Hazardous substances that may be encountered are presented in Table 2.1. In addition to the hazardous chemical substances possibly present at the site, some physical hazards or hazardous conditions may be expected at the site. These include risk of injury while working (slips, trips, and falls), heat and cold exposure, UXO, and biological organisms such as snakes, chiggers and Africanized bees. 

During drilling actions via air coring, a substantial amount of particulate matter will be generated and airborne. A particulate MINIRAM™ monitor and an organic vapor monitor will be used to differentiate between level C and level D protection. If the particulate level exceeds 10 mg/m3 (the threshold limit value [TLV] for limestone dust) or 25 ppm (the TLV for total volatile organic contaminants), respirator protection will be donned. If the particulate level exceeds 250 ppm (the TLV for total volatile organic contaminants), all personnel will stop work and leave the site until conditions subside.

Employees must implement safe work practices while working on-site. Protec­tive clothing will reduce many of the on-site risks. Proper use of protective clothing is described in Section 3.4.

2.1 - Chemical Hazards

Detailed information on the nature of the chemical hazards can be found on the material safety data sheets (MSDSs) and other chemical data in Appendix B. These MSDSs will be available on site and at the Parsons ES office.

Within CSSA, investigative personnel may be exposed to numerous groups of chemical toxicants by both the respiratory and percutaneous (skin absorp­tion) routes. The risk of exposure and the severity of the resultant physiologic reac­tion to any of the contaminants is determined chiefly by their inherent toxicity, concentration, physical characteristics, duration of exposure, and individual suscep­tibility or hypersensitivity. The field team may be exposed to contaminants in soils and groundwater through inhalation, ingestion, and skin and eye contact, as detailed below:

	Skin contact with contaminated solid or liquid samples can occur when a worker does not wear proper protective clothing around sampling activities.
	Eye contact with contaminated liquid or solid samples can occur when a worker does not wear protective eye wear at locations where samples are being taken or handled.
	Respiratory system contact with hazardous airborne materials can occur from lack of or improper use of respiratory equipment.
	Gastrointestinal system contact with samples can occur when workers do not pay attention to personal hygiene rules designed to reduce the chance of ingesting site contaminants (e.g., hand washing before smoking, eating, or drinking).

2.1.1   Volatile Organic Compounds

Volatile organic compounds (VOCs) are not suspected at the low or medium priority SWMUs at CSSA. However, since some VOCs can acutely affect the central nervous system, organic vapor monitoring will be conducted at the site. Depending on the degree of exposure and the solvent involved, the effects may range from mild narcosis to death from respiratory failure.

Vapors from VOCs could be encountered during any surface or subsurface soil, or groundwater sampling activity. Organic vapors can build up under confined conditions, such as in a well casing, in any unventilated environment, or even several inches or feet below ground level where there is a solvent source. Organic vapor monitoring will be conducted at least twice daily, during the site field activities that involve sampling and during the construction of each new well. Section 3 of this document outlines monitoring procedures.

2.2 - Physical Hazards

While working on site, employees must implement safe work practices in accordance with OSHA regulations. Workers should minimize risks of trips, slips, and falls.

2.2.1   Heat Stress

Adverse weather conditions are important considerations in planning and conducting site operations. Hot or cold weather can cause physical discomfort, loss of efficiency, and personal injury. Of particular importance is heat stress resulting when protective clothing decreases natural body ventilation. Heat stress can occur even when temperatures are moderate if employees are wearing impermeable protective clothing. One or more of the following recommendations will help reduce heat stress:

	Provide plenty of liquids to replace body fluids. Water and/or commercial electrolyte mixes should be available on site.
	In extremely hot weather, conduct non-emergency response operations in the early morning or evening.
	Ensure that adequate shelter is available to protect personnel against heat, sun, or other adverse weather conditions which decrease physical efficiency and increase the probability of accidents.
	Maintain good hygienic standards, frequently changing clothing and daily showering. Clothing should be permitted to dry during rest periods. Work­ers who notice skin problems and/or heat rash should immediately inform the Site Health and Safety Officer who will in turn consult medical personnel.

Effects of Heat Stress

If the body's physiological processes fail to maintain a normal body temperature because of excessive heat, a number of physical reactions can occur. They can range from mild symptoms such as fatigue, irritability, anxiety, and decreased concentra­tion, dexterity, or movement, to death. The location of a first-aid manual detailing specific first-aid treatment for mild cases of heat stress should be known at all times by the Site Health and Safety Officer to ensure that it is readily available for reference in the field. Medical help must be obtained for the more serious cases of heat stress.

Heat-Related Problems

	Heat rash: Caused by continuous exposure to heat and humid air and aggra­vated by chafing clothes. Decreases ability to tolerate heat and is a nuisance.
	Heat cramps: Caused by profuse perspiration with inadequate fluid intake and chemical replacement, especially salts. Signs include muscle spasms and pain in the extremities and abdomen. Figure 2.1 describes the actions that should be taken to relieve heat cramps.
	Heat exhaustion: Caused by increased stress on various organs to meet increased demands to cool the body. Signs include shortness of breath; increased pulse rate (120-200 beats per min.); pale, cool, moist skin; profuse sweating; and dizziness and lassitude. Figure 2.1 describes the actions that should be taken to relieve heat exhaustion.
	Heat stroke: The most severe form of heat stress. Body must be cooled immediately to prevent severe injury and/or death. Signs include red, hot, dry skin; no perspiration; nausea; dizziness and confusion; strong, rapid pulse; and possibly coma. Medical help must be obtained immediately. Figure 2.2 describes the actions that should be taken in route to the hospital or while waiting for an ambulance.

Heat-Stress Monitoring

Monitoring of personnel wearing impervious clothing may begin when the ambi­ent temperature is 70°F or above. Monitoring of heat stress for other working conditions will occur at the worker's request, at the discretion of the Site Health and Safety Officer, or as conditions change. Table 2.2 presents the suggested frequency for such monitoring.

Monitoring frequency will increase as the ambient temperature increases or as slow recovery rates are observed. Heat-stress monitoring will be performed by a person with a current first-aid certification who is trained to recognize heat-stress symptoms. For monitoring the body's recuperative abilities from excess heat, one or more of the techniques listed below will be used. Other methods for determining heat-stress monitoring, such as the wet bulb globe from the American Conference of Governmental Industrial Hygienists TLV Booklet, may be used.

To monitor the worker, measure:

	Heart rate: Count the radial pulse during a 30-second period as early as possible during the rest period.
	If the heart rate exceeds 110 beats per minute at the beginning of the rest period, the next work cycle will be shortened by one-third and the rest period will remain the same.
	If the heart rate still exceeds 110 beats per minute at the next rest period, the following work cycle will be reduced by one-third.
	Oral Temperature: Use a clinical thermometer (3 minutes under the tongue) or similar device to measure the oral temperature at the end of the work period (before drinking).
	If oral temperature exceeds 99.6°F (37.6°C), the next work cycle will be reduced by one-third without changing the rest period.
	If oral temperature still exceeds 99.6°F (37.6°C) at the beginning of the next rest period, the following cycle will be reduced by one-third.
	No worker will be permitted to wear a semipermeable or impermeable garment when oral temperature exceeds 100.6°F (38.1°C).

2.2.2   Cold Exposure

Persons working in temperatures at or below freezing may suffer from cold exposure. During prolonged outdoor periods with inadequate clothing, effects of cold exposure may even occur at temperatures well above freezing. Cold expo­sure may cause severe injury by freezing exposed body surfaces (frostbite) or result in profound generalized cooling (hypothermia), possibly causing death. Areas of the body that have high surface-area-to-volume ratios, such as fingers, toes, and ears, are the most susceptible to frostbite.

Local injury resulting from cold is included in the generic term frostbite. There are several degrees of damage. Frostbite of the extremities can be categorized into:

	Frost nip or incipient frostbite: characterized by suddenly blanching or whitening of skin.
	Superficial frostbite: skin has a waxy or white appearance and is firm to the touch, but tissue beneath is resilient.
	Deep frostbite: tissues are cold, pale, and solid; extremely serious injury.

Systematic hypothermia is caused by exposure to freezing or rapidly dropping temperature. Its symptoms are usually exhibited in five stages: (1) shivering and incoordination; (2) apathy, listlessness, sleepiness, and (sometimes) rapid cooling of the body to less than 95°F; (3) unconsciousness, glassy stare, slow pulse, and slow respiratory rate; (4) freezing of the extremities; and (5) death.

If work is conducted at ambient temperatures below 39°F (4°C), workers shall wear cold protective clothing appropriate for the level of cold and physical activity. If the available clothing does not give adequate protection to prevent hypothermia or frostbite, work shall be modified or suspended until adequate clothing is made available or until weather conditions improve.

If work is to be performed at temperatures below 20°F, heated shelters shall be made available, and employees will break to seek warmth at regular intervals, the frequency depending on the severity of exposure. The onset of shivering will require immediate return to the warm shelter for a period of time necessary for the employee to warm up. Figure 2.3 describes the actions that shall be taken when an employee is suffering from cold exposure.

Evaluation and Control

For exposed skin, continuous exposure shall not be permitted when the air speed and temperature result in an equivalent chill temperature of -32°C (-25.6°F). Superficial or deep local tissue freezing will occur only at temperatures below -1°C (30.2°F) regardless of wind speed.

Guidelines recommended for properly clothed workers for periods of work at temperatures below freezing are shown in Table 2.3.

Special protection of the hands is required to maintain manual dexterity for the prevention of accidents:

	If fine work is to be performed with bare hands for more than 10 to 20 minutes in an environment below 16°C (60.8°F), special provisions shall be established for keeping the workers' hands warm. Metal handles of tools and control bars shall be covered by thermal insulating material at temper­atures below -1°C (30.2°F).
	If the air temperature falls below 16°C (60.8°F) for sedentary, 4°C (39.2°F) for light, or -7°C (19.4°F) for moderate work, and fine manual dexterity is not required, then gloves shall be worn.

To prevent contact frostbite, the workers shall wear anti-contact gloves.

	When cold surfaces below -7°C (19.4°F) are within reach, a warning shall be given to each worker by the supervisor to prevent contact by bare skin.
	If the air temperature is -17.5°C (0°F) or less, the hands shall be protected by mittens. Machine controls and tools for use in cold conditions shall be designed so that they can be handled without removing the mittens.

Provisions for additional total body protection are required if work is performed in an environment at or below 4°C (39.2°F). The workers shall wear cold protective clothing appropriate for the level of cold and physical activity:

	If the air velocity at the job site is increased by wind, draft, or artificial ventilating equipment, the cooling effect of the wind shall be reduced by shielding the work area or by wearing an easily removable windbreak garment. If only light work is involved and if the clothing on the worker may become wet on the job site, the outer layer of the clothing in use may be of a type impermeable to water. With more severe work under such conditions, the outer layer shall be water repellent, and the outerwear shall be changed as it becomes wetted. The outer garments shall include provisions for easy ventilation in order to prevent wetting of inner layers by sweat. If work is done at normal temperatures or in a hot environment, before entering the cold area, the employee shall make sure that clothing is not wet as a consequence of sweating. If clothing is wet, the employee shall change into dry clothes before entering the cold area. The workers shall change socks and any removable felt insoles at regular daily intervals or use vapor barrier boots. The optimal frequency of change shall be determined empirically and will vary individually and according to the type of shoe worn and how much the individual's feet sweat.
	If exposed areas of the body cannot be protected sufficiently to prevent sensation of excessive cold or frostbite, protective items shall be supplied in auxiliary heated versions.
	If the available clothing does not give adequate protection to prevent hypothermia or frostbite, work shall be modified or suspended until adequate clothing is made available or until weather conditions improve.
	Workers handling evaporative liquid (i.e., decontamination solvents) at air temperatures below 4°C (39.2°F) shall take special precautions to avoid soaking of clothes or gloves with the liquids because of the added danger of cold injury due to evaporative cooling.

2.2.3   Snake and Africanized Bee Hazards

Snakes and Africanized bees may be encountered at the site. Workers should use caution and avoid walking in overgrown areas. Field team members who are allergic to bee or wasp stings shall notify the Site Health and Safety Officer prior to initial field work. 

If a worker is bitten, the following steps should be taken:

	Keep the victim calm.
	Minimize movement.
	Apply ice to the area bitten being careful not to freeze the tissue.
	Transport victim from the site. The victim should then be transported to the nearest medical facility.

2.2.4   Poison Ivy

Skin contact with poison ivy can cause swelling, breathing difficulty, blisters, fever, and severe itching. Poison ivy commonly grows along creek banks and is poisonous year-round. To prevent contact with poison ivy, personnel should wear long sleeves, long pants and gloves. If contact is suspected, the affected area shall immediately be washed with soap and water and clothes shall be changed. Poison ivy oils may remain on clothing or equipment until they are washed. Figure 2.4 describes poison ivy and steps that shall be taken if a person has had skin contact with poison ivy. The initial health and safety briefing will discuss possible poisonous plants at CSSA.

2.2.5   Noise

High noise levels are anticipated to be found in the vicinity of operating drilling equipment and other heavy machinery. Field personnel shall use the approved and appropriate hearing protection when working in these areas. Unprotected long-term exposure to noise above 85 decibels (dB) can result in hearing loss.

2.2.6   Chiggers and Ticks Hazards

Chiggers may be encountered at the site. Chigger bites cause intense itching and the affected skin tissue becomes red and swollen. Protection with repellents is the best means of reducing chigger bites. If exposed to chigger-infested areas, immediately take a hot soapy bath to kill and remove chigger larvae, then apply an antiseptic to welts to prevent infection.

There are three species of ticks common to Texas and may be encountered at the site. In addition to dermatosis caused by tick bites, ticks can transmit diseases by infecting hosts. Possible diseases carried by ticks are Rocky Mountain spotted fever, tularemia, and Lyme diseases. 

Level D personal protective equipment (PPE) is expected to provide sufficient protection from chiggers and ticks. If chiggers and tick bites are encountered requiring more attention than first aid, the field team member will seek medical treatment.

2.3 - Hazard Evaluation

To ensure a strong safety awareness program during site prescreening, geophysical surveying, drilling, and sampling, personnel must have adequate training; this health and safety plan must be communicated to the employees; and standing work orders must be developed and communicated to the employees. Sample standing orders for personnel working at the site are as follows:

	Do not touch, kick or pick up any unidentified objects on the ground.
	If a UXO is encountered STOP WORK in this area, evacuate the site, inform the Site Health and Safety Officer, Project Manager and the CSSA Environmental Officer or his designee of the findings. Stake around the perimeter of the SWMU. No unauthorized personnel will be allowed in the area. At this time the Health and Safety Plan will be amended as necessary.
	Avoid leaning, sitting, or kneeling on contaminated surfaces.
	No touching, kicking or disturbing any metal debris or any other containers.
	No smoking, eating, or drinking at the site.
	No matches or lighters at the site.
	No personal vehicles at the site.
	Use buddy system at all times.
	Wear appropriate personal protective equipment.
	Avoid walking through puddles or stained soil.
	Discovery of unusual or unexpected conditions will result in immediate eval­uation and reassessment of site conditions and health and safety practices.
	Conduct safety briefings daily prior to on-site work. All health and safety briefings must be documented in the field logbook and checked daily by the Site Health and Safety Officer.
	Take precautions to prevent injury from heavy equipment and other tools.
	Only qualified operators will be allowed to operate heavy equipment.

If climbing activities are required, conditions of the footing and the need for spotting will be determined prior to initiating the climb. Prior to any field activities, the Parsons ES project health and safety officer will hold an initial health and safety brief­ing. Each employees and subcontractor scheduled to be on-site during the survey must attend an initial health and safety briefing. Topics to be discussed at this briefing will include specific procedures and protocol for working at SWMUs; a description of the site chemical hazards and toxicologi­cal properties of chemicals; a description of physical hazards, such as heat stress, cold-related illness, Africanized bees, etc., and how to avoid them; personal protective equipment; and emergency procedures. In addition, a brief health and safety meeting will be held each day prior to starting field activities. Both these briefings and the initial health and safety meeting will be documented in the field logbook.

Site visitors and noncontractor oversight personnel will attend the brief health and safety meeting prior to site visit. These personnel may not enter the exclusion zone unless they have proof that they have completed training that satisfies the requirements of 29 CFR 1910. 

2.3.1   Geophysical Survey

Prior to collecting surface geophysical data, a grid system will be established at each site which will encompass the areas of suspected ground disturbance. Staking out of the site and the geophysical survey will be performed in Level D. Heat stress, trips, slips, falls, snakes, and bees will be the physical dangers of concern. Many of these topics are discussed Section 2.2. The geophysical survey does not involve disturbing the soil and, therefore, chemical exposure will be limited.

2.3.2   Drilling/Well Installation

Field team leaders are experienced in drilling safety and good engineering practices detailed in the Parsons ES Drilling Safety Guide. This guide has been prepared using information gathered from delegations of the Drilling Care Drill Manufacturers Association and the National Drilling Contracts Association. Safe drilling operations specified in this guide are: housekeeping on and around the drilling rig, maintenance safety, safe use of hand tools, start-up, safety during drilling operations, safe use of augers, etc. Basic practices to be used for the drilling effort expected at CSSA are in the following discussion. 

Efforts will be made prior to mobilization of the drilling equipment to determine if underground installations (i.e., sewers, telephone, water, fuel, elec­trical lines, or liners) are present in the vicinity and, if so, exactly where such underground installations are located. Drilling locations may be adjusted in the field to avoid underground obstructions. Based on Parsons ES previous experience and information from CSSA personnel, none of the sites to be investigated are expected to have underground installations in the vicinity. 

The drilling rig is heavy equipment, and all field personnel must also be careful in the drilling area. The rig is used to hoist and turn augers, drill rods, hammers, and other heavy tools or equipment. Parsons ES personnel should be visible to the drilling rig operators when working near the rig. A hard hat, safety glasses, ear protection, and steel-toed boots must be worn by all personnel within 50 feet of the drilling rig.

All equipment on the rig will be inspected periodically by the drillers as required by applicable guidance regulations for conditions of ropes, cables, hooks, U-bolts or other hoisting harnesses which, if defective, it may drop heavy objects on individuals working in the vicinity of the rig.

Low and medium priority SWMU drilling will be performed in Level D PPE since volatile organic compounds (VOCs) and semivolatile organic compounds (SVOCs) are not expected to be present in the breathing zone. However, air monitoring for VOC and levels of limestone dust (air-borne particulates) will be performed during drilling. Non-drilling personnel will be instructed to stay upwind of the limestone dust plume anticipated to result from drilling. PPE is further described in section 3.4. Drilling in the oxidation pond will be started in Level C PPE because of suspected VOC contamination. Air monitoring will be performed with a photoionization detector (PID) or an flame ionization detector (FID). In the event air monitoring indicates Level C is not necessary, the Site Health and Safety Officer, in conjunction with Parsons ES Austin health and safety officer, may allow Level D PPE.

Airborne dust is the primary route of exposure to metals. All employees on site will avoid exposure to excessive dust particles. Monitoring with an air particulate meter (MINIRAM™) will be performed. If particulate levels reach the action levels specified in Table 3.1, respiratory protection and goggles will be donned. All drilling and sampling personnel will wear gloves to prevent exposure through skin adsorption.

2.3.3   Surface Soil, Surface Water, Groundwater, and Sediment Sampling

Field personnel shall be cautious of splash hazards when obtaining soil, sediment, and water samples. Use of the appropriate PPE will help to minimize risks of liquid contact with the skin. Personnel shall wear modified Level D PPE during sampling. Since they will not be working near a drilling rig, hard-hats will not be necessary.

Samples will be collected using decontaminated sampling equipment. Disposable nitrile gloves will be worn and changed between collection of samples. If samples appear to be contaminated, outer nitrile gloves will be donned.

Vapors from VOCs could be encountered during any surface or subsurface soil, or groundwater sampling activity. Organic vapors can build up under confined conditions, such as in a well casing, in any unventilated environment, or even several inches or feet below ground level where there is a solvent source. An organic vapor monitor will be used to differentiate between level C and level D protection. If the vapor concentration exceeds 25 ppm (the TLV for Total Volatile Organic Contaminants), Level C PPE is required. If the particulate level exceeds 250 ppm (the TLV for Total Volatile Organic Contaminants), all personnel will stop work and leave the site until vapors disperse.

Areas where sediment and surface water samples are obtained are frequently wet and can result in slip, trip, and fall hazards. Field personnel will survey each sample collection location to determine the safest route and method of sampling.

Material safety data sheets for approved solvents and contaminants of concern are contained in Appendix B of this plan. If other solvents are required, field team members must obtain a MSDS and approval of the Site Health and Safety Officer prior to bringing the solvent to the work site. The solvents must be added to the Health and Safety Plan.

The sampling team for this portion of the work will consist of a minimum of two Parsons ES personnel. The surface water samples will be collected with an appropriate sampler from outside of the surface water body.

2.3.4   Mapping

Prior to field activities, each SWMU will be mapped during an initial visit.. Heat stress, trips, slips, falls, snakes, and bees will be the physical dangers of concern. Many of these topics are discussed Section 2.2. Mapping does not involve disturbing the soil and, therefore, chemical exposure will be limited.

2.3.5   Soil Gas Survey

Efforts will be made prior to conducting the soil gas survey to determine if underground installations (i.e., sewers, telephone, water, fuel, elec­trical lines, or liners) are present in the vicinity and, if so, exactly where such underground installations are located. A preliminary site visit and records search did not indicate the presence of any underground or overhead lines (ES, 1993). Soil gas locations may be adjusted in the field to avoid underground obstructions.

All field personnel must be careful in the soil gas survey area. Steel-toed boots, ear plugs, and safety glasses must be worn by all personnel while using the pneumatic hammer. 

Low and medium priority SWMU soil gas surveys will be performed in Level D PPE since VOCs and SVOCs are not expected in the breathing zone. However, air monitoring for VOCs will be performed during soil gas surveys. PPE is further described in section 3.4.

2.3.5.1   Soil Gas Analytical Equipment

Soil gas samples will be analyzed with an HNuÔ model 321 GC equipped with an electron-capture detector (ECD) and a photoionization detector (PID) with a 10.2 eV light source. A Spectra-Physics model 4400 dual-channel integrator will be used to plot the chromatograms, to measure the size of the peaks, and to compute compound concentrations.

The ECD contains a radioactive nickel-63 foil with a source strength of 5 millicuries. This source decays by emitting beta particles at a maximum energy of 0.063 million electron volts (MeV) and are absorbed by less than 1 milligram per centimeter squared (mg/cm²) of aluminum. There is no discernible radiation from the nickel-63 source external to the detector chamber and no hazard as long as the chamber integrity is not violated. A current leak test certification will be maintained on site. The shipment of the ECD to and from the site shall comply with DOT regulations. The instrument is operated under a general license for radioactive sources.

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