3.0 ACCIDENT PREVENTION PLAN
Safety and accident prevention are the project's highest priority. All activities are to be conducted in a manner that minimizes the probability of incidents, accidents, injuries, or illnesses. Work that cannot be performed in a safe manner shall not be attempted.
3.1 Description of Work
3.1.1 Activity 1, Site Preparation
Task includes mobilization and staging of equipment, installation of erosion control measures, upgrading the site access, preparing a container filling area, construction of support area pad, and energizing of all trailers. Activities required to accomplish site preparation include the following:
· Travel to/at project site
· Unload equipment
· Setting up trailers
· Construct filling area
· Install select drainage swales and silt fence
· Construct support facilities
· Improve haul road
· Install fence and signs.
3.1.2 Activity 2, Radiological Survey
This task includes three types of surveys: characterization, boundary, and remediation control. These surveys will be used to determine the extent and magnitude of contamination as well as the effectiveness of the excavation efforts.
3.1.3 Activity 3, Shelter 204 Demolition
This task includes the operation of heavy equipment, cleaning of contaminated surfaces, dismantlement of contaminated portions of Shelter 204, loading of material into transportation containers, and removal of sand from launch pit.
3.1.4 Activity 4, Excavation of Soils
This task includes the operation of heavy equipment, excavating soil from the contaminated area, filling containers with contaminated soil. Placing of the clean soil in a spoils pile, survey of the soil from the excavation site to determine the activity (<8pCi/g or >8 pCi/g.). Radiological surveying of the containers with the contaminated soil, and any of the vehicles that are leaving the radiologically controlled area. Using engineering controls for dust control; such as spraying water on the excavation area. Activities required to accomplish the excavation task include the following:
· Use of heavy equipment
· Load dump trucks to transport soil
· Fill intermodal containers
· Decontamination of equipment.
3.1.5 Activity 5, Transport of Intermodal Containers
This task involves the use of a forklift or crane to load the collapsible intermodal containers onto flat bed trucks. After the intermodal containers are loaded they will be transported off-site.
3.1.6 Activity 6, Final Status Survey
This task will be conducted after completion of the remedial efforts to demonstrate that all radiological parameters satisfy the established guideline values.
3.1.7 Activity 7, Site Restoration and Removal of Support Facilities
Following Air Force approval of the Final Status Survey results for the area, the clean soil can be returned to the excavation. The top soil will be revegetated with an appropriate seed mixture in order to return the area in to a natural condition. The seed mixture will be covered to prevent wind dispersal and promote germination. Fencing, fence posts, and support facilities and equipment will then be removed.
3.1.8 Activity 8, Demobilization
Upon completion of site restoration activities, a final site walk through will be conducted with the IOC and their representatives. After approval of the site conditions, all equipment, materials, and temporary facilities will be removed from the site
3.2 Indoctrination of New Employees
Personnel are required to attend a safety orientation meeting prior to working on-site. These orientation meetings are documented and kept on file on-site. Refer to Section 8.4, Site Specific General Employee Training, for an outline of the information that is conveyed to all personnel.
3.3 Fire Prevention and Protection
This section details fire prevention and protection procedures/resources at the project:
· The local Volunteer Fire Department and McGuire AFB Fire Department are available for fire fighting service. Prior to the start of any field activities, training of the primary responder will be conducted to inform these responders to the site specific hazards.
· There are fire extinguishers mounted on all heavy equipment, as well as in site support controlled facilities.
· Hot Work Permits are required before flame or spark-producing activity is to commence. Refer to Section 4.4.3, Fires, Explosions, and Hot Work.
· Grass and shrubs in vehicle traveled areas will be mowed.
· Flammable and oxidizing materials are to be stored in marked (No Smoking) areas with fire extinguishers available.
· Smoking will only be allowed in designated areas
· Periodic site walkdowns will be performed by the PM or designee to assess potential fire conditions.
Only properly trained project personnel are permitted to extinguish fires in their incipient stages. Fighting fires is prohibited by project personnel and shall only be performed by the designated fire department. Refer to Section 10.5, Fire Control.
3.4 Housekeeping
Housekeeping shall be a priority at the project site. The following provisions are in place to maintain housekeeping at a high standard:
· The importance of housekeeping and the expectations that good housekeeping shall be maintained will be regular topics of the morning safety meetings.
· Job sites shall be cleaned up on a daily basis.
· Subcontractors shall be informed of their responsibilities to maintain their housekeeping.
· Dumpsters and adequate trash receptacles are positioned at several locations and are to be regularly emptied. Contaminated trash must be segregated from sanitary trash for proper disposal. Hazardous waste containers shall be labeled according to RCRA regulations.
· Housekeeping is an operational/safety item which is regularly considered during routine inspections.
· Nails shall be removed from scrap lumber immediately.
· Non-contaminated facilities are to be swept on a weekly basis.
3.5 Health and Safety Inspections
As a minimum, weekly safety inspections of the site shall be conducted with the PM or CM, CHP and an employee in attendance. These walkdown inspections will be documented and given to the QA Officer to file on-site. Deficiencies will be tracked for occurrence frequency and correction. As many deficiencies as possible shall be corrected on the spot.
All heavy equipment shall be inspected by the operators prior to use on the project and shall then be inspected on a daily basis. Daily inspections of all heavy equipment shall be documented.
All inspection documentation shall note deficiencies and be submitted to the CHP. Deficiencies shall be corrected in a timely manner. If during any inspection or walkdown (formal or informal), a deficiency is noted that could cause injury, loss of life, damage to equipment or property or harm to the environment, associated work shall be stopped and the deficiency corrected before activities can continue.
All inspection records are to be kept on file in the field office.
Lifting equipment (cranes) require annual certified inspections and documentation by an independent inspector prior to starting any work on-site.
3.6 First Aid and Medical Facilities
The following addresses first aid and medical facilities:
A first aid kit is provided and maintained in the project office trailer. There shall be a first aid kit available in each zone access support area trailer, the container filling area, railcar loading area, and exclusion zone access control point. An ear thermometer will be available in the Contamination Reduction Zone.
Emergency phone numbers are posted at all site controlled telephones and shall be available in all project vehicles, and are included in this HASP.
The route to emergency medical facilities is posted in the project office trailer and in Appendix G Drawing 799147-B2. However, the facility to care for serious medical emergencies shall be determined by those responding to the incident.
At a minimum, two on-site employees shall be certified in First Aid and Cardio Pulmonary Resuscitation (CPR) by the American Red Cross.
3.7 Sanitation
The following provisions will be made to address sanitation:
· Portable toilets will be provided, as necessary, at locations around the project. Arrangements will be made for the routine servicing and cleaning of these units.
· Safe drinking water is provided at the project office trailer and provisions will be made as necessary to provide safe drinking water at individual field locations. Disposable sanitary cups will be provided along with receptacles for their disposal. All outlets dispensing non-potable water will be posted with appropriate warning signs. Systems furnishing non-potable water and systems furnishing potable water will be constructed to remain completely independent of each other.
· Permanent washing facilities are provided in the project change trailer.
3.8 Safety Promotions
The following methods for promoting accident prevention will be enacted:
· Accident prevention will be a regular topic discussed at safety meetings.
· All personnel will be encouraged to sign a Zero Accident Pledge poster which is to be posted in the project office trailer.
· Accident prevention videos will be shown occasionally at safety meetings.
· An Employee Safety Council (Safety Committee) will be established.
3.9 General Work Rules
While all the procedures outlined in this HASP are required, the following list presents general work rules, which will be enforced by the PM, CM, CHP, and Subcontractor Supervisors:
· The minimum PPE requirements include long pants, hard hat, safety glasses and safety shoes unless specifically changed on applicable work permits.
· Employees are not allowed on-site without the prior knowledge and consent of the CM or CHP.
· Loose jewelry, clothing, or long hair is not permitted on or near equipment with moving parts.
· Personnel shall not enter a restricted area unless authorized.
· Whenever possible, avoid contact with contaminated (or potentially contaminated) surfaces. Walk around (not through) puddles and discolored surfaces. Do not kneel or set equipment on potentially contaminated ground.
· All regulated work zones, as established at the project, shall be controlled and observed. Entry into a contaminant reduction zone (CRZ), Contamination Area, Radiation Area, and Exclusion Zone (EZ) shall be by prior notification and authorization of the CM or CHP. All required Personal Protective Equipment (PPE) shall be worn prior to entering these zones.
· Contaminated equipment and PPE, such as respirators, gloves, boots, etc. (if not discarded) shall not be removed from the CRZ until they have been properly cleaned and surveyed.
· Legible and understandable labels shall be affixed prominently to the containers of waste materials.
· Food, beverages, unapplied cosmetics, and tobacco products are not allowed in regulated work zones. These are only allowed in designated areas of the Support Zone.
· Beards, facial hair, or other facial obstructions that interfere with respirator fit will preclude admission to the EZ when respirators are required.
· Field personnel are to observe each other for signs and symptoms of toxic material exposures. These signs and symptoms include, but are not limited to:
- Changes in complexion and skin color
- Changes in coordination
- Changes in demeanor
- Excessive salivation and papillary response
- Changes in speech pattern.
· Any detected effects of toxic exposure shall be reported to the CHP immediately.
· An emergency eyewash unit shall be located immediately adjacent to employees who handle hazardous or corrosive materials. All operations involving the potential for eye injury, splash, etc., must have eye wash units locally available capable of delivering at least 0.4 gallons per minute for at least 15 minutes.
· If on-site activities, including decontamination, continue later than dusk, adequate lighting must be provided.
· Field activities will be suspended during severe weather such as thunderstorms, lightning, tornado warnings, and winter storm warnings.
· Damaged PPE or clothing will be immediately repaired or replaced, as appropriate.
· Personnel must thoroughly wash their hands and face before eating, smoking, or drinking.
· Unauthorized removal of materials from the project-site is prohibited.
· Possession of controlled substances and prohibited items, such as alcohol, firearms, weapons while working on-site is strictly prohibited.
· Operations involving the potential for fire hazards shall be conducted in a manner as to minimize the risk of fire.
· Overhead and underground utility hazards shall be identified and/or located prior to conducting operations.
3.10 Buddy System
The "buddy system" will be used at all times while in an EZ/Contamination Area/Radiation Control Area - this requires that personnel maintain visual, voice, or radio communication.
3.11 Site Control and Work Zones
The purpose of site control is to minimize potential radiological and chemical exposures to workers, protect the public from hazards due to project activities, and prevent vandalism. The work areas that pose radiological, chemical, and physical hazards to personnel may be regarded as regulated or restricted. To prevent both exposure to unprotected personnel and migration of contamination due to tracking by personnel or equipment, work areas known to contain radioactive and/or chemical contamination will be clearly identified.
Work at the BOMARC Missile Site Plutonium Remediation Project will be performed and controlled under a Radiation Protection Plan (RPP) as required by 10 CFR 20.1101. The RPP is found in Appendix B of the Site Operations Work Plan.
Work zones will be designated at the project as required by 10 CFR 20 Subpart J, specifically 1901 "Caution Signs," 1902, "Posting Requirements," and 1904 "Labeling of Containers." Work areas where radioactively contaminated soils are being excavated, stored, or loaded for transport or disposal will be posted as a Contaminated Area. If dose rates exceed 5 millirem per hour (mrem/hr) at 30 cm from the in-place or excavated soil the area will also be posted as a Radiation Area. If airborne contamination exceeds 30% of the applicable derived air concentration (DAC): gross alpha 3 x10E -12, or Pu-239 3 x 10E -12 µCi/cc as found in 10 CFR 20 Appendix B, Table 1, Column 3, the area shall be posted as an Airborne Radioactivity Area. Areas where radioactive materials are stored or used in excess of the limits found in 10 CFR 20, Appendix C shall be posted as a Radioactive Materials area. Drummed PPE or other radioactively contaminated materials will be labeled as required in 10 CFR 20.1904.
Entrance to posted Contamination Areas or Radiation Areas will be through designated entry ways. For personnel, these entry areas will be noted as a CRZ, where PPE will be doffed as the worker leaves the contaminated area. For large equipment, an equivalent CRZ will be designated.
An NRC Form 3 "Notice to Employees," shall be posted in the break area trailer.
If chemical contamination exists, work zones will be divided, as suggested in Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities, NIOSH/OSHA/United States Coast Guard (USCG)/USEPA, November 1985 into three zones: EZ, CRZ, and Support Zone.
A map of the remediation area shall be posted in a location for ready review by all personnel on-site. The map as a minimum, shall indicate the following:
· Exclusion Zone Boundaries
· Buffer Zone
· Points of Ingress/Egress Personnel and Vehicles/Equipment
· Safety Equipment
· Decon Facilities
For work areas which have both radiological and chemical contamination, the restricted area(s) will be designated accordingly.
3.11.1 Exclusion Zone
The EZ is, in general, the area where chemical, physical, or other hazards occur/exist during project work. All employees are required to follow established procedures, such as wearing the proper PPE, when working in these areas. The location of the EZ will be identified by fencing or other appropriate means. An entry log is kept daily which records the time of entry and exit from the EZ for each person. Unauthorized personnel will not be allowed in these areas. An EZ may also be identified by radiological postings.
3.11.2 Contamination Reduction Zone
Personnel and equipment decontamination will be performed in the CRZ. All personnel and small equipment entering or leaving the EZ will pass through the CRZ in order to prevent cross-contamination and for the purpose of accountability. Personal protective equipment will be removed in the CRZ, cleaned, and properly stored or disposed of. Drums for handling radioactively contaminated trash and reusable PPE shall be maintained in the CRZ. Each drum will be labeled as to the appropriate contents of the drum. All water generated from equipment and personnel decontamination will be contained on-site and disposed of in an appropriate manner.
At each CRZ, appropriate monitoring equipment shall be available for personnel to frisk themselves for the presence of radioactive contamination prior to their leaving the CRZ. Note: if site background radiation precludes performing a frisk, that is the instrument background is high (>300 cpm), the frisking station can be moved from the CRZ to a low background area. In this case, the worker will exit the CRZ and go directly to the frisking station.
For large equipment, an equivalent CRZ will be designated where the equipment will be monitored by an HPT for radioactive contamination, and decontaminated as required, prior to leaving a Contaminated Area.
3.11.3 Support Zone
The Support Zone, or clean zone, will be the area outside the posted radiological area, EZ, and CRZ and within the geographic perimeters of the site. The Support Zone is used for staging of materials, parking of vehicles, office facilities, sanitation facilities, and receipt of deliveries. Eating, drinking, and smoking will be allowed only in designated areas of the Support Zone.
3.11.4 Emergency Entry and Exit
During an emergency, personnel will evacuate to a pre-determined location at the site. If conditions such as wind direction or physical hazards do not allow access to the prescribed evacuation routes, personnel are to evacuate by the safest means available. If possible, personnel should doff their PPE in the CRZ when leaving the area. However, if this is not possible, personnel should exit to the rally point. At the rally point, the remaining PPE can be doffed and personnel frisked for contamination. Normal ingress and egress locations are depicited on the site map.
3.11.5 Site Entry Requirements
In order to allow an individual into regulated areas of the site (Contaminated Area and/or Radiation Area, CRZ, and EZ) they must meet the following requirements:
· Documentation of completing training requirements as described in Section 8.4 (including review of this HASP and signing off as such)
· Documentation of completing medical surveillance requirements.
· Respiratory fit testing as necessary (Section 5.1)
· Attend the project-site orientation session
· Review the specific AHA
· Obtain authorization from CHP
· Don the appropriate PPE
· Sign the Radiation Work Permit
· Sign the site entry log.
All work within a Contamination or Radiation Area shall be performed as required by a Radiation Work Permit.
3.11.6 Site Posting
Appropriate warning signs will be strategically placed where people enter an EZ, radiologically posted areas, CRZ, and at other locations where personnel may approach the area. Typically, signs shall be placed a maximum distance of 100 feet apart at all four sides of a posted area.
Signs shall be consistent with the potential radiological hazards, contamination or radiation, and shall use the colors magenta and yellow or black and yellow. The universal trefoil symbol for radioactivity or radiation shall be used on all postings and labels. If warning rope is used to identify radiologically posted boundaries, it shall be magenta and yellow. In addition, the following posting may be present: "Danger-Authorized Personnel Only, Personal Protective Equipment Required Beyond This Point" or similar. Signs may be more hazard specific as necessary. Additional warning signs may be posted at the perimeter of the site.
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