SAFETY--Water Resources Division National Pollutant Discharge Elimination System Safety Policy and Guidance
In Reply Refer To:
Mail Stop 405 Aug. 10, 1992
WATER RESOURCES DIVISION MEMORANDUM NO. 92.54
Subject: SAFETY--Water Resources Division National Pollutant
Discharge Elimination System Safety Policy and
Guidance
The Water Resources Division (WRD) has been contacted by more than 20
cities requesting our assistance in monitoring urban stormwater runoff.
The monitoring is required in order for the cities to obtain a National
Pollutant Discharge Elimination System (NPDES) Permit from the U.S.
Environmental Protection Agency. Additional cities and some military
installations are in the process of formalizing agreements with WRD
for NPDES-type monitoring work.
The attached WRD NPDES Safety Policy and Guidance has been developed
to assist in protecting the safety of all WRD personnel. The Protocol
will be effective as of the date of this memorandum. It is the
responsibility of managers and supervisors to ensure that the safety
procedure and guidance prescribed in this document are followed for
all NPDES and NPDES-type projects.
The document was prepared by the WRD Safety Subcommittee on NPDES.
The Subcommittee consists of G.J. Hwang, Joanne Kurklin, Carlos
Arozarena, and John Neil. If you have any questions regarding this
document and its implementation, please contact G.J. Hwang, the
Subcommittee Chairman and WRD Safety Officer, at (703) 648-5255.
William B. Mann IV
Attachment
Distribution: A,B,S,FO,PO
This memorandum does not supersede any previous WRD memorandum.
KEY WORDS: Hazardous Waste Sites, Safety
U.S. GEOLOGICAL SURVEY, WATER RESOURCES DIVISION,
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM--
SAFETY POLICY AND GUIDANCE
Prepared by
The Water Resources Division Safety Subcommittee
on Safety in NPDES Operations
Subcommittee Members
G.J. Hwang
Joanne K. Kurklin
Carlos E. Arozarena
John M. Neil
This Safety Policy and Guidance is for the administrative use of
Members of the Water Resources Division, U.S. Geological Survey.
It should not be quoted or cited as a publication.
U.S. GEOLOGICAL SURVEY, WATER RESOURCES DIVISION,
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM--
SAFETY POLICY AND GUIDANCE
CONTENTS
Page
CONTENTS 1
1. INTRODUCTION 5
A. General Statement 5
B. Legal and Regulatory Perspective 5
C. Responsibility 6
2. SAFETY PROGRAM PLANNING 6
A. Planning Requirements 6
B. Safety Organization 6
C. Safety Plan 6
3. MEDICAL SURVEILLANCE PROGRAM 7
A. Legal Requirements 7
B. Medical Program Elements 8
(1) Initial Consideration 8
(2) Initial Screening Test 8
(3) Initial Baseline Medical Examination 8
(4) Immunization Requirements 9
(5) First-Aid Provisions 9
(6) Periodic or Followup Medical Examinations 10
(7) Exit Medical Examination 10
(8) Recordkeeping 10
4. SITE CHARACTERIZATION 11
A. Offsite Reconnaissance 11
B. Onsite Survey 11
(1) NPDES Sites 11
(2) NIOSH Confined Space Classification 12
(3) ANSI and ASSE Confined Space Classification 13
(4) Hazard Recognition 13
C. Site Inventory 16
(1) WRD NPDES Site Classification 16
(2) WRD NPDES Site Inventory 16
D. Site Entry Procedures 16
(1) Job Hazard Analysis 16
(2) Entry Permit 17
(3) Atmospheric Testing 19
(4) Monitoring 22
(5) Labeling and Posting 23
E. Hazard Controls 23
(1) Controlling Atmospheric Hazards 23
(2) Controlling Ignition Sources 24
(3) Safe Use of Equipment and Tools 24
5. STANDARD OPERATING PROCEDURES 25
A. Requirements 25
B. WRD NPDES Standard Operating Procedures 26
(1) WRD NPDES Class "A" Site 26
(2) WRD NPDES Class "B" and Class "C" Sites 26
(3) WRD NPDES Class "D" Site 26
(4) Personnel 26
(5) Monitoring Site Conditions 27
6. TRAINING PROGRAM 28
A. Objectives 28
B. Requirements 28
C. Training Courses 29
D. Training Certification 30
E. Training Plan and Recordkeeping 30
7. LABORATORY SAFETY 30
A. Introduction 30
B. Collecting and Processing Samples 31
C. Packaging and Labeling Samples 32
D. Analytical Service Request 32
E. Laboratory Handling of Sample Bottles 32
F. Sample Disposal Procedures 33
8. SPILL CLEAN-UP PROCEDURES 33
9. HAZARDOUS MATERIALS AND WASTE DISPOSAL 33
10. CONCLUSION AND RECOMMENDATIONS 34
REFERENCES 35
APPENDIXES
A. WRD NPDES SCREENING TEST FORM 36
B. WRD NPDES SITE INVENTORY FORM 39
C. WRD JOB HAZARD ANALYSIS FORM 41
D. WRD CONFINED SPACE ENTRY PERMIT FORM 43
U.S. GEOLOGICAL SUREY, WATER RESOURCES DIVISION,
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM--
SAFETY POLICY AND GUIDANCE
1. INTRODUCTION
A. General Statement
To control stormwater runoff quality in compliance with
Section 402(p) of the Water Quality Act of 1987, 24 large- (those
with a population exceeding 250,000) and medium-sized (those with
a population exceeding 100,000) cities have requested that the
Water Resources Division (WRD) provide the urban stormwater
monitoring assistance needed to obtain a National Pollutant Discharge
Elimination System (NPDES) permit from the U.S. Environmental
Protection Agency (USEPA). Additional cities and military
installations will probably seek similar assistance from the WRD for
the NPDES-type monitoring work in the near future. (For
convenience, "NPDES" will be used hereafter to refer to "NPDES and
NPDES type".) Specifically, NPDES investigations require WRD
personnel to work in unsafe urban environments at potentially
hazardous sites. NPDES project sites may include sewer inlets and
outfalls, stormwater ponds, sewer pipes, natural or manmade open
channels, culverts, and manholes. Some of these sites are designated
as "confined space" by the Occupational Safety and Health
Administration (OSHA), requiring special safety procedures set forth
in the OSHA regulations (OSHA 29 CFR #1910.146). To comply with
the OSHA regulations and to be in accordance with the U.S. Geological
Survey (USGS) Director's memorandum dated February 7, 1992, on
the USGS Safety and Occupational Health Program (Ref. A), this Safety
Policy and Guidance has been developed. The purpose is to establish
minimum safety and health requirements and procedures for the
WRD personnel working at NPDES project sites.
B. Legal and Regulatory Perspective
This Safety Policy and Guidance is intended to comply with the most
recent Federal environmental and safety regulations relevant to
NPDES project sites and the USGS safety policy on confined space
(Ref. B). The Federal regulations shall be considered to be the
minimum requirements because State and local jurisdictions may
have elected to administer stricter environmental and safety
regulations. Federal agencies are required to abide by the State and
local regulations in these instances. However, this Safety Policy and
Guidance does not attempt to address or cover all the different
permutations that site-specific conditions and State and local
regulations will create.
C. Responsibility
It is the responsibility of managers and supervisors to ensure that
the safety procedures and guidance prescribed in this Safety Policy
and Guidance along with the applicable Federal, State, and local
regulations be followed for all NPDES projects. In addition, they need
to document that all personnel working at NPDES project sites have
the required training, medical surveillance, and safety equipment as
stipulated in this Safety Policy and Guidance.
2. SAFETY PROGRAM PLANNING
A. Planning Requirements
Development of an adequate safety organization and strict adherence
to a rigorous safety plan are the most critical and essential elements
for safe site operations.
B. Safety Organization
An adequate safety organization shall include a Project Chief, who
has the responsibility for the overall project's safety program, and a
Project Safety Officer designated by the Project Chief to implement
the safety program. In addition, each site must designate a Site
Safety Officer to implement the safety program at the site. For
smaller projects, the Project Chief can be the Project Safety Officer
and the Site Safety Officer.
C. Safety Plan
Based on this Safety Policy and Guidance, a safety plan shall be
developed by the Project Chief or the Project Safety Officer or both
to establish the overall safety operational procedures. A safety plan
shall consist of the following elements and documents:
(1) Copy of this Safety Policy and Guidance (emphasis on the
Standard Operating Procedures Section)
(2) Medical Program and documentation
(3) Written project site inventory
(4) Written project site entry procedure
(5) Training program and documentation
(6) Written sample shipping and storage procedure
(7) Written guide for laboratory safety
(8) Written spill cleanup plan
(9) Written material and waste-disposal procedure
3. MEDICAL SURVEILLANCE PROGRAM
A. Legal Requirements
A medical surveillance program is essential to assess and monitor the
health and fitness of the project personnel, to provide emergency
treatment, and to keep records for future reference. In a
memorandum dated May 29, 1979, the USGS instituted a medical
surveillance program for personnel exposed to on-the-job health
hazards (Ref. C). As the first step in implementing the medical
surveillance program, it is essential that those personnel who are or
might be exposed to a host of hazardous substances or conditions or
both in the work environment be identified. After consulting with
the U.S. Department of the Interior (DOI) Medical Director, a
determination was made that the risk of exposure of NPDES project
personnel to certain on-the-job health hazards is great and that a
proper medical surveillance program should be required.
Consequently, in a memorandum dated January 22, 1992, the DOI
Medical Director recommended specific medical requirements
regarding WRD personnel working at NPDES project sites (Ref. D.)
The WRD has adopted the DOI Medical Director's recommendations
and developed the following medical surveillance program:
B. Medical Program Elements
(1) Initial Consideration
The immediate step after the identification of those personnel
who will be part of an NPDES project team is to brief them on
the nature of the hazards of working at the project sites and to
find out if anyone is medically fit to work on the project sites
by the following medical measures:
(2) Initial Screening Test
(a) To ensure NPDES project personnel are not
suffering from any form of phobias, particularly when
working at NPDES sites, the WRD NPDES Screening Test
Form (Appendix A), which was prepared by the DOI
consulting psychologist, shall be used as a screening
instrument. This form shall be completed by all NPDES
field personnel prior to an assignment to an NPDES site.
(b) The completed Screening Test Form shall be
forwarded to the WRD Safety Officer who will forward it
through the Office of Personnel to the DOI Medical
Director for evalution and recommendation by the
consulting psychologist. Employees will be evaluated
before requiring them to work at project sites.
(c) It should be noted that the Psychological Evaluation
results cannot and should not be utilized as a condition of
participation in a NPDES project other than a field
assignment.
(3) Initial Baseline Medical Examination
(a) To evaluate the ability to carry out the assigned
duties and to detect any diseases or abnormalities which
may make it difficult to work at NPDES sites, all NPDES
field personnel shall have an initial Baseline Medical
Examination by a licensed physician experienced in
occupational medicine. The Examination shall include,
but not be limited to, resting electrocardiogram and
pulmonary function studies. It shall also include the
following tests:
(i) Laboratory tests shall include complete blood
count and differentials, liver and kidney function
profiles, and urinalysis. In addition, plasma and
red cell cholinesterase shall also be included
because of the high probability that NPDES
personnel could be exposed to phosphate
contaminants.
(ii) Respirator fit testing shall be conducted to
demonstrate the ability to use positive pressure
respirators as cited in the OSHA regulations (OSHA
29 CFR #1910.134).
(iii) Vision and audiometric tests shall be
conducted to demonstrate the ability to see and
hear warnings, such as flashing lights, buzzers,
or sirens.
(b) The completed Baseline Medical Examination results
shall be forwarded to the WRD Safety Officer who will
forward them through the Office of Personnel to the DOI
Medical Director for his evaluation and recommendation.
Employees will then be evaluated as to their medical
fitness to working at project sites.
(4) Immunization Requirements
Because of the nature of the worksite environment, all NPDES
field personnel shall have an update of their tetanus
immunizations and hepatitis B shots, including administration
of gamma globulin; if they could be exposed to human waste
then an update of their typhoid immunization is recommended.
(5) First-Aid Provisions
(a) NPDES field personnel shall be currently trained
and certified in CPR and basic first-aid procedures.
(b) NPDES field personnel shall be aware of the location
of the nearest first-aid equipment and how to obtain
emergency assistance and medical attention.
(6) Periodic or Followup Medical Examinations
(a) A periodic or followup medical examination shall be
conducted at least every 12 months or when recommended
by the DOI Medical Director or examining physician
who administered the initial Baseline Medical Exam-
ination. The examinations shall be an update of
medical and occupational history, a physical examination,
and testing based on examination results, exposures, and
job class and task. More or less frequent testing may
be required on the basis of specific exposures.
(b) All periodic or followup medical examination
results shall be forwarded to the DOI Medical Director
through channels following the same procedures as the
Baseline Medical Examination results.
(7) Exit Medical Examination
A full medical examination shall be conducted when field
personnel are reassigned or separated. However, a less-than-
full medical examination may be conducted if the last full
examination was within the last 6 months, no exposure
occurred since the last examination, and no symptoms
associated with exposure occurred since the last examination.
(8) Recordkeeping
All medical records and data pertaining to NPDES Medical
Surveillance Program, including records of exposure to known
health hazards, shall be filed in employee medical folders
maintained by the servicing personnel office. The OSHA
regulations (OSHA 29 CFR #1904 and #1910.20) mandate that
unless a specific occupational safety and health standard
provides a different time period, Federal agencies must:
(a) Maintain and preserve medical records on exposed
workers for 30 years after separation.
(b) Make available to workers their full medical
records.
(c) Maintain records of occupational injuries and
illnesses and post a yearly summary report.
4. SITE CHARACTERIZATION
A site characterization shall be conducted by the Project Chief or
designated project personnel to identify specific hazards at or near the site
and to determine the appropriate safety and health control procedures
needed to protect personnel from the identified hazards when working at
the site. It consists of the following measures:
A. Offsite Reconnaissance
Prior to entering a project site, a reconnaissance outside the site
perimeter shall be conducted to gather information about the site
and its accessibility, potential hazards, pathways for hazardous
substances (including offsite sources of hazardous materials and
paths by which they could be transported to the site), and locations
of medical facilities, fire stations, and police stations. The purpose is
to develop safe procedures for conducting an onsite survey.
B. Onsite Survey
To supplement information from the offsite reconnaissance, an onsite
survey without site entry shall be conducted on the premises, or
operations or both and shall include a general site hazard assessment
and site classification. The purpose is to develop project site
inventory and project site entry procedures before commencing any
site entry.
(1) NPDES Sites
All NPDES project sites are either a confined or a nonconfined
space. A confined space is any area that by design, has
restricted openings for entry and exit, has hazardous
atmosphere that could contain or produce dangerous air
contaminants, and that is not intended for continuous human
occupancy. Examples of confined spaces on NPDES sites include
sewers, sewer manholes, most sewer inlets and outfalls, and
some culverts. Most other NPDES sites, such as natural or
manmade open channels and stormwater ponds, are considered
to be nonconfined spaces.
(2) NIOSH Confined Space Classification
The National Institute for Occupational Safety and Health
(NIOSH) has recommended the following classification of
confined spaces (Ref. E):
(a) Class "A"
This space presents situations that are immediately
dangerous to life or health (IDLH). The NIOSH Pocket
Guide to Chemical Hazards (Ref. F) defines IDLH
concentration as the "...maximum level from which one
could escape within 30 minutes without any escape-
impairing symptoms or any irreversible health effects..."
These include, but are not limited to, oxygen deficiency or
enrichment with an oxygen concentration of less than
16 or greater than 25 percent, explosive or flammable
atmospheres exceeding 20 percent of lower flammable
limit (LFL), and toxic substances reaching IDLH exposure
concentrations. Rescue procedures require the entry of at
least two trained individuals fully equipped with life
support equipment. Maintenance of communication
requires an additional standby person stationed within
the confined space.
(b) Class "B"
This space presents situations that have the potential for
causing injury and illness if preventive measures are not
used but not immediately dangerous to life and health.
These include, but are not limited to, oxygen content
between 16.1 and 19.4 percent or between 21.5 and 25
percent, flammable atmosphere of between 10 and 19
percent of LFL, and toxicity greater than contamination
level referenced in the OSHA standard (OSHA 29 CFR
#1910.Z) and less than IDLH. Rescue procedures require
the entry of only one trained individual fully equipped
with life support equipment. Indirect visual or auditory
communication with employee(s) is required.
(c) Class "C"
This space presents situations in which the potential
hazards would not require any special modifications of
the work procedure. These include, but are not limited
to, oxygen content of between 19.5 and 21.4 percent,
flammable atmosphere of less than 10 percent of LFL,
and toxicity of less than contamination level referenced
in OSHA standard (OSHA 29 CFR #1910.Z). Direct
communication with employee(s) from outside the
confined space is required.
(3) ANSI and ASSE Confined Space Classification
American National Standard Institute, Inc. (ANSI) and
American Society of Safety Engineers (ASSE) have
recommended the following classification of confined spaces
(Ref. G):
(a) Nonpermit Confined Space
A space that, by configuration, meets the definition of a
confined space but, after evaluation, is found to have
little potential for generating hazards or has the hazards
potential eliminated by engineering controls.
(b) Low-Hazard Permit Space
A space where the likelihood that an IDLH or engulfment
hazard could be present is extremely low and where all
other serious hazards have been controlled. However, a
written entry permit is required.
(c) Permit-Required Confined Space
A space that after evaluation, has actual or potential
hazards that require written authorization for entry.
(4) Hazard Recognition
Special Hazards in most NPDES sites include, but are not limited
to, the following:
(a) Some toxic vapors, gases, liquids, and dusts
including carbon monoxide, hydrogen sulfide, sulfur
dioxide, and methane, in excess of their permissible
exposure limit.
(b) Flammable gases or liquids in excess of
20 percent of the LFL or lower explosive limit (LEL).
(c) A lack of (less than 19.5 percent) or excess of
(greater than 21.4 percent) oxygen may cause
asphyxiation or increased fire hazard.
(d) Wastes from hospitals and research facilities may
contain disease-causing microorganisms, including human
immunodeficiency virus. Etiologic agents may be
dispersed by means of water and wind. Other biologic
hazards include pathogens and leakage of sanitary
sewage into storm-drain systems.
(e) Heat stress is a major hazard, especially when
wearing protective clothing. The same protective
materials that shield the body from chemical exposure
also limit the dissipation of body heat and moisture.
Depending on the ambient conditions and the work being
performed, heat stress can occur in as little as 15 minutes
and can pose as great a danger to health as chemical
exposure. Heat stress can cause heat rash, heat cramp,
heat exhaustion, and heat stroke.
(f) Inability to readily get into or out of the confined
space as a result of the location or size of openings or
both.
(g) Most NPDES sites are located in urban areas where
workers can fall victim to urban crimes and associated
violence and where heavy traffic creates dangerous
working environments with potentially fatal motor vehicle
accidents.
(h) Most NPDES personnel are required to work during
wet-weather, severe-storm events. Workers are exposed
to extreme hazardous conditions that can lead to
accidents, such as slipping, falling, and tripping.
(i) NPDES personnel are required to work in areas in
which ionizing radiation is present. The three most likely
sources of this radiation are illegal disposal of radioactive
waste into storm drains, dumping of stolen sources (for
example, a neutron moisture probe), and the
accumulation of radon in cement storm-drain systems.
The first two sources are unlikely to produce significant
employee exposures during a storm-sampling event
because the high flows will significantly dilute any
radioactive waste in the system.
However, the first two sources could produce some exposure
during low-flow conditions if personnel work at the site
for extended periods of time. If the site survey
identifies possible sources (for example, hospitals,
analytical laboratories, manufacturing facilities, and so
forth) of radioactive material upstream from the site or if
the cooperator has detected radioactive material at the
site in the past, then a radiation meter shall be used to
check for above-background levels of radiation. If
radiation is present, then personnel working at the site
shall be provided with radiation monitoring (for example,
film badges), and the radiation meter will be used each
time the site is occupied. The results of personnel
monitoring shall be maintained with the medical records,
and in the unlikely case that an employee receives more
than the permitted annual dose or single exposure, that
employee will not be allowed to continue working at that
site.
USEPA regulations require action if more than 4
picocuries of radon are present in a confined space. This
level of radon has been documented in poorly ventilated,
cement-enclosed spaces and can only be measured with
special monitoring equipment that collects data for
extended periods of time.
C. Site Inventory
(1) WRD NPDES Site Classification
An inventory of project sites to be entered by its project
personnel shall be developed and maintained after an onsite
survey is completed. Each site on the inventory shall be
classified according to the NIOSH classification of Class "A",
Class "B", and Class "C"; an additional WRD classification of Class
"D" shall be used to identify nonconfined space sites.
(2) WRD NPDES Site Inventory
The inventory shall include, but not be limited to, the following
information:
(a) Site ID and Location
(b) Site Classification
(c) Site Description
(d) Access or Entry Pathway
(e) Known or Potential Hazards
(f) Entry Permit Status
A WRD NPDES Site Inventory Form is provided in Appendix B.
D. Site Entry Procedures
(1) Job Hazard Analysis
A formal written job hazard analysis (JHA) shall be performed
for each NPDES job and site, and all personnel working at that
site shall be briefed on the JHA prior to entry. A JHA is a
procedure for documenting hazards associated with a specific
job or assignment and for identifying actions needed to avoid
accident or injury. A WRD JHA Form is provided in Appendix C.
Each JHA must address the following elements:
(a) The job activity or task.
(b) A breakdown of the basic job steps or tasks
describing what is done, not how it is done.
(c) Hazards associated with each job step.
(d) Safe job procedures and precautions required to
alleviate the hazard.
(2) Entry Permit
(a) Entry to nonconfined space sites (Class "D") requires
no entry permits. Entry permits shall be prepared and
issued by the Project Chief for all confined space sites
(Classes "A", "B", and "C") prior to each entry. A WRD
Confined Space Entry Permit Form (Appendix D) has been
developed for use in NPDES projects. The entry permit
shall contain the following:
(i) Project Job and Site
--Project office
--Entry and permit time and duration
--Job location and description
--Site description and classification
(ii) Project Personnel
--Project Chief and Safety Officer
--Entry and other assigned personnel
--Other entry supporting personnel
--Rescue personnel
(iii) Hazard Recognition
--Oxygen deficiency
--Flammable and explosive materials
--Toxic and corrosive materials
--Other safety problems and hazards
(iv) Safety Equipment
--Personal protective equipment
--Respirators
--Shields
--Lighting
--Fire Extinguishers
--Safety lifelines and harness
--Other
(v) Testing and Monitoring Equipment
(vi) Rescue and Escape Equipment
--Tripod emergency escape unit
--Escape lifelines and harness
--Resuscitator and inhalator
(vii) Communications Equipment
(viii) Atmospheric Testing and Monitoring
--Initial atmospheric test readings for oxygen
level, flammability or explosive levels or both,
and toxicity levels
--Atmospheric monitoring while work is
being performed
(ix) Emergency and Rescue Plan
--Emergency rescue procedures
--Location of first-aid equipment
--Emergency telephone numbers
(b) The original of an entry permit shall be posted at
the site, with copies being distributed to the project office
and to project files.
(c) The entry permit for a job site shall be dated and
carry an expiration time that will be valid for one entry
only. The permit shall be updated for each subsequent
entry with the same requirements. However, the entry
permit may be valid for multiple entries for the duration
of the job at that site if the following conditions are met:
(i) The conditions in the confined space have no
known potential for presenting either an
atmosphere that is IDLH or an engulfing condition.
(ii) Acceptable conditions for entry are validated
by inspection and atmospheric testing each time the
site is occupied.
(iii) No new process or procedure will be
conducted if it is not covered under the original
entry permit.
(d) An entry permit that is valid for up to 1-year may
be issued in operation where workers are required to
make routine, repetitive entry into confined spaces that
have no known potential for presenting an atmosphere
that is IDLH or an engulfment condition or both. Specific
practices and procedures must be established and
followed. Atmospheric conditions must be tested prior to
entry.
(e) All personnel must be immediately withdrawn
from the confined space and entry permits shall be
voided if inspection and atmospheric testing indicate that
a condition exists that poses a threat to the personnel or
that conditions outside the space could pose a hazard to
personnel on the inside. After abatement of these
hazards, a new permit must be obtained before
reentering the confined space.
(3) Atmospheric Testing
(a) Purpose
Except for Class "D" sites, atmospheric testing shall be
conducted to identify any IDLH and other dangerous
conditions, such as flammable or explosive atmospheres,
oxygen-deficient environments, and highly toxic levels of
airborne contaminants. Most atmospheric hazards are
invisible and can develop anytime; therefore, different
test equipment, including oxygen meters, combustible gas
indicators, flame ionization detectors, photoionization
detectors, colorimetric indicator tubes, and organic vapor
monitors, must be used during the entire entry process.
Testing sequence shall be oxygen, flammability, and
toxicity.
(b) General Guidelines
(i) If possible, begin testing without disturbing
the space.
(ii) Test from top to bottom and around ductwork
and uneven surfaces.
(iii) Avoid leaning over the space being tested.
(iv) Allow time for the sample to reach the
sensors in the equipment.
(v) If test equipment is lowered into a hazardous
atmosphere, then make sure it is rated for that
environment (it must be intrinsically safe).
(c) Measuring Oxygen
(i) Oxygen is measured in percent by volume.
(ii) Air is made up of approximately 21 percent
oxygen at sea level.
(iii) Oxygen can be used up by people, combustion,
and other natural and manmade processes.
(iv) Oxygen can be displaced by other gases and
vapors.
(v) Because low or high oxygen concentrations
can affect flammability readings, test oxygen first.
(vi) Lack of oxygen can lead to brain damage or
death.
(vii) Because oxygen starvation can bring on a
feeling of happiness or well being called "euphoria,"
employees tend to be unaware of being in danger.
(d) Detecting Flammable Gases and Vapors
(i) At the LEL, a vapor/air mixture will explode
if a spark or flame is added.
(ii) When a vapor/air mixture is below the lower
explosive limit, it is too lean to burn; when it is
above the upper explosive limit, it is too rich to
burn.
(iii) Vapor/air mixtures between the lower and
upper explosive limits are in the flammable range.
(iv) Standard flammable-gas detectors read
flammable gases and vapors as a percentage of the
LFL or LEL.
(v) Percentage LEL detectors are not designed to
detect conditions in or above the flammable range
accurately. However, they will indicate that the
lower explosive limit has been exceeded.
(vi) There is equipment designed to detect gases
and vapors in and above the flammable range.
(vii) Flammable gases, such as methane, can be
created by the decay of organic matter.
(e) Detecting Toxic Gases and Vapors
(i) Because universal toxic gas detectors are not
available at this time, testing personnel must know
the specific toxic gas to be detected.
(ii) Most electronic toxic gas detectors detect
carbon monoxide or hydrogen sulfide or both.
(iii) Most toxics must be measured in parts per
million or parts per billion.
(iv) A concentration of a gas or vapor will be toxic
long before it is flammable.
(v) Carbon monoxide will combine with human
blood more readily than will oxygen.
(vi) Hydrogen sulfide will cause olfactory fatigue.
The nose will lose its ability to smell the gas, even
though it is present in the space.
(f) Testing equipment shall be selected for its
functional ability to measure hazardous concentrations.
Calibration of the instruments shall be conducted in
accordance with the manufacturer's guidelines or
manuals. Each calibration shall be recorded, filed by the
employer, and available for inspection for 1 year after
the last calibration date.
(g) When the contaminants in the atmosphere cannot
be kept within permissible exposure levels as set forth in
OSHA 29 CFR #1910.Z, then the employee shall wear a
NIOSH- and Mine Safety and Health Administration-
approved respirator that shall be fitted and maintained
in accordance with OSHA 29 CFR #1910.134. In addition,
only fully trained personnel may use a respirator, and
only positive-pressure, atmosphere-supplying respirators
are permitted.
(4) Monitoring
A Class "A" site shall be monitored on a continuous basis. All
Class "B" and Class "C" sites shall be monitored periodically to
include at least a followup and an exit testing after the initial
testing. Equipment for continuous monitoring shall be
explosion proof and equipped with an audible alarm or danger
signaling device that will alert employees when a hazardous
condition develops. All monitoring results shall be recorded on
the permit.
(5) Labeling and Posting
(a) All entrances to any confined space shall be posted
as follows:
DANGER
CONFINED SPACE
ENTRY BY PERMIT ONLY
(b) When specific work is performed or safety
equipment is necessary, the following warning signs shall
be added:
RESPIRATORS REQUIRED FOR ENTRY
LIFELINE REQUIRED FOR ENTRY
(c) Emergency procedures, including telephone
numbers of fire departments and emergency medical
services, shall be posted conspicuously within the
immediate area of the confined space or at the telephone
from which help would be summoned.
E. Hazard Controls
(1) Controlling Atmospheric Hazards
Atmospheric hazards are created in confined spaces by natural
and manmade processes, such as welding, decaying plants and
animals, painting, cleaning with solvents, and fumigating.
Controls vary from good housekeeping to purging and
ventilation.
(a) Purging
Prior to entry, purging with air to displace the air in a
confined space site.
(b) Ventilation
After entry, fresh air shall be circulated through the
space to supply fresh air to breathe, to remove
potentially hazardous conditions before they become
hazardous, and to supply cool air for comfort. A
ventilation system may be a forced air system or an
exhaust system or a combination of the two.
(2) Controlling Ignition Sources
The sources include open flames, heat-producing equipment,
spark-producing tools, broken lightbulbs, damaged electrical
cords, and any ungrounded metal equipment. Bonding and
grounding can eliminate the chance of a static spark in a
potentially flammable atmosphere.
(3) Safe Use of Equipment and Tools
(a) Portable electric tools shall be approved in
accordance with OSHA 29 CFR #1910.S and be equipped
with a ground fault circuit interrupter that meets the
OSHA requirements (OSHA 29 CFR #1910.309). All
electrical cords, tools, and equipment shall be of a heavy-
duty type with heavy-duty insulation and be inspected
for visually detectable defects before use. Electrical lines,
junctions, and accessories shall be in accordance with
National Electrical Code and National Fire Code (Ref. H) as
cited in OSHA 29 CFR #1910.309.
(b) Air-driven power tools shall be used when
flammable liquids are present. The use of such tools will
only reduce the risk of explosion, not eliminate it.
(c) Lighting used shall be of explosion-proof design and
be equipped with guards. Lighting shall not be hung by
electric cords unless specifically designed for that
purpose. Illumination of the work area shall be sufficient
to provide for safe work conditions, and under no
circumstances shall matches or open flames be used for
illumination.
(d) Cylinders of compressed gases shall never be taken
into a confined space except when they are part of self-
contained breathing apparatus or resuscitation
equipment. Only hose lines and components designed
especially for the compressed gas and working pressure
shall be used, and such systems shall have a pressure
relief valve outside the confined space.
(e) Ladders shall be adequately secured or be of a
permanent tyupe that provides the same degree of safety
as cited in OSHA 29 CFR #1910.D. Use ladders equipped
with safety feet; set ladders at the correct angle and tie
ladders off at the top. Do not use a metal ladder when
working around electricity, and use fall-arresting devices
whenever the potential for a fall exists.
(f) Scaffolding and staging shall be properly designed
to carry a maximum expected load (safety factor of 4), be
equipped with traction type planking, and meet the OSHA
requirements (OSHA 29 CFR #1910.28).
(g) Protective clothing can make movement difficult. It
also might cause personnel to become overheated
quickly. Drink plenty of liquids, even in cold weather.
(h) Noise might keep personnel from hearing an alarm.
It also could interfere with communication between
employees. Maintain good visual contact, or use some
other method of communication.
5. STANDARD OPERATING PROCEDURES
A. Requirements
The following WRD NPDES standard operating procedures (SOP) have
been adopted to provide instructions on how to accomplish specific
tasks in a safe manner and to supplement or complement or both
existing WRD safety procedures when working at all NPDES sites.
Any deviations from the SOP must be approved in advance by the
WRD Safety Officer. All NPDES personnel involved in site activities
must have copies of the SOP and be briefed on their use by the
Project Chief or Safety Officer.
B. WRD NPDES Standard Operating Procedures
(1) WRD NPDES Class "A" Site
(a) No WRD personnel shall enter this site without
authorization from the project office chief.
(b) As an alternative, contractors shall be called in to
perform any necessary work within this site and shall be
informed of potential hazards with this site.
(2) WRD NPDES Class "B" and Class "C" Sites
(a) Entry can only be made by authorized and trained
employees listed on the permit if authorized by the
Project Chief.
(b) Permit must be completed in full.
(c) For a Class B site, a minimum of two employees,
and, for a Class C site, two employees shall be assigned--
one as an authorized entrant and one or more as
attendant(s)--to maintain constant visual and audio
contact.
(d) Attendant(s) shall have a radio or other
communication with the project office.
(e) The project office shall be notified when entry is
made and when completed.
(3) WRD NPDES Class "D" Site
(a) Entry can be made by one employee without
standby attendants and requires no entry permit.
(b) The project office shall be notified when entry is
made and when completed.
(4) Personnel
(a) All entry and standby personnel shall be properly
trained, have current fit tests and medical surveillance,
and be in the same level of personal protective
equipment.
(b) The "buddy" system shall be in effect for all
permit-required entries. It requires standby personnel
to be present and to be in constant communication with
the entry personnel. It also requires the addition of new
standby personnel each time an existing standby
employee makes entry.
(c) Under no circumstances shall standby personnel
make entry to resuce entry personnel if there are no
other standby personnel present at the site. Any rescue
shall be executed by properly trained rescue personnel.
(d) Standby personnel shall be in communication with
entry personnel and the project office at all times during
entry and egress of entry personnel. Lines of
communication shall be established prior to all entries.
(e) Standby personnel shall have the rescue equipment
needed to remove the entry personnel through the use of
mechanically assisted devices and shall ensure that
ventilation and rescue equipment remain functional
during entry and egress of the entry personnel.
(5) Monitoring Site Conditions
(a) All NPDES permit-required sites shall be evaluated
for oxygen deficiency, LEL, and specific air contaminants
utilizing properly functioning, properly calibrated
equipment fitted with remote probes designed to provide
data before physical entry by personnel.
(b) Oxygen level testing shall precede all other testing.
Acceptable levels are established as those greater than
19.5 percent. It is recognized that low oxygen levels will
result in inaccurate LEL determinations. Entry into
oxygen-deficient sites is prohibited until levels are
increased and stabilized above 19.5 percent by
ventilation.
(c) Lower explosive levels shall be collected by
utilizing a remotely probed instrument prior to entry
where there is suspicion that flammable gases are
present. Acceptable levels are established as those levels
that are less than 10 percent of the LEL.
(d) Special air monitoring shall be conducted for such
contaminants as methane, carbon monoxide, and
hydrogen sulfide. Continuous ventilation shall be
required to provide fresh air and for the removal of
contaminants. Entry into sites having unknown
contaminants shall require supplied air respirators with a
self-contained breathing apparatus as the minimum.
(e) Those sites with egress problems shall require
escape respirators in addition to the supplied air systems.
All escape respirators shall be of the self-contained type.
All rescue harnesses shall be of a type that will facilitate
removal in a position similar to that of the entry.
6. TRAINING PROGRAM
A. Objectives
The training program has been developed to make workers aware of
the potential hazards, to provide the knowledge and skills necessary
to perform the work with minimal risk, to make workers aware of
the purpose and limitations of safety equipment that they will be
using, and to ensure that workers can safely avoid emergency
situations and escape if one occurs.
B. Requirements
To comply with the legislation and OSHA Regulations and to be in
accordance with the USGS policy on confined space entry procedures,
the WRD policy requires that all NPDES field personnel must have as
a minimum an initial 32-hour training course that includes a 24-hour
basic NPDES site safety training and 8-hour basic first-aid and CPR
training. The 8-hour basic first-aid and CPR training shall be
conducted locally at each project office by the Red Cross or an
equivalent. The WRD will provide the 24-hour initial basic site
safety training course through the National Training Center (NTC) in
Denver for all NPDES field personnel. The NTC course will be
conducted annually by a contractor selected through competitive
processes. If the basic site safety training course is to be given by
someone other than the one contracted by the NTC, then the course
syllabus will need approval by the WRD Safety Officer. In addition,
at each project office, the Project Chief or the Project Safety Officer or
both shall provide a 4-hour annual onsite refresher site-specific
training.
C. Training Courses
Training courses shall include, but not be limited to the following:
(1) WRD NPDES Project Safety Policy and Guidance
(2) WRD NPDES Standard Operation Procedure
(3) WRD NPDES Site Classification
(4) WRD NPDES Site Entry Permit System
(5) WRD NPDES Medical Surveillance Program
(6) First-Aid and CPR
(7) Handling Emergencies and Self-Rescue
(8) Safe Work Practices
(9) Hazard Recognition, Evaluation, Analysis, and Control
(10) Use of Instruments to Measure Explosivity, Oxygen
Deficiency, Flammability, and Toxicity
(11) Personal Protective Equipment Use
(12) Buddy System and Use of a Standby Person
(13) Communication Systems and Emergency Signals
(14) Safety and Rescue Equipment Use and Procedures
(15) Use of Respirators
(16) Safe Sampling Techniques
(17) Safety in Handling, Shipping and Storage of NPDES
Samples
D. Training Certification
All personnel working at a NPDES project site must have a certificate
issued by the WRD Safety Officer. A certificate will be issued upon
receiving a Standard Form 182 (Request, Authorization, Agreement
and Certification of Training) after completion of the 24-hour basic
NPDES site safety training and the 8-hour basic first-aid and CPR
training.
E. Training Plan and Recordkeeping
The Project Chief shall prepare a training plan for development of
training schedules, coordinate with the WRD Safety Officer, and
maintain a written record of training as part of personnel files. The
records shall be made available when requested during safety
inspections by the Region or Division or both.
7. LABORATORY SAFETY
A. Introduction
(1) In most circumstances, laboratory safety is established in
the USGS Safety and Environmental Health Handbook dated
August 1989 (Ref. I); the USGS Laboratory Safety Handbook
dated 1983 OFR 83-131 1983) (Ref. J); and various safety
procedures, protocols, and memoranda by District Chiefs.
(2) Careful planning is the key to minimizing the potential
hazards associated with laboratory work activities. The
laboratory work activities include sampling and collection of
samples, storage of bottles in a vehicle, transportation to the
project office, processing bottles for shipment to the National
Water Quality Laboratory (NWQL) in Denver, Colorado, log-in
procedures in NWQL, preparation and analysis of the NPDES
samples, NWQL sample storage procedure, and, finally, disposal
of the NPDES stream waste and samples.
(3) Many of the potential hazards can be identified by
inspecting the areas surrounding the site. Any unusual
incidents or occurrences must be recorded on the analysis
request form. Records of unusual occurrences will warn NWQL
employees to wear appropriate personal protective equipment.
Also, it may help identify problems that could interfere with
laboratory procedures and analyses. The information provided
also expedites the disposal of the stream samples and waste.
(4) Minimizing unnecessary handling of the samples will
greatly avoid potential exposures and reduce breakages and
spillages of the sample bottles.
(5) Clearly established procedures and techniques will
maintain chain-of-custody requirements, and enforcement of
sample-storage procedures will prevent tampering with
samples.
B. Collecting and Processing Samples
(1) A flowchart is a good way to organize and optimize steps
involved in sampling, collecting, and processing samples at the
project office laboratories and NWQL.
(2) All samples must be treated as hazardous and potentially
biohazardous.
(a) Strict personal hygiene must be enforced when
processing samples.
(b) Use of personal protective equipment or
engineering controls must be available to prevent direct
contact with the samples.
(3) Plans, equipment, and materials for decontamination of
known or potential hazards must be available.
(4) Procedures that maintain chain-of-custody requirements
must be established, followed, and documented.
(5) Secure sample storage must be available at the sampling
sites, project office laboratories, and NWQL.
C. Packaging and Labeling Samples
(1) NPDES samples shall be carefully packaged the same way
as regular samples; however, they are to be clearly labeled and
segregated from regular samples by double bagging them
separately.
(2) Individual NPDES sample bottles and shipping packages
(Gott cooler) shall be clearly labeled.
(3) The shipping packages shall be carefully sealed with tape
to prevent the top of the package from opening during transit.
(4) In a memorandum dated March 20, 1992, the WRD Office
of Water Quality issued a report on sample shipping integrity
and cost (Ref. K). This is a good reference for sample shipping
procedure.
D. Analytical Service Request
In addition to the usual information (site identification, coordinates,
schedules, laboratory codes, field data, and other information), it is
important to record in the "remarks" section any unusual occurrences
observed while inspecting or working at the site. Unusual
occurrences could be odor, color, quality of the run-off streams, and
so forth. The information provided will warn laboratory workers of
known hazards so that they can wear appropriate personal
protective equipment. Also, it will help in the process of preparing
and analyzing the samples.
E. Laboratory Handling of Sample Bottles
(1) A written procedure of receiving and processing NPDES
samples must be established. The procedure must include
safety practices dealing with breakage and spillage of samples
inside the shipping containers.
(2) All samples known or suspected to be hazardous shall be
flagged appropriately to warn laboratory workers of known
hazards and unusual occurrences at the site.
(3) The Gott coolers used to ship NPDES samples to NWQL
shall be cleaned (decontaminated) if there is any breakage or
spillage from the samples.
F. Sample Disposal Procedures
The storage and disposal procedure of NPDES samples and laboratory
waste streams must be followed in accordance with the appropriate
USEPA regulations. Documentation from the project offices and
NWQL is the determining factor to establish baselines for appropriate
disposal. Therefore, it is critical that as much information as possible
be provided by the project offices to complement information
collected by NWQL.
The WRD has established a goal to minimize quantities and volumes
of hazardous materials and wastes used and generated. Therefore, it
is important that project offices and NWQL minimize the use of
chemicals and potentially hazardous samples.
So that problems related to NPDES laboratory safety can be handled
quickly and properly, questions should be referred to the NWQL
Safety Officer at (303) 467-8035.
8. SPILL CLEAN-UP PROCEDURES
A. The project offices and NWQL shall have a written spill cleanup
plan in effect for handling NPDES samples.
B. The plan must identify the required equipment and material.
These items must be available, and everyone working with NPDES
samples must have a clear understanding on how to use them. The
location of these items must be easily accessible wherever a spill
could occur.
9. HAZARDOUS MATERIALS AND WASTE DISPOSAL
Liquid and solid hazardous materials and waste must be handled and
disposed of in accordance with the transportation and handling procedures
as outlined in the Department of Transportation (DOT) regulations (DOT 49
CFR #171-173), and the disposal and containment of hazardous materials
and waste, as outlined in USEPA regulations (USEPA 40 CFR #261 and
#262).
10. CONCLUSIONS AND RECOMMENDATIONS
A. NPDES sites have a much higher degree of risk than other
routine sampling sites because of confined space worksites. There
exists an extensive body of regulatory requirements for working in
confined spaces; this includes OSHA and USGS regulations.
B. Safety must be a priority in all NPDES projects, and
considerable attention must be paid to safety program planning.
C. Sufficient time and money must be budgeted for safety
program planning, training, medical program, and safety equipment.
REFERENCES:
A. USGS Memorandum, "Safety and Occupational Health Program,"
from Director, February 7, 1992.
B. "USGS Occupational Hazards and Safety Procedures Handbook,"
445-2-H, April 1992.
C. USGS Memorandum, "Medical Surveillance Program for
Employees Exposed to On-the-Job Health Hazards," from
Assistant Director for Administration, May 29, 1979.
D. DOI Memorandum, "Medical Surveillance," from Medical
Director, January 22, 1992.
E. NIOSH 80-106, "Criteria for A Recommended Standard for
Working in Confined Spaces." Dec. 1979.
F. NIOSH 90-117, "The NIOSH Pocket Guide to Chemical Hazards,"
June 1990.
G. ANSI Z117.1-1989, "American National Standard," American
Society of Safety Engineers and American National Standards
Institute, Inc., Oct. 1989.
H. National Fire Codes, 1988.
I. USGS Safety and Environmental Health Handbook, USGS
445-1-H, 1989.
J. USGS Laboratory Safety Handbook, OFR 83-131, 1983.
K. USGS WRD Office of Water Quality Technical Memorandum
92.06, "Report--Report of Committee on Sample Shipping
Integrity and Cost," March 20, 1992.
APPENDIXES
(Contact the Branch of Operational Support, Reston, for a copy
of these Appendixes.)