Attachment 4 Confined Space Policy-Tunnel Projects-Utility Distribution System-Standard Operating Procedure (June 2011).pdf

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Date:

Subject:

Purpose:

Applicability:

Effective Date:

Scope:

Supersedes:

We is

Order of the Architect of the Capitol

June 2011

Architect of the Capitol, Capitol Power Plant (CPP) Utility Distribution System (UDS) Standard Operating Procedure (SOP).

The purpose of this SOP is to provide guidance for all persons requiring access to the utility distribution system (including tunnels and vaults) managed by the CPP.

This SOP applies to all UDS Entrants who require access to the CPP UDS tunnels and vaults.

Immediately

All utility distribution system tunnels and vaults in the Capitol Complex managed by the CPP.

None

Director of tilities and Power Plant U.S. Capitol Power Plant

CPP UDS SOP for the Architect of the Capitol

FOR OFFICIAL USE ONLY

Public Law 108-447 Security Review Pending

Do Not Disseminate As Report May Contain Security Sensitive Information

Architect of the Capitol

Capitol Power Plant Utility Distribution System Standard Operating Procedure

Table of Contents

Page

A. Definitions 4

B. Introduction 5

C. Tunnel Access Authorization Process 6

D. Training for Personnel Requiring Access to the UDS 7

E. Tunnel Entry Procedures 8

F. Roles and Responsibilities 10

G. Access and Egress Constraints and Requirements 13

H. Job Hazard Analysis 14

I. Off-Hour Entry Procedures 14

J. Recordkeeping 15

K. Guidelines for Other Potential Hazards 16

Attachment A: Pre- and Post-Entry Signature Page 21

Attachment B: Summary of Procedures for Access Authorization into the CPP UDS (flowchart) 23

Attachment C: Summary of CPP UDS Entry Procedures (flow chart) 25

Attachment D: U.S. Capitol Power Plant Confined Space Entry Permit 27

Attachment E: CPP UDS Exit Decontamination Procedures 29

Attachment F: CPP UDS Personal Heat Stress Monitoring Form 31

Attachment G: Attendant Checklist 35

Attachment H: Authorized Entrant Checklist 37

CPP UDS SOP for the Architect of the Capitol FOR OFFICIAL USE ONLY Public Law 108-447 Security Review Pending

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Utility Distribution System Standard Operating Procedure Table of Contents (cont.)

Attachment I: Confined Space Entry Supervisor Checklist 39

Attachment J: Utility Tunnel Discrepancy Reporting Form 41

Attachment K: Map of Assembly Areas 43

Attachment L: Security Bar Access Instructions 44

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A. Definitions

“Acceptable entry conditions" means the conditions that must exist in a permit space to allow entry and to ensure that employees involved with a permit-required confined space entry can safely enter into and work within the space.

“Access Authorization” means approval granted by the Capitol Power Plant for an individual to enter the Utility Distribution System tunnels and vaults. Each individual shall be required to provide necessary documentation to be granted Authorization. There are two levels of Access Authorization: “Escort Required” and “Unescorted.”

"Attendant" means an individual stationed outside one or more permit spaces who monitors the Authorized Entrants and who performs all Attendant's duties assigned in the employer's permit space program.

"Authorized Entrant" means an employee who is authorized by the Capitol Power Plant to enter a permit-required confined space.

“Confined space" means a space that:

(1) Is large enough and so configured that an employee can bodily enter and perform assigned work; and

(2) Has limited or restricted means for entry or exit; and

(3) Is not designed for continuous employee occupancy.

“Entry" means the action by which a person passes through an opening into a permit-required confined space. Entry includes ensuing work activities in that space and is considered to have occurred as soon as any part of the entrant's body breaks the plane of an opening into the space.

“Entry Authorization” means approval granted by the Capitol Power Plant for each entry into the Utility Distribution System. Entry will not be allowed without prior Access Authorization.

“Escort Required Authorized Entrant” means an Individual authorized by the Capitol Power Plant to enter into the Utility Distribution System tunnels and vaults but requires an escort to do so.

"Confined Space Entry Supervisor” means the person responsible for determining if acceptable entry conditions are present at a permit space where entry is planned, for authorizing entry and overseeing entry operations and for terminating entry as required in this Utility Distribution System Standard Operating Procedure.

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"Permit-required confined space (permit space)" means a space that in addition to meeting the definition of confined space as listed above, the confined space also has one or more of the following characteristics:

(1) Contains or has a potential to contain a hazardous atmosphere;

(2) Contains a material that has the potential for engulfing an Entrant;

(3) Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section; or

(4) Contains any other recognized serious safety or health hazard.

"Permit system" means the employer's written procedure for preparing and issuing permits for entry and for returning the permit space to service following termination of entry.

"Retrieval system" means the equipment (including a retrieval line, chest or full-body harness, wristlets, if appropriate, and a lifting device or anchor) used for non-entry rescue of persons from permit spaces.

“Tunnel” means an underground passage.

“Utility Distribution System (UDS)” means the series of tunnels and vaults used to distribute utilities from the Capitol Power Plant to the buildings comprising the Capitol Complex. The UDS is under the jurisdiction of the Capitol Power Plant.

“Unescorted Authorized Entrant” means an individual authorized by the Capitol Power Plant to enter into the Utility Distribution System tunnels and vaults without requiring an escort.

“Unescorted” Authorized Entrants can serve as escorts for “Escort Required” Authorized Entrants.

“Vault” means an underground chamber.

B. Introduction

1. Purpose:

The Capitol Power Plant (CPP) Utility Distribution System (UDS) Standard Operating Procedure (SOP) was developed to provide instructions for safe entry as well as to define specific requirements unique to the UDS. Additional specific requirements may exist and any Federal, State and Local regulations that are more stringent, as well as all Architect of the Capitol (AOC) policies and procedures, must be followed.

2. Background:

The CPP UDS is part of the CPP, which is a jurisdiction of the AOC. The CPP UDS is comprised of eight interconnected tunnels that extend several miles throughout Capitol Hill. The primary purpose of the UDS is to supply steam and chilled water to 17 government buildings and 2 underground garages located on Capitol Hill. The 8 tunnels that this document applies to are B, BG, CVC, G, O, R, V and Y.

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3. Objective:

The objective of the CPP UDS SOP is to list the requirements for safely entering the CPP UDS. Detail for the following items is provided in the SOP:

A. Security clearance requirements.

B. Pre-entry, entry and post-entry requirements and procedures.

C. Definitions of roles and responsibilities.

D. Guidance for recognizing and addressing potential hazards that exist in the UDS.

4. Applicability:

The CPP UDS SOP applies to all personnel who are associated with a CPP UDS entry. Non-AOC personnel must meet the requirements of the CPP UDS SOP at a minimum; however:

A. Contactors may provide and follow their own AOC-approved Safety and Health Plan. All plans must be approved by the Tunnel Safety Specialist (TSS).

B. U.S. Capitol Police and D.C. Fire and Emergency Medical Services (EMS) may use their own health and safety plans that have been accepted by CPP UDS management.

C. Tunnel Access Authorization Process

1. Security Badging Process:

Prior to entering the tunnels, all Attendants, Authorized Entrants and Confined Space Supervisors must complete the AOC security clearance and badging process.

Personnel requiring entry into the tunnels must submit the following:

A. Contactors must complete a “CPP Power Plant Site ID Request” form specific for Contactors.

B. Contractors must complete a “Request for Check of Criminal History Records.”

C. All personnel requiring access to the UDS must have security badges to be granted access. Two exceptions to this rule are:

a. The entrant will need access to the UDS once and not again.

b. An emergency entry is required for an entrant and there is insufficient time to receive a badge.

D. A request for an escort must be provided to the UDS Supervisor or designated representative and the escort a minimum of 48 hours prior to the time of entry.

E. Allow at least 4 weeks to complete the security badging process.

2. Required Entrant Submittals (Prior to Entry):

All Attendants, Authorized Entrants and Confined Space Supervisors must submit training records as described in Section D to the TSS prior to entering the UDS.

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3. Provisions for Unescorted Entry The TSS determines if Authorized Entrants require an escort when entering the UDS.

Entrants meeting the other requirements of the CPP UDS SOP may be granted unescorted access with the following minimum requirements:

A. At least one previous escorted entry into each tunnel to which the entrant requires access.

B. A thorough familiarity with the requirements of the CPP UDS SOP, Asbestos Operation and Maintenance (O&M) plan, Security Bar Access Instructions (Attachment L) and the Emergency Action and Response Plan (EARP).

C. A thorough familiarity with operations of the CPP UDS such that the Authorized Entrant and Attendant are capable of distinguishing between “routine operation” and emergency situations.

D. Approval of the TSS.

D. Training for Personnel Requiring Access to the UDS

Documentation or certification of training must be provided to the TSS prior to initial entry into the UDS. It is the responsibility of the Confined Space Entry Supervisor to ensure that all training associated with tunnel entry is current and to inform the TSS or designee of all training updates. Contractors are required to keep all current training certifications onsite for all Authorized Entrants, Attendants and Confined Space Supervisors at all times. Authorized Entrants, Attendants and Confined Space Supervisors training requirements are listed below:

1. Permit-Required Confined Space per 29 Code of Federal Regulations (CFR) 1910.146

A. Annual refresher training is not required; however, additional training is required:

a. When there is a change of assigned duties

b. When a new hazard is identified in the UDS

2. Asbestos Training per 29 CFR 1910.1001 and 29 CFR 1926.1101

A. Minimum 2-hour awareness B. Annual refresher

3. Heat Stress Prevention Training per AOC Heat Stress Prevention Program for

Work Performed in the CPP UDS A. Initial Training

4. Respiratory Protection Program per 29 CFR 1910.134, if exposure to an airborne hazard may exceed the Permissible Exposure Limit (PEL) A. Initial training B. Annual fit testing and physical medical evaluation C. Annual refresher

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5. Personal Protective Equipment (PPE) Selection and Usage per 29 CFR 1910.132 and Training in Proper Use of PPE per 29 CFR 1926.21 (required but not provided to the TSS)

A. Steel Toe Shoes B. Hard Hats C. Safety Glasses D. Full Body Harness E. Flashlight F. Other work activity-specific PPE

6. CPP UDS Emergency Action and Response Plan (required but not provided to the TSS) A. Initial training B. Annual training C. Contractors must provide their own training D. Review of the EARP is provided during the Safety Brief E. Must understand, be familiar with and abide by plan contents

7. CPP UDS SOP and CPP Asbestos O&M Plan (required but not provided to the

TSS)

A. Review plan processes prior to entry B. Must understand, be familiar with and abide by plan contents

E. Tunnel Entry Procedures

The following procedures must be followed for each entry into the UDS by Attendants, Authorized Entrants and Confined Space Supervisors:

1. Pre-Entry A. The TSS must provide Entry and Access authorization to the Attendant, Authorized Entrants and Confined Space Entry Supervisor.

B. The Confined Space Supervisor must attend the Safety Brief:

a. The Confined Space Supervisor is responsible for informing the Authorized Entrants and Attendant of the contents of the Safety Brief.

b. The following documentation will be provided to the Confined Space Supervisor at the Safety Brief:

I. Pre- and Post-Entry Signature Page (Attachment A) II. U.S. Capitol Power Plant Confined Space Entry Permit

(Attachment D). Contractors may use an Occupational Safety and Health Administration (OSHA) compliant permit-required confined space permit.

III. AOC Exit Decontamination Procedures (Attachment E) IV. UDS Personal Heat Stress Monitoring Form (Attachment F) V. Table of Egress Points and Correlating Locations

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c. The Confined Space Supervisor shall ensure that the Emergency Action and Response Guidance pamphlet is available for the Attendant.

d. The Confined Space Supervisor must provide the following information in the entry log after receiving the Safety Brief:

I. Date II. Estimated Time of Entry III. Attendant Location IV. Attendant Name V. Attendant Phone Number VI. Number of Entrants VII. Primary Assembly Area Location

2. Entry

A. The Confined Space Entry Supervisor shall ensure the following entry requirements are met immediately prior to and during entry in the UDS:

a. Ensure that every entry team member is authorized to enter the UDS.

b. Brief the Attendant and Authorized Entrants on the information provided at the Safety Brief including a review of the anticipated hazards associated with the entry, emergency egress locations and assembly areas in the event of an emergency.

c. Record the time that entry is initiated for each Authorized Entrant on the Pre- and Post-Entry Signature Page (Attachment A).

d. Ensure, at a minimum, two Authorized Entrants will be entering the UDS.

e. The Attendant completes the U.S. Capitol Power Plant Confined Space

Entry Permit (Attachment D):

I. Verify PPE and other equipment prior to entry.

II. Ensure acceptable entry conditions are present.

III. Verify communication system:

i. A radio check must be performed prior to entering the CPP UDS and every 30 minutes.

ii. If radio contact is lost during an entry, Authorized Entrants must immediately exit the tunnel.

iii. If an entry must take place and radio communication is not functioning, then a suitable system approved by the TSS may be used.

IV. Take stratified atmospheric readings prior to entry.

V. Continuously monitor and record atmospheric readings every

30 minutes.

VI. Take and record environmental temperature readings (indoor wet bulb globe temperature [WBGT], humidity and ambient temperature) every 30 minutes.

f. Review temperature readings relative to Table 6.2 (Heart Rate Recovery Criteria) of the Heat Stress Prevention Program.

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g. Ensure that an egress point is available within 300 feet of all entrants at all times.

h. Entrants don the required PPE as described in the Daily Safety Brief.

i. The Utility Tunnel Discrepancy Reporting Form found in Attachment J shall be used to report any malfunctions or disruptions from normal operations.

All discrepancies in the UDS shall be reported to the TSS.

3. Post-Entry

A. The Attendant will ensure all Authorized Entrants have exited the tunnel and record the exact time of exit on Pre- and Post-Entry Signature Page (Attachment A).

B. Any required decontamination procedures will be followed for all tunnels under asbestos restrictions as noted in the Safety Brief (See Section K.1 for more details regarding decontamination procedures). Decontamination procedures will also be followed for other types of hazardous work practices if deemed necessary.

C. Heat stress monitoring data (pulse and body temperature) will be taken and recorded in accordance with the OSHA Technical Manual on Heat Stress Prevention and the AOC Heat Stress Prevention Program. Adjust work/rest cycles according to Attachments B and C in the Heat Stress Prevention Program.

D. The Confined Space Entry Supervisor will ensure that the completed U.S. CPP Confined Space Entry Permit and associated paperwork is submitted to the UDS Shop or designee at the end of each shift.

F. Roles and Responsibilities

1. Attendant A. Maintains communication with Authorized Entrants:

a. Performs radio checks every 30 minutes.

b. Maintains one functional radio.

c. Ensures radios are compatible with leaky cable system.

B. Signs Pre- and Post-Entry Signature Page (Attachment A).

C. Completes U.S. CPP Confined Space Entry Permit (Attachment D):

a. Records atmospheric and temperature readings every 30 minutes.

b. Records heat stress readings (pulse and ear canal temperature).

D. Stays at the Entry Point Location:

a. Remains outside the permit-required confined space at all times.

b. Determines when to initiate an evacuation and rescue procedure.

c. Continuously maintains an accurate count of all Authorized Entrants.

E. Calls CPP Operations Control Room and informs of entry and exit during off-hours.

F. Completes training requirement as described in Section D.

G. Reports issues or safety concerns to the TSS using the Utility Tunnel

Discrepancy Reporting Form (Attachment J).

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H. Refer to the Attendant Checklist (Attachment G, optional form) for guidance of responsibilities.

I. Provides initial coordination per requirements of the Emergency Action Response Plan with U.S. Capitol Police and D.C. Fire and Emergency Medical Services Department and contacts the CPP Operations Control Room in the event of an emergency.

2. Authorized Entrant A. Follows confined space entry permit requirements:

a. Maintains communication with the Attendant:

I. Performs a radio check every 30 minutes.

b. Takes atmospheric and temperature reading every 30 minutes.

c. Dons appropriate PPE.

d. Operates direct gas reading and temperature monitors.

e. Provides ear canal temperature and pulse when exiting the tunnel.

f. Dons personal air sampler (if deemed necessary).

B. Signs Pre- and Post-Entry Signature Page (Attachment A).

C. Remains within eyesight of team entrants.

D. Completes training requirement as described in Section D.

E. Reports issues or safety concerns to the TSS using the Utility Tunnel

Discrepancy Reporting Form (Attachment J).

F. Refer to the Authorized Entrant Checklist (Attachment H, optional form) for guidance of responsibilities.

3. Confined Space Entry Supervisor A. Ensures that all entry team members are authorized to enter the UDS.

B. Attends the Safety Brief.

a. Ensures the Attendant and Authorized Entrants receive the Safety Brief C. Signs Pre- and Post-Entry Signature Page (Attachment A).

D. Reviews U.S. CPP Confined Space Entry Permit (Attachment D) for completeness and accuracy:

a. Ensures that the Pre- and Post-Entry Signature Page (Attachment A) is given to the TSS or designee at the end of each shift.

b. Ensures personal air monitoring is performed when required.

c. Verifies acceptable entry conditions are present.

d. Reviews WBGT readings to determine extreme heat environment conditions.

e. Adjusts work/rest cycles according to the AOC Heat Stress Prevention

Program.

E. Verifies direct gas reading gas monitor calibration is current.

F. Verifies that an exit-able egress point is available within 300 feet for each entry.

G. Reports unauthorized individuals who attempt to enter the UDS to the TSS.

H. Completes training requirements as described in Section D.

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I. Reports issues or safety concerns to the TSS using the Utility Tunnel Discrepancy Reporting Form (Attachment J).

J. Refer to the Confined Space Entry Supervisor Checklist (Attachment G, optional form) for guidance of responsibilities.

4. CPP Operations Control Room

A. Logs in entry information provided by the Attendant or UDS during off-hours:

a. Date

b. Time of Entry

c. Time of Exit

d. Attendant’s name

e. Attendant’s phone number

f. Entry location

B. Reports issues or safety concerns to the TSS using the Utility Tunnel

5. Director of the Capitol Power Plant A. Approves and signs any revisions and updates made to the CPP UDS SOP.

B. Appoints AOC staff to ensure compliance with the CPP UDS SOP.

C. Reports issues or safety concerns to the TSS using the Utility Tunnel

6. Tunnel Safety Specialist A. Approves and signs any revisions and updates made to the CPP UDS SOP.

B. Assesses and approves Authorized Entrants, Attendants and Confined Space

Entry Supervisors qualifications.

C. Periodically reviews the Confined Space Entry Permits.

D. Reviews and updates Permit Space Program annually.

E. Ensures Daily Briefs are available for all entries.

a. Verifies that all Confined Space Entry Supervisors have attended the Daily Brief.

F. Compiles issues or safety concerns as reported by UDS personnel. The TSS develops and implements corrective actions if warranted.

G. Oversees UDS Job Hazard Analysis program.

H. Ensures compliance with the CPP UDS SOP.

I. Reviews CPP UDS SOP annually.

7. UDS Supervisor

A. Oversees recordkeeping procedures (see Section J).

B. Ensures CPP Operations Control Room is informed of off-hour entries (See

Section I).

C. Oversees escort procedures (See Section C).

D. Overall responsibilities for operations of UDS.

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8. U.S. Capitol Police

A. Unlocks and secures locked egress points for entries (see Section G.3 and Attachment L for more detail).

B. Incident commander during an emergency response.

G. Access and Egress Constraints and Requirements

1. Signage A. Placed in the UDS to reinforce safety requirements and provide direction.

a. Exit signs provide direction to the closest exit by following the lit side of exit signs to an exit. Ensure exits are usable before entry.

b. When certain sections of the tunnel are closed, “Tunnel Closed” signs will be posted.

2. Manhole Entry Requirements

The O and BG tunnels contain vaults only accessible through manholes. Other tunnels may also be entered through manholes if deemed necessary. The following requirements shall be followed when entering a manhole into the UDS:

A. The Confined Space Entry Supervisor will be responsible for contacting the U.S.

Capitol Police prior to a manhole entry.

B. Tripods with retrieval cable must be placed immediately above the manhole:

a. A minimum of two entrants must enter the manhole unless the manhole is too small for two bodies.

I. In the event that the space is only large enough for one entrant, the entrant must stay hooked to the retrieval cable throughout the entry.

C. Manholes that impact traffic shall be barricaded sufficiently to divert and alert approaching traffic.

D. Manholes that do not impact traffic shall be barricaded sufficiently to ensure that pedestrians do not enter the work area.

E. Free-standing water shall be pumped out of the manholes prior to entry.

F. Stratified direct reading gas meter data must be collected and recorded on the

Confined Space Entry Permit prior to entering the manholes.

3. Locked Egress Points:

The UDS contains various doors leading from the tunnels into occupied buildings which may serve as egress points for the UDS. These doors must remain locked or guarded at all times as a security measure. In order to maintain 300 feet maximum travel distance from any given egress point, these locked doors may have to be unlocked to serve as egress points. Security Bar Access Instructions (Attachment L) in this SOP contain detailed instructions for identifying and entering the locked egress points.

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4. Special Instructions Prior to Entering and Exiting GD 13

A. The Office of the Supreme Court Facility Manager must be contacted at

(202) 512-1320 prior to entering or exiting the G tunnel through GD-13.

H. Job Hazard Analysis

Job hazard analysis (JHA) reduces the risk of performing certain tasks by breaking down the steps of the task and determining if there are any hazards associated with those tasks.

When hazards are found, the JHA process provides the opportunity to develop techniques to reduce or eliminate the identified hazard. The following tasks require that a JHA is completed or reviewed prior to entering the CPP UDS:

1. Use of electric tools and portable electrical equipment

2. When performing welding, cutting, brazing and hotworks

3. When working with hot water and steam

4. When working with concrete that has the potential to create silica dust

5. When work may impact or damage asbestos-containing material (for example, as a result of sanding, painting or usage of solvents)

6. When the UDS Supervisor, the Confined Space Entry Supervisor or TSS determines that a JHA is required

A JHA will be completed by each organization for the work that they will be performing in the UDS. The JHA will be reviewed and approved by the health and safety officer of the organization developing the JHA, after which the JHA will be reviewed by the TSS.

I. Off-Hour Entry Procedures

Off-hours work is often necessary in the CPP UDS. The Capitol Power Plant must verify the safe egress of Authorized Entrants in the CPP UDS in the event of an emergency response.

Details of the off-hours procedures can be found in Appendix M of the EARP. Note: Off-hours are Monday through Thursday from 3:00 pm to 6:00 am, and from 3:00 pm on Friday until 6:00 am on Monday. The following procedures are required for off-hour entry:

1. UDS Supervisor Responsibilities

A. Prior to anticipated entry, the UDS Supervisor or designee e-mails CPP Operations with the following information:

a. Names of Attendants

b. Name of AOC jurisdiction or name of contractor

c. Work location

d. Estimated time and date of entry

e. Estimated duration of work

f. Estimated time and date of exit

B. Updates UDS log book if off-hour work will continue into regular work hours.

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2. Attendant Responsibilities

A. At the time of entry, the Attendant cell phones CPP Operations Control Room at

(202) 225-4180 and provides the following information:

a. Name

b. Number of Authorized Entrants

c. Time of entry

d. Estimated time of exit

e. When exiting CPP UDS or if work will continue into regular work hours

3. CPP Operations Control Room Responsibilities

A. Logs the following information provided by the TSS and the Attendant in the off-hours log-book found in the CPP Operations Control Room:

a. Date

b. Name of Attendant

c. Number of Authorized Entrants*

d. Entry Location

e. Time of Entry

f. Time of Exit or if work continues into normal working hours

* The names of the Authorized Entrants are located on the Pre- and Post-Entry Signature Page (Attachment A).

J. Recordkeeping

The UDS Supervisor is responsible for maintaining the following records, or ensuring that they are maintained:

1. Training Records

A. Only current records are maintained by the UDS Supervisor for AOC employees.

B. The TSS will review the required documentation prior to initial tunnel entry authorization.

C. It is the responsibility of the Contracting Officer’s Technical Representative

(COTR) for each project to ensure that all entry team members working on their projects maintain current certifications.

D. All contractors are required to have current training records for each individual entering the CPP UDS available for review on-site at each entry location.

E. The TSS has the authority to audit training records at on-site entry locations.

F. AOC training records will be maintained for one year past the final date of employment per 29 CFR 1910.1001(m)(4) and 1926.1101(n)(4).

2. Exposure Assessment Records (maintained for 30 years per 29 CFR 1910.1020 when assessments have been performed)

A. Environmental monitoring results (if collected) including:

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a. Sampling results

b. Collection methodology

c. A description of the analytical/mathematical methods

d. Summary of pertinent background information

B. Biological monitoring results (if collected)

3. Daily Entry Documentation A. Pre- and Post-Entry Signature Page B. Permit-Required Confined Space Permit

a. Cancelled Confined Space Permits generated until December 13, 2010, will be maintained for 30 years past the final date of employment since these are integral to the exposure assessment record retention requirements of

29 CFR 1910.1020.

b. Canceled Confined Space Permits after December 13, 2010, are maintained for one year.

C. Heat Stress Documentation D. Asbestos exposure monitoring records will be maintained for 30 years from the last date of employment.

4. Medical Records A. Are maintained by the Office of the Attending Physician for AOC employees for

30 years from the last date of employment.

B. Non-AOC employee medical records are the responsibility of the employer.

C. Only current records are maintained by the UDS Supervisor for AOC employees.

D. The TSS will review medical records prior to initial tunnel entry authorization.

E. It is the responsibility of the COTR for each project to ensure that all entry team members working on their projects maintain current medical records.

F. All contractors are required to have current medical records for each individual entering the CPP UDS available for review on-site at each entry location.

G. The TSS has the authority to audit medical records at on-site entry locations.

5. Job Hazard Analysis A. JHA database of the AOC contains records of JHAs for the UDS. See Section H.

6. Hot Works Permits A. Shall be maintained for one year.

K. Guidelines for Other Potential Hazards

1. Asbestos

A. Asbestos containing materials are present in the UDS. Any activities that may disturb ACM must follow the CPP Asbestos O&M Plan. The CPP Asbestos O&M Plan addresses the general asbestos requirements for the UDS and shall be referred to for routine asbestos procedures. Safe Work Practices as defined in

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Appendix F of the Asbestos O&M Plan shall be followed if ACM may be disturbed in the UDS. Familiarity and compliance on the CPP Asbestos O&M Plan is a requirement for entry into the CPP UDS, as described in Section D.

B. Tunnels currently considered to have the potential for asbestos contamination are detailed in the Safety Brief. The following procedures must be used for entry into designated areas of the CPP UDS:

a. A minimum of 2-hour asbestos awareness training per 29 CFR 1910.1001 and 29 CFR 1926.1101 as applicable must be completed prior to entering the UDS.

b. Respiratory protection and PPE as listed on the Safety Brief.

C. The Confined Space Entry Supervisor is responsible for ensuring all decontamination procedures (Attachment E) are carried out correctly.

2. Crystalline Silica The Confined Space Entry Supervisor shall ensure the following procedures are followed when working with crystalline silica in the CPP UDS:

A. The PPE listed below in addition to other required PPE as defined in the CPP

UDS SOP must be donned when working with crystalline silica in the UDS:

a. A minimum of a half-face respirator with P100 cartridge. Increased respiratory protection may be required. Refer to Section XI (Program Procedures) Paragraph B #3 (Respiratory Protection) of the OSHA National Emphasis Program for crystalline silica for additional information.

b. Disposable cover-alls with hoods and boot coverings.

c. Hearing protection (if a noise hazard is present).

B. Workers that are exposed to silica at or above the PEL and are required to wear silica-related PPE must decontaminate upon exit from the work area, following requirements as determined by the competent industrial hygienist responsible for the activity.

C. Baseline air sampling shall be performed:

a. Negative Exposure Assessment (NEA) shall be developed for the different tasks performed.

b. JHAs shall be used to assist in developing the NEA.

D. Work areas will be isolated if work methods will cause crystalline silica to be airborne. Isolation methods may include polyethylene sheeting barriers or other feasible methods and must be approved by the TSS.

E. If abrasive blasting is to take place, the operation must meet OSHA requirements in 29 CFR 1926.57(f) Abrasive Blasting. Air sampling is required during abrasive blasting. The placement of isolation barriers and the donning of additional PPE may be required. Other safety requirements listed is Section XI (Program Procedures) Paragraph B #7 (Abrasive Blasting) of OSHA’s National Emphasis Program for crystalline silica will be reviewed and followed as applicable.

F. Control and reduce airborne crystalline silica dust by using high-efficiency particulate air (HEPA) filtration devices and/or applying wet methods when

CPP UDS SOP for the Architect of the Capitol FOR OFFICIAL USE ONLY Public Law 108-447 Security Review Pending

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G. A JHA must be performed prior to disturbing materials that contain or are suspected of containing crystalline silica, including concrete, brick, crushed stone and ceramics. The JHA must be submitted to the TSS.

Additional information on crystalline silica can be found in OSHA’s National Emphasis Program (NEP-Crystalline Silica Directive Number: CPL 03-00-007 January 24, 2008) and the OSHA standards found in 29 CFR 1910.1000 and 29 CFR 1926.55.

3. Lead The following requirements pertain to lead-based paint for the CPP UDS:

A. All painted surfaces in the UDS are considered to be lead-based paint.

B. All activities that disturb lead-based paint must comply with the CPP Lead

Compliance Program.

C. Workers that are exposed to lead at or above the PEL and are required to wear lead-related PPE must decontaminate upon exit from the work area, following requirements as determined by the competent industrial hygienist responsible for the activity.

D. The TSS must be informed prior to disturbing lead-based paint.

4. Welding, Cutting, Brazing and Hotworks The Confined Space Entry Supervisor shall ensure the following procedures are followed when welding, cutting, brazing and hotworks takes place in the UDS:

A. The TSS must be notified prior to any welding, cutting, brazing and hotworks taking place.

a. A hotwork permit must be completed prior to starting work.

b. Copies of completed hotwork permits must be submitted to the TSS upon completion of work.

B. The CPP SOP 9-3 for Welding, Cutting, Brazing and Hotworks (dated May 20, 2008) must be followed when performing work in the UDS.

C. Gas cylinders greater than 20 cubic feet will not be brought inside the tunnel.

D. Gas cylinders shall not be stored in the UDS.

E. A Job Hazard Analysis must be completed and submitted to the TSS.

5. Lighting:

A. Task-specific lighting may be necessary to augment the permanently installed lighting.

6. Slip, Trip and Obstruction Hazards:

A. The floors in the tunnels often are wet, which may create slippery conditions. In addition, protruding pipes, valves, low ceilings and narrow passageways also create trip, head or other bodily hazards. Entrants shall use caution while walking or working in the UDS.

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7. Falling Concrete:

If work tasks to be performed could cause loose concrete to fall, or if damaged or loose concrete is observed in the work area, the following procedures must take place:

A. The Tunnel Safety Specialist shall be notified of any observed concrete hazards:

a. The TSS will in turn notify the CPP Director or Deputy Director, who will determine what actions must be taken to correct the loose concrete problem.

B. A pre-work structure inspection performed by a structural engineer or trained designated representative may be required.

a. If necessary, loose concrete shall be removed or stabilized prior to the start of the proposed work task.

8. Pinchpoints:

Entrants shall not crawl under or through steam lines to access other portions of the tunnel at the following locations:

A. V tunnel at Station 14+40 (VD-6)

9. Electric Tools and Portable Electrical Equipment:

The Confined Space Entry Supervisor shall ensure the procedures listed below are followed when using portable electric equipment in the UDS:

A. A JHA shall be completed prior to using electric tools and portable electrical equipment.

B. Ground Fault Circuit Interrupters shall be used on all portable electrical devices, tools and equipment.

C. Electrical tools and equipment shall be inspected for damage prior to each use.

D. Immediately discontinue use of electric tools or equipment if atmospheric readings indicate out of range gas parameters found on the CPP UDS Confined Space Entry Permit.

E. Electric cords must be out of the way of the main path to prevent trip hazards and damage to cords.

F. Tools and equipment electric cords must either be equipped with grounding conductor (three prongs) or double insulated.

G. Multi-cord power strips must have over-current protection.

Detailed information can be found in the AOC Electrical Safety Policy, #10-10 February 27, 2002 and AOC Hands and Portable Power Tools Safety Policy #10-13 February 19, 2002.

10. Hot Water and Steam

The Confined Space Supervisor shall ensure the procedures listed in this section are followed when working with hot water and steam in the UDS:

A. Lockout/tagout procedure shall be followed per the AOC policy #10-9 December 18, 2001.

B. A JHA must be performed prior to conducting work on condensate and steam piping and associated equipment.

CPP UDS SOP for the Architect of the Capitol FOR OFFICIAL USE ONLY Public Law 108-447 Security Review Pending

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Do Not Disseminate As Report May Page 20 of 44 Contain Security Sensitive Information

C. Ensure that thermal insulation has been determined to be non asbestos-containing prior to working on any insulated materials. Asbestos-containing thermal systems insulation or any other asbestos-containing materials that may be disturbed during work activities must be abated prior to work activities.

D. Report steam or hot water leaks to the TSS.

11. Access Underneath Catwalk in Dip Area of the R Tunnel The Confined Space Supervisor shall ensure the procedures listed in this section are followed when walking underneath the catwalk in the dip area of the R tunnel.

A. The area beneath the catwalk will be taped off to prevent entry underneath the catwalk when work is taking place within this section of the R-tunnel, and the catwalk is in use to assist in work activities.

B. An Assigned Entrant will be stationed at each end of the catwalk on ground level to ensure that no one passes underneath the catwalk area while overhead work is occurring. Each Assigned Entrant will be in contact with an Entrant performing work on top of the catwalk by radio.

C. In the event that Entrants need to pass underneath the catwalk, the Assigned Entrant stationed at one end of the catwalk will contact the Entrant at the top of the catwalk to halt work. Work on the catwalk will continue when the Assigned Entrant at the other end of the catwalk signals via radio that the person or group has passed underneath the catwalk and the overhead hazard has been cleared.

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Attachment A:

Pre- and Post-Entry Signature Page

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Pre- and Post-Entry Signature Page

By signing I acknowledge that I have reviewed and agree to follow all procedures as described in the CPP UDS SOP. Furthermore, I have attended or been briefed on the pre-entry Safety Briefing, have reviewed and agree to comply with the U.S. Capitol Power Plant Confined Space Entry Permit (Attachment D) and any applicable CPP UDS requirements (Attachment E). Any questions or violations shall be reported to the TSS at 202-226-7083. Note: Authorized Entrants must sign in and out for every entry and exit including breaks.

Print Sign

Confined Space Supervisor:

Attendant:

Print Sign Time-in Time-out

Authorized Entrant:

Authorized Entrant:

Authorized Entrant:

Authorized Entrant:

Authorized Entrant:

Authorized Entrant:

Authorized Entrant:

Authorized Entrant:

Authorized Entrant:

Authorized Entrant:

Authorized Entrant:

Authorized Entrant:

Authorized Entrant:

Authorized Entrant:

Make additional copies as necessary

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Attachment B:

Summary of Procedures for Access Authorization into the CPP UDS

Do Not Disseminate As Report May Page 24 of 44 Contain Security Sensitive Information

UDS Supervisor or designee maintains records of approved AOC Authorized

Entrants

UDS Supervisor or designee maintains records of approved AOC Authorized

Entrants

Capitol Power Plant Tunnel Safety Specialist reviews training records

Capitol Power Plant Tunnel Safety Specialist reviews training records

Is access approved by the Tunnel Safety Specialist?

Is access approved by the Tunnel Safety Specialist?

Superintendent or Contracting Representative or Project Manager submits training records to the Capitol Power Plant Tunnel

Safety Specialist1

Yes

No

Capitol Power Plant Tunnel Safety Specialist informs

Superintendent or Contracting Representative or Project Manager of approved Authorized

Entrants

Access Denied

Process

KEY

Documentation

Decision

Terminator

1All personnel requesting access to the UDS must be approved and have a current valid badge issued by the House Sergeant at Arms.

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Summary of Procedures for Access Authorization into the CPP UDS

Superintendent or Contracting Representative or Project Manager submits training records to the Capitol Power Plant Tunnel

Safety Specialist1

Yes

No

Process

KEY

Documentation

Capitol Power Plant Tunnel Safety Specialist informs

Superintendent or Contracting Representative or Project Manager of approved Authorized

Entrants

Access Denied

Decision

Terminator

No

1All personnel requesting access to the UDS must be approved and have a current valid badge issued by the House Sergeant at Arms.

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Attachment C:

Summary of CPP UDS Entry Procedures

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Summary of CPP UDS Entry Procedures

Attendant(s) and Authorized Entrants(s) complete Confined Space Entry Permit

Approved Authorized Entrants need to enter the tunnels

KEY

Authorized Entrants follow CPP UDS

SOP entry requirements

No

Confined Space Entry Supervisor ensures the UDS Supervisor or designee receives a completed copy of the Confined Space Entry Permit

Process

Documentation

Has the Confined Space Entry Supervisor attended the Safety

Brief and in turn briefed the Attendant(s) and Authorized

Entrant(s)?

Attendant(s) and Authorized Entrants are denied tunnel access into the tunnels

Decision

Terminator

UDS Supervisor or designee maintains records of the Confined

Space Entry Permit

Yes

Is the entry team composed of at least two (2) Authorized Entrants?

Permission to enter the tunnels is denied

Confined Space Entry Supervisor attends the Safety Brief and briefs the Attendant(s) and

Authorized Entrant(s)

No

Yes

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Attachment D:

U.S. Capitol Power Plant Confined Space Entry Permit

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U.S. Capitol Power Plant Confined Space Entry Permit

DATE & TIME

Date & Entry Time: Date & Exit Time:

Attendant(s): Entry Supervisor:

*The names of the entrants are located on the Pre- and Post-Entry Signature Page (Attachment A)

TASK DESCRIPTION

Jobsite Location/address:

Purpose of entry:

Egress Location(s):

Emer. Evacuation Assembly Area:

Attendant Location (Door Designation, Cross Street, etc.):

Hazards associated with entry: High temperature [ ] Poor illumination & Physical obstructions [ ] Falling Hazards (spalling concrete) [ ] Designated rescue procedures: Call USCP: 202-224-0911 or 202-225-0911 and CPP Ops: 202-225-4180

EQUIPMENT

Type of direct reading gas monitor: Personal Air Monitor:

Date gas monitor was calibrated:

Ventilation: Natural [ ] Mechanical [ ] List of personal protective equipment: Hard Hat [ ] Gloves [ ] Flashlight [ ] Disposable coveralls with hood/boots [ ] Safety Shoes [ ]

Respirator with HEPA Cartridge [ ] Body Harness [ ] Safety Glasses [ ]

COMMUNICATION

Communication method between attendant & entrant: Radio & Voice Communication method between attendant & rescue: Radio & Cell Phone/Telephone Rescue service provider phone #: Call 202-224-0911 or 202-225-0911

Is this an extreme heat environment per the Heat Stress Prevention Program, Y/N?

(If yes, use the UDS PERSONAL HEAT STRESS MONITORING FORM – Attachment F)

ADDITIONAL PERMITS OR CONTROL MEASURES:

ATMOSPHERIC TESTING (to be taken by Authorized Entrant every 30 minutes and recorded by Attendant)

TIME LOCATION COMBUSTIBLE

<10% of LEL

OXYGEN

19.25-23.5 %

CARBON

MONOXIDE

<35 PPM

HYDROGEN

SULFIDE

<10 PPM

TEMP HUMDITY INDOOR

WBGT*

* WBGT – Wet Bulb Globe Temperature

Attachment E:

CPP UDS Exit Decontamination Procedures

Public Law 108-447 Security Review Pending

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CPP UDS Exit Decontamination Procedures

The following procedures may be required prior to exiting the CPP UDS. The Confined Space Entry Supervisor is responsible for ensuring that all equipment necessary for decontamination procedures, as described below, is available.

Exit Decontamination Procedures from Asbestos Regulated Areas

1. Identify decontamination area prior to starting work.

2. Place 6 mil poly on the floor.

3. Vacuum off disposable coveralls; remove disposable coveralls and gloves.

4. Fold up poly and clothing and place in asbestos bag.

5. Remove respirator; clean and seal HEPA cartridges (if being reused) or place

HEPA cartridges in asbestos disposal bag; clean respirator.

6. Twist asbestos bag into a goose neck and secure with tape; 3 wraps minimum.

7. HEPA vacuum the asbestos disposal waste bag.

8. Label bag if applicable.

9. Seal all openings of the HEPA vacuum, and HEPA-vacuum the exterior of the HEPA vacuum.

10. Showers are available in the CPP Administration building.

11. All personnel must shower at the end of last entry of the day.

Note: If you see any entrants not complying with the above procedures, please notify CPP TSS at 202-329-6522 (office) or (202) 329-6522 (cell), or the Deputy Director of the Capitol Power Plant at (202) 226-3864 (office) or (202) 641-6651 (cell).

Attachment F:

UDS Personal Heat Stress Monitoring Form

Public Law 108-447 Security Review Pending

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UDS PERSONAL HEAT STRESS MONITORING

Have environmental conditions been evaluated per Attachment B of the Heat Stress Prevention Program (included on following pages)? Y N Are conditions considered extreme heat environment? Y N If yes, follow evaluation procedures below and implement work rest cycles.

To check the heart rate, count the radial pulse for 30 seconds at the beginning of the rest period. If the heart rate exceeds 110 beats per minute, shorten the next work period by one-third and maintain the same rest period.

The recovery heart rate can be checked by computing the pulse rate taken at 30 seconds (P1) with the pulse rate taken at 2.5 minutes (P3) after the rest break starts.

The two pulse rates can be interpreted using Table 6.2 below.

Table 6.2: Heart Rate Recovery Criteria Heart rate recovery pattern (OSHA Technical Manual Table III:4-4)

P1

Difference between P1 & P3

Satisfactory recovery <90 --- High recovery (conditions may require further study) ≥90 ≥10 No recovery (may indicate too much stress) ≥90 <10

For acclimatized and unacclimatized personnel, if core body temperature taken through the ear canal exceeds 100.4°F, shorten the next work cycle by one-third.

NAME TEMP. P1 P3 REMARKS

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Recommended Work/Rest Schedule (Heat Stress Prevention Program, Attachment B)

The ACGIH TLV® booklet provides criteria for work/rest cycles, which have been converted from degrees Celsius to Fahrenheit and are reproduced below. Temperatures listed are recommended WBGT limits for the rotation period specified. To determine the appropriate work-load column, use the final table, Metabolic Rate Categories and Representative Metabolic Rate with Example Activities. The WBGT Adjustments for Clothing Ensembles (Heat Stress Prevention Program, Table 6.1), reproduced below, should be applied to these TLVs and Action Limits in order to determine appropriate limits based on the clothing being worn.

Screening Criteria for TLV® Heat Stress Exposure for Acclimatized Workers based on the 2011 ACGIH TLV® booklet (Heat Stress and Heat Strain, Table 2)

Work-Rest Cycle Light Work Moderate Heavy Very Heavy 60-minutes work/hr No rest time/hr

WBGT 87.8 WBGT 82.4 Not…