Short termim workplan_20100602_part3

Short-Term IM Work Plan

APPENDIX B Demolition Asbestos Survey and Assessment


APPENDIX C Demolition Permit Applications and Plans

Work Plan Summary Demolition of Buildings Former Koppers Facility Gainesville, Florida

Chemtron Corporation has been contracted to demolish buildings and structures at the former Koppers site in Gainesville, Florida, there are approximately 8 buildings and 2 tanks that will be demolished. See Attachment H of this plan for drawings of specific buildings. This project is anticipated to last for approximately 4 weeks. Working hours on site will be from 7 am to 5 pm Monday through Saturday. No concrete breaking operations will take place outside of 8 am to 4 pm Monday through Friday to mitigate noise disturbance to residents. During the project, the gate located at NW 23rd Street will be used as access for vehicles. This gate will remain locked at all times except when entering or exiting. All buildings are to be removed to ground level, including foundations, and no digging is to take place. First, Chemtron will mobilize to site and set up all necessary signs, barricades and equipment prior to the start of any work. A secondary decontamination area will be set up for the tanks. Spill prevention controls will be set up in work areas. Utilities will have disconnections completed and verified. At this point of the project, the city and DEP will be involved in the process of verification of disconnection of utilities and waste management practices. Next, heavy equipment such as excavators and bobcats will be used to remove the buildings and structures. All buildings are to be disassembled using a grapple attachment with an excavator and loaded into trucks for offsite disposal. The concrete and brick is to go to a recycling facility. All wood and debris is to be sent to a landfill as construction and demolition debris. All steel is to be sent to recycling as well. All material will be loaded into roll offs or dump trailers. All truck traffic on the site is to enter and exit at the gate located on NW 23rd Street. The tanks will be removed following the procedures set forth in Attachment C of this manual. All ancillary pipes connecting the boiler building to the process area are to be removed as well. The pipe track housing these pipes is to remain. Hand tools and an excavator will be used to accomplish this task. This site is located in a heavy residential and commercial area. Therefore, airborne dust is of a particular concern to neighboring areas while work is being performed. While on site, all vehicles and equipment must observe the best manageable practices of keeping dust to an absolute minimum. All roadways will be kept wet while work is being performed. Also, areas where heavy equipment is working will be kept wet at all times where the equipment is tracking and where the exhaust emanates from the equipment. A water truck is on site at all times and will be utilized for this purpose. There is no need for the containment of such water as these areas are currently exposed to rain and there are monitoring wells and waste water treatment on site. During concrete breaking and brick breaking activities, the surfaces shall be wetted to control dust emissions during the entire demolition process. No building is being dropped at one time with wrecking balls or the like and they are being dismantled with grapplers to avoid dust.

All chemicals and environmental concerns have been removed from the buildings. All utilities have been disconnected from the buildings. There are some pieces of equipment which are to be decontaminated which will take place throughout the course of the project. Finally, following the conclusion of the remediation of buildings and tanks, the site will have continuing remediation. All disturbed areas as well as areas of bare ground will be seeded with grass to prevent wind erosion and maintain permanent dust control. A waste water treatment plant is to be maintained on site for many years to come. The property will remain locked and access will be restricted.

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Contractor Name: Chemtron Corporation Project Name: Demolition of buildings at former Koppers site Work Location: Former Koppers Plant 200 NW 23rd Ave. Gainesville, Florida Projected Job Start Date: 6/1/10 Time: 7:30 a.m. Projected Job Finish Date: 7/31/10 Time: 4:00 p.m.. PREPARED BY: Michael Perry COMPANY PREPARED BY: Chemtron Corporation Date: 5/22/10 Phone: 440.933.6348 Cell: 440.336-0262 DATE SUBMITTED: 5/24/10

Attachment A – Plan Acknowledgement Signature Page

Attachment B – OSHA Logs

Attachment C – Tank Removal Procedures

Attachment D – Insurance Certificate and Workers Comp

Attachment E – Confined space program and permit

Attachment F – Hot Work Permit

Attachment G – MSDS Information

Attachment H – Drawings

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INTRODUCTION: The purpose of this HASP is to set forth, in an orderly and logical fashion, appropriate health and safety procedures to be followed during onsite demolition activities at the former Koppers Facility in Gainesville, Florida. During the performance of the task, this HASP identifies potential hazards which Chemtron Corporation personnel and any sub contractors may be exposed to. Chemtron Corporation personnel, and any sub contractors shall not participate in the performance of this task without having read this plan in its entirety. This plan has been developed to be as complete as possible; however, should conditions dictate revisions or additions to this plan, amendments shall be drafted, added, and distributed to all persons involved with this plan. This plan works in concert with the Chemtron Corporate “Safety and Health Plan”, OSHA standards CFR 1926, Environmental Protection Agency regulations, National Fire Protection Association Codes, and any other applicable city or state codes. It shall be the prime contractor’s responsibility to ensure that all of its subcontractors comply with the provisions set forth in this plan. STATEMENT OF COMPANY’S SAFETY GOALS AND OBJECTIVES:

Chemtron Corporation has a commitment to sound EH&S management, which is also and expression of our concern for the physical health and safety of our employees, client employees and the well being of our environment. Chemtron Corporation intends to remain a responsible health and safety manager through compliance with all Federal, State, and Local health and safety regulations and requirements.

DESCRIPTION OF WORK: Prior to the start of project, the site specific heath and safety plan (SSHP) will be reviewed in a group with all personnel involved on project. All personnel not involved in such meeting will review and sign the SSHP prior to entering site. Chemtron will mobilize to site and set up all necessary signs, barricades and equipment prior to the start of any work. There are 8 buildings and 2 tanks to be demolished and removed on this site. Heavy equipment such as excavators and bobcats will be used to remove such buildings and structures. All buildings are to be disassembled using a grapple attachment with an excavator and loaded into trucks for offsite disposal. The tanks will be removed following the procedures set forth in Attachment C of this manual. The site has a known source contamination of Arsenic and Chrome in low concentrations. Also, this site is located in a heavy residential and commercial area. Airborne dust is of a particular concern to neighboring areas while work is being performed. While on site, all vehicles and equipment must observe the best manageable practices of keeping dust to an absolute minimum. All roadways will be kept wet while work is being performed. Also, areas where heavy equipment is working will be kept wet at all times where the equipment is tracking and where the exhaust emanates from the equipment. A water truck is on site at all times and will be utilized for this purpose. There is no need for the containment of such water as these areas are currently exposed to rain and there are monitoring wells and waste water treatment on site. During concrete breaking and brick breaking activities, the surfaces shall be wetted first to control dust emissions. No building is being dropped at one time with wrecking balls or the like and they are being dismantled with grapplers to avoid dust. All chemicals and environmental concerns have been removed from the buildings. All utilities have been disconnected from the buildings. All buildings are to be removed to ground level and no digging is to take place.

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COMPANY’S SAFETY PERFORMANCE: Chemtron Corporation has provided similar scopes of service for NASA GRC, General Electric, and Beazer East

Inc. Chemtron has provided demolition and excavation services as well as tank cleaning and confined space for the above mentioned companies as well as many others for over 25 years.

See Attachment B EMPLOYEE AWARENESS OF SAFETY: In an effort to provide a safe and healthful working environment, Chemtron Corporation has implemented the following Health and Safety policies and procedures throughout our organization: • new hire safety indoctrinations • monthly safety committee meetings • safety meeting relevant to customer site-specific job safety requirements • job safety inspections • job site “tail gate” safety meetings • annual training on required 29 CFR 1910 General Industry Standards and 29 CFR 1926 Construction

Standards • employee accident injury OSHA 300 Accident Injury Prevention Program • employee recognition for Continuous Safe Work Practices • Drug Awareness Program • 8 hour OSHA update • CPR and First Aid Responders

Employees are trained and qualified to perform their work safely and are held accountable for intentional or negligent noncompliance. Each employee is empowered and expected to stop his or her own work or the work of co-workers if any person’s safety or the environment are at risk. The Construction Supervisor is expected to support and reinforce this expectation. Stopped work shall not resume until the hazard has been controlled and a review has been performed. In addition, all employees are encouraged to seek ways to enhance the effectiveness of the H&S Program.

The Subcontractor Site Safety and Health Officer (SSHO) shall ensure that at the start of each work day, a tailgate safety briefing is performed that reviews the THAs (task hazard analysis) applicable to the daily activities, unique site conditions, hospital route, personal protective equipment (PPE), and stop work authority. The SSHO shall ensure that all site personnel involved attend the tailgate briefing and that they sign as having attended. If personnel do not attend the tailgate briefing, the SSHO shall approach the personnel when they arrive onsite, provide them with an individual tailgate briefing, and have them sign as attending. Project training shall include at least the following. The Construction Supervisor, and SSHO shall have current hazardous waste safety training (40 hour, 8 hour refresher within past 12 months), hazardous waste supervisor training, and sufficient experience to understand the potential hazards. All other field personnel shall have current hazardous waste safety training including 40 hour and current 8 hour refresher. The SSHO shall present a project kick-off safety briefing to cover this plan, physical hazards, hazardous contaminants and chemicals, required hazard controls, and emergency contacts and additional safety briefings as needed (at least once per week). At least one person onsite shall have current first aid and cardiopulmonary resuscitation (CPR) training. The SSHO shall maintain documentation of completed training onsite. Additional training may include, but not be limited to, Respiratory Protection and Hearing Conservation. Field personnel shall be enrolled in a medical surveillance program and have current hazardous waste medical clearance.

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SITE COMPLIANCE:

This health and safety plan will be reviewed by all employees of Chemtron and its’ subcontractors on this project. A copy of the plan will be kept on site at all times during work operations to be accessible to all persons involved in and around the project. The site safety supervisor will conduct daily “tailgate” safety meetings to address work for the day and relate it specifically to the provisions of this plan. The site safety supervisor will monitor all daily on site operations and ensure the compliance of safety protocols set forth in this plan.

Position & Responsibilities Name Cell Phone Project Manager ___Karl Guenther_____ __440.653.3438______ Field Superintendent ___ ____ _______ Safety Coordinator ___Mike Perry _ __440.336-0262_____ Technician_________________ ___ _______ ________ Technician_________________ ___ ____ _______

(additional names and numbers will be added as needed)

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POTENTIAL HAZARDS*: (Identify those hazards that relate to the work activity) –

Heavy equipment work, high pressure water, crane work, confined space, hot work 1. Asbestos

- A thorough asbestos survey has been conducted by Avanco and all asbestos has been abated from this site.

2. Barricading - Fencing and signs will be used around working areas to identify work zones; - Spotters will be used to keep area clear of non essential personnel and direct personnel in and out

of work zone as needed and keep personnel clear from overhead work load; Spotters must wear safety vests to maintain visibility for operators and pedestrians;

- Duration of work will be approximately 4 weeks; - Lane closure will not be required during this project.

3. Biological

- Biological hazards are present for this project and include spiders, ticks, bees, wasps, mosquitoes, poison ivy, snakes, wildlife.

- Wear work clothes; tape pant legs as necessary. - Use insect repellant as necessary; - Self inspection for ticks and other insects during the work day and at the end of the day; - Wash hands as necessary; - Personnel with severe life threatening allergies to stings should inform FM for assignment to

areas free of the hazard.

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4. Chemical/ Flammable Hazards - Gasoline for generators and power washer if used;

a) To be stored on site in approved storage area in 5 gallon safety containers with vents and no more than 10 gallons on site.

b) Spill controls to be kept on site including absorbent pads, boom, floor dry, 55 gallon drums, non sparking shovels, and brooms.

c) Pads to be placed under point of transfer of liquids to contain any leaks - Diesel fuel for heavy equipment.

a) A portable OSHA approved diesel tank will be stored on construction vehicles with approximately 100 gallons of fuel.

b) Pads will be placed under fill points to prevent release from leaks.

- Vehicles contain gasoline or diesel fuel, engine oil, hydraulic fluid, power steering fluid, brake fluid, and antifreeze (ethylene glycol). Other lubricants will be used during minor maintenance repairs.

- Excavator also contains hydraulic fluid.

- Calibration gases for air monitoring equipment and spray paint may also be used onsite.

- All equipment will be turned off prior to filling.

- All equipment will only be filled in the approved storage and refuel area.

- Fire extinguishers will be available on excavation equipment and near fuel storage areas. - Equipment will be inspected on a daily basis prior to use. Repairs will be performed prior to

use. - Indoor work will be conducted with electrical tools and equipment.

- No wastes are to be generated from these chemicals as they are used as fuel products.

- Level D PPE will be required including safety glasses and hard hat. No respiratory protection is required.

- MSDS are located in Attachment G and shall be readily available at every work zone. - Personnel shall be informed of hazardous chemicals during pre-entry briefing and/or daily

tailgate briefings.

5. Confined Space Entry (Permit Required) - Confined space entry will be required to clean tanks prior to demolition; - Chemtron Confined Space Entry Permit, shall be completed before any entry is performed; - See Attachment E for confined space procedures; - Level C PPE with full face respirators and HEPA/ Organic cartridges will be required for any entry; - Life lines and harnesses will be used for means of egress.

6. Crane/ Aerial - A crane will be used for the lowering of the tanks for cleaning; - A man lift will be used to remove lighting and insulation; - Harnesses and fall arrestors shall be worn on lifts; - Spotters and controlled working zones shall be heavily employed during crane operations; - Only licensed crane operator shall operate crane; - No crane work will be done where winds exceed 25 mph.

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7. Demolition - 8 buildings and 2 tanks are to be demolished ( see attachment H); - Excavators and bobcats will be used to demolish buildings; - Concrete footers will be broken using and excavator with hammer hoe attachment; - Utility disconnects are to be verified by GRU, the city of Gainesville, and Chemtron Employees; - Single hearing protection consisting of 85 dBA in ear plugs or over ear muffs will be required

during concrete breaking or cutting activities; - All demolition areas will be marked with tape and spotter controlled zones; - Level D PPE consisting of hard hat, safety glasses, steel toe boots, and DOT class 3 safety vests

will be worn on site at all times except where higher levels of PPE are noted.

8. Discharging Down Sewers - No sewer discharge will be required on this project - Sewers will be protected with dyke materials to prevent any run off contamination; - All sewer inlets will be capped or cemented prior to building demolition.

9. Egress

- All employees will be made aware of egress route for the specific area they are working. This topic and rally point will be addressed in daily safety meeting.

10. Excavations

- Excavations will be required for the capping of utilities; - Excavations will not exceed 3 feet below surface.

11. Falls

- A man lift will be used in the removal of lights and insulation; - Anyone working in the man lift is required to wear a harness and be securely attached to the lift

with a fall arrest system.

12. General Maintenance Checkout - No new equipment will be installed on this project.

13. Hand Tools/ Power Tools

- Hand tools will only be used in the manner which they were designed to be used. - GFCIs will be used on any and all electrically operated power tools; - When using pneumatic tools, 85 dBA hearing protection will be used at all times; - Level D PPE is a minimum requirement for hand tool use; however, higher levels of PPE will be

required based on the job task. - Anticipated tools are hand shovels, power washer, vacuum, concrete saw, and low impact hand

tools.

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14. Hazardous Energy/ Lockout Tagout - Utilities are to be locked out by Chemtron and verified by City and GRU personnel; - If a utility is encountered that needs to be locked out which is not connected to one of the

buildings scheduled for demolition, GRU, the City of Gainesville, and Chemtron personnel will meet to discuss necessary steps.

15. Hot Work

- “Hot Work” is anticipated on this project; - Hot work may occur for minor equipment repairs or saw cut of rebar if found; - Propane/ Oxygen torches may also be used to cut; - A Chemtron Hot Work Permit will be completed prior to any work being performed (see

Attachment I); - Fire watch will be maintained during all hot work and continue at least 30 minutes after last hot

work has been performed. 16. Indoor Air Quality

- No work will be performed in any occupied building; - Vehicles are not to park near any air inlet to a building; - Doors to any building being worked in must be left open during work to prevent any fume build

up from equipment or tools; - No smoking or equipment exhaust will be permitted near an air inlet to a building.

17. Interruption of Safety Services

- No safety services will be interrupted during this project; 18. Ladders

- Ladders my be used to reach some lighting fixtures unable to be reached with man lift; - Fall protection must used on ladders when height exceeds 6 feet.

19. Laser Construction Activities

- No laser activities will be conducted on this project.

20. Lead - No lead is present on this project.

21. Mercury

- No Mercury is present on this project. 22. Noise

- Single hearing protection will be required around heavy equipment operation; - Protection may either be 85 dBA plugs or over the ear muffs; - Hearing protection requirements have also been listed in specific job tasks.

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23. Painting - No painting is anticipated for this project. However, marking spray paint may be used for

surveying purposes during excavation. 24. Personal Protective Equipment (PPE)

- Unless otherwise noted in specific tasks, Level D PPE is required throughout the project - Level D shall be considered no less than safety glasses, steel toe boots, safety vests, and hard hats - All other levels of PPE are specifically noted in each task and must be observed while that task is

being performed. Consult Site Safety Supervisor prior to start of tasks to ensure proper level of PPE is being met.

25. Radiation

- There is no radiation present on this project.

26. Respiratory Protection - Respiratory protection is encountered during specific tasks of this project; - Respiratory protection is indicated in the tasks where it is required; - All employees have yearly medical surveillance and fit testing.

27. Sanitation

- A portable restroom will be kept on site for employees. 28. Scaffolding

- No scaffolding will be used on this project. 29. Traffic Control

- Traffic will be maintained as much as possible throughout the project; - No lane closure is anticipated for this project.

30. Utility Service Interruption

- No utilities will be interrupted during this project with the exception of those being disconnected from the buildings being demolished.

31. Heat Stress

- Employees are trained in signs and symptoms of heat stress. - Site safety supervisor is trained in recognition of signs as well as first aid measures and this topic

will be addressed in daily safety meeting. - If temperature is above 70°F or below 40°F, administrative controls will be implemented (cooled

or warmed drinks, routine breaks in heated or shaded area, and provisions for emergency heating or cooling within 5 minutes travel time).

- Avoid caffeinated beverages during warm weather work. Site supervisor shall make sure all employees have access to cool beverages.

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32. Lifting

- If equipment is to be moved, an evaluation of potential pinch points and/or weight strain will be conducted.

- Clear area of all unnecessary equipment and slip/trip hazards. - Additional help will be obtained by workers or mechanical assistance used on-site if equipment

to be moved is unwieldy, has a weight >50 lbs or has to be moved by maneuvering through awkward positioning.

33. Weather

- In the event of lighting, work shall immediately stop. Work shall not resume until 30 minutes after the last lightning strike.

- Seek shelter in the event of storms. - Excavations shall not be left uncovered in rain so work shall be planned accordingly taking

weather into account and allowing enough time for site to be covered in the event of approaching weather.

34. Dust Control

- No visible air emissions will be allowed during demolition process; - Building materials will be kept wet during demolition as needed to prevent any visible emissions; - All roadways shall be kept wet during working times.

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EMERGENCY PROCEDURES AND EQUIPMENT

The Chemtron Site Supervisor shall remain in charge of all personnel during any potential emergency activities. To minimize the potential for accidents and injuries, daily safety and health inspections will be conducted by the Construction Supervisor or Chemtron SSHO. After an emergency occurs, the Project Manager, Supervisor, and Chemtron SSHO, and field team will participate in a briefing to discuss the event, identify the causes, identify corrective measures, and evaluate the responses.

A) EVACUATION

The Chemtron SSHO or Supervisor will designate the evacuation routes along with the assembly area. All employees shall be familiar with the evacuation routes and assembly area. Development of an evacuation plan with rally point(s) and head count procedures will be addressed within the SSHP Addendum and Implementation.

B) EMERGENCY EQUIPMENT

Several items of emergency equipment will be maintained at the work site. The required emergency equipment may include:

• 16-unit first aid kit with an eye wash station indoors or in weatherproof container, inspected weekly; • Fire extinguisher(s) (at least 20-B) • Spill kit suitable to handle small spills of decontamination fluids; • Pads, boom, floor dry; • Cell phone.

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Task Hazard Analysis: Building Demolition Koppers Gainesville

1. Project Title Building Demolition Koppers Gainesville

2. Location: Koppers plant Gainesville Florida

3. Date: 5/23/10

4. Prime Contractor: Chemtron Corp. 5. Competent Person: Karl Guenther

6. Sub Contractors: Al’s Dozer Service 7. Emergency information: Dial 911 8. Work Activity

9. Hazard 10. Controls 11. PPE Required

12. Other Information

Confined Space work

Lead dust Open Air Level D Full face espirator

Concrete excavation

Heavy equipment

Safe work zone defined by signs and spotters

Level D, single hearing protection

Not to exceed 3 feet

Power washer Ricocheting debris

Face shields on respirators Level C

Site set up and demobilization

Slips, trips, falls, struck by vehicles

Identify slip or fall hazards and remove if possible. If removal not possible, mark and identify hazards with signs or barricades. Assure proper clearance from road and use lane closure if necessary. Seek help to lift >50 lbs. or use mechanical lifting device.

Level D

Crane operations Crush injuries, Pinch points

Spotters to control zones, asses pinch points during rigging

Level D No person other than licensed crane operator to operate crane

Hot work Burns, fires Use fire watch, complete permit Level D

Heavy Equipment work

Crush injuries Spotter control zones; Zones must keep 50 foot radius from equipment

Level D Hearing protection is required in certain phases, see specific tasks

Concrete Saw cutting if performed

Dust exposure, ricocheting debris

Safety guards must be in place on tools

Level D with single hearing protection

Refueling equipment/ fuel storage

Chemical spills, fires

Spill containment materials, fire extinguishers

Level D

material handling/ transfer

Trailer hook up, vehicle accident

Use spotter as needed Level D

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PROJECT CONTACTS: (to be updated prior to start of project)

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Attachment A Plan Acknowledgement Sheet

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SAFETY PLAN ACKNOWLEDGMENT: I hereby acknowledge that I have read, understand and accept the conditions outlined in this Health and Safety Plan (HASP) and I agree to perform work on this task in accordance with this plan, safe work practices, and OSHA regulations. (List all subcontractors working on this activity) Al’s Dozer service Name Company Signature Date

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Attachment B OSHA Logs

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Attachment C Tank Removal Proceedures

Tank Demolition Procedures Revised 5/31/10

The following procedures are to be followed for the demolition of tanks at the Koppers plant in Gainesville, Florida. This purpose of this procedure set is to reduce any risk of contamination from occurring due to the process of demolition. These procedures do not address all personnel safety concerns involved with demolition work and shall not be used as substitute for Health and Safety procedures detailed in the site specific plan. The tanks are jacketed with a layer of aluminum sheeting which covers fiberglass insulation. The aluminum sheeting is to be rinsed inside the tank containment area. All water collected will be treated as Hazardous Waste and disposed of accordingly. Once rinsed, the aluminum sheeting will be sent for metal recycling. The fiberglass insulation will be containerized in roll offs and treated as Hazardous waste. Once the insulation layers are removed, the tanks can get moved for decontamination and demolition. There is to be an area set up directly to the east side of the containment zone for this procedure. The area will consist of a 50 foot by 100 foot square area of triple layered 6 mil poly sheeting. The perimeter edges of the sheeting will be set on containment booms to raise them from ground level and create a pool effect whereas negating water from leaving the sheeted area or running into it from ground sources. The area shall be weighted with sand or similar material on the interior perimeter to sufficiently enough to prevent winds from blowing containment around. Wooden 4x4 posts are to be wrapped in plastic and placed on the containment to support the tanks. The post placement shall be sufficient such that no part of the tank touches the containment. Once this containment is set in place, the tanks will be moved by crane one by one to be decontaminated and demolished. Prior to moving, the man doors on the tanks shall be secured to prevent any material from dropping during the move. The tanks will be set in the containment in a horizontal position with the door of the tank facing the center of the containment. The tanks will be blocked in place to prevent any rolling. Tanks should be placed in accordance with diagram. Following the tanks being set into containment, they will be cleaned. A confined space crew will enter the tanks and use hand tools and power washers to remove residual contamination from the interior of the tanks. The waste will be collected with a vacuum truck. Any accumulation of waste on the outside of the tanks in the containment area is to be collected as it accumulates with the vacuum truck. All waste collected will be containerized and sent to Chemtron’s TSDF for disposal. Once the tanks have been cleaned, they can be visually inspected for decontamination. After decontamination has been verified, a shear on an excavator will be used to cut the tanks into small enough pieces to fit into a roll off. All scrap metal will be sent for recycling. Once the tanks are gone, the containment will be removed and sent appropriately for disposal. All of the containment area will be treated as hazardous waste. Any holes in the containment are to be spray painted before the containment is removed. Once the containment area is removed from the ground, any area that are painted, saturated, or discolored are to be dug up. Any soils removed are to be treated as hazardous waste.

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Attachment D Insurance Certificate and Workers Comp

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Attachment E Confined Space Procedure and Permit

Chemtron Corporation 35850 Schneider Court Avon, Ohio 44011 Phone: 800-676-5091 Fax: 440-937-1038

Permit Required Confined Space Entry 29 CFR 1910.146

Category: Job Site Health and Safety

Established: Revised: May 20, 2005

Procedure #: CC 19 By: By: J. Erclauz

Chemtron Corporation 35850 Schneider Court, Avon, Ohio 44011

Chemtron Corporation 35850 Schneider Court Avon, Ohio 44011 (440) 937-6348 CONFINED SPACE ENTRY PROGRAM Compliant With: OSHA General Industry Regulations

29 CFR 1910.146






Chemtron Corporation 35850 Schneider Court, Avon, Ohio 44011

ACKNOWLEDGEMENTS The information contained in this document is not to be considered a substitute for any

provision of the standard. This document shall be used in conjunction with all applicable rules and regulations.

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1) PURPOSE

a) Chemtron Corp. and its associated work places have confined spaces that due to various

chemical and physical properties may cause death or serious injury to employees who may enter them. This Confined Space Entry Program is developed and established to identify, evaluate, and control such spaces, and more important, to detail procedures and responsibilities for entering and working within confined spaces.

b) Adherence to the policies and directives contained in this program is mandatory for all

supervisors and employees of this company. Supervisors and employees failing to follow this program are subject to disciplinary action and/or dismissal.

2) DEFINITIONS

a) Confined Space - A space that:

i) Is large enough and so configured that an employee can bodily enter and perform assigned work; and

ii) Has limited or restricted means for entry or exit; and

iii) Is not designed for continuous employee occupancy.

b) Permit Required Confined Space - A confined space that:

i) Contains or has a potential to contain a hazardous atmosphere; or

ii) Contains a material that has the potential for engulfing an entrant; or

iii) Has an internal configuration such that an entrant could be trapped or asphyxiated by

inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross section; or

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iv) Contains any other recognized serious safety or health hazard.

c) Acceptable Entry Conditions - The conditions that must exist in a permit space to allow entry and to ensure employees can safely enter into and safely work within a permit required confined space.

d) Entry - The action by which a person passes through an opening into a permit required

confined space. Entry is considered to occur as soon as any part of the entrant's body breaks the plane of an opening into the space. NOTE: For entry to occur, there must be intent to bodily enter the confined space. You may reach into a space, and not bodily enter (say to adjust a valve), and do so without an entry permit being required.

e) Entry Permit - The written or printed document provided by this company to allow and

control entry into a permit space.

f) Entry Supervisor - The person responsible for determining if acceptable entry conditions are present at a permit space where entry is planned, for authorizing entry and overseeing entry operations, and for terminating entry.

g) Hazardous Atmosphere - An atmosphere that may expose employees to the risk of death,

incapacitation, impairment of ability to self-rescue, injury, or acute illness from one or more of the following conditions:

i) Flammable gas, vapor, or mist in excess of 10 percent of its lower flammable limit

(LFL);

ii) Airborne combustible dust at a concentration that meets or exceed its LFL. (this may be approximated as a condition in which the dust obscures vision at a distance of 5 feet or less);

iii) Atmospheric oxygen concentration below 19.5 percent or above 23.5 percent;

iv) Atmospheric concentration of any substance for which a dose of permissible limit is

published (in Subpart G Occupational Health and Environmental Control; or Subpart Z

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Hazardous and Toxic Substances); or

v) Any other atmospheric condition that is immediately dangerous to life or health.

h) Non-Permit Confined Space - A confined space that does not contain, or with the respect to atmospheric hazards, have the potential to contain any hazard capable of causing death or serious physical harm.

i) Prohibited Condition - Any condition in a permit space that is not allowed by the permit

during the time when entry is authorized.

j) Testing - The process by which the hazards are identified and evaluated. Testing includes specifying the tests that are to be performed in the permit space.

3) CONFINED SPACE LOCATIONS

a) Workplaces within this company have been surveyed to identify any confined spaces that may be present. Such locations are listed below.

i) Non-Permit: The following locations have been identified as non-permit confined

spaces, and may be entered and worked in using normal work procedures: (1) (No locations currently exist).

ii) Permit-Required: The following locations have been identified as permit required

confined spaces, and may be entered ONLY by following the entry permit procedures established in this program:

(1) (All tanks at Chemtron Corp. are Permit-Required Confined Spaces).

iii) Alternate Entry: The following permit required confined spaces may be entered by

following the Alternate Entry Procedures:

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(1) (All tanks at Chemtron Corp. may qualify after initial assessment).

iv) Reclassify: The following permit required confined spaces may be reclassified and entered as a non-permit space ONLY after their hazards have been eliminated following prescribed procedures:

(1) (No locations currently exist).

4) RESPONSIBILITIES

a) Chemtron Corp:

i) Will evaluate the work place and identify permit required confined spaces.

ii) Inform exposed employees of the existence, location of, and the danger posed by the

permit space by posting danger signs or by any other equally effective means.

iii) Determine if employees will or will not enter permit required space. If not, take effective measures to prevent employees from entering the permit spaces.

iv) Provide and document training for entrants, attendants, entry supervisors, and (if used)

in-house rescue personnel.

v) Protect entrants from all external hazards.

vi) Designate the appropriate supervisor(s) as entry supervisor(s).

vii) Provide all specified equipment required for entry in a permit required confined space as outlined in this and OSHA 1910.146 at no cost to the employees, maintain that equipment properly, and ensure that employees use that equipment properly.

b) When acting as host employer for a contractor performing permit space entry work,

Chemtron Corp. shall,

6






i) Inform contractor of permit space entry program;

ii) Apprise contractor of hazards of particular permit spaces and precautions and procedures implemented for protection of employees in or near permit spaces;

iii) Coordinate entry operations with contractor when both will be working in or near

permit spaces and debrief contractor after entries.

iv) Obtain information from contractor of permit program to be followed and coordinate multiple entry operations.

v) Debrief contractors of the hazards encountered or created.

vi) If necessary, reclassify a non-permit confined space as a permit space when there are

changes in use or configuration.

c) Employees:

i) Will not enter any permit required confined space unless specifically authorized by an entry supervisor and only in full accordance with this program and the OSHA standard.

ii) Attend and complete any scheduled training required by his/her supervisor and this

program.

iii) When selected as an entrant, attendant, or entry supervisor, perform those duties as outlined in this program.

5) PERMIT REQUIRED CONFINED SPACE ENTRY PROGRAM AND PROCEDURES

a) All permit required confined spaces will be identified by [supervisors, department heads,

safety manager]. Exposed employees will be informed of such spaces through posting with warning signs or other equally effective means, such as facility maps or training [employer should specify which procedure is used in this program].

7






b) Only trained and qualified employees will be authorized as permit space entrants, attendant, or entry supervisor.

c) No employee shall enter a permit space without having a properly completed entry permit

signed by an entry supervisor.

d) Entry permit procedures are as outlined below:

i) Entrants will obtain an entry permit from the Plant Manager prior to entry of the space.

ii) The entrant will accomplish all pre-permit actions required for entering the space, such as atmospheric testing, hazard control/elimination actions, have all required equipment on hand, provide for attendant and rescue services, etc.

iii) Complete all items on the permit.

iv) The entry will be authorized and the permit will be signed only by an authorized entry

supervisor. If any item on the permit is checked as "NO" (meaning not yet completed or available), the permit will not be signed.

v) Entry may proceed. A copy of the entry permit will be placed outside the confined

space until the permit has been cancelled by appropriate personnel.

6) TESTING AND MONITORING

a) Test the space with the necessary, calibrated equipment, to determine if acceptable entry conditions exist before beginning entry operations. Initial testing of the atmosphere must be done from outside the confined space prior to any entry with all affected employees present. If isolation of the space is infeasible because the space is large or part of a continuous system (such as a sewer), entry conditions will be continuously monitored where entrants are working.

b) Test or monitor the permit space continually to determine if acceptable entry conditions are

being maintained during the course of entry operations.

8






c) When testing for atmospheric hazards, test first for oxygen, then for combustible gases and

vapors, and then for toxic gases and vapors. Parameters for non-hazardous atmospheres are:

i) Oxygen between 19.5 and 23.5 percent;

ii) Flammability less than ten percent of the lower explosive limit (LEL).

iii) Toxicity less than the permissible exposure limit (PEL).

d) An authorized attendant must be present and monitoring the entry at all times. The

attendant will not be assigned any other duties that may interfere with his attendant duties. Attendant duties are outlined below.

e) Equipment required for permit required confined space entry includes that equipment

required for testing and monitoring; ventilating; communications between the entrant and attendant, and for summoning rescue; personal protection; lighting; barriers/shields for openings; means of ingress and egress; and any other equipment necessary for safe entry and rescue.

f) Re-evaluate the space and or re-test as requested by affected employees or contractors

7) RESCUE AND EMERGENCY SERVICES

a) Non-entry rescue is the preferred method for rescue of personnel from a permit required

space. Employees will not enter a permit space for rescue unless they have been specifically trained and equipped for such rescue.

b) The attendant or designated employee responsible for rescue shall be immediately available

at the confined space location in PPE that is equivalent or higher than the PPE of the entrants. That employee will also use a self contained breathing apuratice (SCBA) if non-entry rescue from an IDLH atmosphere is not feasible.

9






c) To facilitate non-entry rescue, retrieval systems or methods shall be used whenever an authorized entrant enter a permit space, unless the retrieval equipment would increase overall risk of entry or would not be of value to any rescue. Retrieval system requirements are:

i) Each entrant shall use a chest or full body harness, with a retrieval line attached at the

center of the back near shoulder level, or other appropriate point.

ii) Other end of retrieval line shall be attached to a mechanical device or fixed point outside of permit space enabling immediate use. A mechanical device will be used to retrieve personnel from vertical type permit spaces more than five feet deep.

iii) If injured entrant is exposed to any substance with a required MSDS or similar

document, that MSDS or document will be made available to the medical facility treating entrant.

d) If rescue should become necessary, the attendant will:

i) Notify their supervisor, the supervisor will then call 911;

ii) Attempt non-entry rescue procedures to the extent possible by the circumstances.

iii) Monitor the situation and be ready to give rescuers information on how many victims

and they’re status, what hazards, chemical types, concentrations, etc. are present.

e) Only designated personnel will enter permit spaces for rescue purposes. Each designated rescue team member will be trained on:

i) The specific site at which they are providing rescue services.

ii) Use of personal protective and rescue equipment necessary for making the rescue from

the permit space;

iii) Performance of assigned rescue duties and also that training required of authorized

10






entrants;

iv) Basic first-aid and cardiopulmonary resuscitation (CPR). At least one member of the rescue team will hold current certification in first aid and CPR.

f) Permits will be cancelled by the entry supervisor upon completion of the work, or when any

prohibited condition arises. Permits cannot just be let to expire. Cancelled permits must be kept for the annual review.

8) PROGRAM REVIEW

a) Cancelled entry permits will be retained on file for at least one year. The Permit Space

Program will be reviewed within one year of each entry using these cancelled permits to revise the program as necessary to ensure employees are protected from permit space hazards. A single review covering all entries in the preceding year may be conducted.

9) DUTIES OF THE ENTRANT, ATTENDANT, AND ENTRY SUPERVISOR

a) Entrant

i) Know the hazards that may be faced, including the mode, signs or symptoms, and

consequences of the exposure;

ii) Properly use equipment as required;

iii) Communicate with the attendant as necessary to enable the attendant to monitor entrant status and to alert entrants of the need to evacuate the space.

iv) Alert the attendant whenever the entrant recognizes any warning sign or symptom of

exposure to a dangerous situation, or detects a prohibited condition.

v) Exit from the permit space as quickly as possible whenever:

(1) An order to evacuate is given by the attendant or the entry supervisor, or an

11






evacuation alarm is activated.

(2) The entrant recognizes any warning sign or symptom of exposure to a dangerous situation, or detects a prohibited condition.

b) Attendant

i) Know the hazards that may be faced during entry, including the mode, signs or

symptoms, and consequences of the exposure.

ii) Is aware of possible behavioral affects of hazard exposure.

iii) Continuously maintain an accurate count and identity of authorized entrants.

iv) Remain outside the permit space during entry operations until relieved by another attendant

v) Communicate with entrants as necessary to monitor entrant status and to alert entrants

of the need to evacuate.

vi) Monitor activities inside and outside space to determine if safe for entrants to remain in space and orders evacuation when necessary.

vii) Summon rescue and emergency services when assistance for emergency exit from

permit space is necessary.

viii) Take the following actions when unauthorized persons approach or enter a permit space while entry is underway:

(1) Warn them to stay away, or exit immediately if they have entered.

(2) Inform the entrants and entry supervisor if unauthorized persons enter the permit

space.

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(3) Perform non-entry rescues as specified by company procedure.

(4) Perform no duties that might interfere with their primary duty to monitor and protect authorized entrants.

c) Entry Supervisor

i) Know the hazards that may be faced during entry, including the mode, signs or

symptoms, and consequences of the exposure.

ii) Verify that acceptable conditions for entry exist before endorsing the permit and allowing entry to begin.

iii) Terminate the entry and cancel the permit when entry operations are complete or a

prohibited condition arises.

iv) Verify that rescue services are available and the means for summoning them are operable.

v) Remove unauthorized individuals who enter or who attempt to enter the permit space.

vi) Determine, whenever responsible and at appropriate intervals, that acceptable entry

conditions are maintained.

10) TRAINING

a) Only trained and qualified employees may be authorized as entrant, attendant, entry supervisor, or in-house rescue team members. The training will establish proficiency in the duties required by this program so that the employee acquires the understanding, knowledge, and skill necessary for the safe performance of his/her duties.

b) Training must be completed before employee is assigned duties under this program, before

there is a change in assigned duties and, whenever a supervisor has reason to believe either that there are deviations from permit space entry procedures or inadequacies in the

13






employee's knowledge or use of this program.

c) Supervisors will certify that this training has been accomplished. The certification will contain the employee's name, signatures or initials of the trainers, and the dates of training. The certification will be kept on file.

11) ALTERNATE ENTRY PROCEDURES

a) Alternate entry procedures may only be used when the only hazard is an actual or potential

hazardous atmosphere. If alternate entry procedures are used, no permits are needed, no attendant or supervisor is required, and rescue provisions need not be used. Training and a written certification are required.

b) Conditions To Be Met To Qualify For Alternate Procedures:

i) The only hazard posed by permit space is an actual or potential hazardous atmosphere.

(See Note after the Permit Space Reclassification section.)

ii) Continuous forced air ventilation alone is sufficient to maintain safe permit space.

iii) Monitoring and inspection data that supports above demonstrations have been developed and documented.

iv) If initial entry is necessary to obtain above data, it shall be performed in accordance with

this program.

v) Documented determinations and supporting data will be made available to entrants.

c) Entry must be in accordance with the following requirements:

i) Any condition making it unsafe to remove an entrance cover shall be eliminated before removing the cover. When entrance covers are removed, the opening shall be promptly and effectively guarded.

14






ii) Before entry, the internal atmosphere shall be tested with a calibrated direct-reading instrument, for the following conditions in the order given:

(1) Oxygen content: 19.5 - 23.5%

(2) Flammable gases and vapors: <= 10% of LEL

(3) Potential toxic air contaminants: < PEL

iii) There may be no hazardous atmosphere within the space whenever any employee is

inside the space.

iv) Continuous forced air ventilation shall be used as follows:

(1) Entry not permitted until hazardous atmosphere is eliminated.

(2) Ventilation shall be directed to immediate areas where employees are or will be present and will continue until all employees have left the space;

(3) Air supply shall be from a clean source and may not increase hazards in space.

(4) Atmosphere within space shall be periodically tested as necessary to ensure that

ventilation is adequate. If hazardous atmosphere is detected during entry:

(a) Each employee shall leave space immediately;

(b) Space shall be evaluated to determine how hazardous atmosphere developed;

(c) Measures must be taken to protect employees from hazardous atmosphere before any subsequent entry.

(d) The entry supervisor will verify that the space is safe for entry and that all of the

above requirements have been met. Such verification will be in writing to include the date, location of the space, and the signature of the person providing

15






the certification, and shall be made available to each employee before entry.

12) PERMIT SPACE RECLASSIFICATION

a) A permit space may be reclassified as a non-permit space:

i) If there are no actual or potential atmospheric hazards and if all hazards within permit space are eliminated without entry, space may be reclassified for as long as the non-atmospheric hazards remain eliminated.

ii) Hazards may be eliminated by such actions as purging or inerting tank/vessels of

contaminants, emptying material from hoppers/bins, use of company lockout/tag procedures for electrical/ mechanical hazards. The control of atmospheric hazards through forced air ventilation does not constitute elimination of that hazard (it only controls the hazard: the preceding Alternate Entry Procedures must be used in such cases).

b) If entry is required to eliminate hazards, it shall be according to regulations and the space

may be reclassified for as long as the hazards remain eliminated.

c) Entry supervisors will certify in writing that all hazards in permit space have been eliminated and make this document available to each entrant.

d) If hazards arise in declassified permit space, employee(s) shall exit and the employer shall

determine whether to reclassify space.

NOTE: A combination of reclassification procedures and alternate entry procedures (e.g. using lockout/tagout to eliminate a physical hazard, then continuous forced air to control an atmospheric hazard) may not be used together. Situations as such must be entered under the permit program.

13) WRITTEN PERMIT

a) The following information must be included in the written permit. The permit must be a

16






standardized format for each entry.

i) The permit space to be entered.

ii) The purpose of the entry.

iii) The date and the authorized duration of the entry permit.

iv) The authorized entrants within the permit space, by name or by such other means.

v) The personnel, by name, currently serving as attendants.

vi) The individual, by name currently serving as entry supervisor, with space for

signature or initials.

vii) The hazards of the permit space to be entered.

viii) The measure used to isolate the permit space and to eliminate or control permit space hazards before entry.

ix) The acceptable entry conditions.

x) The results of initial and periodic tests, with the names or initials of the testers and when

the tests were done.

xi) The rescue and emergency services that can be summoned and the means for summoning them.

xii) The communications procedures used by authorized entrants and attendants to maintain

contact during the entry.

xiii) Equipment (such as personal protective equipment, testing, communications alarm system, and rescue equipment) to be provided for compliance with this

17






section.

xiv) Any other information whose inclusion is necessary in order to ensure employee safety.

Chemtron Corporation Confined Space Entry Permit

Chemtron Corporation 35850 Schneider Court Avon, Ohio 44011

Good on this date only:____________ From:_________ a.m. p.m. To: ___________ a.m. p.m. Location:_________________________________________________ Job Number:__________________ Authorized Entrants Attendants/Monitors Site Supervisor ______________________ ______________________ ________________________ ______________________ ______________________ ________________________ Description of Job or Special Procedures:_____________________________________________________ ______________________________________________________________________________________ Employee Training Pre-Entry Briefing

1. Safe entry and rescue training conducted on (Date) _____________________________________ 2. Mandatory Pre-entry briefing conducted on (Date) _____________________________________ 3. Does the job require special training? YES NO

Contractor Notification Contractor notified of: PERMIT CONDITIONS________ POTENTIAL HAZARDS________ N/A____ Lighting Requirements Special Tools/Equipment Communication Data ____________________ ______________________ ___________________ ____________________ ______________________ ___________________ 1. Are all electrical devices intrinsically safe? YES NO 2. Have all power cords and tools been visually inspected? YES NO Vessel Preparation 1. Work area isolated with signs/barriers? YES NO 2. All energy sources Locked/Tagged Out? YES NO 3. All input lines Capped/Blinded? YES NO 4. Vessel contents drained/flushed/neutralized? YES NO 5. Vessel cleaned and purged? YES NO 6. Ventilation provided 30 minutes before entry? YES NO Pre-Entry Atmosphere Testing Reading Time Initials 1. Test for oxygen content: _________% oxygen __________ ___________ 2. Test for flammable concentration: _________% LEL __________ ___________ 3. Test for toxic concentration: _________ppm of (TLV=) __________ ___________ 4. Test for heat stress hazard: ________F ________C _______WBGT ___________ ___________ Emergency / Rescue Procedures 1. Location of written Emergency/Rescue Plan: _____________________________________________ 2. Type of Emergency / Rescue Team required: On-Site____ Off-Site____ Phone #___________________ Safety Equipment Personnel Protective Equipment required: Area Safety Equipment Required: _________________________________ ____________________________________ _________________________________ ____________________________________ 1. Self Contained Breathing Apparatus required? YES NO TYPE_________ 2. Portable atmosphere monitor required? YES NO TYPE_________ Permit Authorization I certify that I have inspected the work area for safety and reviewed all safety precautions recorded on the permit. (Signature) Chemtron Entrant Supervisor________________________________ Date_____________

Page 20 of 23

Attachment F Hot Work Permit

Page 21 of 23

Attachment G MSDS Information

Page 22 of 23

Attachment H Project Prints and Drawings

Page 23 of 23

List Of Onsite Chemicals

- Gasoline - Motor oil - Windshield washer fluid - Diesel fuel - Brake fluid - Hydraulic oil - Power steering fluid - Spray paint - Antifreeze


APPENDIX D Waste Summary

Waste Summary for Koppers Plant Gainesville, FL

The following is list of chemicals and quantities found at the Koppers plant in Gainesville, Florida. All mentioned waste has been containerized and labeled for proper shipment and disposal in accordance with federal and state EPA and DOT guidelines. Waste classifications have been made by using MSDS sheets, field testing methods, and product labeling. All waste will be verified upon receipt. All waste will be shipped to the Chemtron Corporation TSDF located in Avon, Ohio. It is anticipated that all of this waste will be shipped in the next several weeks following the demolition of on site structures. Chemicals Various Non RCRA oils and greases- 4 drums Flammable liquids loosepack (paints, thinners, solvent wash) – 4 drums Light Ballasts for fluorescent bulbs – 2 drums Ammonium Hydroxide lab pack (6x500mL bottles) – one 5 gallon pail Lead acid Batteries Universal Waste – 1 Non PCB transformers with oil – 6 Alkaline Batteries – one 5 gallon pail Mercury switches Universal Waste – one 5 gallon pail Calcium hydroxide solid – one 5 gallon pail NiCad Batteries Universal Waste – one 5 gallon pail Florescent light bulbs Universal Waste – 4 light bulb tubes ( approximately 40 per tube) HID light bulbs Universal Waste – 1 drum Epoxy resin – one 5 gallon pail Amine hardener – one 5 gallon pail Caustic boiler reagents- one drum

Short termim workplan_20100602_part3

Technology

work areas

koppers site

heavy equipment

shortterm im work plan

drawings of specific

demolition debris

attachment c

water truck