3.1 - General Safety Training Requirements

All personnel involved in the project field work must be adequately trained and thoroughly briefed on anticipated hazards, equipment to be worn, safety practices to be followed, emergency procedures, and communications. 

Where required based on scope of work, site personnel will be trained in accordance with OSHA requirements as contained in 29 CFR 1910.120, Hazardous Waste Operations and Emergency Response. Employees will not participate in field activities until they have been trained to the level required by their job function and responsibility. In addition, at least one person involved in field investigation activities will have completed Red Cross or equivalent first-aid and cardiopulmonary resuscitation (CPR) courses. All training documentation will be verified by the Site Health and Safety Officer.

Consistent with OSHA 29 CFR 1910.120, individuals designated as site health and safety supervisors must receive an additional eight hours of specialized training on managing hazardous waste operations. Such training will also be documented.

3.2 - Medical Surveillance

Parsons ES uses the services of a licensed occupational health physi­cian (Medical Services Network) with knowledge of or experience in the hazards associ­ated with the work to perform the medical examinations and surveillance specified herein. The medical monitoring program meets the requirements of 29 CFR 1910.120. Parsons ES also requires that subcontractors have their own annual medical monitoring program, as necessary.

Personnel involved in this operation undergo medical surveillance at 12-month intervals. The medical exam is performed under the direction of a licensed occupa­tional health physician, who issues a medical certification of each worker's fitness or unfitness for employment on hazardous waste projects, identifying any restrictions on worker activity that may be indicated. This evaluation will be repeated as indi­cated by substandard performance or evidence of particular stress that is evident by injury or time-loss illness on the part of any worker.

3.3 - Site-Specific Training

The Site Health and Safety Officer and Field Team Leader will be responsible for developing a site-specific occupational hazard training program and for training all Parsons ES personnel who are to work at CSSA. This training will specifically address the activities, procedures, monitoring, and equipment applicable to the site's operations as well as, site layout, potential hazards, and emergency response services at the site. Individual responsibilities regarding health and safety procedures during field work will be clarified. Addi­tional topics that will be addressed at the first safety briefing, and at subsequent briefings as necessary, include:

	Names of personnel responsible for site safety and health;
	Safety, health, and other hazards at the site;
	Exposure risk;
	Proper use of personal protective equipment;
	Decontamination procedures to be followed;
	Location of safety equipment;
	Work practices by which the employee can minimize risk from hazards;
	Safe use of engineering controls and equipment on the site;
	Acute effects of chemicals at the site;
	Accident reporting;
	Emergency and evacuation procedures;
	Review of planned activities.

One member of the field team must document that all of the above listed topics were addressed.

All personnel on the job will receive initial site-specific safety training. Safety briefings will also be held daily. Both the initial health and safety training and the daily briefings will be documented in the field logbook. Documentation will include topics discussed and the names of personnel attending the briefing.

3.4 - Personal Protective Equipment and Action Levels

Paragraph 1910.132[f] of the new OSHA standard, effective July 4, 1994, requires employers to train employees in the proper use of their PPE. Employee training will consist of the following:

	When PPE is necessary;
	What type of PPE is required;
	How to properly don, doff, adjust, and wear PPE;
	The limitations of the PPE; and
	The proper care, maintenance, useful life, and disposal of PPE.

OSHA requires employer verification of training through a written certification. Since these topics will be covered in the initial safety briefing and periodically during daily safety briefings, signatures on the plan acceptance form and on the daily briefings attendance forms (Appendix A) will constitute written certification of this training. 

3.4.1   Level D Operations

Level D (no respiratory protection) may be used when the workplace atmo­sphere contains no potential respiratory hazard and when work functions do not involve splashes, immersion, or the potential for unexpected inhalation of or contact with hazardous levels of any chemicals.

Most of the field work conducted at each SWMU site will be conducted in Level D-modified. Depending on the nature of the work being performed, protective clothing may also consist of Tyvek* suits, protective gloves, and other protective clothing as described below. Level D-modified consists of:

	Tyvek or similar disposable coverall (optional): For use during any field activity which requires that personnel come into contact with soil or water;
	Inner gloves (nitrile) as determined: For use during any field activity which requires that personnel come into contact with soil or water;
	Outer gloves such as nitrile or neoprene (optional): For use during any field activity which requires that personnel come into contact with contaminated soil and water;
	Rubber or leather steel toed, steel shank boots (chemical-resistance is optional): Mandatory for all field investigation activities;
	Safety glasses with side shields: For use during all drilling and sampling activities;
	Hearing protection (when working in a noisy environment such as within 50 feet of drilling equipment);
	Hard hat (when working around heavy equipment): Mandatory for all personnel working adjacent to an operating rig and in the exclusion zone; and
	Additional items may be required in specific locations or tasks.

Dust masks or some other form of respiratory protection with dust protection cartridges will be donned if the particulate level exceeds 10 mg/m3. The particulate level will be measured with a MINIRAM™.

Respiratory protection will not be required if the concentration of Total VOCs is below 25 ppm. If the concentration of Total VOCs is above 25 ppm, colormetric tubes will be used to measure the concentrations of the constituents of concern. Total VOCs are measured with a PID or FID. If the concentration of total VOCs exceeds 250 ppm, all personnel shall stop work and leave the area. See Table 3.1 for the action levels for implementing C and D levels of protection. Contaminant concentrations can be controlled using engineering controls (ventilation, wetting, etc.) to allow the use of a lower level of protection, provided that monitoring shows that the concentrations have been reduced to the appropriate ranges. 

Drilling actions in the oxidation pond will be started in level C PPE because of suspected VOC contamination. If in the event air monitoring indicates Level C as not necessary, the Site Health and Safety Officer, in conjunction with Parsons ES Austin designated health and safety officer, may allow Level D PPE.

3.4.2   Level C Operations

Personnel conducting field activities when air monitoring indicates the action levels specified in Table 3.1 have been met will upgrade to level C PPE. Personnel will use only National Institute of Occupational Safety and Health (NIOSH) approved particulate and organic vapor respirators if monitoring indicates respiratory protection is required. Respiratory protection shall follow the requirements contained in the OSHA standard 29 CFR 1910.134 and American National Standards Institute standard Z88.2-1969. 

3.4.3   PPE and Equipment Decontamination Procedures

Decontamination procedures are required as equipment may come into contact with chemicals listed in Table 2.1.

An exclusion zone (EZ), contamination reduction zone (CRZ), and support zone (SZ) will be established whenever field personnel are using PPE. Defined boundaries (access and egress points) will be established whenever feasible, and personnel will enter and exit only through these points. In addition, all personnel who are involved in daily field investigations will be required to shower as soon as possible after leaving for the day.

All equipment that requires decontamination will be decontaminated according to the procedures described in the Field Sampling Plan. Decontamination procedures will be monitored by the Site Health and Safety Officer (SHSO).

3.4.3.1   Decontamination Equipment

Equipment decontamination will take place on-site and may generate liquids from washing and rinsing procedures. All liquids will be containerized, sampled, and disposed as stated in the approved work plan. If substantial contamination is found, liquids will be collected and contained for appropriate disposal. Changes in the equipment used for decontamination may be made at the discre­tion of the SHSO. Decontamination equipment will include:

Table 3.1 - Action Levels for Personnel Protective Equipment.

3.4.4   Equipment Needs

The field team will have the following items readily available:

	Copy of this site health and safety plan;
	First aid kit;
	Eyewash bottle;
	Eye protection (as necessary);
	Potable water;
	Hard hat (as necessary);
	Hearing protection;
	Fire extinguisher (type A, B, C);
	Adequate supply of PPE; and
	Decontamination supplies.

3.4.5   Monitoring Requirements

During drilling, air monitoring for VOCs, explosive vapor monitoring, and particulates will be performed by Parsons ES personnel. Moni­toring methods to detect exposure for specific contaminants must take into account the expected concentrations and species of contaminants, and the limitations and advantages of available methods. Only Level D PPE will typically be necessary during field actions other than when drilling within the oxidation pond.

Particulate Monitoring

The real-time air/dust monitor (MINIRAM™) should be operated in a temperature range of 32°F to 120°F. At least 10 seconds are required for each reading. With a complete charge, the unit is operable for 10 hours, but the total measurement period is 8-1/3 hours. The monitor will be zeroed to background before use in an upwind area.

If air rotary drilling method is used, monitoring for particulates will be done continuously. If an auger rig is implemented, the field team can monitor for particulates as necessary.

Organic Vapor Monitoring

Organic vapor monitoring, using a PID or FID, will be performed prior to the start of work, periodically during work, and as working conditions change. Colormetric tubes will be used to identify organic vapors when necessary, but are not considered an accurate means of determining exposure levels.

If the levels of organic vapor are at or above action levels, increased monitoring will be initiated. Monitoring will take place at a frequency and pattern needed to represent the levels of exposure of all the field team members. Where exposures are above the TLV, monitoring will assure the adequacy of respiratory selection and the effectiveness of engineering controls. If above the TLV, the protection level must be upgraded and respirators are necessary. Personal air monitoring will take place if organic vapors are above the TLVs, and at least twice during the project using more specific methods than colorimetric tubes.

Either a PID or a FID will be used as the initial indicator of possible exposure to organic vapors. 

Combustible Gas/Explosive Environment Monitoring

An explosivity meter (oxygen/combustible gas meter), HMX271 combustible gas indicator, will be used during excavation and drilling operations for measuring combustible gas levels. The instrument is portable, lightweight, fully automatic, and provides characteristic warning signals when unacceptable levels of combustible gas are detected. The instrument can detect combustible concentrations up to the lower explosive limit.

NIOSH has established the following guidelines concerning working in an explosive environment:

	If explosivity readings are detected between 10-25 percent LEL, then work activities in the area should be limited to those that do not generate sparks.
	If the explosivity readings on the combustible gas indicator is above 25 percent, operations will terminate and the on-site area must be immediately evacuated until appropriate action can be taken to eliminate the hazard.

These guidelines will be followed during the monitoring for explosive environments. Once the site has been evacuated, the resumption of on-site activities will not occur until the SHSO has consulted with personnel experienced in fire or explosion hazards.

3.5 - Low and Medium Priority SWMU

3.5.1   Geophysical Survey

Level D PPE will be used for geophysical survey. If there are no overhead dangers, hard-hats will not be required. 

3.5.2   Drilling/Well Installation

Level D PPE will be used for drilling and well installation unless high levels of VOCs are detected with the PID/FID. Eye and ear protection should be worn around drilling rigs at all times. 

3.6 - High Priority SWMU

3.6.1   Geophysical Survey

Level D PPE will be used for geophysical survey. If there are no overhead dangers, hard-hats will not be required. Level C PPE is not required for performing a geophysical survey in a high priority SWMU because the ambient air should not exceed action levels specified in Table 3.1. Personnel will not enter the incinerator during field activities.

3.6.2   Soil Gas Survey

Level D PPE will be used for soil gas surveys. Eye and ear protection will be worn at all times while using pneumatic hammer. Hard-hats are not required unless there is an overhead danger.

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