Remedial Investigation Burgess Brother Superfuns d Site … · 2020. 11. 30. · SECTION 12 - SPECIAL PRECAUTION ANS D PROCEDURE 3S 3 12.01 Heat Stress/Col Injurd Preventioy 3n 3

FINAL HEALTH ANDSAFETY PLAN

Remedial InvestigationBurgess Brothers Superfund SiteWoodford and Bennington, Vermont

Burgess Brothers Superfund SiteSteering Committee

September 1992

OBRIENCGEREENGINEERS, INC.

5271.001

FINAL HEALTH AND SAFETY PLAN

(Section 5.0 of Remedial Investigation Work Plan)

REMEDIAL INVESTIGATION/FEASIBILITY STUDY

LANDFILL AREA

Burgess Brothers Superfund Site Woodford and Bennington, Vermont

BURGESS BROTHERS SUPERFUND SITE STEERING COMMITTEE

SEPTEMBER 1992

O'Brien & Gere Engineers, Inc. 5000 Brittonfield Parkway Syracuse, New York 13221

FINAL HEALTH AND SAFETY PLAN (Section 3.3 of Remedial Investigation Work Plan)

LIMITED FIELD INVESTIGATION BURGESS BROTHERS SUPERFUND SITE

WOODFORD AND BENNINGTON, VERMONT

TABLE OF CONTENTS

Page

SECTION 1 - INTRODUCTION 1

SECTION 2 - PROJECT PERSONNEL 4

SECTION 3 - HEALTH AND SAFETY HAZARDS 7

SECTION 4 - PERSONAL PROTECTIVE EQUIPMENT 9

SECTION 5 - SITE ACTIVITIES AND ASSOCIATED PERSONAL PROTECTIVE REQUIREMENTS 12

5.01 Site Survey 12 5.02 Geophysical Investigations 13 5.03 Soil Investigations 14 5.04 Soil Gas Investigation 15 5.05 Subsurface and Hydrogeological Investigations 15 5.06 Air Quality Assessment 16 5.07 Surface Water and Sediment Assessment 17 5.08 Ecological Assessment 17 5.09 Test Pit Sampling 18

SECTION 6 - AIR MONITORING 22

SECTION 7 - SITE ACCESS AND SITE CONTROL 24

SECTION 8 - MEDICAL SURVEILLANCE 25

SECTION 9 - PERSONNEL TRAINING 26

SECTION 10 - DECONTAMINATION 28

FINAL - September 1992 O'Brien & Gere Engineers (DivlO:burgess)

TABLE OF CONTENTS

(Continued)

SECTION 11 - EMERGENCY RESPONSE 29 11.01 Notification of Site Emergencies 29 11.02 Responsibilities 29 11.03 Accidents and Injuries 30 11.04 Communications 30 11.05 Safe Refuge 31 11.06 Security and Control 31 11.07 Emergency Evacuation 31 11.08 Resuming Work 31 11.09 Fire Fighting Procedures 31 11.10 Emergency Decontamination Procedure 31 11.11 Emergency Equipment 32

SECTION 12 - SPECIAL PRECAUTIONS AND PROCEDURES 33 12.01 Heat Stress/Cold Injury Prevention 33 12.02 Site Refuse 33 12.03 Additional Safety Practices 34 12.04 Daily Log Contents 35

TABLES

Table 1 - Emergency Response Telephone Numbers

FIGURES

Figure 1 - Map to Hospital

FINAL - September 1992 O'Brien & Gere Engineers (DivlO:burgess)

SECTION 1 - INTRODUCTION

This Health and Safety Plan (HASP) has been developed to provide the

requirements and general procedures to be met by O'Brien & Gere Engineers, Inc.

(O'Brien & Gere) supervisory or inspection personnel, while performing a Remedial

Investigation/ Feasibility Study (RI/FS) for the Burgess Brothers Landfill site. This

HASP describes the responsibilities, training requirements, protective equipment, and

standard operating procedures necessary for protection of on-site O'Brien & Gere

workers and official O'Brien & Gere visitors from exposure to contaminant levels which

are greater than published limits. This plan specifies procedures and equipment to be

utilized to minimize exposures of O'Brien & Gere personnel to hazardous materials as

well as measures to be employed by O'Brien & Gere personnel for decontamination of

field equipment and during emergency response. This HASP incorporates by reference

the applicable Occupational Safety and Health Administration requirements in 29 CFR

1910 and 29 CFR 1926.

The requirements and guidelines in this HASP are based on a review of available

information and an evaluation of potential on-site hazards. This HASP will be discussed

with site personnel and will be available on-site for review while work is underway. On-

site O'Brien & Gere personnel will report to the O'Brien & Gere Site Safety and Health

Officer (SSHO) in matters of health and safety. The on-site O'Brien & Gere Project

Coordinator will be responsible for the implementation of the O'Brien & Gere HASP.

Subcontractors are responsible for complying with regulations and client policies

applicable to the work that they are performing. O'Brien & Gere will inform personnel,

subcontractors, and visitors of potential site safety and health hazards. O'Brien & Gere

subcontractors working on this site must develop HASPs which are at least as stringent

as this one.

This HASP is specifically intended for those O'Brien & Gere personnel who will

be conducting activities within the defined scope of work in specified areas of the site.

Future actions that may be conducted at this site may necessitate the modification of the

requirements of this HASP. The SSHO will recommend modifications to this HASP and

FINAL - September 1992 O'Brien & Gere Engineers (DivlO:burgess) \

the Project Coordinator will have overall responsibility for approving and implementing

modifications.

1.01 Site Background and Description

The Burgess Brothers Superfund Site lies within the towns of Bennington and

Woodford, located directly due east of the City of Bennington, Vermont. (See Site Plan

in RI/FS Work Plan.) The privately operated landfill is situated on the western slope

of Harmon Hill and is part of a 60 acre plot owned by Clyde Burgess, Jr., and operated

by Burgess Brothers, Inc. The focus of the investigation is an approximately two to three

acre site located in the northeastern section of the property, adjacent to Green Mountain

National Forest. The portion of the area formerly used for unlined lagoon disposal has

been backfilled, cleared, graded and seeded. Except for several empty 55-gallon drums,

materials have been removed from the surface. An unnamed stream flows adjacent to

the southeast side of the landfill and joins Barney Brook approximately 1,500 feet from

the landfill. In addition, there are a number of drainage swales and intermittent streams

that periodically discharge into the unnamed stream and Barney Brook.

Various investigative activities have occurred at this site since 1984. Various

sampling programs were conducted at the site from 1985 to 1989 by Geraghty and Miller

(for Eveready Battery Company) and Roy F. Weston, Inc. (for USEPA). These

programs were conducted to characterize the potential impact of residues from the

former lagoon on the surrounding environment.

On March 31, 1989, the Burgess Brothers site was placed on the National

Priorities List as a Superfund site. In the most recent, March 1989, sampling phase,

volatile organic compounds (VOCs) were not detected in the upgradient well. However,

VOCs were detected in all downgradient wells west of the unnamed stream in quantities

exceeding 10,000 micrograms per liter. This confirmed results dating back to 1985. The

main constituents detected in these downgradient wells included trichloroethene,

tetrachloroethene, dichloroethene, and vinyl chloride. VOCs were not detected in the

wells on the eastern side of the unnamed stream in 1989. However, during other

sampling rounds, samples from a shallow and deep well on the eastern side of the

FINAL - September 1992 O'Brien & Gere Engineers (DivlO:burgess) 2

unnamed stream contained 80 and 22 micrograms per liter of carbon disulfide,

respectively. In 1989, neither well contained any of the VOCs detected in the other

wells, although 13,000 ^g/1 of trichloroethane was detected at this location during a 1985

sampling round.

Soil samples collected from near surface soils in the marshy area were evaluated

and reportedly contain elevated concentrations of iron, nickel, and zinc when compared

to background samples. Soil samples located in and around the lagoon area contain

elevated concentrations of lead, mercury, iron, zinc and nickel. A few semivolatile

compounds as well as VOCs were also detected in the soil samples.

The work activity governed by this HASP includes conducting a Remedial

Investigation/ Feasibility Study (RI/FS) for the site, in accordance with federal and State

guidelines. Prior to the start of the RI/FS a Limited Field Investigation was conducted

to develop a conceptual site model and refine sampling plans for the Phase I RI/FS.

Tasks of the RI/FS will be conducted to increase the level of understanding concerning

various migration pathways in the study area and potential effects on humans and the

environment surrounding the site. The following tasks will be performed:

*• Site Survey

+ Soils Investigations

> Subsurface and Hydrogeological Investigations

+ Air Quality Assessment

+ Surface Water and Sediments Assessment

* Ecological Assessment.

FINAL - September 1992 " O'Brien & Gere Engineers (DivlO:burgess) 3

SECTION 2 - PROTECT PERSONNEL

While each person involved in the RI/FS implicitly has a part in implementing

the overall health and safety plan, certain individuals have specifically designated

responsibilities. Within O'Brien & Gere, these are the Project Officer, Project

Coordinator, and the Company and Site Safety and Health Officers. The lines of

authority follow in the order presented.

Project Officer

Mr. Robert C. Ganley, P.E., will serve as Project Officer for this study. Mr.

Ganley will be responsible for the overall administration and technical execution of the

project as well as being responsible for the acquisition and delegation of resources

necessary for project completion.

Project Coordinator

Cheryl L. Cundall, P.E., Esq., will act as the Project Coordinator for this study.

Ms. Cundall will be directly responsible for the technical progress and financial control

of the project. Ms. Cundall will see that time schedules are met, will serve as the main

contact with the Steering Committee, will track and control the project budget, and will

chair the progress meetings. Ms. Cundall is responsible for implementation of the

HASP.

Company Safety and Health Officer

Dr. Swiatoslav Kaczmar, C.I.H., is the Company Safety and Health Officer for this

study. Dr. Kaczmar is responsible for development of this HASP. Procedural changes

and modifications to this HASP will be approved by Dr. Kaczmar.

Site Safety and Health Officer

Mr. Mark Randazzo is the O'Brien & Gere Site Safety and Health Officer

(SSHO) for this study. In the case of Mr. Randazzo's absence, an alternate SSHO will


be named. The SSHO for O'Brien & Gere employees administers the health and safety

operating standards for the Project Coordinator and coordinates overall O'Brien & Gere

safety and health activities for the site. The SSHO reviews project plans and revisions

to plans to determine that safety and health procedures are maintained throughout the

RI/FS. The SSHO suggests changes, if necessary, to the Project Coordinator.

Specifically the SSHO is responsible for:

1. Providing a copy of the HASP at the site prior to the start of sampling activities

and familiarizing workers with it.

2. Conducting on-site health and safety training and briefing sessions.

3. Documenting the availability, use, and maintenance of personal protective,

decontamination and other safety or health equipment.

4. Maintaining safety awareness among O'Brien & Gere employees and

communicating safety and health matters to them.

5. Reviewing field activities for performance in a manner consistent with this HASP.

6. Monitoring health and safety conditions during field activities.

7. Coordinating with emergency response personnel and medical support facilities.

8. Recommend corrective actions to the Project Coordinator, in the event of an

emergency, an accident or identification of a potentially unsafe condition.

9. Notifying the Project Coordinator of an emergency, an accident, the presence of

a potentially unsafe condition, a health or safety problem encountered or an

exception to this HASP.

10. Recommending improvements in safety and health measures to the Project

Coordinator.

11. Conducting safety and health performance and system evaluations.

The SSHO has the authority to:

1. Recommend to the project manager, suspension of field activities or other actions

to limit exposures if the health or safety of an O'Brien & Gere employee appears

to be endangered.


2. Alter work practices that the SSHO considers to be not protective of O'Brien &

Gere employees or the environment surrounding the Burgess Brothers Landfill.

3. Recommend the suspension of an O'Brien & Gere employee from field activities

for the violation of the requirements of this HASP.


SECTION 3 - HEALTH AND SAFETY HAZARDS

Materials that have been detected on the site during previous investigative studies

as components of the volatile organic compounds (VOCs) include:

+ Trichloroethene (TCE)

» Tetrachlorethene (PCE)

+ Dichlorethene (DCE) (vinylidene chloride)

*• Vinyl chloride

* Carbon disulfide

>• Metals including: Iron, Nickel, Zinc, Lead, and Mercury.

Soil gas headspace measurements made during a soil gas and soil sampling

program in the winter and spring of 1989 found TCE and PCE concentrations ranging

from 1.2 ppm to greater than 40 ppm. The Occupational Safety and Health

Administration (OSHA) Permissible Exposure Limit (PEL) is 50 ppm for TCE and

25 ppm for PCE. The OSHA PEL for vinyl chloride and DCE is 1 ppm. Vinyl chloride,

carbon disulfide and DCE were found in water samples collected from wells

downgradient of the closed lagoons. Iron, nickel, zinc, lead and mercury were detected

in the site soils at levels greater than the background levels expected of these metals in

the soil.

Although the potential for drowning exists because of the need to collect water

and sediment samples from the streams bordering the site, the potential is anticipated

to be slight given the shallow depth of the surface waters to be sampled. Other safety

hazards, such as noise, moving equipment, tripping and loose soil, have been identified

that are normally associated with on-site testing and investigations. These hazards will

be communicated to the personnel involved. Also, personnel will be referred to the

hazard control information in the O'Brien & Gere Hazardous Waste Training Manual.

Measures within this HASP have been selected to protect workers from exposure

of the respiratory system to mixtures of TCE and PCE in VOCs and to respirable dusts

as well as protection from dust and water entering the eyes and contacting the skin.

Protection to limit the risk of drowning are also specified.


Use of engineering controls, work practices and personal protective equipment

specified in this Plan is intended to minimize the risks of potential overexposure to

hazardous materials and conditions. If field measurements or observations indicate that

a potential exposure is greater than the protection afforded by the equipment or

procedures specified below, work will be stopped and O'Brien & Gere personnel will be

removed until the exposure has been reduced and/or the level of protection provided

has been increased.


SECTION 4 - PERSONAL PROTECTIVE EQUIPMENT

Personnel will be provided with personal safety equipment and protective clothing

selected for the work tasks. Each individual will be trained in the use of this safety

equipment before the start of field activities. Cleaning and maintaining equipment and

clothing in accordance with the manufacturer's specifications is the responsibility of

project personnel. The SSHO will monitor the protective equipment maintenance

procedures.

Safety equipment and protective clothing will be used as directed by this HASP.

Personal protective equipment will be worn at times designated by this HASP. Levels

of protective clothing and equipment have been assigned to specific work tasks at OSHA

Level C and Modified Level D. The level of protection will not be changed without the

SSHO's approval.

The respiratory protective equipment will be approved by NIOSH/MSHA. No

excessive facial hair that interferes with the effectiveness of a respirator will be

permitted on personnel required to wear respiratory protection equipment. The

respirator will seal against the face so that the wearer receives air only through the air

purifying cartridges attached to the respirator. Fit testing, conducted by the SSHO, will

be performed prior to respirator use to provide that a proper seal is obtained by the

wearer. Respirators will be inspected daily by the user. Respirators will be issued for

the exclusive use of one worker and will be cleaned and disinfected after each use by the

worker. Cartridges for air-purifying respirators in use will be changed weekly, at a

minimum as indicated in the O'Brien & Gere Hazardous Waste Training Manual.

Level C Protection

1. Full-face air-purifying respirator equipped with organic vapor cartridges and high-

efficiency dust filters

2. Chemical-resistent disposable coveralls, made of materials such as Poly-coated

Tyvek®; suits will be one piece with hoods


3. Outer nitrile gloves and inner latex surgical gloves (taped over the suit). Workers

must be able to write with the gloves selected

4. Leather, steel-toed boots with rubber overboots (taped under the suit)

5. Hearing protection; disposable, form-fitting plugs are preferred

6. As required

a. Disposable outer boots

b. Hard hat

c. Waders selected for the stream depth

d. Personal floatation device during in-stream sampling.

Modified Level D Protection

1. Disposable, chemical resistent coveralls with hood over work clothes

2. Outer nitrile gloves and inner latex surgical gloves (taped over the suit); workers

must be able to write with the gloves selected

3. Leather, steel-toed boots with rubber overboots (taped under the suit)

4. Hearing protection; disposable, form-fitting plugs are preferred

5. Eye protection (splash goggles or face shield)

6. As required:


b. Hard hat

c. Full-face air-purifying respirator equipped with organic vapor cartridges

and high-efficiency dust filters will be available for use, and potential users

will be trained and medically approved for such use

d. Waders selected for the stream depth

e. Personal floatation device during in-stream sampling.

Level D Protection

1. Work clothes

2. Steel-toed boots


3. As required:


b. Hard hat

c. Hearing protection; disposable, form-fitting plugs are preferred

d. Eye protection (splash goggles on face shield)

e. Waders selected for stream depth

f. Disposable, chemical resistenf coveralls with hood.

If any equipment fails and/or any employee experiences a failure or other

alteration of their protective equipment that may affect its protective ability, that

employee and site-partner ("buddy") will immediately leave the work area. Re-entry will

not be permitted until the equipment has been repaired or replaced and the cause of the

failure identified. The Project Coordinator and the SSHO will be notified and, after

reviewing the situation, determine the effect of the failure on the continuation of

ongoing operations. If the failure affects the safety of personnel, the work site or the

surrounding environment, personnel will be evacuated until appropriate corrective

actions have been taken.

FINAL - September 1992 O'Brien & Gere Engineers (DivlO:burgess) \ I

SECTION 5 - SITE ACTIVITIES AND

ASSOCIATED PERSONAL PROTECTIVE REQUIREMENTS

The levels of protection assigned to each activity below represent a best estimate

of exposure potential and protective equipment needed for that exposure.

Determination of levels was based on data available from previous studies of the site.

The SSHO may recommend revision of these levels of protection based on air

monitoring results and on-site assessment of actual exposures.

5.01 Site Survey

1. Operation and tasks to be performed: Potential areas of contaminant migration

or pathways will be identified and the appropriate area will be incorporated into

small and large scale site maps. Non-invasive geophysical surveying will be

performed to identify the locations of on-site anomalies which may represent

buried wastes.

2. Potential health hazards and contaminants: Exposed wastes may be present in

areas undergoing geophysical investigations which creates a potential for exposure

to surface wastes, including the release of gases from the off-gassing of newly

exposed soil. VOCs, including vinyl chloride, dichlorethene, trichlorethene,

tetrachlorethene, and carbon disulfide were detected in the ground water. The

potential exists for their presence in and release from the water and soil at levels

that may present an inhalation or skin contact hazard. Also, iron, nickel, zinc,

lead, and mercury were detected in soil samples.

3. Contaminant dispersion pathways: The contaminants can exist in air, soil, and

water and can be spread through the air or by skin contact.

4. Exposure control: Level D protection will be worn during the site survey.

Decontamination with soap and water will be accomplished in accordance with

the protocol in Section 10. The geologist on site will use a direct reading

instrument for monitoring hydrocarbon and vinyl chloride levels prior to


personally detecting the odor of the soil sample. Response to the monitoring

must be in accordance with the action levels in Section 6.

5.02 Geophysical Investigations

1. Operation and tasks to be performed: A seismic refraction survey will be used

to identify the depth to glacial till and bedrock around the landfill.

2. Potential health hazards and contaminants: An explosive device is used as the

source of the seismic energy measured. VOCs may be present in the air above

the areas being evaluated. The potential exists for release of these materials into

the atmosphere at levels that may present an inhalation and skin contact hazard.

3. Contaminant dispersion pathways: The explosive source may detonate at an

unexpected time or location. The volatile contaminants may be spread through

the air and absorbed through direct contact.

4. Exposure control: The built-in safety mechanisms will be in place and operating.

Access by O'Brien & Gere Engineers personnel to the area immediately

surrounding the storage facility for the explosive devices will not be permitted.

The operator of the seismic survey will be required to conform with the

applicable portions of 29 CFR 1910.109, Explosives and Blasting Agents.

Operation of the seismic device will be in accordance with the manufacturer's

guidelines. O'Brien & Gere Engineers personnel will wear hearing protection

whenever the seismic survey is being conducted. The operator will be required

to decontaminate his field sampling equipment as necessary to prevent the

potential spread of surface residuals off site. During the investigation, air in the

breathing zone of the site personnel will be continuously sampled for VOCs using

a PID. Chemical resistant coveralls and gloves are to be donned when there is

a need to handle or work with potentially contaminated soil or liquid. An air

purifying respirator with organic vapor cartridges will be donned by the SSHO

and the operator of the seismic survey equipment when the sustained VOC

concentration in the breathing zone exceeds 50 units as indicated on the PID.

FINAL - September 1992 O'Brien & Gere Engineers (DivlO-.burgess) 13

The field decontamination wastes are to be collected, drummed and disposed of

in accordance with the procedures in the Work Plan.

5.03 Soil Investigations

1. Operation and tasks to be performed: Soil borings will be installed in various

portions of the landfill. Soil samples will be collected continuously through the

landfill by split spoons and will be field screened for total VOCs by a

Photoionization Detector (HNu®) calibrated to trichloroethene (TCE) equivalent.

(See the Quality Assurance Project Plan (QAPP) for calibration procedures.) In

addition, soil samples will be collected by hand auger or suitable shovel from the

marshy area.

2. Potential health hazards and contaminants: There is the potential for release of

gases from the off-gassing of newly exposed soil. Once in operation, the

possibility exists of splash of the well contents onto personnel. The potential

exists for the presence of VOCs, including vinyl chloride, dichlorethene,

trichlorethene, tetrachlorethene, and carbon disulfide in the soil and ground

water. They may be released at levels that may present an inhalation or skin

contact hazard. In addition, iron, nickel, zinc, lead, and mercury were detected

in soil samples. Hazards generally associated with drilling operations include

noise levels exceeding the OSHA PEL of 90 dBA; exhaust gases, including carbon

monoxide, from the engine powering the drill rig; moving parts, i.e. augers, on the

drill rig that may catch clothing; free or falling parts from the cat head that may

cause head injury; moving the drill rig over uneven terrain and the potential for

the vehicle to roll over; and high pressure hydraulic lines and air lines in ill repair

or incorrectly assembled that may rupture.



4. Exposure control: Workers will wear Modified Level D protective clothing

including hearing protection, hard hats and eye protection. In addition, loose

clothing will be secured; each employee will be cautioned to check the position

FINAL - September 1992 - O'Brien & Gere Engineers (DivlO:burgess) 14

of the drill boom prior to approaching the drill rig and maintain a reasonably

practical distance from high pressure lines. The geologist on site during the

drilling operations will use an HNu® and a Draeger® detector tube for

monitoring hydrocarbon and vinyl chloride levels respectively, prior to personally

detecting the odor of the soil sample. The instrument will also be used for

breathing zone monitoring during the drilling operations. Response to the

monitoring will be in accordance with the action levels in Section 6.

5.04 Soil Gas Investigation

1. Operation and tasks to be performed: A portable gas chromatograph will be

used to identify, if present, chlorobenzene isomer "hot-spots."

2. Potential health hazards and contaminants: Traces of various chlorinated

benzene compounds and mercury may be present in soil samples collected from

the site. A limited potential may exist for direct contact with chlorobenzene

isomers and the release of vapors that may present an inhalation hazard.

Chlorobenzene isomers, if present, may also generate an offensive odor at

concentrations below the PEL.

3. Contaminant dispersion pathways: The contaminants may be spread through the

air and through skin contact with contaminated soil or free product.

4. Exposure control: Health protection during the operations will be provided by

use of chemical resistant coveralls and organic solvent resistant gloves. Workers

must be able to write while wearing the gloves selected. The soil gas monitoring

equipment will be cleaned and decontaminated. The field decontamination

wastes will be disposed of on-site.

5.05 Subsurface and Hydrogeological Investigations

1. Operation and tasks to be performed: Monitoring wells will be used as ground

water elevation monitoring points. Water from the wells will be collected by field

personnel and witnessed by others. Decontamination of the well evacuation

equipment and limited water analyses are to be performed in the field.


2. Potential health hazards and contaminants: VOCs, including vinyl chloride,

dichlorethene, trichlorethene, tetrachlorethene and carbon disulfide were

identified in the ground water at the site. The potential exists for their presence

in the soil and well water. They may be released at levels that may present an

inhalation or skin contact hazard. In addition, iron, nickel, zinc, lead, and

mercury were detected in soil samples. During sampling, the possibility exists for

splash of the sampler contents onto personnel.




including eye protection (splash goggles or face shield) and water resistent

(nitrile) gloves. When utilizing pumps to purge wells, a ground fault interrupter

will be used, and extension cords will be guarded from damage and maintained

in good condition.

5.06 Air Quality Assessment

1. Operation and tasks to be performed: Three areas will be assessed: upgradient

and upwind locations to provide background data; source locations to provide

information on atmospheric releases from source locations; and downwind

locations to provide data on off-site air transport.

2. Potential health hazards and contaminants: Concentrations of VOCs, including

vinyl chloride, dichlorethene, trichlorethene, tetrachlorethene and carbon disulfide

are expected to be below the OSHA Permissible Exposure Limits. Monitoring

of soils and water samples with a photoionization detector (HNu®) for general

hydrocarbon content will be performed as part of the sample screening. These

measurements will be used as an indication of the need to increase worker

protective measures.

3. Contaminant dispersion pathways: The contaminants can be spread through the

air.


4. Exposure control: Workers will wear Level D protection. Response to the

monitoring will be in accordance with the action levels in Section 6.

5.07 Surface Water and Sediment Assessment

1. Operation and tasks to be performed: Surface water and sediment samples will

be collected from both surface water and sediments at various locations at the

site.

2. Potential health hazards and contaminants: The potential exists for the release

of contaminants at levels that may present an inhalation or skin contact hazard.

During sampling, the possibility exists for splash of the contents onto personnel.

3. Contaminant dispersion pathways: The contaminants can be spread through the

air and through skin contact.


including eye protection (splash goggles or face shield) and water resistent (nitrile

or neoprene) gloves. Response to the monitoring will be in accordance with the

action levels in Section 6.

5.08 Ecological Assessment

1. Operation and tasks to be performed: An ecological assessment will be

performed as specified in the Work Plan to examine existing impacts to the

environment potentially caused by conditions at the site, and to identify potential

ecological effects of remedial actions. As part of the ecological assessment, a

delineation of wetland boundaries, a site reconnaissance, and a resource

characterization will be performed.

2. Potential health hazards and contaminants: Exposed wastes may be present in

areas undergoing geophysical investigations creating a potential for exposure to

surface wastes, including the release of gases from the off-gassing of newly

exposed soil. VOCs, including vinyl chloride, dichlorethene, trichlorethene,

tetrachlorethene, and carbon disulfide were detected in the ground water. The

potential exists for their presence in and release from the water and soil at levels


that may present an inhalation or skin contact hazard. Also, iron, nickel, zinc,

lead, and mercury were detected in soil samples.



4. Exposure control: Level D protection will be worn during the ecological

assessment.

5.09 Test Pit Sampling

1. Operation and tasks to be performed: Sample and composite soil samples from

one side wall of each test pit.

2. Potential health hazards and contaminants: There is the potential for release of

gases from the off-gassing of newly exposed soil. The potential also exists for the

presence of VOC's in the soil and ground water. Additionally, there is a

possibility of contacting soil containing heavy metals. Potential hazards generally

associated with heavy construction equipment used in excavation work will also

be present. These hazards include noise levels exceeding the OSHA PEL of 90

dBa, and exhaust gases, including carbon monoxide.

3. Contaminant dispersion pathways: Contaminants, if encountered, can exist in air,

soil and water and can be spread through the air or by skin contact with ground

water and/or soil containing VOCs and metals.

4. Contaminant Control:

a. Initially Modified Level D equipment will be worn.

b. Vinyl chloride was identified in ground water samples from the landfill

site. The OSHA PEL for vinyl chloride and the VOC action level for this

work will be 1.0 ppm. Background VOC concentrations will be

determined prior to the initiation of the daily work activities. If the

concentration of VOCs in the breathing zone, both inside and above the

test pit, are at or above 1 ppm (above background concentration) for a

period greater than 5 minutes, the SSHO has the following options:

(1) Work area evacuation


(2) Engineering controls, or

(3) Level B respiratory protection.

If the SSHO decides to evacuate the work area, O'Brien & Gere

employees may not re-enter the area until the concentration of VOCs in

the area is below 1.0 ppm (above the background concentration). If the

SSHO decides to initiate engineering controls, such as forced ventilation

(i.e., air blowers) the SSHO will select the number and location of the

ventilation equipment and will regularly monitor the concentration of

VOCs. If the concentration of VOCs remains 1.0 above background

concentration, the SSHO will either evacuate O'Brien & Gere personnel

from the work area or require O'Brien & Gere personnel to wear Level

B respiratory protection equipment. Monitoring for vinyl chloride using

a Draeger calorimetric tube will not be performed at these test pit

locations. The vinyl chloride Draeger tube is not compound-specific; it

reacts with other halogenated hydrocarbons. Therefore, the results could

potentially indicate false positive levels of vinyl chloride.

c. Air in the breathing zone will also be monitored at regular intervals for

VOCs using a HNu®. The concentration of VOCs in the site work areas

will be determined prior to the initiation of the daily work activities. This

value will be used as a background concentration. If the concentrations

of VOCs in the breathing zone are at or above 25 ppm above the back

ground concentration for a period greater than 5 minutes, Level C

personal protection clothing and equipment, including a half face

respirator with organic vapor cartridges and high-efficiency paniculate

filters will be donned. If the VOC concentrations are measured at or

above 50 ppm above the background concentrations, the workers will leave

that work area. O'Brien & Gere employees may re-enter the work area

wearing Modified Level D personal protective equipment when the VOC

concentration has been reduced to below 25 ppm, or Level C personal

protective equipment if the VOC concentration is between 25 ppm and 50

FINAL - September 1992 O'Brien & Gere Engineers (DivlO.burgess) 19

ppm. The respirable particulate concentration downwind of the work area

will be monitored at regular intervals using a particulate monitor. If

concentrations exceed 0.05 mg/m3 over a 15 minute period, the

concentration of respirable particulate upwind of the work area will be

measured to determine the background level. If the downwind

concentration is greater then 0.05 mg/m3 above the upwind concentration,

Level C personal protection clothing and equipment will be donned.

Efforts will then be made to reduce the concentration of airborne particu

lates by using appropriate engineering controls. If the respirable particu

late concentrations are above 0.5 mg/m3, workers will leave that work

area. The O'Brien & Gere employees may re-enter the site with Modified

Level D protective equipment if the particulate concentration is below

0.05 mg/m3 or in Level C personal protective equipment if the particulate

concentration is between 0.05 mg/m3 and 0.5 mg/m3.

d. After the Contractor has inspected the test pit, according to applicable

OSHA standards, the Project Coordinator or the SSHO will perform a

safety survey of test pits deeper than four feet for compliance with 29 CFR

Subpart P prior to the entry of O'Brien & Gere personnel. If the Project

Coordinator or SSHO identify a situation that could result in trench cave-

ins, indications of failure of protective systems or other hazardous

conditions, O'Brien & Gere employees will not be allowed into the test pit

until the conditions have been corrected.

e. O'Brien & Gere personnel entering a test pit or other confined space

during this task will meet the requirements of the June 5, 1989 Proposed

Confined Space Standard, 29 CFR Part 1910.146 or the final Confined

Space Standard, if published during this project.

f. The air in the test pit will be tested continuously, during O'Brien & Gere

employee occupancy for oxygen and explosive gas levels. If the oxygen

level is less than 19.5 percent or greater than 22 percent, or the explosive

gas meter reads above 10 percent of the Lower Explosive Limit (LEL) for


methane, entry will not be allowed and the O'Brien & Gere workers will

be removed from the test pit. O'Brien & Gere workers will not be

allowed in the test pit until the oxygen level is between 19.5 percent and

22.0 percent and the explosive gas meter reads below 10 percent of the

LEL for methane,

g. Decontamination of Equipment: See Section 10.


SECTION 6 - AIR MONITORING

Concentrations of vinyl chloride, dichlorethene, trichlorethene, tetrachlorethene,

VOCs, and carbon disulfide are expected to be below the OSHA Permissible Exposure

Limits. Monitoring of soils and water samples with a photoionization detector (HNu®)

for general hydrocarbon content will be performed as part of the sample screening.

These measurements will be used as an indication of the heed to increase worker

protective measures.

Monitoring for volatile hydrocarbons with a PID (HNu®) will be performed at 15

minute intervals during active work. The HNu® will be fitted with a 10.2 eV lamp to

provide the highest range of detection capability. Monitoring frequency can be reduced

to 30 minute intervals if results show that the level of materials being released is less

than 1 ppm. Air monitoring for health will be in accordance with the following plan.

>• If HNu® analysis of breathing zone air indicates that more than 5 ppm of volatile

organic compounds are present, respirators equipped with organic vapor

cartridges will be worn.

*• If HNu® analysis of breathing zone air indicates that more than 25 ppm of

volatile organic compounds are present, the area will be evacuated until the VOC

level is below 25 ppm.

*• Colorimetric (Draeger®) tubes for vinyl chloride will be used when the PID

indicates more than 5 units (ppm). If the Draeger® tube readings indicate more

than 3 ppm of vinyl chloride, the area will be evacuated until the vinyl chloride

level is below 3 ppm.

Records meeting the requirements of 29 CFR 1910.20 will be kept for the air

monitoring performed for health and safety protection.

Three areas will be evaluated during air quality assessment activities: upgradient

and upwind locations to provide background data; source locations to provide

information on atmospheric releases from source locations; and downwind locations to

provide data on off-site air transport. The assessment will be performed in two parts:

data gathering through the use of appropriate sampling and analytical methods; and the


assessment of the data collected during the sampling and analytical portion, including

modeling the potential emission sources and evaluating the factors that are critical in

characterizing the nature and extent of the airborne contaminants.


SECTION 7 - SITE ACCESS AND SITE CONTROL

Site control procedures will be established to reduce the possibility of worker

contact with the contaminants present, to protect the public in the area surrounding the

site by preventing the movement of contaminated materials and contaminants from the

site and to limit access to the site to these personnel required to be on it.

Work zones that will accomplish the general objective stated above will be

established by the Project Coordinator working with the SSHO. Three categories of

work zones, an exclusion/contaminated work zone, a contamination reduction/buffer

zone and a support/clean zone, will be established. A map depicting these work zones

will be posted in a conspicuous location and reviewed during the daily safety briefings.

The project manager and the SSHO will establish a system appropriate to the site, the

work and the work zones that will provide routine and emergency communications within

and off the site. (See Section 11)

Site access will be monitored by the SSHO, who will maintain a log-in sheet for

O'Brien & Gere personnel and guests, that will include, at the minimum, personnel on

the site, their arrival and departure times and their destination on the site.

O'Brien & Gere personnel exiting the exclusion zone will be decontaminated

prior to entering the support zone. The Project Coordinator and the SSHO will establish

a decontamination system and decontamination procedures appropriate to the site and

the work that will prevent potentially hazardous materials from leaving the site (See

Section 10). The decontamination procedures will be reviewed at the daily safety

briefings conducted prior to work beginning each day.

Personal hygiene (toilet and hand-washing) facilities and potable water will be

provided in the support zone.


SECTION 8 - MEDICAL SURVEILLANCE

The hazards identified in Section 3 will not require medical monitoring beyond

that provided by the O'Brien & Gere Health and Safety Program.

OSHA has established requirements for medical surveillance programs designed

to monitor and reduce health risks to employees potentially exposed to hazardous

materials (29 CFR 1910.120). This program has been designed to provide baseline

medical data for each employee involved in hazardous waste operations and to

determine the ability to wear personal protective equipment, such as chemical resistant

clothing and respirators.

O'Brien & Gere employees who wear or may wear respiratory protection are

provided respirators as regulated by 29 CFR 1910.134 and an individual's ability to wear

respiratory protection will be medically certified before duties requiring the wear of

respirators are performed. Where medical requirements of 29 CFR 1910.120 overlap

those of 29 CFR 1910.134, the most stringent of the two have been enforced.

Medical examinations are administered on a pre-employment and annual basis

and as warranted by symptoms of exposure or by specialized activities. The examining

physician makes a report to O'Brien & Gere of medical condition(s) which could place

O'Brien & Gere employees that are performing the RI/FS at increased risk of wearing

a respirator or other personal protective equipment. O'Brien & Gere maintains the

medical records of O'Brien & Gere site personnel, as regulated by 29 CFR 1910.120,

where applicable.

FINAL - September 1992 O'Brien & Gere Engineers (DivlO:bur%ess) 25

SECTION 9 - PERSONNEL TRAINING

Employees involved with on site RI/FS activities will meet one of the following

requirements prior to the start of work:

1. A training course of at least 40 hours that meets the requirements specified in 29

CFR 1910.120(e) on safety and health at hazardous waste operations within the

last 12 months.

2. A refresher course of at least 8 hours meeting the requirements of 29 CFR

1910.120(e) on safety and health at hazardous waste operations within the last 12

months.

On-site management and supervisors have completed a course of at least 8 hours

meeting the requirements of 29 CFR 1910.120(e) on supervisor responsibilities for safety

and health at hazardous waste operations within the last 12 months. Employees who will

respond to emergency situations involving hazardous materials have been trained in how

to respond to such emergencies in accordance with the provisions of 29 CFR

1910.120(q). A copy of the written certification of training completion will be

maintained on site for each employee, supervisor and emergency responder requiring

such training.

Site specific training will be provided to each employee and will be reviewed at

daily safety briefings. Personnel will be briefed by the Project Coordinator or the SSHO

as to the potential hazards to be encountered. Topics will include:

>• Availability of this HASP.

+ General site hazards and specific hazards in the work areas including those

attributable to the chemicals present.

> Selection, use, testing and care of the body, eye, hand and foot protection being

worn, with the limitations of each.

*• Decontamination procedures for personnel, their personal protective equipment

and other equipment used on the site.

+ Emergency response procedures and requirements.


Emergency alarm systems and other forms of notification, and evacuation routes

to be followed.

Methods to obtain emergency assistance and medical attention.

FINAL - September 1992 O'Brien & Gere Engineers (DivlO:bur%ess) 27

SECTION 10 - DECONTAMINATION

Splash protection garments will be washed with soap and clean potable water and

air dried prior to storage. Dirt, oil grease or other foreign materials that are visible will

be removed from surfaces. Scrubbing with a brush may be required to remove materials

that adhere to the surfaces. Decontamination waste waters will be disposed of with the

waste waters from the sampling equipment decontamination. Employees should refer

to the O'Brien & Gere Hazardous Waste Training manual for detailed personnel and

equipment decontamination procedures.

Sampling equipment will be segregated and, after decontamination, stored

separately from splash protection equipment. The equipment will be washed with soap

and clean potable water and air dried prior to storage. Decontaminated or clean

sampling equipment, not in use, will be covered with plastic and stored in a designated

storage area in the support zone. Waste and drum handling procedures are identified

in the RI Work Plan Site Management Plan.


SECTION 11 - EMERGENCY RESPONSE

11.01 Notification of Site Emergencies

In the event of an emergency, O'Brien & Gere personnel will signal distress with

three blasts from a horn (vehicle horn, air horn, etc.), provided by and maintained on-

site by the SSHO. The Project Coordinator and the SSHO will then be immediately

notified of the nature and extent of the emergency.

Table 1 contains Emergency Response Telephone Numbers. This table will be

maintained at the work site by the SSHO. The location of the nearest telephone is

described in Section 11.04.

11.02 Responsibilities

The SSHO will be responsible for responding to emergencies, and will:

1. Notify individuals, authorities and/or health care facilities of the potentially

hazardous activities and potential wastes that may develop as a result of the

investigation;

2. Confirm that the following safety equipment is available: eyewash station, first aid

supplies, emergency horn and fire extinguishers;

3. Have a working knowledge of the operation of the safety equipment available;

and

4. Confirm that a map and directions detailing the most direct route to the hospital

is prominently posted with the emergency telephone numbers.

The SSHO will be responsible for directing notification, response and follow-up

actions and for contacting outside response personnel (ambulance, fire department or

others). In the case of an evacuation, the SSHO will account for O'Brien & Gere

personnel. A log of O'Brien & Gere individuals entering and leaving the site will be

kept so that each can be accounted for in an emergency.

Upon notification of an exposure incident, the SSHO will contact the appropriate

emergency response personnel for recommended medical diagnosis and, if necessary,

treatment. The SSHO will evaluate whether and at what levels exposure actually


occurred, the cause of such exposure, and the means to prevent similar incidents from

occurring.

11.03 Accidents and Injuries

Personnel trained in first aid will be present during site activities to treat injuries

or illnesses to O'Brien & Gere personnel occurring during operations. In the event of

an accident or injury, measures will be taken to assist those who have been injured or

exposed and to protect others from hazards. First aid will be administered by O'Brien

& Gere personnel trained and competent in first aid procedures. Other on-site medical

and/or first aid response to an injury or illness will be provided by trained personnel

competent in such matters. If an individual is transported to a hospital or doctor, a copy

of this HASP will accompany the individual.

The SSHO will be notified and will respond according to the seriousness of the

incident. The SSHO will perform an investigation of the incident and prepare a signed

and dated report documenting the investigation. An exposure-incident reporting form

will also be completed by the SSHO, the Project Coordinator and the exposed individual.

The form will be filed with the employee's medical and safety records to serve as

documentation of the incident and the actions taken.

11.04 Communications

Two-way radios will be provided for use during field activities to facilitate

communications. If possible, mobile telephones will be present during site activities for

emergency response and office communications. Hand signals will be utilized where

radios are impractical or unsafe. The telephone located in the Burgess Brothers, Inc.

office will serve as back up to the mobile telephone system and will serve as the primary

off-site communication network.


11.05 Safe Refuge

Vehicles or project trailers will serve as the immediate place of refuge in the

event of an emergency. If evacuation from the area is necessary, the vehicles will be

used to transport on-site O'Brien & Gere personnel to safety.

11.06 Security and Control

Site security and control during emergencies, accidents and incidents shall be

monitored by the Project Coordinator and the SSHO. Site security and control duties

consist of limiting O'Brien & Gere access to the site to authorized personnel and to

overseeing reaction activities.

11.07 Emergency Evacuation

In case of an emergency, O'Brien & Gere personnel will evacuate to safe refuge,

such as the Burgess Brothers parking lot, both for their personal safety and to prevent

the hampering of response/rescue efforts.

11.08 Resuming Work

Before on-site work is resumed following an emergency, necessary emergency

equipment will be recharged, refilled or replaced. Government agencies will be notified

as appropriate.

11.09 Fire Fighting Procedures

A fire extinguisher will be available in the Project Coordinator's (or a designee's)

vehicle during on-site activities. The extinguisher is intended for small fires. When a

fire cannot be controlled with the extinguisher, the area will be evacuated and the fire

department will be called immediately.

11.10 Emergency Decontamination Procedure

The extent of emergency decontamination depends on the severity of the injury

or illness and the nature of the contamination. Whenever possible, decontamination will


consist of (at a minimum) washing, rinsing and/or removal of contaminated outer

clothing and equipment. If time does not permit decontamination, the person will be

given first aid treatment, and then wrapped in plastic or a blanket prior to transport to

medical care. If heat stress is a factor in the victim's illness/injury, the outer protective

garment will be removed from the victim immediately. The SSHO will call for an

ambulance to transport the victim to the hospital.

11.11 Emergency Equipment

On-site equipment for safety and emergency response will be maintained in the

field vehicle of the on-site Project Coordinator and/or the SSHO, as follows:

*• fire extinguisher,

+ first aid kit,

*• eye wash station (wash bottles at a minimum),

>• water source (shower or garden hose),

»> extra copy of this Health and Safety Plan, and

*• mobile telephone.


SECTION 12 - SPECIAL PRECAUTIONS AND PROCEDURES

The activities associated with this research project may involve potential risks of

exposure to both chemical and physical hazards. The potential for chemical exposure

to hazardous substances will be significantly reduced through the use of air monitoring,

personal protective clothing, engineering controls, and implementation of safe work

practices.

Other potential hazards that are associated with the RI/FS activities may include

working around heavy equipment and heat and cold injuries. Precautionary measures

have been established to reduce these risks to a minimum during work activities.

12.01 Heat Stress/Cold Injury Prevention

Training in prevention of heat and/or cold injuries will be provided as part of the

site specific training. The anticipated timing of this project may be such that heat

stress/cold stress may pose a threat to the health and safety of personnel. Work/rest

regimens will be employed as necessary so that personnel do not suffer adverse effects

from heat stress/cold stress. Special clothing and appropriate diet and fluid intake

regimes will be recommended to personnel to further reduce these temperature-related

hazards. The work/rest regimens for heat stress will be developed following the

guidelines in the ACGIH, Threshold Limit Values and Biological Exposure Indices for

1991-1992. Procedures for identifying potential heat casualties are found in the O'Brien

& Gere Hazardous Waste Training Manual. The availability of a warm dry rest area

will be required because of the possibility of exposure to cold.

12.02 Site Refuse

Site refuse will be contained in appropriate areas or facilities. Personnel will

make certain that fencing, cement, drill cuttings, etc. are not scattered throughout the

area of activity and that trash and scrap materials are immediately and properly

disposed.

FINAL - September 1992 O'Brien & Cere Engineers (DivlO:burgess) 33

12.03 Additional Safety Practices

The following are important safety precautions which will be enforced during this

investigation:

1. The activities in the exclusion zone will be conducted using the "Buddy System".

The Buddy is another worker fully dressed in the appropriate personal protective

equipment, who can perform the following activities:

a. Provide partner with assistance;

b. Observe partner for signs of chemical or heat exposure;

c. Periodically check the integrity of partner's personal protective equipment;

and

d. Notify others if emergency help is needed.

2. Medicine and alcohol can potentiate the effect from exposure to certain

compounds. Controlled substances and alcoholic beverages will not be consumed

during investigation activities. Consumption of prescribed drugs will be at the

direction of a physician familiar with the person's work.

3. Eating, drinking, chewing gum or tobacco, smoking, or other practices that

increase the probability of hand-to-mouth transfer and ingestion of material is

prohibited except in areas designated by the SSHO.

4. Contact with potentially contaminated surfaces will be avoided whenever possible.

Workers will not walk through puddles, mud, or other discolored surfaces; kneel

on ground; or lean, sit or place equipment on drums, containers, vehicles, or the

ground.

5. Personnel and equipment in the work areas will be minimized, consistent with

effective site operations.

6. Unsafe equipment left unattended will be identified by a "DANGER, DO NOT

OPERATE" tag.

7. Work areas for various operational activities will be established.

8. Unidentified drums will be reported to the Project Coordinator. O'Brien & Gere

Engineers personnel will not handle, move or otherwise disturb drums of

unidentified material or condition.


12.04 Daily Log Contents

' The Project Coordinator and the SSHO will establish a system appropriate to the

site, the work and the work zones that will record, at a minimum, the following

information:

1. O'Brien & Gere personnel on the site, their arrival and departure times and their

destination on the site.

2. Incidents and unusual activities involving O'Brien & Gere personnel that occur

on the site such as, but not limited to, accidents, spills, breaches of security,

injuries, equipment failures and weather related problems.

3. Conversations that may affect the work such as: media visits; Safety and health

inspections by the SSHO and/or external agencies; owner/agency meetings; and

employee/union meetings.

4. Changes to the Work Plan and the HASP.

5. Daily information generated such as: changes to work and health and safety

plans; work accomplished and the current site status; and air monitoring results.


Tables

OBRIEN&GERE ENGINEERS, INC.

TABLE 1

EMERGENCY RESPONSE TELEPHONE NUMBERS

Police (802) 422-5464

Fire (802) 442-5555

Ambulance (802) 442-5465

Regulatory - DEC (802) 244-8702

Project Coordinator ((Cheryl Cundall) (315) 437-6100 (W)

Project Officer (Robert Ganley) (315) 437-6100 (W)

Health Department (800) 642-3323

Hospital (802) 442-6361

Southwestern VT Medical Center Dewey Avenue

Directions to Hospital

Burgess Road West, pick up Route 9. Turn left onto Dewey Avenue. Four blocks South on Dewey Avenue. Hospital is on the Right.

FINAL - September 1992 O'Brien & Gere Engineers (DivlO burgess) \

Figures

O BRIEN G GERE ENGINEERS, INC.

FIGURE 1

SITE LOCATION SOUTHWESTERN VERMONT MEDICAL CENTER

DIRECTIONS TO SOUTHWESTERN VERMONT

MEDICAL CENTER NOT TO SCALE

5271.001-39P

ENGINEERS INC.

Documents

Remedial Investigation Burgess Brother Superfuns d Site … · 2020. 11. 30. · SECTION 12 - SPECIAL PRECAUTION ANS D PROCEDURE 3S 3 12.01 Heat Stress/Col Injurd Preventioy 3n 3