Attachment Ill.

Black widow spiders and brown recluse spiders, both venomous, may also be present in and around

structures (e.g., buildings, well casings) or vegetation. Bites from these spiders can cause swelling and

intense pain in the bite area and in some instances have caused deaths. Site personnel will be made

aware of the potential hazards associated with venomous spiders and instructed to avoid contact with

them. Symptoms associated with a black widow bite include abdominal pain, dizziness, headache,

sweating, severe cramps, weakness, and difficulty breathing. Symptoms of a brown recluse bite may

include fever, chills, nausea, vomiting, itching, and brown urine that may develop within 36 hours. In either

eventuality, medical attention should be sought immediately.

Chiggers may also be present at the site. Precautionary measures against chiggers include tucking

clothing in pants and pant legs into boots.

Venomous insects include wasps, bees, hornets, and red ants. Most of these insects are not considered

to be dangerous. In the event of an insect sting, the following general procedures should be followed:

0

0 Wash the site.

Apply a cold pack.

Remove the stinger with the edge of a credit card or something similar.

If a stinging victim develops serious symptoms including shortness of breath, flushing, swelling of the face,

or severe swelling of a body part, medical attention should be sought immediately. A severe reaction

could mean that a life-threatening condition is developing.

5.3.1.3 Other Animals

Rodents carry diseases such as Hantavims Pulmonary Syndrome (HPS). Human infection may occur

when infective rodent saliva or excreta are inhaled as aerosols produced directly from the animal.

Transmission may also occur when dried or fresh materials contaminated by rodent excreta are disturbed,

directly introduced into broken skin, introduced onto the eye membrane (conjunctivae), or possibly

ingested in contaminated food or water. The disease begins with one or more symptoms including fever,

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muscle aches, headache, and cough and progresses rapidly to severe lung disease. Medical attention

should be immediately sought if these symptoms are observed.

5.3.2 - Flora

Work sites may contain numerous irritant plants with toxins, including poison ivy, poison sumac, and

poison oak. Published research has shown that approximately 45% of those exposed to the resin of these

plants may develop an allergic reaction within 12 to 24 hours. Symptoms of this reaction could include

severe skin irritation characterized by redness, blisters, swelling, and intense burning and itching. Severe

allergic reactions may result in abscesses, enlarged glands, fever, and, infrequently, kidney problems

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