ML20128B645

Health & Safety Plan for Remediation of National Park Svc Property Located Near Pawling,New York for Chevron USA, Inc

ML20128B645
Person / Time
Site:	07000903
Issue date:	11/30/1992
From:	CHEVRON U.S.A., INC.
To:
Shared Package
ML20128B622	List: ML20128B619 ML20128B632 ML20128B645
References
PROC-921130-01, NUDOCS 9212040037
Download: ML20128B645 (102)

Text

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I IIEALTH & SAFETY PLAN

I FOR THE REMEDIATION

,ll OF THE

g ll NATIONAL PARK SERVICE PROPERTY 4

l LOCATED NEAR PAWLING, NEW YORK FOR THE CHEVRON USA, INCORPORATED I

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,l NOVEMBER 1992 il l

PREPARED AND SUBM11TED BY:

INTEGRATED ENVIRONMENTAL SERVICES DIVISION OF NUCLEAR ENERGY SERVICES lI I

.P ADO K O

903

-C, PDP

....... ~..

TAllLE OF CONTI'NTS

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ATTACith!ENT A - NES/IES ENVIRONh1 ENTAL 11EALTli & SAFETY PROGRAh!

I ATTACithiENT fl EXCAVATION SUPPLlih1ENT ATTAClihiENT C RADIOLOGICAL CONTROL PLAN I

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ATTACIIMENT A I

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ENVIRONMENTAL HEALTil & SAFETY PROGRAM I

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.I NUCLEAR ENERGY SERVICES,INC.

l INTEGRATED ENVIRONMENTAL, SERVICES DIVISION l

(NES/IES)

'I ENVIRONMENTAL HEALTH & SAFETY PROGRAM iI

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I TAllLE OF CONTENTS I

Section:

I-Introduction Corporate Policy 1.

Accident Loss Control Responsibility I

2.

Selection and Placement of Employees l

3.

OSHA Inspections and Citadons Guidelines 4.

OSHA (BLS) Reponing and Recording Occupational Injury and liltiens 5.

Occupational Safety and Health Act (OSHA)

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Safety 7.

Power Lif t Truck Sately 8.

Risk Management Policy 9.

Right-To-Know (Hazard Communication)

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10.

LOCKOUT tat.OUT Policy and Procedure l

11.

Confined Space Entry Policy and Procedure 12.

Respiratory Protection Policy and Procedure 13.

Eye Protection Policy and Procedure 14 Hearing Conservation Policy and Program 15.

Seat Bt.'r Use Policy 16.

Medical Surveillance Program I

Lg Integrated E^nvironmental Services. a division ofNES,44 Shelter Rock Road. Danbury. CT 06810

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f NUCLEAR ENERGY SERVICES,INC.

ENVIRONMENTAL IIEALTil & SAFETY PROGRAM The Safety of our employees is one of our first considerations. It is, therefore, the policy of Nuclear Energy Services, Inc. (NES) to provide a safe and healthy environment for all. To fulfill this aim, safety shall be of the utmast concem in the training of personnel, use of equipment and facilities, and the devopmer of new methods and processes.

l The NES Environmental Health and Safety (El!&S) program seeks the eduction ci and control of hazardous / incidents which have the potential to cause injury to our employees, damage to o'tr property and/or disruption to communities in which our facilities are located, in meeting this objective, it is our policy to actively confonn and surpass the requirements set forth in the Occupational Safety and Health Act, as well as any other safety and health standards which may apply to our operations.

i The success of our EH&S efferts are dependent upon the full cooperation and participation of all levels of management and personnel. While the implementation of the company's EH&S policy is the responsibility cf all small Business Unit (SBU) managers, all NES employees are responsible for the performance of their job in accordance wSh all applicable safety rules and reculations.

In addition to its humanitarian aspect, EH&S is good business. Our approach is an investment in effort, time and money which 1/ili pay dividends in increased production, reduced waste, greater efficiency and good employee relAa*

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Gubert H. Vaiderwerken James M. Ruopp IE3 Health ar'd Safety Officer Section Leader Environmental Compliance

afety training courses and participate in project and/or team leader safety meetings and on the project's safety com.mittee.

1.3.

NES EMPLOYEES / WORKERS RESPONSIBILITIES 1.3.1. Follow all safety rules, regulations and instructions, including but not limited to the

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following:

a)

Know and follow supervisory instruction en specific work specifications as l

to procedures, equipment and chemical / physical hazards.

Where instructions have been issued for working with hazardous chemicals, such instruction must be followed rigidly, b)

If you are unsure of how a particularjobis to be done or if you are unsure of l

any instructions pertaining to how a job is to be done, talk to your supervisor / group leader before staning the job.

c)

Maintain a clean and orderly work area.

d)

Use Personal Protective Equipment provided.

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Report all accidents / incidents to your immediate supervisor.

1.3.2. Actively support the corporate safety program by working in a safe manner, reporting unsafe conditions to your supervisor and serving on safety committees when appointed.

1.3.3. A site safety officer must have:

a)

The support of NES management.

b)

Sufficient time to carry out his/her duties effectively.

c)

Good general knowledge of the various processes and operations of the

g project.

d)

Ability to cooperate with supervisors and others involved in the safety program.

e)

Ability to attend outside safety training programs, as needed, to increase general knowledge in accident-loss control methods.

Integrated Environmental Semces, a division ofNES. 44 Shelter Rock Road, Danbury. CTD6810 Page 1-3

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2. SELECTION AND PLACEMENT OF EMPLOYEES

2.1. Genera

While interviewing and selection of employees for larger projects may L the responsibility of the Personnel Department,in many locations the responsibility may rest with the project manager or site manager. It is of primary importance that workers be selected for both mental and physical capacity to match the mental, emotional and physical demands of the job to which he or she will be assigned.

Applicable state laws differ among the states, and contractual agreements with labor very widely. Such differences require that each project manager adopt procedures for employee selection and placement which have been reviewed and approved by the Corporate Personnel Department. Corporate will ensure that the various provisions of governmental (Federal. State) laws and contract agreements are met.

in the following, general guidelines are presented to assist project managers in taking I

actions covered under this section.

2.2.

Procedures 2.2.1. Positions Specific job demand.; and task descriptions should be listed in advance for each position to te filled.

2.2.2. Selection a)

Each prospective will complete a standard employment application form.

The applicant will be interviewed by the appropriate individual (s) so that their background can be evaluated.

b)

Employee safety begins when the applicant is interviewed. During the interview, e interviewer should discuss any special knowledge or skills the e

job may require and advise the applicant of the particular demands and tasks involved in the position available.

c)

Some state and federal laws prohibit questions of applicants, unrelated to job l

requirements, that may influence the decision to hire, all of which may Integrated Environmental Services a division ofNES,44 Shelter Rock Road, Danbury. CT06810 Page 2-1

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1EN provide a basis for future charges of discrimination. It is proper, however, to make inquiries of prospective employees in matters that have a direct l

bearing on the particular job demands for the position being applied for.

Therefore, questions relating to previous medical history illness, allergies, accidents must be pertinent to the job function.

d)

A skilled interviewer explores information (i.e., prior work history, absentecism, etc.) supplied by the applicant and should look for positive personality traits and attitudes which worker.

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If the prospective employee will have access to or use a company owned or leased vehicle the interviewer will advise that said use or access is I

contingent upon the applicant meeting and maintaining the driver qualification and performance requirements (i.e., valid state drivers license, check of Motor Vehicle Record, DOT physical if necessary, etc.)

f)

Pre-employment medical exams-see Section 2.3.

g)

It is imponant that the interviewer make the normal inquiry of previous employers to verify applicant's job related responses.

2.2.3. Placement a)

Upon selection, immediately begin indoctrinating the new employee in the I

company's loss control policies by discussion of the over all safety program, gaining their full cooperation with company goals. Individual will be shown Nuclear Energy Services, Inc. Safety Policy.

b)

Establish that the new employee's immediate supervisor / group leader will review with them, the employee's speci6cjob function (s), applicable safety rules and their responsibilities under the plant's safety program.

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Establish that the new employee undergo the introductory Hazard Communication in accordance with OSHA 29 CFR 1910.1200 training with more detailed and speciGe training to occur within the new hires first 90 days.

Integrated Environmental Services, a division ofNES 44 Shelter Rock Road. Danbury, CT 06810 Page 2-2

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If need be, inform the project manager or the immediate supervisor in detail on selection criteria in order that they will know any special condition under which the new employee may have to work.

2.3.

Pre-Placement Medical Exams /Occuentional Medicine Procrams In seeking to protect the worker, the company strives to adequately match the physical capability of the employee to the physical demands of theirjob. One of the primary ways in which this can be initially acc nplished is thm medical examinations conducted at the time of selection / placement of new employees.

The pre-placement exam is nel a screening. If the examination is used as a screen, in an attempt to hire only seemingly robust healthy individuals, management will be depriving itself of many potentially fine, effective employees.

2.3.1. Pumose The pre-placement medical is designed to accomplish the following:

a)

Establish a baseline for future reference in carrying out medical surveillence for on-the-job exposures. OSHA compliance (Respirator Protection, HAZ MAT, Hearing Conservation. specific Health Standards) obviously increases the importance of, and need for, this type of baseline data.

b)

Establish a baseline for future health maintenance efforts. This would apply specifically the Medical Monitoring Program.

c)

Establish eligibility for recovery under any existing or future state second injury statues and/or occupational disease laws. Information on existing statues may be obtained from our insurance carrier.

d)

Identify those disabilities in the applicant which directly interfere with performance of the specific demands of the job under consideration.

e)

Identify those applicants with a communicable disease.

f)

Identify potential applicant sensitivity on allergic re-action to a chemical environment.

Integrated Ennronmental Sernces, a division ofNESJJ Shelter Rock Road, Danbury. CT 06810 Page 2-3

O 2.3.2. Scope The scope of the examination should be specific to the kind of work involved. A brief but adequate health inventory should be included as part of all examinations, to which are added specifics relating to the health hazards involved, the physical l

demand of the job and peninent environmental factors. Therefore the following-actions should be taken:

a)

As a first step, physical requirements for each job at each location should be prepared and maintained on file. The job demands for the position that is open should be indicated in the employees job application package.

b)

An adequate health / inventory of the applicant is a vital part of the examination, as it offers valuable clues that may be of assistance in the medical appraisal.

The applicant should sign the questionnaire form to attest for its accuracy.

The completed form should be included in the job application package which the examining physician will review during the examination.

c)

The examining physician should fill in and sign all examination forms and should indicate the suitability of the employee for the particularjob demand involved. Physician shall be board certified and practicing occupational medicine.

The examining physician must indicate in the report whether or not the examiner is medically qualified to use respiratory protective devices.

Negative findings are of value and should be recotded as such. Nothing l

should be labeled as negative or normal unless found to be so as a result of actual examination.

I-2.3.3. The physician should be invited to the plant to observe working conditions and to obsetve the particular requirements of the jobs and tasks involved. Such visits should be frequent as possible so that the physician is thoroughly familiar with the environmental factors and the physical demands of the variousjobs. An examining g

physician will usually find it difficult to render an opinion as to the applicants' suitability if the physician is unfamiliar with the job demands and the work environment. Note, most physicians will expect to be compensated for this service.

Integrated Environmental Services. a division ofNES. 44 Shelter Rock Road. Danburv. CT06810 Page 2--

I 1EL4 I-2.3A. Confidentiality of Pre-Placement Medical Exam a)

Matters discussed between a physician and a patient are confidential or privileged. This exists only when a private physician-patient relationship exists.

This type of relationship does not exist between employee and the I-examining physician in pre-placement examination situations, it is thus acceptable for the physician to report their results to the employer, b)

The physician shall send all medical records, X-rays and test results to the l

Company along with the report of findings and recommendations. This information/ material will be retained in a Confidential Medical file, separate from the Personnel Record file. Medical records are available forinspection by the employee, physicians, insurance (NES carriers) and Federal officials ONLY. They will nci be shown to or discussed with any other persons.

I Record retention times will conform with OSHA regulations.

2.3.5. Medical Advice To The Emelovec a)

If the physician uncovers a medical or physical condition for which I

treatment is advisable, the physician should make this. known to the employee.

b)

The physicians' report to the employer should state whether the employee is capable of performing the tasks defined for the position, c)

If the employee is rejected because of some medical or physical condition which could preclude performing the required tasks, this information should be made known to the employee and confirmed by the person responsible for j-hiring the employee of for placement.

This will be possible if the report from the physician translates the I

physicians' findings into work abilities and limitations, and an opinion of the suitability of the applicant for the job and any related health hazard exposures.

Integrated Enuronmental Sernces. a dnision ofNES,44 Shelter Rock Road. Danbwy. CT06810 Page 2 l

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2.3.6. Tests of employees hearing will be conducted on all new employees and at periodic or annual intervals for all employees exposed to noise environments at or above 85 DBA TWA for an eight (8) hour shift. The testing will conform to the OSHA requirements as given in 1910.5.

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1 Integrated Environmer,tal Services, a division of NES. 44 Shelter Rock Road, Danbury. CT 06810 Page 2-6

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3. OSilA INSPECTIONS AND CITATIONS GUIDELINES -

3.1.

GENERAL l

It is Nuclear Energy Services Inc. policy to comply with the requirements of the Occupational Safety and Health Act (OSHA). The Act requires the admission without delay of representatives of the U.S. Department of Labor for the purpose of conducting an OSHA inspection. The inspectors may enter NES' project sites during regular working hours or at other reasonable times for purposes of:

a)

Routine inspection b)

Response to a complaint c)

As a result of an occupational fatality d)

A disaster involving five hospitalizations e)

An inspection under the "special emphasis" program f)

A records only inspection Therefore, alllocations should be prepared for an OSH A inspection for which no advance notice may legally be given.

The U.S. Supreme Court decision in Barlow vs. Secretarv reiterated the employer's right to I

request a warrant prior to entry of an OSHA inspector. Although the rights exist,it is generally not recommended that NES require a warrant. However,it may be appropriate under certain circumstances, such as during an emergency or when the site is undergoing remediation/ decontamination, to require a warrant. Consult the Corporate Health and Safety Officer if you have any questions or wish to request a warrant for entrance to the site.

3.2.

PROCEDURES With regards to such inspections and any citations receiv'd, the procedures listed below should be followed:

3.2.1. The SBU manager should be immediately informed of the arrival of a Compliance l-Safety and Health Officer (s), (CSHO). The credentials should be examined in case integrated Enysronmental Services a division of NES.44 Sheher Rock Road. Danbury. CT06810

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of doubt, a check should be made with local office of OSHA. Each SBU manager should designate an individual to whom the CSHO should be referred in the event they are absent. The natrtre of the inspection should be determined as soon as possible (i.e., employee complaint, general schedule, etc.) and an attempt made to limit the scope of the inspection to the extent possible.

3.2.2. Once the scope of the inspection is negotiated, the NES management official should be careful to describe any trade secret items or trade secret areas that may be covered during the coarse of the inspection.

In this n gard, questions about whether something is or is not a trade secret I

obviously should be resolved in favor of NES and protection for the item or area involved. Call the Corporate Health and Safety Officer if any questions arise, in addition, it is a good idea to get an understanding in writing concerning the trade secret items or areas that may be covered during the course of the inspection.

Before OSHA is allowed to enter the site, the NES management official should question the compliance officer about his or her intent to take photographs and to do industrial hygiene sampling.

If the compliance officer intends to take photographs, and assuming that an understanding has been reached conceming trade secrets, the NES management official should attempt to reach an agreement with the compliance officer to pennit -

NES to take custody of the film at the conclusion of the inspection. NES then will have the film developed with at least two sets of prints. The negatives and one set of prints will be retumed to OSHA and NES will retain the remaining set or sets of prints. If an agreement with regards to the custody of the film cannot be reached, a -

- NES official should also take a camera on the walkaround inspection and should duplicate to the extent possible, those photographs taken by the compliance officer.

l If the compliance officer intends to conduct industrial hygiene sampling during the inspection, the compliance officer should be told that NES' Health and Safety l

Officer wishes to accompany the CSHO.

Integrated Enytronmental Services. a division ofNES. 44 Shelter Rock Road, Danbury. CT 06810 Page 3-2

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in the likely event that an industrial hygienist is not available at the time of the inspection, the CSHO should be requested to postpone any such industrial hygiene inspection until another time mutually satisfactory to NES and OSHA. However, whether such request is granted is within the discretion of the CSHO.

Note that NES has the right under the Act to meaningful participation in the walkaround inspection. NES is giving up that right if it does not have the Health and I

Safety Officer present during OSHA's industrial ! giene sampling. NES has a strong argument that the CSHO should postpone the sampling. If possible, the NES Health and Safety Officer should conduct concurrent sampling. If OSHA refuses to postpone sampling and goes forward with its sampling, NES management may deny entrance and reques' a warrant or, at the very least, the NES Health and Safety Officer should be with the OSHA industrial hygienist dunng all sampling procedures.

3.2.3. The manager, or their designee (s) should accompany the CSHO on the tour of the l

premises. In addition to the company representative (s), the inspector has the right to request an employee (s) representative (i.e., a Union) accompany him on the tour of the premises. Be careful about choosing the facility inspection route. The choice of inspection route can make a substantial difference in the outcome of the inspection because of the potential for " plain view" issues, especially when the scope of the inspection is narrow.

Non--employees such as a union specialist in safety or health matters, or an outside consultant to OSHA will nal be permitted to accompany the inspector without prior clearance from the SBU manager and the Corporate Health and Safety Officer.

Compensation to an employee for regular lost time lost in accompanying the inspector is at the option of management. OSHA has taken the position that such an employee must be paid; however, the DC Circuit has decided that an employer's failure to compensate an employee for time spent in accompanying an OSHA inspector is not a "per se" violation of the Act's discrimination provision, Section l l(c).

Iflocal management elects not to pay, Corporate will litigate the issue should OSHA allege that non-payment is in violation of the law.

Integrated Environmental Semces, a division of NES,44 Shelter Rock Road. Danbury. CT 06810 Page 3-3

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195 3.2.4. The OSHA compliance officer is responsible for obeying all of the site safety and health rules. Thus,if personal protective equipment is required to enter a cenain area of the plant, the compliance officer shall not be permitted to enter that area of the site until they are wearing the appropriate protective equipment.

At all time during the course of the inspection, the manager should be careful to record what the CSHO says and does. Be very careful regarding what" admissions" I

NES management makes to the CSHO because they will record everything NES says and does.

The company is required to produce any and all of the following records upon request:

a)

OSHA Poster -

Safety and Health Protection on the Job (required to be posted).

b)

OSHA Form #100

" Supplementary Record of Injuries and Illness" or equivalent.

OSHA Form #200

" Log and Summary of Occupational Injuries and Illness" This summary must be posted by February 1 and removed not earlier than March 1.

c)

Maintenance and Inspection records of employees exposure to hazardous materials / chemicals as required by_ OSHA standard.

d)

The information required under 29 CFR 1910.120 such as 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> training I

certificates, site health and safety plan, respirator fit test records.

A request by the CSHO for other records shall be in writing and requires the approval of the Company President, Corporate Health and Safety Officer and the Corporations Legal Cous.:1.

3.2.5. Although NES managers certainly should be professional and courteous in their l

dealings with OSHA, they must be cautious about volunteering information.

Admissions against interest by one or more of a company's managers can make it difficult to litigate against OSHA.

Integrated Enytronmental Serruces. a division of NES,44 Shelter Rock Road. Danbury. CT 06810 Page 3-4

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3.2.6. While conducting an inspection, OSHA has no right to unreasonable disrupt the operations of the employer. his means, for example, that the compliance officer may not demand that a process be run if it is not scheduled to mn.

3.2.7. Section ll(c) of the OSHA Act generally prohibits all discrimination against I

employees because of the exercise of any rights afforded by the Act.

Therefore, panicularly with regard to employee complaints, NES management cannot take any action, even for inaccurate accusations against employee complaints. Since a complaint's name is protected by OSHA, the CSHO will generally make a copy of the complaint available with the complainant's name deleted.

3.2.8. The CSHO has the right to talk privately with any employee. However, privately means privatelv. just the compliance ofncer and the employee. If the compliance officer permits a union representative to join the " private" conversation, the compliance officer is giving the union representative a walkaround right that nuts be extended to NES as well and NES should object to such treatment.

3.2.9. A record should be made of the entire inspection.

3.2.10. If air, dust, noise or other samples are taken, identify time, place, quantity, type /model sampling equipment, and other significant data.

3.2.11. An exit interview is always conducted by the CSHO. De project manager or their designee must be present be present for the entire meeting. A record shall be kept of everything discussed. Every effort shall be made to leam the detailed basis for any potential citation or any criticism of a site condition. The project manager should be very careful about admitting any violations or even suggesting a reasonable timetable for corrective action or abatement periods.

3.2.12. Prompt notice of the inspection (via telephone or beeper) should be given to the Corporate Health and Safety Officer and the SBU Manager. Copy of the citation (if any). when received should be faxed immediately to the Corporate Health and Safety Officer for review.

3.2.13. All citations shall be reviewed by the Senior V.P. for Administration, Corporation Legal Counsel and the Corporate Health and Safety Officer.

Integrated Ennronmental Services, a divnion of NES,44 Shester Rock Road. Danbury. CT 06810 Page 3-5

9 4-1EF.E5i 3.2.14.Within 15 working days (exclusive of Saturdays, Sundays and llolidays) of the receipt notice of proposed penalties, a notice of contest or payment of the penalties by certified check must be made to the Area Director shown on the Citation and Penalty Notice. With the concurrence of Company President, Corporate Legal

-l Counsel and the Corporate Health and Safety Of6cer, a conference may be requested with the Area Director to discuss the citation OSHA may or may not make changes in the citation, penalties or abatement after such a conference. In order to give maximum time for a decision on a contest, such a conference should be u

held as soon as possible after receipt of the citation and before the 15 days have I-expired.

3.2.15. The notice of contest if any, will be submitted by the Health and Safety Of6cer, it may be directed to the substance of the citation, the proposed penalty, or the abatement date. Once a contest is filed, the abatement period will only begin when the Review Commission has handed down a decision. Location management must post next to the citation notice indicating that the citation is being contested upon advice that the notice of contest has been docketed by the Review Commission.

Posting must continue until the case has been adjusted.

3.2.16.The actual contest will be handled by the Corporations Legal Counsel and the Corporate Health and Safety Officer.

'I Whether or not the citation is contested, a copy of the citation, unedited, must be posted at the site of each alleged violation. Where this is not practical, the citation must be posted in a prominent place where it is readily observable by affected employees.

The citation must remain posted until the violation has been abated and riot for less than 90 days.

3.2.17. Violations that are not contested must be corrected with the abatement period specified, unless an extension has been granted by OSHA in writing. Failure to correct within the specified period may result in further assessment of penalties.

3.2.18. The Area Director should be kept informed or corrective action taken and progress toward correction as set forth in the abatement schedule or spelled out in the citation l-cover letter.

Integrated Ennronmental Sernces, a dwision ofNES. 44 Shelter Rock Road. Danbury, CT 06810

I lu 3.2.19, A follow-up inspection is usually made to ascertain that the citations have been posted as required and the corrective action taken as reported. False reponing is punishab!c by a fine of $10,000.00 and/or six months imprisonment.

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4. OSilA (HLS) REPORTING AND RECORDING OCCUPATIONAL INJURY AND ILLNESS 4.1.

GENERAL 4.1.1. Scope The Occupational Safety and Health Act, Section 8(c)(2), and related state regulations require employers to maintain records of all work-related deaths,

.k injuries and illness which involve lost workdays, medical treatment (other than first aid), loss of consciousness, restriction of work or transfer to anotherjob. The Act l

places upon the employer the ultirnate responsibility for deciding whether a case is recordable. The below definitions and interpretations are based on the provisions of Part 1904, Title 29 Code of Federal Regulations (CFR) and the Bureau of Labor Statistics (BLS) recordkeeping guidelines for_ occupational injuries and illness of 1986 and describe the scope of the OSHA method of reporting and recording occupational injuries and illness and shall be followed by all NES locations.

Locations under the jurisdiction of state-run plans shall comply with any state interpretations which are more stringent.

4.1.2. Recordkeepine In compliance with the Occupational Safety and Health Act and Part 1904. Title 29

-l CFR, all NES locations are required to maintain the following records:

a)

OSHA Fonn 200" Log and Summary of OccupationalInjuries and Illness" b)

OSHA Form 101 " Supplementary Record of Occupational Injuries and Illness" c)

State first Report of Injury I

4.1.3. Definitions l

These definitions apply to recordkeeping, reporting, and other requirements under the OSHA Act, implementing administrative regulations and the BLS. Guide to l

Occupational Injury and Illness Recordkeeping:

Integrated En vironmental Services. a division ofNES. 41 Shelter Rock Road. Danbury. CT D681G l

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Occuoational Illness - Any abnormal condition or disorder, other than on resulting from an occupational injury, caused by exposure to environmental factors associated with employment. It includes acute and chronic illness or diseases which may be caused by inhalation, absorption, ingestion, or direct contact.

b)

Occouational Iniury - Any injury such as a cut, fracture, sprain, amputation, etc., which results from a work accident or from a single instantaneous exposure in the work environment. Conditions resulting from bites, such as l

insects or snake bites, and one-time exposure ta chemicals are considered to be injuries.

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Emolover's Premises or Work Environment - Consist of the employer's total establishment; they include the primary work facility and other areas in l

the employer's domain such as company storage facilities, cafeterias, and restrooms, d)

Establishment -(for Recordkeeping Location Purposes)- A single physical location where business is conducted or where services or' industrial operations are performed; the place where the employees report for work, operate from, or from which they are paid, distinctly separate activities performed at the same physical location shall each be considered as a I

separate establishment for recordkeeping purposes, e)

Postine -The annual summary of occupational injuries and illness (OSHA)

Form 200) must be posted at each establishment by February I and remain in place until March I to provide employees with the record of thedt I-establishment's injury and illness experience for the previous calendar year.

f)

Recordable Occucational Injuries and Illness - Any occupationalinjuries or I-illness which result in:

1. Fatalities, regarriless of the time between injury and death, or the length of the illness:

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2. Lost workdays cases. other than fatalities, that result in lost workdays;

3. Non-fatal cases without lost workdays which result in transfer to another -

job or termination of employment, or require medical treatment (other integrated Enstronmental Serraces, a division ofNES 44 Sheher Rock Road. Danbury, CT 06810

g-I than first aid) or involve: loss of consciousness or restriction of work or motion. This category also includes any diagnosed occupational illness which are reported to the employer but are not classified as fatalities or lost workday cases.

g)

Death - Any death resulting from a work injury or occupational illness.

h)

Lost Workdays - The number of days (consecutive or not) after, but not including, the day ofinjury orillness during which the employee would have I

worked but could not do so; that is, could not perform all or any part of his normal assignment during all or any part of the workday or shift, because of the occupational injury or illness, not to include scheduled days off, I

holidays, etc.

1. Away From Work Case The number of workdays (consecutive or not) on which the employee l

would have worked but could not because of occupational injury or

illness,

2. Restricted Activity Case The number of workdays (consecutive or not) on which, because of injury or illness:

a. the employee was assigned in another job on a temporary basis;

b. the employee worked at a permanent job less than full-time; I

c. the employee worked at a permanently assigned job could not perform all duties normally connected with it.

When the injury restricts work or motion but does not interfere with any of the employce's regular duties. the case is a non-lost workday case.

i)

Restriction of Work or Motion - Occurs when the employee, because of a result of a jot >-related injury or illness, is physically or mentally unable to -

perform all or any part of their normal assignment during all or any part of the workday or shift.

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Loss consciousness - If an employee loses consciousness as a result of a work-related injury, the case must be recorded no matter what type of I

treatment was provided. The rationale behind this recording requirement is that loss of consciousness is generally associated with the more serious

injury, i

k)

First Aid - Any one-time treatment, and any follow-up visit for the purpose of observation, or minor scratches, cuts, bums, splinters, and so fonh, which do not ordinarily require medical care. Such one-time treatment, and follow-up visit for the purpose of observation, is considered first aid even -

though provided by a physician or registered professional personnel.

1)

Medical Treatment - Any treatment of injuries administered by physicians, I

registered professional personnel, or lay person (i.e., non-medical personnel), Medical treatment does not include first aid treatment (one-time treatment and subsequent observation of minor scratches, cuts, burns, i

splinters and so forth, which do not ordinarily n: quire medical care) even j

though provided by a physician or registered professional personnel, m)

Termination and Permanent Transfers - A case shall be recorded under this classification if a termination or permanent transfer made as a result of an injury or illness. Each case must likewise appear as a lost workday case or as a non-fatal case without lost workdays, depending on whether days were lost prior to the temlination or permanent transfer.

n)

Chance in Iniurv/ Illness Status - If at a later date a minor (recordable I

without lost workday) injury or illness results in absence from work or transfer to a restricted (light duty) job, the injury would be considered " Lost Workday".

o)

Lavoff Due to Lack of Work -If an employee is laid off due to cutback or lack of work, recording of" Lost Workdays" ends on their last day of work even though they are not released for full duty.

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FL 4.2.

MEDICAL VS. FIRST AID DETERMINATION 4.2.1. Medical Treatment The following are generally considered medical treatment. Work-related injuries for which this type of treatment is provided or should have been provided are almost always recordable:

a)

Treatment of INFECTION b)

Application of ANTISEPTICS dunne second or subscouent visits to medical personnel c)

Treatment of SECOND OR TIIIRD DEGREE IlURN(S) d)

Application of SUTURES (stitches)

I e)

Application of BLTITERFLY ADilESIVE DRESSING (S) or Steri Strip (s)in lieu of sutures f)

Removal of FOREIGN BODIES EMBEDDED IN EVE g)

Removal of FOREIGN BODIES from wound; if procedure is COMPLICATED because of depth of embedment, size or location h)

Use of PRESCRIPTION MEDICATIONS (except when a sincle dose administered on first visit for minor iniurv or discomfort) i)

Use of hot or cold SOAKING TIlERAPY durine second or subseauent y.hil to medical personnel j)

Application of hot or cold COMPRESS (ES) durine second and subseouent visit to medical personnel k)

CUTTING AWAY DEAD SKIN (surgical debridement) 1)

Application of IIEAT TIIERAPY durine second or subseauent visit to medical personnel.

rn)

Use of WIIIRLPOOL BATil TIIERAPY dunng.second or subscouent visit to medical personnel.

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POSITIVE X-RAY DI AGNOSIS (fractures, broken bones, etc.).

o)

ADMISSION TO A IlOSPITAL or equivalent medical facility for treatment.

4.2.2. First Aid Treatment The following are generally considered first aid treatment (i.e., one-time treatment and subsequent observations of minor injuries) and should not be recorded if the work-related injury does not involve loss of consciousness, restriction of work or motion, or transfer to anotherjob:

1 a)

Application of ANTISEI' TICS durine first visit to medical personnel b)

Treatment of FIRST DEGREE BURN (S) c)

Application of II ANDAGE(S) durinc any visit to medical personnel d)

Use of ELASTIC IIANDAGE(S) durine first visit to medical personnel e)

Removal of FOREIGN BODIES NOT EMllEDDED IN EYE if only irrigation is required f)

Removal of FOREIGN BODIES from wound, if procedure is I

UNCOMPLICATED, and is, for example, by tweezers or other simple technique I

g)

Use of NONPRESCRIPTION MEDICATIONS AND administration of single dose of PRESCRII'rION MEDICATIONS on first visit for minor injury or discomfort l

h)

SOAKING TIIERAPY ON INITIAL VISIT to medical personnel or removal of bandages by SOAKING 4

i)

Application of hot or cold COMPRESS (ES) durinc first visit to medical personnel j)

Acolication of OINTMENTS to abrasions to orevent dryinc or crackinc k)

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Use of WIIIRLPOOL BATl! TIIERAPY durinc first visit to medical personnel m)

NEGATIVE X-RAY DIAGNOSIS OBSERVATION of injury during visit to medical personnel 4.3.

GENERAL RECORDING EXAMPLES 3

I a)

Pre-existine Condition - The aggravation of a pre-existing employee medical condition by a new work-related incident involving the employee is deemed I

recordable, b)

Back. Hernia. Joints - An injury is recordable when it results from a work-related event or exposure in the work environment. Injuries that are caused elsewhere and merely surface in the work environment are not recordable.

c)

Disorders Due To Physical Acents (other than toxic materials)- Examples:

1.

Heat Stroke l

2.

Heat Exhaustion 3.

Effects to exposure to low temperatures are recordable if unable to return to work on the next scheduled shift.

d)

Comoany Parkinc Facilities - Company parking facilities are generally not considered part of employers premises for OSHA recordkeeping purposes and are not recordable unless the employee was engaged in some work-related activity.

e)

Formaldehyde or Mercury -If an employee is removed from working with these -

materials because of high levels, the case is considered an illness only if the employee exhibits symptoms of formaldehyde or mercury poisoning.

f)

Allercies - A diagnosed allergic reaction to chemicals or dust is considered an illness only if the employee:

1.

Becomes a lost workday case:

2.

Receives medical treatment:

Integrated Ennronmental Servstes. a division of NES,44 Sheher Rock Road, Danbury, CT 06810

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Is transferird to anotherjob;

_l 4.

Is terminated as a result of t'ne allergic reaction.

An allergic reaction caused by an instantaneous event is considered aa injury.

I g)

Hearing Loss - A hearing loss is considered an illness only if proven to be noise induced as a result of the employee's work environment. A head.ng loss is considered an injury if it is the result of instantaneous exposure, f

h)

Employees in Travel - Employees who travel on company business shall be considered to be engaged in work-related activities all the time they spend in the interest of the company, including, but not limited to, travel to and from customer contacts and entertaining or being entertained for the parpose of transacting, discussing or promoting business. However, an injury / illness would not-be recordable if it occurred during normal living activities (eating, sleeping, recreation).

'I Insect Snike Bites -Conditions resulting from bites such as insect or snake bites are i)

/

not considered to be injuries unless the employee suffers a reaction as a result.

4.4.

" GRAY AREAS" If there are any questions as to the recordability of specific cases, they must be referred to g

the Corporate Personnel Administrator and/or the Corporate Safety and Regulatory

'E Compliance Manager.

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Integrated Environmental Semces a division ofNES. 44 Shelter Rock Road. Danbury. CT06810

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5. OCCUPATIONAL SAFETY AND llEALTII ACT (OSIIA) 5.1.

GENERAL 5.1.1. Purpose To set forth NES' policy with regards to compliance with the Occupational Safety I

and Health Act (OSHA).

(

5.1.2. Pohev it is the expressed policy of NES to comply with the Occupational Safety and Health Act to the extent possible and practical and further, in cases where strict compliance cannot be achieved, to provide equivalent protection for NES employees consistent with the intentions of the Act and in accordance with the prescribed variance procedures.

I 5.1.3, Maior Provisions of the Act a)

Score of Coverace Exceptfor specific exclusions, the Act is applicable to every employer who I

has one or more employees and who is engaged in a business effecting commerce. For NES purposes, the Act is applicable to each SBU in which business is conducted.

b)

Emnlover Duties As an employer covered under the Act, NES:

I 1.

Has a general duty to furnish each of its employees with a place of employment free from recognized hazards that cause or are likely to cause death or serious physical harm. (This is commcaly known as the general duty clause).

d 2.

Has a specific duty to comply with the safety and health standards promulgated under the Act.

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c)

Emolovee Dutits Each employee has a duty to comply with applicable safety and health

]

• tandartis plus all rules, regulations, and orders which apply to their own actions and conduct on the job.

I 5.2.

PROCEDURE Specific details regarding compliance with the Occupational Safety ar, Health Act are too numerous to cite here. The requirements relating to recordkeeping, training and compliance are covered in other sections of this manual. As a minimum, however, each SBU/ location must:

a)

Maintain on premises a current copy of prevailing Occupational Safety and Health standards. Copies of this publication can be obtained by contacting the Corporate l

Health and Safety Officer or any area OSHA office.

b)

Periodically review OSHA standards which apply to your particular SBU operations.

c)

In all purchases, alterations, construction, etc., consider the applicable OSHA I

regulations, complying with them in accordance with the intent of this policy, it is also highly recommended that a copy of any process or physical structure changed I

proposed at a site be reviewed by the Corporate Health and Safety Officer to ens tre that all applicable safety, environmental and insurance requirements have been addressed.

Questions relating to compliance with OSHA should be directed to the Corporate Health I

and Safety Officer, Integrated Envuronmental Servuces, a division of NES. 44 Shelter Rock Road. Danbury. CT 06810 Page 5-2

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5. SAFETY 6.1.

GENERAL.

Ilefore any lasting rasults can be expected, the mental attitude toward environmental health l

and safety of NES personnel as a whole must be raised to a high level. If conducted in a proper nunner training, safety meetings and safety. elated programs provide excellent means to initiate and maintain this attitude.

As all NES personnel become familiar with the " safety idea", they will not only practice l

accident loss controls, ho also make it a habit to install the proper attitude in others.

6.2.

S AFETY TRAINING 6.2.1. Traininc of Sunsors and Grou, Leaden 6.2.2. Orneral

]

As a representative of management, the Project Manager is the key individualin the Environmental liealth and Safety Program. frhey are the closest to the worker s and i

has a major responsibility to conduct the operations of his department in the safest manner possible with minimum accidents).

6.2.3. On The Job Traininc l

While supervisory training is largely geared to production, it must include thorough understanding of NES' policies and goals in accident control and the t chnique of implementing them in their area of :rsponsibility. Training, if it is e, retive and objective, cannot exclude safety.

6.2.4. Outside Training it is important that early ire the Project Managers carter or soon after their l

appointment to the position, the supervisor should have the opportunity to take special courses in safety.

Such courses including text material are available through insurance carrier service organizations, American Society of Safety Engineers National Safety Council and various state business sponered safety councils, As periodic follow-up training, l

excellent films on leadership and safety subjects are also available through the same sources.

Integrated Ennronmental Sernces. a division of NES. 44 Shelter Rcick Road. Danbury. CT 06310 Page 6-1

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6.3.

EMPLOYEE TRAINING On the job training is the responsibility of the Project Manager.

6.3.1. The following steps should be taken in training new employees and any employees transferred or assigned to new jobs:

Step.1 - Prepare the worker by: Putting them at ease, finding out what they already may know about the job and getting them interested in leaming the job.

Step 2 - Presen: J e operation by: Educating, instructing, illustrating and carefully

~

l and patiently questioning the employees' understanding. Stress these key points: hazards of the operations, safe operating methods, purpose of guards and use of personal protective equipment.

S-3 - Try out their performance by: Treating their understanding of the job by

^

having them tell, show and explain the key points to you, as they perform the job. Ask questions and correct errors continuing the project until all are satisfied with their performance.

Step 4 - Putting them on the job: Designate to w hom they go to for help, frequently check on their perfonnance and encourage questions.

Step 5 - Follow-up periodically on their performance.

6.3.2. General Instmetion Although specific training will vary according to the employee'sjob assignment, all employees are to be instructed in the following:

a)

Chemical Hazards All chemicals should be regarded with care and treated with respect. Even though certain chemicals do not cause immediate and spectacular injuries commonly associated with concentrated acids or alkalis, they may act insidiously to produce a commutative or delayed effect.

liowever potentially dangerous, with adequate care, any chemical can in used safely.

While proper steps for handling chemicals depend largely upcti the material, the location in which the work is being perfonned, and the immediate circumstances a few general rules apply:

lntetraird Environmental Semces. a division of NES. 44 Shelter Rock Road, Danbury. CT 06S10 Pace 6 2 i

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1.

Obtain and fully understand complete information (MSDS -

Material Safety Data Sheet) and instructions tefore working with chemicals.

2.

Wear the proper personal protective equipment for the job.

3.

Plan your work to minimize serious consequences should an accident occur. Know where emergency eyewash / shower stations are located.

l 4.

Make a habit of always washing up after work to remove chemical substances and never cat or smoke in the work area.

5.

Report all injuries, illness, skin rashes, etc., to your supervisor / group learie.

I b)

Liftmg l

Regardless of the weight of the object, every person who lifts improperly is one step closer to back injury. Therefore, before lifting any object, size up g

the job,if the object is too heavy - get help to lift it, if you do lift an object remember:

1.

Be sure you have good footing.

2.

Don't bend at the waist, squat down.

3.

Bend at the knees and get close to the object.

4.

Get a finn hold, keep your back straight.

5.

Then, lift gradually by straightening the legs. When you set the load I

down just reverse the procedure. It is also important to remember when ever you are carrying a load, make sure you can see around or over whatever you are carrying.

c)

Personal Protective Eouinment Each job may call for specific type of personal protective equipmeat, for example, it is mandatory to wear safety glasses / goggles and or face shield Integrated Ennronmental Servtces. a dnision ofNES,44 Shelter Rock Road. Danbury. CT 06810 Page 6-3 m

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uhen chemical splash hazards can occur. In addition to using required personal protective equipinent, it is important to remember to:

1.

Wear proper clothing for the job.

2.

Avoid wearing finger rings. wrist watches and chains, as they can catch on equipment or objects.

3.

Protect your feet by wearing only approved footwear provided by NES.

d)

Slips and Falh Falls are a major cause of injury, however, slips and falls can be prevented when some simple safety precautions are taken. For example:

l 1.

Floort/ Platforms If yo: see something on the floor, pick it up. The same goes for a i

I spill. clean it up.

b. Look around for and become aware of tripping hazards like pallets, loose floor coverings, electrical wires or cords across aisles tools, etc.

2.

Stairs Never run down or upstairs. Hold on to the handrail and always a.

look in the direction you are going.

b. Never try to cany something too big on a stairway, c.

Don't leave anything on the stairs and if you should find something, pick it up.

3.

Ladders If you have to reach, clean or work n. omething that is too high, a.

use the proper size ladder. Don ase a chair, pallets, drum.

forklift or other makeshift climbing device.

I integrcted Enytronmental Services a dartsion of NFS. 44 Shelter Rock Road. Danbury. CT 06810 Page 6 -t

b. 11efore mounting any ladder make sure it is fimily set.

c. Always face the ladder when climbing up and working. Don't I

climb above the third to last round and do not lean sideways or over-reach.

d. Defective, broken ladders or those without safety shoes should not be used and should be reported for replacement or repair.

6.3.3. General Rules / Procedures Understanding and following site safety rules, smoking regulations, security and emergency procedures are paramount for the individual employee's protection as well as for the protection of their fellow workers.

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Integrated Environmental Senices a dnision ofNES. 44 Shelter Rock Road. Danbury. CT 06310 Page 6-5

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7. POWERED LIFT TRUCK SAFETY PROGRAM I

7.1.

PURPOSE The purpose of this program is to provide management with a comprehensive guide to

" Powered Lift Truck Safety". It is beyond the scope of this program to cover every technical detail involved in safe fork lif t operation and maintenance, llowever, this guide does contain many legal requirements of OSilA, as well as generally accepted safe procedures recommended by manufacts ' suppliers and users of this equipment. It can I

be used to develop Powered Lift fr A '4D.

mu-throughout NES' Si1U's and facilities.

7.2.

APPLICAlllLITY This program contains safety requirements relut.ng to fire protection, design inaintenance and use of fork trucks, tractors platform lift trucks, motorized hand tmeks, and other specialized industrial trucks powered by electric motors or internal combustion engines.

Refer to Exhibit F for a model program.

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I truerrated Enuronmental Services, a dwtston of NES,44 Shelter Rock Road. Danburs. CT 06810 Page 7-1

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8. RISK 51ANAGE51ENT POLICY I

8.1.

STATEhiENT OF POLICY lt is NES' policy to protect against accidental loss or losses which in the aFgreFate would significantly affect NES' personnel, property or the ability of the Corporadon to continue to I

fulfill its responsibilities. NES will design, build and operate its facilities and distribute its products in a manner which approximately minimizes financial loss due to accident.

8.2.

Ih1PLEhiENTATION I

The Corporation will apply to risks of loss a logical management process which includes a systematic and continuous identification of loss exposures, analysis of these exposures in terms of frequency and severity probabilities, application of sound risk control procedures and financing the risks consistent with Corporate financial resources and the spread of its physical assets NES may accept uninsured losses up to certain amounts based on guidelines recommended by the Treasurer.

I 8.3.

LOSS PREVENTION PROGRAhtS To ensure the proper degree of protection of propeny and production against loss due to accident, each SBU shall have an active loss prevention program which shall include appropriate operating and emergency training for all employees. The design of new facilities and the renovation of existing facilities shall be done in accordance with approved NES loss prevention and safety Fuidelines and standards Capital appropriation requests and operating lease commitment requests shall include adequate funds to protect against or minimize losses. Special attention shall be given to large loss possibilities that could affect the profitability of a project.

8.4.

RESPONSIBILITY Operating management is directly accountable for the protection of propeny, production and products. Therefore, loss prevention awareness and performance shall be an integral part of the performance evaluatbn of management personnel.

Integrated Enttronmental Services. a division of NES. 44 Shelter Rock Road. Danbury, CT 06810 Pace 8-1

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'ihe Corporate Safety and Regulatory Compliance Manager, Tr:asurer and Director of Personnel are responsible for developing loss prevention criteria and maximize acceptable loss levels relative to the design of new facilities and the renovation of existing facilities, and for reviewing capital appropriation requests and plans for major facilities to determine the adequacy of protection for property and production. Administration of NES' risk management program will be the responsibility of the Treasurer and the Corporate Safety and Regulatory Compliance Manager. Each SDU manager will keep the above informed on a timely basis of all developments relative to preventing and protecting NES from substantial financiailosses.

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lI lI trierrated Environmental Semces, a division of NESAt Shelter Rock Road, Danbury, CT 06810 Page 8-2

9. RIGilT-TO-KNOW (ll AZARD COMMUNICATION) 9.1.

l'OLICY NES feels that it is good management to maintain a system whereby employees are provided with the best available health and safety information relative to their work site.

Presently enacted or contemplated regulations in nuny states stipulate a I

("Right-To-Know") law for all employees. It is NES' policy that all employees have a right-to-know about potential hazards in the workplace.

I 9.2.

IMPLEMENTATION To carry out it's obligation. NES will:

a.

Inform workers about the health effects of toxic substances at their work site. This will include but not be limited to making available:

1.

Current Corporate Material Safety Data Sheets and/or Technical Data Sheets.

2.

Posting of notices telling employees they have a right to information about toxic substances.

3.

Documents published by Federal, State or Local Government Agencies.

b.

Plan and implement a program to provide training and education for employees who routinely work with toxic substances. This program will be on-going, affording information to new employees upon staning employment with NES, and I

reemphasize that informatlon periodically to all employees at least once every two (2) years, or as the regulation (s) may stipulate. Maintain records of those who have attended such a program, c.

Maintain accurate records of all worker exposure data (biological / air) for the regulated time (but not less than 30 years after employment) making them available to employees or their representatives where so stipulated.

d.

When necessary, provide a procedure for handling inquiries and complaints from NES employees.

Integrated Environmental Semces. a divinon of NES. 44 Sheher Rock Road. Danbury. CT(W110 Page 9-1

O1E3ii Provide any and all additionally requested infonnation specincally required under c.

state statutes.

9.3.

RESPONSIBILTIT While each state may vary to some extent, there are minimum requirements established

{

cominon to all Right-To-Know regulations. It is the responsibility of each SBU management team, as well as the Corporate Safety and Compliance Manager, to be familiar

~

with these regulations, enacted in each state to assist in complying with them.

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10. LOCKOUT-TAGOUT POLICY AND PROCEDURE I

10.1.

STANDARD LOCKOUT PROCEDURE 10.1.1. LOCKOUT-TAGOUT refers to complete isolation or de-energization of equipment or machinery that is actuated by air, water, hydraulic, steam or electric power.

a.

Any employee who repairs. adjusts, inspects, cleans or services machinery l

or other equipment must lockout all power, to avoid the risk of being injured if the machinery or equipment automatically stans or is staned by another employee.

b.

The use of lockouts is the most positive and practical guarantee that employees will not be injured while performing maintenance on or around equipment. All power sources for machinery or equipment movement, or flow of material must be turned off, and securely locked in the off position.

c.

An acceptable lockout is determined by the nature of the machine or object to be locked out and the nature of the control which power is supplied to the machine or equipment being locked out.

I d.

Specific individuals responsible for lockouts will vary depending on size and complexity of an operation but genemlly the electrician will be included I

among those responsible for the lockout the machinery or equipment.

l e.

Each employee who engages in any work on equipment shall have a padlock and lockout device readily available to de-energize power soun:es before work begins.

Each lock should be keyed individually to prevent unauthorized opening, and should be identified with the name of the employee. Duplicate keys should be kept under strict control to avoid I

unauthorized use, f.

Use of tags or labels is um an acceptable substitute for lockout devices, under OSilA. " DANGER" tags may be used in addition to locking devices, if needed for recognition purposes, or to record special instructions.

Integrated Environmental Semccs. a division of NES. 44 Shelter Rock Road. Danbury. CT 06810 Page 1(L-l

I g.

A " LOCKOUT-TAGOUT" rule shall be established, and supervisors will enforce the rule at all times. a schedule of disciplinary actions will also be established for use in the event of violations of this safety rule. Training in LOCKOUT-TAGOUT procedures will be conducted periodically, to insure that all employees are thoroughly familiar with their use.

10.1.2. Procedures (General) 13efore isolating or de-enerF zing equipment, all main power sources must i

a.

be positively identified.

b.

Tum the main power breaker or disconnect to the OFF or CLOSED position, if air, steam water or hydraulic.

c.

Piping systems and process lines must be closed off, and locked, or otherwise secured, and care taken that pressure is released and material drained.

d.

After the switch, breaker, valve or disconnect is moved to the OFF position, the person (s) mvolved in the job must snap their locks on the control lever by I

means of a multiple lock adapter. The first individual to place a lock on the lever should be the supervisor.

e.

Test the disconnect or valve to make sure it cannot be moved to the ON position.

f.

The person applying the lockout will test the machine start controls to make cenain that power is disconnected if electrical, an electrician should test the circuit with a meter. This test should also make certain that there are no l

secondary sources of energy. Any limit switches and automatic restart switches must be checked for complete isolation, g.

As cach employee completes work, all tools and materials used on the job will be removed. If more than one person has applied the lock, the last person involved should notify the supervisor in charge of the area that the work is completed, the equipment ready, and that the final lock may be l

removed.

Integrated Environmental Services, a division of NES. 44 Shelter Rock Road. Danbury. CT 06810 Page 10-2

h.

The supervisor will check that no one is in or around the machinery or equipment, also that all tools or materials have been removed. The supervisor will also make an inspection of all guards, to make certain they are in place. The supervisor will then remove the last lockout device, and authorize start-up of the machine or equipment, i.

In the event a lockout of a piece of equipment carries over to another shift, unless there is an alternative pmcedure, the oncoming employee will lockout, then the outgoing employee shall remove his lockout.

j.

In the event an employee neglects to remove a lockout and leaves the premises, the area supervisor or person most directly involved with the job shall be responsible for inspecting the equipment and determining whether the equipment is operational before removing the lock.

This will be in accordance with a standard procedure such as the following:

1.

The individual whose lock is on the switch must be contacted by the highest Supervisor present. With the owners consent, and with approval from that Supervisor, the lock may then be removed.

2.

If contact cannot be made with the individual who installed the lock, and start-up is necessary, a complete and thorough investigation of the total operation involved with the locked out electromechanical circuit shall be made by the Supervisor. Such inspection shall be both for the integrity of the system as well as for the location of I

hidden personnel, tools and equipment that could be C.'ected by start-up. Upon completion of the inspection and determination that the system is clear and operational, the Supervisor may give permission to remove the lockout device (s) and system start-up. In this event, the employee whose lock was removed, will be notified immediately upon return to the job.

10.1.3 Procedures (Soccific) a.

Electrical:

1.

A keyed lock, multiple lock adapter and identification of person applyiag the lock (whether by tag or lock identification) shall be Integrated Ennronmental Services, a division of NES,44 Shelter Rock Road, Danbury. CT D6810 Page 10-3

utilized. Tile LOCK IS TO llE NITACilED TO Tile MAIN IIREAKER DISCONNECT, b.

Compressed Air Power Trains:

l 1.

Where machinery derives its power from compressed air, the lockout procedure sha;l consist of closing the manual valve, bleeding off the residual air and disconnecting both lines between the manual control valve and the cylinder, 2.

When an air line is removed to provide a lockout, the line itself must be identined with a lockout tag stating the name of the person applying the tag.

3.

Each person involved in the operation shall apply an identi$ cation tag.

c.

Ilydraulic or Water Actuated Equipment:

1.

The motor which drives the hydraulic pump or water actuated equipment must be locked out.

2.

Any residual pressure in the line must be bled off, the line drained l

and disconnected.

d.

Steam Lines:

1.

When high pressure steam lines are under repair, or equipment deriving power from steam is being worked on, the high pressure steam valve supplying the steam must be closed, locked and tagged.

Where possible, a chain shall be locked around the shut-off valve as tightly as possible and either chain or valve identified with a tag, e.

Portable or Plugged-In Equipment:

1.

Stationary equipment which obtains all of its power through a quick disconnecting plug shall be locked out by removing the plug from the receptacle and tagging the plug ifit is in the immediate vicinity of the

l equipment it serves.

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2.

Extreme caution must be taken where equipment in series is locked out by disconnecting a plug.

ALWAYS DISCONNECT EQUIPMENT AllEAD OF AND IIElllND TIIE UNIT IIEING WORKED ON.

10.1.4. Soecial Conditions l

When it becomes necessary to perform adjustments to equipment unc'er a.

operating conditions, the following rules shall be adhered to:

1.

A competent and qualified individual shall perform the adjustments or measurements.

2.

An individual must stand by at the shut-off switch.

3.

Operations will be perfomied in the presence of a Supervisor.

b.

Other exceptions may be granted by receiving written procedures and permission from the plant manager.

10.1.5. Lockout Precautions I

a.

Sometimes locking out one sourte of power is not sufficient. Some machinery uses a combination of power supply; electric, hydraulic, steam, etc. In such cases. never begin maintenance without lockout of all auxiliary power supplies.

b.

Never guess as to the identity of controls for a given machine. All l

disconnects and valves must be clearly identified.

this is especially important when control are remote from the equipment or on master panels containing several controls, c.

Do not assume that equipment which is not functioning will remain that way.

l Intennittently operating equipment such as pumps, blower fans and compressors may seem hannless whe.. dormant, but can cause serious injury if they suddenly become energized.

d.

Never assume that anyjob is too small to merit lockout. DO NOT BYPASS l

TIIE LOCKOUT PROCEDURE UNDER ANY CIRCUMSTANCES.

Integrated Ennronmental Serntes, a dnnion ofNES. 44 Shelter Rock Road. l>anburs, CT06810 Page 10-5

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I Lockouts applied to local stops or at control panels are not acceptable, A LL c.

LOCKOUTS MUST llE Al'I' LIED TO Tile MAIN llREAKElt DISCONNECTS, AND M AIN SOURCES OF All, OTilEll I'OWER, WilERE l'OSSillLE.

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Integrated Environmental Semces, a dnhion of NES 44 Shelter Rock Road, Danbury, CT 06810 Page 10-6

I II, CONFINED SPACE ENTRY POLICY AND PROCEDURE 11.1. CONFINED SPACE ENTRY AND WORK PROCEDURE A confmed or enclosed space rneans any space having a limited means of egress. Under this definition, the following should be considered as confined or enclosed space work areas:

stcrape tanks, process vessels, bins, hoppers, silos, cyclones, boilers, ventilation and exhaust ducts, tunnels, sewers, pipelines, underground utility vaults and open-top space more than four (4) feet in depth such as pits and tubs.

Periodically such areas mee ing this definition must be entered for inspection, cleaning or repair. In the past, too many fatal accidents have been caused by haphazard entries. To avoid such occurrences, all employees required to enter into confined or enclosed spaces must be made aware of the hazards involved and the procedures to be followed to insure a safe work environment.

I 1.1.1. Ibrards The specific hazards that a worker may encounter will vary depending upon the particular operation, however, the main dangers that an employee may be subject to can be broken down into two basic categories which are:

1.

Environmental-created by the lack of proper ventilation resulting in:

a.

The accumulation of toxic or flammable contaminants.

b.

An oxycen deficient or enriched atmosphere.

These conditions may exist due to several factors, for example, the type of materials stored, the nature of the process, oxidation of the walls of an enclosure from rust, I

leaks from faulty shut-off valves or seepage of other gases into the confines area and even from work being performed within the enclosure such as welding, using pneumatic tools, cleaning materials, etc.

2.

Physical-arising out of the performance of work within an enclo;ure:

a.

Material Movement -The shift of material within a confined space

. caused by the accidental movement of material into or out of the integrated Environinental Senices, a division ofNES,44 Shelter Rock Road. Danbury, CT 06810 I

Page 11-1

I area, the collapse of biidged or aerated material being used as a work platfonn or the cave-in of material previously adhering to the sides or top of the enclosure can all result in the burying of the worker and their suffocation.

b.

. Unit Movement - Unless a proper lockout procedure is followed, a worker faces the unnecessary danger of coming in contact with movine onns tagitators, mixing blades, etc.) oflor having the system

• (mixers, rotating kilns, etc.) activated while inside, or of having material inadvenently introduced to the enclosed area.

c.

Use Of Tools - Hesides she danger of tools falling through hatch openings or while being Infted or lowered within the work area, employees should le aware of the proper procedure or tools needed to work in a particular environment. For example, all portable grounded tools should te spark proof, explosion proof or air operated if flammable vapors are present 11.1.2. General Precautions in order to insure the safety of our employees, the following general precautions must be observed:

An employee shall never enter into a confined or enclosed space for any a.

l reason unless they have been trained and authorized to do so by the Corporate Health and Safety Officer, who is designated to authorize such entries. A " Permit to Enter" systern will be established, spelfic to each site operation. No individual suffering claustrophobia should ever be allowco to enter a confined space.

b.

To prevent unauthorized entry, the means of acceu to such areas should te locked or otherwise guarded.

Where applicable, tests for oxygen content, flammability and toxicity must c.

be conducted by the Corporate Ilealth and Safety Officer or a competently trained technician before entry to assure oxygen supply, zero flammability and/or toxicity. By competent supervisor,it means, any supervisor who has --

Integrated Environmental Serviers. a division ofhES. 44 Sheher Rock Road, Danbury, CT 06810 I

Pape 112

teen trained in the proper use, care and reading of the specific testing equipment involved.

Some of the more familiar instmments used for these tests include:

1.

Combustible pas indicators and/or explosion level meters.

2.

Oxygen indicators - oxygen levels must be between 19.5% and 23.0%.

3.

Carbon monoxide detectors-carbon monoxide levels must be below 35 ppm. Other tests should be carried out where the possibility of carbon dioxide, hydrogen sulfide or any other substance which might affect the atmosphere may exist.

d.

If the atmosphere of an enclosed space is determined to present a hazard, the I

area must be purged and ventilated. The types and method of purging and continuous ventilation selected will vary depending upon such factors as:

I 1.

Nature of material in use or stored.

l 2.

Nature of the decomposition products or other chemical changes that may have occurred within the material.

3.

Size and shape of enclosure - possibility of pockets of hazardous pas, mist or materials.

I 4.

Size, shape and location of openings used to enter the enclosure.

l-5.

Amount of scale build-up or other residue found inside enclosure walls.

11,1,3 Personal Protection The type of personal protection equipment issued to the c_mployee will a.

depend upon the space to be entered, the nature of the operation and the type

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of work to be done. Such equipment should include:

1.

Proper respiratory equipment - dust and/or chemical respirators, air lines, etc.

Intepared Environmental Semces. a division ofNES. 44 Shelter Rock Road. Danbury CT 06810 Page 11-3

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Suitable apparel 3.

Suitable gloves designed for the material to be handled 4.

1*totection for the eyes, face head, cars, and feet b.

Each and every employee entering any tank, vessel or other like confined space must wear a suitable safety harness attached to a lifeline by a quick-release catch. The Site Safety Official in charge will inspect the lifeline to detennine that is it in pod condition and of suf0cient length and of proper size and has been properly tied off (the line should have enough slack to allow freedom of movement but not enough u. low the worker to slip below the working level).

c.

Adequate and approved lighting facilities for entry and servicing are mandatory. Either approved flashlights or extension lamps must be of the low-voltage type.

I1.1.4. Emercency Procedures At times, incidents can occur, for this reason:

All workers must be made aware of and have a clear path of escape.

a.

b.

A standard form of signals must be implemented to allow the worker to g

communicate with the outside attendant.

c.

The outside attendant must have a means of signalling for additional help (air hom, etc.). The attendant will not enter the enclosure unless properly equipped and help has arrived at the scene of the emergency.

d.

Training and drilling procedures in rescue work should be carried out regularly and workers should be instructed and retained at least annually in the method of ardficial respiration and/or cardiopulmonary resuscitation, c.

Workers entering areas that had contained a hazardous material should te instructed in any symptoms, etc., which might signal the presence of residual concentrations of this material.

Integrated Environmental Senices, a dnision ofNES. 44 Shelter Rock Road, Danbury. CT 06810 Page 11-4

I f.

should anyind iual inside the confined space feel abnonnal in any way. all those within the confined area shall immediately leave the area until the cause of the illness can be detennined.

I1.1.5. Outside Csntractors Outside contractors shall be required to follow these procedures on all work being performed on existing structures at any NES plant site. It is imperative that personnel of such contractors te infonned of special harards connected with a particular job involving confined work space areas.

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12. RESPIRATORY PROTECTION POLICY AND PROCEDURE l

12.1. INTRODUUrlON While most air is safe to breathe, there are sorne processes which necessitate the t!se of respiratory protection. The OSilA standards for General Industry 29 CFR 1910.134 established permissible practices and requirements for a minimal acceptable program.

NES' program is designed to provide basic guidance, training, selection, use and care in a corporate respiratory protection program. Additions to this program may be necessary in order to adapt to spcdal conditions and situations which may exist or arise at each NES site project.

12.2. EMPLOYER AND EMPLOYEE RESPONSIBILITY 12.2.1. Emplover Resoonsibility a.

Respirators shall be provided by the employer when they are necessary to protect the health of the employee, b.

NES shall provide the respirator which is applicable and suitable for the intended purpose and conforms to NIOS11 approvals.

c.

NES shall be responsible for the establishment and maintenance of a respiratory protection program.

12.2.2 Emolovee Responsibillry NES employees shall use a respirator when necessary and in accordance a.

with the instructions and training received.

b.

NES employees shall guard against damage to the respirator.

c.

NES employees shall report any trouble or malfunction to their Site Safety l

Officer.

12.3. Maintenance And Care Of Resoirators 12.3.1, Insnection a.

All respirators shall be inspected routinely before and after each use, b.

Respirators kept for emergency use must be inspected after each use and at l

least monthly to assure that they are in satisfactory working condition.

Integrated Environmental Services, a divii.on ofNES. 44 Shelter Rock Road. Danbury. CT 068!0 PaFe 12-1

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A record shall tx kept of inspection dates and findings for respirators c.

maintained for emergency use.

d.

Respirator inspections should include:

1.

Check the tightness of connections and the condition of the face piece.

2.

Check the headbands.

3.

' Check the valves and seats.

4.

Check the connecting tube and cr.J.sters and/or cartridges.

5.

Rubber or elastomer parts shall be checked for pliability and deterioration.

12.3.2. Cleanine and Disinfectinc a.

Respirators shall be cleaned and disinfected after each use, b.

Cleaning Procedures 1.

Remove any filters, cartridges, headbands, and disassemble the major respirator pans.

l 2.

Wash all respirator parts (except cartridges and clastic headbands)in a cleaner-disinfectant solution at about 120 degrees F. Use a hand bmsh to remove din.

3.

Rinse completely in clean, wann water.

4.

Air dry in a clean area.

5.

Inspect all parts: replace with new parts if defective.

6.

Reassemble the respirator.

7.

Place the respirator in a new plastic bag and seal it for storage.

8.

Disposable type respirators shall be used for one shift only, and therefore, need no cleaning and disinfecting.

Disposal and reauestine a new resoirator is the resconsibility of the emoloym Integrated Environmental Sernces, a doision ofNES 44 Shcher Rock Road. Danbury CT06810 Page 12-2

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12.3.3. Storace of Reseir;tica a.

Atter inspection, cleaning and necessary trpairs, respirators shall be stored to protect against dust sunlight, heat, extreme moisture or damaging chemicals, b.

Respirators shall not te placed in lockers or tool boxes unless they are in a carrying case.

c.

Respirators shall te packed or stored so that the face piece and exhalation valve will rest in a near nonnal position.

12.4. MEDICAL LIMITATIONS a.

Persons will not be assigned tasks requiring the use of respirators unless they are physically able to perform the work and use the equipment.

I b.

The respirator users medical status will be reviewed annually as part of the employee's annual medical physical.

12,5. SELECTION. ISSUANCE AND TRAINING PRACTICES 12.5.1. Sdendon of Resoirators a.

Respirator type and make will be selected by the Corporate licalth and I

Safety Officer, b.

Only respirators approved by the National Institute of Occupational Safety and licalth may be used. Refer to NIOS11 Certified Equipment List,llEW publication No. (NIOSli) W145, and supplements, c.

The proper type of respirator for the specific hazard involved will te selected in accordance with the manufacture's instructions.

12.5.2. Issuance of Resoirators a.

Management reserves the right to determine if a respirator is needed.

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Air sampling data will be taken and shall be the determining factor in the case of a disagreement between NES and an employee on whether a respirator is needed.

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I 12.5.3. Trainine Practices a.

Instruction on the nature of the hazard (s) and an honest appraisal of what 1

may result if the respirator is not utilized, b.

An explanation of why engineering controls are not immediately possible, and that effort is tring made to climinate the need for the respirator.

c.

Ar. explanation why this is the proper type of respirator for the particular hazard (s).

d.

An explanation of the care and cleaning program.

e.

A discussion of the respirator's capabilities and limitations, f.

Instruction and training in actual use, and close and frequent supervision to assure proper use.

p.

Any other emergency instructions.

12.6. OPERATING PROCEDURES FOR RESPIRATORS a.

Respirators must be stored in a proper area when not in use.

b.

Whenever tespirators are not in use during the shift, they must be stored in a clean plastic bag in which they were issued.

c Respirators may not be wom when conditions prevent a good face seal (such as growth of a beard or missing dentures).

d.

To assure proper protection the face fit must be checked by the wearer before each shift.

I 1.

Positive Pressure Tests - Close off the exhaJation valve with heel of your hand. Breathe air into your mask. The face fit is sa$fa: tory if some pressuit can be built-up inside the r;ask without airleakuq out between the mask and the face of the wearer.

2.

Negative PressureTests - Close-off the irdet cpenings of the cartridge with I

the palm of your hand. Some masks may regtdre that the filter holder be Integrated Environmental Sr tvices a division ofNES. 44 Sheher Rock Roa.i Danbury. CT 06810 Page 12 4

O removed to seal off the intake valve. Inhale genij so that a vacuum occurs y

within the f ace piece. Iloid your breath for 10 seconds, if the vacuum l

remains, the respirator is properly fit.

12.7. TOXIC ATMOSPilERE During nonnat operations no toxic atmospheres are present as long as established work procedures are being followed.

In cmergency situations whete an atmosphere exists in which the wearer of the respirator could tw overcome by a toxic or oxygen-deGeient atmosphere, the following procedure shall be followed:

a.

Never enter a dangerous atmosphere without first obtaining the proper protective equipment and pem11ssion to enter from the Site Safety Officer.

b.

Never enter a dangerous atmosphere without at least one additional man present, who must remain in the safe atmosphere, c.

Communications (voice, visual, or signal line) must be maintained between both

{

individuals at all times.

d.

The person remaining in the safe atmosphere must have the proper rescue equipment to enable them to aid the person in the dangerous atmosphere if problems are encountered.

12.8. CONTROL AND EVALUATION OF RESPIRATOR PROGRAM in order to maintain an effective respiratory program, control and feedback on how the proFram is functioning is necessary. In this manner, improvements can be made and l

deficiencies climinated.

12.8.1. Wemr Accentance a.

Comfort b.

Ability to breath without objectionable effort

.g c.

Adequate visibility under all circumstances Integrated Environmental Senices, a division ofNES,44 Shelter Rock Road. Danbury. CT 06810 Page 12-5

d, Provisions for wearing presenption plasses e.

Ability to perfonn all tasks.,>ithout undue interference f.

Confidence in the face piece fit 12.8.2. Examination Of Resrirators in Use E

a.

Even though a respirator is worn conscientiously, the protection provided is no better than the respirator in use.

b.

Frequent random inspections shall be conducted by a qualified individual to assure that respirators are properly selected, used, cleaned, and maintained.

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13. EYE PHOTECTION POLICY AND PROCEDURE lt is NES' policy that all projects owned leased. or operated by NES shall cover NES employees, employees of vendors, employees of contractors and visitors while at NES project sites.

As a minimum, the program shall require that:

a.

Eye protection be worn by all persons at sites operated by NES.

b.

Safety glasses be provided at hES expense for all NES employees required to wear eye protection. Each NES Si3U shall set a maximum amount it will contribute to prescription safety glasses. Safety glasses funded by NES must have side safety shields attached or NES will not reimburse the employee for the expense of their safety glasses.

c.

Safety glasses must be of ANSI approved industrial quality, d.

Side shields, goggles, face shields, welding shields be provided for huards where safety glasses alone are not adequate.

l e.

Contact lenses are to tx prohibited at all project sites.

f.

Appropriate eye protection be provided by NES to all outside visitors.

I g.

NES employees servicing customers are required to wear safety glasses and/or appropriate eye protection as may be warranted while on customers premises.

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14. IIEARING CONSERVATION POLICY AND PROGRAM 14.1. GENERAL Excessive noise exposure is detrimental m the health of NES' employees.

The Occupational Stfety and licalth Act (29 CFR 1910.134) requires that employees be protected against the effects of such noise exposure when the sound levels exceed the l

following:

Sound Level dBA Duration Per Day. Hours Slow Resoonse 3

8 90 6

92

{

4 95 3

97 2

100 1-1/2 102 I

1 105 1/2 110 1/4 or less 115 I

In o. der to comply with this requimment and to protect the health of NES employees. each SBU shall carry out the following noise control and hearing conservation program.

14.2. PROCEDURES a.

All areas of the site shall be monitored at least during the beginning of each operation such as drilling or trenching by the corporate industrial hygienist to determine sound levels and the duration of employee exposures. The results of all such surveys shall be recorded and appropriately filed.

I b.

Where noise levels exceed the above duration-decibel standard the following actions are to be followed:

1.

Personal prot =tive equipment shall be mandatory for all employees subject to excessive noise exposure. These reqairements shall be rigidly enforced by the SBU/ plant manager until the noise exposures are reduced to allowable limits.

Integrated Environmental Semces, a division ofNES. 44 Shelter Rock Road. Danbury, CT 06810 Page 14-1 j

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Feasible engineering and/or administrative methods shall_be instituted to reduce noise exposures. All studies and expenditures shall be documented and forwarded to the corporate Health and Safetv Officer.

c.

When engineering controls fail to reduce noise levels belew the prescribec 2, a I

continuing, effective hearing conservation program shall be administered for all employees whose work requires them to enter, with or without personal protective equipment, such high noise level areas. The program at least shall consist of the following:

1.

Baseline audiograms 2.

Annual audioraerne testing 3.

Documented records of all tests I

4.

Comparison of the annual audiogram with the baseline audiogram by a qualified individual d.

Purchase orders for new equipment shall specify construction or protection which will limit noise levels to 85 dBA or less for individual sources. When suppliers cannot meet these specifications they shall be required to submit sound level estimates to the Corporate Health and Safety Offiper so that the effects on the noise control program of the SBU can be evaluated before purchase.

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integrated Environmental Sernces, a division ofNES. 44 Shelter Rock Road, Danaury. CT 06810 Page N-2

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15. SEAT llELT USE POLICY 15.1 OBJECTIVE TO MAXIMlZE Tile SAFETY OF OCCUPANTS OF ALL VEHICLES USED IN COMPANY BUSINESS l

15.2 REQUIREMENTS 1.

It is required that all NES-owned or leased automobiles and trucks and any privately owned automobiles and trucks used in company business be equipped with seat belts.

2.

In accordance to local law the use of seat belts is mandatory for all front-seat occu-pants of such vehicles and recommended and encouraged for back-seat occupants.

15.3 RESPONSIBILITY The driver of the vehicle is responsible for making sure NES' seat belt procedures are adhered to.

15.4 EXCEfrTIONS Any specific exception to this policy must be requested and approval granted in writing.

The Corporate Health and Safety Officer may grant exceptions.

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16. MEDICAL SLRVEILLANCE PROGRAM OSilA requires a medical examinauon for employees to wear a respirator (29 CFR 1910.13400(10)), and other OSil A standards include specific medical requirements; e.g.,29 CFR 1910.120(f) (Medical Surveillance) 29 CFR Pans 1910.1001-1910.1045 (Substance Specific Standards) and 29 CFR 1910.95 (Audimetric Testing). Specifically, any employee who, in the performance of their work assignment, has the potential to te exposed to hazardous substances I

above their PEL for more than thirty (30) days a year, or wi!' be using respiratory protection for more than thirty (30) days a year will participate in the Medical Surveillance Program.

I 16.1. OBJECTIVES l

Medical surveillance shall be an integral component of the NES occupational health and safety program in order to monitor the health of individual personnel through the use of initial and periodic medical examinations and diagnostic testing. Such a program will accomplish the following objectives:

comply with OSHA regulations:

establish a base line against which future changes in health or physical well being can be evaluated; identify any under lying illnesses or conditions which might be aggravated I

by cenain exposures or job activities:

recognize any abnormalities, toxic reactions, or other changes at the earliest opportunity so that corrective measures may be taken.

l No NES employee shall participate in NES site activities where the potential for exposure to harmful substances or physical injury could occur unless a licensed physician has determined that the individual is medically qualified to perform field activities and is medically qualified to use respiratory prer.ective devices. Assignments which may require panicipation in the medical surveillance program include work conducted with radiological or biological agents c.nd work at sites where hazardous (chemical) substances may be present.

The MSP shall utilize a Board Certified physician located near the Danbury office to perform medical evaluations. Such physicians will be responsible for administering a Integrated Environmental Services. a division ofNES. 44 Si:elter Rock Road. Danbury, CT 06810 Page 16-1 i

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standardized questionnaire, performing physical examinationt., and collecting and processing biological samples. The data obtained from these tests and procedures shall be-interpreted by the physician responsible for the individual's examination. As appropriate, a

" Fit for Duty" statement for the specific employee shall be completed by the examining physician.

Employees have a right to review the information obtained during this examination. All l

medical infom1ation is considered confidential, but summary data shall be made available to project managers'to detemene whether employees may be assigned to a field task.

Employees must sign a disclosure agreement prior to receiving the physical examination in order to release their medical records to NES to determine suitability for work assignments (See Appendix).

16.2.

INITIAL AND PERIODIC MEDICAL EXAMINATIONS The level of the medical surveillance shall be based on the nature of the hazards to be encountered during site activities and the expected duration of exposure. Additional l

individual health factors may also influence the level of monitoring. The level shall be determined by the examining in conjunction with the NES Health and Safety Officer.

Medical examinations instituted as part of the Health and Safety program are not to be considered substitutes for regular checkups that are designed to monitor general health.

Medical examinations undertaken for this program are designed to screen for evidence of potential adverse effects due to exposure to toxic substances and physical agents.

Therefore, the examination does not necessarily pmvide for screening of pre-existing common, non-occupational chronic disorders.

l Each individual enrolled in the medical surveillance program shall be subject to initial and periodic medical examinations based upon the following conditions:

At least once every twelve (12) months unless the physician believes a longer interval (not greater than biennially) is appropriate, more frequent examinations may be necessary depending on the extent of potential or actual exposure:

Following an acute exposure to any toxic or hazardous material; At the discretion of the HSO and/or consulting occupational physician; Integrated Enytronmental Services. a division of NES,44 Shelter Rock Road. Danbury, CT 06810 Page 16-2

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1EN At the request of an employee with demonstrated symptoms of exposure to toxic or hazardous materials and approval of the HSO and/or consulting occupational physician.

16.3. EXTT EX AMINATION If an employee is permanently reassigned or tenninates employment with NES, that I

employee shall be offered a tennination physical examination, unless the following three criteria have been met:

The last complete medical examination was within the last six (6) months:

The employee has not been involved in site work in which a potential exposure could occur; No symptoms associated with exposure occuned since the last examination.

The consulting physician will assist the HSO of NES in determining whether an exit physicalis necessary, if the employee declines the exit physical, a si ned waiver should be F

obtained and placed in the employee's medical file.

l Per 1910.120(f)(6), NES shall provide the consulting physician with the following infonnation for each employee requiring a medical examination:

description of the employee's duties as they relate to the employee's exposures:

I employec's exposure levels or anticipated exposure levels; l

description of any personal protective equipment used or to be used; and information from previous medical examinations of the employee.

16.4. SPECIAL MEDICAL EXAMINATIONS A medical examinations shall be performed as soon as possible upon an employee's development of signs or symptoms indicating possible overexposure to a hazardous l-substance or health hazards, or upon injury or exposure limits (PELS) or published exposure levels in an emergency situation. The consulting physician will be notified immediately to conduct a physical.

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The occunence of an " exposure"(e.g., breathing 200 ppm of a chemical vapor when the PEL is 500 ppm) is not, without extenuating circumstances, a reason for medical exam. The PEL is a time weighted average concentration of a contaminant that a worker may be exposed for an 8-hour shift,40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> a week, without adverse health effects.

16.5, RECORDKEEPING All medical records shall be maintained in the office of the consulting physician Exposur'e i

records shall be filed in the Danbury office for a period of at least thirty (30) years beyond an employce's last date of employment with NES. These records shall be accessible to the

.I participants and NES consulting physicians. Medical records are classified as confidendal and therefore shall be maintained under secure conditions. Pertinent medical information may be shared with emergency medical facilities adjacent to hazardous work sites. " Fit for Duty" forms that are kept with the employee's personnel records in NES offices should also be considered confidential information.

16.6. ACCESS TO MEDICAL RECORDS As required by OSHA standards, records of employee medical history must be made available on request to the employees, an employee representative, and OSHA. The

. standard applies to all employers in general industry, construction and maritime operations whose employees are exposed to toxic substances and harmful physical agents. By J

providing workers with information they can use to detect, treat, and prevent occupational diseases, the policy is intended to increase awareness of workplace hazards and allow I

workers to play a meaningful role in the own management.

)

Medical records will be maintained for the duration of employment plus thirty (30) years.

All medical and other information obtained in the course of administering the program and the services provided shall be maintained as confidential and made available only to other I

1 personnel as deemed necessary by company procedures. Disclosure shall be restricted to the following conditions:

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records of a participant upon written request; records of a participant to the NES consulting firm; and records to others outside the form with written consent of the panicipant.

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As required by law, NES will forward copies of requested records to an eligible requester within fifteen (15) days of receipt of the wntten request.

I Medical information obtained in implementing of the MSP will be used to determine the presence or absence of work restrictions specific to the job for which an individual is I

applying or already engaged.

16.7. MEDICAL CLEARANCE 1

The Reproductive Protection Policy complies with Title Vil of the Civil Rights Act as amended and ensures that every effort will be made to eliminate nsk or harm to unborn children of employees due to participation in hazardous substances activities. The policy is based on mutual trust, understanding, sharing of information, and cooperation between employee and employer.

The provisions of the NES Policy include:

Obtaining reproductive histories of employees as part of the preassignment I'

and periodic physicals that are a requirement of the MSP and counseling through medical providers for pregnant field workers and those trying to conceive; Possible restriction from hazardous field activities and change in work assi nments of pregnant employees, or of ernployees exhibiting medical F

conditions that may jeopardize an unborn offspring, based upon the I

recommendation of the employce's personal physician, with consultation and concurrence or MSP physician's recommendation.

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ATTACHMENT B I

EXCAVATION SUPPLEMENT I

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I APPENDIX Construction Excarntion Policy Scope: This policy applies to all open excavations, including trenches.

l General Requirements: Excavations and trenches shall be made in conformance with 29 CFR 1926 Subpart P. This regulation includes the following general requirements:

Surface encumbrances which may create hazards must be removed or supported a.

b Underground installations (sewer, telephone, fuel, electric, water lines, etc.) which

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I may be encountered must be identified prior to opening the excavation.

Access and egress means shall be provided. These may include ramps designed by a c.

competent person, stairways, ladders, or other safe means. Trenches 4 feet or more I

in depth must have a safe means of egress so that no more than 25 feet oflateral travel is required by employees,

d. Employees exposed to public vehicular traffic shall wear warning vests or other l

suitable garments marked with or made of highly visible material,

e. Employees shall not be exposed to falling loads. No employee shall be pennitted uncerneath loads handled by lifting or digging equipment or vehicles being loaded or unloaded.

Warning systems (barricades, hand or mechanical systems, or stop logs) shall be 4.

provided for mobile equipment operating adjacent to an excavation.

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g. Trenches and excavations greater than 4 feet in depth shall be considered confmed spaces and shall be tested for hazardous atmospheres. Emergency rescue equipment I.

(such as breathing apparatus, safety harness and line, or basket stretcher) shall be provided where hazardous annospheres exist or may be expected to develop.

h. Employees shall not work in excavations containing accumulated water unless precautions have been taken. Water removal and excavations subject to runoff shall be monitored and inspected by a competent person.

i. Support systems such as shoring, bracing, or underpinning shall be provided to ensure the stability of adjacent structures. Excavation below the base or footing of foundations or retaining walls or undermining sidewalks pavements or other structures is not nermitted except when the conditions of 29 CFR 1926.251 (i) are I

met.

j. Employees shall be protected from loose soil or rock, Materials and equipment I

shall be kept at least 2 feet from the edge of excavations or retaining devices shall be used to prevent materials or equipment from rolling into the excavation.

k. Excavations, surrounding areas, and protective systems shall be inspected daily by I

a competent person. Inspections shall also be made after every rainstorm or other hazard increasing event, prior to the start of work, and as needed throughout the shift.

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Walkways or bridges shall be provided where employees or equipment are required or permitted to cross excavations. Adequate barriers shall be provided at remotely I

located excavations. All wells, pits, shafts. etc. shall be barricaded or covered.

Upon completion of exploration and similar operations, temporary excavations shall be backfilled.

Protective Systems Requirements for protective systems are addressed in 29 CFR 1926.652. Employees shall be protected from cave-ins by adequate protective systems designed in accordance with 29 CFR 1926.652 unless:

I Excavations are entirely in stable rock Excavations are less than 5 feet deep and an examination by a competent person provides no indication of a potential cave-in.

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RADIOLOGICAL CONTROL PLAN

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NUCLEAR ENERGY SERVICES

' DOCUMENT NO.

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1 29 EE PAGE OF um I

I RADIOLOGICAL CONTROL PLAN I

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] Propet Appucaton Copy No, Assigned To APPROVALS i

TITLE / DEPT. - SIGNATURE - DATE REV NO PREPARED BY PROJECT MGR.

DIRECTOR E'

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Eric Abelquist F-gju,.,

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V DATE PAGE DESCRIPTION APPROVAL 2

8/21/92 17,21 CRA 8428 I

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I 82A8038 DOCUMENT NO.

l NUCLEAR ENERGY SERVICES 3

9 PAGE OF TAllLE OF CONTENTS PAGE 1.

INTRODUCTION 5

1.1 Scope and Purpose 5

1.2 Responsibilities 6

I 1.3 Operational Procedures and Review Requirements 6

2.

CONTROL OF PERSONNEL EXPOSURE 7

I 2.1 Radiation Exposure Limits 7

2.1.1 Occupational Radiation Exposure Limits 7

2.1.2 Non-Occupational Exposure Limits 7

2.2 Control of Radiation Exposure 8

2.2.1 Occupational Radiation Exposure 8

2.2.2 Exposure to Minors 8

2.2.3 Exposure to Unborn Child 10 2.2.4 Exposure to Visitors 10 3.

PERSONNEL MONITORING FOR RADIATION EXPOSURE 11 3.'

External Monitoring 11 3.1.1 Personal Dosimetry 11 I

3.1.2 Estimation of Dose 12 3.1.3 Loss or Damage of TLDs 13 3.1.4 Wearing TLDs 13 3.1.5 Tracking Radiation Exposure 13 l

3.2 Internal Radiation Exposure Monitoring 13 3.2.1 Personnel Contamination 13 3.2.2 Routine Bioassay 14 3.2.3 Special Internal Dosimetry Evaluation 14 3.2.4 Dose Commitment 14 I

3.2.5 Work Restriction 15 4.

PERSONNEL RECORDS AND REPORTS 16 4.1 Exposure Records 16 5.

IDENTIFICATION AND MONITORING OF CONTROLLED AREAS 17 5.1 Controlled Areas 17 5.2 Identifying Controlled Areas 18 I

FORM #NES 205 7/90

I 82A8038 DOCUMENT NO.

l NUCLEAR ENERGY SERVICES 4

29 PAGE OF TAllLE OF CONTENTS (continued)

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l' AGE 6.

RADIOLOGICAL SURVEYS 18 6.1 Survey Frequencies 18 6.2 Safety Precautions 20 6.3 Calibration and Maintenance of Instruments 20 7.

EMERGENCY ACTIONS 22 7.1 Accidental Spillage of Radioactive Materials 22 7.2 Fire in A Controlled Area 23 l

7.3 Contaminated injured Man 24 7.4 liigh Airborne Radioactivity 25 7.5 Loss of Radioactive Material 26 I

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l I M2AWM OOCUMENT NO, NUCLEAR ENERGY SERVICES 5

29 PAGE OF I

1. INTRODUCTION I

1.1 SCOPE AND PURPOSE I

This manual presents the radiation protection standards and controls to be in effect for a facility during decommissioning. All management personnel responsible for operations in a I

radiation environment involving handling or processing of radioactive materials must be knowledgeable of the contents of this manual and must ensure that each employee has a good understanding of the sections which apply to his/her job assignment. Any deviation from this manual requires the wntten approval of the NES Project Manager.

Thn: radiological safety requirements have been developed based on the recommendations and requirements of the National Council on Radiation Protection and Measurements, the U.S. Department of Energy, the Intemational Commission on Radiological Protection, and on standards which have been reviewed and accepted by the Public Health Service, the U. S. Nuclear Regulatory Commission, the Department of Labor and the Environmental Protection Agency.

All personnel associated with the handling of radioactive material or who work in radiation areas must understand that a knowledge of standard radiation protection rules and practices is an internal part of their job related responsibilities in order to to minimize radiation exposure. To assist in ensuring such an understanding, each person associated with the handling of radioactive material shall receive periodic instruction in the general and specific aspects of radiation safety.

The major purpose of this manual is to establish the basic practices to be implemented during the cleanup project conducted by NES to ensure satisfactory control of radioactive materials and radiation exposures to personnel. The basic philosophy shall be to maintain radiation exposures as low as reasonably achievable (ALARA) and to keep radioactive l

material contained at all times in the smallest practical volume. The implementation of this operating philosophy will be the responsibility of the NES Site Supervisor and Project Manager.

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82A803M NUCLEAR ENERGY SERVICES 6

29 PAGE OF 1.2 RESPONSIBILITIES The Site Supervisor (SS), the Radiological Controls Supervisor (RCS) and the Radiological Controls Technicians (RCT) have the authority to cease operations in the event that operatmg conditions are not in compliance with safety controls or approved operating procedures. In addition, NES' SS, RCS and RCT have the authority to prohibit authorized employees from conducting radiological activities whose occupational radiadon exposures have approached the established administrative limits or have not demonstrated a continued understanding of, or the need for, comphance with radiation safety procedures.

l In order to control radiation safety hazards, NES' RCTs shall have the authority to stop work w hich violates the applicable work procedures or which, in their opinion, presents an imminent danger of:

A.

Excessive radiation exposure to personnel.

l B.

Con' amination of personnel or the environment.

C Personnel injury or equipment damage from an identified industrial safety hazard.

When it becomes necessary to stop a job due to a safety hazard, conditions should be stabilized as soon as possible. Unless precluded by the urgency of the situation, cessation of operations will be implemented through the Project Manager who is responsible for the overall conduct of the job.

l.3 OPERATIONAL PROCEDURES AND REVIEW REQUIREMENTS Detailed procedures incorporating radiological and other safety considerations are required for operations involving the handling of radioactive materials. The preparation of such procedures by the operating organizations shall assist in minimiz.ing the problems encountered by requirmg explicit planning in advance of the operational phase. The written procedure will serve as a step-by-step guide for the personnel performing the operation.

NES shall review and approve of all procedures prior to their implementation.

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I 82A M DOCUMENT NO.

NUCLEAR ENERGY SERVICES 7

29 PAGE OF

2. CONTROL OF PERSONNEL EXPOSURE 2.1 RADIATION EXPOSURE LIMITS 2.1.1 Occupational Radiation Exposure Limits The radiation exposure limits established in Title 10 Code of Federal Regulation.

Part 20 (10 CFR 20)." Standards for the Protection Against Radiation", are used for controlling personnel exposure to radiation (excluding medical and dental exposures) to levels which are believed to cause no detectable biological effects even if the employee was exposed to these levels throughout his/her entire working life Despite the establishment of administrative limits, personnel should endeavor l

to maintain their own exposures as low as reasonably achievable, it shall be the goal of NES to maintain individual whole body radiation exposure as low as reasonably achievable ( ALARA).

Table 2-1 illustrates the administrative occupational exposure limits.

l No employee shall exceed these limits without receipt of a formal written extension of allowable exposure by the Radiological Controls Supervisor (RCS) and the Site Supervisor (SS). This extension shall be limited to one calendar quarter in duration, after which another formal written extension may be issued. In no event shall these extensions exceed the limitations imposed by 10 CFR 20 for individual exposure, in addition, no employee shall be exposed to further occupational radiation l

exposure of any kind whatsoever which may produce a lifetime exposure to the individual greater than the following limiting dose (rem), as specified in 10 CFR 20:

5 times (N-18) where "N" = worker age in calendar years 2.1.2 Non-Occuoational Excosure Limits NES shall control the radioactive material in its possession so that exposure to l

members of the general public is limited to as low as reasonably achievable not to exceed 0.125 rem per quartet or 0.5 rem per calendar year.

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l NUCLEAR ENERGY SERVICES 8

PAGE OF 2.2 CONTROL OF RADIATION EXPOSURE I-2.2.1 Occuoational Radiation Excosure The three most important methods to minimize exposure in fulfillment of ALARA objectives are the proper use of time, distance, and shielding. Each of these items is discussed below.

A.

TIME Exposure to radiation decreases with the reduction in time spent in radiation l

areas. Therefore, to minimize the time that is spent in radiation areas, all jobs should be pre-planned. Such pre-planning should include:

1.

Making sure you have all the tools and equipment tequired for thejob grigI to entering the area.

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Being familiar with the equipment and plans gIicI to enterine the area.

3.

Knowing the radiation levels as well as component location print to entering the area.

B.

DISTANCE Exposure to radiation can be significantly reduced by keeping as much distance between yourself and the source as possible.

C.

SHIELDING The third method of controlling / minimizing radiation exposure is by means of I

shielding, NES shal! utilize shielding as necessary to limit exposure to personnel.

2.2.2 Exposure to Minors Individuals under the age of 18 are not permitted to enter controlled, restricted or radiation areas at the facility.

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FORM #NES 205 7/90

82A8038 DOCUMENT NO..

NUCLEAF. ENERGY SERVICES 9

29 PAGE

_ OF TAllLE 2.1 Radiation %urker Occupational Exposure Limits and Controls I

10 CFR 20 Limits. Rem Administrative Controls. Rem Tvoe Of Excosms Annual Ouarter Ananl Ouarter Dajjy Whole Body, Head and 1r:m..

5 3

3 1.25 (1)

Gonads,1 ens of Eye, Ree Bone Marrow, Active Blood Forming Organs Unlimited Areas of the Sc 30 7.5 15 3.75 (1)

(Except hands, feet, ankle.

and forearms)

Forearms 75 18.75 15 3.75 (2)

Extremities 75 18.75 15 3.75 (2) an Minors (less than 18 year, 10'7c of above levels No Exposure Allowed

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(1)

As measured by the ' an window" of the TLD (2)

As measured by aparmate supplemental dosimetry I

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1I 82A803N DOCUMENT NO.

I NUCLEAR ENERGY SERVICES 10 29 PAGE OF 2.2.3 Excosure to Unborn Child i

The National Council on Radiation Protection and Measurements (NCRP) recommends:

"During the entire gestation period, the maximum permi.sible dose I

equivalent to the fetus from occupation exposuie of the expectant mother should not exceed 0.5 rem."

I Prior to being issued dosimetry equipment, all personnel authorized to receive radiation exposure shall be given specific instruction concerning prenata) exposure risks to the developing embryo and fetus. This instruction shall be given both orally and in writing, the applicable information in the appendix to U.S. Nuclear I

Regulatory ( smmission Guide 8.13. " Instruction Concerning Prenatal Radiation Exposure."

I Instruction concerning prenatal exposure to the unborn child shall be given during initial and reverification training.

All personnel receiving instruction in accordance with this paragraph shall sign the l

following statement prior to being issued dosimetry:

"The recommendation of the National Council on Radiation Protection and Measurements to limit radiation exposure to the unborn chi;d to the very lowest practical level, not to exceed 0.5 rem during the entire period of pregnancy, has been explained to me."

Signature

.I Typed or printed name Date The signed statements shall be kept with the training records.

2.2A Excosure to Visitors I

NES shall control the exposure ci visitors at its worksites to levels as low as is reasonably achievable. For exposure control purposes a " visitor" is defined as any I

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I 82AM03M DOCUMENT NO.

NUCLEAR ENERGY SERVICES II 29 PAGE OF person not qualified as a radiation worker and who requires access to controlled areas.

Visitors who will not enter controlled areas shall be instructed as to their location and designation (e.g., radiation area signs). Visitors who will enter controlled areas shall normally require an escort and will be issued temporary dosimetry.

Entry by a visitor to a controlled area shall require the following:

1.

Assignment of a temporary self-reading pocket 60simeter (SRPD);

2.

Escort by a qualified radiation worker at all times while in the controlled area.

I Visitors are not allowed access to any area where there is a significant risk of internal deposition of radioactive material.

If repeated entries to controlled areas are required by a visitor, over periods exceeding two weeks, a temporary TLD can be issued if the visitor meets I

appropriate requirements as a radiation worker.

3. PERSONNEL MONITORING FOR RADIATION EXPOSURE 3.1 EXTERNAL MONITORING 3.1.1 Personal Dosimetry 3.1.1.1 Issue of Personal Dosimetry All personnel who are likely to receive a dose in excess of 125 mrem in a quarter year shall be morntored using whole body dosimeters including:

1.

Personnel entering an area posted as a radiation area or high I

radiation area.

2.

Personnel who routinely remain in spaces immediately adjacent to radiation areas. Even though the general area radiation levels in the g

space are less than one mrem per hour, personnel shall be monitored B

if they are likely to receive a dose in excess of 125 mrem in a quarter g

year.

3.

Personnel who directly handle or touch radioactive material. or personnel in a controlled surface contamination area, even though I

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82A8038 DOCUMENT NO.

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NUCLEAR ENERGY SERVICES 12 29 PAGE OF they do not enter a radiation area. Ilowever, it is permissible for personnel to handle radiation survey instruments containing check sources without being monitored with dosimeters.

3.1.1.2 Types of Dosimeters 1.

Thermoluminescent Device (TLD)

NES shall issue TLD badges to all radiation workers in order to

.I measure their whole body radiation exposure. The results of the TLD

,g badge measurements shall serve as the basis for the permanent, legal B

record of an employee's exposure. Therefore, any deliberate action by an employee which invalidates the TLD measurements is cause for disciplinary action.

Those personnel who have qualified as radiation workers and who I

have a need to enter a controlled area shall be issued a permanent TLD.

I An individual's permanent TLD normally shall be worn on the front of the body between the waist and neck, the open window shall face I

away from the body, 2.

Self-Reading Pocket Dosimeters Self-reading pocket dosimeters (SRPD) shral be issued to escorted visitors who will enter controlled areas for only a short period of time. The SRPD shall be read by the RCT upon entry and exit of the visitor and the reading shall be recorded in the " Visitor's Log".

3.1.2 Estimation Of Dose All exposures indicated by the TLD shall be considered to have been received by the individual unless it can be clearly demonstrated to be erroneous.

If an exposure measurement result from a TLD is lost or proven erroneous, an estimate of the dose received by the individual during the period in question shall be established by the RCS and documented as a part of the employee's Exposure l

Record. An example of a Dose Evaluation Report is provided as Figure 3.

1 FORM #NES 205 7/90

LI 82A %38 DOCUMENT NO.

'l' NUCLEAR ENERGY SERVICES I3 PAGE OF Estimates of dose received shall consider at least the following:

3.1.2.1 Dose rates in the individual's work area 3.1.2.2 Actions taken by the individual during the time for which dose information is desircJ. This teview should include consideration of work position, time in controlled areas, etc.

3.1.2.3 Doses received by other personnel doing similar work in the area 3.1.3 I oss or Damace of TLD's All lost or damaged personnel TLDs shall be reported promptly to radiological control personnel.

I individuals who lose or damage their TLD while in a controlled area shall immediately exit the area and report the condition to the RCT, The individual shall I

be restricted from entering controlled areas until an exposure estimate has been completed and a new TLD issued.

3.l A Wearine TLD's The wearing of TLD's by all radiation workers shall be strictly enforced.

3.1.5 Trackine Radiation Excesure Prior to personnel performing work at the facility, NRC Form-4," Occupational l

External Radiation Exposure History", will be completed to determine personnel lifetime exposure. N~RC Form-5, " Current Occupational External Radiation Exposure", will be completed to determine personnel exposure for the current year and quarter.

l 3.2 INTERNAL RADIATION EXPOSURE 3.2.1 Personnel Contamination I

Surveying (frisking) for personnel contamination shall be performed by all individuals in the restricted area. The instructions for using the equipment, the acceptable limits of contamination and the action to be taken if individuals exceed the limits shall be discussed in training.

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I 82A8038 DOCUMENT NO.

lH HUCLEAR ENERGY SERVICES I4 29 PAGE 0F 3.2.2 Routine Bioassav 3.2.2.1 In-vitro Bioassay in-vitro sampling lurinalysis) and/or a whole body count will be perf rmed at least twice during the e urse f w rk.The first sarnple will be

-E3 collected prior to the actual start of work. The e,econd sample will be collected upon work completion or personnel termination. Bioassay _

samples will also be collected in emergency situations.

3.2.3 Snecial Internal Dosimetry Evaluation Personnel who are involved in radiological work will have internal dosimetry evaluations in the form of urinalysis and/or whole body counts when internal contamination is confirmed or suspected,in accordance with the following criteria:

3.2.3.1 Whenever personnel are exposed to high airborne radioactivity above limits in 10 CFR 20, Appendix B without the aid of a respirator.

3.2.3.2 Whenever personnel are exposed to high airbome concentrations exceeding the protection factor of the respiratory equipment being worn.

I 3.2.3.3 Whenever nasal swabs or personnel frisking indicates detectable counts of alpha or beta-gamma activity above limits of Section 1.4 of the NES, Surface Contamination Program.

l 3.2.3.4 Whenever the Radiological Controls Supervisor feels that internal monitoring is needed.

When in-vivo examinations are required as a result of internal contamination, the involved personnel shall be transported directly to the l

whole body counter facility as soon as practicable after the incident.

Additionally,in-vitro fecal sampling may be required,if the urinalvsis or in-vivo examination indicates internal contamination.

3.2.4 Dose Commitment I

When an internal deposition is detected, the employee's dose commitment (s) shall be estimated by methods consistent with reports 26 and 30 of the Internauonal I

FORM #NES 205 7/90

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DOCUMENT NO.._.{2AW38 l-NUCLEAR ENERGY SERVICES 15 9

PAGE OF Commission on Radiological Protection (ICRP). The dose commitment shall be reported to the employee and shall become a part of his/her exposure history file.

The dose comrmtment is defined as the dose equivalent (rem) received by specific I

organs during a period of one calendar year, resulting from the uptake (single or multiple) of radionuclides.

I 3.2.5 Work Restriction An employee may have his radiation work activities altered or limited as a result of:

1.

Approaching the control levels of Section 2.1 herein.

2.

Unknown exposure status.

3.

Increased potential for internal deposition such as an open skin break.

4.

Repeated violations of safety requirements.

The RCS is responsible for implementing work restrictions when necessary. The employee's supermor shall be notified in writing that a work restriction has been imposed within hours of determining the need for a restriction. Copies of work restrictions will be maintained in the employee's dosimetry record.

No person shall exceed the admmistrative contrcl levels of Section 2.1 without prior, written approval of the RCS and the SS.

I An employee whose exposure status is unknown (e.g.,iost dosimeter) shall not enter a controlled area until his current exposure status is determined by the RCS.

When an employee has an internal deposition of a radioisotope induced for medical diagnostic purposes, he shall be restricted from wearing a TLD until the medical isotope is eliminated from the body, This is done to avoid including exposure from the medical isotope to that received as occupational exposure.

Employees who work with radioactive materials shall report any skin breaks (e.g.,

unhealed wounds, open cracks from chapping, injuries such as lacerations, abrasions, punctures, and blisters or burns) which they may have to their immediate supervisor and radiological controls personnel. A clearly open wound shall be sufficient reason to prohibit entry to a controlled area, irrespective of protective clothing or medical dressings.

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I 82A8038 DOCUMENT NO.

l NUCLEAR ENERGY SERVICES 29 PAGE OF Safeguards shall be maintaineJ by supervision to minimize the likelihood of accidental introduction on radioactive materials beneath the skin. If the, skin is broken while working with radioactive materials, the employee shall immediately report to his immediate supervisor who will have the skin break surveyed by an RCT. The RCS will determine if additional follow-up action is required.

Contaminated personnel shall be decontaminated in accordance with approved procedures.

4. PERSONNEL RECORDS & REPORTS 4.1 EXPOSURE RECORDS The RCS shall assure that records are maintained to permit a ready accounting of an l

employee's accumulated radiation exposure. This occupational exposure record shall include:

A.

Any known prior employment external occupational exposure history. (See Figure 1)

B.

External occupational exposure received, including that received at other installations. (See Figure 2) l C.

Special dose evaluations and work restrictions. (See Figure 3)

D.

Reports of unusual exposure such as overexposure or incidents with potential for internal deposition. The incident forms will be supplied by NES.

Each employee shall be informed of the results of all record dosimetry evaluations.

Non-record exposure control information shall be preserved for two years to enable exposure re-evaluation, if it should become necessary. Employee exposure records shall be retained by NES indefinitely.

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82A8 2 DOCUMENT NO.

l NUCLEAR ENERGY SERVICES I7 9

PAGE 0F 5, IDENTIFICATION AND MONITORING OF CONTROI.l.ED AREAS l

5.1 CONTROLLED AREAS A radiological contw. led area applies to controlled surface contamination areas and to an area which contains one or more controlled surface contamination areas.

g There are five (5) area posting classifications as derned below:

A.

Radiation Area I

A Radiation Area is an accessible area where a major ponion of the body could receive a dose from 1 mrem to 100 mrern in one hour.

Entrance to radiation areas shall be conspicuously posted with " RADIATION l

.. EA" signs.

B.

Airborne Radioactivity Ar '

ecessible to personnel will be posted as " AIRBORNE RADIDACTIVITY l

Alt

' if airborne radioactivity exists or is likely to exist in concentrations exceet ig 25 percent of those specified in 10 CFR 20. Appendix B, Table I, Column 1.

Each Airborne Radioacti' Area must be posted with signs meeting applicable standards, including the raatation symbol, and the words " CAUTION - AIRBORNE RADIOACTIVITY AREA" C.

High Radiation Area A high radiation area is an accessible area where a major portion of the body could l

1eceive a dose in excess of 100 mremin one bour. Such areas shall be posted as "High Radiation Areas" and locked or guarded, Positive controls shall be established for each entry into the area in such a way that no individualis prevented from leaving a high radiation area. Prior to locking the area, a search will be performed to ensure all person. 'I have exited. Signs shall be posted containing the conventional magenta three bladed syrnbol on yellow background and the words " CAUTION - HIGH RADIATION AREA".

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I 82AM DOCUMENT NO.

NUCLEAR ENERGY SERVICES IN PAGE OF.

D.

l<adioactive Materials A Radioactive Materials Area is an area that contains radioactive material in quantities exceeding ten times the 10 CFR 20 Appendix C quantity. Each Radioactive Materials Area shall be posted with signs meeting applicable standards, including radiation symbol, and tne words " CAUTION RADIOACTIVE MATERIALS".

5.2 IDENTIFYING CONTROLLED AREAS l

The boundaries of controlled areas, if not a permanent wall or fence, shall be clearl'y indicated by rope, or chain. Radiation warning signs printed in the standard yellow and magenta colors shall be conspicuously posted to identify to personnel the presence of radiation and shall not be used for any purpose other than radiological controls. All radiological posting shall tv done by or at the direction of radiological control personnel.

I Movement or removal of posted radiation warning signs, tags, or boundary markers by personnel other than radiological control personnel or without their approval rnay be cause I

for disciplinary action.

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6. RADIOLOGICAL SURVEYS Radiation surveys are performed as necessary to ensure that personnel do not exc~:d limits of I

Section 2.1 and do not receive unnecessary exposure to radiation. The primary concern is to minimize personnel exposure as low as reasonably achievable ( ALARA) by providing information to radiation workers on the radiation levels in the work area so work will be completed efficiently.

6.1 SURVEY FREQUENCIES I

Radiation surveys are performed as necessaiy to ensure personnel do not exceed external radiation exposure limits and to meet requirements for posting radiation areas. These I

surveys are performed to determine whether abnormal radiation levels exist and to determine the extent and magnitude of radiation levels. The following surveys shall be the minimum performed:

1.

Facilities Containine Radioactive Material a.

Radiation surveys shall be performed to control external radiation exposure whenever operations are performed that might be expected to change existing I

radiation levels. Examples of such operations include accumulation of waste and relocation of highly radioactive materials.

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I 82A M DOCUMENT NO.

l NUCLEAR ENERGY SERVICES 39 PAGE OF b.

Temporary boundaries /

g., rope boundaries) of radiation areas shall be surveyed weekly to ensure controlled areas do not extend beyond posted boundaries.

c.

Gamma surveys shall be periormed at least weekly in occupied posted radiation areas and high radiation areas,in all occupied areas of radiological f acilities and in radioactive material short-term storage areas. Long-term storage areas shall be suneyed at least monthly.

d.

Other surveys shall be performed as necessary to control personnel exposure to gamma, beta and alpha radiation.

2.

Durine Casualties I

Radiation surveys shall be peri'ormed as necessary to assess the extent and a.

magnitude of a radiation condition in the event of an accident which might I

cause abnonnal radiation levels.

3.

Records a.

Records of radiation suneys shall be retained until the end of the job and submitted to the client. The survey information shall be recorded on a standard fonn. if specified, or on locally prepared forms which contain at least the l

following information:

Date and time of survey Reason for survey and type of radiation measured (e.g., weekly gamma)

T3pc and identif).ng number of instruments used Instrument calibration due dates l

Location (shall be shown on a survey map or listed in a table)

Radiation level measured Remarks Signature of surveyor Signature of persons reviewing results te.g., Radiological Controit Supen'ison I

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DOCUMENTNO.

l NUCLEAR ENERGY SERVICES U

PAGE OF 6.2 sal'ETY PRL AUTIONS The following safety pr ins shall tv observed by personnel using portable radiation monitoring equipmen' 1.

Only personnel trained in the use et portable radiation monitoring equipment shall be I

allowed to use this equipment. As a minimum, training shall consist of a lecture on the use of the instrument, and the meaning ofits measurements, a demonstration of its proper handling, and a period of supervised use.

2.

Damage to or loss of a radioactive check source can result in spreading, inhaling, or I

ingesting contamination. Therefore, radioactise check sources require careful handling and accountability control if a source is lost,immediate steps shall be taken f or its recovery and to mininuie resulting radiation exposure and/or contamination of personnel as a result of its loss.

I 3.

All check sources except for those which are permanently attached to monitoring equipment shall be kept m a locked cabmet w hen not in use.The number of keys shall I-be kept at a minimum. Combinanon locks are permitted, however, the number of personnel having the combination shall be kept to a minimum.

6.3 CALillRATION AND MAINTENANCE OF SURVEY INSTRUMENTS Radiological control supervisory personnel shall ensure that the appropriate survey insuuments are available, functional, and calibrated using accepted source standards.

The types and uses of spec fic radiation momtoring devices recc,mmended for use are listed i

in Table 7-1.

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I FORM 4NES 205 7/90

I M2AM03M DOCUMENTNO, lH NUCLEAR ENERGY SERVICES 21 PAGE 0F TAllLE 7-1 RADI ATION MONITORING DEVICES RECOMMENDED APPI.lCATION INSTRUMENTS Personnel dosimetry, record Landauer Dorimetry (e.g., TLDs, film badges)

Personnel dosimetry, self-reading Dosimetry Corporation Model 862, or equivalent Contarnination monitoring alpha ESP-1 survey meter with AC3-7 probe, or I

equivalent Area radiation monitonng beta / gamma Eberline RO-2, or equivalent Contamination monitonng beta / gamma Ludlum Model 2221 with 44-9 probe, or 44-40 shielded probe, or equivalent liigh level gamma radiation Automess Teletector 6112D, or equivalent Area exit surveys Ludlum Model 3 w.th 44-9 probe, or equivalent Portable air sampling device Radeco H-809V, Eberlin:: RAS-1, or equivalent isotopic analysis Canberra Model 85 MCA with in:rinsic germanium crystal, or equivalent Smear Counter Ludlum Model 2929 with Phoswich Detector for Alpha and lleta/ Gamma, or equivalent Liquid Scintillation Counter Packard 2500TR, or equivalent llackground Radiation Level Bieron Micro Rem survey meter, or equivalent I

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I 82A W 8 DOCUMENT NO.

I NUCLEAR ENERGY SERVICES 22 29 PAGE OF

7. EN1ERGENCY AC 1 )NS 7.1 ACCIDENTAL SPILI. AGE OP RADIOACTIVE MATERI ALS I

Should radioactn e or contaminated matenals be accidentally released from their container the following actions shall be taken. NES personnel are to follow the instructions below I

which have been developed using the SWIMS acronyrn:

"S" = Stop the spill "W" = Warn other personnel "l" = !solate the spill area "M" = Minimize personnel exposure "S" = Secure the appropriate equipment Stop The Spill-Take the immediate measures necessary to stop the spill (e.g., closing a valve or blocking the path of the fluid with absorbent material), if mechanical action is needed, such as clostng a valve or disabling a pump, knowledge of the effect on the total system or machinery involved is required prior to such actions.

Warn Other Personnel-Others in the immediate area and those entering the area must be informed of the event in order to take the appropnate response actions. Health physics personnel must be notified as soon as possible.

Isolate The Spill Area-Non-vital personnel shall be kept out of the immediate vicinity, If necessary, designated personnel shall be posted at the entrance to the area to control access, Personnel who have been contaminated shall remain in the immediate vicinity in l

order to prevent the spread of contaminants until released by health physics personnel unless radiation level are high or a traumatic injury has occurred, l

Minimize Personnel Exposure-Personnel shall remain in the immediate vicinity until health physics personnel l

arrive both to assist in spill control and to be available for surveying of exposed individuals. The nature of the spill, both chemical and radiological, and the need to monitor the spill shall dictate how close personnel should remain.

I FORM pHES 205 7/90

82A W38 DOCUMENT NO.

I NUCLEAR ENEHGY SERVICES 23 9

PAGE_.

OF Secure The Appropriate Equipment -

Ventilation or other operating equipment may be selected for shutdown due to the nature of the spill and to prevent f urther occurrence. Knowledge of the systems and equipment involved is necessary prior to taking such action.

7.2 FIRE IN A CONTROLLED AREA Areas shall be evacuated by all non-cmergency personnel when a fire, heavy smoke, or similar fumes occur in a controlled area. llealth physics, operational and/or fire response personnel shall be immediately notified. This is true for all fire events, including those l

where personnel in the immediate vicinity have extinguished a minor event, such as a wastebasket fire.

l.

When possible the fire shall be extinguished by personnel in the immediate vicinity rather than allowing it to grow into larger proportions while designated personnel are on their way, 2.

If a fire cannot be rapidly extinguished, the local fire department shall be sumrnoned I

for fire detail:

fire detail shall wear self-contamed respiratory equipment, protective clothing, and any other items deemed necessary by the lead health physics individual the primary function of the fire detail shall be to evacuate personnel from the fire area I

the secondary function of the fire detail shall be to save equipment and property without endangering their own or other lives the tertiary function of the fire detailis to minimize the spread of contamination l

outside the and airborne radioactivity controlled area 3.

Fire extinguishing agents shall be used which minimize the volume of potentially contarninated liquids.

4.

All fire fighting personnel shall be surveyed prior to exiting the event area except for those in need of immediate medical assistance outside the controlled area.

Minimizing the spread of contamination shall be kept in mind at all times.

I CM #NES 205 7/90 m -

I 82A W 8 DOCUMENT No.

I NUCLEAR ENERGY SERVICES 24 9

PAGE OF 7.3 CONTAMINATED INJURED M AN 1.

Minor Wounds Several steps should be taken when open wounds could be contaminated.

Wash minor wounds immediately under running water, spreading the edges of o

I the gash. If at all pracucal, collect and retain cotton sponges, fluids, etc., for

analyses, Repon all radiation accidents invohing personnel wounds, ingestion or o

inhalation to the RCS as soon as possible.

Call, at once, a physician qualifi d to treat radiation injuries and to collect additional bioassay samples.

Permit no person involved in a radiation injury to return to work without the o

approval of the attending physician and the RCS.

Prepare a complete history of the accident and subsequent activity related thereto for 'he RCS.

2.

Serious Iniury in emergency situations where an individual is seriously injured in a contaminated area, the first priority is to treat the injury.

Other actions include:

Contact the RCS o

Call or have someone call an ambulance o

Notify the nearest hospital qualified to treat contaminated injuries that a o

potentially contaminated injured person would soon arrive.

A Heuith Physics Technician equipped with appropriate survey instruments shall accompany the contaminated, injured individual to the hospital, Once at the hospital, the Technician shall survey the emergency transport vehicle and I

paramedic crew. The Technician shall support the medical staff treating the patient regarding survey results, accident history, etc.

I No injured individual may return to work without written approval of the attending physician and the RCS.

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FORM #NES 205 7/90

I 8 A 038 DOCUMENT NO, l

NUCLEAR ENERGY SERVICES 25 PAGE-OF

~.

111Gll AIRilORNii RADIOACTIVITY Particulate Radioactn ity e uceding NRC guidelines for the dominant isotope specific to the f acility as shown in 10 CFR 20 App. B., Table 1, column 1, will require the following actions:

NOTli:

liigh airborne contamination is not expected in ground moving tasks. Ilowever, cutung, gnndmg or buming of other material rnay be performed in containment thus warranting these precautions.

A.

Inunediate Action: Notifv Radiological Controls Supervisor.

I (l) fivacuate personnel from affected areas. Don respiratory equipment in accordance with the Airborne Radioactivity Prograin (No. 82A8037) for personnel who must return to the affected area.

(2)

Verify that the high airborne results u.e., from portable air sampling, (e.g.,

R ADECO high volume samplers) or elevated instrument readings) are correct.

(3)

Stop operations which might be causing high airbome radioactivity until adequate control of airborne radioactivity is established.

(4)

Secure air moving equipment (e.g., fans, window air conditioners, and unit heaters)in the atfected spaces.

I (5)

Determine the extent of the airborne radioactivity by sampling the affected area and adjacent areas which might be affected using portable air samplers.

II.

Succlementary Action:

(1)

Attempt to identify the radionuclide causing the airborne radioactivity. For example, by promptly measuring the sample for alpha radioactivity and l

determining the half-life.

(2)

Measure and control surface contamination in areas affected by high airborne I

radioactivity.

(3)

Perform alpha and beta / gamma surveys of ventilation filters and ducts and measure surface contamination in the vicinity of the ventilation exhaust discharge point.

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mmt =MES 205 7/90

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82A8038 DOCUMENT NO.

NUCLEAR ENERGY SERVICES 26 29 PAGE OF (4)

When resuming operations, take a portable air sample to verify that the cause of high airborne radioactivity is corrected.

(5)

Check personnel exposed to high particulate radioactivity for internal radioactivity.

(6)

Exposure reports shall be filed per 10CFR Part 20. Sections 20.103 and 20.408.

7.5 LOSS OF RADIOACTIVE MATERIAL If radioactive material is lost, the following procedures shall be followed:

A.

NES will immediately conduct a search. The primary reason for this is to ascertain that no persons will receive inadvertent internal or external exposure from the material.

B.

If the material cannot be located before the end of the work day, NES will prepare an incident report in accordance with 10 CFR 20.402 and notify the NRC as appropriate.

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I FOTsM #NES 205 7/90

l

!I 82AMG DOCUMENT NO.

NUCLEAR ENERGY SERVICES 27 29 PAGE OF I

Nse s a sw ee,u,cun 2d'a rc U S NUCLEAR REGULATORY COMM:SSION OCCUPATIONAL EXTERNAL RADIATION EXPOSURE HISTORY s

,w-

. w.

F >f N T f t* A ' r%

I N AML (PHlN1 - LAST. FIRST. AND MIDDLE; 2 SOCIAL SECURITY NO 3 DAT E OF B!HTH (MONTH. DAY YLARJ 4 AGE tN FULL YLAHS (N)

I occ+atow I avosse ntyous H s? car i ewivous t 9 novus Nis motveo a t;AttsortunovutNT t rfhoDso5Exposuns I

AA14iCN 1f DSVRE + Us1 NAwk AND

1. 40w. t O 6

• C l BODY S 54ECOhD Oft CALCmATtD A:x>ns ss 0$ 6 unort k is w, oNst at ONu I

I I

I 10 REMARKS 11 ACCUMULATED OCCUPATIONAL DOSE

. TOTAL I

I 13 CALCULATIONS-PERM:SSIBLE DOSE 12 CERT 6FICATION.1 CERTIFY THAT THE EXPOSURE HISTORY WHOLE BODY-LISTED IN COLUMNS 5 6 AND 7 IS CORRECT AND COMPLETC.

^

(A) PERMISSIBLE ACCOMULATED -

REM DOSE. 5sN-18)

(B) TOTAL EXPOSURE TO DATE REM (FROM ITEM 11)

EMPLOYEE'S SIGNATURE DATE (C) UNUSED PART OF REM I

~

PERMISS:BLE ACCUMULATED 14 NAME OF LICENSEE DOSE 1 A - 81 l'IGUllE I I

I FORM #NES 205 7/90

I 82^8#

DOCUMENT NO.

NUCLEAR ENERGY SERVICES 28 2

PAGE OF I

vc6. 6 Acom ee e, ous Udrlra U S NUCLE AR REGULATORY COMM:SSION CURRENT OCCUPATIONAL EXTERNAL R ADIATION EXPOSURE w. -, -. e,ae e

• t A. Tit 1" A U %

1. NAME (PRINT -last, hrnt ano mod.e)

I SOCIAL SECURITY NO 3 DATE OF BIRIH (Month. nay yuf; 4 NAME OF LICENSEE I

$ DOSE RECORDED FOR (bteofy Whoie t>oof 6 WHOLE BODY Dobt 7 VET HOD OF MOtilTORING to p. hirn baog*-

pan of wtone body, or hanos and forearms ST AT U S tremi f B. Pocket Chamoer-PC. Cacutabons-Caic )

I tout sno ansoes I X OR GAMMA DETA NEUTRONS 0 PERIOD OF EXPOSURE DOSE FOR THE PERIOD #remi 13 RUNNING TOTAL (F rom - To)

FOR C AL ENDAR 9 X OR GAMMA 10 DETA 11 NEUTRON 12 TOTAL QUART E R trom)

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mi,u, ccsus. con tose 14 PkkVOU5 TOT A6 Pe++ 19 T01 A6 QUARTE AV 16 'OT A6 A00UMsiA'IC 17 FE RM ACO DCSE 6%-146 0ew 14 UNus[D PART OF P! hvi$$1BLE CG5E DOM eemi AOCUhtAATED D054 Domi I

we en I

FIGURE 2 I

FORM #NES 205 7/90

'I 82At4038 DOCUMENT NO, I

NUCLEAR ENERGY SERVICES 29 29 PAGE OF I

NUCLE AR ENERGY SERVICES, INC.

Rey, I

DOSE EVALUATION REPORT Date NAME SOCIAL SECURITY NO.

DATE OF B!RTH COMPANY OR CRAFT I

LOST TLDO No.

NEUTRON DOSE EVALUATION O LOST FILM BADGE D No Lost Dosimeter O No DAMAGED D (Describe >

DESCRIPTION OF OCRUEf.SZ I

(Use astonal the+ts it necessary and criecA here it used Oi Summary of Avait.se Records of Exoosure (Give burvey Numbers. RWP Numbers, Dosimeter Readings, ete )

I (Use amuonal sneq4ts it necessary and check hern it used Oi I

Ett:rrate1Letw;1e (Evaluate above Data and Est. mate Occucationai Erlemal Rad'aten Exposure. Descree Evaluaton boow ana atta:n addrtional sneets it necessary. Check here 0;t usea adaitonai snests i Aem Aom Aem Whole Body Skin Extremnies I

Emocyee Suoervisor investigator r

I ACTIC,N FILE THIS REPORT WITH APPLICABLE Personnel Monitonng Records Aclusted DOSIMETRY RECORDS FOR PERIOD Date e,

y nmua y

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l F0FIM NNES 205 7/90

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