1.1 - Purpose and Policy

The purpose of this safety plan is to establish personnel protection standards and mandatory safety practices and procedures for all work conducted in association with the closure activities of low, medium, and high priority SWMUs at the U.S. Army installation, CSSA, located about 10 miles south of Boerne, Texas. The plan assigns responsibilities, establishes standard operating procedures, and provides for contingencies that may arise during performance of work tasks at the project site. This plan complies with requirements of OSHA 29 CFR 1910 and 1926, and other applicable health and safety regulations.

The provisions of the plan are mandatory for all on-site Parsons ES field personnel and site visitors (i.e. CSSA and AFCEE representatives). All Parsons ES personnel will abide by this plan as indicated by their signatures on the plan acceptance form (Appendix A). All Parsons ES personnel who engage in project activities must be familiar with this plan and comply with its requirements. Accidents specifically related to this project will be reported using the form in Appendix A. In addition, the U.S. Department of Labor OSHA, "Job Safety and Health Notice" is presented in Appendix A and must be present on site.

The expertise of personnel from various disciplines will be employed to assist in safely conducting the field investigation. A drilling crew will provide drilling services. Parsons ES personnel will collect samples and provide oversight of field activities. Subcontractors will be required to submit their own health and safety plans which must conform to the requirements of this plan at a minimum.

Although the primary mission of CSSA is to receive, store and issue military supplies, the risk is low that field team members will encounter any unexploded ordnance (UXO) during the duration of the field effort. UXO is an item of ordnance and explosive waste (OEW) which has been prepared for action, and which has been fired, dropped, launched, projected, or placed in such a manner as to constitute a hazard and remains unexploded for any reason. OEW includes anything related to munitions designed to cause damage to personnel or material through explosive force. Although UXO may be encountered at any SWMU, the following SWMUs may include UXO due to historic use: Building 43, B-1, B-2, B-5, B-7, B-8, B-10, B-11, B-15, B-16, B-19, B-24, B-28, and DD.

The majority of the SWMUs planned for closure activities are listed as low and medium priority SWMUs. In particular, an Environmental Assessment at CSSA used old records and field observations to note small ammunition (ES, 1993). These notes will be verified before any invasive work takes place. However, if any UXO material is encountered at any of the SWMUs designated for work actions, work at that SWMU will stop immediately. The perimeter surrounding the area will be secured and only qualified personnel will be allowed to enter. The Site Health and Safety Officer, Field Team Leader, Project Manager and installation point of contact (POC) will be notified and the Health and Safety plan will be amended as necessary.

The Contracting Officer’s Representative (COR) and CSSA environmental officer shall be immediately notified, via telephone, of any investigation results that may indicate potential imminent health risk to contracted or federal personnel, or the public at large, followed within 3 days by written notification and supporting documentation. 

All field team members are responsible for reading and complying with this health and safety plan. No employee shall perform a project activity that he or she believes may endanger his or her health and safety or the health and safety of others.

1.2 - Site History and Description

CSSA is a subinstallation of the US Army Red River Depot (RRAD), located in Texarkana, Texas. The primary mission of CSSA is receipt, storage, and issuance of supplies, as well as quality assurance testing and maintenance of military weapons and ammunition (US Army, 1971). Figure 1.1 shows the location of CSSA. Figure 1.2 shows the location of the SWMU sites within CSSA.

Project data collection will be through review of available environmental and other relevant CSSA documents, and field data collection actions such as drilling and sampling. However, the appropriate level of data collection per each SWMU will be based on known data about each site. Preliminary evaluation of SWMUs at CSSA has categorized the SWMUs as of low, medium, or high priority based on risk to human health and the environment. The historic use and description of each SWMU is listed in Tables 1.1, 1.2, and 1.3. 

Low priority CSSA SWMUs are identified as B-1, B-5, B-6, B-7, B-8, B-12, B-14, B-19, B-22, and coal bins. Expected closure information requirements should be minimal for B-1, B-8, B-14, B-19, and the coal bins; therefore, expected work include letter reports delisting these SWMUs, with no field activities. For the remaining low priority SWMUs, minimal field investigation activities, including sampling and analysis, are expected. Table 1.1 lists the low priority SWMUs.

Medium priority SWMUs are identified as B-9, B-13, B-25, B-26, B-27, B-29, B-30, B-31, B-32, B-33, and B-34. B-25 is assumed to be included as it is listed on the CSSA Environmental Assessment, September 1993 list of SWMUs, though it was not listed in Table A-1 of the SOW. The medium priority SWMUs are expected to require conventional and reasonable field activities to gather appropriate closure data. Site activities are expected to include topographical and geographical surveys, drilling, and surface and subsurface sampling. Table 1.2 lists the medium priority SWMUs.

High priority SWMUs for CSSA include the oxidation pond and B-2, B-3, B-4, B-10, B-11, B-15/16, B-23 and 23A, B-24, B-28, the demolition dud (DD) area, building 43 and incinerator I-1. In accordance with paragraph 4.01, the cost estimate for high priority SWMUs includes a treatability study of the oxidation pond. The costs also include mapping, geophysical surveys, and soil gas surveys, at the building 43, incinerator-1, and B-10, and soil surveys at B-11, B-15/16, and B-23/23A. However, if the delivery order schedule and funds permit, then closure activities for the remaining high priority SWMUs will be conducted. Table 1.3 lists the high priority SWMUs.

1.3 - Scope of Work

For project numbers C1195 and C1295, Parsons ES’ understanding of the project requirements is based on the AMC’s Statement of Work (SOW) and our past working experience at CSSA.

The SOW specifies the primary services as closure investigations for identified SWMUs (task 1), and preparation of an integrated waste management and spill plan (task 2). Secondary services shall include actions necessary to obtain data to establish closure procedures for task 1.

SWMU closure actions are discussed in the SOW in accordance with Resource Conservation and Recovery Act (RCRA) Facility Investigations (RFIs) and Corrective Measures Studies (CMSs). The effort for task 1 is structured under an RFI approach that is defined under federal regulations; however, the goal of this task is to investigate SWMUs for certified closure under the guidance of appropriate State of Texas regulations as well as federal regulations. The State of Texas has an approved program for SWMU closures under 30 Texas Code of Administration 335, and therefore the SWMU closure task is considered to be work towards certified SWMU closures rather than a structured RFI. Project work under the SWMU closure task will assess the closure potential of each SWMU identified in the SOW and provide the necessary information to accomplish certified closures for approval by the State of Texas in a cost-effective manner.

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