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ATC Associates Inc. OV TC 1117 Lone Palm Avenue, Suite 201 Modesto, California 95351 209-579-2221 ASS O C I ATE S INC , faX: 209-579-2225 HEALTH AND SAFETY PLAN ATC has established a Health and Safety Program (HSP) to ensure the personal health and safety of ATC employees . The HSP defines safety practices and procedures to be instituted in ATC work places , as applicable . The program meets , and often exceeds , the requirements promulgated by the Occupational Safety and Health Act (OSHA) . As part of the HSP , ATC personnel are appropriately trained and under a Medical Surveillance Program in accordance with OSHA 40 CFR 1910 . 120 . ATC's primary mechanism to ensure employee, environmental , and public safety at the project site will be the Health and Safety Plan (HASP) . ATC will update , approve and implement a revised HASP based on the work scope activities associated with this Workplan . All individuals working under the purview of ATC will be required to read and sign the HASP to acknowledge their understanding of the information contained in it. The HASP will be site-specific and task-specific, describing hazardous conditions that may be encountered and prescribing the necessary safety protocols to protect employees from these hazards. The HASP will be reviewed by the project management team and then reviewed and approved for field use by the Site Health and Safety Officer. The HASP will be implemented and enforced on site by the assigned Site Health and Safety Officer. At a minimum , the HASP will identify: roles and responsibilities of key site personnel ; hazard analysis for all chemical , physical , and physiochemical hazards anticipated ; a personnel protection plan ; site safety procedures for specific site operations , (e.g . , drilling , etc. ) ; a decontamination plan ; and an emergency response/contingency plan . The HASP will specify levels of protection for site personnel on a task-specific basis . As with any project of this magnitude , there are inevitable encounters with a variety of physical hazards ranging from simple housekeeping to temperature extremes . ATC will provide continual evaluation of all potentially hazardous conditions , as the project is undertaken and prescribe additional safety protocols to protect site personnel as needed . PERMITTING ATC will pursue an access agreement with the Reclamation District to install remediation wells on the levee adjacent to Honker Cut. When the Reclamation district has granted permission to install wells on the levee, ATC will complete and submit the necessary drilling permit application to the SJCEHD prior to initiating fieldwork activities . Once approved by SJCEHD , ATC will schedule the drilling activities and notify SJCEHD at least 48 hours in advance for the requisite grout inspections . WELL INSTALLATION The general locations and construction details of the proposed wells were selected after consideration of the geometry of the contaminant mass, the stratigraphical information obtained from previous site work and the patterns of groundwater elevation observed and recorded at the site . The locations of the proposed wells are shown on the KIR 2009 WP for Pilot Testing.doc ATC Associates Inc. S:IEnvironmentah62514 — KIR ATC Project No. 54.62514.0001 Page 7 I