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Addendum to CSSA Health and Safety Plan
1.0 - Introduction
This addendum modifies the existing Health and Safety Plan for the Closure of Solid Waste Management Units (SWMUs) (Parsons ES, 1995). This Health and Safety Plan was prepared to address specific upcoming field tasks at Camp Stanley Storage Activity (CSSA), in Boerne, Texas.
Included in this addendum are site-specific descriptions and proposed activities; hazard evaluation; personal protective equipment (PPE); air monitoring; site control procedures; employee exposure monitoring; and emergency response procedures.
2.0 - Site-specific Description and Project Activities
During this effort, field work will take place at several solid waste management units (SWMUs) at CSSA. This fieldwork will be conducted from approximately early March 2001 through September 2002. During previous investigations, fieldwork was conducted at the B-20 former open burn/open detonation (OB/OD) area. During this investigation, field work will also be conducted at the demolition dud area, and SWMUs B-24, B-28 and B-8. Each of these units and the activities to be conducted there are described below. In general, the field work will consist of field demonstration(s) of potential remedial technologies.
2.1 B-8 Former Trench and Fill Area
The B-8 former trench and fill area is located in the north pasture, and occupies approximately one acre. This site was identified in the field during the 1993 environmental assessment (ES, 1993). Metal, small ammunition, and metal ammunition parts were observed there. Investigations conducted at the site in 1994 and 1995 included a geophysical survey and drilling and sampling of soil borings. The geophysical survey indicated that there is one isolated anomaly at the site. This anomaly was found east of the burn area and may be associated with buried metal debris. This anomaly is thought to consist of waste scrap metal and possibly minor amounts of UXO mixed in a soil matrix. This material will be excavated and sifted to remove the UXO and metal scrap to the greatest extent possible. In addition, a trailer-mounted electromagnet will be pulled over the excavated material to remove scrap metal.
2.2 B-20 Former OB/OD Area
The B-20 former OB/OD area is described in detail in the Health and Safety Plan for Remedial Investigation at the B-20 Site (Parsons ES, 1994). The primary objectives for work efforts at the B-20 site are removal of lead-contaminated soils (in the ammunition disposal areas), UXO, and scrap metal. Removal of lead-contaminated soils will be accomplished by excavation, stabilization, and off-site disposal. UXO and scrap metal will be removed by sifting the soil. The top 6 inches of surface soils in the northern 5-acre area of the site, where the majority of buried UXO and metal has been identified during previous investigations, will be sifted. A trailer-mounted electromagnet will be pulled over the excavated material to remove scrap metal.
2.3 Demolition Dud Area
The demolition dud area consists of approximately 3.5 acres in the inner cantonment area of CSSA, and was first identified during the 1993 environmental assessment (ES, 1993). Prior uses of the site are unknown; however, the area is posted with �Demolition Dud Area� warning signs. Investigation of the site commenced with a sweep for surface UXO. During this work, a disposal trench measuring 250 feet long and estimated to be about 2 feet deep was identified. A number of UXO items have been identified, primarily including fuses and Stokes mortars. The trench consists of waste scrap metal and possibly UXO mixed in a soil matrix. This material will be excavated and sifted to remove the UXO and metal scrap. In addition, a trailer-mounted electromagnet will be pulled over the excavated material to remove scrap metal.
2.4 B-24 Disposal Area
The B-24 site covers approximately 5 acres in the north pasture of CSSA. This site was identified in the field during the 1993 environmental assessment (ES, 1993). Spent ammunition and small spent rockets were observed there. A geophysical survey was conducted at the site in 1995. Three isolated anomalies were identified at the site. Preliminary UXO work done at the site this year indicates that four trenches were used to dispose of waste material consisting primarily of rifle cartridges. A small number of 20 mm projectiles (UXO) have also been identified at the site. Each trench is estimated to be approximately 15 feet deep. Each trench consists of waste scrap metal and a minor amounts of UXO mixed in a soil matrix. This material will be excavated and sifted to remove the UXO and metal scrap to the greatest extent possible. In addition, a trailer-mounted electromagnet will be pulled over the excavated material to remove scrap metal. However, small brass bullet casings in the waste material will be difficult to remove because they are non-ferrous material. The brass casings will be removed to the greatest extent possible by sifting and manual separation.
2.5 B-28 Disposal Area
The B-28 site covers less than one acre in the inner cantonment of CSSA. This site was identified in the field during the 1993 environmental assessment (ES, 1993). Molten metal, small ammunition, and metal ammunition parts were observed there. Investigations conducted at the site in 1994 and 1995 included a geophysical survey, a soil gas survey, and drilling and sampling of soil borings. The geophysical survey indicated that there are two northwest-southeast trending trenches containing buried metal. The northern trench is approximately 300 feet long and 15 feet wide. The southern trench is approximately 100 feet long and 15 feet wide. The trenches are apparently shallow (less than 3 feet deep) as evidenced by field observations where the northern trench intersects the drainage ditch. Each trench consists of waste scrap metal and a minor amounts of UXO mixed in a soil matrix. This material will be excavated and sifted to remove the UXO and metal scrap to the greatest extent possible. In addition, a trailer-mounted electromagnet will be pulled over the excavated material to remove scrap metal.
3.0 - Hazard Evaluation
3.1 Chemical Hazards
General hazards are addressed in the health and safety plan for remedial investigation of the B-20 site. Specific hazards associated with the trenching and sifting activities are identified below.
The major chemical known or suspected to occur at the sites listed above is lead. Previous sampling results indicate that only lead occurs at levels exceeding industrial site soil-air ingestion standards (30 TAC 335 Subchapter S). Other chemicals potentially occurring include copper, mercury, zinc, and 2,6-DNT. Health hazard qualities for 2,6-DNT are presented in Section 2 of the B-20 Health and Safety Plan (Parsons ES, 1994). Toxicologic properties of the metals are listed in the following table.
Toxicologic Properties of Compounds
| Compound | PEL (mg/m3) | TLV (mg/m3) | IDLH (mg/m3) | Odor Threshold (ppm) | Physical Description/Health Effects/Symptoms |
| Copper (dust/mists) | 1 | 1 | 100 | NA | Reddish, lustrous, malleable, and odorless, solid metal. Irritates eyes, nose, skin, and pharynx. Causes a metallic taste, nasal perforation, nausea, vomiting, and dermatitis. In animals, causes anemia and lung, liver, and kidney damage. Experimental teratogen, questionable carcinogen. |
| Lead | 0.05 | 0.15 | 100 | NA | Heavy, ductile, bluish-gray, soft metal. Irritates eyes. Causes weakness, exhaustion, insomnia, facial pallor, anorexia, low-weight, malnutrition, constipation, abdominal pain, gastritis, colic, gingival lead line, anemia, wrist and ankle paralysis, joint tremors, low blood pressure, and kidney disease. Mutagen, experimental teratogen, suspected carcinogen. |
| Compound | PEL (mg/m3) | TLV (mg/m3) | IDLH (mg/m3) | Odor Threshold (ppm) | Physical Description/Health Effects/Symptoms |
| Mercury (aryl, inorganic, vapors) | 0.1 (ceiling) 0.05 (vapor) | 0.1 (skin) 0.025 (inorg) | 10 | NA | Silver-white, heavy, odorless, liquid or tin-ductile, malleable, soft, solid metal. Corrosive to skin, eyes, and mucous membranes. Causes dermatitis, coughing, chest pain, shortness of breath, bronchitis, lung inflammation, ringing in the ears, tremors, insomnia, irritability, indecision, headaches, fatigue, weakness, fever, salivation, inflammatory disease of the mouth, gastrointestinal disturbances, anorexia, low-weight, and protein in the urine. Mutagen, experimental teratogen, questionable carcinogen. |
| Zinc (based on zinc oxide) | 5 (fume, respirable fraction) 10 (dust) | 5 (fume) 10 (dust) | 500 | NA
| Fine, white or yellowish, odorless particulate. Irritates respiratory system. Causes metallic taste, cough, chills, fever, tight chest, headaches, rales, blurred vision, muscle aches, nausea, vomiting, dry throat, weakness, lower back pain, exhaustion, fatigue, vague discomfort, shortness of breath, and decreased pulmonary function. Fumes cause metal fume fever. Mutagen, experimental teratogen. |
3.2 Physical Hazards
Potential physical hazards at these sites include risks associated with UXO, sifting, trenching, underground utilities; heavy equipment; motorized vehicles; slip, trip, and fall hazards; noise; dust, and heat stress.
Protection standards for physical hazards are contained in Section 3 of the Health and Safety Plan (Parsons ES, 1995). Topics not discussed in that document are addressed below.
3.2.1 Mixing operations
Soils containing metal debris from excavation, sifting and stockpiling operations from the B-20 site will be mixed with Appatite II material. The stockpiled soils will be loaded into the mixer�s hopper by a front-end loader. Once the material has been mixed the treated soils will be taken and placed within a designated area.
Caution will be taken when working around the earth-moving equipment. Hand signals will be established before any field work commences.
3.2.2 Trenching
Before excavation activities are initiated, the estimated location of all underground utilities will be determined in coordination with CSSA personnel. Excavations at all locations are expected to reach a maximum depth of five feet or less. Trenches greater than 4 feet deep will not be entered without a confined space permit.
US Occupational Safety and Health Administration (OSHA) excavation, trenching, and shoring standards will be followed in accordance with 29 Code of Federal Regulations (CFR) 1926, Subpart P. Excavations greater than 4 feet in depth will be sloped at least 34 degrees, which is considered safe by OSHA for any type of soil classification. Daily inspections of excavations, the adjacent areas, and any protective systems will be made by a competent person representing Parsons ES for evidence of a situation that could result in possible cave-ins, indications of failure of protective systems, hazardous atmospheres, or other hazardous conditions. Such inspections will be conducted prior to the start of work and as needed throughout the day�s activities. Inspections also will be made after every rainstorm or other occurrence that might increase hazards. If indications are observed of possible cave-in of the excavation or failure of the protective system, then the protective system will be redesigned, if necessary, and proper construction or assembly of the protective system will be confirmed before work continues at that excavation. If hazardous conditions are suspected, appropriate steps will be taken as necessary to minimize such hazards before work is continued.
3.2.3 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.
Provide cooling devices to aid in natural body ventilation. These devices, however, add weight, and their use should be balanced against worker efficiency.
Wear cotton long underwear, which acts as a wick to help absorb moisture and protect the skin from direct contact with heat-absorbing protective clothing.
Install mobile showers and/or hose-down facilities to reduce body temperature and cool protective clothing.
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.
In hot weather, rotate workers wearing protective clothing.
Maintain good hygienic standards, frequently changing clothing and daily showering. Clothing should be permitted to dry during rest periods. Workers who notice skin problems 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 for reference in the field. Medical help must be obtained for the more serious cases of heat stress.
Heat-Related Problems
Heat rash: Cause by continuous exposure to heat and humid air and aggravated by chafing clothes. Decreases ability to tolerate heat and is a nuisance.
Heat cramps: Cause by profuse perspiration with inadequate fluid intake and chemical replacement, especially salts. Signs include muscle spasms and pain in the extremities and abdomen.
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 minute); pale, cool, moist skin; profuse sweating; and dizziness and lassitude.
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.
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. The following table presents the suggested frequency for such monitoring. Monitoring frequency will increase as 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 (ACGIH) Threshold Limit Values (TLV) Booklet, may be used.
Suggested Frequency of Physiological Monitoring for Fit and Acclimatized Workers1
| Temperature | Normal Work Ensemble | Impermeable Ensemble |
| 90�F (32.2�C) or above | After each 45 minutes of work | After each 15 minutes of work |
| 87.5-90�F (30.8-32.2�C) or above | After each 60 minutes of work | After each 30 minutes of work |
| 82.5-87.5�F (28.1-30.8�C) or above | After each 90 minutes of work | After each 60 minutes of work |
| 77.5-82.5�F (25.3-28.1�C) or above | After each 120 minutes of work | After each 90 minutes of work |
| 72.5-77.5�F (22.5-25.3�C) or above | After each 150 minutes of work | After each 120 minutes of work |
| 1 For moderate work, e.g. walking about with moderate lifting and pushing. | ||
| 2 A normal work ensemble consists of cotton coveralls or other cotton clothing with long sleeves and pants. | ||
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).
4.0 - Air Monitoring
Soil samples collected and analyzed in the B-20 area recently show an elevated level of lead in the clay soil matrix. The highest concentration measured in this area is 2,400 mg/kg. Preliminary samples have been collected at B-24 and B-28; however, analytical data are not yet available. Based on the nature of waste disposal at these sites (including the demolition dud area), lead is the primary contaminant of concern. Sand which contains lead bullet shot will be excavated in three areas (B-31, B-32 and B-33) which also have a potential for possible elevated lead levels. Since the lead is in a solid form, lead dust levels should not be a concern. Nevertheless, dust levels will be suppressed with engineering controls such as spraying water on the surface soils and excavated soils were the dust is being generated. If particulate levels still persist, dust masks or respirators with HEPA cartridges will be donned and particulate levels will be monitored. A real-time air/dust monitor (Miniram) may be used to monitor particulates in the field teams breathing zone, during soil excavation and soil sifting operations if high levels of particulate are observed and continue to exist after being suppressed. The Miniram can only measure total dust particulates that are airborne, and cannot measure potential ambient lead.
5.0 - Site Control Procedures
Site control measures will be followed to minimize potential contamination of workers, protect the public from potential site hazards, and control access to the sites. Site control involves the physical arrangement and control of the operation zones and the methods for removing contaminants from workers and equipment. Section 4 of the Health and Safety Plan includes a description of the site control procedures.
Specific site control procedures at these site will include establishment of site work zones whenever sifting or trenching activities are underway, or if any trenches are open. All open excavations will be barricaded until backfilled, and unauthorized personnel will be restricted from entering the immediate work area.
6.0 - Personal Protective Equipment
It is anticipated that all work will be conducted in Level D respiratory protection, with a contingency provision for use of dust masks or respirators. Additional guidelines for the selection of respiratory protection at these sites are contingent upon the discovery of elevated lead particulates in the worker breathing zone while performing site activities. Site crews will assess the need for respiratory protection, or PPE, as applicable with a Miniram. In addition, engineering controls such as spraying water in areas where dust is being generated will be incorporated.
Protective clothing to be used at these sites includes:
| Hard hats | |
| Safety glasses | |
| Dust mask | |
| Respirator, if needed (HEPA cartridges) | |
| Outer gloves (Leather) | |
| Boots (Safety boots ) | |
| Proper hearing protection |
7.0 - Employee Exposure Monitoring
Employee exposure monitoring will be conducted on this site in accordance with OSHA standards (29 CFR 1910) and the B-20 Health and Safety Plan.
8.0 - Emergency Response Plan
8.1 Safe Distances and Places of Refuge
Prior to initiation of field activities, the field crew shall decide on safe distances to retreat to and select a place of refuge in the event of an emergency. This information shall be provided to all field personnel during daily site-specific safety briefings. All other guidelines established in the Health and Safety Plan for emergency planning, training, and recognition shall be followed.
8.2 Emergency Information
Listed below are the names and telephone numbers for medical and emergency services for this project.
Hospital Methodist Hospital
Address
7700 Floyd Curl Rd.
San Antonio, TX
Phone
(210) 692-4444
Description of the route to the hospital:
Hospital is located on the corner of Medical and Floyd Curl Drive. The route from the Camp Stanley main gate is south on Ralph Fair Road about 0.75 mile, south on Interstate 10 about 12.5 miles, exit on Wurzbach Road, take access road to Medical Drive, west on Medical Drive about 0.5 mile, and south on Floyd Curl Drive to hospital.
Other Emergency Numbers:
Fire Department: 911
Security Police: 911
Ambulance: 911
Project Manager:
Ken Rice work: (512) 719-6050