change no. rar-047 document no. 400 section no. all page ... · 4.0 scope of work 4.1 objective 4.2...

57
Interim Change Notice Change No. RAR-047 Document No. 400 Section No. All Page No. See pages listed below. Revision No. 3 Requirement: RAR Scoping and Planning Document #400, Health and Safety Plan Change: RAR Scoping and Planning Document #400, Health and Safety Plan Update and revise Health and Safety Plan. The following pages are replaced in this ICN: i, iii, 2-3, 5-9, 11, 13-14, 16-19,24-26,35-36,38-42,44,46-47,49-50,52-54, 56-60,62-64,66-70, 72. 74-75, 77,87, 89, and illustrations. Effective Date: May 22, 2000 Review: MANAGER </ DATE (TO PROJECT MANAGER (Site/Offsite) DATE WCP 103 01/25/00

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Page 1: Change No. RAR-047 Document No. 400 Section No. All Page ... · 4.0 SCOPE OF WORK 4.1 Objective 4.2 Envirocon Tasks (30-35 Personnel) 4.3 Subcontractors 5.0 HEALTH AND SAFETY HAZARD

Interim Change Notice

Change No. RAR-047 Document No. 400Section No. AllPage No. See pages listed below.Revision No. 3

Requirement: RAR Scoping and Planning Document #400, Health and Safety Plan

Change: RAR Scoping and Planning Document #400, Health and Safety Plan

Update and revise Health and Safety Plan. The following pages are replaced in this ICN: i, i i i , 2-3, 5-9,11, 13-14, 16-19,24-26,35-36,38-42,44,46-47,49-50,52-54, 56-60,62-64,66-70, 72. 74-75, 77,87, 89,and illustrations.

Effective Date:May 22, 2000

Review:

MANAGER </ DATE

(TOPROJECT MANAGER (Site/Offsite) DATE

WCP 103 01/25/00

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TABLE OF CONTENTS

1.0 INTRODUCTION

2.0 KEY PERSONNEL AND RESPONSIBILITIES

2.1 Project Manager: Mr. Rex Long2.2 Corporate Director Health and Safety: Mr. Joe Ocken, CIH, CHMM, MHS2.3 Site Health and Safety Officer (SHSO): Mr. Robert Valdez2.4 Excavation Superintendent: Mr. Dean Biegel2.5 Restoration Superintendent: Mr. Dean Biegel2.6 Excavation Competent Person2.7 Subcontractors

3.0 REVIEW OF SITE SAFETY PLAN /DAILY SAFETY MEETINGS

3.1 Site-Specific Safety Plan3.2 Daily Toolbox Safety Meetings

4.0 SCOPE OF WORK

4.1 Objective4.2 Envirocon Tasks (30-35 Personnel)4.3 Subcontractors

5.0 HEALTH AND SAFETY HAZARD ANALYSIS

5.1 Radiological Hazards5.2 Chemical Hazards5.3 General Hazards

5.3.1 Buddy System5.3.2 Slippery and Unstable Surfaces, Uneven Terrain5.3.3 Hazardous Noise5.3.4 Lifting Heavy Objects

6.0 RADIATION PROTECTION

6.1 Radiological Hazards6.2 Personnel Monitoring Devices

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TABLE OF CONTENTS (con't)

11.3 Site Security

12.0 COMMUNICATION PROCEDURES

12.1 General Communication12.2 Emergency

13.0 PERSONAL HYGIENE /DECONTAMINATION PROCEDURES

13.1 Sanitation13.2 Procedure for Personnel Decontamination13.3 Equipment Decontamination13.4 Disposition of Decontamination Wastes

14.0 HAZARD COMMUNICATION PROGRAM

14.1 Envirocon Hazard Communication Program14.2 Material Safety Data Sheets (MSDSs)14.3 Container Labeling14.4 Chemicals Brought to the Site by Envirocon14.5 Chemicals Brought to the Site by Subcontractor14.6 Employee Training and Information

15.0 GENERAL CONSTRUCTION SAFE WORK PRACTICES

15.1 Insects and Pests15.2 Slips, Trips, and Falls15.3 Work From Elevated Surfaces15.4 Portable Tools15.5 Housekeeping and Material Storage15.6 Personal wireless telephones

16.0 FIRE PROTECTION

16.1 General Safety Guidelines16.2 Site-Specific Precautions16.3 Evacuation/Fire Fighting Procedures

17.0 EXCAVATION, TRENCHING, AND SHORING

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2.0 KEY PERSONNEL AND RESPONSIBILITIES

2.1 Project Manager: Mr. Rex Long

The Project Manager is responsible for oversight and management of all aspects of the projectincluding health and safety, quality assurance, construction, remedial design, equipment, andpersonnel.

2.2 Corporate Director Health and Safety: Mr. Joe Ocken. CIH. CHMM, MHS

A. Envirocon's Corporate Director of Health and Safety shall be responsible for thedevelopment, implementation and oversight of the Site Health and Safety Program (SHP)and Site Health and Safety Plan (SSHP). This individual will direct all Safety operationsand review/approve any changes or modification to the SSHP.

B. Envirocon's Corporate Director of Health and Safety will schedule semi-annual routine siteaudits to evaluate implementation of site safety plans, effectiveness of control measures,and interpretation of air or biological monitoring results.

[ 1 ] All Site Audits will be coordinated in advance with the Project Manager.

[2] Findings and accompanying recommendations will be prepared in narrative reportform and sent to the Project Manager and the President of Envirocon. Kerr-McGeewill be sent a copy of the final audit finding.

2.3 Site Health and Safety Officer (SHSOV Mr. Robert Valdez

A designated individual will be assigned to the site on a full-time basis with functionalresponsibility for implementing the Site Health and Safety Plan as it applies to Enviroconpersonnel. Supervisory powers will be limited to Competent person i.e., shutting a job down in theevent of an immediate hazard to life and health. In all other matters, the SHSO will function in anadvisory capacity to the Project Manager. In the event that personnel will not adhere to establishedsafety guidelines, the Project Manager will assume responsibility for disciplinary actions.

Specific duties which must be performed include:

A. Document safety problems and violationsB. Supervise decontamination of personnel and equipment;C. Ensure that Envirocon's monitoring equipment is calibrated/operational;D. Perform respiratory fit tests;E. Inventory/inspect PPE prior to personnel entries;F. Select protective equipment levels based upon chemical properties, method of contact, and

air sample results;G. Insure all personnel are "Fit for Duty";

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H. Inspect first aid kits/fire extinguishers/SCBA;I. Accompany all injured employees to clinic.J. Report/coordinate return-to-work issues with Corporate; andK. Administrate the Site Safety Incentive Plan.

2.4 Excavation Superintendent. Mr. Dean Biegel

Supervision of all site-specific property removal and associated operations. Responsibilities includeEnvirocon and subcontractor personnel.

2.5 Restoration Superintendent. Mr. Dean Biegel

Supervision of all site-specific property restoration and associated operations. Responsibilitiesinclude Envirocon and subcontractor personnel.

2.6 Excavation Competent Person. Mr. Robert Valdez, Mr. Rex Long, Mr. Dean Biegel, Mr. SteveVonmotz, Mr. Kevin Uranich

This individual will have direct supervisory control over all excavation activities involvingpersonnel located within the excavation or trench. Specific duties include:

A. Knowledge of 29 CFR 1926.650 - 652;

B. Familiar with OSHA soil classification;

C. Understand use and application of protective systems;

D. Monitor all excavation activities for associated hazards;

E. Authorization to take corrective action to eliminate hazardous or dangerous situations; and

F. Perform inspections prior to start of work, as needed throughout shift and after everyrainstorm.

2.7 Subcontractors

A. Health & Safety Responsibility:

[1] This safety plan does not address hazards specific to specialty contractor's work(e.g., drill safety as it applies to the operation of the rig, or construction safety);

[2] The specialty subcontractor is responsible for developing health and safetyprocedures and plans specific to their work in compliance with 29 CFR; and

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3.0 REVIEW OF SITE SAFETY PLAN/DAILY SAFETY MEETINGS

3.1 Site-Specific Safety Plan

A. All personnel, including subcontractors, will read and understand the site-specific safetyplan prior to starting work.

B. A copy of the site-specific safety plan signed by all personnel will be kept on sitethroughout the project.

C. The plan will also be kept at the Envirocon Corporate Health and Safety office.

D. All revisions to the plan will be made only by Corporate Health and Safety, and sent to thejob site with a new revision number.

E. All personnel are expected to notify the Envirocon Project Manager of any situationpresenting a risk that has not been addressed in the plan.

F. The plan will be revised as jobsite conditions and hazards change.

G. Amendments to the plan will be necessary if site conditions or procedures change. Theamendments will be attached to the plan and addressed in the Tool Box Safety Meetings.

3.2 Daily Toolbox Safety Meetings

A. A Tool Box Safety Meeting will be held daily, as a minimum, but also before any newactivity and following any accident or development of new condition.

B. Attendance is mandatory for all Envirocon site personnel. Attendance for subcontractorswill be determined on a case-by-case basis by the Envirocon Project Manager.

C. This meeting will discuss the suspected hazards for that days work and what precautions arenecessary to deal with these hazards.

D. Minutes will be maintained. All legitimate recommendations will be acted upon in a timelymanner.

E. Personnel will be questioned each morning during this meeting regarding sores, cuts andwounds or any condition which may be aggravated by assigned duties or contaminants.

F. A Tool Box safety meeting will be held before any new piece of equipment is used on thejobsite.

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4.0 SCOPE OF WORK

4.1 Objective

The overall objective of this work is to excavate and remove contaminated soils from propertiesand to restore the properties to a condition comparable to that which existed before the excavation.

4.2 Envirocon Tasks (30-35 Personnel)

A. Clearing and grubbing

B. Dust abatement

C. Excavate to specified depth:

[1] Excavations greater than 18-inch depth will follow the Excavation Proceduresoutlined in Section 17; and

D. Remove patios, sheds, asphalt, and concrete surfacing

E. Remove other encumbrances as specified in the work plan

F. Load out contaminated soil for transport to Rare Earth Facility (REF)

G. Backfill with clean soil

H. Landscaping

I. Personnel:

[1] Laborers;

[2] Excavator operators;

[3] Front-end loader operators;

[4] Water truck driver; and

[5] Dumptruck Drivers (DOT)

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4.3 Subcontractors

A. Tree removal

B. Septic systems

C. Concrete workers

D. Asphalt installers

E. Surveying

F. Material Testing

G. Garage construction

H. Building moving and jacking

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5.0 HEALTH AND SAFETY HAZARD ANALYSIS

Potential health and safety hazards are summarized in this section. The SHSO is tasked tocontinuously observe site activities, and to identify potential health and safety concerns notdescribed in this HASP. These health and safety concerns will also be identified to the PM for theirinformation and action.

5.1 Radiological Hazards

Isotopes from the thorium and uranium decay chains are the radionuclides of concern at the site.These contaminants may have harmful effects on the body if they are inhaled or ingested.

Worker exposures to external whole body ionizing radiation are generally small due to the lowconcentration of thorium in the residual materials found throughout most of the Site. -Higherexternal exposures can occur in areas where larger volumes of higher activity thorium materials arepresent. These areas include the stabilization and neutralization pad, tailings and pond sedimentpiles on the disposal site, the Building 19 pad where redefined and intermediate thorium and rareearth products were stored, and process sumps and trenches located on the Factory Site.

The most significant potential pathway for radiation exposure at the Site is the inhalation of dustcontaining thorium residual materials. Work practices which minimize dust, along with good dustcontrol methods, are important factors in minimizing inhalation exposures. When work practicesand dust control methods are insufficient or infeasible, the proper selection and use of respiratoryprotection equipment will minimize inhalation exposures.

Since the primary dose pathway is the inhalation of alpha and other radioactive particles,atmospheric monitoring for these radionuclides will be conducted during all decommissioningactivities.

5.2 Chemical Hazards

Radioactive wastes are the primary hazard associated with the Site. However, initial screeningsduring the engineering report phase (1986) indicated that process residuals in the Tailings Pile andSediment Pile contained naturally occurring constituents including lead (up to 2700 ppm and up to870 ppm, respectively). Low levels of other metals, polynuclear aromatic hydrocarbons (PNAs),and phthalates were also detected during the initial screening at these Piles. Ponds 1 and 2 alsocontained relatively low levels of phthalates. Tailings Pile soils ranged in pH from 1.9 to 8.8 (themean being 3.54).

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During pre-design drilling activities on the Factory Site, volatile organic compounds (VOCs) weredetected in the bore hole in isolated areas of the Site, including RD-1 (up to 20 ppm), RD-2 (up to8ppm), and RD-4 (up to 4.4 ppm). An oily sheen was noted at RD-1 and Rd-2. Air monitoringwith a Photoionization Detector (PID) or Flame lonization Detector shall be conducted in areaswhere VOCs were detected previously. Based on low levels of VOCs detected during pre-designactivities, it is not anticipated that respiratory protection against VOCs will be necessary duringdecommissioning activities.

Personal air monitoring for airborne lead may be conducted in areas where lead has been detectedpreviously. Air monitoring results will determine protection/mitigation requirements. Lead isassociated with the Monzanite Ore and will be found in conjunction with thorium tailings. Basedon the relative concentrations of lead and thorium in the tailings and sediments, maintainingairborne releases of thorium within regulatory limits will ensure lead concentrations are belowregulatory limits.

5.3 General Hazards

Construction-related hazards that could be encountered during demolition, excavation and removalinclude the following: trips, slips, and falls; hazardous noise exposure; thermal stress; electricalequipment; lockout/tagging; a general discussion is given below; precautions for specific hazardswill be outlined in separate sections.

5.3.1 Buddy System

The buddy system will be utilized in the jobs or areas with potential hazards, i.e., confined space,torch work, excavation of previously undisturbed areas.

5.3.2 Slippery and Unstable Surfaces, Uneven Terrain

Wet conditions on the site caused by rain and/or work activities are likely to be encountered duringthe project. Employees will be informed of the hazards associated with walking on slippery and oruneven surfaces. When possible, pedestrian traffic will be redirected around potentially dangerousareas.

5.3.3 Hazardous Noise

The operation of heavy equipment will, in all probability, produce hazardous noise for site workersin the immediate vicinity. The following hearing conservation program elements will be applicableto operations at this site:

A. Hearing protection will be worn by site workers when noise producing equipment isoperating;

B. Medical surveillance will include audiometric testing; and

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6.0 RADIATION PROTECTION

6.1 Radiological Hazards

A. Envirocon recognizes that radioactive contamination may include decayed products inpaniculate and gas forms which pose the possibility of internal exposure (primary hazard)and, to a much lesser degree, external whole-body radiation exposure to workers.

B. Internal radioactive exposure exists as contaminated particulates and radioactive gases areairborne and pose inhalation and ingestion risks. These hazards will be identified in eachHASP.

6.2 Personnel Monitoring Devices

A. Personnel Dosimetry

Site workers will participate in a dosimetry program administered by the Site Manager, andimplemented by the Health Physics Department. Kerr-McGee will provide dosimetry forContractor personnel. Kerr-McGee will maintain records of radiation exposures incurred byfield personnel, including Contractors. These records will be maintained in an up-to-datemanner to comply with the requirements of 32 IAC 340.4010. During site orientation.Contractors will be required to submit to the Health Physics Department, prior to fieldactivities, radiation exposure histories for their employees. Records will be maintained inpersonnel files kept in document control. The Site Manager will review the results ofpersonal exposure monitoring to determine compliance with exposure limit requirements.

B. Requirement for Dosimetry

Any person who enters or works in a designated radiation area will be required to have apersonal dosimeter. As a matter of policy, all personnel on the property shall be required touse a dosimeter whenever they enter the Contamination Reduction Zone and ExclusionZone. An exception may be made for a group of visitors to use a single (or few) pocketdosimeters when that group will be visiting the same areas and will only be in the radiationarea for a short time, and the radiation hazard is known to be low. Dosimeters are checkedout daily at the Kerr-McGee contamination reduction zone's control point by health physicstechnicians.

C. Internal Monitoring

Will be performed as needed based upon the results of the air sampling program. Bioassaymethods to be considered should include in-vivo as well as in-vitro assessments.

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B. The site-specific Safety Plan will address all relevant worker training and medicalsurveillance as required by OSHA, state, and applicable installation requirements. Includedare the procedures that Envirocon will utilize for the identification of occupational healthhazards and the protection methods that will be implemented for the radiological hazardsencountered on site.

C. Envirocon will prevent internal exposure to particulate and gaseous radiation through dustcontrol and, if found necessary, the combined use of air-purifying and air-suppliedrespirators. The task-specific requirements outlined in the HASP will be closely followed.

D. The effects of external Alpha and Beta radiation will be minimized through use of coverallsand eye protection.

E. It is understood that protective clothing and other worn PPE will not prevent whole-bodyexposure to Gamma radiation. Avoidance techniques using distance from knownradioactive sources will be the primary control technique when Gamma sources areencountered or suspected. Areas where Gamma radiation is present will be identified usingyellow and magenta rope.

F. Envirocon understands the risks and required procedures for working with externalradiation; however Envirocon will rely heavily on real-time monitoring by Kerr-McGeeHealth Physicists of all areas and containers to ensure that whole-body exposure is not inexcess of allowable levels.

G. Control of the spread of radioactive material during the decontamination process forpersonnel and equipment is critical. Experience has shown that a well thought-out processof protecting areas and equipment that are not easily washed (seats of equipment, delicateequipment, etc.) is the first step in the decontamination process.

H. The location of the hot line beyond which no radioactive material will pass is the first step.Utilizing a systematic approach to personnel decon where likely areas of contamination onpersonnel are monitored with a monitoring instrument will confirm whether radioactivematerial is initially present and how effective personnel are in keeping measurable amountsoff their body.

I. Envirocon is prepared to equip personnel decon stations with HEP A vacuums to removeaccumulated dust on protective outer ware prior to its removal. In addition, if necessary,wash stations can be set up such that personnel can rinse/wash at the decon station if bodymonitoring indicates contamination in excess of established thresholds. Provisions would bemade for the collection of any waters/solutions considered radioactive materials.

J. Personal Protective Equipment (PPE)

PPE is in accordance with Section 8.0.

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K. Personnel Decontamination:

[1] All personnel will process through a decontamination line and remove all outerprotective clothing; and

[2] After completion of decontamination. Any personnel readings above backgroundwill be cause for redecontamination and remonitoring of that individual.

[3] Personnel contamination surveys will be conducted on each individual with a Pac-4Alpha Meter;

L. Equipment Decontamination

All equipment will be washed with water, dried, and monitored with the Pac-4 AlphaMeter.

M. Safe Work Procedures:

[1] On-site areas with radioactive readings above background survey readings will bedesignated as a restricted area; and

[2] The restricted area(s) will be posted and blocked off.

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7.2 Envirocon Medical Monitoring Requirements

Central DuPage Clinic for Business Health245 S. Gary AvenueBloomingdale, IL60108(630) 894-8404

TESTCOMPONENT

History & Physical

Audiometry

Visual Acuity

Chest X-ray (P.A.)

Pulmonary Function Test

Stool Occult Blood

CBC, Chemistry Panel

Urinalysis (Micro)

Panel Ten Drug Screen

Back Assessment

Fitness For Duty

BASELINE/sm:

yes

yes

yesyes

yes

yes

yes

yes

yes

yeslaborers &

operators only

yes

OVER EXPOSURE

XXX

XXX

N/A

XXX

XXX

XXX

XXX

IF REQUESTED

XXX

XXX

If Injured

EXITEXAMINATION

yes

yes

no

if requested

yes

yes

yes

yes

no

Yes

N/A

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8.0 PROTECTIVE EQUIPMENT

8.1 Job Task Specific Envirocon/Subcontractors Personal Protective Equipment Assignment

JOB TASK/LOCATIONRESPIRATOR

LEVELS/EQUIPMENT PROTECTIVE CLOTHINGSPECIAL SAFETY

EQUIPMENTAny Position Upgraded toLevel C

Level Cfull-face respirator withPI00 cartridges

cotton coverallswork gloves (type TBD byHSO)boot covers

leather steel toe bootshard hatssafety glasseshearing protection

Tree Removal (subs) Level D Leather work glovesfall protection equipment

leather steel toe bootshard hatssafety glasseshearing protection

Shrub Removal (subs) Level D Leather work gloves leather steel toe bootshard hatssafety glasseshearing protection

Selective Demolition withHand Tools (Envirocon)*

Level D Leather work gloves leather steel toe bootshard hatssafety glasseshearing protectionsafety vests______

Selective Demolition withPneumatic, Gas or DieselPowered Equip (Envirocon)*

Level D Leather work glovesFaceshield for Jackhammers

leather steel toe bootshard hatssafely glasseshearing protectionsafety vests______

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JOB TASK/LOCATIONRESPIRATOR

LEVELS/EQUIPMENT PROTECTIVE CLOTfflNGSPECIAL SAFETY

EQUIPMENTExcavation EquipmentOperator*

Level D work glovesboot covers

Leather steel toe bootshard hats (See 8.3B.3)safety glasseshearing protectionsafety vestsLeather work gloves outside ofmachine.

Excavation Laborer* Level D Leather work glovesboot covers

leather steel toe bootshard hatssafety glasseshearing protectionsafety vests______

Hand excavation to exposeburied electric lines.

LevelD Dielectric boots and gloves leather steel toe bootshard hatssafety glasseshearing protectionsafety vests______

Dumptruck Driver Level D leather steel toe bootshard hatssafety glasseshearing protectionsafety vestsLeather work gloves outside oftruck.

Maintain Dump Pad(laborer/sweep)

Level D Cotton coverallsLeather work glovesboot covers

leather steel toe bootshard hatssafety glasseshearing protectionsafety vests______

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JOB TASK/LOCATIONBackfill Equipment Operator

Backfill Laborer

Concrete Forming andPouring

Pressure Washing

Remove/Stockpile Asphalt*

Asphalt Paving (subs)

RESPIRATORLEVELS/EQUIPMENT

Level D

Level D

Level D

Level D

Level D

Level D

PROTECTIVE CLOTHING

Leather work gloves

Protective gloves such asrubber or nitrile for pouring.Leather work gloves forforming.

rain gear or water resistantmaterial,boot coversface shield

Leather work gloves

SPECIAL SAFETYEQUIPMENT

leather steel toe bootshard hats (See 8.3B.3)safety glasseshearing protectionsafety vestLeather work gloves outside ofequipment.leather steel toe bootshard hatssafety glasseshearing protectionsafety vestsleather steel toe bootshard hatssafety glasseshearing protectionsafety vests

leather steel toe bootshard hatssafety glasseshearing protectionsafety vestsleather steel toe bootshard hatssafety glasseshearing protectionsafety vestsleather steel toe bootshard hatssafety glasseshearing protection

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8.2.3 Action Levels as Determined by Air Monitoring for Volatile OrganicCompounds

Instrument Action Level Level of RespiratoryProtection/Action

PID/FID Continuous readings ofbackground (0.2 ppm) to 1ppm in breathing zone

Level D

PID/FID* Continuous readings of 1ppm above background 0.2)to 5 ppm in breathing zone

Level C(based on identification ofcontaminant

PID/FID* Continuous reading of 5 to250 ppm above backgroundin breathing zone

Level B (if Level C is notappropriate for contaminantidentified)

*In the event action levels are exceeded, work activities shall be halted and an attempt will bemade to identify the contaminants present using colorimetric indicator tubes for benzene sothat correct respiratory protection can be selected. The HP or CHSR shall notify the HPsimmediately and prior to upgrading the level of respiratory protection.

8.3 Protective Equipment Rules

All personnel are required to use the personal protection specified for their work. Thismay include, but is not limited to cartridge respirator, protective suit, gloves, boots, hardhat, hearing protection, and safety glasses.

A. Safety Boots/Shoes

[1]

[2]

Safety steel-toed boots that meet the requirements and specifications ofANSI Z41.1 shall be worn while working in field locations.

Boots/shoes must be in good repair and laced or fastened. Sandals andtennis-style shoes of any type shall not be worn while working.

B. Safety Hats

[1] Approved safety hats that meet requirements and specifications establishedin ANSI Z89.1 shall be worn at all times in the field or constructionzone/yard removal locations.

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[2] Safety hats are not required to be worn in vehicles (passenger cars ortrucks)or offices.

[3] Safety hats are not required in construction equipment with enclosed cabs.

[4] Safety hats must be worn in all construction equipment (loaders, bobcats,excavators, dumptrucks, backhoes, etc.) that do not have enclosed cabs.

C. Eye Protection

[1] As a minimum, ANSI-approved safety glasses with side shields will beworn at all times when working in field locations.

[2] ANSI-approved safety glasses must be worn by equipment operators whilein cabs unless eye hazards are adequately controlled by other methodslisted in the most recent eye hazards analysis for this project.

[3] Proper eye protection (goggles, safety glasses, etc.) must be worn whenperforming work with a recognized hazard to the eyes such as wirebrushing, hammering, buffing, chipping, grinding, welding, cuttingwireline, working on rust, dirty chains, cables, or handling chemicals.

[4] Special goggles or helmets must be worn while helping or working withinclose range of welders.

[5] Goggles or transparent full-face shields must always be worn whengrinding, cutting concrete, asphalt, or using jackhammers and chippinghammers.

[6] Envirocon will not provide prescription safety glasses; Envirocon willprovide safety glasses capable of fitting over prescription glasses.

[7] Clear face shields must always be worn when operating pressure washers.

D. Hearing Protection

Approved earplugs or earmuffs must be worn in areas of high noise levels. Highnoise level is defined as areas where noise levels exceed the permissible noiseexposures in 29 CFR1926.52. In absence of documented sound levels, allconstruction equipment will be considered as hazardous noise producing.

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E. Safety Vests

DOT lime green safety vests are required anytime Envirocon personnel areworking in the field around trucks and heavy equipment regardless of whether it isrunning or not; this requirement applies to equipment operators whose dutiesinvolve them leaving the cab of their equipment and working in general area.

F. Clothing

[1] Sleeved shirts must be worn on the job. Tank tops will not be allowed.

[2] Long pants shall be worn. Pants shall cover the work boot top. Shorts willonly be allowed if they are worn under coveralls.

[3] Loose or ragged clothing shall not be worn.

G. All personnel are responsible to clean and maintain the protective equipmentissued to them. Any noted defects in the equipment shall immediately be reportedto the Envirocon SHSO, Project Manager, or the site Superintendent, asappropriate.

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11.0 SITE CONTROL

11.1 General

A. The Envirocon Superintendent and Crew Foreman are designated to coordinateaccess control and security into Exclusion Zones.

B. Perimeters will be established around all active excavation areas.

C. The Superintendent and Crew Foreman will establish site security in accordancewith job tasks and job locations.

D. Unauthorized personnel will not be permitted in the exclusion areas.

11.2 Site Boundaries

A. Control boundaries between the Exclusion Zones (the contaminated areas), theContamination Reduction Zone (CRZ), and the Support Zone (clean area) aredesignated as follows:

[1] General work area consists of private residences in the West Chicago area;

[2] Haul route: see attached Traffic Control Plan;

[3] Exclusion Zone - the area where contamination is either known or likely tobe present, or because of activity, will provide a potential to cause harm topersonnel'

[4] Control line - the boundary between the Exclusion Zone and the CRZ;

[5] CRZ - the area where personnel conduct equipment and personaldecontamination - essentially a buffer zone between the exclusion zoneand the support zone; and

[6] Support Zone - situated in clean areas where the chance to encounterhazardous materials or conditions is minimal.

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B. These boundaries will be identified by boundary tape as follows:

[ 1 ] Exclusion zone - yellow/magenta rope;

[2] Control line - orange boundary fence; and

[3] The CRZs will be relocated throughout the project, as necessary, toprovide convenient decontamination station access for project personnel.

C. At this site, the boundaries are located as follows:

[1] Exclusion Zone; and[2] Contamination Reduction/Decon Area.

11.3 Site Security

Only authorized site personnel will be permitted on the Kerr-McGee Rare Earth Facilitysite in accordance with the requirements of the Kerr-McGee Site Security Plan.

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13.0 PERSONAL HYGIENE / DECONTAMINATION PROCEDURES

13.1 Sanitation

A. Drinking Water

[1] An adequate supply of potable water will be provided on site.

[2] Portable water containers will be capable of being tightly closed andequipped with a tap.

[3] Water shall not be dipped from containers for drinking purposes. Singleservice, disposable drinking cups will be provided.

[4] No one shall place any objects (e.g. soda pop, ice tea, etc.) in watercontainers.

B. Restroom Facilities

One Sanolet will be provided for each excavation crew.

C. Washroom Facilities

[1] Kerr-McGee shall provide a readily accessible lunchroom or break area.Employees shall be required to wash their hands and face prior to eating,drinking, smoking or applying cosmetics.

[2] The Kerr-McGee lavatory shall be equipped with hot and cold runningwater or tepid running water, hand soap or cleansing agent and individualhand or paper towels.

13.2 Procedure for Personnel Decontamination

All equipment and personnel will be decontaminated before leaving the site.

Envirocon shall assure that food, beverages, tobacco products or cosmetics shall not bepresent or consumed in the contaminated work area, and that they are used only in changerooms, lunchrooms, or designated areas.

A. Entering Contaminated Area through Support Zone:

[ 1 ] Pick up clean PPE and boots;

[2] All donning of clothing and equipment, taping, etc is done here;

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B. Control Point / Frisking station for entry or exit from the exclusion zone:

[1] Prior to entering this area, be sure that all personnel protective equipmentis in good working condition;

[2] Conduct final inspection of tape and PPE; and

[3] Enter Exclusion Zone.

C. Exiting Exclusion Zone

The following protocols shall be used for the decontamination stations accordingto the level of protection as follows:

1.2.

3.

4.

5.

6.

7.

8.

9.

LEVEL CEquipment drop

Outer boot/glove wash

Outer boot/glove rinse

Outer boot/glove removal

Coverall removal/disposal

Respirator removal

Inner gloveremoval/disposal

Hand/face wash

Respiratorcleaning/sanitizing

LEVEL D

Equipment drop

Glove removal (stay atsite)

Rubber Boot removalstay at site

Coverall removalstay at site

remove and frisk hardhat

Hand/face wash

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D. Emergency Decontamination

Facilities and materials for decontamination shall be provided in the immediatework area for employees to:

[1] Immediately wash the affected area which comes into contact with anycontaminated materials;

[2] Immediately flush the eyes with copious amounts of water (15 minutecontinuous flush) if the eyes come into contact with any contaminatedmaterial; and

[3] First Aid equipment is available in all Envirocon pickups and 1-Ton crewtrucks. The SHSO also has first aid equipment.

13.3 Equipment Decontamination

A. Following decontamination and prior to exit from the Exclusion Zone, theSuperintendent or a designated alternate, shall be responsible for insuring thateach piece of equipment (i.e., monitoring instruments, tools, generators, etc.) hasbeen sufficiently decontaminated.

B. Any equipment moved from either the CRZ or the Exclusion Zone will beinspected for visible contamination and survey frisked. If contamination is seen oris suspected to exist on the item, it will be thoroughly decontaminated prior tomovement outside the zones.

C. If material is judged as uncleanable it will not be used outside the ContaminationZone and will be disposed of at the end of its usefulness.

D. Decontamination shall be performed by washing the equipment with water.

E. Surface debris and dirt will be removed from small equipment and tools byscraping and washing with water.

F. Heavy Equipment/Vehicle Decontamination:

[1] Vehicles will go through a two-stage decontamination processaccomplished at the site;

[2] Vehicles will be washed with water. This will focus on any signs ofresidual dirt; special attention must be given to mudflaps, wheel wells,tracks, undercarriage and foot surfaces (cab floor, control pedals, orwalking boards); and

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[3] The vehicles will be held in the area for a short time to allow theequipment to dry and for collection of drippings.

[4] Excavators/loaders moved from one area to another will havewheels/tracks frisked and cleaned and buckets wrapped in plastic.

13.4 Disposition of Decontamination Wastes

A. All equipment and solvents used for decontamination shall bedecontaminated or disposed of with the established waste streams.

B. Kerr-McGee will assume responsibility for laundering of all coveralls, anddisposal of all boot covers and cotton gloves used during excavationoperations.

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14.0 HAZARD COMMUNICATION PROGRAM

Envirocon will be responsible for maintaining a copy of their Hazardous CommunicationProgram and MSDSs on site. The following items are specific to this jobsite.

14.1 Envirocon Hazard Communication Program

A. The Envirocon Program, in its entirety, is located in a separate labeled notebookabove the Administrative assistant's desk in the Envirocon Project Trailer. Thenotebook is available for review by employees at any time during normal workshift.

B. Subcontractors will be responsible for keeping an individual copy of theirrespective programs.

14.2 Material Safety Data Sheets TMSDSs)

A. MSDSs will be located in a separate labeled notebook above the administrativeassistant's desk in the Envirocon Project Trailer.

B. MSDSs will be available to all employees for review during the work shift.

14.3 Container Labeling

All containers received on site will be inspected to ensure the following:

A. All containers clearly labeled;

B. Appropriate hazard warning; and

C. Name and address of the manufacturer.

14.4 Chemicals Brought to the Site by Envirocon

A. Diesel.

B. Gasoline.

C. See MSDS booklet in Envirocon's Project Trailer.

14.5 Chemicals Brought to the Site by Subcontractor

A. See MSDS booklet in Envirocon's project trailer.

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15.0 GENERAL CONSTRUCTION SAFE WORK PRACTICES

A. Personnel must abide by all safety rules and procedures as described in the workrules and/or throughout the project.

B. No drinking or illegal drugs will be allowed on site. Anyone reporting to workunder the influence of alcohol and/or illegal drugs shall be subject to disciplinaryaction UP TO AND INCLUDING TERMINATION. Any employee under aphysician's care and/or taking prescribed medications must notify the SHSO.

C. Eating, drinking, smoking, and chewing gum or tobacco are allowed only indesignated areas and never in contaminated or decontamination work areas.

D. All personnel must report all injuries and/or illnesses to their supervisor. Thisincludes minor or slight injuries.

E. No firearms will be allowed on site. Anyone found with firearms in theirpossession will be subject to disciplinary action.

F. All personnel must participate in the air quality exposure monitoring program bywearing the personal monitors or sampling devices if requested by the SHSO. Anypersonnel refusing to participate in the program or who tamper with a sample willbe subject to disciplinary action.

G. All posted signs shall be obeyed.

H. All unsafe conditions or practices shall be reported to the SHSO or ProjectManager immediately.

15.1 Insects and Pests

A. Yellow jackets, wasps, and black widow spiders may be found in the area.Locations where these insects prevail should be sprayed periodically with suitableinsect spray.

B. Mosquitoes

Mosquitoes are a common pest in this area. The following practices arerecommended to reduce their frequency:

[1] Eliminate any potential breeding areas such as standing pools of water.Insure that hoses or other water containers are not leaking;

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[8] The base of the ladder must be set back a safe distance from the vertical;approximately one-fourth the working length of the ladder.

B. Rolling Scaffolds

Scaffolds will be constructed, installed, and operated as specified in the OSHAScaffolding standard, 29 CFR 1926, Subpart L. The standard providesspecifications for scaffold/ladder materials; load bearing properties; and safetydevices such as guard rails, safety belts and lifelines, and toe boards.Manufactured systems which meet the above criteria may also be used.

[1] All scaffolds more than 6-feet high shall have approved guardrails,midrails, and toeboards on all exposed ends and sides.

[2] When adequate guardrails cannot be provided where required, employeesshall wear appropriate fall protection.

[3] Only approved scaffolds shall be used.

[4] Scaffold planks must be cleated and must extend over the end supports atleast 6 inches but no more than 12 inches.

[5] All scaffolds must be at least two planks wide (20"); no employee maywork from a single plank

[6] Scaffold planks must be visually inspected before each use.

[7] Overhead protection is required if employees working on scaffolds areexposed to overhead hazards.

[8] Training requirements - see 29 CFR 1926, Subpart L.

C. Duties involving heights greater than 6 feet above the ground:

[1] Will utilize fall protection or restraint system as described in theEnvirocon Fall Protection Program;

[2] The HASP will be amended to specify type and design of fall protectionsystem on a case by case basis; and

[3] The open edges of all floors 6 feet or more above the next floor or levelshall be guarded by an approved barricade secured to prevent accidentaldisplacement.

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15.4 Portable Tools

A. Portable electrical power tools will be equipped with constant pressure switchesor controls that will shut off power when the pressure is released.

B. All tools will be equipped with appropriate guards, the guards will be properlyadjusted, and the guards will be replaced if they are damaged.

C. Hand/Powered tools may be used only for their intended purpose. The design orguard capacity shall not be exceeded or circumvented by unauthorizedattachments or modifications.

D. All portable electrical powered tools shall be double insulated or grounded.

E. Ground Fault Interrupters (GFIs) will be used with all supplemental power cords.

F. Power tools shall be hoisted or lowered by a handline; never by the cord or hose.

15.5 Housekeeping and Material Storage

A. All material shall be stored in a manner that will ensure that the material is safefrom unexpected movement, falling, rolling, blowing, or any other uncontrolledmotion.

B. Materials and supplies shall be kept away from edges of floors, stairways andaccess/egress routes (36 inches minimum).

C. Forms and scrap lumber and all other debris shall be cleared from work areas,passageways, stairs, and in and around buildings or other structures. Protrudingnails in lumber will be bent over or removed.

D. Tripping hazards, protruding nails, oil slicks, scrap materials and other hazardousconditions occurring during the course of the job shall be eliminated as workprogresses.

E. Tools and equipment shall not be strewn about where they might cause tripping orfalling hazards and shall, at the end of each workday, be collected and stored ordisposed of as appropriate.

F. All food waste and oily/greasy rag containers will be metal and shall be equippedwith tight closing lids.

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16.0 FIRE PROTECTION

16.1 General Safety Guidelines

A. All heavy equipment must be equipped with fire extinguisher rated at 5 # ABC.

B. A 20 # ABC fire extinguisher must be provided within 75 feet of but no closerthan 25 feet to all refueling operations and flammable storage areas (includinggenerators).

C. Access routes to fire extinguisher shall be kept clear at all times.

D. All fire extinguishers shall be inspected monthly.

E. All fuel cans such as 5 gallon cans shall be free of deformities and have selfclosing lids and flame arresters (i.e. safety cans).

F. Fuel cans shall be labeled as to their contents.

G. Gasoline powered equipment shall not be fueled while the engine is running, orhot.

H. All equipment shall be fueled through funnels or spouts that prevent spillage. Allspouts and funnels must be of metal construction.

I. Any transfer of a flammable liquid from one container to another requires bondingfrom one container to the other.

J. All fuel tanks set up on site will be grounded.

K. Smoking is prohibited while using, dispensing, or being around flammable orcombustible liquids, or as otherwise posted.

L. Flammable and combustible liquids shall be used and stored away from ignitionsources.

M. Oily rags, trash and other combustible scrap materials shall be placed in closedreceptacles separate from other trash.

16.2 Site-Specific Precautions

A. Firewatch with a fully charged Fire extinguisher shall be used anytime personnelare performing cutting operations.

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B. In the event of a building/facility fire:

[1] Envirocon personnel will immediately notify the Fire Department: 911.

[2] Envirocon personnel will make every attempt to fight the fire defensivelyuntil the fire department arrives.

[3] Defensive fighting will include controlling spread of flames withextinguishers or charged water hoses from a distance sufficient to preventinhalation of smoke or vapors from burning products.

[4] Personnel will NOT attempt to enter burning buildings, crawl overstructures, enter confined areas to find or extinguish flames.

16.3 Evacuation/Fire Fighting Procedures

A. If a fire or explosion occurs, personnel shall evacuate the area, making sure thatthe excavation route will put distance between themselves and the incidentwithout passing through smoke. The gathering location shall be establishedupwind from the area of concern.

B. As soon as all personnel are safely away, the incident shall be reported to theEnvirocon Project Manager:293-6354 or Radio Channel 3A. The EnviroconProject Manager will notify Kerr-McGee.

C. Upon notification of a fire or explosion on site:

All site personnel shall assemble at the Crew Truck.

D. The fire department shall be summoned, and all personnel moved to a safedistance from the involved area according to procedures identified above.

E. Upon the arrival of the fire department, the SHSO or PM will advise the firecommander of the location, nature, and identification of the hazardous materialson site.

F. If the fire is small or confined, to fight the fire personnel may fight a smalllocalized fire with defensive attempts including on-site fire extinguishingequipment, and/or remove or isolate flammable or other hazardous materialswhich might contribute to the fire.

G. Support the fire department response forces as appropriate (probably will belimited to providing information regarding site activities, hazards, and missingpersonnel, if any).

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17.0 EXCAVATION, TRENCHING, AND SHORING

17.1 General Sloping Requirements

Wherever people enter excavations 4 feet or deeper, sides will be sloped utilizing OSHArequirements, or alternate methods such as approved trench boxes or shoring will be used.

SOIL ORROCK TYPE

Stable Rock

Type A Cohesive

TypeBCohesive/Granular

Type C Granular

EXAMPLES

Clay, Hardpan, Silty Clay

Silt, Unstable Rock, sandyLoam, Fissured type A

Gravel, Submerged, Loamy,Sand

MAXIMUM ALLOWABLE SLOPESHORIZONTAL TO VERTICAL

FOR EXCAVATIONS > 20 FEET DEEP

Vertical ( 90 Degrees)

3/4 : 1 (53 degrees)

1 : 1 ( 45 degrees)

1.5 : 1 (34 degrees)

A. Whenever, groundwater may be encountered; specific classification and slopedeterminations will be made on site by Competent Person.

B. An additional > 0.5 H : 1 V slope will be added if flowing conditions areencountered at the toe of the slope where personnel are working.

17.2 Site-Specific Requirements

A. All excavation soils will be considered as Type C.

B.

C.

Excavations greater than 4 feet in depth requiring personnel entry will be sloped atan angle of 1.5 to 1 (34 degrees).

Personnel will not be allowed in excavations if gasoline (CO producing) enginesare exhausted into the excavation until the atmosphere has been tested anddeemed safe.

17.3 General Safety Precautions

A.

B.

C.

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Ramps will be constructed as determined by the Superintendent to allowequipment to enter and exit.

Soil samples will be collected from the excavation after the contaminated soil isremoved.

In excavations where employees may be required to enter, excavated or othermaterials shall be effectively stored and retained at least 2 feet or more from theedge of the trench.

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D. In excavations where employees may be required to enter, excavations of greaterthan 4 feet shall have the atmosphere tested before each entry and as conditionschange.

E. Employees exposed to vehicular traffic shall be provided with and instructed towear warning vests made of reflective or high visibility materials.

F. All employees in trenches shall wear the appropriate PPE, e.g., hard hats, safetyglasses, hard-toed boots, etc.

G. No employees will be permitted under loads handled by shovels, derricks, orhoist.

H. Conditions shall be maintained so that no visible dust is generated.

I. Where employees or equipment are allowed to cross over excavations, allwalkways and/or bridges will have guardrails and toeboards.

J. Adequate barrier protection will be provided for excavations (e.g., reflective conesor sawhorse barriers).

K. Each excavation must be inspected daily. If evidence of cave-ins or slides isapparent, all work in the excavation must cease until necessary precautions havebeen taken to safeguard employees.

L. Where vehicles or equipment operate near excavations or trenches, the sides ofthe excavation must be shored or braced as required to withstand the forcesexerted by the superimposed load.

M. Safe access must be provided into all excavations by means of ladders, stairs orramps requiring no more than 25 feet of travel to access them.

N. Personnel in excavations will not work under suspended loads. The use of taglines should be used to control material rotation.

O. Work activities on the surface of the excavated area will be restricted to preventworking above personnel.

P. All excavated material and other loose objects will be kept at least 2 feet awayfrom the edge of the excavation or restrained.

Q. Banner guard and barriers will be placed across the access road to the excavationareas at night to protect and warn personnel if necessary as determined by theSHSO or PM.

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R. Personnel exposed to traffic will wear high visibility vests; DOT lime green fordaytime and reflective for night operations.

S. Prior to commencing excavation work on a property, the ExcavationSuperintendent and crew foreman will complete a property checklist form andsubmit it to the Project Manager.

17.4 Underground Utility Lines

A. Be aware and always suspect the existence of underground utilities such aselectrical power, gas, petroleum, telephone, sewer and water.

B. Overhead and buried utilities should be located, noted and emphasized on allexcavation and property drawings (regardless of depth of excavation).

C. When overhead electrical power lines exist at or near an excavation site, considerall wires to be alive and dangerous.

D. Locate underground utilities by contacting local water, phone, and electric andcable TV companies. At this site the number is:

JULIE: 800- 892 -0123

E. If a sign warning of underground utilities is located on a site boundary, do notassume that underground utilities are located on or near the boundary or propertyline or under the sign. Telephone the utility company and check it out. Theunderground utilities may be considerable distance away from the warning sign.

F. Initial Survey:

[1] JULIE representative will perform initial survey and mark location withflags and paint marks on ground;

[2] Experience has shown that the JULIE identification will indicate thepresence within 2 feet;

[3] When excavation depths exceed 18 inches, the Envirocon Project Engineermay do a follow-up survey with the Ditch Witch; and

[4] A Laborer will then perform a series of hand potholes to the depth of thelines to pinpoint location.

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f. If buried electric lines located within an area to be excavated cannot be relocated or deenergized, excavation around the line will benecessary. Excavation around buried electric lines shall beconducted in accordance with the following:

Crew Foreman shall notify the SHSO prior to commencing anyexcavation work on the property.

SHSO will closely monitor excavation around the buried electricline.

Locate the horizontal and vertical location of the buried line byhand digging a series of pothole.

Expose the entire length of the buried line which is located withinthe area to be excavated by hand digging. Machine excavationaround buried electric lines is prohibited.

Once the entire length of the buried line has been exposed, paintthe line with orange spray paint so it is highly visible.

Items listed above shall be completed prior to starting any machineexcavation work on the property.

H. Excavation of and Around Buried Utility

[ 1 ] All excavation of and around the gas or electric utility will be done only byhand shovel.

[2] SHSO will supervise excavation and gas/electric lines.

I. Once located, the utilities shall be protected, supported or removed as necessary toprotect employees.

J. In the event that a gas or electric line is severed or damaged, the job will be shutdown immediately, personnel should be evacuated from the area and the ProjectManager notified.

17.5 Trenches

A trench is an excavation in which the depth exceeds the width. Excavations more than15 feet wide at the bottom are not trenches despite depth. Trenches more than 4 feet indepth must either be shored supported or the excess height laid back. For more detailed

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information on excavation and trenching, please refer to OSHA Standard 1926.650Subpart P. Following is a list of do's with regard to trenches:

A. Before making an excavation opening, check with local utilities e.g., sewer lines,telephone lines, water lines, fuel lines, and electric lines;

B. All trenches more than 4 feet deep have to conform to OSHA regulations forsloping/shoring depending on soil type A, B, or C (see OSHA Standard 1926.650Subpart P). Others less than 4 feet may require sloping/shoring based on acompetent person's judgement; and

C. Access and egress (ladders, ramps, stairways) are to be provided within 25 feet oflateral travel along the trench.

17.6 Competent Person

A. Will supervise each excavation where personnel are required to enter or work.

B. Oversee all operations while employees are in the excavation.

C. Will make a daily inspection of the excavation area before each shift begins, afterany changes in the excavation area or after a rainstorm.

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EXCAVATION COMPETENT PERSON DESIGNATION

The following individual has been designated as the "Competent Person," meaning one who iscapable of identifying existing and predictable hazards in the surroundings or working conditionswhich are unsanitary, hazardous, or dangerous to employees, and who has authorization to takeprompt corrective measures to eliminate them.

The person named below has knowledge of the systems, equipment, conditions and procedures inrelationship to the proper use, inspection, manufacturer's recommendations and instructions, andmaintenance as designated below. This person has been delegated the responsibility to coordinateall activities and operations of as defined by the designation(s).

An evaluation conducted by the Contractor has determined that this person is qualified as thecompetent person in the designation(s) named.

i^^^mmmm^^)Robert Valdez

Rex K. Long

Dean Biegel

Steve VonMotz

Kevin Uranich

;• ;. ̂ HWY

Envirocon

Envirocon

Envirocon

Envirocon

Envirocon

COMPETENT PERSONExcavation

Excavation

Excavation

Excavation

Excavation

Created 11/97Revised 03/27/00

58

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18.0 TREE TRIMMING / REMOVAL PROCEDURE

18.1 Chain Saw

A. All chain saws must have an automatic chain brake or kickback device.

B. The idle speed shall be adjusted so that the chain does not move when the engineis idling.

C. Operators will wear the following personal protective equipment (PPE):

[ 1 ] Steel toe leather boots;[2] Safety glasses;[3] Hardhat;[4] Hearing protection; and[5] Leather gloves; and[6] Chainsaw chaps

D. Chain saws will not be fueled while running, hot, or near open flame.

E. The operator will hold the saw with both hands during all cutting operations.

F. The chain saw must never be used to cut above the operator's shoulder height.

18.2 Tree Removal

A. Prior to removal operations, the employee shall consider:

[1] The tree and surrounding area for anything that may be potentiallydamaged during tree removal;

[2] The shape of the tree, the lean of the tree, and decayed or weak spots;

[3] Wind force and direction;

[4] Location of other people;

[5] Above-ground utility lines and electrical hazards; and

[6] Steps shall be taken during the removal of all trees to ensure that propertyimprovements which are not planned to be removed as part of theremediation activities are not damaged.

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B. Prior to felling operations, the work area shall be cleared to permit safe workingconditions and an escape route shall be planned.

C. Tree cutting teams will work in pairs.

D. Each worker shall be instructed as to exactly what he is to do.

E. All workers not involved in the operations shall be kept clear of the work area.

F. Before cutting, the operator shall be sure of his footing and must clear away brush,fallen trees, limbs and other materials that might interfere with cutting operations.

G. The employee shall work from the uphill side whenever possible.

H. Just before the tree or limb is ready to fall, an audible warning shall be given toall those in the area; all persons shall be safely out of range when the tree falls.

I. If there is danger that the trees being felled may fall in the wrong direction ordamage property, wedges block and tackle, rope, shall be used to lower limbs tothe ground. Section of trees will be cut small enough to ensure their decent can becontrolled.

J. All limbs shall be removed from trees to a height and width sufficient to allow thetree to fall clear of any wires and other objects in the vicinity.

K. Special precautions shall be taken when roping rotten or split trees due to thepotential for falling in an unexpected direction even though the cut is made on theproper side.

L. Persons shall be kept back from the butt of a tree that is starting to fall.

M. In general, trees are to be taken down and removed in sections or parts. Freefalling of trees is not allowed without prior approval from Envirocon's Projectmanager.

18.3 Working From Branches/Fall Protection

A. All cutting involving personnel working at heights greater than 6 feet above thebase of the trunk will utilize fall protection systems.

B. Options:

[ 1 ] Hydraulic manlift; and[2] Personnel secured to trunk of tree.

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[3] Park on level ground when possible or at right angles to any slope;

[4] Apply parking brake;

[5] Block the wheels on a slope or incline; and

[6] Jumping on or off equipment is prohibited; employees climbing on or offequipment shall face the equipment and use handrails, handholds, andsteps provided.

J. Employees shall not ride on the outside of mobile equipment.

K. At no time shall an operator allow anyone to ride in or on a piece of equipmentwithout a seat and seat restraints in place.

L. Employees shall not get on or off moving equipment.

M. Driving Speed:

[ 1 ] Match the speed of your machine to the job conditions; and

[2] Know the stopping distances at any given speed, slope, or groundconditions.

N. Headlights:

[1] Headlights should be used at all times on active site haul roads; and

[2] Headlights should be used anytime visibility is poor (dusk, dawn, highdust, rain, snow).

O. Equipment or vehicles shall not be driven over compressed air or oxygen andacetylene hoses unless the hoses have been physically protected from damage.

P. All vehicles used in hauling, whose payload is loaded by cranes, power shovels orsimilar equipment, must have a cab shield and/or canopy strong enough to protectthe operator from shifting or falling materials.

Q. Dump trucks or vehicles with raising platforms or beds must be equipped with apermanently attached, positive means of support which can be locked in positionto prevent accidental lowering of the body.

R. All vehicles with cabs must be equipped with windshields wipers and rear viewmirrors.

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S. When Loading/Unloading Equipment:

[ 1 ] Load or unload only on level ground/platform/surface;

[2] Block the transport vehicles wheels to prevent movement/shifting;

[3] Use ramps with sufficient strength, height, and angle;

[4] Make sure the trailer bed is free of all slippery materials such as clay oroil;

[5] Know the manufacturer's recommended procedure for loading andunloading your machinery; and

[6] Be sure the equipment is properly secured before moving the trailer.

T. Site Haul Routes:

[1] Heavy equipment work areas and haul routes should be established to indesignated areas;

[2] Loaded vehicles have right-of-way on haul roads; and

[3] Dumptrucks driving to and from excavation areas shall follow the haulroutes depicted in the attached Traffic Control Plan.

U. Safe Operation Around Highwall:

[1] Machine's weight and vibration can cause the edge of a highwall tocollapse; keep the machine back from the edges of banks or excavations;and

[2] If the machine cannot be kept back from edges, face the machine towardsthe banks edge while operating.

V. Overhead Hazards:

[1] Investigate haul route or work area for overhead hazards including trees,banks, falling rocks, and overhead wires;

[2] Use spotter if unable to gauge or see distance from cab; and

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[3] If machine comes in contact with charged lines, remain in the cab anddon't let anyone close to the machine until power has been cut off orsource has been broken.

W. Equipment Shut Down Procedures:

[ 1 ] Lower all attachments completely to the ground;

[2] Put all controls in neutral;

[3] Shut off the engine after allowing it to idle and gradually cool down;

[4] Set the transmission lock and the parking brake;

[5] Remove any keys; and store in central controlled location

[6] Install and lock all vandalism guards;

[7] All equipment left unattended at night, adjacent to a highway or activeconstruction site must have lights, reflectors or barricades with lights orreflectors;

[8] Equipment parts or machinery which are suspended or held aloft by slings,hoists or jacks must be substantially blocked or cribbed to prevent fallingor shifting before employees are allowed to work under them;

[9] Bulldozer and grader blades, end-loader buckets, dump bodies and similarequipment must be fully lowered or blocked when not in use or beingrepaired; and

[10] All controls must be in a neutral position, with the motors stopped andbrakes set, unless the work at hand requires otherwise.

19.2 Operator Care

A. Each individual operator is responsible to verify the safe operating condition of avehicle prior to its operation. This verification includes but is not limited to:

[1] Inspection and operation (i.e., lights, turn signals, seat belts, wipers, etc.)of all vehicle safety equipment;

[2] Safe operation of mechanical systems (i.e., brakes, steering, etc.);

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[5] Inspections shall include the following items:

a. Service brakes, including trailer brake connections;b. Parking system(hand break);c. Emergency stopping system(brakes);d. Tires;e. Horns;f. Steering mechanism;g. Coupling devices;h. Seat belts;i. Operating controls;j. Safety devices;k. Lights (where required);1. Reflectors (where required);m. Windshield wipers;n. Defrosters;o. Fire extinguishers;p. Audible backup warning device;q. Rear view mirror or mirrors;r. Non-slip step surfaces;s. Intact safety glass; andt. Safety chains on tow trailers.

[6] See attached checklists. Inspection checklists shall be turned into theSuperintendent daily.

D. Before moving the machine, test all your controls for proper functioning:

[ 1 ] Service and parking brakes;

[2] Governor control lever; decelerator lever;

[3] Attachment controls;

[4] Recheck lights, back-up alarms and other warning devices;

[5] Check gauges for correct readings; shut down the machine if you seeimproper readings; and

[6] Listen for unusual noises coming from the engine or gear compartments.

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E. Attention to Personnel Around Machinery:

[ 1 ] Never allow riders on your machine;

[2] Never let anyone stand in the pivot area of an articulated machine whilethe engine is running;

[3] Never move or hoist a load over the heads of other workmen or over truckcabs;

[4] Before starting or backing up, make sure that the immediate work areaaround your machine is clear of all personnel;

[5] All equipment operators shall pay deliberate attention to watching forworkers on the ground and provide warning to these people beforemoving; and

[6] Operators shall not permit any person to ride on any vehicle or equipmentthat is not specifically designed for carrying passengers (i.e. no riding intruck beds).

F. Vehicle operators shall not wear any devices other than hearing protection whichrestrict or impair hearing or vision (e.g., radio headphones).

G. No vehicle shall be loaded in a manner which obscures the driver's view in anydirection or interferes with the safe operation of the vehicle.

H. All vehicle loads shall be secure and vehicles shall not be loaded beyond theirrated capacity.

I. It is the responsibility of the equipment operator to make the machinery safe priorto leaving the cab or equipment control area.

J. The equipment operator will ensure that End loader buckets, dozer/scraper blades,dump bodies and similar equipment are fully lowered or blocked when not in useor being repaired.

K. The equipment operator will ensure that all controls are in a neutral position anddisengaged or with the motors stopped when the equipment operator is not insidethe cab or at the controls.

L. It shall be the driver's responsibility to ensure safe passage of the vehicle and loadunder power lines or other overhead obstructions. If the driver can't ensure it, theymust request the assistance of a 'spotter1.

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M. During periods of poor weather or deteriorated road conditions, vehicle operatorsshall reduce speed, increase following distances, and use other defensive drivingmeasures appropriate to the situation.

N. No vehicle or equipment shall be put in motion until all window surfaces are clearof obstruction (e.g., dirt, snow, ice, frost).

O. When backing in congested areas, where vision is obstructed or at unprotectededges, a spotter should always be used. Backing should always be done slowly,looking for other objects in the area.

19.3 Safety Procedure for Support Personnel When Working Around Heavy Equipment

The following steps must be taken by Envirocon or subcontractor personnel to ensure thataccidents involving contact with heavy equipment do not occur. These requirements arespecified in OSHA Regulation 29 CFR 1926.600 with interpretive guidance provided bythe OSHA Construction and Engineering Office, Washington D.C.

A. When working around operating or moving equipment, all personnel shall:

[ 1 ] Listen for warning signals on construction equipment;

[2] Yield to construction equipment; and

[3] Insure they have made eye contact with equipment operator beforeapproaching.

B. Anytime that personnel are approaching heavy equipment, it is the responsibilityof the person approaching or working around the equipment to establish eye oraudio contact with the equipment operator.

C. Employees are Not permitted to work under or between heavy machinery,equipment or associated parts which are suspended or capable of shifting.

D. Envirocon personnel shall not enter a confined area (demolition, drop box, sump,etc.) while it is being loaded or filled by loaders, track-hoes, dumptrucks, etc.).

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E. The assigned equipment operator is the only person authorized to enter the caband/or operate the machinery; all other personnel must be specifically authorizedor instructed by the Site Superintendent or Site Project Manager to enter, inspector perform maintenance.

F. Heavy equipment/haul trucks have right-of-way.

19.4 General Vehicle Rules

This category includes pickups, 1-tons, and sedans rented or leased. These guidelines arein addition to requirements in the Envirocon Vehicle Policy.

A. MAXIMUM SPEED is 15 mph on all site roads unless otherwise posted.

B. All emergency vehicles (lights flashing), heavy equipment and haul trucks havethe right-of-way; pull to the right and stop; continue when it is safe to do so.

C. Wearing of seat belts in all vehicles so equipped is mandatory for drivers andpassengers.

D. Professional drivers (bus, truck, etc.) are required to have a state driver's licensewith the proper endorsements or DOT Commercial Driver's License (CDL).Personnel tasked with chauffeuring Envirocon/Joint Venture personnel shall havea commercial driver's license.

E. Drivers will use caution and reduce speed when approaching guarded orunguarded railroad crossings.

F. All buses and trucks carrying hazardous materials must stop at railroad crossingsthat are not controlled by signal devices.

19.5 General Use of Class II/III Vehicles

A. Definitions

[1] Class II

a. Those used for business use and also for commuting (defined astravel to and from authorized business sites, destinations).

b. Such commuting is allowed when, in the opinion of management,the commuting directly benefits the Company.

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[2] Class III

a. Those vehicles designated for business only.

b. These vehicles will remain on the project or the designatedEnvirocon office and not be used for commuting other than to andfrom the designated parking area to the project/office locations.

c. These vehicles will be parked in designated parking areas andstored on the Company premises when not in use or after hours.

d. Vehicles may be taken off the project site or from the office forbusiness uses such as picking up parts, etc.

B. Envirocon general policies and procedures specifically forbids the use ofEnvirocon owned or leased vehicles for non-authorized company business orpersonal use.

C. If damages or injuries are incurred during unauthorized use, you and/or yourinsurance company will be held liable.

D. The following items may result in suspension, permanent loss of vehicle usage, ortermination:

[ 1 ] Unauthorized personal use of company vehicles;

[2] Driving while under the influence of alcohol or drugs;

[3] Consuming alcoholic beverages or drugs while or prior to driving;

[4] Accidents or abuse of equipment;

[5] Knowingly allowing a subordinate or unauthorized person to violate thispolicy;

[6] Operating the vehicle in an unsafe manner. If the company has reason tosuspect that an individual has or is operating a company vehicle in amanner dangerous to himself or others, the individual may lose drivingprivileges; and

[7] Moving traffic violations.

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D. Conspicuous and legible signs prohibiting smoking or open flames shall be postedat the area.

E. The motors of all equipment being fueled shall be shut off during the fuelingoperation.

F. Each service or fueling area shall be provided with at least one fire extinguisherhaving a rating of not less than 20 B:C located within 75 feet of each pump, butno closer than 25 feet.

G. Fuel cans should never be filled while in the back of a truck bed. The can shall beplaced on the ground before filling to avoid any potential generation of staticelectricity

19.7 Hydraulic Excavators

A. Keep the boom 10 feet or more from all power lines.

B. When moving your excavator over a long distance, position the boom in thedirection of travel, unless moving up a steep slope.

C. When Travelling Up/Down Slopes:

[1] Raise the boom and curl the stick and bucket sufficiently to maintainstability;

[2] While travelling up a slope, you can maximize machine's stability byfacing the heavier engine side of the machine uphill; and

[3] Your machine's boom will be in the direction of travel only whentravelling down a slope.

D. Watch your boom clearance when travelling; uneven ground may cause the boomto weave or bob into overhead obstructions.

E. Loading Trucks:

[ 1 ] Load trucks from the rear or from the side;

[2] Load evenly;

[3] Never swing over the truck cab; and

[4] Make sure the truck driver remains in a safe position.

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D. When dumping into a ditch or off a highwall, keep a berm at the edge of the drop-off as a safety stop for the truck's rear wheels.

E. When the underfooting is too soft for your truck, dump your load back from theedge of the fill so that a track-type tractor can safely finish moving material intothe fill.

F. Do not move the truck bed hoist to the dump position until the truck is stopped.

G. Fully lower the truck bed before pulling away from the dumping area.

H. On downgrades, put your truck in the proper gear and use the retarder wheneverpossible to prevent excessive brake wear.

I. Following Vehicles:

[1] Always give yourself enough room to stop safely when following anothervehicle;

[2] Maintain a timed interval between your vehicle and the vehicle in front ofyou of one second for each ten feet of vehicle length; and

[3] Slow down when approaching blind curves or switchbacks.

J. Pass on the haul roads only in designated areas.

19.10 Water Trucks

A. Be aware that a loaded water truck has a much higher center of gravity than anempty one:

[ 1 ] Make slow gradual turns; and

[2] Choose level paths; avoid driving on side slopes.

B. Never operate without the seatbelt in place.

C. Inspect hoses, valves, couplers, nozzles and spray bars before operating each dayto ensure they are in proper working order.

D. Never back-up to the edge of a cut or excavation without a spotter to prevent theedge from breaking away. Keep in mind the 2 foot rule.

E. If your spray bar won't reach an area, use hoses and nozzle to prevent accidents.

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F. Wheels will be chocked each time the vehicle is parked at the job site foroperations.

19.11 Equipment Abuse

A. Any violation of the preceding safety rules will be considered as vehicle orequipment abuse.

B. All incident of equipment abuse shall investigated by SHSO and SiteSuperintendent and documented on the Envirocon Safety Violation/IncidentReport form.

C. The Incident Report form should be given to the Project Manager the day of theincident.

D. The Project Manager in conjunction with the Vice President of operations andEnvirocon Corporate Health and Safety will make a determination regardingdisciplinary actions and assignment of repair costs.

19.12 Subcontractor Responsibilities

A. Insuring that their employees follow, as a minimum, all safety procedures outlinedabove.

B. Ensuring the On-site rules of the road are given to all employees, new hires andrehires during the orientation.

C. Ensuring Each employee driving a vehicle shall have in his/her possession a validstate driver's license for the type of vehicle driven.

D. Investigating motor vehicle accidents involving their employees.

E. Ensuring permits are obtained for oversized loads.

F. Motor vehicles shall have seat (safety) belts for each passenger.

G. Passengers riding in vehicles which are equipped with seat belts shall wear theirseat belts at all times while the vehicle is in motion.

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B. Protective Clothing

[ 1 ] All welders/cutters shall wear flameproof gauntlet gloves.

[2] Flameproof aprons made of leather, or other suitable material, must beused as protection against radiated heat and sparks.

[3] Leather jackets will be utilized if personnel are performing hotcutting/welding work above their shoulders.

[4] Nylon clothing is not permitted for welding/cutting operations.

[5] All outer clothing, such as jumpers or overalls, should be free from oil orgrease.

C. Respiratory Protective Equipment

[1] When respiratory protective equipment is required, the contractor writtenRespiratory Protection Program shall be adhered to.

[2] Respiratory protection will be required depending on job duration andcontaminant specific personal time weighted average air sample results.

20.4 Gas Welding and Cutting Safety

A. Fuel-gas hose and oxygen hose are easily distinguishable from each other.

[1] The contrast is made by different colors or by surface characteristicsreadily distinguishable by touch.

[2] Oxygen and fuel-gas hoses shall not be interchangeable.

[3] A single hose having more than one gas passage shall not be used.

B. When parallel sections of oxygen and fuel-gas hose are taped together, not morethan 4 inches out of 12 inches shall be covered by tape.

C. All hose in use shall be inspected at the beginning of each working shift.Defective hose shall be removed from service.

D. Hoses, cables, and other equipment shall be kept clear of walkways, ladders, andstairs.

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23.0 EMERGENCY PROCEDURES

23.1 Responsibilities

The SHSO has the responsibility for ensuring that the provisions of this HASP areadequate and implemented in the field. Changing field conditions may require decisionsto be made concerning adequate protection procedures. The SHSO is also responsible forconducting site inspections on a regular basis to ensure the continuing effectiveness ofthis HASP.

23.2 Emergency Contacts for Site

Fire: 911

Police: 911

Ambulance: 911

Hospital:

Minor Injuries: Central DuPage clinic for Business Health:(630) 894-8404

Serious Injury: Central DuPage Emergency Room:(630) 682-1600

ENVIROCON SAFETY HOTLINE: 800-224-7389

23.3 General Emergency Procedures

A. The SHSO shall be notified of any on-site emergencies and shall be responsiblefor ensuring that the appropriate procedures are followed. The following standardemergency procedures will be used by on-site personnel. The Project Managerwill notify Kerr-McGee as soon as the situation is under control.

B. In the event that there is an emergency in the Exclusion Zone, or immediatenotification of project personnel is needed, audible signals previously describedwill be used.

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23.5 Personnel Injury in the Exclusion Zone

A. Upon notification of an injury, the base station will be notified via radio.

B. The SHSO and PM (or the senior individual certified in First- Aid and CPR) willevaluate the nature of the injury, and ensure that injured personnel aredecontaminated.

C. If required, the medical facility will be notified and ambulance support requested.

D. No persons shall reenter the Exclusion Zone until the cause of the injury isdetermined and corrective procedures implemented (if needed).

23.6 Emergency Decontamination

Injured or affected personnel must be decontaminated. If decontamination is not possibleor feasible, the injured person will be transported to the medical treatment facility in hisprotective clothing. The medical treatment facility officials will be notified that apotentially contaminated casualty is in transit. The SHSO will assist the medical officialsin preparing to receive the casualty, advice in appropriate protective equipment andprocedures, and assist in clean-up after treatment is completed.

A. HP carry emergency eyewash stations in each truck.

B. Emergency decontamination will include the following stations*:

..i'-';^>-'y" "<«.''"'•;• : . . :, I'"£Ki

1.4.

5.

6.

7.

;; iCl:i(liii?^v : -Equipment drop

Outer boot/glove removal

Coverall removal/disposal

Respirator removal

Equipment dropBoot/glove removal

Coverall removal

If circumstances dictate that contaminated clothing cannot be removed, wrap injuredpersonnel with clean garments, blankets, etc., to avoid contaminating other personnel andtransportation equipment. Notify the medical facility that injured personnel have notundergone decontamination.

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MAP DEPICTING ROUTE TO NEAREST MEDICAL FACILITIES

KERR-McGEEWEST CHICAGO SITE

^oosevaran .

I

>AOE

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fotm 1406.0040039/10/97

EQUIPMENT TRANSFER INSPECTION FORM

torn Information:DateEquipment NumberMoke / ModelMteoge

To Information:DateProject NomeProject NumberInspected By

Run engine before making inspection. Note recent repairs and problems in 'Comments'

Good Poor Comments1NGINE/ELECTRICAL

Ol PressureWater TemperatureAir CleanerExhaust SystemOl LeaksHour MeterBeltsCooing SystemFuel SystemWiring /Work LightsAlternatorStarting SystemBatteries

:AB/CANOPYWindows / Doors / GlassHand Rails / Steps

U__-€/DOZERCutting EdgesPush ArmsCracked/PatchedHoses / GuardsRipper/Winch

3UCKET/SOOMCutting Edges / Te,*(hThumbCracked / PatchedPins and Bushinas

WHEELS / TIRES / BRAKESCracks /Splits /Wear

JNOERCARRIAGETracks / Rollers / GuardsDamage_______

1YDRAUUCS / HYDROSTATICS___Leaks / Seepage_______MISCELLANEOUS

Operation and Maint ManualOther ManualsComponents / extra filters / etcSeats and seat beltsHeater /Defroster /ACBackup Alarm / Horn

'tonal Comments:

Distribution:Original - Equipment Manager Copy - Oiginaloi

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TRAFFIC CONTROL PLANANN ST.

ALIEN AVE.ARBOR AVE.AURORA ST.BARBER AVE.

BELLVIEW AVE.BISHOP AVE.

BLAIR ST.BLAKELY AVE.

BROWN ST.CENTER ST.CHURCH ST.

CLAREMONT AVE.CONDE ST.

EASTON AVE.ELITE AVE.

ELMWOOD AVE.FACTORY ST.FOREST AVE.FREMONT ST.

GALENA ST.GEORGE ST.GENEVA RD.

GRAND LAKE BLVD.HAHNDORF ST.

HIGH ST.JOUET ST.LANE RD.MAIN ST.

McCONNELL AVE.NATIONAL ST.PARKER ST.PEARL ST.PINE ST.

POMEROY ST.PRINCE CROSSING RD.

RIDGELAND AVE.RIVER GLEN RD.

SHERMAN ST.SPENCER ST.STIMMEL ST.ROUTE 38ROUTE 59

WASHINGTON ST.WEYRAUCH ST.

WILSON ST.WOOD ST.YORK AVE.

LfCfUD!

PKOPEKJXS TO BE CLEWS) UP W 1999

i nwnc ROUTES

Wast Chicago PoliceOapt. Approval of Design: