|
•
<br />FIELDWORK HEALTH & SAFETY PLAN (HASP) FOR FIELD INVESTIGATIONS OF PETROLEUM DISTILLATE FUELS
<br />All pressured lines and fittings should be 'tethered' or otherwise secured to minimize whipping or'launching' of lines in the event of an equipment
<br />failure. Any "quick connect" type fittings (compressed air or fluid) should be secured with appropriate pins, clips to prevent accidental disengagement
<br />of the fitting during operation.
<br />Inspect all equipment, hoses, pressure lines, and fittings daily and prior to pressurizing.
<br />Chemical Storage
<br />Some injection chemicals, such as strong oxidizers, may have stringent storage requirements per local or National Fire Codes. Verify that appropriate
<br />storage provisions are in place prior to starting work.
<br />NOTE: Counties and cities may have requirements specific to storing these chemicals. Also, storage and use of certain chemicals such as potassium
<br />permanganate and hydrogen peroxide may be subject to the new Chemical Facility Anti -Terrorism Standards of the Department of Homeland Security
<br />— the applicability depends on the chemical, quantity/concentration, and type of facility. Please contact the project Safety Manager to determine
<br />whether chemicals are subject to these standards.
<br />Chemicals must be stored in a designated, secured area with spill prevention capabilities. Review MSDS or other information to determine potential
<br />incompatible materials. Incompatible materials shall not be stored together. Ensure all containers are labeled.
<br />Substrates That Create Reducing Conditions to Facilitate Bioremediation
<br />Materials such as Emulsified vegetable oil (EVO) or emulsified oil substrate (EOS), lactate, and cheese whey are commonly used as the electron donors or "fuel"
<br />during enhanced reductive dechlorination (ERD) treatment. ERD can be an effective method for degrading various chlorinated solvents dissolved in
<br />groundwater.
<br />Addition of these "electron donors" can also cause changes that need to be recognized and monitored, such as production of gases such as methane and
<br />hydrogen sulfide, and increases in carcinogenic byproducts, such as vinyl chloride, in groundwater or in the vadose zone. These gases or byproducts are not
<br />yet formed during the injection work, but are observed weeks following the injections as the biological process take place. These hazards must be considered
<br />during subsequent groundwater sampling activities. The air monitoring protocol and action levels, as well as required PPE, are discussed in later sections of this
<br />HSP.
<br />Although EVO is food -grade material, MSDSs for the material must be kept onsite, as well as added to the chemical inventory, and specific training on hazards
<br />conducted and documented in the Attachments in this HSP.
<br />The Clean Water Act requires a Spill Prevention, Control, and Countermeasures (SPCC) Plan for storage of more than 1320 gallons of oil (including EVO and
<br />EOS) in >_55 gallon aboveground containers. Additionally, spill kits/materials capable of stopping the spread of a leak/spill must be available and accessible.
<br />Involve your Safety Manager for assistance to determine whether a plan is required, to prepare an SPCC Plan, or to plan for spill control if EVO or other oils will
<br />be used around a body of water.
<br />Methane (as a Product of Injection Activities)
<br />Methane is a colorless, odorless gas with a wide distribution in nature. Methane is created when organic matter decomposes (rots) without any oxygen present
<br />("anaerobic" decomposition) and is common in landfills, marshes, septic systems and sewers.
<br />Methane may be produced as a by-product of the biological process when biological additives are used in a remediation process (such as when emulsified oil is
<br />injected to enhance dechlorination of contaminated groundwater).
<br />Experience has shown that methane may be present in the well space following the injection of emulsified oil, once the biological process has had time to
<br />progress. This needs to be considered when returning to collect ground water samples. Although methane degrades Engineering controls shall be considered
<br />to bring the concentrations of methane down to an acceptable level in the breathing zone.
<br />Methane is a "simple asphyxiant," which means that it can displace available oxygen. Methane is combustible and mixtures of methane with air are explosive
<br />within the range 5-15% by volume of methane (the lower and upper explosive limits). At room temperature, methane is lighter than air, so in an outdoor
<br />environment, it tends to dissipate.
<br />Methane is not toxic when inhaled, but it can produce suffocation by reducing the concentration of oxygen inhaled. When exposed to concentrations high
<br />enough to displace oxygen, you may experience dizziness, deeper breathing, possible nausea and eventual unconsciousness.
<br />The primary danger is from fire and explosion, so ensure that you work in a well -ventilated area, and that there is no source of ignition present. Use spark -proof
<br />tools and intrinsically safe equipment, if necessary. If working in a confined space, make sure that appropriate controls are in place and follow an approved
<br />permit -required confined space entry plan.
<br />H2S as a Project Hazard
<br />Elevated levels of H2S have not been reported during normal drilling activities, but experience has shown that high levels of H2S may be present in the well
<br />space and in the breathing zone following the injection of emulsified oil, once the biological process has had time to progress. Engineering controls shall be
<br />considered to bring the concentrations of H2S down to an acceptable level in the breathing zone, followed by administrative controls, and respiratory protection.
<br />Utility Clearance
<br />Confirm that both a private utility locate company and the public one call Utility Notification Center have been notified. Confirm that all utility companies that are
<br />known to have underground utilities in the area have been to the site and have marked utilities with the appropriate color marking paint. Walk site to observe
<br />private utility locator markings. Best practices for utility location involve use of Vac/Air Knife for utility clearance. Confirm that all boring locations are a minimum
<br />of three (3) feet from any underground utility locate mark, measured from closest edge of boring to closest edge of utility, per CDLP policy. Boring locations
<br />must be a minimum of ten (10) feet from any natural gas (yellow) lines.
<br />Review any available as -built plans for underground utility locations. Discuss locating ductile vs non -ductile utilities with client. Non -ductile utilities are much
<br />more difficult to locate and require additional procedures frequently overlooked. Check with client for any company -specific conditions that may be more
<br />restrictive. Stop Work and call CDLP Operations before beginning a boring closer than the minimum allowed distances, as it may be possible to obtain a waiver
<br />if the utility can be exposed.
<br />- 8 - Revision: 7 — June 2013
<br />
|