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Home My WebLink AboutMITIGATION 1986 (2) ~'- ._~.' . ~'Ü' .'¡, ~ ~~ ~. . - - - -- - ------ - ---~- - ---~- - --- ~- ENVIRONMENTAL MANAGEMENT A Proposal Prepared For: Mr. Jack Garriott Garriott Crop Dusting 2010 S. Union Avenue Bakersfield, California GEOTECHNICAL SITE ASSESSMENT GARRIOTT CROP DUSTING BAKERSFIELD AIRPARK BAKERSFIELD, CALIFORNIA by ~-,-._~-- Mark W. Roser, President Positive Incident Control P.O. Box 10630 Bakersfield, California 93389 August 11, 1986 P.O. BOX 10630. BAKERSFIELD. CA 93389 · BAKERSFIELD · REDDING . POSITIVE INCIDENT CONTROL · HAZAROOUS SPILL rEAM · ENGINEERING · CONSUL rING · OlSPOSAL LICENSE NA463254 · EMERGENCY (800) 421-5807 . · RIVERSIDE · CONCORD HEADOUARTERS (805) 393-3059 · SANTA BARBARA e e TABLE OF CONTENTS ------------------------------------------------------------------ ------------------------------------------------------------------ PAGE 1.0 INTRODUCTION.......................................... 1 2 . 0 BACKGROUND............................................ 2 3.0 PROPOSED SCOPE OF SERVICES................ ............ 4 3.1 Exploratory Borings.. ..................... ....... 5 3.2 Sample Selection for Laboratory Analysis......... 6 3.3 Laboratory Analysis.............................. 7 3.4 Investigative Heport............................. 8 ILLUSTRATIONS APPENDIX - . 1.0 INTRODUCTION Positive Incident Control (PIC) is pleased to submit this proposal to Mr. Jack Garriott for the site contamination assessment of soils and groundwater at your Bakersfield Airpark location. Plate 1 shows the vicinity of the site location. We understand that the Department of Health Services has asked for a site assessment to determine the extent of soil and groundwater contamination. This document contains our proposed site assessment plan. ( 1 ) 1/7 7/~ e e 2.0 BACKGROUND A Senior Environmental Specialist from PIC visited the site on August 6, 1986, noted general site conditions I and discussed the situation with Mr. Jack Garriott, the land owner. Plate 2 is a sketch of the site. From these discussions, we learned that the Department of Health Services has issued Garriott Crop Dusting a Notice of Violation and Schedule of Compliance dated July 31, 1986. We noted apparent contamination at the location of one (1) unlined holding pond and at various locations on site. Neither the duration of use of the pond, nor the amount or type of product used are known. Available information suggests that during the course of business conducted on Garriott property, the workers would bring the crop dusters back to the airpark location, rinse the airplanes out and collect the rinse water in the holding pond for evaporation. The use of this pond was discontinued approximately May I 1986. We understand that: * groundwater occurs at approximately 190 feet below the site, ( 2 ) _-___ =-"o__-:;_~..,.:;::-~ . e * water wells tested in the nearby area turned up clean, the use of the holding pond has been discontinued I all aircraft are now being rinsed in the field, not on the airpark location, and all containers are now being triple-rinsed in the field I brought back to the location and then crushed I and placed into sealed roll-off bins for disposal at the county landfill. * * * ( 3 ) · e 3.0 PROPOSED SCOPE OF SERVICES PIC proposes to conduct a site assessment consisting of exploratory borings to determine the extent of soil and groundwater contamination. We will sample soil and ground water I submit samples for laboratory analysis of pesticides and related compounds I and prepare a report of results. (4 ) e e 3.1 EXPLORATORY BORINGS PIC proposes to drill exploratory borings to delineate lateral and vertical extent of contamination. We will: drill borings with a truck-mounted I 10-inch to 12-inch diameter hollow-stemed auger I steam clean the auger before each boring I log the borings I sample soil with a Sprague and Henwood sampler at 5-foot intervals I monitor the samples with a photoionizer detector (PID) for volatile organics and record PID readings I select samples for laboratory analysis based on PID readings I * collect samples in brass tubes I seal ends with Teflon film, plastic end caps I and tape, and * store the samples I on ice (4°C) for delivery within 24 hours to the laboratory. PIC proposes to first determine the approximate radius and depth of contamination by drilling adjacent to the exposed holding pond to determine the radius and depth of contamination. We will sample soils as described above, monitor soil samples with a PID, and submit selected samples to the laboratory for a chemical analysis. * * * * * * (5 ) e - 3.2 SAMPLE SELECTION FOR LABORATORY ANALYSIS PIC proposes to select samples for analysis based on field PID readings. For the subsurface contamination assessment I we will submit for laboratory analysis, soil samples obtained at 5-foot intervals for which a positive PID reading is obtained. Two additional samples will be obtained for laboratory analysis at 5-foot intervals below that depth from which a zero PID reading is obtained. In boreholes that penetrate a water bearing strata, fluid samples will be taken for analysis using the previously described procedures. If a state regulatory agency wishes splits on any samples PIC will cut the lining tube with a tubing cutter I seal the ends with Teflon, plastic end caps I and tape them. Sample cooling, storage or transportation will not be provided. We will similarily, if desired, collect ground-water samples in agency-provided glass containers at the same time we take samples for laboratory analysis. ( 6 ) e 3.3 LABORATORY ANALYSIS e PIC proposes to submit selected samples to a California state approved laboratory I for chemical analysis. PIC will analyze for: Aldrin ::.t,'-BHC ,: - BHC j -BHC 'ì' -BHC (Lindane) Chlordane 4,41-DDD 4,4'-DDE 4,4'-DDT Dieldrin Endosulfan I Endosulfan II Endosulfan sulfate Endrin These compounds will be analyzed by Method 8080, Method 8250, or Method 8210 as described in "Test Methods for Evaluating Solid Waste I Physical/Chemical Methods" I SW-846, 2nd edition I u.S. Environmental Protection Agency, 1982. These methods are applicable to groundwater I liquid, and solid samples. The Appendix contains a proposed quality assurance/quality control program for field use. I ... , Endrin aldehyde Heptachlor Heptachlor epoxide Kepone Methoxychlor Toxaphene PCB-1016 PCB-1221 PCB-1232 PCB-1242 PCB-1248 PCB-1254 PCB-1260 · e 3.4 INVESTIGATIVE REPORT PIC will prepare a report which describes our activities, methods I and findings from the site assessment. The report will be signed and submitted to Mr. Jack Garriott, and will be in format suitable for presentation to the regulatory agencies. It will contain: * a description of areal geology and hydrology I a site plan showing locations of borings and monitoring wells, copies of boring logs, tabulation of all water level measurements I summaries of laboratory analyses I copies of all laboratory reports I interpretation of data regarding extent of soil and ground-water contamination I and recommendations regarding containment and clean-up of contamination encountered. * * * * * * * ( 8 ) ... I -<-=. ~J---, I ¡ \ I " ~-~. "i ' 'H2nfor." , ' "",:" I . " ',I I' , ",,' /~// /~u;U~;¡'i'" , --L _.J,: ¡ ,_ ~-T- .; ,_ "" ", ::Xi", ' I.-~ :" .. ì I . ~ n~.1 "'J '.. I' -~ / : \ \: I ~ / -~ I \ c "e, \-L-ì--.-- ~ " ' , I \ \I I· . ' I, 1 .".,:\ . . .. , ~""",,\ \/ih- \- ,/\ ·'-\L-~,-"helafle, \ 1 ,~ ; ~ ""\-' ì r I ' ",L--, ,----,,' i '., / \ II" ."", '\ \ "',\ "';'. ", ~"'''-r ." / -.-/',., ~<, \ \ . ~ .. "JI~ , X '-- """-...( , .L "'! I ' ¡-'V:S 3:1.~?- lL¡ , '., '.- !'" """ _,f'_, ~ ì C. ''\.~...., ...~t.' _. . ... .; ", I "'Off-,. ". ~.¥'.H ( "" " , --'. ) R F. r' t~1 . .. '\ , I , . ,t 1. 25~"*"'" / . n..,lch Ffl" ,0_".( .ff," . Y \.: .. ",",,<JIQoJ ! /1- , (C'. ........ . ;¿ '4'1-1 'Y <' .,.. ... "t.. ¡' ....../ " 8 '(-is f> (j / !. ",. ~" ,S) A ~ , r: ~ "::~:.~7 ... 1,>-.,\ ., Lie, ~ f"... ,I-, . )#..,'~ 1'10,"":' ·,·,..',".~¡:.r-'.:.:;..; "'.,~' ~:.:.:.~:.~- --..., '. ,.,'..~" ~ "JI...cltI ' :, rI.;.-." ¡'k~.", ..." '_\-~':'" ' - --....:.. " ". ~'-' '". I -~. ,~,}<tt-~ .' ",' .'.., Santa CarOlnfll'. usaw~. Barba ra ,J.: ,,_ ~..' '(;IElÏdora. ~ . Sðn ¡):r:lih . '. Scale 20 miles PLATE If: . '... . -'. -. '-"" - -' -:: .;; . -: ~- .-:- -- . .- . . EÑvti/ONMENTAt · . MANAGEMENT DRAWN BY GLD APPROVED V I C I N I TV MAPDusting 'ott Crop Garr~ . Id Airpark Bakersf1e REVISED DATE 8/11/R6 1 JOB NUMBER 86-219 DATE ø~~ ~ ¡ I í I t Î ! I , i t i I } 1 ; I I I ! ! i f . f i , ~ } : J : t 1 I b I ~ r ¡ , I t ! I ~ // I ./ ,/ ~~ov:red ~ t:! Plt__ // [I, i--~ / I ",/ ,/ ./ " I 1 I I J ¡ , ¡ .i. i Lot.I ¡ I I i ! Shop '( .~ ".- ~ t ~L_J'--¡ . ( . Storaqp.: , ....-- z ,~ ! ì!-¡ Ii I .. '''' !¡ r,oen Ii ¡pit ~ ./ ~,..-- I ! II i 'L..l I I ! , , Ij , I , \ Drainage & Access Easement I ------. ..~ ') t ./ i _---'.- 1 )'----- r---j"""'-· Fue 1 Is land---- , Shop r1 I I I , .J BAKERSFIELD AIRPARK l SITE PLAN PLATE 2 Garriott Crop Dusting Bakersfield Airpark DRA t-JN GLD APPROVED DATE 8/11/86 REVISED DATE JOB Nm1fip.'q R6-2l9 e - APPENDIX FIELD WORK QUALITY ASSURANCE/QUALITY CONTROL PLAN 1.0 O~jective anq Scope Statement The object of this project is to conduct a surface and subsurface assessment at a site where pesticide and herbicide materials have leaked from an unlined rinsewater containment facility. Apparent surface contamination is also present in the immediate area resultant from day to day crop dusting operations. We plan to conduct surface and subsurface investigations to assess the degree and extent of contamination. We plan to drill exploratory borings, analyze samples for pesticide residues I and if necessary I install appropriate monitoring devices. 2.0 Data Usage Data gathered during this project will be used to determine the extent of subsurface contamination. Decisions regarding additional soils excavations and possible ground-water clean up will be based on these data. 3.0 Sampling Plan Design and Rationale We plan to sample soil from borings at 5-foot intervals to a depth 10-feet below positive PID readings. We plan to take a water sample from water bearing subsurface strata where PID screening of samples indicates contamination into water bearing strata. e . The options for sampling soil range from continuous sampling to collection of no samples at all. Continuous sampling and appropriate analysis of portions of the soil column would theoretically provide the best picture of soil conditions. However, continuous sampling techniques are either much slower or less reliable than taking driven samples at intervals. We have chosen a 5-foot sampling interval for apparently contaminated soil because the borings are expected to be shallow and we wish to collect sufficient samples to be able to log the borings. 4.0 Minumum Detection EPA publication SW-846, 2nd edition, 1982, "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods" reports the following typical minimum detection limits using Method 8080. Constituent Minimum Detection LimitL~g¡.u Aldrin ,~::.( -BHC ,:·i-BHC ,~. -BHC ~(-BHC (Lindane) Chlordane 4,4'-DDD 4,41-DDE 4,4'-DDT Dieldrin Endosulfan I Endosulfan II Endosulfan sulfate Endrin Endrin aldehyde Heptachlor Heptachlor epoxide Methoxychlor PCB-I016 PCB-1221 PCB-1232 PCB-1242 PCB-1248 PCB-1254 PCB-1260 0.004 0.004 0.006 0.009 0.004 0.014 0.012 0.004 0.012 0.002 0.014 0.004 0.066 0.006 0.023 0.004 0.083 0.176 ND ND NO 0.065 NO ND NO e e 5.0 Data R~presentativeness The degree to which the data gathered represents actual subsurface contamination will depend upon judicious choice of boring locations. We have chosen to first determine how far contamination extends verticallYI and then to determine how far contamination extends radially from the unlined containment pond. We feel that this approach is both systematic and thorough. 6.0 Data Comºleteness The work plan provides for analysis of subsurface samples taken from borings for all primary pesticide residues of interest to regulatory agencies. The parameters chosen are those used to determine whether soil must be excavated or left in place. 7.0 Sampling Procedures Pesticides have volatile components. Our sampling procedures require sealing and cooling the samples to avoid loss of volatile components. We will collect undisturbed soil samples in 6-inch brass tubes with a Sprague and Henwood sampler. We will seal the sample tubes with Teflon film, plastic end caps I tape and store on ice (4°C) for delivery within 24 hours to the laboratory. e - 8.0 Sam~le Custody Procedur~ We plan to observe EPA chain-sustody procedures and will * clean brass sample tubes with soap and water before use, * transport the tubes in sealed chests to prevent inadvertent contamination or tampering before use I identify the samples with gummed labels containing sample number I name of collector, date and time of collection I and place of collection I seal the samples with gummed seals containing sample number I collector's name I and date and time of sampling I maintain a field log book which records sample identification, location of sampling point, volume of sample, description of sampling point and sampling methodology, sample distribution I and field measurements I date and time of collection, and signatures of data collector, and prepare and use a chain-af-custody record which will contain sample number I signature of collector I date and time of collection, place and address of collection, signature of persons involved in the chain of possession, and inclusive dates of possession. * * * * e e 9.0 Calibrªtion Pr~cedures At the start of each day, we will calibrate the photoionizer detector in accordance with the manufacturers suggestions (10.2 ev lamp, simple-point calibration, direct reading for benezene). e e P.I.C. CORPORATE HEALTH AND SAFETY PROGRAM Introduction and Polic~atement P.I.C. is committed to providing a safe work environment I thereby protecting the health of its employees I clients, and the general public. In order to accomplish this goal, P.I.C. has adopted a Corporate Health and Safety Program (CHASP). This program specifies policies, procedures I and responsibilities for implementation that will insure all operations are conducted safely. All health and safety governmental regulations and requirements as they apply to P.I.C. IS operations are satisfied through implementation of this program. The CHASP serves as a conduit of information needed by supervisors and employees concerning health and safety policies and procedures. General Policy Goals P.I.C. 's goal is to protect its employees from occupational e e accidents and illnesses. Accordingly, P.I.C. has adopted a policy of prevention intended to: 1. Provide a safe work environment. 2. Comply fully with all governmental regulations and requirements pertaining to employee health and safety. 3. Maintain high standards and performance in the areas of environmental protection I industrial health, and first in emergency response (F.I.E.R.) safety. 4. Conduct all operations within established company safety guidelines and requirements. 5. Initiate and maintain a rigid medical surveillance program. 6. Develop and implement an extensive employee training program. Managem~nt - Re~ponsib~)i!'y Relative To CHASP Project managers and foremen have the primary responsibility for preserving the health and safety of personnel and for correcting improper conditions and safety practices on-site. Supervisors must insure acceptable levels of risk are maintained with respect to activities within their purview. When supervisors suspect or have knowledge of improper safety conditions, they must terminate associated activities and correct the hazardous condition. e e Employee Responsibility Relative to the CHASP Employees are responsible for taking all precautions necessary to prevent injury to themselves and to their fellow workers. They are expected to learn and comply with approved standards and procedures applicable to their work. When employees have doubts regarding the propriety of a particular safety protocol I they are encouraged to "stop and think" before performing work under which such protocol is operative. Employees are expected to perform only those tasks they believe they can perform safely and to report immediately unsafe or improper conditions to work site supervisors or designated safety representatives. All employees are encouraged to participate in and provide input for safety committee policy, review, and implementation. Corporate Health and Safety Committee {C.H.S.C.l The Corporate Health and Safety Committee "CHSC" relies entirely on non-management volunteers who meet monthly, or more frequently, in order to review current policies and procedures and to evaluate both management and co-worker on-site job performance. Findings and recommendations of the C.H.S.C. are transmitted to the Corporate Health and Safety Officer, who is required to respond in writing to the C.h.S.C. within seven (7) work days. A copy of the C.H.S.O. 's response is required to be sent to the president of P.I.C. for review. e e P.I.C. 's corporate health and safety committee is responsible for the following: * Administration of the CHASP * Review of work site investigations and periodic reports * Review of accident investigation reports * Review of hazard identification reports * Review of safety data collected * Review of P.I.C. internal safety reports and recommendations * Recommendations for additions and refinements of the CHASP * Implementation - general problems pertaining thereto. ~.I.C. Corporate Commitment to the CHASP P.I.C. demonstrates its commitment to provide for the health and safety of all its employees by: * Adoption of the CHASP policy * Assignment of organizational responsibility for implementation * Providing required resources for implementation of the CHASP * Periodic review of health and safety committee recommendations e e P.I.C. Corporate Implementa~ion of the CHASP The CHASO (Corporate Health and Safety Officer) is responsible for: * The implementation and management of P.I.C. 's CHASP. * Compliance with, P.I.C. IS CHASP. * Appointing a site safety officer for each response to a known or suspected hazardous field site. * Maintenance of a healthy and safe work environment at all work sites. The CHASO or assignee has authority to stop all work if work practices or conditions on-site expose any person to an eminent danger. * Review of site safety plans on a scheduled basis. * Review of changes in processes and equipment. * Accident investigation. * Implementation and follow-up on corrective actions as needed. * Collection of data and reports related to P.I.C. IS CHASP. * Maintenance of P.I.C. IS CHASP, which contains detailed information on safety requirements and procedures. Medical Policies - Medical Screening To safeguard the health of hazardous material personnel a medical e e surveillance program has been developed. P.I.C. is responsible for maintenance of the program. Medical screening consists of pre-placement I periodic, and termination examinations. These examinations establish an individual's state of health base line, physiological data, and ability to use protective equipment. Medical screeening also provides for special medical examinations to evaluate known or suspected exposure to toxic substances. They are performed annually, or more frequently, depending on the nature of the exposure. Pre-placement Examination Pre--placement or base line examinations serve an essential function in medical surveillance by providing a historical record of previous exposures through a carefully documented occupational history indicating all jobs held (dates I places I etc.). If any previous occupational disease has been experienced the circumstances related to such occupational disease are reported in detail. The exam includes a personal and family history. The physical includes an organ inventory I notations relative to any major and/or minor physical changes I and an evaluation of functional capacity. The exam is intended to insure workers are physically able to use personnel protective equipment as specified by OSHA standards. The pre-placement exam serves to document preexisting conditions and exposures and to establish a point of reference. e e Examination After Illness or Inju~ "Post illness absence" examinations are necessary to determine if a worker is physically fit to return to the job held prior to the illness. This is extremely important when a worker comes in contact with hazardous materials I or operates machinery. Many non-occupational physicians have a poor understanding of the environment in which personnel work, and consequently I release patients prematurely. The CHASO must be aware of this potential problem. An exam will not be required if the absence is a brief one I but may be necessary if the period away from the work is excessive I or when surgery I cardiac I or respiratory systems are involved. A tracking system is established in which routine sickness (e.g" Influenza) is tracked against previous contract with hazardous materials. Such a procedure furnishes information regarding previously unknown occupational illness. e - INDUSTRIAL HYGIENE SURVEILLANCE DOCUMENTATION AND CONTROL DURING EMERGENCY RESPONSE General Statement This section defines a coordinated procedure followed by P.I.C. 's CHO and/or outside industrial hygienist I when appropriate I to evaluate the occupational environment in order to effectively protect the safety and health of employees performing work therein. Pursuant to the Occupational Safety and Health Act of 1970, employers are required to measure, record, and report upon the exposure of employees to potentially harmful or toxic agents. The pervasive nature of P.I.C. 's work necessarily provides ample opportunity for such exposure. The goal of P.I.C. 's IH procedure is to facilitate the recognition, evaluation, and subsequently, the correction of conditions in the work environment which may adversely affect worker health. This goal is the hallmark of P.I.C. safety program for accident and injury prevention. Generally, industrial hygiene deals with environmental conditions or stresses that may adversely affect worker health. Safety deals with hazards posing a more immediate threat to life and limb. Consequently, close coordination between the safety program and e . industrial hygiene program must be maintained. To ensure maximum protection of workers, industrial hygiene must take into account protective requirements as well as accident and fire prevention concerns in the design of new facilities and equipment and in the procurement of supplies and materials. Procedures outlined in this section are intended to insure that prevention is given as much emphasis as surveillance and correction. Procedures and Coordination P.I.C. provides for the availability of an industrial hygienist for periodic evaluation and consultation when requested by a project manager or supervisor. The CSO is directly responsible for overseeing these services. Once potential health hazards are identified, the assigned industrial hygienist or CHO will determine the extent of such hazards. Through analysis of facts determined during initial review of the incident, the nature and concentration of the substances involved I and the duration of exposure to such hazardous substances can be evaluated. In many cases I adverse affects from exposure to toxic materials do not appear until the exposure has occurred for several years. The purpose of threshold limit values (TLV) or standards is to protect against future appearance of such symptoms. When potential occupational e e exposure is determined I such identification and attendant supporting evidence is made a matter of record. When it is determined a potential health hazard sufficient to produce illness or injury exists I or if there is noncompliance with applicable procedural requirements I control methods are formally recommended. The satisfactory control of occupational health hazards requires continuing attention and reevaluation despite imposition of control measures. The type of control implemented is dictated by individual situations. Industrial hygienists can provide representative monitoring of incident mitigations (again, the frequency of such monitoring is a function of the processes I materials I and controls associated with the specific incident). Records and ReQorts P.I.C. maintains written records of all environmental and medical surveillance measures including industrial hygienist surveys. These records are maintained in accordance with OSHA records requirements. Copies of formal recommendations, interoffice communications I and other documents associated with industrial hygiene activities also remain on file. E~ployee Exposure Records Documentation of findings resulting from environmental e e surveillance of toxic chemicals and biological and physical hazards is formatted to provide qualitative analysis of worker exposure to such hazards. P.I.C. employees are given an opportunity to observe monitoring activities and are provided access to all reports and records associated with and emanating from environmental surveillance. Industrial Hygiene Check List An industrial hygiene survey check list is used in conjunction with the safety appraisal. The format of the industrial hygiene survey check list is as follows: 1. Initial evaluation of potential exposures at response sites. 2. Evaluation of exposures of limited groups of workers to specific agent(s). 3. Determination of compliance with specific recognized standards. 4. Evaluation of effectiveness of engineering controls. Procedure upon arrival at response site: 1. Draw or obtain incident layout. 2. Immediately obtain from project manager or chemist an inventory of chemicals (including soil contaminants and hazardous waste) on site. e e 3. Review Material Safety Data Sheets (MSDS) if available. 4. Review relevant toxicological and chemical information relative to above materials. 5. Obtain a list of cleanup crew members and identify specific site stresses to which workers may be exposed. 6. Determine which chemical and physical agents are to be evaluated from general inventory. 7. Estimate, if possible, the range of contaminant concentrations. 8. Review or develop, if necessary I sampling and analytical methods, paying particular attention to the limitations attendant to such methods (E.G., sensitivity, specificity). 9. Calibrate field equipment as necessary. 10. Assemble all field equipment. 11. Obtain personal protective equipment as required (hard hat, safety glasses I goggles, hearing protection, respiratory protection, safety shoes, coveralls, gloves I etc.). 12. Prepare a tentative sampling schedule. 13. Confirm field crew work schedules with supervisory personnel. 14. Advise representatives of management and labor of your presence in the area. 15. Deploy personnel monitoring or general area sampling units, if necessary. e e 16. For each sample I record the following data on P.I.C. data sheets. a. Sample identification number b. Description of sample (as detailed as possible) c. Time sampling began d. Flow rate of sample air (check frequently) e. Time sampling ended f. Any other information or observations which may be significant (E.G., process upsets, ventilation system not operating, etc). 17. Fill out P.I.C. emergency response site safety plan. e e RESPIRATORY PROTECTION PLAN P.I.C. has developed its respiratory protection plan to comply with the Occupational Health and Safety Administration (OSHA) Safety and Health standards I 29 CFR 1910.134. This plan has been developed based on 29 CFR 1910.134, 30 CFR Part II and the American National Standards Institute (ANSI) Standard 288.2, "Practices for Respiratory protection", (1980 revision). The purpose of this plan is to establish standard operating procedures (S.O.P.) to be followed by all P.I.C. employees who perform work in hazardous environments. P.I.C. provides its employees with all necessary equipment for proper respiratory protection, and P.I.C. employees use only equipment provided by P.I.C. and approved by N.I.O.S.H./M.S.H.A. S.O.P. for respiratory protection covers information needed by P.I.C. employees to properly protect themselves from airborne hazards in areas in which they are required to work. S.O.P. covers topics pertaining to: * Administration of plan * Medical examination for employees who are required to use respiratory protection e e * Selection of proper respiratory protection equipment * Training of employees on the selection, wearing, and maintenance of equipment * Fit testing of employees to equipment * Assignment of respirators - face pieces * Cleaning and disinfection * Storage of respiratory protection equipment * Inspection and maintenance * Reevaluation of respiratory protection plan to ensure its effectiveness This plan is an integral part of the C.H.S.P. Many segments of this plan are directly connected to segments of the medical surveillance and training section of the C.H.S.P. e e MEDICAL SURVEILLANCE PROGRAM Introguction The following program establishes the minimum occupational medical program requirements deemed necessary by P.I.C. and its outside Medical Toxicologist - Occupational Health Physician. The program is primarily designed to protect P.I.C. employees who are full and partial participants in the Corporate Health and Safety Plan against health hazards in their work environment. In addition, the plan assists management in evaluating placement of employees without undue hazard to the employee I or to his fellow worker. Continual medical surveillance of P.I.C. employees and their work environment assures the early detection, treatment I and rehabilitation of occupational and non-occupational health problems. The primary objective of the program is to apply preventative medical measures toward the maintenance of good physical and mental health. P.I.C. employees are encouraged to maintain their physical and mental health and are provided professional guidance and counseling, when requested I in subjects dealing with physical and mental health. e e Program Participants The Occupational Medicine Program (OMP) applies to full and partial participants in hazardous waste removal operations. Persons placed in hazardous job classifications have potential to exposure to hazardous materials during work operations. Persons performing sedentary work, with no potential for such exposures I do not participate in the medical program. Program Benefits The P.I.C. medical program provides many participant benefits; the OMP: 1. Safeguards the health and safety of employees in the work environment through the application of occupational principals of medicine. 2. Provides comprehensive assessment of the physical and mental fitness of employees to perform job assignments without undue hazard to themselves I fellow employees I or to the public at large. 3. Assures the early detection and treatment of employee illness or injury by means of scheduled periodic health evaluation. 4. Serves as an interface for improving and updating procedures for the Occupational Health and Medical Program. 5. Assists in the development and implementation of a medical emergency plan. e e 6. Provides for review and recommendations relative to medical equipment and supplies to be used by P.I.C. 7. Contributes data needed to assess existing training for P.I.C. employees. 8. Provides an overview of all physical exams I including pre-employment exams. 9. Provides for referrals to specialists, if necessary I for further testing, examination, treatment I or consultation on employee health conditions. 10. Coordinates requirements for assimilation of medical and health hazard data to the safety officer. Supportive Professional Assistance P.I.C. 's occupational medical consultant (OMC) conducts periodic visits to work sites and facilities for familiarization with employee job tasks I work site environments I and related health hazards (or potential health hazards). Such visits are coordinated with P.I.C. 's Health and Safety Officer. Periodic visits include a review of materials, processes, and procedures used with emphasis on physical, chemical, and biological hazards. The knowledge gained can form the basis for recommendations to management for corrective action directed at existing safety protocol. P.I.C. endeavors to identify locations of facilities near response job sites at which treatment for hazardous material related illness and injury is available. Few hospitals have e e decontamination capabilities, therefore I an important function of the occupational medical consultant is to identify properly equipped facilities. The consultant will convey to the nearest facility P.I.C. 's medical requirements pertaining to the health and safety of P.I.C. employees. Close cooperation and coordination between the industrial hygienist consultant and P.I.C. 's Corporate Health Officer optimize the maintenance of healthful work environments. HSO interface: P.I.C. 's health and safety officer furnishes the occupational medical consultant with full and timely information pertaining to all new hazardous physical I chemical I and biological agents encountered on project sites. Administrative Interface: P.I.C Administrative personnel check workers' compensation forms for completeness, submit such forms, and maintain OSHA logs. Administrative personnel provide lists of new employees and new terminations and coordinate assimilation of other pertinent matters such as placement problems I sick leave usage I employees injury compensation program data requirements I alcohol and drug abuse problems, etc. Administrative personnel furnish the physician with copies of injury and illness report forms when e e received to assure consistency of data in personnel I accounting I and medical records. Role of Supervisors and Project Managers The Supervisor and Project Manager Insure: 1. Review and implementation of recommendations emanating from the examining physician and/or the medical consultant pertaining to employee placement and work restrictions (such as refraining from heavy lifting, etc.). 2. The transportation and care of injured or ill employees to the nearest hospital for all life threatening accidents. For occupationally related conditions resulting from hazardous field work requiring professional medical attention, employees report to the Safety Officer for dispatch to the company physician. When the company physician treats such cases I he invoices the workers Compensation insurance carrier I as instructed, on appropriate compensation forms. 3. That employees who are away from work five (5) days or more due to injury or illness (whether job related or not) report to the Safety Officer who may require the employee to undergo a medical exam and receive clearance before restarting work. Alternatively, employees may bring a e e copy of their personal physicians return to work clearance to the safety officer who will contact the medical consultant to determine if further examination is necessary. Additional Medical Surveillance for Handling PCB's and Dioxins (TCDQ1 The objective of the placement examination is to detect employees that are unduly at risk. Such employees include individuals with a previous exposure to PCB's and TCDD including people with a history of acne I a high incident of skin disorders in the family I and people with previous reproductive disorders, or previous liver damage. Serum PCB and serum TCDD (GCMS) should be drawn to extablish base lines. Care must be taken in the selection of a qualified laboratory. If the job is for a brief period I samples may be drawn and frozen. If problems resulting from this procedure do not develop I cost related to analysis can be saved. In any event I P.I.C. recommends clients freeze a base line sample I so that when exposure to PCB's/TCDD is alleged I the base line can be reexamined and GCMS peaks compared to identify the alleged exposure. Yearly interval exams should be conducted for the purpose of detecting, at an early stage, diseases resulting from exposure or to detect other diseases that might increase potential risk due e e to PCB or TCDD exposure. Again, a complete history, physical examination, and repeat of all blood and urine tests, should be conducted. Body weight I the condition of the skin, (including pigmentation or scaly dermatitis), pattern of hair growth (especially on the shoulders) I history of headaches I fatigue, nervousness I dizziness I joint swelling I and pin prick sensation in all extremities I should be documented and reported. e e EMPLOYEE SAFETY AND HEALTH COMPLAINT PROCEDURE General Statement P.I.C. endeavors to perform all its activities in such a manner as to minimize the risk of personal injury or property damage. Employees are expected to perform their duties in a reasonable and prudent manner relative to safety. P.I.C. employees do not knowingly expose themselves to conditions that present an eminent hazard of injury or illness. Responsibilities Employees: Employees recognize there are inherent risks associated with any activity. Each employee has a responsibility to be familiar with safety and health procedures and to follow all safety regulations. In addition, all employees are encouraged to promptly inform their immediate supervisor of conditions which they believe to be unsafe or unhealthy. Project Manager e e REPORTING PROCEDURES - (Intercompany) General Statement The objective of all reporting procedures is to facilitate swift communication and efficient response. The standard flow of inter-company reporting is as follows: Employee: Project Manager: Corporate Health and Safety Officer: Corporate Health and Safety Committee. It is the responsibility of the CHSO to maintain a comprehensive file containing various reports related to health and safety. In addition, the CHSO establishes and maintains reporting procedures and acts as liaison for reports between P.I.C. employees and the Corporate Health and Safety Committee. Reports and documents include: Industrial hygiene data Employee exposure records Employee health and safety complaint procedure Acknowledgment of reading corporate documents Hazardous waste project site safety plan Hazardous waste incident report Employee health and safety classification report e . P.I.C. STANDARD SCENE MANAGEMENT PROCEDURE P.I.C. generally divides and classifies an incident scene into three (3) zones: * Exclusion (hot) * Contamination reduction (warm) * Support (cold) The exclusion zone denotes the area of maximum hazard; the contamination reduction zone surrounds and includes the exclusion zone; and the support zone is the area beyond the boundaries of the contamination reduction zone. The size and shape of the control zones are influenced by a wide range of variables, including physical and chemical properties; quantities of hazardous materials; the size, shape I and condition of the containers; the dispersion patterns of the material; existing and anticipated weather and wind conditions; and, the geographic feature surrounding the incident. Incident control zones are established by P.I.C. response personnel as soon as possible after arrival at the incident scene. Minor incidents may only require a small exclusion zone with traffic cones e e delineating control areas and emergency responders maintaining security. However I if conditions change I p.I.e. emergency responders are trained to establish all three zones. The influence of natural factors such as weather and geography will often result in irregularly shaped zones. The exclusion zone is restricted to essential personnel wearing proper protective clothing and having a specific activity to perform. A hot line is the inner perimeter of the contamination control zone. Ideally, the hot line is identified using "hazardous materials - do not enter" tape. However I other available devices such as traffic cones an/or natural or man made barricades (ditches, roads I fences I etc.) are also used. The contamination reduction zone surrounds the exclusion zone and is also a restricted area. Only essential personnel are allowed in this area and, as in the exclusion zone, entering into the contamination reduction zone is restricted to just one location. A contamination reduction corridor is at times necessary in the contamination reduction zone. The extent of decontamination is determined by the materials involved and the amount of exposure. All personnel exiting the exclusion zone must be properly decontaminated and I when necessary, leave their protective clothing in the area. All equipment being removed from the exclusion zone decontaminated or packaged and properly disposed of by p.I.e. response personnel. e e The outer perimeter of the contamination reduction zone is a contamination control line and is also appropriately marked. The support zone is utilized as a clean area beyond the outer perimeter of the contamination reduction zone where the command post and staging area are located. Although this zone is considered safe I P.I.C. prefers to keep the area restricted to emergency servic(~ personnel (keeping the public several hundred feet beyond the outer perimeter of the contamination reduction zone). Control zones provide an organized system that assists P.I.C. in properly controlling the spill cleanup and also assists government agencies in controlling the public, greatly minimizing potential for injury. e . PROJECT COST CONTROL Nearly all emergency response incidents involve rapid mitigation and disposal of hazardous waste. While incidents may be short lived in terms of duration, they often involve the services of great many lower tier subcontractors and suppliers. Accordingly, P.I.C. must accommodate cost control demands resulting from such incidents. Cost accounting and control procedures are directed by administrative personnel and implemented I on the job site, by field reponse foreman. P.I.C. maintains its records in such a manner as to provide a clear distinction between the direct cost of work performed by P.I.C. and the cost of work performed by others. Response foreman prepare work reports itemizing materials used, the names I identification, and classifications of workman I their hourly rate of pay, and the number of hours each employee performed specific types of work. Information pertaining to the size, type, identification number I and hours operated of equipment is also maintained. Material charges are substatiated by valid copies of vendors' invoices. Such invoices are submitted for billing along with daily work reports and job logs. P.I,C, administrative personnel compare subcontractor · e invoices with completed daily work reports and make any necessary adjustments. Daily work reports are submitted to P.I.C. clients (on a daily basis) and are agreed upon and signed by both parties. These reports become the basis of payment for work performed I but shall not preclude subsequent adjustment based on a later audit by P.I.C. or its client. Where payment for materials, labor, or equipment is based on the cost thereof I P.I.C. makes every reasonable effort to insure that cost records of material suppliers and subcontractors are open to inspection and audit by representatives of P.I.C. 's client on the same terms and conditions as the cost records of P.I.C. are open to P.I.C. 's client. Each subcontractor dispatched to a project is issued a Purchase Order number attendant to the project. Upon arrival at the project site, the subcontractor is logged. The time of his arrival I the type equipment or service offered, the names of personnel sent, and the nature of work to be performed by the subcontractor is noted. All work performed by subcontractors is directed by project foreman or their designee. Any problem encountered by the subcontractor in performance of his work is noted. The same general procedure is used with regard to all personnel dispatched to an incident. All such information is communicated to the home office on a daily basis for computer input. Job cost control reports are generated from such data and I subsequently, communicated to project managers. Upon e e completion of his work, each contractor, or agent of the contractor, submits to the project foreman for signature an invoice depicting the type of equipment or service furnished I a brief description of work performed I and the number of hours each day the service, or work, was performed. When the subcontractor or supplier's final invoice is submitted to P.I.C. for payment I the invoice is compared with the signed job site invoice and the daily work record. If consistent I a copy of each is submitted to P.I.C. 's client along with the general billing for all work performed under the contract. Imagination and hard work by all personnel are encouraged. Suggestions from response personnel I subcontract personnel, and technical support personnel I directed toward the cost effective performance of the work assist project foreman in evaluating the cost effectiveness of the work plan. Control of cost is accomplished through implementation of accounting protocol I while cost effectiveness is largely a function of the judgment I skill I and coordination of project foreman, response personnel I and other persons associated with a project. e e STANDARD WORK PROCEDURES Standard work procedures at any work site require a minimum of two (2) safety briefings per day from P.I.C. 's industrial hygienist I program manager I or foreman to work crews. Specifically, a tailgate safety meeting covers the day's activities, potential hazards (eg. heat prostation and respiratory protection) and other pertinent matters. A safety briefing is conducted prior to the start of each work shift. At any time a safety deficiency or procedural discrepancy is observed during the work day, dependent upon its seriousness I the deficiency or discrepancy noted will be either corrected immediately as work proceeds I or all work will be stopped until corrective measures can be taken. At the end of each work shift, a safety debriefing is held in which input is requested from all team members and obervers. Observations relative to the day's activities are discussed. Recommendations I changes I etc. I are considered at this time. It is P.I.C. IS policy to ask all agencies involved to participate in this debriefing. It is the responsibility of the Project Manager or Corporate Safety Officer to insure that any deviation from this policy is immediately corrected. e e As projects progress, situations may arise not addressed specifically in P.I.C. 's Corporate Health and Safety Plan or in P.I.C. training programs. The P.I.C. Project Manager I with his experience and background I is responsible for developing specific safety protocol to deal with these situations as they arise. Standard Operating procedures are needed for all phases of operations in spill clean up and each phase should include health and safety options. These procedures are dependent upon the type of work involved and, therefore I are adapted or modified to meet site specific requirements. e e DISPOSAL Disposal of hazardous substances is an important aspect of a hazardous material clean up. The liability associated with improper disposal of hazardous substances is substantial. Billions of dollars are presently being extracted from private industry for cleanup of hazardous waste placed I according to regulations operative at the time I in facilities ill-equipped to handle such wastes. Generally, if it has been demonstrated that prior disposal of hazardous chemicals at a disposal site remains acceptable, any additional similar waste should not cause a problem provided that the site's capacity is not overloaded. This is particularly true regarding deposition of small quantities of hazardous waste. However I the problem becomes complex if the chemical in question is not normally landfilled as waste. Substances I such as water soluble toxics, the behavior of which cannot be predicted I should clearly be disposed in a containment (class 1) site. Only in exceptional circumstances is land burial of hazardous materials at the source of the spillage recommended. Normally, e . there simply is not time to throughly investigate local hydrogeology I and, even if satisfactory, the site may be inadvertently exhumed at a later date. Disposal of hazardous waste in accordance with State and Federal regulations has proven to be only a minimum criteria necessary to minimize the future liability of the generator. Evaluation of disposal alternatives must include a comprehensive review of documentation associated with prospective disposal sites. · e IV GOVERNMENT PERMIT~1 LICENSES & LIABILITY INSURANCE P.I.C. currently holds the following permits and licenses: * E.P.A. Registration No. CAD065621088 * state of California Waste Hauler Permit Nos.: 1398, 52081, 57230, 57048, 56160, 56787, and 50095 * State of California General Engineering Contractor No. 463254 in the name of S. T. Environmental Corporation (d.b.a. Positive Incident Control) Liabi!ity Ins'l!~ç,~ P.I.C. provides the following minimum insurance coverage: Comprehensive Public Liability insurance including bodily injury liability, property damage liability, and automobile bodily injury each in the amount of $1,000,000 per person and property insurance in the amount of $1,000,000 per occurrence. Copies of such coverage I naming P.I.C. clients as additional insured I are available upon request. e e V TYPES OF SPILL EQUIPMENT OWNED BY POSITIVE INCIDENT CONTROL Positive Incident Control owns and maintains emergency response spill equipment generally described as follows: * Respiratory Equipment * Protective Clothing (Hand « Foot) * Eye I Ear, and Head Protection * Extraction Equipment * Miscellaneous Safety Equipment * Chemical Analysis Equipment * Chemicals (Lab) * Absorbing and Neutralizing Equipment * Testing and Monitoring Instruments * Vehicle Support Equipment * Containers * Pumps * Hand Tools * Miscellaneous Support Equipment * Power Equipment * Library All heavy equipment, including vacuum trucks, loaders, e e excavators I etc. are provided to PIC by subcontractors specializing in operation of such equipment. For costs attendant to material and equipment supplied by PIC and by others please see Section VIII herein. As stated previously, P.I.C. currently maintains five (5) fully equipped response units at response facilities located in Redding I Hayward I Bakersfield I the China Lake Naval Weapons Center, and Riverside. Each such response vehicle, at a minimum I contains: 1. Fully encapsulated Butyl rubber environmental suits; 2. PVC and Neoprene calf-length steel toed ANSI approved boots; 3. Vinyl I Neoprene I PVC, Nytral and Viton gloves; 4. Two (2) or more positive pressure type self-contained breathing apparatuses of the 30 minute variety; 5. Spare bottles supported by a cascade charging system capable of recharging 30 minute bottles or serving as a primary air supply for positive pressure line breathers; e e 6. Full face cartridge respirators supported by a wide variety of cartridges; (only full face respirators are used by P.I.C. because of the eye and face protection afforded); 7. Fogless soft goggles I hard hats, and ear plugs; 8. Protective suits including Tyvek, Vinyl I Saranex, Poly coated Tyvek, PVC, Neoprene and Butyl rubber; 9. A full complement of bonding and grounding equipment accompanied by an assortment of small tools; 10. Direct reading instruments capable of monitoring explosibility, oxygen availability, radio activity, organic vapor, and a wide variety of gases; 11. A portable wet laboratory supporting hazard analysis; 12. Fingerprinting chemicals; 13. A fifteen gallon partable shower and eye wash; 14. An extensive library including CFR 49, CFR 33, Title 22 excerpts, Farm Chemical Handbook, CHRIS MANUAL I etc. ~ ----- . . VI ABILITY TO RESPOND IN REMOTE AR~AS. PIC responds to remote area spill incidents in accordance with the level of response necessary to deal with the specific hazardous material release. However, while methods utilized in dealing with a remote area spill are the consequence of site specific conditions, PIC can respond to remote area spills via the following modes of response transportation: * Fixed wing aircraft * Helicopter * Fourwheel drive vehicle * Horse or mule * On foot * Conventional Vehicle