MALTA ROCKET FUEL AREA SITE - semspub.epa.gov

ENVIROCLEAN-NORTHEASTMALTA ROCKET FUEL AREA SITE

WORK, SAFETY, HEALTH AND EMERGENCY RESPONSE PLAN

OCTOBER, 1994

Our mission is to Provide the Total Solution to Compressed Gas Problemswith a Commitment to Safety and Quality.

To:

ENVIROCLEAN-NORTHEAST

DISCLOSURE STATEMENT

This Work, Safety, Health and Emergency Response Plan includes datathat shall not be disclosed outside ENVIROCLEAN-NORTHEAST and shallnot be duplicated, used or disclosed - in whole or in part - for anypurpose other than to evaluate this plan. This restriction does not limitENVIROCLEAN-NORTHEAST's right to use information contained in thisdata if it is obtained from another source without restriction. The datasubject to this restriction are contained in all sheets of the Work, Safety,Health and Emergency Response Plan, including accompanying drawings.

Submitted by:t,'

EARTH RESOURCES CORPORATION1227 Marshall Farms Road

Ocoee, Florida 34761(407) 877-0877

i»»ue N*. i Work, Safety, Health, and Emergency Response PlanDate: October. 1994 EnviroClean-Northeast, Malta Rocket Fuel Area Site

PLAN APPROVAL

for

WORK, SAFETY, HEALTH & EMERGENCY RESPONSE PLAN

For Earth Resources Corporation:

Dan Nickens, Vice President

For EnviroClean-Northeast

'Use or disclosure of data contained on this sheet is subject to therestrictions on the title page of this Work, Safety, Health and Emergency Response Plan. '

FM #0219-94

i««u« t* 1 Work, Safety, Health, and Emergency Response PlanDate: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

TABLE OF CONTENTS

PAGESECTION 1.0 - PROJECT SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Section 1.1 - Site Description and Location . . . . . . . . . . . . . . . . . . . 1Section 1.2 - Contamination Pathways . . . . . . . . . . . . . . . . . . . . . . 1Section 1.3 - Project Objectives . . . . . . . . . . . . . . . . . . . . . . . . . . . 2Section 1.4 - Project Schedule . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

SECTION 2.0 - WORK TASKS AND PROCEDURES . . . . . . . . . . . . . . . . . . 7Section 2.1 - Preliminary Container Inspection and Evaluation . . . . . . 7Section 2.2 - Mobilization and Site Preparation . . . . . . . . . . . . . . . . 7Section 2.3 - Large Container Sampling Operations (with operable

valve(s)) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9Section 2.4 - Large Container Sampling Operations (without operable

valves) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11Section 2.5 - CRV Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11Section 2.6 - On-Site Treatment . . . . . . . . . . . . . . . . . . . . . . . . . . 12

Section 2.6.1 - Controlled Venting . . . . . . . . . . . . . . . . . . . . 13Section 2.6.2 - Absorption/Reaction (Wet Scrubbing) . . . . . . . 13Section 2.6.3 - Adsorption . . . . . . . . . . . . . . . . . . . . . . . . . . 14

Section 2.7 - Demobilization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

SECTION 3.0 - SAFETY AND HAZARD ANALYSIS . . . . . . . . . . . . . . . . . . 20Section 3.1 - Anticipated Hazards . . . . . . . . . . . . . . . . . . . . . . . . . 20Section 3.2 - Identified Hazards by Task . . . . . . . . . . . . . . . . . . . . . 22

Section 3.2.1 - Hazards Associated with Mobilization . . . . . . . 22Section 3.2.2 - Hazards Associated with Inspection and

Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . 22Section 3.2.3 - Hazards Associated with Sampling . . . . . . . . . 23Section 3.2.4 - Hazards Associated with Laboratory Analysis . . 23Section 3.2.5 - Hazards Associated with Transportation . . . . . 24Section 3.2.6 - Hazards Associated with Treatment . . . . . . . . 24Section 3.2.7 - Hazards Associated with Cylinder

Decommissioning . . . . . . . . . . . . . . . . . . . . 25Section 3.2.8 - Hazards Associated with Demobilization . . . . . 25Section 3.2.9 - Hisprical Incidents Involving Boranes . . . . . . . 25

Section 3.3 - Safety Engineering Controls . . . . . . . . . . . . . . . . . . . . 25

'Use or disclosure of data contained on this sheet is subject to therestrictions on the title page of this Work, Safety, Health and Emergency Response Plan.

i««ue N* 1 Work, Safety, Health, and Emergency Response PlanD.t.: October. 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

TABLE OF CONTENTS (CONTINUED)

PAGESECTION 4.0 - SITE CONTROL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

Section 4.1 - Work Zones . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29Section 4.2 - Buddy System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30Section 4.3 - Communication . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30Section 4.4 - Site Security . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

SECTION 5.0 - PERSONAL PROTECTIVE EQUIPMENT . . . . . . . . . . . . . . . . 32Section 5.1 - Selection Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . 32Section 5.2 - PPE Requirements by Task . . . . . . . . . . . . . . . . . . . . . 33

Section 5.2.1 - Mobilization and Demobilization . . . . . . . . . . . 33Section 5.2.2 - Cylinder Sampling Operations . . . . . . . . . . . . . 34

Section 5.3 - Use and Limitations . . . . . . . . . . . . . . . . . . . . . . . . . 34Section 5.4 - Maintenance and Storage . . . . . . . . . . . . . . . . . . . . . 34Section 5.5 - Decontamination and Disposal . . . . . . . . . . . . . . . . . . 34Section 5.6 - Training and Fitting . . . . . . . . . . . . . . . . . . . . . . . . . . 35Section 5.7 - Donning and Doffing Procedures . . . . . . . . . . . . . . . . . 35Section 5.8 - Inspection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35Section 5.9 - Effectiveness Evaluation . . . . . . . . . . . . . . . . . . . . . . 35

SECTION 6.0 - TRAINING REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . 40Section 6.1 - General Requirements . . . . . . . . . . . . . . . . . . . . . . . . 40Section 6.2 - Initial Safety Briefing . . . . . . . . . . . . . . . . . . . . . . . . . 42Section 6.3 - Daily and Periodic Training . . . . . . . . . . . . . . . . . . . . . 42

SECTION 7.0 - MEDICAL AND PERSONNEL MONITORING . . . . . . . . . . . . . 43Section 7.1 - Medical Monitoring Requirements . . . . . . . . . . . . . . . . 43Section 7.2 - Temperature Stress Monitoring . . . . . . . . . . . . . . . . . . 44Section 7.3 - Exposure Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . 46

SECTION 8.0 - AIR MONITORING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47Section 8.1 - Sampling Techniques and Instrumentation . . . . . . . . . . 47Section 8.2 - Sampling Types and Frequency . . . . . . . . . . . . . . . . . 49Section 8.3 - Equipment Calibration . . . . . . . . . . . . . . . . . . . . . . . . 49

SECTION 9.0 - DECONTAMINATION PROCEDURES ' . . . . . . . . . . . . . . . . . 50

'Use or disclosure of data contained on this sheet is subject to therestrictions on the title page of this Work, Safety, Health and Emergency Response Plan.'

FM *0219-94

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i«»ue N* 1 Work, Safety, Health, and Emergency Response PlanDate: October. 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

TABLE OF CONTENTS (CONTINUED)

PAGESECTION 10.0 - CONFINED SPACE ENTRY . . . . . . . . . . . . . . . . . . . . . . . 52

SECTION 11.0 - SPILL CONTAINMENT . . . . . . . . . . . . . . . . . . . . . . . . . . 53Section 11.1 - Spill Scenarios . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53

Section 11.1.1 - Release of Gas or Vapors . . . . . . . . . . . . . . . 53Section 11.1.2 - Liquid Spills . . . . . . . . . . . . . . . . . . . . . . . . 54Section 11.1.3 - Solid Spills . . . . . . . . . . . . . . . . . . . . . . . . . 54

Section 11.2- Spill Response . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55

SECTION 12.0 - EMERGENCY RESPONSE . . . . . . . . . . . . . . . . . . . . . . . . 57Section 12.1 - Emergency Medical Assistance and First Aid . . . . . . . 57Section 12.2 - Explosion or Fire . . . . . . . . . . . . . . . . . . . . . . . . . . . 58Section 12.3 - Pre-emergency Planning and Coordination . . . . . . . . . 59Section 12.4 - Personnel Responsibilities . . . . . . . . . . . . . . . . . . . . 59Section 12.5 - Communication and Notifications . . . . . . . . . . . . . . . 60Section 12.6 - Emergency Recognition and Prevention . . . . . . . . . . . 61Section 12.7 - Safe Refuge Locations . . . . . . . . . . . . . . . . . . . . . . . 62Section 12.8 - Evacuation Routes and Procedures . . . . . . . . . . . . . . 62Section 12.9 - Emergency Decontamination . . . . . . . . . . . . . . . . . . 62Section 12.10 - Emergency Training and Rehearsal . . . . . . . . . . . . . 63Section 12.11 - Emergency PPE and Equipment . . . . . . . . . . . . . . . . 63Section 12.12 - Response Review and Follow-up . . . . . . . . . . . . . . . 63

SECTION 13.0 - PROJECT ORGANIZATION . . . . . . . . . . . . . . . . . . . . . . . 65Section 13.1 - General Organization . . . . . . . . . . . . . . . . . . . . . . . . 65Section 13.2 - Safety Administration . . . . . . . . . . . . . . . . . . . . . . . 66Section 13.3 - Project Data and Files . . . . . . . . . . . . . . . . . . . . . . . 67

SECTION 14.0 - GENERAL SAFETY PROVISIONS . . . . . . . . . . . . . . . . . . . 70Section 14.1 - General Cylinder Handling Precautions . . . . . . . . . . . . 70Section 14.2 - Safe Work Practices and Personal Hygiene . . . . . . . . . 70Section 14.3 - Facility Work Requirements . . . . . . . . . . . . . . . . . . . 71

SECTION 15.0 REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72


FM 90219-94 jjj

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Work, Safety, Health, and Emergency Response PlanEnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

TABLES

PAGE

TABLE 5.1 Chemical Resistance of Suit . . . . . . . . . . . . . . . . . . . . . . 36TABLE 5.2 Resistance to Chemicals of Common Glove Materials . . . . . 37TABLE 7.1 Required Frequency of Physiological Monitoring . . . . . . . . . 46

FIGURES

FIGURE 1.1 Site Map . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6FIGURE 2.1 Proposed Site Layout . . . . . . . . . . . . . . . . . . . . . . . . . . . 17FIGURE 2.2 LCTU . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18FIGURE 2.3 Cylinder Recovery Vessel . . . . . . . . . . . . . . . . . . . . . . . . 19FIGURE 5.1 Level A Donning/Doffing Procedures . . . . . . . . . . . . . . . . . 39FIGURE 12.1 Route to Nearest Hospital . . . . . . . . . . . . . . . . . . . 64FIGURE 13.1 Project Organization . . . . . . . . . . . . . . . . . . . . . . . 69

APPENDIX AAPPENDIX BAPPENDIX CAPPENDIX DAPPENDIX E

APPENDICES

Chemical Hazard Plan for Laboratory AnalysisProject QA/QC FormsThe Malta Rocket Fuel Area Site Health and Safety PlanPentaborane Treatment MethodologyHistorical Incidents Involving Boranes

"Use or disclosure of data contained on this sheet is subject to therestrictions on the title page of this Work, Safety, Health and Emergency Response Plan. *

FM 90219-94 IV

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issue M*: i Work, Safety, Health, and Emergency Response PlanDate: October. 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

SECTION 1.0 - PROJECT SUMMARY

EnviroClean-Northeast has been contracted to dispose of two waste compressed gascontainers. The work includes identification and on-site treatment of the cylindercontents. The work is to be completed in accordance with this Work Plan.

Operations will include identification of cylinder contents, followed by on-sitetreatment. Residual wastes will be identified and staged for appropriate disposal. Allwork will be completed in accordance with applicable State and Federal requirements.

This Work, Safety, Health and Emergency Response Plan describes the site-specificwork to be completed by ERG. All work will be conducted as specified by theapproved project plan. Applicable safety guidelines of a general nature may be foundin ERC's Corporate Health and Safety Manual.

The work will also be governed by a Quality Assurance and Quality Control Plan.General quality control programs of the company are contained in ERC's GenericQuality Assurance Plan.

Section 1.1 - Site Description and Location

The work will be completed at the Malta Rocket Fuel Area Site located in Malta, NewYork.

The subject cylinders that will be sampled, analyzed, treated and disposed of arelocated at two separate areas of the site. ERC's equipment will be set-up in closeproximity to the containers. The equipment will include the Cylinder Recovery Vessel(CRV), the Large Cylinder Transfer Unit (LCTU), a Mobile Laboratory, and a VaporContainment Structure.

Section 1.2 - Contamination Pathways

Some liquid and solid hazardous materials will be handled during operations. Liquidsinclude treatment reagents (acids, caustics or oxidizing solutions). Solid adsorbentsmay be used for some treatment processes (activated carbon, alumina, and molecularsieve adsorbents).

Liquids or solids could inadvertently enter the environment though spillage. Becauseof this possibility, all operations will occur on level areas of the site and all hazardousreagents will be stored in areas with secondary containment.

301497'Use or disclosure of data contained on this sheet is subject to the

restrictions on the title page of this Work, Safety, Health and Emergency Response Plan. "FM #0219-94

i«ue M* 1 Work, Safety, Health, and Emergency Response PlanDate: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

Section 1.3 - Project Objectives

This plan generally describes tasks and operating procedures that will be used duringthe cylinder decommissioning operations at the Malta Rocket Fuel Area Site. Theseprocedures are designed to: 1) provide for the safety of personnel working at the site;2) provide for the safety of off-site personnel and the surrounding communityregarding activities occurring during site operations; and 3) minimize the potential forenvironmental degradation caused by the site operations.

The purpose of this work is to properly identify and dispose of two waste compressedgas containers. This will be accomplished by identification or confirmation of cylindercontents, followed by off-site disposal.

As an initial task, both cylinders will be individually inspected. Data obtained from theinspection will be used in subsequent phases of the work.

Gas samples will be analyzed on site using ERC's mobile laboratory. The samples willbe identified using a mass spectrometer (MS) and/or a Fourier Transform Infraredspectrometer (FTIR).

Following identification of the cylinder contents, treatment will be performed, in theLCTU. Generally the gases will be reacted with reagents or adsorbed on solid media.If treatment cannot be effectively completed, the cylinder contents will berecontainerized into an appropriate D.O.T. specification container.

Health and Safety procedures are detailed in this plan for preventing accidents,protecting personnel from injury and illness, identifying specific hazards, and safecompletion of compressed gas cylinder processing.

Quality control is an important aspect of this project. A separate Quality Assuranceand Quality Control Plan describes procedures to be followed to successfully completethe project.

This plan incorporates, and is intended to comply with all applicable federal regulationsincluding:

29 CFR 1910.119 - Process Safety

29 CFR 1910.120 - OSHA Protection of Hazardous Waste Site Workers

29 CFR 1910.1000 - Tables Z-1-A, Z-2, and Z-3 (Air Contaminants);

29 CFR 1920 - Written Hazard Communication Program(Right To Know Regulations)(OSHA); OA1 Aftft


FM 90219-94 2

N* 1 Work, Safety. Health, and Emergency Response PlanDat.: October. 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

29 CFR 1910.134 - Respiratory Protection;

29 CFR 1910.120 (i) - Respirator Fit Testing;

29 CFR 1910.135 - Head Protection;

29 CFR 1910.133 (a) - Eye and Face Protection;

29 CFR 1910.95 - Noise Exposure;

29 CFR 1910.136 - Foot Protection;

29 CFR 1910.137 - Electrical Protective Devices;

49 CFR 172.101 - Hazardous Materials Tables;

49 CFR 173 - Flammable and Combustible Liquids;Subpart D

49 CFR 390 - Federal Motor Carrier Safety Regulations; and

49 CFR 391 - Driver Qualifications.

In addition to the requirements of this plan, all ERG personnel will abide by the MaltaRocket Fuel Area Site's general safety and health policies.

Section 1.4 - Project Schedule

The project is scheduled to be completed in a safe and expeditious manner. Once theSafety and Work Plan has been approved, ERG will begin to mobilize the necessarypersonnel and equipment. This should take approximately two (2) to four (4) days.On-site operations will be scheduled upon approval of project plans.

The following tasks associated with the management of the waste compressed gasand liquid containers at the Malta Rocket Fuel Area Site have been identified:

Task 1: Mobilization

The ERG cylinder treatment team will mobilize to the site upon completion andapproval of the Work Plan.


restrictions on the title page of this Work, Safety, Health and Emergency Response Plan. 'FM 10219-34

i««u« N* i Work, Safety, Health, and Emergency Response PlanDat.: October. 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

Site preparation will begin immediately upon the arrival of equipment and personnel.During this period, equipment will be staged and preparations completed for the opera-tional phase. A site safety meeting will be held immediately before on-site activitiesbegin.

The evaluation and set-up will take approximately one week at the Malta Rocket FuelArea Site. A project orientation and safety meeting will be held once the site set-upis complete. Plans and requirements will be discussed with all project personnel.Special emphasis will be given to safety requirements and procedures.

Immediately following the meeting, procedures applicable to the work will bedemonstrated using on-site equipment. The proper operation of all equipment will beconfirmed. Any modifications and repairs resulting from the operational checks willbe completed before undertaking operations.

Task 2: Pre-Project Meeting

Prior to the initiation of cylinder transport and treatment activities, EnviroClean-Northeast will conduct a pre-project meeting with ERG personnel and appropriatelocal, state, and federal regulatory personnel.

Task 3: Cylinder Sampling and Treatment

Sampling and treatment of the cylinder contents and decontamination and destructionof the empty container will be conducted serially. After the content of each containeris determined by analysis in ERC's mobile laboratory appropriate treatmentmethodologies will be selected. Once treatment of the containers is complete, theresidual wastes will be containerized.

Task 4: Sampling and Analysis of Residual Wastes

Samples of the residual wastes will be collected and analyzed at an off-site contractlaboratory, as appropriate, prior to shipment to an authorized off-site treatment and/ordisposal facility. This task will be completed by ERG.

Task 5: Demobilization

Upon completion of the treatment activities, ERG will dismantle their equipment anddemobilize from the site.

Decontamination and demobilization require about the same time frame as set-up. Itis anticipated that this can be accomplished in less than one (1) week.


FM10219-94 A

n»: 1 Work, Safety, Health, and Emergency Response PlanDate: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

Task 6: Disposition of Residual Wastes

Once an appropriate waste determination has been made for each residual waste thewastes will be transported off-site by an authorized waste hauler for treatment and/ordisposal. The scrap metal resulting form destruction of the empty cylinders will berecycled. This task will be managed by EnviroClean through contractors other thanERG.

Task 7: Final Project Report

Upon completion of the aforementioned tasks, ERG will prepare a final report detailingall project activities. The report will include summaries of the analytical data obtainedduring the project, documentation of all hazardous waste determination activities,treatment methodologies for each container, a summary of the air emissions data foreach chemical identified, and disposition of the residual waste materials.


restrictions on the title page of this Work, Safety, Health and Emergency Response Plan. 'FM 90219-94

M* 1 Work, Safety, Health, and Emergency Response PlanOctober. 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

FIGURE 1.1

SITE MAP - Malta Rocket Fuel Area Site

>i M-19[J H UONI7OKING K€U LOCATION AND ID/

|f 11S/HD?, B MONITORING YfLL PAIR LOCATION AND K

\ LEGEND

U-28S/J8I D ^Vjq

TRIANGULAR

PARCa'MW-I/HO

800'

1f oÂMAGAZINE

301502*6/s« or disclosure of data contained on this sheet is subject to the

restrictions on the title page of this Work. Safety. Health and Emergency Response Plan. 'FM #0219-94

i* i Work, Safety, Health, and Emergency Response PlanOau: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

SECTION 2.0 - WORK TASKS AND PROCEDURES

Section 2.1 - Preliminary Container Inspection and Evaluation

The two containers will be individually inspected by ERC personnel.

The inspection will compare cylinder external markings with the cylinder and valvetype. They will also evaluate cylinder condition for stability during handling andtransportation to the process facility.

Where possible, the serial number will be recorded. A project identification numberwill also be assigned and the container will be labeled accordingly.

Section 2.2 - Mobilization and Site Preparation

Mobilization of personnel and equipment to the site and initial preparation foroperations will begin upon approval of project plans.

Specialized equipment is required for some site operations. This equipment includesthe CRV, the LCTU, the analytical laboratory, personnel protective equipment, andmonitoring and analytical equipment. Most of the equipment will be mobilized fromEarth Resources Corporation's Florida office.

Major equipment items which may be required for site operations provided by ERC arelisted below:

LCTU and associated equipment;Vapor Containment StructureMobile analytical equipment (MS and FTIR);Communications equipment;Cylinder handling equipment;Cylinder overpack;Air monitoring equipment;Decontamination station;CRV and associated equipment;Breathing air equipment;Personnel protection equipment;Office and administrative equipment;Miscellaneous hand and power tools; andSupport vehicles.

Other equipment will be available for various contingencies.

3^1503'Use or disclosure of data contained on this sheet is subject to the

restrictions on the title page of this Work, Safety, Health and Emergency Response Plan. 'FM 90219-94 7

ta«u« M* i Work, Safety, Health, and Emergency Response PlanDat.-. October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

Experienced, trained personnel will also be mobilized to the site. Expected projectpersonnel requirements are described in Section 13 of this plan.

Power will be required for each of the major equipment components. This will beprovided by portable generators. Water will be provided in portable tank(s).

Sanitary facilities will be provided on-site.

Site security is afforded by existing fencing and security procedures. Entry and exitfrom ERG facilities will be monitored by site personnel.

An emergency shower will be established near the contamination reduction corridor.

A mobile, cellular telephone will be available at ERC's command trailer.

Upon arrival at the site, an initial survey will be accomplished by ERC's Site Manager(SM) with the designated EnviroClean-Northeast representative. Based on this survey,specific staging areas will be located for equipment. A preliminary proposed sitelayout is shown in Figure 2.1.

The SM and Site Safety Officer will determine the level of protection to be requiredfor pre-operation activities. It is anticipated that Level D will be used as a minimumfor on-site activities. Level A or B is generally required for waste cylindermanagement operations.

After the initial survey, a task initiation meeting will be convened at the site. Themeeting will serve to familiarize all personnel with the project plans. Safetyprocedures will be emphasized.

Support facilities required for the operation will be staged outside of the cylinderprocessing area. Figure 2.1 shows a typical site layout for LCTU, CRV, VCS, andmobil laboratory. Equipment and materials will be neatly stored in support vehiclesuntil they are required on site.

The mobile laboratory and the LCTU are contained in separate vehicles. The lab vanis less than twenty feet (20') long and the LCTU and CRV are each forty feet (40')long by eight feet (8') wide. The vehicles can easily be arranged to meet siterequirements.

A temporary Vapor Containment Structure (VCS) will be constructed. This buildingconsists of an aluminum frame covered with a polyethylene fabric. It is intended toretard the off-site movement of hazardous gases in the event of a release. Anemergency dry adsorbent system will be interfaced with the VCS.


restrictions on the title page of this Work, Safety, Health and Emergency Response Plan. *FM 10219-94 8

k«u« » 1 Work, Safety, Health, and Emergency Response PlanDat«: October. 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

A meteorological station will be set up prior to operations. This station monitors winddirection, speed, temperature and humidity.

After all equipment and facilities have been established on site, task procedures willbe demonstrated. The demonstration will cover all major processing components. Allprocedures, including emergency response procedures, will be periodicallyimplemented on a test basis.

Immediately following the demonstration, a meeting will be convened to evaluate theresults. Any deficiencies will be noted and corrected before operations begin. Anyproposed modification to procedures will also be reviewed.

Section 2.3 - Large Container Sampling Operations (with operable valve(s))

After equipment has been set up, chemical information pertaining to the suspectedcontainer contents will be reviewed with all operations personnel. Appropriateemergency handling procedures will also be reviewed.

Sampling will be accomplished inside the LCTU. The unit provides a method oftreating gases in the event of a leak during operations (see Figure 2.2, Large CylinderTransfer Unit (LCTU).

The Large Cylinder Transfer Unit (LCTU) is housed in a standard seabox. It hasdimensions of approximately forty feet (40') long, eight feet (8') wide, and thirteenfeet (13') high.

A Vapor Containment Structure is attached to the LCTU.

An emergency adsorption system is attached to the VCS. It consists of molecularsieve and carbon adsorption units.

The control room containing the LCTU remote sampling system is isolated frompersonnel by a % "-steel barrier.

Comprehensive procedures have been developed for ERC's large container samplingoperations. These procedures are described in equipment manuals maintained foreach processing unit. Copies of these manuals shall be maintained on site during alloperations involving the units.

The general valve sampling procedure is as follows:

Position and secure container, in Sampling Chamber;Remove dome cap and dust cap (if applicable);Verify valves are in the fully closed position; 3^1505


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i««ue t* 1 Work, Safety, Health, and Emergency Response PlanDate: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

Verify packing nut is tight;Attach sampling assembly;Attach remotely operated valve opener;Evacuate sample lines;Fill sample lines to above atmosphericpressure with inert gas and soap check allconnections to verify no leaks;Evacuate lines again and wait 60 seconds to verifypressure stability;Open cylinder valve - note pressure reading onregulator gauge through the camera system;Open sample line and take sample (sample to be at< 1 atmosphere pressure);Close sample line;Close cylinder valve;Evacuate sample lines and wait 30 seconds to verify pressurestability;Purge and evacuate sample line two (2)additional times (leaving 1 atmosphere of inertgas in line); andRemove cylinder and stage.

A secondary valve is attached to the target cylinder. This provides a backup meansfor closing the cylinder should the cylinder valve fail.

Once sampled, the cylinders will be staged in an appropriate area and made ready fortreatment and disposal.

Samples obtained will be analyzed in the ERC's mobile laboratory using massspectroscopy and/or infrared analysis equipment. Identification is expected to takeno more than five to ten minutes for a library analysis. During this time, the samplelines will be purged with inert gas and discharged through a dry scrubber. After thecontents have been identified, the cylinder will be marked with the name of thecontents. Identification will also be noted on the cylinder log.

The cylinder will then be relocated to staging areas according to the findings anddisposal methods available for the product identified. Each cylinder will be labeledfollowing identification. A cylinder label will be attached directly to the cylinder (seeAppendix B, Form 6). This will provide general content information.


restrictions on the title page of this Work, Safety, Health and Emergency Response Plan. "FM 90219-94 10

i«iu« tf. i Work, Safety, Health, and Emergency Response PlanDat.: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

Section 2.4 - Large Container Sampling Operations (without operable valves)

Large containers with inoperable valves may be sampled inside the LCTU using aremotely operated tapping device. The device is banded to the container and sealintegrity is checked at, or greater than, container working pressure. When a gas tightseal is confirmed, the container is pierced and a sample is withdrawn for identificationin the on-site laboratory. Once the contents are identified, the material is processedas in Section 2.3 above.

Section 2.5 - C R V Operations

A Cylinder Recovery Vessel (CRV) is used for sampling cylinders in poor conditionor with inoperable valves. It is based on providing an inert atmosphere for releasingand containing the cylinder contents in a remote operation.

The CRV is an ASME-coded vessel which provides containment for the gases.Principal components are shown in Figure 2.4. It is housed inside a secondarycontainment chamber.

After a cylinder is properly positioned within the CRV the CRV hatch is closed. Thetechnicians exit the secondary containment chamber and enter the Vapor ContainmentStructure. From within the Vapor Containment Structure, they seal the rear outerdoor of the CRV Trailer. The technicians and other personnel then exit the VaporContainment Structure and assemble in the support area during cylinder processingoperations.

Cylinder processing will be handled by the Site Manager from a remote location.

Detailed operating procedures have been developed for the CRV. These are describedin operating handbooks (Equipment Manuals) developed for each unit. Generaloperating procedures for the cylinder processing are as follows:

Remove air from the CRV; verify integrity ofsystem by monitoring for pressure increase;Recharge CRV with nitrogen to slightly greaterthan atmospheric and pressure monitor forpressure decay;Pierce cylinder;Record pressure and temperature;Sample gases in CRV, analyze;Recontainerize or dispose of gas;Induce vacuum in CRV;Purge system with nitrogen; - .,.. _r Ôpen vent; ^ J '' '

"Use or disclosure of data contained on this sheet is sub/ect to therestrictions on the title page of this Work, Safety, Health and Emergency Response Plan.'

FM*0219-94 11

u«ua N* 1 Work, Safety, Health, and Emergency Response PlanDate: October. 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

Monitor atmosphere inside containment chamber forcontaminants; andEnter chamber, open CRV and remove empty cylinder.

Included in the operation are controls to verify the functioning of the equipment. Theentire operation is monitored by a closed circuit video system. Pressure andtemperature are monitored at numerous points in the process system. These systemsallow the operator to effectively control the process.

After contents of the cylinder are released into the CRV a sample may be withdrawnthrough a sampling port extending to the exterior of the CRV. An evacuated samplevessel attached to the port is opened to permit a small volume of sample to enter.This vessel is removed and transported by a technician to the on-site laboratory forimmediate analysis. Only after analysis is completed do further operations proceed.

Most compressed materials can be handled in the gaseous phase. The system can,however, accommodate liquid withdrawal. To facilitate liquid removal, the CRV isequipped with a liquid withdrawal system.

The CRV system includes equipment for recontainerization of cylinder contents.Ordinarily this system is used only where the contents are extremely valuable orcannot be effectively treated on site.

When cylinder processing has been completed, the open cylinder is removed from thechamber. The cylinder is inspected to verify that it is empty. The cylinder is removedfrom the CRV into the outer containment chamber.

The cylinder is then cut in half. The remains of the cylinder will be containerized andstaged for disposal.

Section 2.6 • On-Site Treatment

Many gases may be safely treated and rendered innocuous by simple processes.Additionally, by changing the state from gaseous to solid or liquid, many morecommercial disposal options are available.

Upon identification of the cylinder contents, multiple on-site processing options willbe available. Possible options include recontainerization of the contents, controlledventing to the atmosphere, adsorption, combustion or absorption/reaction via wetscrubbing. These options may also be used in combination.



i««u« N* i Work, Safety, Health, and Emergency Response PlanOctober. 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

The selected option is principally dependent upon the nature of the contents.Appendix D describes the hydrolysis for pentaborane.

As a back-up to the treatment systems, the CRV Trailer can be used to recontainerizeany of the material in the improbable event a gas is found that may not be effectivelytreated.

Section 2.6.1 - Controlled Venting

Controlled venting of the contents is a treatment option suitable for inert or innocuousmaterials. Typically these are common components of air. These atmospheric gasesinclude air, argon, carbon dioxide, helium, neon, and nitrogen. The primary hazardassociated with these gases is concentration in a confined area. Controlled andmonitored venting will permit these to be released without further processing inaccordance with local, state and federal regulations.

Section 2.6.2 - Absorption/Reaction (Wet Scrubbing)

Reactive gases may be rendered innocuous by absorption/reaction with an appropriatereagent in wet-scrubbing units. The source gas is fed directly into the absorbentliquor for disposal. Under certain circumstances, liquefied gas can be fed into thescrubber in the liquid phase. This method is employed where an absorbent liquor isavailable which strongly and readily reacts with the gas.

The nature of the residual scrubber liquor is dependent upon the original liquor, theprocess gas and relative concentrations. The waste liquor will be containerized insuitable drums for off-site disposal in accordance with applicable regulations.

Monitoring for the specific waste compound will be done inside the gas tightcontainment chamber housing the treatment systems. After analyses indicate that thetreatment process is complete, the next cylinder can be processed.

The scrubber breakthrough testing procedures are as follows:

1. The results of the analysis of the source cylinder contents will dictate both theproper absorbent reagents for absorption treatment and the method to beemployed in determining whether breakthrough has occurred. If the scrubberexit gases can be analyzed via gas-specific indicator tubes, such as thosemanufactured by Draeger or Sensidyne, then these instruments will beemployed. If the correct gas-specific indicator tube is unavailable, then aphotoionization detector unit may be used.

301509"Use or disclosure of data contained on this sheet is subject to the

restrictions on the title page of this Work, Safety. Health and Emergency Response Plan. 'FM 10219-94 -J3

NT. 1 Work, Safety, Health, and Emergency Response PlanDate: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

2. With determinations having been made for the type of absorbent and methodof analysis of exit gases, source gases will be introduced into the scrubberunder regulated pressure.

3. Exit gases will be analyzed at least once every twenty minutes and the resultsrecorded in the site log book. Indicator tubes will be used at the vent stackand samples for MS or FTIR analysis will be taken from a sample port locatednear the receiving vessels. Samples may be taken more frequently if, forexample, pressure changes occur in the scrubber.

4. When breakthrough is detected, the batch treatment process will besuspended or the gas redirected to a different unit.

5. Spent absorbent will be containerized for off-site disposal in accordance withall applicable hazardous and solid waste regulations.

6. The spent absorbent will be replaced with virgin material, and the date andtime will be noted in the site log book. The absorption process will berestarted.

The acid and base gas scrubbers will have continuous pH monitoring and recording.The pH data will be retained with the other project records as prescribed in the projectQuality Assurance and Quality Control Plan (QA/QC Plan). Sampling, calibration, andmonitor operating procedures associated with the measurement of pH can also befound in the QA/QC Plan.

Section 2.6.3 - Adsorption

Adsorption offers a viable alternative for safely treating certain gases. This processinvolves exposing the gas to a suitable solid media. The gas is adsorbed andstabilized on the media. Since the material is no longer in a gaseous state, many morecommercial disposal options are available.

Eighty-five (85)-gallon canisters will be available for gas adsorption. These canisterscan be charged with any of a number of adsorption media depending upon the exactcomposition of the waste gas {zeolite, alumina, activated carbon, etc.). If a gas isencountered which can be stabilized and adsorbed onto this media, a regulated flowthrough this system will be initiated. After adsorption has been completed, the spentadsorbent will be transferred to fiber drums. These drums will be overpacked in metalfifty-five (55)-gallon drums pending off-site disposal at a permitted facility.



te*u« N* 1 Work, Safety, Health, and Emergency Response PlanDate: October. 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

The adsorption bed testing procedures are essentially the same as for the absorbersas follows:

1. The results of the analysis of the source cylinder contents will dictate both theproper solid media for adsorption treatment and the method to be employedin determining whether breakthrough has occurred. If the adsorber exit gasescan be analyzed via gas-specific indicator tubes, such as those manufacturedby Draeger or Sensidyne, then these instruments will be employed.Alternatively, a survey instrument (such as a photoionization detector) may beused.

2. With determinations having been made for the type of adsorbent and methodof analysis of exit gases, source gases will be introduced into the solid mediaadsorber under regulated pressure.

3. Exit gases will be analyzed at least once every twenty minutes where theexhaust port enters the containment area. Samples may be taken morefrequently if, for example, pressure changes occur in the absorber bed.

4. When breakthrough is detected, the process gas source will be shut off andthe untreated exit gases will be directed into the secondary adsorbent trap.The occurrence of the breakthrough will be recorded in the site log book.

5. Spent adsorbent will be containerized for off-site disposal in accordance withall applicable hazardous and solid waste regulations.

6. The spent adsorbent will be replaced with virgin material and the date andtime will be noted in the site log book. The adsorption process will berestarted beginning with the treatment of breakthrough gases in the receivingvessels.

Section 2.7 - Demobilization

With completion of the sampling, treatment and recovery activities, demobilization canbe initiated. Objectives of demobilization include restoration of site conditions andremoval of equipment and personnel.

Empty cylinders will be prepared for disposal or recycling. Each processed cylinderwill have its valve removed or will be cut into halves. The interior of each cylinder willbe rinsed with an appropriate reagent.


restrictions on the title page of this Work, Safety, Health and Emergency Response Plan. *FM »'0219-94 T5

N*. 1 Work, Safety, Health, and Emergency Response PlanData: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

Very little adhering contamination will remain as a result of operations involvingcompressed gases. Decontamination procedures will be followed, however, indemobilizing equipment which is exposed to nonvolatile contaminants. Wherenecessary, contaminated equipment will be cleaned using a high pressure, hot watercleaner. The purpose is to remove any residue of site activities from equipment.

The CRV and its trailer will be thoroughly cleaned prior to removal from the site.Cleaning of the CRV itself will occur between each operation with appropriate purgingor rinsing. Any rinse liquids will be collected, drummed, labelled, and staged on sitefor subsequent analysis and disposal.

In conjunction with the removal of personnel and equipment, final data submissionand reports will be completed. This task may extend beyond site close-out activitiesby several weeks.

Data submitted at the conclusion of the project will consist of field logs and laboratoryanalyses. These will include the following:

Site Access Logs;Meteorological Data;Air Monitoring Data;QA/QC Logs;Operation Logs;Cylinder Inventory List;Waste Inventory List;Content Identification Analyses;Project Photographs; andSite Safety Data.

A summary report will also be prepared describing site operations and results.



M* 1 Work, Safety, Health, and Emergency Response PlanD.ta: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

FIGURE 2.1

PROPOSED SITE LAYOUT(to be inserted at a later date)



M* i Work, Safety, Health, and Emergency Response PlanD«u: October. 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

FIGURE 2.2

LARGE CYLINDER TRANSFER UNIT

Vapor ContainmentStructure Double Door

Air Tight Sealed Hatch

Source Cylinder

• EmergencyTreatmentSystem

CausticScrubber

Air TightBulkheadwith Door

CirculationPump

N2 Purge Gas

Control Room Door -Air Compressor -

ControlRoom

FM §0213-94

'Use or disclosure of data contained on this sheet is subject to th»restrictions on the title paga of this Work, Safety, Health and Emergency Response Plan. *

3^1514

18

»* i Work, Safety, Health, and Emergency Response PlanD«u: October. 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

AIRTIGHT

SEALEDHATCH

' uir i '.. ' GATE /N, \,X s'

FIGURE 2.3

CYLINDER RECOVERY VESSEL (CRV)

VAPORCONTAINMENT

STRUCTURE

CRV(ASME PRESSURE

VESSEL)

LECTUREBOTTLE

CRV

HYDRAULIC POWER& CONTROL SYSTEM

COMMANDVEHICLE

MONITORS

EMERGENCYTREATMENT

UNIT

COMPRESSOR REMOTECONTROL

PANELSECONDARY

CONTAINMENTCHAMBER

Non-transportable CylindersCylinders with Inoperable Valves

• Cylinder Recovery Vessel• Valve Sampling System

"Use or disclosure of dels contained on this sheet is subject to therestrictions on the title page of this Work, Ssfety, HteJth end Emergency Response Ptun.'

FM 102! 9-94

30151519

i««u« tr. i Work, Safety, Health, and Emergency Response PlanD«t.: October. 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

SECTION 3.0 - SAFETY AND HAZARD ANALYSIS

Section 3.1 - Anticipated Hazards

The following hazard assessment has been performed to define, identify, and evaluatethe potential on-site hazards, and their impact on personnel and the project. As adirect result of the assessment, criteria have been established for the proper PersonalProtective Equipment and safety procedures to be used on site. The equipment andprocedures selected for this project represents the most conservative approach(ALARA principle - As Low As Reasonably Achievable) to safe-guarding on-siteemployees and the surrounding environment.

General Gas Hazard Description: Management of waste compressed gas cylinderspose special hazards which are peculiar to these materials. The potential hazardsinclude all those which are associated with other chemical wastes. In addition, thereare hazards associated with the energy of compression and from the mobility of thematerials when released.

Pressurization of the waste receptacle creates a potential hazard even for otherwiseinert gases. A typical cylinder pressurized to two thousand pounds-per-square-inch(2,000 psi) contains energy equivalent to about one and a half pounds of TNT. Failureof the cylinder or valve can create projectiles capable of creating serious injuries andproperty damage.

Cylinder leakage into a confined or enclosed space can create a potential asphyxiationhazard through dilution or displacement of breathable oxygen. Special respiratoryprotection must be worn by personnel when the oxygen content of a work area is lessthan 19.5 percent.

Extremely toxic gases are commonly stored in compressed gas cylinders. These typesof gases can affect humans through inhalation and/or absorption through unprotectedskin or eyes.

Lethal concentrations of toxic materials may be found in "empty" cylinders. Severalworkers were killed or injured in 1983 in Hanover County, Virginia, when sampling acylinder containing pentaborane, a non-pressurized liquid.

Reactive materials and gases are often present in compressed gas cylinders. Theseinclude powerful oxidizers such as fluorine compounds and oxygen. Oxygen cylinderscan cause explosions when the released gas contacts organic materials. Fluorine iseven more reactive and can ignite metal in non-oxygen environments. Many gasesused as rocket fuels (such as hydrazines and chlorine trifluoride) are capable ofexplosive reactions in otherwise inert atmospheres.


FM 90219-34 20

N* 1 Work, Safety, Health, and Emergency Response PlanDate: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

Ordinarily, reactive mixtures of gases are not stored in a single cylinder. Manifoldingof cylinders can result, however, in the creation of potential bombs. A cylindercontaining silane and nitrous oxide detonated during handling, killing three workers inNew Jersey. The resultant fire destroyed the laboratory.

Some unstable gases are inherently hazardous due to the potential for exothermicpolymerization. These include such gases as hydrogen cyanide and ethylene oxide.

Compressed gas cylinders are commonly used to contain a variety of hazardous,non-pressurized materials. For example, pyrophoric compounds such as metal alkylsare frequently stored in a solvent containing cylinder.

Flammable gases present both fire and explosion risks. For example, hydrogen hasan extremely broad flammable range (4-75%) and burns with an almost invisibleflame.

Powerful corrosives are commonly stored in compressed gas cylinders. Examplesinclude anhydrous hydrogen chloride and hydrogen fluoride. Further, on exposure tomoist air, many gases react to form acids which are extremely dangerous to workers.

All of these hazards must be addressed to safely manage waste compressed gascylinders. When contents of a cylinder are not positively identified it must beassumed that any of these hazards may be present. The procedures contained in thisplan account for these hazards for the protection of personnel and the environment.

Chemical Inhalation: The greatest potential chemical danger (in terms of probability)posed by working on site is that of respiratory inhalation during an accidental releaseor leak when handling the cylinders. Inhalation protection will be afforded by arigorous air monitoring program and supplied air respiratory protection equipment.

Dermal Adsorption: Another potential chemical danger is dermal (skin) contact withgases in an event of a release or leak, or from residual solids or liquids associated withthe cylinders. Dermal protection will be afforded by wearing gas-tight, positive-pressure, semi-encapsulating suits during sampling activities.

Overall, any exposure potential is minimized because the appropriate action level forsampling of gas cylinders on this project will be Level B Personal Protective Equipment(PPE) providing for total body coverage, in conjunction with air monitoring.

Heat Stress: A physical hazard is heat stress because of the physical work ofhandling the cylinders in Level A PPE. Heat stress occurs in three phases: heatexhaustion, heat cramps, and heat stroke.

3«'15t7"Use or disclosure of data contained on this sheet is subject to the

restrictions on the title page of this Work, Safety, Health and Emergency Response Plan.'FM 90219-94 21

u«u< N* i Work, Safety, Health, and Emergency Response PlanDate: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

Heat exhaustion is the first phase of heat stress, and is characterized by profusesweating, tiredness, weakness, headache, nausea, dizziness, pale and clammy skin,and possible fainting spells. First aid for heat exhaustion involves resting in a coolarea, and drinking plenty of fluids. After an attack of heat exhaustion, it is advisablefor the individual not to return to work until rested and fully recovered.

The second phase of heat stress is heat cramps, and is characterized by cramps in themuscles of the legs and abdomen with heat exhaustion symptoms because of thelarge loss of body fluids and salt from profuse sweating. An individual at this point willbe given first aid as in cooling down the body, drinking electrolytic fluids over a hourperiod, and referred to a doctor immediately for evaluation and treatment.

The final phase of heat stress is heat stroke, and is the most severe heat stresscondition. It is characterized by the skin being hot, red, and dry with a rapid andstrong pulse rate. The individual may be unconscious, and emergency medicalattention is required immediately.

Section 3.2 - Identified Hazards by Task

Each phase of the work is associated with specific hazards. The hazards which canbe identified are described below.

Section 3.2.1 - Hazards Associated with Mobilization

Physical injuries are possible during this phase because of the construction typeactivities. This includes cuts and abrasions from use of hand tools. Lifting injuriesmay be associated with unloading of equipment and materials.

Accidents involving heavy equipment are possible. A fork lift may be used to facilitatematerial handling.

Electrical shock is a hazard from electrical lines and equipment.

Chemical hazards are posed by materials used during the project. These chemicalsinclude caustics, acids, oxidizing solutions, nitrogen, and molecular sieve adsorbents.

Section 3.2.2 - Hazards Associated with Inspection and Evaluation

During the initial phase of the project cylinders will be visually inspected andevaluated. Ordinarily this will not require handling of the cylinders. Cylinder handlingcould be necessary, and will be done in Level A PPE.

30J5;'Use or disclosure of data contained on this sheet is subject to the ' *restrictions on the title page of this Work, Safety, Health and Emergency Response Plan. '

FM 90219-94 22

i*«ue N* 1 Work, Safety, Health, and Emergency Response PlanData: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

Handling of cylinders increases the potential for cylinder leakage. Protection againstrespiratory and skin contact will be used any time handling is required during initialinspection.

Handling of the cylinders during inspection could pose physical hazards. Thesehazards include mashing of fingers or toes from handling of heavy containers.

Section 3.2.3 - Hazards Associated with Sampling

The primary hazard associated with the operations results from handling of drums,containers, and cylinders by personnel. Physical handling is required for sampling.

Handling of drums, containers and cylinders presents physical hazards of lifting.These containers may also be dangerous if dropped. Careless handling could resultin crushed fingers or toes. Damage to the containers could result in leaks, spills,explosions, and, in the case of cylinders, creation of a projectile.

Sampling work will be done in Level A Personal Protective Equipment (PPE). Wearingof the PPE can restrict vision and movement thus making tripping or falling morelikely. Heat stress is also possible because of the confined suit. Containers will onlybe moved using a cylinder hand cart, cradle or rack, drum cart or fork lift.

Nitrogen will be used for purging. There are hazards associated with high pressurelines and asphyxiation.

The Vapor Containment Structure is considered a confined space and poses hazardsfrom oxygen deficiency and toxic vapor concentration.

Temperature stress is possible while working inside confined spaces. Because of thePPE, heat stress is the most probable temperature problem.

For valve sampling operations, the valve must be connected to sampling apparatus.There is a higher potential for leakage when the cylinder and valve are being handled.

Equipment used for sampling operations include pressure vessels, vacuum pumps,compressors and specialized cylinder handling equipment. Specific hazards associatedwith the equipment are described in ERC's Equipment Manuals.

Section 3.2.4 - Hazards Associated with Laboratory Analysis

Samples of compressed gases will be analyzed in an on-site laboratory. Analyticalprocedures are designed to minimize the potential hazards. These procedures aredescribed in the Quality Assurance and Quality Control Plan.

3''J519"Use or disclosure of data contained on this sheet is subject to the

restrictions on the title page of this Work, Safety, Health and Emergency Response Plan. 'FM»0219-94 23

IUIM N": i Work, Safety, Health, and Emergency Response PlanData: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

Hazardous gases may be contained in sample containers. Even though the samplesize is small (typically 100 cc) and close to atmospheric pressure, the samplecontainer could leak.

The sample containers are handled by workers involved in the sampling operation. Itis possible for the exterior to become contaminated with solid or liquid reactionproducts. Very few chemicals are used in the laboratory. Those used,bromofluorobenzene and alcohol, are used in small quantities. These may behazardous by ingestion.

A specific Chemical Hazard Plan for the laboratory has been developed for and isincluded in Appendix A.

Section 3.2.5 - Hazards Associated with Transportation

Hazards associated with transportation include the physical hazards associated withgeneral drum/container handling, such as pinched or crushed appendages and musclestrains and pulls. Highway transportation of gas cylinders presents the potential forcylinders to roll or fall. Thus, prior to transportation, all cylinders must be secured andtheir cylinder valves protected.

To prevent leakage during transportation, all cylinders must meet D.O.T. packagespecifications. If cylinders are suspected of leaking, they must be overpacked in aD.O.T.-approved compressed gas cylinder overpack.

Section 3.2.6 - Hazards Associated with Treatment

There is a potential for leakage of hazardous gases during transfer operations.Further, inadequate cleaning and purging of transfer lines could result in a release.

Working with the scrubber system may create the potential for exposure to treatmentreagents. Because of the heat of reaction, the scrubbers and reagents may be hot.

Equipment used for treatment operations include reactor vessels, vacuum pumps,compressors and specialized cylinder handling equipment. Specific hazards associatedwith the equipment are described in ERC's Equipment Manuals.

15 on'Use or disclosure of data contained on this sheet is subject to the


N* i Work, Safety, Health, and Emergency Response PlanD«t.: October, 1994 EnviroClean-Northeast, Inc.. Malta Rocket Fuel Area Site

Section 3.2.7 - Hazards Associated with Cylinder Decommissioning

After a cylinder's pressurized contents are evacuated, it will be back-filled withdeactivation fluids to react out any residual solids that may have formed in thecontainers. These may include methanol, detergent, surfactant, or other agent topromote complete deactivation of the residues. The containers will then bedecommissioned by accessing the interior for inspection and scrapping. This caninvolve valve removal or cutting the cylinder into halves.

Care must be exercised to positively ascertain that the cylinder has been completelydepressurized.

Residual non-pressurized contents can be extremely hazardous. The residue may beair or water reactive, or extremely toxic. Further, a residual flammable atmospherecould ignite during the cylinder cutting operation.

Use of a power saw presents mechanical and electrical hazards.

Section 3.2.8 - Hazards Associated with Demobilization

Hazards associated with demobilization include those described in Section 3.2.1.Additional hazards are posed by the spent reagent and rinseate. These may be includeoxidizers, acids or caustics. Decontamination of equipment may result in exposureto liquids which may be corrosive.

Section 3.2.9 Historical Incidents Involving Boranes

There are several incidents and accidents involving boranes (boron hydrides) whichhave been widely reported. In some cases the factual circumstances surrounding theincidents discussed below are based upon newspaper reports and conversations withinvolved parties. Conclusions are based on the best available information in order toimprove the safety of site operations.

Reaction with Chlorinated Organics

Explosions have been reported with the use of carbon tetrachloride as an elutingsolvent for chromatic separation (Hermanek, S., Chem. Abs., 1976, 84, 38364). Useof carbon tetrachloride to extinguish a diborane fire resulted in a violent explosion(Manual of Hazardous Chemical Reactions, NFPA 491M, Boston, National FireProtection Association, 1975).



i««u« M*. i Work, Safety, Health, and Emergency Response PlanD<t«: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

Based on this information, chlorinated organic solvents should be avoided withboranes (acetone, carbon tetrachloride, chloroform, dioxane, freons, trichloroethane,and trichloroethylene). Any such solvents used to clean the system must bethoroughly dried and purged.

In 1955 an explosion occurred in a process building at the Malta site (See AppendixD, "Literature Search for the Malta Rocket Fuel Area Superfund Site," Geraghty &Miller, Volume 1, 1992). The explosion originated in a process vessel used forconversion of diborane to pentaborane. The vessel contained only solid decaborane.The reaction occurred when acetone was inadvertently introduced to the vessel duringa nitrogen purge.

Pyrophoricity

Impure pentaborane is known to ignite spontaneously in air (Safety Data Sheets, MCASD-84, Washington, 1961, NSC 508, 1979). Air will be excluded from theprocessing system used by ERC to avoid ignition.

Diborane is an endothermic gas ( + 31 kJ/mol, 1.12 kJ/g) which is pyrophoric unlesspure and dry. Violent explosions of the gas may be delayed by three to five daysfollowing release (Schlessinger, H.I. et al, Chem. Rev., 1942, 31, 8). An explosionhas also resulted from spillage of liquid diborane (Hydrides of Boron and Silicon,Stock, A.E., Ithaca, Cornell Univ. Press, 1933). Spontaneous explosive reactions withair and benzene or moisture in vapor phase occur with diborane (Simons, H. P. et al.,Ind. Eng. Chem., 1958, 50, 1665, 1659). This experience also indicates thenecessity of excluding air from the processing system. It is also important to verifyby testing that diborane has be completely processed and all residuals removed fromthe processing equipment.

Toxicity

In July of 1992 an incident occurred at the Divex Superfund site in Columbia, SCduring the processing of pentaborane (see Appendix D, "Cleanup halted after workercollapses" and "Worker might have inhaled rocket fuel"). Work underway involvedthe processing of cylinders containing pentaborane. The cylinder involved hadreportedly been emptied. The site work plan provided for removing blocked cylindervalves from chilled cylinders in an enclosed environment. The worker was wearingLevel B Personal Protective Equipment.

According to reports, the PPE was fully functional. The worker was exposed whileworking in the contaminated enclosure. The exposure was related to a loose fittingsupplied air respirator (it is stated that the mask loosened when removed from an airconditioned change trailer to a hot, humid environment).


restrictions on the title page of this Work, Safety, Health and Emergency Response Plan. *FM 90219-94 25-A

I*«IM t* i Work, Safety. Health, and Emergency Response PlanD*U: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

An accident occurred in 1982 during the processing of small pentaborane cylindersin Virginia. Two people died and one suffered permanent brain damage. Six rescueworkers were exposed. (See Appendix D, "No known treatment for accident victims,""Lessons, memories of pentaborane spill still vivid," "This stuff is getting to all ofus").

The accident occurred when pentaborane was released from a recovery vesselfollowing failure of the ramming device used to shear cylinder valves. Workersinvolved used not PPE.

The potential for exposure to pentaborane will be minimized at the Malta site by useof engineering controls to remotely process the material. Personal ProtectiveEquipment will not be used as the primary means of protection.

Where potential for exposure exists, the highest level of PPE (Level A) will be used.To verify proper fit, testing will be completed with irritant smoke prior to entry intothe exclusion zone.

Section 3.3 - Safety Engineering Controls

Safety engineering controls are those mechanisms used to minimize the potentialhazards associated with the operation. The following controls will be employed:

Pollution control equipment to reduce thelevels of airborne contaminants;

Remotely operated sampling equipment:(LCTU and CRV); and

Air monitoring equipment for detection ofvapors and oxygen deficient atmospheres.


FM *0219-94 25-B

i«»u« tf. 1 Work, Safety, Health, and Emergency Response PlanD«M: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

The LCTU is engineered for the sampling of large compressed gas cylinders. Thedesign permits remote sampling and isolates personnel from both gases and reactions.The following safety engineering features are incorporated into the LCTU:

Materials used in the sampling system arecomposed of monel, stainlesssteel andteflon;

The piping system is oxygen cleaned andpassivated;

Pressure ratings of all components exceedpressures which may be contained in thecylinders;

A vacuum/inert gas purge system is used toremove air and residual gases from thesystem;

A pressure regulator limits the quantity andpressure of gas entering the sample system(samples are obtained at atmosphericpressure); and

Emergency treatment is available should arelease occur within the sampling chamber.

The CRV was designed to accommodate all compressed gases and liquids. Thesystem provides for remote release and recontainerization of pressurized gases andliquids in a completely contained, inert environment. Design features incorporated intothe CRV system to provide for containment and control of compressed materialsinclude:

Pressure rating sufficient to accommodate thehighest pressures in common commercialcylinders. The CRV is an ASME-rated pres-sure vessel;

Secondary containment by means of an airtight chamber housing the vessel and processequipment;


restrictions on the title page of this Work, Safety, Health and Emergency Response Plan. 'FM »0219-94 26

i«»u« M* 1 Work, Safety, Health, and Emergency Response PlanDat«: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

Inert environment for tapping cylinder.Cylinder tapping is accomplished by a drillingmechanism or puncture device housed withinthe vessel. Prior to piercing a 10'1 Torrvacuum is obtained and an atmosphere ofnitrogen is introduced. All internalcomponents are hydraulically actuated,eliminating possible sources of ignition;

Non-reactive materials of construction. Theinterior of the vessel and its associatedsystems are composed of passivated steel,stainlesssteel or teflon. All hydrocarbonsand other reactive materials have beenexcluded from possible contact with cylindercontents. Hydraulic fluid used for CRVcomponents is a non-reactive, fluorinated oil;

Remote sensing equipment for monitoring ofoperations. Pressure and temperaturetransducers are located at key points in theCRV and ancillary systems. Direct viewing ofthe CRV is obtained through a video system;

Remote operation from outside of the CRVtrailer. All operations are controlled from aremotely located panel;

Identification of the cylinder contents. Aftercylinder contents are released inside of theCRV, a port permits a small sample to beobtained from outside of the trailer. On-siteanalytical equipment provide an identificationof the contents; and

Vacuum and purge system for systemcleaning. The interior of the CRV and ancillarysystems can be cleaned by means of vacuumwithdrawal and purging with an inert gas;

Although releases of volatile materials are controlled by the LCTU and CRV units,personnel are protected against potential exposure by Personal Protective Equipment.Encapsulating suits with supplied air provide another level of safety against thecontingency of an accidental release.

oQ-J Kor'Use or disclosure of data contained on this sheet is subject to the


u«u« N* 1 Work, Safety, Health, and Emergency Response PlanDat«: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

A Vapor Containment Structure (VCS) may be used for particularly sensitiveoperations. The VCS provides a capability for temporary containment of gases whichmay be accidentally released during cylinder handling. Emergency treatment systemsare used to clean the atmosphere inside the structure.

Handling of the cylinders during staging and reloading offers the greatest potential fora release from the cylinders. For this reason, cylinder handling will be minimized.Should a leak occur during handling, the cylinder may immediately be moved into theCRV or the LCTU chamber and contained.

A cylinder overpack, meeting D.O.T. requirements, will be available during the project.The overpack can be used in emergencies for containment and transportation ofleaking cylinders.

The laboratory is designed to handle samples of potentially hazardous gases. Samplesare contained in small stainless-steel cylinders (rated to 1800 psi) at atmosphericpressures. The sample transfer apparatus is maintained in a vented hood and thetransfer occurs under a negative air pressure.

ERG will comply with ERA Item number 87 that states:

In the event that EPA determines that the activities being conductedpursuant to this Order, any other activities being conducted at theSite, or changes in conditions at the Site pose a threat to public healthor welfare or the environment, EPA may direct Respondents to stopfurther implementation of actions pursuant to this Order and/or to takeother actions reasonably necessary to abate the threat. Neither thisprovision nor any other provision of this Order shall be construed soas to limit any powers EPA may have under Section 300.65 of theNCP, 40 CFR $ 300.65, any other applicable provision of the NCP,or any other applicable law or regulation.


restrictions on the title page of this Work, Safety, Health and Emergency Response Plan. 'FM 102 J 9-94 28

N* 1 Work, Safety, Health, and Emergency Response PlanDat.: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

SECTION 4.0 - SITE CONTROL

Section 4.1 - Work Zones

The work site will be strictly controlled to minimize: 1) exposure of non-protectedpersons to potentially harmful chemicals; and 2) migration of contaminants out of theimmediate work area through either equipment or personnel. In order to achieve thistype of control, the following measures will be placed into effect:

Minimization of on-site work force;Establishment of specific work zones on the site;Establishment of a single point for site access:both entering and exiting; andImplementing a thorough decontamination procedure.

For the purposes of the operation, three contiguous work zones will be established.These three zones are:

ZONE 1 - Exclusion Zone ("Hot" Zone);

ZONE 2 - Contamination Reduction Zone; and

ZONE 3 - Support Zone ("Clean" Zone).

Zone 1 - Exclusion Zone ("Hot Zone")

The Vapor Containment Structure and LCTU will be deemed to be the exclusion zone.During sampling or treatment operations, personnel working in the exclusion zone arerequired to wear the full level protection prescribed for such work.

Zone 1 will only be entered at the designated point through the decontamination area.This single entry/exit point aids in regulating the flow of personnel and equipment intoand out of the "hot" zone.

Zone 2 - Contamination Reduction Zone

The area between Zone 1 and Zone 3 is termed either the "Decontamination Zone"or "Contamination Reduction Zone". This area serves as a buffer area between thepotentially contaminated zones to provide an area where personnel and equipment canundergo decontamination and thus prevent the spread of contaminants into the cleanzone. The decontamination area will serve as the control point for access to Zone 1and all entry and exit from the site will occur at this point. An entry and exit log willbe maintained in the decontamination area and will serve as documentation of site

qnir;'Use or disclosure of data contained on this sheet is subject to the «J V/ I »•»


M* 1 Work, Safety, Health, and Emergency Response PlanD.t.: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

entry for each day of the operation. In this manner, personnel access to Zone 2 willbe kept to a minimum.

Zone 3 - Support Zone

The support zone, the outermost part of the work area, is considered anon-contaminated or clean zone. All of the facilities necessary for the logisticalexecution of the project will be located within this zone and will include the commandarea. There is no special protective clothing (other than that required by the plan) thatis required in this area.

The support zone is located entirely within the fenced site. Access is controlledthrough a single entry and exit gate. The fenced area can be secured during non-workhours.

Section 4.2 - Buddy System

The "buddy system" organizes workers into work in such a manner that eachemployee is observed by at least one other designated individual. It is intended toallow rapid assistance in the case of injury or other emergency.

For this project, the buddy system requires that workers be in visual contact at alltimes. During site preparation and demobilization this will require a minimum of twopeople on-site when work is being done.

For operations inside of the exclusion zone, a minimum of two people attired in thehighest level of PPE required for the operation is required. Backup personnel must atall times be immediately able to offer assistance in the event of an emergency.

A closed circuit video system may be used to maintain the required visual contact.

Section 4.3 - Communication

Communications at the site will include visual signals, alarms, radios, and telephone.

A cellular phone will be in the analytical lab for emergencies. An additional phone islocated outside of the entrance to the waste storage facility.

Radios will be used to communicate with workers. One radio will remain in thelaboratory at all times. At least one radio will be maintained by workers inside of theExclusion Zone. Radio contact must be maintained with workers in the ExclusionZone and in the support area. Speaking diaphragms will be used on respiratoryequipment for workers in the Vapor Containment Structure.

3<U528"Use or disclosure of data contained on this sheet is subject to the


l*«ue N». 1Data: October, 1994


Visual signals are required for operations where respiratory protection is used.Recognition of hand signals is mandatory for all employees regardless of theavailability of other means of communication.

The following will be used as standard hand signals for all who enter the site:

SIGNAL

Hand gripping throat

Gripping partner's wrist, or gripping bothhands on wrist

Hands on top of head

Thumbs up

Thumbs down

I MEANING

Out of air, cannot breathe

LEAVE AREA IMMEDIATELY!

Need assistance

Okay, I'm alright, I understand

No, negative

The following emergency air horn signals will be used on site:

Series of Short Blasts

Series of Long Blasts

Continuous Long Blast

Personal Injury

Release or Spill

Explosion or Fire

Section 4.4 - Site Security

The site is located within a fenced area. As such, primary security will be affordedby the limited access. During nonworking hours the site will be secured.

Entrance into the Exclusion Zone during operations will be controlled by ERGpersonnel. An entry/exit log will be maintained. Entry and exit will be solely throughthe Contamination Reduction Zone.

Unauthorized persons entering the work area will be asked to leave. Work will besuspended anytime there are unauthorized persons present. If necessary, the clientrepresentative will be asked to intervene if cooperation is not obtained and theoperation is being impeded.



i««ue tr. 1 Work, Safety, Health, and Emergency Response PlanData: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

SECTION 5.0 - PERSONAL PROTECTIVE EQUIPMENT

Due to the potential health effects of the expected materials, all operations in thefield will be carried out using suitable personal protection equipment.

Section 5.1 - Selection Criteria

The purpose of Personal Protective Equipment (PPE) is to reduce contaminant levelsbelow Permissible Exposure Levels (PEL). The goal, however, is no exposure.

If operations proceed as planned, concentration of contaminants will always be lessthan PEL. The protective equipment is, however, necessary should there be a leak orsystem failure. As a conservative measure, PPE shall be worn any time there is asignificant potential for exposure (i.e., during sampling or treatment operations).

The following factors will be evaluated in selecting an appropriate PPE level:

- Routes of potential exposure- Inhalation- Skin absorption- Ingestion- Eye and skin contact- Performance of PPE materials- Task specific conditions- Durability of PPE.

Criteria for the various levels are as follows:

Level A - Required where the greatest level of skin, respiratory and eye protection isnecessary. Types of hazards include (1) where an identified hazardous substancerequires the highest level of protection for skin, eyes, and the respiratory systembased on high concentrations of atmospheric vapors, gases, or particulates, or thework involves a high potential for splash, immersion, or exposure to unexpectedvapors, gases or particulates of materials which are harmful to skin or capable ofabsorbency through the skin; (2) where substances with a high degree of skin hazardare present and skin contact is possible; and.(3) where operations are conducted inconfined or poorly ventilated areas with unknown conditions.

Level B - Appropriate where the highest level of respiratory protection is required buta lesser level of skin protection is needed. Types of hazards where Level B can beused include (1) types and concentrations of substances have been determined thatrequire a high level of respiratory protection, but not skin protection; (2) theatmosphere contains less than 19.5% oxygen; and, (3) where incompletely identified



N* i Work, Safety, Health, and Emergency Response PlanDate: October. 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

vapors or gases are indicated by air monitoring but are not suspected of containinghigh levels of chemicals harmful to skin or capable of absorbency through skin.

Level C - Used where the concentrations and types of airborne substances are knownand the criteria for air purifying respirators are met (i.e., where the contaminants areknown, an appropriate filter is available, concentrations are within acceptable limits(not IDLH), and the contaminant has good warning properties) Level C can be usedwhere (1) the atmospheric contaminants, liquid splash, or other direct contact will notadversely affect or be absorbed through exposed skin; (2) the types of air contami-nants have been identified, concentrations measured, and an air-purifying respiratoris capable of removing the contaminants; and (3) all criteria for use of a respirator aremet.

Level D - Where only a minimal level of protection is necessary (i.e., for nuisancelevels of contaminants). This low level of protection may be appropriate where (1)there are no atmospheric hazards; (2) the work will not involve splashes, immersion,or inhalation or contact with hazardous levels of any chemical.

Section 5.2 - PPE Requirements by Task

Section 5.2.1 - Mobilization and Demobilization

Level D will be used for general mobilization activities not involving the handling ofhazardous materials. Level D will also be worn by laboratory personnel.

For the EnviroClean-Northeast project, minimal Level D equipment will consist of:

- Hard hat;- Safety glasses/goggles;- Safety boots;- Gloves; and- Hearing protection (preformed foam hearing plugs, NRR33) (as needed).

Mobilization activities may also include handling of treatment reagents and molecularsieve adsorbents. The following additional Level D equipment is required for handlingof these materials:

- Face shield;- Impermeable coveralls;- Rubber safety boots; and- Respiratory protection (as appropriate).


restrictions on the title page of this Work. Safety, Health and Emergency Response Plan.'FM 10219-94 33

u*u« M*. 1 Work, Safety, Health, and Emergency Response PlanDai.: October. 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

Section 5.2.2 - Cylinder Sampling Operations

Cylinder sampling will be carried out in a completely encapsulating Level A ensemble.This includes LCTU sampling and CRV operation. This level of protection is alsorequired during repair and maintenance of equipment which has not been purged andevacuated.

The primary elements of the Level A protection for the cylinder managementoperations are as follows:

- Positive pressure-demand SCBA- Fully encapsulating Level A suit

Section 5.3 - Use and Limitations

General limitations on the use of PPE associated with Levels A and D are discussedunder Section 5.1, Selection Criteria.

Use of chemical protective suits may be limited by temperature stress, particularlyheat stress. The impermeable suit traps heat and does not allow sweat to evaporateand cool the body. Section 7.2 describes monitoring and work periods required toavoid heat stress.

Section 5.4 - Maintenance and Storage

Level A suits must be stored in a cool, dry location. They should not be stored wherethey can be exposed to direct sunlight. They should not be stored where electricalsparking is possible, or in places where there may be abnormally high levels of ozone.

The suit should be stored upright on a hanger. The boots should be stored upsidedown if possible.

The suit should be cleaned prior to storage. It should not be dried in direct sunlight.

Respirators must be stored in a clean, dry and cool location. They should be storedin protective plastic bags.

Section 5.5 - Decontamination and Disposal

Level A suits will be decontaminated after each use. The interior will be cleaned usingsoap and water. The exterior will be decontaminated using a water rinse as describedin Section 9.



-. i Work, Safety, Health, and Emergency Response PlanD.te. October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

The suits are reusable. They should only be disposed of when determined by theSafety Officer to be unserviceable.

Section 5.6 - Training and Fitting

The human respiratory system is the easiest and most vulnerable route of entry intothe body for airborne contaminants. To minimize the chances for any gases or vaporsto enter the lungs, a respiratory protection program will be established for use at thesite.

Respiratory training for the safety training program will educate site personnel in theproper use of the respiratory equipment selected for this job and the differentprotection levels afforded by this equipment as it relates to compressed gases.Instruction will also be supplied to workers in the proper maintenance and care of therespiratory equipment. The respiratory protection program is described in ERC'sHealth and Safety Manual (Section 18, Revision 2). A copy of the manual will bemaintained on site.

Section 5.7 - Donning and Doffing Procedures

The Level A suit should be donned in accordance with manufacturer's instructions.Figure 5.1 shows the proper procedure.

Prior to removal of PPE, decontamination procedures must be completed.

Section 5.8 - Inspection

All PPE must be inspected before and after every use. It should be generallyevaluated for wear, rips, tears or other damage. Any visible dirt or other contaminantsshould be removed.

The Level A suit will be periodically tested for integrity.

Testing and repair procedures are specified in the suit reference manual and will beperformed only by trained and certified repair personnel.

Section 5.9 - Effectiveness Evaluation

The effectiveness of the PPE must be reevaluated after each use or as additionalinformation is obtained. As a minimum this will be reviewed at each daily safetymeeting. Any change in conditions of the work will trigger such an evaluation andshould promptly be reported to the Project Manager.


restrictions on the title page of this Work, Safety, Health and Emergency Response Plan.'FM *0213-94 35

IMIM N*. 1Data: October, 1994


TABLE 5.1

CHEMICAL RESISTANCE OF SUIT

MATERIAL

HBr, anhydrous

HCI, anhydrous

HF, anhydrous

HCN

BrF5

C2N2

COCI2

CI2

[ RESISTANCE

2

2

2

2

5

2

3

4

SCALE:

1.2.3.4.5.

NOTE:

Resistance time at least 8 hours. Material not affected.Resistance time at least 4 hours. Material affected slightly.Resistance time at least 2 hours. Material can be destroyed.Resistance time at least 1 hour. Material can be destroyed.Resistance time at least 20 minutes. Material can be destroyed.

Resistance time for chlorine (UN 1017) refers to the gaseousform. Resistance time is one grade lower for contact with thischemical in liquid form.

FM 90213-94


36

1

Data: October, 1994Work, Safety, Health, and Emergency Response Plan

EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

TABLE 5.2

RESISTANCE TO CHEMICALS OF COMMON GLOVE MATERIALS

CHEMICAL

AcetaldehydeAcetic AcidAcetoneAcrylonitrileAmmonium hydroxide (sat)

AnilineBenzaldehydeBenzene*Benzyl chloride*Bromine

ButaneButyraldehydeCalcium hypochloriteCarbon disulfideCarbon tetrachloride*

ChlorineChloroacetoneChloroform*Chromic acidCyclohexane

Dibenzyl etherDibutyl phtalateDiethanolamineDiethyl etherDimethyl sulfoxideb

Ethyl acetateEthylene dichloride*Ethylene glycolEthylene trichloride*Fluorine

FormaldehydeFormic acidGlycerolHexaneHydrobromic acid (40%)

NATURALRUBBER

GEGPG

FFPFG

PPPPP

GFPPF

FFFF-

FPGPG

GG

' GPG

NEOPRENE

GEGGE

GFFPG

EGGPF

GEFFE

GGEG-

GFGPG

EEGEE

NITRILE

EEG-E

EEGG-

.-GGG

.-GF-

_--E-

GGE--

EEE-~

VINYL

GEFFE

GGFPG

PGGFF

GPPEP

PPEP-

FPEPG

EEEPE

FM 90219-94

"Us* or disclosure of data contained on this shftt is subject to therestrictions on the title page of this Work, Safety, Health end Emergency Response Plan.'

301535

37

ft 1Date: October, 1994

Work, Safety/ Health, and Emergency Response PlanEnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

TABLE 5.2 (Cont.)

RESISTANCE TO CHEMICALS OF COMMON GLOVE MATERIALS

CHEMICAL

Hydrochloric acid (cone)Hydrofluoric acid (30%)Hydrogen peroxideIodineMethylamine

Methyl cellosolveMethyl chloride*Methyl ethyl ketoneMethylene chloride'Monoethanolamine

MorpholineNapthalene*Nitric acid (cone)Perchloric acidPhenol

Phosphoric acidPotassium hydroxide (sat)Propylene dichloride1

Sodium hydroxideSodium hypochlorite

Sulfuric acid (cone)Toluene*Trichloroethylene*Trieresyl phospateTriethanolamineTrinitrotoluene

NATURALRUBBER

GGGGG

FPFFF

FGPFG

GGPGG

GPPPFP

NEOPRENE

GGGGG

EEGFE

EGPGE

EGFFP

GFFFEE

NITRILE

GGG-E

_

-GG-

_

EPF-

.G-GF

FGG-E~

VINYL

EEEGE

PPPFE

EGGEE

EEPEG

GFFFEP

(E = Excellent, G=Good, F = Fair, P = Poor)

a Aromatic and halogenated hydrocarbons will attack all types of natural andsynthetic glove materials. Should swelling occur, the user should change tofresh gloves and allow the swollen gloves to dry and return to normal.

b No data on the resistance to dimethyl sulfoxide of natural rubber, neoprene,nitrile rubber, or vinyl materials are available; the manufacturer of thesubstance recommends the use of butyl rubber gloves.

FM 10219-94

'Us* or disclosure of dat* contained on this sheet is subject to therestrictions on the title page of Ms Work, Safety, Health end Emergency Response Plan.

301536

38

Nfc i Work, Safety, Health, and Emergency Response Plan: October, 1994 EnviroClean-Northeast, Inc.. Malta Rocket Fuel Area Site

How to dress:Trellchem Super Extra, Trellchem Butyl FIGURE 5.1Extra and Trellchem Light Extra

He* :o connect thf internal vwitilstiorsysteT

How to take off the suit

FM 90219-34

'Use or disclosure of data contained on this sheet is subject to tftorestrictions on the title page of this Work, Safety, Health and Emergency Response Plert.

39

M* i Work, Safety, Health, and Emergency Response PlanDat.: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

SECTION 6.0 - TRAINING REQUIREMENTS

Section 6.1 - General Requirements

All personnel working in the field during the operations will be trained in both generaland site-specific safety procedures. All personnel entering the work area will beinformed of the possible dangers and long-term effects of the chemical hazardspresent at the site.

The purpose of the safety training is: 1) to develop safe work habits among the workcrew; and, 2) to train and inform personnel involved with the site work regarding thehazards present at the site in order to minimize the potential for accidents, or for anymember of the crew to be unduly exposed to harmful environmental conditions.

All of the personnel working on the project site will have undergone a site-specificsafety and operations training program. This training is a mandatory part of beingallowed access to the exclusion zone during the operational phases of the field work.

Each employee will be advised that disregard of safety precautions will be cause fortermination. Continued and on-going safety training will be conducted as necessaryto ensure that the work environment is safe.

Key areas in the safety training curriculum will include:

- Hazard analysis: chemical, physical and biological;- Standard safety operating procedures;- Safety equipment to be used;- Personal Protective Equipment to be worn;- Areas of restricted access;- Emergency procedures and plans;- Evacuation procedures;- Respiratory training and fit-testing;- Use of the SCBA;- Relevant first aid procedures;- Internal and external communications;- Hazardous materials handling procedures;- Air monitoring program;- Weather conditions affecting chemical concentrations;- Hazardous materials recognition;- The "Buddy System" to be used at the site; and- First Aid and CPR.

'Use or disclosure of data contained on this sheet is subject to therestrictions on the title page of this Work, Safety, Health end Emergency Response Plan.'

FM 90219-94 40

t* 1 Work, Safety, Health, and Emergency Response PlanDau: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

The Respiratory Protection Training Program is further defined in ERC's CorporateHealth and Safety Manual. For this project it will encompass the following items:

1. The Site Manager (SM) and Site Safety Officer (SSO) will perform an initialdetermination as to exactly what levels of respiratory protection are necessaryfor the performance of the job.

2. The appropriate air-supply device will be used in the designated work areasbased upon all available data prior to and during site operations.

3. Instruction and Training

a. Medical Approval: Prior to work on-site, documented approval will beobtained for employees to use a respirator. This approval will be obtainedfrom the physician that has conducted the physical examination (includingan examination of pulmonary function) for each employee prior to the startof site operations.

b. Respirator Fit-Testing: The Site Safety Officer will conduct the fit testingprocedure described in this section. All of the members of the field crewwill have been fit tested (qualitative) in the following types of respiratorsprior to site activities:

- Positive-pressure airline respirator- Positive-pressure SCBA.

c. Employee Instruction: Each user will be instructed in the following beforethey are allowed to start work at the site:

- Usage, limitations, and cleaning procedure for each type of respirator,including the emergency egress respirator. (Maintenance work, such asvalve replacement, will be performed by trained technician. Workperformed on the supplied air systems, such as the regulators, will bedone by a technician certified for the specific repairs).

- Discussion of the engineering and administrative controls in use and whyrespirators are needed.

- Explanation of the nature of the respiratory hazard and what happens ifthe respirator is not used properly.

- Explanation of why a particular type of respirator has been selected.

- Discussion of how to recognize and handle emergencies.3^1539


FM 90219-94 41

N*. i Work, Safety, Health, and Emergency Response PlanData: October. 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

4. Each site worker will be responsible for ensuring that his respirator is functioningproperly prior to each day of use.

5. Each worker required to use the respirator (either an SCBA or supplied air) will beassigned an individual unit and will be responsible for its care.

6. SCBA and supplied air respiratory equipment, will be inspected daily when in use.Spare cylinders for the SCBA's will be kept available on-site.

7. SCBA and air-bank air quality will meet the requirements for Grade D breathing airas described in Compressed Gas Association Commodity SpecificationG-07.1-1966 (or local equivalent). The air quality monitoring equipment forbreathing air quality will be calibrated regularly to ensure proper operation.

8. Air cylinders in use will have been tested in accordance with the ShippingContainer Specification Regulations of the Department of Transportation.

9. Air cylinders will be marked in accordance with Compressed Gas Associationpamphlet C-4 (or ANSI Z 48.1).

Section 6.2 - Initial Safety Briefing

Prior to any work on the site, a safety briefing will be held to cover those aspects ofthe work related to site setup. All workers involved in site preparation will attend.

Before starting on-site operations involving potentially hazardous materials, an initialsafety briefing will be held. Each aspect of this Work, Safety, Health and EmergencyResponse Plan will be covered. All interested parties from EnviroClean-Northeast andState or Local agencies may attend the meeting.

Section 6.3 - Daily and Periodic Training

Daily safety meetings will be held prior to the start of each day's activities to reviewpertinent safety information, changes in the scope of work, and project schedulegoals.

Should the nature of the work assignments or site conditions change during the day,another meeting will be convened to discuss potential hazards and safetyconsiderations.

3^1540"Use or disclosure of data contained on this sheet is subject to the


N* i Work, Safety, Health, and Emergency Response PlanDate: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

SECTION 7.0 - MEDICAL AND PERSONNEL MONITORING

Section 7.1 - Medical Monitoring Requirements

The purpose of the medical surveillance program is threefold:

- Ensure that the workers involved in the site operations are in good health;

- Document that the site workers are physically capable of using respiratoryprotection equipment and performing the necessary tasks; and

- Establish medical base-line data for the purpose of historical comparison (i.e., toestablish a "starting point" against which future medical testing may refer todetect increases or decreases in the parameters examined).

The medical surveillance program established and outlined below will conform to therequirements of the U.S. Occupational, Safety, and Health Administration (OSHA) (29CFR 1910.120), with National Institute of Occupational Safety and Health (NIOSH)recommendations for such a program, and with the company Health and SafetyManual.

All of the personnel working with compressed gases undergo a thorough medicalexamination on an annual basis. All of the personnel selected for this project will havecompleted a physical exam within twelve (12) months of working on the site.

The specific tests that are performed during the course of the physical examinationare as follows:

- Chest X-ray PA view, ILO interpretation (over 35 years of age) (Final X-rayat the discretion of the physician);

- Electrocardiogram (EKG);

- Pulmonary Function (Vital Capacity, FVC, FEV-1, FVC-5);

- Visual Acuity;

- Audiogram;

- Complete Blood Count with Differential;

- Complete Urinalysis with Micro;

- SMAC 26 Blood Chemistry; ^301541

'Use or disclosure of data contained on this sheet is subject to therestrictions on the title page of this Work, Safety, Health and Emergency Response Plan. *

FMt0219-94 43

u«ua N* 1 Work, Safety, Health, and Emergency Response PlanData: October. 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

- RPR (Serology);

- T4 (Thyroid Function);

- Physical Exam - Pulse, Blood Pressure, etc.;

- Medical History;

- Heavy Metals Screen (Urine analysis for arsenic, cadmium, chromium, lead,mercury and zinc);

- Evaluation of Ability of Employee to Use Respiratory Equipment; and

- Pulmonary History.

Once all of the physicals have been performed, a certificate signed by the examiningphysician will be provided indicating that the employee is capable of performing thenecessary work and is physically suited to wearing respiratory protection equipment.

The full battery of tests contained within the physical examination will be repeated asnecessary whenever there is evidence of particular stress or chemical exposure. Anon-the-job injury or time-loss illness will serve as an indicator for evaluation of theemployee and consideration of that employee for undergoing the complete physicalexam.

Prior to the initiation of site activities, all workers will have had to be approved asmedically fit to work on the project. Anyone who is shown to have medical problemswhich would affect their ability to work under the conditions posed by this operationwill be prohibited from working at the site.

Section 7.2 - Temperature Stress Monitoring

Heat or cold stress on the project will be managed through monitoring the siteworkers at regular intervals and adjusting work/rest schedules in accordance with themonitoring results.

The Site Safety Officer will be responsible for maintaining the temperature stressmonitoring program on-site to assure the safety of the work crew. Pulse andbreathing rates of the crew will be monitored to determine relative heat stress shouldthis become necessary. In addition, all of the crew members will be trained torecognize the symptoms of heat exhaustion and heat stoke in themselves and othersand will be instructed to exit the work zone and take a break should these symptomsbecome evident.


restrictions on the title page of this Work, Safety, Health and Emergency Response Plan. *FM #0219-94 44

issue N* 1 Work, Safety, Health, and Emergency Response PlanDate: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

The following heat stress/cold stress monitoring program will be utilized at the projectsite:

For workers wearing impermeable encapsulating ensembles, monitoring will take placewhen the ambient temperature is above 70° F. It may also be necessary to monitorat lower temperatures if the relative humidity is high.

To monitor the worker, the following physiological test will be performed:

Heart Rate. Count the radial pulse during a 30-second period immediately followingthe end of a work period.

If the heart rate exceeds 140 beats-per-minute at the end of a work period and 100beats-per-minute at the end of a rest period, shorten the next work cycle by one-thirdor lengthen the rest period by one-third.

If the heart rate still exceeds 140 beats-per-minute at the end of the next work cycle,shorten the following work cycle by one-third or lengthen the rest period by one-third.

The frequency of physiological monitoring depends on the air temperature adjustedfor solar radiation and the level of physical work (see Table 7.1). Energy levels forwork rarely exceed 250 kcal per hour, except for short intervals of elevated activitylabor. The length of the work cycle will be governed by the frequency of the requiredphysiological monitoring.

Cold stress will be mitigated through training workers to recognize the signs of coldstress (e.g., hypothermia), monitoring the outside temperature, and ensuring the useof "warming" breaks during cold temperature operations.

An ample supply of potable water will be maintained in the support zone for use bythe crew during breaks.


restrictions on the title page of this Work, Safety, Health and Emergency Response Plan. *FM »0219-94 45

l«iue N* 1Date: October. 1994


TABLE 7.1

REQUIRED FREQUENCY OF PHYSIOLOGICAL MONITORING

ADJUSTED TEMPERATURE

90° F. or Above

87.5° -90° F.

82.5° - 87.5° F.

77.5° - 82.5° F.

72.5° - 77.5° F.

IMPERMEABLE ENSEMBLE

After each 15 minutes of work





Adjusted air temperature (ta adj) is calculated using the following equation:

ta adj (degrees F.) = ta degrees F. + (13 x % sunshine).

Measure air temperature (ta) with a standard mercury-in-glass thermometer, the bulbshielded from radiant heat.

Estimate percent sunshine by judging what percent time the sun is not covered byclouds that are thick enough to produce a shadow. (100 percent sunshine = nocloud cover and a sharp, distinct shadow; 0 percent sunshine = no shadows.)

Section 7.3 - Exposure Monitoring

Ambient conditions will be monitored using the procedures described in Section 8.Such monitoring will help define the potential for exposure to hazardous airbornecontaminants.

Any employee who is exposed to hazardous substances will be taken to a medicalfacility for professional evaluation. Anytime that an employee has developed signsor symptoms indicating possible exposure to a hazardous substance, the employeewill be taken to a hospital for examination, and can return to work only when theexamining physician has given a written clearance.

3H1544

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'Use or disclosure of data contained on this sheet is subject to therestrictions on the title page of this Work, Safety. Health and Emergency Response Plan. *

46

i««ue M* 1 Work, Safety, Health, and Emergency Response PlanData: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

SECTION 8.0 - AIR MONITORING

Section 8.1 - Sampling Techniques and Instrumentation

Protection of personnel and the environment require that air quality be monitoredduring the project. Air quality data will permit the use of adequate Personal ProtectiveEquipment. It will also demonstrate the effectiveness of engineering controls incontaining and disposing of potential air contaminants.

A variety of techniques will be employed due to the range of possible gases.Atmospheric conditions will be monitored at an on-site meteorological station. Airquality will be monitored with a photoionization detector, combustible gas and oxygendeficiency indicators, and calorimetric indicator tubes.

The Meteorological Station will provide instantaneous and historical records ofatmospheric conditions. This includes instantaneous temperature, daily high and lowtemperatures, wind speed and direction.

A wind sock will be present on site for quick reference by personnel in the event ofan emergency.

Survey equipment will be used to provide real time measurements of air quality duringoperations. These instruments will include either a portable photoionization detectoror flame ionization detector. Concentrations of volatile organic compounds can bedetermined by these techniques.

An HNu photoionization detector with a 10.2 eV probe will be used to detect a varietyof gases ranging from simple, saturated hydrocarbons to arsine compounds, if arelease or leak should occur when handling or treating a cylinder.

The HNu will be calibrated daily before the start of the work day to a 100 ppm NBStraceable isobutane source standard. The instrument directly reads in ppm (0 to 2000ppm range - 3 scales (x1, x10, x100), and is also intrinsically safe for explosiveatmospheres. With the 10.2 eV probe, the HNu is capable of detecting a wideselection of chemical compounds with ionization potentials below 10.2 eV.

Many gases cannot be detected by the organic vapor survey instruments. Becauseof this gas-specific indicator tubes will be used for periodic sampling duringoperations. Indicator tubes for a variety of gases will be available at the site.Indicator tubes will be used any time there has been an apparent release or after oneof the specific gases has been identified by other means.

3"1545"Use or disclosure of data contained on this sheet is subject to the

restrictions on the title page of this Work, Safety, Health and Emergency Response Plan. *FM t0219-94 47

N*. i Work, Safety, Health, and Emergency Response PlanData: October. 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

Draeger Tubes will be used on a periodic basis in the exclusion zone to qualitativelydefine readings. In case the HNu fails on site, they will serve as backup instrumentsfor air monitoring.

The tubes are direct reading and require no calibration within ambient temperature andhumidity ranges. They are available for approximately two hundred (200) differentchemicals in different ppm or mg/m3 ranges, and ERC will store on site a selection ofsome of the most common, hazardous compressed gas detector tubes.

A combustible gas indicator and oxygen deficiency meter will also be available on site.These will be used prior to entry into enclosed spaces such as the VCS or CRV.

The CGM Model 929 or equivalent portable gas monitor will be used whenever thereis a potential or suspected leak or release of a flammable gas, toxic gas, or oxygengas during handling of cylinders. It will show any potential explosive atmosphericconditions for flammables, sudden increases in specific toxic gas levels, or suddenincreases or decreases in oxygen content in the surrounding environment andexclusion zone.

The instrument is a solid state microprocessor with the following sensors: combustiblegas meter, oxygen meter, carbon monoxide or hydrogen sulfide, and toxic alert meter.The instrument will be field calibrated daily to a 50% LEL methane, 200 ppm carbonmonoxide, 20% per volume oxygen combination test gas daily. It is a direct readinginstrument for all four sensors simultaneously, and is intrinsically safe for flammableatmospheres.

The special toxic alert sensor reads out in a increasing bar graph with an user setalarm. Since the sensor is based on solid state semiconductor toxic gas principle, thetoxic alert sensor detects a wide array of toxic chemicals including acids, bases,fluorochlorocarbons, nitrogen-based compounds, solvents, alcohols, petroleumhydrocarbons, cyanide and its derivatives, plus sulfur compounds.

A primary function of the Site Safety Officer will be air monitoring. He will coordinatemonitoring of the contained work areas and perimeter monitoring. Ambientmonitoring of some sort will occur continuously throughout operations.

An Air Analysis Data Form (Appendix B, Form 11) will be maintained, and reviewedon a regular basis. This record will document the air monitoring program and includethe following information:

- Instrument field calibration;- Type of instrument being used;- Date and time;- Location of monitoring; ,- .. -

Jl'154'Use or disclosure of data contained on this sheet is subject to the

restrictions on the title page of this Work, Safety, Health and Emergency Response Plan.'FM *0219-94 48

M* i Work, Safety, Health, and Emergency Response PlanDate: October, 1994 EnviroClean-Noitheast, Inc., Malta Rocket Fuel Area Site

- Wind direction;- Air temperature;- Instrument air readings; and- Suspected compounds and exposure limits.

Section 8.2 - Sampling Types and Frequency

Air monitoring will be conducted on a regular and periodic basis and whenever:

- Employees are handling a leaking gas cylinder;

- Any reaction or vapor cloud is observed;

- During all treatment operations;

- Entry into secondary chamber of the CRV or LCTU; and

- Upon request by the client.

Air monitoring is particularly important during the batch treatment operations. The airmonitoring technique will be selected based upon the nature of the gas being treatedand any expected reaction products. Pressure transducers within the system also givean indirect indication of treatment efficiencies.

Section 8.3 - Equipment Calibration

Air monitoring equipment will be calibrated in accordance with the manufacturer'sinstructions. These procedures are described in the project Quality Control andQuality Assurance Plan.



(••(Ml* 1

Data: October, 1994Work, Safety, Health, and Emergency Response Plan

EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

SECTION 9.0 - DECONTAMINATION PROCEDURES

Decontamination is an essential function of any field activity that deals withpotentially hazardous chemicals. Decontamination of personnel and equipmentprevents the uncontrolled spread of potentially toxic materials into cleanenvironments.

Since the potential for non-volatile contamination is small when handling gas cylin-ders, personnel decontamination is required only under special circumstances. Thesewould include the development of non-volatile reaction products during a release orfinding non-volatile cylinder contents. On the other hand, all equipment used duringthe sampling procedures will be decontaminated at the end of the project to ensurethat all residues are removed.

Due to the volatile and gaseous nature of the compounds on site, CRV and valvesampling equipment decontamination will typically be accomplished through vacuum- purge sequences.

Any wastes generated during the decontamination process will be properly contained,packaged, and labeled according to applicable regulations.

All decontamination activity will be monitored by the Site Safety Officer, who isresponsible for ensuring that all personnel and equipment undergo adequatedecontamination prior to leaving the confines of the site. The SSO also ensures thatall appropriate decontamination protocols are followed by personnel going through thedecontamination.

In addition, all ERC personnel working on the project are thoroughly trained in thereasons behind decontamination and in the proper ERA protocol to follow for Level A.These protocols, which will be implemented on-site, meet the EPA's standarddecontamination procedures, and are summarized below:

Personnel Decon: Located within the Contamination Reduction Corridor (CRC)

Level A Protocol:

Station - 1:

Station - 2:

Station - 3:

Equipment drop - See equipment decon below.

Suit, boots, and outer gloves wash - suit, boots, and gloves arescrubbed with a dishwashing detergent solution in separateportable tubs.

Suit, boots, and outer gloves rinse - suit, boots, and gloves arerinsed off in separate primary then secondary rinse tubs.

3H1548'Use or disclosure of data contained on this sheet is sub/act to the


H*. 1 Work, Safety. Health, and Emergency Response PlanD.M: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

Station - 4.0:

Station - 4.1:

Station - 5:

Equipment Decon:

Station - 1.0:

Station - 1.1:

Station - 1.2:

Station - 1.3:

Suits, boots, and outer gloves removal - suit and boots arestored, and gloves are discarded in a drum.

Respirator cleaning - All respirators will be hand washed/rinsedin provided tubs only for respirators. After cleaning, masks willbe disinfected and properly stored.

Personnel clothing change, if appropriate.

(Hand Tools)

Equipment drop - Tools and equipment will remain in the workarea unless they require service, repair, or need to betransported out of the Exclusion Zone.

Equipment wash - Equipment will be washed down in portabletubs separate from the personnel decon tubs.

Equipment rinse - Equipment will be doubled rinsed in portabletubs separate from the personnel decon tubs.

Equipment tagged - All equipment deconned thoroughly, will betagged to identify it being clean and safe for removal from CRCto the Support Zone.

FM 10219-34

"Use or disclosure of data contained on this sheet is subject to therestrictions on the title page of this Work, Safety, Health and Emergency Response Plan.'

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i»»u« M*. 1 Work, Safety, Health, and Emergency Response PlanData: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

SECTION 10.0 - CONFINED SPACE ENTRY

Personnel working in limited egress/confined spaces may be exposed to potentialsafety hazards. To help ensure the safety of its personnel, ERG requires that workwithin confined spaces be based on the practices adopted by the American NationalStandards Institute (ANSI), the Chemical Manufacturing Association (CMA), and theNational Institute for Occupational Safety and Health (NIOSH).

The definitions of a confined space is as follows:

- Enclosures that have limited openings for entering and exiting;

- Lack adequate ventilation;

- Contain life-endangering atmospheres such as those containing toxicflammable or corrosive contaminants or those without enough oxygen; and

- Present potential mechanical, electrical, or fire hazards.

Confined spaces include storage tanks, process vessels, towers, stacks, pits,trenches, degreasers, boilers, ventilation and exhaust ducts, manholes, and anyopen-topped space more than four feet (4') in depth, that does not have adequateventilation.

The Hot Zone is confined space for purposes of this project and will include the VaporContainment Structure, the LCTU, and the CRV when they are closed or in use.

A confined space entry permit is required every time a worker enters the limitedegress area. A confined space permit is good for one day only and must include dateof entry, time of entry and exit, hazard identification, operational scope, oxygencontent, toxic levels if any, lower explosive level (LEL), personnel requirements, andsignatures from all personnel involved in the project.

The confined space entry permit form is included in Appendix B, Form 7.


restrictions on the title page of this Work, Safety, Health and Emergency Response Plan.'FM10219-94 52

IHU« M*. 1 Work, Safety, Health, and Emergency Response PlanDaw: Octobar. 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

SECTION 11.0 - SPILL CONTAINMENT

The ultimate objective of the project is to remove wastes from the site while pre-serving off-site areas. Degradation of air, water, land and other natural resources willbe avoided through procedures and operational protocol described in this plan.

Section 11.1 - Spill Scenarios

Section 11.1.1 - Release of Gas or Vapors

Site operations will focus on remediation of compressed gas cylinders. Typically thesematerials are reactive or have high vapor pressures at room temperature. Given thenature of these materials, air is the portion of the environment most likely to beimpacted by site operations.

A cylinder may release volatile contents in a variety of failure modes. The mostcommon is failure of the valve. Leakage around the valve threads is also a commonleak point. Most leaks of this nature are not catastrophic and occur over an extendedperiod of time.

Catastrophic failure of cylinders with complete release of contents is uncommon. Itcan occur, however, where the cylinder integrity is affected by corrosion, damage, oroverpressurization.

Cylinder failure can also occur through reaction or exothermic decomposition of thecontents.

The primary means of protecting air quality at the site is containment of thecompressed gases. This is accomplished in the enclosed sampling and treatmentsystems.

Containment for leaking cylinders is available at the site. A leaking cylinder may betransferred to a suitable overpack. Additionally, the CRV and LCTU offer chamberswhich may be used to control leakage.

The sampling and treatment systems are housed in air-tight chambers. Should arelease occur during operations, the secondary containment chamber can controlrelease to the environment.

The Vapor Containment Structure is intended to control most releases of pressurizedcontainers. Emergency treatment systems are located inside of the structure forremoval of contaminants. Although the system does not offer complete containment,it does effectively slow the movement of contaminates into the environment.



i»ua N* 1 Work, Safety, Health, and Emergency Response PlanDate: October. 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

Treatment of the cylinder contents will be carefully controlled and monitored toprevent adversely impacting air quality at the site. On-site air monitoring capabilitiescan detect releases from the exhaust into the vapor containment area. Regulators andvalves used in the system provide positive control of the process with emergency shutdown capability. The system is designed to exhaust into a contained area providingadditional opportunity to treat an uncontrolled release.

Section 11.1.2 - Liquid Spills

Liquids will be handled during the project. These include decontamination rinsewaters, fuels, and possibly non-volatile cylinder contents. Release of liquids couldaffect soil, surface, and ground water quality.

Liquids used for treatment reagents may include acids (sulfuric and hydrochloricsolutions), caustic (sodium and potassium hydroxide), and potassium permanganateand bleach, (oxidizing solutions). These liquids are stored in fifty-five (55)-gallondrums until use.

Rinse water will also be produced from personnel decontamination and cylinder shellcleaning. These liquids will be containerized in drums along with spent reagents.

Control of liquid spills will be facilitated by minimizing the container quantities.Further, all storage areas will be lined with plastic for secondary containment.

Liquids used in scrubbers within the LCTU trailer have secondary containment in thetreatment chamber.

Section 11.1.3 - Solid Spills

A variety of granular solids are used in the cylinder management operation.Adsorbents such as activated carbon, molecular sieve, and alumina may be presenton site.

The adsorbents are stored in fifty-five (55)-gallon drums. The emergency treatmentunit contains approximately five hundred (500) gallons of dry, granular adsorbent. Aspill from these containers would be very localized and easily recovered.

Solid wastes generated during the project will consist principally of general refuse andcleaned cylinder shells. As these are non-hazardous wastes, they may be disposedof as scrap metal.



to«ua I* i Work, Safety, Health, and Emergency Response PlanData: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

Solid waste to be disposed of as hazardous waste include any adsorption media usedin sampling processes. These will also be staged for disposal at a permitted treatmentor disposal facility. These materials will be containerized in drums at the site for laterdisposition.

Solid residues will be removed after the cylinders are opened for inspection. Thesewill be transferred to fifty-five (55)-gallon steel drums for subsequent identificationand disposal.

Section 11.2 -Spi l l Response

Cylinders found at the site may be in deteriorated condition. Handling of the cylindersas required for operations increases the possibility of an uncontrolled release. Eventhough such an occurrence is unlikely, handling will be minimized to reduce this risk.

A leaking cylinder can be quickly secured by transferring it into the CRV and sealingthe hatch. These procedures can also pertain to the LCTU chamber and cylinderoverpack.

The following procedures will be followed should a cylinder leak be detected duringhandling.

1. The portable air horn will be sounded immediately to clear the site of allnon-essential, unprotected personnel. Personnel not involved in the spillresponse will exit to an upwind location outside of the fenced compound.

2. The general emergency procedures for spills will be implemented andnotifications initiated. Specific contingency plans for a gaseous release asdescribed in this plan will immediately be implemented.

3. If possible, the cylinder handlers will leave the leak oriented in such a way thatit would be above the liquid level in a liquefied gas cylinder (generally with theleak point located at the highest possible position).

4. Cylinder handling personnel will exit the area. The Site Manager will determineby examination and air monitoring whether the cylinder is safe to approach.

5. If the CRV is present and the Site Manager indicates that the cylinder can beapproached, handlers should immediately move it to the CRV. If it cannot beapproached, monitoring should continue at a safe distance to determine theeffectiveness of the emergency treatment systems.

3f>1553"Use or disclosure of data contained on this sheet is subject to the

restrictions on the title page of this Work. Safety, Health and Emergency Response Plan. 'FM 90219-94 55

i»u« M»: i Work, Safety, Health, and Emergency Response PlanDate: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

6. If the cylinder is removed to the CRV, a sample should be obtained as soon aspossible for identification. When the compound has been identified, airmonitoring should be focused to determine the effectiveness of emergencytreatment systems and the containment structure.

7. Depending on the contents, the Site Manager will determine whether the gascan be safely processed following standard CRV operation protocol. Theprotocol may be modified due to the presence of an air mixture in the CRV.Unless the atmosphere is non-explosive, drilling will not be done and contentswill be extracted through the leak.

8. The atmosphere of the containment chamber will be tested for significantconcentrations of the gas. If necessary, the chamber atmosphere will bepurged through an appropriate treatment system.

Because of the sealed containment chamber, it is highly unlikely that a release willoccur during cylinder sampling. If a release does occur and the compound can beidentified, the containment chamber will be purged through an appropriate treatmentsystem.

Equipment and materials will be maintained on-site to respond to spills of liquidsencountered during the operation. Adsorbent and shovels will be the primary meansof control since the quantities of liquids handled are typically fifty-five (55) gallons orless. In the event of this type of spill, the client will be immediately notified.Personnel will attempt to contain the leak in suitable Personal Protective Equipment.Absorbent will be used where free liquids are present.

Open head drums shall be maintained on site for the purpose of containerizing anywaste generated during the operation, including spill contaminated soil.

The procedures specified in this section are to be implemented in conjunction with theMalta Rocket Fuel Area Site Health and Safety Plan (Appendix C).

3<'1554'Use or disclosure of data contained on this sheet is subject to the


N*. i Work, Safety, Health, and Emergency Response PlanDat«: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

SECTION 12.0 - EMERGENCY RESPONSE

Based on the Site Hazard Assessment and the approved work plan, the followingemergency procedures for the project are geared towards responding effectively toeither a personal injury crisis, an uncontrolled gas release or leak, or an explosion orfire.

These procedures are additional to those specified in the Malta Rocket Fuel Area SiteHealth and Safety Plan (see Appendix C). A copy of the plan shall be maintained inthe control trailer and will be reviewed at site "orientation meetings.

Section 12.1 - Emergency Medical Assistance and First Aid

The most common accidents that occur during site operations are physical injuries.Adequate protection from the chemical and physical hazards will be afforded to eachemployee. Accidents such as tripping, falling, and bumping into stationary objectsare, however, difficult to completely protect against. Each person working at the sitemust use their own judgment and common sense to keep these kinds of accidents toa minimum.

Rudimentary first aid equipment will be available at the site to treat minor injuries butfor more serious accidents, outside professional help will be called upon. All ERCpersonnel have received training in emergency First Aid and CPR.

A copy of the Matheson First Aid for Exposures to Compressed Gases will bemaintained on site for ready reference.

Victims of toxic inhalation must be moved to fresh air. Artificial respiration may berequired immediately if breathing has stopped. Oxygen should be administered if therehas been a severe exposure and breathing is difficult.

Dermal exposures may be treated by flushing the skin with copious amounts of freshwater. This should be continued as required to control the burning sensation. If theskin has been broken or blisters, professional medical assistance is also required.

An emergency shower will be located immediately outside of the Vapor ContainmentStructure.

For eye contact there should be an immediate flushing with water. This shouldcontinue for at least 15 minutes. The victim's eyelids should be held open to providecomplete irrigation. Medical assistance is required when there has been eye contact.



M* 1 Work, Safety, Health, and Emergency Response PlanDat.: October. 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

For eye injuries, a portable safety eye wash station will be located in each CRC. Afirst aid kit will be fully stocked and ready for on site use. The first aid kit will belocated in the support zone, and employees will be notified of its location.

Medical emergencies requiring immediate care will be handled at the nearestemergency treatment facility. Emergency telephone numbers, including theambulance phone number, will be kept posted in conspicuous location in thecommand area.

Each location will have a map showing the most direct route to the hospital (seeFigure 12.1). The maps will be posted in the mobile laboratory and in ERG vehicles.

Upon identification of an injury requiring emergency medical assistance, thedesignated emergency signal will be sounded (a series of short blasts), and all on-siteactivities will cease. The injured person, if in one of the exclusion zones, will beretrieved and moved into the Contamination Reduction Corridor (CRC) as quickly aspossible, if permitted by the type of injury. The SSO will assess the injury(ies), andthe person will be decontaminated as best as reasonable under the circumstancesprior to movement to the hospital. The SSO will initiate the appropriate first aid, and,depending on the injury, the injured worker may be taken to the hospital, or waitarrival for the paramedics and ambulance.

If the injured person is in the support zone, first aid will be given immediately, anddepending on the nature of the injury, the SSO will notify the paramedics andambulance.

A list of the potential gas hazards to which the person was exposed, and thesuspected cause of injury will be taken with the injured person to the hospital. All on-site activities will cease until a full investigation and report is made by the SSO, andreviewed (at a minimum) by the Corporate Safety Officer.

Section 12.2 - Explosion or Fire

Upon identification of an explosion or fire, the designated emergency signal will besounded (a long continuous blast), and all site personnel will evacuate the site to thedesignated upwind area (outside of the entrance gate to the storage facility). At thistime, the SSO will determine if an attempt should be made to extinguish the fire usingon-site extinguishers. If no attempt is made, or the fire is uncontrollable, the SSO willimmediately notify the EnviroClean-Northeast Emergency Coordinator (see the MaltaRocket Fuel Area Site Health and Safety Plan, Appendix C) and the local firedepartment.



laaua NT. i Work, Safety, Health, and Emergency Response PlanData: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

At least one fire extinguisher rated 1-A:10-B:C or better will be located in each of thefollowing areas in:

- Cylinder staging areas;- CRC zones;- Secondary containment chambers; and- Each support trailer.

If the Site Manager or Site Safety Officer determines that an attempt to extinguish thefire should be made, the following practices will be adhered to:

- Only those individuals trained in how to use a fire extinguisher will operate them;

- Employees using the fire extinguishers will not allow the fire to come betweenthem and their safe exit from the site; and

- If after the application of the fire extinguishing agent the fire is not out or atanytime seems to intensify, the employees fighting the fire will immediately exitthe area, and the Site Safety Officer will notify the fire department immediately.

Section 12.3 - Pre-emergency Planning and Coordination

ERG will work with the EnviroClean-Northeast personnel to complete pre-emergencyplanning and coordination. Prior to start of operations, ERC's Site Manager and theEnviroClean-Northeast Emergency Coordinator will meet to discuss their respectiveroles in implementation of emergency procedures.

Section 12.4 - Personnel Responsibilities

Each member of the crew will have designated duties and responsibilities to performin the event of an emergency situation at the site. These duties will include suchtasks as shut-down of various equipment, activation and use of containmentprocedures, and other emergency-related tasks.

The Site Manager is primarily responsible for coordination of ERC's response to theemergency. He will evaluate the appropriate technical response. He will also beresponsible for notification of the EnviroClean-Northeast Emergency Coordinator.

The Site Manager will assign personnel to the various tasks required for the response.ERC's technical personnel will implement the response actions as directed by the SiteManager.


FM *0219-94 59

M* 1 Work, Safety, Health, and Emergency Response PlanDaw: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

Section 12.5 - Communication and Notifications

An alarm system will be established at the site in order to notify crew members inthe event of an emergency. Air horns will be located in the containment area and inat least one location in the Support Zone (see "Safety Zone Delineation"). In eventof an emergency, the person first recognizing the situation will institute the alarm.

One steady blast of the warning alarm will be used to indicate an uncontrolled releaseand will serve as notification that emergency procedures should be set into motion.

Intermittent blasts of the warning system indicates an injury or illness at the locationof the blasts. (The team leader of the cylinder handling crews will carry a portable airhorn.) Remaining crew members will respond immediately and render whateverassistance is necessary. First aid kits will be located on-site in order to expediteemergency care. In the event of an injury emergency, the injured person will beremoved from the working area immediately (depending on the severity of the injury)and given prompt medical attention.

External communications at the site will be handled through the use of a telephone.This telephone will be located in the command trailer or Mobile Laboratory and usedas the principal communication link to emergency service agencies (e.g., firedepartment and emergency medical services).

The key telephone numbers that will be posted at the site are as follows:

LOCAL

Ambulance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . (518) 889-2100Local Fire Department . . . . . . . . . . . . . . . . . . . . . . . . . . . (518) 885-1701Local Police . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . (518) 885-6761Hospital . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . (518) 587-3222All Emergency Services can also be reached by . . . . . . . . . . . . . . . . . . . 911

NATIONAL

National Response Center . . . . . . . . . . . . . . . . . . . . . . . . . (800) 424-8802Pesticide Information Service . . . . . . . . . . . . . . . . . . . . . . . (800) 845-7633RCRA Hotline . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . (800) 424-9346CMA Chemical Referral C e n t e r . . . . . . . . . . . . . . . . . . . . . . (800) 262-8200U.S. D.O.T. - Day . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . (202) 366-0656U.S. D.O.T. - Hotline . . . . . . . . . . . . . . . . . . . . . . . . . . . . (202) 426-2075

3 r. 155 8'Use or disclosure of data contained on this sheet is subject to the

restrictions on the title page of this Work, Safety, Health and Emergency Response Plan. 'FM *0219-94 60

i««u« >* i Work, Safety, Health, and Emergency Response PlanData: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

Earth Resources Corporation

CONTACTS

24-Hour Answering Service . . . . . . . . . . . . . . . . . . . . . . . . (407) 877-0877Direct Office Line, After Hours . . . . . . . . . . . . . . . . . . . . . . (407) 877-0877Fax: Automated Line, 24 Hours A Day . . . . . . . . . . . . . . . . (407) 877-3622Director of Operations, Ed Van Schoick, Home . . . . . . . . . . (813) 269-9279

As an additional contingency, emergency vehicles and/or personnel, including fire,ambulance, and police, can be dispatched through calling the emergency number,911.

In the event of an emergency at the site, both the police and fire departments may benotified. These agencies will then respond and implement the evacuation plan and/orrender emergency assistance as necessary in the potentially affected areas.

On-site communications will be conducted using hand-carried air horns and radios.Radio communications will be used whenever possible to link active work areas withthe command post. Workers in the command trailer will continuously monitorprogress of the work by means of the radio.

Section 12.6 - Emergency Recognition and Prevention

An emergency associated with a release of compressed gas will be recognized by airmonitoring equipment. A release can be prevented by careful operations inaccordance with the procedures established in this plan.

Should a release occur, the severity of the emergency will be evaluated by the SiteManager based upon a number of factors. These factors include:

- The location of the leak;- Whether the leak is vapor or liquid phase;- The volume of the release;- The capacity of emergency treatment systems;- The measured effectiveness of the Vapor Containment Structure based on

air monitoring results; and- The ability to stop the release and the required time.

The Site Manager will provide the EnviroClean-Northeast Emergency Coordinator withinformation describing each factor and a recommended action. Any leak will requireimmediate response by ERC personnel.


FM 10219-94 61

N* i Work, Safety, Health, and Emergency Response PlanDate: Octobsr, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

Release of liquid from a container will be recognized by visible indications of moisture.Leakage can be avoided by care in handling of the liquids.

A medical emergency can be recognized by co-workers' observations. This is thebasic principle supporting the buddy system. Medical emergencies will be preventedby observing the work and safety procedures described in this plan.

Section 12.7 - Safe Refuge Locations

Safe Refuge locations will be dependent upon wind direction. Any such location willbe in an upwind direction as shown by site wind indicators. The primary Safe Refugelocation will be immediately outside of the fenced storage area next to the telephone.

Section 12.8 - Evacuation Routes and Procedures

Evacuation of on-site personnel will take place should a large-scale release take placeand pose a health threat to these personnel based upon current wind speed/winddirection information. ERG personnel will exit the site to the primary safe refugelocation unless wind direction makes the location hazardous.

ERG will assist the Emergency Coordinator and the local agencies in the evacuationeffort as directed.

When an alarm is sounded, all unprotected personnel shall evacuate the site.Evacuation shall be by means of the gate to a safe, upwind location.

After exiting the site, personnel shall move in an upwind direction at least twohundred feet (200') from the site. An accounting shall be made to determine whoremains on site.

Designated individuals in the support zone may, if safety permits, move to emergencySCBA staging areas and don Level A PPE. With this equipment they may attempt (inpairs) to investigate the source of alarm and offer such assistance as may be safe andappropriate under the circumstances.

Section 12.9 - Emergency Decontamination

Decontamination in an emergency will be completed only to the extent necessary toavoid contamination of unprotected personnel. In the case of an injury, the need fordecontamination will be balanced against such a potential exposure.

Decontamination will not be a major concern for releases of most compressed gases.Drench showers will be available for gross decontamination.

3<\1560'Use or disclosure of data contained on this sheet is subject to the


N* i Work, Safety, Health, and Emergency Response PlanData: October. 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

Section 12.10 - Emergency Training and Rehearsal

Emergency response procedures will be reviewed at the initial site safety briefing.Prior to the start of operations, response procedures will be rehearsed using full PPEand equipment.

Section 12.11 - Emergency PPE and Equipment

All on-site workers will have an assigned SCBA readily available at the site. There willbe two (2) spare SCBA's located on-site for the duration of this project for use inemergency situations and for short-term ingress egress to the active work areas. Allof the SCBA's will be equipped with a spare air supply cylinder to allow expeditiouschange-out of depleted tanks should the units be placed into service for protractedperiods.

Support personnel located in the command area will not be required to wearrespiratory protective devices for normal operations. However, emergency escapepacks and/or SCBA's for two (2) individuals will be provided in the command area atall times.

An emergency drench shower will be located next to the containment area for usein the event that a large quantity of liquid comes in contact with any site personnel.

Section 12.12 - Response Review and Follow-up

A review of each response is required prior to resumption of normal operations. Thereview will cover the nature of the emergency, how it occurred and how it could havebeen prevented. The appropriateness of the response actions will also be reviewed.

Any changes implemented as a result of the response review will be formallyincorporated into this written plan.

3r'156l'Use or disclosure of data contained on this sheet is subject to the

restrictions on the title page of this Work. Safety, Health and Emergency Response Plan. 'FM 90219-94 63

M* i Work, Safety, Health, and Emergency Response PlanD.t.: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

FIGURE 12.1

ROUTE TO NEAREST HOSPITAL

Directions to Hospital

Leaving the west access road from the site, proceed west along Dunning Street toRoute 9. Take Route 9 North to Saratoga Springs. After approximately 4.5 miles,turn left on Church Street. After approximately 1/3 mile, the hospital is on the right.

SARATOGA HOSPITALChurch Street

Saratoga Springs, New YorkPH: (518) 587-3222

Emergency PH: (518) 583-8313

"Use or disclosure of data contained on this sheet is subject to therestrictions on the title page of this Work, Safety, Health and Emergency Response Plan. '

FM t02J9-94 64

»* 1 Work, Safety, Health, and Emergency Response PlanOctober. 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

SECTION 13.0 - PROJECT ORGANIZATION

Section 13.1 - General Organization

ERG will provide the services described in this plan under a contract with EnviroClean-Northeast. ERG will interface with the designated representative from the Office ofEnvironmental Health and Safety.

A project organization is proposed which will provide the correct mix of professionalexpertise and technical ability to complete the project. Project organization isgenerally depicted by Figure 13.1. Resumes of key personnel are included in theproject Quality Assurance and Quality Control Plan.

ERC's Director of Operations, Mr. Ed Van Schoick, will be responsible for the overallperformance of the contract. He will be assisted by the Quality Control Manager (Mr.Chuck Mattern), and ERC's Health and Safety Manager (Mr. Dan Nickens). Contractadministration will be provided by Mr. Bob McBride.

Mr. Ed Van Schoick will serve as Project Director. He has managerial responsibilitiesfor technical operations. He will coordinate field efforts from both the office and field.

Mr. Tom Gysin will serve as Site Manager. Mr. Gysin is responsible for routineoperations and personnel assignments.

Ms. Linda Stewart will serve as Site Safety Officer. On-site analysis will be performedby Ozzie Vargas.

The function of Quality Control Officer will be performed by Mr. Chuck Mattern. Thesite analyst will provide copy of all laboratory data to Mr. Mattern for review andapproval. Mr. Mattern will be available for consultation on unusual analytical andtechnical problems.

Remedial technicians proposed for this project are all experienced in cylinder handlingand CRV operations. All site personnel have as a minimum completed a forty-hourcourse for remedial operations and other training required by ERG.


FM »0213-94 65

i«iu* N* i Work, Safety, Health, and Emergency Response PlanD«t«: October. 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

Section 13.2 - Safety Administration

The safety organization at ERG is based on line management responsibility. Safetyresponsibilities are a major part of every employee's annual review.

The Corporate Health and Safety Officer, Mr. Dan Nickens, will overseeimplementation of safety programs on a corporate level. He will be responsible toensure compliance with all applicable health and safety standards.

Mr. Mattern wHI assist the Project Director in implementing specific safety programsin his capacity as Quality Control Officer. He will oversee and provide technicalguidance to field managers and analysts.

ERC's Site Manager (SM), Mr. Tom Gysin, and the Project Director (PD), Mr. Ed VanSchoick, will be responsible for the general oversight and progress of the project. TheSite Manager and Project Director will ensure that all work is completed in accordancewith project plans and contractual requirements.

The Site Manager will have the following responsibilities for site safety:

- Promoting personnel health and safety awareness by providing training andfamiliarity with health and safety procedures and emergencyresponse/contingency plans:

- Providing information to all personnel concerning potential hazardsassociated with the site conditions and operations;

- Supervising and monitoring compliance with the site safety plan, and theperformance of good work practices of all personnel; and

- Correcting any work practices or conditions that would expose personnelto possible injury or hazardous conditions.

ERC's Site Safety Officer (SSO), Ms. Linda Stewart, will be responsible for on-siteimplementation and enforcement of the Site Safety Plan. The SSO will report directlyto ERC's corporate safety officer, Mr. Dan Nickens.

Duties of the SSO will include:

- Enforcing compliance with the site safety plan;

- Maintaining health and safety equipment used at the site;

- Initial site orientation training of all on-site personnel; and301564


FM 10219-94 66

* i Work, Safety, Health, and Emergency Response PlanDat.: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

- Development, assistance, supervision, and execution of the air monitoringprogram;

- Collection and interpretation of readings from field instrumentation anddevices pertaining to air quality;

- Providing on-site support, safety supervision, and maintenance of safetyequipment and supplies;

- Monitoring of employees for heat stress;

- Activation of emergency response procedures;

- Maintenance of all reports relating to the safety aspects of the project;

- Monitoring of decontamination procedures;

- Ensuring that all federal safety requirements are met and exceeded;

- Conducting and logging in the daily safety meeting; and

- Stopping all site activities at any time if he feels there is a potential dangerto a person's health and safety or to the surrounding environment.

If at any time during the project an employee feels that there is a safety problem thatwas not anticipated and/or that he is not prepared to meet in an operation, he willimmediately notify the SSO or SM for re-evaluation of the operation. The SSO or SMat that time will cease the specific activity in question until the problem is resolved.

Section 13.3 - Project Data and Files

Project files containing technical and administrative information will be maintained byERC at its Orlando, Florida headquarters. The Site Manager will maintain a field copyof all relevant technical information. This will be given to ERC's contractadministrator, Mr. Bob McBride, at the conclusion of the project. Copies of all projectdocuments and data will be provided to EnviroClean-Northeast.

At the conclusion of the project a brief report will be prepared. As a minimum, thereport will describe site activities and report results. Data collected during the courseof the project will be organized and summarized. Information included in the reportwill include:

- Air monitoring results;- Cylinder sampling results; 3

'Use or disclosure of date contained on this sheet is subject to therestrictions on the title page of this Work, Safety, Health and Emergency Response Plan. *

FM 90219-94 67

tf. 1 Work, Safety, Health, and Emergency Response PlanD.t.: October. 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

- Site access logs;- QA/QC daily reports;- Cylinder tracking logs.

Copies of all project photographs will be forwarded with the report.


restrictions on the title page of this Work, Safety, Health and Emergency Response Plan.'FM $0219-94 68

i Work, Safety, Health, and Emergency Response PlanData: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

FIGURE 13.1

EARTH RESOURCES CORPORATIONProject Oraganization

EdVanSchoickProjectDirector

BobMcBrideContract

Administrator

ChuckMattemQuality

Control Officer

Tom GysinSite

Manager

Dan NickensHealth

& Safety Officer

Ozzievargas/st

SiteTechnicians

Linda StewartSite

Safety Officer

FM i0219-94


69

. 1 Work, Safety, Health, and Emergency Response PlanD.t.: October. 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

SECTION 14.0 - GENERAL SAFETY PROVISIONS

In addition to the procedures delineated throughout this plan, operations will beconsistent with EnviroClean-Northeast'ssafety procedures and ERC's corporate healthand safety manual.

Section 14.1 - General Cylinder Handling Precautions

1. All cylinder sampling will be done in Level A Personal Protective Equipment.

2. Handling of the cylinders will be minimized to the greatest extent practicable.

3. Large cylinders are to be moved by means of cart or stretcher. The rolling ofany cylinder is prohibited.

4. General safe handling practices described in CGA P-1 1991 will be followed.

Section 14.2 - Safe Work Practices and Personal Hygiene

1. Every effort possible will be made to assure compliance by all employees withthe requirements of this safety plan. Each employee will be provided withinstruction regarding the general and site-specific requirements of the project.

2. A hand held air horn will be used to meet the requirements for an on-sitealarm.

3. Those employees using any equipment on site will follow the manufacturer'srecommendations on the safe use and handling of said equipment.

4. Only those employees trained in the use of specific equipment will bepermitted to use it. Those pieces of equipment requiring a driver's license willbe operated only by those employees possessing both the license and trainingto do so.

5. Horse play of any kind will be expressly forbidden while on the site.

6. Under no circumstances will employees eat, drink, chew tobacco or gum whilein the exclusion zone, contamination reduction corridor, or restricted areas.Smoking will be forbidden on-site at all times for the duration of the project.

7. Personnel will have clothing exclusively for wearing under the PersonalProtective Equipment. Also, semi-permeable coverall garments will beprovided for wearing during breaks. Clothes worn in contaminated zones shallnot be worn for transit to and from the site.


FM f 0219-34 70

Ift i Work, Safety, Health, and Emergency Response PlanDM.: October, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

8. Employees are encouraged to shower prior to eating or conducting personalbusiness.

9. The consumption of any alcoholic beverage on-site or the use of any narcoticwhile on-site is forbidden. The use of such items will result in the terminationof the employee plus possible legal actions.

Section 14.3 - Facility Work Requirements

1. ERC's employees will comply with all EnviroClean-Northeast policies andprocedures.

2. In case of fire, unauthorized entry or other emergency, the EnviroClean-Northeast Emergency Coordinator will be contacted. If the primary emergencycoordinator cannot be reached, an alternate emergency coordinator will becalled.

3. The work area will be kept free at all times from an accumulation of debris orunused equipment and tools.

4. All accidents and injuries, even minor in nature are to be reported.



i*«ue N* 1 Work, Safety, Health, and Emergency Response PlanOctober, 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

SECTION 15.0 REFERENCES

A variety of references are used in conjunction with this plan. Copies of the variousreferences will be maintained at the site during operations.

1. Corporate Health and Safety Manual. This document contains generalcompany policies governing health and safety. More detailed descriptions oftraining programs, respiratory protection programs, and hazard communicationprograms are contained in this manual.

2. HazGAS™ Operation and Maintenance Manual. This manual covers StandardOperating Procedures for the HazGAS™ unit. It contains equipmentspecifications, drawings, hazard analysis and maintenance guide.

3. CRV Operation and Maintenance Manual. This manual covers StandardOperating Procedures for the CRV. It contains equipment specifications,drawings, hazard analysis and maintenance guide.

4. Multiple Use Unit Operation and Maintenance Manual. This manual coversStandard Operating Procedures for the Multiple Use Unit (including the ValveSampling Chamber). It contains equipment specifications, drawings, hazardanalysis and maintenance guide.

5. Project Quality Assurance and Control Plan. Quality control proceduresapplicable to the project are described in this plan.

6. Generic Quality Assurance Plan. General procedures to assure quality controlare described in this document. It has been approved by the State of FloridaDepartment of Environmental Regulation for environmental analyses.

7. Chemical Data Sheets. ERC has developed data concerning chemicals foundin compressed gas cylinders. Data relevant to ERC operations are summarizedon these sheets.

8. Material Safety Data Sheet Notebook. MSDS information covering commongases, treatment reagents, and other chemicals which may be encounteredduring the work are maintained by ERC in a notebook.

9. Mass Spec Catalogue. A reference of mass spectroscopy data collected andmaintained by ERC.

10. FTIR Scans - Reference. Collected FTIR scans from analyses completed byERC using the Bomem Michelson 100 unit.

3<<1570


FM»0219-94 72

i*iue N»I 1 Work, Safety, Health, and Emergency Response PlanDate: October. 1994 EnviroClean-Northeast, Inc., Malta Rocket Fuel Area Site

11. Handbook of Compressed Gases. Third Edition, Compressed Gas Association,Arlington, VA, 1990. This is a basic reference for information coveringcylinders and compressed gases.

12. Gas Data Book. Sixth Edition, Matheson Gas Products, Secaucus, NJ, 1980.The book contains data covering common compressed gases.

13. The Merck Index. Eleventh Edition, Merck & Co., Inc., Rahway, NJ, 1989.An encyclopedia of chemicals, drugs and biologicals.

14. Hazardous Materials. Substances & Wastes Compliance Guide. 1993.Hazardous Materials Publishing Co., Kutztown, PA. Reference book withcopies of federal regulations covering hazardous materials and wastes.

15. Effects of Exposure to Toxic Gases. Second Edition, Matheson Gas Products,Secaucus, NJ, 1984. Practical first aid guide for exposure to hazardousgases.

16. Pocket Guide to Chemical Hazards. DHHS (NIOSH) Publication No. 90-117,Washington, D.C. 1990. Data related to industrial hygiene.

17. Safe Handling of Compressed Gas in Containers. Eighth Edition, CompressedGas Association P-1, Arlington, VA, 1991. This document covers general safehandling practices for cylinders.

301571


FM 90219-94 73

APPENDIX A

Chemical Hazard Plan forLaboratory Analysis

. ~:l^-.

(Chemical Hygiene Plan)

301572

CHEMICAL HYGIENE PLAN

Reference 29 CFR 1910.1450

Occupational Exposure to HazardousChemicals in Laboratories

May, 1993

Laboratory Analyst

Chemical Hygiene Officer

"Die or diicloture of the data contained on this theet it eubject to therettrictiona on the title page of tNt Work, Safety, Health and Emergency Retponta Plan.*

3"1573

FOREWORD

On January 31, 1990 the Occupational Safety and Health Administration (OSHA)promulgated a final rule for occupational exposure to hazardous chemicals inlaboratories. Included in the standard, which became effective on 1 May, 1990 is arequirement for all employers covered by the standard to develop and carry out theprovisions of a Chemical Hygiene Plan (CHP).

A CHP is defined as a written program which sets forth procedures, equipment,personal protective equipment and work practices that are capable of protectingemployees from the health hazards presented by hazardous chemicals used in thatparticular workplace. Components of the CHP must include standard operatingprocedures for safety and health, criteria for the implementation of control measures,measures to ensure proper operation of engineering controls, provisions for trainingand information dissemination, permitting requirements, provisions for medicalconsultation, designation of responsible personnel, and identification of particularlyhazardous substances.

This plan is the Chemical Hygiene Plan developed for mobile laboratories operated byEarth Resources Corporation (ERC). This CHP is maintained readily available tolaboratory employees in each laboratory. All laboratory personnel must know andfollow the procedures outlined in this plan. All operations performed in the laboratorymust be planned and executed in accordance with the enclosed procedures. Inaddition, each employee is expected to develop safe personal chemical hygiene habitsaimed at the reduction of chemical exposures to themselves and coworkers.

This document was developed to comply with paragraph (e) of the referenced OSHA1910.1450 standard. ERC will maintain the facilities and procedures employed in thelaboratory compatible with current knowledge and regulations in laboratory safety.This CHP will be reviewed, evaluated and updated at least annually and is readilyavailable to all personnel and any representative of the Assistant Secretary of Laborfor OSHA.

The CHP is intended to augment provisions of ERC's Health and safety Manual as wellas site specific Safety, Health and Emergency Response Plans. As always, thepurpose of these plans is to promote ERC's policy to maintain safest possible workingenvironment.

CHEMICAL HAZARD PLAN FOR LABORATORY ANALYSES

301574

TABLE OF CONTENTS

Section and Title Page

1.0 Standard Operating Procedures for Laboratory Chemicals . . . . . . . . . . 11.1 Chemical Procurement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11.2 Chemical Storage . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11.3 Chemical Handling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21.4 Laboratory Equipment and Glassware . . . . . . . . . . . . . . . . . . . 41.5 Personal Protective Equipment . . . . . . . . . . . . . . . . . . . . . . . . 41.6 Personal Work Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51.7 Labeling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

2.0 Criteria for Implementation of Control Measures . . . . . . . . . . . . . . . . 62.1 Air Sampling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62.2 Housekeeping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72.3 Safety and Emergency Equipment . . . . . . . . . . . . . . . . . . . . . . 7

3.0 Engineering Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 83.1 Intent . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 83.2 Modification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 83.3 Improper Function . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 83.4 Usage . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

3.4.1 Local Exhaust Ventilation . . . . . . . . . . . . . . . . . . . 83.4.2 Laboratory Hoods . . . . . . . . . . . . . . . . . . . . . . . . 93.4.3 Glove Boxes and Isolation Rooms . . . . . . . . . . . . . 103.4.4 Cold Rooms and Warm Rooms . . . . . . . . . . . . . . . 103.4.5 Storage Cabinets . . . . . . . . . . . . . . . . . . . . . . . . 10

4.0 Employee Information and Training . . . . . . . . . . . . . . . . . . . . . . . . . 104.1 Hazard Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 104.2 Forms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 104.3 Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

5.0 Prior Approval of Laboratory Activities . . . . . . . . . . . . . . . . . . . . . . . 115.1 Permit System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

5.1.1 Off-Hours Work Procedures . . . . . . . . . . . . . . . . . 115.1.2 Sole Occupancy . . . . . . . . . . . . . . . . . . . . . . . . . 115.1.3 Hazardous Work . . . . . . . . . . . . . . . . . . . . . . . . . 125.1.4 Unattended Operations . . . . . . . . . . . . . . . . . . . . 12

6.0 Medical Consultations and Examinations . . . . . . . . . . . . . . . . . . . . . 12


i

7.0 Chemical Hygiene Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . 137.1 Chief Executive Officer . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 137.2 Chemical Hygiene Officer . . . . . . . . . . . . . . . . . . . . . . . . . . . . 137.3 Laboratory Workers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

8.0 Special Precautions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 148.1 Working with Allergens and Embryotoxins . . . . . . . . . . . . . . . . 148.2 Working with Chemicals of Moderate Chronic or High Acute

Toxicity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 158.3 Working with Chemicals of High Chronic Toxicity . . . . . . . . . . 158.4 Working with Animals and Chemicals of High Chronic

Toxicity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

9.0 Recordkeeping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

10.0 Chemical Spills, Releases and Accidents . . . . . . . . . . . . . . . . . . . . . . 17

11.0 Annual Chemical Hygiene Plan Audit . . . . . . . . . . . . . . . . . . . . . . . . 17

12.0 References and Recommended Reading . . . . . . . . . . . . . . . . . . . . . . 17

Appendices

A Laboratory Safety Equipment Inspection Schedule

B Resistance to Chemicals of Common Glove Materials

C New Chemical Purchasing Request

D Chemical Hazard Audit Sheet

E Air Sampling Data Record

F New Employee Chemical Hygiene Training Checklist

G Transfer Chemical Hygiene Training Checklist

H New Chemical Training Checklist

I Chemical Hygiene Checklist

J OSHA Hazardous Chemicals in Laboratories Standard Compliance Checklist


ii

301570


1.0 Standard Operating Procedures for Laboratory Chemicals

1.1 Chemical Procurement

1.1.1 The decision to procure a chemical shall be a commitment to handle anduse the chemical properly from initial receipt to ultimate disposal.

1.1.2 Requests for procurement of new chemicals shall be submitted to theChemical Hygiene Officer for approval. The form entitled "New ChemicalPurchasing Request", Appendix C to this plan, shall be used for thispurpose. Information on proper handling, storage and disposal shall beknown to all involved personnel prior to the procurement of the chemical.Chemicals utilized in the laboratory shall be those which are appropriatefor the ventilation system.

1.1.3 All chemicals shall be received in a central location by the laboratoryanalyst. Personnel who receive chemical shipments shall beknowledgeable of the proper procedures for receipt. Chemical containersshall not be accepted without accompanying labels, material safety datasheets and packaging in accordance with all appropriate regulations. Allchemical shipments should be dated when received and opened.

1.2 Chemical Storage

1.2.1 Received chemicals shall be immediately moved to the designatedstorage area. Large glass containers shall be placed in carryingcontainers or shipping containers during transportation.

1.2.2 The storage area shall be well-illuminated, with all storage maintainedbelow eye level. Large bottles shall be stored no more than two feetfrom ground level.

1.2.3 Chemicals shall be segregated by hazard classification and compatibilityin a well identified area, with local exhaust ventilation.

1.2.4 Mineral acids should be separated from flammable, and combustiblematerials. Separation is defined by NFPA 49 as storage within the samefire area but separated by as much space as practicable or by interveningstorage from incompatible materials.

1.2.5 Acid-resistant trays shall be placed under bottles of mineral acids.


1

3<4577

1.2.6 Acid-sensitive materials such as cyanides and sulfides shall be separatefrom acids or protected from contact with acids.

1.2.7 Highly toxic chemicals or other chemicals whose containers have beenopened shall be stored in unbreakable secondary containers.

1.2.8 The storage area shall not be used as a preparation or repackaging area.

1.2.9 The storage area shall be accessible during normal working hours. Thestorage area is under the control of the senior laboratory analyst.

1.2.10 When chemicals are taken from the storage area, they shall be placed inan outside container or bucket.

1.2.11 Storage of chemicals at the lab bench or other work areas shall belimited to those amounts necessary for one operation or shift. Thecontainer size shall be the minimum convenient. The amounts ofchemicals at the lab bench shall be as small as practical. Chemicals inthe workplace shall not be exposed to sunlight or heat.

1.2.12 Stored chemicals shall be examined at least annually by the ChemicalHygiene Officer for replacement, deterioration, and container integrity.The inspection should determine whether any corrosion, deterioration,or damage has occurred to the storage facility as a result of leakingchemicals.

1.2.13 Periodic inventories of chemicals outside the storage area shall beconducted by the Chemical Hygiene Officer. Unneeded items shall beproperly discarded or returned to the storage area.

1.3 Chemical Handling

Each laboratory employee with the training, education and resources provided bysupervision, shall develop and implement work habits consistent with this CHP tominimize personal and coworker exposure to the chemicals in the laboratory. Basedon the realization that all chemicals inherently present hazards in certain conditions,exposure to all chemicals shall be minimized.

General precautions which shall be followed for the handling and use of all chemicalsare:

1.3.1 Skin contact with all chemicals shall be avoided.


2

1.3.2 All employees shall wash all areas of exposed skin prior to leaving thelaboratory or work area.

1.3.3 Mouth suction for pipeting or starting a siphon is prohibited.

1.3.4 Eating, drinking, smoking, gum chewing, or application of cosmetics inareas where laboratory chemicals are present shall be avoided. Theseareas have been posted. Hands shall be thoroughly washed prior toperforming these activities.

1.3.5 Storage, handling and consumption of food or beverages shall not occurin storage areas, refrigerators, glassware or utensils also used forlaboratory operations.

1.3.6 Risk determinations shall be conservative in nature.

1.3.7 Any chemical mixture shall be assumed to be as toxic as its most toxiccomponent.

1.3.8 Substances of unknown toxicity shall be assumed to be toxic.

1.3.9 Laboratory employees shall be familiar with the symptoms of exposurefor the chemicals with which they work and the precautions necessaryto prevent exposure.

1.3.10 The intent and procedures of this Chemical Hygiene Plan shall becontinuously adhered to.

1.3.11 In all cases of chemical exposure, neither the Permissible Exposure Limits(PELs) of OSHA or the Threshold Limit Values (TLVs) of the AmericanConference of Governmental Industrial Hygienists (ACGIH) shall beexceeded.

1.3.12 The engineering controls and safety equipment in the laboratory shall beutilized and inspected in accordance with Appendix A of this plan.

1.3.13 Specific precautions based on the toxicological characteristics ofindividual chemicals shall be implemented as deemed necessary by theChemical Hygiene Officer (see 7.2). These special precautions are listedin Section 8.0.


3

3^1579

1.4 Laboratory Equipment and Glassware

Each employee shall keep the work area clean and uncluttered. All chemicals andequipment shall be properly labeled in accordance with Section 1.7. At thecompletion of each work day or operation, the work area shall be thoroughly cleanedand all equipment properly cleaned and stored.

In addition, the following procedures shall apply to the use of laboratory equipment:

1.4.1 All laboratory equipment shall be used only for its intended purpose.

1.4.2 All glassware will be handled and stored with care to minimize breakage;all broken glassware will be immediately disposed of in the broken glasscontainer.

1.4.3 All evacuated glass apparatus shall be shielded to contain chemicals andglass fragments should implosion occur.

1.4.4 Labels shall be attached to all chemical containers, identifying thecontents and related hazards.

1.4.5 Waste receptacles shall be identified as such.

1.4.6 All laboratory equipment shall be inspected on a periodic basis asspecified in Appendix A, and replaced or repaired as necessary.

1.5 Personal Protective Equipment

1.5.1 Safety glasses meeting ANSI Z87.1 are required for employees andvisitors to the laboratory and will be worn at all times when in thelaboratory. Contact lenses are prohibited in the laboratory.

1.5.2 Chemical goggles and/or a full face shield shall be worn during chemicaltransfer and handling operations as procedures dictate.

1.5.3 Sandals, perforated shoes, sneakers and bare feet are prohibited. Safetyshoes, per ANSI 47 are required where employees routinely lift heavyobjects.

1.5.4 Lab coats are provided and must be worn in the laboratory. Laboratorycoats will be laundered on a periodic basis, not to exceed monthly.Laboratory coats shall be removed for proper disposal immediately upondiscovery of significant contamination.


3^1580

1.5.5 Appropriate chemical-resistant gloves based on the Table in Appendix 3shall be worn at all times when there may be skin contact withchemicals. Used gloves shall be inspected and washed prior to re-use.Damaged or deteriorated gloves will be immediately replaced. Glovesshall be washed prior to removal from the hands.

1.5.6 Thermal-resistant gloves shall be worn for operations involving thehandling of heated materials and exothermic reaction vessels. Thermal-resistant gloves shall be non-asbestos and shall be replaced whendamaged or deteriorated.

1.5.7 Respirator usage shall comply with the OSHA Respiratory ProtectionStandard, 29 CFR 1910.134, and ERC's Respiratory Protection Program.

1.6 Personal Work Practices

1.6.1 Laboratory supervision must ensure that each employee knows andfollows the rules and procedures established in this plan.

1.6.2 All employees shall remain vigilant to unsafe practices and conditions inthe laboratory and shall immediately report such practices and/orconditions to the laboratory supervisor. The supervisor must correctunsafe practices and or conditions promptly.

1.6.3 Long hair and loose-fitting clothing shall be confined close to the bodyto avoid being caught in moving machine/equipment parts.

1.6.4 Use only those chemicals appropriate for the ventilation system.

1.6.5 Avoid unnecessary exposure to all chemicals by any route.

1.6.6 Do not smell or taste any chemicals.

1.6.7 Encourage safe work practices in coworkers by setting the properexample. Horseplay is strictly forbidden.

1.6.8 Seek information and advice from knowledgeable persons, standards andcodes about the hazards present in the laboratory. Plan operations,equipment and protective measures accordingly.

1.6.9 Use engineering controls in accordance with Section 3.0.


3<<1581

1.6.10 Inspect personal protective equipment prior to use, and wear appropriateprotective equipment as procedures dictate and when necessary to avoidexposure.

1.7 Labeling

1.7.1 All containers in the laboratory shall be labeled. This includes chemicalcontainers and waste containers.

The label shall be informative and durable, and at a minimum, willidentify contents, source, date of acquisition, storage location andindication of hazard.

1.7.2 Portable containers shall be labeled by the individual using the container.

1.7.3 Exemptions for labeling requirements shall be made for chemicaltransfers from a labeled container into a container which is intended onlyfor the immediate use of the employee who performed the transfer.

1.7.4 The labeling program shall be periodically inspected by the ChemicalHygiene Officer to ensure that labels have not been defaced or removed.The form entitled "Chemical Hazard Audit Checklist", Appendix D to thisplan, shall be used for this purpose.

2.0 Criteria for Implementation of Control Measures

2.1 Air Sampling

2.1.1 Air sampling for evaluating employee exposure to chemical substancesshall be conducted periodically or as specified by specific codes orregulations.

2.1.2 Upon addition of new chemicals or changes in control procedures,additional air sampling will be considered to determine the exposures.Conduct air sampling if there is reason to believe that exposure levels forregulated substances that require sampling routinely exceed the actionlevel, or in the absence of an action level, the PEL. Air sampling will beimplemented when usage of highly toxic substances exceeds three timesper week.

2.1.3 The results of air sampling studies performed in the laboratory aremaintained and recorded on the form shown in Appendix E to this plan.


3"15S?

2.2 Housekeeping

2.2.1 Each laboratory worker is directly responsible for the cleanliness of hisor her work space, and jointly responsible for common areas of thelaboratory. Laboratory management shall insist on the maintenance ofhousekeeping standards.

2.2.2 The following procedures apply to the housekeeping standards of thelaboratory:

2.2.2.1 All spills on lab benches or floors shall be promptly cleaned and properlydisposed of. Large spills will necessitate the implementation of theEmergency Action Plan per OSHA 1910.38 and 1910.120.

2.2.2.2 The lab benches shall be kept clear of equipment and chemicals exceptthose necessary for the work currently being performed.

2.2.2.3 The work area shall be cleaned at the end of each operation and eachshift.

2.2.2.4 All apparatus shall be thoroughly cleaned and returned to storage uponcompletion of usage.

2.2.2.5 All floors, aisles, exits, fire extinguishing equipment, eyewashes,showers, electrical disconnects and other emergency equipment shallremain unobstructed.

2.2.2.6 All labels shall face front.

2.2.2.7 Chemical containers shall be clean, properly labeled and returned tostorage upon completion of usage.

2.2.2.8 All chemical wastes will be disposed of in accordance with the projectwaste disposal plan.

2.3 Safety and Emergency Equipment

2.3.1 Telephone numbers of emergency personnel, supervisors and otherworkers as deemed appropriate will be prominently posted.

2.3.2 All laboratory personnel will be trained in the proper use of fireextinguishers when hired and annually thereafter. Prior to theprocurement of newchemicals, the Chemical Hygiene Officer shall verify


301583

that existing extinguishers and other emergency equipment areappropriate for such chemicals.

2.3.3 All employees who might be exposed to chemical splashes shall beinstructed in the location and proper usage of emergency showers andeyewashes. The eyewash and emergency shower shall be inspectedweekly. These inspections shall be performed by the senior laboratoryanalyst or his designated representative. These inspections shall be inaccordance with ANSI Z358.1 and manufacturer's specifications.Records shall be maintained.

2.3.4 Location signs for safety and emergency equipment will be posted ateach project location.

3.0 Engineering Controls

3.1 Intent

The engineering controls installed in the laboratory are intended to minimize employeeexposure to chemical and physical hazards in the workplace. These controls must bemaintained in proper working order for this goal to be realized.

3.2 Modification

No modification of engineering controls will occur unless testing indicates that workerprotection will continue to be adequate.

3.3 Improper Function

Improper function of engineering controls must be reported to the Chemical HygieneOfficer immediately. The system shall be taken out of service until proper repairshave been executed.

3.4 Usage

All employees shall follow proper work practices when using the engineering controls.

3.4.1 Local Exhaust Ventilation

The following procedures shall apply to the use of local exhaust ventilation:

3.4.1.1 Openings of hoods shall be placed as close as possible to sources of theair contaminant.


83M5S4

3.4.1.2 Clear the screen on the face of the hood prior to usage.

3.4.1.3 Hood fans shall operate when hoods are being used.

3.4.1.4 After using hoods, operate the fan for an additional period of timesufficient to clear residual contaminants from the ductwork.

3.4.1.5 The ventilation system shall be inspected every three months. The ductvelocity shall be maintained at 3500 feet per minute, minimum. Arecord of each inspection shall be maintained by the Chemical HygieneOfficer.

3.4.1.6 Prior to a change in chemicals or procedures, the adequacy of theventilation system shall be determined by the Chemical Hygiene Officer.

3.4.2 Laboratory Hoods

The laboratory hoods shall be utilized for all chemical procedures which might resultin release of hazardous chemical vapors or dust. As a general rule, the hood shall beused for all chemical procedures involving substances which are appreciably volatileand have a permissible exposure limit (PEL) less than 50 ppm.

The following work practices shall apply to the use of hoods:

3.4.2.1 Confirm adequate hood ventilation performance priorto opening chemicalcontainers inside the hood. An inward flow of air can be confirmed byholding a piece of paper at the face of the hood and observing themovement of the paper.

3.4.2.2 Keep the sash of the hood closed at all times except when adjustmentswithin the hood are being made. At these times, maintain the sashheight as low as possible.

3.4.2.3 Storage of chemicals and equipment inside the hood shall be kept to aminimum.

3.4.2.4 Minimize interference with the inward flow of air into the hood.

3.4.2.5 Leave the hood operating when it is not in active use if hazardouschemicals are contained inside the hood or if it is uncertain whetheradequate general laboratory ventilation will be maintained when the hoodis non-operational.


301585

3.4.2.6 The ventilation system shall be inspected every three months. The hoodface velocity shall be maintained between 75 and 125 feet per minute.A record of each inspection shall be maintained by the Chemical HygieneOfficer.

3.4.2.7 The hood shall not be used as a means of disposal for volatile chemicals.

3.4.2.8 Prior to the introduction of new chemicals, the adequacy of hoodventilation systems shall be determined by the Chemical Hygiene Officer.

3.4.3 Glove Boxes and Isolation Rooms

The exhaust air from a glove box or isolation room will pass through scrubbers orother treatment before release into the regular exhaust system.

3.4.4 Cold Rooms and Warm Rooms

In event of electrical failure, the following provisions will be followed: NOTAPPLICABLE TO CURRENT ERC MOBILE LABORATORY OPERATIONS.

3.4.5 Storage Cabinets

Storage cabinets for flammable and hazardous chemicals will be ventilated as needed.

4.0 Employee Information and Training

4.1 Hazard Information

All employees will be apprised of the hazards presented by the chemicals in use in thelaboratory. Each employee shall receive training at the time of initial assignment tothe laboratory, prior to assignments involving new exposure situations, and at aregular frequency as determined by the Chemical Hygiene Officer.

4.2 Forms

The forms in Appendices F-H entitled "New Employee Chemical Hygiene Orientationand Training Checklist", "Transfer Chemical Hygiene Training Checklist", and "NewChemical Training Checklist" shall be used for these purposes.


10 3'<15S6

4.3 Training

This training shall include methods of detecting the presence of a hazardous chemical,physical and health hazards of chemicals in the lab, and measures employees can taketo protect themselves from these hazards. The training shall present the details of theChemical Hygiene Plan, and shall include;

4.3.1 the contents of the OSHA laboratory standard, and its appendices;

4.3.2 the location and availability of the Chemical Hygiene Plan;

4.3.3 the permissible exposure limits for OSHA regulated substances orrecommended exposure values for other hazardous chemicals notregulated by OSHA which are present in the laboratory;

4.3.4 signs and symptoms associated with exposure to the chemicals presentin the laboratory;

4.3.5 location and availability of reference material on chemical hygiene;

4.3.6 training shall be conducted by the Chemical Hygiene Officer or hisdesignated representative.

5.0 Prior Approval of Laboratory Activities

5.1 Permit System

A permit system shall be used for laboratory activities which present specific,foreseeable hazards to the employees. These activities include off-hours work, soleoccupancy of building, hazardous operations and unattended operations. The permitentitled "Chemical Hygiene Permit" is included in Appendix I to this plan and shall beexecuted prior to the performance of these activities.

5.1.1 Off-Hours Work Procedures

Laboratory personnel are not permitted to work after hours in the lab, except whenpermitted.

5.1.2 Sole Occupancy

At no time shall work be performed in the laboratory when the only person in thebuilding is the laboratory person performing the work. Under unusual conditions,


11

3"15S7

crosschecks, periodic security guard checks, closed circuit television, or othermeasures may be taken when permitted.

5.1.3 Hazardous Work

All hazardous operations are to be performed during a time when at least twopersonnel are present at the laboratory. At no time shall a laboratory person, whileworking alone in the laboratory, perform work which is considered hazardous. Thedetermination of hazardous operations shall be made by the laboratory supervisor andpermitted.

5.1.4 Unattended Operations

When laboratory operations are performed which will be unattended by laboratorypersonnel (continuous operations, overnight reactions, etc.), the following procedureswill be employed:

5.1.4.1 The permit system shall be utilized.

5.1.4.2 The Chemical Hygiene Officer will review work procedures to ensure forthe safe completion of the operation.

5.1.4.3 An appropriate sign will be posted at all entrances to the laboratory.

5.1.4.4 The overhead lights in the laboratory will be left on.

5.1.4.5 Precautions shall be made for the interruption of utility service during theunattended operation (loss of water pressure, electricity, etc.).

5.1.4.6 The person responsible for the operation will return to the laboratory atthe conclusion of the operation to assist in the dismantling of theapparatus.

6.0 Medical Consultations and Examinations

6.1 An opportunity to receive medical attention is available to all employeeswho work with hazardous chemicals in the laboratory. The opportunityfor medical attention will be made available to employees under thefollowing circumstances:

6.1.1 Whenever an employee develops signs or symptoms associated with ahazardous chemical to which the employee may have been exposed inthe laboratory.


12

6.1.2 Medical surveillance programs will be established where exposuremonitoring reveals an exposure level above the action level for an OSHAregulated substance for which there are exposure monitoring and medicalsurveillance requirements, and/or,

6.1.3 Whenever an event takes place in the laboratory such as a spill, leak,explosion or other occurrence resulting in the likelihood of a hazardousexposure the employee will be provided an opportunity for medicalconsultation for the purpose of determining the need for medicalexamination.

6.2 These medical consultations and examinations shall be provided withoutcost to the employees, without loss of pay and at a reasonable time andplace.

6.3 These medical consultations and examinations shall be administered byor under the direct supervision of a licensed physician. A current list ofavailable physicians is maintained by the Chemical Hygiene Officer.Employees seeking the opportunity of medical consultation shouldrequest the listing from the Chemical Hygiene Officer.

7.0 Chemical Hygiene Responsibilities

7.1 Chief Executive Officer

Ms. Ann Blakeley, President and Chief Executive Officer, has the ultimateresponsibility for chemical hygiene for laboratory operations and with assistance ofother program administrators, will provide continued support for chemical hygiene.

7.2 Chemical Hygiene Officer

The Chemical Hygiene Officer shall:

7.2.1 Work with administrators and other employees to develop and implementappropriate chemical hygiene policies and practices,

7.2.2 Monitor procurement and use of chemicals in the lab, includingdetermining that facilities and training levels are adequate for thechemicals in use,

7.2.3 Perform regular, formal chemical hygiene and housekeeping inspectionsincluding inspections of emergency equipment,


13

7.2.4 Help project managers develop precautions and adequate facilities,

7.2.5 Maintain current knowledge concerning the legal requirements ofregulated substances in the laboratory,

7.2.6 Review and improve the Chemical Hygiene Plan on an annual basis,

7.2.7 Maintain overall responsibility for the laboratory operation,

7.2.8 Ensure that workers know and follow the chemical hygiene rules,

7.2.9 Determine the proper level of personal protective equipment, ensure thatsuch protective equipment is available and in working order,

7.2.10 Ensure that appropriate training has been provided to employees,

7.2.11 Monitor the laboratory waste disposal program.

7.3 Laboratory Workers

The laboratory workers are individually responsible for;

7.3.1 Planning and conducting each laboratory operation in accordance withthe Chemical Hygiene Plan,

7.3.2 Developing good personal chemical hygiene habits.

8.0 Special Precautions

When laboratory procedures change to require the use of additional classifications ofchemicals (allergens, embryotoxins, teratogens, carcinogens, etc.), additional specialprecautions shall be implemented as deemed necessary by the Chemical HygieneOfficer. The permit system shall be utilized for all special activities. All questionsregarding the use of the permit system should be addressed to the Chemical HygieneOfficer.

8.1 Working with Allergens and Embryotoxins (Special Precautions)

8.1.1 Suitable gloves to prevent hand contact shall be worn when exposed toallergens or substances of unknown allergen activity.


143H1590

8.1.2 Women of child-bearing age will handle embryotoxins only in a hood withconfirmed satisfactory performance and will use protective equipment toprevent skin contact as prescribed by the Chemical Hygiene Officer.

8.1.3 Embryotoxins will be stored in adequately ventilated areas in unbreakablesecondary containers.

8.1.4 The site manager and the Chemical Hygiene Officer will be notified ofspills and other exposure incidents. A physician will be consulted whenappropriate.

8.2 Working with Chemicals of Moderate Chronic or High Acute Toxictty (SpecialPrecautions)

8.2.1 Areas where these chemicals are stored and used are of restrictedaccess and have special warning signs.

8.2.2 A special hood with a minimum face velocity of 60 linear feet per minuteor other containment device will be used. Released vapors will notdischarge with the hood exhaust, but will be trapped.

8.2.3 Gloves and long sleeves will be used. Hands and arms will be washedimmediately after working with these chemicals.

8.2.4 Two people will always be present during work with these chemicals.

8.3 Working with Chemicals of High Chronic Toxicity (Special Precautions)

8.3.1 All transfer and work with these substances shall be in a designatedarea: a restricted access hood, glove box or portion of lab.

8.3.2 Approval of the site manager will be obtained before use.

8.3.3 Vacuum pumps must have scrubbers or high efficiency particulateabsolute (HEPA) filters.

8.3.4 Any contaminated equipment or glassware will be decontaminated in thehood before removing them from the designated area.

8.3.5 For powders, a wet mop or vacuum with a HEPA filter will be used forcleanup.


15

8.3.6 The designated area will be marked with warning and restricted accesssigns.

8.3.7 Containers will be stored in a ventilated, limited access area in labeled,unbreakable, chemically resistant, secondary containers.

8.4 Working with Animals and Chemicals of High Chronic Toxicity (SpecialPrecautions)

8.4.1 For large scale studies, special facilities with restricted access will beprovided.

8.4.2 The substance will be administered by injection or garage when possiblerather than by diet. When diet is used, a caging system under negativepressure or under laminar air flow directed toward HEPA filters will beused.

8.4.3 Procedures will be used to minimize contaminated aerosol from food,urine and feces:

HEPA filtered vacuum equipment for cleaning.

Moisten contaminated bedding before removal from cage.

Mix diets in closed containers in hood.

8.4.4 Plastic or rubber gloves and fully buttoned lab coats will be worn in theanimal room.

9.0 Recordkeeping

9.1 Accident investigations will be conducted by the site manager with assistancefrom other personnel as deemed necessary.

9.2 Accidents reports will be forwarded to the Chemical Hygiene Officer and thepersonnel director.

9.3 Exposure records for hazardous chemicals and harmful physical agents will bemaintained for 30 years per 29 CFR 1910.20.

9.4 Medical records for employees exposed to hazardous chemicals and harmfulphysical agents will be maintained for the duration of employment plus 30years per 29 CFR 1910.20.


16

301592

9.5 Inventory and usage records for high risk substances (amounts of substanceson-hand, amounts used and names of workers involved) shall be maintained bythe Chemical Hygiene Officer.

9.6 Records of inspections of equipment will be maintained on site for the durationof the project, then filed with project data.

9.7 Records of employee training will be maintained with personnel records.

10.0 Chemical Spills, Releases and Accidents

In the event of a chemical spill, release or other accident, the procedures outlined inthe project Safety, Health and Emergency Response plan will be implemented (inaccordance with OSHA standard 29 CFR 1910.38 and 1910.120.

11.0 Annual Chemical Hygiene Plan Audit

The Chemical Hygiene Officer will conduct an audit of all phases of the ChemicalHygiene Plan each year. Results will be provided to the Vice President responsible foroperations and the laboratory manager. Supervisors are responsible for takingcorrective action. Appendix J will be used as a guide for the audit.

12.0 References and Recommended Reading

National Research Council, Prudent Practices for Handling Hazardous Chemicals inLaboratories, National Academy Press, Washington, D.C. 1981.

National Research Council, Prudent Practices for Disposal of Chemicals fromLaboratories, National Academy Press, Washington, D.C. 1983.

Freeman, N.T., Introduction of Safety in the Chemical Laboratory, Academy Press,1982.

Manufacturing Chemists' Association, Inc., Guide For Safety In The ChemicalLaboratory, D. Van Nostrand Company, Inc., 1954.

Green, Michael E., Safety In Working With Chemicals, MacMillan Publishing Co., Inc.1978.

Pipitone, David A., Safe Storage of Laboratory Chemicals, Wiley & Sons, Inc. 1984.

Code of Federal Regulations, 29 CFR part 1910 subpart Z section 1910.1450,Occupational Exposure to Hazardous Chemicals in Laboratories, 1990.


17

APPENDICES


APPENDIX A

LABORATORY SAFETY EQUIPMENT INSPECTIONSCHEDULE


301595

I AnodotM. tne.

LABORATORY SAFETY EQUIPMENTINSPECTION SCHEDULE »

Page of

Laboratory:

Address:

Laboratory Manager Telephone:

Purpose: The purpose of this schedule is to assure that all laboratory safety equipment is inspected on aroutine basis by competent personnel. Records in the form of inspection tags, stickers or logswill be maintained for all equipment.

Equipment Location Frequencyof Inspection

Ref. Stand.Code, Procd.

Inspector

Chemical Hygiene Officer Telephone:

APPENDIX B

RESISTANCE TO CHEMICALS OF COMMONGLOVE MATERIALS


301597

RESISTANCE

CHEMICAL

AcetaldchydeAccdc AcidAcetoneAcrylonitrilcAmmonium hydroxide (sat)

AnilineBenzaldchydcBenzene1

Benzyl chloride1

Bromine

ButaneButyraldchydeCalcium hypochloritcCarbon disulfidcCarbon tenrachloride1

ChlorineChloroacctoneChloroform1

Chromic acidCyclohexanc

Dibcnzyl etherDibutyl phtalateDiethanolamineDicthyl etherDimethyl sulfoxidcb

Ethyl acetateEthylenc dichloridc*Ethylcnc glycolEthylcnc trichloride3

Fluorine

FormaldehydeFormic acidGlycerolHcxancHydrobromic acid (-Ofc)

Hydrochloric acid (cone)Hydrofluoric xid (30<&)Hydrogen peroxideIodineMcthylaminc

Methyl ccllosolvcMethyl chloride1

Methyl ethyl kctoneMcthylcne chloride1

Monocthanolaminc

TO CHEMICALS

NATURALRUBBER

GEGPG

FFPFG

PPPPP

GFPPF

FFFF-

FPGPG

GGGPG

GGGG.G

FPFFF

OF COMMON

NEOPRENE

GEGGE

GFFPG

EGGPF

GEFFE

GGEG-

GFGPG

EEGEE

GGGGG

EEGFE

GLOVE MATERIALS

NITRILE

EEG—E

EEGG-

_-GGG

_-GF-

_-—E-

GGE_-

EEE

.—-

GGG-E

_-GG-

VTNYL

GEFFE

GGFPG

PGGFF

GPPEP

P?EP-

FPEPG

EEEPE

EEEGE

PPPFE

301598

CHEMICAL

MorpholineNapthalcne1

Nitric acid (cone)Perchloric acidPhenol

Phosphoric acidPotassium hydroxide (sat)Propylene dichloridc*Sodium hydroxideSodium hypochlorite

Sulfuric acid (cone)Toluene*Trichloroethylcnc1

Tricresyl phosphateTristhanolamineTrinitrotoluene

NATURALRUBBER

FGPFG

GGPGG

GPPPFP

• NEOPRENE

EGPGE

EGFFP

GFFFEE

N1TRILE

_

EPF—

_G-GF

FGG-E-

VTNYL

EGGEE

EEPEG

GFFFEP

(E=Exccllent, G=Good. F=Fair, P=Poor)a Aromatic and halogcnated hydrocarbons will attack all types of natural and synthetic glove materials. Should

swelling occur, the user should change 10 fresh gloves and allow the swollen gloves to dry and return to normal.b No data on the resistance to dimethyl sulfoxide of natural rubber, neoprene, nitrile rubber, or vinyl materials arc

available; the manufacturer of the substance recommends the use of butyl rubber gloves.

APPENDIX C

NEW CHEMICAL PURCHASING REQUEST


301600

NEW C H E M I C A L PURCHASING REQUESTNo.Date

1. Requesting Area: _______________ 2. Requestor:

3. Chemical Substance: ____________________

4. Material Safety Data Shcci(MSDS) Aiiachcd: Q YES

This request cannot be processed unless the MSDS is attached.

5. Proposed Chemical Use (amounts, duration, etc.):

6. Engineering Controls (enclosures, ventilation systems, etc.):

7. Storage Requirements:

8. Employee Exposure:

9. Expected Workplace Exposure Levels: ____

10. Personal Protective Equipment Required:G Respiratory Protection G

G Eye and Face Protection G

G Protective Clothing G

11. Required Medical Surveillance:G Pulmonary Tests G

Q Urine Analysis G

G Blood Analysis G

12. Routine Monitoring Requirements:

A. Workplace Exposure Levels: ______B. Medical Surveillance: _________

13. Request approval by Laboratory SupervisorDate:

14. Request Approval by Chemical Hygiene Officer

Date:

3«'1601

APPENDIX D

CHEMICAL HAZARD AUDIT SHEET


301602

IESI ss:^No.

CHEMICAL H A Z A R D AUDIT SHEET Datc:

1 . Chemical Substance Audited:

2. Work Area Audited:

3. Audit Performed bv:

4. Reason for Audit:3 RoutineD Special -- Reason:

5. Date Audit Performed: 6. Time of Audit: a.m. p.m.

7. Items Audited and Findings:

ITEM

D Current MSDS in work area

H Engineering controls maintainedD Employees trainedD Labels appropriateD Emergency procedures known

D Personal protective equipment usedD Workplace monitoring performed

Q Employees told of monitoring resultsD Required medical tests performedD Employee concerns, if anyD Supervisory concerns, if any

DD

FINDING RECOMMENDATIONS

8. Other Comments:

9. Auditor's Signature: Date:

10. Route a copy 10: 1- Area Supervisor, 2- Chemical Hygiene Officer. 3- Personnel Department File

3til603

APPENDIX E

AIR SAMPLING DATA RECORD


3^1604

oen

flrtlIw

&Aliociuloi.bK.

AIK SAMPLING DATATABLII NUMBER

COMPANY LOCATION SURVEY DATE

AIR SAMPLING RESULTS FOR: Sampled Uy:

TYPE SAMPLE: ANALYTE:

SAMPLE MEDIA: ANALYTICAL METHOD:

ACGIIITLV-TWA: OS! IA PEL: OSIIASTEL:

SAMPLE LOCATION SAMPLENUMUEK

TIME(minutes)

VOLUME(liters)

SAMPLECONCENTRATION

UNIT1 DATE

Remarks:

i • pi""mg/nrC

Purls of vujHir ur g«s |x;r inilliun parts nf coiiianiiiiiilcd air by vMluinu in '25 ' C aiul 7(>0 loir.A|>pruxiinalu milligrams of substance per cubic meter of uir.Ceiling limit - limit which should never be exceeded even instantaneously.__________

APPENDIX F

NEW EMPLOYEE CHEMICAL HYGIENEORIENTATION AND TRAINING CHECKLIST


ErriiItmden

Soytton

NEW EMPLOYEE CHEMICAL HYGIENEORIENTATION AND T R A I N I N G CHECKLIST

No.Date:

NAME: ___________________________ S.S. »:

JOB ASSIGNMENT: ____________________ Supervisor:

EMPLOYMENT DATE:

1. BY PERSONNEL DEPARTMENT ON THE FIRST DAY OF EMPLOYMENT:

Q Management's safety and hcalih philosophyQ Management's, supervisor's, and employee's safety and health responsibilitiesQ General plant safety and health rules3 Chemical Hygiene Training ProgramQ Location and availability of Chemical Hygiene Plan

Completed by: ______________________ Date: _____

2. BY CHEMICAL HYGIENE OFFICER:

A. First Day In Work Area Date:Q Introduction to operations where chemical and physicial hazards are present -

types of hazards encounteredQ Required work practices3 Personal protective equipmentQ Emergency procedures

Q Detection o f chem ical hazardsQ Location and availability of Chemical Hygiene PlanQ Labeling systems

B. One Week Follow-up Date: _______

Q Review work practices and procedures with employeeO Answer employee questionsQ Return completed checklist to Personnel Department for filing in employee personnel folder

Completed By: Date:

Employee's Signature: Date:

301607

APPENDIX G

TRANSFER CHEMICAL HYGIENE TRAININGCHECKLIST


301608

TRANSFER CHEMICAL HYGIENE TRAINING CHECKLIST

No.Date:

I. Employee Transferred:.

2. First day in the new work area:. .(date)

3. New supervisor's name: 4. Title:

5. New Work Area: 6. Old Work Area:

7. Training date for transferred employee:

8. Employee training provided:G Emergency proceduresG Work area safely rulesG Work area hazards

• Physical hazards

Health hazardsG Material Safety Data Sheets (MSDS)

G LabelsG Work area monitoringG Work practices

G Personal protective equipmentG Chemical Hygiene PlanG Location of Reference Material

G Detection of release or presence of hazardous chemicals

9. Additional safety and health information provided:

10. Instructor's Signature: Date:

11. Employee's Signature: Date:

12. Route a CODV to: 1- Area Supervisor. 2- Chemical Hveiene Officer. 3- Personnel Department File

30I60s

APPENDIX H

NEW CHEMICAL TRAINING CHECKLIST


1610

En*lin

BcMitonlAnociamx

NEW CHEMICAL T R A I N I N G CHECKLISTNo.Date:

1. Work Area: 2. Instructor:

Chemical Substance:

4. Material Safety Data Sheet (MSDS) Attached: Q YES

The MSDS must be attached to this iVcw Chemical Training Sheet.

5. New Chemical Use: _______________________

6. Employee Training Provided:G MSDS reviewedG Engineering controls

G Personal protective equipment

Q Detection of release or presenceQ Labels

7. Training Date: __________

8. Employees Trained:

Employee Signature

G Work area monitoring

G Work practicesG Emergency procedures

G ____________

G ____________

Employee Signature

(use back if necessary)

9. Instructor's Signature: Date:

10. Route a copy to: 1- Area Supervisor, 2- Chemical Hygiene Officer. 3- Personnel Dcpanmcnt File

APPENDIX I

CHEMICAL HYGIENE PERMIT


3016.12

CHEMICAL H Y G I E N E PERMIT

PERMIT NUMBER:

LOCATION:

PERSON REQUESTING PERMIT:

Page 1 of

DATE:

TIME:

POTENTIAL HAZARDS AND REQUIRED CONTROLS

Safety

Hazards:

Precautions Y N NA

Provide guards

Personal protective eouio.

Soecial safetv trainins

Soecial safetv procedures

Lockouts reauired

L'nattended operation

Work Alone

Sole Occuoancv

Special considerations:

Health

Hazards:

Precautions

Possible oxveen deficiency

Special ventilation

Toxic materials

Personal protective eauip.

Specia] rescue procedures

Lockouts reauired

Exceed PELs

Y N NA


Fire

Hazards:

Precautions Y N N'A

Fire extinsuishcrs

Open flame permit

Explosion protection

Remove combustibles

Test Atmosphere

Emercencv Eeress

Pvrophcrics

Unattended operation


Additional Comments:

Approval of Chemical Hygiene Officer: Name:

Date:

301613

APPENDIX J

OSHA HAZARDOUS CHEMICALS INLABORATORIES STANDARD COMPLIANCE

CHECKLIST


301614

EfrwLimtden

BoyWon& Axsoocrtoi, he.

OSHA HAZARDOUS CHEMICALS IN LABORATORIES STANDARD COMPLIANCE CHECKLIST

PURPOSE: This laboratory chemical hygiene program checklist is intended for use by companies in conducting annual chemicalhygiene program evaluations to ensure continuing effcciivcncss and regulatory compliance.

REFERENCE: Refer to OSHA Standard 29 CFR 1910.1450. Occupational Exposure 10 Hazardous Chemicals in Laboratories, for detailsconcerning the requirements of the standard.

ORGANIZATION:

LABORATORY:

LAB MANAGER:

ITEM

1

2

3

i

5

5

7

S

9

10'

29 CFR 1910.1450 REQUIREMENT

APPLICATION

Laboratory engaged in the use of hazardous chemicalsas defined by standard

Work performed on laboratory scale

OCCUPATIONAL EXPOSURE

Employes exposure to OSHA regulated substances donot exceed the permissible exposure limits specificin 29 CFR part 1910. subpari Z

EXPOSURE MONITORING

Initial monitoring performed for employees exposureto any substance regulated by a standard which requiresmonitoring if there is reason to believe that exposurelevels for that substacc routinely exceed the actionlevel (or in the absence of an action level, the PEL)

Exposure monitoring provisions of relevant standardscomplied with for employee exposures over the actionlevel (or in the absence of an action level, the PEL)

Employee monitoring terminated in accordance withrelevant standard

EMPLOYEE NOTIFICATION

Employees notified of monitoring results within 15days of receipt


A written Chemical Hygiene Plan is developed andimplemented for hazardous chemical use as definedin the standard

The Chemical Hygiene Plan is capable of protectingemployees from health hazards associated with thechemicals in the laboratory

The Chemical Hygiene Plan is capable of maintainingemployee exposures below the permissible exposurelimits specified in 29 CFR oart 1910. suboart Z

LOCATION:

DATE OF AUDIT:

CHEMICAL HYGIENE OFFICER:

REFNO.

UXD

(b)

(c)

(d)0)

(d)(2)

(d)(3)

(d)(4)

(e)(l)

(e)(l)(i)

(cHlVii)

YES NO COMMENTS

301615.

ITEM

11

12

13

14

15

16

17

13

19

20

21

22

23

2-i

29CFR 1910.1450 REQUIREMENT

The Chemical Hygiene Plan is readily available toemployees, employee representatives and, uponrequest, to the Assistant Secretary

The Chemical Hygiene Plan indicates specificmeasures to ensure laboratory employee protectionand includes each of the following elements:

Standard operating procedures relevant to safety andhealth to be utilized when using hazardous chemicals

Criteria for the implementation of control measuresincluding engineering controls, personal protectiveequipment and hygiene practices

Measures to ensure adequate performance and properusage of engineering controls

Provisions for employee information and training inaccordance with the standard

Circumstances which require prior approval prior toimplementation

Provisions for medical consultation and examinationin accordance with the standard

Designation of responsible personnel andresponsibilities

Identification of. and provisions for work with.particularly hazardous substances, including:• establishment of designated areas• use of containment devices• removal of waste• decontamination procedures

PLAN REVIEW

The Chemical Hygiene Plan is reviewed and updatedat least annually

EMPLOYEE INFORMATION AND TRAINING

Employees receive information and training toerasure that they arc apprised of the hazards ofchemicals present in their work area

Information and training provided at the time ofinitial assignment and prior to assignmentsinvolving new exposure situations

Employees are informed of:• contents of the standard• location of Chemical Hygiene Plan• PELs or recommended exposure limits for

substances in the laboratory• signs and symptoms associated with exposures

to hazardous chemicals in the laboratory• location and availability of known reference

material

REFNO.

(e)(2)

00(3)

(e)(3)(5)

(e)(3)(ii)

(e)(3)(iii)

(e)(3)(iv)

(c)(3)(v)

(e)(3)(vi)

(e)(3)(vii)

(c)(3)(viii)(eX3)(vm)(A)(e)(3)(viii)(B)(e)(3)(viii)(C)(e)(3)(viii)(D)

(e)(4)

(IXD

(0(2)

(0(3)(i)(0(3)(ii)

(f)(3)(iii)

(0(3)(iv)

(0(3)(v)

YES

-

NO

-

COMMENTS

301616

ITEM

25

26

27

23

29

30

31

- -

33

3-

35


Employee training includes:• methods to detect the presence of a hazardous

chemical• physical and health hazards of chemicals in the

work area• measures employees can take to protect

themselves from hazards• details of the Chemical Hygiene Plan

MEDICAL CONSULTATIONS

Employees are provided an opportunity to receivemedical attention under the circumstances definedin the standard

Medical consultations are performed by or under thedirect supervision of a licensed physician

Medical consultations arc performed without cosito the employee, without loss of pay and at areasonable time and place

Information on chemical identity, exposureconditions and exposure symptoms is provided to thephysician performing medical consultation

A written opinion is obtained from :he examiningphysician which includes results, rccommcndaiionsand any medical condition resulting in increaseemployee risk as a result of exposure to a hazardouschemical in the work area

The written opinion docs not address diagnosesunrelated to occupational exposure

HAZARD IDENTIFICATION

Labels on incoming containers of hazardouschemicals are not removed or defaced

All received material safety data sheets are maintainedand readily available :o laboratory employees

Training is provided for ail hazardous chemicalsproduced in the laboratory which arc for the exclusiveuse of the laboratory

Chemical byproducts of unknown compositionproduced in the laboratory arc assumed hazardousand covered in the Chemical Hygiene Plan

Chemical production for a user outside of thelaboratory comply with -Jie Hazard CommunicationStandard. 29 CFR 1910.1200

RF.SPIRATORY PROTECTION

Where respirators arc used to maintain employeeexposure below permissible exposure limits;• respirators arc provided at no cost to the

employee• respirators are selected and used in accordance

with 29 CFR 1910.134

REFNO.

(0(4)(i)(A)

(0(4XiXC)(0(4)(ii)

(gXD

(SX2)

(S)(2)

(tXSXiHiii)

(sX4)(a)(A)-(D)

WXIO

(hXiXi.

(h)(1)(ii)

(h)(2)(i)

(h)(2)(ii)

(h)(2)(iii)

(i)

(i)

YES NO COMMENTS

i i

IITE.M

36

37


RECORDKEEPING

A rccordkeeping system is established to maintain,for each employee, accurate records of measurementstaken to monitor employee exposures and any medicalconsultations and examinations

Records are kept, transferred, and made available inaccordance with 29 CFR 1910.20

REFNO.

OKD

YES NO COMMENTS

Notes: (Use additional sheets as necessary)

Conducted By: Tiiie(s) Date:

Revciwed By: Title(s) Date:

FOR ASSISTANCE CONTACT: ELB & Associates. Inc.. Chapel Hill. NC (800) 334-5478

3"16!8

PROJECT QUALITY ASSURANCE AND QUALITY CONTROL FORMS

FORM 1

FORM 2

FORM 3

FORM 4

FORM 5

FORM 6

FORM 7

FORM 8

FORM 9

FORM 10

FORM 1 1

FORM 12

FORM 13

FORM 14

FORM 15

FORM 16

FORM 17

FORM 18

FORM 19

FORM 20

FORM 21

Quality Control Daily Report

Cylinder Inspection Log

Air Monitoring Report

Analytical Summary Form

Site Access Log

Cylinder Identification Label

Confined Space Entry Permit

ERC's Site Safety Plan Employee Acknowledgement Form

Daily Safety Meeting

Personnel Heat/Stress Record

Air Analysis Data

Hazardous Waste Label

Non-regulated Waste Label

Instrument Calibration Record

Incident Information Report

Wilson Safety Products - Respirator Fit Test Record

Inspection of SCBA Bottles and Five-minute Packs

Breathing Air Test Records

Trellchem® Log for Suit Number

ERC Personal Safety Record

Production Detail

3^1620

'Use or disclosure of data contained on this sheet is subject to therestrictions on the title page of this plan.'

Form 1

QUALITY CONTROL DAILY REPORT Page 1 of 2

PROJECT N«

WEATHER TEMP. MIN.

DATE

TEMP. MAX.

1. Phase of operation in progress:

2. Results of operational check:

A. SAFETY EQUIPMENT CHECK:

Suits (Okay). If not, list deficiencies:

B.

SUPPLIED AIR EQUIPMENT INCLUDES:

Compressor (Okay)Air Lines (Okay)Air Bank (Okay)Masks (Okay)SCBA's (Okay)5 Min Packs (Okay)

MONITORING EQUIPMENT:

Explosion/Oj Meter (Okay)HNu (Okay)Detector Tubes (Okay)

Cylinder Recovery Vessel (CRV)Hydraulic System (Okay)Pneumatic System (Okay)Pumps (Vac & Comp) (Okay)Pressure Temp. Readouts (Okay)Valves (Okay)Video (Okay)Other Deficiencies

List Deficiencies

"Use or disclosure of data contained on this sheet is subject to therestrictions on the title page of this plan. '

Form 1

QUALITY CONTROL DAILY REPORT Page 2 of 2

C. HazGAS" (Okay)Pneumatic System (Okay)Pumps (Okay)Pressure Temp. Readouts (Okay)Valves (Okay)Video (Okay)Other Deficiencies

NOTE: Deficiencies listed will be recorded in the maintenance log by date andreport number.

3. Verbal instructions - received from Client Representative on deficiencies or retesting required:

4. Remarks:

SIGNATURE OF PROJECT MANAGER

5. CERTIFICATION: I certify that the above report is complete and correct, and that all material andequipment used and work performed during this reporting period are in strict compliance with the plansand specifications except as may be noted above.

AUTHORIZED REPRESENTATIVE

'Use or disclosure of data contained on this sheet is subject to therestrictions on the title page of this plan. '

Project Name:

Date:

Cylinder Serial It:

Color: ______

DOT Rating:

Other:

Cylinder Type: H.P.

Form 2CYLINDER INSPECTION LOG

Inspector:

3E1800 312015

L.P.

Labels and/or Markings:

ERC#:

Dimensions:

Owner Stamp: ___

3AA2400 3A2215

Test Date(s):

Valve Type:

General Condition:

Comments:

Good

Valve Condition:

Comments: __

Good

Pre-operation Weight:

Approved to Handle:

Handling Precautions:

Approved for Valve Sampling:

Sample Method:

Comments:

Sample Date:

Identified Contents:_

Analytical Method:

Disposition:

Fair Poor

Fair Poor

Post-operation Weight:

Yes

Yes

Large CRV Small CRV

Pressure:

Mass Spec FTIR

No

No

Val

Other

Caustic Scrub

Recontainerized:

Recontainerized Cylinder #:

Acid Scrub ______ Oxidizing Carbon

Mole Sieve ______ Flare

Yes No


restrictions on the title page of this plan. '

Form 3

AIR MONITORING REPORT

COMPANY/DIVISION:

DATE:

Sample N*

Pump N°

Flow (l/min)

Filter Checked

Type

1 I 2

Name

3

Operation

4 I

Assignment

5

I TimeOn/Off

6

DurationProtectiveEquipmentWorn +

* ABBREVIA TIONS:Airline Respirator - AR; Full-face Respirator - FF; Encapsulating Suit - ES; Tyvek - TK; Gloves - GL; Boots - BT; Hard Hat - HH;.

LOCATION AND HEIGHT (FEET) OF SAMPLES:

(Location Map Attached)

COo»-*03

'Use or disclosure of the data contained on this sheet is subject to therestrictions on the title page of this plan. '

Form 4ANALYTICAL SUMMARY FORM

OVERPACK #: _________ CYLINDER It:

MASS SPECTRUM INTERPRETATION

Analyst Signature: ______________________________ Date:QA Confirmation Yes D No DComments: ______________________________________

FTIR INTERPRETATION

Analyst Signature: ______________________________ Date:QA Confirmation Yes D No DComments:

COLORIMETR1C OR OTHER INTERPRETATION

Analyst Signature: ______________________________ Date:QA Confirmation Yes D No DComments:

INTERPRETED RESULTS:

QA or Document Officer Signature:16

DATE:

"Use or disclosure of the data contained on this sheet is subject to therestrictions on the title page of this plan. '

Form 5

SITE ACCESS LOG

DATETIME

IN OUT IN OUT PERSONNEL REP

COMMENTS:

'Use or disclosure of the data contained on this sheet is subject to therestrictions on the title page of this plan."

Form 6

CYLINDER IDENTIFICATION LABEL

DATE:

CYCLE Nfl:

WEIGHT:

PRESSURE:

ANALYSIS:

TYPE OF

INSTRUMENT:

INITIALS:

'Use or disclosure of the data contained on this sheet is subject to therestrictions on the title page of this plan. *

Form 7CONFINED SPACE ENTRY PERMIT Page 1 of 2

A permit is required for entering any tank or enclosed space for any purpose and may be grantedonly in accordance with review and approval by the Health and Safety Officer.

This permit can be used only during the date and time specified. Additional permits must be usedfor different dates and extended time periods - No Exceptions.

SITE: ______________________________________________________

LOCATION: __________________________________________________

PURPOSE:

ENTRY DATE:

TIME: TO:

Person(s) to enter confined space:

Standby person(s):

Entry Conditions:1. All vessel inlet lines locked out?

2. All electrical switches locked out?

3. Vessel atmosphere tested for flammable concentration?

4. Vessel atmosphere tested for poisonous gases?

5. Surrounding area checked for flammable and/or poisonousgases?

6. Vessel tested for oxygen deficiency?

7. Standby person(s) assigned and properly instructed?

8. Persons properly instructed for safe entry into vessel?

9. Rescue harness provided?

10. Lifeline attached?

Yes/Not Necessary

Yes/Not Necessary

Yes/Not Necessary

Yes/Not Necessary

Yes/Not Necessary

Yes/Not Necessary

Yes/Not Necessary

Yes/Not Necessary

Yes/Not Necessary

Yes/Not Necessary

301628'Use or disclosure of the data contained on this sheet is subject to the

restrictions on the title page of this plan.'

Form 7CONFINED SPACE ENTRY PERMIT Page 2 of 2

11. Rescue equipment available? Yes/Not Necessary

12. PPE provided and worn? Yes/Not Necessary

ATMOSPHERIC ANALYSIS:

_______________ ________ mg/m* or ppm

_______________ ________ mg/m3 or ppm

_______________ ________ mg/m3 or ppm Time: ________

Lower Explosive Limit (LED Analysis: _______________ Time:

Oxygen Content Analysis: ______________________% Time:

Additional Precautionary Remarks:

I certify that all necessary precautions have been taken to make this confined space entry job safe

for entering and carrying on the prescribed work.

Project Manager: ___________________________ Date:

Site Supervisor: ____________________________ Date:

Field Technician: Date:

Field Technician: ___________________________ Date:

Field Technician: ___________________________ Date:

Approval for entry: D Yes D No

Health and Safety Officer: _______________________________

Date: Time:

'Use or disclosure of the data contained on this sheet is subject to therestrictions on the title page of this plan.'

Form 8

ERC's Site Safety Plan

EMPLOYEE ACKNOWLEDGEMENT FORM

Cylinder Management Project for: ________

DATE:

I have received an introductory training orientation lecture regarding the hazardsfound at this site. I have also looked at a copy of the Site Safety Plan and knowwhere a copy of the plan is kept for reference purposes.

I understand that site safety is a joint responsibility of all employees, and I will domy share in trying to minimize injury and/or exposure.

1.

2.

3.

4.

5.

6.

7.

8.

9.

10.

11.

12.

13.

SIGNATURE / NAME (prim) / DATE

3D1630'Use or disclosure of the data contained on this sheet is subject to the


Form 9

DAILY SAFETY MEETING

DATE: _______

TIME:

CYLINDER MANAGEMENT PROJECT FOR:

EMPLOYEES PRESENT:

1. _____________________________

2. ___,_____________________

3. ___________________________

4. ____________________________

5. ___________________________

6. __________________________

7. ___________________________

8. __________________________

9. __________________________

10. __________________________

PLANNED ACTIVITIES:

TOPICS DISCUSSED:

'Use or disclosure of the data contained on this sheet is subject to therestrictions on the title page of this plan.' O f~) 1 C O 1

Form 10

PERSONNEL HEAT STRESS RECORD

DATE: TEMPERATURE: HUMIDITY:MONITORINITIALS: |

Any daily air temperatures over 70° F or day of high relative humidity (> 60%) will result ina heat stress monitoring program. The program will use disposable Therma-Dot oralthermometers under the tongue for 45 seconds and heart rate monitoring using a digitalLabTron Monitor.

1. If oral temperature exceeds 99.6° F, shorten the next work cycle by Va or lengthenthe rest period by Va.

2. If oral temperature still exceeds 99.6° F at the end of the next work cycle, shortenfollowing work cycle by Va more or increase rest period by Va more.

3. If oral temperature ever exceeds or equals 100.6° F, cease work immediately forthe day.

4. If heart rate exceeds 140 beats per minute at the end of a work period and 100beats per minute at the end of a rest period, shorten the work period by Va orlengthen the rest period by Va.

5. If the heart rate still exceeds 140 beats per minute at the end of the next workcycle, shorten the following work cycle by Va or lengthen the rest period by Va.

ON-SITEPERSONNEL TIME

ORALTEMP

HEARTRATE CONDITION

OK / 1/3

OK / Va

OK / Va

OK / 1/3

OK / Vs

OK / Vs

OK / 1/3

OK / Vs

OK / Vs

3"1632'Use or disclosure of the data contained on this sheet is subject to the

restrictions on the title page of this Work. Safety, Health and Emergency Response Plan. *

Form 11

AIR ANALYSIS DATA

Date:

SUSPECTED COMPOUNDS EXPOSURE LIMITS ERG'S ACTION LEVELS

1)

2)

3)

TIME

LOCATION

TEMPERATURE

WINDDIRECTION

WEATHERCONDITION

OVA- 128 orHNu

EXPLOSI-02METER

READING(s)ppm

COMPOUNDS)

SURVEYOR'SINITIALS

-

Field Calibration for OVA-128:

Calibration Gas Used: Potentiometer Setting: Instrument Reading:


301633

Form 12

HAZARDOUS WASTE LABEL

* * *

HAZARDOUSWASTE

FEDERAL LAW PROHIBITS IMPROPER DISPOSAL

IF FOUND, CONTACT THE NEAREST POLICE, ORPUBLIC SAFETY AUTHORITY, OR THE U.S.ENVIRONMENTAL PROTECTION AGENCY.

Name:

Address:

City:

GENERA TOR IN FORM A TION:

Phone:

_ Zip: _State:

EPA ID N"/MANIFEST DOCUMENT N»

ACCUMULATIONSTART DATE

EPAWASTE N8

DOT PROPER SHIPMENT NAME AND UN OR NA N* WITH PREFIX

HANDLE WITH CARE

'Use or disclosure of the data contained on this sheet is subject to therestrictions on the title page of this plan.' 301684

Form 13

NON-REGULATED WASTE LABEL

NONSREGULATED WASTE

GENERATOR JNFQRMATION (optional)

ADDRESS

CITY®STATE; ZIP

PROPER DOT SHIPPING NAME

UNOR NANO.

CONTENTS

'Use or disclosure of the data contained on this sheet is subject to therestrictions on the title page of this plan. '

301635

Form 14

INSTRUMENT CALIBRATION RECORD

Instrument: Serial Number:

Office Calibration: Calibration should be on a monthly basis

Field Use: Calibration should be on a daily basis

DATE CALIBRATIONGAS USED

POTENTIOMETERSETTING

METER READING CALIBRATED BY:

Factory Calibrations: (whenever instrument needs factory service or repair)

Date Shipped: Date Shipped:

Date Returned: Date Returned:


restrictions on the title page of this plan. *

Name of Caller:

Location:

Form 15

INCIDENT INFORMATION REPORT

Date:

Form 1 of 2

Time:

Location of Incident:

Shipping Point:

Phone:

Phone:

Carrier:

(If different from above)

Unit Number:

Type of Gas or Chemical:(May be Tradename)

Type of Container: ___

Nature of Problem (Description of Accident, Quantity leaking, etc.)

Weather Conditions:

Terrain:

Temperature:

Population: _____

Wind:

Property Damage:

Injuries/Exposures:

Special Medical Personnel Contacted:

Medical Response, Advise, Disposition:


restrictions on the title page of this plan. *

Form 15

INCIDENT INFORMATION REPORT Form 2 of 2

Directions to Accident:

Other Information/Comments/Developments/lnvestigation:

Cause/Conclusion of Investigation:

Cause/Conclusion of Investigation:

Action/Recommendation:

Responder: _______________________ Signature:

Obtain a copy of this report and forward it to the Director of Corporate Safety andLoss Prevention (Retain Original copy). Q () 1 R *3


Form 16WILSON SAFETY PRODUCTS - RESPIRATOR FIT TEST RECORD

A. EMPLOYEE: DATE:EMPLOYEE No.:

EMPLOYEE JOB TITLE/JOB DESCRIPTION:

B. EMPLOYER:

LOCATION/ADDRESS:

C. RESPIRATOR SELECTED:MANUFACTURER: ____NIOSH APPROVAL NUMBER:MODEL:

D. CONDITIONS WHICH COULD AFFECT RESPIRATOR FIT:D CLEAN SHAVEN D FACIAL SCARD 1-2 DAY BEARD GROWTH D DENTURES ABSENTD 2+ DAY BEARD GROWTH D GLASSESD MOUSTACHE D NONE

COMMENTS:

E. FIT CHECKS:NEGATIVE PRESSURE: D PASS D FAIL

POSITIVE PRESSURE: D PASS D FAIL

D NOT DONE

D NOT DONE

F. FIT TESTING:D QUANTITATIVE

FIT FACTOR: .

D ISOAMYL ACETATE D IRRITANT SMOKE

QUALITIVED PASS

QUALITIVED FAIL

COMMENTS:D PASS D FAIL

G. EMPLOYEE ACKNOWLEDGEMENT OF TEST RESULTS:EMPLOYEE SIGNATURE:

TEST CONDUCTED BY:

DATE:

DATE:

DISCLAIMERThe above respirator fit test was performed on and by the persons listed. The results indicate the performance of the listedrespiratory protective device, as fitted on the employee named on this record under controlled conditions. Fit testing, a* performed,measures the ability of the respiratory protective device to provide protection to the individual tested. Wilton Safety Products orthe Test Conductor express or imply no guarantee that this or an identical respiratory protective device will provide adequateprotection under conditions other than were present when this test was performed. Improper use. maintenance, or application ofthis or any other respiratory protective device will reduce or eliminate protection. Q f I 1 fi *-» Q


Form 17

INSPECTION OF SCBA BOTTLES AND FIVE-MINUTE PACKS

FOR THE MONTH OF:

BOTTLE NUMBER: TEST DATE:

DATE INSPECTOR TIME REMARKS



Form 18

BREATHING AIR TEST RECORDS

DATE: LOCATION:

NUMBER OF BOTTLES TESTED:

NAME OF TESTER:

RESULTS:

BOTTLE # OXYGEN CARBON MONOXIDE | CARBON DIOXIDE | ou. I

ACCEPT LEVELS 20-22%

-

10 PPM 500 PPM 2 mg

3D1641'Use or disclosure of the data contained on this sheet is subject to the

restrictions on the title page of this plan. '

TRELLCHEM® LOG FOR SUIT No.

DATE

i

CHEMICAL(s) TOWHICH SUIT

WAS EXPOSEDDURATION OF

EXPOSURENAME OFWEARER REMARKS

SUIT INSPECTEDON (DATE) BY

(NAME):

301642'Use or disclosure of this data is subject to the restriction written

on the title page of this plan. '

20

ERC PERSONAL SAFETY RECORDOperations Department

EMPLOYEE NAME————————————————— ———————————————————

MONTH

Saturday

Sunday

Monday

Tuesday

Wednesday

Thursday

Friday

r ProjectName

GROUP

DATES

SiteSupervisor

HSPOn Site

Levelof

PPE

PotentialChemicalHazards

SIGNATURE

TO

Routesof

Entry

PotentialPhysicalHazards

Incidents,Injuries, or

Symptoms (if any)

COMMENTS:

Reviewed by Site £

Reviewed by Projei

Reviewed by HSO:

Requires Discussio

•Supervisor: D Date: *

•:t Manager: D Date: •

•D Date: »

•r Yes D No D *

FOR COMPLETION BY HSO:

ACTION(s) REQUIRED:

"Use or disclosure of this data is subject to the restriction writtenon the title page of this plan. "

Form 21

PRODUCTION DETAILS

DATE LOCATION:

WORK LOG NOTES

START

STOP

START

STOP

START

STOP

START

STOP

TOTAL HOURS:

TOTAL HOURS:

TOTAL HOURS:

TOTAL HOURS:

TOTAL HOURS:

TOTAL HOURS:

TOTAL HOURS:

TOTAL HOURS:

TOTAL HOURS WORKED THIS CALENDAR DATE:

CYLINDER PROCESSING LOG

ERCCYLINDER* INVENTORY » CONTENT SIZE TYPE OPERATION

ERC Representative:

Client Representative: 3^16/34'Use or disclosure of this data is subject to the restriction written

on the title page of this plan.'

APPENDIX C

Malta Rocket Fuel Area Site. • jg--'- •

Health and Safety Plan

Jf CoroorateInvironmentai Proorams

October 22, 1991

Chief, New York/Caribbean Compliance BranchU.S. Environmental Protection Agency26 Federal Plaza - Room 737New York, New York 10278Attn: Alison Hess, Project Manager

Malta Rocket Fuel Area Site, Malta, NY(3 copies)

Chief, New York/Caribbean Superfund BranchU.S. Environmental Protection Agency26 Federal Plaza - Room 437New York, New York 10278Attn: Malta Rocket Fuel Area Attorney - Virginia Capon

(1 copy)

Bureau of Eastern Remedial ActionDivision of Hazardous Waste RemediationNYS Department of Environmental Conservation50 Wolf Road - Room 222Attn: Jon Greco, Project Manager

Malta Rocket Fuel Area Site, Malta, NY(3 copies)

Re: Malta Rocket Fuel Area Site - Modifications to Health and Safety Plan

Dear Ms. Hess et al.:

In planning for the beginning of the RI field investigation, ERM reviewed the project Health andSafety Plan (HASP) for the Malta Rocket Fuel Area Site. ERM has recommended a few minormodifications to improve the efficiency of the field activities and provide flexibility in makingfield decisions regarding health and safety precautions, while ensuring that safe workingconditions are maintained throughout the field investigation. This letter requests EPA reviewand approval of the recommended modifications, which are described below.

301646

Alison HessOctober 22, 1991Page 2

HASP Breathing Zone VOC Monitoring

As currently required in the HASP, the breathing zone of workers is to be monitored forairborne volatile organic compounds (VOCs) with a PID instrument during all site activities.An action limit of 2 ppm sustained needle deflection for a duration of five minutes is identifiedin the HASP. If VOC concentrations exceed this action level, drager tubes are to be drawn forcarbon tetrachloride and chloroform to confirm their presence. These two compounds arequalitatively investigated because they have the most stringent OSHA standards (2 ppm eighthour time weighted threshold limit value) of the site-specific VOCs. According to the HASP,if the drager tube analysis confirms the presence of either of these compounds at or above 2ppm, workers will be moved to a safe area upwind, and a decision will be made to either waitto allow the vapors to vent and fall below the action level or to upgrade the protection level.ERM has recommended minor modifications (described below) with regard to PID monitoringduring non-intrusive and intrusive field investigations.

' The HASP also requires that drager tubes for carbon tetrachloride be drawn at a minimum of• at the beginning of each task and every two hours following this. We believe this requirement

is excessive given the requirement to draw drager rubes for carbon tetrachloride and chloroformwhen PID readings reach or exceed 2 ppm. We recommend that this requirement be deleted.

Screening for Non-Intrusive Field Investigations

As currently required in the HASP, the worker's breathing zone will be monitored for airborneVOCs with a real time PID during all tasks performed at the site. ERM believes that duringnon-intrusive field tasks, this is unnecessary for protection of worker health and safety.

ERM recommends performing an initial survey of the areas to be investigated with a PID toidentify any area that, while undisturbed, exhibits potentially hazardous (i.e., above OSHA PEL)concentrations of VOCs in the breathing zone. This initial survey will serve to identify thoseareas that can be investigated by non-intrusive methods (i.e., surveying, geophysics, and surfacewater and surface soil sampling) without the necessity for real time VOC monitoring. Flamma-ble/explosive gas surveying of the site will also be performed during this initial site survey toidentify any explosion hazards to the non-intrusive site activities field teams.

301647


ERM recommends that non-intrusive work in areas identified as non-hazardous (based on theinitial site survey) be conducted without real time PID monitoring. Any areas identified aspotentially hazardous will be monitored during the non-intrusive phase of work following theplan described below.

VOC Screening During Intrusive Field Investigations

Both VOC and explosive gas monitoring will be performed at all times during intrusive phasesof the investigation (i.e., soil gas survey, drilling, monitoring well installation, trenching, welldevelopment, and subsurface soil/sludge and water sampling).

ERM recommends that the 2 ppm/five minute action limit be employed as suggested by theHASP. If the action level is reached, drager tubes will be drawn to determine if the PIDresponse is due to the presence of chloroform and/or carbon tetrachloride, as currently providedin the HASP. If one or both of these compounds is present at or above 2 ppm, the field teamwill be moved to a safe upwind location and a decision will be made to either allow the vaporsto vent and fall below the action limit or to upgrade the personal protection level. If personalprotection is upgraded, ERM recommends that the upgraded protection level be left in place untilthe PID readings fall below the 2 ppm action limit for a period of five minutes or until dragertube results indicate that chloroform and carbon tetrachloride levels have fallen below 2 ppm.

When personal protection has been upgraded, and full face respirators are in use, ERMrecommends continual monitoring of workers' breathing zones for VOCs with the PID. Thereis no need to employ the drager tubes on a rigid two hour schedule as currently required by theHASP. ERM recommends that drager tubes be drawn at the discretion of the on-site health andsafely officer, rather than on a regular two hour schedule.

If the PID response (above 2 ppm) is not due to the presence of chloroform and/or carbontetrachloride (as indicted by drager tube testing), work will continue as before withoutinterruption. As long as PID readings remain above 2 ppm, drager tubes will be drawn everytwo hours to ensure that proper respiratory protection is being employed. In the event thatdrager tube results remain below 2 ppm, no respiratory protection will be required until PIDreadings climb above 50 ppm. Above this secondary action level, the OSHA threshold limitvalue for trichlorethene (TCE) will be exceeded, and the field team will be moved to a safeupwind location and a decision will be made to wait until the vapors vent to below 50 ppm orto upgrade the level of personal protection.

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Since no OSHA ceiling limits for exposure have been set in the HASP for carbon tetrachlorideor chloroform, ERM recommends establishing a third action level of 200 ppm (100 times the2 ppm OSHA 8 hour PEL). At this concentration (as indicated by PID readings), the workerswill be moved to a safe area upwind until the vapors have vented, regardless of the level ofpersonal protection currently in use.

This plan provides action levels not only for those compounds with low threshold limits and forthose with higher values (trichlorethene). Therefore, it allows for more flexibility in makingfield decisions regarding health and safety precautions. This flexibility will enable field teamsto safely continue work in condidons where work would be interrupted under the current HASP.

Please call if you have questions or require additional information to clarify this request.

Very truly yours,

Barbara C. HotchkinFacility Coordinator

Hal Brodie, Esq., NYS Energy Research and Development AuthorityDennis Colton/Laine Vignona, Geraghty & MillerDon Hooker, US Army Corps of EngineersJane Gardner, Esq., GEPhil Gitlen, Esq., Whiteman, Osterman & HannaAngus Macbeth, Esq./Peggy O'Brien, Esq., Sidley & Austin

.William Miller, ERM - Northeast .August Spallo, Esq., US Army Corps of Engineers

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7.0 HEALTH AND SAFETY PLAN

7.1 INTRODUCTION

This Health and Safety Plan (HASP) has been developed for the remedialinvestigation to be conducted at the MRFA Superfund site, Towns of Malta and Stillwater,Saratoga County, New York. The plan provides procedures for use by RI personnel tominimize the potential for accidents from physical hazards and the potential for workerexposure to chemical contaminants in water, soil, and air.

The Scope of Work for the MRFA Site RI is fully described in Section 4.1 of the"Revised Remedial Investigation Work Plan for the Malta Rocket Fuel Area Site, Towns ofMalta and Stillwater, Saratoga County, New York, February, 1991." Detailed descriptionsof all procedures are contained in the FSAP (Section 5.0). Site activities will be performedin a safe and environmentally acceptable manner. We will ensure that our personnel complywith the specified health and safety requirements.

7.2 PURPOSE/OBJECTIVE

The protection of workers and environmental safety and health are major concernsduring this project and cannot be understated. The objective of this HASP is to assure thatsafe working conditions exist at the site during the field activities. The safety organizationand procedures have been established based on an analysis of potential hazards at theMRFA site. Safe work procedures and personal measures have been selected in responseto these potential hazards.

This occupational HASP contains the requirements for protection of personnel and

the general public during the Remedial Investigation of MRFA site. Site activities whichinvolve walk-through instrumental surveys, drilling soil borings, monitoring well installation,

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soil, sediment, ground-water and wipe sampling, trenching, construction of pipelines, welldevelopment, aquifer testing, or which otherwise have a potential for exposure to site-contaminated materials are subject to this HASP. This HASP was developed with inputfrom occupational and industrial health and safety personnel, physicians, chemists, andhealth and safety personnel. In addition, the HASP adheres to the applicable guidelines,texts, and references.

This HASP has been developed based upon a review of the requirements describedin the EPA Standard Operating Safety Guide, the U.S. Department of Labor OSHAStandards 29 CFR Part 1910 (especially, 29 CFR 1910.120 covering hazardous wasteoperations). All reasonable precautions will be taken to ensure the safety and health ofworkers and the general public. All site activities which might expose personnel to sitecontamination are subject to this HASP.

7.2.1 Assignment of Responsibilities

All personnel will be responsible for adherence to the safety procedures detailed inthis HASP during the performance of the work. In no case may work be performed in amanner that conflicts with the intent of, or the inherent safety and environmental cautionsexpressed in, these procedures. After due warnings, personnel violating safety procedures

will be dismissed from the site and potentially terminated. Field personnel will be properlytrained in health and safety regulations associated with handling hazardous materials.

The requirements listed may change as work progresses due to changing conditions,but no changes will be made without prior approval by the RI Site Safety Coordinator.

Avoiding adverse health effects and injuries to the site workers is totally dependenton the contribution of all project participants.

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7.2.2 RI Site Safety Coordinator

The RI Site Safety Coordinator will be responsible for providing technical coordinationof the health and safety program. The health and safety program includes information onmedical programs, training requirements, hazard assessment, personnel air monitoring,personnel protective equipment, respiratory protection, and field implementation. Liaisonwith officers or representatives of EPA on matters relating to health and safety will behandled by the RI Site Safety Coordinator or the RI Site Safety Officer. The RI .Site SafetyCoordinator also provides the RI Site Safety Officer with details concerning the complete,work specific, safety and health program.

7.23 RI Site Safety OfTicer/RI Project Hvdrogeologist

The RI Site Safety Officer/RI Hydrogeologist will be assigned to monitor the dailyactivities to ensure that all health and safety procedures/policies are being followed. Thisincludes communicating the specific requirements to all personnel, and consultation with theRI Site Safety Coordinator regarding appropriate changes in health and safety requirements.

7.2.4 RI Project Manager

The RI Project Manager is ultimately responsible for ensuring that all projectparticipants abide by the requirements set forth in this plan. The RI Site Safety Coordinatorwill report directly to the RI Project Manager.

7.2.5 USEPA Project Manager

The USEPA Project Manager will be notified for his/her approval of any changesmade to this HASP.

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73 HAZARD EVALUATION

Constant attention shall be given to physical hazards which may be encountered duringdaily work activities, particularly those associated with heavy equipment and chemicalhazards. The field activities previously described consist of walk-through instrumentalsurveys, ambient air, soil-gas, and geophysical surveys, drilling soil borings, monitoring wellinstallation, soil, sampling various media, trenching, well development, and aquifer testing.An evaluation of the potential hazards associated with these activities has been completedutilizing site history and existing sludge, soil, wastewater, surface water, and ground-watersampling data. The following potential exposure pathways have been identified:

Inhalation of contaminated particles and vapors.

Ingestion of contamination sediments and surface soils (accidental/poor hygiene).

Skin absorption and skin contact with contaminated sediments, surface soils,equipment, borehole drilling fluids, and pumped ground-water samples.

73.1 Volatile Organic Compounds (VOCs)

VOCs have been identified through a review of the past soil and ground-watersampling results. The primary compounds of concern are chloroform, carbon tetrachloride,and trichloroethylene. Based on the presence of these compounds, minimizing exposed skinand air monitoring will be performed for the protection of the workers. Air monitoring willbe conducted prior to and during all tasks performed at this site. These tasks include soilgas and geophysical surveys, soil borings, well installation, sampling various media, aquifertest, etc. Air monitoring will be conducted at the operator's breathing zone to ensure thattheir exposure to airborne VOC concentrations are not excessive. An upgrade in the

protection level will be based on the following action level.

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An action level on the PID of 2 ppm needle deflection for a 5 minute sustained periodhas been established based on the current occupational airborne contaminant standards andguidelines for chloroform and carbon tetrachloride, two common VOCs in ground water atthe site. They have the most stringent OSHA standards of the site-specific VOCs. Table4 contains the current OSHA occupational airborne contaminant standards and guidelinesfor the pertinent compounds. Table 11 summarizes the current occupational airbornecontaminant standards and guidelines for the most common VOCs at the site. Should thesecompounds be found at those or higher levels, drager tubes for chloroform and carbontetrachloride will be drawn to confirm the presence of the compounds. Drager tubes forcarbon tetrachloride, the VOC most common in ground water at the site, will also be drawnat the beginning of each task and every 2 hours. This will ensure that carbon tetrachloridelevels are not in excess of the 2 ppm OSHA standard. Should the action level forchloroform and/or carbon tetrachloride be met or exceeded, the job will be temporarilydiscontinued, the workers will be moved to a safe area upwind, and a decision will be madeby the RI Project Manager to allow the vapors to vent and fall below the action level forthese two compounds before the work resumes or to upgrade the protection level.

Flammable/Explosive Gases and Vaor s

Since there is a possibility for flammable/explosive gases and vapors to be presentduring all field investigations, particularly in the investigation of the aboveground andunderground tanks that have been used to store VOCs, an explosimeter will also be availablefor monitoring purposes during each task. Should a meter reading meet or exceed 10percent of the lower explosive limit (LEL), the standard action level, the work will bediscontinued, and the workers will be moved to a safe area until the gases and vapors havevented. Work will resume when readings indicate that the levels are below the 10 percentLEL level.

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733 lonizine Radiation

In the investigation of the GE/Exxon Nuclear Building and the drywells, site historyindicates that there may be a potential exposure to workers based on a possibility thatresidual uranium exists. In order to protect the workers during the investigation and samplegathering stage, readings will be taken using a geiger-mueller meter equipped with a probethat is capable of measuring alpha and beta particles. An action level or hot line of 375millirem per hour (mR/hr) has been established. This action level is based on a 1-day, 8-hour shift exposure. This reading will be used as a point in which the investigation will ceasetemporarily, the workers will move back to an area where the meter readings are atbackground levels and the RI Project Manager shall be contacted and informed of thissituation before proceeding. A secondary level has also been set, since it is anticipated thatthe investigation of the GE/Exxon Nuclear Building may take up to 10 days, meter readingsshould not exceed 37.5 mR/hr as an average during these 10 days. If this level is exceeded,full-face air purifying respirators equipped with radionculide cartridges will be used. Thesetwo levels have been established based on the current standard of 3 rem for a whole bodyexposure for any calendar quarter set by the National Council on Radiation Protection(NCRP).

73.4 Dioxins and Furans

In the investigation of the burning pit, it may be possible that dioxins and furans arepresent. In order to protect the workers, dust suppression techniques using a water spraywill be used to ensure that airborne dust and ash will be kept to a minimum. If this measureis unsuccessful, workers will be required to wear full-faced air purifying respirators equippedwith high efficiency paniculate air (HEPA) filter cartridges, along with personal protectiveequipment to minimize exposed skin.

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73.5 PCBs

In the investigation of the PTI investigation, measures will also be taken to protect theworkers of potential exposure to PCBs. Site history indicates that transformers which mayhave contained PCBs were removed. In order to protect the workers, dust suppressiontechniques using a water spray will be used to minimize airborne dust particles. If thismeasure is unsuccessful, workers will be required to wear full-faced air purifying respiratorsequipped with HEPA filter cartridges, along with personal protective clothing to minimizeexposed skin.

73.6 Trenching/Excavation

At the present time, it is not anticipated that workers will enter any of the test pits.Should it be necessary for workers to enter the test pits, health and safety procedures basedon the Occupational Safety and Health Administration Regulation, "Excavation," 29 Codeof Federal Regulations, Part 1910.26 will be provided.

73.7 Explosion Hazard

For the investigation at the magazine area, the work plan has not been finalized at thispoint and therefore health and safety considerations cannot be finalized. Once the workplan has been finalized, an addendum to this health and safety plan for the investigation ofthe magazine area will be included, if necessary.

7.4 AIR MONITORING .

Air monitoring with direct reading instruments will be performed during all remedialinvestigation activities. The hazard evaluation section has stipulated the various pieces of

equipment needed and they are as follows:

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The main survey instrument will be a photoionization detector (PID) equippedwith an 11.7 electron volt (eV) ultraviolet lamp. Equipped with this lamp, thePID will be capable of monitoring the presence of chloroform and other VOCs.This instrument is designed to measure trace qualities of VOCs in air with aparts per million (ppm) sensitivity range.

Drager colorimetric tubes will also be available at the site. Specific tubes forchloroform and carbon tetrachloride will be available. These tubes will affordthe capability of isolating and confirming the presence of chloroform and carbontetrachloride as specified by the action level.

• An explosimeter will also be available to measure the presence offlammable/explosive gases and vapors. This meter will be used in order toensure that the flammable/explosive hazard is monitored.

The Victoreen™ geiger counter or equivalent will also be available on the site.This meter will be equipped with a model 489-35 probe or equivalent which iscapable of measuring down to alpha radiation.

7.5 PERSONAL PROTECTIVE EQUIPMENT

Based on the hazard evaluation, it is anticipated that we will be begin a modified LevelD protection for all tasks in order to minimize exposed skin and direct contact with sitecontaminants which can be absorbed directly through the skin. These contaminants includecarbon tetrachloride, dioxins and furans, and PCBs. Several action levels have beenestablished. For exposure to VOCs, an action level of 2 ppm above background in theworker's breathing zone has been established as the upgrade point based on the presenceof chloroform and carbon tetrachloride, two common VOCs in ground water at the site.Should this action level be met or exceeded, and the project manager makes a decision tocontinue on with the work while the action level is exceeded, the level of protection will be

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upgraded to Level C using full-face air purifying respirators equipped with organic vaporcartridges and a dust prefilter. These cartridges will be changed after each shift. HEPAcartridges will be used, if necessary, for dioxins, furans, and PCBs.

In the event that the explosimeter indicates that flammable/explosive vapors/gassesexceed the 10 percent LEL level, the work will be discontinued, the workers will be movedto a safe area, and the vapors and gasses will be permitted to vent to below the 10 percentLEL figure before work can resume.

In the event that the ionizing radiation levels exceed the 37.5 mr/hr level, the level ofprotection will be upgraded to Level C using full-face air purifying respirators equipped withradionuclide cartridges.

7.5.1 Levels of Protection

The following levels of protection will be utilized at the MRFA site:

7.5.1.1 Level D Protection

Chemically resistant coveralls (all tasks).

Hard hat.

Eye protection (safety glasses, goggles, face shield).

Steel toe and shank boots.

Chemically resistant outer boots.

Chemically resistant gloves. . _o'' 1 D. > S

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Hearing protection, NRR rating of 37 decibels (required during well

installation).

Splash suit (required during pumping tests).

7.5.1.2 Level C Protection

Chemically resistant coveralls.

Hard hat.

Eye protection (safety glasses, goggles, face shield).

Steel toe and shank boots.

• Chemically resistant outer boots.

Full-face respirator.

Organic vapor cartridges and dust prefilter for VOCs and contaminatedparticulates (change after each 8 hour shift).

Radionuclide cartridges (to be used during the GE/Exxon Nuclear Building

investigation and dry well investigation).

Chemically resistant gloves.

Duct taping gloves and boots.

• Splash suit (required during pumping tests).

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Hearing protection, noise reduction rating of 37 decibels (required during well

installation.

7.6 HEALTH AND SAFETY PROCEDURES

7.6.1 Regulated Areas

The site shall be divided into three delineated zones (Figure 8), as follows:

Exclusion Zone - This zone includes the actual areas of contamination. Thiszone has the highest inhalation exposure potential and/or presents a highprobability of skin contact with cutaneous or percutaneous effecting chemicals.

Decontamination Zone - This zone includes the areas immediately surroundingthe Exclusion Zone. This zone has the next highest inhalation hazard, but doesnot have a high probability of skin contact with cutaneous or percutaneous ef-fecting chemicals.

Clean Zone (Support Zone") - This zone covers all area outside of the abovezones. Adverse exposure to chemicals is unlikely.

7.6.2 Decontamination

The process of removing or neutralizing contaminants that have accumulated onpersonnel and equipment is critical to personnel. Decontamination protects workers fromhazardous substances that may contaminate and eventually permeate the protective clothing,respiratory equipment, tools, vehicles, and other equipment used on site; it protects all sitepersonnel by minimizing the transfer of harmful materials into clean areas; it helps preventmixing of incompatible chemicals; and it protects the community by preventing uncontrolledtransportation of contaminants from the site.

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Prior to leaving the MRFA site at the end of the day, all protective clothing will bewashed and rinsed to remove potentially-contaminated sediments from boots, gloves, andrespirators. The clothing will be removed and properly stored or disposed of in trash bagsor 55-gallon drums until removal from site. All decontamination water will be stored untilit can be disposed of properly.

7.6.2.1 Personal Decontamination Procedures and Guidelines

Personal decontamination will be performed after completion of tasks wheneverpotential for contamination exists, and upon leaving the exclusion zone.

1. Boots will be washed in Alconox™ or equivalent solution and rinsed with water. Ifdisposable latex booties are worn over boots in the work area, they will be rinsed withAlconox™ or equivalent solution, removed, and discarded into a Department ofTransportation (DOT) approved 55-gallon drum.

2. Outer gloves will be washed in Alconox™ or equivalent solution, rinsed, removed, anddiscarded into a DOT approved 55-gallon drum.

3. Disposable coveralls ("Tyveks") will be removed and discarded into a DOT approved55-gallon drum.

4. Inner gloves will be removed and discarded.

5. At the end of the work day, personnel will shower the entire body, including hair,either at the work site or at home.

6. Respirators (if worn) will be sanitized.

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7.6.2.2 Health and Safety Monitoring Equipment Decontamination

1. Before use, the base of the instrument will be wrapped in plastic to eliminate contactwith soil and to reduce the need for subsequent cleaning.

2. Equipment surfaces that had possible contact with contaminated materials will bewiped with a paper towel wet with Alconox™ or equivalent solution, followed by atowel with methanol solution, followed by three rinses with a towel wet with distilledwater. All used paper towels will be disposed in a DOT approved 55-gallon drum.

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Access to contaminated work areas (exclusion and decontamination reduction zones)shall be regulated and limited to authorized persons. A daily roster containing the date, theperson's name, the person's signature, the time of entry, and the time of exit shall be keptof all persons working in such areas. Any visitors to the area must present properidentification and be authorized to be on site. Visitors must comply with all aspects of theHASP and shall sign the site visitors log included in Appendix G.

7.6.4 Posting/Barri cades

Warning signs shall be posted and hung, as applicable, in readily visible locations inor near contaminated work areas. Barricades and barricade tape shall be utilized to preventaccess to various work areas.

7.6.5 General Work Practices

At least one copy of this procedure will be available at each job work site.


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Contaminated protective equipment, such as respirators, hoses, boots, etc., will not beremoved from the regulated areas until it has been cleaned, or properly packaged andlabeled.

No food or beverages will be present or consumed in the regulated areas. No tobaccoproducts will be present or used and cosmetics shall not be applied in the regulatedareas.

Containers will be moved only with the proper equipment and will be secured duringtransport to prevent dropping or loss of control.

During the operation, all employees will be required to wash their hands and facebefore eating, drinking, smoking, or applying cosmetics.

Portable eyewash stations will be located in the regulated area near work activities.

All personnel will be required to field wash, as a minimum, at the end of their shiftbefore leaving the job site if they are contaminated. Hands and face will be washedduring breaks.

All personnel will avoid contact with potentially contaminated substances. Walkingthrough puddles or mud, or kneeling on the ground, will be avoided wheneverpossible.

Monitoring equipment will not be placed on potentially contaminated surfaces.

Field personnel will observe each other for signs of toxic exposure. Indications ofadverse effects include, but are not limited to:

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changes in complexion and skin discoloration,changes in coordination,changes in demeanor,excessive salivation and pupillary response, andchanges in speech pattern.

Field personnel will be cautioned to inform each other of non-visual effects of toxicexposure such as:

headaches,dizziness,nausea,blurred vision,cramps, andirritation of eyes, skin, or respirator tract.

7.6.6 Prilling Activities

Drilling activities shall comply with the following rules:

1. Before drilling, the existence and location of underground pipe, electrical equipment,etc., will be determined. This will be done, if possible, by contacting the appropriateutility company to mark the location of their lines. If the utility company cannot beutilized, an appropriate device, such as a pipe locator, shall be used to locate theservice line.

2. Combustible gas readings of the general work area will be made.

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3. No ignition sources will be permitted if the ambient airborne concentration offlammable vapors exceeds 10 percent of the lower explosive limit (LEL) when drilling.A combustible gas indicator will be available to make this determination.

7.6.7 Heavy Equipment Operation

The following information warrants extra • attention regarding work around heavyequipment (drilling rigs, front end/backhoe loaders, etc.).

Use common sense.

Hard hats and safety glasses will be worn at all times on site. Other protectivegear as specified in the HASP is applicable as well.

• Pay attention at all times.

Maintain visual contact at all times.

Establish hand signal communication when verbal communication is difficult.Specify one person per work group to give hand signals to equipment operators.

Be aware of footing at all times.

All heavy equipment will have backup alarms of some type.

Only licensed, qualified people will operate heavy equipment.

Use chains, hoists, straps, and other equipment to safely aid in moving heavymaterials.

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Use proper personal lifting techniques. Use your legs, not your back.

Never walk directly in back of, or to the side of, heavy equipment without the

operators' knowledge.

Never use a piece of equipment unless you are familiar with its operation. Thisapplies to heavy as well as light equipment (for example, chain saws).

Pipe sections and other materials to be utilized during this project are extremelyheavy. Make sure all precautions have been taken prior to the moving. Let theequipment, not your body, do the moving.

Be sure that no underground or overhead power lines, sewer lines, gas lines, ortelephone lines, will present a hazard in the work area.

Get help whenever you are in doubt about a material's weight. Use the buddysystem.

Ensure that air bottles are secured properly to heavy mobile equipment.

7.6.8 Heat Stress

Heat stress may be of concern depending upon the ambient temperature.

One or more of the following control measures can be used to help control heat stress:

Provision of adequate liquids to replace lost body fluids. Employees mustreplace water and salt lost from sweating. Employees will be encouraged todrink more than the amount required to satisfy thirst. Thirst satisfaction is notan accurate indicator of adequate salt and fluid replacement.

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Replacement fluids can be a 0.1 percent salt water solution, commercial mixessuch as Gatorade™ or equivalent or Quick Kick™ or equivalent, or a combinationof these and fresh water.

Establishment of a work regimen that will provide adequate rest periods forcooling down. This may require additional shifts for workers or earlier/later workschedules.

Cooling devices such as vortex tubes or cooling vests can be worn beneathprotective garments.

All breaks are to be taken in a shaded rest area.

Employees will remove impermeable protective garments during rest periods.

Employees will not be assigned other tasks during rest periods.

All employees will be informed of importance of adequate rest, acclimatizationand proper diet in the prevention of heat stress.

7.6.9 Cold Stress

If the project extends into the winter, cold stress could be an occupational stress whichneeds to be addressed.

Persons working outdoors in temperatures at or below freezing may be frostbitten.Extreme cold for a short time may cause severe injury to the surface of the body,or result in profound generalized cooling, causing death. Areas of the body which

have high surface-area-to-volume ratio such as fingers, toes, and ears, are the mostsusceptible.

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Two factors influence the development of a cold injury: ambient temperature andthe velocity of the wind. Wind chill is used to describe the chilling effect ofmoving air in combination with low temperature. For instance, 10°F with a windof 15 miles per hour (mph) is equivalent in chilling effect to still air at -18°F.

As a general rule, the greatest incremental increase in wind chill occurs when awind of 5 mph increases to 10 mph. Also, water conducts heat 240 times fasterthan air. Thus, the body cools suddenly when chemical-protective equipment isremoved if the clothing underneath is perspiration soaked.

Local injury resulting from cold is included in the generic term frostbite. Thereare several degrees of damage. Frostbite of the extremities can be categorizedinto:

Frostbite nip or initial frostbite: characterized by suddenly blanching orwhitening of skin.

Superficial frostbite: skin has a waxy or white appearance and is firm to thetouch, but tissue beneath is resilient.

Deep frostbite: tissues are cold, pale, and solid; extremely serious injury.

Systemic hypothermia is caused by exposure to freezing and rapidly droppingtemperature. Its symptoms are visually exhibited in five stages: (1) shivering,(2) apathy, listlessness, sleepiness, and sometimes rapid cooling of the bodyto less than 95°F, (3) unconsciousness, glassy state, slow pulse, and slowrespiratory rate, (4) freezing of the extremities, and finally (5) death.

Thermal socks, long cotton or thermal underwear, hard hat liners and other coldweather gear can aid in the prevention of hypothermia.

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Blankets, warm drinks (other than caffeinated coffee) and warm break areas areessential.

The overall goal is to keep from getting wet. When wet, the employee should dryoff and change clothes.

Cold stress training is also appropriate for work at the site.

7.7 TRAINING

All employees attend a 40-hour health and safety training course for conducting workat hazardous waste sites. This course satisfies the initialtraining requirements of 29 CFR 1910.120 (OSHA regulation of hazardous waste siteactivities). Site personnel also receive annual 8 hour refresher training and 8 hourproject manager training when applicable.

7.7.1 Contractors

Prior to initiating site work, all site personnel and subcontractors will be required toattend Tailgate Safety Meetings given by the RI Site Safety Officer. This session willinclude, but is not limited to, the following topics:

- Site history- Specific hazards- Hazard recognition- Standard operation procedures- Decontamination (personnel and equipment)- Emergency procedures- Respirator fit test and use


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These meetings will be recorded on the 'Tailgate Safety Meeting" forms included inAppendix G.

7.8 HEALTH MONITORING

Geraghty & Miller has established a Health Monitoring Program with occupationalhealth specialists at the Plainview Medical Group, Plainview, New York. Geraghty &Miller personnel receive yearly physicals consisting of the following:

- Personal, family and environmental history.- Hands-on physical examination.- Snellen's eye examination.- Hearing test.- Respirator clearance.- EKG and pulmonary function for those involved in Levels C and B work.- Pap Smear (females over age 21).- Hemoccult testing (over age 40).- Laboratory Testing.A. Complete Blood Count- Red Blood Count.- White Blood Count.- Differential Screening.- Hemoglobin.- Hematocrit.

B. Urine Analysis- Sugar.- Albumin.- Specific Gravity.

- Microscopic.

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C. Laboratory Chemistries- A.G. Ration.- Albumin.- Alkaline Phosphatase.- Bilirubin, Total.- Calcium.- Chloride.- Cholesterol.- Creatinine.- GOT.- Globulin.- Glucose.- Iron.- Lactic Dehydrogenase (LDH).- Phosphorous.- Potassium.- Protein, Total.- SGOT.- SGPT.- Sodium.- Triglycerides.- Urea Nitrogen (BUN).- Uric Acid.

D. Special Testing- PCBs in serum.- Serum and Plasma Cholinesterase.- Heavy Metals Screen (Blood) for field personnel.

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7.9 EMERGENCY PROCEDURES

The RI Site Safety Coordinator shall be notified of any on-site emergencies and beresponsible for ensuring that the appropriate procedures are followed. Table 9 is a

; summary of the general emergency response plan. In addition, the following standardemergency procedures will be used by on-site personnel.

7.9.1 Personal Injury in the Exclusion Zone

In the event of an injury in the exclusion zone, all site personnel shall exit at theexclusion zone and assemble at the decontamination line. The on-site hydrogeologistshould evaluate the nature of the injury and the affected person should be

; decontaminated to the extent practical prior to movement to the support zone.Appropriate first aid should be initiated, and an immediate request should be made for

i an ambulance (if necessary) and the designated medical facility will be notified (ifv—' required). No persons shall reenter the exclusion zone until the cause of injury or

• symptoms is determined.

7.9.2 Personal Injury in the Support Zone

vIn the event an injury occurs in the support zone, the on-site hydrogeologist and/or

safety manager must be notified immediately. Appropriate first aid will be administeredand, if necessary, the injured individual will be sent to the designated medical facility.If the injury does not affect the performance of site personnel, operations may continue.

Any injury/illness to an employee will be recorded on the OSHA 101 form includedin Appendix G. The SSO will be responsible for completing this form and forwardingit to the Office Health and Safety Manager within 6 working days. In the event of oneor more fatalities or five or more hospitalized injuries/illnesses as a result of a single

^, event, the office Health and Safety Manager will be notified immediately and this event

301672GERAGHTV & MILLER. INC.

7-24

will be reported to OSHA within 48 hours. Subcontractors will be recommended tofollow these same procedures for their employees.

7.93 Fire/Explosion

In the event a fire or explosion occurs at the site, the fire department shall be alertedand all personnel moved to a safe distance from the area.

7.9.4 Personal Protective Equipment Failure

If any site worker experiences a failure or alteration of protective equipment thataffects the protection factor, that person and his/her buddy shall immediately leave theexclusion zone. Reentry shall not be permitted until the equipment has been repairedor replaced.

7.10 EMERGENCY PHONE NUMBERS

Emergency phone numbers and directions to the nearest medical facility are providedbelow. This information will be posted at conspicuous places in the support zone.

- Police (518) 885-6761- Fire (518) 885-1701- Ambulance (518) 899-2100

- Hospital (518) 587-3222

In addition, all emergency services can be reached by dialing 911.

7.10.1 Directions to Hospital

Leaving the west access road from the site, proceed west along Dunning Street to

301673GERAGHTY r MILLER. INC

7-25

Route 9. Take Route 9 North to Saratoga Springs. After approximately 4.5 miles, bearleft on Church Street. After approximaely 1/3 mile, the hospital is on the right.

Saratoga HospitalChurch Street

Saratoga Springs, New YorkTelephone No. (518) 587-3222Emergency No. (518) 583-8313

7.11 SAFETY EQUIPMENT

Safety equipment to be kept on site:

1. First aid kit.2. Eye wash station.3. Type A, B, and C fire extinguishers.4. Potable water.

5. Gatorade (for summertime).6. Hot drinks (for wintertime).7. Ice chest.8. Paper cups.

301674

GERAGHTY i- MILLER. INC

Table 11. Currant Occupational Ajrborna Contaminant Standards and Guideline*.

OSHA-PEL (PPM)

OSHA - Occupational Safety and Health Administration

PEL - Permissible Exposure Limit, 1989

ACGIH - American Conference of Governmental Industrial Hygienist

TLV - Threshold Limit Value

TWA - 8 Hour Time Weighted Average

STEL - 15 Minute Short Term Exposure Limit

PPM • Part Per Million

A(2) - Suspected Human Carcinogen

Skin - Absorbed through the Skin

ACGIH (PPM)

Carbon Tetrachloride

Chloroform

Trichloroethylene

Toluene

TWA-2

2

TWA-50STEL-200

TWA-100STEL-150

TWA-5, A2, Skin

TWA-10, A2

TWA-50STEL-200

TWA-100STEL-150

OCCAiaXLS

GERAGHTYo-MILLER. INC.

301675

Table 12. Contingency Plan* tor Potential Problem*. MaJta Rocket Fuel Area Site, Town* of Malta and Stillwater.Saratoga County, New York.

Potential Problem Contingency Ran

Changes are made in program guidance. Consult with EPA and incorporate appropriate newguidance into project deliverable*.

Bad weather forces cancellation ofscheduled sampling trip.

Reschedule CLP space and coordinate with EPA.

Scheduled work does not delineateextent of existing contamination.

Work wrtti EPA to quickly scope alternative plan.

Soil gas survey is unreasonably extensiveand does not delineate extent of existingcontamination.

Work with EPA to quickly scope alternative plan.

CLP data are received late. Work overtime when data are received to get backon schedule. Request preliminary data withoutreview and do preliminary in-hous* QA/QC review.Adjust schedule rf necessary.

Legal access or easements cannot beobtained.

Request assistance of EPA.

EPA deadlines move up. Accelerate schedule with overtime, additionalstaff, dual tracking of project elements, or acombination of the three.

Data gathered in the remedialinvestigation provide unexpectedresults (contamination) much better orworse than expected, more contaminantsdetected, drums discovered, etc.

Schedule immediate review of facts with EPAand develop work plans amendment to coverchanged scope of work and schedule.

Delay in procurement of subcontractor. Accelerate schedule or extend deliverableschedule with overtime, additional drill rigsor select another bidder. Consult with EPAon schedule and adjustments.

301676PROBROC.XLS

GERAGHTV r MILLHR. INC

COo

EXCLUSION ZONESEGREGATEDEQUIPMENT DROP

x — x — x — x — x — x — x,— -x — x — x — x — HOTLINE —— x ——

tno

3o

i09Or\j

1

<nsIT

I

O

Vea.

CARTRIDGECHANGE

CONTAMINATIONREDUCTION ZONE

OUTER GARMENT, BOOTS. ANDGLOVES WASH AND RINSE

OUTER BOOT ANDGLOVE REMOVAL

MINIMUMDECONTAMINATION LAYOUT i

BOOTS, GLOVES, ANDOUTER GARMENT REMOVAL

RESPIRATORYPROTECTION REMOVAL

_CONTAMINATION__" CONTROL LINE

J] FIELD WASH

SUPPORT ZONE

ro^2

9CAU

GERAGHTY8 MILLER, INC.

Envvronrntntai 5mric«s

SITE WORK ZONES AND DECONTAMINATIONPROCEDURE

GE

30167?

FIGURE

8

C/lO

g3

tno

9o

<COo

o

o>z

¥-r

N

CALM WINDS 10.755

8.0 13.0 19.0 I24.0

WIND SPEED CLASS BOUNDARIES(WILES/HOUR)

NOTES:DIAGRAM OF THE FREQUENCY OFOCCURRENCE FOR EACH WIND DIRECTION.WIND DIRECTION IS THE DIRECTIONFROM WHICH THE WIND" IS BLOWING.EXAMPLE - WIND IS BLOWING FROM THENORTH 15.1 PERCENT OF THE TIME.

£

sou;

GERAGHTY& MILLER, INC.

Services

WINDROSE DIAGRAM FOR 1989 AT STATIONNUMBER 14735, ALBANY, NEW YORK

GE

301678

FIGURE

,G DATE: 3-6-91 PRJCT NO.: NY04605 I FILE NO.: 1208 IORAWG: EMERGNCYP I CHECKED: OS I APPROVED: LV I DRAFTER: CS

IMMINENT OR ACTUALEMERGENCY IS

DISCOVERED

NOTIFY ON-SITESAFETY OFFICER

OFF SITENOTIFY

AMtlULANCEOR HOSPITAL

AS NECESSARYAUOULANCE 911

HOSPITAL 584-6000

NOTIFYPROJECT MANAGER

NOTIFY CORPORATESAFETY OFFICER

NOTIFY OCCUPATIONALHEALTH PHYSICIAN

ON-SITENOTIFY

FIRE DEPT. 885-1701POLICE OEPT. 885-6761

AMBULANCE 885-6761HOSPITAL 584-6000

CO 1 GERAGHTY& MILLER, INC.

Environmental Services

EMERGENCY RESPONSE PLAN TOR THE MALTA ROCKET EUEL AREA SUPERFUNDSITE, TOWN OF MALTA AND STILLWATER. SARATOGA COUNTY. NEW YORK

GE

FIGURE

10

APPENDIX D

Treament IV^thodologies

301680

ERC TREATMENT METHODOLOGIES

GAS PHYSICAL PROPERTIES SAFETY CONSIDERATIONS DISPOSAL METHOD

ACETYLENE - Flammable

- Subject to exothermic selfdecomposition

- Gas in cylinder is dissolvedin solvent/porous mass

- Poor warning properties

-Density similar to air

- Avoid copper, silver andmercury

- Use steel, wrought iron orbrass containing less than65% copper

- Maximum working pressure1.5 bar

- Keep cylinder upright

- Flashback arrester should beused

- combustion followedby absorption

AMMONIA Toxic, 25 vpm TLV

Flammable, 15 - 28% in air

Liquefied gas, bp ca. -35°C,vp ca. 8 bar

• Vapor 1.7 x lighter than air

• Good odor warning

- Avoid copper, tin, zinc,mercury, and viton

- Beware of suckback ofwater

- acid scrubber

ARGON Asphyxiant

No warning properties

Gas 1.5 x heavier than air

- Use common materials - vent


restrictions on the title page of this Work, Safety, Health and Emergency Response Plan.'



ARSINE - Toxic, 0.05 vpm TLV

- Poor warning properties(Garlic odor)

- Fast acting, irreversible,systemic poison

- Flammable, 4 - 10% in air

- Toxic products produced byburning

- Liquefied gas, bp ca. -62°C,vp ca. 14 bar

- Vapor 3 x heavier than air

- Use common materials

- Elemental arsenic may bepresent in cylinders andlines. Disposal productscontain arsenic compounds(toxic)

- Oxidants that can be usedinclude: permanganate orhypochlorite

oxidizing scrubber oradsorbers

BORONTRIBROMIDE

- Toxic

- Liquid, bp ca. 92°C, vp ca.0.06 bar absolute


- Corrosive when moist

- Use common materials - caustic scrubber

BORONTRICHLORIDE

- Toxic, TLV unestablished

- Very corrosive when moistHydrochloric acid formed

- Liquefied gas, bp ca. 12°C,vp ca. 0.3 bar


- Pungent odor, white fumesin air

Use copper, Monel,Hastelloy (heavy gauge mildsteel), PVC or PTFE

Ensure that blockage bycorrosion products does notgive false indication ofempty cylinder or system

- caustic scrubber


restrictions on the title page of this Work, Safety. Health and Emergency Response Plan.'



BORONTRIFLUORIDE

- Toxic, 1 vpm TLV (ceiling)

Very corrosive when moistHydrofluoric acid formed


Critical temperature -12°C

Pungent odor, white fumesJn air

- Avoid PVC

Use copper (heavy gaugemild steel, aluminum), PTFE,polyethylene

Beware of danger ofhydrofluoric acid formed(risk of severe chemicalburns)

> Ensure that blockage bycorrosion products does notgive false indication ofempty cylinder or system

• Unwanted residual gasesmust be securely containedand safely transported to afacility properly equippedand staffed for disposal

- caustic scrubber

BROMINETRIFLUORIDE

Toxic, 1 vpm TLV (ceiling)

Extremely powerful oxidant

• Corrosive

• Liquid, bp ca. 126°C

• Pungent odor

- In the event of eye or skincontact, immediately washwith copious amounts ofwater

- Avoid grease and all othercombustible contaminants

- Use Monel nickel or heavygauge mild steel and PTFE

- Preclean and passivate allmaterials in use

- Reacts violently with water

- Initially introduce only smallquantities until convincedthat system is passivated

- Unwanted residual gasesmust be securely containedand safely transported tofacility properly equippedand staffed for disposal

- caustic scrubber

'Use or disclosure of the data contained on this sheet is subject to therestrictions on the title page of this Work, Safety, Health and Emergency Response Plan.'

301683



BROMOMETHANE - Toxic, 15 vpm TLV

- Systemic poison withpersistent and sometimesdelayed effects

- Flammable, 13.5 - 14.5% inair




- Avoid aluminum, plastics,rubber, eta with liquid

- Use other common metalsand PTFE

- Toxic products produced byburning


1,3 BUTADIENE - Flammable, 2 - 8.5% in air

- Subject to selfpolymerization

- Asphyxiant

- Liquefied gas bp ca. -4°C,vp ca. 1.5 bar

- Moderate odor warning


- Avoid plastics, rubber, etc.with liquid

- Use common materials forvapor

- Guard against polymerblockage

- Check that content is stable;i.e. that no temperature riseof cylinder


BUTANE - Flammable, 2 - 8.5% in air

- Asphyxiant

- Poor warning properties(unless stenched)

- Liquefied gas bp ca. -0.5°C,vp ca. 1.0 bar





301684'Ust or disclosure of the data contained on this sheet is subject to the




iso-BUTANE Flammable, 1.8 - 8.4% in air

Asphyxiant

Poor warning properties





combustion followedby absorption

1-BUTENE - Flammable, 1.6 - 9.3% in air

- Asphyxiant




• Avoid plastics, rubber, etc.with liquid



cis-2-BUTENE - Flammable, 1.8 - 9.4% in air

- Asphyxiant







trans-2-BUTENE - Flammable

- Asphyxiant


- Liquefied gas, bp ca. 1 °C,vp ca. 1 bar



• Use common materials forvapor


'Us* or disclosure of th* data contained on this sheet is subject to therestrictions on the title page of this Work, Safety. Health and Emergency Response Plan.'

MI68!


GAS PHYSICAL PROPERTIES: SAFETY CONSIDERATIONS DISPOSAL METHOr

iso-BUTENE Flammable, 1.8 - 9.6% in air

Asphyxiant

Poor warning properties(unless stenched)

Liquefied gas, bp ca. -7°Cvp ca. 1.6 bar

Avoid plastics, rubber, etc.with liquid

Use common materials forvapor


CARBON DIOXIDE - Asphyxiant


- Liquefied gas, sublimationpoint ca. -78°C, vp ca. 55bar

- Vapor 1.5 x heavier than air

- Cryogenic solid can causefreezing cold burns


vent or causticscrubber

CHLORIDE - vapor only

Powerful oxidizing agent

Corrosive when moist

Liquefied gas, bp ca. 12°C,vp ca. 0.5 bar

Vapor 3 x heavier than air

Good odor warning


- Use copper, Monel, nickel,aluminum (heavy gauge mildsteel) precleaned andpassivated, PTFE


- Ensure that blockage bycorrosion products does notgive false indication ofempty cylinder or system

- Introduce initially only smallquantities until one isconvinced system ispassivated

- Unwanted residual gasesmust be securely containedand safely transported to afacility properly equippedand staffed for disposal


restrictions on the title page of this Work, Safety, Health end Emergency Response Plan.'


GAS PHYSICAL PROPERTIES SAFETY CONSIDERATIONS DISPOSAL METHOr

CHLOROETHANE - Flammable, 3.8 - 15.4% inair

- Asphyxiant



- Moderate odor warning(ethereal)

- Avoid aluminum, zinc, andmagnesium


- Use other common materials


CHLOROMETHANE - Toxic, 100 vpm TLV(ceiling)

- Flammable, 8 - 17.2% in air

- No warning properties



- Avoid aluminum


- Use other commonmaterials, PTFE


CYANOGEN - Toxic, 10 vpm TLV

- Fast acting irreversiblesystemic poison


- Poor warning properties(almond like odor)

- Liquefied gas, bp ca. -21 °C,vp ca. 4 bar


Immediate expert medicalattention should be availablein case of poisoning

Use stainless steel, Monel(heavy gauge mild steel) andPTFE

Burning with hot, efficientflame. Control combustionconditions to minimizeformation of nitrogen oxides


301687

'Use or disclosure of the data contained on this sheet is subject to therestrictions on the title page of this Work. Safety. Health and Emergency Response Plan. *


GAS PHYSICAL PROPERTIES: SAFETY CONSIDERATIONS DISPOSAL METHOD

;YANOGEN-:HLORIDE

- Toxic, 0.3 vpm TLV

Fast acting irreversiblesystemic poison

Liquefied gas, bp ca. 13°C,vp ca. 1 bar

-Vapor 2 x heavier than air


Use stainless steel, Monel(heavy gauge mild steel) andPTFE


CYCLOPROPANE Flammable, 2.4- 10.4% inair

- Asphyxiant





- Use common materials withvapor


DEUTERIUM Flammable, 5 - 75% in air

Asphyxiant


Gas 7 x lighter than air

- Use common materials - combustion followedby absorption

DIBORANE Toxic, 0.1 vpm TLV

Flammable, 0.9 - 98% in air

• Subject to exothermicdecomposition

• Normally only a minorcomponent

• Gas density similar to air

• Moderate odor warning

• Liquefied gas, bp ca. -92°C,vp ca. 38 bar, critical temp.16.6°C

Avoid aluminum

Use other common materials

Beware of possibility ofhigher boranes(spontaneously flammable)remaining in cylinder

caustic scrubber

'Use or disclosure of the data contained on this sheet is subject to therestrictions on the title page of this Work, Safety, Health and Emergency Response Plan. *

a



DICHLOROSILANE - Toxic, 0.5 vpm TLV


- Spontaneous ignition/selfdecomposition is possiblearound 100°C or by shock

- Liquefied gas, bp ca. 8.2°C.vp ca. 0.6 bar


- Moderate odor warning(suffocating)

Ensure that blockage bycorrosion/combustionproducts does not give falseindication of empty cylinderor system

Use nickel, nickel steels,stainless steels (heavygauge mild steel) and PTFE

• Forms hydrochloric acid andhydrogen in presence ofwater


DIMETHYLAMINE - Toxic, 10 vpm TLV





- Good odor warning (fishlike,ammoniacal)

- Avoid copper, nickel, tin,mercury, and zinc


- Use steel and PTFE


DIMETHYL ETHER - Flammable, 3.4 - 27% in air

- Asphyxiant



- Moderate odor warning(ethereal)








DIMETHYL-PROPANE

- Flammable, 1.4 - 7.5% in air

- Asphyxiant







ETHANE Flammable, 3 -12.4% in air

Asphyxiant



Critical temperature 32.2°C

Vapor density similar to air




ETHYLACETYLENE - Flammable, rangeunestablished

- Asphyxiant




- Avoid air suckback

- Avoid copper, silver andmercury


- Use steel, brass with lessthan 65% copper


301690

'Use or disclosure of the data contained on this sheet is subject to therestrictions on the title page of this Wbrk. Safety, Health and Emergency Response Plan.'



ETHYLAMINE - Toxic, 10 vpm TLV

Flammable, 3.5 - 13.9% inair


Liquefied gas, bp ca.16.6°C, vp ca. 0.2 bar


Good odor warning (fishlike,ammoniacal)

- Avoid copper, nickel, tin,mercury, zinc




ETHYLENE Flammable, 2.7 - 32% in air

Asphyxiant


• Poor warning properties

• Gas density similar to air


• If temperature falls below10°C, ensure liquid ethyleneis not left in the cylinderor system


ETHYLENE OXIDE - Toxic, 5 vpm TLV


- Vapor can explode by spark,detonation or heating above440°C

- Subject to exothermic selfdecomposition and selfpolymerization


- Liquefied gas, bp ca. 11 °C,vp ca. 0.4 bar


- Avoid suckback of water,acid, or alkali or othercatalysts

- Liquid and aqueous solutionsare corrosive to skin andeyes

- Liquid causes cold burns

- Avoid copper, mercury,magnesium and silver if C His present


- Use precleaned and driedsteel and PTFE

- Ensure polymer blockage orskinning does not give falseindication of emptiedcylinder or system


'Use or disclosure of the date contained on this sheet is subject to the O ' ' J O • 'restrictions on the title page of this Work, Safety. Health and Emergency Response Plan.'



FLUORINE - Toxic, 1 vpm TLV

- Highly corrosive when moist

- Extremely powerful oxidant,igniting most organiccompounds and somemetals

- Gas 2 x heavier than air

- Good odor warning (irritatingand suffocating)

-EXTRA CARE!!!!

- Beware of danger ofhydrofluoric acid formed(risk of severe chemicalburns)


- Avoid all organic materials

- Use nickel, Monel, stainlesssteel (heavy gauge mildsteel, brass) all equipmentmust be precleaned andpassivated

- Initially introduce only smallquantities until convincedthat system is passivated

- Unwanted residual gasesmust be securely containedand safely transported toa facility properly equippedand staffed for disposal

caustic scrubber veryslowly

FLUOROETHANE - Flammable, 3.5 - 15.4% inair

- Asphyxiant







- High temp, decompositionproducts are toxic


301692

'Use or disclosure of the data contained on this sheet is subject to therestrictions on the title paga of this Work, Safety, Health and Emergency Response Plan.'



FLUOROMETHANE - Flammable, limitsunestablished

- Asphyxiant



- Vapor density similar to air





GERMANE - Toxic, 0.2 vpm TLV

- Spontaneously flammable inair (pyrophoric)



- Good warning properties(flames and smoke)

- Ensure that blockage bycombustion products doesnot give false indication ofempty cylinder or system



oxidizing scrubber andadsorber

HALOCARBON R11 - Asphyxiant








HALOCARBONR114B2

High temp, decompositionproducts are toxic

Liquid, bp ca. 47 °C, vp ca.0.4 bar absolute








HALOCARBONR12 - Asphyxiant








HALOCARBONR12B1

- Asphyxiant



- Liquefied gas, bp ca. -4°C,vp ca. 1.4 bar





HALOCARBONR12B2

- Asphyxiant



- Liquid, bp ca. 25°C, vp ca.1 bar absolute











- Use common materials for'vapor



restrictions on the title page of this Work, Safety, Health and Emergency Response Plan. *



HALOCARBONRI3B1

- Asphyxiant








HALOCARBONR14 - Asphyxiant






HALOCARBON R21 - Toxic, 10 vpm TLV

- Asphyxiant

















1'Use or disclosure of the data contained on this sheet is subject to the « (J 1 D O 5

restrictions on the title page of this Work, Safety. Health and Emergency Response Plan. *











HALOCARBONR113


Liquid, bp ca. 48°C, vp ca.0.4 bar absolute




HALOCARBONR114

- Asphyxiant


- Liquefied gas, bp ca. 3.6°C,vp ca. 0.8 bar





HALOCARBONR114B2






HALOCARBONR115

- Asphyxiant











GAS PHYSICAL PROPERTIES SAFETY CONSIDERATIONS DISPOSAL METHO'

HALOCARBONR116

Asphyxiant





• Vapor 5 x heavier than air




HALOCARBONR142B

- Flammable, 9 - 14.8% in air

- Asphyxiant






Use other common materialsfor vapor


HALOCARBONR152a

- Flammable, 3.7 - 18% in air

- Asphyxiant








"Us* or disclosure of the data contained on this sheet is subject to therestrictions on the title page of this Work, Safety. Health and Emergency Response Plan.'



HALOCARBONR218

- Asphyxiant



- Liquefied gas, bp ca.-36.7°C, vp ca. 7 bar





HALOCARBONC-318

- Asphyxiant








HALOCARBONR1113


- Asphyxiant






• Use other common materialsfor vapor






HALOCARBONR1113B1

- Flammable

- Asphyxiant




Avoid alloys > 2%magnesium, aluminum andplastics

Use other common metalsand PTFE


HALOCARBONR1114

Flammable, 11 - 60% in air

Asphyxiant


Subject to violent selfpolymerization

Liquefied gas, bp ca.•75.6°C, vp ca. 25 bar

• Poor warning properties

• Gas 3 x heavier than air

Ensure that blockage bypolymerization productsdoes not give falseindication of empty cylinderor system

Avoid PTFE



HALOCARBONR1132a


- Asphyxiant








3f)l6 fie'Use or disclosure of th» data contained on this sheet is subject to the



GAS PHYSICAL PROPERTIES SAFETY CONSIDERATIONS DISPOSAL METHOC

HALOCARBONR1216

- Asphyxiant








HALOCARBONR1318

- Asphyxiant

- Toxic, TLV established



- Liquefied gas, bp ca. 1.2°C,vp ca. 1 bar





HELIUM Asphyxiant



- Use common materials vent or recontainerize

HEXAFLUORO-ACETONE



- Poor odor warning



In the event of eye or skincontact, immediately washwith copious amounts ofwater

Use nickel, Monel, stainlesssteel

• All equipment must beprecleaned and dried


30170C'Use or disclosure of the data contained on this sheet is subject to the




HYDROGEN Flammable, 4 - 75% in air

Asphyxiant



- Ignites very readily, flamebarely visible

- Open valves, etc., slowly



HYDROGENBROMIDE

- Toxic, 3 vpm TLV

- Corrosive especially whenmoist



- Good odor warning


- Use common materials fordry gas

- Use Monel, heavy gaugemild steel with moist gas

- Avoid suckback of water

- caustic scrubber

HYDROGENCHLORIDE

- Toxic, 5 vpm TLV




- Good warning properties





- caustic scrubber

HYDROGENCYANIDE

- Toxic, 10 vpm TLV

- Fast acting, irreversible,systemic poison


- Liquid, bp ca. 25.7°C,vp ca. 0.8 bar absolute


- Moderate odor warning(bitter almonds)


Avoid suckback of catalystand water acid or alkaliswhich promotepolymerization (explosionpossible)

• Use stainless steel, Moneland PTFE


'Use or disclosure of tht data, contained on this sheet is sub/act to therestrictions on the title page of this Work, Safety. Health and Emergency Response Plan.'

301701



HYDROGENFLUORIDE

- Toxic, 3 vpm TLV

- Corrosive, especially whenmoist

- Liquefied gas, bp ca. 20°C,vp ca. 1 bar absolute


- Moderate odor warning(irritating) with white fumesin air

Attacks and penetrates theskin, causes delayed,severe, deep-seated necrosis

If contact with body, washcopiously with water andobtain immediate medicalattention


• Use heavy gauge mild steel,copper and PTFE

- caustic scrubber

HYDROGEN IODIDE - Toxic, TLV unestablished




- Good odor warning





- caustic scrubber

HYDROGENSELENIDE

Toxic, 0.05 vpm TLV

Flammable

• Corrosive

• Liquefied gas, bp ca. -41 °C,vp ca. 8 bar

• Vapor 3 x heavier than air

• Good odor warning

- Elemental selenium may bepresent in cylinders andlines

- Disposal products containselenic components



- oxidizing scrubber andadsorber

30170'. O


22


GAS PHYSICAL PROPERTIES! SAFETY CONSIDERATIONS DISPOSAL METHOD

HYDROGENSULPHIDE

- Toxic, 10 vpm TLV


- Corrosive



- Good odor warning (rotteneggs) initially but decreaseswith exposure

Use aluminum, stainlesssteel (brass with dry gas)and PTFE

- caustic scrubber

HYDROGENTELLURIDE


- Flammable

- Unstable, decomposes toform elemental tellurium

- Liquefied gas, bp ca.-1.5°C, vp ca. 1.5 bar


Elemental tellurium may bepresent in cylinders andlines

Disposal products containtelluric components

Use Monel, stainless steelor heavy gauge mild steel

oxidizing scrubber andadsorber


restrictions on the title page of this Work, Safety. Health and Emergency Response Plan. '


GAS PHYSICAL PROPERTIES i SAFETY CONSIDERATIONS DISPOSAL METHOr

ODINEPENTAFLUORIDE

Toxic, 3 vpm TLV

Powerful oxidizing agent

Corrosive, especially whenmoist


Good odor warning(irritating)

-EXTRA CARE!!!!

- In the event of eye or skincontact immediately washwith copious amounts ofwater


- Use Monel, nickel (heavygauge mild steel) and PTFE.All equipment to beprecleaned and passivated



- Introduce initially only smallquantities until convincedthat the system ispassivated

- Unwanted residual gasesmust be securely containedand safely transported to afacility properly equippedand staffed for disposal

- caustic scrubber veryslowly, vapor only

IRON CARBONYL - Toxic




- Check for propellant



KRYPTON Asphyxiant


Gas 3 x heavier than air

- Use common materials - vent or recontainerize

3017M'Use or disclosure of the data contained on this sheet is subject to the

restrictions on the title page of this Work. Safety, Health and Emergency Response Plan.'



METHANE Flammable, 5 - 15% in air

Asphyxiant



- Use common materials combustion followedby absorption

METHYL-ACETYLENE

- Flammable, 5 -15% in air

- Subject to exothermic selfdecomposition




- Avoid copper, silver, andmercury




METHYLAMINE - Toxic, 10 vpm TLV




- Use common materials combustion followedby absorption

3 METHYL-BUTENE1

- Flammable, 1.5 - 9.1 % inair

- Asphyxiant


- Liquid, bp ca. 20°C, vp ca.1 bar absolute




- Avoid suckback of air

combustion followedby air

301705'Us* or disclosure of the data contained on this sheet is subject to the




METHYLMERCAPTAN


Flammable, 3.9 - 21.8% inair

Liquefied gas, bp ca. 6°C,vp ca. 0.7 bar


Good odor warning (likerotten eggs)




METHYLSILANE - Toxic, TLV unestablished


- Liquefied gas, bp ca. -57°C,vp


- Good odor warning(repulsive)

- Use metals and PTFE - combustion followedby absorption

MONOCHLORO-SILANE

- Toxic, 0.5 ppm TLV

- Spontaneously flammable




- Good odor warning (pungentand irritating)

- Ensure that blockage bycorrosion/combustionproducts does not give falseindications of empty cylinderor system


- Use Monel, heavy gaugemild steel if moist

- Forms hydrochloric acid inpresence of water

- Avoid suckback of aqueoussolutions


NEON Asphyxiant


Gas 1.5 x lighter than air

• Use common materials - vent or recontainerize



GAS PHYSICAL PROPERTIES SAFETY CONSIDERATIONS DISPOSAL

NICKEL CARBONYL - Toxic, 0.05 ppm TLV


- Liquid, bp ca. 43 °C, vp ca.0.5 bar absolute


- EXTRA CARE!!!!



NITRIC OXIDE - Toxic, 25 vpm TLV

Oxidizes in air to NOand N 0

Gas density similar to air

Moderate warning properties

Use common materials fordry conditions

Use stainless steel and PTFEin presence of oxygen ormoisture

- caustic scrubber

NITROGEN Asphyxiant



- Use common materials - vent

NITROGENDIOXIDE

- Toxic, 5 vpm TLV

- Corrosive

- Oxidizing agent

- Liquefied gas, bp ca. 21 °C,vp ca. 1 bar absolute


- Good odor warning, browncolored

Avoid plastics, rubber, etc.

Use stainless steel and PTFE

- caustic scrubber

NITROGENTRIFLUORIDE

- Toxic, 10 vpm TLV

- Powerful oxidizing agent atelevated temperatures


- Gas 2.5 x heavier than air

Avoid oil, grease, and othercombustible contaminants


• Use other precleanedcommon materialsPTFE, Kel. F


30170?'Use or disclosure of the data contained on this sheet is subject to the




NITROGENTRIOXIDE

Toxic, 5 vpm TLV

Corrosive

Oxidizing agent

Critical temperature 3°C

Vapor 2 x heavier than air

• Moderate odor warning


Use stainless steel and PTFE

- caustic scrubber

NITROSYLCHLORIDE





- Good warning properties


Use nickel, Monel, tantalum,lead (heavy gauge mildsteel)

- caustic scrubber

NITROUS OXIDE - Asphyxiant

- Oxidizing agent






OXYGEN Powerful oxidant



Avoid oil, grease and othercombustible contaminants

• Use precleaned commonmaterials

• Avoid localized oxygenenrichment

- vent


30.1708

TREATMENT METHODOLOGIES


PENTABORANE - Toxic, 0.005 ppm TLV

- SpontaneouslyCombustible, Poison; a lowvolatility liquid

- Vapor odor is irritating

vp = 66 mm Hg @ 0°C

Vapor density heavier thanair

- slowly hydrolyzes in H2O

Reacts with NH3 to formtetramoniate (B5H9)

Decomposes slowly @150°C

B5H,, - Decomposes overtime or if heated toproduce diborane,tetraborane, hydrogen,pentaborane, decaborane

Hydrolyzed in water toform boric acid andhydrogen

May react explosively withchlorinated solvent

- Scrub in water withsurfactant, flare H2

PHOSGENE - Toxic, 0.1 vpm TLV



- Liquefied gas, bp ca.7.6°C, vp ca. 0.5 bar


Ensure that blockage bycorrosion products does not givefalse indication of empty cylinderor system

Avoid plastics, rubber, etc. withliquid

Use Monel, stainless steel (heavygauge mild steel) and PTFE

- caustic scrubber

PHOSPHINE - Toxic, 0.3 vpm TLV

- Spontaneously flammablein air (pyrophoric)

- No Odor warning at TLV

- Liquefied gas, bp ca.-88°C, vp ca. 35 bar


- Use common materials - combustion followed byadsorption

PHOSPHORUSPENTAFLUORIDE

- Toxic, TLV not established


- Liquefied gas, bp ca.-85°C, vp ca. 28 bar

- Vapor odor warning(irritating)

• In the event of eye or skincontact, immediately wash withcopious amounts of water

• Use nickel, Monel (heavy gaugemild steel)

• Use hard rubber, PVC for moistgas

- caustic scrubber

'Use or disclosure of the data contained on this sheet is subject to the /f U 1 f V Srestrictions on the title page of this Work, Safety, Health and Emergency Response Plan.'



PROPADIENE - Flammable, 2.16 - 12% inair

- Subject to selfpolymerization

- Asphyxiant

- Liquefied gas, bp ca.-34.5°C, vp ca. 6 bar


- Moderate odor warning

Guard against polymerblockage, check thatcontent is stable; i.e. thatno temperature rises ofcylinder




PROPANE - Flammable, 2.2 - 9.5% in air

- Asphyxiant







PROPYLENE - Flammable, 2.4 - 10.3% inair

- Asphyxiant


- Liquefied gas, bp ca.-47.7°C, vp ca. 9.4 bar





3<»17IO'Use or disclosure of the data contained on this sheet is subject to the




PROPYLENE OXIDE - Toxic, 20 vpm TLV


- Vapor can explode by spark,detonation, or heating

- Subject to exothermic selfdecomposition and selfpolymerization




Avoid copper, silver,mercury, magnesium is C His present


Use precleaned and driedsteel and PTFE

Avoid suckback of water,acid, alkali, or othercatalysts

• Ensure that polymerblockage does not give falseindication of empty cylinderor system


SILANE - Toxic, 0.5 vpm TLV


- Critical temperature -3.5°C

- Gas density similar to air

- Good warning properties(flames and smoke)

- Ensure that blockage bycombustion products doesnot give false indication ofempty cylinder or system


oxidizing scrubber

SILICONTETRACHLORIDE

- Toxic, 5 vpm TLV


- Hydrolysis with water orwet air



- Good odor warning


- Use heavy gauge mild steel


- caustic scrubber

'Use or disclosure of the data contained on this sheet is subject to therestrictions on the title page of this Work, Safety. Health and Emergency Response Plan.'

3!


GAS PHYSICAL PROPERTIES SAFETY CONSIDERATIONS DISPOSAL METHOf

SILICONTETRAFLUORIDE


Corrosive especially whenmoist


Good odor warning


If contact with body washcopiously with water andobtain immediate medicalattention

- caustic scrubber

STIBINE -Toxic, 0.1 vpm TLV




- Use iron or steel

- Elemental Sb may bepresent in cylinders andlines. Disposal productscontain Sb-compounds


SULPHUR DIOXIDE - Toxic, 2 vpm TLV




- Use common materials • caustic scrubber

SULPHURHEXAFLUORIDE

- Asphyxiant



- Liquefied gas, sublimationpoint-63.8°C, vp ca. 21.6bar


- Use common materials - vent or recontainerize

'Use or disclosure of the data contained on this sheet is subject to therestrictions on the title page of this Work, Safety, Health and Emergency Response Plan. '

32



SULPHURTETRAFLUORIDE



- Poor odor warning at TLV



If contact with body washcopiously with water andobtain immediate medicalattention


- caustic scrubber

SULPHURYLFLUORIDE

- Toxic, 5 vpm TLV




- Avoid plastics, rubber, etawith liquid


- caustic scrubber


restrictions on the title page of this Work, Safety, Health and Emergency Response Plan. *33


GAS PHYSICAL PROPERTIES! SAFETY CONSIDERATIONS DISPOSAL METHO'

TETRAFLUORO-HYDRAZINE

- Extremely powerful oxidant

- Explosive self-decompositionpossible with heat or shock(pressurized gas)

- Highly toxic, TLVunestablished

- Gas 3.5 x heavier than air

-EXTRA CARE!!!!

- Due to extreme reactivityand small quantity normallysupplied per cylinder onlymethod recommendable issafe release by leakage toatmosphere

- Do not strike or hammerpressurized container

- Beware of danger ofhydrofluoric acid, etc.formed (risk of severe,persistent chemical burns)


- Avoid all organic materials

- Use nickel, Monel, stainlesssteel, or heavy gauge mildsteel. All equipment must beprecleaned and passivated

- Prepassivated precleaneddisposal system by graduallyand cautiously increasingflow of tetrafluorohydrazineinto continuous diluentstream of nitrogen

- Unwanted residual gasesmust be contained andsafely transported to afacility properly equippedand staffed for disposal

caustic scrubber veryslowly


restrictions on the titla pagt of this Work, Safety, Health and Emergency Response Plan.'



TRICHLOROSILANE - Toxic, TLV unestablished



- Ensure that blockage bycorrosion/combustionproducts does not give falseindication of empty cylinderor system

- Use stainless steel, iron,steel, or borosilicate glass

- Avoid oxidizing materials


TRIMETHYLAMINE - Toxic, 10 vpm TLV

- Flammable, 2-11.6% in air

- Liquefied gas, bp ca. 3°C,vp ca. 1 bar


- Good odor warning (fishlike,ammoniacal)





TUNGSTENHEXA-FLUORIDE


- Corrosive






- caustic scrubber

VINYLBROMIDE - Toxic, 5 vpm TLV

- Flammable




- Avoid copper, silver,mercury if C H is present




301715

'Use or disclosurt of the data contained on this sheet is subject to therestrictions on the title pagt of this Work, Safety, Health and Emergency Response Plan.'


GAS PHYSICAL PROPERTIES SAFETY CONSIDERATIONS DISPOSAL METHOF

VINYLCHLORIDE - Toxic, 5 vpm TLV



- Liquefied gas, bp ca.-13.9°C, vpca. 2.3 bar






VINYLFLUORIDE - Flammable 2.6 - 21.7% inair

- Asphyxiant









VINYLMETHYL-ETHER


- Asphyxiant









APPENDIX E

Historical Incidents Involving Boranes

301717

S ERM 005 P02/06 OCT 10 '94 11:26

,8

LITERATURE SEARCH"7] FOR THE

J MALTA ROCKET FUEL AREArn SUPERFUND SITE•] TOWNS OF MALTA AND STILLWATER

SARATOGA COUNTY, NEW YORK

J VOLUME I

1

J May 1992

Prepared by

Geraghty & Miller, Inc.125 East Bethpage Road

Plainview, New York 11803(516)249-7600 3'VI 71 8

452-42y5 ERM 005 P03/0& QCT 10 '94 11:26

8-16available showing disposal of debris from the explosion in an unidentified open field, possiblythe baseball field (the D-5 and, possibly, D-6 Areas) (81).

The building was repaired and used by GE for the Atlas Propellant Utilizationi Program. This program involved metering and equalizing fuel and oxidizer over a specific

period of time. The program lasted two years (69). Later, the U.S. Army used the facilityi for their tank projects (80).

2 In 1976, MTI leased the building to design, manufacture, and test high efficiencystreamdriven turbines and turbo machinery. Freon 113 was used in a closed loop to cool

} the turbines. The freon did not vaporize during use. In 1985, 440 gallons of Freon weredrummed and disposed off-site by North East Solvent Reclamation Corporation, Lawrence,Massachusetts (75A), During the 1980s, MTI used approximately 9,000 gallons of No. 2 fueloil and 250 gallons of diesel fuel per year (96, 97).

\

NYSERDA instituted a monthly sampling program for the potable water supply at| this facility in October 1987 after the air stripper was installed. Available data show that

carbon tetrachJoride and TCE are detected occasionally at 1 to 2 ug/L. Compounds1 associated with the ehlorination of the water supply are also present at concentrations of 1

to 2 ug/L (Table C-12 in Appendix C), (1).

JIn 1987, NYSERDA sampled the septic system at Building 20. Toluene was the only

nJ VOC detected: 457 ug/L was reported in the wastewater sample, and 120 ug/kg was reported

in the sludge sample (1). In May 1988, the septic system tanks were pumped out and rinsed.

Building 21: Ram Jet Laboratory

In the 1950s, Building 21 was the ramjet facility in which a 12-cyiinder diesel enginewas used to power compressors to test the ram jets in a supersonic wind tunnel (71, 79).

301719

452-4295 ERI1 °05 P04/06 OCT 10 '94 11:27

SJ 8-14

•-•n area where chemicals were stored. A drain is present in the bottom of the concrete bunker"••'J and any spillage/leakage from storage or overflow pipes would enter the drain. The drain.q line from Building 18 appears to be shown'on Figure 3. Discharge from the end of this line

would enter the on-site drainage ditch connected to Muggetts Pond.

In the late 1950s, Curtiss-Wright may have used the building while testing in Building~l 24 (71). During these years, the building was used to store propellants in drums and

contained two 500-gallon aluminum tanks of hydrogen peroxide (71, 69). The fireF! department was instructed to avoid the building in the event of a fire because it was an

underground explosives magazine (82). At some point, a container of peroxide developed•-1 a leak and exploded in the area between Buildings 18 and 24 (SO).

•-• In later years, the building was "a secured hazardous waste area for solids,"manifested and hauled away by Clean Harbors or Northeast Solvents for incineration (80).GE has used Building 18 since the early 1980s to store waste for less than 30 days prior totransport by a licensed waste hauler to a TSD facility for disposal. The building is used by

.-: GE to store 5-gallon containers of liquid hydroxyl ammonium nitrate propellant. Empty 5-gallon containers are presently stored in the facility (73). Carbon tetrachloride has beendetected in downgradient monitoring well cluster 13S and 13D during the Early Warning

__ System Monitoring Program.

Building 20; Chemical Plant/MTI Facilityi-itt

_ Building 20 was designed and built by the U.S. Army Corps of Engineers as a% chemical plant. From 1952 to 1955, GE used this facility to manufacture diborane and_ pentaborane rocket fuels (79,183). In 1955, Olin Mathieson Chemical Company took over

^ production of diborane and pentaborane (79, 183) and may have performed experimental~ work on pulse jets for the U.S. Air Force (80).?• 301720

035 P05/0S OCT 10 '94 11=2'

452-4295 ERM

:*•.«?8-15

Building 20 exploded at approximately 1:12 p.m. on June 21, 1955. The plant wasill scheduled for closure on June 30 and was being cleaned. All processing of materials had__, been completed except for a final charge of crude pentaborane which was in the process of-- purification and distillation. The operation of preparing diborane had been shut down the,^~ previous week. The conversion of diborane to pentaborane had been completed that^ morning and the four conversion units were in varying stages of being cleaned. One unit was.v-! completely clean, two had all solids removed, and had been steamed and washed with-•^ acetone. The fourth unit had been evacuated of all process gases and repressurized with^-i nitrogen that morning. It was to be cleaned of accumulated decaborane containing solids

by slurring with carbon tetrachloride. The plan was for the three clean units to be filled with~ nitrogen to 50 psi to prevent recontammation. They were to be sealed off from the founh

unit via a system of valves (146, 147).

The explosion occurred when one of the valves was left open and the 50 psi ofnitrogen in one of the clean pressurized units forced acetone into contact with thedecaborane-rich solids in the fourth unit. The two engineers performing the task died as aresult of the explosion (146).

Chemicals present at Building 20 prior to the explosion included the following (147):

Carbon tetrachlorideLiquid and solid hydridesPentaboraneEthyl alcoholLithium hydrideDiboraneDrums of ether, ethyl alcohol, kerosene, boron trifluoride etherate, acetonePressurized cylinders of pentaborane, ethane, diborane, freon

After the explosion, the remaining borane was taken to the bank area east of TestPits 2 and 3, where it was exploded by a sharpshooter (80). Photographic negatives are

3M7Z1

Metro TodayLive Wire B2State Report B2

Forest Acresnames newpolice chief,B3 METRO/REGION BWho will

police videogamblingpayoffs? B5 ! Business

Obituaries B4B6

COLUMBIA. SOUTH CAROLINA

Cleanup halted after worker collapsesCrew was removingrocket fuel at Divex

By WARREN BOLTONStaff Writrr

EPA officials halted cleanup efforts atthe Divex Inc. explosives manufacturingsite on Montgomery Road after a workerfell ill while rinsing a cylinder that hadbeen filled with volatile rocket fuel.

Keith Jolly, 37, of Atlanta remainedunconscious after collapsing about 4 p.m.Monday at the Divex site, said MichaelByrd, Richland County's Emergency Ser-vices director. Jolly was in critical condi-tion in the intensive care unit at RichlandMemorial Hospital.

"We don't know whether or not he hada medical problem or if he came in contactwith some of the materials that they weretreating out there. If he did, it was anisolated-type incident," Byrd said.

None of the other workers with Jollywas affected, he said.

Authorities reported no releases andno danger to surrounding communities,Byrd said. "They have monitors set up.Nothing has moved off site," he said.

Jolly was among workers participatingin what officials consider the most deli-cate part of the cleanup of (he Divex plant,which has been labeled a Superfund site,making it eligible for federal aid.

Divex owner Jack Sutherland waskilled in a blast on Labor Day 1993 whilemixing dhcmicals at (he plant, in the 500

block of Montgomery Road in northernRichland County.

In May, officials began the tedious anddangerous work of identifying and remov-ing toxic gases from the site. Most of theexplosives and chemical wastes — morethan 45,000 pounds of explosives and15,000 gallons of chemicals so far — havebeen removed.

According to Byrd. Jolly became illMonday while working with several otherworkers in a domelike structure fashionedto keep any possible releases of gas fromescaping.

The group was rinsing a cylinder from

PLEASE SEE DIVEX PAGE B5

JULY 13, 1994

DIVEXFROM PAGE Blwhich they had removed pentabor-anc, a product used as a rocket fuel.The product was used in the 1960sand 1970s, Byrd said, but is so vola-tile that it is no longer used.

When the work started about amonth ago, several hundred poundsof the material were on site, he said.

The workers wore protectivesuits and were breathing air from

masks. Jolly's equipment is beingchecked, Byrd said.

The hospital has been given in-formation on what products are be-ing treated at the site so technicianscan run tests on Jolly, Byrd said.

Jolly is employed by IntegratedEnvironmental Services, a compa-ny helping with the cleanup under acontract with the federal Environ-mental Protection Agency.

Work was suspended at the Di-vex site pending the outcome of in-quiries into Jolly's illness.

I

•vltOro

THE STATE. COLUMBIA. S.C.

Worker M

might haveinhaledrocket fuel

IJy WARKEN UOLTONSluf/Wrltr

• ———_.—.^————; A worker who collapsed ai• the Divex Inc. explosives mnnu-•' facturing plant might hnvc in-. haled a volatile rocket fuel.; An investigation of the pro-; Icctive suit and mask that Keith'• Jolly. 37. of Atlanta was weari ng\ when he collapsed Monday sug-; gests he might have been ex-. posed to penlaborane. a product'. used as rocket fuel, said Michael: Dyrd. Richland County's Emcr-; gency Services director.'• "It appears that there's a pos-', sibility that he inhaled pentabor-: ane or pentahoranc entered hisI breathing mask." Dyrd said..' "The two possibilities as we sec', it right now are equipment fail-; urc or operator error."•. Jolly, who was unconscious'.(or more than a day. was con-; scious and listed in (air conditionThursday at Richland Memorial

• Hospital, according to a spokes-woman.

; "I'm really glad to hear that; he's getting better. That's great."• Byrd said. He said emergency.personnel responded quickly. and probably saved Jolly's life.

Jolly became ill Mondaywhile working with several nth-

' crs in a domelike structure fash-.ioncd to keep any possible re-• leases of gas from escaping. Thegroup was rinsing a cylinderfrom which they hod removed

Ipcntaborane.< Byrd said the matter will be'turned over to EnvironmentalProtection Agency officials and

.Integrated Environmental Scr-•vices, the company for which"Jolly works. The company is; helping EPA with the cleanup.; Also. Dyrd said, work on; cleanup at the site, which was'discontinued after Jolly's col-lapse, will remain suspended for

; several more days. The EPA will• decide when work will resume.'. Protective equipment worn. by other workers will be inspect-,cd. Dyrd said. "It certainly ap-pears that this was an isolated

• case." he said, adding no other! workers were affected.

In May, officials began the lr-dious and dangerous work of

'identifying and removing toxic, gases from the Montgomery, Road site where owner Jack; Sutherland was killed in a blast'. on Labor Day 1993 while mixing.' chemicals.; Most of the explosives andchemical waste; — mom th:m-15.000 pounds of explosives and15.000 gallons of chemicals so

; far — have been removed.301723

SUNDAY TIMES, TRENTON N.J., SUNDAY, FEBRUARY 28. 1982 B7

No known treatment for accident victimsRICHMOND, Va. IAP) — Doctors arc "charting

unknown territory" in their efforts to save thelives of two of the most seriously injured victims ofa toxic chemical accident, a physician saidyesterday.

William Andcrson, 27, of New Kent County, andJames M. Kachur. 37, of Bridgcwater, N.J., werelisted in critical condition last night at the MedicalCollege of Virginia Hospital.

'A third man. Joseph Feyti, 35, of Morrisvillc,. Pi., was conscious and in serious condition at St.

'.e's Hospital, a spokeswoman said.dix rescue workers, who were among the 18

people believed to have been exposed to the borongas, were admitted to St. Luke's Friday forobservation..

•O

LATE YKSTKRDAY MOKNINC. four otherrescue workers wort- taken to St. Luke's, and ;\hospital spokeswoman said one more was expectedto be admitted.

Investigators are still were trying to piecetogether the events which led up lo the accidentThursday evening at Environmental LaboratoriesInc. in Hanover County.

Kaclnir and Fcyti. employees of A Lino Indus-tries Inc. of Bridgcwater, were trying lo neutralizethe last of 20 cylinders when the process wentawry, releasing a vapor cloud, authorities said.Andcrson, a vice president of EnvironmentalLaboratories, apparently was felled by the chemi-cal when he went to help Kachtir and Feyti.

Doctors at MCV Hospital were maintaining thebodily functions of Anderson and Kachur with1

respirators, according to Dr. Jeff Weiland. aresident physician at the hospital's intensive careunit where they arc being treated.

Andcrson and Kachur have remained uncon-scious since they were admitted .Thursday night.

THE PROBLEM, he said, is that "there is noknown treatment for what we believe they wereexposed to."

"We're charting unexplored territory." he said,since doctors still arc not sure of the exact natureof the boron compound or compounds involved inthe accident. Mixing various compounds, even inminute quantities, can drastically alter the natureof the original compound, he said.

He said, however, that he was encouraged byinformation MCV doctors have received from twoout-of-statc physicians with some experience intreating exposure to boron compounds.

The rescue squad members who were treatedcomplained of headaches, dizziness, difficulty inbreathing and slight chest pains.; Authorities now say the boron gas which

workers were attempting to neutralize was penta-borane, a hydrogen and boron compound. Initialreports were that the gas was diboranc, which issimilar lo pentaborane.

PEfcTABORANE. which is used primarily inmanufacture of rocket fuel, is believed to be 10times more lethal than diborane, said HanoverFire Chief Mike Harman.

Authorities believe that 13 of the 20 cylindersfound at the site came from property in Richmondowned by' Philip Morris Inc. However, PhijjpMorris spokesman Kobert E. Oateman said all 20cylinders were from the property.

The cylinders were found buried there in 1900.The properly at one time belonged to ExperimentInc., a now-defunct firm that held aerospaceresearch contracts with the government.'Thecompany ceased operations in 1%)!.

A^Richmon'd'times'-Dispat'ch, Sun.. March 6, 1983•5* -.- . .' V - -- ' . ' '2i«- , . - . - . ;.y.;.y..i' «v < _ _ f — • _ _.

CM'r-

. .,Ccmfjnued Frbrri-Firsl Patfeaccident'^'might':. never have'happeneji.-v .yv' '>'< r«i- "^-Vv..*'.Or. the.drv-of-thc accident,-Feb. 25,"l982," A-Linj workci-swere.not .wearing breathingmasks..',-?! protective._ suits,Smith sa:id. And they were per-.. :i i.~i-.i ,•..'••• : , • • • . ' , . • •forming a, hazardous task in a

'heavily 'populated area, theHanover Industrial Air .Parknear Interstate 05, a'small air-'port,' 'several .'homes ' and a.campground, he'said. . ;

William ,G. Saddinglon, aPhilip'^'Morris''engineer, wasoverseeing the'operation butwas pot present when the acci-dent occurred about 6 p.m.• .r-^YV . t~." •':!, > i - : Did. ha vera ^number\- A-Line "did..- have ' an EPAidentification 'number. Smithsaid. Onlhe application for thenumber, "a company must listthe type of service and area ofoperation, he said, i "'•

:.Thc EPA number for A-Lincapplied lo work in 'New Jer-sey.'-'riot Virginia', according to

. Willjsm F. Gilley. director ofthe'state division of solid andhazardous "waste" manage-ment. Morcovcr.'A-Line neverapp!ied ; rfor'"tha "pe-.-mit re-quired :froT: '.no state, Gi ' ievsaid?''\ / ; • ' - ' ••. "Evca'lf A-Line'had applied,the 'firm', probably would nothave gotten'one,'Gilley said.There are'no'approved facili-ties'in the state for disposal ofcompressed-gas cylinders, hesaid. :. • • • :V-y \V- ! : ( • .' 'A-Line carried 51 million ininsurance from Canadian Uni-versal Insuranre Co. and anadditional S9 .ni l l ion from In-tegrity Insurance'Co., courtpapers show' • "• •

TV. o days before the acci-dent','a'pickup truck with New-Jersey license plates pulled upto the "bay door at Environ-mental Laboratories at 103 S.Leadbeiter Road in the indus-trial park. On the driver's sidedoor, a msrnctic sign read: A-Line Services Inc.

I'liolo

Fire Chief Mike HirmanInvestigated accidentThe men f r o m A - L i n c ,

•James Kachur, 37, the founderand president, and JosephFeyti. 35, set up their "blowdown" equipment to renderharmless the cylinders byforc ing the contents thr urh..r. ib-gaiior. c j ^ m o: neu t r a l -izing solution, or caustic bath.

' According to the report byEnvironmental LaboratoriesPresident Steven R. Pond, whotried to iden t i fy the chemicalsfor Phi l ip Morris, two of thecylinders were labclec L^H,,the c h e m i c a l m a k e u p ofpenlaborane.

Two other cylinders werem a r k e d boron t r i ch lo r ide .Some contained the refnger--ant Freon or fluorine gas.Others had no markings orwere too rusted to decipher.About half of the cylinders hadholes in them.

On Jan. 5, 1982, Phi l ip Mor-ris officials had met in Rich-mond wi th Pond and Kachurof A-Lme, according to asworn statement by Charles Z.Horner, a Philip Morris em-

ployee. At the meeting, Ka-chur inspected the cylindersand said his company couldhandle the disposal, Hornerslated. ' '. ,

Ir. a letter from A-Line toPhilip Morris, the New Jerseycompany said it would chargeJ750 per cylinder for disposal,plus J75 per drum packed withempty cylinders' and otherwaste products. The operationwould take four days, accord-ing to the letter. If it wentlonger, the company wouldcharge $975 for each addition-al day. The total cost of the jobwas set at $15,000. The letterwas signed by Kachur.

A-Line had successfully dis-posed of hazardous waste inthe past but, according to W.Burton Blackburn, lab super-visor at Environmental Lab-.oratories, the men told him1

they were not chemists.Kachur and Fcyti used lit-

mus paper to test the pH (alka-linity or acidity) of the sub-stances , accord ing toB l a c k b u r n a n d a n o t h e rsource. Kachur and Feyti had\no permission to use the labfor U.-sting or any other pur-pose. Blackburn and Pondsaid.

"We let them use the bath-room and the telephone andthat was about it," Blackburnsaid.

Blackburn said the litmuspaper was the only testingequipment he saw. Two offi-c ia l s s u p p o r t e d t h a tstatement.

The men sealed the cyUi. •ders, which measured a foot inlength or less, in a larger "de-struction cylinder" that wasabout the size of those used byballoon vendors. The destruc-tion cylinder bad a hydraulicramming device to pop o£f thevalve on the smaller cylinderinside.

If anything was releasedfrom the smaller cylinder, apressure gauge would registerit. The men then turned on a

tank of nitrogen that pushedthe contents down through thedestruction cylinder and out aline at the bottom leading lothe Dcutralizing bath.

Ir. theory, .a harmless gasthen bubbled out of the bath.

Labora to ry tests la tershowed that the squatty, un-marked cylinder involved inthe accident contained almostpure pentaborane. developedunder contract with the De-fense Department as a rocketfuel. The substance, a liquidthat turns into gas at roomtemperature, reacts violentlywith air or water.

According to Chuck Ram- .sey, the state hazardous mate- :rials ,. response officer, theblack -logbook with • onand gold trim kept by . ,iurdid not mention pcntaborane.It mentioned only "diboraneand other unknown gases."

Ramscy, whose accountwas v e r i f i e d by a n o t h e rsource, said Kachur had a lotof literature about diborane, aless toxic chemical cousin.

. y"0n pcntaborane, he had

..zero," Ramscy said. "TheyHust.-didn't realize the totalityor\the'ijob ti-ey were working.Thcy'iid •-..•; kr.c * Iht. ;;utu-ôf tl>o-reactor." ••

The\qtries in the logbookfor the day of the .accidentshowed that the surface of thebath had burst into flamesseveral times, Ramsey said,indicating that raw pentabor-aoe was being released intothe air.

In his report on the acci-dent. Hanover Fire Chief MikeHarman mentions an inter-

. view with Blackburn, the su-pervisor at EnvironmentalLabs. Both Blackburn andPond complained to K irand Feyti about their m jsand the proximity of the oper-ation to the open bay doors ofthe building, according to therepor t d a t e d a b o u t twomonths after the accident

Blackburn also told Har-

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man Lhit he noiiced what heco.-îdcred unsafe methodsused by the A-Lir,e men sincethe day they arrived. On oneoccasion, Blackburn said, hes^w one of the men open avalve at the botto;n of the de-struction cylinder. A sub-s t a n c e t h a t s m o k e d a n dflamed carnc out . he said.

The falal accident occurredtwo days after they started,yet Kachur and Fcyti mayhave been get t ing whi f f s ofpcntaboranc since the daythey arrived, i m p a i r i n g theirphysical and menial abilities.Ramsey wid the A-Line log.which contained ne.it. carefulentries at the s t^r t . "lookedLike slop" ID the bsi pages.

The accident occurred ont>.c 20th of the :i cvlj-.dcrs.

' ', . < Slaff PboUj by Cl«ne« Bn>V.']

::2 in Jnbora «'; y. W.B. DinckbL-rn (l'_-ft), Stevcn R Pond s.'ty ••

nrt Ramc^v.1 anrt /ânf R^ Tâvr-. I I - / < * - - \ . » . F » <- . innAr>te> * K ^ < V'^^Vmr"Only two living men witnessedw h a t happened . Feyti,reached at his home in Morris-ville. Pa., would not commenton the accident, but local doc-tors interviewed him.: The other witness was H.C."Ted" Mentz, the owner of En-vironmental Equipment Inc.,in the rear of the same bui ld-ing as Environmental Labs.

According to Menu, theramming device got stuck. Torelieve the pressure inside thecylinder, one of the A-Lincmen opened a valve and re-leased a white mist into the a;rfor seven or eight minutes,MTUZ said.

The men then apparentlyopened the destruction cylm-der. It was found with the topc3 by s-jtc o;:icul O. ic»

Ramsey and Capl. R.C. Daw-son of the Henrico County haz-ardous materials team when.they r e sponded to theaccident.

According to an articlewritten by medical people in-volved, some liquid pentabor-ane ran over Kachur's barehands and out onto a plywoodsiicct on the ground when hetried to dislodge the ram. :

The pentaborane turned togas and prevailing breezesblew i; through the bay doorsinto Environmental Laborato-ries, where a chemist, WilliamAnderson. was at his desk, ac-cording to the paper. As aresult, Andcn>on has sufferedsevere brain disintegration,,the paper said.

Ar.cir.cr scenario previous-

ly drawn suggests that Kachur"drew off a beaker of thepcnts-borane and look it into the labfor analysis. A beaker wasfound inside the lab that Ram-_sey and others believe wasused. As the pentaboranewarmed to room temperature,it turned to gas and rilled thebu i ld ing . As he carried thebeaker, according lo Lhia ao'count, Kachur probably In-".haled the fatal dose several

Mentz, who doctors sayhas eipeneaced iUwas sitting in his office,has a separate ventilation sys- •tern, when he heard the fcrs:'. 'ambdajice arrive. It was bis: 'first indication that something *had gone terribly wronc '.''. '

<: IJ i a n ic-l.y;* *! a : I /:<>^"

"/A/7, ff)/s sfuff ts peftng toall of us, ah, ah, ... takeover," radioed the- rescuesquad.

Every victim at the scenehad been found unconsciousor incoherent from anunknown gas poisoning. Therescuers went in to get themand were transporting them tothe hospital. Then, one byone, the rescuers becamevictims.

"It's-a good idea to keep agood little ways away," saidanother rescuer over theradio, "because everybodyseems to be normal and all ofa sudden, you know, it hits, ithits 'em."

Twelve rescue squadmembers were hospitalized.Even hospital personnelreceiving the victims becamesick, and the emergencyroom was quarantined. Backat the scene, fire officialsraced to identify thisdangerous gas.

BY CHIEF M. G. HARMAN. SB.

Accurate information was a problemfrom the first telephone can reporting the"gas poisoning" at the Hanover IndustrialAir Park in Hanover. Va. After getting theaddress, the dispatcher asked what busi-ness it was. The caller erroneously calledit Chemical Analysis instead of the correctname of Environmental Laboratories. Thatmeant that no fie card for Chemical Anal-ysis could be found in the communicationscenter to identify owners or whom to callin an emergency.

The fire department was not dispatchedon this first caJI at 6:08 p.m. on Feb. 25.1982 - only the ambulance rescue squad.When the fre department was dispatchedfour minutes later, an order went out toresponding fre personnel that no oneshould enter the area of the incident with-out wearing complete protective clothing

-•*xJ positive-pressure breathing apparatus.Unfortunately, the separate ambulancerescue squads were not equipped withSCBA.

The first fire units and I arrived at 6:2-5.We found that the rescue squad had al-ready entered the building and was pre-paring to transport four vk'.ims to thehospital. Three were suifering from bothcardiac and respiratory problems, unable-to tei us anything about what had oc-curred! The fourth person, while con-scious, could not provide any information-either.- -Squad members get-sick

As the victims were being transported tothe hospital by the Ashland and AshcakeVolunteer Rescue Squads, each squadmember began to get sick. One memberreportedly was in "respiratory distress."and .mother reported feeing "intoxicated" _and stoned speeding at more than 85 mphto the hospital.

When a communications link was com-pleted \yiih two hospu afc. Medical College01 .Virginia (MCV) and St. Lukes, we soonleorned thjt even the hosyital emergencyroom stall became sick, presurrubly alterbreathy jir-irom the. victim's lungs and.

• clothes. For the iirst time in history, theMGV frmerucncy room wj» closed Jnd •qujrjnnnt-0. Ambulances u>ed to irons-port victims were Jiso Quarantined.

AU»jm\hiie. I vow IUQ iirp injhters enterihi-'jrp.r \\.ihout iC2A Thcv \\ere re-moval immtniuifiv. 01 course, but it indi-CJU"> J tonnnuou-) rei-ti lo

Effons continued at the scene to identifythe chemical or gas responsible for thisemergency, and :he hospitals began testingblood samples for some due. An explo-sion meter was used to test for explosiveflames. There were rone.

The material has not yet been named inthis report so you can share in our suspense

.-- ^_ A «•> -srV>T£ .""*. .- **j>^/^^t

eyiincefs. contents unknowrTh«y were orousni in !cr Oissosai.

and frustration at the unavailability of irformjsion. -

A command sou was set uo jus; nor:of the buiidirz. and a team of lire iitr-.te1

led bv District Ch:ei Pe:e Ta\ior er-.terec :rbuilding to cr.eciuor oiher vicr.rrs arc :seafcn lor rrore iniorrnaiion. The :e •phone was :ouna.o:f :.~e .K.oo< in :.ue :.-;•ofiice. jna J noseooe* wan ooDor?''chemicaf !c:~iu:os. was 'ourâ. So:.-..-else unusuJi •••>"* tourri m !êjjbora-p_,area. Thc'e -vJi some 'nc-cjiion :p

'0 J ".lorjge room jr.o \*r

'ENGINEERING

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Xf.area, the team found g:'oves and breathingapparatus lying abput the area . Vanoustools were founc on the floor. In f ront ofan overhead c'oor. tar.ks with air and ni-trogen were found.

The overhead door was raised. About5 feet outside, a strange device was found

. and later identified as a "destruction ram"used to destroy and neutralize small cylin-

This destruction ram was uses ;o ces:ny cyl-incers. A hose cameo cyiincer c;n:er:s :o aneutralize; cain.

ders of ch.errvrals. A hose ran iror-i theram to J 55-gonon crum in tr-» OJ.'K:-? let

'about *0 leet jwjv insîe tr-e cru~> wasa cau>i>c so!ui'0.i. or r e u t r a ^ u - i-e D J I M •»,ptckuo true*; \v, is in : r~e .ot. .is ccor ccen'ond kcvs in i.-e 'C~ vcn - •i.rnoc onEventually, a row 01 smj.i c\:..-ccrs ^jsfound on ;.~e ccunrj ;o :oe' c-.\ jv o~.v

". two 01 tr.e ogee's i~o>.\ -c o.~v H-.P—,-,-CJtion- bcrare £u! : ~ J t \ \ . i s r-o: :o •••:<:the uho'e sto'v

The t eam r r^ . - r - c - : :o :-•.• •. e n - — • - • :•post jn<! st;-"^ .i.'ej v\,-,.c- 'vccJ :,""irr:o\fU ii'J-J ti1-'. _:)•••• "'! C _ ~ ' . - " ' • • i:

gear w^s s :ac€" «; ire PJ>: > t:c ci :"? . 'r*j

and unused gear was assembled on thewest side.

During th'rs time the sheriff's departmenthad evacuated the air park area to thesouth and west, and other residents weretold to prepare for evacuation. Theweather bureau was asked to keep us ad-vised of wind and weather conditions.Ribbons were also placed to show usconstant wind direction at the scene.

The Environmental Protection Agencywas notified. Chud< Ramsay, head of thehazardous materials response team of theVirginia Office of Emergency and EnergyServices, arrived 25 minutes af ter beingnotified. State police assistance arrivedshortly after.

Another team went back inside thebuilding at 9:04 to attempt to seal any leaksin the destruction ram and crurn. Afterthis, at 11:24. officials agreed to stop furtheraction until daylignt. The area remainedevacuated and secured by poke.The next morning

Work continued at 7 a.m. . Interviewswith the company owner and otr.ers didnot reveal to us the chemical involved.Worse, we learned that several rescuesquad members who had been releasedfrom the hospital were gett ing s;clc again,complaining of seizures, depression, con-fusion, headaches and gory creams.

In the afternoon crews reenrered thebuilding to carefully obtain g;s of liquidsamples from within the ram. They weresuccessful, but one state "expert" hadasked the team to collect the samples mordinary glass Mason jars. Another labwas then asked to br ing in more appro-priate containers ror ;he obviously lethal

•material .More questions arose over who should

perform me investigation of the ;nc:cent.The person represen t ing the agencythough: responsible ceierrea. saving mata determination hod to be mace or criminalactivitv. If criminal ac t iv i tv was involved.the s t a t e police wouid be responsible.Who would rr.aVe the determinat ion 'The head ot the Virginia D.vision 01 Haz-ardous Waste Manjgerr.ent was broughtto the scene. He SJid his acency !j\w?r\vou:d hove 10 rule on iurisc:ct:on. Ct?r:j:nviolations I'ouno earner were c^cussen.When I .Jiked \srictrer irev \\ ere cr;rr.;nol.1 was juxn io!0 ir-.jt ;r.e bw\cr wo^.c nj \eto mjê J t i e t c rmmj i ion

CoiVcied s j r rn^s or the r~j;c"j! \ \e re!lown to j wt) m Ki en mend Jnc ;o :np Nj-t ionj l C u f i M u DI MontMrr . s ou:«..ce Ol\Y.!Mi:.-<!on. O C. 'LV.;i).'!^n.::fv ire':•_! i: n^ uv\" iV c > i o r : p f l :r-c sjrv.;-, ^ *Q '^

i,na.

The Scene:'• ... .. ...... .-.-v.i VÂ; i.,'..-— -- f.T*/f'Hanover Courty. Va.. has a&out _'

50.000 population in 467 sqjare miles- * *It is 15 miles roth of Richmond. ':?j?

.Tho county is served by a fire de-partment with a paid county chief, /;deputy chiel and fire marshal. .Thedepartment has 48 voia-iteer officersamong me 3',5 volunteer personnel. "They operate 11 Tire stations with 57pieces ol apparatxa. Three volunteerrescue squads are separate organize- _tions also serving '.he county. — v>..-^.

The Hanover bdustrial Air Park is inthe southern part of the county, 5 milesfrom the nearest fee company. It hasover 200 businesses of all kinds and isbordered by a small airport. Interstate95 and a 200-Jaciiity campground.

ings: diborane, hexsborane and per.t3-borane.

On Saturday morning we found "0inches of new snow dumped on :he area.At 11:20 a.m.. personnel from CECOS in-ternational. Inc.. of New York arrived.They had been csiied in to assist m the d;vposal and cleanup of tne cyiir.cers and ;r4 •»destruction ram. Ey now we had learnec*that a cyiincer that apoarent iv containedpentaborane was sti' i-.ssc'e tne ces;ruc!:onram. It was ODVIOUS i.hot a hole nac beenpunched into tr.e cvimcer. one tne remainsof per.taborane had been released into theinside of the ram.

Because of the weather 's severity, nofur ther action occurred curing the dayother than to make recovery plans fcr T-.enext day. Of course, the state policecontinued their invest igat ion.

At 7:30 a.m. Sundav. presoratiors beganfor recovery anc clearvjp operations. Thestate highway department hoc cleared ailthe roacs of the snow accumulation. Thefire deoartmen; and rescue scuad assem-bled at the comrr.ar.c: post and were g:veninstructions on what was being plannedand what their raes would be. Commu-nications were established between ail firedeoartment. rescue scuad and ooi:ce oer-sonnel Ecu:D.T.e.~t checks were moce onail breaming ocr^rjtus and en t rv suits.Spore air bottles \ \ e re orcugnt m io ensuresuttic:ent air suco'ies cunrg recove rv anac.'eanuo cseraiors Strcs 01 r. noons \\ eref Js;cneO to :e:eorione i>oie\ in ire area to

us c&ns:jr.: '.MHC u-rect:on Tr.eshe r i i f s cJoOJr r r re r : ?vacu;:cC p\e'\or.*r!O ire souin jnt t sc-:~'.\ei! '.cC'.\r".\.f"i n 01

he pon '.v

CestruCtic" r j r

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HAZARDOUS MATERI/

and then place the cylinder into a causticbath in hopes of neutralizing it.

At 6:40 p.m.. however, when the cylin-der was placed into the caustic bath a veryviolent reaction occurred, even thoughonly the tip of the cylinder (about the sizeof a penes) acuaJV touched the bath. Thecylinder was placed back into the ram andthe ram was sealed and secured tightly.Operations were suspended because ofdarkness at 6:50 p.m.

Preparations were again made onMonday to try to neutralize the cylinder.However, since it was a regular businessday for all businesses in the area, it wasdecided not to begin recovery until 3 p.m.I personnally went door to door to advisebusinesses that the south and southwesternpan of the air park would be evacuatedagain at 3 p.m. While many businessmenwere upset about the inconvenience of theevacuation. aO were very pleased to beinformed on what was actually going on.

Wind changeAt 2:15 p.m.. I noticed that a piece of

ribbon that I had put on my car's antennawas pohtng to the nonh-nonheast. whichindicated a wind direction change. Theweather bureau confirmed the change.Then, an evacuation of the north,

. northeastern and northwestern portions ofthe air park had to be made.

At 5:01 p.m. we were then advised bvCECOS personnel, after their consultationwith a company that had once producedpentaborane. that it was too risky to :ry toneutralize the cylinder inside the ram.

We were then advised to transport theentire destruction ran. with the cylinderhside, to a military facility and to destroyboth by detonation. At this time, ar-rangements were made to transport thedestruction ram to Fort A. P. Hiii in theneighboring county, some 30 miies awav.The ram was loaded into a dump trucx andsurrounded by 8 tons of sand. Fireasoa-ratus. ambulances and police units we-eprepared to escort the truck to Fon A. P.Hill.

Unfortunately, at 10:15 p.m.. I was in-formed that authorities at Fort A. P. Hillwould not allow us to bnng the ram to thatfacility. Further operations were sus-pended at 10:33 p.m.. while state officialscontinued attempts to get permission 10proceed to Fort A. P. Hill.

larnvedat :he scene agamat 9:15 a m.Tuesday. I was told that kim Ancerson.coordinator of the state Office o: Emer-gency and Energy Services, was bnenng ['Governor Chjries Robb with reierence '.oour problems m imdmg a disoosjl site

Negotiations continued ior the remjin-der 01 the djv. when nnîiv at 5 '0 o ~i iwas iniormed thjt aDoroval hoc oeengamed to tronsoon the ram to For: A ? H!iior cestoiction Still, hours went bv js we

HAZARDOUS MATERIALS

PentaboranePentaborarw is a clear, colorless.

vary poisonous flammable liquid, nwas formerly used as an experimentalrocket fuel and is rarely us«d tooay—making it subject to improper disposalanywhere. According to Or. LorenaGarrenson. medical director (or theCentra) Virginia Poison Center at MCV."This country has sufficient pentabc-rane now to sustain its present use (orme next 3000 years.

One reference book sales: "Va-pors from these fuels are highly toxicand can causa damage to the eyes,kings and respiratory tract as well assystemic effects. The systemic ef-fects are not completely understood.Central nervous system excitation ismanifested by tremors and convulsionsbut depression may be observed inother cases. There are carciovascuareffects including changes in heart rateand blood pressure: in severe poison-ing, blood pressure may be very highand later fall to shock levels. Thoughthe odor of these vapors is objection-able, odor should not be relied upon assufficient warning of Ganger. However,the converse is true: when an odor isdetected, an immeciate hazard ex-ists."

As Dr. Garrenson said. "If you canirnell it, you've had it: you're going tob« sick."

waited for documents to be signed byfederal state and local authorities, a con-dition that had to be met before we couldbegin the transportation.

At 10:30 p.m.. the documents weresigned and were delivered to Fort A. P. Hillat 11:06 p.m. At 11:30 p.m.. County Ad-ministrator Allan T. XVKams advised me viaradio to proceed to Fort A. P. Hill.

Following a predetermined route, aconvey consisting of fire apparatus, anambulance, the state's mobile hazardousmaterials response unit, the truck loadedwi;h the ram. and my vehicle, escorted byseveral state police cars, traveled to FortA. P. HiD. arrrvmg at 12:27 a.m. Wednesday.At 3M5 a.m.. the destruction ram with thecylinder inside was destroyed.

The remainder ot Wednesday and dur-ing Thursday the area ot detonation wassearched lor remaining debris. All pieceswere wasned. declared saie by the s ta tehealth department and transporteddwjy.

Back ot Environmental laborjiores. oilrerr.j:.-.;r.i; oimders lounc Ivmc on :he

ue-e pjdoeeri. icentitied andtor trjnspOMJtion to o clisoos.il

\

site in New York. At 1 1 a.m. I was acthat the '.ruck loaced with ;he rema.r.icylinders had leu Hanover County.

Investigations of this inocent. wmch ,'one dead and "8 hospitalized, have cc;tinued. Questions reEarcmg :he or:§:rithe pentaborane anc how it was traported, stored and hancied have all beconsidered. Answers will probably notfully known untii we go to court. It seethat the cylinders had been removed :analysis and disposal from a dump s:

where construction of the lames River I;cility was under way.Lessons learned

• The fire department should ha-been dispatched with the first amilance.

• The incident points out how imoctant it is for everyone involved — fire cpartments. rescue squacs. police, hosprpersonnel and other outside agencuetc. -to expand their training for har.cii;hazardous materials incidents. Anashould be a joint effort because that's howe respond to the emergency in :he i;e'Planning, practice and critiques snou.'d !done together.

• Personal safety on the scene .T.US: iconstantly stressed, and we all mav netto review very careiully our memoesapproaching hazardous materials inccervThe ambulance squads now have SC5-1.

• A more clearer ce:ermi-ianon mube mace sooner about which agercv irpersonnel are responsible for a sart.c-j..type or incident. Anv :;me spen; tr\ ir.g :determine responsibility (consulting -MLawyers) dunr.g :he actual emerge""/absurd.

• Persons no: involved in emergentservices should not be resDOnsrbie ior ecorting critical r.ems like chemical sarr.sjto a lab unless accompanied by someonfrom the eme-gency services. This is :make certain :.-.at important inforrr.atioreaches the emergency services.

• After having so much trouble get1.:-permission to destroy the ram at the tece r.facility. I recommend that plans be crawup to locate more suitable sites for dispos.of such chemicals in the future.

• Telephones should have been IS-stalled close to the command post for :.-•extended operation rather than using ::-.phones insioe the affected building.

• We still con t know very muc.i aoo.pentaborane. Physicians round it cifficuto treat the victims, one ot whom cecbecause of the r-.anv unknowns. Hut research wiih these victims wnl be cor.tirvj.-v.{or months.

9 We must share our experiences •••• ••:>others. esoec.ai'v wnere we saw we^«.nesses, so we cjn imnro\ e our e~e-g?-cservices tor tre :jiufe c C

Documents

MALTA ROCKET FUEL AREA SITE - semspub.epa.gov