SSSP_Goodfellow_Federal_Center_Buildings.pdf

DRAFT

Attachment A

Site Specific Safety Plan

Goodfellow Federal Center

4300 Goodfellow Boulevard

St. Louis, MO 63120

INTRODUCTION

Due to the disclosures made by the General Services Administration (GSA) regarding the identification of legacy contamination at the Goodfellow Federal Center, (Insert Company Name) understands that many of the facilities and grounds on the Goodfellow Federal Center, St.

Louis, Missouri have been reported to be environmentally contaminated with varying concentrations of hazardous chemicals/materials. Approximately 83 total contaminants that have the potential to affect worker safety and health have been noted at the Federal Center in reports dating from 1985 through 2016.

LOCATION AND DESCRIPTION OF WORK

(Insert Company Name maintains the United States Department of Agriculture (USDA) card reader system installed on the Goodfellow Federal Center. Card reader system components (power supply, wires, cables, control panels, etc.) that are located above the ceiling plenum, below the raised floor, in mechanical rooms, elevator shafts, elevator penthouses, and telephone closets located in the following buildings/column numbers:

Building 104, 1st Floor:

- Column H-52 (Elevator Control Panel Enclosure) Dust with lead and other heavy metals.

Building 104, 2nd Floor:

- Column F-3 Airborne Cadmium. Dust with lead and other heavy metals above the ceiling plenum.

- Column G-4 Airborne Cadmium. Dust with lead and other heavy metals above the ceiling plenum.

- Column F-5 (Control Panel Enclosure) Airborne Cadmium. Dust with lead and other heavy metals above the ceiling plenum.

- Column G-9 Airborne Cadmium. Dust with lead and other heavy metals above the ceiling plenum.

- Column F-10 (Control Panel Enclosure) Airborne Cadmium. Dust with lead and other heavy metals above the ceiling plenum.

- Column J-15 Airborne Cadmium. Dust with lead and other heavy metals above the

- Column B-16 (Elevator Penthouse Control Panel Enclosure) Dust with lead and other heavy metals.

- Column F-16 (Control Panel Enclosure) Airborne Cadmium. Dust with lead and other heavy metals above the ceiling plenum.

- Column B-17 Airborne Cadmium. Dust with lead and other heavy metals above the ceiling plenum.

- Column F-27 (Control Panel Enclosure) Airborne Cadmium and Barium. Dust with lead and other heavy metals above the ceiling plenum.

- Column J-27 Airborne Cadmium and Barium. Dust with lead and other heavy metals above the ceiling plenum.

- Column E-29 Airborne Cadmium and Barium. Dust with lead and other heavy metals above the ceiling plenum.

- Column E-29 #2 Airborne Cadmium and Barium. Dust with lead and other heavy metals above the ceiling plenum.

- Column F-29 Airborne Cadmium and Barium. Dust with lead and other heavy metals above the ceiling plenum.

- Column F-30 (Control Panel Enclosure) Airborne Cadmium and Barium. Dust with lead and other heavy metals above the ceiling plenum.

- Column B-34 Airborne Cadmium. Dust with lead and other heavy metals above the ceiling plenum.

- Column F-35 Dust with lead and other heavy metals above the ceiling plenum.

- Column D-35 Airborne Cadmium. Dust with lead and other heavy metals above the

- Column F-36 Airborne Cadmium

- Column C-43 Airborne Cadmium and Barium.

- Column J-44 Airborne Cadmium and Barium.

- Column F-44 (Control Panel Enclosure) Airborne Cadmium and Barium.

- Column H-52 (Elevator) Airborne Barium

- Column H-53 Airborne Barium. Dust with lead and other heavy metals above the

Building 104-E, 2nd Floor:

- Column L-43 Airborne Cadmium. Dust with lead and other heavy metals above the ceiling plenum.

- Column M-43 (Elevator) Airborne Cadmium. Dust with lead and other heavy metals above the ceiling plenum.

- Column L-49 Airborne Cadmium. Dust with lead and other heavy metals above the

- Column L-49 (Mechanical Room Control Panel Enclosure) Dust with lead and other heavy metals.

Building 104-F, 1st Floor:

- Column P-28 Dust with lead and other heavy metals above the ceiling plenum.

- Column P-35 (Control Panel Enclosure) Dust with lead and other heavy metals.

Building 104-F, 2nd Floor:

- Column L-28 Dust with lead and other heavy metals above the ceiling plenum.

- Column L-28 #2 Dust with lead and other heavy metals above the ceiling plenum.

- Column L-34 Dust with lead and other heavy metals above the ceiling plenum.

- Column L-35 (Control Panel Enclosure) Dust with lead and other heavy metals.

Building 105, 1st Floor:

- Column G-1 Dust with lead and other heavy metals above the ceiling plenum.

- Column G-3 Dust with lead and other heavy metals above the ceiling plenum.

- Column G-7 (Control Panel Enclosure) Dust with lead and other heavy metals.

- Column B-8 Dust with lead and other heavy metals above the ceiling plenum.

- Column D-8 Dust with lead and other heavy metals above the ceiling plenum.

- Column D-9 Dust with lead and other heavy metals above the ceiling plenum.

- Column B-10 Dust with lead and other heavy metals above the ceiling plenum.

- Column B-12 Dust with lead and other heavy metals above the ceiling plenum.

- Column G-15 (Control Panel Enclosure) Dust with lead and other heavy metals.

- Column J-15 Dust with lead and other heavy metals above the ceiling plenum.

- Column B-17 Dust with lead and other heavy metals above the ceiling plenum.

- Column B-17 #2 Dust with lead and other heavy metals above the ceiling plenum.

- Column B-17 (Elevator Penthouse Control Panel Enclosure) Dust with lead and other heavy metals.

- Column G-25 Dust with lead and other heavy metals above the ceiling plenum.

- Column G-25 (Elevator Penthouse Control Panel Enclosure) Dust with lead and other heavy metals.

- Column G-26 (Control Panel Enclosure) Dust with lead and other heavy metals.

- Column B-27 Dust with lead and other heavy metals above the ceiling plenum.

- Column F-28 Dust with lead and other heavy metals above the ceiling plenum.

- Column C-30 Dust with lead and other heavy metals above the ceiling plenum.

- Column C-33 Dust with lead and other heavy metals above the ceiling plenum.

- Column G-34 Dust with lead and other heavy metals above the ceiling plenum.

- Column G-35 (Control Panel Enclosure) Dust with lead and other heavy metals.

- Column G-36 Airborne Cadmium. Dust with lead and other heavy metals above the ceiling plenum.

- Column G-36 #2 Dust with lead and other heavy metals above the ceiling plenum.

- Column B-37 Airborne Cadmium. Dust with lead and other heavy metals above the ceiling plenum.

- Column G-39 (Control Panel Enclosure) Dust with lead and other heavy metals.

- Column C-42 Dust with lead and other heavy metals above the ceiling plenum.

- Column G-42 Dust with lead and other heavy metals above the ceiling plenum.

Building 105, 2nd Floor:

- Column G-3 Dust with lead and other heavy metals above the ceiling plenum.

- Column G-7 (Control Panel Enclosure) Dust with lead and other heavy metals.

- Column J-15 Airborne Cadmium. Dust with lead and other heavy metals above the ceiling plenum.

- Column G-15 (Control Panel Enclosure) Airborne Cadmium. Dust with lead and other heavy metals.

- Column G-26 (Control Panel Enclosure) Dust with lead and other heavy metals.

- Column J-27 Dust with lead and other heavy metals above the ceiling plenum.

- Column G-29 Dust with lead and other heavy metals above the ceiling plenum.

- Column G-34 Dust with lead and other heavy metals above the ceiling plenum.

- Column G-34 (Control Panel Enclosure) Dust with lead and other heavy metals.

- Column G-35 Dust with lead and other heavy metals above the ceiling plenum.

- Column G-35 #2 Dust with lead and other heavy metals above the ceiling plenum.

- Column G-36 Dust with lead and other heavy metals above the ceiling plenum.

- Column B-37 Dust with lead and other heavy metals above the ceiling plenum.

HAZARD ASSESSMENT

ASSESSMENT

- Dust with lead and other heavy metals may be present above the ceiling plenum, below the raised floor, in mechanical rooms, elevator shafts, elevator penthouses, and telephone closets . While working above ceiling tiles within USDA space located at the Goodfellow Federal Center, workers may come in contact with, and be exposed to, contaminated dust. The current primary concerns are noted in surface dust on horizontal surfaces (i.e. on top of ceiling tiles, I-beams, ducts, piping or other appurtenances) above suspended ceiling tiles.

PERSONAL PROTECTIVE EQUIPMENT (PPE) REQUIRED

- Safety toed work boots

- Nitrile gloves

- Work/leather gloves

- Hardhat

- Safety Glasses

- Tyvek sleeves (if contact with dusty side of ceiling tile cannot be avoided)

- Respirator (Specify type of respirators to be used)

RESPONSIBILITIES

(Contract Company), will be the safety manager for this plan. He will oversee training personnel in the following:

- Correct usage of the safety equipment on the site,

- Ensure that all workers have their PPE `prior to personnel traveling to the Goodfellow Federal Center, the installation site superintendent will ensure that PPE is used/worn while working in the hazardous locations.

- Ensures that all respirators for workers have been fitted prior to personnel departing for the Goodfellow Federal Center.

- Be available to answer safety related question that may arise during the installations,

- Superintendent will ensure the site is properly cleaner on a daily bases prior to the team leaving for the day.

OPERATING PROCEDURES

While working above ceiling tiles within USDA space located at the Goodfellow Federal Center, workers may come in contact with, and be exposed to, dust contaminated with lead and other heavy metals. The current primary concerns are noted in surface dust on horizontal surfaces (i.e.

on top of ceiling tiles, I-beams, ducts, piping or other appurtenances) above suspended ceiling tiles. Lead safe work practices will be followed to protect workers from exposure to lead and heavy metal contaminated dust.

The following activities should be accomplished prior to accessing the ceiling.

Step 1: Set up poly sheeting drop cloth on the floor adequate to contain any released dust into the work area.

Step 2: Cover furniture or objects directly beneath the operation with poly sheeting to contain any released dust into the work area.

Step 3: Don Tyvek sleeves if used

Step 4: Put on nitrile gloves.

Step 5: Put on work gloves.

The following lead safe work practices should be utilized by individuals working in the spaces above suspended ceilings to protect workers and tenants during the work and after its conclusion.

- Work will be performed after hours/when the tenants are not present.

- Employees should set up poly sheeting below the intended work area, as well as cover furniture or objects beneath the operation, prior to work above the suspended ceiling. Poly sheeting should extend approximately 6-feet around the work area.

- Placements of signs outside the work area stating: “Warning, the work being performed in this area has the potential to create airborne environmental contaminant dust. Entry to this area is prohibited to all personnel except CRI utilizing the appropriate personal protective equipment, until the space has been determined to be acceptably clean and free of visible dust and or possible contamination”

- Employees will contact GSA to disable the applicable HVAC equipment supplying the area, prior to the disturbance or removal of ceiling tiles. This action will reduce air movement in the plenum space above the ceiling tiles, minimizing the release of contaminated dust from surfaces.

- The employee should ascend the ladder and/or lift and utilize a HEPA vacuum to capture any dust build up on the horizontal surfaces of the suspended ceiling grid and tops of ceiling tiles surrounding the opening.

- The employee should HEPA vacuum any horizontal surface (tops of pipes, I-beams, duct work, brackets, etc.) where dust may be disturbed by the work being performed.

- Once work above the suspended ceiling is completed and the ceiling tile reinstalled, HEPA vacuum all equipment, drop cloth, and the floor surrounding the work area. Then, the employee should remove nitrile gloves and place them in a 6 mil poly bag along with poly sheeting for disposal.

- Employees should always wash their hands after conducting this work, removing PPE and before eating.

- All equipment should be maintained in a clean working order.

- Email communications to notify the USDA Physical Security Office who in turn will notify GSA St. Louis Field Office of upcoming work within USDA space will be used. Emails regarding upcoming work will be sent prior to the initiation of work activities.

*Include operating procedures for working below raised flooring, elevator penthouses, mechanical rooms

DECONTAMINATION EQUIPMENT

6 mil poly disposal bag 6 mil poly sheeting HEPA vacuum with true HEPA filtration Disposable Wipes or Paper Towels Utility Knife/Safety Cutter Traffic Cones Signs Barrier tape Scissors Duct tape D-Lead Solution

Decontamination:

To the extent possible, (Insert Company Name) will take measures to help prevent contamination of tools, equipment and reusable PPE, (small tools, equipment, and reusable PPE will be placed/stored into plastic bags when not in use). If/when a tool, piece of equipment, or reusable PPE comes into contact with a contaminated surface, it shall be decontaminated by wiping it down with an approved cleaner. All material used to decontaminate tools and equipment will be bagged and disposed of according to GSA recommendations. All equipment will be decontaminated prior to the removal of PPE. Disposable PPE, such as Tyvek sleeves, gloves, etc. will be bagged and disposed of according to GSA recommendations.

Waste generated through the completion of activities within the contaminated spaces (i.e., used disposable PPE, HEPA Vacuum filters, other waste materials, etc.) and accumulated in disposal bags will be segregated until toxicity characteristic leaching procedure (TCLP) analysis for Resource Conservation and Recovery Act (RCRA) lead and metals can be completed in accordance with EPA regulations [40 CFR 261.24]. TCLP is an analytical method used to determine if waste is characteristically hazardous, and therefore, must be treated and disposed as such. All waste materials shall be identified as "hazardous waste" if the materials exceed the regulated levels, (e.g., lead = 5 ppm, cadmium = 1ppm, etc.). Waste that is defined as hazardous waste by the TCLP method shall be properly disposed in a specialty permitted landfill. If the waste is deemed non-hazardous through the TCLP analysis, the waste stream will be disposed of as general waste in a typical municipal landfill. All hazardous waste shall be properly disposed of in accordance with EPA, State and Local regulations.

INDUSTRIAL HYGIENE AND OCCUPATIONAL HEALTH

Avoid any hand-to-mouth actions which could result in the ingestion of dust or other materials.

Chewing gum in restricted areas is prohibited.

Eating/drinking while in restricted access areas is prohibited.

Smoking, use of smokeless tobacco and use of e-cigarettes is prohibited in restricted access areas.

Wash hands and exposed skin immediately upon leaving restricted access areas and removing PPE.

EMERGENCY PROCEDURES

The following procedure will be utilized when reporting an emergency at 4300 Goodfellow Boulevard:

Call the Federal Protective Service MEGA Center at (877) 437-7411, ASK FOR THE ST.

LOUIS DISPATCHER and provide the following information:

Your name and call-back number.

Location: 4300 Goodfellow Boulevard, building number, floor and column number.

Nature of the incident: medical emergency, fire, bomb threat, etc.

If available, have someone from the location of the incident go outside and be ready to direct emergency personnel to the incident location and allow access to the secure areas.

Calling 911 if time permits.

Insert Emergency Contact Names and Phone Numbers of (Insert Company Name)