Environmental Restoration Program Oak Ridge National Laboratory Waste Area Grouping 13 Health and Safety Plan

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Environmental Restoration Program Oak Ridge National Laboratory Waste Area Grouping 13 Health d Safety Plan Oak Ridge Operations Lee Wan & Associates, Inc. 120 S. Jefferson Circle, Suite 100 Oak Ridge, Tennessee 37830

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LIST OF TABLES ................................................ LIST OF FIGURES ............................................... 1.1 PURPOSE AND SCOPE .................................. 1.3 ADHERENCE TO SAFETY REQUIREMENTS ................ 2. ORGANIZATION AND RESPONSIBILITIES ...................... 3. PROGRAM REQUIREMENTS 8................................. 83.1 PERSONNEL TRAINING .................................. 94.1 STANDARD OPERATING PROCEDURES ................... 124.5 RELEASE OF EQUIPMENT AND MATERIAL ................ 4.6 PERSONNEL RADIOLOGICAL DECONTAMINATION ......... 12 4.8 BREAKS AND LUNCH AREA. 15 4.1 1 SOIL SAMPLING WITH HAND AUGERS OR TROWELS ....... 20 Groundwater Sampling with Bailers ...................... 20 4.12.2 Surface Water Sampling ............................... 20 5. HAZARD CONTROL AND MONITORING ........................ 22 5.1 H&S MONITORING AND SAMPLING FREQUENCY ........... 22

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5.2 TOOLS AND EQUIPMENT ................................ 23 5.3 SAFETY PRECAUTIONS NEAR UTILITY LINES .............. 23 5.5 TRANSPORT OF CONTAMINATED MATERIAL .............. 23 6.1 GENERAL EMERGENCY ACTION PROCEDURES ............ 24 6.3 EMERGENCY TELEPHONE NUMBERS ..................... 25

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4.1 Recommended Maximum Contamination Guide €or Skin 4.2 Maximum Contamination Guide for Shoes and Clothing ................. 14 4.3 Levels of Personal Protective Equipment ............................ LIST OF FIGURES 1.1 Contaminated Enclosures at WAG 13 .............................. 4.1 WAG 13 Sampling Areas ....................................... Map from WAG 13 to Methodist Medical Center ......................6.1

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American Conference of Governmental Industrial Hygienists as low as reasonably achievable U.S. Department of Energy Martin Marietta Energy Systems Environmental Restoration Program health and safety lower explosive limit Oak Ridge National Laboratory Occupational Safety and Health Administration Permissible Exposure Limit personal protective equipment Radiation Emergency Assistance Centernraining Site Threshold Limit Value Waste Area Grouping

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This Health and Safety (H&S) Plan is designed to provide guidance for the safe conduct of the remedial investigation (RI) work activities performed at Waste Area Grouping (WAG) 13. As such, it is a site-specific plan that will guide the RI Contractors (RIG) in conducting their activities in a manner that protects worker H b S . It is designed to be used with the Environmental, Safety and Health Plan for the Oak Ridge National Laboratory 87/99053/3( O W 1987), which provides more general H&S guidance. Both plans will be followed by all individuals who enter the site as part of the implementation of the Environmental Restoration Program (ERP). The remainder of this section discusses the philosophy and regulatory requirements governing this H&S Plan and the hazards that have been identified at the site to date. The U.S. Department of Energy (DOE), ORNL, and the ERP contractors are committed to limiting chemical and radiation exposures to levels that are as low as reasonably achievable (ALARA), and this safety policy applies ALARA principles to all activities associated with the WAG 13 RI, including work performed by subcontractors. Personnel working on the WAG 13 project will be informed of known and potential hazards associated with the work to be performed so that they may effectively apply required safety precautions. Completion of the training course mandated by the Occupational Safety and Health Administration (OSHA)in accordance with 29 CFR 1910.120 is prerequisite for workers onMaintaining a safe and healthy work environment is the responsibility of DOE and the RIC. Through a comprehensive training program, the site workers shall be informed of hazard potentials, proper use of personal protective equipment (PPE), applicable procedural requirements, and their responsibilities for maintaining safe working environments. Once trained, personnel will be held accountable for adhering to all safety requirements. Because of potentially harmful impacts to workers and the environment that could result from failure to adhere to procedural requirements, environmental protection H&S violations shall not be tolerated. Personnel who develop a history of safety violations or who blatantly or willfully violate environmental protection H&S procedures shall be removed from

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The environmental, safety, and health protection requirements applicable to the WAG 13 project are set forth in DOE Orders and applicable federal, state, and local requirements and standards. Relevant DOE Orders and applicable standards and requirements that constitute the basis for the H&S Plan include the following: U.S. Environmental Protection Agency (EPA) 40 CFR 116, 117, 129, 162, and Threshold Limit Values (TLVs) and Biological Exposure Indices (for current year), American Conference of Governmental Industrial Hygienists (ACGIH) DOE 5400.3 - Hazardous and Radioactive Mixed Waste Program DOE 5480.1B - Environmental Protection, Safety, and Health Protection Program for DOE Operations DOE 5480.2A - Hazardous and Radioactive Mixed Waste Management DOE 5480.3 - Safety Requirements for the Packaging and Transportation of Hazardous Materials, Hazardous Substances, and Hazardous Wastes DOE 5480.4 - Environmental Protection, Safety, and Health Protection DOE 5480.10 - Contractor Industrial Hygiene Program DOE 5480.11 - Radiation Protection; the applicability of specific provisions is given in Appendix A DOE 5482.1A - Environmental, Safety, and Health Appraisal Program DOE 5483.1A - Occupational Safety and Health Program for GovernmentDOE 5484.1 - Environmental Protection, Safety, and Health Protection Information Reporting Requirements DOE 5484.2A - Unusual Occurrence Reporting System As a matter of policy, DOE and its contractors are committed to compliance with applicable OSHA regulations. The DOE and its contractors have generally adopted ACGIH

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from "LVs, the most stringent limit will be applied. Where 29 CFR 1910 does not specify for a particular chemical substance or physical agent, the TLVs will be used when available, followed by recommended exposure limits adopted by the National Institute for Occupational Safety and Health. The H&S Plan meets requirements set forth in 29 CFR 1910.120 and applicable regulatory requirements of the state of Tennessee. The packaging and shipment of samples to and from laboratory facilities over any public road shall be performed in accordance with U.S.Department of Transportation (DOT) regulations and with Tennessee Department of Transportation Regulations. Other regulations that may be applicable to safe operations include National Fire Protection Association codes and federal and local fire codes. The radiological hazards associated with the WAG 13 project include the potential for direct exposure to ionizing radiation internal exposure or by ingestion, inhalation, and entry through breaks in the skin of cesium (13'Cs), cobalt or strontium (%r) (ORNL 1988a). Exposure could occur within the radiation area and, to a limited extent, from surface drainages downgradient of the site. The presence of cesium is a result of Civil Defense research activities; the sources of cobalt and strontium are unknown. ALARA principles mandate that strict radiological controls be maintained and real-time radiological monitoring be conducted while work is proceeding. Gamma exposure rate measurements were taken at each of the four contaminated enclosures at WAG 13 in 1988 (ORNL 1988b). Each enclosure was measured at its southwest corner. Because surface radiation levels were highest at enclosure 4, measurements were also taken on the north side, the center, and 15 cm above the surface at the center. The resulting gamma exposure rates were as follows: exposure rate at 1 m

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Figure 1.1 illustrates the location of the contaminated enclosures and the gamma exposure rate measurements for each. These levels of gamma radiation are sufficiently high that the immediate area must be designated a "radiation area" and controlled as described in Section 4.3. A person working in or near Enclosure 4 for 1 hour could receive a dose of 15 to 30 mrem, roughly equal to the radiation received from a chest X-ray. Appropriate measures would be taken to limit exposures to the lowest possible level. Available documentation indicates that no chemicals were ever used or disposed of at WAG 13. Therefore, no exposure to chemicals in toxic amounts is anticipated. Physical hazards that may be encountered during the WAG 13 project include fire, equipment failure (electrical, mechanical, hydraulic, etc.), noise, heat (especially when wearing protective clothing during warm periods), cold, tripping, and slipping in wet areas. Noise from equipment operation can cause hearing impairment when exposures occur over long periods. Therefore, noise levels will be routinely evaluated. Hearing protection during drilling operations will be provided or equipment modifications implemented, as appropriate, to ensure that 8-hour time-weighted average noise levels remain below 85 decibels (dB) in Other possible physical hazards include hand and finger injuries from handling dangerous equipment, foot injuries from dropping heavy equipment on them, and head injuries from working around heavy equipment. To reduce the potential for injuries of this type, heavy work gloves should be worn when handling equipment that may cause cuts, abrasions, or pinch points. Safety-toed shoes will be required when handling heavy tools, samples, and other heavy objects, and hard hats will be required when working around heavy equipment such as drilling rigs. Small biting insects, poison ivy, and poison oak are likely to be present in the area. To protect against these, long-sleeved coveralls and gloves should be worn at all times. Workers should avoid touching their face or other exposed skin with gloves or protective clothing that has come into contact with poison ivy or hazardous materials. For protection against snakebites during warm weather, snake guards will be available. Sampling, well drilling, or other activities along the shore of the Clinch River pose a risk of drowning. For activities in close proximity to the river, personnel will use basic water safety equipment, such as personal flotation devices. If extensive activities near the river are necessary, emergency response equipment should be installed, including a tethered flotation ring and a rescue pole.

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2 ORGANIZATION AND RESPONSIBILITIES This section describes the project responsibilities and organization. Section 2.1 illustrates the relationships of the major organizations which are involved in R I activities, while Section 2.2 discusses the individual positions within each organization which are responsible for H&S activities during the WAG 13 project. Martin Marietta Energy Systems (Energy System) is responsible for activities associated with the WAG 13 RI and has awarded contracts to the RIC to manage and conduct the activities associated with the WAG 13 RI. Figure 2.1 illustrates the project organization. The members of the project team are responsible for coordinating the RI sampling or drilling activities and resolving any problems. The H&S Coordinator reports to, and receives direction from, the H&S Officer. There will be one H&S Coordinator for the WAG 13 site during RI activities. The H&S Coordinator will be responsible for documenting all H&S activities in an H&S log. This includes prescribing PPE and generating area surveys and respirable and nonrespirable particulate surveys for radiological contaminants. The H&S Coordinator will perform periodic real-time monitoring during sampling activities to assure that personnel protection is adequate. The H&S Coordinator will be responsible for controlling all aspects of H&S during RI activities and will have the authority to stop work for H&S concerns. If this authority is exercised, the H&S Coordinator will notify the H&S Officer or Project Manager, who, in turn, will notify the DOE representative. PPE requirements may be changed based on surveys and professional judgement. Occupational exposure monitoring for the WAG 13 RI activities will be conducted in accordance with the H&S project procedures and this H&S Plan. The medical surveillance requirements of field personnel will conform to 29 CFR 1910.120,as specified in the Master The bioassay program, as described in the Master H&S Plan, is used to document any intake of hazardous materials into the body. The results of this program will be used to determine the degree of adherence to the ALARA principles during the WAG 13 project.

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In accordance with 29 CFR 1910.120 and the Master H&S Plan, all personnel will be required to successfully complete a minimum of 40 hours of applicable training off-site prior to working at a Comprehensive Environmental Response, Compensation, and Liability Act or Resource Conservation and Recovery Act-listed hazardous waste site. Three days of onthe-job training are required €or workers, and an additional 8 hours of training are required Site-specific personnel training will also be required and will include, but not be limited to, the following: specific hazards and potential hazards which have been identified at the WAG emergency response for accident or injury, including notification procedures; location of emergency response equipment on-site; specific controls that may be used to prevent the spread of contamination to the environment from this site and contamination procedures; specific construction or sampling activities which may cause the greatest potential for hazardous exposure, such as digging or drilling on-site; and any additional site-specific safety concerns. All site workers will make an information copy of their records for the project files and transmit these to the H&S Officer 1week prior to field activities. These records include, but are not limited to, exposure records for radiation and hazardous materials, personnel and environmental monitoring, training, safety work permits, respirator fit testing results, and a physician’s statement of qualification. The examining physician will provide a statement of qualification, including the qualification to wear negative pressure respirators. The statement will be based on the results of a pulmonary function examination and any additional examination that is deemed appropriate by the examining physician.

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4.1 SI'ANDARD OP m TING PROCEDURES The following requirements are necessary to protect the H&S of field workers: The buddy system will be used. Hand signals Will be established and utilized. During site operations, each worker should consider himself as a safety backup to his partner. Off-site personnel only provide emergency assistance. All personnel should be aware of dangerous situations that may develop. Visual contact must be maintained between buddies on-site. Eating, drinking, chewing gum or tobacco, smoking, or any practice that increases the probability of hand-to-mouth transfer and ingestion of potentially contaminated material is prohibited in any area designated as contaminated. Prescription drugs should not be taken by personnel where the potential for contact with substances at toxic levels exists, unless specifically approved by a Alcoholic beverage intake is prohibited during the work day. Alcohol may be consumed in moderate amounts during off-work hours. Individuals wearing contact lenses will not be permitted on-site. Disposable clothing will be used whenever possible to minimize the risk of crossThe number of personnel and amount of equipment in any contaminated work area should be minimized, but effective site operations must be ensured. Work areas for various operational activities (for example, equipment testing or decontamination) will be established. Procedures for leaving any contaminated area will be planned and reviewed prior to entering these areas. Work areas and decontamination procedures will be established based on prevailing site conditions and will be subject to change. Wind direction indicators will be strategically located on-site. Contact with contaminated or potentially contaminated surfaces should be avoided. Whenever possible, do not walk through puddles, mud, or discolored

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ground surface. Individuals should not kneel, lean, or sit on the ground or place equipment on drums, containers, vehicles, or the ground. No personnel will be allowed to enter the site without the proper safety 0 Proper decontamination procedures will be followed before leaving the site, except in medical emergencies. 0 All personnel must comply with established safety procedures. Any staff member or visitor who does not comply with safety policy, as established by the Field Safety Coordinator, will be immediately dismissed from the site. 0 Any medical emergency supersedes routine safety requirements. 4 2 CONTROL OF SAMPLING AND DRILLING Control measures will be required during RI sampling and drilling activities to …