4.0 Project Hazards and Hazard Control Measures
There are numerous radiological, chemical, physical, and environmental hazards potentially present at the project. These hazards, if not properly controlled, can cause harm to project personnel, visitors, and the public. The anticipated hazards at the project and the recommended control measures are presented in this section.
4.1 Activity Hazard Analysis
Activity Hazard Analyses (AHA) identify potential safety, health, and environmental hazards associated with specific tasks and provide protective measures for personnel, the community and the environment.
Project members will develop an AHA before beginning activities at new work or site areas. Once developed, the AHA's will be reviewed and approved by the CHP, and CM (with input from field employees and subcontractors).
An AHA shall also be prepared when new tasks are added, job situations change, or when it becomes necessary to alter safety requirements. Work will not proceed on a particular task/work area until the AHA has been reviewed and a preparatory meeting has been conducted. The preparatory meeting will be conducted, with the CHP in attendance, to discuss its contents with all personnel engaged in the activity. Attachment A contains the AHAs completed to date. As work is expanded and progresses to other work or site areas, completed (developed and reviewed) AHAs shall be added to Attachment A.
4.2 Chemical Hazards
Historical information indicate the presence of organics and metals in the soil and groundwater. This section provides an overview of the chemical contaminants of concern detected in the proposed work areas and an assessment of the chemical hazards associated with each chemical of concern.
There is potential for exposure to personnel through all routes (dermal contact, inhalation, ingestion, injection). Controls have been specified in this HASP to reduce the risk of these potential exposures.
Relevant information for the chemicals of concern is detailed below. For review, a brief definition of important terms are also provided below:
· Threshold Limit Value (TLV). Airborne concentrations of substances, generally expressed as an eight-hour time weighted average (TWA) and represent conditions under which it is believed that nearly all workers may be repeatedly exposed day after day for a 40-hour work week without adverse health effects. TLVs are guidelines for occupational exposures established by the American Conference of Governmental Industrial Hygienists (ACGIH) (1998).
· Recommended Exposure Limit. The up to ten-hour per workday, TWA exposure limits recommended by the National Institute of Occupational Safety and Health (NIOSH).
· Immediately Dangerous to Life or Health (IDLH). Concentration which poses an immediate threat to life or produces irreversible, immediate debilitating effects on health (American National Standards Institute). NIOSH defines IDLH as, air concentrations which represent the maximum concentration from which, in the event of respirator failure, one could escape within 30 minutes without a respirator and without experiencing any escape-impairing or irreversible health effects.
· Permissible Exposure Limit (PEL). The 8-hour TWA, short term exposure limit (STEL) or ceiling concentration above which workers cannot be exposed. Enforceable standards by OSHA.
4.2.1 Inorganic Chemicals
Various inorganic chemicals, specifically metals, have been identified as being potentially present at the BORMAC site. The metals are considered toxic and some are identified as being carcinogenic.
· Lead. Lead was present in soils located inside the shelter 204 launch bay. Exposure to lead targets the eyes, gastrointestinal tract, central nervous system, kidneys, blood, and gums (lead line). Symptoms of exposure include weakness, lassitude, insomnia, constipation, abdominal pain, colic, anemia, hypertension, anorexia, low body weight, visible lead lines on gingival tissue (gums), malnutrition, pallor, tremors, and paralysis of the wrist/ankles. (PEL: 0.050 mg/m3; IDLH: 100 mg/m3; TLV: 0.05 mg/m3.) TLV Basis - Critical Effect(s): Central Nervous System (CNS); GI; blood; kidney; reproductive.
· Plutonium. Plutonium is a toxic metal produced when uranium absorbs neutrons. As an alpha emitter, nearly all energy from plutonium is deposited on the outer, nonliving layer of skin causing no damage. If inhaled or ingested, plutonium may deposit in the bones and liver increasing an individual's cancer risk.
4.2.2 Organic Compounds
Several organic compounds (volatile and semi-volatile) were identified as contaminants in the soils and waters. All of these organic chemicals are considered toxic and some are identified as being carcinogenic. Information about the organic chemical contaminants present is summarized in this section. Additional information about these organic chemicals can be found in the Material Safety Data Sheets (MSDS) kept on-site. A listing of the available MSDSs will be maintained at the health and safety field office.
· Polycyclic aromatic hydrocarbons (PAH) are a group of semi-volatile organics that are rather persistent in the environment. Some PAHs are carcinogenic with inhalation as the primary exposure route. The greatest carcinogenic effect is at the point of contact (i.e., lungs, skin, stomach). Skin disorders may also result due to high concentration exposures. Exposure limits have not been established for many specific PAHs in this large group of compounds. (PEL: 0.2 mg/m3 - chrysene.)
4.2.3 Operational Chemicals/Hazard Communication Program
Hazardous chemicals will be brought to the project-site for use in activities supporting the planned work. These chemicals are used for fuels in operating heavy equipment, glues for welding pipes, painting, etc. The use of operational chemicals is regulated by OSHA under the Hazard Communication Standard (29 CFR 1910.1200). Air monitoring will be performed as needed to assess exposures resulting from their use. MSDSs for operational chemicals are kept on file in the project office trailer. An inventory list of the anticipated operational/laboratory chemicals (Hazardous Chemical Inventory List) for use at the BOMARC project is maintained at the Project office trailer. If any additional products are used during field activities, MSDSs for these products will be obtained at the time of procurement.
4.3 Radiological Hazards
The principle radioactive contaminant of concern (COC) is Pu-239/240. The site became contaminated following a fire that resulted in the melting of a nuclear warhead. Alpha emissions were detected in concentrations in excess of two million counts per minute inside the shelter following the fire. Surface contamination was also detected outside the shelter along the concrete apron.
The radioactive emissions given off during radioactive decay of Pu-239/240 and progeny are alpha beta and gamma.
Alpha particles are an internal radiation hazard. Since alpha particles are stopped by the outer dead layer of the skin. However, if the alpha source is inside the body, the particle's energy may be deposited in the living tissue.
Beta particles are considered an external and internal radiation hazard. The energy of the beta particles can be deposited externally in the skin, or internally if the radioactive material gets inside the body.
Gamma-rays typically cause whole body irradiation and are considered an external hazard.
CNS Radiation Protection Procedure will be followed throughout this project. This will include an as low as reasonably achievable (ALARA) program.
4.4 Physical Hazards
There are numerous physical hazards associated with project operations that require consideration. Some of these physical hazards are as follows:
· Noise
· Slips, trips, and falls
· Fires, explosions, and hot work
· Use of ladders and scaffolding
· Use of small tools
· Use of heavy and mechanized equipment
· Operation of motor vehicles
· Materials handling
· Hazardous energies (electrical, mechanical, pressure)
· Demolition
· Excavation
· Confined space entry
· Dust
· Workplace Reproductive Hazards
4.4.1 Noise and Hearing Conservation
There are many sources of noise at the project-site. This noise is primarily from the use of heavy equipment and tools. Hearing loss, resulting from occupational exposure to noise, can be prevented. A hearing conservation program will be implemented at the project. As part of the criteria for the medical surveillance program, audiometric testing is conducted annually. The CHP will conduct noise surveys, as necessary, to determine if engineering controls should be implemented and/or if hearing protection is adequate. As noise monitoring indicates, hearing protection will be worn by personnel working with or around heavy equipment and power tools. Warning signs shall be posted in areas where noise (>85 dB) necessitates the use of hearing protection.
4.4.2 Slips, Trips, Falls
The following details procedures to prevent slips, trips, and falls:
· Personnel shall keep working areas clean and orderly. Tools, equipment, and materials shall be used and stored in a fashion to minimize tripping hazards.
· Small, loose items such as tools, materials, and other small objects and debris shall not be left lying around in any place, particularly in areas where personnel walk.
· Walkways shall be kept free of obstacles. Openings in walkways shall be repaired immediately, if possible. If not immediately repaired, the section must be roped off or closed until repairs can be made.
· Spills shall be cleaned up immediately.
· Personnel shall take extra precautions, such as establishing firm hand holds, wearing suitable footwear, and walking slowly when walking or working during wet, snowy, or icy weather.
· Personnel shall not jump from elevated places or equipment.
· Personnel using hand and mechanical tools shall position themselves properly and consider the events if a tool slips or suddenly moves.
· Personnel shall not walk or climb on piping, valves, fittings or any other equipment not designed as walking surfaces.
· Stairways, walkovers, or ramps shall be installed where personnel must walk or step over equipment in the course of their normal duties.
· Electrical extension cords and electrical wiring must be kept clear of walking and working areas and/or covered, buried, or otherwise secured.
· Walking and working surfaces shall be properly maintained during inclement winter weather.
· Running is prohibited on job sites unless under emergency conditions.
· Elevated work, where a fall potential exists, shall be performed using appropriate ladders and/or fall protection (i.e., full body harness and lanyard, or guardrails). No employee may be exposed to a fall of over 6 feet without being adequately protected.
4.4.3 Fires, Explosions, and Hot Work
Hot work (welding, burning, cutting, etc.) conducted on-site must comply with the following requirements:
· The CHP will establish areas approved for welding, cutting, and other hot work.
· A Hot Work Permit shall be obtained from the CHP, if required.
· The CHP is responsible for authorizing welding, cutting, and other hot work in areas not specifically designed or approved for such operations.
· All personnel shall be protected from welding radiation, flashes, sparks, molten metal, and slag.
· All welding, burning, and cutting equipment shall be inspected daily by the operator. Defective equipment shall be tagged and removed from service, replaced or repaired, and reinspected before again being placed in service.
· All welders, cutters, and their supervisors shall be properly trained in the safe operation of their equipment, safe welding/cutting practices, and welding/cutting respiratory and fire protection.
· The handling of compressed gas cylinders will comply with the requirements established in Step 4.4.9.
· Cutting, welding, or other hot work shall be permitted only in areas that are or have been made firesafe.
· Cutting or welding shall NOT be permitted in the following situations:
- In areas not authorized by the CHP.
- In the presence of explosive atmospheres (mixtures of flammable gases, vapors, liquids, or dusts with air), or explosive atmospheres that may develop inside uncleaned or improperly prepared drums, tanks, or other containers, and equipment which has previously contained such materials.
- In any area where Combustible Gas Indicator (CGI) readings are in excess of ten percent of the Lower Explosive Limit (LEL).
- On storage or process vessels or lines in service which contain flammable or combustible liquids, gases, vapors, or solids.
· Before any welding, cutting, or other hot work is permitted, the area shall be inspected by the CHP to verify that the following requirements have been met:
- Cutting and welding equipment to be used shall be in safe operating condition and in good repair.
- Where practical, all combustible material shall be relocated at least 35 feet away from the hot work site. Where relocation is impractical, combustibles shall be protected with flame-proofed covers or otherwise shielded.
- At a minimum, two fully charged and operable fire extinguishers, appropriate for the type of possible fire (10- A:B:C), shall be available at the work area.
- A fire watch shall be required whenever hot work is performed and a minimum of 30 minutes after hot work is complete.
- Evaluation by the CHP is performed to assure the work area is free of combustible gases and vapors.
- The work area is free of toxic contaminants at concentrations in excess of established threshold limit values or all personnel who will work in the area have been provided respiratory protection and protective apparel appropriate for the degree of exposure.
- When hot work is to be performed on tanks or other vessels that contain or have contained flammable or combustible liquids, the vessel shall be properly isolated, purged, cleaned, or inerted as appropriate, to reduce the concentrations of flammable/combustible vapors to safe levels.
- A hot work permit will be completed by the CHP (if required), reviewed with personnel who will perform the hot work, and posted near the job site.
- The hot work permit is good only for the date issued and is valid only for the eight-hour shift for which it is issued.
- If at any time during the hot work operation a change in conditions at the work site is suspected, such as a release of flammable gases or vapors in the work area, work shall be stopped immediately and the CHP shall be notified. Such work stoppage invalidates the hot work permit, and a new permit shall be completed after inspections and tests have been performed by the CHP.
- No erasures or changes of dates on hot work permits shall be permitted.
4.4.4 Use of Ladders and Scaffolds
Ladders and scaffolding shall only be used at the project under the following conditions:
· Ladder use shall comply with 29 CFR 1926.105.
· Scaffold erection and use shall comply with all applicable USACE requirements and OSHA regulations. A trained competent person shall supervise all scaffold erection and use.
4.4.5 Use of Small Tools
Hand and power tools will be used, inspected, and maintained in accordance with the manufacturer's instructions and recommendations and will be used only for the purpose for which designed. A copy of the manufacturer's instructions and recommendations will be maintained at the project site. The following requirements will be adhered to:
· Tools designed to accommodate guards will be equipped with such guards when in use.
· Tools will be inspected before each use to verify safe operating condition and be kept clean and free of accumulated dirt.
· Electric power tools and extension cords shall be used with Ground Fault Circuit Interrupters (GFCI) circuits.
· Portable power cords will be designated as hard usage or extra hard usage and shall not be used if damaged, patched, oil-soaked, worn, or frayed.
· Connections on pneumatic lines shall be secured with safety lashing.
· Pressure shall be shut off and exhausted from the line before disconnecting the line from any tool or connection.
· Safety clips or retainers shall be installed and on pneumatic impact tools to prevent dies and tools from being accidentally expelled from the barrel.
· Hand tools that may be utilized by field and drill crews, such as hammers and chisels, shall be inspected and dressed if necessary to remove mushroomed heads, which may separate and become projectile hazards.
· Explosive-activated tools will meet the design requirements of ANSI A10.3 and only be operated by a qualified operator.
· Explosive-activated tools and charges will be secured at all times to prevent unauthorized possession or use.
· Explosive-activated tools will not be loaded until just prior to the intended firing time; neither loaded nor empty tools are to be pointed at any employees; hands will be kept clear of the open barrel end.
4.4.6 Use of Heavy and Mechanized Equipment
There are various types of heavy construction, such as excavators, hoe rams, mechanical shears, front end loaders, and other equipment that will be used during the execution of this project. All operators of this equipment must be familiar with the requirements for inspection and operation of the equipment they will be using. Before equipment is placed into use, it will be inspected by the operator to verify that it is in safe operating condition. The following guidelines will be adhered to while operating heavy construction equipment:
· Equipment will not be operated in a manner that will endanger persons or property nor will the safe operating speeds or loads be exceeded.
· Getting off or on any equipment while it is in motion is prohibited.
· Equipment will be operated in accordance with the manufacturer's instructions and recommendations
· Determinations of road conditions and structures will be made in advance to verify that clearances and load capacities are safe for the passage of equipment.
· All machinery or equipment will be shut down and positive means taken to prevent it's operation while repairs or manual lubrications are being done. Equipment designed to be serviced while running are exempt from this requirement.
· Buckets, blades, dump bodies, and similar equipment will be either fully lowered or blocked when being repaired or when not in use. All controls shall be in a neutral position, with the engines stopped and brakes set, unless work being performed on the machine requires otherwise.
· No guard, safety appliance, or device will be removed from machinery or equipment, or made ineffective except for making immediate repairs, lubrications, or adjustments, and then only after the power has been shut-off. All guards and devices will be replaced immediately after completion of repairs and adjustments and before power is turned on.
· Mechanized equipment will be shut down prior to and during fueling operations. Closed systems, with automatic shut-off which prevent spillage if connections are broken, may be used to fuel diesel powered equipment left running.
· Each piece of heavy equipment and other similar equipment will be equipped with at least one dry chemical or carbon dioxide fire extinguisher with a minimum rating of 10-B:C.
· Personnel will not work or pass under or ride in the buckets or booms of loaders in operation.
· All self-propelled construction equipment, whether moving alone or in combination, must be equipped with a reverse signal alarm.
· Equipment shall be equiped with rollover protection.
· Seat belt use is required while operating equipment.
Spotters, for tight areas, overhead and underground utilities, excavation limits, etc., will be the only personnel allowed in the vicinity of the heavy equipment. Spotters shall stay out of the boom radius area. Personnel needing to approach heavy equipment while operating will observe the following protocols:
· Make eye contact with the operator (and spotter).
· Signal the operator to cease heavy equipment activity.
· Approach the equipment only after the operator has given signal to do so.
4.4.7 Operation of Motor Vehicles
Subcontractors operating motor vehicles shall comply with all federal, state, and local traffic regulations. Subcontractors shall only use vehicles which are in good condition and safe to operate. Subcontractors shall inspect vehicles routinely used on a weekly basis and retain the inspection documentation for review and/or audit.
Vehicle operation shall observe the posted speed limits. Personal vehciles shall not be allowed on the work site, but will be parked in the designated parking area.
All personnel shall drive defensively and wear seat belts while vehicles are in motion. Since backing accidents at this type of project are frequent, the following guidelines shall be observed:
· Backing of vehicles shall be avoided when possible. Extra care shall be taken to back vehicles when unavoidable.
· When parking vehicles, vehicles shall be backed into the space whenever possible.
· Before backing a vehicle, which has been parked, the driver shall physically walk to the back of the vehicle to observe the area before entering the vehicle.
· Spotters shall be used to back vehicles whenever possible.
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