5.0 PERSONAL PROTECTIVE EQUIPMENT
When engineering and administrative controls are not feasible or not adequate to protect personnel from the hazards associated with project activities, Personal Protective Equipment (PPE) use will be required.
5.1 Respiratory Protection
A respiratory protection program will be implemented that is compliant to the requirements of 10 CFR 20 Subpart H "Respiratory Protection and Controls to Restrict Internal Exposure in Restricted Areas" and 29 CFR 1910.134 "Respiratory Protection." Respiratory protection equipment shall be NIOSH-approved and respirator use will conform to American National Standards Institute (ANSI) Z88.2.
All personnel (including visitors) using a negative pressure respirator, must have successfully passed a qualitative respirator fit test in accordance with OSHA 29 CFR 1910.134 within the last 12 months. Fit testing and any training related to respiratory protection for project personnel will be documented on the Training Acknowledgment Form.
5.2 Levels of Protection
The following is a description of the PPE that will be required during various phases of the project. The EPA terminology for protective equipment will be used; Levels A, B, C, and D.
5.2.1 Level A Protection
Level A Protection use is not anticipated during this project.
5.2.2 Level B Protection
Level B Protection use is not anticipated during this project. Confined Space Entry, if necessary, may require the use of Level B Protection. This requirement will be determined by a CIH on a case by case basis.
Level B protective equipment, if utilized, shall consist of:
· Supplied air respirator
· Work clothing (light or insulated) as prescribed by weather
· Steel-toed boots
· Chemical resistant boot covers and/or outer boots (as selected by a CIH)
· Tyvek® coveralls with hoods (as determined by the CHP), elastic wrists and ankles (or equivalent cloth/synthetic fiber)
· Saranex® coveralls with hoods, elastic wrists, and ankles (as determined by a CIH)
· Acid gear, splash suit, rain gear, etc. (as determined by a CIH)
· Nitrile, latex, or vinyl gloves (inner) and/or cloth liners
· Outer gloves (as selected by a CIH)
· Hearing protection (if necessary)
· Cooling vest (if necessary)
· Hard-hat
· Splash shield (if necessary)
· Openings at ankles, wrists, and hoods shall be taped (as directed by the CHP).
5.2.3 Level C Protection
Level C Protection use is not anticipated during this project. Level C protection will, however, be required if real time airborne concentrations of contaminants exceed the action levels established in Table 7-1. Decontamination efforts in Shelter 204 may require Level C until the actual hazard has been properly evaluated by the CHP.
Level C protective equipment, if utilized, shall consist of:
· Full-face air purifying respirator (APR) with NIOSH-approved combination high efficiency particulate air (HEPA)/organic vapor cartridges
· Work clothing as prescribed by weather
· Steel-toed boots
· Chemical resistant boot covers and/or outer boots (PVC/Latex/Neoprene)
· Tyvek® coveralls with hoods (as determined by the CHP), elastic wrists and ankles (or equivalent cloth/synthetic fiber)
· Nitrile, latex, or vinyl gloves (inner) or cloth liners
· Nitrile gloves or PVC (outer) or leather palm gloves
· Hearing protection (if necessary)
· Cooling vest (if necessary)
· Hard-hat
· Splash shield (if necessary)
· Openings at ankles, wrists, and hoods shall be taped (as directed by the CHP).
5.2.4 Level D-Modified Protection
Level D-Modified protection will be required for various activities during this project. Level D-Modified PPE at a minimum shall consist of:
· Work clothing as prescribed by weather
· Steel-toed boots
· Chemical resistant boot covers and/or totes (or equivalent) (PVC/Latex/Neoprene)
· Tyvek® coveralls with hoods (as determined by the CHP), elastic wrists and ankles (or equivalent cloth/synthetic fiber)
· Nitrile or vinyl gloves (inner) or cloth liners
· Nitrile or PVC gloves (outer) or leather palm gloves
· Hearing protection (if necessary)
· Splash shield (if necessary)
· Cooling vest (if necessary)
· Hard-hat
· Splash shield (if necessary)
· Safety glasses
· Openings at ankles, wrists, and hoods shall be taped (as directed by the CHP).
5.2.5 Level D Protection
Level D protection is the minimum level of protection that will be used at the project. Level D PPE, at a minimum, shall consist of:
· Steel-toed work boots
· Safety glasses
· Hearing protection (if necessary)
· Hard-hat
· Splash shield (if necessary)
· Leather work gloves (as necessary).
5.3 Activity Specific Levels of Protection
The required level of personal protection is specific to the activity being conducted. Based on the available information reviewed at the time of the generation of this HASP, the activities being performed, and the projected engineering/administrative controls, the initial levels of PPE have been established as follows:
Activity Initial Level of PPE
General ConditionsField mobilizationInstall temporary facilitiesConstruction of storage/load-out facilityPrepare site (install fencing and signage)Perform confirmation sampling in posted areasPerform confirmation sampling in non-posted areasDecontamination/Dismantlement of Shlter 204Excavate and remove contaminated soilLoad excavated soils for transport and disposalPerform area restoration (backfill, compact, grade and seed) DDDDDD-ModifiedD-ModifiedD-Modified/Level CD-ModifiedD-ModifiedD-Modified
As project activities progress, levels of PPE are subject to change or to modification. Additional project information, actual site conditions, or site monitoring (real-time and time-integrated) will be used to confirm or upgrade the selected levels of PPE. This can occur when action levels or exposure limits are reached or when the need arises to increase the levels of protection for project personnel. Levels of PPE will not be downgraded without prior approval from a CIH and CHP.
5.4 Donning/Doffing Personal Protective Equipment
All persons entering an EZ/Contamination Area/Radiation Area shall put on the required PPE in accordance with the requirements of this HASP. When leaving these restricted areas, PPE will be removed in accordance with the procedures listed in the Radiation Protection Plan.
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