524048 - AWP - Appendices.pdf

MARYLAND

DEPARTMENT

OF

TRANSPORTATION

CONTRACTOR, TENANT,

AND PORT USER

ENVIRONMENTAL

HANDBOOK

APPENDIX I

UPDATED MARCH 2023 P A G E | 1

Contractor, Tenant, and Port User Environmental Handbook

March 2023

Maryland Port Administration’s Environmental Policy

“Maryland Port Administration (MPA) believes that stewardship and sustainability of the environment, its business and protection of public health are essential elements to accomplish its mission to promote the flow of waterborne cargo through the port. MPA is committed to environmental compliance and continual improvement; pollution prevention; and effective engagement with its employees, communities, port users/tenants, government and non-government organizations.”

1.0 Introduction

To ensure environmental compliance, MPA uses an Environmental Management System (EMS).

The EMS will facilitate an on-going process to determine activities and conditions that impact the environment and how best to eliminate or reduce those impacts. This Contractor, Tenant, and Port User Environmental Handbook (Handbook) was developed as part of the EMS process.

This Handbook describes some of the procedures and best management practices (BMPs) that can reduce or eliminate potential impacts that MPA contractors, tenants, and port users have through their daily work activities. All contractors, tenants, and port users are expected to adhere to the practices required and to the extent possible implement BMPs set forth in this Handbook that are above and beyond what is contained in specifications and drawing documents related to this contract or lease restrictions.

2.0 Jobsite and Terminal Work Areas

Work areas are to be kept clean and litter free. Debris from the worksite should be cleared daily and disposed of properly. Sweep work areas regularly to prevent small debris, sand, grit, and other contaminants from building up and entering storm water systems.

3.0 Waste Management

Waste generated through contractor, tenant, and port user activities must be disposed of properly and is the responsibility of the contractor or tenant to do so lawfully. Each contractor, tenant, or port user is encouraged to eliminate and minimize waste where feasible and recycle waste through local recyclers, if possible.

UPDATED MARCH 2023 P A G E | 2

3.1 Hazardous Waste

Hazardous waste is a solid waste that the U.S. Environmental Protection Agency (EPA) has defined as a “Listed Waste” or a solid waste that is Ignitable, Corrosive, Reactive or Toxic. The following sections list common hazardous wastes that may be generated during your operations at MPA facilities; however, it should not be considered a complete list. If there are any questions regarding proper disposal practices for hazardous waste, please contact the MPA Environmental Department at (410) 633-1142.

3.1.1 Aerosol Can Fluids – The contractor, tenant, or port user is responsible for proper disposal of aerosol cans and fluids. An aerosol can is a container in which gas under pressure is used to aerate and dispense liquid through a valve as a spray or foam. The aerosol shall be punctured; the fluids shall be drained, collected, and treated as a hazardous waste. The aerosol can may be crushed and recycled or disposed of properly.

3.1.2 Capacitors – If the label on a capacitor indicates that the capacitor contains PCBs, the used capacitors must be treated and disposed as a hazardous waste.

3.1.3 Lead Acid Batteries – Battery acid is a hazardous chemical. Lead Acid Batteries must be stored inside in an upright position and away from flammable liquids, ignition sources, and drains. Secondary containment is preferable. Batteries should not be stacked and should be spaced to avoid falling and cracking. A spill kit with a neutralizing agent should be readily available. Batteries can never be stored outdoors.

3.1.4 Lead and Oil-based Paints – These types of paints must be treated as a hazardous waste and disposed of properly. The best management option is to use up contents whenever possible. Completely empty paint cans may be disposed of as a solid waste.

3.1.5 Hazardous Waste Drums – When storing hazardous wastes for disposal, the drums shall be labeled with the contents (i.e., Hazardous Waste - XYZ 123) and with the accumulation start date. The contractor, tenant, or port user is responsible for making sure the drums are in good condition with lids tightly closed when not adding materials, stored in secondary containment units, properly labeled, and disposed of on time. Drums containing hazardous waste must be removed from the site as soon as possible, but no later than 90 days from the accumulation date.

3.1.6 Hazardous Waste Manifests – A manifest must accompany all hazardous waste shipments. Hazardous waste manifests must be coordinated with the MPA Environmental Department at (410) 633-1142.

3.1.7 Unknown Waste Drums – If a contractor, tenant, or port user has identified a drum containing an unknown waste, the drum shall be handled as a hazardous waste.

UPDATED MARCH 2023 P A G E | 3

3.2 Universal Waste

EPA universal waste (UW) regulations address certain hazardous waste. EPA promulgated the UW regulations on May 11, 1995, to ease the management burden and promote the collection and recycling of these commonly generated wastes.

UW generated at MPA facilities would include batteries, lamps and bulbs, mercury containing equipment, and PCB light ballasts. UW must be sent to an approved facility within one year of accumulation. Each UW should be stored in its own labeled container (with lid). UW should not be commingled. The contractor, tenant, or port user shall not place any UW in solid waste containers or trash dumpsters. The contractor must dispose of UW properly.

3.2.1 Batteries (except lead acid batteries) – Batteries to be managed as UW include:

nickel-cadmium, alkaline, 3.6-volt, 6-volt, 9-volt, and gel.

3.2.2 Lambs and Bulbs – Lamps and bulbs to be managed as UW include: high-pressure sodium, mercury vapor, fluorescent, metal-halide, and halogen bulbs or tubes. It is recommended that used UW lamps are stored in the original sleeve or box.

3.2.3 Mercury Containing Equipment – Mercury Containing Equipment to be managed as UW includes thermostats and lamps.

3.3 Non-hazardous Waste

Non-hazardous waste may include used oil, oil/fuel filters, recyclables, and used absorbent materials. The contractor is solely responsible for handling, disposing of, or recycling non-hazardous waste properly.

3.3.1 Used Waste Oil – Used waste oil shall be stored in above ground storage tanks (AST) or drums in good condition and labeled as “Used Oil.” The ASTs or drums shall be free of visible leaks and must have a secondary containment mechanism. The contractor shall recycle their used waste oil. A spill kit must be readily available next to all drums and ASTs containing oil. All oil spills must be cleaned up immediately.

3.3.2 Fuel Filters – Fuel filters include gasoline, diesel, and used oil.

Gasoline Filters – Gasoline filters shall be collected after use and positioned to allow collection of the used gasoline. The filter should be disposed in an appropriate container specifically for used gasoline filters.

Diesel and Oil Filters – Used diesel and oil filters shall be collected and positioned to allow for proper drainage. The oil and diesel mixture shall be put into a drum or tank with secondary containment and labeled – Used Oil. The drained filter can be crushed and discarded in a drum labeled Oil filters.

UPDATED MARCH 2023 P A G E | 4

3.3.3 Used Anti-Freeze – Used anti-freeze shall be stored in labeled containers and tanks with secondary containment. The containers shall be maintained in good condition and all spills and leaks must be cleaned up immediately. Used anti-freeze is disposed of offsite in an appropriate manner and the contractor shall maintain receipts for all transfers offsite.

3.3.4 Recyclables: Scrap Tires, Scrap Metal, Wire Rope, and Wood Pallets – MPA considers scrap tires, scrap metal, wire rope, and wood pallets as recyclable materials. Whenever possible, MPA contactors, tenants, and port users should recycle these materials in an appropriate manner. MPA requires that their contractors, tenants, and port users cover spools of used wire rope to ensure that the oil and grease on the wire is not exposed to stormwater and released into storm drains.

3.3.5 Used Absorbent Materials – Absorbent materials used to clean up an oil spill shall be cleaned up immediately, placed in a plastic bag, sealed, and disposed of as a solid waste in the dumpster. If the absorbent material is used to clean up a hazardous waste, the absorbent material is managed as a hazardous waste, per section 3.1 of this document.

3.3.6 Non-Hazardous Waste Drums – Non-hazardous waste that is stored in drums includes used oil, used hydraulic fluid, used anti-freeze, and used parts washer fluid. These drums must be stored inside or in a mechanism providing secondary containment and labeled with the drum’s contents. Drums containing new product such as oil, anti-freeze, hydraulic fluid, and grease should not be stored with used product.

3.3.7 Latex Paint – Latex paint is non-hazardous and shall only be disposed of if the paint can is completely empty or if the paint has completely dried or solidified in the can. The best management option is to use up the contents and eliminate the waste.

3.4 General Waste Management Best Management Practices

Materials associated with construction and general work activities must be stored and disposed of properly as described in Sections 3.1 through 3.3. However, additional BMPs for general waste management should be considered at all work sites and include the following:

Provide clearly labeled recycling and waste facilities and allow for separation and sorting of materials

Conduct pre-construction and routine site audits to determine the nature and amount of materials to be reused, recycled, or disposed

Develop a plan to minimize waste and maximize recycling and include training and clear signage to support the plan

Identify ways of reusing materials (e.g., concrete crushing) on site

UPDATED MARCH 2023 P A G E | 5

Encourage onsite materials management for reuse opportunities

4.0 Oil and Pollutant Spill Prevention Controls and Countermeasures

Spill Prevention, Controls, and Countermeasures include the methods to prevent spills before they happen, the methods to contain or control a spill once it has occurred, and the countermeasures to reduce the impact of a spill.

Note: A spill of one gallon of oil can contaminate a MILLION gallons of water!

The Oil Pollution Prevention Rule was put into law in 1974 by the authority of the Clean Water Act. Oil means any kind of oil in any form. This includes petroleum; fuel oil; oil mixed with wastes;

fats, oils or greases of animals, fish, or marine life; vegetable oils; and other oils including synthetic and mineral oils.

All MPA contactors, tenants, and port users conducting oil handling procedures on MPA property are required to have an oil response spill kit and be responsible for the 3Rs – React, Report and Respond.

React if you see an oil spill.

Report the oil spill.

Respond to the oil spill.

4.1 How to Control an Oil Spill

First, do not put yourself or anyone else in danger.

Stop the flow.

This may involve turning a drum upright, closing a valve, or plugging a hole.

Classify the spill.

Determine appropriate clean-up measures.

Contain the spill.

Prevent the spill from migrating, especially to a storm drain.

Use absorbent materials, booms, or pillows from a spill response kit.

If the spill cannot be contained, block off nearby storm drains to prevent spills from entering them.

Notify MDTA Police at (410) 537-7911.

Notify Maryland Department of the Environment Emergency Spill Response Officials at

(866) 633-4686.

Document the incident.

UPDATED MARCH 2023 P A G E | 6

4.2 Spill Kits

MPA contractors, tenants, and port users are required to have spill kits readily available at their facilities/sites and must restock kits as needed.

4.3 Spill Prevention, Control, and Countermeasure Best Management Practices

Spill prevention and prompt appropriate spill response reduces the potential for polluting water, soil, and air. Spills of concern include contaminants covered under the Oil Pollution Prevention Rule as well as chemicals and hazardous wastes such as herbicides, fertilizers, de-icing products, lubricants, paints, solvents, and fuels. Additional examples of spills that could occur include the following:

Diesel fuel spill from equipment during re-fueling or a break in a fuel line

Hydraulic fluid spill from a hydraulic line break

Liquid spills during transfers

Evaporation of solvents from open containers (including soiled rag storages containers)

Prior to starting work, a site inspection should be completed to assess the potential for spills and preventative actions that can be taken. If equipment or facilities are identified as having a high potential for spills, spill and leak monitoring systems and emergency spill-response equipment should be located nearby. On-water activities should include spill prevention plans that specify emergency response and emergency equipment (e.g. oil booms).

5.0 Stormwater Pollution Prevention Plan

MPA contractors, tenants, and port users must be aware that every time it rains, pollutants form the surface discharge into storm drains. The contaminated stormwater goes directly into our creeks, rivers, and bay. The pollution poses a risk to humans, wildlife, and the environment and the following actions are key to reducing and eliminating contaminated stormwater from entering adjacent water bodies.

Storm drains or catch basins collect stormwater runoff during and following a rain event.

Water collected in the storm drains is not treated at a wastewater treatment plant, but rather drains directly into local streams, rivers, and eventually empties into the Chesapeake Bay.

Any time pollutants, such as used wash water, motor oil, fertilizers, pesticides, grit, debris, or trash are dumped or washed into a storm drain they end up in our streams, rivers, and the Chesapeake Bay. These pollutants degrade various forms of aquatic life, waterways used for recreation, and sources of our drinking water.

UPDATED MARCH 2023 P A G E | 7

When a product is biodegradable, it does not mean that it is non-toxic to aquatic life or safe to enter our waterways. Therefore, even environmentally friendly products are banned from being disposed into storm drains.

Non-permitted discharge of any kind to a storm drain is called non-point source pollution. This non-point source pollution is illegal, and it is the leading cause of water quality deterioration of the bodies of water throughout the United States.

Contractors, tenants, and port users are responsible for maintaining a work environment that prevents discharges to the waters of Maryland. Recommended procedures include the following:

Maintain work areas as neatly as possible.

Ensure that all equipment is regularly inspected and functioning correctly.

Clean oil spills immediately.

Minimize storage of materials outside.

Do not wash vehicles or equipment outside.

Closely follow procedures as outlined in this handbook.

5.1 Additional Stormwater Pollution Prevention Plan Best Management Practices

BMPs include both structural devices and nonstructural practices designed to temporarily store or treat stormwater runoff to mitigate flooding and reduce pollution. Some example BMPs are included below and should be considered as part of a site and project plan for reducing the potential for contaminated stormwater reaching adjacent water bodies.

Consider choosing materials made for exterior or in-water use to minimize the contribution of common pollutions to stormwater or aquatic environments. Review and avoid or minimize using the following materials:

Copper and zinc roofs, gutters, downspouts, siding, or galvanized materials

Treated lumber, treated piling, or dock bull rails

Coal tar sealants on asphalt pavement

Fertilizers and pesticides through effective low-maintenance landscape design

Reduce stormwater runoff from infrastructure by adopting the following practices:

Minimize impervious surfaces and maximize pervious or semi-pervious surfaces such as concrete/asphalt or pavers.

Retain or increase existing trees and natural vegetation on site to the extent feasible.

UPDATED MARCH 2023 P A G E | 8

Include low impact water quality features (e.g., below ground media filtration devices; compost berms; vegetated strips; constructed stormwater wetland;

biorientation facility; or buffer strips).

Include rainwater harvesting designs.

Include green roofs.

Minimize the amount of stormwater runoff from demolition sites into the harbor by installing temporary water catchments.

Divert stormwater in contact with maintenance areas or operations containing or using potential polluting substances to collection basins or sanitary sewer.

Provide stormwater water quality controls and/or treatment for routine maintenance and fueling of operation equipment.

6.0 Air and Noise Pollution Best Management Practices

MPA supports measures to mitigate and reduce air and noise pollution and encourages contractors, tenants, and port users to consider BMPs that can reduce impacts on workers and the community. Contractors and tenants are encouraged to implement the following BMPs to reduce air and noise pollution.

6.1 Air

Require tenant-owned and construction-related trucks, cargo handling equipment, ships, barges, and marine equipment to use low sulfur or ultra-low sulfur fuels where possible.

Cover trucks hauling material such as debris or fill while operating on and off port property.

Minimize idling of construction equipment, cargo handling equipment, off-road and on-road vehicles.

Evaluate types of equipment used for maintenance (e.g., hybrid or electric maintenance vehicles, natural gas-powered street sweepers, or electric mowers in place of gas or diesel-powered and/or solar chargers for use in light-duty battery-operated equipment).

Minimize emission generation by using hybrids, electric, or human power vehicles, or low fuel consumption vehicles.

Conduct regular energy audits and identify ways to switch from diesel to hybrid or electric, reduce fuel and energy consumption, and incorporate alternative fuels (e.g., biogas, natural gas).

UPDATED MARCH 2023 P A G E | 9

6.2 Noise

Reduce noise generation at the source by specifying use of less noisy equipment, requiring muffler systems on equipment, employing shields, modifying vehicles and equipment to reduce noise levels.

Use noise barriers where appropriate; detour construction-related transportation away from sensitive public and port areas.

Evaluate the impact of noise and light generated during construction and operation on the surrounding areas.

7.0 Natural Resources Protection and Conservation Best Management Practices

MPA believes taking responsibility for clean air, land, and water not only complements good business, but drives it. Protecting and conserving our natural resources is a key part of MPA’s commitment as a good neighbor and for long-term sustainability of the Patapsco River and Chesapeake Bay. Contractors, tenants, and port users are expected to incorporate protection and conservation practices into special projects and everyday activities. BMPs include the following:

Minimize site disturbance through clearing and grading; maintain natural drainage courses if possible.

Retain or increase existing trees and natural vegetation on site to the extent feasible.

Ensure construction equipment is decontaminated prior to entering site and prior to leaving the site to prevent the spread of invasive species.

Use construction materials from local or regional sources.

8.0 Contractor Acceptance

By accepting this contract, the contractor acknowledges receipt of the Contractor, Tenant, and Port User Environmental Handbook and agreement to adhere to the practices set forth in the Handbook. The contractor also agrees to train its employees on the requirements within the handbook. These training records should be maintained on site and available to the MPA for review. This Handbook does not specifically identify all applicable environmental laws and regulations. The contractor is still required to adhere to all applicable local, state, and federal environmental laws and regulations, even if not specifically identified in this handbook.

PORT

ADMINISTRATION

MASTER HEALTH AND

SAFETY PROGRAM FOR

CHROME-RELATED WORK

PROJECTS

APPENDIX II

MARYLAND PORT ADMINISTRATION

MASTER HEALTH AND SAFETY PROGRAM

FOR CHROMIUM-RELATED WORK PROJECTS

Dundalk Marine Terminal

Prepared for:

Maryland Port Administration 2310 Broening Highway

Baltimore, MD 21224

Prepared By:

Emilcott 466 Southern Blvd.

Chatham, NJ 07928

December 2006

TABLE OF CONTENTS

ACRYONMS ................................................................................................................................................. II

1.0 PURPOSE

1.1 THE CONSENT DECREE REQUIREMENTS AND TASKS

1.2 DEFINITION OF CHROMIUM RELATED WORK PROJECTS AND EXPOSURE GROUPS

1.3 HOW TO USE THE MPA HASP

2.0 GENERAL BACKGROUND

2.1 H&S ROLES AND RESPONSIBILITIES OF THE VARIOUS ORGANIZATIONS WORKING AT THE DMT . 4

2.1.1 MPA Management Team (MPA Team)

2.1.2 Primary Contractor (PC)

2.1.3 Secondary Contractors (SC)

2.1.4 MPA Employees Who Perform Work in COPR Area

2.1.5 Visitors

2.2 APPLICABLE H&S REGULATIONS AND CRITERIA

3.0 GENERAL HAZARD ASSESSMENT

3.1 HEALTH EFFECTS OF CRVI

3.2 EXPOSURE ASSESSMENT OF CRVI AT DMT

3.2.1 Definition of Exposure Groups (EG)

3.2.2 Mechanism to Determine Exposure Group Classification

4.0 H&S REQUIREMENTS FOR EACH CRVI EXPOSURE GROUP

4.1 EXPOSURE GROUP 1 (EG 1)

4.2 EXPOSURE GROUP 2 (EG 2)

4.3 EXPOSURE GROUP 3 ( EG 3)

5.0 GENERAL H&S REQUIREMENTS AT DMT

5.1 PROCEDURES TO IDENTIFY COPR

5.2 GENERAL AIR MONITORING REQUIREMENTS FOR CHROMIUM-RELATED WORK

5.2.1 Personal Monitoring

5.2.2 Area Monitoring

5.3 PERSONAL PROTECTIVE EQUIPMENT AND RESPIRATORY PROTECTION

5.3.1 Work Clothing

5.3.2 Modified Level D Personal Protection

5.3.3 Level C Personal Protection

5.4 HEALTH & SAFETY TRAINING REQUIREMENTS

5.5 MEDICAL SURVEILLANCE REQUIREMENTS

5.6 CLEAN UP AND PERSONAL HYGIENE

5.7 EMERGENCY RESPONSE PROCEDURES

5.7.1 Evacuation (Reference Marine Terminal Evacuation Plan – 2/6/2006)

5.7.2 MPA’s Hazardous Waste Evacuation Plan…………………………………………………………22

Appendices

A-1 Model Site Specific H&S Plans - 1

Site-Specific Health and Safety Plan for Chromium Related Work Projects A-2 Model Site Specific H&S Plans - 2

Site-Specific Health and Safety Plan for Potential Chromium Related Work Projects

Maryland Port Administration Page i

ACRYONMS

CM Construction Management CMIPP Corrective Measures Implementation Project Plan COPR Chromium Ore Processing Residue CrIII Trivalent Chromium CrVI Hexavalent Chromium DMT Dundalk Marine Terminal EG Exposure Group EPA US Environmental Protection Agency H&S Health and Safety HAZMAT Hazardous Materials

HAZWOPER OSHA Standard for Hazardous Waste Operations and Emergency Response

IC Incident Commander MDE Maryland Department of the Environment MdTA Police Maryland Transportation Authority Police MES Maryland Environmental Services MOSH Maryland Occupational Safety and Health MPA Maryland Port Administration MPA HASP Maryland Port Administration Master Health & Safety Program MSRM Safety & Risk Management OSHA US Occupational Safety and Health Administration PC Primary Contractors, Tenants PEL Permissible Exposure Limit PLHCP Physician or Licensed Health Care Professional PPE Personal Protective Equipment SC Secondary Contractors, Subcontractors and Consultants SSHASP Site Specific Health and Safety Plan

Maryland Port Administration Page ii

1.0 PURPOSE

The purpose of this Maryland Port Administration Master Health & Safety Program (MPA HASP) is to develop Health and Safety (H&S) procedures and processes to address all chromium-related work projects at the Dundalk Marine Terminal (DMT) pursuant to Section 9(d) of the DMT Consent Order dated April 4, 2006 (the “Consent Decree”).

Maryland Port Administration (MPA) has developed the MPA HASP to provide both general and specific requirements regarding potential exposure to chromium and Chromium Ore Processing Residue (COPR) at the Dundalk Marine Terminal. This program must be followed by all personnel performing chrome-related or potentially chrome-related work projects at the Dundalk Marine Terminal (DMT). This plan outlines the responsibilities of all parties operating on this site, and requires coordination of all health and safety plans to ensure compliance with Maryland Occupational Safety and Health (MOSH) regulations and other applicable law. The MPA HASP is intended to reduce the potential of health and safety hazards to personnel performing chrome-related or potentially chrome-related work projects at DMT.

It is a general requirement at DMT that all contractors, subcontractors, and tenants performing chromium-related work at DMT exercise reasonable care to ensure that their employees, representatives, and guests are following appropriate health and safety procedures. Each contractor, subcontractor, and tenant working at DMT is responsible for the health and safety of its employees and authorized visitors. Each contractor, subcontractor, and tenant is also responsible for complying with the procedures in this document and for developing appropriate Site Specific Health and Safety Plans (SSHASP) covering the activities on its site. Each contractor and its subcontractor shall submit to MPA a copy of its project and an integrated SSHASP for review. The contractor SSHASP must meet or exceed the requirements of the MPA HASP.

1.1 The Consent Decree Requirements and Tasks

The Consent Decree is designed to protect the public health and the environment by providing a final remedy for addressing, treating, controlling, preventing, or mitigating the presence and/or releases or threatened releases of chromium at or from the DMT.

Generally speaking, the Consent Decree is a continuation of corrective measures taken pursuant to a 1992 administrative consent order between MPA and Maryland Department of the Environment (MDE). Under the 1992 consent order, MPA undertook a wide variety of remedial measures, including, but not limited to: (i) the preparation of a Corrective Measures Implementation Project Plan (CMIPP); (ii) construction of outfall structures to serve as backflow preventors; (iii) rehabilitation of the storm water pipes; (iv) monitoring of groundwater and surface water flow; (v) a new plan for management of chromium contaminated soils excavated; and (vi) design and construction of extraction wells and a wastewater treatment plant to treat contaminated groundwater and dry weather flow in the stormdrains. Under the new Consent Decree, MPA and Honeywell will update and continue corrective measures undertaken under the 1992 consent order, perform certain interim corrective measures and studies; complete a Corrective Measures

Maryland Port Administration Page 1

Alternatives Analysis to evaluate all permanent and/or long term remedial alternatives;

and implement all permanent or long term corrective measures chosen by MDE within 17 years.

As part of the Consent Decree, MPA and Honeywell are required to develop and implement a master health and safety plan that addresses all chromium-related work projects at the site. This document and its attachments (appendices) are designed to meet this requirement.

1.2 Definition of Chromium Related Work Projects and Exposure Groups

Definition of Chromium Related Work Projects

The DMT is an active marine terminal with a wide variety of operations and activities.

The majority of DMT is covered by asphalt or other similar materials that act as a physical barrier covering the subsurface soil which may consist of COPR or potentially COPR contaminated soil. It is believed that approximately 120 acres of the DMT site consists of chromium ore processing residue (COPR) fill which is located beneath the asphalt cap (the COPR Fill Area). It is also possible soil in the non-COPR Fill Area may have come into contact with chromium-contaminated groundwater from the COPR Fill Area. Therefore, for the purposes of this MPA HASP, chromium-related work projects shall include any work to be performed in the COPR Fill Area that involves, or is reasonably likely to involve, contact with known or potential COPR or chromium-contaminated soil and water.

This covers all remedial type activities in the COPR Fill Area. All work performed outside the boundaries of the COPR Fill Area at DMT will be considered to be potentially chromium related, and all contractors, subcontractors, and tenants must be aware of the potential for encountering chromium or COPR, and may request screening, sampling or other analytical methods as set forth in this MPA HASP.

Everyone who works or visits DMT will be classified into one of three exposure groups (EGs) based on potential for contact or exposure to chromium. Based on work activities, personnel and activities will be categorized as Exposure Group 1 (EG1), Exposure Group 2 (EG2) or Exposure Group 3 (EG3). The personnel, activities, and who is responsible for classifying these Exposure Groups are outlined in Section 3.2.1.

Work activities that are determined by screening, sampling or historical data to have no reasonable probability of contacting chromium-containing material at DMT will not be considered a chromium-related work project or activity and will be classified as an EG1.

All other work activities will be considered potentially chromium-related work projects or activities and will be categorized as either an Exposure Group 2 (EG2) or Exposure Group

3 (EG3).

The site map below indicates the locations of the COPR Fill Area:

Maryland Port Administration Page 2

1.3 How to Use the MPA HASP

This MPA HASP defines the exposure potential for personnel performing work at the DMT and the subsequent requirements and provides direction for the next steps to be taken by personnel depending on their exposure group (EG) classification.

In this plan, the MPA determines and advises the involved parties if the work to be performed is in a (COPR) area. The next step is for the affected organization to classify the work and personnel performing the work into one of two exposure groups Exposure Group 2 (EG2) or Exposure Group 3 (EG 3). Work in COPR or non-COPR areas found to contain chromium contamination triggers the need for certain requirements:

• Development of a Site Specific Health &Safety Plan

• The need for conducting air monitoring and field screening for chromium

• Worker training and medical requirements

• Personal Protective Equipment (PPE) and respirator requirements.

This document and its appendices provide the logic and details for managing H&S programs in chromium related projects.

Maryland Port Administration Page 3

2.0 GENERAL BACKGROUND

2.1 H&S Roles and Responsibilities of the Various Organizations Working at the

DMT

At DMT, there may be multiple chromium-related projects running simultaneously and involving various companies and organizations. MPA personnel, contractors, sub-contractors and consultants are conducting chromium–related maintenance, construction and remedial activities occurring on this site and must work under the MPA HASP. Each individual company and organization is responsible for its own H&S program and procedures, and ultimately the performance of its employees and subcontractors. There is a need, however, to establish an H&S management system that ensures that each program meets minimum requirements, is coordinated to work with other H&S programs, and is technically correct, reasonable, effective and performing to expectations.

The H&S organization at DMT consists of five major groups:

• MPA Management Team (MPA Team)

• Primary Contractors, Tenants (PC)

• Secondary Contractors, Subcontractors and Consultants: (SCs)

• MPA Employees who perform maintenance work in COPR areas

• Visitors

Responsibilities of each group will be defined in sections 2.1.1- 2.1.5.

2.1.1 MPA Management Team (MPA Team)

This group is the MPA management team that has project management oversight for all H&S related matters and the MPA HASP. The MPA Team consists of five groups:

• MPA Engineering

• MPA Construction Management (CM)

• MPA Manager Safety and Risk Management (MSRM)

• MPA DMT Security

• Maryland Environmental Services (MES) H&S Support

The overall role of the MPA Team is to ensure that procedures are in place and being implemented to:

• Protect the workers, public and environment from possible chromium-related contamination associated with activities being conducted on site.

• Provide security for the DMT.

Maryland Port Administration Page 4

• Establish H&S management systems to maintain regulatory compliance, worker safety, and environmental protection.

MPA Engineering – MPA Engineering has overall project authority for MPA construction projects. MPA Engineering has the following H&S responsibilities:

• Develop clear project specifications identifying the work with regards to COPR area;

• Designate H&S responsibilities (e.g. Primary Contractors (PCs) and Secondary Contractors (SCs) for each project and/or project phase;

• Provide direction in disputes that involve H&S issues;

• Communicate and meet regularly with the MPA team regarding H&S issues;

• Serve as the liaison with public officials as required.

MPA Construction Management (CM)- CM’s primary job function is to provide direction and construction oversight of site activities to determine compliance with the project work plan and other project performance expectations. Specific H&S responsibilities may include:

• Become knowledgeable of the H&S requirements, procedures, organization and responsibilities of the project and the companies/organizations involved;

• Receive and maintain H&S documentation which includes: H&S plans, personnel training and medical qualification documents, incident reports, and other H&S documentation as appropriate;

• Obtain and distribute SSHASP and other related H&S documentation to appropriate persons;

• Document daily H&S oversight activities and provide feedback to appropriate parties;

• Terminate work for violation or discrepancy with agreed-to H&S work plans;

• Communicate and meet regularly with the other members of the MPA team regarding H&S issues.

Maryland Port Administration Page 5

MPA Manager, Safety & Risk Management (MSRM) has responsibility for safety, environmental, and emergency response for the MPA. Specific H&S responsibilities related to the MPA HASP include:

• Review and accept/reject all chromium-related contractor H&S plans, including the SSHASP, and provide comments to appropriate persons; major changes must also be reviewed by the MSRM;

• Provide H&S advice or consultation on projects or work activities where MPA team is taking the role of the PC or MPA employees are performing the work;

• Provide H&S oversight, in conjunction with CM, of contractor H&S program implementation;

• Conduct Health Hazard Evaluation and oversight as necessary;

• Determine H&S actions as required;

• Conduct DMT site orientation training;

• Lead Incident Investigations, as needed;

• Provide H&S technical resources and support as needed;

• Communicate and meet regularly with the MPA team regarding H&S issues;

• Serve as the liaison with public officials when directed by MPA engineering.

MPA DMT Security consists of the Maryland Transportation Authority (MdTA) Police, a law enforcement agency, and the MPA Security Department and its subcontractor, a guard force.

• Manage the overall DMT security program;

• Manage the site emergency response program; all emergencies must be coordinated through the MdTA Police Dispatch (410.633.1092).

MES H&S Support

Maryland Environmental Services (MES) is a MPA primary contractor at DMT that provides a variety of site environmental and maintenance services as directed by MPA.

For the majority of the work onsite, MES must meet the H&S responsibilities of the Primary Contractor as detailed in Section 2.1.2. MES also plays a technical support role as directed by the MPA HSM. This support role includes:

• Conducting field screening samples for chromium in soil and water.

Maryland Port Administration Page 6

2.1.2 Primary Contractor (PC)

MPA Engineering will formally designate a PC for each project or project phase prior to the onset of field project activities. The PC is responsible for coordinating overall project site H&S activities within its area of control, so that all groups associated with the project can successfully integrate their SSHASP. The PC’s SSHASP must address all the construction type hazards that may apply to the project task, as well as the potential hazards associated with possible chromium contamination. The SSHASP of Secondary Contractors (SC) must be integrated with the plans and procedures of the PC, when necessary. No project activity may begin until the PC’s SSHASP, including integration of the SC’s SSHASP, has been reviewed and accepted by the MPA.

The PC’s SSHASP must meet the requirements of the Maryland Occupational Safety and Health (MOSH) Hazardous Waste Standard (1910.120 (b)), Construction standards and/or other applicable MOSH, EPA, and MDE standards and regulations, as well as the MPA HASP. The PC must, as part of this plan, ensure that the plans and procedures of all other designated Secondary Contractors are coordinated and integrated

At minimum, the PC's H&S Procedures and SSHASP must specifically address the following issues as detailed in the model H&S plans:

• Site Control

- PC must control the project worksite to ensure that only authorized personnel are permitted access to the site. As part of this step, clearly outline how all personnel are briefed or trained on pertinent aspects of the SSHASP.

- Clearly designate who determines the establishment of project restricted zones and exclusion zones and the control for access to these zones.

- Develop procedures for handling and controlling SCs, MPA Team personnel and site visitors. Such procedures should permit authorized project personnel and site visitors limited access to the site and perform some oversight duties within exclusion zones, provided these individual are qualified to enter.

• Decontamination and/or Clean-up

- Clearly designate who is responsible for building and maintaining the decontamination setup and how field personnel clean-up will be accomplished. Include language that will permit other authorized project personnel and site visitors use of the decontamination setup and/or clean-up facilities when needed.

• Air Monitoring

- Devise and submit for approval an air monitoring plan of the work site. The plan should include:

Maryland Port Administration Page 7

1. Who is responsible for air monitoring both within the project work zones, exclusion zones and perimeter areas.

2. Address how air-monitoring results are communicated and made available to other authorized site personnel (e.g., site visitors or other contractor personnel who are not conducting air monitoring) so they can make appropriate H&S decisions.

• Emergency Response

- Description of emergency procedures must be provided; they shall integrate the emergency response procedures of other authorized project personnel so that there is no duplication in emergency response responsibilities, inconsistency in communication procedures, and/or contradictions or inefficiencies on how emergencies are handled.

• H&S Evaluation

- Clearly detail how the PC is going to evaluate the H&S performance of its workers and other organizations working on the project worksite. Included in this evaluation are the means and methods for making improvements and remedying deficiencies when necessary.

• Environmental

- Clearly detail how the PC is going to handle chromium contaminated soil and water, including storage and dust control. How releases of dust emissions or water to the environment will be controlled and mitigated must be included.

• S&H Hazard Analysis

- Each chromium-related job or task must be broken down by step, potential hazard to personnel and environment, tools to be used, and measures to be taken to eliminate or minimize hazard (to include PPE).

2.1.3 Secondary Contractors (SC)

Secondary Contractors are designated for a specific project or a specific phase of a chromium related project. The SC can consist of one or more or the following:

engineering and environmental consultants, construction contractors or subcontractors, transportation contractors and/or other support organizations for a designated project.

The SC is responsible for coordinating its own H&S activities with the designated PC for every project or task. A copy of the SC’s SSHASP will be submitted to the PC for review to ensure that the plans and procedures are coordinated and integrated with similar plans and procedures of the other organizations involved with a designated project. These submittals and any revisions must be reviewed and approved by PC prior to the onset of

Maryland Port Administration Page 8 the SC field activities. Copies of the SC’s SSHASP and its integration into the PC’s SSHASP will be provided to MPA. The MPA will review and accept/reject.

The SC may be covered under the PC’s SSHASP, but this must be described and accepted by the MPA.

At minimum, the SC's SSHASP must specifically address the following issues as detailed in the model H&S plans:

• Site Control

- Detail site control procedures used by the SC. If the SC is going to rely on zones, decontamination setup, air monitoring results, etc. of PC or other SC, then this should be stated in the plan.

- Clearly designate SC's role (if any) in determining when exclusion or restricted zones are established and who controls access to these zones

• Decontamination - Clearly designate how decontamination or personnel clean-up is going to be accomplished including the use of decontamination and clean-up facilities of other on site companies when needed.

• Air Monitoring – Provide air monitoring plan to PC who will forward to MPA.

If the company is relying on the air monitoring results of other organizations then the plan should specify this.

• Emergency Response - Description of emergency procedures must be provided;

they shall integrate the emergency response procedures of other authorized project personnel so that there is no duplication in emergency response responsibilities, inconsistency in communication procedures, and/or contradictions or inefficiencies on how emergencies are handled.

• Environmental - Clearly detail how the SC is going to handle potentially chromium contaminated soil and water, including storage and dust control. How releases of dust emissions or water to the environment will be controlled and mitigated must be included.

• H&S Hazard Analysis - Each chromium-related job or task must be broken down by step, potential hazard to personnel and environment, tools to be used, and measures to be taken to eliminate or minimize hazard (to include PPE).

2.1.4 MPA Employees Who Perform Work in COPR Area

MPA maintenance employees are required to perform utility repairs within the COPR area. They will work under the MPA HASP. In addition, a SSHASP will be developed and include the key components of the plan, as identified above for the PC in 2.1.2.

Maryland Port Administration Page 9

2.1.5 Visitors

All personnel onsite, who may be involved with chromium-related projects at DMT and are not part of the MPA team, PC or SC, are considered a Visitor as part of this H&S procedure. There are two levels of visitors:

• Escorted Visitors

• Restricted Visitors

Escorted Visitors - These are people that come to the MPA site and are authorized to be onsite at a potential chromium-related project for a specific limited purpose. They must have an escort at all times and are limited to site areas and operations that are classified as non-hazardous.

Restricted Visitors - These are people that come to the MPA site and are authorized to be at a chromium related project site for a specific purpose that may require being on-site for an extended period of time. They do not need an escort at all times if they are limited to site areas and operations that are classified as non-hazardous. They will be permitted to go to other potentially hazardous areas if they meet the H&S requirements of a Secondary Contractor (SC).

2.2 Applicable H&S Regulations and Criteria

Chapter 01 Hazardous Waste Management System: General Authority: Environment Article, Title 7, Subtitle 2, Annotated Code of Maryland

Maryland Occupational Safety and Health (MOSH) -

Occupational Health and Safety Administration (OSHA), Title 29

29 CFR 1926 Construction (including but not limited to)

• Subpart D, Section 65, Hazardous Waste Operations and Emergency Response

• Subpart Z, Section 1126, Occupational Exposure to Hexavalent Chromium

29 CFR 1910 General Industry (including but not limited to)

• Subpart H, Section 120, Hazardous Waste Operations and Emergency Response

• Subpart Z. Section 1026, Occupational Exposure to Hexavalent Chromium

3.0 GENERAL HAZARD ASSESSMENT

Chromium compounds are present in COPR, which is located both above and below the ground water table in areas of the site shown on the MPA COPR Fill Area site map.

Potential exposure to chromium is possible when the ground areas containing COPR are disturbed during construction activities. To minimize the potential for exposure, engineering controls and work practices have been put into place.

Maryland Port Administration Page 10

The COPR contains both trivalent (CrIII) and hexavalent chromium (CrVI). However, the primary chemical of concern is CrVI as the Occupational Safety and Health Administration (OSHA) permissible exposure limit (PEL) for CrVI is 5 micrograms/cubic meter of air (µg/m3). This is 100 times lower than the PEL for CrIII which is 500 µg/m3 for CrIII. Methods implemented to minimize exposure to CrVI are focused on controlling exposure to COPR dust and will provide appropriate protection for exposure to CrIII as well as CrVI.

3.1 Health Effects of CrVI

The primary means of exposure to CrVI is inhalation, ingestion, and skin contact with CrVI-containing dust. CrVI may be inhaled when dust containing CrVI is present in the air. Particles of CrVI-containing dust may contaminate hands, clothing, hair, food, and beverages. The MPA HASP and SSHASPs are designed to keep worker exposure well below the recognized OSHA PEL for CrVI. MOSH/OSHA has established a PEL for CrVI of 5 µg/m3 (8-hour, time-weighted average) with an action level of 2.5 µg/m3.

OSHA considers the primary health effects from workplace overexposure to CrVI as lung cancer, nasal irritation, nasal tissue ulcerations, and nasal septum perforations asthma, and damage to the skin. The information that OSHA used to define these health effects and establish the PEL was based on occupational health studies from many different industries including chromium ore mining and processing; chromium compound manufacturing and application (including pigments and paints); stainless steel production and welding; and chromic acid manufacturing and use. No operations handling COPR were included in the OSHA investigation. The type of and mechanism for exposure to CrVI through COPR may be very different than those studied by OSHA. Below is a summary of the health effects from overexposure to CrVI. The MPA HASP and SSHASPs are designed to keep worker exposure well below the OSHA PEL for CrVI.

• The scientific literature document that at very high exposure concentrations, CrVI may increase the risk of developing lung cancer. It is not anticipated that CrVI exposures at DMT will be at these high concentrations or at overexposure concentrations exceeding those considered acceptable by MOSH.

• Occupational overexposure to CrVI can lead to nasal tissue ulcerations and nasal septum perforations. Direct "hand to nose" contact in addition to inhalation of CrVI can contaminate the nasal passages. The nasal septum separates the nostrils and is composed of a thin strip of cartilage. The nostril tissue consists of an overlying mucous membrane known as the mucosa. The initial lesion after CrVI exposure is characterized by localized inflammation or a reddening of the affected mucosa, which can later lead to atrophy. This may progress to an ulceration of the mucosa layer upon continued overexposure. If exposure is discontinued, the ulcer progression will stop and a scar may form. If the tissue damage is sufficiently severe, it can result in a perforation of the nasal septum, sometimes referred to as a chrome hole. Individuals with nasal perforations may experience a range of signs

Maryland Port Administration Page 11 and symptoms, such as a whistling sound, bleeding, nasal discharge, and infection.

Some individuals may experience no noticeable effects.

• CrVI is considered to be an airway sensitizer. Airway sensitizers cause asthma through an immune response. The sensitizing agent initially causes production of specific antibodies that attach to cells in the airways. Subsequent exposure to the sensitizing agent, such as CrVI, can trigger an immune-mediated narrowing of the airways and onset of bronchial inflammation. All workers overexposed do not become sensitized to CrVI and the asthma only occurs in sensitized individuals.

OSHA has stated that it is not clear what occupational exposure levels of CrVI compounds lead to airway sensitization or the development of occupational asthma. Occupational asthma is considered "a disease characterized by variable airflow limitation and/or airway hyperresponsiveness due to causes and conditions attributable to a particular occupational environment and not to stimuli encountered outside the workplace. Asthma is a serious illness that can damage the lungs and in some cases be life threatening. The common symptoms associated with asthma include heavy coughing while exercising or when resting after exercising, shortness of breath, wheezing sound, and tightness of chest.

• Occupational overexposure to CrVI is a well-established cause of adverse health effects of the skin.