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APPENDIX B
Demolition Asbestos Survey and Assessment




Short-Term IM Work Plan
APPENDIX C
Demolition Permit Applications and Plans




Short-Term IM Work Plan
Work Plan Summary
 Demolition of Buildings Former Koppers Facility Gainesville, Florida
        Chemtron Corporation has been contracted to demolish buildings and structures at
the former Koppers site in Gainesville, Florida, there are approximately 8 buildings and 2
tanks that will be demolished. See Attachment H of this plan for drawings of specific
buildings. This project is anticipated to last for approximately 4 weeks. Working hours
on site will be from 7 am to 5 pm Monday through Saturday. No concrete breaking
operations will take place outside of 8 am to 4 pm Monday through Friday to mitigate
noise disturbance to residents. During the project, the gate located at NW 23rd Street will
be used as access for vehicles. This gate will remain locked at all times except when
entering or exiting. All buildings are to be removed to ground level, including
foundations, and no digging is to take place.

        First, Chemtron will mobilize to site and set up all necessary signs, barricades and
equipment prior to the start of any work. A secondary decontamination area will be set
up for the tanks. Spill prevention controls will be set up in work areas. Utilities will
have disconnections completed and verified. At this point of the project, the city and
DEP will be involved in the process of verification of disconnection of utilities and waste
management practices.
        Next, heavy equipment such as excavators and bobcats will be used to remove the
buildings and structures. All buildings are to be disassembled using a grapple attachment
with an excavator and loaded into trucks for offsite disposal. The concrete and brick is to
go to a recycling facility. All wood and debris is to be sent to a landfill as construction
and demolition debris. All steel is to be sent to recycling as well. All material will be
loaded into roll offs or dump trailers. All truck traffic on the site is to enter and exit at
the gate located on NW 23rd Street. The tanks will be removed following the procedures
set forth in Attachment C of this manual. All ancillary pipes connecting the boiler
building to the process area are to be removed as well. The pipe track housing these
pipes is to remain. Hand tools and an excavator will be used to accomplish this task.
        This site is located in a heavy residential and commercial area. Therefore,
airborne dust is of a particular concern to neighboring areas while work is being
performed. While on site, all vehicles and equipment must observe the best manageable
practices of keeping dust to an absolute minimum. All roadways will be kept wet while
work is being performed. Also, areas where heavy equipment is working will be kept
wet at all times where the equipment is tracking and where the exhaust emanates from the
equipment. A water truck is on site at all times and will be utilized for this purpose.
There is no need for the containment of such water as these areas are currently exposed to
rain and there are monitoring wells and waste water treatment on site. During concrete
breaking and brick breaking activities, the surfaces shall be wetted to control dust
emissions during the entire demolition process. No building is being dropped at one time
with wrecking balls or the like and they are being dismantled with grapplers to avoid
dust.
All chemicals and environmental concerns have been removed from the buildings.
All utilities have been disconnected from the buildings. There are some pieces of
equipment which are to be decontaminated which will take place throughout the course
of the project.
        Finally, following the conclusion of the remediation of buildings and tanks, the
site will have continuing remediation. All disturbed areas as well as areas of bare ground
will be seeded with grass to prevent wind erosion and maintain permanent dust control.
A waste water treatment plant is to be maintained on site for many years to come. The
property will remain locked and access will be restricted.
Contractor Name: Chemtron Corporation

Project Name: Demolition of buildings at former Koppers site

Work Location: Former Koppers Plant 200 NW 23rd Ave. Gainesville, Florida

Projected Job Start Date: 6/1/10            Time: 7:30 a.m.

Projected Job Finish Date: 7/31/10           Time: 4:00 p.m..

PREPARED BY: Michael Perry

COMPANY PREPARED BY: Chemtron Corporation                  Date: 5/22/10

Phone: 440.933.6348    Cell: 440.336-0262           DATE SUBMITTED:    5/24/10


  Attachment A – Plan Acknowledgement Signature Page
  Attachment B – OSHA Logs
  Attachment C – Tank Removal Procedures
  Attachment D – Insurance Certificate and Workers Comp
  Attachment E – Confined space program and permit
  Attachment F – Hot Work Permit
  Attachment G – MSDS Information
  Attachment H – Drawings




                                            Page 1 of 23
INTRODUCTION:
        The purpose of this HASP is to set forth, in an orderly and logical fashion, appropriate health and
safety procedures to be followed during onsite demolition activities at the former Koppers Facility in
Gainesville, Florida. During the performance of the task, this HASP identifies potential hazards which
Chemtron Corporation personnel and any sub contractors may be exposed to. Chemtron Corporation
personnel, and any sub contractors shall not participate in the performance of this task without having read
this plan in its entirety. This plan has been developed to be as complete as possible; however, should
conditions dictate revisions or additions to this plan, amendments shall be drafted, added, and distributed to
all persons involved with this plan. This plan works in concert with the Chemtron Corporate “Safety and
Health Plan”, OSHA standards CFR 1926, Environmental Protection Agency regulations, National Fire
Protection Association Codes, and any other applicable city or state codes. It shall be the prime contractor’s
responsibility to ensure that all of its subcontractors comply with the provisions set forth in this plan.

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

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




                                                   Page 2 of 23
COMPANY’S SAFETY PERFORMANCE:
  Chemtron Corporation has provided similar scopes of service for NASA GRC, General Electric, and Beazer East
Inc. Chemtron has provided demolition and excavation services as well as tank cleaning and confined space for the
above mentioned companies as well as many others for over 25 years.
See Attachment B

EMPLOYEE AWARENESS OF SAFETY:
      In an effort to provide a safe and healthful working environment, Chemtron Corporation has
implemented the following Health and Safety policies and procedures throughout our organization:
• new hire safety indoctrinations
• monthly safety committee meetings
• safety meeting relevant to customer site-specific job safety requirements
• job safety inspections
• job site “tail gate” safety meetings
• annual training on required 29 CFR 1910 General Industry Standards and 29 CFR 1926 Construction
   Standards
• employee accident injury OSHA 300 Accident Injury Prevention Program
• employee recognition for Continuous Safe Work Practices
• Drug Awareness Program
• 8 hour OSHA update
• CPR and First Aid Responders

     Employees are trained and qualified to perform their work safely and are held accountable for intentional
or negligent noncompliance. Each employee is empowered and expected to stop his or her own work or the
work of co-workers if any person’s safety or the environment are at risk. The Construction Supervisor is
expected to support and reinforce this expectation. Stopped work shall not resume until the hazard has been
controlled and a review has been performed. In addition, all employees are encouraged to seek ways to
enhance the effectiveness of the H&S Program.
     The Subcontractor Site Safety and Health Officer (SSHO) shall ensure that at the start of each work day,
a tailgate safety briefing is performed that reviews the THAs (task hazard analysis) applicable to the daily
activities, unique site conditions, hospital route, personal protective equipment (PPE), and stop work
authority. The SSHO shall ensure that all site personnel involved attend the tailgate briefing and that they
sign as having attended. If personnel do not attend the tailgate briefing, the SSHO shall approach the
personnel when they arrive onsite, provide them with an individual tailgate briefing, and have them sign as
attending.
     Project training shall include at least the following. The Construction Supervisor, and SSHO shall have
current hazardous waste safety training (40 hour, 8 hour refresher within past 12 months), hazardous waste
supervisor training, and sufficient experience to understand the potential hazards. All other field personnel
shall have current hazardous waste safety training including 40 hour and current 8 hour refresher. The SSHO
shall present a project kick-off safety briefing to cover this plan, physical hazards, hazardous contaminants
and chemicals, required hazard controls, and emergency contacts and additional safety briefings as needed
(at least once per week). At least one person onsite shall have current first aid and cardiopulmonary
resuscitation (CPR) training. The SSHO shall maintain documentation of completed training onsite.
Additional training may include, but not be limited to, Respiratory Protection and Hearing Conservation.
Field personnel shall be enrolled in a medical surveillance program and have current hazardous waste
medical clearance.


                                                    Page 3 of 23
SITE COMPLIANCE:
        This health and safety plan will be reviewed by all employees of Chemtron and its’ subcontractors on
this project. A copy of the plan will be kept on site at all times during work operations to be accessible to all
persons involved in and around the project. The site safety supervisor will conduct daily “tailgate” safety
meetings to address work for the day and relate it specifically to the provisions of this plan. The site safety
supervisor will monitor all daily on site operations and ensure the compliance of safety protocols set forth in
this plan.

Position & Responsibilities                            Name                          Cell Phone

Project Manager                               ___Karl Guenther_____                  __440.653.3438______

Field Superintendent                          ___         ____                       _______

Safety Coordinator                            ___Mike Perry        _                 __440.336-0262_____


Technician_________________                   ___ _______                                ________

Technician_________________                   ___ ____                                   _______

  (additional names and numbers will be added as needed)




                                                    Page 4 of 23
POTENTIAL HAZARDS*: (Identify those hazards that relate to the work activity) –
       Heavy equipment work, high pressure water, crane work, confined space, hot work



1. Asbestos
      -   A thorough asbestos survey has been conducted by Avanco and all asbestos has been abated
          from this site.
2. Barricading
      -   Fencing and signs will be used around working areas to identify work zones;
      -   Spotters will be used to keep area clear of non essential personnel and direct personnel in and out
          of work zone as needed and keep personnel clear from overhead work load; Spotters must wear
          safety vests to maintain visibility for operators and pedestrians;
      -   Duration of work will be approximately 4 weeks;
      -   Lane closure will not be required during this project.

3. Biological
          -   Biological hazards are present for this project and include spiders, ticks, bees, wasps,
              mosquitoes, poison ivy, snakes, wildlife.
      -   Wear work clothes; tape pant legs as necessary.
      -   Use insect repellant as necessary;
      -   Self inspection for ticks and other insects during the work day and at the end of the day;
      -   Wash hands as necessary;
      -   Personnel with severe life threatening allergies to stings should inform FM for assignment to
          areas free of the hazard.




                                                 Page 5 of 23
4. Chemical/ Flammable Hazards
     -   Gasoline for generators and power washer if used;
                     a) To be stored on site in approved storage area in 5 gallon safety containers with
                         vents and no more than 10 gallons on site.
                     b) Spill controls to be kept on site including absorbent pads, boom, floor dry, 55
                         gallon drums, non sparking shovels, and brooms.
                     c) Pads to be placed under point of transfer of liquids to contain any leaks
     -   Diesel fuel for heavy equipment.
                     a) A portable OSHA approved diesel tank will be stored on construction vehicles
                         with approximately 100 gallons of fuel.
                    b) Pads will be placed under fill points to prevent release from leaks.
     -   Vehicles contain gasoline or diesel fuel, engine oil, hydraulic fluid, power steering fluid, brake
         fluid, and antifreeze (ethylene glycol). Other lubricants will be used during minor maintenance
         repairs.
     -   Excavator also contains hydraulic fluid.
     -   Calibration gases for air monitoring equipment and spray paint may also be used onsite.
     -   All equipment will be turned off prior to filling.
     -   All equipment will only be filled in the approved storage and refuel area.
     -   Fire extinguishers will be available on excavation equipment and near fuel storage areas.
         - Equipment will be inspected on a daily basis prior to use. Repairs will be performed prior to
             use.
     -   Indoor work will be conducted with electrical tools and equipment.
     -   No wastes are to be generated from these chemicals as they are used as fuel products.
     -   Level D PPE will be required including safety glasses and hard hat. No respiratory protection is
         required.
     -   MSDS are located in Attachment G and shall be readily available at every work zone.
     -   Personnel shall be informed of hazardous chemicals during pre-entry briefing and/or daily
         tailgate briefings.

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

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

                                                Page 6 of 23
7. Demolition
      -     8 buildings and 2 tanks are to be demolished ( see attachment H);
      -     Excavators and bobcats will be used to demolish buildings;
      -     Concrete footers will be broken using and excavator with hammer hoe attachment;
      -     Utility disconnects are to be verified by GRU, the city of Gainesville, and Chemtron Employees;
      -     Single hearing protection consisting of 85 dBA in ear plugs or over ear muffs will be required
            during concrete breaking or cutting activities;
      -     All demolition areas will be marked with tape and spotter controlled zones;
      -     Level D PPE consisting of hard hat, safety glasses, steel toe boots, and DOT class 3 safety vests
            will be worn on site at all times except where higher levels of PPE are noted.


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

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

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

11. Falls
      -     A man lift will be used in the removal of lights and insulation;
      -     Anyone working in the man lift is required to wear a harness and be securely attached to the lift
            with a fall arrest system.

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

13. Hand Tools/ Power Tools
      -     Hand tools will only be used in the manner which they were designed to be used.
      -     GFCIs will be used on any and all electrically operated power tools;
      -     When using pneumatic tools, 85 dBA hearing protection will be used at all times;
      -     Level D PPE is a minimum requirement for hand tool use; however, higher levels of PPE will be
            required based on the job task.
      -     Anticipated tools are hand shovels, power washer, vacuum, concrete saw, and low impact hand
            tools.




                                                   Page 7 of 23
14. Hazardous Energy/ Lockout Tagout
      -     Utilities are to be locked out by Chemtron and verified by City and GRU personnel;
      -     If a utility is encountered that needs to be locked out which is not connected to one of the
            buildings scheduled for demolition, GRU, the City of Gainesville, and Chemtron personnel will
            meet to discuss necessary steps.

15. Hot Work
      -     “Hot Work” is anticipated on this project;
      -     Hot work may occur for minor equipment repairs or saw cut of rebar if found;
      -     Propane/ Oxygen torches may also be used to cut;
      -     A Chemtron Hot Work Permit will be completed prior to any work being performed (see
            Attachment I);
      -     Fire watch will be maintained during all hot work and continue at least 30 minutes after last hot
            work has been performed.

16. Indoor Air Quality
      -     No work will be performed in any occupied building;
      -     Vehicles are not to park near any air inlet to a building;
      -     Doors to any building being worked in must be left open during work to prevent any fume build
            up from equipment or tools;
      -     No smoking or equipment exhaust will be permitted near an air inlet to a building.

17. Interruption of Safety Services
      -     No safety services will be interrupted during this project;

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

19. Laser Construction Activities
      -     No laser activities will be conducted on this project.

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

21. Mercury
      -     No Mercury is present on this project.

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




                                                     Page 8 of 23
23. Painting
      - No painting is anticipated for this project. However, marking spray paint may be used for
           surveying purposes during excavation.

24. Personal Protective Equipment (PPE)
       -   Unless otherwise noted in specific tasks, Level D PPE is required throughout the project
       -   Level D shall be considered no less than safety glasses, steel toe boots, safety vests, and hard hats
       -   All other levels of PPE are specifically noted in each task and must be observed while that task is
           being performed. Consult Site Safety Supervisor prior to start of tasks to ensure proper level of
           PPE is being met.

25. Radiation
     - There is no radiation present on this project.

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

27. Sanitation
       -   A portable restroom will be kept on site for employees.

28. Scaffolding
      - No scaffolding will be used on this project.

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

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

31. Heat Stress
       -   Employees are trained in signs and symptoms of heat stress.
       -   Site safety supervisor is trained in recognition of signs as well as first aid measures and this topic
           will be addressed in daily safety meeting.
       -   If temperature is above 70°F or below 40°F, administrative controls will be implemented (cooled
           or warmed drinks, routine breaks in heated or shaded area, and provisions for emergency heating
           or cooling within 5 minutes travel time).
       -   Avoid caffeinated beverages during warm weather work. Site supervisor shall make sure all
           employees have access to cool beverages.



                                                  Page 9 of 23
32. Lifting
      -   If equipment is to be moved, an evaluation of potential pinch points and/or weight strain will be
          conducted.
      -   Clear area of all unnecessary equipment and slip/trip hazards.
      -   Additional help will be obtained by workers or mechanical assistance used on-site if equipment
          to be moved is unwieldy, has a weight >50 lbs or has to be moved by maneuvering through
          awkward positioning.

33. Weather
      -   In the event of lighting, work shall immediately stop. Work shall not resume until 30 minutes
          after the last lightning strike.
      -   Seek shelter in the event of storms.
      -   Excavations shall not be left uncovered in rain so work shall be planned accordingly taking
          weather into account and allowing enough time for site to be covered in the event of approaching
          weather.

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




                                               Page 10 of 23
EMERGENCY PROCEDURES AND EQUIPMENT
The Chemtron Site Supervisor shall remain in charge of all personnel during any potential emergency
activities. To minimize the potential for accidents and injuries, daily safety and health inspections will be
conducted by the Construction Supervisor or Chemtron SSHO. After an emergency occurs, the Project
Manager, Supervisor, and Chemtron SSHO, and field team will participate in a briefing to discuss the event,
identify the causes, identify corrective measures, and evaluate the responses.




A) EVACUATION

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


B) EMERGENCY EQUIPMENT

Several items of emergency equipment will be maintained at the work site. The required emergency
equipment may include:
   • 16-unit first aid kit with an eye wash station indoors or in weatherproof container, inspected weekly;
   • Fire extinguisher(s) (at least 20-B)
   • Spill kit suitable to handle small spills of decontamination fluids;
   • Pads, boom, floor dry;
   • Cell phone.




                                                Page 11 of 23
Task Hazard Analysis: Building Demolition Koppers Gainesville
1. Project Title                     2. Location:                              3. Date: 5/23/10
Building Demolition Koppers          Koppers plant Gainesville Florida
Gainesville
4. Prime Contractor: Chemtron Corp.     5. Competent Person: Karl
                                        Guenther
6. Sub Contractors: Al’s Dozer Service
7. Emergency information: Dial 911
8. Work Activity 9. Hazard             10. Controls                            11. PPE        12. Other Information
                                                                               Required
Confined Space       Lead dust          Open Air                               Level D                          Full face
work                                                                                                            espirator
Concrete             Heavy              Safe work zone defined by signs and    Level D,       Not to exceed 3 feet
excavation           equipment          spotters                               single
                                                                               hearing
                                                                               protection
Power washer         Ricocheting        Face shields on respirators            Level C
                     debris
Site set up and      Slips, trips,      Identify slip or fall hazards and      Level D
demobilization       falls, struck by   remove if possible. If removal not
                     vehicles           possible, mark and identify hazards
                                        with signs or barricades. Assure
                                        proper clearance from road and use
                                        lane closure if necessary. Seek help
                                        to lift >50 lbs. or use mechanical
                                        lifting device.
Crane operations     Crush injuries,    Spotters to control zones, asses       Level D        No person other than licensed
                     Pinch points       pinch points during rigging                           crane operator to operate crane
Hot work             Burns, fires       Use fire watch, complete permit        Level D
Heavy Equipment      Crush injuries     Spotter control zones;                 Level D        Hearing protection is required in
work                                    Zones must keep 50 foot radius from                   certain phases, see specific tasks
                                        equipment
Concrete Saw         Dust exposure,     Safety guards must be in place on      Level D with
cutting if           ricocheting        tools                                  single
performed            debris                                                    hearing
                                                                               protection
Refueling            Chemical spills,   Spill containment materials, fire      Level D
equipment/ fuel      fires              extinguishers
storage
material handling/   Trailer hook up,   Use spotter as needed                  Level D
transfer             vehicle accident




                                                          Page 12 of 23
PROJECT CONTACTS: (to be updated prior to start of project)




                                   Page 13 of 23
Attachment A
Plan Acknowledgement Sheet




          Page 14 of 23
SAFETY PLAN ACKNOWLEDGMENT:
I hereby acknowledge that I have read, understand and accept the conditions outlined in this Health and
Safety Plan (HASP) and I agree to perform work on this task in accordance with this plan, safe work
practices, and OSHA regulations.

(List all subcontractors working on this activity)
Al’s Dozer service


Name                                    Company                      Signature                   Date




                                                     Page 15 of 23
Attachment B
 OSHA Logs




   Page 16 of 23
Attachment C
Tank Removal Proceedures




        Page 17 of 23
Tank Demolition Procedures
                                Revised 5/31/10
        The following procedures are to be followed for the demolition of tanks at the
Koppers plant in Gainesville, Florida. This purpose of this procedure set is to reduce any
risk of contamination from occurring due to the process of demolition. These procedures
do not address all personnel safety concerns involved with demolition work and shall not
be used as substitute for Health and Safety procedures detailed in the site specific plan.
        The tanks are jacketed with a layer of aluminum sheeting which covers fiberglass
insulation. The aluminum sheeting is to be rinsed inside the tank containment area. All
water collected will be treated as Hazardous Waste and disposed of accordingly. Once
rinsed, the aluminum sheeting will be sent for metal recycling. The fiberglass insulation
will be containerized in roll offs and treated as Hazardous waste.
        Once the insulation layers are removed, the tanks can get moved for
decontamination and demolition. There is to be an area set up directly to the east side of
the containment zone for this procedure. The area will consist of a 50 foot by 100 foot
square area of triple layered 6 mil poly sheeting. The perimeter edges of the sheeting will
be set on containment booms to raise them from ground level and create a pool effect
whereas negating water from leaving the sheeted area or running into it from ground
sources. The area shall be weighted with sand or similar material on the interior
perimeter to sufficiently enough to prevent winds from blowing containment around.
Wooden 4x4 posts are to be wrapped in plastic and placed on the containment to support
the tanks. The post placement shall be sufficient such that no part of the tank touches the
containment.
        Once this containment is set in place, the tanks will be moved by crane one by
one to be decontaminated and demolished. Prior to moving, the man doors on the tanks
shall be secured to prevent any material from dropping during the move. The tanks will
be set in the containment in a horizontal position with the door of the tank facing the
center of the containment. The tanks will be blocked in place to prevent any rolling.
Tanks should be placed in accordance with diagram.
        Following the tanks being set into containment, they will be cleaned. A confined
space crew will enter the tanks and use hand tools and power washers to remove residual
contamination from the interior of the tanks. The waste will be collected with a vacuum
truck. Any accumulation of waste on the outside of the tanks in the containment area is
to be collected as it accumulates with the vacuum truck. All waste collected will be
containerized and sent to Chemtron’s TSDF for disposal. Once the tanks have been
cleaned, they can be visually inspected for decontamination.
        After decontamination has been verified, a shear on an excavator will be used to
cut the tanks into small enough pieces to fit into a roll off. All scrap metal will be sent
for recycling. Once the tanks are gone, the containment will be removed and sent
appropriately for disposal. All of the containment area will be treated as hazardous
waste. Any holes in the containment are to be spray painted before the containment is
removed. Once the containment area is removed from the ground, any area that are
painted, saturated, or discolored are to be dug up. Any soils removed are to be treated as
hazardous waste.
Attachment D
Insurance Certificate and Workers Comp




               Page 18 of 23
Attachment E
Confined Space Procedure and Permit




             Page 19 of 23
Chemtron Corporation
     35850 Schneider Court Avon,                     Permit Required Confined Space Entry
     Ohio 44011
     Phone: 800-676-5091                                       29 CFR 1910.146
     Fax: 440-937-1038
         Category:           Job Site            Established:            Revised:   May 20, 2005
                         Health and Safety
      Procedure #:            CC 19                      By:                 By:    J. Erclauz




                                    Chemtron Corporation
                                              35850 Schneider Court
                                                Avon, Ohio 44011
                                                  (440) 937-6348




                                CONFINED SPACE
                                ENTRY PROGRAM



                                               Compliant With:

                   OSHA General Industry Regulations

                                             29 CFR 1910.146


Chemtron Corporation 35850 Schneider Court, Avon, Ohio 44011
Chemtron Corporation
     35850 Schneider Court Avon,                     Permit Required Confined Space Entry
     Ohio 44011
     Phone: 800-676-5091                                       29 CFR 1910.146
     Fax: 440-937-1038
         Category:           Job Site            Established:            Revised:   May 20, 2005
                         Health and Safety
      Procedure #:            CC 19                      By:                 By:    J. Erclauz


                                              ACKNOWLEDGEMENTS




          The information contained in this document is not to be considered a substitute for any
          provision of the standard. This document shall be used in conjunction with all applicable
          rules and regulations.




Chemtron Corporation 35850 Schneider Court, Avon, Ohio 44011
Chemtron Corporation
      35850 Schneider Court Avon,                Permit Required Confined Space Entry
      Ohio 44011
      Phone: 800-676-5091                                  29 CFR 1910.146
      Fax: 440-937-1038
             Category:       Job Site        Established:                     Revised:   May 20, 2005
                         Health and Safety
          Procedure #:        CC 19                  By:                          By:    J. Erclauz




1)    PURPOSE

     a)      Chemtron Corp. and its associated work places have confined spaces that due to various
             chemical and physical properties may cause death or serious injury to employees who may
             enter them. This Confined Space Entry Program is developed and established to identify,
             evaluate, and control such spaces, and more important, to detail procedures and
             responsibilities for entering and working within confined spaces.

     b)      Adherence to the policies and directives contained in this program is mandatory for all
             supervisors and employees of this company. Supervisors and employees failing to follow
             this program are subject to disciplinary action and/or dismissal.


2)    DEFINITIONS

     a)      Confined Space - A space that:

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

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

          iii)    Is not designed for continuous employee occupancy.

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

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

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

          iii)    Has an internal configuration such that an entrant could be trapped or asphyxiated by
                  inwardly converging walls or by a floor which slopes downward and tapers to a smaller
                  cross section; or




                                                            2
Chemtron Corporation
 35850 Schneider Court Avon,                Permit Required Confined Space Entry
 Ohio 44011
 Phone: 800-676-5091                                  29 CFR 1910.146
 Fax: 440-937-1038
        Category:       Job Site        Established:                   Revised:   May 20, 2005
                    Health and Safety
     Procedure #:        CC 19                  By:                        By:    J. Erclauz


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

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

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

e)      Entry Permit - The written or printed document provided by this company to allow and
        control entry into a permit space.

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

g)      Hazardous Atmosphere - An atmosphere that may expose employees to the risk of death,
        incapacitation, impairment of ability to self-rescue, injury, or acute illness from one or more
        of the following conditions:

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

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

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

     iv)     Atmospheric concentration of any substance for which a dose of permissible limit is
             published (in Subpart G Occupational Health and Environmental Control; or Subpart Z




                                                       3
Chemtron Corporation
      35850 Schneider Court Avon,                   Permit Required Confined Space Entry
      Ohio 44011
      Phone: 800-676-5091                                     29 CFR 1910.146
      Fax: 440-937-1038
             Category:          Job Site        Established:                Revised:   May 20, 2005
                            Health and Safety
          Procedure #:           CC 19                  By:                     By:    J. Erclauz


                   Hazardous and Toxic Substances); or

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


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

     i)      Prohibited Condition - Any condition in a permit space that is not allowed by the permit
             during the time when entry is authorized.

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


3)    CONFINED SPACE LOCATIONS

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

           i)      Non-Permit: The following locations have been identified as non-permit confined
                   spaces, and may be entered and worked in using normal work procedures:

                 (1)     (No locations currently exist).

          ii)      Permit-Required: The following locations have been identified as permit required
                   confined spaces, and may be entered ONLY by following the entry permit procedures
                   established in this program:

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

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




                                                               4
Chemtron Corporation
      35850 Schneider Court Avon,                    Permit Required Confined Space Entry
      Ohio 44011
      Phone: 800-676-5091                                      29 CFR 1910.146
      Fax: 440-937-1038
             Category:           Job Site        Established:                   Revised:   May 20, 2005
                             Health and Safety
           Procedure #:           CC 19                  By:                        By:    J. Erclauz


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

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

                 (1)      (No locations currently exist).

4)    RESPONSIBILITIES

     a)       Chemtron Corp:

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

           ii)     Inform exposed employees of the existence, location of, and the danger posed by the
                   permit space by posting danger signs or by any other equally effective means.

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

          iv)      Provide and document training for entrants, attendants, entry supervisors, and (if used)
                   in-house rescue personnel.

           v)      Protect entrants from all external hazards.

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

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

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




                                                                5
Chemtron Corporation
      35850 Schneider Court Avon,                Permit Required Confined Space Entry
      Ohio 44011
      Phone: 800-676-5091                                  29 CFR 1910.146
      Fax: 440-937-1038
             Category:       Job Site        Established:                      Revised:   May 20, 2005
                         Health and Safety
          Procedure #:        CC 19                  By:                           By:    J. Erclauz


           i)     Inform contractor of permit space entry program;

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

          iii)    Coordinate entry operations with contractor when both will be working in or near
                  permit spaces and debrief contractor after entries.

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

           v)     Debrief contractors of the hazards encountered or created.

          vi)     If necessary, reclassify a non-permit confined space as a permit space when there are
                  changes in use or configuration.

     c)      Employees:

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

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

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

5)    PERMIT REQUIRED CONFINED SPACE ENTRY PROGRAM AND PROCEDURES

     a)      All permit required confined spaces will be identified by [supervisors, department heads,
             safety manager]. Exposed employees will be informed of such spaces through posting with
             warning signs or other equally effective means, such as facility maps or training [employer
             should specify which procedure is used in this program].




                                                            6
Chemtron Corporation
      35850 Schneider Court Avon,                Permit Required Confined Space Entry
      Ohio 44011
      Phone: 800-676-5091                                  29 CFR 1910.146
      Fax: 440-937-1038
             Category:       Job Site        Established:                   Revised:   May 20, 2005
                         Health and Safety
          Procedure #:        CC 19                  By:                        By:    J. Erclauz


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

     c)      No employee shall enter a permit space without having a properly completed entry permit
             signed by an entry supervisor.

     d)      Entry permit procedures are as outlined below:

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

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

          iii)    Complete all items on the permit.

          iv)     The entry will be authorized and the permit will be signed only by an authorized entry
                  supervisor. If any item on the permit is checked as "NO" (meaning not yet completed or
                  available), the permit will not be signed.

           v)     Entry may proceed. A copy of the entry permit will be placed outside the confined
                  space until the permit has been cancelled by appropriate personnel.

6)    TESTING AND MONITORING

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

     b)      Test or monitor the permit space continually to determine if acceptable entry conditions are
             being maintained during the course of entry operations.




                                                            7
Chemtron Corporation
      35850 Schneider Court Avon,                Permit Required Confined Space Entry
      Ohio 44011
      Phone: 800-676-5091                                  29 CFR 1910.146
      Fax: 440-937-1038
             Category:       Job Site        Established:                    Revised:   May 20, 2005
                         Health and Safety
          Procedure #:        CC 19                  By:                         By:    J. Erclauz




     c)      When testing for atmospheric hazards, test first for oxygen, then for combustible gases and
             vapors, and then for toxic gases and vapors. Parameters for non-hazardous atmospheres
             are:

           i)     Oxygen between 19.5 and 23.5 percent;

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

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

     d)      An authorized attendant must be present and monitoring the entry at all times. The
             attendant will not be assigned any other duties that may interfere with his attendant duties.
             Attendant duties are outlined below.

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

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

7)    RESCUE AND EMERGENCY SERVICES

     a)      Non-entry rescue is the preferred method for rescue of personnel from a permit required
             space. Employees will not enter a permit space for rescue unless they have been
             specifically trained and equipped for such rescue.

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




                                                            8
Chemtron Corporation
 35850 Schneider Court Avon,                Permit Required Confined Space Entry
 Ohio 44011
 Phone: 800-676-5091                                  29 CFR 1910.146
 Fax: 440-937-1038
        Category:       Job Site        Established:                       Revised:   May 20, 2005
                    Health and Safety
     Procedure #:        CC 19                  By:                            By:    J. Erclauz


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

      i)     Each entrant shall use a chest or full body harness, with a retrieval line attached at the
             center of the back near shoulder level, or other appropriate point.

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

     iii)    If injured entrant is exposed to any substance with a required MSDS or similar
             document, that MSDS or document will be made available to the medical facility
             treating entrant.

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

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

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

     iii)    Monitor the situation and be ready to give rescuers information on how many victims
             and they’re status, what hazards, chemical types, concentrations, etc. are present.

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

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

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

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




                                                       9
Chemtron Corporation
      35850 Schneider Court Avon,                   Permit Required Confined Space Entry
      Ohio 44011
      Phone: 800-676-5091                                     29 CFR 1910.146
      Fax: 440-937-1038
             Category:          Job Site        Established:                    Revised:   May 20, 2005
                            Health and Safety
          Procedure #:           CC 19                  By:                         By:    J. Erclauz


                   entrants;

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

     f)      Permits will be cancelled by the entry supervisor upon completion of the work, or when any
             prohibited condition arises. Permits cannot just be let to expire. Cancelled permits must be
             kept for the annual review.

8)    PROGRAM REVIEW

     a)      Cancelled entry permits will be retained on file for at least one year. The Permit Space
             Program will be reviewed within one year of each entry using these cancelled permits to
             revise the program as necessary to ensure employees are protected from permit space
             hazards. A single review covering all entries in the preceding year may be conducted.

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

     a)      Entrant

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

          ii)      Properly use equipment as required;

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

          iv)      Alert the attendant whenever the entrant recognizes any warning sign or symptom of
                   exposure to a dangerous situation, or detects a prohibited condition.

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

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




                                                               10
Chemtron Corporation
 35850 Schneider Court Avon,                    Permit Required Confined Space Entry
 Ohio 44011
 Phone: 800-676-5091                                      29 CFR 1910.146
 Fax: 440-937-1038
        Category:           Job Site        Established:                   Revised:   May 20, 2005
                        Health and Safety
      Procedure #:           CC 19                  By:                        By:    J. Erclauz


                     evacuation alarm is activated.

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

b)       Attendant

       i)     Know the hazards that may be faced during entry, including the mode, signs or
              symptoms, and consequences of the exposure.

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

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

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

      v)      Communicate with entrants as necessary to monitor entrant status and to alert entrants
              of the need to evacuate.

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

     vii)     Summon rescue and emergency services when assistance for emergency exit from
              permit space is necessary.

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

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

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




                                                           11
Chemtron Corporation
       35850 Schneider Court Avon,                   Permit Required Confined Space Entry
       Ohio 44011
       Phone: 800-676-5091                                     29 CFR 1910.146
       Fax: 440-937-1038
              Category:          Job Site        Established:                   Revised:   May 20, 2005
                             Health and Safety
           Procedure #:           CC 19                  By:                        By:    J. Erclauz


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

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

      c)      Entry Supervisor

            i)      Know the hazards that may be faced during entry, including the mode, signs or
                    symptoms, and consequences of the exposure.

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

           iii)     Terminate the entry and cancel the permit when entry operations are complete or a
                    prohibited condition arises.

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

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

           vi)      Determine, whenever responsible and at appropriate intervals, that acceptable entry
                    conditions are maintained.

10)    TRAINING

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

      b)      Training must be completed before employee is assigned duties under this program, before
              there is a change in assigned duties and, whenever a supervisor has reason to believe either
              that there are deviations from permit space entry procedures or inadequacies in the




                                                                12
Chemtron Corporation
       35850 Schneider Court Avon,                Permit Required Confined Space Entry
       Ohio 44011
       Phone: 800-676-5091                                  29 CFR 1910.146
       Fax: 440-937-1038
              Category:       Job Site        Established:                     Revised:   May 20, 2005
                          Health and Safety
           Procedure #:        CC 19                  By:                          By:    J. Erclauz


              employee's knowledge or use of this program.

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

11)    ALTERNATE ENTRY PROCEDURES

      a)      Alternate entry procedures may only be used when the only hazard is an actual or potential
              hazardous atmosphere. If alternate entry procedures are used, no permits are needed, no
              attendant or supervisor is required, and rescue provisions need not be used. Training and a
              written certification are required.

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

            i)     The only hazard posed by permit space is an actual or potential hazardous atmosphere.
                   (See Note after the Permit Space Reclassification section.)

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

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

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

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

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

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




                                                             13
Chemtron Corporation
35850 Schneider Court Avon,                Permit Required Confined Space Entry
Ohio 44011
Phone: 800-676-5091                                  29 CFR 1910.146
Fax: 440-937-1038
   Category:           Job Site        Established:                     Revised:   May 20, 2005
                   Health and Safety
 Procedure #:           CC 19                  By:                          By:    J. Erclauz


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

       (1)      Oxygen content: 19.5 - 23.5%

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

       (3)      Potential toxic air contaminants: < PEL

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

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

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

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

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

       (4)      Atmosphere within space shall be periodically tested as necessary to ensure that
                ventilation is adequate. If hazardous atmosphere is detected during entry:

             (a)   Each employee shall leave space immediately;

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

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

             (d)   The entry supervisor will verify that the space is safe for entry and that all of the
                   above requirements have been met. Such verification will be in writing to
                   include the date, location of the space, and the signature of the person providing




                                                      14
Chemtron Corporation
       35850 Schneider Court Avon,                Permit Required Confined Space Entry
       Ohio 44011
       Phone: 800-676-5091                                  29 CFR 1910.146
       Fax: 440-937-1038
             Category:        Job Site        Established:                    Revised:   May 20, 2005
                          Health and Safety
           Procedure #:        CC 19                  By:                         By:    J. Erclauz


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

12)    PERMIT SPACE RECLASSIFICATION

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

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

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

      b)      If entry is required to eliminate hazards, it shall be according to regulations and the space
              may be reclassified for as long as the hazards remain eliminated.

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

      d)      If hazards arise in declassified permit space, employee(s) shall exit and the employer shall
              determine whether to reclassify space.

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

13)    WRITTEN PERMIT

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




                                                             15
Chemtron Corporation
35850 Schneider Court Avon,              Permit Required Confined Space Entry
Ohio 44011
Phone: 800-676-5091                                29 CFR 1910.146
Fax: 440-937-1038
    Category:        Job Site        Established:                    Revised:   May 20, 2005
                 Health and Safety
  Procedure #:        CC 19                  By:                         By:    J. Erclauz


     standardized format for each entry.

   i)    The permit space to be entered.

  ii)    The purpose of the entry.

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

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

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

 vi)     The individual, by name currently serving as entry supervisor, with space for
         signature or initials.

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

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

 ix)     The acceptable entry conditions.

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

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

xii)     The communications procedures used by authorized entrants and attendants to maintain
         contact during the entry.

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




                                                    16
Chemtron Corporation
35850 Schneider Court Avon,             Permit Required Confined Space Entry
Ohio 44011
Phone: 800-676-5091                               29 CFR 1910.146
Fax: 440-937-1038
   Category:        Job Site        Established:                 Revised:   May 20, 2005
                Health and Safety
 Procedure #:        CC 19                  By:                      By:    J. Erclauz


        section.

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




                                                   17
Chemtron Corporation
                                       Confined Space Entry Permit
Good on this date only:____________ From:_________ a.m. p.m.           To: ___________ a.m. p.m.

Location:_________________________________________________ Job Number:__________________
Authorized Entrants           Attendants/Monitors          Site Supervisor
______________________        ______________________       ________________________

______________________                  ______________________          ________________________

Description of Job or Special Procedures:_____________________________________________________

______________________________________________________________________________________

Employee Training Pre-Entry Briefing

    1. Safe entry and rescue training conducted on (Date) _____________________________________
    2. Mandatory Pre-entry briefing conducted on (Date) _____________________________________
    3. Does the job require special training?                  YES        NO
Contractor Notification
Contractor notified of: PERMIT CONDITIONS________ POTENTIAL HAZARDS________ N/A____
Lighting Requirements                  Special Tools/Equipment     Communication Data
____________________                   ______________________      ___________________
____________________                   ______________________      ___________________
1. Are all electrical devices intrinsically safe?              YES        NO
2. Have all power cords and tools been visually inspected?     YES        NO

Vessel Preparation
1. Work area isolated with signs/barriers?                     YES               NO
2. All energy sources Locked/Tagged Out?                       YES               NO
3. All input lines Capped/Blinded?                             YES               NO
4. Vessel contents drained/flushed/neutralized?                YES               NO
5. Vessel cleaned and purged?                                  YES               NO
6. Ventilation provided 30 minutes before entry?               YES               NO

Pre-Entry Atmosphere Testing                Reading               Time                    Initials
1. Test for oxygen content:                 _________% oxygen     __________              ___________
2. Test for flammable concentration:        _________% LEL        __________              ___________
3. Test for toxic concentration:            _________ppm of (TLV=) __________             ___________
4. Test for heat stress hazard: ________F ________C _______WBGT ___________               ___________

Emergency / Rescue Procedures
1. Location of written Emergency/Rescue Plan: _____________________________________________
2. Type of Emergency / Rescue Team required: On-Site____ Off-Site____ Phone #___________________

Safety Equipment
Personnel Protective Equipment required:                       Area Safety Equipment Required:
_________________________________                              ____________________________________
_________________________________                              ____________________________________
1. Self Contained Breathing Apparatus required?                YES              NO     TYPE_________
2. Portable atmosphere monitor required?                       YES              NO     TYPE_________

Permit Authorization
I certify that I have inspected the work area for safety and reviewed all safety precautions recorded on the
permit.
(Signature) Chemtron Entrant Supervisor________________________________ Date_____________



Chemtron Corporation 35850 Schneider Court Avon, Ohio 44011
Attachment F
Hot Work Permit




    Page 20 of 23
Attachment G
MSDS Information




    Page 21 of 23
Attachment H
Project Prints and Drawings




         Page 22 of 23
List Of Onsite Chemicals

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




                                Page 23 of 23
APPENDIX D
Waste Summary




Short-Term IM Work Plan
Waste Summary for Koppers Plant Gainesville, FL

        The following is list of chemicals and quantities found at the Koppers plant in
Gainesville, Florida. All mentioned waste has been containerized and labeled for proper
shipment and disposal in accordance with federal and state EPA and DOT guidelines.
Waste classifications have been made by using MSDS sheets, field testing methods, and
product labeling. All waste will be verified upon receipt. All waste will be shipped to
the Chemtron Corporation TSDF located in Avon, Ohio. It is anticipated that all of this
waste will be shipped in the next several weeks following the demolition of on site
structures.

Chemicals

Various Non RCRA oils and greases- 4 drums
Flammable liquids loosepack (paints, thinners, solvent wash) – 4 drums
Light Ballasts for fluorescent bulbs – 2 drums
Ammonium Hydroxide lab pack (6x500mL bottles) – one 5 gallon pail
Lead acid Batteries Universal Waste – 1
Non PCB transformers with oil – 6
Alkaline Batteries – one 5 gallon pail
Mercury switches Universal Waste – one 5 gallon pail
Calcium hydroxide solid – one 5 gallon pail
NiCad Batteries Universal Waste – one 5 gallon pail
Florescent light bulbs Universal Waste – 4 light bulb tubes ( approximately 40 per tube)
HID light bulbs Universal Waste – 1 drum
Epoxy resin – one 5 gallon pail
Amine hardener – one 5 gallon pail
Caustic boiler reagents- one drum

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Short termim workplan_20100602_part3

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  • 103. APPENDIX C Demolition Permit Applications and Plans Short-Term IM Work Plan
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  • 111. Work Plan Summary Demolition of Buildings Former Koppers Facility Gainesville, Florida Chemtron Corporation has been contracted to demolish buildings and structures at the former Koppers site in Gainesville, Florida, there are approximately 8 buildings and 2 tanks that will be demolished. See Attachment H of this plan for drawings of specific buildings. This project is anticipated to last for approximately 4 weeks. Working hours on site will be from 7 am to 5 pm Monday through Saturday. No concrete breaking operations will take place outside of 8 am to 4 pm Monday through Friday to mitigate noise disturbance to residents. During the project, the gate located at NW 23rd Street will be used as access for vehicles. This gate will remain locked at all times except when entering or exiting. All buildings are to be removed to ground level, including foundations, and no digging is to take place. First, Chemtron will mobilize to site and set up all necessary signs, barricades and equipment prior to the start of any work. A secondary decontamination area will be set up for the tanks. Spill prevention controls will be set up in work areas. Utilities will have disconnections completed and verified. At this point of the project, the city and DEP will be involved in the process of verification of disconnection of utilities and waste management practices. Next, heavy equipment such as excavators and bobcats will be used to remove the buildings and structures. All buildings are to be disassembled using a grapple attachment with an excavator and loaded into trucks for offsite disposal. The concrete and brick is to go to a recycling facility. All wood and debris is to be sent to a landfill as construction and demolition debris. All steel is to be sent to recycling as well. All material will be loaded into roll offs or dump trailers. All truck traffic on the site is to enter and exit at the gate located on NW 23rd Street. The tanks will be removed following the procedures set forth in Attachment C of this manual. All ancillary pipes connecting the boiler building to the process area are to be removed as well. The pipe track housing these pipes is to remain. Hand tools and an excavator will be used to accomplish this task. This site is located in a heavy residential and commercial area. Therefore, airborne dust is of a particular concern to neighboring areas while work is being performed. While on site, all vehicles and equipment must observe the best manageable practices of keeping dust to an absolute minimum. All roadways will be kept wet while work is being performed. Also, areas where heavy equipment is working will be kept wet at all times where the equipment is tracking and where the exhaust emanates from the equipment. A water truck is on site at all times and will be utilized for this purpose. There is no need for the containment of such water as these areas are currently exposed to rain and there are monitoring wells and waste water treatment on site. During concrete breaking and brick breaking activities, the surfaces shall be wetted to control dust emissions during the entire demolition process. No building is being dropped at one time with wrecking balls or the like and they are being dismantled with grapplers to avoid dust.
  • 112. All chemicals and environmental concerns have been removed from the buildings. All utilities have been disconnected from the buildings. There are some pieces of equipment which are to be decontaminated which will take place throughout the course of the project. Finally, following the conclusion of the remediation of buildings and tanks, the site will have continuing remediation. All disturbed areas as well as areas of bare ground will be seeded with grass to prevent wind erosion and maintain permanent dust control. A waste water treatment plant is to be maintained on site for many years to come. The property will remain locked and access will be restricted.
  • 113. Contractor Name: Chemtron Corporation Project Name: Demolition of buildings at former Koppers site Work Location: Former Koppers Plant 200 NW 23rd Ave. Gainesville, Florida Projected Job Start Date: 6/1/10 Time: 7:30 a.m. Projected Job Finish Date: 7/31/10 Time: 4:00 p.m.. PREPARED BY: Michael Perry COMPANY PREPARED BY: Chemtron Corporation Date: 5/22/10 Phone: 440.933.6348 Cell: 440.336-0262 DATE SUBMITTED: 5/24/10 Attachment A – Plan Acknowledgement Signature Page Attachment B – OSHA Logs Attachment C – Tank Removal Procedures Attachment D – Insurance Certificate and Workers Comp Attachment E – Confined space program and permit Attachment F – Hot Work Permit Attachment G – MSDS Information Attachment H – Drawings Page 1 of 23
  • 114. INTRODUCTION: The purpose of this HASP is to set forth, in an orderly and logical fashion, appropriate health and safety procedures to be followed during onsite demolition activities at the former Koppers Facility in Gainesville, Florida. During the performance of the task, this HASP identifies potential hazards which Chemtron Corporation personnel and any sub contractors may be exposed to. Chemtron Corporation personnel, and any sub contractors shall not participate in the performance of this task without having read this plan in its entirety. This plan has been developed to be as complete as possible; however, should conditions dictate revisions or additions to this plan, amendments shall be drafted, added, and distributed to all persons involved with this plan. This plan works in concert with the Chemtron Corporate “Safety and Health Plan”, OSHA standards CFR 1926, Environmental Protection Agency regulations, National Fire Protection Association Codes, and any other applicable city or state codes. It shall be the prime contractor’s responsibility to ensure that all of its subcontractors comply with the provisions set forth in this plan. STATEMENT OF COMPANY’S SAFETY GOALS AND OBJECTIVES: Chemtron Corporation has a commitment to sound EH&S management, which is also and expression of our concern for the physical health and safety of our employees, client employees and the well being of our environment. Chemtron Corporation intends to remain a responsible health and safety manager through compliance with all Federal, State, and Local health and safety regulations and requirements. DESCRIPTION OF WORK: Prior to the start of project, the site specific heath and safety plan (SSHP) will be reviewed in a group with all personnel involved on project. All personnel not involved in such meeting will review and sign the SSHP prior to entering site. Chemtron will mobilize to site and set up all necessary signs, barricades and equipment prior to the start of any work. There are 8 buildings and 2 tanks to be demolished and removed on this site. Heavy equipment such as excavators and bobcats will be used to remove such buildings and structures. All buildings are to be disassembled using a grapple attachment with an excavator and loaded into trucks for offsite disposal. The tanks will be removed following the procedures set forth in Attachment C of this manual. The site has a known source contamination of Arsenic and Chrome in low concentrations. Also, this site is located in a heavy residential and commercial area. Airborne dust is of a particular concern to neighboring areas while work is being performed. While on site, all vehicles and equipment must observe the best manageable practices of keeping dust to an absolute minimum. All roadways will be kept wet while work is being performed. Also, areas where heavy equipment is working will be kept wet at all times where the equipment is tracking and where the exhaust emanates from the equipment. A water truck is on site at all times and will be utilized for this purpose. There is no need for the containment of such water as these areas are currently exposed to rain and there are monitoring wells and waste water treatment on site. During concrete breaking and brick breaking activities, the surfaces shall be wetted first to control dust emissions. No building is being dropped at one time with wrecking balls or the like and they are being dismantled with grapplers to avoid dust. All chemicals and environmental concerns have been removed from the buildings. All utilities have been disconnected from the buildings. All buildings are to be removed to ground level and no digging is to take place. Page 2 of 23
  • 115. COMPANY’S SAFETY PERFORMANCE: Chemtron Corporation has provided similar scopes of service for NASA GRC, General Electric, and Beazer East Inc. Chemtron has provided demolition and excavation services as well as tank cleaning and confined space for the above mentioned companies as well as many others for over 25 years. See Attachment B EMPLOYEE AWARENESS OF SAFETY: In an effort to provide a safe and healthful working environment, Chemtron Corporation has implemented the following Health and Safety policies and procedures throughout our organization: • new hire safety indoctrinations • monthly safety committee meetings • safety meeting relevant to customer site-specific job safety requirements • job safety inspections • job site “tail gate” safety meetings • annual training on required 29 CFR 1910 General Industry Standards and 29 CFR 1926 Construction Standards • employee accident injury OSHA 300 Accident Injury Prevention Program • employee recognition for Continuous Safe Work Practices • Drug Awareness Program • 8 hour OSHA update • CPR and First Aid Responders Employees are trained and qualified to perform their work safely and are held accountable for intentional or negligent noncompliance. Each employee is empowered and expected to stop his or her own work or the work of co-workers if any person’s safety or the environment are at risk. The Construction Supervisor is expected to support and reinforce this expectation. Stopped work shall not resume until the hazard has been controlled and a review has been performed. In addition, all employees are encouraged to seek ways to enhance the effectiveness of the H&S Program. The Subcontractor Site Safety and Health Officer (SSHO) shall ensure that at the start of each work day, a tailgate safety briefing is performed that reviews the THAs (task hazard analysis) applicable to the daily activities, unique site conditions, hospital route, personal protective equipment (PPE), and stop work authority. The SSHO shall ensure that all site personnel involved attend the tailgate briefing and that they sign as having attended. If personnel do not attend the tailgate briefing, the SSHO shall approach the personnel when they arrive onsite, provide them with an individual tailgate briefing, and have them sign as attending. Project training shall include at least the following. The Construction Supervisor, and SSHO shall have current hazardous waste safety training (40 hour, 8 hour refresher within past 12 months), hazardous waste supervisor training, and sufficient experience to understand the potential hazards. All other field personnel shall have current hazardous waste safety training including 40 hour and current 8 hour refresher. The SSHO shall present a project kick-off safety briefing to cover this plan, physical hazards, hazardous contaminants and chemicals, required hazard controls, and emergency contacts and additional safety briefings as needed (at least once per week). At least one person onsite shall have current first aid and cardiopulmonary resuscitation (CPR) training. The SSHO shall maintain documentation of completed training onsite. Additional training may include, but not be limited to, Respiratory Protection and Hearing Conservation. Field personnel shall be enrolled in a medical surveillance program and have current hazardous waste medical clearance. Page 3 of 23
  • 116. SITE COMPLIANCE: This health and safety plan will be reviewed by all employees of Chemtron and its’ subcontractors on this project. A copy of the plan will be kept on site at all times during work operations to be accessible to all persons involved in and around the project. The site safety supervisor will conduct daily “tailgate” safety meetings to address work for the day and relate it specifically to the provisions of this plan. The site safety supervisor will monitor all daily on site operations and ensure the compliance of safety protocols set forth in this plan. Position & Responsibilities Name Cell Phone Project Manager ___Karl Guenther_____ __440.653.3438______ Field Superintendent ___ ____ _______ Safety Coordinator ___Mike Perry _ __440.336-0262_____ Technician_________________ ___ _______ ________ Technician_________________ ___ ____ _______ (additional names and numbers will be added as needed) Page 4 of 23
  • 117. POTENTIAL HAZARDS*: (Identify those hazards that relate to the work activity) – Heavy equipment work, high pressure water, crane work, confined space, hot work 1. Asbestos - A thorough asbestos survey has been conducted by Avanco and all asbestos has been abated from this site. 2. Barricading - Fencing and signs will be used around working areas to identify work zones; - Spotters will be used to keep area clear of non essential personnel and direct personnel in and out of work zone as needed and keep personnel clear from overhead work load; Spotters must wear safety vests to maintain visibility for operators and pedestrians; - Duration of work will be approximately 4 weeks; - Lane closure will not be required during this project. 3. Biological - Biological hazards are present for this project and include spiders, ticks, bees, wasps, mosquitoes, poison ivy, snakes, wildlife. - Wear work clothes; tape pant legs as necessary. - Use insect repellant as necessary; - Self inspection for ticks and other insects during the work day and at the end of the day; - Wash hands as necessary; - Personnel with severe life threatening allergies to stings should inform FM for assignment to areas free of the hazard. Page 5 of 23
  • 118. 4. Chemical/ Flammable Hazards - Gasoline for generators and power washer if used; a) To be stored on site in approved storage area in 5 gallon safety containers with vents and no more than 10 gallons on site. b) Spill controls to be kept on site including absorbent pads, boom, floor dry, 55 gallon drums, non sparking shovels, and brooms. c) Pads to be placed under point of transfer of liquids to contain any leaks - Diesel fuel for heavy equipment. a) A portable OSHA approved diesel tank will be stored on construction vehicles with approximately 100 gallons of fuel. b) Pads will be placed under fill points to prevent release from leaks. - Vehicles contain gasoline or diesel fuel, engine oil, hydraulic fluid, power steering fluid, brake fluid, and antifreeze (ethylene glycol). Other lubricants will be used during minor maintenance repairs. - Excavator also contains hydraulic fluid. - Calibration gases for air monitoring equipment and spray paint may also be used onsite. - All equipment will be turned off prior to filling. - All equipment will only be filled in the approved storage and refuel area. - Fire extinguishers will be available on excavation equipment and near fuel storage areas. - Equipment will be inspected on a daily basis prior to use. Repairs will be performed prior to use. - Indoor work will be conducted with electrical tools and equipment. - No wastes are to be generated from these chemicals as they are used as fuel products. - Level D PPE will be required including safety glasses and hard hat. No respiratory protection is required. - MSDS are located in Attachment G and shall be readily available at every work zone. - Personnel shall be informed of hazardous chemicals during pre-entry briefing and/or daily tailgate briefings. 5. Confined Space Entry (Permit Required) - Confined space entry will be required to clean tanks prior to demolition; - Chemtron Confined Space Entry Permit, shall be completed before any entry is performed; - See Attachment E for confined space procedures; - Level C PPE with full face respirators and HEPA/ Organic cartridges will be required for any entry; - Life lines and harnesses will be used for means of egress. 6. Crane/ Aerial - A crane will be used for the lowering of the tanks for cleaning; - A man lift will be used to remove lighting and insulation; - Harnesses and fall arrestors shall be worn on lifts; - Spotters and controlled working zones shall be heavily employed during crane operations; - Only licensed crane operator shall operate crane; - No crane work will be done where winds exceed 25 mph. Page 6 of 23
  • 119. 7. Demolition - 8 buildings and 2 tanks are to be demolished ( see attachment H); - Excavators and bobcats will be used to demolish buildings; - Concrete footers will be broken using and excavator with hammer hoe attachment; - Utility disconnects are to be verified by GRU, the city of Gainesville, and Chemtron Employees; - Single hearing protection consisting of 85 dBA in ear plugs or over ear muffs will be required during concrete breaking or cutting activities; - All demolition areas will be marked with tape and spotter controlled zones; - Level D PPE consisting of hard hat, safety glasses, steel toe boots, and DOT class 3 safety vests will be worn on site at all times except where higher levels of PPE are noted. 8. Discharging Down Sewers - No sewer discharge will be required on this project - Sewers will be protected with dyke materials to prevent any run off contamination; - All sewer inlets will be capped or cemented prior to building demolition. 9. Egress - All employees will be made aware of egress route for the specific area they are working. This topic and rally point will be addressed in daily safety meeting. 10. Excavations - Excavations will be required for the capping of utilities; - Excavations will not exceed 3 feet below surface. 11. Falls - A man lift will be used in the removal of lights and insulation; - Anyone working in the man lift is required to wear a harness and be securely attached to the lift with a fall arrest system. 12. General Maintenance Checkout - No new equipment will be installed on this project. 13. Hand Tools/ Power Tools - Hand tools will only be used in the manner which they were designed to be used. - GFCIs will be used on any and all electrically operated power tools; - When using pneumatic tools, 85 dBA hearing protection will be used at all times; - Level D PPE is a minimum requirement for hand tool use; however, higher levels of PPE will be required based on the job task. - Anticipated tools are hand shovels, power washer, vacuum, concrete saw, and low impact hand tools. Page 7 of 23
  • 120. 14. Hazardous Energy/ Lockout Tagout - Utilities are to be locked out by Chemtron and verified by City and GRU personnel; - If a utility is encountered that needs to be locked out which is not connected to one of the buildings scheduled for demolition, GRU, the City of Gainesville, and Chemtron personnel will meet to discuss necessary steps. 15. Hot Work - “Hot Work” is anticipated on this project; - Hot work may occur for minor equipment repairs or saw cut of rebar if found; - Propane/ Oxygen torches may also be used to cut; - A Chemtron Hot Work Permit will be completed prior to any work being performed (see Attachment I); - Fire watch will be maintained during all hot work and continue at least 30 minutes after last hot work has been performed. 16. Indoor Air Quality - No work will be performed in any occupied building; - Vehicles are not to park near any air inlet to a building; - Doors to any building being worked in must be left open during work to prevent any fume build up from equipment or tools; - No smoking or equipment exhaust will be permitted near an air inlet to a building. 17. Interruption of Safety Services - No safety services will be interrupted during this project; 18. Ladders - Ladders my be used to reach some lighting fixtures unable to be reached with man lift; - Fall protection must used on ladders when height exceeds 6 feet. 19. Laser Construction Activities - No laser activities will be conducted on this project. 20. Lead - No lead is present on this project. 21. Mercury - No Mercury is present on this project. 22. Noise - Single hearing protection will be required around heavy equipment operation; - Protection may either be 85 dBA plugs or over the ear muffs; - Hearing protection requirements have also been listed in specific job tasks. Page 8 of 23
  • 121. 23. Painting - No painting is anticipated for this project. However, marking spray paint may be used for surveying purposes during excavation. 24. Personal Protective Equipment (PPE) - Unless otherwise noted in specific tasks, Level D PPE is required throughout the project - Level D shall be considered no less than safety glasses, steel toe boots, safety vests, and hard hats - All other levels of PPE are specifically noted in each task and must be observed while that task is being performed. Consult Site Safety Supervisor prior to start of tasks to ensure proper level of PPE is being met. 25. Radiation - There is no radiation present on this project. 26. Respiratory Protection - Respiratory protection is encountered during specific tasks of this project; - Respiratory protection is indicated in the tasks where it is required; - All employees have yearly medical surveillance and fit testing. 27. Sanitation - A portable restroom will be kept on site for employees. 28. Scaffolding - No scaffolding will be used on this project. 29. Traffic Control - Traffic will be maintained as much as possible throughout the project; - No lane closure is anticipated for this project. 30. Utility Service Interruption - No utilities will be interrupted during this project with the exception of those being disconnected from the buildings being demolished. 31. Heat Stress - Employees are trained in signs and symptoms of heat stress. - Site safety supervisor is trained in recognition of signs as well as first aid measures and this topic will be addressed in daily safety meeting. - If temperature is above 70°F or below 40°F, administrative controls will be implemented (cooled or warmed drinks, routine breaks in heated or shaded area, and provisions for emergency heating or cooling within 5 minutes travel time). - Avoid caffeinated beverages during warm weather work. Site supervisor shall make sure all employees have access to cool beverages. Page 9 of 23
  • 122. 32. Lifting - If equipment is to be moved, an evaluation of potential pinch points and/or weight strain will be conducted. - Clear area of all unnecessary equipment and slip/trip hazards. - Additional help will be obtained by workers or mechanical assistance used on-site if equipment to be moved is unwieldy, has a weight >50 lbs or has to be moved by maneuvering through awkward positioning. 33. Weather - In the event of lighting, work shall immediately stop. Work shall not resume until 30 minutes after the last lightning strike. - Seek shelter in the event of storms. - Excavations shall not be left uncovered in rain so work shall be planned accordingly taking weather into account and allowing enough time for site to be covered in the event of approaching weather. 34. Dust Control - No visible air emissions will be allowed during demolition process; - Building materials will be kept wet during demolition as needed to prevent any visible emissions; - All roadways shall be kept wet during working times. Page 10 of 23
  • 123. EMERGENCY PROCEDURES AND EQUIPMENT The Chemtron Site Supervisor shall remain in charge of all personnel during any potential emergency activities. To minimize the potential for accidents and injuries, daily safety and health inspections will be conducted by the Construction Supervisor or Chemtron SSHO. After an emergency occurs, the Project Manager, Supervisor, and Chemtron SSHO, and field team will participate in a briefing to discuss the event, identify the causes, identify corrective measures, and evaluate the responses. A) EVACUATION The Chemtron SSHO or Supervisor will designate the evacuation routes along with the assembly area. All employees shall be familiar with the evacuation routes and assembly area. Development of an evacuation plan with rally point(s) and head count procedures will be addressed within the SSHP Addendum and Implementation. B) EMERGENCY EQUIPMENT Several items of emergency equipment will be maintained at the work site. The required emergency equipment may include: • 16-unit first aid kit with an eye wash station indoors or in weatherproof container, inspected weekly; • Fire extinguisher(s) (at least 20-B) • Spill kit suitable to handle small spills of decontamination fluids; • Pads, boom, floor dry; • Cell phone. Page 11 of 23
  • 124. Task Hazard Analysis: Building Demolition Koppers Gainesville 1. Project Title 2. Location: 3. Date: 5/23/10 Building Demolition Koppers Koppers plant Gainesville Florida Gainesville 4. Prime Contractor: Chemtron Corp. 5. Competent Person: Karl Guenther 6. Sub Contractors: Al’s Dozer Service 7. Emergency information: Dial 911 8. Work Activity 9. Hazard 10. Controls 11. PPE 12. Other Information Required Confined Space Lead dust Open Air Level D Full face work espirator Concrete Heavy Safe work zone defined by signs and Level D, Not to exceed 3 feet excavation equipment spotters single hearing protection Power washer Ricocheting Face shields on respirators Level C debris Site set up and Slips, trips, Identify slip or fall hazards and Level D demobilization falls, struck by remove if possible. If removal not vehicles possible, mark and identify hazards with signs or barricades. Assure proper clearance from road and use lane closure if necessary. Seek help to lift >50 lbs. or use mechanical lifting device. Crane operations Crush injuries, Spotters to control zones, asses Level D No person other than licensed Pinch points pinch points during rigging crane operator to operate crane Hot work Burns, fires Use fire watch, complete permit Level D Heavy Equipment Crush injuries Spotter control zones; Level D Hearing protection is required in work Zones must keep 50 foot radius from certain phases, see specific tasks equipment Concrete Saw Dust exposure, Safety guards must be in place on Level D with cutting if ricocheting tools single performed debris hearing protection Refueling Chemical spills, Spill containment materials, fire Level D equipment/ fuel fires extinguishers storage material handling/ Trailer hook up, Use spotter as needed Level D transfer vehicle accident Page 12 of 23
  • 125. PROJECT CONTACTS: (to be updated prior to start of project) Page 13 of 23
  • 126. Attachment A Plan Acknowledgement Sheet Page 14 of 23
  • 127. SAFETY PLAN ACKNOWLEDGMENT: I hereby acknowledge that I have read, understand and accept the conditions outlined in this Health and Safety Plan (HASP) and I agree to perform work on this task in accordance with this plan, safe work practices, and OSHA regulations. (List all subcontractors working on this activity) Al’s Dozer service Name Company Signature Date Page 15 of 23
  • 128. Attachment B OSHA Logs Page 16 of 23
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  • 133. Attachment C Tank Removal Proceedures Page 17 of 23
  • 134. Tank Demolition Procedures Revised 5/31/10 The following procedures are to be followed for the demolition of tanks at the Koppers plant in Gainesville, Florida. This purpose of this procedure set is to reduce any risk of contamination from occurring due to the process of demolition. These procedures do not address all personnel safety concerns involved with demolition work and shall not be used as substitute for Health and Safety procedures detailed in the site specific plan. The tanks are jacketed with a layer of aluminum sheeting which covers fiberglass insulation. The aluminum sheeting is to be rinsed inside the tank containment area. All water collected will be treated as Hazardous Waste and disposed of accordingly. Once rinsed, the aluminum sheeting will be sent for metal recycling. The fiberglass insulation will be containerized in roll offs and treated as Hazardous waste. Once the insulation layers are removed, the tanks can get moved for decontamination and demolition. There is to be an area set up directly to the east side of the containment zone for this procedure. The area will consist of a 50 foot by 100 foot square area of triple layered 6 mil poly sheeting. The perimeter edges of the sheeting will be set on containment booms to raise them from ground level and create a pool effect whereas negating water from leaving the sheeted area or running into it from ground sources. The area shall be weighted with sand or similar material on the interior perimeter to sufficiently enough to prevent winds from blowing containment around. Wooden 4x4 posts are to be wrapped in plastic and placed on the containment to support the tanks. The post placement shall be sufficient such that no part of the tank touches the containment. Once this containment is set in place, the tanks will be moved by crane one by one to be decontaminated and demolished. Prior to moving, the man doors on the tanks shall be secured to prevent any material from dropping during the move. The tanks will be set in the containment in a horizontal position with the door of the tank facing the center of the containment. The tanks will be blocked in place to prevent any rolling. Tanks should be placed in accordance with diagram. Following the tanks being set into containment, they will be cleaned. A confined space crew will enter the tanks and use hand tools and power washers to remove residual contamination from the interior of the tanks. The waste will be collected with a vacuum truck. Any accumulation of waste on the outside of the tanks in the containment area is to be collected as it accumulates with the vacuum truck. All waste collected will be containerized and sent to Chemtron’s TSDF for disposal. Once the tanks have been cleaned, they can be visually inspected for decontamination. After decontamination has been verified, a shear on an excavator will be used to cut the tanks into small enough pieces to fit into a roll off. All scrap metal will be sent for recycling. Once the tanks are gone, the containment will be removed and sent appropriately for disposal. All of the containment area will be treated as hazardous waste. Any holes in the containment are to be spray painted before the containment is removed. Once the containment area is removed from the ground, any area that are painted, saturated, or discolored are to be dug up. Any soils removed are to be treated as hazardous waste.
  • 135. Attachment D Insurance Certificate and Workers Comp Page 18 of 23
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  • 138. Attachment E Confined Space Procedure and Permit Page 19 of 23
  • 139. Chemtron Corporation 35850 Schneider Court Avon, Permit Required Confined Space Entry Ohio 44011 Phone: 800-676-5091 29 CFR 1910.146 Fax: 440-937-1038 Category: Job Site Established: Revised: May 20, 2005 Health and Safety Procedure #: CC 19 By: By: J. Erclauz Chemtron Corporation 35850 Schneider Court Avon, Ohio 44011 (440) 937-6348 CONFINED SPACE ENTRY PROGRAM Compliant With: OSHA General Industry Regulations 29 CFR 1910.146 Chemtron Corporation 35850 Schneider Court, Avon, Ohio 44011
  • 140. Chemtron Corporation 35850 Schneider Court Avon, Permit Required Confined Space Entry Ohio 44011 Phone: 800-676-5091 29 CFR 1910.146 Fax: 440-937-1038 Category: Job Site Established: Revised: May 20, 2005 Health and Safety Procedure #: CC 19 By: By: J. Erclauz ACKNOWLEDGEMENTS The information contained in this document is not to be considered a substitute for any provision of the standard. This document shall be used in conjunction with all applicable rules and regulations. Chemtron Corporation 35850 Schneider Court, Avon, Ohio 44011
  • 141. Chemtron Corporation 35850 Schneider Court Avon, Permit Required Confined Space Entry Ohio 44011 Phone: 800-676-5091 29 CFR 1910.146 Fax: 440-937-1038 Category: Job Site Established: Revised: May 20, 2005 Health and Safety Procedure #: CC 19 By: By: J. Erclauz 1) PURPOSE a) Chemtron Corp. and its associated work places have confined spaces that due to various chemical and physical properties may cause death or serious injury to employees who may enter them. This Confined Space Entry Program is developed and established to identify, evaluate, and control such spaces, and more important, to detail procedures and responsibilities for entering and working within confined spaces. b) Adherence to the policies and directives contained in this program is mandatory for all supervisors and employees of this company. Supervisors and employees failing to follow this program are subject to disciplinary action and/or dismissal. 2) DEFINITIONS a) Confined Space - A space that: i) Is large enough and so configured that an employee can bodily enter and perform assigned work; and ii) Has limited or restricted means for entry or exit; and iii) Is not designed for continuous employee occupancy. b) Permit Required Confined Space - A confined space that: i) Contains or has a potential to contain a hazardous atmosphere; or ii) Contains a material that has the potential for engulfing an entrant; or iii) Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross section; or 2
  • 142. Chemtron Corporation 35850 Schneider Court Avon, Permit Required Confined Space Entry Ohio 44011 Phone: 800-676-5091 29 CFR 1910.146 Fax: 440-937-1038 Category: Job Site Established: Revised: May 20, 2005 Health and Safety Procedure #: CC 19 By: By: J. Erclauz iv) Contains any other recognized serious safety or health hazard. c) Acceptable Entry Conditions - The conditions that must exist in a permit space to allow entry and to ensure employees can safely enter into and safely work within a permit required confined space. d) Entry - The action by which a person passes through an opening into a permit required confined space. Entry is considered to occur as soon as any part of the entrant's body breaks the plane of an opening into the space. NOTE: For entry to occur, there must be intent to bodily enter the confined space. You may reach into a space, and not bodily enter (say to adjust a valve), and do so without an entry permit being required. e) Entry Permit - The written or printed document provided by this company to allow and control entry into a permit space. f) Entry Supervisor - The person responsible for determining if acceptable entry conditions are present at a permit space where entry is planned, for authorizing entry and overseeing entry operations, and for terminating entry. g) Hazardous Atmosphere - An atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue, injury, or acute illness from one or more of the following conditions: i) Flammable gas, vapor, or mist in excess of 10 percent of its lower flammable limit (LFL); ii) Airborne combustible dust at a concentration that meets or exceed its LFL. (this may be approximated as a condition in which the dust obscures vision at a distance of 5 feet or less); iii) Atmospheric oxygen concentration below 19.5 percent or above 23.5 percent; iv) Atmospheric concentration of any substance for which a dose of permissible limit is published (in Subpart G Occupational Health and Environmental Control; or Subpart Z 3
  • 143. Chemtron Corporation 35850 Schneider Court Avon, Permit Required Confined Space Entry Ohio 44011 Phone: 800-676-5091 29 CFR 1910.146 Fax: 440-937-1038 Category: Job Site Established: Revised: May 20, 2005 Health and Safety Procedure #: CC 19 By: By: J. Erclauz Hazardous and Toxic Substances); or v) Any other atmospheric condition that is immediately dangerous to life or health. h) Non-Permit Confined Space - A confined space that does not contain, or with the respect to atmospheric hazards, have the potential to contain any hazard capable of causing death or serious physical harm. i) Prohibited Condition - Any condition in a permit space that is not allowed by the permit during the time when entry is authorized. j) Testing - The process by which the hazards are identified and evaluated. Testing includes specifying the tests that are to be performed in the permit space. 3) CONFINED SPACE LOCATIONS a) Workplaces within this company have been surveyed to identify any confined spaces that may be present. Such locations are listed below. i) Non-Permit: The following locations have been identified as non-permit confined spaces, and may be entered and worked in using normal work procedures: (1) (No locations currently exist). ii) Permit-Required: The following locations have been identified as permit required confined spaces, and may be entered ONLY by following the entry permit procedures established in this program: (1) (All tanks at Chemtron Corp. are Permit-Required Confined Spaces). iii) Alternate Entry: The following permit required confined spaces may be entered by following the Alternate Entry Procedures: 4
  • 144. Chemtron Corporation 35850 Schneider Court Avon, Permit Required Confined Space Entry Ohio 44011 Phone: 800-676-5091 29 CFR 1910.146 Fax: 440-937-1038 Category: Job Site Established: Revised: May 20, 2005 Health and Safety Procedure #: CC 19 By: By: J. Erclauz (1) (All tanks at Chemtron Corp. may qualify after initial assessment). iv) Reclassify: The following permit required confined spaces may be reclassified and entered as a non-permit space ONLY after their hazards have been eliminated following prescribed procedures: (1) (No locations currently exist). 4) RESPONSIBILITIES a) Chemtron Corp: i) Will evaluate the work place and identify permit required confined spaces. ii) Inform exposed employees of the existence, location of, and the danger posed by the permit space by posting danger signs or by any other equally effective means. iii) Determine if employees will or will not enter permit required space. If not, take effective measures to prevent employees from entering the permit spaces. iv) Provide and document training for entrants, attendants, entry supervisors, and (if used) in-house rescue personnel. v) Protect entrants from all external hazards. vi) Designate the appropriate supervisor(s) as entry supervisor(s). vii) Provide all specified equipment required for entry in a permit required confined space as outlined in this and OSHA 1910.146 at no cost to the employees, maintain that equipment properly, and ensure that employees use that equipment properly. b) When acting as host employer for a contractor performing permit space entry work, Chemtron Corp. shall, 5
  • 145. Chemtron Corporation 35850 Schneider Court Avon, Permit Required Confined Space Entry Ohio 44011 Phone: 800-676-5091 29 CFR 1910.146 Fax: 440-937-1038 Category: Job Site Established: Revised: May 20, 2005 Health and Safety Procedure #: CC 19 By: By: J. Erclauz i) Inform contractor of permit space entry program; ii) Apprise contractor of hazards of particular permit spaces and precautions and procedures implemented for protection of employees in or near permit spaces; iii) Coordinate entry operations with contractor when both will be working in or near permit spaces and debrief contractor after entries. iv) Obtain information from contractor of permit program to be followed and coordinate multiple entry operations. v) Debrief contractors of the hazards encountered or created. vi) If necessary, reclassify a non-permit confined space as a permit space when there are changes in use or configuration. c) Employees: i) Will not enter any permit required confined space unless specifically authorized by an entry supervisor and only in full accordance with this program and the OSHA standard. ii) Attend and complete any scheduled training required by his/her supervisor and this program. iii) When selected as an entrant, attendant, or entry supervisor, perform those duties as outlined in this program. 5) PERMIT REQUIRED CONFINED SPACE ENTRY PROGRAM AND PROCEDURES a) All permit required confined spaces will be identified by [supervisors, department heads, safety manager]. Exposed employees will be informed of such spaces through posting with warning signs or other equally effective means, such as facility maps or training [employer should specify which procedure is used in this program]. 6
  • 146. Chemtron Corporation 35850 Schneider Court Avon, Permit Required Confined Space Entry Ohio 44011 Phone: 800-676-5091 29 CFR 1910.146 Fax: 440-937-1038 Category: Job Site Established: Revised: May 20, 2005 Health and Safety Procedure #: CC 19 By: By: J. Erclauz b) Only trained and qualified employees will be authorized as permit space entrants, attendant, or entry supervisor. c) No employee shall enter a permit space without having a properly completed entry permit signed by an entry supervisor. d) Entry permit procedures are as outlined below: i) Entrants will obtain an entry permit from the Plant Manager prior to entry of the space. ii) The entrant will accomplish all pre-permit actions required for entering the space, such as atmospheric testing, hazard control/elimination actions, have all required equipment on hand, provide for attendant and rescue services, etc. iii) Complete all items on the permit. iv) The entry will be authorized and the permit will be signed only by an authorized entry supervisor. If any item on the permit is checked as "NO" (meaning not yet completed or available), the permit will not be signed. v) Entry may proceed. A copy of the entry permit will be placed outside the confined space until the permit has been cancelled by appropriate personnel. 6) TESTING AND MONITORING a) Test the space with the necessary, calibrated equipment, to determine if acceptable entry conditions exist before beginning entry operations. Initial testing of the atmosphere must be done from outside the confined space prior to any entry with all affected employees present. If isolation of the space is infeasible because the space is large or part of a continuous system (such as a sewer), entry conditions will be continuously monitored where entrants are working. b) Test or monitor the permit space continually to determine if acceptable entry conditions are being maintained during the course of entry operations. 7
  • 147. Chemtron Corporation 35850 Schneider Court Avon, Permit Required Confined Space Entry Ohio 44011 Phone: 800-676-5091 29 CFR 1910.146 Fax: 440-937-1038 Category: Job Site Established: Revised: May 20, 2005 Health and Safety Procedure #: CC 19 By: By: J. Erclauz c) When testing for atmospheric hazards, test first for oxygen, then for combustible gases and vapors, and then for toxic gases and vapors. Parameters for non-hazardous atmospheres are: i) Oxygen between 19.5 and 23.5 percent; ii) Flammability less than ten percent of the lower explosive limit (LEL). iii) Toxicity less than the permissible exposure limit (PEL). d) An authorized attendant must be present and monitoring the entry at all times. The attendant will not be assigned any other duties that may interfere with his attendant duties. Attendant duties are outlined below. e) Equipment required for permit required confined space entry includes that equipment required for testing and monitoring; ventilating; communications between the entrant and attendant, and for summoning rescue; personal protection; lighting; barriers/shields for openings; means of ingress and egress; and any other equipment necessary for safe entry and rescue. f) Re-evaluate the space and or re-test as requested by affected employees or contractors 7) RESCUE AND EMERGENCY SERVICES a) Non-entry rescue is the preferred method for rescue of personnel from a permit required space. Employees will not enter a permit space for rescue unless they have been specifically trained and equipped for such rescue. b) The attendant or designated employee responsible for rescue shall be immediately available at the confined space location in PPE that is equivalent or higher than the PPE of the entrants. That employee will also use a self contained breathing apuratice (SCBA) if non- entry rescue from an IDLH atmosphere is not feasible. 8
  • 148. Chemtron Corporation 35850 Schneider Court Avon, Permit Required Confined Space Entry Ohio 44011 Phone: 800-676-5091 29 CFR 1910.146 Fax: 440-937-1038 Category: Job Site Established: Revised: May 20, 2005 Health and Safety Procedure #: CC 19 By: By: J. Erclauz c) To facilitate non-entry rescue, retrieval systems or methods shall be used whenever an authorized entrant enter a permit space, unless the retrieval equipment would increase overall risk of entry or would not be of value to any rescue. Retrieval system requirements are: i) Each entrant shall use a chest or full body harness, with a retrieval line attached at the center of the back near shoulder level, or other appropriate point. ii) Other end of retrieval line shall be attached to a mechanical device or fixed point outside of permit space enabling immediate use. A mechanical device will be used to retrieve personnel from vertical type permit spaces more than five feet deep. iii) If injured entrant is exposed to any substance with a required MSDS or similar document, that MSDS or document will be made available to the medical facility treating entrant. d) If rescue should become necessary, the attendant will: i) Notify their supervisor, the supervisor will then call 911; ii) Attempt non-entry rescue procedures to the extent possible by the circumstances. iii) Monitor the situation and be ready to give rescuers information on how many victims and they’re status, what hazards, chemical types, concentrations, etc. are present. e) Only designated personnel will enter permit spaces for rescue purposes. Each designated rescue team member will be trained on: i) The specific site at which they are providing rescue services. ii) Use of personal protective and rescue equipment necessary for making the rescue from the permit space; iii) Performance of assigned rescue duties and also that training required of authorized 9
  • 149. Chemtron Corporation 35850 Schneider Court Avon, Permit Required Confined Space Entry Ohio 44011 Phone: 800-676-5091 29 CFR 1910.146 Fax: 440-937-1038 Category: Job Site Established: Revised: May 20, 2005 Health and Safety Procedure #: CC 19 By: By: J. Erclauz entrants; iv) Basic first-aid and cardiopulmonary resuscitation (CPR). At least one member of the rescue team will hold current certification in first aid and CPR. f) Permits will be cancelled by the entry supervisor upon completion of the work, or when any prohibited condition arises. Permits cannot just be let to expire. Cancelled permits must be kept for the annual review. 8) PROGRAM REVIEW a) Cancelled entry permits will be retained on file for at least one year. The Permit Space Program will be reviewed within one year of each entry using these cancelled permits to revise the program as necessary to ensure employees are protected from permit space hazards. A single review covering all entries in the preceding year may be conducted. 9) DUTIES OF THE ENTRANT, ATTENDANT, AND ENTRY SUPERVISOR a) Entrant i) Know the hazards that may be faced, including the mode, signs or symptoms, and consequences of the exposure; ii) Properly use equipment as required; iii) Communicate with the attendant as necessary to enable the attendant to monitor entrant status and to alert entrants of the need to evacuate the space. iv) Alert the attendant whenever the entrant recognizes any warning sign or symptom of exposure to a dangerous situation, or detects a prohibited condition. v) Exit from the permit space as quickly as possible whenever: (1) An order to evacuate is given by the attendant or the entry supervisor, or an 10
  • 150. Chemtron Corporation 35850 Schneider Court Avon, Permit Required Confined Space Entry Ohio 44011 Phone: 800-676-5091 29 CFR 1910.146 Fax: 440-937-1038 Category: Job Site Established: Revised: May 20, 2005 Health and Safety Procedure #: CC 19 By: By: J. Erclauz evacuation alarm is activated. (2) The entrant recognizes any warning sign or symptom of exposure to a dangerous situation, or detects a prohibited condition. b) Attendant i) Know the hazards that may be faced during entry, including the mode, signs or symptoms, and consequences of the exposure. ii) Is aware of possible behavioral affects of hazard exposure. iii) Continuously maintain an accurate count and identity of authorized entrants. iv) Remain outside the permit space during entry operations until relieved by another attendant v) Communicate with entrants as necessary to monitor entrant status and to alert entrants of the need to evacuate. vi) Monitor activities inside and outside space to determine if safe for entrants to remain in space and orders evacuation when necessary. vii) Summon rescue and emergency services when assistance for emergency exit from permit space is necessary. viii) Take the following actions when unauthorized persons approach or enter a permit space while entry is underway: (1) Warn them to stay away, or exit immediately if they have entered. (2) Inform the entrants and entry supervisor if unauthorized persons enter the permit space. 11
  • 151. Chemtron Corporation 35850 Schneider Court Avon, Permit Required Confined Space Entry Ohio 44011 Phone: 800-676-5091 29 CFR 1910.146 Fax: 440-937-1038 Category: Job Site Established: Revised: May 20, 2005 Health and Safety Procedure #: CC 19 By: By: J. Erclauz (3) Perform non-entry rescues as specified by company procedure. (4) Perform no duties that might interfere with their primary duty to monitor and protect authorized entrants. c) Entry Supervisor i) Know the hazards that may be faced during entry, including the mode, signs or symptoms, and consequences of the exposure. ii) Verify that acceptable conditions for entry exist before endorsing the permit and allowing entry to begin. iii) Terminate the entry and cancel the permit when entry operations are complete or a prohibited condition arises. iv) Verify that rescue services are available and the means for summoning them are operable. v) Remove unauthorized individuals who enter or who attempt to enter the permit space. vi) Determine, whenever responsible and at appropriate intervals, that acceptable entry conditions are maintained. 10) TRAINING a) Only trained and qualified employees may be authorized as entrant, attendant, entry supervisor, or in-house rescue team members. The training will establish proficiency in the duties required by this program so that the employee acquires the understanding, knowledge, and skill necessary for the safe performance of his/her duties. b) Training must be completed before employee is assigned duties under this program, before there is a change in assigned duties and, whenever a supervisor has reason to believe either that there are deviations from permit space entry procedures or inadequacies in the 12
  • 152. Chemtron Corporation 35850 Schneider Court Avon, Permit Required Confined Space Entry Ohio 44011 Phone: 800-676-5091 29 CFR 1910.146 Fax: 440-937-1038 Category: Job Site Established: Revised: May 20, 2005 Health and Safety Procedure #: CC 19 By: By: J. Erclauz employee's knowledge or use of this program. c) Supervisors will certify that this training has been accomplished. The certification will contain the employee's name, signatures or initials of the trainers, and the dates of training. The certification will be kept on file. 11) ALTERNATE ENTRY PROCEDURES a) Alternate entry procedures may only be used when the only hazard is an actual or potential hazardous atmosphere. If alternate entry procedures are used, no permits are needed, no attendant or supervisor is required, and rescue provisions need not be used. Training and a written certification are required. b) Conditions To Be Met To Qualify For Alternate Procedures: i) The only hazard posed by permit space is an actual or potential hazardous atmosphere. (See Note after the Permit Space Reclassification section.) ii) Continuous forced air ventilation alone is sufficient to maintain safe permit space. iii) Monitoring and inspection data that supports above demonstrations have been developed and documented. iv) If initial entry is necessary to obtain above data, it shall be performed in accordance with this program. v) Documented determinations and supporting data will be made available to entrants. c) Entry must be in accordance with the following requirements: i) Any condition making it unsafe to remove an entrance cover shall be eliminated before removing the cover. When entrance covers are removed, the opening shall be promptly and effectively guarded. 13
  • 153. Chemtron Corporation 35850 Schneider Court Avon, Permit Required Confined Space Entry Ohio 44011 Phone: 800-676-5091 29 CFR 1910.146 Fax: 440-937-1038 Category: Job Site Established: Revised: May 20, 2005 Health and Safety Procedure #: CC 19 By: By: J. Erclauz ii) Before entry, the internal atmosphere shall be tested with a calibrated direct-reading instrument, for the following conditions in the order given: (1) Oxygen content: 19.5 - 23.5% (2) Flammable gases and vapors: <= 10% of LEL (3) Potential toxic air contaminants: < PEL iii) There may be no hazardous atmosphere within the space whenever any employee is inside the space. iv) Continuous forced air ventilation shall be used as follows: (1) Entry not permitted until hazardous atmosphere is eliminated. (2) Ventilation shall be directed to immediate areas where employees are or will be present and will continue until all employees have left the space; (3) Air supply shall be from a clean source and may not increase hazards in space. (4) Atmosphere within space shall be periodically tested as necessary to ensure that ventilation is adequate. If hazardous atmosphere is detected during entry: (a) Each employee shall leave space immediately; (b) Space shall be evaluated to determine how hazardous atmosphere developed; (c) Measures must be taken to protect employees from hazardous atmosphere before any subsequent entry. (d) The entry supervisor will verify that the space is safe for entry and that all of the above requirements have been met. Such verification will be in writing to include the date, location of the space, and the signature of the person providing 14
  • 154. Chemtron Corporation 35850 Schneider Court Avon, Permit Required Confined Space Entry Ohio 44011 Phone: 800-676-5091 29 CFR 1910.146 Fax: 440-937-1038 Category: Job Site Established: Revised: May 20, 2005 Health and Safety Procedure #: CC 19 By: By: J. Erclauz the certification, and shall be made available to each employee before entry. 12) PERMIT SPACE RECLASSIFICATION a) A permit space may be reclassified as a non-permit space: i) If there are no actual or potential atmospheric hazards and if all hazards within permit space are eliminated without entry, space may be reclassified for as long as the non- atmospheric hazards remain eliminated. ii) Hazards may be eliminated by such actions as purging or inerting tank/vessels of contaminants, emptying material from hoppers/bins, use of company lockout/tag procedures for electrical/ mechanical hazards. The control of atmospheric hazards through forced air ventilation does not constitute elimination of that hazard (it only controls the hazard: the preceding Alternate Entry Procedures must be used in such cases). b) If entry is required to eliminate hazards, it shall be according to regulations and the space may be reclassified for as long as the hazards remain eliminated. c) Entry supervisors will certify in writing that all hazards in permit space have been eliminated and make this document available to each entrant. d) If hazards arise in declassified permit space, employee(s) shall exit and the employer shall determine whether to reclassify space. NOTE: A combination of reclassification procedures and alternate entry procedures (e.g. using lockout/tagout to eliminate a physical hazard, then continuous forced air to control an atmospheric hazard) may not be used together. Situations as such must be entered under the permit program. 13) WRITTEN PERMIT a) The following information must be included in the written permit. The permit must be a 15
  • 155. Chemtron Corporation 35850 Schneider Court Avon, Permit Required Confined Space Entry Ohio 44011 Phone: 800-676-5091 29 CFR 1910.146 Fax: 440-937-1038 Category: Job Site Established: Revised: May 20, 2005 Health and Safety Procedure #: CC 19 By: By: J. Erclauz standardized format for each entry. i) The permit space to be entered. ii) The purpose of the entry. iii) The date and the authorized duration of the entry permit. iv) The authorized entrants within the permit space, by name or by such other means. v) The personnel, by name, currently serving as attendants. vi) The individual, by name currently serving as entry supervisor, with space for signature or initials. vii) The hazards of the permit space to be entered. viii) The measure used to isolate the permit space and to eliminate or control permit space hazards before entry. ix) The acceptable entry conditions. x) The results of initial and periodic tests, with the names or initials of the testers and when the tests were done. xi) The rescue and emergency services that can be summoned and the means for summoning them. xii) The communications procedures used by authorized entrants and attendants to maintain contact during the entry. xiii) Equipment (such as personal protective equipment, testing, communications alarm system, and rescue equipment) to be provided for compliance with this 16
  • 156. Chemtron Corporation 35850 Schneider Court Avon, Permit Required Confined Space Entry Ohio 44011 Phone: 800-676-5091 29 CFR 1910.146 Fax: 440-937-1038 Category: Job Site Established: Revised: May 20, 2005 Health and Safety Procedure #: CC 19 By: By: J. Erclauz section. xiv) Any other information whose inclusion is necessary in order to ensure employee safety. 17
  • 157. Chemtron Corporation Confined Space Entry Permit Good on this date only:____________ From:_________ a.m. p.m. To: ___________ a.m. p.m. Location:_________________________________________________ Job Number:__________________ Authorized Entrants Attendants/Monitors Site Supervisor ______________________ ______________________ ________________________ ______________________ ______________________ ________________________ Description of Job or Special Procedures:_____________________________________________________ ______________________________________________________________________________________ Employee Training Pre-Entry Briefing 1. Safe entry and rescue training conducted on (Date) _____________________________________ 2. Mandatory Pre-entry briefing conducted on (Date) _____________________________________ 3. Does the job require special training? YES NO Contractor Notification Contractor notified of: PERMIT CONDITIONS________ POTENTIAL HAZARDS________ N/A____ Lighting Requirements Special Tools/Equipment Communication Data ____________________ ______________________ ___________________ ____________________ ______________________ ___________________ 1. Are all electrical devices intrinsically safe? YES NO 2. Have all power cords and tools been visually inspected? YES NO Vessel Preparation 1. Work area isolated with signs/barriers? YES NO 2. All energy sources Locked/Tagged Out? YES NO 3. All input lines Capped/Blinded? YES NO 4. Vessel contents drained/flushed/neutralized? YES NO 5. Vessel cleaned and purged? YES NO 6. Ventilation provided 30 minutes before entry? YES NO Pre-Entry Atmosphere Testing Reading Time Initials 1. Test for oxygen content: _________% oxygen __________ ___________ 2. Test for flammable concentration: _________% LEL __________ ___________ 3. Test for toxic concentration: _________ppm of (TLV=) __________ ___________ 4. Test for heat stress hazard: ________F ________C _______WBGT ___________ ___________ Emergency / Rescue Procedures 1. Location of written Emergency/Rescue Plan: _____________________________________________ 2. Type of Emergency / Rescue Team required: On-Site____ Off-Site____ Phone #___________________ Safety Equipment Personnel Protective Equipment required: Area Safety Equipment Required: _________________________________ ____________________________________ _________________________________ ____________________________________ 1. Self Contained Breathing Apparatus required? YES NO TYPE_________ 2. Portable atmosphere monitor required? YES NO TYPE_________ Permit Authorization I certify that I have inspected the work area for safety and reviewed all safety precautions recorded on the permit. (Signature) Chemtron Entrant Supervisor________________________________ Date_____________ Chemtron Corporation 35850 Schneider Court Avon, Ohio 44011
  • 158. Attachment F Hot Work Permit Page 20 of 23
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  • 171. Attachment H Project Prints and Drawings Page 22 of 23
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  • 183. List Of Onsite Chemicals - Gasoline - Motor oil - Windshield washer fluid - Diesel fuel - Brake fluid - Hydraulic oil - Power steering fluid - Spray paint - Antifreeze Page 23 of 23
  • 185. Waste Summary for Koppers Plant Gainesville, FL The following is list of chemicals and quantities found at the Koppers plant in Gainesville, Florida. All mentioned waste has been containerized and labeled for proper shipment and disposal in accordance with federal and state EPA and DOT guidelines. Waste classifications have been made by using MSDS sheets, field testing methods, and product labeling. All waste will be verified upon receipt. All waste will be shipped to the Chemtron Corporation TSDF located in Avon, Ohio. It is anticipated that all of this waste will be shipped in the next several weeks following the demolition of on site structures. Chemicals Various Non RCRA oils and greases- 4 drums Flammable liquids loosepack (paints, thinners, solvent wash) – 4 drums Light Ballasts for fluorescent bulbs – 2 drums Ammonium Hydroxide lab pack (6x500mL bottles) – one 5 gallon pail Lead acid Batteries Universal Waste – 1 Non PCB transformers with oil – 6 Alkaline Batteries – one 5 gallon pail Mercury switches Universal Waste – one 5 gallon pail Calcium hydroxide solid – one 5 gallon pail NiCad Batteries Universal Waste – one 5 gallon pail Florescent light bulbs Universal Waste – 4 light bulb tubes ( approximately 40 per tube) HID light bulbs Universal Waste – 1 drum Epoxy resin – one 5 gallon pail Amine hardener – one 5 gallon pail Caustic boiler reagents- one drum