McLouth_Steel_Draft_SSHP_(Final_2-16-17).pdf

SITE SAFETY AND HEALTH PLAN

DSC MCLOUTH STEEL GIBRALTAR PLANT

CITY OF GIBRALTAR, MICHIGAN

EPA SITE ID # MIN000510362

PREPARED FOR:

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY,

REGION 5

77 WEST JACKSON BOULEVARD, SR-6J

CHICAGO, ILLINOIS 60604-3507

INTERAGENCY AGREEMENT/AMENDMENT NO. DW96958743-01-0

PREPARED BY:

U.S. ARMY CORPS OF ENGINEERS - BUFFALO DISTRICT

1776 NIAGARA STREET

BUFFALO, NEW YORK 14207

FEBRUARY 2017

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SITE SAFETY AND HEALTH PLAN (SSHP)

DSC MCLOUTH STEEL GIBRALTAR PLANT

Prepared By:

Michael Polek, Safety Specialist, CELRB-SO Date

Reviewed By:

In-House Project Delivery Team (PDT) The following individuals are the primary technical PDT members responsible for product development to ensure that the SSHP meets all the design, environmental, legal and real estate requirements:

Name Title Organization

Jeffrey Follett Project Manager CELRE-PM

Frank D’Andrea Contracting Officer CECT-LRB

Timothy Ifkovich Project Engineer CELRB-TD-EE

Michelle Barker Senior Environmental Engineer CELRB-TD-EE

David Mitchell Geotechnical Engineer CELRB-TD-DC

Jeffrey Hall Quality Control Officer CELRB-TD-EE

Peter Lorey Chemist CELRB-TD-EH

Karen Keil Risk Assessor CELRB-TD-EH

Neil Miller Site Safety and Health Officer CELRB-TD-EH

Shawn McCabe Geographic Information Systems Specialist / Database Manager CELRB-TD-EH

Roseanne Weidner Industrial Hygienist CELRB-TD-EH

William Frederick Hydro Geologist CELRB-TD-HD

Colin Ozanne Counsel CELRB-OC iv

SSHP APPROVALS

Approved By:

Karen Keil, Environmental Health Team Leader Date

CELRB-TD-EH

Approved By:

David G. Frothingham, Chief, Environmental Branch Date

CELRB-TD-E

Concurrence By:

Roseanne H. Weidner, Industrial Hygienist Date

CELRB-TD-EH

Concurrence By:

William Pioli, Safety & Occupational Health Manager Date

CELRB-SO

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TABLE OF CONTENTS

IN-HOUSE PROJECT DELIVERY TEAM………………………………………………….….iii

TABLE OF CONTENTS ................................................................................................................ v

INTRODUCTION

1.1 BACKGROUND INFORMATION

1.2 PURPOSE

1.3 SITE ACTIVITIES

1.3.1 Site Visit

1.3.2 Site Clearing

1.3.3 Utility Clearance

1.3.4 Installation of Subsurface Sampling Devices and Collection of Subsurface Soils . 4

1.3.5 Groundwater, Subsurface Soil, Soil Gas and Vapor Intrusion Sampling

1.3.6 Handling of Investigation Derived Waste

1.4 HAZARDS DISCUSSION

RESPONSIBILITIES AND LINES OF AUTHORITIES

2.1 RESPONSIBILITY STATEMENT

2.2 RESPONSIBLE PERSONNEL

2.2.1 Safety and Occupational Health Manager

2.2.2 Project Manager

2.2.3 Environmental Branch Team Leaders

2.2.4 Industrial Hygienist

2.2.5 Field Personnel

2.2.5.1 Field Operations Lead

2.2.5.2 Designated Site Safety Representative

2.2.5.3 Other Field Personnel

HAZARD ASSESSMENT

3.1 CHEMICAL CONSTITUENTS OF POTENTIAL CONCERN

3.1.1 Hazard Communication

3.2 PHYSICAL HAZARD IDENTIFICATION

3.2.1 On-Site Movement of Equipment and Trucks

3.2.2 Underground Services

3.2.3 Electrical Hazard Identification

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3.2.4 Hand Tools

3.2.5 Slips, Trips, and Falls

3.2.6 Lifting Hazards

3.2.7 Drum Handling

3.2.8 Severe Weather

3.2.8.1 Heat Stress

3.2.8.2 Cold Exposure

3.2.9 Noise Hazards

3.3 BIOLOGICAL HAZARD IDENTIFICATION

3.3.1 Ticks

3.3.2 Spiders

3.3.3 Poisonous Plants

3.3.4 Animal or Insect Bites

TRAINING REQUIREMENTS

4.1 PERIODIC TRAINING

4.1.1 Basic HAZWOPER Training

4.1.2 First Aid and Cardio Pulmonary Resuscitation Training

4.1.3 Site-Specific Safety and Health Training/Pre-Entry Briefing

4.1.4 Blood-Borne Pathogen Training

4.1.5 Respiratory Protection Training

4.1.6 Personal Protective Equipment Training

ACTIVITY HAZARD ANALYSIS

SITE CONTROL

6.1 GENERAL SITE ACCESS

6.1.1 Site Sanitation

6.2 SITE VISITORS

6.3 ACCOUNTABILITY

6.4 BUDDY SYSTEM

6.5 SAFE WORK PRACTICES

6.6 WORK ZONES

EXPOSURE MONITORING

PERSONAL PROTECTIVE EQUIPMENT

8.1 LEVELS OF PROTECTION

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8.2 PLANNED LEVELS OF PERSONAL PROTECTION

8.2.1 Field Activity (non-intrusive)

8.2.2 Field Activity (intrusive – performed by subcontractor)

8.3 RESPIRATOR USE

8.3.1 Respirator Inspection

8.3.2 Respirator Cleaning

8.3.3 Respirator Maintenance

8.3.4 Respirator Storage

DECONTAMINATION PROCEDURES

9.1 PERSONNEL DECONTAMINATION PROCEDURES

9.2 EQUIPMENT DECONTAMINATION PROCEDURES

EMERGENCY RESPONSE AND NOTIFICATION PLAN

10.1 PERSONNEL ROLES/LINES OF AUTHORITY

10.1.1 Designated Site Safety Representative

10.1.2 Project Manager

10.2 EMERGENCY CONTACTS AND NOTIFICATION

10.3 MEDICAL EMERGENCY RESPONSE

10.4 PERSONAL EXPOSURE OR INJURY

10.5 SITE EVACUATION PROCEDURES

10.6 EMERGENCY DECONTAMINATION PROCEDURES

10.7 ADVERSE WEATHER CONDITIONS/NATURAL DISASTERS

10.8 EMERGENCY EQUIPMENT

10.9 ACCIDENT REPORTING & FOLLOW-UP OF EMERGENCY PROCEDURES ... 39

MEDICAL SURVEILLANCE REQUIREMENTS

REFERENCES

LIST OF FIGURES

(Following Text)

1-1 Site Map viii

LIST OF TABLES

(Following Figures)

1-1 Summary of Historically Detected Soil Analytical Results in Investigation Areas Zoned for General Industrial or Commercial Use

1-2 Summary of Historically Detected Soil Analytical Results in Investigation Areas Zoned for Residential or Planned Unit Development Use

1-3 Summary of Historically Detected Groundwater Analytical Results in Investigation Areas Zoned for General Industrial or Commercial Use

1-4 Summary of Historically Detected Groundwater Analytical Results in Investigation Areas Zoned for Residential or Planned Unit Development Use

1-5 Summary of Historically Detected Surface Water Analytical Results

1-6 Summary of Historically Detected Sediment Analytical Results

1-7 Summary of Historically Detected Leachate Analytical Results

LIST OF APPENDICES

(Following Tables)

Appendix A: EM 385-1-1 (ELECTRONIC COPY ON ENCLOSED CD)

Appendix B: Safety Data Sheets (SDSs)

Appendix C: ENG FORM 3394

Appendix D: SSHP Acknowledgement Form

Appendix E: Activity Hazard Analysis

Appendix F: Emergency Contact List and Hospital Location Map ix

ACRONYM LIST

ACGIH American Conference of Governmental Industrial Hygienists ACM asbestos containing material ADP acid dosing pond AHA activity hazard analysis ANSI American National Standards Institute APP accident prevention plan AST above ground storage tanks ATVs all-terrain vehicles BBP blood-borne pathogens BPM beats per minute C&D construction and demolition CERCLA Comprehensive Environmental Response, Compensation, and Liability

Act COI constituent of interest CPR cardiopulmonary resuscitation CRZ contaminant reduction zone CWLF Countywide Landfill dBA A-weighted decibels °C degrees Celsius °F degrees Fahrenheit DOT Department of Transportation DSSR designated site safety representative EE environmental engineering EH environmental health EM engineer manual EMS Emergency Medical Services ER engineer regulation EZ exclusion zone FID flame ionization detector FOL field operations lead GOVs government-owned vehicles HAZWOPER hazardous waste operations and emergency response HTRW hazardous, toxic, and radioactive waste IA investigation area IH industrial hygienist IDW investigation derived waste NCP National Oil and Hazardous Substances Pollution Contingency Plan NEC National Electric Code MDNR Michigan Department of Natural Resources MDPH Michigan Department of Public Health mg/m3 milligrams per cubic meter NPL National Priorities List OEL occupational exposure limit OSHA Occupational Safety and Health Administration x

PAH polycyclic aromatic hydrocarbons PCB polychlorinated biphenyls PCOI potential constituent of interest PDT project delivery team PEL permissible exposure limit pH potential of hydrogen PID photo ionization detector PM project manager PPB parts per billion PPE personal protective equipment PPM parts per million PPMV parts per million by volume RI remedial investigation RI/FS remedial investigation/feasibility study ROE right of entry SDP sludge drying pond SDS safety data sheet SOH safety & occupational health SOHM safety & occupational health manager SPF sun protection factor SSHP site safety and health plan STEL short term exposure limit SVOC semi-volatile organic compounds T&D transportation and disposal the City City of Gibraltar, Michigan the Site DSC McLouth Steel Gibraltar Plant TLV threshold limit value TMP tandem mill pond TWA time weighted average µg/m3 micrograms per cubic meter µm micrometer USACE United States Army Corps of Engineers USEPA United States Environmental Protection Agency UVs utility vehicles VOCs volatile organic compounds WBGT wet bulb globe temperature

INTRODUCTION

1.1 BACKGROUND INFORMATION

The Site is located in the City of Gibraltar (the City), Wayne County, Michigan. For the purpose of this RI, the Site is bound by West Jefferson Avenue, a National Wildlife Refuge, and residential homes to the east; Vreeland Road, residential homes, commercial property, and undeveloped land containing radio towers are north of the site; Gibraltar Road, residential homes, and a rail spur are to the south; and the Consolidated Rail Corporation rail line and commercial properties are located to the west. Two rail lines and the Frank & Poet Drain bisect the site between Countywide Landfill (CWLF) and Landfill Areas A and B. Brownstown Creek drains into the Frank & Poet Drain before it runs into the Detroit River. The Trenton Channel of the Detroit River is approximately 1,500 feet east of the site. Two municipal drinking water intakes (i.e., the Belle Isle and Fighting Island intakes) are located on the Detroit River upstream from the Site. The Humbug Marsh, a Detroit River International Wildlife Refuge, is directly across West Jefferson Avenue from the Site.

Operations at the Site began in 1954 as a steel finishing facility, including annealing, pickling, and cold rolling processes. The Site consists of several different areas including: CWLF, Landfills A and B, the leachate treatment lagoon system, and other historic fill areas, which are described below. Portions of the land within the site boundaries are actively farmed and also currently zoned residential.

Countywide Landfill

Development of CWLF began in the late 1970s by McLouth and filling operations began in January 1981. The formerly active portion of the landfill is approximately 50 acres in size and is located to the west of the steel mill. The landfill is technically made up of a lower and upper landfill. The lower landfill was originally constructed over a dense native clay with engineered clay dikes around the perimeter. The lower landfill accepted steel manufacturing waste including mill scale, blast furnace dust, filter cake, and grit from the Trenton and Gibraltar plants until 1999.

After the lower landfill no longer accepted steel mill waste, another landfill was constructed on top of the lower landfill which accepted construction and demolition (C&D) debris. At this time, the landfills were then collectively known as CWLF. The upper landfill received the last load of waste in August 2007. CWLF is currently not operating and does not have an operating license.

Other areas around CWLF include: an area historically used as an excavation/staging area located west of the North Pond; on-site surface water conveyances including Marsh Creek, Brownstown Creek and the Frank & Poet Drain; largely native/farmed land south of Marsh Creek and Brownstown Creek, which includes Quarry Lake; and native/undeveloped land east of the North and South Ponds. An abandoned above ground storage tank (AST) has also been found in this area near the entrance to CWLF.

Landfills A and B

Landfill A was constructed in 1977. The landfill is located south of the leachate treatment lagoon system and is approximately 23 acres in size. Landfill A was included in an industrial waste landfill license issued to McLouth in 1976. Landfill A was filled from 1977 into the early 1980s and initially capped in 1984. Construction of Landfill B began in 1959. The landfill is located west of the lagoon system and is approximately 32 acres in size. Landfill B was filled from the 1960s into the early 1970s, prior to landfill licensing requirements. Both landfills were constructed over a dense native clay with engineered clay dikes around the perimeter of the landfills. Both landfills accepted steel manufacturing waste including mill scale, blast furnace dust, filter cake, and grit from the Trenton and Gibraltar Plants.

Other areas around Landfills A and B include the Frank & Poet Drain, and largely native/undeveloped land west of the Frank & Poet Drain.

Leachate Treatment Lagoon System

The leachate treatment lagoon system includes a series of interconnected ponds and basins: 4 water retention basins including: water retention basin #1 (pH adjustment pond), water retention basin #2 (solids settling pond), water retention basin #3, and water retention basin #4 (aeration pond #2);

2 ponds including: an acid dosing pond (ADP), and a sludge drying pond (SDP); and four ponds that make up the partially closed Tandem Mill Pond (TMP). The lagoon system treated landfill leachate and oily process water generated by steel mill operations. The treated water was then discharged into an on-facility ditch. Spent noncontact cooling water used to cool the rollers, air compressors, generators, and annealing furnaces was also discharged to a storm drain, located west of the mill building. The effluent from the lagoon system and spent noncontact cooling water then mixed together and discharged to the Frank & Poet Drain. The configuration of interconnection between the leachate treatment lagoon system ponds has been modified over time and is currently configured to share a common discharge point through an outfall from water retention basin #4

(EPA, 2014).

Several abandoned ASTs have also been found around the leachate treatment lagoon system, west and south of the TMPs.

Historic Fill Areas

There are two main historic fill areas including the area north of Landfill B, and the area directly south of the ADP and SDP. The area north of Landfill B was formerly known as the northwest fill area and recently dubbed ‘Landfill X’ in the Historical Aerial Photo Analysis. The Historical Aerial Photo Analysis shows significant areas of Landfill X cleared in June 1959 with a more defined boundary appearing in August 1960. After 1975, the area appears inactive and by 1978 vegetation can be seen growing within the boundaries of the area. Available information for Landfill X is very limited and the actual use of the area is unknown. Numerous abandoned ASTs and scrap material have also been found in this area. The area directly south of the ADP and SDP was formerly known as the southeast fill area, however the actual use of the area is unknown.

Review of the Historical Aerial Photo Analysis does not show much activity in this area.

1.2 PURPOSE

This Site Safety and Health Plan (SSHP) has been prepared for the DSC McLouth Steel Gibraltar Plant Site, U.S. Environmental Protection Agency (USEPA) Site ID # MIN000510362, which is located in Gibraltar, Michigan. The U.S. Army Corps of Engineers (USACE), under the authority of Interagency Agreement No. DW-96-95874301-0 with the USEPA, has prepared this SSHP in preparation to perform field activities in support of a Remedial Investigation/Feasibility Study (RI/FS) at the Site. The USACE will perform the RI/FS in compliance with and meeting the requirements of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), the National Oil and Hazardous Substances Contingency Plan (NCP), and USEPA guidance.

This SSHP summarizes the planned activities that will be conducted at the site and the hazard information associated with those activities. Presented are safety and health procedures for USACE personnel who will be accessing the Site to perform or oversee activities ranging from:

• Site visits;

• Clearing, grubbing and geophysical investigations;

• Collection of subsurface soils, sediments, pond basin sediments, geotechnical borings and thin-walled tube sampling;

• Test pit investigations and landfill cover sampling;

• Collection of Asbestos Containing Material (ACM), Lead and Polychlorinated

Biphenyls (PCB) samples from Aboveground Storage Tanks (AST);

• Installation of groundwater monitoring wells and piezometers;

• Collection of groundwater, surface water, landfill gas, leachate samples and aquifer testing.

The procedures presented herein are designed to reduce the risk of exposure to physical, biological, and chemical hazards associated with the field work performed at the' Site by USACE personnel.

Contractors will be required to create and follow their own Accident Prevention Plan (APP)/SSHP that has been accepted by USACE. The protocols and procedures in this SSHP are intended for use during all site visits associated with the activities identified in Section 1.3 and apply to all USACE personnel. Appendix A of this SSHP is USACE’s Safety and Health Requirements Manual [Engineer Manual (EM) 385-1-1] providing direction on all Safety and Health topics. An outline of this SSHP is listed below:

• Identifies the location and setting in which the work may be conducted,

• Describes the work which may be conducted,

• Discusses the hazards likely to be encountered at the site,

• Presents the standards and procedures that will ensure that all activities are conducted in a safe manner and will avoid accidents,

• Outlines emergency plans for the protection of on-site personnel during unusual occurrences, and

• Designates the responsibilities for implementation of all standards and procedures.

1.3 SITE ACTIVITIES

The Site has been broken into fifteen investigation areas (IAs) to focus the RI field activities and data analysis as related to impacts from known and potential sources. Site activities will be conducted within the fifteen IAs. Tasks may consist of the following:

1.3.1 Site Visit

A site visit would consist of transgressing across the investigative areas, either on foot or in a vehicle. Personal Protective Equipment (PPE) requirements will be situation and task specific but for general Site visits, Level D PPE is required.

1.3.2 Site Clearing and Grubbing

Site clearing will be conducted by a subcontractor as needed and includes the removal of brush and vegetation in areas leading up to and in the vicinity of anticipated field activities. This work would be conducted to facilitate the field activities and for personnel safety and health. Clearing of large areas is not anticipated but would be conducted using mechanical means (brush hog) whereas smaller discrete clearing may be conducted utilizing hand tools like a machete, hand saw, weed trimmer or double-edged weed cutter. Saplings with a diameter of up to 3 inches will be removed using a hydro-ax or equivalent.

1.3.3 Utility Clearance

Before conducting intrusive activities, 811 “MISS DIG System” will be called to have any underground utilities marked out. If that system is inconclusive, or there is reason to believe there may be other subsurface piping or utilities in a work area, further utility investigation will be conducted to screen for and locate subsurface utilities. The following methods may be implemented by a subcontractor as applicable:

• Geophysical Survey performed with Ground Penetrating Radar and/or high-resolution time domain electromagnetic metal detection.

• Air knifing at investigation points utilizing an air compressor and vacuum truck or portable Vactron® unit/drum vac. Knifing shall be performed to remove materials if within 3-feet of a utility, to a depth of 5-feet below grade.

• Physical removal of soils. Conducted either as soft excavation utilizing hand tools like post-hole diggers and an insulated/nonconductive digging/pry bar.

1.3.4 Installation of Subsurface Sampling Devices and Collection of Subsurface Sample

Media

Auger or direct-push drilling technology will be utilized for deep soil boring, groundwater monitoring well and piezometer installation, thin-walled tube sampling, and/or geotechnical and environmental sampling. Bucket hand augers will also be utilized for surface and subsurface soil sampling. All drilling will be conducted by a qualified subcontractor.

1.3.5 Groundwater, Surface Water, Subsurface Soil, Landfill Gas, Leachate Sampling

Soils will be collected by a subcontractor utilizing methods stated above. Soils will be laid out and screened by USACE personnel with a photoionization detector (PID) equipped with the proper lamp (ionization potential (IP or eV) for Site constituents of interest (COI), to determine what material will be sampled. Samples will be collected with stainless steel tools and placed into sample containers containing appropriate preservative.

Groundwater monitoring wells will be installed by a subcontractor as stated above. Wells will be developed using the pump and surge method. Groundwater samples will be collected by USACE personnel utilizing either a bladder pump or peristaltic pump adhering to USEPA Low Flow groundwater sampling methodology and USEPA Region 4 Soda Straw method. Surface water and leachate samples will be collect utilizing dip buckets. Water quality parameters will be recorded utilizing a Horiba® U-52 multi-parameter instrument with flow through cell.

Landfill gas sampling will be conducted by driving a ¾ - 1 inch hole into the ground to a depth of 5 feet utilizing slide-bar/slide-hammer methods. A ¼ inch stainless steel probe is inserted into the hole and the top of the hole is sealed with modeling clay around the top of the probe. An air sampling pump pulls the gas contained in the interstitial space of the soil through the probe where the gas is analyzed by a Flame Ionization Detector (FID).

Sediment sampling will be conducted utilizing grab samples, bucket hand augers, a Vibracore, or Wildco® sediment samplers, being driven below grade using a slide-hammer anvil. Waders may be used to access sample locations within Brownstown and Marsh Creeks and the Frank & Poet Drain. The use of a boat may be required to access sampling locations within the on-site ponds and basins.

1.3.6 Handling of Investigation Derived Waste

All development/purge water will be disposed of within the respective areas. Development/purge water generated from monitoring wells near CWLF will be disposed of in the CWLF leachate collection sump. Development/purge water generated from monitoring wells near Landfills A and B and the leachate treatment lagoon system will be disposed of in the lagoon system. If possible, decontamination fluids will be disposed of in their respective areas. All soil cuttings, auger cuttings, decontamination fluids if needed and used PPE shall be containerized in Department of Transportation (DOT) approved -55 gallon drums and handled as Investigative Derived Waste (IDW). Drums will be staged at a designated IDW staging area pending analytical testing (i.e., profiling) and disposal. Where practical, waste will be segregated by field observations (e.g. odor, visual staining, presence of free product, PID readings). Other solid IDW including PPE, disposable sampling equipment, and miscellaneous trash will be segregated into visibly and non-visibly contaminated material. Non-contaminated IDW will be placed in trash bags and stored in a rented dumpster for periodic disposal at a municipal landfill.

Waste storage drums and containers will be labeled as they are generated to ensure proper identification and management of the stored wastes. Container labels reading Empty, Pending Analysis, Hazardous, and/or Non-hazardous, will be affixed to the container and the container will be stored upright. Once filled and labeled, waste drums will be transported to the primary or secondary staging areas for future shipment and disposal. Containers and staging areas will be inspected on a weekly basis while USACE personnel are on-site during this RI to ensure integrity of the containers.

1.4 HAZARDS DISCUSSION

All of the COIs are either hazardous, toxic, carcinogenic, asphyxiate or a combination there of.

Based upon an analysis of the data from previous investigations and remedial action at the Site, the initial list of COIs consists primarily of volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs) including some polycyclic aromatic hydrocarbons (PAHs), and metals and minerals. Additionally there are pesticides and polychlorinated biphenyls (PCBs).

For all COIs, in all forms of media (soil, water, gas), the primary exposure route for this project is inhalation of vapors. When the VOCs and SVOCs are exposed to the atmosphere they volatilize and can be directly absorbed through the lungs. Based on the planned RI activities, dermal absorption is a secondary potential exposure route that needs to be protected against. The list of COIs are liquid in nature or dissolved in groundwater and will be readily absorbed by the skin or eyes. The third exposure route is through the inhalation or ingestion of fugitive dust. Based on the planned site activities that will be conducted by USACE personnel, dust exposure is expected to be negligible. All drilling will be conducted by subcontractors so the activity with the greatest potential to generate airborne particulate contamination are the test pit investigations. A summary of COIs is described below.

Countywide Landfill

Leachate at CWLF has been found to contain carbazole, mercury, silver, PCBs, selenium, vanadium, zinc, cyanide, carbon disulfide, phosphorus, naphthalene, 2,4-dimethylphenol, phenol, nickel, ammonia, and high pH.

Landfills A and B

Leachate from these landfills has been found to contain naphthalene, phenol, mercury, 2,4-dimethylphenol, barium, cyanide, ammonia, and high pH.

Leachate Treatment Lagoon System

Water discharged into the Frank & Poet Drain from the leachate treatment lagoon system contains documented phenols, PCBs, metals, and high pH.

The COIs were found in some assortment in all site media including groundwater, soils and leachate. Additionally, there are historical hits of dozens of other contaminants that either were isolated instances or their concentrations were almost near laboratory detection levels which questions their existence, and allows us to rule them out as an occupational hazard for this project.

The COI VOCs and SVOCs are detectable with portable monitoring equipment that provide real time measurements. These instruments can detect below the American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs) or Occupational Safety and Health Administration (OSHA) Permissible Exposure Limits (PELs) for worker exposure that the USACE adheres to. Additionally, total dust monitoring can be performed in real time. Exposure monitoring for Site COIs is described in Section 7.0. Further analytical data and analysis is presented in Tables 1-1 through 1-7.

RESPONSIBILITIES AND LINES OF AUTHORITIES

2.1 RESPONSIBILITY STATEMENT

USACE is ultimately responsible for the implementation of the Safety and Occupational Health Program and for the safety of its employees. USACE employees have the responsibility to promote a safe workspace, but the ultimate responsibility is with the appropriate level of management as described below.

2.2 RESPONSIBLE PERSONNEL

The functional responsibilities and accountability of key personnel are described in the following parts of this section. Management personnel have been assigned to this project based on the nature of their responsibilities to support operations within their area of expertise, conducted by personnel under their control. Specific field personnel assigned to each of these positions is based on a combination of experience in the type of work to be performed and experience working with government procedures.

2.2.1 Safety and Occupational Health Manager

William Pioli is the USACE Safety & Occupational Health Manager (SOHM). The SOHM is responsible for the USACE’s overall health and safety program and for making health and safety decisions for specific health and safety activities and for verifying the effectiveness of the health and safety program. The SOHM has primary responsibility for the following related items either directly or through subordinates:

• Stopping work or upgrading protective measures (including protective clothing) if uncontrolled health and safety hazards are encountered. The SOHM must also authorize resumption of work following correction of an adverse condition(s); and

• Overall management of accidents/incidents.

2.2.2 Project Manager

The USACE Project Manager (PM) for the project is Jeffrey Follett. The PM ensures the overall management and quality of the project including all phases of work plan development, field activities, data management, and report preparation. The PM coordinates with the Environmental Branch Team Leaders as described in Section 2.2.3 to staff activities and ensure project execution.

The PM serves as the principal point of contact with all project stakeholders and will address nonconformance issues. Specific responsibilities include:

• Coordinating with USACE personnel, including reporting accidents and incidents immediately and submitting written reports;

• Ensuring the creation and implementation of the SSHP;

• Maintaining project documentation of all required records;

• Ensure that projects have the necessary resources to operate safely; and

• Maintaining a current copy of the SSHP.

2.2.3 Environmental Branch Team Leaders

The Buffalo District’s Environmental Branch is composed of two teams. First is the Environmental Health (EH) Team led by Karen Keil. This team includes Health Physicists, Industrial Hygienists (IH), Chemists, Risk Assessors and Geographers/Cartographers. The second is the Environmental Engineering (EE) Team which is comprised of Environmental Engineers and led by Jeffrey Hall.

Specific responsibilities of the team leaders include:

• Ensuring that a qualified safety representative is designated;

• Ensuring that qualified, trained personnel are assigned to support project activities;

• Ensuring that on-site personnel have the proper medical surveillance;

• Ensuring that project staff implement the SSHP; and

• Coordinating with the PM to ensure that projects have the necessary resources to operate safely.

2.2.4 Industrial Hygienist

The EH Team has an IH, Roseanne Weidner. The IH ensures the Safety and Occupational Health (SOH) of USACE personnel on HTRW sites. Specific responsibilities of the IH include:

• Writing and reviewing SOH documents for the Environmental Branch,

• Reviewing and accepting contractor SOH documents for HTRW sites, and

• Acting as a Subject Matter Expert for issues related to USACE safety manual EM

385-1-1.

2.2.5 Field Personnel

Field activities are primarily staffed by PDT members and other Environmental Branch personnel, through coordination between the PM and Team Leaders. If needed, persons from outside the Environmental Branch are solicited by the PM, through their supervisors. The responsibilities described below are assigned to personnel by the Environmental Health Team Leader and change between activities, so a name is not associated with the position. When signing the SSHP Acknowledgement Form, personnel shall list their designated position in the “responsibility” column next to their name.

2.2.5.1 Field Operations Lead

The Field Operations Lead (FOL) for this project is Timothy Ifkovich. Mr. Ifkovich reports directly to the PM and is responsible for the overall direction and management of field project tasks conducted at the site. This includes oversight of field staff ensuring that procedures for field activities are executed in the proper manner, activities are properly documented and communication protocols are followed.

2.2.5.2 Designated Site Safety Representative

The Designated Site Safety Representative (DSSR) reports directly to the FOL and EH Team Leader and consults with the IH or SOHM as needed. The DSSR is the focal point for safety-related communications with field personnel and answering safety-related questions for field personnel. The DSSR has authority to issue stop work orders for on-site tasks that he/she believes may be unsafe. When stopped, work will not recommence until the PM and either the SOHM or DSSR approve the restart. The DSSR will possess a copy of this SSHP for site personnel to access at all times while on site. Additional responsibilities include:

• Conducting a daily site-specific tailgate safety meeting covering potential hazards, safe work practices, and emergency procedures;

• Maintaining the Safety Data Sheet (SDS) located in Appendix B, for applicable materials utilized at the Site;

• Ensuring the calibration/maintenance of safety related field instruments (PIDs, combustible gas indicators, etc.) while overseeing field air quality monitoring activities;

• Working with the PM to ensure sufficient safety-related equipment, instruments, PPE and other materials are available to support safe field activities; and

• Preparing accident investigation forms (USACE Form ENG 3394, Appendix C) in the event of an accident or incident.

2.2.5.3 Other Field Personnel

Other field team members are responsible for performing field activities as stipulated in this plan and will report directly to the FOL. Each person assigned work on the Site is ultimately responsible for their own health and safety while working on this project. Primary safety responsibilities of each person working on the Site include taking all reasonable precautions to prevent injury to themselves and to their fellow site workers and being alert to potentially harmful situations. Field personnel are responsible for:

• Performing only tasks that they can do safely and in which they have been trained;

• Notifying the DSSR of special medical conditions (i.e., allergies, contact lenses, etc.);

• Notifying the DSSR of prescription and/or non-prescription medication the worker may be taking that might cause drowsiness, anxiety or other unfavorable affects;

• Preventing spillage and splashing of IDW materials/wastewater to the greatest extent possible;

• Practicing good housekeeping by keeping the work area neat, clean, and orderly;

• Immediately reporting all injuries to the DSSR;

• Complying with the SSHP and properly using PPE as determined by this SSHP and/or the DSSR; and

• Stopping work and immediately notifying the DSSR if conditions arise or are observed that are believed to be an imminent hazard.

HAZARD ASSESSMENT

The DSSR will make the final determination of PPE levels for hazardous contaminants prior to the start of site activities. The DSSR, in consultation with the IH will upgrade PPE beyond that specified in Section 8.0 of this SSHP in response to changes in field conditions.

3.1 CHEMICAL CONSTITUENTS OF POTENTIAL CONCERN

As discussed in Section 1.3, the planned site activities involve many means and methods to investigate the Site’s different media (soil, water, gas). Two categories of chemical hazards are associated with field activities. First are chemicals used to conduct Site work like fuel for equipment, and there are also sample preservatives and decontamination fluids. Controls for those chemicals are described below in Section 3.1.1.

The second category of chemical hazards are the Site COIs. Previous Site data indicates the presence of chemical compounds in the form of VOCs, SVOCs, PCBs and Pesticides as discussed in Section 1.4. Levels of PPE identified in Section 8.0 are anticipated to fully protect worker health and safety for both the work site chemicals and the chemical compound COIs. Exposure monitoring will be performed and is presented in Section 7.0.

3.1.1 Hazard Communication

The following will apply to all commercial products containing hazardous substances brought on site during site activities:

• The DSSR will maintain SDSs for each hazardous material brought to or used on site.

The SDSs will be added to Appendix B of this SSHP.

• The DSSR will assure that a label is affixed to each container of hazardous material for those containers of hazardous materials not supplied with an adequate label.

• The DSSR will inform personnel of the hazards of hazardous materials on site and the location of appropriate SDSs during the initial site safety briefing.

3.2 PHYSICAL HAZARD IDENTIFICATION

3.2.1 On-Site Movement of Equipment and Trucks

USACE vehicular traffic in the work areas is expected to consist of government-owned vehicles (GOVs), and/or all-terrain vehicles/utility vehicles such as gators/mules. Contractor vehicles/equipment is expected to consist of work trucks, drill rigs, all-terrain vehicles (ATVs)/ utility vehicles (UVs), and other supporting equipment. The following precautions shall be observed when equipment is in use:

• At all times, be aware of the location and operation of heavy equipment and vehicles, and take precautions to avoid getting in the way of their operation. Never assume that the equipment operator sees you. Make eye contact and use hand signals to inform the operator of your intent, particularly if you intend to work near or approach the equipment.

• Level D PPE is required as described in Section 8.0 to include high visibility safety vests.

• Keep all non-essential personnel away from operating equipment. Utilize a spotter for the movement of vehicles/equipment in tight quarters or when working on public roads or near members of the public.

• ATVs/UVs and mechanized equipment shall be fitted with a back-up alarm.

• USACE personnel shall be properly trained and approved to operate GOVs and site equipment. Approval will be determined by the DSSR.

• Vehicles/equipment shall be checked by the operator prior to use, but not more often than daily, to ensure equipment is in safe operating condition and is free of apparent damage that could cause failure while in use. EM 385-1-1 Section 18.A.03.e lists inspection items, summarized below:

o All brakes, tires, horn, steering mechanism, coupling devices, seat belts and operating controls.

o Safety Devices – back-up alarms, fire extinguishers, first-aid kits, etc.

o Accessories – lights, reflectors, windshield wipers and defrosters if necessary.

3.2.2 Underground Services

The DSSR will coordinate with the USACE PM and Project Engineer to ensure that utility clearances have been performed in the areas of anticipated field activities. Utility clearance will initially involve contacting local utility providers and by calling 811 “MISS DIG System” to have any underground utilities marked out. Additional utility clearance activities are described in Section 1.3 and may be performed by a subcontractor if needed. USACE personnel shall position themselves and their work areas upwind from any intrusive activities associated with underground utility location and perform breathing zone air monitoring in accordance with Section 7.0.

3.2.3 Electrical Hazard Identification

To mitigate electrical hazards associated with generators and/or other electrical equipment brought on Site, National Electric Code (NEC) and the following controls will be implemented by the

DSSR:

• Portable electrical equipment will be inspected prior to use to ensure double insulation and/or proper grounding.

• Electrical connections will be made through ground fault circuit interrupters.

• Cords will be inspected daily by the user for fraying or other damage daily prior to use.

Any cords that fail to meet safety standards will be taken out of service and replaced.

• Cords shall contain the number of adequately sized conductors required for the load per NEC, Article 400.

• Portable flexible cords passing through work areas shall be protected from damage

(including that caused by foot traffic, vehicles, sharp corners, protections, and pinching).

• Portable flexible cords shall be supported in place at intervals that ensure that they will be protected from physical damage. Support shall be in the form of cable ties, straps or similar type fittings installed so as not to cause damage. They shall not be hung from nails, or suspended by bare wire.

3.2.4 Hand Tools

Only tools that are in good condition will be used during fieldwork. The following safe practices will be observed when using hand tools:

• Hand and power tools shall be used, inspected, and maintained in accordance with the manufacturer's instructions and recommendations and shall be used only for the purpose for which designed. A copy of the manufacturer's instructions and recommendations shall be maintained with the tools.

• Field personnel should be sure of footing before using any tool.

• Tools that have split handles, mushroom heads, defective electrical components or other defects will not be used.

• Makeshift tools or other improper tools will not be used.

3.2.5 Slips, Trips, and Falls

The most common hazard will be slips, trips and falls during Site transgression. Wet, slippery, or uneven ground, and holes identified at a work area should be covered, flagged, or marked to warn others. Debris and vegetation growth could contribute to falls from tripping. Equipment and materials used during Site activities also pose a slip, trip, and fall hazard. These hazards will be alleviated by safe practices, such as making personnel aware of unsafe areas, clearing vegetation or debris that would contribute to unsafe working conditions, and good housekeeping measures for equipment and material on the ground that could pose such a hazard. If determined by the DSSR, gravel, sand or salt will be placed to reduce hazards.

3.2.6 Lifting Hazards

The following guidelines will be followed whenever lifting equipment such as portable generators, coolers filled with supplies, and any other objects that are of odd size or shape or that weigh over 40 pounds:

• Get help when needed utilizing a two-person lift.

• Plan the lift. If lifting a heavy object, plan the route and where to place the object. In addition, plan communication signals to be used (i.e., “1, 2, 3, lift,” etc.)

• Wear sturdy shoes that are in good condition and supply traction when performing lifts.

Shoes shall be steel toe as described in Section 8.0.

• Keep your back straight and head aligned during the lift, and use your legs to lift the load – do not twist or bend from the waist. Keep the load in front of you – do not lift or carry objects from the side.

• Keep the heavy part of the load close to your body to help maintain your balance.

• Utilize two personnel for slide-bar/slide-hammer activities. Follow manufactures recommended technique. Wear hearing protection.

3.2.7 Drum Handling

IDW will be collected and placed into DOT-approved 55-gallon drums for characterization and disposal by a subcontractor. The drums will be staged in a designated storage area and sampled to determine final disposition. The drums will be labeled “Pending Analysis” and have appropriate contact information, in accordance with DOT requirements. IDW is discussed in Section 1.3.6.

When moving drums a drum dolly may be used if the drum is less than or equal to ½ of its capacity in volume. Drum dollies are to be utilized as a two-person activity. If drums need to be moved by USACE personnel that exceed the manual lifting limit of 40 lbs. per person and are more than 50% full, mechanical means must be utilized and those means are not covered in this SSHP. The USACE IH will be consulted and the Activity Hazard Analysis (AHA) amended. Rolling drums on its rim (tinning) is prohibited.

3.2.8 Severe Weather

In the event of adverse weather conditions at the site such as lightning, high winds, extreme heat or cold, heavy snow, sleet, or freezing rain, the DSSR may instruct the workers to discontinue field operations or to seek shelter in vehicles. Adverse weather is discussed in Section 10.7, heat and cold stress is presented below.

3.2.8.1 Heat Stress

Personnel performing field activities will be made familiar with the signs and symptoms of heat stress. These symptoms include:

• Heat Cramps: Painful muscle spasms, usually occurring in the abdomen and legs. Heat cramps are often the first signals that the body is succumbing to heat exposure.

• Heat Exhaustion: Dizziness, light-headedness, slurred speech, rapid pulse, confusion, fainting, fatigue, copious perspiration, cool skin that is sometimes pale and clammy, and nausea.

• Heat Stroke: Hot, dry, flushed skin; delirium, and coma (in some cases). Heat stroke is a life threatening event and requires immediate medical attention.

Heat stress monitoring will be performed when personnel wearing PPE, including Tyvek®-type coveralls and/or respirators, and the ambient air temperature exceeds 70 degrees Fahrenheit (°F).

If standard work garments (cotton jeans or coveralls) are worn, monitoring will be performed at 75°F with 55% humidity and higher, or at 85°F ambient air temperature regardless of humidity.

Heat stress monitoring will typically involve the following preventative procedures:

• Monitoring utilizing a Wet Bulb Globe Temperature (WBGT) instrument. If needed the WBGT can be obtained from local weather stations. As a last resort, EM 385-1-1 Section 6.J.05, Figure 6-1, the Approximate WBGT Temperature Chart, may be used to approximate the WBGT.

• Employees exposed to solar radiation with the potential for sunburn, should be encouraged to use sun screen with a sun protection factor (SPF) of 30 or greater, and should wear hats, long sleeve shirts, sunglasses, and other protective attire.

• Provide recovery areas where possible, such as air-conditioned enclosures, or shaded areas, with intermittent breaks and water breaks.

• Potable drinking water shall be available and employees are encouraged to frequently drink small amounts, (e.g., 1/2 cup every 15-20 minutes). The water shall be kept reasonably cool 50-60°F to encourage consumption.

• When possible, work should be scheduled for cooler periods during the day.

• Workers who have not previously worked in a hot environment or have had a previous heat-related injury, or are known to be on medication, shall acclimatize with a regimen of increasing exposure each day of work.

If a worker is required to wear semi-impermeable or impermeable clothing, then physiological monitoring shall be implemented to include heart rate and core body temperature monitoring. A standard of a sustained heart rate in excess of 180 beats per minute (BPM) minus the age of the worker in years, recovery heart rate at one minute after a peak work effort is greater than 120 BPM, or Monitoring of the core body temperature with a standard of greater than 100.4°F [38.0 degrees Celsius (°C)] for un-acclimatized workers, and 101.3°F (38.5°C) for acclimated workers shall be utilized. Workers exceeding the above standards are required to have work/rest regimens and fluid replacement schedules per Occupational Safety and Health Administration (OSHA) guidelines.

Heat stress can be prevented by resting frequently in a shaded area and consuming large quantities of fresh, potable water. Dilute electrolytic-replenishing beverages, such as Gatorade, may be used as a secondary source of fluid replacement. If heat exhaustion symptoms are observed, the affected individual will be required to rest in a shaded area and consume liquids until symptoms subside.

Immediate medical attention will be provided if symptoms persist or appear to worsen.

The victim will be cooled immediately and Emergency Medical Services (EMS) will be called if symptoms of heat stroke are observed. Workers will not hesitate to seek medical attention if heat stroke is suspected.

3.2.8.2 Cold Exposure

Protection against cold stress will be initiated when temperatures drop below 45°F. Exposure to cold working conditions can result in cold stress (hypothermia) and/or injury (frostbite) to hands, feet, and head. Hypothermia can result when the core body temperature drops below 96.8°F (36°C). Lower body temperature will be likely to result in dizziness, drowsiness, disorientation, slurred speech, or loss of consciousness, with possible fatal consequences. Pain in the extremities may be the first warning of danger from cold stress. Shivering develops when the body temperature falls to 95°F (35°C).

Hypothermia can be brought on by exposure to cold air, immersion in cold water, or a combination of both. The wind chill factor, which is the cooling power of moving air, is a critical factor in cold stress. Workers must wear adequate insulating clothing if work is performed in temperatures or wind chill could drop below 4°C (40°F). At temperatures of 2°C (35.6°F or less), workers whose clothing becomes wet will be provided immediately with a change of clothing and, if necessary, treated for hypothermia. Treatment includes warming the victim (with skin-to-skin contact or by providing warm blankets or other coverings) and providing warm liquids for the victim to drink.

Skin exposure will not be permitted at temperatures of -32°C (-25°F) or below.

If fine work is to be performed with bare hands for more than 10 to 20 minutes at temperatures below 16°C (60°F), provisions will be made for keeping the workers‟ hands warm. If equivalent chill temperatures fall below 40°F, and fine manual dexterity is not required, gloves will be worn.

Metal handles of tools will be covered with insulating material at air temperatures below -1°C (30°F). If work is to be performed continuously in the cold when the wind chill factor is at or below -7°C (19°F), heated warming shelters (tents, trailers, vehicle cabs) will be made available nearby.

3.2.9 Noise Hazards

Direct-push and sonic drilling equipment can be expected to produce continuous and impact noise at or above the action level of 85 decibels (dBA). Additional support equipment like generators, air compressors and concrete saws may also create a noise hazard. All personnel within 25 feet of operating equipment or near an operation that creates noise levels high enough to impair conversation will wear hearing protective devices (either muffs or plugs). Personnel will wash their hands prior to inserting earplugs to avoid ear infections. USACE field personnel shall participate in the USACE’s hazardous, toxic, and radioactive waste (HTRW) Medical Surveillance Program that includes baseline and annual audiograms.

Use of hearing protection is mandatory whenever powered equipment or other devices are used which produce sound levels over 85 dBA. Powered equipment generally will produce sound levels greater than 85 dBA.