Health and Safety Plan V 2.0 East Palestine Derailment Site Unified Command Group


Cover Sheet

Version Name: Health and Safety Pian

incident Name: East Palestine Train Derailment 02032023

Period: Period 14 [03/31/2023 07:00 - 04/07/2023 07:00]

Approved By



EPA R5:

Dollhopf, Ralph







EPA R3:

Kelly, Jack

7 p (J





Village of East Palestine FD:

Drabick, Keith

z^'uzStcA'





Columbiana Co EMA:

Clark, Peggy







Ohio EPA:

Vogel, Anne

UVtf





Norfolk Southern:

Naranjo, Bryan

(J





Health And Safety Plan (HASP)





We are in the process of ensuring this document is accessible to all audiences. If you need assistance
accessing this document, or any material on the EPA East Palestine, Ohio emergency response
webpages, please contact the Region 5 Public Information Officer on-call





r5 eastpalestinefa

.epa.gov







East Palestine Train Derailment Site
Unified Command Group
Health & Safety Plan
v. 2.0





Prepared by:

Shanna Horvatin, US EPA Safety Officer
Scott Skelton, CTEH Assistant Safety Officer













Cover Sheet

Prepared By Jeffrey Wright, Updated 03/29/2023 14:07 EDT UTC-4 PP

INCIDENT ACTION PLAN SOFTWARE™

Printed 03/29/2023 14:36 EDT UTC-4

1 Of l © TRG

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East Palestine Derailment HASP Preamble and User's Guide

The East Palestine Derailment site maintains a dynamic status and includes a variety of
operational theatres. The purpose of this Health and Safety Plan (HASP) model is to fulfill the
requirements established in the HAZWOPER standard 29 CFR 1910.120(b). Pursuant to this standard,
this HASP seeks to fulfill established criteria while remaining flexible for sustainable implementation.
Perhaps the greatest objective is to provide critical information for site workers to bolster individual safe
work practices.

Plan Construction & Utilization Scope

No one safety plan can fully address all hazards for all tasks on all days. However, this HASP
model was constructed to drive the safety culture to optimize Job Safety Analysis (JSA) and tailgate
briefings to ensure that the conveyance of planning-level hazard awareness is driven into the field where
it is most necessary. This HASP is built upon 4 levels, specifically: 1) Comprehensive Site HASP; 2)
Divisional HASP; 3) Operational Risk Analysis; and, 4) Frontline safety tools and documentation. This
user's guide was prepared to facilitate proper use and consistent utilization across all working theatres.
The following diagram outlines the plan's components.

General - comprehensive view
1910.120

Operational Divisions

Operational Division Risk Analysis
& Control Development

Field-based HASP Tools

Job Safety

I [ Tailgate 1

Analysis

1 1 Safety 1

(JSA)

1 1 Briefings 1

Waste
Management

Surface
Water

Surface Soil

Residential

Community
Engagement

The site HASP was written to comprehensively address site-wide hazards ranging from industrial
wreck site operations to work activity with socio-environmental hazards. This plan relies on the
Operational Division HASP to further address operation-specific hazards and controls specific to the eight
respective environments and workforce dynamics. For each Operational Division, an Operational Risk
Analysis is conducted to focus on high-consequence risk based on the operational tactics. The Operational
Risk Analysis is a focused step to address the hazards more in-depth and establish control measures that
may not be necessary in other operational divisions. Lastly, the field-based HASP tools represent the
"living" portion of the plan wherein day-to-day changes are captured and communicated to site workers
performing the work.

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HASP Progression to Field Activity

The following diagram illustrates the progression from the site-wide HASP down through each planning
function ultimately yielding functional safety planning tools for regular consumption by the workforce at
large.

HASP

Operational
Division

Operational
Division

Risk
Analysis

Field Based
HASP Tools

•Provides
comprehensive
safety analysis of
site-wide
operations in
accordance with
29 CFR 1910.120

\

• Division-specific
safety analysis
•Provides focused
safety planning
for division's
unique

environmental
characteristics

•Establishes
primary tasks
•Declares
principle hazard
categories
•Introduces
control measures
for each primary
hazard

•Focused on task-
based hazard
declaration and
control measures
to be used by
field personnel
•Considered the
"living" portion
of the HASP to
ensure all field
personnel
receive vital
information

Implementation

All personnel should review and be aware of the site-wide HASP (Blue Plan) to gain a full
understanding of the site's hazard profile and exposure control provisions. Once the full plan has been
reviewed and understood, the Operational Division HASP (Green Plan) will serve as each division's
platform to bolt on additional hazards and safety controls not addressed in the Blue Plan based on the
dynamic nature of the operational periods and new tactics. The Operational Risk Analysis is intended to
be completed initially to provide a more rigorous review of high-consequence hazards along with the
benefit of prescriptive controls. Lastly, the content derived from the Green Plan and Operational Risk
Analysis should serve as the basis for JSA and tailgate briefing content. The JSA and tailgate briefings
will bear the responsibility of in-field additions to the overall HASP, where document retention will
capture nuance safety matters and the controls employed.

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Health and Safety Plan (HASP)

Project: East Palestine Train Derailment Site

Location: East Palestine, OH	

Date Prepared: 3-20-2023	

Version: 2.0

Operational Period: 24 hours
Work Zone: General Site

For Emergencies Contact: Site EMT and/or 911	

Scope: This Operations Safety Plan outlines the safety strategy and safe work practices to be
implemented, maintained, and updated in order to accomplish response objectives as determined
for each operational period. This Plan will focus on a hierarchy of controls based on Task Specific
work operations involved.	

Site Health and Safety Plan: East Palestine Train Derailment

1

-------
HASP

Provides
comprehensive
safety analysis of
site-wide
operations in
accordance with
29 CFR 1910.120

Operational Division

Division-specific
safety analysis
Provides focused
safety planning
for division's
unique

environmental
characteristics

Operational Division
Risk Analysis

Establishes
primary tasks
Declares principle
hazard categories
Introduces control
measures for each
primary hazard

Field Based HASP
Tools

•Focused on task-based
hazard declaration and
control measures to be
used by field personnel
• Considered the "living"
portion of the HASP to
ensure all field
personnel receive vital
information

Site Health and Safety Plan: East Palestine Train Derailment

2

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2 Site Characterization & Hazards Overview

Major Operational Divisions:

Description and Location Where Operation(s) to be Performed

1. Wreck site/Track Removal

Primary location: Affected track from Pleasant St. and eastward to derailment area

2. Waste Management

Soil staging on-site adjacent to track. Liquids storage at various frac-tank staging areas

3. Surface Water

Various watersheds beginning with those within and adjacent to track area and downstream

4. Surface Soil

Soil determined to be impacted by derailment contamination. Locals adjacent to wreck area

5. Residential

Residences adjacent to track of interest for assessment, cleaning, outreach, etc.

6. Community Engagement

Efforts associated with community outreach. Located at the EPA Welcome Center and
various community meetings/townhalls

Site Infrastructure

Roadways:

E Taggart Street, N Pleasant Drive, S Pleasant Drive

Waterways:

Topographical drainage,
creeks,

Facility Equipment:

Passing trains, tractor trailers (adj
businesses)

Railways:

Norfolk Southern -
Track 1 (south) & Track
2 (north)

Heavy Machinery:

Excavator, front-end loader, dozer,
crane, mini-ex, vac truck, railway
maintenance equipment

Electrical Sources:

High voltage power line,
temp power, etc.

Pipelines:

Determine with utility

Operational theatres:

Unified Command (Columbiana), Incident command (E. Palestine), Frac-tank staging,
equipment staging, Welding Shop Field Command, Waste stockpiles

Site Health and Safety Plan: East Palestine Train Derailment

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Chemical Hazards

Chemical

Source

Exposure Potential

Estimated Volume

n-Butyl aery late

Damaged railcar, impacted soil, standing liquids,
underground drainage pipes; Transfer equipment,
wastewater storage, vac trucks

1 1 Likely O Unknown
1^1 Possible
I | Unlikely

1 Railcar, spill
volume unknown

Vinyl chloride

Derailed railcars, vent & burn consumed a large portion of
material; Impacted soil & waterways; Leaks may occur
through car manipulations during wrecking

1 1 Likely O Unknown
1^1 Possible
I | Unlikely

5 Railcars, spill
volume unknown

Ethylene glycol monobutyl
ether (2-butoxy ethanol)

Damaged railcar, impacted soil, standing liquids,
underground drainage pipes; Transfer equipment,
wastewater storage, vac trucks

1 1 Likely O Unknown
1^1 Possible
I | Unlikely

1 Railcar, spill
volume unknown

Isobutylene

Car did not release lading. Onsite transfer

1 1 Likely O Unknown
1 1 Possible
^ Unlikely

1 Railcar, no release

2-ethylhexyl acrylate

Damaged railcar, impacted soil, standing liquids,
underground drainage pipes

1 1 Likely O Unknown
1^1 Possible
1 1 Unlikely

1 Railcar, spill
volume unknown

Site Health and Safety Plan: East Palestine Train Derailment

4

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Toxicology Information1: Butyl acrylate

Exposure Route

Exposure

Possible Symptoms /Health Effects of Exposure

How to Avoid



Low Concentration
(< 2 ppm)

Odor threshold of 0.05 ppb (ERPG); odor classified as sharp, fragrant
odor.

Remain upwind, avoid prolonged exposure using
respiratory protection



Moderate
(2 - 25 ppm)

ACGIH TLV-TWA of 2 ppm; Irritation of the URT, drowsiness,
headache, and nausea

Full-faced Air Purifying Respirator (APR)

IlLjI

High

(> 25 ppm)

IDLH: ND (NIOSH 2016); ERPG-2 of 25 ppm; Drowsiness, headache,
nausea; Liver damage; Marked irritation, salivation, conjunctive

Full-faced APR, SCBA for concentrations >100



irritation; pulmonary edema

ppm.



Liquid contact

Repeated contact of the skin may cause skin sensitization in some
individuals, with redness, swelling, itching, and oozing of the affected
areas.

Chemical-resistant protective suit. Handle liquids
with care, full decontamination of CPC

Dermal vapor exposure

Dermal sensitizer; Irritation, redness, and cracking of the skin

Avoid working in atmospheres containing moderate
to high concentrations without chemical protective
clothing.



Irritation from vapor

Irritation, mild discomfort, and redness

Full-face Respiratory protection

•••••••

•••••••

•••••••

Liquid contact

May cause pain disproportionate to the level of irritation to the eye
tissues; slight eye irritation, slight corneal injury

Full-face Respiratory protection

9

Ingestion of liquid

Collapse, severe respiratory difficulties, and CNS stimulation.

Good workplace hygiene. Handle liquids with care,
proper decontamination of protective clothing

1 Agency for Toxic Substances and Disease Registry (ATSDR), NIOSH Pocket Guide, ACGIH TLVs, & Emergency Response Planning Guidelines
(ERPGs)

Site Health and Safety Plan: East Palestine Train Derailment	5

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Toxicology Information2: Vinyl chloride

Exposure Route

Dose

Possible Symptoms /Health Effects of Exposure

How to Avoid



Low

(< 1 ppm)

No apparent observable effects or symptoms



J9L

Moderate
(1 - 1200 ppm)

Acute effects may not be perceptible in this concentration range.
OSHA PEL Ceiling of 5 ppm; Chronic exposure is linked to "vinyl
chloride illness", which includes Raynaud's Syndrome and
acroosteolysis. The toxic effect of greatest concern is cancer of the
liver, which is largely the result of chronic exposure. TLV A1
confirmed human carcinogen.

Supplied Air Respirator (SAR)





PAC-2 of 1200 ppm; Odor threshold observed at 3000 ppm;
anesthesia, drowsiness, slight visual disturbances, faltering gait,
numbness and tingling of extremities. CNS depression and death from
high concentrations. Exposure to 4000 ppm for 5 minutes, no effects;
8000 ppm for 5 minutes - dizziness; 20,000 ppm for 5 minutes-
dizziness, light headedness, nausea, and dulling of vision (Rumack
Poison Index 2016).





High

(>1200 ppm)

Supplied Air Respirator (SAR)



Liquid contact

Frostbite; irritation of skin; contact dermatitis

Chemical-resistant protective suit. Handle liquids
with care, full decontamination of CPC

jr

Dermal vapor exposure

Irritation of skin at very high concentrations

Chemical-resistant protective suit with properly
taped seams.



Irritation from vapor

Irritation

Full-face Respiratory protection

•••••••

Liquid contact

Severe chemical burns and damage to cornea, temporary blindness;
Ocular irritation; conjunctivitis

Full-face Respiratory protection

9

Ingestion of liquid

Severe burns and irritation to GI tract; assumed systemic toxicity after
exposure to critical organs

Handle liquids with care, proper decontamination of
protective clothing

2 Agency for Toxic Substances and Disease Registry (ATSDR), NIOSH Pocket Guide, ACGIH TLVs, & Emergency Response Planning Guidelines (ERPGs)

Site Health and Safety Plan: East Palestine Train Derailment	6

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Physical Hazards

Name of Physical
Hazard

Source

Exposure Potential during
Task/Operation

Affected Work Group(s)

Control Measure

Burns, explosion

Flash or deflagration may
occur with flammable
liquids:

1 1 Likely Q Unknown
1^1 Possible O Unlikely

Workers transferring
material, workers entering
containment, support
personnel

LEL monitoring, hot work safety
procedures, avoid excess heating of
anhydride (flash point 120F)

Heavy machinery

Site equipment with
pivoting tools and abundant
blind spots

1 1 Likely Q Unknown
1^1 Possible O Unlikely

Workers in excavation,
wrecking, remediation,
waste & liquid handling

Pedestrian awareness. Visual contact
before walking near machinery. Backup
alarms. Designated travel pathways.

Corrosion, tissue
damage, ocular
damage

Irritation associated with
liquid products, or other
cleaning agents used

15^1 Likely Q Unknown
1 1 Possible O Unlikely

Workers transferring
material, workers entering
containment, impacted soil,
transfer liquids, sampling

Chemical protective clothing (including
boots & gloves), full-faced respiratory
protection to protect face and eyes

Cold Stress

Cold overnight, early
morning temps.
Hypothermia, trench foot,
and chilblains possible with
wet skin

1 1 Likely Q Unknown
1^1 Possible O Unlikely

All workers in outdoor
spaces exposed to cold
temperatures and
precipitation

OSHA Cold Stress Guidance. In general,
proper rest, insulated layer clothing,
hydration, abundant rest, proper nutrition,
assessment of weather to prepare

Mechanical injury

Compromised steel
structure, heavy equipment,
suspended loads, mashing
or blunt force trauma

15^1 Likely Q Unknown
1 1 Possible O Unlikely

Primarily limited to workers
in exclusion zone and track
repair areas.

Safe distances, eye contact with operators,
backup alarms, boom radius avoidance,
pedestrian awareness and situational
awareness. Avoid suspended loads and
walking between operating machinery

Railroad collision

Pedestrians or vehicles
getting struck by train due
to track protection violation
or crossing.

1 1 Likely Q Unknown
1^1 Possible O Unlikely

All site workers working
near or crossing tracks in
transit

Follow track protection at all times.

Stop, look, listen when crossing tracks

Noise

Small engines, high rpm
vehicle or equipment
engines, etc.

1 1 Likely Q Unknown
1^1 Possible O Unlikely

Workers in work area near
generators, or dose in excess
of 85 dBA site wide

Hearing Protection with a Noise reduction
Rating of 35 dB or greater

Slips, trips, & falls

Uneven walking surfaces on
ballast stone. Potential for
falls into excavations prior
to being barricaded or
covered with fill.

15^1 Likely Q Unknown
1 1 Possible O Unlikely

All workers, especially entry
workers walking among
debris or traversing slick
uneven surfaces.

Three points of contact, good travel
pathway, good visible walking path; do
not traverse aggressive debris.

Site Health and Safety Plan: East Palestine Train Derailment

7

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Trenching hazards -
cave in

Excavation around railcar.
Workers entering to inspect
railcar during soil removal.
Workers entering to rig the
railcar for removal.

15^1 Likely Q Unknown
1 1 Possible O Unlikely

All workers in excavation
area

Trenching standards for safe work
practices

Cuts, abrasions

Sharp metal edges, rigging,
debris removal,
sharps/knives

15^1 Likely Q Unknown
1 1 Possible O Unlikely

Track workers in the
presence of railcar wreckage
or sharp debris. All
personnel using sharps

Leather gloves for handling sharp debris.
Avoid walking near wreckage or damaged
structures. Long-sleeve shirts and pants
capable of resisting abrasion. Safe
handling practices.

Foreign objects in

eyes

Airborne dust and debris,
mechanically generated fine
metals, un-combusted
aerosols,

15^1 Likely Q Unknown
1 1 Possible O Unlikely

All workers

Safety glasses. Awareness of ambient
dust from weather events or roadway
dusts. Limit dust-generating activities
without ventilation or water suppression

Electrical shock

Power chords and portable
electrical equipment will be
predominant sources.

1 1 Likely Q Unknown
1^1 Possible O Unlikely

Workers near affected
utilities, pumps, etc.
Workers using portable
generators or plugging
unplugging electrical
devices

Lockout/Tagout Procedures. De-
energized equipment must be confirmed
before performing work with shock
hazards. Caution when plugging and
unplugging electrical devices.
Maintenance of generators.

Vehicle/machinery
hazards

Blind spots, congested work
area, community air
monitoring/support/logistics

15^1 Likely Q Unknown
1 1 Possible O Unlikely

All workers

Seatbelts. No distracted driving. Obey
all municipal and state roadway laws.
Maintain constant awareness while
driving. Do not drive tired.

Rapid water

Fast flowing water in areas
of surface water or env
mgmt.

1 1 Likely Q Unknown
1^1 Possible O Unlikely

Workers near creeks or
runoff during flash floods

Avoid working near water exceeding 1.3
knots in flow velocity.

Inclimate Weather Procedures

Lightening

Please follow your employers or organizations lightening policy. At a minimum ensure a safe response to lightening within 10 miles to ensure safety of persons working outside

shelter

Severe Weather

Follow local weather alerts and warnings during anticipated severe weather. Consider the following:

• Avoid isolating workers in outdoor tasks when severe weather warnings are issued

• Muster personnel to a tornado shelter when tornado warnings are issued for the work site and staging areas.

• Assign personnel to evaluate weather regularly within each work team or task group.

• Seek shelter when a severe stonn is imminent regardless of the presence of tornado.

Site Health and Safety Plan: East Palestine Train Derailment

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3 Site Control

Zone description

Primary Characteristics

Exclusion Zone

• Mostly limited to the affected track areas, or other locations where prolonged chemical exposure is possible.

• Location where chemical exposure is likely and added safety precautions are necessary to avoid exposure.

• Engineering or administrative controls may be warranted. PPE greater than Level D will be determined as
needed to avoid worker exposure.

• Environmental monitoring should be performed until Exclusion Zone is no longer warranted based on removal.

• All entrants must abide by the protective measures and PPE criteria (when required) for the specified area of
work and the task-specific safety procedures assigned.

Contaminant Reduction Zone

• Perimeter boundary of Exclusion Zone, including frac tank staging areas, decontamination, and EZ entrance
locations.

• Purposed to reduce site contamination from migrating outside of EZ through site control and decontamination

• This zone is dynamic and will change regularly based on decontamination locations and evolution of remediation.

Support Zone

• All work areas outside of CRZ.

• General Site-Specific PPE will be required in the SZ.

• Muster locations have been designated in the SZ, please refer to the site control map for approved muster
locations located near the work site.

Operational Divisions:

Work Zone Description

Zone classification

1. Wreck site/Track Removal

Affected track from Pleasant St. eastward to derailment area, railcar staging on
north and south of track

M EZ ~ CRZ ~ SZ

2. Waste Management

Primary derailment area

~ EZ IE CRZ Kl SZ

3. Surface Water

Watersheds downstream and/or outside derailment area

~ EZ Kl CRZ Kl SZ

4. Surface Soil

Soil impacted areas outside derailment area

~ EZ Kl CRZ Kl SZ

5. Residential

Residences adjacent to derailment area and throughout affected community

~ EZ ~ CRZ M SZ

6. Community Engagement

USEPA Welcome Center on E. Main Street, East Palestine High School Auditorium

~ EZ ~ CRZ M SZ

Site Health and Safety Plan: East Palestine Train Derailment

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Site Control Map

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Scrapping Waste

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AreaJA^esjj

--—'ImiHcisd '

Waste Staging

: Water By pass•

Standby

Tanh Area '

:Wate*,Bypass<

AreagiBAO

Solidification/Excavation

[Siagll

yspioynliiil!

rsMgij

S tend by

¦^bouiniuiicnap
BAImpacted **
Waste Staging

[Wa'rtea

anifesting'

Ca^H

SciS!i::in(! 4

Hml

juBCar H
Scispiiinq 2

^BeaveTtG ountyl
jfeennsytvaniai

Strapping's

^Columbiana]
»*;c6"untyM
prWOKioll

Exclusion Zone - Drainage pipe

Contamination Reduction Zone

Support Zone

Decontamination

Traffic Checkpoiunt

Muster

DRAFT

Attorney-Client Privilege/Attorney Work Product/
Prepared at the Direction of Counsel

3/1/2023

Site Health and Safety Plan: East Palestine Train Derailment

10

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4 Communication Plan

Work Area:

Available Comms

Emergency Communication Procedures

All affected areas

X 2-way Radios
X Hand Signals
X Cell phone
X Air Horn

Emergency Signal

Short Air horn Blast: Attention all personnel
2 Horn Blast: Attention all personnel, controlled egress to SZ
Long Horn Blast: Emergency evacuation

Action

Cross-wind, then upwind to muster point



Hand Signal

Two hands placed on top of head

5 Required Training

~

HAZWOPER 24

Required for workers that:

1.	Are onsite occasionally for a specific limited task, and

•	Are unlikely exposed over permissible exposure limits and published exposure limits

2.	May enter a fully characterized contaminated area, and:

•	Are not at risk of exposure to site contaminants above the OSHA PELs,

•	Will not be wearing respiratory protection

~

HAZWOPER 40

Required for workers that:

1.	Are described as general site workers engaged in hazardous substance removal, and

2.	May be exposed to hazardous substances and associated health hazards

In addition to the 40 hr offsite training, workers must also achieve a minimum of 3 days field experience and work under the direct
supervision of a trained experienced supervisor.

~

Current 8 Hour Refresher

Required for all site workers, must be taken annually beginning the first year after completion of initial training.

~

HAZWOPER Supervisor

Those directly in control of responding personnel

~

First Aid/CPR

Certified first aid/CPR providers

Site Health and Safety Plan: East Palestine Train Derailment

11

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6 Medical Surveillance

Site-Specific
Requirements

Based on limited worker exposure to hazardous substances at or above the PELs or other published exposure limits (less than 30
days per year); limited use of respirators (less than 30 days per year); and the absence of an employee-staffed HAZMAT team, the
medical surveillance program required at this site is also limited. The site medical surveillance program provides that:

1.	workers assigned to tasks requiring the use of respirators receive medical examinations in accordance with 29 CFR
1910.13 4€ to ensure they are physically capable to perform the work and use the equipment,

2.	workers who could potentially be exposed to chemical contaminants at this site are covered by a medical protocol addressing
this exposure, and

3.	if a worker is injured, becomes ill, or develops signs or symptoms of possible over-exposure to hazardous substances or
health hazards, medical examinations are provided to that worker as soon as possible after the occurrence and as required by
the attending physician.

Medical examinations and procedures are performed by or under the supervision of a licensed physician and are provided to
employees free of cost, without loss of pay, and at a reasonable time and place. The need to implement a more comprehensive
medical surveillance program will be re-evaluated in the event of an over-exposure incident.

Site Medical Surveillance
Program Scope

All personnel who enter contaminated areas of this site are covered by the medical surveillance program. In addition, all workers
assigned to tasks requiring the use of respirators receive medical evaluations in accordance with 29 CFR 1910.134€ to ensure they
are physically capable to perform the work and use the equipment.

Substance-specific
Medical Surveillance
Requirements

29 CFR 1910.1017(k)

Applies for persons whose exposure exceeds the OSHA Action Level of 0.5 as 8-hour TWA for
vinyl chloride. Exceedance will be determined based on exposure badge sampling where
applicable.

Site Health and Safety Plan: East Palestine Train Derailment

12

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7 Personal Protective Equipment

General Level D
PPE for site
workers

CPC:

May include nitrile gloves, boot coverings

Hi-Viz Vest:

Should be worn at all times near roadways, railways or
in work area parking lots

Respiratory
Protection:

Chemical-specific, will be determined as
needed. Continuous air monitoring and site
action levels will determine.

Boots:

Must be steel toe and heel with pierce protective soles
and heels.

Hearing Protection:

Must be worn if noise levels are above 85 dBA.

Must meet ANSI S3.19-1974

Est Exp (dBA) = 85 dBA - [NRR x 50%]

Safety Glasses:

Dark shades are appropriate for full or partial sun. If
cloudy conditions exist or working at night, clear
safety glasses should be worn.

Must meet ANSI Z87.1

Hard Hat:

Required in work area. Not required in
community or other support zone locations and
beyond.

Must meet ANSI Z89.1

Fall Harness:

Fall-protection harness must be worn when working at
heights above 4 feet with no suitable guardrails or
other fall protection provisions (29 CFR 1926.501).
Must meet ANSI Z359

Gloves:

Designated glove fabric and type will be
determined if handling sampling material,
leather gloves if handling sharps.

FRC Coverall:

Required if working near fire, flame, or flash hazards.
Must meet NFPA 2113

Designated Levels of Personal Protection

Ops Division:

Work Area (e.g., EZ, CRZ, other):

Job Function:

Baseline Level of Protection

Wreck site/Track
Removal

Affected site along tracks

HAZMAT, track removal, soil remediation,
environmental sampling, track repair, liquids
removal, infrastructure

Waste Management

Frac tank staging, soil piles, EZ for
retrieval

Vac truck ops, transport, soil excavation,
stockpile management, truck loading,
environmental monitoring

Surface Water

Affected waterways, sulfur creek and
tributaries

Environmental sampling, water treatment,
light excavation, infrastructure, test well
installation

Surface Soil

Affected soil and land adjacent to site

Environmental sampling, soil treatment, test
well installation

Residential

At residences in affected community

Home inspections, residential cleaning,
wellness checks

Community
Engagement

USEPA Wellness Center, Townhall
meetings

Community interface personnel

1 Baseline level of protection should be understood as the starting point at which the work can be completed when risk of exposure is minimal or non-existent. Upgrades in PPE to
Level C should be considered if splash hazards or excessive soiling of contaminated materials exist. Upgrades in respiratory protection for vinyl chloride should only include
atmosphere-supplying respiratory protection (Level C not applicable).

Site Health and Safety Plan: East Palestine Train Derailment

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PPE Matrix3: Butyl acrylate

Conditions	PPE Level	Respirator	Dermal Protection









1

Suit:

Control measures first. Fire protective Level A Bunker
or FRC otherwise





Release rate:

Unknown or Uncontrolled





Risk of sudden release:

Unknown or High

Level A for
extensive
dermal contact
with high conc.
vapor

1

















1

















Suit:

Control measures first. Fire protective Level A
Bunker or FRC otherwise

Gloves:

Silver Shield ® if liquid contact is significant; NFPA
gloves otherwise













1

















Conditions

PPE Level

Respirator

Dermal Protection



> 2 ppm, but <100 ppm

1

C



Fire or Flash Risk |

A]

5R

Suit:





Gloves:

Level C is not recommended with significant fire risk

Release rate:

Known and insignificant

Special Instructions:

Boots:

Level C is not recommended with significant fire risk

Risk of sudden release:

Low



Non-fire hazard |

Skin contact w/ vapor:

Very low - intermittent



Cartridge:

PIOO/OV

Suit:



Skin contact w/ liquid:

Indirect, no splash

Style:

Full-face

Gloves & Boots:

Chemical - taped seams |

Conditions

PPE Level

Respirator

Dermal Protection



< 2 ppm

]

D

None
required

Fire or Flash Risk |

Suit:



Gloves:

NFPA gloves

Release rate:

None

Boots:

NFPA

Risk of sudden release:

Low

| Non-fire hazard |

Skin contact w/ vapor:

No vapor contact



Suit:



Skin contact w/ liquid:

No splash risk



1

NIOSH Emergency Response Safety and Health Database, Dupont Safe Spec™, Wiley Quick Selection Guide, 6th edition

Site Health and Safety Plan: East Palestine Train Derailment

14

-------
PPE Matrix4: Vinyl chloride

Conditions





Dermal Protection











Fire or Flash Risk |

Vinyl chloride

Unknown or > 10 ppm







Suit:

Control measures first. If cannot control: Fire-protective
Level A if liquid contact risk; Bunker gear otherwise





A

SCBA

Gloves:

Fire/chemical glove if liquid contact; NFPA otherwise

Release rate:

Unknown or Uncontrolled

A

Boots:

NFPA /chemical resistant

Risk of sudden release:

Unknown or High







Non-fire hazard |

Skin contact w/ vapor:

Greatest







Suit:

Chemical - encapsulating

Skin contact w/ liquid:

Greatest







Gloves &
Boots:

Chemical - taped at seams

Conditions

PPE Level

Respirator



Dermal Protection











Fire or Flash Risk |

Vinyl chloride

>10 ppm







Suit:

Control measures first. If cannot control: Fire-protective
Level B if liquid contact risk; Bunker gear otherwise











Gloves:

Fire/chemical glove if liquid contact; NFPA otherwise

Release rate:

Known and controlled

U

SCR A

Boots:

NFPA /chemical resistant

Risk of sudden release:

Moderate

D





Non-fire hazard |

Skin contact w/ vapor:

Moderate-low







Suit:

Chemical-hooded

Skin contact w/ liquid:

Direct, splash potential







Gloves &
Boots:

Chemical - taped seams

Conditions

PPE Level

Respirator



Dermal Protection











Fire or Flash Risk |

Vinyl chloride

> 1, but< 10 ppm



APR

Suit:

Level C is not recommended with significant fire risk









Gloves:

Level C is not recommended with significant fire risk

Release rate:

Known and insignificant

5

Special Instructions

Boots:

Level C is not recommended with significant fire risk

Risk of sudden release:

Low



Cartridge:

OV/AG; PI00

| Non-fire hazard |

Skin contact w/ vapor:

Very low - intermittent



Style:

Full-face

Suit:

Chemical-hooded

Skin contact w/ liquid:

Indirect, no splash



USE FOR ESCAPE ONLY

Gloves &
Boots:

Chemical - taped seams

Conditions

PPE Level

Respirator



Dermal Protection









Fire or Flash Risk |

Vinyl chloride

< 1 ppm





Suit:

FRC clothing





r^v

None

Gloves:

NFPA gloves

Release rate:

None

1 1

Boots:

NFPA

Risk of sudden release:

Low

ty

required

| Non-fire hazard |

Skin contact w/ vapor:

No vapor contact



Suit:

Long sleeves, reflective vest, safety glasses, hardhat |

Skin contact w/ liquid:

No splash risk







1

4	NIOSH Emergency Response Safety and Health Database, Dupont Safe Spec™, Wiley Quick Selection Guide, 6th edition

5	NIOSH does not recommend using full-face APR for VC. OSHA does permit using full-face APR in the VC standard but limits the maximum use concentration to 10 ppm (1910.1017(f)(3)(ii)).
Caution is warranted for use of APR due to the lack of supporting documentation by the three major respirator manufacturers. See APR changeout schedule on the following page.

Site Health and Safety Plan: East Palestine Train Derailment

15

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8 Decontamination

Decontamination Procedures

Personnel (Level A, B, C) Decontamination Procedures:

Personnel decon is primarily conducted as a boot wash procedure due to the limited use of chemical protective clothing beyond footwear. For chemical suit decontamination,
use the following procedure:

Station 1: Equipment Drop

Deposit equipment used on site (tools, sampling devices and monitoring instruments, radios, etc.) on plastic drop cloths. These items must be decontaminated or discarded
as waste prior to removal from the exclusion zone.

Station 2: Outer Boot and Outer Gannent Soap Wash

Scrub outer boots, outer gloves and/or splash suit with decontamination solution or detergent water. Rinse off using water.

Station 3: Outer Boot and Outer Gannent Rinse

Rinse off using water.

Emergency Decontamination Procedures:

Render first aid first unless contamination puts responders at risk. If such contamination exists, use a high-volume flush from water sources onsite. There is a HAZMAT fire
truck on site that can be used if flushing is necessary. Otherwise, first responders should don nitrile gloves when rendering first aid out of an abundance of caution.

Heavy Equipment Decontamination Procedures:

Truck, transport, and heavy machinery decontamination is located at Leake Oil Corp, on Taggart Rd. High pressure rinse is the primary method of decontamination to loosen
mud and debris from the wheels and soiled portions of the vehicle.

Sampling Equipment Decontamination Procedures:

Decontamination of equipment must be performed by using portable wash tubs, sprayers, and disposable scrub brushes. Any equipment that cannot be thoroughly
decontaminated along with the contents from the wash tub should be decontaminated with higher means such as high-pressure or high temperature with suitable solutions.

Decontamination Waste Disposal Procedures:

Decontamination waste must be segregated, characterized, and disposed of with similar appropriate waste streams generated by the response

Decontamination Equipment:

Location Stored On Site:

Plastic sheeting

Table, chairs, and tent (if possible)

Kiddie swimming pools

5-gallon pails and scrub brushes

Pump (hand or electric)

Water sprayer

Decontamination solution (detennined in SDS)

Sorbent materials (towels, boom, kitty litter)

Site Health and Safety Plan: East Palestine Train Derailment

-------
9 Environmental and Personal Monitoring

AIR MONITORING SUMMARY (common site air requirements)

Instrument Type:

Contaminant:

Frequency:

Action Level/Comments:

RAE Systems MultiRAE Pro

VOCs

As needed

Detection above 0.2 ppm requires assessment for vinyl chloride.

(PID)





Detection above 0.5, don respiratory protection or egress.

RAE Systems MultiRAE Pro (O2

Oxygen

Confined space work

< 19.5% or > 23.5% oxygen, evacuate area and re-evaluate

sensor)







RAE Systems MultiRAE Pro

Combustible range vapors and gases.

Periodic

> 10% of LEL (corrected) prompts work stoppage and personnel

(LEL sensor)

CO



egress

Detector Tubes

Vinyl chloride

As necessary to further evaluate

VC: 0.5 ppm, report detection - prepare for protective controls



Butyl acrylate

photo ionization detector

BA: 2.0 ppm, report detection & don APR for continued work

Drager XPID

Vinyl chloride

As necessary to further evaluate

VC: 0.5 ppm, report detection - prepare for protective controls



Butyl acrylate

photo ionization detector

BA: 2.0 ppm, report detection & don APR for continued work

Personal Monitoring Procedures

Chemical Exposure:

Assay 525 Organic Vapor Monitors (OVM) are utilized to measure workers 8-

hour TWA exposure for butyl acrylate and vinyl chloride. Workers will be notified of their

individual exposure per OSHA reporting criteria for personal sampling notification.



Butyl acrylate: analysis method is conducted per modified NIOSH 2537.





Vinyl chloride: analysis method is conducted per NIOSH 1007 method.





Inclement Weather Monitoring:

Severe weather alerts to be communicated for inclement weather; lightning stand down subject to division supervisor, stand down for 30 minutes for strikes within 10 mile radius

Heat/Cold Stress Monitoring:

Currently, the weather lacks extreme heat or cold temperatures. Supervisors are encouraged to monitor staff for wellness, employees are requested to report any symptoms.

Monitoring Instrument Maintenance and Calibration Methods:

Per manufacturer's recommendations

Delivery of Monitoring Records:

Keep records in a secure location

Norfolk Southern has employed CTEH (private contractor) to provide air monitoring on behalf of site workers and the community. USEPA is also
conducting environmental monitoring for worker and public health. Should you have questions or request air monitoring to support work operations,
contact NS or USEPA for assistance with onsite air monitoring resources.

Site Health and Safety Plan: East Palestine Train Derailment

17

-------
10 HYGIENE AND SANITATION

	Personnel Hygiene and Biological Provisions

Toilets:

Portable toilets have been located throughout the work site, primarily in the affected track work zones and frac tank staging.

•	All portable toilets must be maintained with a 10-person for 1-week maximum usage.

•	Portable toilets should be accompanied by a hand-wash station.

•	Portable toilets should be located away from break areas of food stations to reduce the potential for biological hazards.

•	Where necessary, adequate facilities should be provided for both men and women's usage needs.

Hand sanitizer is located throughout office work areas. Adequate supplies should be maintained to encourage continuous use to prevent the spread of illness.

Biological Waste Removal	

Portable toilet waste should be removed only by a qualified and reputable company whose contract maintains the provision of servicing on a 1-week frequency. Hand-wash
stations should also be serviced and have adequate supply of soap, water, and drying towels.	

Site Health and Safety Plan: East Palestine Train Derailment

18

-------
11 CONFINED SPACE PROCEDURES

Written Programs	

Any employer who allows employee entry into a permit space must develop and implement a written program for the space.

•	Implement necessary measures to prevent unauthorized entry; Identify and evaluate permit space hazards before allowing employee entry;

•	Test atmospheric conditions in the permit space before entry operations and monitor the space during entry; Perform appropriate testing for
the following atmospheric hazards in this sequence: oxygen, combustible gases or vapors, and toxic gases or vapors;

•	Establish and implement the means, procedures and practices to eliminate or control hazards necessary for safe permit space entry
operations;

•	Identify employee job duties;

•	Provide and maintain, at no cost to the employee, personal protective equipment and any other equipment necessary for safe entry and
require employees to use it;

•	Ensure that at least one attendant is stationed outside the permit space for the duration of entry operations;

•	Coordinate entry operations when employees of more than one employer are working in the permit space;

•	Implement appropriate procedures for summoning rescue and emergency services, and preventing unauthorized personnel from attempting
rescue;

•	Establish, in writing, and implement a system for the preparation, issue, use and cancellation of entry permits;

•	Review established entry operations annually and revise the permit space entry program as necessary; and

•	Implement the procedures that any attendant who is required to monitor multiple spaces will follow during an emergency in one or more of

	those spaces.	

Controlling Hazards

Means and procedures to eliminate or control hazards:

•	Acceptable entry conditions: 19.5 - 22.0% oxygen, 0% LEL, no contaminant above the OSHA PEL or site action levels

•	Isolate the permit space

•	Provide barriers

•	Verification of entry conditions using observation and properly functioning calibrated instrumentation

•	Purging, inertion, flushing, or ventilation of permit space.

Site Health and Safety Plan: East Palestine Train Derailment

19

-------
Equipment for Safe Entry

In addition to PPE:

•	Testing, monitoring, ventilating, communications, and lighting equipment

•	Barriers and shields

•	Ladders and retrieval devices

Entry Permits

Entry permits must include:

Name of permit space to be entered, authorized entrant(s), eligible attendants, and individuals authorized to be entry supervisors
Test results of space conditions
Name and signature who authorizes entry
Purpose of entry and known space hazards

Measures to be taken to isolate permit spaces and to eliminate or control space hazards
Name and telephone numbers of rescue personnel and emergency services and means to contact them
Date and authorized duration of entry
Acceptable entry conditions

Communication procedures and equipment to maintain contact during entry

Additional permits, such as for hot work, that have been issue authorizing work in the permit space
Special equipment and procedures, including PPE and alarm systems
Any additional information needed to ensure employee safety

Worker Training

Before the initial work assignment, the employer must provide proper training for all workers who are required to work in permit spaces. Additional training is
required when:

•	Job duties change

•	A change occurs in the permit space program or permit space operation presents any new hazard

•	An employee's job performance shows deficiencies

Assigned Duties

Site Health and Safety Plan: East Palestine Train Derailment

20

-------
Authorized entrant

•	Know space hazards, including information on the means of exposure, signs of symptoms, and consequences of exposure

•	Use appropriate PPE

•	Maintain communication with attendants as necessary to enable them to monitor the entrant's status and alert the entrant to evacuate when necessary

•	Exit from the permit space as soon as possible when:

o Ordered by the authorized person

o He or she recognizes the warning signs or symptoms of exposure
o A prohibited condition exists, or
o The alarm is activated

•	Alert attendant when a prohibited condition exists or when warning signs or symptoms of exposure exist
Attendant

•	Remain outside the permit space during entry operations unless relieved by another authorized attendant

•	Perform non-entry rescues when specified by the rescue procedure

•	Knowing existing and potential hazards

•	Maintain communication with and keep an accurate account of those workers entering the permit space

•	Order evacuation when:

o A prohibited condition exists

o A worker shows signs of physiological effects of hazard exposure
o An emergency outside the confined space exists
o The attendant cannot effectively and safely perform required duties

•	Summon rescue and other services during and emergency

•	Ensure that unauthorized people stay away from permit spaces

•	Inform authorized entrants and the entry supervisor if any unauthorized person enters the permit space

•	Perform no other duties that interfere with the attendant's primary duties

Entry Supervisor

•	Know space hazards including information on the mode of exposure, signs or symptoms and consequences

•	Verify emergency plans and specified entry conditions such as permits, tests, procedures, and equipment before allowing entry

•	Terminate entry and cancel permits when entry operations are completed or if a new condition exists

•	Verify that rescue services are available and that means of summoning them are operable

•	Take appropriate measures to remove unauthorized entrants

•	Ensure that entry operations remain consistent with the entry permit and that acceptable entry conditions are maintained
Rescue Service Personnel

•	Ensure responders are capable of responding to an emergency in a timely manner, qualified to perform such services, and trained in first aid and CPR.

Site Health and Safety Plan: East Palestine Train Derailment

21

-------
12 EMERGENCY RESPONSE

For Emergencies Contact

Agency

Nature of Emergency

Contact Number:

On-site EMT

First aid, initial emergency care, trauma care

911

Air Evac

Emergency, life-threatening, major trauma

911

Fire

Medical, criminal, and fire emergency

Onsite resources, 911

Police

Security, crime, suspicious behavior

911, NS police: (800) 453-2530

Emergency Medical Facility Name

East Liverpool City Hospital - Emergency Room

Emergency Medical Facility Location

425 W. 5th Street: (330) 385-7200

Non-Emergency Medical Facility Name

East Liverpool Hospital

Non-Emergency Medical Facility Location

425 W. 5th Street: (330) 385-7200

First Aid Location

Site vehicles

Fire Extinguisher Location

Site vehicles, heavy machinery

Emergency Notification Procedures

Places of Refuge

Emergency Decon and Evacuation

Site Security Measures

Notify site safety and then call
911 for paramedics. Phone
and/or verbal notification for
evacuation.

Hospital:

See above

Discern whether emergency care
is needed. If in doubt, proceed
to emergency medical facility or
contact 911.

Refuge locations vary, but egress
must be upwind/uphill in all
locations. Work crew supervisors
must account for all personnel
under their direction in the event of
evacuation or relocation. See
Refinery map section

Establish an area of refuge for
contaminated individuals ASAP

Establish the gross decon area using a
water source such as garden hoses, engine
lines or pump sprayers.

Spray individuals with copious amounts of
water to remove overt quantities of
contaminants.

Site security being provided
by local law enforcement.

Site Health and Safety Plan: East Palestine Train Derailment

22

-------
Automated External Defibrillator (AED) Locations:

Incident Command - Centenary United Methodist Church

40 S Market St, East Palestine, OH 44413

(Located on 2nd floor, CTEH/Arcadis Room, above sink)

Unified Command - EPA Command Post

42083 OH-344, Columbiana, OH 44408 - (2 AED locations)

EPA Command Connex / Command & General Staff Meeting (Doublewide)

Derailment Work Site Staging Area - CTEH Trailer

895 E Taggart St, East Palestine, OH 44413

(Located within green/white command trailer, at parking lot entrance)

EPA FOB - EPA START Trailer

1101 W Main St, East Palestine, OH 44413
(Located in EPA START Connex)

East Palestine City Park - Stored in truck with HEPACO Mgmt
https://maps.app.goo.gl/oWpnnmESowRUnNAi7Pg st=ic

(Staged at Park for aeration and remediation work activities; Ortenzio
Chiropractic Center Parking Lot)

Lordstown Tank Car Loading Operation

https://maps.app.goo.gl/G2LbRnhhLRK8iZMr8Pg st=ic

(Staged onsite for work activities)

Norfolk Southern Trailer in Work Area: Location Near Leake Oil, 1000 Taggart Road, East Palestine, OH 44413
httDs://maDs.aDD.20o.2l/aUluA2biozivKGPa9?2 st=ic

Site Health and Safety Plan: East Palestine Train Derailment

23

-------
East Liverpool City Hospital
425 W. 5th St,

East Liverpool, OH 43920
(330) 385-7200

from East Palestine, Ohio 44413

to East Liverpool City Hospital, 425 W 5th St East..

30 min (19.4 miles)	< ft

via OH-170 S

Fastest route now due to traffic conditions

East Palestine

Ohio 44413

>	Follow Walker Alley, N James St and E Main St to
OH-170S/S Market St

3 mln (0.7 mi)

>	Follow OH-170 S and US-30 E to Jackson St in East
Liverpool. Take the exit toward Downtown/E
Liverpool from US-30 E

26 mln (18.2 ml)

>	Drive to W 5th St

2 mln (0.5 ml)

East Liverpool City Hospital

425 W 5th St. East Liverpool, OH 43920

law
Tomahawk

Clarkson

Glenmooi

East Liverpool
City Hospital1

WellSvllle



® > Enon Valley

OP ^

()3) Wampum
New Beaver /s

Ellwood City

B

Winona

New Garden

listen

Hanoverton
Kensington

33 min

231 mit«

(5t5) Gavets

West Point

Summitville

Highlandtown
Wildlife Area

(im) Highlandtown

Mechanlcstown

Salineville

Waterrord

State'Game
! Lands
Number 285

^ 30 min W

g Inwi

Ohioville

BV MHfl

New GtMcc	Koppd

@>
Darlington

Big Beaver

Homewood

Beaver fails
New Brighton

Georgetown	*

Midland .

m

X

^ Kabuta

Beaver

„ Monacs

Aliquipp;

(m,	Hookstown

liondale WW&J*

fnchTroel/	—

MacArthur
independence

Site Health and Safety Plan: East Palestine Train Derailment

24

-------
HASP - Division: Derailment & Track Removal

Project: East Palestine Train Derailment Site

Location: East Palestine, OH	

Date Prepared: 3-20-2023	

Version: 2.0

Operational Period: 24 hours	

Operational Division: Derailment and Track Removal	

For Emergencies Contact: Site EMT and/or 911	

Scope: This condensed HASP is an operation-specific addendum to the East Palestine Train
Derailment site wide HASP. The content in this addendum is not intended to be comprehensive
but focused on health and safety components not specifically covered in the site-wide HASP. For
more inclusive content, please refer to the sitewide HASP.	

Operational Division HASP Addendum: Derailment and Track Removal

1

-------
Provides
comprehensive
safety analysis of
site-wide
operations in
accordance with
29 CFR 1910.120

Operational Division

f	>

•	Division-specific
safety analysis

•	Provides focused
safety planning
for division's
unique

environmental
characteristics

Operational Division
Risk Analysis

Establishes
primary tasks
Declares principle
hazard categories
Introduces control
measures for each
primary hazard

Field Based HASP
Tools

•Focused on task-based
hazard declaration and
control measures to be
used by field personnel
• Considered the "living"
portion of the HASP to
ensure all field
personnel receive vital
information

Operational Division HASP Addendum: Derailment and Track Removal

2

-------
2 Site Characterization & Hazards Overview

Major Tasks:

Risk
Category
(GAR)

Description and Location Where Task(s)/Operation(s) to be Performed

1. Railcar manipulations &
wrecking

46

Access construction; remove, stage, or deconstruct damaged railcars

2. HAZMAT

34

Transfer from railcar, vacuum liquids from spill, remove residue for scrap

3. Environmental Remediation

29

Soil [removal, handling/storage"!, Water [run-off control, storagel

4. Environmental Science

28

Industrial hygiene, public health, environmental (soil/water) impact

5. Railway Track

Vlaintenance

31

Railway workers removing track, and tasked with restoring track after excavation

Site Information

Roadways:

E Taggart Street, N Pleasant Drive, S Pleasant Drive

Waterways:

Topographical drainage,
creeks,

Facility Equipment:

Passing trains, tractor trailers (adj
businesses)

Railways:

NS

Heavy Machinery:

Excavator, front-end loader, dozer,
crane, mini-ex, vac truck, railway
maintenance equipment

Electrical Sources:

High voltage power line,
temp power, etc.

Pipelines:

Determine with utility

Gar Scale

Percentage

0-25

25-50

50-75

75-100

Risk

Slight

Possible

Substantial

Very High

Color

Green

Yellow

Amber

Red

Action

Possibly
Acceptable

Attention
Needed

Correction Needed

Discontinue/
Stop

Operational Division HASP Addendum: Derailment and Track Removal

3

-------
Additional Chemical Hazards

Added chemical

Anticipated source or product utilization description

Exposure Potential

Estimated Volume

Acronal

Used to break down butyl acrylate, topically applied to
soil when air monitoring determines above action level
during work activity

1^1 Likely Q Unknown
1 1 Possible O Unlikely

250-gallon tote

Reason for deviation from
HASP

This material was added as a control measure to reduce
airborne exposure from impacted soil, also to reduce

odor

Expected Interaction

1^1 Hourly O Daily Q Weekly O Once



Additional Physical Hazards

Added Hazard

Source of Hazard

Exposure Potential

Affected Workers

Grinding/metal work

Welding and grinding for track installation

1^1 Likely Q Unknown
1 1 Possible O Unlikely

Railway workers and
support contractors

Reason for deviation from
HASP

Welding not covered in Blue Plan

Expected Interaction

1 1 Hourly O Daily Q Weekly X Once

Operational Division HASP Addendum: Derailment and Track Removal

4

-------
3 Site Control

Zone description

Standard Operating Procedures

Exclusion Zone

• Check in and out of this zone at the EZ access locations.

• This area is off limits to non-authorized, or non-essential personnel during the response and mitigation
operations.

• All entrants must abide by the protective measures and PPE criteria (when required) for the specified area of
work and the task-specific safety procedures assigned.

Contaminant Reduction Zone

• Check in and out of this zone at the approved site entry locations.

• This area will include work activity conducted to support EZ operations. This area also includes decontamination
locations.

• This area is off limits to non-authorized, or non-essential personnel during response and mitigation operations.

Support Zone

• Access will be provided through approved site access locations, maintained by badge check-in and checkout.

• General Site-Specific PPE will be required in the SZ.

• Muster locations have been designated in the SZ, please refer to the site control map for approved muster
locations located near the work site.

Job Tasks:

Work Zone Description

Zone classification

1. Railcar manipulations &
wrecking

Primary derailment area, railcar staging on north track

X EZ ~ CRZ ~ SZ

2. HAZMAT

Primary derailment area

M EZ ~ CRZ ~ SZ

3. Environmental Remediation

Impacted track lanes, soil staging area, liquid management areas

~ EZ |EI CRZ |EI SZ

4. Environmental Monitoring

Throughout derailment and track restoration work area

M EZ M CRZ ~ SZ

5. Railway Track Maintenance

North and south track extents for excavation and track replacement

~ EZ M CRZ ~ SZ

Operational Division HASP Addendum: Derailment and Track Removal

-------
Site Control Map

Jdorth VC Impacted
Sa;i|j]'iin] vV.isk:

jTank*RanTO21

fslylB-61

[SMB-H1

vi.-ij.i.iiii.]

—Area,1A®j

— III'! i' ' .

""Wa9«?Stagim
jAKaTBgcT",

tWater Bypass!

iTanlflftfeai

•W ateT, Bypa ss j



[SMB[6]

[SlvlETll

[SMB?|

jTahkjFaf

[SMB-IH

IHareJIBoom Containment

¦: BeayeTtGountyl
I Pennsylvania!

[Coltjimbianai
County

IRolJlOtf"

Exclusion Zone - Drainage pipe

Contamination Reduction Zone

Support Zone

l;ink I Limi V

Decontamination

Traffic Checkpoiunt

Muster

DRAFT

Attorney-Client Privilege/Attorney Work Product/
Prepared at the Direction of Counsel

Map Date: 3/1 y2023

Operational Division HASP Addendum: Derailment and Track Removal

6

-------
4 Communication Plan

Work Area:

Available Comms

Emergency Communication Procedures

Derailment & Track Removal

X 2-way Radios
X Hand Signals
X Cell phone
X Air Horn

Emergency Signal

Short Air horn Blast: Attention all personnel

2 Horn Blast: Attention all personnel, controlled egress to

SZ

Long Horn Blast: Emergency evacuation

Action

Crosswind, then upwind to muster point



Hand Signal

Two hands placed on top of head

5 Personal Protective Equipment

Designated Levels of Personal Protection

Task:

Work Area (e.g., EZ, CRZ,
other):

Job Function:

Level of Protection:

1. Railcar

manipulations &
wrecking

EZ, CRZ

Removal of damaged railcars, staging, loading for
transport

aD bD cD dM

2. HAZMAT

EZ, CRZ

Control of railcar lading, transfer, mitigation of known
uncontrolled sources

aD bD cD dM

3. Environmental
Remediation

CRZ, SZ

Removal of impacted soils and liquids. Maintenance
of liquids storage, transport. Stockpile of waste soil

aD bD cD dM

4. Environmental
Science

EZ, CRZ, SZ

Ambient air monitoring, worker exposure, soil & water
testing

aD bD cD dM

5. Railway Track
Maintenance

CRZ, SZ

Removal of panels, replenishment of track bed
material, grading, track installation

aD bD cD dM

Operational Division HASP Addendum: Derailment and Track Removal

7

-------
6 Decontamination

	Decontamination Procedures	

Personnel (Level A, B, C) Decontamination Procedures:	

Decontamination of personnel is largely focused on boot wash to prevent contamination migration outside of EZ:

Station 1: Boot Wash/Scrub

Using available boot wash stations, remove heavy soils and mud with soap and brush.

Station 2: Rinse

Using secondary decon pool, rinse boots free of remaining soils and soap.

Emergency Decontamination Procedures:	

If exposure occurs, use the least aggressive but affective means to decon personnel before rendering first aid. If life saving means are necessary, dismiss decontamination unless a
greater hazard is posed to the attending first aid personnel. First aid personnel should use nitrile gloves or conduct localized decontamination to assess injured persons.

7 Environmental and Personal Monitoring

AIR MONITORING SUMMARY

Instrument Type:

Contaminant:

Frequency:

Action Level/Comments:

RAE Systems MultiRAE Pro (PID)

VOCs

As needed

Detection above 0.2 ppm requires assessment for vinyl
chloride.

Detection above 0.5, don respiratory protection or egress.

RAE Systems MultiRAE Pro (O2
sensor)

Oxygen

Confined space work

< 19.5% or > 23.5% oxygen, evacuate area and re-evaluate

RAE Systems MultiRAE Pro (LEL
sensor)

Combustible range vapors and gases,
CO

Periodic

> 10% of LEL (corrected) prompts work stoppage and
personnel egress

Detector Tubes

Vinyl chloride
Butyl acrylate

As necessary to further evaluate
photo ionization detector

VC: 0.5 ppm, report detection - prepare for protective controls
BA: 2.0 ppm, report detection & don APR for continued work

Drager XPID

Vinyl chloride
Butyl acrylate

As necessary to further evaluate
photo ionization detector

VC: 0.5 ppm, report detection - prepare for protective controls
BA: 2.0 ppm, report detection & don APR for continued work

Personal Monitoring Procedures

Chemical Exposure:

Assay 525 Organic Vapor Monitors (OVM) are utilized to measure workers 8-hour TWA exposure for butyl acrylate and vinyl chloride. Workers will be notified of their individual
exposure per OSHA reporting criteria for personal sampling notification.

Butyl acrylate: analysis method is conducted per modified NIOSH 2537.
Vinyl chloride: analysis method is conducted per NIOSH 1007 method.





Operational Division HASP Addendum: Derailment and Track Removal

8

-------
8 EMERGENCY RESPONSE (AED Locations, See Blue Plan)

Agency

Nature of Emergency

Contact Number:

On-site EMT

First aid, initial emergency care, trauma care

911

Air Evac

Emergency, life-threatening, major trauma

911

Fire

Medical, criminal, and fire emergency

Onsite resources, 911

Police

Security, crime, suspicious behavior

911, NS police: (800) 453-2530

Emergency Medical Facility Name

East Liverpool City Hospital - Emergency Room

Emergency Medical Facility Location

425 W. 5th Street: (330) 385-7200

Non-Emergency Medical Facility Name

East Liverpool Hospital

Non-Emergency Medical Facility Location

425 W. 5th Street: (330) 385-7200

First Aid Location

Site vehicles

Fire Extinguisher Location

Site vehicles, heavy machinery

Emergency Notification Procedures

Places of Refuge

Emergency Decon and Evacuation

Site Security Measures

Notify site safety and then call
911 for paramedics. Phone
and/or verbal notification for
evacuation.

Hospital:

See above

Discern whether emergency care
is needed. If in doubt, proceed
to emergency medical facility or
contact 911.

Refuge locations vary, but egress
must be upwind/uphill in all
locations. Work crew supervisors
must account for all personnel
under their direction in the event of
evacuation or relocation. See
Refinery map section

Establish an area of refuge for
contaminated individuals ASAP

Establish the gross decon area using a
water source such as garden hoses, engine
lines or pump sprayers.

Spray individuals with copious amounts of
water to remove overt quantities of
contaminants.

Site security being provided
by local law enforcement.

Operational Division HASP Addendum: Derailment and Track Removal

9

-------
East Liverpool City Hospital
425 W. 5th St,

East Liverpool, OH 43920
(330) 385-7200

from East Palestine, Ohio 44413

to East Liverpool City Hospital, 425 W 5th St, East

30 min (19.4 miles)	£

via OH-170S

Fastest route now due to traffic conditions

East Palestine

Ohio 44413

>	Follow Walker Alley, N James St and E Main St to
OH-170 S/S Market St

3 min (0.7 mi)

>	Follow OH-170 S and US-30 E to Jackson St in East
Liverpool. Take the exit toward Downtown/E
Liverpool from US-30 E

26 mm (18.2 ml)

>	Drive to W 5th St

2 mm (0 5 ml)

East Liverpool City Hospital

425 W 5th SI East Liverpool, OH 43920

lake
Tomahawk

Clarttson

Glenmoot

East Liverpool
City Hospital1

Wellsville

¦ -r" 'j— \?:j rcinsuuiy h

Willow Grove

©
Wmona

NewGatden

Leetonia

© '
Columbiana

<3 - »,	H

0 '



o<

Unity >

@ > Enon Valley

(is?) Wampum
New Beaver ^

State Game1
• Lands,
Niirhber'285

Hanoverton
Kensington

(STS) Gaveis

Sumirrttville

Highlandtown
Wiltiiife Area

(Jm) Highlandtown



Mechaniestown

Saimeville

vva:e'ford

Q A 33 min

231m«H |

'"4

^ 30 min

!9 5mtl«s

55> Georgetown ¦

hI V rQ

New Galilee	Koppel

Ellwood City

®)
Darlington

Homewood

8eaver Falls
New Brighton

West Point
¦© - ©

MgM

Monaca

®C,K

industry

Jfj8 p

Kabuta

[Midland

Aiiguipp;

@	Hookstown

® 1

Rhiei&*lfl.

irondale VelioWtieek

MacArlhu'

%

independence

Operational Division HASP Addendum: Derailment and Track Removal

10

-------
HASP - Division: Waste Management

Project: East Palestine Train Derailment Site

Location: East Palestine, OH	

Date Prepared: 3-23-2023	

Version: 2.0

Operational Period: 7-day	

Operational Division: Waste Management	

For Emergencies Contact: Site EMT and/or 911	

Scope: This condensed HASP is an operation-specific addendum to the East Palestine Train
Derailment site wide HASP. The content in this addendum is not intended to be comprehensive
but focused on health and safety components not specifically covered in the site-wide HASP. For
more inclusive content, please refer to the sitewide HASP.	

Operational Division HASP Addendum: Waste Management

1

-------
Provides
comprehensive
safety analysis of
site-wide
operations in
accordance with
29 CFR 1910.120

Operational Division

Division-specific
safety analysis
Provides focused
safety planning
for division's
unique

environmental
characteristics

Operational Division
Risk Analysis

Establishes
primary tasks
Declares principle
hazard categories
Introduces control
measures for each
primary hazard

Field Based HASP
Tools

•Focused on task-based
hazard declaration and
control measures to be
used by field personnel
• Considered the "living"
portion of the HASP to
ensure all field
personnel receive vital
information

Operational Division HASP Addendum: Waste Management

2

-------
2 Site Characterization & Hazards Overview

Major Tasks: Waste Management
- Liquid/Vapor Extraction

Risk
Category
(GAR)

Description and Location Where Task(s)/Operation(s) to be Performed

1. Water Treatment (HEPACO)

Pleasant St and Railroad intersection, along creek beds, at water treatment plant. Water
aeration with compressors and air knifing in creeks. At Pleasant and the railroad water
treatment through filtration into the large storage tanks

2. Vapor and Liquid Product
Recovery (HEPACO)

In the work zone and containments for lay down yards. HEP ACO will recover liquid and
vapor from to keep liquid level below containment and out of work area

3. Lordstown Tank C ar
Loading (SPSI)

NS Lordstown rail yard. SPSI contracted 18-wheeler tank trucks discharging to tank rail cars

4. Frac. Tank Farm Tank Truck
Loading (SPSI)

Frac. Tank farms 3,5, and 6. SPSI connecting to frac tanks to load the vac trucks and or 18-
wheeler tank trucks for transportation to a disposal location.

5. Frac. Tank Fan
Discharge (HE

n Vac Truck
PACO)

Tank farms 3,5, and 6. HEP ACO is connecting to dedicated frac tanks to discharge collected
liquid and vapor.

Site Information

Roadways:

E Taggart Street, N Pleasant Drive, S Pleasant Drive, Lordstown, and surrounding roadways

Waterways:

Topographical drainage,
creeks,

Facility Equipment:

Passing trains, tractor trailers (adj
businesses)

Railways:

Heavy Machinery:

Excavator, front-end loader, dozer,
crane, mini-ex, vac truck, railway
maintenance equipment

Electrical Sources:

High voltage power line,
temp power, etc.

Pipelines:

Determine with utility

Gar Scale

Percentage

0-25

25-50

50-75

75-100

Risk

Slight

Possible

Substantial

Very High

Color

Green

Yellow

Amber

Red

Action

Possibly
Acceptable

Attention
Needed

Correction Needed

Discontinue/
Stop

Operational Division HASP Addendum: Waste Management

-------
Major Tasks: Waste Management
- Soil Removal/Recovery

Risk
Category
(GAR)

Description and Location Where Task(s)/Operation(s) to be Performed

1. Work Zone Roll Off
Loading (HEPACO)

42

In work zone, long reach excavators loading contaminated soil into roll off dumpsters.

2. Roll Off Staging - truck
loading (HEPACO and
SPSI)

34

Tank farm 5 and 6, HEPACO is loading empty roll offs to take to work area. SPSI loading full
roll offs to dispose of contaminated debris.

3. Roll Off Staging - truck
unloading (HEPACO and
SPSI)

32

Tank farms 5 and 6. HEPACO is unloading full roll offs. SPSI is unloading clean empty roll
offs.

Site Information

Roadways:

E Taggart Street, N Pleasant Drive, S Pleasant Drive, Lordstown, and surrounding roadways

Waterways:

Topographical drainage,
creeks,

Facility Equipment:

Passing trains, tractor trailers (adj
businesses)

Railways:

NS

Heavy Machinery:

Excavator, front-end loader, dozer,
crane, mini-ex, vac truck, railway
maintenance equipment

Electrical Sources:

High voltage power line,
temp power, etc.

Pipelines:

Determine with utility

Gar Scale

Percentage

0-25

25-50

50-75

75-100

Risk

Slight

Possible

Substantial

Very High

Color

Green

Yellow

Amber

Red

Action

Possibly
Acceptable

Attention
Needed

Correction Needed

Discontinue/
Stop

Operational Division HASP Addendum: Waste Management

4

-------
Additional Chemical Hazards

Added chemical

Anticipated source or product utilization description

Exposure Potential

Estimated Volume

Acronal

Used to break down butyl acrylate, topically applied to
soil when air monitoring determines above action level
during work activity

1^1 Likely Q Unknown
1 1 Possible O Unlikely

250-gallon tote

Reason for deviation from
HASP

This material was added as a control measure to reduce
airborne exposure from impacted soil, also to reduce

odor

Expected Interaction

1^1 Hourly O Daily Q Weekly O Once



Additional Physical Hazards

Added Hazard

Source of Hazard

Exposure Potential

Affected Workers

Inclement weather

Strong winds and lightning strikes; follow employers
inclement weather stand down protocol if working
outdoors or on elevated surfaces

1 1 Likely O Unknown
1^1 Possible O Unlikely

Workers and support
contractors

Reason for deviation from
HASP

Inclement weather with strong winds, not covered in
Blue Plan

Expected Interaction

1 1 Hourly O Daily Q Weekly X Once

Operational Division HASP Addendum: Waste Management

5

-------
3 Site Control

Zone description

Standard Operating Procedures

Exclusion Zone

• Check in and out of this zone at the EZ access locations.

• This area is off limits to non-authorized, or non-essential personnel during the response and mitigation
operations.

• All entrants must abide by the protective measures and PPE criteria (when required) for the specified area of
work and the task-specific safety procedures assigned.

Contaminant Reduction Zone

• Check in and out of this zone at the approved site entry locations.

• This area will include work activity conducted to support EZ operations. This area also includes decontamination
locations.

• This area is off limits to non-authorized, or non-essential personnel during response and mitigation operations.

Support Zone

• Access will be provided through approved site access locations, maintained by badge check-in and checkout.

• General Site-Specific PPE will be required in the SZ.

• Muster locations have been designated in the SZ, please refer to the site control map for approved muster
locations located near the work site.

Job Tasks: Waste Management -
Liquid/Vapor Extraction

Work Zone Description

Zone classification

1. Water Treatment (HEPACO)

Pleasant St and Railroad intersection, along creek beds, at water treatment
plant. Water aeration with compressors and air knifing in creeks. At Pleasant
and the railroad water treatment through filtration into the large storage tanks

~ EZ M CRZ X SZ

2. Vapor and Liquid Product
Recovery (HEPACO)

In the work zone and containments for lay down yards. HEP ACO will
recover liquid and vapor from to keep liquid level below containment and
out of work area

~ EZ M CRZ X SZ

3. Lordstown Tank Car Loading
(SPSI)

NS Lordstown rail yard. SPSI contracted 18-wheeler tank trucks discharging
to tank rail cars

~ EZ M CRZ X SZ

4. Frac. Tank Farm Tank Truck
Loading (SPSI)

Frac. Tank farms 3,5, and 6. SPSI connecting to frac tanks to load the vac
trucks and or 18-wheeler tank trucks for transportation to a disposal location.

~ EZ M CRZ X SZ

5. Frac. Tank Farm Vac Truck
Discharge (HEPACO)

Tank farms 3,5, and 6. HEP ACO is connecting to dedicated frac tanks to
discharge collected liquid and vapor.

~ EZ M CRZ X SZ

Operational Division HASP Addendum: Waste Management

-------
Job Tasks: Waste Management -
Soil Removal/Recovery

Work Zone Description

Zone classification

6. Work Zone Roll Off Loading
(HEPACO)

In work zone, long reach excavators loading contaminated soil into roll off
dumpsters.

~ EZ M CRZ X SZ

7. Roll Off Staging - truck loading
(HEPACO and SPSI)

Tank farm 5 and 6, HEPACO is loading empty roll offs to take to work area.
SPSI loading full roll offs to dispose of contaminated debris.

~ EZ M CRZ X SZ

8. Roll Off Staging - truck

unloading (HEPACO and SPSI)

Tank farms 5 and 6. HEPACO is unloading full roll offs. SPSI is unloading
clean empty roll offs.

~ EZ M CRZ X SZ

Operational Division HASP Addendum: Waste Management

7

-------
Site Control Map

Jdorth VC Impacted
Sa;i|j]'iin] vV.isk:

jTank*RanTO21

fslylB-61

[SMB-H1

vi.-ij.i.iiii.]

—Area,1A®j

— III'! i' ' .

""Wa9«?Stagim
jAKaTBgcT",

tWater Bypass!

iTanlflftfeai

•W ateT, Bypa ss j



[SMB[6]

[SlvlETll

[SMB?|

jTahkjFaf

[SMB-IH

IHareJIBoom Containment

¦: BeayeTtGountyl
I Pennsylvania!

[Coltjimbianai
County

IRolJlOtf"

Exclusion Zone - Drainage pipe

Contamination Reduction Zone

Support Zone

l;ink I Limi V

Decontamination

Traffic Checkpoiunt

Muster

DRAFT

Attorney-Client Privilege/Attorney Work Product/
Prepared at the Direction of Counsel

Map Date: 3/1 y2023

Operational Division HASP Addendum: Waste Management

8

-------
4 Communication Plan

Work Area:

Available Comms

Emergency Communication Procedures

Waste Management: Liquid/Vapor
Extraction & Soil Removal/Recovery

X 2-way Radios
X Hand Signals
X Cell phone
X Air Horn

Emergency Signal

Short Air horn Blast: Attention all personnel

2 Horn Blast: Attention all personnel, controlled egress to

SZ

Long Horn Blast: Emergency evacuation

Action

Crosswind, then upwind to muster point





Hand Signal

Two hands placed on top of head

5 Personal Protective Equipment

Designated Levels of Personal Protection

Job Tasks: Waste
Management
l iquid Vapor Extraction

Work Area (e.g., EZ, CRZ,
other):

Work Zone Description:

Level of Protection:

1. Water Treatment
(HEPACO)

CRZ, SZ

Pleasant St and Railroad intersection, along
creek beds, at water treatment plant. Water
aeration with compressors and air knifing in
creeks. At Pleasant and the railroad water
treatment through filtration into the large
storage tanks.

aD

bD

cD

dEI

2. Vapor and Liquid
Product Recovery
(HEPACO)

CRZ, SZ

In the work zone and containments for lay
down yards. HEPACO will recover liquid
and vapor from to keep liquid level below
containment and out of work area.

aD

bD

cD

dEI

3. Lordstown Tank Car
Loading (SPSI)

CRZ, SZ

NS Lordstown rail yard. SPSI contracted 18-
wheeler tank trucks discharging to tank cars.

aD

bD

cD

dEI

4. Frac. Tank Farm
Tank Truck Loading
(SPSI)

CRZ, SZ

Frac. Tank farms 3,5, and 6. SPSI connecting
to frac tanks to load the vac trucks and or 18-
wheeler tank trucks for transportation to a
disposal location.

aD

bD

cD

dEI

Operational Division HASP Addendum: Waste Management

9

-------
5. Frac. Tank Farm
Vac Truck
Discharge
(HEPACO)

CRZ, SZ

Tank farms 3,5, and 6. HEPACO is
connecting to dedicated frac tanks to
discharge collected liquid and vapor.

aD bD cD dM

Job Tasks: Waste
Management - Soil
Removal/Recovery

Work Area (e.g., EZ, CRZ,
other):

Work Zone Description:

Level of Protection:

6. Work Zone Roll Off
Loading (HEPACO)

CRZ, SZ

In work zone, long reach excavators loading
contaminated soil into roll off dumpsters.

aD bD cD dM

7. Roll Off Staging -
truck loading
(HEPACO and
SPSI)

CRZ, SZ

Tank farm 5 and 6, HEPACO is loading
empty roll offs to take to work area. SPSI
loading full roll offs to dispose of
contaminated debris.

aD bD cD dM

8. Roll Off Staging -
truck unloading
(HEPACO and
SPSI)

CRZ, SZ

Tank farms 5 and 6. HEPACO is unloading
full roll offs. SPSI is unloading clean empty
roll offs.

aD bD cD dM

6 Decontamination

Decontamination Procedures

Personnel (Level A, B, C) Decontamination Procedures:

Decontamination of personnel is largely focused on boot wash to prevent contamination migration outside of EZ:

Station 1: Boot Wash/Scrub

Using available boot wash stations, remove heavy soils and mud with soap and brush.

Station 2: Rinse

Using secondary decon pool, rinse boots free of remaining soils and soap.

Emergency Decontamination Procedures:

If exposure occurs, use the least aggressive but affective means to decon personnel before rendering first aid. If life saving means are necessary, dismiss decontamination unless a
greater hazard is posed to the attending first aid personnel. First aid personnel should use nitrile gloves or conduct localized decontamination to assess injured persons.

Operational Division HASP Addendum: Waste Management

-------
7 Environmental and Personal Monitoring

AIR MONITORING SUMMARY

Instrument Type:

Contaminant:

Frequency:

Action Level/Comments:

RAE Systems MultiRAE Pro (PID)

VOCs

As needed

Detection above 0.2 ppm requires assessment for vinyl
chloride.

Detection above 0.5, don respiratory protection or egress.

RAE Systems MultiRAE Pro (O2
sensor)

Oxygen

Confined space work

< 19.5% or > 23.5% oxygen, evacuate area and re-evaluate

RAE Systems MultiRAE Pro (LEL
sensor)

Combustible range vapors and gases,
CO

Periodic

> 10% of LEL (corrected) prompts work stoppage and
personnel egress

Detector Tubes

Vinyl chloride
Butyl acrylate

As necessary to further evaluate
photo ionization detector

VC: 0.5 ppm, report detection - prepare for protective controls
BA: 2.0 ppm, report detection & don APR for continued work

Drager XPID

Vinyl chloride
Butyl acrylate

As necessary to further evaluate
photo ionization detector

VC: 0.5 ppm, report detection - prepare for protective controls
BA: 2.0 ppm, report detection & don APR for continued work

Personal Monitoring Procedures

Chemical Exposure:

Assay 525 Organic Vapor Monitors (OVM) are utilized to measure workers 8-hour TWA exposure for butyl acrylate and vinyl chloride. Workers will be notified of their individual
exposure per OSHA reporting criteria for personal sampling notification.

Butyl acrylate: analysis method is conducted per modified NIOSH 2537.
Vinyl chloride: analysis method is conducted per NIOSH 1007 method.





8 EMERGENCY RESPONSE (AED Locations, See Blue Plan)

Agency

Nature of Emergency

Contact Number:

On-site EMT

First aid, initial emergency care, trauma care

911

Air Evac

Emergency, life-threatening, major trauma

911

Fire

Medical, criminal, and fire emergency

Onsite resources, 911

Police

Security, crime, suspicious behavior

911, NS police: (800) 453-2530

Emergency Medical Facility Name

East Liverpool City Hospital - Emergency Room

Emergency Medical Facility Location

425 W. 5th Street: (330) 385-7200

Non-Emergency Medical Facility Name

East Liverpool Hospital

Non-Emergency Medical Facility Location

425 W. 5th Street: (330) 385-7200

Operational Division HASP Addendum: Waste Management

11

-------
First Aid Location

Fire Extinguisher Location

Site vehicles

Site vehicles, heavy machinery

Emergency Notification Procedures

Places of Refuge

Emergency Decon and Evacuation

Site Security Measures

Notify site safety and then call
911 for paramedics. Phone
and/or verbal notification for
evacuation.

Hospital:

See above

Discern whether emergency care
is needed. If in doubt, proceed
to emergency medical facility or
contact 911.

Refuge locations vary, but egress
must be upwind/uphill in all
locations. Work crew supervisors
must account for all personnel
under their direction in the event of
evacuation or relocation. See
Refinery map section

Establish an area of refuge for
contaminated individuals ASAP

Establish the gross decon area using a
water source such as garden hoses, engine
lines or pump sprayers.

Spray individuals with copious amounts of
water to remove overt quantities of
contaminants.

Site security being provided
by local law enforcement.

Operational Division HASP Addendum: Waste Management

12

-------
East Liverpool City Hospital
425 W. 5th St,

East Liverpool, OH 43920
(330) 385-7200

from East Palestine, Ohio 44413

to East Liverpool City Hospital, 425 W 5th St, East

30 min (19.4 miles)	£

via OH-170S

Fastest route now due to traffic conditions

East Palestine

Ohio 44413

>	Follow Walker Alley, N James St and E Main St to
OH-170 S/S Market St

3 min (0.7 mi)

>	Follow OH-170 S and US-30 E to Jackson St in East
Liverpool. Take the exit toward Downtown/E
Liverpool from US-30 E

26 mm (18.2 ml)

>	Drive to W 5th St

2 mm (0 5 ml)

East Liverpool City Hospital

425 W 5th SI East Liverpool, OH 43920

lake
Tomahawk

Clarttson

Glenmoot

East Liverpool
City Hospital1

Wellsville

¦ -r" 'j— \?:j rcinsuuiy h

Willow Grove

©
Wmona

NewGatden

Leetonia

© '
Columbiana

<3 - »,	H

0 '



o<

Unity >

@ > Enon Valley

(is?) Wampum
New Beaver ^

State Game1
• Lands,
Niirhber'285

Hanoverton
Kensington

(STS) Gaveis

Sumirrttville

Highlandtown
Wiltiiife Area

(Jm) Highlandtown



Mechaniestown

Saimeville

vva:e'ford

Q A 33 min

231m«H |

'"4

^ 30 min

!9 5mtl«s

55> Georgetown ¦

hI V rQ

New Galilee	Koppel

Ellwood City

®)
Darlington

Homewood

8eaver Falls
New Brighton

West Point
¦© - ©

MgM

Monaca

®C,K

industry

Jfj8 p

Kabuta

[Midland

Aiiguipp;

@	Hookstown

® 1

Rhiei&*lfl.

irondale VelioWtieek

MacArlhu'

%

independence

Operational Division HASP Addendum: Waste Management

13

-------
HASP - Division: Surface Water

Project: East Palestine Train Derailment Site

Location: East Palestine, OH	

Date Prepared: 3-23-2023	

Version: 2.0

Operational Period: 7-day	

Operational Division: Surface Water	

For Emergencies Contact: Site EMT and/or 911	

Scope: This condensed HASP is an operation-specific addendum to the East Palestine Train
Derailment site wide HASP. The content in this addendum is not intended to be comprehensive
but focused on health and safety components not specifically covered in the site-wide HASP. For
more inclusive content, please refer to the sitewide HASP.	

Operational Division HASP Addendum: Surface Water

1

-------
Operational Division Risk Analysis
& Control Development

Division
Hazard
Analysis

Provides
comprehensive
safety analysis of
site-wide
operations in
accordance with
29 CFR 1910.120

Operational Division

f	>

•	Division-specific
safety analysis

•	Provides focused
safety planning
for division's
unique

environmental
characteristics

Operational Division
Risk Analysis

Establishes
primary tasks
Declares principle
hazard categories
Introduces control
measures for each
primary hazard

Field Based HASP
Tools

•Focused on task-based
hazard declaration and
control measures to be
used by field personnel
• Considered the "living"
portion of the HASP to
ensure all field
personnel receive vital
information

Operational Division HASP Addendum: Surface Water

2

-------
2 Site Characterization & Hazards Overview

Major Tasks:

Risk
Category
(GAR)

Description and Location Where Task(s)/Operation(s) to be Performed

1. Traffi c / Roadway
Navigation

28

Roadway navigation and community travel; parking, pedestrians, animals

2. Environmental Sampling -
Vessel Over Water / Deep
Water (PFD required)

26

Surface water sampling in locations with deeper and faster moving water; 7 locations at Little
Beaver Creek and further south, W005, W006, W007, W008, WO 17, WO 18, WO 19

3. Environmental Sampling -
Work Area

19

Work area surface water sampling locations; 4 locations, W014, W015, W016, W020

4. Environmental Sampling -
Community

17

Water sampling at strategic waterway locations throughout the community setting

Site Information

Roadways:

All Roadways Surrounding East Palestine, Columbiana, & south to East Liverpool

Waterways:

Topographical drainage,
creeks, swift moving
waterways (PFDs req.)

Facility Equipment:

Passing trains, tractor trailers (adj
businesses)

Railways:

NS

Heavy Machinery:

Dump trucks, Frac Tanks, Vac truck,
railway maintenance equipment

Electrical Sources:

High voltage power line,
temp power, etc.

Pipelines:

Determine with utility

Gar Scale

Percentage

0-25

25-50

50-75

75-100

Risk

Slight

Possible

Substantial

Very High

Color

Green

Yellow

Amber

Red

Action

Possibly
Acceptable

Attention
Needed

Correction Needed

Discontinue/
Stop

Operational Division HASP Addendum: Surface Water

3

-------
Additional Chemical Hazards

Added chemical

Anticipated source or product utilization description

Exposure Potential

Estimated Volume

HC1 preservative contained
within water sampling media

Required for laboratory analysis, Methods 8260 & 1664;
generally safe when appropriately handled, stored, and
secured (special care with glass jars)

1 1 Likely O Unknown
1^1 Possible O Unlikely

5mL HC1
preservative
contained in 1L
Amber sample jar

0.5mL HC1
preservative
contained in 40mL
VOA vial



Additional Physical Hazards

Added Hazard

Source of Hazard

Exposure Potential

Affected Workers

Slips, trips, and falls

Uneven surfaces, steps, slick surfaces (mud/wet), yards,
well locations

1^1 Likely Q Unknown
1 1 Possible O Unlikely

Community workers
and support
contractors

Aggressive residents/pets

Residential engagement, property access, entering
homes for testing

1 1 Likely ^ Unknown
1 1 Possible O Unlikely

Community workers
and support
contractors

Vehicle/traffic hazards

Distracted driving, increased traffic from response, blind
spots, pedestrians, deer, low light, varying weather
conditions

1 1 Likely O Unknown
1^1 Possible O Unlikely

Community workers
and support
contractors

Reason for deviation from
HASP

Blue Plan is specific to work area; this covers residential

Expected Interaction

1^1 Hourly O Daily Q Weekly O Once

Operational Division HASP Addendum: Surface Water

4

-------
3 Site Control

Zone description

Standard Operating Procedures

Exclusion Zone

• Check in and out of this zone at the EZ access locations.

• This area is off limits to non-authorized, or non-essential personnel during the response and mitigation
operations.

• All entrants must abide by the protective measures and PPE criteria (when required) for the specified area of
work and the task-specific safety procedures assigned.

Contaminant Reduction Zone

• Check in and out of this zone at the approved site entry locations.

• This area will include work activity conducted to support EZ operations. This area also includes decontamination
locations.

• This area is off limits to non-authorized, or non-essential personnel during response and mitigation operations.

Support Zone

• Access will be provided through approved site access locations, maintained by badge check-in and checkout.

• General Site-Specific PPE will be required in the SZ.

• Muster locations have been designated in the SZ, please refer to the site control map for approved muster
locations located near the work site.

Job Tasks:

Work Zone Description

Zone classification

1. Traffic / Roadway Navigation

Roadway navigation and community travel; parking, pedestrians, animals

~ EZ ~ CRZ E SZ

2. Environmental Sampling -
Vessel Over Water / Deep
Water (PFD required)

Surface water sampling in locations with deeper and faster moving water; 7
locations at Little Beaver Creek and further south, W005, W006, W007,
W008, WO 17, WO 18, WO 19

~ EZ ~ CRZ X SZ

3. Environmental Sampling -
Work Area

Work area surface water sampling locations; 4 locations, W014, W015,
WO 16, W020

~ EZ M CRZ X SZ

4. Environmental Sampling -
Community

Water sampling at strategic waterway locations throughout the community
setting

~ EZ ~ CRZ X SZ

Operational Division HASP Addendum: Surface Water

-------
Site Control Map

Jdorth VC Impacted
Sa;i|j]'iin] vV.isk:

jTank*RanTO21

fslylB-61

[SMB-H1

vi.-ij.i.iiii.]

—Area,1A®j

— III'! i' ' .

""Wa9«?Stagim
jAKaTBgcT",

tWater Bypass!

iTanlflftfeai

•W ateT, Bypa ss j



[SMB[6]

[SlvlETll

[SMB?|

jTahkjFaf

[SMB-IH

IHareJIBoom Containment

¦: BeayeTtGountyl
I Pennsylvania!

[Coltjimbianai
County

IRolJlOtf"

Exclusion Zone - Drainage pipe

Contamination Reduction Zone

Support Zone

l;ink I Limi V

Decontamination

Traffic Checkpoiunt

Muster

DRAFT

Attorney-Client Privilege/Attorney Work Product/
Prepared at the Direction of Counsel

Map Date: 3/1 y2023

Operational Division HASP Addendum: Surface Water

6

-------
Surface Water Sampling Map

CTEH Surface Water Sampling Locations

Taggart Road Incident \ Mar 18, 3033

Project. PKOJ-024^79
Client Norfolk Southern
City: Kast Palestine, OH
County: Cdumbwna

HhilnOiiR t/TM /u»%r r;N

ast Palestine

i t«QQ*
Alice st
* Mjtn St

[Mikiin W'.s

InciAnt iccmofl
ww nowuH

WMv WipMg loctfaon
Boct^nund Matn Sanpttng
UKJfem

Pjlattin*

I filattnl
-------
4 Communication Plan

Work Area:

Available Comms

Emergency Communication Procedures

Surface Water Sampling Locations

X 2-way Radios
X Hand Signals
X Cell phone
X Air Horn

Emergency Signal

Short Air horn Blast: Attention all personnel
2 Horn Blast: Attention all personnel, controlled
egress to SZ

Long Horn Blast: Emergency evacuation

Action

Crosswind, then upwind to muster point; i.e.,
incident command or tailgate briefing location

Hand Signal

Two hands placed on top of head

Cell comms

Chain of Command communication

5 Personal Protective Equipment

Designated Levels of Personal Protection

Task:

Work Area (e.g., EZ, CRZ,
other):

Job Function:

Level of Protection:

1. T raffi c / Roadway
Navigation

Other

Roadway navigation and community travel;
parking, pedestrians, animals

Modified Level D ^ (hi-viz safety vest)

2. Environmental
Sampling - Vessel
Over Water / Deep
Water (PFD
required)

Other

Surface water sampling in locations with
deeper and faster moving water; 7 locations at
Little Beaver Creek and further south, W005,
W006, W007, W008, WO 17, WO 18, WO 19

Modified Level D ^ (PFD while on vessel
over water or within 10'of swift moving water)

3. Environmental
Sampling - Work
Area

CRZ, SZ

Work area surface water sampling locations;
4 locations, W014, W015, W016, W020

aD bD cD dM

4. Environmental
Sampling -
Community

Other

Water sampling at strategic waterway
locations throughout the community setting

Modified Level D ^ (hi-viz safety vest)

Operational Division HASP Addendum: Surface Water

-------
6 Decontamination (Be advised, if Sampling or Visiting Work Areas, please proceed with directives below)

Decontamination Procedures

Personnel (Level A, B, C) Decontamination Procedures:

Decontamination of personnel is largely focused on boot wash to prevent contamination migration outside of EZ:

Station 1: Boot Wash/Scrub

Using available boot wash stations, remove heavy soils and mud with soap and brush.

Station 2: Rinse

Using secondary decon pool, rinse boots free of remaining soils and soap.

Emergency Decontamination Procedures:

7 Environmental and Personal Monitoring

AIR MONITORING SUMMARY

Instrument Type:

Contaminant:

Frequency:

Action Level/Comments:

RAE Systems MultiRAE Pro (PID)

VOCs

As needed

Detection above 0.2 ppm requires assessment for vinyl
chloride.

Detection above 0.5, don respiratory protection or egress.

RAE Systems MultiRAE Pro (O2
sensor)

Oxygen

Confined space work

< 19.5% or > 23.5% oxygen, evacuate area and re-evaluate

RAE Systems MultiRAE Pro (LEL
sensor)

Combustible range vapors and gases,
CO

Periodic

> 10% of LEL (corrected) prompts work stoppage and
personnel egress

Detector Tubes

Vinyl chloride
Butyl acrylate

As necessary to further evaluate
photo ionization detector

VC: 0.5 ppm, report detection - prepare for protective controls
BA: 2.0 ppm, report detection & don APR for continued work

Drager XPID

Vinyl chloride
Butyl acrylate

As necessary to further evaluate
photo ionization detector

VC: 0.5 ppm, report detection - prepare for protective controls
BA: 2.0 ppm, report detection & don APR for continued work

Personal Monitoring Procedures

Chemical Exposure:

Operational Division HASP Addendum: Surface Water

-------
Assay 525 Organic Vapor Monitors (OVM) are utilized to measure workers 8-hour TWA exposure for butyl acrylate and vinyl chloride. Workers will be notified of their individual
exposure per OSHA reporting criteria for personal sampling notification.

Butyl acrylate: analysis method is conducted per modified NIOSH 2537.

Vinyl chloride: analysis method is conducted per NIOSH 1007 method.

8 EMERGENCY RESPONSE (AED Locations, See Blue Plan)

Agency

Nature of Emergency

Contact Number:

On-site EMT

First aid, initial emergency care, trauma care

911

Air Evac

Emergency, life-threatening, major trauma

911

Fire

Medical, criminal, and fire emergency

Onsite resources, 911

Police

Security, crime, suspicious behavior

911, NS police: (800) 453-2530

Emergency Medical Facility Name

East Liverpool City Hospital - Emergency Room

Emergency Medical Facility Location

425 W. 5th Street: (330) 385-7200

Non-Emergency Medical Facility Name

East Liverpool Hospital

Non-Emergency Medical Facility Location

425 W. 5th Street: (330) 385-7200

First Aid Location

Site vehicles

Fire Extinguisher Location

Site vehicles, heavy machinery

Emergency Notification Procedures

Places of Refuge

Emergency Decon and Evacuation

Site Security Measures

Notify site safety and then call
911 for paramedics. Phone
and/or verbal notification for
evacuation.

Hospital:

See above

Discern whether emergency care
is needed. If in doubt, proceed
to emergency medical facility or
contact 911.

Refuge locations vary, but egress
must be upwind/uphill in all
locations. Work crew supervisors
must account for all personnel
under their direction in the event of
evacuation or relocation. See
Refinery map section

Establish an area of refuge for
contaminated individuals ASAP

Establish the gross decon area using a
water source such as garden hoses, engine
lines or pump sprayers.

Spray individuals with copious amounts of
water to remove overt quantities of
contaminants.

Site security being provided
by local law enforcement.

Operational Division HASP Addendum: Surface Water

-------
East Liverpool City Hospital
425 W. 5th St,

East Liverpool, OH 43920
(330) 385-7200

from East Palestine, Ohio 44413

to East Liverpool City Hospital, 425 W 5th St, East..

30 min (19.4 miles) '-Q g

via OH-170 S

Fastest route now due to traffic conditions

East Palestine

Ohio 44413

> Follow Walker Alley, N James St and E Main St to
OH-170 S/S Market St

3 mm (0.7 mi)

> Follow OH-170 S and US-30 E to Jackson St in East
Liverpool. Take the exit toward Downtown/E
Liverpool from US-30 E

26 mm (18.2 ml)

> Drive to W 5th St

2 mm (0 5 ml)

East Liverpool City Hospital

425 W 5th St. East Liverpool, OH 43920

Lane
Tomahawk

Clarkson

Glenmooi

East Liverpool
City Hospital'

Wellsvilte

F © - m

'"ilf |i Gas 8} EV charging W Hotels ,r Q, More 1

^Willow Gti

.©

Columbiana

Winona

New Garden

Harwverton
Kensington

lt" State Game
j Lards
Nurhber/285

^ ©

Mechanicstown

(P5

leeton a

Watenofd

23 1 miles

a 30 mln I0*9

19 BfnlM

On 0.,1'e

Georgetown

® ¥ I

(iw) Wampum
New Beaver ^

Enon Valley

New Galilee

EllwoodCity

mb <$>

Darlington

Koppd
Homewood

Beaver Falls
New Brighton

(St?) Gavers

West Point

Summitville

BeaverjpfeJI
Mook4

Highlandtown
Wildlife Area

(im) Highlandi'own

Kabuta

ndustry qjj

Salineville

lii

.Midland,

I / ®

Hookstown

irondale Yellorf5fk

(

Aliquipp;

MacAnhuf
independence

Operational Division HASP Addendum: Surface Water

-------
HASP - Division: Surface Soil

Project: East Palestine Train Derailment Site

Location: East Palestine, OH

Date Prepared: 3-23-2023

Version: 2.0

Operational Period: 7-day

Operational Division: Surface Soil

For Emergencies Contact: Site EMT and/or 911

Scope: This condensed HASP is an operation-specific addendum to the East Palestine Train
Derailment site wide HASP. The content in this addendum is not intended to be comprehensive
but focused on health and safety components not specifically covered in the site-wide HASP. For
more inclusive content, please refer to the sitewide HASP.

Operational Division HASP Addendum: Surface Soil

-------
Operational Division Risk Analysis
& Control Development

Division
Hazard
Analysis

Provides
comprehensive
safety analysis of
site-wide
operations in
accordance with
29 CFR 1910.120

Operational Division

f >

• Division-specific
safety analysis

• Provides focused
safety planning
for division's
unique

environmental
characteristics

Operational Division
Risk Analysis

Establishes
primary tasks
Declares principle
hazard categories
Introduces control
measures for each
primary hazard

Field Based HASP
Tools

•Focused on task-based
hazard declaration and
control measures to be
used by field personnel
• Considered the "living"
portion of the HASP to
ensure all field
personnel receive vital
information

Operational Division HASP Addendum: Surface Soil

-------
2 Site Characterization & Hazards Overview

Major Tasks:

Risk
Category
(GAR)

Description and Location Where Task(s)/Operation(s) to be Performed

1. Traffi c / Roadway
Navigation

Roadway navigation and community travel; parking, pedestrians, animals

2. Environmental Sampling -
Work Area

Onsite work area soil sampling locations: multiple locations along rail bed and response
impacted areas

3. Environmental
Community &

Sampling -
Residential

Soil sampling at strategic locations throughout the residential setting

Site Information

Roadways:

All Roadways Surrounding East Palestine, Columbiana, & surrounding communities

Waterways:

Topographical drainage,
creeks, swift moving
waterways (PFDs req.)

Facility Equipment:

Passing trains, tractor trailers (adj
businesses)

Railways:

Heavy Machinery:

Dump trucks, Frac Tanks, Vac truck,
railway maintenance equipment

Electrical Sources:

High voltage power line,
temp power, etc.

Pipelines:

Determine with utility

Gar Scale

Percentage

0-25

25-50

50-75

75-100

Risk

Slight

Possible

Substantial

Very High

Color

Green

Yellow

Amber

Red

Action

Possibly
Acceptable

Attention
Needed

Correction Needed

Discontinue/
Stop

Operational Division HASP Addendum: Surface Soil

-------
Additional Chemical Hazards

Added chemical

Anticipated source or product utilization description

Exposure Potential

Estimated Volume

Methanol preservative
contained within soil
sampling media

Required for laboratory analysis, Method 846; generally
safe when appropriately handled, stored, and secured
(special care with glass jars)

1 1 Likely O Unknown
1^1 Possible O Unlikely

5mL Methanol
preservative
contained in
sampling media

Additional Physical Hazards

Added Hazard

Source of Hazard

Exposure Potential

Affected Workers

Slips, trips, and falls

Uneven surfaces, steps, slick surfaces (mud/wet), yards,
well locations

1^1 Likely Q Unknown
1 1 Possible O Unlikely

Community workers
and support
contractors

Aggressive residents/pets

Residential engagement, property access, entering
homes for testing

1 1 Likely ^ Unknown
1 1 Possible O Unlikely

Community workers
and support
contractors

Vehicle/traffic hazards

Distracted driving, increased traffic from response, blind
spots, pedestrians, deer, low light, varying weather
conditions

1 1 Likely O Unknown
1^1 Possible O Unlikely

Community workers
and support
contractors

Reason for deviation from
HASP

Blue Plan is specific to work area; this covers residential

Expected Interaction

1^1 Hourly O Daily Q Weekly O Once

3 Site Control

Operational Division HASP Addendum: Surface Soil

-------
Zone description

Standard Operating Procedures

Exclusion Zone

• Check in and out of this zone at the EZ access locations.

• This area is off limits to non-authorized, or non-essential personnel during the response and mitigation
operations.

• All entrants must abide by the protective measures and PPE criteria (when required) for the specified area of
work and the task-specific safety procedures assigned.

Contaminant Reduction Zone

• Check in and out of this zone at the approved site entry locations.

• This area will include work activity conducted to support EZ operations. This area also includes decontamination
locations.

• This area is off limits to non-authorized, or non-essential personnel during response and mitigation operations.

Support Zone

• Access will be provided through approved site access locations, maintained by badge check-in and checkout.

• General Site-Specific PPE will be required in the SZ.

• Muster locations have been designated in the SZ, please refer to the site control map for approved muster
locations located near the work site.

Job Tasks:

Work Zone Description

Zone classification

1. Traffic / Roadway Navigation

Roadway navigation and community travel; parking, pedestrians, animals

~ EZ ~ CRZ E SZ

2. Environmental Sampling -
Onsite Work Areas

Onsite work area soil sampling locations: multiple locations along rail bed
and response impacted areas

~ EZ M CRZ X SZ

3. Environmental Sampling -
Community & Residential

Soil sampling at strategic locations throughout the residential setting

~ EZ ~ CRZ X SZ

Operational Division HASP Addendum: Surface Soil

-------
Site Control Map

Jdorth VC Impacted
Sa;i|j]'iin] vV.isk:

jTank*RanTO21

fslylB-61

[SMB-H1

vi.-ij.i.iiii.]

—Area,1A®j

— III'! i' ' .

""Wa9«?Stagim
jAKaTBgcT",

tWater Bypass!

iTanlflftfeai

•W ateT, Bypa ss j

[SMB[6]

[SlvlETll

[SMB?|

jTahkjFaf

[SMB-IH

IHareJIBoom Containment

¦: BeayeTtGountyl
I Pennsylvania!

[Coltjimbianai
County

IRolJlOtf"

Exclusion Zone - Drainage pipe

Contamination Reduction Zone

Support Zone

l;ink I Limi V

Decontamination

Traffic Checkpoiunt

Muster

DRAFT

Attorney-Client Privilege/Attorney Work Product/
Prepared at the Direction of Counsel

Map Date: 3/1 y2023

Operational Division HASP Addendum: Surface Soil

-------
Surface Soil Sampling Map: Orisite Work Area

DRAFT

Operational Division HASP Addendum: Surface Soil

-------
Surface Soil Sampling Map: Residential Area

Operational Division HASP Addendum: Surface Soil

-------
4 Communication Plan

Work Area:

Available Comms

Emergency Communication Procedures

Surface Water Sampling Locations

X 2-way Radios
X Hand Signals
X Cell phone
X Air Horn

Emergency Signal

Short Air horn Blast: Attention all personnel
2 Horn Blast: Attention all personnel, controlled
egress to SZ

Long Horn Blast: Emergency evacuation

Action

Crosswind, then upwind to muster point; i.e.,
incident command or tailgate briefing location

Hand Signal

Two hands placed on top of head

Cell comms

Chain of Command communication

5 Personal Protective Equipment

Designated Levels of Personal Protection

Task:

Work Area (e.g., EZ, CRZ,
other):

Job Function:

Level of Protection:

1. T raffi c / Roadway
Navigation

Other

Roadway navigation and community travel;
parking, pedestrians, animals

Modified Level D ^ (hi-viz safety vest)

2. Environmental
Sampling - Onsite
Work Areas

CRZ, SZ

Onsite work area soil sampling locations:
multiple locations along rail bed and response
impacted areas

aD bD cD dM

3. Environmental
Sampling -
Community &
Residential

Other

Soil sampling at strategic locations
throughout the residential setting

Modified Level D ^ (hi-viz safety vest)

Operational Division HASP Addendum: Surface Soil

-------
6 Decontamination (Be advised, if Sampling or Visiting Work Areas, please proceed with directives below)

Decontamination Procedures

Personnel (Level A, B, C) Decontamination Procedures:

Decontamination of personnel is largely focused on boot wash to prevent contamination migration outside of EZ:

Station 1: Boot Wash/Scrub

Using available boot wash stations, remove heavy soils and mud with soap and brush.

Station 2: Rinse

Using secondary decon pool, rinse boots free of remaining soils and soap.

Emergency Decontamination Procedures:

7 Environmental and Personal Monitoring

AIR MONITORING SUMMARY

Instrument Type:

Contaminant:

Frequency:

Action Level/Comments:

RAE Systems MultiRAE Pro (PID)

VOCs

As needed

Detection above 0.2 ppm requires assessment for vinyl
chloride.

Detection above 0.5, don respiratory protection or egress.

RAE Systems MultiRAE Pro (O2
sensor)

Oxygen

Confined space work

< 19.5% or > 23.5% oxygen, evacuate area and re-evaluate

RAE Systems MultiRAE Pro (LEL
sensor)

Combustible range vapors and gases,
CO

Periodic

> 10% of LEL (corrected) prompts work stoppage and
personnel egress

Detector Tubes

Vinyl chloride
Butyl acrylate

As necessary to further evaluate
photo ionization detector

VC: 0.5 ppm, report detection - prepare for protective controls
BA: 2.0 ppm, report detection & don APR for continued work

Drager XPID

Vinyl chloride
Butyl acrylate

As necessary to further evaluate
photo ionization detector

VC: 0.5 ppm, report detection - prepare for protective controls
BA: 2.0 ppm, report detection & don APR for continued work

Personal Monitoring Procedures

Chemical Exposure:

Assay 525 Organic Vapor Monitors (OVM) are utilized to measure workers 8-hour TWA exposure for butyl acrylate and vinyl chloride. Workers will be notified of their individual
exposure per OSHA reporting criteria for personal sampling notification.

Butyl acrylate: analysis method is conducted per modified NIOSH 2537.
Vinyl chloride: analysis method is conducted per NIOSH 1007 method.

Operational Division HASP Addendum: Surface Soil

-------
8 EMERGENCY RESPONSE (AED Locations, See Blue Plan)

Agency

Nature of Emergency

Contact Number:

On-site EMT

First aid, initial emergency care, trauma care

911

Air Evac

Emergency, life-threatening, major trauma

911

Fire

Medical, criminal, and fire emergency

Onsite resources, 911

Police

Security, crime, suspicious behavior

911, NS police: (800) 453-2530

Emergency Medical Facility Name

East Liverpool City Hospital - Emergency Room

Emergency Medical Facility Location

425 W. 5th Street: (330) 385-7200

Non-Emergency Medical Facility Name

East Liverpool Hospital

Non-Emergency Medical Facility Location

425 W. 5th Street: (330) 385-7200

First Aid Location

Site vehicles

Fire Extinguisher Location

Site vehicles, heavy machinery

Emergency Notification Procedures

Places of Refuge

Emergency Decon and Evacuation

Site Security Measures

Notify site safety and then call
911 for paramedics. Phone
and/or verbal notification for
evacuation.

Hospital:

See above

Discern whether emergency care
is needed. If in doubt, proceed
to emergency medical facility or
contact 911.

Establish an area of refuge for
contaminated individuals ASAP

Establish the gross decon area using a
water source such as garden hoses, engine
lines or pump sprayers.

Spray individuals with copious amounts of
water to remove overt quantities of
contaminants.

Site security being provided
by local law enforcement.

Operational Division HASP Addendum: Surface Soil

-------
East Liverpool City Hospital
425 W. 5th St,

East Liverpool, OH 43920
(330) 385-7200

from East Palestine, Ohio 44413

to East Liverpool City Hospital, 425 W 5th St, East

30 min (19.4 miles) £

via OH-170S

Fastest route now due to traffic conditions

East Palestine

Ohio 44413

> Follow Walker Alley, N James St and E Main St to
OH-170 S/S Market St

3 min (0.7 mi)

> Follow OH-170 S and US-30 E to Jackson St in East
Liverpool. Take the exit toward Downtown/E
Liverpool from US-30 E

26 mm (18.2 ml)

> Drive to W 5th St

2 mm (0 5 ml)

East Liverpool City Hospital

425 W 5th SI East Liverpool, OH 43920

lake
Tomahawk

Clarttson

Glenmoot

East Liverpool
City Hospital1

Wellsville

¦ -r" 'j— \?:j rcinsuuiy h

Willow Grove

NewGatden

Leetonia

<3 - », H

0 '

Unity >

@ > Enon Valley

(is?) Wampum
New Beaver ^

State Game1
• Lands,
Niirhber'285

Hanoverton
Kensington

(STS) Gaveis

Sumirrttville

Highlandtown
Wiltiiife Area

(Jm) Highlandtown

Mechaniestown

Saimeville

vva:e'ford

Q A 33 min

231m«H |

'"4

^ 30 min

!9 5mtl«s

55> Georgetown ¦

hI V rQ

New Galilee Koppel

Ellwood City

®)
Darlington

Homewood

8eaver Falls
New Brighton

West Point
¦© - ©

MgM

Monaca

®C,K

industry

Jfj8 p

Kabuta

[Midland

Aiiguipp;

@ Hookstown

® 1

Rhiei&*lfl.

irondale VelioWtieek

MacArlhu'

independence

Operational Division HASP Addendum: Surface Soil

-------
HASP - Division: Residential

Project: East Palestine Train Derailment Site

Location: East Palestine, OH

Date Prepared: 3-23-2023

Version: 2.0

Operational Period: 7-day

Operational Division: Residential

For Emergencies Contact: Site EMT and/or 911

Operational Division HASP Addendum: Residential

-------
Operational Division Risk Analysis
& Control Development

Division
Hazard
Analysis

Provides
comprehensive
safety analysis of
site-wide
operations in
accordance with
29 CFR 1910.120

Operational Division

f >

• Division-specific
safety analysis

• Provides focused
safety planning
for division's
unique

environmental
characteristics

Operational Division
Risk Analysis

Establishes
primary tasks
Declares principle
hazard categories
Introduces control
measures for each
primary hazard

Field Based HASP
Tools

•Focused on task-based
hazard declaration and
control measures to be
used by field personnel
• Considered the "living"
portion of the HASP to
ensure all field
personnel receive vital
information

Operational Division HASP Addendum: Residential

-------
2 Site Characterization & Hazards Overview

Major Tasks:

Risk
Category
(GAR)

Description and Location Where Task(s)/Operation(s) to be Performed

1. Traffic / Navigation

Roadway navigation and community travel; parking, pedestrians, pets

2. Well Testing

Homeowners with well water requesting tests; accessibility, footing

3. Air Monitoring

Homeowners requesting environmental monitoring inside home; access, pets

4. Personal Communication

Engagement with homeowners requesting monitoring; access, pets

Site Information

Roadways:

All Roadways Surrounding East Palestine & Columbiana

Waterways:

Topographical drainage,
creeks,

Facility Equipment:

Passing trains, tractor trailers (adj
businesses)

Railways:

Heavy Machinery:

Dump trucks, Frac Tanks, Vac truck,
railway maintenance equipment

Electrical Sources:

High voltage power line,
temp power, etc.

Pipelines:

Determine with utility

Gar Scale

Percentage

0-25

25-50

50-75

75-100

Risk

Slight

Possible

Substantial

Very High

Color

Green

Yellow

Amber

Red

Action

Possibly
Acceptable

Attention
Needed

Correction Needed

Discontinue/
Stop

Operational Division HASP Addendum: Residential

-------
Additional Chemical Hazards

Added chemical

Anticipated source or product utilization description

Exposure Potential

Estimated Volume

Calibration Gas

Used to calibrate air monitoring instruments; generally
safe when appropriately stored and secured (especially
while driving)

1 1 Likely O Unknown
1 1 Possible ^ Unlikely

1-Liter cannister

Additional Physical Hazards

Added Hazard

Source of Hazard

Exposure Potential

Affected Workers

Slips, trips, and falls

Uneven surfaces, steps, slick surfaces (mud/wet), yards,
well locations

1^1 Likely Q Unknown
1 1 Possible O Unlikely

Community workers
and support
contractors

Aggressive residents/pets

Residential engagement, property access, entering
homes for testing

1 1 Likely ^ Unknown
1 1 Possible O Unlikely

Community workers
and support
contractors

Vehicle/traffic hazards

Distracted driving, increased traffic from response, blind
spots, pedestrians, deer, low light, varying weather
conditions

1 1 Likely O Unknown
1^1 Possible O Unlikely

Community workers
and support
contractors

Reason for deviation from
HASP

Blue Plan is specific to work area; this covers residential

Expected Interaction

1^1 Hourly O Daily Q Weekly O Once

Operational Division HASP Addendum: Residential

-------
3 Site Control

Zone description

Standard Operating Procedures

Exclusion Zone

• Check in and out of this zone at the EZ access locations.

• This area is off limits to non-authorized, or non-essential personnel during the response and mitigation
operations.

• All entrants must abide by the protective measures and PPE criteria (when required) for the specified area of
work and the task-specific safety procedures assigned.

Contaminant Reduction Zone

• Check in and out of this zone at the approved site entry locations.

• This area will include work activity conducted to support EZ operations. This area also includes decontamination
locations.

• This area is off limits to non-authorized, or non-essential personnel during response and mitigation operations.

Support Zone

• Access will be provided through approved site access locations, maintained by badge check-in and checkout.

• General Site-Specific PPE will be required in the SZ.

• Muster locations have been designated in the SZ, please refer to the site control map for approved muster
locations located near the work site.

Job Tasks:

Work Area Description

Zone classification

1. Traffic / Navigation

Roadway navigation and community travel; parking, pedestrians, pets

No Zone Classification /
Outside of Work Area /
Community Access

2. Well Testing

Homeowners with well water requesting tests; accessibility, footing

3. Air Monitoring

Homeowners requesting environmental monitoring inside home; access, pets

4. Personal Communication

Engagement with homeowners requesting monitoring; access, pets

Operational Division HASP Addendum: Residential

-------
Site Control Map

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[SMB-IH

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¦: BeayeTtGountyl
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County

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Exclusion Zone - Drainage pipe

Contamination Reduction Zone

Support Zone

l;ink I Limi V

Decontamination

Traffic Checkpoiunt

Muster

DRAFT

Attorney-Client Privilege/Attorney Work Product/
Prepared at the Direction of Counsel

Map Date: 3/1 y2023

Operational Division HASP Addendum: Residential

-------
4 Communication Plan

Work Area:

Available Comms

Emergency Communication Procedures

Residential and Community
Monitoring

X 2-way Radios
X Hand Signals
X Cell phone
X Car Horn

Emergency Signal

Short Car horn Blast: Attention to surrounding
personnel, drivers, operators.

Long Car Horn Blast: Emergency egress

Action

Crosswind, then upwind to muster point; i.e.,
incident command or tailgate briefing location

Hand Signal

Two hands placed on top of head

Cell comms

Chain of Command communication

5 Personal Protective Equipment

Designated Levels of Personal Protection

Task:

Work Area (e.g., EZ, CRZ,
other):

Job Function:

Level of Protection:

1. Traffic / Navigation

Other

Roadway navigation and community travel;
parking, pedestrians, pets

Modified Level D ^ (hi-viz safety vest)

2. Well Testing

Other

Homeowners with well water requesting
tests; accessibility, footing

Modified Level D ^ (hi-viz safety vest)

3. Air Monitoring

Other

Homeowners requesting environmental
monitoring inside home; access, pets

Modified Level D ^ (hi-viz safety vest)

4. Personal

Communication

Other

Engagement with homeowners requesting
monitoring; access, pets

Modified Level D ^ (hi-viz safety vest)

Operational Division HASP Addendum: Residential

-------
6 Decontamination (Should not be necessary; however, if visiting work area, please proceed with directives below)

Decontamination Procedures

Personnel (Level A, B, C) Decontamination Procedures:

Decontamination of personnel is largely focused on boot wash to prevent contamination migration outside of EZ:

Station 1: Boot Wash/Scrub

Using available boot wash stations, remove heavy soils and mud with soap and brush.

Station 2: Rinse

Using secondary decon pool, rinse boots free of remaining soils and soap.

Emergency Decontamination Procedures:

7 Environmental and Personal Monitoring

AIR MONITORING SUMMARY

Instrument Type:

Contaminant:

Frequency:

Action Level/Comments:

RAE Systems MultiRAE Pro (PID)

VOCs

As needed

Detection above 0.2 ppm requires assessment for vinyl
chloride.

Detection above 0.5, don respiratory protection or egress.

RAE Systems MultiRAE Pro (O2
sensor)

Oxygen

Confined space work

< 19.5% or > 23.5% oxygen, evacuate area and re-evaluate

RAE Systems MultiRAE Pro (LEL
sensor)

Combustible range vapors and gases,
CO

Periodic

> 10% of LEL (corrected) prompts work stoppage and
personnel egress

Detector Tubes

Vinyl chloride
Butyl acrylate

As necessary to further evaluate
photo ionization detector

VC: 0.5 ppm, report detection - prepare for protective controls
BA: 2.0 ppm, report detection & don APR for continued work

Drager XPID

Vinyl chloride
Butyl acrylate

As necessary to further evaluate
photo ionization detector

VC: 0.5 ppm, report detection - prepare for protective controls
BA: 2.0 ppm, report detection & don APR for continued work

Personal Monitoring Procedures

Chemical Exposure:

Butyl acrylate: analysis method is conducted per modified NIOSH 2537.
Vinyl chloride: analysis method is conducted per NIOSH 1007 method.

Operational Division HASP Addendum: Residential

-------
8 EMERGENCY RESPONSE (AED Locations, See Blue Plan)

Agency

Nature of Emergency

Contact Number:

On-site EMT

First aid, initial emergency care, trauma care

911

Air Evac

Emergency, life-threatening, major trauma

911

Fire

Medical, criminal, and fire emergency

Onsite resources, 911

Police

Security, crime, suspicious behavior

911, NS police: (800) 453-2530

Emergency Medical Facility Name

East Liverpool City Hospital - Emergency Room

Emergency Medical Facility Location

425 W. 5th Street: (330) 385-7200

Non-Emergency Medical Facility Name

East Liverpool Hospital

Non-Emergency Medical Facility Location

425 W. 5th Street: (330) 385-7200

First Aid Location

Site vehicles

Fire Extinguisher Location

Site vehicles, heavy machinery

Emergency Notification Procedures

Places of Refuge

Emergency Decon and Evacuation

Site Security Measures

Notify site safety and then call
911 for paramedics. Phone
and/or verbal notification for
evacuation.

Hospital:

See above

Discern whether emergency care
is needed. If in doubt, proceed
to emergency medical facility or
contact 911.

Establish an area of refuge for
contaminated individuals ASAP

Establish the gross decon area using a
water source such as garden hoses, engine
lines or pump sprayers.

Spray individuals with copious amounts of
water to remove overt quantities of
contaminants.

Site security being provided
by local law enforcement.

Operational Division HASP Addendum: Residential

-------
East Liverpool City Hospital
425 W. 5th St,

East Liverpool, OH 43920
(330) 385-7200

from East Palestine, Ohio 44413

to East Liverpool City Hospital, 425 W 5th St, East

30 min (19.4 miles) £

via OH-170S

Fastest route now due to traffic conditions

East Palestine

Ohio 44413

> Follow Walker Alley, N James St and E Main St to
OH-170 S/S Market St

3 min (0.7 mi)

> Follow OH-170 S and US-30 E to Jackson St in East
Liverpool. Take the exit toward Downtown/E
Liverpool from US-30 E

26 mm (18.2 ml)

> Drive to W 5th St

2 mm (0 5 ml)

East Liverpool City Hospital

425 W 5th SI East Liverpool, OH 43920

lake
Tomahawk

Clarttson

Glenmoot

East Liverpool
City Hospital1

Wellsville

¦ -r" 'j— \?:j rcinsuuiy h

Willow Grove

NewGatden

Leetonia

<3 - », H

0 '

Unity >

@ > Enon Valley

(is?) Wampum
New Beaver ^

State Game1
• Lands,
Niirhber'285

Hanoverton
Kensington

(STS) Gaveis

Sumirrttville

Highlandtown
Wiltiiife Area

(Jm) Highlandtown

Mechaniestown

Saimeville

vva:e'ford

Q A 33 min

231m«H |

'"4

^ 30 min

!9 5mtl«s

55> Georgetown ¦

hI V rQ

New Galilee Koppel

Ellwood City

®)
Darlington

Homewood

8eaver Falls
New Brighton

West Point
¦© - ©

MgM

Monaca

®C,K

industry

Jfj8 p

Kabuta

[Midland

Aiiguipp;

@ Hookstown

® 1

Rhiei&*lfl.

irondale VelioWtieek

MacArlhu'

independence

Operational Division HASP Addendum: Residential

-------
HASP - Division: Community Engagement

Project: East Palestine Train Derailment Site

Location: East Palestine, OH

Date Prepared: 3-23-2023

Version: 2.0

Operational Period: 7-day

Operational Division: Community Engagement

For Emergencies Contact: Site EMT and/or 911

Operational Division HASP Addendum: Community Engagement

-------
Provides
comprehensive
safety analysis of
site-wide
operations in
accordance with
29 CFR 1910.120

Operational Division

f >

• Division-specific
safety analysis

• Provides focused
safety planning
for division's
unique

environmental
characteristics

Operational Division
Risk Analysis

Establishes
primary tasks
Declares principle
hazard categories
Introduces control
measures for each
primary hazard

Field Based HASP
Tools

•Focused on task-based
hazard declaration and
control measures to be
used by field personnel
• Considered the "living"
portion of the HASP to
ensure all field
personnel receive vital
information

Operational Division HASP Addendum: Community Engagement

-------
2 Site Characterization & Hazards Overview

Major Tasks:

Risk
Category
(GAR)

Description and Location Where Task(s)/Operation(s) to be Performed

1. Traffic / Navigation

Roadway navigation and community travel; parking, pedestrians, pets

2. Community Outreach /
Townhall Meetings

Homeowners requesting environmental monitoring or additional information

3. Community Outreach /
Welcome Center

Homeowners requesting environmental monitoring or additional information

4. Personal Communication

Engagement with community; various settings

Site Information

Roadways:

All Roadways Surrounding East Palestine & Columbiana

Waterways:

Topographical drainage,
creeks,

Facility Equipment:

Passing trains, tractor trailers (adj
businesses)

Railways:

Heavy Machinery:

Dump trucks, Frac Tanks, Vac truck,
railway maintenance equipment

Electrical Sources:

High voltage power line,
temp power, etc.

Pipelines:

Determine with utility

Gar Scale

Percentage

0-25

25-50

50-75

75-100

Risk

Slight

Possible

Substantial

Very High

Color

Green

Yellow

Amber

Red

Action

Possibly
Acceptable

Attention
Needed

Correction Needed

Discontinue/
Stop

Operational Division HASP Addendum: Community Engagement

-------
Additional Physical Hazards

Added Hazard

Source of Hazard

Exposure Potential

Affected Workers

Slips, trips, and falls

Uneven surfaces, steps, slick surfaces (mud/wet), yards,
well locations

1^1 Likely Q Unknown
1 1 Possible O Unlikely

Community workers
and support
contractors

Aggressive residents/pets

Residential engagement, property access, various
settings

1 1 Likely ^ Unknown
1 1 Possible O Unlikely

Community workers
and support
contractors

Vehicle/traffic hazards

Distracted driving, increased traffic from response, blind
spots, pedestrians, deer, low light, varying weather
conditions

1 1 Likely O Unknown
1^1 Possible O Unlikely

Community workers
and support
contractors

Reason for deviation from
HASP

Blue Plan is specific to work area; this covers
community settings

Expected Interaction

1^1 Hourly O Daily Q Weekly O Once

Operational Division HASP Addendum: Community Engagement

-------
3 Site Control

Zone description

Standard Operating Procedures

Exclusion Zone

• Check in and out of this zone at the EZ access locations.

• This area is off limits to non-authorized, or non-essential personnel during the response and mitigation
operations.

• All entrants must abide by the protective measures and PPE criteria (when required) for the specified area of
work and the task-specific safety procedures assigned.

Contaminant Reduction Zone

• Check in and out of this zone at the approved site entry locations.

• This area will include work activity conducted to support EZ operations. This area also includes decontamination
locations.

• This area is off limits to non-authorized, or non-essential personnel during response and mitigation operations.

Support Zone

• Access will be provided through approved site access locations, maintained by badge check-in and checkout.

• General Site-Specific PPE will be required in the SZ.

• Muster locations have been designated in the SZ, please refer to the site control map for approved muster
locations located near the work site.

Job Tasks:

Work Area Description

Zone classification

1. Traffic / Navigation

Roadway navigation and community travel; parking, pedestrians, pets

No Zone Classification /
Outside of Work Area /
Community Access

2. Community Outreach /
Townhall Meetings

Homeowners requesting environmental monitoring or additional information

3. Community Outreach /
Welcome Center

Homeowners requesting environmental monitoring or additional information

4. Personal Communication

Engagement with community; various settings

Operational Division HASP Addendum: Community Engagement

-------
Site Control Map

Jdorth VC Impacted
Sa;i|j]'iin] vV.isk:

jTank*RanTO21

fslylB-61

[SMB-H1

vi.-ij.i.iiii.]

—Area,1A®j

— III'! i' ' .

""Wa9«?Stagim
jAKaTBgcT",

tWater Bypass!

iTanlflftfeai

•W ateT, Bypa ss j

[SMB[6]

[SlvlETll

[SMB?|

jTahkjFaf

[SMB-IH

IHareJIBoom Containment

¦: BeayeTtGountyl
I Pennsylvania!

[Coltjimbianai
County

IRolJlOtf"

Exclusion Zone - Drainage pipe

Contamination Reduction Zone

Support Zone

l;ink I Limi V

Decontamination

Traffic Checkpoiunt

Muster

DRAFT

Attorney-Client Privilege/Attorney Work Product/
Prepared at the Direction of Counsel

Map Date: 3/1 y2023

Operational Division HASP Addendum: Community Engagement

-------
4 Communication Plan

Work Area:

Available Comms

Emergency Communication Procedures

Residential and Community
Monitoring

X 2-way Radios
X Hand Signals
X Cell phone
X Car Horn

Emergency Signal

Short Car horn Blast: Attention to surrounding
personnel, drivers, operators.

Long Car Horn Blast: Emergency egress

Action

Crosswind, then upwind to muster point; i.e.,
incident command or tailgate briefing location

Hand Signal

Two hands placed on top of head

Cell comms

Chain of Command communication

5 Personal Protective Equipment

Designated Levels of Personal Protection

Task:

Work Area (e.g., EZ, CRZ,
other):

Job Function:

Level of Protection:

1. Traffic / Navigation

Other

Roadway navigation and community travel;
parking, pedestrians, pets

Modified Level D ^ (Response Badge /
Identification)

2. Community

Outreach / Townhall
Meetings

Other

Homeowners requesting environmental
monitoring or additional information

Modified Level D ^ (Response Badge /
Identification)

3. Community

Outreach / Welcome
Center

Other

Homeowners requesting environmental
monitoring or additional information

Modified Level D ^ (Response Badge /
Identification)

4. Personal

Communication

Other

Engagement with community; various
settings

Modified Level D ^ (Response Badge /
Identification)

Operational Division HASP Addendum: Community Engagement

-------
6 Decontamination (Should not be necessary; however, if visiting work area, please proceed with directives below)

Decontamination Procedures

Personnel (Level A, B, C) Decontamination Procedures:

Decontamination of personnel is largely focused on boot wash to prevent contamination migration outside of EZ:

Station 1: Boot Wash/Scrub

Using available boot wash stations, remove heavy soils and mud with soap and brush.

Station 2: Rinse

Using secondary decon pool, rinse boots free of remaining soils and soap.

Emergency Decontamination Procedures:

7 Environmental and Personal Monitoring

AIR MONITORING SUMMARY

Instrument Type:

Contaminant:

Frequency:

Action Level/Comments:

RAE Systems MultiRAE Pro (PID)

VOCs

As needed

Detection above 0.2 ppm requires assessment for vinyl
chloride.

Detection above 0.5, don respiratory protection or egress.

RAE Systems MultiRAE Pro (O2
sensor)

Oxygen

Confined space work

< 19.5% or > 23.5% oxygen, evacuate area and re-evaluate

RAE Systems MultiRAE Pro (LEL
sensor)

Combustible range vapors and gases,
CO

Periodic

> 10% of LEL (corrected) prompts work stoppage and
personnel egress

Detector Tubes

Vinyl chloride
Butyl acrylate

As necessary to further evaluate
photo ionization detector

VC: 0.5 ppm, report detection - prepare for protective controls
BA: 2.0 ppm, report detection & don APR for continued work

Drager XPID

Vinyl chloride
Butyl acrylate

As necessary to further evaluate
photo ionization detector

VC: 0.5 ppm, report detection - prepare for protective controls
BA: 2.0 ppm, report detection & don APR for continued work

Personal Monitoring Procedures

Chemical Exposure:

Butyl acrylate: analysis method is conducted per modified NIOSH 2537.
Vinyl chloride: analysis method is conducted per NIOSH 1007 method.

Operational Division HASP Addendum: Community Engagement

-------
8 EMERGENCY RESPONSE (AED Locations, See Blue Plan)

Agency

Nature of Emergency

Contact Number:

On-site EMT

First aid, initial emergency care, trauma care

911

Air Evac

Emergency, life-threatening, major trauma

911

Fire

Medical, criminal, and fire emergency

Onsite resources, 911

Police

Security, crime, suspicious behavior

911, NS police: (800) 453-2530

Emergency Medical Facility Name

East Liverpool City Hospital - Emergency Room

Emergency Medical Facility Location

425 W. 5th Street: (330) 385-7200

Non-Emergency Medical Facility Name

East Liverpool Hospital

Non-Emergency Medical Facility Location

425 W. 5th Street: (330) 385-7200

First Aid Location

Site vehicles

Fire Extinguisher Location

Site vehicles, heavy machinery

Emergency Notification Procedures

Places of Refuge

Emergency Decon and Evacuation

Site Security Measures

Notify site safety and then call
911 for paramedics. Phone
and/or verbal notification for
evacuation.

Hospital:

See above

Discern whether emergency care
is needed. If in doubt, proceed
to emergency medical facility or
contact 911.

Establish an area of refuge for
contaminated individuals ASAP

Establish the gross decon area using a
water source such as garden hoses, engine
lines or pump sprayers.

Spray individuals with copious amounts of
water to remove overt quantities of
contaminants.

Site security being provided
by local law enforcement.

Operational Division HASP Addendum: Community Engagement

-------
East Liverpool City Hospital
425 W. 5th St,

East Liverpool, OH 43920
(330) 385-7200

from East Palestine, Ohio 44413

to East Liverpool City Hospital, 425 W 5th St, East

30 min (19.4 miles) £

via OH-170S

Fastest route now due to traffic conditions

East Palestine

Ohio 44413

> Follow Walker Alley, N James St and E Main St to
OH-170 S/S Market St

3 min (0.7 mi)

> Follow OH-170 S and US-30 E to Jackson St in East
Liverpool. Take the exit toward Downtown/E
Liverpool from US-30 E

26 mm (18.2 ml)

> Drive to W 5th St

2 mm (0 5 ml)

East Liverpool City Hospital

425 W 5th SI East Liverpool, OH 43920

lake
Tomahawk

Clarttson

Glenmoot

East Liverpool
City Hospital1

Wellsville

¦ -r" 'j— \?:j rcinsuuiy h

Willow Grove

NewGatden

Leetonia

<3 - », H

0 '

Unity >

@ > Enon Valley

(is?) Wampum
New Beaver ^

State Game1
• Lands,
Niirhber'285

Hanoverton
Kensington

(STS) Gaveis

Sumirrttville

Highlandtown
Wiltiiife Area

(Jm) Highlandtown

Mechaniestown

Saimeville

vva:e'ford

Q A 33 min

231m«H |

'"4

^ 30 min

!9 5mtl«s

55> Georgetown ¦

hI V rQ

New Galilee Koppel

Ellwood City

®)
Darlington

Homewood

8eaver Falls
New Brighton

West Point
¦© - ©

MgM

Monaca

®C,K

industry

Jfj8 p

Kabuta

[Midland

Aiiguipp;

@ Hookstown

® 1

Rhiei&*lfl.

irondale VelioWtieek

MacArlhu'

independence

Operational Division HASP Addendum: Community Engagement

-------
High Consequence SAFETY ANALYSIS

Chemical exposure

Machine-person contact

Soft-tissue damage from debris

High-pressure liquid release

Overhead lifts - mechanical injury

Moving trains

Total

Severity weighted total possible

Gar Scale Percentage

Chemical Exposure

Machine-Person Contact

Soft-tissue damage from debris

High-pressure liquid release

Overhead lifts - mechanical injury

Moving trains

Hazard Scale

Severity/ Probability/ Exposure

CONTROLS

1. Division:

Derailment & Track
Removal

2. Date/Time Prepared:

3-18-2023

Task Groups

Railcar manipulations & wrecking

Ranking 1-5

536.5

Protection Multiplier

0.70

§
LL.

Alarms, travel p
path, visual o

0.95

4- 8

LU >
CL o
CL O)

Safety clamps for P
hose o

0.95

c?5
£
K

0.80

Watchman-
comms

GAR

36.0

100.0

64.0

24.0

36.0

40.0

300.0

Adj GAR

25.2

80.0

60.8

16.8

34.2

32.0

249.0

536.5

HAZMAT

Ranking 1-5

536.5

Protection Multiplier

0.70

(0
LL.

Alarms, travel p
path, visual o

0.95

ad
CC

LL. W

LU S
CL O
CL O)

Safety clamps for P
hose o

0.95

c?5

&
o
co

0.80

Watchman-
comms

GAR

64.0

45.0

24.0

48.0

16.0

40.0

237

Adj GAR

44.8

36.0

22.8

33.6

15.2

32.0

184.4

536.5

Environmental Remediation

Ranking 1-5

536.5

Protection Multiplier

0.70

(0
LL.

Alarms, travel p
path, visual q

0.95

ad
CC

LL. W
i m

W >
CL O
CL O)

Safety clamps for P
hose o

0.95

&
o
co

0.80

Watchman-
comms

GAR

36.0

80.0

24.0

12.0

4.0

40.0

196

Adj GAR

25.2

64.0

22.8

8.4

3.8

32.0

156.2

536.5

Environmental Science

Ranking 1-5

536.5

Protection Multiplier

0.70
S

LL.

Alarms, travel p
path, visual q

0.95

ad
CC

LL. W
i m
UJ >
CL O
CL O)

Safety clamps for P
hose o

0.95

CC
%
£
%

0.80

Watchman -
comms

GAR

64.0

80.0

16.0

6.0

4.0

20.0

190

Adj GAR

44.8

64.0

15.2

4.2

3.8

16.0

148.0

536.5

Railway Track Maintenance

Ranking 1-5

536.5

Protection Multiplier

0.70

§
LL.

Alarms, travel p
path, visual o

0.95

ad
CC

"r 8
UJ >
CL O
CL O)

Safety clamps for P
hose o

0.95

c?5
&

0.80

Watchman-
comms

GAR

16.0

100.0

8.0

3.0

36.0

40.0

203

Adj GAR

11.2

80.0

7.6

2.1

34.2

32.0

167.1

536.5

Scale

ICS Form
215A (mod)

Operational Risk
Management Key

Severity

Slight

Minimal

Significant

Major

Catastrophic

Probability

Remote

Un-high

50/50

>50

Very high

Exposure

Episodic

Weekly

Daily

Hourly

Continuous

-------
High Consequence SAFETY ANALYSIS

Chemical exposure

Machine-person contact injury

Soft-tissue damage (debris /equipment / pinchpc

Vacuum/presurrized liquid release

Slips, Trips, Falls - mechanical injury

Moving trains

Electrical Hazards

Total

Severity weighted total possible

Gar Scale Percentage

Chemical Exposure

Machine-person contact injury

Soft-tissue damage

Vacuum/presurrized liquid release

Slips, Trips, Falls - mechanical injury

Moving trains

Electrical Hazards

Hazard Scale

Severity/ Probability/ Exposure

CONTROLS

1. Division:

Waste Management -

Liquid/Vapor Extraction

2. Date/Time Prepared:

3-23-2023

Task Groups

Water Treatment (HEPACO)

Ranking 1-5

558.7

Protection Multiplier

Fans o

Alarms, travel p
path, visual o

PPE-FR & O
1 tO
gloves m

Safety clamps for P
hose 0

0.95

C£.
%
&
8

Watchman- P
comms o

0.70

Grounding and
Bonding

GAR

24.0

32.0

36.0

30.0

36.0

40.0

32.0

230.0

Adj GAR

16.8

25.6

34.2

21.0

34.2

32.0

22.4

186.2

558.7

Vapor and Liquid Product Recovery
(HEPACO)

Ranking 1-5

558.7

Protection Multiplier

Fans o

Alarms, travel p
path, visual o

PPE-FR & o
i to
gloves O!

Safety clamps for P
hose 0

0.95

C£.

$
o
w

Watchman - P
comms o

0.70

Grounding and
Bonding

GAR

24.0

48.0

36.0

30.0

36.0

40.0

32.0

246

Adj GAR

16.8

38.4

34.2

21.0

34.2

32.0

22.4

199.0

558.7

Lordstown Tank Car Loading (SPSI)

Ranking 1-5

550.8

Protection Multiplier

Fans o

Alarms, travel p
path, visual o

PPE-FR & o
1 to
gloves m

Safety clamps for P
hose 0

0.95

C£.
%
&
8

Watchman- P
comms o

0.70

Grounding and
Bonding

GAR

24.0

48.0

36.0

60.0

36.0

40.0

32.0

276

Adj GAR

16.8

38.4

34.2

42.0

34.2

32.0

22.4

220

550.8

Frac. Tank Farm Tank Truck Loading
(SPSI)

Ranking 1-5

576.5

Protection Multiplier

Fans o

Alarms, travel p
path, visual o

PPE-FR & o
i to
gloves O!

Safety clamps for P
hose 0

0.95

C£.

$
o
w

Watchman - P
comms o

0.70

Grounding and
Bonding

GAR

36.0

18.0

36.0

40.0

32.0

234

Adj GAR

25.2

14.4

34.2

25.2

34.2

32.0

22.4

187.6

576.5

Frac. Tank Farm Vac Truck Discharge
(HEPACO)

Ranking 1-5

576.5

Protection Multiplier

Fans o

Alarms, travel p
path, visual o

PPE-FR & o
1 to
gloves m

Safety clamps for P
hose 0

0.95

C£.
%
&
8

Watchman- P
comms o

0.70

Grounding and
Bonding

GAR

36.0

18.0

36.0

40.0

32.0

234

Adj GAR

25.2

14.4

34.2

25.2

34.2

32.0

22.4

187.6

576.5

Scale

ICS Form
215A (mod)

Operational Risk
Management Key

Severity

Slight

Minimal

Significant

Major

Catastrophic

Probability

Remote

Un-high

50/50

>50

Veiy high

Exposure

Episodic

Weekly

Daily

Hourly

Continuous

Percentage

0-25

25-50

50-75

75-100

Risk

Slight

Possible

Substantial

Very High

Color

Green

Yellow

Amber

Red

Action

Possibly Acceptable

Attention

Correction Needed

Discontinue/

-------
High Consequence SAFETY ANALYSIS

Chemical exposure

Machine-person contact injury

Soft-tissue damage (debris /equipment / pinchpc

Electrical Hazards

Slips, Trips, Falls - mechanical injury

Moving trains

Total

Severity weighted total possible

Gar Scale Percentage

Chemical Exposure

Machine-person contact injury

Soft-tissue damage

Electrical Hazards

Slips, Trips, Falls - mechanical injury

Moving trains

Hazard Scale

Severity/ Probability/ Exposure

CONTROLS

1. Division:

Waste Management -
Soil Recovery/Removal

2. Date/Time Prepared:

3-23-2023

Task Groups

Work Zone Roll Off Loading (HEPACO)

Ranking 1-5

536.5

Projection Multiplier

0.70

Alarms, travel P
path, visual §

0.95

a1 S
a. o)

Grounding and P
Bonding q

0.95

1
£

0.80

Watchman -
comms

GAR

24.0

75.0

64.0

32.0

36.0

40.0

271.0

Adj GAR

16.8

60.0

60.8

22.4

34.2

32.0

226.2

536.5

Roll Off Staging - truck loading (HEPACO
and SPSI)

Ranking 1-5

536.5

Protection Multiplier

0.70

Alarms, travel P
path, visual §

0.95

IL 8
a. en

Grounding and P
Bonding q

0.95

0.80

Watchman -
comms

GAR

24.0

40.0

48.0

32.0

36.0

40.0

220

Adj GAR

16.8

32.0

45.6

22.4

34.2

32.0

183.0

536.5

Roll Off Staging - truck unloading (HEPACO
and SPSI)

Ranking 1-5

543.4

Protection Multiplier

0.70

Alarms, travel P
path, visual §

0.95

a1 S
a. o)

Grounding and P
Bonding q

0.95

1
£

0.80

Watchman -
comms

GAR

24.0

40.0

36.0

32.0

36.0

40.0

208

Adj GAR

16.8

32.0

34.2

22.4

34.2

32.0

171.6

543.4

Ranking 1-5

1571.9

Protection Multiplier

0.70

Alarms, travel P
path, visual §

0.95

IL 8
£L O)

Grounding and P
Bonding q

0.95

0.80

Watchman -
comms

GAR

0.0

Adj GAR

0.0

1571.9

Ranking 1-5

1571.9

Protection Multiplier

0.70

Alarms, travel P
path, visual §

0.95
a1 S

£L oi

Grounding and P
Bonding q

0.95

1
£

0.80

Watchman -
comms

GAR

0.0

Adj GAR

0.0

1571.9

Scale

ICS Form
215A (mod)

Operational Risk
Management Key

Severity

Slight

Minimal

Significant

Major

Catastrophic

Probability

Remote

Un-high

50/50

>50

Very high

Exposure

Episodic

Weekly

Daily

Hourly

Continuous

Percentage

0-25

25-50

50-75

75-100

Risk

Slight

Possible

Substantial

Very High

Color

Green

Yellow

Amber

Red

Action

Possibly Acceptable

Attention

Correction Needed

Discontinue/

-------
High Consequence SAFETY ANALYSIS

Chemical exposure

Vehicular injury

Soft-tissue damage (debris /equipment / pinchpc

Aggressive Personnel / Pets

Slips, Trips, Falls - mechanical injury

Moving trains

Total

Severity weighted total possible

Gar Scale Percentage

Chemical Exposure

Vehicular injury

Soft-tissue damage

Aggressive Personnel / Pets

Slips, Trips, Falls - mechanical injury

Moving trains

Hazard Scale

Severity/ Probability/ Exposure

CONTROLS

1. Division:

Surface Water

2. Date/Time Prepared:

3-23-2023

Task Groups

Traffic / Roadway Navigation

Ranking 1-5

586.5

Protection Multiplier

0.70

c
LL

Alarms, travel P
path, visual q

0.95

LL (ft

uj >

Q_ O
CL O)

Safety clamps for P
hose q

0.95

C£.

£
o
w

0.80

Watchman -
comms

GAR

1.0

100.0

36.0

3.0

18.0

40.0

198.0

Adj GAR

0.7

80.0

34.2

2.1

17.1

32.0

166.1

586.5

Environmental Sampling - Vessel Over
Water / Deep Water (PFD required)

Ranking 1-5

567.2

Protection Multiplier

0.70

c
LL

Alarms, travel P
path, visual q

0.95

LL (ft

uj >

CL O
CL O)

Safety clamps for P
hose q

0.95

C£.

£
o
w

0.80

Watchman -
comms

GAR

1.0

45.0

27.0

12.0

45.0

40.0

170

Adj GAR

0.7

36.0

25.7

8.4

42.8

32.0

145.5

567.2

Environmental Sampling - Work Area

Ranking 1-5

567.2

Protection Multiplier

0.70

c
LL

Alarms, travel P
path, visual q

0.95

LL M
UJ >
CL O
CL O)

Safety clamps for P
hose q

0.95

C£.

£
o
w

0.80

Watchman -
comms

GAR

4.0

45.0

27.0

12.0

4.0

40.0

132

Adj GAR

2.8

36.0

25.7

8.4

3.8

32.0

108.7

567.2

Environmental Sampling - Community

Ranking 1-5

576.5

Protection Multiplier

0.70

c
LL

Alarms, travel P
path, visual q

0.95

LL M
UJ >
CL O
CL O)

Safety clamps for P
hose q

0.95

C£.

£
o
w

0.80

Watchman -
comms

GAR

1.0

45.0

27.0

20.0

4.0

20.0

117

Adj GAR

0.7

36.0

25.7

14.0

3.8

16.0

96.2

576.5

Ranking 1-5

536.5

Protection Multiplier

0.70

c
LL

Alarms, travel P
path, visual q

0.95

LL M
UJ >
CL O
CL O)

Safety clamps for P
hose q

0.95

C£.
%
£
8

0.80

Watchman -
comms

GAR

16.0

100.0

8.0

3.0

36.0

40.0

203

Adj GAR

11.2

80.0

7.6

2.1

34.2

32.0

167.1

536.5

Scale

ICS Form
215A (mod)

Operational Risk
Management Key

Severity

Slight

Minimal

Significant

Major

Catastrophic

Probability

Remote

Un-high

50/50

>50

Very high

Exposure

Episodic

Weekly

Daily

Hourly

Continuous

-------
High Consequence SAFETY ANALYSIS

Chemical exposure

Vehicular injury

Soft-tissue damage (debris /equipment / pinchpc

Aggressive Personnel / Pets

Slips, Trips, Falls - mechanical injury

Moving trains

Total

Severity weighted total possible

Gar Scale Percentage

Chemical Exposure

Vehicular injury

Soft-tissue damage

Aggressive Personnel / Pets

Slips, Trips, Falls - mechanical injury

Moving trains

Hazard Scale

Severity/ Probability/ Exposure

CONTROLS

1. Division:

Surface Soil Sampling

2. Date/Time Prepared:

3-23-2023

Task Groups

Traffic / Roadway Navigation

Ranking 1-5

586.5

Protection Multiplier

0.70

§
LL.

Alarms, travel P
path, visual q

0.95

4- 8

LU >
CL o
CL O)

Safety clamps for P
hose q

0.95

c?5
&
K

0.80

Watchman-
comms

GAR

1.0

100.0

36.0

3.0

18.0

40.0

198.0

Adj GAR

0.7

80.0

34.2

2.1

17.1

32.0

166.1

586.5

Ranking 1-5

567.2

Protection Multiplier

0.70

(0
LL.

Alarms, travel P
path, visual q

0.95

ad
CC

LL. W
LU §

CL O
CL O)

Safety clamps for P
hose q

0.95

c?5

£
o
co

0.80

Watchman-
comms

GAR

1.0

45.0

27.0

12.0

45.0

40.0

170

Adj GAR

0.7

36.0

25.7

8.4

42.8

32.0

145.5

567.2

Environmental Sampling - Work Area

Ranking 1-5

567.2

Protection Multiplier

0.70

(0
LL.

Alarms, travel P
path, visual q

0.95

ad
CC

LL. W
i m

W >
CL O
CL O)

Safety clamps for P
hose q

0.95

£
o
co

0.80

Watchman-
comms

GAR

4.0

45.0

27.0

12.0

4.0

40.0

132

Adj GAR

2.8

36.0

25.7

8.4

3.8

32.0

108.7

567.2

Environmental Sampling - Community

Ranking 1-5

576.5

Protection Multiplier

0.70

LL.

Alarms, travel P
path, visual q

0.95

ad
CC

LL. W
i m
UJ >
CL O
CL O)

Safety clamps for P
hose q

0.95

CC
%
£
%

0.80

Watchman -
comms

GAR

1.0

45.0

27.0

20.0

4.0

20.0

117

Adj GAR

0.7

36.0

25.7

14.0

3.8

16.0

96.2

576.5

Ranking 1-5

536.5

Protection Multiplier

0.70

§
LL.

Alarms, travel P
path, visual q

0.95

ad
CC

"r 8
UJ >
CL O
CL O)

Safety clamps for P
hose q

0.95

c?5
&

0.80

Watchman-
comms

GAR

16.0

100.0

8.0

3.0

36.0

40.0

203

Adj GAR

11.2

80.0

7.6

2.1

34.2

32.0

167.1

536.5

Scale

ICS Form
215A (mod)

Operational Risk
Management Key

Severity

Slight

Minimal

Significant

Major

Catastrophic

Probability

Remote

Un-high

50/50

>50

Very high

Exposure

Episodic

Weekly

Daily

Hourly

Continuous

-------
High Consequence SAFETY ANALYSIS

Chemical exposure

Vehicular injury

Soft-tissue damage (debris /equipment / pinchpc

Aggressive Personnel / Pets

Slips, Trips, Falls - mechanical injury

Moving trains

Total

Severity weighted total possible

Gar Scale Percentage

Chemical Exposure

Vehicular injury

Soft-tissue damage

Aggressive Personnel / Pets

Slips, Trips, Falls - mechanical injury

Moving trains

Hazard Scale

Severity/ Probability/ Exposure

CONTROLS

1. Division:

Residential

2. Date/Time Prepared:

3-23-2023

Task Groups

Traffic / Roadway Navigation

Ranking 1-5

586.5

Protection Multiplier

0.70

§
LL.

Alarms, travel P
path, visual q

0.95

4- 8

LU >
CL o
CL O)

Safety clamps for P
hose q

0.95

c?5
&
K

0.80

Watchman-
comms

GAR

1.0

100.0

36.0

3.0

18.0

40.0

198.0

Adj GAR

0.7

80.0

34.2

2.1

17.1

32.0

166.1

586.5

Environmental Science - Well Testing

Ranking 1-5

576.5

Protection Multiplier

0.70

(0
LL.

Alarms, travel P
path, visual q

0.95

ad
CC

LL. W
LU §

CL O
CL O)

Safety clamps for P
hose q

0.95

c?5

£
o
co

0.80

Watchman-
comms

GAR

1.0

45.0

27.0

12.0

16.0

40.0

141

Adj GAR

0.7

36.0

25.7

8.4

15.2

32.0

118.0

576.5

Environmental Science - Air Monitoring

Ranking 1-5

576.5

Protection Multiplier

0.70

(0
LL.

Alarms, travel P
path, visual q

0.95

ad
CC

LL. W
i m

W >
CL O
CL O)

Safety clamps for P
hose q

0.95

£
o
co

0.80

Watchman-
comms

GAR

1.0

45.0

27.0

12.0

4.0

40.0

129

Adj GAR

0.7

36.0

25.7

8.4

3.8

32.0

106.6

576.5

Personal Communication

Ranking 1-5

576.5

Protection Multiplier

0.70

LL.

Alarms, travel P
path, visual q

0.95

ad
CC

LL. W
i m
UJ >
CL O
CL O)

Safety clamps for P
hose q

0.95

CC
%
£
%

0.80

Watchman -
comms

GAR

8.0

45.0

8.0

20.0

4.0

20.0

105

Adj GAR

5.6

36.0

7.6

14.0

3.8

16.0

83.0

576.5

Ranking 1-5

536.5

Protection Multiplier

0.70

§
LL.

Alarms, travel P
path, visual q

0.95

ad
CC

"r 8
UJ >
CL O
CL O)

Safety clamps for P
hose q

0.95

c?5
&

0.80

Watchman-
comms

GAR

16.0

100.0

8.0

3.0

36.0

40.0

203

Adj GAR

11.2

80.0

7.6

2.1

34.2

32.0

167.1

536.5

Scale

ICS Form
215A (mod)

Operational Risk
Management Key

Severity

Slight

Minimal

Significant

Major

Catastrophic

Probability

Remote

Un-high

50/50

>50

Very high

Exposure

Episodic

Weekly

Daily

Hourly

Continuous

-------
High Consequence SAFETY ANALYSIS

Chemical exposure

Vehicular injury

Soft-tissue damage (debris /equipment / pinchpc

Aggressive Personnel / Pets

Slips, Trips, Falls - mechanical injury

Moving trains

Total

Severity weighted total possible

Gar Scale Percentage

Chemical Exposure

Vehicular injury

Soft-tissue damage

Aggressive Personnel / Pets

Slips, Trips, Falls - mechanical injury

Moving trains

Hazard Scale

Severity/ Probability/ Exposure

CONTROLS

1. Division:

Community Engagement

2. Date/Time Prepared:

3-23-2023

Task Groups

Traffic / Roadway Navigation

Ranking 1-5

586.5

Protection Multiplier

0.70

c
LL

Alarms, travel P
path, visual q

0.95

LL (ft

uj >

Q_ O
CL O)

Safety clamps for P
hose q

0.95

C£.

£
o
w

0.80

Watchman -
comms

GAR

1.0

100.0

36.0

3.0

18.0

40.0

198.0

Adj GAR

0.7

80.0

34.2

2.1

17.1

32.0

166.1

586.5

Community Outreach / Townhall Meetings

Ranking 1-5

597.5

Protection Multiplier

0.70

c
LL

Alarms, travel P
path, visual q

0.95

LL (ft

uj >

CL O
CL O)

Safety clamps for P
hose q

0.95

C£.

£
o
w

0.80

Watchman -
comms

GAR

1.0

30.0

8.0

18.0

10.0

Adj GAR

0.7

24.0

7.6

5.6

17.1

8.0

63.0

597.5

Community Outreach / Welcome Center

Ranking 1-5

597.5

Protection Multiplier

0.70

c
LL

Alarms, travel P
path, visual q

0.95

LL M
UJ >
CL O
CL O)

Safety clamps for P
hose q

0.95

C£.

£
o
w

0.80

Watchman -
comms

GAR

1.0

30.0

8.0

18.0

10.0

Adj GAR

0.7

24.0

7.6

5.6

17.1

8.0

597.5

Personal Communication

Ranking 1-5

597.5

Protection Multiplier

0.70

c
LL

Alarms, travel P
path, visual q

0.95

LL M
UJ >
CL O
CL O)

Safety clamps for P
hose q

0.95

C£.

£
o
w

0.80

Watchman -
comms

GAR

1.0

20.0

8.0

20.0

18.0

10.0

Adj GAR

0.7

16.0

7.6

14.0

17.1

8.0

63.4

597.5

Ranking 1-5

536.5

Protection Multiplier

0.70

c
LL

Alarms, travel P
path, visual q

0.95

LL M
UJ >
CL O
CL O)

Safety clamps for P
hose q

0.95

C£.
%
£
8

0.80

Watchman -
comms

GAR

16.0

100.0

8.0

3.0

36.0

40.0

203

Adj GAR

11.2

80.0

7.6

2.1

34.2

32.0

167.1

536.5

Scale

ICS Form
215A (mod)

Operational Risk
Management Key

Severity

Slight

Minimal

Significant

Major

Catastrophic

Probability

Remote

Un-high

50/50

>50

Very high

Exposure

Episodic

Weekly

Daily

Hourly

Continuous

-------
JOB SAFETY ANALYSIS

OPERATIONAL DIV:

Wreck site/Track Removal

WORK TASK:

Railcar manipulations & wrecking

DATE:

03/19/2023

COMMUNICATION PLAN:

One member of group should be equipped with a functional radio monitoring the safety channel established for all site
personnel. If operating equipment and using additional radios, monitor safety channel in additional to operational channel

FIRST AID/MEDICAL PROVISIONS:

Ensure access to first aid supplies, identify the kit location before starting work. Identify safe egress from your location to
locate emergency response medical if activated.

PERSONAL PROTECTIVE EQUIPMENT REQUIRED:

Gloves, FRA- approved reflective vests, eye protection, long sleeves, safety boots. If increased PPE is warranted, consult
recommendations in NS JSA(s).

POTENTIAL HAZARDS

RECOMMENDED ACTION

ADDITIONAL CONTROLS

Moving trains

Maintain situational awareness at all
times.

Track protection (if applicable)

Avoid fouling track unless approved by
RR Employee In Charge (EIC)

Identify a group spotter to watch for
trains.

Roadway worker protection rules
Maintain > 4' distance from field
side of nearest running rail

Chemical hazards

Communicate chemicals and potential
for exposure

Avoid BZ entering confined spaces
Describe symptoms of exposure
Assess for presence during work

NS Chemical Specific JSAs

Air monitoring or review of available

data

Radial axial fans for source dilution
and mobilization away from workers

Heavy equipment

Avoid presence or walking through
machine's operating radius
Visual contact with operator when
walking behind or up to machine

Utilize a spotter when working as a
group near operational equipment.
Identify boom radius of excavators
All stop when horn is activated

Sharp objects

Locate scrap steel, existing sharp metal
objects

Avoid contact with sharp objects
through situational awareness

Utilize gloves when handling or
grabbing metal or hardened objects
that can cut or damage skin on hands
Ensure full-length FRC sleeves and
pants

High-pressure liquid release

Ensure hose clamp pins are installed
Use caution when disconnecting once
pressurized lines for residual
Assume all lines are pressurized until
confirmation

Distance during disconnection
Pressure gauges & other means of
determining if lines are pressurized
Control lines when disconnecting
with restraints if applicable

Overhead lifts/mechanical
injury

Avoid walking below suspended loads
on excavators, front-end loaders, etc.
Do not reach between moving
mechanical components or lifted loads

Only qualified personnel and
operators should be in areas where
suspended loads, or mechanical lifts
are underway.

CHANGE IN CONDITIONS

SPECIAL CONSIDERATIONS

EMERGENCY PROCEDURES

Weather-related impact
Operational changes that
challenge existing control
measures

Muster locations on Site
Control map
Communicate additional
chemical hazards upon
observation

All site personnel have STOP WORK
AUTHORITY

Operational changes that create
additional hazards

Identify muster locations before work
begins,

o egress cross then upwind
o remain at muster and rollcall

Health:

o Render first aid for non-life-

threatening injury
o Call 9-11 when injury
requires beyond first aid
Alarms & warnings

o 1 short blast = attention
o 3 long horn blasts = egress

-------
-------
JOB SAFETY ANALYSIS

AREA OF OPERATION:

Work area - Refer to NS JSAs
for more detail

OPERATIONAL PERIOD:

FROM: 07:00 TO: 19:00

DATE:

03/02/2023

COMMUNICATION PLAN:

FIRST AID/MEDICAL PROVISIONS:

Ensure access to first aid supplies, identify the kit location before starting work. Identify safe egress from your location to
locate emergency response medical if activated.

PERSONAL PROTECTIVE EQUIPMENT REQUIRED:

Gloves, FRA- approved reflective vests, eye protection, long sleeves, safety boots. If increased PPE is warranted, consult
recommendations in NS JSA(s).

POTENTIAL HAZARDS

RECOMMENDED ACTION

ADDITIONAL CONTROLS

Moving trains

Maintain situational awareness at all
times.

Track protection (if applicable)

Avoid fouling track unless approved by
RR Employee In Charge (EIC)

Identify a group spotter to watch for
trains.

Roadway worker protection rules
Maintain > 4' distance from field
side of nearest running rail

Chemical hazards

Communicate chemicals and potential
for exposure

Describe symptoms of exposure
Assess for presence during work

NS Chemical Specific JSAs

Air monitoring or review of available

data

Heavy equipment

Avoid presence or walking through
machine's operating radius
Visual contact with operator when
walking behind or up to machine

Utilize a spotter when working as a
group near operational equipment.
Identify boom radius of excavators
All stop when horn is activated

Sharp objects

Locate scrap steel, existing sharp metal
objects

Avoid contact with sharp objects
through situational awareness

Utilize gloves when handling or
grabbing metal or hardened objects
that can cut or damage skin on hands
Ensure full-length FRC sleeves and
pants

Pedestrian traffic hazards

Ensure proper footing when traversing
uneven terrain

Be mindful of ballast and large rock for
lower leg injuries

Assume all operators do not see you

Avoid walking in areas where your
presence is not essential
Avoid standing in areas where your
presence is not warranted

Overhead lifts/mechanical
injury

Avoid walking below suspended loads
on excavators, front-end loaders, etc.
Do not reach between moving
mechanical components or lifted loads

Only qualified personnel and
operators should be in areas where
suspended loads, or mechanical lifts
are underway.

CHANGE IN CONDITIONS

SPECIAL CONSIDERATIONS

EMERGENCY PROCEDURES

Weather-related impact
Operational changes that
challenge existing control
measures

Muster locations on Site
Control map
Communicate additional
chemical hazards upon
observation

All site personnel have STOP WORK
AUTHORITY

Operational changes that create
additional hazards

Identify muster locations before work
begins,

o egress cross then upwind
o remain at muster and rollcall

Health:

o Render first aid for non-life-

threatening injury
o Call 9-11 when injury
requires beyond first aid
Alarms & warnings

o 1 short blast = attention
o 3 long horn blasts = egress

-------
Site Control Map

•Water Bypass

[smBTH

jNorth VGllmpacted]
Scrapping Waste

Scrapping

AreaJAWa
I ffipa clod -
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,Area^W^-

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[Water Bypass]

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Exclusion Zone - Drainage pipe

Contamination Reduction Zone

Support Zone

frTank"][iarm-3t

Decontamination

Traffic Checkpoiunt

Traffic Flow

Muster

DRAFT

Attorney-Client Privilege/Attorney Work Product/
Prepared at the Direction of Counsel

Map Date: 3/1/2023

Drone imagery date: 02/28.

ON SITE FEATURES

P» ARCADIS

-------
JOB SAFETY ANALYSIS

AREA OF OPERATION:

Public work

OPERATIONAL PERIOD:

FROM: 07:00 TO: 19:00

DATE:

03/03/2023

COMMUNICATION PLAN:

FIRST AID/MEDICAL PROVISIONS:

Ensure access to first aid supplies, identify the kit location before starting work. Identify safe egress from your location to
locate emergency response medical if activated.

PERSONAL PROTECTIVE EQUIPMENT REQUIRED:

Professional/work attire. Use high-vis vest for work near active roadways. Visible ID or identification through affiliate
logos

POTENTIAL HAZARDS

RECOMMENDED ACTION

ADDITIONAL CONTROLS

Slip/Trip/Fall

Maintain situational awareness at all
times.

Focus on pedestrian travel path

Communicate difficult travel
conditions to working group

Dangerous animals

Survey the location for animals wild or

domestic outside in proximity to group

Do not interact with or confront animals

of any kind

Use the buddy system

Ensure property owner has control of

any animals at residences

Consider using local law

enforcement or animal control in

certain instances

Stop work if solution cannot be

presented

Disgruntled persons

Avoid contact with visible disturbed or
angry persons

Make a reasonable attempt to de-

escalate confrontations.

Egress if initial efforts to de-escalate are

unsuccessful

Always use buddy system

Consider local law enforcement
escort for instances where contention
is believed or observed prior to
access

Maintain safe egress path at all times
Identify 1 person to activate 9-11 in
all cases even when confrontation is

V ehicle/roadway

Always wear seatbelts
No distracted driving will be tolerated
Abide by all local and state driving
laws, including speed restriction and
approved travel/parking corridors

Use a back-up spotter at all times
when available

Back into approved parking space for
rapid egress, use spotter
Avoid working on or too closely to
active roadways.

CHANGE IN CONDITIONS

SPECIAL CONSIDERATIONS

EMERGENCY PROCEDURES

Weather-related impact
Operational changes that
challenge existing control
measures

Muster locations on Site
Control map
Communicate additional
chemical hazards upon
observation

All site personnel have STOP WORK
AUTHORITY

Operational changes that create
additional hazards

Identify muster locations before work
begins,

o egress cross then upwind
o remain at muster and rollcall

Health:

o Render first aid for non-life-

threatening injury
o Call 9-11 when injury
requires beyond first aid
Alarms & warnings

o 1 short blast = attention
o 3 long horn blasts = egress

-------
Site Control Map

•Water Bypass

[smBTH

jNorth VGllmpacted]
Scrapping Waste

Scrapping

AreaJAWa
I ffipa clod -
. Wast^Staqinql

,Area^W^-

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[SME>6]

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[^qinoTArea"

Exclusion Zone - Drainage pipe

Contamination Reduction Zone

Support Zone

frTank"][iarm-3t

Decontamination

Traffic Checkpoiunt

Traffic Flow

Muster

DRAFT

Attorney-Client Privilege/Attorney Work Product/
Prepared at the Direction of Counsel

Map Date: 3/1/2023

Drone imagery date: 02/28.

ON SITE FEATURES

P» ARCADIS

-------
JOB SAFETY ANALYSIS

AREA OF OPERATION:

Environmental

assessment/impact prevention

OPERATIONAL PERIOD:

FROM: 07:00 TO: 19:00

DATE:

03/03/2023

COMMUNICATION PLAN:

FIRST AID/MEDICAL PROVISIONS:

Ensure access to first aid supplies, identify the kit location before starting work. Identify safe egress from your location to
locate emergency response medical if activated.

PERSONAL PROTECTIVE EQUIPMENT REQUIRED:

Level D PPE, specifically: hardhat, safety toe boots, safety glasses, high visibility vest. Tyvek may be worn to prevent
soiling.

POTENTIAL HAZARDS

RECOMMENDED ACTION

ADDITIONAL CONTROLS

Slip/Trip/Fall

Maintain situational awareness at all
times.

Focus on pedestrian travel path
Establish solid, slip-resistant travel
paths for regular travel corridors

Communicate difficult travel
conditions to working group
Install earthen or synthetic steps for
areas with steep traverse and regular
travel.

Debris hazards, sharp objects

Remove hazardous debris from the
work area if possible
Mark sharp objects if unable to abate
Handle sharps with gloves and only
store sharp objects with covered blades
Use hand tools responsible and with
specific purpose, no modifications

Use tape or high-vis paint to
demarcate sharp objects or hazardous
debris that cannot be removed.
Be your brother's keeper, watch out
for each other when walking
throughout work area

Water hazards

Avoid traversing water ways and creeks
that are of a depth where drowning risk
is present

Maintain sure footing when walking
through or near shallow waterways

USCG approved PFDs may be
necessary in certain instances
Demarcate approved travel pathways
along waterways.

V ehicle/roadway

Always wear seatbelts
No distracted driving will be tolerated
Abide by all local and state driving
laws, including speed restriction and
approved travel/parking corridors

Use a back-up spotter at all times
when available

Back into approved parking space for
rapid egress, use spotter
Avoid working on or too closely to
active roadways.

Overhead lifts/mechanical
injury

Ensure proper ergonomics for lifting or
awkward body positions

Team lifts for objects greater than 50
lbs.

CHANGE IN CONDITIONS

SPECIAL CONSIDERATIONS

EMERGENCY PROCEDURES

Weather-related impact
Operational changes that
challenge existing control
measures

Muster locations on Site
Control map
Communicate additional
chemical hazards upon
observation

All site personnel have STOP WORK
AUTHORITY

Operational changes that create
additional hazards

Identify muster locations before work
begins,

o egress cross then upwind
o remain at muster and rollcall

Health:

o Render first aid for non-life-

threatening injury
o Call 9-11 when injury
requires beyond first aid
Alarms & warnings

o 1 short blast = attention
o 3 long horn blasts = egress

-------
Site Control Map

•Water Bypass

[smBTH

jNorth VGllmpacted]
Scrapping Waste

Scrapping

AreaJAWa
I ffipa clod -
. Wast^Staqinql

,Area^W^-

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[Water Bypass]

[SME>6]

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tTank^reaTll

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jSSIiclification/bxcavation;
fe*a*"'"^Area.2:.-—

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[smbTiI

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Kk&SI

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HtCouritvBl
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fStaqinqfe'i^l

BRolllOff?
[^qinoTArea"

Exclusion Zone - Drainage pipe

Contamination Reduction Zone

Support Zone

frTank"][iarm-3t

Decontamination

Traffic Checkpoiunt

Traffic Flow

Muster

DRAFT

Attorney-Client Privilege/Attorney Work Product/
Prepared at the Direction of Counsel

Map Date: 3/1/2023

Drone imagery date: 02/28.

ON SITE FEATURES

P» ARCADIS

-------
JOB SAFETY ANALYSIS

AREA OF OPERATION:

Aeration WWTP

OPERATIONAL PERIOD:

FROM: 07:00 TO: 19:00

DATE:

COMMUNICATION PLAN:

Communication methods between crews shall be verbal/face to face. If other crews need to contact other personnel, cell phones will
be used

FIRST AID/MEDICAL PROVISIONS:

First Aid Kits Shall be in the closest SPSI supervisor truck

PERSONAL PROTECTIVE EQUIPMENT REQUIRED:

Water Resistant Gloves, FRA- approved reflective vests, eye protection, long sleeves, safety boots, hip waders. If increased PPE is
warranted, consult recommendations inNS JSA(s).

POTENTIAL HAZARDS

RECOMMENDED ACTION

ADDITIONAL CONTROLS

Working in and around water

When working within 6' of the shoreline, a
Personal floatation must be worn
No working inside the water is allowed
during the night shift

No working inside the water is allowed
if swift water conditions are present

Chemical Exposure

When working in water, PVC gloves and
hip waders must be worn.

Before lunch or end of shift, hand must be
washed with soap and water or hand wipes.

If air quality becomes unsafe provided
by CTEH, all personnel will immediately
leave the area

Pedestrian Traffic/Rough Terrain

Avoid deep mud areas if possible.

When performing maintenance on machines
avoid climbing on trailers
During cold weather conditions avoid
wet/icy walking surfaces

A rope set up should be used to assist
entry into the creek

Spills/Leaks

Containments under machines must be
cleaned out daily.

Contain all possible drips with white
absorbent pads

When starting up aeration ops using
portable monitors, ensure they are
pointed in appropriate direction back
into sulfur run

Hot engines

When checking fluids on machines, hot
engines should be shut off and left to cool
down before checking fluids.

Gloves must be worn when checking fluids

If any fuel spills or drips occur on
containment, they should be cleaned up
before operations continue.

CHANGE IN CONDITIONS

SPECIAL CONSIDERATIONS

EMERGENCY PROCEDURES

Weather-related impact
Operational changes that
challenge existing control
measures

Muster locations on Site
Control map
Communicate additional
chemical hazards upon
observation

All site personnel have STOP WORK
AUTHORITY

Operational changes that create additional
hazards

Identify muster locations before entering
work area,

o egress cross then upwind
o remain at muster and rollcall

Health:

o Render first aid for non-life-

threatening injury
o Call 9-11 when injury requires
beyond first aid
Alarms & warnings

o 1 short blast = attention
o 3 long horn blasts = egress

-------
JOB SAFETY ANALYSIS

AREA OF OPERATION:

South Side (Excavation and Dirt
Moving Operations)

OPERATIONAL PERIOD:

FROM: 07:00 TO: 19:00

DATE:

COMMUNICATION PLAN:

A form of communication between operators and truck drivers must be established (i.e. horn). All other communications will be visual
contact with spotters

FIRST AID/MEDICAL PROVISIONS:

A first aid kit will be available in the nearest SPSI supervisor vehicle. If treatment above first aid is required, call 911 for emergency
services or take the induvial(s) to a medical treatment center.

PERSONAL PROTECTIVE EQUIPMENT REQUIRED:

Gloves, FRA- approved reflective vests, eye protection, long sleeves, safety boots. If increased PPE is warranted, consult
recommendations in NS JSA(s).

POTENTIAL HAZARDS

RECOMMENDED ACTION

ADDITIONAL CONTROLS

Moving trains

Always maintain situational awareness.
Track protection (if applicable)

Avoid fouling track unless approved by RR
Employee in Charge (EIC)

Identify a group spotter to watch for
trains.

Roadway worker protection rules
Maintain > 6' distance from field side of
nearest running rail

Inhalation/Dermal Exposure

Communicate chemicals onsite and
potential for exposure.

Describe symptoms of exposure
Assess for presence during work

NS Chemical Specific JSAs

Air monitoring or review of available

data

Dermal PPE (PVC Boots, Gloves)
Respiratory Protection (APR/SCBA)

Moving Machinery

Avoid presence or walking through
machine's operating radius.

Visual contact with operator when walking
behind or up to machine

Utilize a spotter when working as a
group near operational equipment.
Identify boom radius of excavators.
All stop when horn is activated

Sharp objects

Locate scrap steel, existing sharp metal
objects.

Avoid contact with sharp objects through
situational awareness.

Utilize gloves when handling or
grabbing metal or hardened objects that
can cut or damage skin on hands.
Ensure full-length FRC sleeves and
pants

Rough Walking Working
Surfaces/Working From Heights

Ensure proper footing when traveling

through uneven terrain.

Be mindful of ballast, large rock, and rail

for lower leg injuries.

Assume all operators do not see you.

Avoid walking in areas where your

presence is not essential.

Avoid standing in areas where your

presence is not warranted.

Three Points of Contact when Climbing

A competent person must inspect

scaffolding every day.

Avoid reaching over hand rails of

scaffolding

Overhead lifts/mechanical injury

Avoid walking below suspended loads on
excavators, front-end loaders, etc.

Do not reach between moving mechanical
components or lifted loads

Only qualified personnel and operators
should be in areas where suspended
loads, or mechanical lifts are underway.

CHANGE IN CONDITIONS

SPECIAL CONSIDERATIONS

EMERGENCY PROCEDURES

Weather-related impact
Operational changes that
challenge existing control
measures

Muster locations on Site
Control map
Communicate additional
chemical hazards upon
observation

All site personnel have STOP WORK
AUTHORITY

Operational changes that create additional
hazards

Identify muster locations before work
begins,

o egress cross then upwind
o remain at muster and rollcall

Health:

o Render first aid for non-life-

threatening injury
o Call 9-11 when injury requires
beyond first aid
Alarms & warnings

o 1 short blast = attention
o 3 long horn blasts = egress

-------
Name

Signature

Date

-------
JOB SAFETY ANALYSIS

AREA OF OPERATION:

Around Site (Fueling Operations)

OPERATIONAL PERIOD:

FROM: 07:00 TO: 19:00

DATE:

COMMUNICATION PLAN:

Communication shall be designated through cell phones and fuelers must pull over to respond to phone calls and text messages

FIRST AID/MEDICAL PROVISIONS:

First Aid Kits Shall be

PERSONAL PROTECTIVE EQUIPMENT REQUIRED:

Petroleum Resistant Gloves, FRA- approved reflective vests, eye protection, long sleeves, safety boots. If increased PPE is warranted,
consult recommendations in NS JSA(s).

POTENTIAL HAZARDS

RECOMMENDED ACTION

ADDITIONAL CONTROLS

Fire/Explosion

Fueling operations shall be carried out in
well-ventilated areas.

Ignition sources shall be shut off or be at
least 35' away from fueling

A fire extinguisher must be on standby
within 50' of fueling.

Do not store flammable liquids inside
cab or any enclosed space

Rough Walking Working Surfaces

Ensure proper footing when on ballast, large
stone, and muddy areas.

When climbing on machines, use three
points of contact to climb

Avoid ice covered areas and wait for salt
or temperature to melt the ice.

Traffic and vehicle operation
hazards

Obey all road laws and follow traffic
controls direction.

Perform a 360 walk around before backing
up vehicles

If possible, use a spotter when backing
up

Lifting and Ergonomic Hazards

Avoid carrying multiple fuel containers.
Lift predominantly with legs
Avoid holding fuel containers above the
shoulder area.

Fuel gas containers on tailgate of vehicle
to prevent unnecessary lifts.

Dermal Exposure

Use nitrile or PVC gloves when fueling.
Contain any drips or spills on white pads or
containments.

Monitor filling to prevent overflows

CHANGE IN CONDITIONS

SPECIAL CONSIDERATIONS

EMERGENCY PROCEDURES

Weather-related impact
Operational changes that
challenge existing control
measures

Muster locations on Site
Control map
Communicate additional
chemical hazards upon
observation

All site personnel have STOP WORK
AUTHORITY

Operational changes that create additional
hazards

Identify muster locations before entering
work area,

o egress cross then upwind
o remain at muster and rollcall

Health:

o Render first aid for non-life-

threatening injury
o Call 9-11 when injury requires
beyond first aid
Alarms & warnings

o 1 short blast = attention
o 3 long horn blasts = egress

-------
: JOB SAFETY ANALYSIS

AREA OF OPERATION:

Jetting Operation on Sulfur
Run by T & M Industries

OPERATIONAL PERIOD:

FROM: 09:30 TO: 19:00

DATE:

03/16/2023

COMMUNICATION PLAN:

On both sides of the jetting operation, at least one crew member should have a radio to establish safe communication of
jetter line location.

FIRST AID/MEDICAL PROVISIONS:

Ensure access to first aid supplies, identify the kit location before starting work. Identify safe egress from your location to
locate emergency response medical if activated.

PERSONAL PROTECTIVE EQUIPMENT REQUIRED:

Gloves, FRA- approved reflective vests, eye protection, long sleeves, safety boots. Near shoreline operations, waterproof
waders and a PFD are required. If increased PPE is warranted, consult recommendations in NS JSA(s).

POTENTIAL HAZARDS

RECOMMENDED ACTION

ADDITIONAL CONTROLS

High Pressure Jetter Line

Communicate Jetter Distance Inside
Tunnel/Culvert

Keep 50' Distance from Tunnel
Entrance/Exit when Jetter is in
Operation

Keep Jetting Operations contained
within the confined area.

Working In and Around Water

Keep Secure footing and avoid climbing
on rocks/ Debris.

Don PFD when around or in water
Don Waterproof Gloves

Wash/Clean hands when breaking for
lunch or end of shift

Pinch Points around Jetter
Truck

Avoid contract with jetter hose or real
when retracting jetter line.

Keep Clear of jetter head when
retracting in the event of a kick or jump

Utilize a spotter when jetter line is
retracting/advancing into the tunnel.
Utilize a spotter when positioning
jetter

Sharp objects

When working in the stream, ensure
proper footing to prevent falls onto
rocks or debris in water.

When handling hoses and metal
equipment, leather gloves should be
used

If any sharps or needles are found in
the work area, Hepaco will be the
party responsible for disposing of the
material

Pedestrian traffic hazards

Ensure proper footing when traversing
uneven terrain.

Be mindful of ballast and large rock for
lower leg injuries.

Assume all operators do not see you

Avoid walking in areas where your
presence is not essential.

Avoid standing in areas where your
presence is not warranted

Chemical Exposure

When working with and around creek
water, PVC gloves and rubber boots
should be used.

During Jetting operations, air
monitoring must be present

When packaging impacted material
in waste containers, use proper PPE
and double bag material to move
across rough terrain

CHANGE IN CONDITIONS

SPECIAL CONSIDERATIONS

EMERGENCY PROCEDURES

Weather-related impact
Operational changes that
challenge existing control
measures

Muster locations on Site
Control map
Communicate additional
chemical hazards upon
observation

All site personnel have STOP WORK
AUTHORITY

Operational changes that create
additional hazards

Identify muster locations before work
begins,

o egress cross then upwind
o remain at muster and rollcall

Health:

o Render first aid for non-life-

threatening injury
o Call 9-11 when injury
requires beyond first aid
Alarms & warnings

o 1 short blast = attention
o 3 long horn blasts = egress

-------
-------
JOB SAFETY ANALYSIS

AREA OF OPERATION:

Lordstown Water Transfer

OPERATIONAL PERIOD:

FROM: 07:00 TO: 19:00

DATE:

COMMUNICATION PLAN:

Communication methods between crews shall be verbal/face to face. If other crews need to contact other personnel, cell phones will
be used

FIRST AID/MEDICAL PROVISIONS:

First Aid Kits Shall be in the closest SPSI supervisor truck

PERSONAL PROTECTIVE EQUIPMENT REQUIRED:

PVC Gloves, FRA- approved reflective vests, eye protection, long sleeves, safety boots. If increased PPE is warranted, consult
recommendations in NS JSA(s).

POTENTIAL HAZARDS

RECOMMENDED ACTION

ADDITIONAL CONTROLS

Fire/Explosion

Grounding and bonding must be in place
when loading and unloading railcars.
When loading Rail cars, tanks must be
vented to prevent and increase of pressure

Transfer pumps must be shut off before
fueling operations can begin.

Highway tankers must not exceed 10 psi
when pressuring up

Chemical Exposure

PVC gloves must be worn when moving
waste.

When gauging tanks, APR's with
PlOO/organic vapor cartridges must be worn

Contain all lines breaks within
containments and open hoses away from
the body

Working From Heights

When gauging railcars, Personnel should
only be on top of the tank for a limited time
to measure outage.

When climbing on rail cars, three points of
contact must be always maintained

Personnel climbing on top of highway
tankers must always maintain 3 points of
contact.

Tools shall not be carried to the top of
tanks; rope bags must be used to lift
tools

Struck by/Vehicle Accident

Spotters must be always used when vehicles
are backing up or near other vehicles/
property.

Rail cars being involved in transfer ops
must be choked.

When walking around vehicles, contact
with drivers must be made to prevent
working in blind spots.

Spills/Leaks

Transfer hoses must be cleared and walked
out into a container before breaking down
transfer system.

Camlock fittings must be taped/secured
during liquid movement

All Line breaks must be over
containments and in drip pans to prevent
any uncontrolled liquid

-Pedestrian Traffic/Rough Terrain

Keep secure footing when walking on large
stone, rail, or over containments.
No walking between railcars is permitted

When hoses are not in use they should be
rolled neatly and placed in an area that
would not make them a tripping hazard

CHANGE IN CONDITIONS

SPECIAL CONSIDERATIONS

EMERGENCY PROCEDURES

Weather-related impact
Operational changes that
challenge existing control
measures

Muster locations on Site
Control map
Communicate additional
chemical hazards upon
observation

All site personnel have STOP WORK
AUTHORITY

Operational changes that create additional
hazards

Identify muster locations before entering
work area,

o egress cross then upwind
o remain at muster and rollcall

Health:

o Render first aid for non-life-

threatening injury
o Call 9-11 when injury requires
beyond first aid
Alarms & warnings

o 1 short blast = attention
o 3 long horn blasts = egress

-------
JOB SAFETY ANALYSIS

AREA OF OPERATION:

Tank Farm Water Transfer

OPERATIONAL PERIOD:

FROM: 07:00 TO: 19:00

DATE:

COMMUNICATION PLAN:

Communication methods between crews shall be verbal/face to face. If other crews need to contact other personnel, cell phones will
be used

FIRST AID/MEDICAL PROVISIONS:

First Aid Kits Shall be in the closest SPSI supervisor truck

PERSONAL PROTECTIVE EQUIPMENT REQUIRED:

Petroleum Resistant Gloves, FRA- approved reflective vests, eye protection, long sleeves, safety boots. If increased PPE is warranted,
consult recommendations in NS JSA(s).

POTENTIAL HAZARDS

RECOMMENDED ACTION

ADDITIONAL CONTROLS

Fire/Explosion

Grounding and bonding must be in place
when loading and unloading trucks.

When loading highway tankers, tanks must
be vented to prevent and increase of
pressure

Transfer pumps must be shut off before
fueling operations can begin.

Chemical Exposure

PVC gloves must be worn when moving
waste.

When gauging tanks, respirators must be
worn

Contain all lines breaks within
containments and open hoses away from
the body

Working From Heights

When gauging highway tankers, Personnel
should only be on top of the tank for a
limited time to measure outage
When climbing on frac tanks, three points
of contact must be maintained

Personnel climbing on top of highway
tankers must always maintain 3 points of
contact.

When taking tank measurements on frac
tanks, 3 points of contact must be
maintained

Struck by/Vehicle Accident

Spotters must be always used when vehicles
are backing up or near other vehicles or
property.

When walking around vehicles, contact
with drivers must be made to prevent
working in blind spots.

Spills/Leaks

Transfer hoses must be cleared and walked
out into container before breaking down
transfer system.

Camlock fittings must be taped/secured
during liquid movement

All Line breaks must be over
containments and in drip pans to prevent
any uncontrolled liquid

-Pedestrian Traffic/Rough Terrain

Keep secure footing when walking on large
stone or over containments.

Avoid walking on wet/ice covered
containments

When climbing frac tank steps, use
handrails.

CHANGE IN CONDITIONS

SPECIAL CONSIDERATIONS

EMERGENCY PROCEDURES

Weather-related impact
Operational changes that
challenge existing control
measures

Muster locations on Site
Control map
Communicate additional
chemical hazards upon
observation

All site personnel have STOP WORK
AUTHORITY

Operational changes that create additional
hazards

Identify muster locations before entering
work area,

o egress cross then upwind
o remain at muster and rollcall

Health:

o Render first aid for non-life-

threatening injury
o Call 9-11 when injury requires
beyond first aid
Alarms & warnings

o 1 short blast = attention
o 3 long horn blasts = egress

-------
JOB SAFETY ANALYSIS

AREA OF OPERATION:

Truck Decon.

OPERATIONAL PERIOD:

FROM: 07:00 TO: 19:00

DATE:

COMMUNICATION PLAN:

Communication methods between crews shall be verbal/face to face. If other crews need to contact personnel, cell phones will be
used

FIRST AID/MEDICAL PROVISIONS:

First Aid Kits Shall be in the closest SPSI supervisor truck

PERSONAL PROTECTIVE EQUIPMENT REQUIRED:

Petroleum Resistant Gloves, Tychem QC, FRA- approved reflective vests, eye protection, long sleeves, safety boots. If increased PPE
is warranted, consult recommendations in NS JSA(s).

POTENTIAL HAZARDS

RECOMMENDED ACTION

ADDITIONAL CONTROLS

Fire/Explosion

Heaters and pressure washer units must be
turned off before fueling operations can
begin.

Ensure caps to fuel tanks are secured and
tightened.

The hot pressure washer should not be
run inside the trailer.

When pressure washer units are not in
use, units should be turned off.

Chemical/Mud Exposure

Tychem QC suits should be worn to prevent
clothing becoming contaminated by
splashes.

Face shields and gloves should also be worn
to prevent any splashing from hitting the
operators face

A distance should be kept from the point
of operation to minimize the amount of
splash/mud kick up.

Avoid entry to pressure washer trailers
while they are running

Pressure Washer

The pressure washer gun should always be
pointed away from people.

When changing pw gun tips. The pressure
washer should be shut down and all the
pressure in the hose should be bled off

Windows of vehicles getting pressure
washed, must close all windows,
otherwise operators must leave the
vehicle

Struck by/Vehicle Accident

Stand out of the way of vehicles pulling
onto containment.

Spot vehicles backing onto containment.
Keep clear of equipment blind spots

Contact driver before spotting vehicles.
Work area must maintain good
housekeeping and leave clear paths for
vehicles to prevent injury/damage.

-Pedestrian Traffic/Rough Terrain

Keep secure footing when walking on large
stone or over containments.

Avoid walking on wet/ice covered
containments

Avoid walking on containment berms.
Keep Hoses neat and out of walking
paths.

CHANGE IN CONDITIONS

SPECIAL CONSIDERATIONS

EMERGENCY PROCEDURES

Weather-related impact
Operational changes that
challenge existing control
measures

Muster locations on Site
Control map
Communicate additional
chemical hazards upon
observation

All site personnel have STOP WORK
AUTHORITY

Operational changes that create additional
hazards

Identify muster locations before entering
work area,

o egress cross then upwind
o remain at muster and rollcall

Health:

o Render first aid for non-life-

threatening injury
o Call 9-11 when injury requires
beyond first aid
Alarms & warnings

o 1 short blast = attention
o 3 long horn blasts = egress

-------
rJOFtFOLK SOUTHEfflS!

JOB SAFETY ANALYSIS
CHEMICAL-SPECIFIC WORKSHEET

< FLAMMABLE >

\ /

Date:

February 13, 2018

Chemical:

Butyl acrylate

Location:

Emergency Response Site

Prepared By:

Scott Skelton, MS, CIH

Version:

Butyl Acrylate_JSA2.0_2018

Emergency Procedures

Muster Point

Egress cross-wind, then upwind to:
Entrance Gate

Medical Emergency

1) Call 911, 2) Administer First Aid, 3) Contact
Site Safety Officer

Emergency Signal

3 long horn blasts, hand signals for entry team

Site Safety Contact

John Doe, Site Safety Officer, Phone: 555-123-
5555

Notice: The content included in this JSA has been prepared in advance of its use during
an actual event. Workers engaged in response operations associated with butyl acrylate
should use this JSA only after assessing site hazards daily to determine the effectiveness
and completeness of this JSA's content. This JSA should not be used as the only safety
provision for activities involving a butyl acrylate tank car. Please refer to the Norfolk
Southern Corporate Emergency Response Plan (ERP), Contractor and Employee Safety
rules, and site safety plans as necessary for policies and procedures not identified
herein.

-------
IMOFtFOi-K SOUTHER!M

Job Safety Analysis Chemical-Specific Worksheet

Butyl ocrylote

Chemical Safety Information1:

Butyl acrylate

Hazardous Property

Important Considerations & Safety Procedures

Health Hazard

Acute exposure to butyl acrylate vapor can cause redness, tearing, and irritation of the eyes, runny nose, scratchy
throat, difficult breathing, and redness and cracking of skin. Repeated contact of the skin with butyl acrylate may
cause skin sensitization in some individuals, with redness, swelling, itching, and oozing of the affected areas.
Nervous system and behavioral effects are also possible. (NIOSH, 1992).

OSHA (GHS) hazard statements:

~ Causes skin irritation,

~ May cause allergic skin reaction,

~ Causes serious eye irritation,

~ Harmful if inhaled, and

~ May cause respiratory irritation

Flammability & Explosion

HIGHLY FLAMMABLE: Will be easily ignited by heat, sparks or flames. Vapors may form explosive
mixtures with air. Vapors may travel to source of ignition and flash back. Most vapors are heavier
than air. They will spread along ground and collect in low or confined areas (sewers, basements,
tanks). Vapor explosion hazard indoors, outdoors or in sewers. Those substances designated with a
(P) may polymerize explosively when heated or involved in a fire. Runoff to sewer may create fire or
explosion hazard. Containers may explode when heated. Many liquids are lighter than water. (ERG,
2016)

Flash Point: 120 ° F (NTP, 1992)

Lower Explosive Limit (LEL): 1.5 % (NTP, 1992)

Upper Explosive Limit (UEL): 9.9 % (NTP, 1992)

Autoignition Temperature: 534 ° F (USCG, 1999)

Firefighting

Excerpt from ERG Guide 129P [Flammable Liquids (Water-Miscible / Noxious)]:

CAUTION: All these products have a very low flash point: Use of water spray when fighting fire may
be inefficient.

SMALL FIRE: Dry chemical, C02, water spray or alcohol-resistant foam. Do not use dry chemical
extinguishers to control fires involving nitromethane (UN1261) or nitroethane (UN2842).

LARGE FIRE: Water spray, fog or alcohol-resistant foam. Do not use straight streams. Move
containers from fire area if you can do it without risk.

1 NOAA CAMEO Chemicals, Globally Harmonized System, OSHA

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i\joFti=oL-i< sou~rni=Ftr\i • Job Safety Analysis Chemical-Specific Worksheet Butyl acrylate

FIRE INVOLVING TANKS OR CAR/TRAILER LOADS: Fight fire from maximum distance or use
unmanned hose holders or monitor nozzles. Cool containers with flooding quantities of water until
well after fire is out. Withdraw immediately in case of rising sound from venting safety devices or
discoloration of tank. ALWAYS stay away from tanks engulfed in fire. For massive fire, use unmanned
hose holders or monitor nozzles; if this is impossible, withdraw from area and let fire burn. (ERG,
2016)

Reactivity

BUTYL ACRYLATE reacts exothermically with acids to liberate heat along with alcohols and acids.
Reacts with strong oxidizing agents, perhaps sufficiently exothermically to ignite the reaction
products. Mixing with basic solutions generates heat. Generates flammable hydrogen with alkali
metals and hydrides. Attacks many plastics [Handling Chemicals Safely 1980. p. 233], Polymerizes
readily, generating much heat in a reaction that is favored by heat and light [Handling Chemicals
Safely 1980. p. 235],

From DOW (Manufacturer): Stable under recommended storage conditions. Unstable at elevated
temperatures. Hygroscopic inhibitor may be added to product, depending on whether classified as
"stabilized". However this material can undergo hazardous polymerization. Avoid moisture. Do not
blanket or purge with an inert gas to avoid depleting of oxygen concentration. Avoid direct sunlight
or ultraviolet sources.

Avoid contact with oxidizing materials. Avoid contact with: aldehydes, azides, amines, ethers, free
radical inhibitors, halides, mercaptans, mineral acids, peroxides, rust, strong inorganic bases; metals
such as: brass and copper. Avoid unintended contact with silica gel and activated carbon. Avoid
contact with absorbent materials such as clay-based sorbents.

Volatility/Mobility

Vapor Pressure: 10 mm Hg at 95.9 ° F ; 4 mm Hg at 68° F (NTP, 1992)

Vapor Density (Relative to Air): 4.42 (NTP, 1992)

Specific Gravity: 0.899 at 68 ° F (USCG, 1999)

Boiling Point: 295 to 298 ° F at 760 mm Hg (NTP, 1992)

Molecular Weight: 128.17 (NTP, 1992)

Water Solubility: less than 1 mg/mL at 68° F (NTP, 1992)

Ionization Potential: data unavailable

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l\IOFtf=OLI< SOLJTHEFttM

Job Safety Analysis Chemical-Specific Worksheet

Butyl ocrylote

Toxicology Information2:

Butyl acrylate

Exposure Route Exposure

Possible Symptoms /Health Effects of Exposure How to Avoid

Low Concentration
(< 2 ppm)

Moderate
(2 - 25 ppm)

High

(> 25 ppm)

Odor threshold of 0.05 ppb (ERPG); odor classified as
sharp, fragrant odor.

ACGIHTLV-TWA of 2 ppm; Irritation of the URT,
drowsiness, headache, and nausea

IDLH: ND (NIOSH 2016); ERPG-2 of 25 ppm; Drowsiness,
headache, nausea; Liver damage; Marked irritation,
salivation, conjunctive irritation; pulmonary edema

Remain upwind, avoid prolonged exposure
using respiratory protection

Full-faced Air Purifying Respirator (APR)

Full-faced APR, SCBA for concentrations
>100 ppm.

Liquid contact

Repeated contact of the skin may cause skin sensitization
in some individuals, with redness, swelling, itching, and
oozing of the affected areas.

Chemical-resistant protective suit. Handle
liquids with care, full decontamination of
CPC

Dermal vapor
exposure

Dermal sensitizer; Irritation, redness, and cracking of the
skin

Avoid working in atmospheres containing
moderate to high concentrations without
chemical protective clothing.

Irritation from vapor

Irritation, mild discomfort, and redness

Full-face Respiratory protection

Liquid contact

May cause pain disproportionate to the level of irritation
to the eye tissues; slight eye irritation, slight corneal injury

Full-face Respiratory protection

Ingestion of liquid

Collapse, severe respiratory difficulties, and CNS
stimulation.

Good workplace hygiene, Handle liquids
with care, proper decontamination of
protective clothing

2 Agency for Toxic Substances and Disease Registry (ATSDR), NIOSH Pocket Guide, ACGIH TLVs, & Emergency Response Planning Guidelines (ERPGs)

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i\joFti=oL-i< sou~rni=Ftr\i • Job Safety Analysis Chemical-Specific Worksheet Butyl acrylate

First Aid Measures

Exposure Recommended First Aid Treatment

Inhalation

INHALATION: IMMEDIATELY leave the contaminated area; take deep breaths of fresh air. If symptoms (such as
wheezing, coughing, shortness of breath, or burning in the mouth, throat, or chest) develop, call a physician and be
prepared to transport the victim to a hospital. Provide proper respiratory protection to rescuers entering an unknown
atmosphere. Whenever possible, Self-Contained Breathing Apparatus (SCBA) should be used; if not available, use a
level of protection greater than or equal to that advised under Protective Clothinq.

Skin & Eye Contact

SKIN: IMMEDIATELY flood affected skin with water while removing and isolating all contaminated clothing. Gently wash
all affected skin areas thoroughly with soap and water. If symptoms such as redness or irritation develop,
IMMEDIATELY call a physician and be prepared to transport the victim to a hospital for treatment.

EYES: First check the victim for contact lenses and remove if present. Flush victim's eyes with water or normal saline
solution for 20 to 30 minutes while simultaneously calling a hospital or poison control center. Do not put any
ointments, oils, or medication in the victim's eyes without specific instructions from a physician. IMMEDIATELY
transport the victim after flushing eyes to a hospital even if no symptoms (such as redness or irritation) develop.

Ingestion

INGESTION: DO NOT INDUCE VOMITING. If the victim is conscious and not convulsing, give 1 or 2 glasses of water to
dilute the chemical and IMMEDIATELY call a hospital or poison control center. Be prepared to transport the victim to a
hospital if advised by a physician. If the victim is convulsing or unconscious, do not give anything by mouth, ensure
that the victim's airway is open and lay the victim on his/her side with the head lower than the body. DO NOT INDUCE
VOMITING. IMMEDIATELY transport the victim to a hospital. (NTP, 1992)

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i\joFti=oL-i< sou~rni=Ftr\i • Job Safety Analysis Chemical-Specific Worksheet Butyl acrylate

PPE Matrix3: Butyl acrylate

Conditions

Suit:

Control measures first. Fire protective Level A Bunker or
FRC otherwise

Release rate:

Unknown or Uncontrolled

Risk of sudden release:

Unknown or High

Level A for
extensive dermal
contact with high
conc. vapor

Suit:

Control measures first. Fire protective Level A Bunker
or FRC otherwise

Gloves:

Silver Shield ® if liquid contact is significant; NFPA
gloves otherwise

1 1

Conditions

PPE Level

Respirator

Dermal Protection

> 2 ppm, but < 100 ppm

Fire or Flash Risk

APR

Suit:

Gloves:

Level C is not recommended with significant fire risk

Release rate:

Known and insignificant

(

Special Instructions:

Boots:

Level C is not recommended with significant fire risk

Risk of sudden release:

Low

Non-fire hazard

Skin contact w/ vapor:

Very low - intermittent

Cartridge:

PIOO/OV

Suit:

Skin contact w/ liquid:

Indirect, no splash

Style:

Full-face

Gloves & Boots:

Chemical -taped seams

Conditions

PPE Level

Respirator

Dermal Protection

Fire or Flash Risk

< 2 ppm

Suit:

None

Gloves:

NFPA gloves

Release rate:

None

Boots:

NFPA

Risk of sudden release:

Low

required

Non-fire hazard

Skin contact w/ vapor:

No vapor contact

Suit:

Skin contact w/ liquid:

No splash risk

NIOSH Emergency Response Safety and Health Database, Dupont Safe Spec™, Wiley Quick Selection Guide, 6th edition

-------
l\IOFtf=OLI< SOLJTHEFttM

Job Safety Analysis Chemical-Specific Worksheet

Butyl ocrylote

Chemical Resistance Table for Suits and Gloves'

Key

Gloves

Suits

Recommended
>8h

Recommended
>4h

<
>

PVC

Q_
i

<
>

Caution 1-4 h

1—

~o
c

o
+-»

o
(U

M—

Zytron ® 300

Not Recom,
< lh

-
_c

o
>-

+->
D
CO

E
(u
_c

o
o

E
(u
_c

00
©
E
(u

u
©
E
(u

Ll_

_c
H

Zytron® 500

Not Tested

>
+-»
D
CO

4->

ro
2

(D
2

'Z
2

>
o

O
+¦»

o
+¦»

ro
CO

(U
_>

'<7i

1—
LL.

4->

o
>
H

o
>-
H

o
>
H

o
>-
H

o
>
H

o
>-
H

o
>
H

Butyl acrylate

Cartridge Life Using Full Face APR by Brand

Criteria

Scott AV3000 Full-Face APR

3M 60293 Full-Face APR

MSA Advantage 3200

Site Concentration

100 ppm

250 ppm

Exposure Limit

2 ppm

50 ppm

Maximum Use
Concentration

100 ppm

250 ppm

Protection Factor (APF)

Temperature

68°F

77°F

Work Rate

Moderate, Breathing Rate 40 Ipm

Moderate, Breathing Rate 60 Ipm

Service Life5

Not available

24 hours (replace after shift)

11 hours and 17 minutes

4 th

Taken directly from Wiley 6 Edition Quick Selection Guide to Chemical Protective Clothing; Dupont SafeSpec™

5 The service life may far exceed 8-12 hour usage; however, it is best practice to change out cartridges before each new work shift.

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i\joFti=oL-i< sou~rni=Ftr\i • Job Safety Analysis Chemical-Specific Worksheet Butyl acrylate

Site Action Levels

Analyte

Action Level

Basis

Comments

Butyl acrylate

1 ppm

1/2 ACGIH® TLV-TWA for BA - Reading
sustained

Exposure at this concentration is not considered unhealthy; however, workers should be alert
to the presence and situational awareness should be increased.

2 ppm

ACGIH® TLV-TWA - for BA
Reading sustained

Exposure at this concentration is not considered life threatening; however, workers and site
management should implement controls and/or PPE to reduce exposure below the TLV-TWA
for unprotected workers.

Not
established

ACGIH® TLV-STEL for BA
Reading sustained for 15 minutes

Workers can be exposed up to 15 ppm for a 15-minute period as per the short-term exposure
limit (STEL).

Not
established

IDLH (Immediately Dangerous to Life
and Health)

Exposure at this concentration should be considered life threatening and all protective
measures, including immediate evacuation of un-protected workers should be considered.

LEL

1% of LEL for BA
Reading sustained for 1 minute

Although 1% of the LEL is conservative, workers and site management should be aware of
conditions and prepare for protective action to avoid reaching flammable limits

10%

10% of LEL for BA
Reading sustained for 1 minute

10% of the LEL is a reasonable precautionary action level to halt work activity so that source
mitigation techniques can be employed to reduce the flammable atmosphere prior to the
continuation of work activity.

Monitoring Strategy

Flammability

Instrument

Instrument
Reading

Corrected
Value

Correction Factor

Basis

Action to be Taken

MultiRAE
PID

937 ppm

1,500 ppm

1.6 for BA (10.6eV lamp)

10% LEL

Notify Site Management

Exposure

Instrument

Instrument
Reading

Corrected
Value

Correction Factor

Basis

Action to be Taken

MultiRAE
PID

1.2 ppm

2 ppm

1.6 for BA (10.6eV lamp)

ACGIH TLV-TWA

Don respiratory protection or Egress; Notify Site
Management

Gastec Tube
142L

10 ppm

Tube LOD is > 2 ppm

ACGIH TLV-TWA

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l\IOFtf=OLI< SOLJTHEFttM

Job Safety Analysis Chemical-Specific Worksheet

Butyl ocrylote

Job Steps

Hazards

Hazard Controls

1.1 Slips/Trips/Falls

1. Initial Entry & Damage
Assessment

1.2 Fire/Explosion

1.3 Chemical Exposure

1.1.1 Watch footing on loose/shifting rocks. Visualize a safe travel path.

1.1.2 Wear railroad approved work boots with ankle support.

1.1.3 Avoid climbing on wreckage if suitable walking/working surfaces and or climbing
structures are not available.

1.1.4 If tank car ladder and guardrail at protective dome housing are damaged, configure
a suitable fall-arrest system before accessing the protective dome housing area.

1.1.5 Ensure that entrants in aggressive PPE are physically able to withstand the
demands of the suit and also physically strong enough to traverse difficult terrain.

1.2.1 Identify all open sources and other potential flammable liquids & gases using
manifest.

1.2.2 Identify potential ignition sources, locate all active fires.

1.2.3 If potential for ignition is real: wear flash-protective bunker gear/FRC only if
vapor/liquid exposure risk is moderate-low. If protection from vapor and liquid is
necessary and fire risk is elevated, utilize proper control measures to reduce fire threat
first. Using control measures to reduce the threat of fire will allow use of more common
PPE. If fire threat cannot be reduced, use fire protective Level B. If aggressive
protection from liquids and vapor is not warranted, bunker gear with SCBA can be worn.

1.2.4 Conduct LEL monitoring. Action level 10% of LEL should result in egress.

1.2.5 Utilize hot work procedures before conducting activity capable of generating
sparks or could ignite flammable vapors or liquid.

1.2.6 Provide fire fighting measures to control fires.

1.2.7 Use appropriate fire fighting measures to cool cars with flame impingement or
adjacent to active fires or hot spots.

1.2.8 Use caution when walking among wreckage, look for subsurface pooling of liquid,
especially in the vicinity of active fires.

1.3.1 Don Level A PPE if release conditions are unknown or vapor/skin contact will be
significant. Downgrade to B or C PPE to continue damage assessment if conditions
permit (see PPE matrix).

1.3.2 Perform air monitoring on initial entry, document readings.

1.3.3 Observe wind direction and deploy a windsock.

1.3.4 Identify and mark areas of liquid releasing, secondary containment/ liquids,
impacted soil, or standing liquid.

1.3.5 All workers entering the site in PPE must receive a full decontamination of all

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l\IOFtf=OLI< SOLJTHEFttM

Job Safety Analysis Chemical-Specific Worksheet

Butyl ocrylote

Job Steps

Hazards

Hazard Controls

respiratory protection, CPC and equipment prior to exiting the warm zone.
1.3.6 Decon workers must perform decontamination activities in 1 lower-level PPE
ensemble unless contamination is significant.

1.4 Heat Stress from PPE

1.4.1 Using CPC and respiratory protection can increase heat stress risk if ambient
conditions are warm or hot.

1.4.2 Conduct medical monitoring prior to and after entry to evaluate worker's
condition.

1.4.3 If necessary, limit the duration of each entry and maximize rest periods based on
site conditions and medical monitoring information.

1.4.4 Drink plenty of water; avoid excessive use of sports drinks.

1.4.5 Rest in shaded, cool areas. Consider adding fans, misting devices, or air-
conditioned rest areas (vehicles).

1.4.6 Avoid excessive intake of caffeine while at work and alcoholic beverages after
work.

1.5 Mechanical Injury from
wreckage or falling

1.5.1 Stay clear of unstable or elevated wreckage.

1.5.2 Avoid reaching/walking between unstable cars/loads.

1.5.3 Use caution when tightening valves. Observe all pinch points for hands.

1.6 Miscommunication

1.6.1 Establish effective hand signals for entrants to use if radio corns are not available.

1.6.2 Establish radio or cell phone communication with all responders.

1.6.3 Safety briefing conducted prior to initial entry.

1.7 Polymerization

1.7.1 Can polymerize rapidly leading to container explosion. Monitor tank temperature
and pressure to assess if polymerization is occurring.

1.7.2 If polymerization is occurring, isolate area and evacuate immediately. Monitor
polymerization rate through temperature readings at a safe distance.

1.7.3 If polymerization is confirmed, isolate for 800 (1/2 mile) meters in all directions
and consider evacuation for same distance.

1.7.4 Be aware that during polymerization, the PRV will activate and vapor may be
emitted at a high rate. Site concentrations may increase and all personnel should be
moved upwind to avoid exposure.

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l\IOFtf=OLI< SOLJTHEFttM

Job Safety Analysis Chemical-Specific Worksheet

Butyl ocrylote

Job Steps

Hazards

Hazard Controls

2. Release Mitigation

2.1 Fire/Explosion

2.2 Injury from valve or
container repair

2.1.1 Identify all open sources and other potential flammable liquids & gases using
manifest.

2.1.2 Identify potential ignition sources, locate all active fires.

2.1.3 If potential for ignition is real: wear flash-protective bunker gear/FRC only if
vapor/liquid exposure risk is moderate-low. If protection from vapor and liquid is
necessary and fire risk is elevated, utilize proper control measures to reduce fire
threat first. Using control measures to reduce the threat of fire will allow use of
more common PPE. If fire threat cannot be reduced, use fire protective level B. If
aggressive protection from liquids and vapor is not warranted, bunker gear with
SCBA can be worn.

2.1.4 Conduct LEL monitoring. Action level 10% of LEL.

2.1.5 Utilize hot work procedures before conducting activity capable of generating
sparks or could ignite flammable vapors or liquid.

2.1.6 Provide fire fighting measures to control fires.

2.1.7 Use appropriate fire fighting measures to cool car(s) with flame impingement
or adjacent to active fires or hot spots.

2.1.8 Use caution when walking among wreckage, look for subsurface hot spots or
subsurface pooling in the vicinity of active fires.

2.1.9 All tools used during release mitigation should be non-sparking, intrinsically
safe. Combustion engines or electrical tools should not be used near flammable
atmospheres.

2.2.1 Use secure hoist to raise tools to the protective dome housing.

2.2.2 Avoid single-man manual lifting for loads greater than 50 lbs.

2.2.3 Ensure all connections are tight and secured.

2.2.4 Avoid body contact with high-pressure liquid streams.

2.2.5 Wear protective clothing capable of protecting from high-pressure water
impact.

2.2.6 Remember, aggressive PPE will make tasks requiring good manual dexterity
very difficult. Work safely and slowly to ensure proper use of valves, fittings, and
tools.

2.2.7 All tools should be non-sparking (brass).

2.2.8 Avoid contact chemical protective clothing with sharp edges of damaged shell,
brake lines, catwalk, railing etc. to keep the suit from tearing.

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l\IOFtf=OLI< SOLJTHEFttM

Job Safety Analysis Chemical-Specific Worksheet

Butyl ocrylote

Job Steps

Hazards

Hazard Controls

2.3 Miscommunication

2.3.1 Establish effective hand signals for entrants to use if radio corns are not
available.

2.3.2 Establish radio or cell phone communication with all responders.

2.3.3 Safety briefing conducted prior to initial entry.

2.4 Chemical Exposure

2.4.1 Don Level A or B PPE to approach leak source depending on release conditions.
If leak is insignificant and controlled, and worker can be upwind, then consider Level
C PPE using PPE matrix.

2.4.2 Continuous air monitoring with workers during mitigation.

2.4.3 All workers entering the site in PPE must receive a full decontamination of all
respiratory protection, CPC and equipment prior to exiting the warm zone.

2.4.4 Decon workers must perform decontamination activities in 1-lower level PPE
ensemble.

2.6 Mechanical Injury

2.6.1 Stay clear of unstable or elevated wreckage.

2.6.2 Avoid reaching/walking between unstable cars/loads.

2.7 Slips/trips/falls

2.7.1 Watch footing on loose/shifting rocks. Visualize a safe travel path.

2.7.2 Wear railroad approved work boots with ankle support.

2.7.3 Abide by site fall protection safety protocols while working at elevations above
6 feet.

2.7.4 Ensure workers are prepared and trained to traverse the worksite with
movement-restrictive PPE. Only fit workers with the strength to wear such PPE
should be used to traverse challenging terrain or wreckage.

2.8 High Pressure Release

2.8.1 Perform all necessary pressure checks to ensure tank car is not pressurized
from polymerizing styrene.

2.8.2 Ensure that valves are manipulated in a safe and controlled manner when
tightening.

2.8.3 Essential personnel only at protective dome housing.

2.1.4 Conduct LEL monitoring. Action level 10% of LEL for known substances.

2.9 Polymerization

2.9.1 Can polymerize rapidly leading to container explosion. Monitor tank
temperature and pressure to assess if polymerization is occurring

2.9.2 If polymerization is occurring, isolate area and evacuate immediately. Monitor
polymerization rate through temperature readings at a safe distance.

2.9.3 If polymerization is confirmed, isolate for 800 (1/2 mile) meters in all directions
and consider evacuation for same distance.

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Job Safety Analysis Chemical-Specific Worksheet

Butyl ocrylote

Job Steps

Hazards

Hazard Controls

2.9.4 Be aware that during polymerization, the PRV will activate and styrene vapor
will be emitted at a high rate. Site concentrations may increase and all personnel
should be moved upwind to avoid exposure.

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rjoFtr=oi-K soLj-rnEmyj • Job Safety Analysis Chemical-Specific Worksheet Butyl acrylate

Job Steps

Hazards

Hazard Controls

3.1.1 Perform air monitoring at the protective dome housing prior to connecting

transfer equipment to damaged car's valve assembly.

3.1.2 Don Level B when connecting transfer hose to damaged car's liquid and vapor

valves. See PPE Matrix to determine Level based on conditions.

3.1.3 Ensure that transfer hoses, pumps, and compressors are free of liquid product

and depressurized before opening lines.

3.1 Chemical Exposure

3.1.4 Don Level C PPE (if conditions warrant-see PPE matrix) when disconnecting
hoses, pumps, and compressors that have been emptied of free liquids.

3.1.5 All workers entering the site in PPE must receive a full decontamination of all
respiratory protection, CPC and equipment prior to exiting the warm zone.

3.1.6 Decon workers must perform decontamination activities in CPC.

3.1.7 Employ vapor scrubbing systems such as charcoal canisters to reduce vapor
emissions into work area. Monitor temperature of charcoal canisters to avoid
temperature increase and fire risk.

3.2.1 Be cautious of pressure buildup in lines during transfer.

3. Transfer of Butyl acrylate

3.2.2 Continue pressure checks on tank cars to monitor pressure conditions.

3.2.3 Valves should only be manipulated by competent persons.

3.2.4 Use chemical compatible, valves, fittings, and hoses.

3.2.5 Ensure all system pressures are within manufacture recommended ranges.

3.2 Transfer system release

3.2.6 Ensure all connections are tight and secured.

or pressurization

3.2.7 Avoid body contact with pressurized liquid and gas streams even though
worker is protected by PPE.

3.2.8 Initially and periodically monitor pumps, hoses, valves, and fittings for liquid or
vapor leaks.

3.2.9 Use caution when connecting and disconnecting hydraulic pump lines; avoid
pressurized release of compressed air.

3.3.1 Establish effective hand signals for entrants to use if radio corns are not

3.3 Miscommunication

available.

3.3.2 Establish radio or cell phone communication with all responders.

3.3.3 Safety briefing conducted prior to initial entry.

3.4 Static Electrical Discharge

3.4.1 Ensure that all transfer equipment and receiving vessels are grounded and
bonded according to best practice.

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l\IOFtf=OLI< SOLJTHEFttM

Job Safety Analysis Chemical-Specific Worksheet

Butyl ocrylote

Job Steps

Hazards

Hazard Controls

3.5 Mechanical Injury

3.5.1 Stay clear of unstable or elevated wreckage.

3.5.2 Avoid reaching/walking between unstable cars/loads.

3.5.3 Ensure that tank car is secured to stabile equipment during tank car rotations.

3.6 Slips/trips/falls

3.6.1 Watch footing on loose/shifting rocks. Visualize a safe travel path.

3.6.2 Wear railroad approved work boots with ankle support.

3.6.3 Abide by site fall protection safety protocols while working at elevations above
6 feet.

3.6.4 Ensure that workers are aware of the decrease in flexibility and mobility when
wearing aggressive PPE, especially when climbing onto railcars or other equipment.

3.7 Fire/Explosion

3.7.1 Identify all open sources and other potential flammable liquids & gases using
manifest.

3.7.2 Identify potential ignition sources, locate all active fires.

3.7.3 If potential for ignition: wear flash-protective bunker gear/FRC and SCBA when
vapor concentrations are moderate to low; if airborne concentrations are extreme &
sustained, use control measures to reduce threat.

3.7.4 Conduct LEL monitoring. Action level 10% of LEL for known substances.

3.7.5 Utilize hot work procedures before conducting activity capable of generating
sparks or could ignite flammable vapors or liquid.

3.7.8 All tools used during release mitigation should be non-sparking, intrinsically
safe. Combustion engines or electrical tools should not be used near flammable
atmospheres.

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rjoFtr=oi-K soLj-rnEmyj • Job Safety Analysis Chemical-Specific Worksheet Butyl acrylate

Job Steps

Hazards

Hazard Controls

4.1 Fugitive emissions

4.1.1 Use chemical compatible, valves, fittings, and hoses.

4.1.2 Ensure that vapor lines are properly secured to vapor scrubbing system if used.

4.1.3 Ensure all connections are tight and secured.

4.1.4 Initially and periodically monitor pumps, hoses, valves, and fittings for liquid or
gas leaks.

4.1.6 Properly decontaminate all hoses, fittings, tools, and other equipment used
during scrubbing operation.

4.1.7 If using a propane-assisted flare to control emissions, ensure flare lighting is
safe by following hot work procedures, specifically, identifying all flammable
materials and monitoring the area for flammable gas (LEL monitor) before lighting
flare. Use caution when connecting propane lines, ensure tight fittings and vapor
leaks.

4.1.8 If using charcoal canister scrubbing system, periodically monitor system
exhaust to ensure proper scrubbing of vapor. Be sure to monitor the temperature of
the charcoal bed to ensure that a flammable atmosphere is not present inside the
system.

4. Clean and purge

4.2 Chemical Exposure

4.2.1 Perform air monitoring at the protective dome housing prior to connecting
transfer equipment to damaged car's valve assembly.

4.2.2 Don Level B or Level C PPE when connecting vapor line to damaged car's vapor
valves. See PPE Matrix to determine Level B or C based on conditions.

4.2.3 Ensure that transfer hoses, pumps, and compressors are free of liquid product
before opening lines.

4.2.4 Don Level C PPE when disconnecting hoses, pumps, and compressors that have
been emptied of free liquids.

4.2.5 All workers entering the site in PPE must receive a full decontamination of all
respiratory protection, CPC and equipment prior to exiting the warm zone.

4.2.6 Decon workers must perform decontamination activities in CPC.

4.3 System release or
pressurization

4.3.1 Be cautious of pressure buildup in lines during purge.

3.2.2 Continue pressure checks on tank cars to monitor pressure conditions.

3.2.3 Valves should only be manipulated by competent persons.

3.2.4 Use chemical compatible, valves, fittings, and hoses.

3.2.5 Ensure all system pressures are within manufacture recommended ranges.

3.2.6 Ensure all connections are tight and secured.

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l\IOFtf=OLI< SOLJTHEFttM

Job Safety Analysis Chemical-Specific Worksheet

Butyl ocrylote

Job Steps

Hazards

Hazard Controls

3.2.7 Avoid body contact with pressurized liquid and gas streams.

3.2.8 Initially and periodically monitor pumps, hoses, valves, and fittings for liquid or
vapor leaks.

3.2.9 Use caution when connecting and disconnecting hydraulic pump lines; avoid
pressurized release of compressed air.

4.4 Mechanical Injury

4.4.1 Stay clear of unstable or elevated wreckage.

4.4.2 Avoid reaching/walking between unstable cars/loads.

4.5 Slips/trips/falls

4.5.1 Watch footing on loose/shifting rocks. Visualize a safe travel path.

4.5.2 Wear railroad approved work boots with ankle support.

4.5.3 Abide by site fall protection safety protocols while working at elevations above
6 feet.

4.6 Fire/Explosion

4.6.1 Identify all sources and other potential flammable liquids & gases using
manifest.

4.6.2 Identify potential ignition sources, locate all active fires.

4.6.3 If potential for ignition: wear flash-protective bunker gear/FRC.

4.6.4 Conduct LEL monitoring. Action level 10% of LEL for known substances.

4.6.5 Utilize hot work procedures before conducting activity capable of generating
sparks or could ignite flammable vapors or liquid.

4.6.6 If using charcoal canister scrubbing system, periodically monitor system
exhaust to ensure proper scrubbing of vapor. Be sure to monitor the temperature of
the charcoal bed to ensure that a flammable atmosphere is not present inside the
system.

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l\IOFtf=OLI< SOLJTHEFttM

Job Safety Analysis Chemical-Specific Worksheet

Butyl ocrylote

Job Steps

Hazards

Hazard Controls

5. Removal of residual
materials and impacted soil

5.1 Chemical Exposure

5.2 Vac operations

5.1.1 Provide continuous air monitoring to determine if vapors are elevated in the
work areas near impacted soil.

5.1.2 Don Level C PPE to work in close proximity to impacted soils with elevated
vapor. If vapor levels are high, return to using Level B until vapor concentrations are
reduced.

5.1.3 All workers entering the site in PPE must receive a full decontamination of all
respiratory protection, CPC and equipment prior to exiting the warm zone.

5.1.4 Decon workers must perform decontamination activities in LEVEL C PPE, but
full-faced respirator may not be required if minimal contamination is present.

5.1.5 Excavation, loading, and unloading of impacted soil or debris may generate
elevated vapor. Excavation operators should be prepared to don full-faced APR if
conditions require respiratory protection. Ground-level workers may be required to
don Level C PPE to avoid inhalation of vapor and skin contact with impacted soil.

5.1.6 Vapor suppressants, surfactants, and scavengers may be applied where
approved and suitable to arrest excessive contaminant generation from soil or
during soil agitation.

5.1.7 Plastic sheeting and sand may also be used to suppress vapor if workers must
be in close proximity to saturated soil. Ensure that no static buildup occurs through
the use of plastic sheeting. Do not remove sheeting where continuous friction is
applied from the soil surface.

5.2.1 Use chemical compatible, valves, fittings, and hoses.

5.2.2 Ensure all system pressures are within manufacture recommended ranges.

5.2.3 Ensure all connections are tight and secured.

5.2.4 Avoid body contact with liquid streams.

5.2.5 Initially and periodically monitor hoses, valves, and fittings for liquid leaks.

5.2.6 Ensure that all vent hoses are positioned to direct vacuum exhaust away from
the work area.

5.2.7 Ensure that vac trucks are parked on secure areas and are properly staged to
minimize potential for unwanted equipment movements.

5.2.8 Properly ground and bond all vac truck equipment to avoid static discharge.

5.2.9 The use of a vac truck to remove liquids may require the most aggressive form
of PPE if the liquid is highly concentrated or pure product, based on the volume and
disposition of liquid being removed.

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l\IOFtf=OLI< SOLJTHEFttM

Job Safety Analysis Chemical-Specific Worksheet

Butyl ocrylote

Job Steps

Hazards

Hazard Controls

5.3 Excavation operations

5.3.1 Ensure that all machinery is equipped with properly functioning audible alarms
for movement.

5.3.2 Avoid unnecessary foot traffic within the operating distances of the machinery.

5.3.3 Workers within the operating distance of the machine must remain within the
line-of-sight of the operator at all times. Use hand signals to signal movement once
within the operating distance of the machine.

5.3.4 Keep all workers from working beneath suspended loads.

5.3.5 All receiving containers must be properly staged on a suitable foundation and
secured before loading.

5.3.6 All machinery must be operated from secure locations.

5.3.7 Open trenches must be maintained within the requirements of applicable
trenching/shoring standards. Workers should not enter an un-secured trench at any
time. Use barricades to prevent workers from working closely to trench or pit
openings.

5.4 Slips/trips/falls

6.4.1 Watch footing on loose/shifting rocks. Visualize a safe travel path.
6.4.1 Wear railroad approved work boots with ankle support.

5.5 Railway hazards

6.5.1 All workers must be briefed on track protection

6.5.2 All workers must abide by railroad track safety rules as covered by contractor
orientation.

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Job Safety Analysis Chemical-Specific Worksheet

Butyl ocrylote

Additional Site Hazards

Actions to Eliminate Hazards

10.

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i\joFti=oL-i< sou~rni=Ftr\i • Job Safety Analysis Chemical-Specific Worksheet Butyl acrylate

Name

Signature

Date Signed

-------
rJOFtFOLK SOUTHEfflS!

JOB SAFETY ANALYSIS
CHEMICAL-SPECIFIC WORKSHEET

< FLAMMABLE >
GAS

Date:

February 13, 2018

Chemical:

Vinyl chloride

Location:

Emergency Response Site

Prepared By:

Scott Skelton, MS, CIH

Version:

Vinyl Chloride_JSA2.0_2018

Emergency Procedures

Muster Point

Egress cross-wind, then upwind to:
Entrance Gate

Medical Emergency

1) Call 911, 2) Administer First Aid, 3) Contact
Site Safety Officer

Emergency Signal

3 long horn blasts, hand signals for entry team

Site Safety Contact

John Doe, Site Safety Officer, Phone: 555-123-
5555

Notice: The content included in this JSA has been prepared in advance of its use during
an actual event. Workers engaged in response operations associated with vinyl chloride
should use this JSA only after assessing site hazards daily to determine the effectiveness
and completeness of this JSA's content. This JSA should not be used as the only safety
provision for activities involving a vinyl chloride tank car. Please refer to the Norfolk
Southern Corporate Emergency Response Plan (ERP), Contractor and Employee Safety
rules, and site safety plans as necessary for policies and procedures not identified
herein.

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rjoFtr^ot-K southefum * Job Safety Analysis Chemical-Specific Worksheet Vinyl chloride

Chemical Safety Information1:

Vinyl chloride

GHS Label

Hazardous Property

Important Considerations & Safety Procedures

Inhalation of high concentrations cause dizziness, anesthesia, lung irritation, SKIN: may cause
frostbite; phenol inhibitor may be absorbed through skin if large amounts of liquid evaporate.
(USCG,1999)

<$>

Health Hazards

OSHA GHS Hazard Statements:

• May cause cancer,

• May displace oxygen and cause rapid suffocation

Exposure to vinyl chloride can cause dizziness, lightheadedness, nausea, dullness of visual and
auditory responses, drowsiness, and unconsciousness. Irritation of the skin and eyes can also occur.
Skin contact with liquid may cause frostbite. Prolonged exposure to VC can cause thickening of the
kin, contact and allergic dermatitis, fatigue, coughing and sneezing, abdominal pain, gastrointestinal
bleeding, nausea, vomiting, indigestion, diarrhea, jaundice, weight loss, anorexia, and a cold and
tingling sensation of the hands and feet (NIOSH 1978).

Highly flammable, Class IA Flammable Liquid, NFPA Flammability Rating of 4.

<§>

Flammability & Explosion

Flash Point: -110° F (NTP, 1992)

Lower Explosive Limit (LEL): 3.6 % (USCG, 1999)
Upper Explosive Limit (UEL): 33 % (USCG, 1999)
Autoignition Temperature: 882 ° F (USCG, 1999)

Hazardous decomposition products: Toxic gases and vapors (e.g., hydrogen chloride, phosgene, and
carbon monoxide) may be released in a fire involving vinyl chloride (NIOSH Occupational Safety and
Health Guideline 0621).

Firefighting

FIRE: If tank, rail car or tank truck is involved in a fire, ISOLATE for 1600 meters (1 mile) in all
directions; also, consider initial evacuation for 1600 meters (1 mile) in all directions. (ERG, 2016)

Excerpt from ERG Guide 116P TGases - Flammable (Unstable)l:

DO NOT EXTINGUISH A LEAKING GAS FIRE UNLESS LEAK CAN BE STOPPED.

SMALL FIRE: Dry chemical or C02.

LARGE FIRE: Water spray or fog. Move containers from fire area if you can do it without risk.

1 NOAA CAMEO Chemicals

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Job Safety Analysis Chemical-Specific Worksheet

Vinyl chloride

FIRE INVOLVING TANKS: Fight fire from maximum distance or use unmanned hose holders or
monitor nozzles. Cool containers with flooding quantities of water until well after fire is out. Do not
direct water at source of leak or safety devices; icing may occur. Withdraw immediately in case of
rising sound from venting safety devices or discoloration of tank. ALWAYS stay away from tanks
engulfed in fire. For massive fire, use unmanned hose holders or monitor nozzles; if this is
impossible, withdraw from area and let fire burn. (ERG, 2016)

Reactivity

VINYL CHLORIDE is peroxidizable. Forms explosive polymeric peroxides in contact with air (in the
presence of any of a variety of catalysts) [Bretherick 1979. p. 164], Long storage in contact with air
increases the concentration of the polyperoxides to hazardous levels [MCA Case History 1551. 1969],
The peroxides may initiate exothermic polymerization of the remaining material [Handling Chemicals
Safely 1980.p. 958; Bretherick 1979. p. 160], Light-sensitive. Many oxidizing agents apparently
initiate polymerization (oxides of nitrogen, 02, etc.). May react with very hot water or steam to
produce toxic fumes.

Pressurized System

Vinyl chloride tankcars are typically equipped with a PRV rated for 225 psig. If using pressure assist
to transfer, ensure that pressurization does not exceed the PRV capacity thus resulting in vapor
emissions.

Volatility/Mobility

Vapor Pressure: 3877.5 mm Hg (USCG, 1999)
Vapor Density: 2.15 (Air = 1) (Sax's, 2004)
Specific Gravity: 0.969 at 8.6 ° F (USCG, 1999)
Boiling Point: 7 ° F at 760 mm Hg (NTP, 1992)
Molecular Weight: 62.5 (NTP, 1992)

Water Solubility: Slightly soluble (NTP, 1992)
Ionization Potential: 9.99 eV (NIOSH, 2016)

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i\joFti=oL-i< sou~rni=Ftr\i • Job Safety Analysis Chemical-Specific Worksheet Vinyl chloride

Toxicology Information2: Vinyl chloride

Exposure Route Dose Possible Symptoms /Health Effects of Exposure How to Avoid

Low

(< 1 PPm)

Moderate
(1-1200 ppm)

High

(>1200 ppm)

No apparent observable effects or symptoms

Acute effects may not be perceptible in this concentration
range. OSHA PEL Ceiling of 5 ppm; Chronic exposure is
linked to "vinyl chloride illness", which includes Raynaud's
Syndrome and acroosteolysis. The toxic effect of greatest
concern is cancer of the liver, which is largely the result of
chronic exposure. TLV A1 confirmed human carcinogen.

PAC-2 of 1200 ppm; Odor threshold observed at 3000
ppm; anesthesia, drowsiness, slight visual disturbances,
faltering gait, numbness and tingling of extremities. CNS
depression and death from high concentrations. Exposure
to 4000 ppm for 5 minutes, no effects; 8000 ppm for 5
minutes - dizziness; 20,000 ppm for 5 minutes-dizziness,
light headedness, nausea, and dulling of vision (Rumack
Poison Index 2016).

Supplied Air Respirator (SAR)

Liquid contact

Dermal vapor
exposure

Frostbite; irritation of skin; contact dermatitis

Chemical-resistant protective suit. Handle
liquids with care, full decontamination of
CPC

Irritation of skin at very high concentrations

Chemical-resistant protective suit with
properly taped seams.

Irritation from vapor

Irritation

Full-face Respiratory protection

2 Agency for Toxic Substances and Disease Registry (ATSDR), NIOSH Pocket Guide, ACGIH TLVs, & Emergency Response Planning Guidelines (ERPGs)

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i\joFti=oL-i< sou~rni=Ftr\i • Job Safety Analysis Chemical-Specific Worksheet Vinyl chloride

Liquid contact

Severe chemical burns and damage to cornea, temporary
blindness; Ocular irritation; conjunctivitis

Full-face Respiratory protection

Ingestion of liquid

Severe burns and irritation to Gl tract; assumed systemic
toxicity after exposure to critical organs

Handle liquids with care, proper
decontamination of protective clothing

First Aid Measures

Exposure Recommended First Aid Treatment

Inhalation

IMMEDIATELY leave the contaminated area; take deep breaths of fresh air. IMMEDIATELY call a physician and be prepared to
transport the victim to a hospital even if no symptoms (such as wheezing, coughing, shortness of breath, or burning in the mouth,
throat, or chest) develop. Provide proper respiratory protection to rescuers entering an unknown atmosphere. Whenever possible,
Self-Contained Breathing Apparatus (SCBA) should be used; if not available, use a level of protection greater than or equal to that
advised under Protective Clothing.

Skin & Eye Contact

EYES: First check the victim for contact lenses and remove if present. Flush victim's eyes with water or normal saline solution for
20 to 30 minutes while simultaneously calling a hospital or poison control center. Do not put any ointments, oils, or medication in
the victim's eyes without specific instructions from a physician. IMMEDIATELY transport the victim after flushing eyes to a hospital
even if no symptoms (such as redness or irritation) develop.

SKIN: CAUTION: Exposure of skin to compressed gases may result in freezing of the skin. Treatment for frostbite may be
necessary. Remove the victim from the source of contamination. IMMEDIATELY wash affected areas gently with COLD water (and
soap, if necessary) while removing and isolating all contaminated clothing. Dry carefully with clean, soft towels. If symptoms such
as inflammation or irritation develop, IMMEDIATELY call a physician or go to a hospital for treatment.

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rjoFtr=oi-K soLj-rnEmyj • Job Safety Analysis Chemical-Specific Worksheet Vinyl chloride

PPE Matrix3: Vinyl chloride

Conditions PPE Level Respirator Dermal Protection

Fire or Flash Risk

Vinyl chloride

Unknown or > 10 ppm

Suit:

Control measures first. If cannot control: Fire-protective
Level A if liquid contact risk; Bunker gear otherwise

SCR A

Gloves:

Fire/chemical glove if liquid contact; NFPA otherwise

Release rate:

Unknown or Uncontrolled

Boots:

NFPA/chemical resistant

Risk of sudden release:

Unknown or High

# 1

Non-fire hazard

Skin contact w/ vapor:

Greatest

Suit:

Chemical - encapsulating

Skin contact w/ liquid:

Greatest

Gloves & Boots:

Chemical - taped at seams

Conditions

PPE Level

Respirator

Dermal Protection

Fire or Flash Risk

Vinyl chloride

> 10 ppm

Suit:

Control measures first. If cannot control: Fire-protective
Level B if liquid contact risk; Bunker gear otherwise

SCBA

Gloves:

Fire/chemical glove if liquid contact; NFPA otherwise

Release rate:

Known and controlled

Boots:

NFPA/chemical resistant

Risk of sudden release:

Moderate

Non-fire hazard

Skin contact w/ vapor:

Moderate-low

Suit:

Chemical-hooded

Skin contact w/ liquid:

Direct, splash potential

Gloves & Boots:

Chemical -taped seams

Conditions

PPE Level

Respirator

Dermal Protection

Fire or Flash Risk

Vinyl chloride

> 1, but < 10 ppm

APR

Suit:

Level C is not recommended with significant fire risk

Gloves:

Level C is not recommended with significant fire risk

Release rate:

Known and insignificant

Special Instructions

Boots:

Level C is not recommended with significant fire risk

Risk of sudden release:

Low

Cartridge:

OV/AG; P100

Non-fire hazard

Skin contact w/ vapor:

Very low - intermittent

Style:

Full-face

Suit:

Chemical-hooded

Skin contact w/ liquid:

Indirect, no splash

USE FOR ESCAPE ONLY

Gloves & Boots:

Chemical -taped seams

Conditions PPE Level Respirator Dermal Protection

Fire or Flash Risk

Vinyl chloride

< 1 ppm

Suit:

FRC clothing

None

Gloves:

NFPA gloves

Release rate:

None

Boots:

NFPA

Risk of sudden release:

Low

required

Non-fire hazard

Skin contact w/ vapor:

No vapor contact

Suit:

Long sleeves, reflective vest, safety glasses, hardhat

Skin contact w/ liquid:

No splash risk

3 NIOSH Emergency Response Safety and Health Database, Dupont Safe Spec™, Wiley Quick Selection Guide, 6th edition

NIOSH does not recommend using full-face APR for VC. OSHA does permit using full-face APR in the VC standard, but limits the maximum use concentration to 10 ppm (1910.1017(f)(3)(ii)).
Caution is warranted for use of APR due to the lack of supporting documentation by the three major respirator manufacturers. See APR changeout schedule on the following page.

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l\IOFtf=OLI< SOLJTHEFttM

Job Safety Analysis Chemical-Specific Worksheet

Vinyl chloride

Chemical Resistance Table for Suits and Gloves'

Key

Gloves

Suits

Recommended
>8h

Recommended
>4h

<
>

PVC

Q_
l

<
>

Caution 1-4 h

1—

~o
c

o
+->

o
(U

M—

Zytron ® 300

Not Recom,
< lh

o
>
_c

4->

D
CO

(U
O

E
(u
_c

o
o

E
(u
_c

00
©
E
(u

u
©
E
(u

Ll_

_c
H

Zytron® 500

Not Tested

>•
+-»
D
CO

4->

ro
2

(D
2

'Z
2

>
o

O
+¦»

o
+¦»

ro
CO

(U
_>

'<7i

1—
LL.

(U
+-»
_C

o
>-
H

Vinyl choride

Cartridge Life Using Full Face APR by Brand

Criteria

Scott AV3000 Full-Face APR

3M 60293 Full-Face APR

MSA

Site Concentration

Exposure Limit

Maximum Use
Concentration

Protection Factor (APF)

Temperature

Work Rate

Service Life6

Not recommended

5 Taken directly from Wiley 6th Edition Quick Selection Guide to Chemical Protective Clothing

6 The service life may far exceed 8-12 hour usage; however, it is best practice to change out cartridges before each new work shift.

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l\IOFtf=OLI< SOLJTHEFttM

Job Safety Analysis Chemical-Specific Worksheet

Vinyl chloride

Site Action Levels for Airborne Vinyl chloride

Analyte

Action Level

Basis

Comments

Vinyl chloride

0.5 ppm

K ACGIH® TLV-TWA for VC - Reading
sustained for 15 minutes

1 ppm

ACGIH® TLV-TWA for VC
Reading sustained for 15 minutes

LEL

1% of LEL for VC
Reading sustained for 1 minute

Although 1% of the LEL is conservative, workers and site management should be aware of
conditions and prepare for protective action to avoid reaching flammable limits

10%

10% of LEL for VC
Reading sustained for 1 minute

10% of the LEL is a reasonable precautionary action level to hault work activity so that source
mitigation techniques can be employed to reduce the flammable atmosphere prior to the
continuation of work activity.

Monitoring Strategy

Flammability

Instrument

Instrument
Reading

Corrected
Value

Correction Factor

Basis

Action to be Taken

MultiRAE
PID

1800 ppm

3600 ppm

2.0 for VC using PID

10% LEL

Egress and Notify Site Management

MultiRAE
LEL Sensor

10%

2.0 for VC using LEL Sensor

10% LEL

Exposure

Instrument

Instrument
Reading

Corrected
Value

Correction Factor

Basis

Action to be Taken

MultiRAE
PID

0.5 ppm

1 ppm

2.0 for VC using PID

ACGIH TLV-TWA

Don respiratory protection or Egress; Notify Site
Management

Gastec Tube
No. 131L

1 ppm

1.0 for VC with 2-100 mL
pump strokes

ACGIH TLV-TWA

Job Steps

Hazards

Hazard Controls

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l\IOFtf=OLI< SOLJTHEFttM

Job Safety Analysis Chemical-Specific Worksheet

Vinyl chloride

Job Steps

Hazards

Hazard Controls

1.1 Slips/Trips/Falls

1. Initial Entry & Damage
Assessment

1.2 Fire/Explosion

1.3 Chemical Exposure

1.1.1 Watch footing on loose/shifting rocks. Visualize a safe travel path.

1.1.2 Wear railroad approved work boots with ankle support.

1.1.3 Avoid climbing on wreckage if suitable walking/working surfaces and or climbing
structures are not available.

1.1.4 If tank car ladder and guardrail at protective dome housing are damaged, configure
a suitable fall-arrest system before accessing the protective dome housing area.

1.1.5 Ensure that entrants in Level A PPE are physically able to withstand the demands
of the suit and also physically strong enough to traverse difficult terrain.

1.2.1 Identify all open sources of and other potential flammable liquids & gases using
manifest.

1.2.2 Identify potential ignition sources, locate all active fires.

1.2.3 If potential for ignition is real: wear flash-protective bunker gear/FRC only if liquid
and vapor exposure is not a threat. If protection from vapor and liquid exposure is
necessary and fire risk is elevated, utilize control measures to reduce fire threat first.
Using control measures to reduce the threat of fire will allow use of more common PPE.
If fire threat cannot be reduced, a more aggressive flash protective suit may be
necessary.

1.2.4 Conduct LEL monitoring. Action level 10% of LEL should result in egress.

1.2.5 Utilize hot work procedures before conducting activity capable of generating
sparks or could ignite flammable vapors or liquid.

1.2.6 Provide fire fighting measures to control fires.

1.2.7 Use appropriate fire fighting measures to cool cars with flame impingement or
adjacent to active fires or hot spots.

1.2.8 Use caution when walking among wreckage, look for subsurface pooling of liquid,
especially in the vicinity of active fires.

1.3.1 Don Level B PPE if release conditions are unknown. Downgrade to Level C PPE to
continue damage assessment if conditions permit (see PPE matrix).

1.3.2 Perform air monitoring on initial entry, document readings.

1.3.3 Observe wind direction and deploy a windsock.

1.3.4 Identify and mark areas of liquid releasing, secondary containment/ liquids,
impacted soil, or standing liquid.

1.3.5 All workers entering the site in PPE must receive a full decontamination of all
respiratory protection, CPC and equipment prior to exiting the warm zone.

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1.3.6 Decon workers must perform decontamination activities in 1 lower-level PPE
ensemble unless contamination is significant.

1.4 Heat Stress from PPE

1.4.1 Using CPC and respiratory protection can increase heat stress risk if ambient
conditions are warm or hot.

1.4.2 Conduct medical monitoring prior to and after entry to evaluate worker's
condition.

1.4.3 If necessary, limit the duration of each entry and maximize rest periods based on
site conditions and medical monitoring information.

1.4.4 Drink plenty of water; avoid excessive use of sports drinks.

1.4.5 Rest in shaded, cool areas. Consider adding fans, misting devices, or air-
conditioned rest areas (vehicles).

1.4.6 Avoid excessive intake of caffeine while at work and alcoholic beverages after
work.

1.5 Mechanical Injury from
wreckage or falling

1.5.1 Stay clear of unstable or elevated wreckage.

1.5.2 Avoid reaching/walking between unstable cars/loads.

1.5.3 Use caution when tightening valves. Observe all pinch points for hands.

1.6 Miscommunication

1.6.1 Establish effective hand signals for entrants to use if radio corns are not available.

1.6.2 Establish radio or cell phone communication with all responders.

1.6.3 Safety briefing conducted prior to initial entry.

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Job Safety Analysis Chemical-Specific Worksheet

Vinyl chloride

Job Steps

Hazards

2. Release Mitigation

2.1 Fire/Explosion

2.2 Injury from valve or
container repair

Hazard Controls

2.1.1 Identify all open sources of and other potential flammable liquids & gases
using manifest.

2.1.2 Identify potential ignition sources, locate all active fires.

2.1.3 If potential for ignition is real: wear flash-protective bunker gear/FRC only if
liquid and vapor exposure is not a threat. If protection from vapor and liquid
exposure is necessary and fire risk is elevated, utilize control measures to reduce fire
threat first. Using control measures to reduce the threat of fire will allow use of
more common PPE. If fire threat cannot be reduced, a more aggressive flash
protective suit may be necessary.

2.1.4 Conduct LEL monitoring. Action level 10% of LEL.

2.1.5 Utilize hot work procedures before conducting activity capable of generating
sparks or could ignite flammable vapors or liquid.

2.1.6 Provide fire fighting measures to control fires.

2.1.7 Use appropriate fire fighting measures to cool car(s) with flame impingement
or adjacent to active fires or hot spots.

2.1.8 Use caution when walking among wreckage, look for subsurface hot spots or
subsurface pooling in the vicinity of active fires.

2.1.9 All tools used during release mitigation should be non-sparking, intrinsically
safe. Combustion engines or electrical tools should not be used near flammable
atmospheres.

2.2.1 Use secure hoist to raise tools to the protective dome housing.

2.2.2 Avoid single-man manual lifting for loads greater than 50 lbs.

2.2.3 Ensure all connections are tight and secured.

2.2.4 Avoid body contact with high-pressure liquid streams.

2.2.5 Wear protective clothing capable of protecting from high-pressure water
impact.

2.2.6 Remember, aggressive PPE will make tasks requiring good manual dexterity
very difficult. Work safely and slowly to ensure proper use of valves, fittings, and
tools.

2.2.7 All tools should be non-sparking (brass).

2.2.8 Avoid contact chemical protective clothing with sharp edges of damaged shell,
brake lines, catwalk, railing etc. to keep the suit from tearing.

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Vinyl chloride

Job Steps

Hazards

Hazard Controls

2.3 Miscommunication

2.3.1 Establish effective hand signals for entrants to use if radio corns are not
available.

2.3.2 Establish radio or cell phone communication with all responders.

2.3.3 Safety briefing conducted prior to initial entry.

2.4 Chemical Exposure

2.4.1 Don Level A PPE to approach leak source. If leak is insignificant and controlled,
and worker can be upwind, then consider Level B PPE using PPE matrix.

2.4.2 Continuous air monitoring with workers during mitigation.

2.4.3 All workers entering the site in PPE must receive a full decontamination of all
respiratory protection, CPC and equipment prior to exiting the warm zone.

2.4.4 Decon workers must perform decontamination activities in 1-lower level PPE
ensemble.

2.6 Mechanical Injury

2.6.1 Stay clear of unstable or elevated wreckage.

2.6.2 Avoid reaching/walking between unstable cars/loads.

2.7 Slips/trips/falls

2.7.1 Watch footing on loose/shifting rocks. Visualize a safe travel path.

2.7.2 Wear railroad approved work boots with ankle support.

2.7.3 Abide by site fall protection safety protocols while working at elevations above
6 feet.

2.8 High Pressure Release

2.8.1 Perform all necessary pressure checks, PRV will activate at 75 psi.

2.8.2 Ensure that valves are manipulated in a safe and controlled manner when
tightening.

2.8.3 Essential personnel only at protective dome housing.

2.1.4 Conduct LEL monitoring. Action level 10% of LEL for known substances.

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Vinyl chloride

Job Steps

Hazards

Hazard Controls

3. Transfer of Vinyl chloride

3.1 Chemical Exposure

3.2 Transfer system release
or pressurization

3.3 Miscommunication

3.4 Static Electrical
Discharge

3.1.1 Perform air monitoring at the protective dome housing prior to connecting
transfer equipment to damaged car's valve assembly.

3.1.2 Don Level B when connecting transfer hose to damaged car's liquid and vapor
valves. See PPE Matrix to determine level based on conditions.

3.1.3 Ensure that transfer hoses, pumps, and compressors are free of liquid product
and depressurized before opening lines.

3.1.4 Don Level B PPE (if conditions warrant-see PPE matrix) when disconnecting
hoses, pumps, and compressors that have been emptied of free liquids.

3.1.5 All workers entering the site in PPE must receive a full decontamination of all
respiratory protection, CPC and equipment prior to exiting the warm zone.

3.1.6 Decon workers must perform decontamination activities in CPC.

3.1.7 If pressurizing damaged car with nitrogen to transfer, be aware that excessive
concentrations of nitrogen can displace oxygen and will asphyxiate unprotected
workers in the area of high concentration.

3.2.1 Be cautious of pressure buildup in lines during transfer.

3.2.2 Continue pressure checks on tank cars to monitor pressure conditions.

3.2.3 Valves should only be manipulated by competent persons.

3.2.4 Use chemical compatible, valves, fittings, and hoses.

3.2.5 Ensure all system pressures are within manufacture recommended ranges.

3.2.6 Ensure all connections are tight and secured.

3.2.7 Avoid body contact with pressurized liquid and gas streams even though
worker is protected by PPE.

3.2.8 Initially and periodically monitor pumps, hoses, valves, and fittings for liquid or
vapor leaks.

3.2.9 Use caution when connecting and disconnecting hydraulic pump lines; avoid
pressurized release of compressed air.

3.3.1 Establish effective hand signals for entrants to use if radio corns are not
available.

3.3.2 Establish radio or cell phone communication with all responders.

3.3.3 Safety briefing conducted prior to initial entry.

3.4.1 Ensure that all transfer equipment and receiving vessels are grounded and
bonded according to best practice.

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Job Safety Analysis Chemical-Specific Worksheet

Vinyl chloride

Job Steps

Hazards

Hazard Controls

3.5 Mechanical Injury

3.5.1 Stay clear of unstable or elevated wreckage.

3.5.2 Avoid reaching/walking between unstable cars/loads.

3.5.3 Ensure that tank car is secured to stabile equipment during tank car rotations.

3.6 Slips/trips/falls

3.6.1 Watch footing on loose/shifting rocks. Visualize a safe travel path.

3.6.2 Wear railroad approved work boots with ankle support.

3.6.3 Abide by site fall protection safety protocols while working at elevations above
6 feet.

3.6.4 Ensure that workers are aware of the decrease in flexibility and mobility when
wearing aggressive PPE, especially when climbing onto railcars or other equipment.

3.7 Fire/Explosion

3.7.1 Identify all open sources and other potential flammable liquids & gases using
manifest.

3.7.2 Identify potential ignition sources, locate all active fires.

3.7.3 If potential for ignition: wear flash-protective bunker gear/FRC and SCBA. If
airborne concentrations are high & sustained, use control measures to reduce threat
first.

3.7.4 Conduct LEL monitoring. Action level 10% of LEL for known substances.

3.7.5 Utilize hot work procedures before conducting activity capable of generating
sparks or could ignite flammable vapors or liquid.

3.7.8 All tools used during release mitigation should be non-sparking, intrinsically
safe. Combustion engines or electrical tools should not be used near flammable
atmospheres.

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rjoFtr=oi-K soLj-rnEmyj • Job Safety Analysis Chemical-Specific Worksheet Vinyl chloride

Job Steps

Hazards

Hazard Controls

4.1 Fugitive emissions

4.1.1 Use chemical compatible, valves, fittings, and hoses.

4.1.2 Ensure that vapor lines are properly secured to vapor scrubbing system if used.

4.1.3 Ensure all connections are tight and secured.

4.1.4 Initially and periodically monitor pumps, hoses, valves, and fittings for liquid or
gas leaks.

4.1.6 Properly decontaminate all hoses, fittings, tools, and other equipment used
during scrubbing operation.

4. Clean and purge

4.2 Chemical Exposure

4.2.1 Perform air monitoring at the protective dome housing prior to connecting
transfer equipment to damaged car's valve assembly.

4.2.2 Don Level B PPE when connecting vapor line to damaged car's vapor valves.
See PPE Matrix to determine based on conditions.

4.2.3 Ensure that transfer hoses, pumps, and compressors are free of liquid product
before opening lines.

4.2.4 Don Level B or C PPE when disconnecting hoses, pumps, and compressors that
have been emptied of free liquids.

4.2.5 All workers entering the site in PPE must receive a full decontamination of all
respiratory protection, CPC and equipment prior to exiting the warm zone.

4.2.6 Decon workers must perform decontamination activities in CPC.

4.3 System release or
pressurization

4.3.1 Be cautious of pressure buildup in lines during purge.

3.2.2 Continue pressure checks on tank cars to monitor pressure conditions.

3.2.3 Valves should only be manipulated by competent persons.

3.2.4 Use chemical compatible, valves, fittings, and hoses.

3.2.5 Ensure all system pressures are within manufacture recommended ranges.

3.2.6 Ensure all connections are tight and secured.

3.2.7 Avoid body contact with pressurized liquid and gas streams.

3.2.8 Initially and periodically monitor pumps, hoses, valves, and fittings for liquid or
vapor leaks.

3.2.9 Use caution when connecting and disconnecting hydraulic pump lines; avoid

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Job Safety Analysis Chemical-Specific Worksheet

Vinyl chloride

Job Steps

Hazards

Hazard Controls

pressurized release of compressed air.

4.4 Mechanical Injury

4.4.1 Stay clear of unstable or elevated wreckage.

4.4.2 Avoid reaching/walking between unstable cars/loads.

4.5 Slips/trips/falls

4.5.1 Watch footing on loose/shifting rocks. Visualize a safe travel path.

4.5.2 Wear railroad approved work boots with ankle support.

4.5.3 Abide by site fall protection safety protocols while working at elevations above
6 feet.

4.6 Fire/Explosion

4.6.1 Identify all sources and other potential flammable liquids & gases using
manifest.

4.6.2 Identify potential ignition sources, locate all active fires.

4.6.3 If potential for ignition: wear flash-protective bunker gear/FRC.

4.6.4 Conduct LEL monitoring. Action level 10% of LEL for known substances.

4.6.5 Utilize hot work procedures before conducting activity capable of generating
sparks or could ignite flammable vapors or liquid.

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Job Safety Analysis Chemical-Specific Worksheet

Vinyl chloride

Job Steps

Hazards

Hazard Controls

5. Removal of residual
materials and impacted soil

5.1 Chemical Exposure

5.2 Vac operations

5.3 Excavation operations

5.1.1 Provide continuous air monitoring to determine if vapors are elevated in the
work areas near impacted soil.

5.1.2 Don Level B PPE to work in close proximity to impacted soils with elevated
vapor. If vapor levels are high, return to using Level A until vapor concentrations are
reduced.

5.1.3 All workers entering the site in PPE must receive a full decontamination of all
respiratory protection, CPC and equipment prior to exiting the warm zone.

5.1.4 Decon workers should perform decontamination activities in LEVEL C PPE, but
full-faced respirator may not be required if minimal contamination is present.

5.1.5 Excavation, loading, and unloading of impacted soil or debris may generate
elevated vapor. Excavation operators should be prepared to don full-faced APR if
conditions require respiratory protection. Ground-level workers may be required to
don Level B PPE to avoid inhalation of vapor and skin contact with impacted soil.

5.2.1 Use chemical compatible, valves, fittings, and hoses.

5.2.2 Ensure all system pressures are within manufacture recommended ranges.

5.2.3 Ensure all connections are tight and secured.

5.2.4 Avoid body contact with liquid streams.

5.2.5 Initially and periodically monitor hoses, valves, and fittings for liquid leaks.

5.2.6 Ensure that all vent hoses are positioned to direct vacuum exhaust away from
the work area.

5.2.7 Ensure that vac trucks are parked on secure areas and are properly staged to
minimize potential for unwanted equipment movements.

5.2.8 Properly ground and bond all vac truck equipment to avoid static discharge.

5.2.9 The use of a vac truck to remove liquids may require the most aggressive form
of PPE if the liquid is highly concentrated, based on the volume and disposition of
liquid being removed.

5.3.1 Ensure that all machinery is equipped with properly functioning audible alarms
for movement.

5.3.2 Avoid unnecessary foot traffic within the operating distances of the machinery.

5.3.4 Keep all workers from working beneath suspended loads.

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Job Steps

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Hazard Controls

5.3.5 All receiving containers must be properly staged on a suitable foundation and
secured before loading.

5.3.6 All machinery must be operated from secure locations.

5.4 Slips/trips/falls

6.4.1 Watch footing on loose/shifting rocks. Visualize a safe travel path.
6.4.1 Wear railroad approved work boots with ankle support.

5.5 Railway hazards

6.5.1 All workers must be briefed on track protection

6.5.2 All workers must abide by railroad track safety rules as covered by contractor
orientation.

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Job Safety Analysis Chemical-Specific Worksheet

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Additional Site Hazards

Actions to Eliminate Hazards

10.

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i\joFti=oL-i< sou~rni=Ftr\i • Job Safety Analysis Chemical-Specific Worksheet Vinyl chloride

Name

Signature

Date Signed

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CTEH

THE SCIENCE OF READY3"

Norfolk Southern Train derailment East Palestine, OIH

East Palestine, OH

CTEH® Site-Specific Health and Safety Plan

(HASP)

Version 1.0

Prepared By:

CTEH,LLC
5120 Northshore Drive
North Little Rock, Arkansas 72118
501-801-8500

CTEH Project Number PROJ-024579

Name

Signature

Date Signed

Prepared By:

Jason Davis

Reviewed By:

Micah Kendrick, CSP

M —

February 3,

2023

Approved By:

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Incident Information

Effective Date

Incident Name

Norfolk Southern Train derailment East Palestine, OH

Location

East Palestine, OH

1.0 DESCRIPTION OF INCIDENT:

This incident is involving a fire caused by a train derailment in East Palestine, OH.

2.0 PURPOSE:

This plan addresses air and environmental monitoring tasks by CTEH®, LLC (CTEH). The activities may
include: worker air monitoring, community assessment air monitoring, site assessment air monitoring,
water sampling, sediment sampling, and soil sampling.

This site-specific information has been developed from the latest available information. Revisions and
alterations to this plan may become necessary as further information, (i.e., environmental sampling
results, changes in site conditions, changes in scope of work, etc.), is developed or becomes available. All
alterations to this plan should be recorded in the Health & Safety Plan Management of Change section.

All on-site personnel are required to review and comply with this Health and Safety Plan. It is the
responsibility of the project manager to ensure this plan is implemented.

3.0 SITE & EMERGENCY CONTACTS

3.1 Emergency Services Contact Information

Fire/Police/Ambulance - 911

East Liverpool City Hospital - (330) 385-7200

3.2 Project Contact Information

Air PM - Ethan Currie - CTEH - 409-204-2751

Project Technical Director - Katrina Jew - CTEH - 760-576-9696

Client Contact - Mark Duddle - 404-273-2082

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4.0 SITE CONTROL

See Addendum for a Location map and hospital route.

1 Site Control

Location 1

Staging Area:

Site Security and Access Points:

TBD

Exclusion Zone:

TBD

Support Zone:

TBD

5.0 HAZARD ASSESSMENT

5.1 Chemical Hazards

Vinyl Chloride is a colorless gas with a sweet odor. Easily ignited. Shipped as a liquefied gas under own
vapor pressure. Contact with the unconfined liquid may cause frostbite by evaporative cooling. Leaks
may be liquid or vapor. Vapors are heavier than air. May asphyxiate by the displacement of air. Under
prolonged exposure to fire or intense heat the containers may rupture violently and rocket. Suspected
carcinogen. Used to make plastics, adhesives, and other chemicals. Chemical health hazards include
INHALATION: high concentrations cause dizziness, anesthesia, lung irritation. SKIN: may cause frostbite;
phenol inhibitor may be absorbed through skin if large amounts of liquid evaporate. (USCG, 1999)

Liquefied Petroleum Gas is a mixture of butane, isobutane, propane, propylene, butylenes and other
hydrocarbons of low molecular weight that is refined from petroleum. Maintained as a liquid under
pressure. Leaking vessels can release either the liquid, which quickly vaporizes, or the gaseous mixture.
The gas is heavier than air- a flame can flash back to the source of the leak very easily. Under prolonged
exposure to heat the containers may rupture violently and rocket. Used as a fuel, an aerosol propellant,
in cigarette lighters, and to make other chemicals. Chemical health hazards include Concentrations in air
greater than 10%; cause dizziness in a few minutes, 1% concentrations give the same symptom in 10 min.
High concentrations cause asphyxiation. (USCG, 1999)

Isobutylene is a colorless gas with a faint petroleum-like odor. For transportation it may be stenched. It
is shipped as a liquefied gas under its own vapor pressure. Contact with the liquid can cause frostbite. It
is easily ignited. Its vapors are heavier than air and a flame can flash back to the source of leak very easily.
The leak can either be a liquid or vapor leak. It can asphyxiate by the displacement of air. Under prolonged

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exposure to fire or heat the containers may rupture violently and rocket. It is used in the production of
isooctane, a high octane aviation gasoline. Chemical health hazards include Inhalation of moderate
concentrations causes dizziness, drowsiness, and unconsciousness. Contact with eyes or skin may cause
irritation; the liquid may cause frostbite. (USCG, 1999)

Benzene is a clear colorless liquid with a petroleum-like odor. Flash point less than 0°F. Less dense than
water and slightly soluble in water. Hence floats on water. Vapors are heavier than air. Chemical health
hazards include Dizziness, excitation, pallor, followed by flushing, weakness, headache, breathlessness,
chest constriction, nausea, and vomiting. Coma and possible death. (USCG, 1999)

Ethylene glycol is a clear, colorless syrupy liquid. The primary hazard is the threat to the environment.
Immediate steps should be taken to limit its spread to the environment. Since it is a liquid it can easily
penetrate the soil and contaminate groundwater and nearby streams. Chemical health hazards include
Inhalation of vapor is not hazardous. Ingestion causes stupor or coma, sometimes leading to fatal kidney
injury. (USCG, 1999)

2-Ethylhexyl Acrylate is a clear colorless liquid with a pleasant odor. Less dense than water and insoluble
in water. Vapors heavier than air. Flash point 180°F. Used in making of paints and plastics. Chemical
health hazards include Inhalation of concentrated vapor causes drowsiness and convulsions. Liquid
causes irritation of eyes and may irritate skin on prolonged exposure. Ingestion produces same symptoms
as inhalation. (USCG, 1999)

Sulfuric acid is a colorless oily liquid. It is soluble in water with release of heat. It is corrosive to metals
and tissue. It will char wood and most other organic matter on contact, but is unlikely to cause a fire.
Density 15 lb / gal. Long term exposure to low concentrations or short term exposure to high
concentrations can result in adverse health effects from inhalation. It is used to make fertilizers and other
chemicals, in petroleum refining, in iron and steel production, and for many other uses.

Rate of onset: Immediate
Persistence: Hours, days
Odor threshold:

Source/use/other hazard: Battery/dyes/paper/glue/metals industries; volcanic gas; toxic fumes when
heated. Chemical health hazards include Corrosive to all body tissues. Inhalation of vapor may cause
serious lung damage. Contact with eyes may result in total loss of vision. Skin contact may produce severe
necrosis. Fatal amount for adult: between 1 teaspoonful and one-half ounce of the concentrated
chemical. Even a few drops may be fatal if the acid gains access to the trachea. Chronic exposure may

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cause tracheobronchitis, stomatitis, conjunctivitis, and gastritis. Gastric perforation and peritonitis may
occur and may be followed by circulatory collapse. Circulatory shock is often the immediate cause of
death. Those with chronic respiratory, gastrointestinal, or nervous diseases and any eye and skin diseases
are at greater risk. (EPA, 1998)

See attached Safety Data Sheet (SDS) for more details on chemical hazards.

See the CTEH® Air Sampling and Analysis Plan for site-specific action levels.

5.2 Physical Hazards
5.2.1 Weather Information

Responders should always maintain situational awareness of changing weather conditions through their
CTEH® provided handheld device. Additionally, a safety briefing will occur prior to the beginning of each
shift and weather information should be presented at that time. The current weather for the incident site
can be accessed via the QR code below:

Link to current weather

5.2.2 Thermal Stress

Thermal stress (heat stress or cold stress) hazards and strategies for mitigating impact on worker safety
and health can be addressed based on information obtained in the OSHA-NIOSH Heat App. An addendum
to this document may be added if deemed necessary by the project manager and corporate safety officer.

5.2.3 Severe Weather Hazard

In the event that a severe weather event disrupts work activity, seek shelter immediately. Egress work
areas to the nearest enclosed shelter and stay away from windows if possible. Alert the CTEH® division
supervisor or project manager as soon as possible, and provide a situational update.

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If a lightning strike is observed within 10 miles of the work site, a mandatory 30-minute stand down will
be in effect. Seek shelter indoors or in a vehicle. The stand down will continue to restart until the last
lightning strike within 10 miles is observed. Stay indoors or in a vehicle until the entire 30-minute stand
down period expires.

5.2.4 Moving Vehicles

Be cautious of all motor vehicles on site as well as in the community. As a pedestrian, look 360° before
walking to identify any moving vehicles in your nearby vicinity. Personnel should wear reflective safety
gear as the outermost layer of clothing on site, day or night.

5.2.5 Distracted Driving and Driving Safety

CTEH® personnel must abide by CTEH®, client, state, and local regulations and guidelines regarding driving
while using cell phones. Under no circumstances are CTEH® personnel permitted to text or email while
driving. In most cases, CTEH® personnel should pull over safely, away from traffic, to conduct cell phone
or radio communications.

CTEH® personnel are not permitted to operate a motor vehicle without seatbelts being properly worn.
Once you have secured your seatbelt, please adjust your window and driver mirrors. Do not block
windows with contents such that your view is obstructed while driving.

5.2.6 Motor Vehicle Hazards

When operating a motor vehicle, look both ways before entering a roadway or crossing intersections.
Look for pedestrians on or near roadways. Do not email or text while operating a motor vehicle. Driving
at dusk and dawn or low light conditions decrease driver visibility, and be aware that animals are much
more active during these times. Driving on wet, snowy, gravel, or dirt roads warrant operation of the
vehicle at a conservative speed. Not all gravel road crossings are controlled crossings; some do not have
stop signs. In addition to lack of signage, high grasses may obstruct a driver's view at crossings

5.2.7 Heavy Equipment

Track hoes, bulldozers, dump trucks, vacuum trucks, commercial pickup trucks, and other heavy
machinery may be present at the site during remediation activities. Stay outside of the boom radius of
any lever-based heavy machinery.

5.2.8 Electrical

Underground power lines, generators, light plants, and plug-in power sources may create the potential
for electrical shock or electrocution. Assess all CTEH® power equipment and power cords for defects. If

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any electrical equipment is defective, remove from service. For your own safety, maintain awareness of
other site personnel and equipment that may cause electrical issues.

5.2.9 Fire & Explosion

The nature of the site and existence of an ignition source, fire, variable pressures, and variable unknown
sources may create explosion hazards either indoors or outdoors. Containers may explode when heated.
CTEH® personnel will don flame resistant clothing (FRCs) when in the work area.

Vapors may travel to source of ignition and flash back. Most vapors are heavier than air. They will spread
along ground and collect in low or confined areas (basin, sewers, basements, tanks). Runoff to sewer may
create fire or explosion hazard. Containers may explode when heated. Many liquids are lighter than water.

The flammability hazards associated with vinyl chloride are as follows. Highly flammable. Burns readily.
Rapidly or completely vaporizes at atmospheric pressure and normal ambient temperature. Special
Hazards of Combustion Products: Forms highly toxic combustion products such as hydrogen chloride,
phosgene, and carbon monoxide.

Behavior in Fire: Container may explode in fire. Gas is heavier than air and may travel considerable
distance to a source of ignition and flash back. (USCG, 1999).

The flammability hazards associated with liquefied petroleum gas are as follows. Excerpt from GUIDE 115
[Gases - Flammable (Including Refrigerated Liquids)]:

EXTREMELY FLAMMABLE. Will be easily ignited by heat, sparks or flames. Will form explosive mixtures
with air. Vapors from liquefied gas are initially heavier than air and spread along ground. CAUTION:
Hydrogen (UN1049), Deuterium (UN1957), Hydrogen, refrigerated liquid (UN1966) and Methane
(UN1971) are lighter than air and will rise. Hydrogen and Deuterium fires are difficult to detect since they
burn with an invisible flame. Use an alternate method of detection (thermal camera, broom handle, etc.)
Vapors may travel to source of ignition and flash back. Cylinders exposed to fire may vent and release
flammable gas through pressure relief devices. Containers may explode when heated. Ruptured cylinders
may rocket. (ERG, 2016).

The flammability hazards associated with isobutylene are as follows. Highly flammable. Burns readily.
Rapidly or completely vaporizes at atmospheric pressure and normal ambient temperature. Behavior in
Fire: Containers may explode in fire. Vapor is heavier than air and may travel a long distance to a source
of ignition and flash back. (USCG, 1999).

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The flammability hazards associated with benzene are as follows. Highly flammable. Can be ignited under
almost all ambient temperature conditions. Behavior in Fire: Vapor is heavier than air and may travel
considerable distance to a source of ignition and flash back. (USCG, 1999).

The flammability hazards associated with ethylene glycol are as follows. This chemical is combustible.
(NTP, 1992).

The flammability hazards associated with 2-ethylhexyl acrylate are as follows. Must be moderately
heated or exposed to relatively high ambient temperatures before ignition can occur. Behavior in Fire:
Heat can result in a severe polymerization with rapid release of energy. Sealed containers may rupture
explosively if hot. (USCG, 1999).

The flammability hazards associated with sulfuric acid are as follows. Will not burn under typical fire
conditions. It is highly reactive and capable of igniting finely-divided combustible materials on contact.
When heated, it emits highly toxic fumes. Avoid heat; water and organic materials. Sulfuric acid is
explosive or incompatible with an enormous array of substances. Can undergo violent chemical change at
elevated temperatures and pressure. May react violently with water. When heated, it emits highly toxic
fumes. Hazardous polymerization may not occur. (EPA, 1998).

Refer to the attached CTEH® Air Sampling and Analysis Plan (SAP) for information regarding site-specific
action levels for flammable atmospheres.

5.2.10 Hot Work

Response operations may include hot work (i.e. cutting or grinding). Due to the potential fire and
explosion hazards of VINYL CHLORIDE, LIQUEFIED PETROLEUM GAS, ISOBUTYLENE, BENZENE, ETHYLENE
GLYCOL, 2-ETHYLHEXYL ACRYLATE, SULFURIC ACID constituents, WELDING OR USE OF TORCHES IS NOT
PERMITTED UNLESS A HOT WORK PERMIT OR OTHER WRITTEN PERMISSION IS OBTAINED FROM THE
SITE HEALTH AND SAFETY OFFICER - NO EXCEPTIONS. CTEH® employees will not participate or assist in
the performance of hot work if this condition is not met. If hot work occurs and CTEH® is tasked with
providing air monitoring for the hot work permit, LEL monitoring (confirmed by VOC readings) will be
performed to determine whether combustible vapors are detected at or near the relevant Action Levels.
See the CTEH® hot work policy or speak with the Corporate Safety Officer for clarification.

5.2.11 Trip Hazards

Uneven or slick terrain provides an environment in which slips, trips, and falls should be considered. Be
aware of your travel path prior to walking or changing directions. Search for any obstructions that may
present as a trip hazard.

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5.2.12 Noise

Emergency Response work sites are considered non-traditional and often difficult to characterize noise
exposures. Please keep hearing protection readily accessible. For work areas experiencing high noise
levels (greater than 90 dB) and/or impact noise (greater than 140 dB), please utilize hearing protection.

5.2.13 Eye Protection

The site may include dusty conditions or particulate hazards from other sources. If dusty conditions are
present, helmet-mounted goggles should replace safety glasses to further protect your eyes from
particulate-induced eye injury.

5.2.14 Dermal Contact Hazards

VINYL CHLORIDE, LIQUEFIED PETROLEUM GAS, ISOBUTYLENE, BENZENE, ETHYLENE GLYCOL, 2-
ETHYLHEXYL ACRYLATE, SULFURIC ACID may cause contact dermatitis if exposed to skin for prolonged
periods. Avoid skin contact with constituents with use of appropriate chemical resistant gloves, boots,
and coveralls. If skin contact occurs, was with copious amounts of water for at least 15 minutes. Remove
any contaminated clothing and discard. If redness or other irritation symptoms persist, seek medical
attention. Poison Oak and Poison Ivy may be present in areas encountered by field personnel. Use
caution to avoid contact with these plants, this includes equipment as well.

5.2.15 Water Hazards

Employees working in areas unprotected by passive fall protection systems (OSHA specified railings or
nets), where the danger of drowning exists, must wear U.S. Coast Guard approved life jacket or buoyant
work vest, commonly referred to as personal flotation device (PFD). However, this regulation can be
superseded with the use of fall protection. If an employee cannot fall into the water as a result of use of
active or passive fall protection, there is no danger of drowning, and a PFD is not required. Safety lines
that prevent employees from reaching the water eliminate the danger of drowning, and negate the need
for a PFD. The same is true when working on a barge or floating platform with an approved railing system.

5.2.16 Biological Hazards

CTEH has adopted the following guidelines based on current CDC recommendations. All employees, both
vaccinated and unvaccinated, will wear a facial covering in accordance with the poster shown below:

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U Mask Requirements for Offices in
I cn COVID-l9 Community Levels

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All Employees, Contractors, and Visitors

No One Within
6 Feet

Someone Within
6 Feet

Stationary / Seated

No Mask Required

Mask Required

Mobile / Walking

Mask Required

NOTES:

CTEH employees must adhere
to any city, county, and state
mask regulations.

Masks are not required for
offices in Low and Medium
COVID-19 Community Levels.

Talk to your healthcare provider
about mask recommendations if
you are immunocompromised
or at high risk for severe illness.

Check Your
Community Level

Additional precautions should be taken to aid in prevention of transmission of COVID-19. CTEH employees
should observe the following:

• When possible, put 6 feet of distance between yourself and people who don't live in your
household. Remember that some people without symptoms may be able to spread the virus.
Keeping distance form others is especially important for people who are at higher risk of getting
very sick.

• Wash your hands often with soap and water for at least 20 seconds especially after you have been
in a public, or after blowing your nose, coughing, or sneezing. If hand washing is not available use
an alcohol-based hand sanitizer with at least 60% ethyl alcohol.

• If you have been exposed or potentially exposed to SARS-CoV-2, contact the CTEH Nurse Hotline
at 1 (800) 699-3083 for guidance related to isolation, quarantine, or healthcare. If you have
symptoms of COVID-19 (including fever greater than 100.4°F or 38°C and additional symptoms,
such as coughing or difficulty breathing) it is important to stay away from other people.

• Monitor your health daily. Be alert to symptoms and complete your daily wellness report. If you
are sick, do not come to work. Contact the Nurse Hotline for guidance on isolation and testing

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requirements. Each employee is required to their wellness daily, and if yes to any of the 4 wellness
questions, submit a report at www.cteh.com/wellness.

CTEH personnel will adhere to the most current CDC guidelines for mask usage or requirements outlined
by the client for which they are working, whichever is more protective.

6.0 EXPOSURE CONTROL

6.1 Personal Protection Requirements

The following is the default level of PPE required. This level may be modified depending on specific site
conditions or job tasks as determined by the Project Manager. Prior to beginning any work task determine
the appropriate level of PPE through consultation with the PM or Site Safety Officer.

Level D - Hardhat, eye protection, foot protection, hearing protection, and fire resistant clothing (FRC).
Level D PPE may also include helmet-mounted eye protection goggles.

6.2 Respiratory Protection Guidelines

Refer to the attached CTEH® Air Sampling and Analysis Plan or specific Job Safety Analysis (JSA) for
recommendations. Additionally, if CTEH® elects or is requested to engage in operations necessitating
respiratory protection, an addendum to this document may be produced.

6.3 Regulated Area & Critical Operations

Based on the potential presence of benzene vapor, and as per OSHA 29 CFR 1910.1028, a regulated area
will be established for locations where >0.5 ppm (OSHA Action Level) benzene vapor is sustained. This
regulated area shall be demarcated in any manner that minimizes the number of persons within the area
and protects persons outside the area from exposure to levels above the action level. Signs shall be posted
at entrances to the regulated area. Respiratory protection must be used for those entering the regulated
area. At a minimum, a full-faced APR equipped with cartridges compatible for protection against
benzene is required for CTEH8 entrants into the regulated area.

Personnel are required to be trained in accordance with OSHA 29 CFR 1910.120 for the level at which they
are performing duties.

7.0 EDUCATION & TRAINING

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7.1 Facility to perform medical testing/monitoring:

If medical monitoring is to be performed, representatives from CTEH® will locate the nearest qualified
healthcare facility.

7.2 Site specific training required:

In addition to the training requirements above, the following site-specific training topics may be reviewed
prior to work on the site:

XI Site Hazards (material released, physical hazards, etc.)

XI Work areas / activities identified

XI Site Emergency Alerting / Contingency Plan

XI Evacuation Route / Assembly Areas

Required PPE
1X1 Obtaining Medical Treatment / First Aid

XI Decontamination procedures
[XI Buddy System
]] Confined Space
H Other:

~ Other:

7.3 Safety Briefing/Hazard Communication

A safety briefing will occur prior to the beginning of each shift and anytime that work conditions change.
Site safety briefings will be completed each day and kept on file.

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8.0 MEDICAL SURVEILLANCE

8.1 Special Medical Monitoring Required:

1910.1017(k) Medical surveillance. A program of medical surveillance shall be instituted for each
employee exposed, without regard to the use of respirators, to vinyl chloride in excess of the action level.
The program shall provide each such employee with an opportunity for examinations and tests in
accordance with this paragraph. All medical examinations and procedures shall be performed by or under
the supervision of a licensed physician, and shall be provided without cost to the employee.

1910.1017(k)(l) At the time of initial assignment, or upon institution of medical surveillance;

1910.1017(k)(l)(i) A general physical examination shall be performed, with specific attention to detecting
enlargement of liver, spleen or kidneys, or dysfunction in these organs, and for abnormalities in skin,
connective tissues and the pulmonary system (See appendix A).

1910.1017(k)(l)(ii) A medical history shall be taken, including the following topics:

1910.1017(k)(l)(ii)(A) Alcohol intake;

1910.1017(k)(l)(ii)(B) Past history of hepatitis;

1910.1017(k)(l)(ii)(C) Work history and past exposure to potential hepatotoxic agents, including drugs
and chemicals;

1910.1017(k)(l)(ii)(D) Past history of blood transfusions; and
1910.1017(k)(l)(ii)(E) Past history of hospitalizations.

1910.1017(k)(l)(iii) A serum specimen shall be obtained and determinations made of:
1910.1017(k)(l)(iii)(A) Total bilirubin;

1910.1017(k)(l)(iii)(B) Alkaline phosphatase;

1910.1017(k)(l)(iii)(C) Serum glutamic oxalacetic transaminase (SGOT);

1910.1017(k)(l)(iii)(D) Serum glutamic pyruvic transaminase (SGPT); and
1910.1017(k)(l)(iii)(E) Gamma glustamyl transpeptidase.

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1910.1017(k)(2) Examinations must be provided in accordance with this paragraph at least annually.

1910.1017(k)(3) Each employee exposed to an emergency shall be afforded appropriate medical
surveillance.

1910.1017(k)(4) A statement of each employee's suitability for continued exposure to vinyl chloride
including use of protective equipment and respirators, shall be obtained from the examining physician
promptly after any examination. A copy of the physician's statement shall be provided each employee.

1910.1017(k)(5) If any employee's health would be materially impaired by continued exposure, such
employee shall be withdrawn from possible contact with vinyl chloride.

1910.1017(k)(6) Laboratory analyses for all biological specimens included in medical examination shall be
performed by accredited laboratories.

1910.1017(k)(7) If the examining physician determines that alternative medical examinations to those
required by paragraph (k)(1) of this section will provide at least equal assurance of detecting medical
conditions pertinent to the exposure to vinyl chloride, the employer may accept such alternative
examinations as meeting the requirements of paragraph (k)(l) of this section, if the employer obtains a
statement from the examining physician setting forth the alternative examinations and the rationale for
substitution. This statement shall be available upon request for examination and copying to authorized
representatives of the Assistant Secretary and the Director., No medical surveillance guidance available.,
No medical surveillance guidance available.,

1910.1028(i)(l) General.

1910.1028(i)(l)(i) The employer shall make available a medical surveillance program for employees who
are or may be exposed to benzene at or above the action level 30 or more days per year; for employees
who are or may be exposed to benzene at or above the PELs 10 or more days per year; for employees who
have been exposed to more than 10 ppm of benzene for 30 or more days in a year prior to the effective
date of the standard when employed by their current employer; and for employees involved in the tire
building operations called tire building machine operators, who use solvents containing greater than 0.1
percent benzene.

1910.1028(i)(l)(ii) The employer shall assure that all medical examinations and procedures are performed
by or under the supervision of a licensed physician and that all laboratory tests are conducted by an
accredited laboratory.

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1910.1028(i)(l)(iii) The employer shall assure that persons other than licensed physicians who administer
the pulmonary function testing required by this section shall complete a training course in spirometry
sponsored by an appropriate governmental, academic or professional institution.

1910.1028(i)(l)(iv) The employer shall assure that all examinations and procedures are provided without
cost to the employee and at a reasonable time and place.

1910.1028(i)(4) Emergency examinations.

1910.1028(i)(4)(i) In addition to the surveillance required by (i)(l)(i), if an employee is exposed to benzene
in an emergency situation, the employer shall have the employee provide a urine sample at the end of
the employee's shift and have a urinary phenol test performed on the sample within 72 hours. The urine
specific gravity shall be corrected to 1.024.

1910.1028(i)(4)(ii) If the result of the urinary phenol test is below 75 mg phenol/L of urine, no further
testing is required.

1910.1028(i)(4)(iii) If the result of the urinary phenol test is equal to or greater than 75 mg phenol/L of
urine, the employer shall provide the employee with a complete blood count including an erythrocyte
count, leukocyte count with differential and thrombocyte count at monthly intervals for a duration of
three (3) months following the emergency exposure.

1910.1028(i)(4)(iv) If any of the conditions specified in paragraph (i)(5)(i) of this section exists, then the
further requirements of paragraph (i)(5) of this section shall be met and the employer shall, in addition,
provide the employees with periodic examinations if directed by the physician., No medical surveillance
guidance available., No medical surveillance guidance available., No medical surveillance guidance
available.

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9.0 SAFETY EQUIPMENT, LOCATION, RESPONSIBILITY

First Aid/CPR trained personnel may use this kit to

First Aid Kit All Sites ... ...

administer first aid as necessary.

Fire Extinguisher trained personnel may use this to
extinguish small, manageable fire. Do not attempt to
extinguish chemical fires based on compatibility, nor large
fires for which the extinguisher is incapable of mitigating.
For chemical fires or large fires, contact the fire dept.

Communication

Throughout site

Cell phones shall be used to maintain communication for all

personnel.

Sanitation

Throughout site

Portable latrines or designated restroom facilities should be
used accordingly.

Portable light plants should be used to illuminate the work

Lighting

Throughout site and

area during dark or night operations. Personnel should also

on personnel

be equipped with flashlights or headlamps during dark or
night operations.

10.0 Decontamination

General Guidelines: Effective decontamination procedures should be practiced to minimize secondary
contamination of workers or the environment. Utilize available PPE at each site and always discard PPE
onsite in appropriate containers. Bags of contaminated PPE should be taken to the nearest designated
disposal area, as identified by the site supervisors.

General Decontamination Solutions: The use cleaning solutions should be appropriate for cases of severe
contamination. Environmental and Safety personnel will permit solvents for use on personnel, equipment,
and tools upon review of the SDS. All decontamination solutions are to be contained and collected for
proper disposal.

11.0 CONTINGENCY PLANS

In the event of an emergency (at this incident site) the person first noticing the emergency should notify
other workers in the immediate area. Evacuation should commence at once if the emergency poses any
threat to the safety of the workers. Upon receiving notification of an emergency, the individual in charge
of the work area should take appropriate measures to protect human life, the environment (including
wildlife), and property.

11.1 Escape Routes:

Evacuate to crosswind and upwind locations.

Fire Ask Site

Extinguisher Safety Officer

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11.2 Evacuation Procedures:

Evacuate up or crosswind to an upwind location.

11.3 Alerting Method:

Due to the nature of an emergency response, be aware of alerting methods, such as air horns, whistles,
etc., that may indicate site conditions are no longer safe and workers should egress as directed in section
11 above. Communication will be through two-way radios and/or cell phones.

12.0 AMENDMENTS TO SITE SPECIFIC HEALTH & SAFETY PLAN

This Site-Specific Health and Safety Plan is based on information available at the time of preparation.
Unexpected conditions may arise which necessitate changes to this plan. Unplanned activities and/or
changes in the hazard status should initiate a review of major changes in this plan.

Changes in the hazard status or unplanned activities are to be submitted on "Amendments to Site-Specific
Health and Safety Plan" which is included as Page 12 of this plan.

Amendments must be approved by the Project Manager prior to implementation.

All notes, documentation, and records must NOT be discarded after their use. Documents are to be
submitted to designated personnel for record retention.

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Health & Safety Plan Management of Change

Change 001

Description of Change (include sections & page numbers):

Name/Position Signature Date Signed

Prepared By:

Approved By:

Change 002

Description of Change (include sections & page numbers):

Name/Position Signature Date Signed

Prepared By:

Approved By:

Change 003

Description of Change (include sections & page numbers):

Name/Position Signature Date Signed

Prepared By:

Approved By:

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Sign-In

Name

Signature

Date Signed

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Addendum A

Hospital Map

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East Liverpool City Hospital
425 W. 5th St,

East Liverpool, OH 43920
(330) 385-7200

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Addendum B

SDS

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Addendum C

CTEH Hot Work Policy

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CTEH® 0011

Welding, Cutting, & Hot Work

Introduction and Purpose:

Hot work is defined as work involving burning, welding, or other operations that are capable of
producing sparks and initiating fires or explosions. Similar operations include, without limitation,
cutting, brazing, grinding and soldering.

CTEH0 employees do not perform hot work, but may be called upon to work in settings where related
hazards exist such as the presence of potentially explosive atmospheres or other flammable
materials. CTEH0 also does not authorize the performance of hot work, or prepare, verify or execute
hot work permits. CTEH0 may, upon request, perform lower explosive limit ("LEL") air monitoring for
clients or their other contractors as part of the safety protocols established by the responsible parties
in connection with hot work. Only employees that have been trained as set forth below shall perform
this service.

This hot work policy applies to CTEH® projects in which hot work is being performed by other
employers. Because CTEH® employees may be exposed to related hazards and work in the immediate
vicinity of hot work, relevant information is provided for situational awareness regarding the
procedures and protocols being implemented by the responsible parties. The CTEH0 Project Manager
or staff should consult with the Director of Health & Safety Services or senior management regarding
any questions or uncertainties.

CTEH® SPECIFIC POLICIES:

1. Before air monitoring for hot work is started, a CTEH0 qualified person and other
contractors or personnel involved shall discuss the planned project completely, including
the type of hot work to be conducted, the hazards in the area, and the provisions of the
permit (if applicable). CTEH® personnel will advise the responsible party(ies) of the air
monitoring results and make clear that it has no other responsibility for compliance with
hot work regulations or other guidance.

2. If at any time lower explosive limit instrument readings are identified, CTEH® employees
will immediately advise the involved party(ies) and personnel performing the hot work to
discontinue those operations until the situation can be assessed by qualified personnel.

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3. CTEH® personnel will, when performing air monitoring for hot work or around potentially
flammable atmospheres, wear appropriate PPE including, without limitation, flame
resistant clothing.

4. CTEH® policy will be to not perform air monitoring in connection with hot work unless an
appropriate permit is prepared by the responsible party. However, as a limited exception,
air monitoring for hot work without a permit may be performed in an area designated,
designed, or approved for hot work that has been verified as such by the facility owner to
the CTEH0 Project Manager (see NFPA 51B §5.2.2). A sample permit is located in NFPA
51B.

5. CTEH® employees must consult with the CTEH0 Project Manager prior to the performance
of LEL monitoring in connection with hot work.

PERMIT REQUIRED? Yes. The party responsible for authorizing hot work must designate
appropriate precautions preferably in the form of a written permit following an inspection of the area.
See §1910.252(a)(2)(iv) and §1910.119(k).

DEFINED TERMS: Defined terms (bold faced in this policy) are set forth in §1910.251, Definitions.
NFPA 51B Ch. 3, Definitions; and API 2201 Ch. 3, Definitions.

TRAINING: CTEH® employees will be provided with training regarding potential ignition risks
associated with hot work and, separately, operations training regarding the lower explosive level of
hazardous materials and measurement thereof using appropriate equipment. CTEH® personnel that
may participate in air monitoring in support of Permit Required Hot Work will complete the following
annual training:

1. LEL monitoring

2. Permit Required Hot Work Safety

The CTEH® Project Manager will confirm that all employees performing LEL air monitoring for, or
otherwise working near, hot work have the required training.

SITUATIONAL AWARENESS: The responsible party(ies) planning and performing hot work and
preparing appropriate permit(s), should consider among other matters the information set forth
below. It is provided in this policy for the situational awareness of CTEH® personnel and to inform their
discussions with such party(ies):

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Regulatory requirements and materials incorporated by reference:

1. Basic Precautions from §1910.252(a):

a. If the object that is the subject of the hot work cannot be moved, all movable fire
hazards in the vicinity shall be taken to a safe place.

b. If all of the fire hazards cannot be removed, then guards shall be used to confine
the heat, sparks, and slag, and to protect the immovable fire hazards.

c. If the foregoing precautions cannot be met and any welding or cutting is unable to
be conducted safely, then hot work should not be performed.

d. Suitable fire extinguishing equipment shall be maintained in a state of readiness for
instant use and may consist of pails of water, buckets of sand, hoses or portable
fire extinguishers depending upon the nature and the quantity of combustible
material exposed.

2. Specific requirements of §1910.252 and, for elaboration, and delineation of the
responsibilities of welders and cutters, their supervisors, and those in management on
whose property the hot work is to be performed, NFPA Standard 51B.

Key Lessons from Hot Work Accidents (adapted from 2010 Chemical Safety Board):

1. Use alternatives: Whenever possible, avoid hot work and consider alternative methods.

2. Analyze the hazards: Prior to the initiation of hot work, perform a hazard assessment that
identifies the scope of the work, potential hazards, and methods of hazard control.

3. Monitor the atmosphere: Conduct effective gas monitoring in the work area using a
properly calibrated combustible gas detector prior to and during hot work activities, even
in areas where a flammable atmosphere is not anticipated.

4. Test the area: In work areas where flammable liquids and gases are stored or handled,
drain and/or purge all equipment and piping before hot work is conducted. When in the
vicinity of storage tanks and other containers, properly test and if necessary continuously
monitor all surrounding tanks or adjacent spaces (not just those being worked on) for the
presence of flammables and eliminate potential sources of flammables.

5. Use written permits: Ensure that qualified personnel familiar with the specific site hazards
review and authorize all hot work and issue permits specifically identifying the work to be

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conducted and the required precautions.

6. Train thoroughly. Train personnel on hot work policies/procedures, safety equipment, and
job specific hazards and controls in a language understood by the workforce. Workers
assigned to maintain the equipment and their supervisors should be suitably trained and
qualified in the safe operations of their equipment and the safe use of the process.

Supervise contractors: Safety supervision for outside contractors conducting hot work should be
provided by a competent person. Inform contractors about site-specific hazards including the presence
of flammable materials.

Additional Considerations:

1. First aid equipment must be available at all times.

2. Oxygen cylinders must be stored in an upright, secured position at least 20 feet from any
flammable gases or petroleum products.

3. In addition to other precautions, a fire watch should be established where advisable or
required when any of the following conditions exist:

a. Locations where other than a minor fire might develop.

b. Appreciable combustible material, in building construction or contents,
closer than 35 feet to the point of operation.

c. Appreciable combustibles are more than 35 feet away, but are easily
ignited by sparks.

d. Wall or floor openings within a 35-foot radius that expose combustible
material in adjacent areas including concealed spaces in walls or floors.

e. Combustible materials are adjacent to the opposite side of metal partitions,
walls, ceilings, or roofs and are likely to be ignited by conduction or
radiation.

4. Fire watch personnel should have fire extinguishing equipment readily available and be
trained in its use by a competent person. The fire watch will also be required to be able to:

a. Watch for fires in all exposed areas

b. Only attempt to extinguish fires that are obviously within the capacity of the
available equipment

c. Sound the alarm should they be unable to extinguish a fire or judge it unsafe to do

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d. Continue the fire watch for at least a half hour after completion of welding or
cutting operations.

5. Any hot work to be performed in confined spaces should conform to Permit-required
Confined Space procedures and the following requirements:

a. Adequate ventilation is a prerequisite to work in confined spaces.

b. When welding or cutting is being performed in any confined spaces, the gas
cylinders and welding machines will be kept outside of the space.

c. If entry is through a small opening, a method for quickly removing the
welder in case of emergency will be provided. Such lifelines will be attached
to the welder's body such that his or her body cannot be jammed in the exit
opening.

d. If any arc welding is to be suspended for a substantial period of time, such
as lunch or overnight:

1. All electrodes will be removed from the holders.

2. The holders will be moved such that accidental contact cannot
occur.

3. The machine will be disconnected from its power source.

e. When a gas welding or cutting torch is not going to be used for a substantial
amount of time, such as during lunch or overnight, the torch valves will be
closed and the fuel-gas and oxygen supply positively shut off at a point
outside of the confined area. The torch will be removed from the confined
area as well if practical.

f. Following the completion of welding operations, the welder will mark the
hot metal or provide some other form of warning sign to warn other
workers.

6. Welding, cutting, or burning of metals containing lead, zinc, cadmium, mercury, beryllium,
or other exotic metals, paints, coatings, or preservatives will require appropriate
ventilation or respiratory protection.

7. If the possibility exists during hot work for the creation of hazardous fumes, gases, or dust
according to the metals involved, then local exhaust or general ventilating systems will be
arranged to keep the amount of toxic fumes, gases, or dusts below the maximum
allowable concentrations as specified in §1910.1000.

Health and Safety Plan

Norfolk Southern Train derailment East Palestine, OH
Effective Date:

CTEH

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8. The operator of any hot work equipment should report any equipment defects or safety
hazards to his supervisor and discontinue use of the equipment until its safety has been
assured and, if needed, repaired by a qualified person.

9. Any welding or brazing materials used in hot work which might possibly generate
hazardous fumes, gases, or dusts due to the metals involved should be suitably labeled to
indicate the hazard, and appropriate measures for ventilation or respiratory protection
provided to ensure that no employee is exposed to higher than permissible levels of
hazardous fumes.

References

29 CFR §1910.252; 2009 NFPA 51B Standard for Fire Prevention During Welding, Cutting and Other Hot
Work (incorporated by reference by §1910.252(a)(1)); 2003 API 2201 Safe Hot Tapping Practices in the
Petroleum and Petrochemical Industries (incorporated by reference in §1910.252(d)(l)(vi)). For
additional information, see 2010 Chemical Safety Board - Seven Key Lessons to Prevent Worker Deaths
During Hot Work in and around Tanks; 2010 NFPA 326 Standard for the Safeguarding of Tanks and
Containers for Entry, Cleaning or Repair.

Revision History

Original Document: 11/21/2013

Revision 1: 1/31/2019 - removal of CSB Video as a training requirement, adjustment to definition of
hot work, and addition of Revision History

Health and Safety Plan

Norfolk Southern Train derailment East Palestine, OH
Effective Date:

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CTEH® Policy Review

Reviewing Official Responsibilities:

1. The Reviewer. The reviewer should use informal methods to recommend changes or corrections
whenever practicable. These methods, however, are not a substitute for a formal response when
requested by the initiating office. The reviewer is obligated to make a prompt response indicating
either:

a. Concurrence (approval);

b. Concurrence with comments (reservations);

c. Non-concurrence (disagreement) with attached comments; or

2. Concurrence by Reviewers. Concurrence by reviewers indicates that the material is:

a. Legal, correct, and complete.

Consistent with regulations, directives and policies, or is an approved change thereto and will be incorporated
into the directives for which they are responsible.

Health and Safety Plan

Norfolk Southern Train derailment East Palestine, OH
Effective Date:

CTEH

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CTEH

THE SCIENCE OF READY3"

Norfolk Southern Train derailment East Palestine, OH

East Palestine, OH

Cold Stress Management Plan

Version 1.0

Prepared By:

CTEH®, LLC
5120 Northshore Drive
North Little Rock, AR 72118
501-801-8500

February 4, 2023
CTEH PROJECT NUMBER #024579

Name/Organization

Signature

Date Signed

Prepared by:

Jason Davis/CTEFI

February 3, 2023

Reviewed by:

Micah Kendrick, CSP

February 3, 2023

Approved by:

Cold Stress Management Plan
East Palestine, Ohio Incident

Effective Date: February 3, 2023

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1.0 Work Environment and Weather Conditions

The American Conference of Industrial Hygienists has developed a wind chill chart that estimates the equivalent
wind chill temperature (in degrees Celsius) based on ambient temperature vs wind. Please use the chart below
to determine the wind chill for each work shift.

Table 1ACGIH TLV Wind Chill Chart

1 WIND CHILL CHART 1

-1

•7

Ambient Temperature j-C)
-12 -16 -23 -29

•34

-40

Wind

km/h

Velocity
mpfi

Equivalent Chill Temperature (~C)

Calm

•1

•7

-12 -16

-23

-29

-34

-40

•3

-9

-14 -21

-26

-32

-44

•2

•I

-16

-23 -30

-36

•50

-S7

-6

•13

•20

-28 36

-43

-50

-56

1 65

•8

-16

•23

-32 39

-47

« |

-63

•71

•9

•16

-26

W *42

-61

-59

•67

•76

•16

•18

•22

-36 -44

¦62

•70

•78

•11

-20

•29

-57 -46

-63

•72

¦81

•12

•21

•29

88 <47

•56

•73

-82

AflawwJ 'font: Pircsbuld LlmH
vjiues fUV™) snd BtoJocttai
txposure mdeces (BEO hoctef;

LJMb dMiger i less dan ana
hour expofiire
-------
2.1.1 Symptoms

Symptoms of hypothermia can vary depending on how long you have been exposed to the cold temperatures.
Symptoms include:

Shivering

• Blue skin

Fatigue

• Dilated pupils

Loss of coordination

• Slowed pulse and breathing

Confusion and disorientation

• Loss of consciousness

• No shivering
2.1.2 First Aid

Take the following steps to treat a worker with hypothermia:

• Alert the supervisor and request medical assistance.

• Move the victim into a warm room or shelter.

• Remove their wet clothing.

• Warm the center of their body first-chest, neck, head, and groin-using an electric blanket, if available;
or use skin-to-skin contact under loose, dry layers of blankets, clothing, towels, or sheets.

• Warm beverages may help increase the body temperature, but do not give alcoholic beverages. Do not
try to give beverages to an unconscious person.

• After their body temperature has increased, keep the victim dry and wrapped in a warm blanket,
including the head and neck.

• If victim has no pulse, begin cardiopulmonary resuscitation (CPR).

2.2 Cold Water Immersion

Cold water immersion creates a specific condition known as immersion hypothermia. It develops much more
quickly than standard hypothermia because water conducts heat away from the body 25 times faster than air.
Typically people in temperate climates don't consider themselves at risk from hypothermia in the water, but
hypothermia can occur in any water temperature below 70°F. Survival times can be lengthened by wearing
proper clothing (wool and synthetics and not cotton), using a personal flotation device (PFD, life vest, immersion
suit, dry suit), and having a means of both signaling rescuers (strobe lights, personal locator beacon, whistles,
flares, waterproof radio) and having a means of being retrieved from the water.

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East Palestine, Ohio Incident
Effective Date: February 3, 2023

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2.3 Frostbite

Frostbite is an injury to the body that is caused by freezing. Frostbite causes a loss of feeling and color in the
affected areas. It most often affects the nose, ears, cheeks, chin, fingers, or toes. Frostbite can permanently
damage body tissues, and severe cases can lead to amputation. In extremely cold temperatures, the risk of
frostbite is increased in workers with reduced blood circulation and among workers who are not dressed
properly.

2.3.1 Symptoms

Symptoms of frostbite include:

• Reduced blood flow to hands and feet (fingers or toes can freeze)

• Numbness

• Tingling or stinging

• Aching

• Bluish or pail, waxy skin

2.3.2 First Aid

Workers suffering from frostbite should:

• Get into a warm room as soon as possible.

• Unless absolutely necessary, do not walk on frostbitten feet or toes-this increases the damage.

• Immerse the affected area in warm-not hot-water (the temperature should be comfortable to the touch
for unaffected parts of the body).

• Warm the affected area using body heat; for example, the heat of an armpit can be used to warm
frostbitten fingers.

• Do not rub or massage the frostbitten area; doing so may cause more damage.

• Do not use a heating pad, heat lamp, or the heat of a stove, fireplace, or radiator for warming. Affected
areas are numb and can be easily burned.

2.4 Trench Foot

Trench foot, also known as immersion foot, is an injury of the feet resulting from prolonged exposure to wet and
cold conditions. Trench foot can occur at temperatures as high as 60 degrees F if the feet are constantly wet.
Injury occurs because wet feet lose heat 25-times faster than dry feet. Therefore, to prevent heat loss, the body

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Effective Date: February 3, 2023

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constricts blood vessels to shut down circulation in the feet. Skin tissue begins to die because of lack of oxygen
and nutrients and due to the buildup of toxic products.

2.4.1 Symptoms

Symptoms of trench foot include

• Reddening of the skin

• Numbness

• Leg cramps

• Swelling

• Tingling pain

2.4.2 First Aid

Workers suffering from trench foot should:

• Remove shoes/boots and wet socks.

• Dry their feet.

• Avoid walking on feet, as this may cause tissue damage.

2.5 Chilblains

Chilblains are caused by the repeated exposure of skin to temperatures just above freezing to as high as 60
degrees F. The cold exposure causes damage to the capillary beds (groups of small blood vessels) in the skin.
This damage is permanent and the redness and itching will return with additional exposure. The redness and
itching typically occurs on cheeks, ears, fingers, and toes.

2.5.1 Symptoms

Symptoms of chilblains include:

• Redness

• Itching

• Possible blistering

• Inflammation

• Possible ulceration in severe cases

• Blisters or ulcers

• Bleeding under the skin

• Gangrene (the foot may turn dark purple,
blue, or gray)

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2.5.2 First Aid

Workers suffering from chilblains should:

• Avoid scratching

• Slowly warm the skin

• Use corticosteroid creams to relieve itching and swelling

• Keep blisters and ulcers clean and covered

3.0 Controls for Protection Against Cold Stress & Hypothermia

This section outlines reasonable control measures designed to prevent cold stress and hypothermia. This section
only includes recommendations; therefore, field judgment may be required for circumstances that do not clearly
meet the constraints provided herein. The control measures stated below have been derived from the ACGIH
TLV Manual.

• For exposed skin, continuous exposure should not be permitted when the wind speed and the ambient
temperature produce a resultant equivalent wind chill temperature of -32 degrees C.

• For workers who have become wet or immersed in water at temperatures of 2 degrees C or less,
treatment for hypothermia must be administered. This includes a complete exchange of wet clothes for
dry clothes. Workers should be kept in a warm, dry area during their hypothermia treatment.

3.1 Prevention of Cold Stress to Bare Hands

• For fine work in temperatures below 16 degrees C, auxiliary heating units such as warming fans, radiant
heaters or contact warm plates should be used.

• For work in temperatures below 16 degrees C for sedentary, 4 degrees C for light, and -7 degrees C for
moderate work, gloves must be worn.

3.2 Prevention of Frostbite

• When work is being performed on surfaces that are below -7 degrees C, contact with bare skin should
be prevented. Gloves are required.

• If the air temperature is -17.5 degrees C or below, hands should be protected with mittens (gloves are
not sufficient).

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3.3 Prevention of Total Body Cold Stress

• Based on the forecasted temperatures and the likely presence of above average wind speeds, workers
should use wind-blocking garments, such as Gore-Tex®. Wind blocks may be provided as well.

• In the presence of high humidity, snow, rain, ocean-spray, or mist, workers should be equipped with a
waterproof outer layer. Workers should not be permitted to work in wet environments with non-
waterproof outer garments.

• Workers should not work at a work rate, nor wear such insulation that causes sweating. Garments
should be equipped with ventilation such that a vigorous work rate does not cause sweat to dampen
the layers of clothing closest to their body.

• Workers handling evaporative liquids (such as gasoline, alcohol, or solvent-based cleaning fluids) should
take special precautions not to soak their gloves or clothing. If soaking occurs, the impacted gloves or
garments must be replaced immediately.

4.0 Work-Warming Regimen

This section includes recommendations for providing a warm-up schedule for workers exposed to cold
environments. In each work area, shelter should be provided in a manner that provides easy access and is
reasonably close to the area(s) where work is to be performed. Controlled indoor environments are preferred;
however, if a controlled indoor environment is not available, special heating shelters should be provided. The
following items should be considered:

• A buddy system should be used so that workers can monitor each other's signs and symptoms of
imposing cold stress.

• The work rate should not be so high that workers begin to sweat. If heavy work must be done, rest
periods should be considered to avoid excessive sweating and provide workers opportunities to change
from dampened clothes to dry clothes.

The ACGIH TLV manual provides a work-warming schedule designed to reduce worker exposure to conditions
conducive to cold stress or hypothermia. Special considerations should be given to establishing a work-warming
schedule the meets or exceeds the conditions included in Table 2 below.

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Table 2 ACGIH TLV Work/Warm-Up Schedule for a 4-Hour Shift

Air temperature -
Sunny sky

No noticeable
wind

8 km/h wind

16 km/h wind

25 km/h wind

30 km/h wind

°C °F
(approx.) (approx.)

Max.
work
period

No. of
breaks

Max.
work
period

No. of
breaks

Max.
work
period

No. of
breaks

Max.
work
period

No. of
breaks

Max.
work
period

No. of
breaks

-26° to -28° -15° to-19°
-29° to-31° -20° to-24°
-32° to -34° -25° to -29°
-35° to -37° -30° to -34°
-38° to -39° -35° to -39°
-40° to -42° -40° to -44°
-43° & -45° &
below below

(Norm, b
(Norm, b
75 min
55 min
40 min
30 min
Non-em
work sho

reaks) 1
reaks) 1

ergency
uld cease

(Norm, b
75 min
55 min
40 min
30 min
Non-em
work sho

reaks) 1

ergency
uld cease

75 min
55 min
40 min
30 min
Non-em
work sho

ergency
uld cease

55 min
40 min
30 min
Non-em
work sho

ergency
jld cease

40 min
30 min
Non-em
work sho*

ergency
.ild cease

1. Schedule applies to any 4-hour work period with moderate to heavy work activity, with warm-up periods of 10 minutes in a warm location and
with an extended break (e.g., lunch) at the end of the 4-hour work period in a warm location. For light-to-moderate work (limited physical
movement), apply the schedule one step lower in the table. For example, at -35° C (-30° F) with no noticeable wind (Step 4), a worker in a job with
little physical movement should have a maximum work period of 40 minutes with 4 breaks in a 4-hour period (Step 5).

2. The following is suggested as a guide for estimating wind velocity if accurate information is not available: 8 km/h - light flag moves; 16 km/h - light
flag fully extended; 25 km/h - raises newspaper sheet; 30 km/h - blowing and drifting snow.

3. If only the wind chill cooling rate is available, a rough rule of thumb for applying it rather than the temperature and wind velocity factor given
above would be: (1) special warmup breaks should be initiated at a wind chill cooling rate of about 1750 W/m2; (2) all non-emergency work should
have ceased at or before a wind chill of 2250 W/m2. In general, the warm-up schedule provided above slightly under-compensates for the wind at
the warmer temperatures, assuming acclimatization and clothing appropriate for winter work. On the other hand, the chart over-compensates for
the actual temperatures in the colder ranges because windy conditions rarely prevail at extremely low temperatures.

4. TLVs apply only to workers in dry clothing.

5. Refer to the "Cold Stress" section of the current Threshold Limit Values and Biological Exposure Indices publication for further information

Cold Stress Management Plan
East Palestine, Ohio Incident
Effective Date: February 3, 2023

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Job Hazard Analysis (JHA) Form

Description of Task/Work Activity:

Air (Atmospheric) Monitoring

Required PPE for Specific Task:

^Hard Hat

^Chemical-Resistant Boots/Boot Covers

^Safety Glasses (Clear/Indoor)

~Tyvek/MicroMAX Coveralls

^Safety Glasses (Tinted/Outdoor)

^Chemical Protective Clothing (CPC)

^Steel/Composite-Toe Boots

~CPC Type:

^Hi-Visibility Vest/Clothing

^Chemical-Resistant Gloves:

^Gloves (Leather/General Use/Cut-Resistant)

~dove Type:

~ Hearing Protection (Ear Plugs/Earmuffs/Both)

^Air-Purifying Respirator

~ FR Coveralls/Clothing

~Cartridges:

^Fall Protection (Full Body Harness & Lanyard/Lifeline)

^Supplied Air Respirator (Airline)

~ PFD (Personal Flotation Device) - USCG-Rated

ISISCBA

~ Face Shield

~Other:

Page 1

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Sequence of Task Steps:

Potential Hazards:

Controls/Preventative Measures:

Don necessary PPE

Exposure to site

Wear appropriate PPE (i.e., safety glasses,

Contaminants

nitrile

Collect PID/LEL meter

gloves, steel-toed shoes, highly visible

Readings

Slips, trips, and falls

clothing, and level D attire).

Ladder safety

• Review and understand action levels

noted in the HASP.

Errant Reading

• Monitor (evaluate) breathing zone of

workers with PID.

• Monitor (evaluate) any enclosure with

a PID.

• If action levels are met, either Level C

PPE must be donned or the space

must be ventilated.

• If IDLH action levels are met, SCBA

must be donned and PPE must be

reevaluated

Maintain all equipment and tools in

designated areas

and out of pathways.

• Identify and protect all air lines, water

lines, electrical

cords, and cables.

Use the proper type of ladder (i.e., step

ladder expanded

or straight ladder with a 4:1 pitch).

Calibrate/Bump Test at appropriate time

intervals (daily calibration, daily bump test)

Page 2

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Job Hazard Analysis (JHA) Form

Description of Task/Work Activity:

Air Knifing

Required PPE for Specific Task:

^ Hard Hat

~ Chemical-Resistant Boots/Boot Covers

^ Safety Glasses (Clear/Indoor)

^ Tyvek/MicroMAX Coveralls

^ Safety Glasses (Tinted/Outdoor)

~ Chemical Protective Clothing (CPC)

^ Steel/Composite-Toe Boots

~ CPC Type:

~ Hi-Visibility Vest/Clothing

~ Chemical-Resistant Gloves:

^ Gloves (Leather/General Use/Cut-Resistant)

EH Glove Type:

^ Hearing Protection (Ear Plugs/Earmuffs/Both)

~ Air-Purifying Respirator

~ FR Coveralls/Clothing

~ Cartridges:

~ Fall Protection (Full Body Harness & Lanyard/Lifeline)

~ Supplied Air Respirator (Airline)

~ PFD (Personal Flotation Device) - USCG-Rated

~ SCBA

^ Face Shield

~ Other:

Page 1

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Sequence of Task Steps:

Potential Hazards:

Controls/Preventative Measures:

Air Knifing

Staging Equipment (Air Compressor)

Trip Hazards (Air Hoses)

Failure of Air Hose Connections - Personnel
stuck-by "whipping" hoses

Flying Debris
Noise Above 85 dBA
Dermal Exposure/Contact

Staging Equipment - Use wheel chocks on
parked equipment to prevent unexpected
rolling or movement when disconnected from
tow vehicle.

Trip Hazards - Implement good hose
management (keeping runs together and out
of walking paths, to the extent possible). Use
caution tape and/or safety cones to mark
areas where the hose could present a trip
hazard.

Failure of Air Hose Connections - All air line
connections must be secured using safety
pins/clips and "whip check" cables or straps.

Flying Debris - Unless wearing a full-face
respirator, an impact-resistant face shield
(with safety glasses) shall be worn by the air
knife operator and anyone else in the
immediate work area to prevent soil and
debris from striking the employee's face
and/or entering eyes.

Noise Above 85 dBA - Hearing Protection
shall be worn by the knife operator and
anyone else in the work area.

Dermal Exposure/Contact - Knife operator
and anyone else in the immediate work area
shall wear TyVek Covealls.

Page 2

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Job Hazard Analysis (JHA) Form

Description of Task/Work Activity:

Boom Deployment from Shoreline

Required PPE for Specific Task:

^ Hard Hat

~ Chemical-Resistant Boots/Boot Covers

^ Safety Glasses (Clear/Indoor)

~ Tyvek/MicroMAX Coveralls

^ Safety Glasses (Tinted/Outdoor)

~ Chemical Protective Clothing (CPC)

^ Steel/Composite-Toe Boots

~ CPC Type:

^ Hi-Visibility Vest/Clothing

~ Chemical-Resistant Gloves:

^ Gloves (Leather/General Use/Cut-Resistant)

EH Glove Type:

~ Hearing Protection (Ear Plugs/Earmuffs/Both)

~ Air-Purifying Respirator

~ FR Coveralls/Clothing

~ Cartridges:

~ Fall Protection (Full Body Harness & Lanyard/Lifeline)

~ Supplied Air Respirator (Airline)

^ PFD (Personal Flotation Device) - USCG-Rated

~ SCBA

~ Face Shield

Kl Other: Over boots that are hiah enouah for water conditions and or waders if needed.

Page 1

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Sequence of Task Steps:

Potential Hazards:

Controls/Preventative Measures:

1. Review "General Site Activities" JHA

2. Review "Boat operations" JHA if applicable

3. Review project HASP and Tailgate

4. Review Working on or Near Active Waterways
Procedure

5. Working Near the Waterway

6. Boom Deployment

7. Boom Securement

8. Boom Recovery

Falling into waterway
Lifting injuries
Slips / Falls
Wildlife

No employees will be permitted to work near a waterway
for any reason until the waterway has been checked for
depth, width and flow, and these items must be identified
prior to proceeding.

The flow or current of the waterway must be investigated

prior to work being initiated.

-The crew can only work near a waterway, which has

standing or calm water, if water is visually turbid boom

should be placed in an alternate location.

-In addition to determining if water is standing or calm,

the depth of the waterway must be investigated prior to

work being initiated.

-The employee must be equipped with a life vest. The life
vest must be rated for the employee's weight.

-The field crew must be comprised of at least two
individuals. One will secure the boom and the attendee
will watch for the safety of the employee.

- First Aid: The attendee must be trained in both first aid
and CPR and a first aid kit must be made readily
available.

At least two individuals or employees are required, and
both shall be equipped with a life vest, and other
appropriate Personal Protective Equipment dictated by the
atmosphere and other hazards.

-If one individual must lean outside of the boat or enter
the water from the shoreline to perform a task, a lifeline
must be attached to the individual. If the individual falls
into the water, the lifeline will permit the individual from
floating away from the immediate work area and permit a
less hazardous rescue.

Note: If the passenger of the boat should fall into the
waterway, the boat operator should never attempt a
rescue by leaving the boat.

Unless the boat is anchored, the operator of the boat
shall always remain at the steering controls.

-The boat operator must possess sufficient experience for
the boat operation and trained in the following:

• Know the hazards that may be faced during the
operation.

• Proper use of all equipment.

• Recognizes any warning signs of a dangerous or
prohibited situation.

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Page 3

• Safety requirements for boat launching and
exiting from the waterway.

• Knowledgeable in how to summon rescue and
other emergency services as soon as the operator
determines that the boat occupants may need assistance
to escape from the waterway hazards.

-Conditions that exist that prevent boating operations
consist of the following:

• Small craft weather advisory

• Ice packs are observed on the waterway

• Severe weather warning that includes but not
limited to thunderstorms and winter weather

When recovering the boom proper lifting techniques
should be used to prevent injury

• Be aware of slick surfaces and sharp edges when
handling boom.

-------
Job Hazard Analysis (JHA) Form

Description of Task/Work Activity:

Coverina SdoMs Piles (Manually handlina and carrvina sandbaas on uneven terrain") If Dossible. the use of personnel on uneven around or
terrain should be avoided. EauiDment should be used in Dlace of Dersonnel manuallv handlina anv material fsandbaas, oolv

sheetina, etc.)

Required PPE for Specific Task:

^ Hard Hat

~ Chemical-Resistant Boots/Boot Covers

^ Safety Glasses (Clear/Indoor)

~ Tyvek/MicroMAX Coveralls

^ Safety Glasses (Tinted/Outdoor)

~ Chemical Protective Clothing (CPC)

^ Steel/Composite-Toe Boots

~ CPC Type:

^ Hi-Visibility Vest/Clothing

^ Chemical-Resistant Gloves:

^ Gloves (Leather/General Use/Cut-Resistant)

^ Glove Type: Inner Nitrile/Outer PVC

~ Hearing Protection (Ear Plugs/Earmuffs/Both)

~ Air-Purifying Respirator

~ FR Coveralls/Clothing

~ Cartridges:

^ Fall Protection (Full Body Harness & Lanyard/Lifeline)

~ Supplied Air Respirator (Airline)

~ PFD (Personal Flotation Device) - USCG-Rated

~ SCBA

~ Face Shield

~ Other:

Page 1

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Sequence of Task Steps:

Potential Hazards:

Controls/Preventative Measures:

Preparing to move materials.
Moving materials.

Moving materials by hand
Moving materials with machinery.

Muscle strains, pulls and repetitive motion
injuries.

Exposure to contaminated materials

Injuries resulting from lack of
communication, or miscommunication.

Foot or leg injuries.

Finger or hand injuries.

Vehicle or machinery damage, operator
injury, or injury to others working around
machinery.

-Each employee should be provided training
on the safe and proper use of the most
important, primary tool—their bodies
Proper techniques of stretching, lifting,
bending, moving, rolling rocks, securing good
footing, the importance of good nutrition and
hydration, etc., should be addressed.

-Each employee will be given time on the job
to properly stretch and warm-up before and
during physical activity for a period of time
deemed appropriate by the crew

leader, or on-site supervisor.

-Employees will be encouraged to switch
hands often and vary the types of activities
performed to limit exposure to repetitive
motion injuries.

-The appropriate number of workers should
be used to move materials. This decision
may vary between individuals.

Review SDS for possible chemical
contaminants in soil and on equipment.
Don the proper PPE (Chemical Protective
Gloves)

Perform Atmospheric Monitoring and don
respirator when necessary (review
atmospheric monitoring JHA)

-Crew leaders will conduct tailgate safety
talks to provide orientation, discuss project,
safety concerns, assign work, etc.

-Good communication between crewmembers
should reinforce individual awareness of real
and potential hazards.

Page 2

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Page 3

-Communication methods should be
discussed and agreed upon prior to moving
materials.

-The plan of attack should be discussed
before attempting to move materials.

-Instructions should come from one person
when working in teams of two or more.

-Workers need to maintain constant
awareness of their feet and foot placement
in relation to objects being moved and avoid
placing them under materials or on material
that may slide, give way, crumble, etc.

-It is recommended that workers use
lifting techniques to minimize the potential
for injuries to hands.

-If hands are absolutely necessary use

extreme caution and 100% communication
with other workers should follow.

-Refer to JHA—Equipment Use and
Maintenance.

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Job Hazard Analysis (JHA) Form

Description of Task/Work Activity:

Handling Drums (55-Gal, Hazardous Waste, Drum Dolly, By Hand)

Required PPE for Specific Task:

^ Hard Hat

~ Chemical-Resistant Boots/Boot Covers

^ Safety Glasses (Clear/Indoor)

~ Tyvek/MicroMAX Coveralls

^ Safety Glasses (Tinted/Outdoor)

~ Chemical Protective Clothing (CPC)

^ Steel/Composite-Toe Boots

~ CPC Type:

^ Hi-Visibility Vest/Clothing

~ Chemical-Resistant Gloves:

^ Gloves (Leather/General Use/Cut-Resistant)

EH Glove Type:

~ Hearing Protection (Ear Plugs/Earmuffs/Both)

~ Air-Purifying Respirator

~ FR Coveralls/Clothing

~ Cartridges:

~ Fall Protection (Full Body Harness & Lanyard/Lifeline)

~ Supplied Air Respirator (Airline)

~ PFD (Personal Flotation Device) - USCG-Rated

~ SCBA

~ Face Shield

~ Other:

Page 1

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Sequence of Task Steps:

Potential Hazards:

Controls/Preventative Measures:

Examine the rim of the drum, lid, and sealing
ring to be sure they will sit properly.

Place the lid on the drum, sit the ring, and
tighten the bold using a wrench

Attach the ring clamp for hard to sit rings, and
torque into place by turning the handle

Secure and tighten the nut on the ring bold
using the pneumatic hammer drill

Tilting it toward you about 30° after ensuring
that the drum is closed

Rolling the drum on the edge of the base

Releasing the Drum

Drum Dolly Usage:

Pushing the dolly up to the drum and position
the dolly's feet at the drum's base

Tipping the dolly forward and engaging dolly-
drum-lock

Pulling the dolly and the drum back until the
dolly rests on the wheels

Pinch hand while handling parts

Cuts or abrasions from burrs on metal part

Abrasion or impact from tightening the bolt

Impact and pinch while positioning the ring
clamp

Muscle strain from tightening the clamp

Muscle strain from tightening the ring bolt

Back or muscle strain

Abrasions from sharp edges or burs

Back or muscle strain

Foot injury

Pinch Points

Drum Dolly Usage:

Tripping or falling

Hand and Finger Injuries

Back Strain

Wear leather or similar gloves

Use care (don't grab) while examining parts

Wear leather or similar gloves

Keep your hands open (don't grab) while
examining parts

Position your body so the wrench can be
easily turned

Hold the clamp so the components don't slip
over the threaded shaft

Position your body so the clamp tightening
handle can be easily turned.

Seat the drill properly on the nut. Position
your body to stabilize the position of the drill
prior to pulling the trigger.

Clear path before moving the drum

Do not wear loose clothing

Test weight of the drum before tilting, use
team lift if possible

Brace feet apart, one against the drum's base
and the other behind you

Use your weight, rather than your muscles,
to tilt the drum. Do not jerk the drum

Maintain control of the drum
Roll the drum slowly

Do not cross legs. Take side steps

Page 2

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Page 3

Wear safety boots with toe protection

Keep feet clear of drum

Do not allow hand to be pinched between
other drum or objects

Maintain control of drum

Release the drum slowly

Wear safety boots with toe protection

Keep feet clear of drum

Drum Dolly Usage:

Ensure that the drum is fully closed

Clear path in front of the moving dolly

Be aware of the other workers in the area

Make sure the lock is properly engaged

Hold the dolly in position with left hand;
engage the lock with right hand (Reverse if
left-handed)

Use a single, smooth pulling motion
Get assistance if available

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Job Hazard Analysis (JHA) Form

Description of Task/Work Activity:

Drum Vac Operations (Electrical & Pneumatic)

Required PPE for Specific Task:

^Hard Hat

~Chemical-Resistant Boots/Boot Covers

^Safety Glasses (Clear/Indoor)

~Tyvek/MicroMAX Coveralls

^Safety Glasses (Tinted/Outdoor)

~Chemical Protective Clothing (CPC)

^Steel/Composite-Toe Boots

~CPC Type:

^Hi-Visibility Vest/Clothing

~Chemical-Resistant Gloves:

^Gloves (Leather/General Use/Cut-Resistant)

~dove Type:

~ Hearing Protection (Ear Plugs/Earmuffs/Both)

~Air-Purifying Respirator

~ FR Coveralls/Clothing

~Cartridges:

^Fall Protection (Full Body Harness & Lanyard/Lifeline)

~Supplied Air Respirator (Airline)

~ PFD (Personal Flotation Device) - USCG-Rated

~SCBA

~ Face Shield

~Other:

Page 1

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Sequence of Task Steps:

Potential Hazards:

Controls/Preventative Measures:

General Use (Electrical)

Eye Injury

Goggles (for handling exposed

Ergonomic Hazards/Strains

chemicals)

General Use (Pneumatic)

Foot Injury

Situational awareness, Wear

Electric Shock/Explosion

proper PPE

Static Electricity

Use two people to move/lift heavy drums.

Eye Injury

l\l ni co

Read and understand Safety Data

IMUIbC

Sheet for chemical being handled.

Chemical Incompatibility

Know where the nearest emergency

Pressure-related hazards

eye wash/shower is and ensure a clear

(Pneumatic)

path.

Ground/Bond prior to use and use conductivity

meter to check resistance (< 10 Ohms)

Plan movement route to avoid hazards and

minimize exposure to chemicals.

Use mechanical means to handle

drums if available.

Secure drums when in transit to avoid tipping and

spilling contents. Use proper body mechanics

when handling heavy/awkward loads.

Only move drums when properly closed

(Unless empty and purged).

Push drums versus pulling them on a dolly to

prevent them from falling on

worker in case of a fall.

Operate all equipment in strict

accordance with Manufacturer's

instructions.

Do not use electrical (not intrinsically safe)

drum vacuums in an explosive environment

where any LELs are present.

Page 2

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Page 3

Conduct atmospheric monitoring prior to use.

Only authorized users can operate
equipment.

Operate equipment in strict accordance
with Manufacturer's instructions.

Report any observed defect or safety hazard to
your supervisor immediately. Where any object
handled would possibly cause injury to feet if
dropped, safety shoes will be worn.

Where any object handled could
possibly cause cuts, punctures or
abrasions to hands, appropriate gloves
will be worn. (Exception: where rotating
machinery presents a greater hazard of
entangling gloves, they are optional with
written justification).

Keep hands, hair and loose clothing
clear of all moving parts.

Ensure that the proper drum material
(poly/steel) is being used for the
substance/chemical to be vacuumed.

Ensure that the proper hoses are being
used for the substance/chemical to be
vacuumed

Turn off all compressed air connections
to the compressed air source at the
nearest valve.

Ensure whipchecks are in place on all
quick-connect connections.

Disconnect compressed air connections
only after the compressed air supply
has been turned off and the air supply
hose has been vented by opening the
valve on the vacuum head

Always ground/bond a drum vac,
regardless of power source
(Electrical/Pneumatic)

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Page 4

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Job Hazard Analysis (JHA) Form

Description of Task/Work Activity:

Equipment Refueling

Required PPE for Specific Task:

^ Hard Hat

~ Chemical-Resistant Boots/Boot Covers

^ Safety Glasses (Clear/Indoor)

~ Tyvek/MicroMAX Coveralls

^ Safety Glasses (Tinted/Outdoor)

~ Chemical Protective Clothing (CPC)

^ Steel/Composite-Toe Boots

~ CPC Type:

^ Hi-Visibility Vest/Clothing

~ Chemical-Resistant Gloves:

^ Gloves (Leather/General Use/Cut-Resistant)

EH Glove Type:

~ Hearing Protection (Ear Plugs/Earmuffs/Both)

~ Air-Purifying Respirator

~ FR Coveralls/Clothing

~ Cartridges:

~ Fall Protection (Full Body Harness & Lanyard/Lifeline)

~ Supplied Air Respirator (Airline)

~ PFD (Personal Flotation Device) - USCG-Rated

~ SCBA

~ Face Shield

~ Other:

Page 1

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Sequence of Task Steps:

Potential Hazards:

Controls/Preventative Measures:

Turn off Vehicle and/or Equipment.

Potential for fires or explosion resulting in
personal injury, property damage and/or
death. Fuels spills may also create slip, trip
& Fall Hazards as well as environmental
clean-up responsibilities and potential fines.

WHEN AT THE PUMPS - Refueling Equipment
Remove nozzle from pump and insert into
equipment tank.

Potential for fires or explosion resulting in
personal injury,

property damage and/or death

WHEN AT THE PUMPS -Filling fuel containers -
Remove nozzle from

pump and insert into approved container.

Potential for fires or explosion resulting in
personal injury,

property damage and/or death.

1. Turn off engine(s).

2. Do not smoke while refueling equipment/
filling fuel containers.

3. Do not use your cell phone - turn it off
while refueling or filling containers.

4. When exiting the vehicle, avoid spilled
fuels, where possible, that may create a
slippery surface. Note: Some equipment
requires a "cool down" period before
refueling. Ensure these instructions are
understood for all equipment being used,
prior to refueling.

1. Do not re-enter vehicle or climb on
equipment after pumping has begun - This
can create static electricity buildup that has
been proven to cause fires and explosions.

2. Do not leave a fueling piece of equipment
unattended for any reason.

3. Do not "top-off" tanks - This can lead to
overflow and excessive vapor release.

4. Ensure the proper fuel type is chosen, i.e.
Gas or diesel.

1. Ensure that the container is an approved
container, meeting OSHA or DOT
requirements. Note: plastic gas cans or
containers are not allowed for storing any
fuels unless the container specifically states
that it meets OSHA or DOT requirements.

2. Do not fill containers while in the back of
truck beds with plastic liners or inside
vehicles or trunks with carpeted floors.

3. After placing the container on the
ground, release vapor pressure slowly. Do
this prior to removing nozzle from pump.

Page 2

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WHILE IN "FIELD" LOCATIONS - Refueling
Equipment/Filling

Containers.

Static electricity combined with sudden vapor
release may ignite

vapors, resulting in fire and/or explosion,
which may cause

injury, property damage and/or death.

4. One all vapor has been released from the
container, remove nozzle from pump and
insert nozzle into container for fueling.

5. Fill the container slowly to avoid
excessive vapor and static electricity buildup.

6. Do not overfill - Fill fuel containers to
approximately 95% capacity to allow for
vapor expansion.

7. Place cap on tightly.

8. Any gasoline that spills on the container
must be allowed to evaporate or be cleaned
off prior to placing the container inside the
vehicle, in the bed of the vehicle or on the
trailer.

9. Secure containers against tipping and
sliding and out of direct sunlight exposure or
excessive heat from the trunk of a car.

Ensure the proper fuel type is chosen, i.e.
Gas or diesel.

1. Only use approved Safety Cans, meeting
OSHA or DOT requirements for refueling
equipment. Ensure that gas cans have not
been left in direct sunlight.

2. Ensure that equipment has had plenty of
time to cool down before refueling. Some
equipment requires a "cool down" period
before refueling. Ensure these instructions
are understood for all equipment being used,
prior to refueling. A Minimum of lOminutes is
recommended unless otherwise specified by
the manufacturer.

3. Slowly release spring loaded handle to
release gasoline vapors. Complete this step
away from equipment and other potential
ignition sources.

4. Where necessary, insert funnel into tank
to avoid spilling fuel on equipment.

5. Once positioned, again release spring-
loaded handle to allow vapors to escape prior

Page 3

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Potential for mild to severe burns, oth
injuries and/or death.

Page 4

to touching any metal surface on the
equipment that is being refueled.

6. Fill the equipment slowly to avoid
excessive vapor and static electricity buildup.
This will also decrease splattering and
spilling.

7. Do not overfill - Fill fuel containers to
approximately 95% capacity to allow for
vapor expansion.

8. Place cap on tightly.

9. Any gasoline that spills on the equipment
must be allowed to evaporate or be cleaned
off prior to engine start-up.

10. Where possible, store fuel container in a
location away from excessive heat and/or
direct sunlight.

1. Move away from the hazard immediately.
Warn others as you swiftly and safely seek a
safer location.

2. If possible, press the emergency cut-off
switch and then call 911. In field locations,
call 911immediately.

3. At the pumps - Use portable extinguishers
only after the cutoff switch has been
activated and only if the fire is away from the
vehicle. Do not approach a burning vehicle
or equipment! In field locations - Use
portable extinguishers only when the fire
does not appear to be coming from the tank
itself, such as may be the case, where fuel
may have leaked onto the engine and ignited.
Do not approach an engulfed piece of
equipment!

4. Remember the "STOP, DROP and ROLL"
technique should you or someone else catch
on fire. Immediately try to find a water
source and/or another non-flammable and
non-hazardous liquid that could also be used
to help extinguish the fire.

-------
Job Hazard Analysis (JHA) Form

Description of Task/Work Activity:

Confined Space Entry - Cleaning Frac Tank w/ 9" of Sediment. The frac tank has 9 inches (~1800 gals) of sediment in it from dewatering
operations for this site. We will be using a liquid-vac truck to remove the sediment from the tank. We will dump the sediment on a stabilization
pad onsite and solidify it for offsite disposal. We then will pressure wash the inside of the tank and vac out the wash water. The wash water will
be blown off into another tank we have onsite.

*NOTE: TASK/ATMOSPHERE/HAZARDS WITHIN THE SPACE MAY DICTATE A HIGHER LEVEL OF PPE** If, as we work with the sediment, LELs or other
Atmospheric Hazards arise, we will exit the space and perform ventilation or other mitigation to prevent hazards associated with atmospheric hazards.

Required PPE for Specific Task:

^Hard Hat

^Chemical-Resistant Boots/Boot Covers

^Safety Glasses (Clear/Indoor)

~Tyvek/MicroMAX Coveralls

^Safety Glasses (Tinted/Outdoor)

^Chemical Protective Clothing (CPC)

^Steel/Composite-Toe Boots

IEICPC Type: TyChem 4000

^Hi-Visibility Vest/Clothing

^Chemical-Resistant Gloves:

^Gloves (Leather/General Use/Cut-Resistant)

^Glove Type: Inner Nitrile/Outer Nitrile

^Hearing Protection (Ear Plugs/Earmuffs/Both) Double Hearing Protection
above 95dB

^Air-Purifying Respirator

~ FR Coveralls/Clothing

^Cartridges: Organic Vapor Cartridges (Defender Combo Cartridges)

^Fall Protection (Full Body Harness & Lanyard/Lifeline)

~Supplied Air Respirator (Airline)

~ PFD (Personal Flotation Device) - USCG-Rated

~SCBA

^Face Shield

~Other:

Page 1

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Sequence of Task Steps:

Potential Hazards:

Controls/Preventative Measures:

Entry into a Confined Space

Vac Truck Operation (removal of sediment)

Pressure Wash tank and Remove Rinsate

Chemical Hazards (i.e. Inhalation, Ingestion,
Dermal Contact, etc.)

Actual or Potential

Hazardous Atmosphere (i.e.: oxygen
deficiency, flammable, explosive, toxic)

Physical Hazards (i.e.: electrical, mechanical,
pressure, moving parts, engulfment, internal
configuration, temperature extremes,
slips/trips/falls, low clearances, poor lighting,
noise)

Entrant unable to exit the space under
their own power (Confined Space Rescue)

Vacuum Truck Hazards

Pressure Washer Hazards

Chemical Hazards (i.e. Inhalation, Ingestion,
Dermal Contact, etc.) ¦ Actual or Potential
Hazardous Atmosphere (i.e.: oxygen deficiency,
flammable, explosive, toxic) Physical Hazards
(i.e.: electrical, mechanical, pressure, moving
parts, engulfment, internal configuration,
temperature extremes, slips/trips/falls, low
clearances, poor lighting, noise) Entrant unable to
exit the space under their own power (Confined
Space Rescue). HEPACO treats all Confined Spaces
as Permit- Required. The Entry Supervisor must
review and approve the entry documentation (i.e.:
entry permit, plans to isolate the space, purging
procedures, monitoring equipment, equipment
calibration records, communications methods,
training records, coordination procedures, and
authorizations) and concur on their adequacy.
Ensure Confined Space warning signs are
posted where entry is possible.

Chemical Hazards/Hazardous Atmosphere:

Analyze and eliminate through continuous forced
ventilation, all atmospheric hazards and confirmed
through continuous air monitoring as acceptable.
Calibrate and bump test
atmospheric monitoring equipment before each
use. Review SDS for additional information. No
Entry shall be made in oxygen enriched or
flammable atmospheres (>10% LEL). Supplied Air
Respirators shall be worn in oxygen
deficient atmospheres (<19.5% 02), toxic
atmospheres (> IDLH or MUC for vapor
cartridges), or as directed by the SDS for that
chemical. Review Analytical Document Provided by
ROUX

Physical Hazards: Analyze and eliminate or control
all physical hazards (e.g. Energy Isolation).

Confined Space Rescue: For all permit entries into
a Confined Space, HEPACO shall provide for stand-
by emergency rescue capabilities and personnel as
required by OSHA.

Review Vacuum Truck JHA & Pressure Washer JHA
(SEPARATE)

Page 2

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Page 3

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Job Hazard Analysis (JHA) Form

Description of Task/Work Activity:

General Site Work Activities

Required PPE for Specific Task:

^ Hard Hat

~ Chemical-Resistant Boots/Boot Covers

^ Safety Glasses (Clear/Indoor)

~ Tyvek/MicroMAX Coveralls

^ Safety Glasses (Tinted/Outdoor)

~ Chemical Protective Clothing (CPC)

^ Steel/Composite-Toe Boots

~ CPC Type:

^ Hi-Visibility Vest/Clothing

~ Chemical-Resistant Gloves:

^ Gloves (Leather/General Use/Cut-Resistant)

EH Glove Type:

^ Hearing Protection (Ear Plugs/Earmuffs/Both)

~ Air-Purifying Respirator

~ FR Coveralls/Clothing

~ Cartridges:

~ Fall Protection (Full Body Harness & Lanyard/Lifeline)

~ Supplied Air Respirator (Airline)

~ PFD (Personal Flotation Device) - USCG-Rated

~ SCBA

~ Face Shield

~ Other:

Page 1

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Sequence of Task Steps:

Potential Hazards:

Controls/Preventative Measures:

General Site Work Activities

Slips/T rips/Falls

Biological Hazards (i.e. poison ivy, ticks,
bees, mosquitoes)

Heat Stress

Noise

Severe Weather Conditions

- Rain

- Lightning

- Tornado

Pinch Points/Cuts/Abrasions (Hands)
Manual Lifting/Handling
Vehicle Traffic

Slips/Trips/Falls - Maintain good
housekeeping procedures to prevent
slip/trip/fall hazards. Steps, heavy debris,
and other protruding obstructions may be
marked with flagging, cones or high visibility
paint. If necessary, vehicle pathways will be
delineated around dangerous terrain. Watch
your footing placement when traversing the
worksite.

Biological Hazards - Avoid contact with
poisonous vegetation, snakes, mosquitoes,
ticks and bees. If stung or bitten, take
necessary first aid measures and call for
emergency services, if needed. Utilize insect
repellents or barrier creams as/if needed.
Inspect for ticks at the end of each work
shift. Report any stings or bites.

Heat Stress - Dress appropriately. Stay
hydrated - water, ice, & sports drinks shall
be made available to employees. Monitor
yourself and other employees for signs of
fatigue or other heat stress symptoms. Take
breaks and rest as needed. Wear sun block
as needed to protect skin from sun exposure.

Noise - Workers must wear approved hearing
protection when working around equipment
that produces sound levels in excess of 85
decibels, whenever signs/labels indicate that
hearing protection is required, and/or
whenever voices must be raised to be heard
at a distance of three feet or less.

Severe Weather Conditions - Site Supervisor
must monitor weather forecasts. Ensure
equipment, fuel tanks, and portable buildings
are secured. Stop Work and immediately
seek shelter until severe weather passes (30
minutes after last observed lightning
strike/lightning strike within 10-mile radius of

Page 2

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work location).

Pinch Points/Cuts/Abrasions - Employees
shall wear the appropriate gloves for the
task. Gloved hands can still be injured, keep
your hands away from areas where they may
become caught-in or between objects.

Manual Lifting/Handling - Use mechanical
equipment to perform lifting activities
whenever possible. If you must lift, bend at
the knees and use leg muscles when lifting.
Ask for assistance when lifting
heavy/awkward loads. Use tools (e.g.
wheelbarrows) to assist in lifting/carrying
heavy loads. Avoid prolonged
awkward/unnatural body postures.

Vehicle Traffic - Traffic patterns shall be
delineated to keep traffic away from ground
personnel to the extent possible. Utilize
spotters when backing, negotiating around
obstacles, or other confined/congested areas.

Page 3

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Job Hazard Analysis (JHA) Form

Description of Task/Work Activity:

Hand & Power Tool Use

Required PPE for Specific Task:

^ Hard Hat

~ Chemical-Resistant Boots/Boot Covers

^ Safety Glasses (Clear/Indoor)

~ Tyvek/MicroMAX Coveralls

^ Safety Glasses (Tinted/Outdoor)

~ Chemical Protective Clothing (CPC)

^ Steel/Composite-Toe Boots

~ CPC Type:

^ Hi-Visibility Vest/Clothing

~ Chemical-Resistant Gloves:

^ Gloves (Leather/General Use/Cut-Resistant)

EH Glove Type:

~ Hearing Protection (Ear Plugs/Earmuffs/Both)

~ Air-Purifying Respirator

~ FR Coveralls/Clothing

~ Cartridges:

~ Fall Protection (Full Body Harness & Lanyard/Lifeline)

~ Supplied Air Respirator (Airline)

~ PFD (Personal Flotation Device) - USCG-Rated

~ SCBA

^ Face Shield

~ Other:

Page 1

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Sequence of Task Steps:

Potential Hazards:

Controls/Preventative Measures:

Hand Tools - Non-Electrical

Faulty Operation

Tools Appropriate for jobs

Operating Accident

Good House Keeping

Flying Fragments

Correct Work Surface and clamps

Worn Tools

Proper Balance, Stance & Grip

Muscle Strains

Training on Use of Equipment

Mislaid Equipment

Use Proper Leverage and Body Positioning

Slip/Trip/Fall

Eye Injury, flying chips and slivers

Cuts-Abrasions-Punchers

Identification of hazardous activities and

Overexertion

materials; Correct eye protection; tool guards

Accidental Movement

Hand tools, cuts, impacts, punctures and

abrasions tools appropriate for jobs, well

maintained, sharpened and lubricated.

Hand tools, repetitive stress injury Symptom

awareness; Regular breaks; Vary work type

Hand Tools - Electrical

Slip/Trip/Fall due to Bad House Keeping

Place away from walkways

Cracked or Broken Tools

Good House Keeping

Cracked or Broken Bits/Wheels

Keep Hands Clear

Cuts/Lacerations/Amputations

Be sure to always cut away from body

Drop Tools on Feet

Ensure Tools are in Good Condition

Loud Noise

Inspect Tools Prior to Each Use

Electrical Shock

Ensure Dry Working Area

Electrical Wires Exposed

Ensure Guards are in Place

Ground Missing From Plug

Tools are plugged into a GFCI Outlet

Bad Electrical Cords

Always use Proper PPE

Safety Glasses

Steel Toe Boots

Gloves

Ear Plugs

Long Pants/Shirt

Hand Tool - Grinder

Grinding Wheel Failure

Place away from walkways

Cracked or Broken Wheel

Ensure Guard is in place

Slip/Trip/Fall

Fire Extinguisher

Cuts/Lacerations/Amputations

Keep Hands Clear

Page 2

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Noise

Ensure proper grinding wheel is in place and

Fire

is in good condition

Fumes

Ensure power cord is unplugged at all times

Burns

when installing/changing disks/wheels

Ensure that all loose clothing, hair, jewelry

etc., is contained

Maintain control and a firm grip on tool

Be aware of adjacent surfaces and disk's

rotation direction

Ensure that disk/wheel has stopped rotating

before placing hand(s) near disk/wheel area

and before placing tool on any surface

Hand Tool - Saw

Faulty Operation

Good ventilation

Wrong Blade Size

Notify Everyone in Work Area

Operating Accident

Ensure guard is in place

Flying Fragments

Fire extinguisher

Saw Kick-Back

Keep hands clear

Blade Falling Off

Good housekeeping

Excessive Noise

Inspect power cord

Electrocution

Recommended PPE

Slip/Trip/Fall

Safety Glasses

Accidental Movement

Sturdy Work Boots

Cuts/Lacerations/Amputations

Leather Gloves

Face Shield

Long Pants/Shirt

Hearing Protection

Page 3

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Job Hazard Analysis (JHA) Form

Description of Task/Work Activity:

Heavy Equipment Operations (Clearing and Grubbing)

Required PPE for Specific Task:

^ Hard Hat

~ Chemical-Resistant Boots/Boot Covers

^ Safety Glasses (Clear/Indoor)

^ Tyvek/MicroMAX Coveralls

^ Safety Glasses (Tinted/Outdoor)

~ Chemical Protective Clothing (CPC)

^ Steel/Composite-Toe Boots

~ CPC Type:

^ Hi-Visibility Vest/Clothing

~ Chemical-Resistant Gloves:

^ Gloves (Leather/General Use/Cut-Resistant)

EH Glove Type:

^ Hearing Protection (Ear Plugs/Earmuffs/Both)

~ Air-Purifying Respirator

~ FR Coveralls/Clothing

~ Cartridges:

~ Fall Protection (Full Body Harness & Lanyard/Lifeline)

~ Supplied Air Respirator (Airline)

~ PFD (Personal Flotation Device) - USCG-Rated

~ SCBA

^ Face Shield

~ Other:

Page 1

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Sequence of Task Steps:

Potential Hazards:

Controls/Preventative Measures:

Heavy Equipment Operations (Clearing &
Grubbing)

Equipment Damages/Deficiencies

Ground Personnel Struck-By Equipment

Equipment Contact with Overhead Utilities

Equipment Contact with Underground Utilities

Refueling Equipment

Vehicle/Equipment Traffic

Working on Steep Slopes

Biological Hazards

Flying Debris

Equipment Damages/Deficiencies - Operator
must inspect equipment each day, prior to
use. Any deficiencies must be reported to the
Site Supervisor before use. If any deficiencies
reported are "safety sensitive" (e.g. back-up
alarm, steering, brakes, etc.), the equipment
must be removed from service until
repaired/replaced.

Struck-By Equipment - Ground Personnel
must remain a safe distance away from
equipment in operation. If you must
approach equipment in operation, make eye
contact with the operator and signal for him
to stop. Wait for operator to "ground &
disengage" equipment before approaching.
Ground personnel shall wear high-visibility
vests/clothing, so they are easily seen by
equipment operators. A spotter shall be
utilized when loading/unloading equipment
from trailers, or equipment is
backing/negotiating tight turns around
obstructions, obstacles, or other ground
personnel.

Overhead Utilities - Before work begins,
inspect work area for Overhead Utilities.
Ensure equipment remains at least 10' from
overhead powerlines, follow OSHA's
"Minimum Approach Distance" guidelines. If
overhead powerlines are present, a spotter
must be utilized to ensure the equipment
does not encroach the minimum approach
distance.

Underground Utilities - Before work begins,
inspect work area for Underground Utilities.
When excavating below existing grade,

Page 2

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Page 3

ensure a utility locate

(811 or private party) has been completed.
Follow regulations and guidelines for
excavating around underground utilities.

Refueling Equipment - Equipment must be
shut off and allowed time to cool prior to
refueling. Keep open sparks/flames (including
smoking) at least 50' away from refueling
area.

Vehicle/Equipment Traffic - Traffic patterns
shall be established to keep traffic away from
ground personnel to the extent possible.
Utilize spotters when backing, negotiating
around obstacles, or other
confined/congested areas.

orking on Steep Slopes - Avoid operating on
steep slopes whenever possible, follow
equipment manufacturer's guidelines when
operating on a grade/incline. Avoid traversing
slopes perpendicular to the grade. Always
keep loads uphill from the machine.

Biological Hazards: Be alert for bees, snakes,
or other wild animals that may be present. Be
alert for poisonous plants. Additional PPE
(such as Tyvek disposable coveralls) may be
necessary to protect workers in areas where
poisonous plants are identified.

Flying Debris: Ground personnel must remain
a safe distance away from heavy equipment
clearing operations as to not be struck by
flying debris that may be ejected during
clearing.

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Job Hazard Analysis (JHA) Form

Description of Task/Work Activity:

Heavy Equipment Operations (Excavation of Contaminated Soils)

Required PPE for Specific Task:

^ Hard Hat

~ Chemical-Resistant Boots/Boot Covers

^ Safety Glasses (Clear/Indoor)

~ Tyvek/MicroMAX Coveralls

^ Safety Glasses (Tinted/Outdoor)

~ Chemical Protective Clothing (CPC)

^ Steel/Composite-Toe Boots

~ CPC Type:

^ Hi-Visibility Vest/Clothing

~ Chemical-Resistant Gloves:

^ Gloves (Leather/General Use/Cut-Resistant)

EH Glove Type:

~ Hearing Protection (Ear Plugs/Earmuffs/Both)

~ Air-Purifying Respirator

~ FR Coveralls/Clothing

~ Cartridges:

~ Fall Protection (Full Body Harness & Lanyard/Lifeline)

~ Supplied Air Respirator (Airline)

~ PFD (Personal Flotation Device) - USCG-Rated

~ SCBA

~ Face Shield

~ Other:

Page 1

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Sequence of Task Steps:

Potential Hazards:

Controls/Preventative Measures:

Heavy Equipment Operations -
Excavation/Trenching

Entering Open Excavation/Trench

Equipment Damages/Deficiencies

Ground Personnel Struck-By Equipment

Equipment Contact with Overhead Utilities

Equipment Contact with Underground Utilities
Refueling Equipment

Dermal Contact with Contaminated Soils

Vehicle/Equipment Traffic

Working on Steep Slopes

Open Excavations (Cave-ins)

Working in a Confined Space

Underground Utilities - Before work begins,
inspect work area for Underground Utilities.
When excavating below existing grade,
ensure a utility locate (811 or private party)
has been completed. Follow regulations and
guidelines for excavating around
underground utilities.

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Page 3

Refueling Equipment - Equipment must be
shut off and allowed time to cool prior to
refueling. Keep open sparks/flames (including
smoking) at least 50' away from refueling
area.

Dermal Contact with Contaminated Soils -
Chemical-Resistant Boots/Boot Covers and
Chemical-Resistant Gloves (such as Nitrile)
shall be worn inside of contaminated area.
Avoid direct dermal contact with
contaminated material. Immediately wash
hands, arms, and face with soap and water
after exiting the work area prior to eating,
drinking, smoking, etc.

Open Excavations (Cave-ins) - Open
excavations shall be appropriately
marked/barricaded to prevent entry by
unauthorized personnel. Open excavations
deeper than 5 feet shall not be entered
without prior inspection and approval by a
Competent Person. Excavations deeper than
5 feet which are entered by employees shall
be sloped, shored, or protected by some
other equivalent means. When employees are
required to work in an excavation 4 feet or
deeper, a ladder (or some other appropriate
means of egress) shall be provided. The
maximum horizontal travel distance to the
ladder shall be 25 feet. The ladder shall
extend a minimum of 3 feet above the
excavation and be secured. Air monitoring
will be required for the testing of excavations
and trenches that are greater than 5' deep or

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Page 4

are in close proximity to sewer and gas lines
or where hazardous conditions may present.

Confined Space - Air Monitoring shall be
conducted. A Confined Space Permit &
Attendant shall be in place during Confined
Space Entry. A trained and equipped 2-
person Rescue shall be available in the
immediate area during Confined Space Entry.

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Job Hazard Analysis (JHA) Form

Description of Task/Work Activity:

Mobilization & Demobilization

Required PPE for Specific Task:

^Hard Hat

~Chemical-Resistant Boots/Boot Covers

^Safety Glasses (Clear/Indoor)

~Tyvek/MicroMAX Coveralls

^Safety Glasses (Tinted/Outdoor)

~Chemical Protective Clothing (CPC)

^Steel/Composite-Toe Boots

~CPC Type:

^Hi-Visibility Vest/Clothing

~Chemical-Resistant Gloves:

^Gloves (Leather/General Use/Cut-Resistant)

~dove Type:

^Hearing Protection (Ear Plugs/Earmuffs/Both)

~Air-Purifying Respirator

~ FR Coveralls/Clothing

~Cartridges:

~ Fall Protection (Full Body Harness & Lanyard/Lifeline)

~Supplied Air Respirator (Airline)

~ PFD (Personal Flotation Device) - USCG-Rated

~SCBA

~ Face Shield

~Other:

Page 1

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Sequence of Task Steps:

Potential Hazards:

Controls/Preventative Measures:

Driving to/from Project Site
Loading/Unloading Equipment and Trailers

Motor Vehicle Accident

- Pre-Existing Vehicle Damage/Safety Issues

- Distracted Driving

- Driving While Fatigued

- Other Drivers

Escorting equipment from the unloading area
to the project site.

Removing Equipment Tie-Downs

- Pinch Points

- Stored/Potential Injury

Mounting/Dismounting Equipment

- Slips/Trips/Falls

Employees Struck-By or Caught-In/Between
Equipment and Cargo

- Pinch Points

Sprains/Strains During Manual Liftin

Motor Vehicle Accident - Plan your travel
route. Perform a vehicle inspection before
departure (360 walkaround). Use spotters
when backing or negotiating tight
turns/confined or congested areas. Secure
loads properly and inspect frequently.

Escorting Equipment - If/when equipment
has to be unloaded and escorted to the
project site on public roadways, the
equipment will be escorted by at least two
vehicles (one in front of the equipment, one
behind) with emergency lighting/flashers.
Spotter(s) must be utilized when traversing
under low bridges, powerlines, or any other
overhead obstacle/obstruction.

Removing Equipment Tie-Downs - Employees
must wear gloves when removing equipment
tie-downs, binders, chains, etc. Stay alert for
stored/potential energy when removing tie-
downs as equipment may have shifted during
transport.

Mounting/Dismounting Equipment - Ensure
hand holds, rails, and steps of equipment are
stable and free of any dirt/debris that might
cause the employee to slip when
mounting/dismounting the equipment.
Maintain 3-points of contact. Ensure footing
and placement on the ground is free from
large rocks/debris when dismounting
equipment. Do not jump off equipment to
dismount.

Struck-By or Caught-In/Between Equipment
& Cargo - Inspect load conditions prior to
removing tie-downs. Inspect equipment
(lifting straps, chains, hooks, etc.) before
lifting. Ensure lifting & rigging equipment can

Page 2

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handle the weight of the load(s). Ground
personnel must remain out of the "Red Zone"
of equipment and loads. Keep hands and
fingers out of rigging apparatus when under
load. Use tag lines to guide/control loads.

Sprains/Strains - Avoid moving
heavy/awkward loads by yourself, get help or
equipment to assist in lifting & handling. Use
proper manual lifting techniques.

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Job Hazard Analysis (JHA) Form

Description of Task/Work Activity:

Pressure Washing

Required PPE for Specific Task:

^Hard Hat

^Chemical-Resistant Boots/Boot Covers

^Safety Glasses (Clear/Indoor)

^Tyvek/MicroMAX Coveralls

^Safety Glasses (Tinted/Outdoor)

^Chemical Protective Clothing (CPC)

^Steel/Composite-Toe Boots

I^CPCType:

^Hi-Visibility Vest/Clothing

^Chemical-Resistant Gloves:

^Gloves (Leather/General Use/Cut-Resistant)

^Glove Type:

^Hearing Protection (Ear Plugs/Earmuffs/Both)

~Air-Purifying Respirator

~ FR Coveralls/Clothing

~Cartridges:

~ Fall Protection (Full Body Harness & Lanyard/Lifeline)

~Supplied Air Respirator (Airline)

~ PFD (Personal Flotation Device) - USCG-Rated

~SCBA

^Face Shield

^Other: Metatarsal Boots or Metatarsal Guard Attachments

Page 1

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Sequence of Task Steps:

Potential Hazards:

Controls/Preventative Measures:

Inspection & Setup of Equipment
Use of Pressure Washer
Making Repairs/Adjustments

Equipment Damages/Deficiencies

Struck-By Pressure Washer Hose/Fitting
During Sudden Failure of Hose Connection

Contact with High-Pressure Stream

Flying Debris, Contact with
chemical/substance to be cleaned

Electrical Shock

Equipment Malfunction / Accidental Discharge
of the Pressure Washer, Burns due to high
temp water

Equipment Damages/Deficiencies - All hoses,
fittings, and other components shall be
checked for evidence of damage, wear, or
imperfections. The hose and connections
shall be checked to ensure that they are
rated for use at the pressures to be used, a
hose shall not be operated at a pressure
exceeding the working pressure. All hoses
should be protected from being tripped over
or run over and crushed by vehicles, forklift
trucks, etc. Hoses should be laid out to avoid
or minimize abrasive wear on the hose. Any
tools, equipment, or machinery found
damaged, defective, or otherwise unsafe
should immediately be removed from service
and not used until repaired or replaced.

Struck-By Pressure Washer Hose/Fitting
During Sudden Failure of Hose Connection -
Safety connectors (whip checks/cable
chokers) shall be used across all hose
connections. Do not use any fitting other
than a soap nozzle when soap is being used,
in order to prevent pressure building and
potential hose failure.

Contact with High-Pressure Stream - Never
use the pressure washer for anything other
than its intended use. Never point a pressure
washer's wand/gun or direct its pressure
stream towards yourself or other individuals.
Ensure good footing and firm grip on the
pressure washer gun during operation. Use
the approved pressure washer attachment tip
that is specific to the application or task.
Dead-man switches or constant pressure
triggers must be equipped on all pressure
washer wands/guns to stop flow if the wand
is released or dropped and these triggers
shall not be tied/locked into place.

Flying Debris - Face shield with safety glasses

Page 2

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Page 3

with face shield or full-face respirator must
be worn to protect operator from flying debris
during pressure washing. Review SDS and
don the proper CPC for the task at hand.

Electrical Shock - Ensure all equipment being
washed is deenergized, and never operate
pressure washers near electrical panels or
energized power sources. Test GFCI
equipment prior to use.

Equipment Malfunction / Accidental Discharge
of the Pressure Washer - No attempt shall be
made to tighten or otherwise adjust any nut,
hose connection, or other fitting or
component of a high-pressure water jetting
system while the system is under pressure.
The pumps shall be stopped and any
pressure in the line discharged before any
repair or other adjustment is made. NOTE: If
HOTSY was in use, cycle cold water through
the system to purge hot water.

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Job Hazard Analysis (JHA) Form

Description of Task/Work Activity:

Pump & Pressurized Vessel Operations

Required PPE for Specific Task:

^Hard Hat

~Chemical-Resistant Boots/Boot Covers

^Safety Glasses (Clear/Indoor)

~Tyvek/MicroMAX Coveralls

^Safety Glasses (Tinted/Outdoor)

~Chemical Protective Clothing (CPC)

^Steel/Composite-Toe Boots

~CPC Type:

^Hi-Visibility Vest/Clothing

~Chemical-Resistant Gloves:

^Gloves (Leather/General Use/Cut-Resistant)

~dove Type:

^Hearing Protection (Ear Plugs/Earmuffs/Both)

~Air-Purifying Respirator

~ FR Coveralls/Clothing

~Cartridges:

~ Fall Protection (Full Body Harness & Lanyard/Lifeline)

~Supplied Air Respirator (Airline)

~ PFD (Personal Flotation Device) - USCG-Rated

~SCBA

~ Face Shield

~Other:

Page 1

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Sequence of Task Steps:

Potential Hazards:

Controls/Preventative Measures:

Rig Up

Equipment Failure

Always wear the proper PPE for the job

Incorrect hoses/connection types

See Mob/Demob, General Site Work Activities

Pump Operations

Slips/Trips/Falls

JSA

Overexertion

PSI Vessel Operations

Heat Stress

Inspect all equipment prior to use

Ensure the correct hoses/fittings are being

Leaking Lines,

used on all hoses/tanks/vessels etc.

Equipment Damage due to not checking fluid

Prior to starting pumps, ensure that all

levels

Running Pump Dry,

connections are secured, perform a pressure
test, if necessary, communicate with all

PSI-related hazards (Trapped/Over

personnel on each side of the transfer, check

Pressurization),

all fluid levels prior to starting the equipment.

Flying Debris,

Ensure that water is flowing to pump. Ensure

Static Electricity

that no hydrocarbons are flowing through

hoses/to equipment that is not rated for

hydrocarbons

Ground all equipment to mitigate static

electricity buildup

Check to make sure that all PSV devices on

tanks, pumps, psi-vessels (carbon

filters/filter sock vessels) are in place and

functioning.

Ensure pump is isolated from system and

pressure is relieved before disassembling

pump, removing plugs, opening vent or drain

valves, or disconnecting piping.

Observe proper decontamination procedures.

Proper personal protective equipment should

be worn. Precautions must be taken to

prevent physical injury. Pumpage must be

handled and disposed of in conformance with

applicable environmental regulations.

Page 2

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Never operate the pump without liquid
supplied to mechanical seal. Running a
mechanical seal dry, even for a few seconds,
can cause seal damage and must be avoided.
Physical injury can occur if mechanical seal
fails.

Page 3

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Job Hazard Analysis (JHA) Form

Description of Task/Work Activity:

Railcar Transfers

Required PPE for Specific Task:

^Hard Hat

^Chemical-Resistant Boots/Boot Covers

^Safety Glasses (Clear/Indoor)

~Tyvek/MicroMAX Coveralls

^Safety Glasses (Tinted/Outdoor)

^Chemical Protective Clothing (CPC)

^Steel/Composite-Toe Boots

I^CPCType:

^Hi-Visibility Vest/Clothing

^Chemical-Resistant Gloves:

^Gloves (Leather/General Use/Cut-Resistant)

^Glove Type:

^Hearing Protection (Ear Plugs/Earmuffs/Both)

^Air-Purifying Respirator

^FR Coveralls/Clothing

^Cartridges:

^Fall Protection (Full Body Harness & Lanyard/Lifeline)

^Supplied Air Respirator (Airline)

~ PFD (Personal Flotation Device) - USCG-Rated

~SCBA

^Face Shield

pother:

Page 1

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Sequence of Task Steps:

Potential Hazards:

Controls/Preventative Measures:

Mob/Demob

General Site Work Activities

Working on/near railroad

Rig up pumps/transfer equipment

Begin Transfer

Complete Transfer

See Mob/Demob JHA

See General Site Work Activities JHA

• Exposure to material to be
transferred

See Working on/Near Railroad JHA

• Moving railcar/on-track equipment

See Pumping Operations JHA

• Static electricity buildup/discharge

Overfill/Spills

Equipment Failure / Material Incompatibility/
Overpressure of vessel

See Mob/Demob JHA

See General Site Work Activities JHA

• Safety equipment, such as safety
showers and eyewash stations should
be present prior to beginning transfer

• Proper PPE must be worn (refer to
SDS of material to be transferred)

See Working on/Near Railroad JHA

• Ensure brakes are set, wheels chocked
before any loading/unloading activities
are started

• Utilize derails, aligned/locked
switches, bumper blocks, other
apparatus

• Inspect car for damage - notify
employee in charge if found

See Pumping Operations JHA

• Tank car containing flammable or
combustible gases or liquids should
be electrically grounded and bonded
during loading and unloading
operations. Grounding and bonding of
cars carrying other commodities may
also be necessary.

The tank/vessel to be transferred to must be
of sufficient capacity, both by weight and
volume to contain the quantity of the product
being loaded/unloaded.

All fittings, valves, gaskets and fasteners
must be in proper condition, i.e. not
corroded, torn, worn, stripped or otherwise
damaged. Materials contacting the lading
must be compatible with the product being

Page 2

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Page 3

loaded into the car (refer to SDS for
incompatibility).

Unless the tank that is being transferred to is
cleaned/purged, ensure that the residue in
the tank is compatible with the product being
loaded into the car. Do not transfer into a
vessel that has an unidentified residue.

If equipped with a safety vent, the rupture
disc must thoroughly inspected. If equipped
with a pressure relief valve, the valve must
be inspected to ensure no debris is in its
discharge area. If a combination pressure
relief device is present each detection device
(including, for example, telltale indicator or
needle valve) should be checked to
determine the integrity of the rupture disk.
These devices must be closed prior to
transportation.

During loading continually monitor the car for
any signs of leakage.

Ensure adequate outage space remains in the
car when loading is completed to prevent
overloading by volume or by weight and to
allow expansion in transit. Refer to applicable
regulations for correct outage, filling density
and other weight restrictions for the
commodity loaded.

When loading is complete re-check the car
for any signs of leakage. If there are any
signs of leakage and if the leak cannot be
stopped, the truck must be transported and
spill procedures must be followed.

Close all valves after car is loaded. Verify
there is no detectable leakage from valves,
flanges, threaded connections and packing

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glands. Secure all plugs and outlet caps with
a suitable tool. Use non-sparking tools if
required

Page 4

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Job Hazard Analysis (JHA) Form

Description of Task/Work Activity:

Roll-off Container Load and Un-load

Required PPE for Specific Task:

^ Hard Hat

~ Chemical-Resistant Boots/Boot Covers

~ Safety Glasses (Clear/Indoor)

~ Tyvek/MicroMAX Coveralls

^ Safety Glasses (Tinted/Outdoor)

~ Chemical Protective Clothing (CPC)

^ Steel/Composite-Toe Boots

~ CPC Type:

^ Hi-Visibility Vest/Clothing

~ Chemical-Resistant Gloves:

^ Gloves (Leather/General Use/Cut-Resistant)

EH Glove Type:

~ Hearing Protection (Ear Plugs/Earmuffs/Both)

~ Air-Purifying Respirator

~ FR Coveralls/Clothing

~ Cartridges:

~ Fall Protection (Full Body Harness & Lanyard/Lifeline)

~ Supplied Air Respirator (Airline)

~ PFD (Personal Flotation Device) - USCG-Rated

~ SCBA

~ Face Shield

~ Other:

Page 1

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Sequence of Task Steps:

Potential Hazards:

Controls/Preventative Measures:

1. Review "General Site Activities" J HA

2. Review "RO Box Loading and
Unloading" J HA

3. Review project HASP and Tailgate

4. Evaluate site

5. Vehicle Placement

6. Loading

7. Securing the load

8. Off-loading

Slips, Trips, Falls, Pinch Points
Over-head power lines or obstructions
Backing

Cable Damage / Burr
Unexpected box movement
Uneven loading / misalignment
Load securement

Ensure work area is clear of hazards

Use a spotter when available to align the
truck with the box

- Always get out and look prior to
backing

Ensure over-head clearance is
available prior to lifting rails

Wear proper PPE when handling the cable

- Inspect for damage prior to use

Inspect box prior to loading

Rear door secured

- Tarp condition and securement

Clear area around the work zone prior to
loading

Ensure the truck brakes are engaged

Check for alignment while loading

After loading is complete

Check load securement

- Attach load straps and secure

Unloading the box

Look at the site prior to offloading
Ensure that the box has room to roll
off the truck

Watch for overhead obstructions

- Apply the parking brake
Remove box securement straps
Raise truck rails

Slowly let winch cable out until box is
secure on the ground

Page 2

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Page 3

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Job Hazard Analysis (JHA) Form

Description of Task/Work Activity:

Trailer Use

Required PPE for Specific Task:

~ Hard Hat

~ Chemical-Resistant Boots/Boot Covers

~ Safety Glasses (Clear/Indoor)

~ Tyvek/MicroMAX Coveralls

~ Safety Glasses (Tinted/Outdoor)

~ Chemical Protective Clothing (CPC)

~ Steel/Composite-Toe Boots

~ CPC Type:

~ Hi-Visibility Vest/Clothing

~ Chemical-Resistant Gloves:

~ Gloves (Leather/General Use/Cut-Resistant)

EH Glove Type:

~ Hearing Protection (Ear Plugs/Earmuffs/Both)

~ Air-Purifying Respirator

~ FR Coveralls/Clothing

~ Cartridges:

~ Fall Protection (Full Body Harness & Lanyard/Lifeline)

~ Supplied Air Respirator (Airline)

~ PFD (Personal Flotation Device) - USCG-Rated

~ SCBA

~ Face Shield

~ Other:

Page 1

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Sequence of Task Steps:

Potential Hazards:

Controls/Preventative Measures:

Hooking Up

Manually Pulling Trailer to Truck

Closing Hitch Lock, Safety
Chain, Electric Hook-Up

Pulling

Turning (Area Too Small)

Spare Tire

Backing up to Trailer Too Fast;
Bump Trailer So It Rolls; Falls Off
Jack or Dents Vehicle

Body Between Truck and Trailer;
Fingers Between Hitch and Bumper;
Tolling Over Foot or Onto Leg

Muscle Strain; Drop on Foot

Pinch points; Dirt in Eyes; Electric

Vehicle Not Suited to Pull Trailer;
Driver Not Proficient; Changing
Road Surfaces; Pavement, Gravel,
Dirt, Sand, Snow or Ice, Combined
with Grade, Visibility; Heavy Trailer;
Slow Uphill and Fast Pushes
Downhill; Allow for Longer Stopping
Distances; Fishtailing from ruts or
hard breaking; Electric Break
Pulling left or Right; Load Shift
(Tank Type) (Flat Bed for Stake
Side); Crush person or body parts -
Load falls off trailer or tips trailer
over causing damage to towing
vehicle or other vehicle on/by
roadway; Injury to pedestrians

Hit with front outside of truck or rear
inside of trailer;

Getting stuck on narrow and dead-
end roads

a) One person: Align Hitch to bumper then
back slowly.

b) Two or more persons: Watch Only One
Back up Guide. Attach safety chains
securely to vehicle.

c) Don't get between trailer and truck hitch
or bumper while truck is moving. Don't
stand behind trailer. Don't let trailer fall
or be pushed off jack.

Don't Overexert, Get Help, Move Slowly, Keep
Proper Balance. Don't let the trailer push you.

Be familiar with the type of hitch. Do not use
snap-ring/Bolt-on Style hitches. If these are
found, trailer is to be taken out of service. Lock
correctly, keeping hands clear of pinch points
between trailer jack and tongue. Take care in
hooking chains under dirt filled bumper or
frayed wires. Ensure feet are not under trailer
tongue or associated equipment.

Before moving, check lights, jack or tongue
prop. Remove chock blocks, check tires and
lug nuts.

Pull trailer with vehicle properly equipped for
towing (licensed operators only). Awareness to
changing conditions. Adjust speed downward.
Practice pulling trailer under controlled "good"
conditions. Practice using electric brakes and
know how to adjust. Practice on size and type
of trailer. No passengers on trailer! Use lower
gears to slow vehicle to save vehicle brakes.
Tie down all loads or secure with suitable
strapping. Plan for extreme vibrations while
securing loads and check strapping our tie
downs frequently.

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Page 3

Plan your route. Know the turning radius
required for each type of trailer. Turn slowly.
Know turning width taken up by truck and
specific trailer.

Avoid roads that do not provide turning areas
for maneuvering the trailer. Avoid going down
steep roads unless there is another way
out. Use 4WD, if necessary.

Ensure that spare tire is available and fully
inflated prior to each trailer use.

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Job Hazard Analysis (JHA) Form

Description of Task/Work Activity:

Vacuum Truck Operations

Required PPE for Specific Task:

^ Hard Hat

~ Chemical-Resistant Boots/Boot Covers

^ Safety Glasses (Clear/Indoor)

~ Tyvek/MicroMAX Coveralls

^ Safety Glasses (Tinted/Outdoor)

~ Chemical Protective Clothing (CPC)

^ Steel/Composite-Toe Boots

~ CPC Type:

^ Hi-Visibility Vest/Clothing

^ Chemical-Resistant Gloves:

^ Gloves (Leather/General Use/Cut-Resistant)

^ Glove Type: Inner & Outer Nitrile

^ Hearing Protection (Ear Plugs/Earmuffs/Both)

~ Air-Purifying Respirator

~ FR Coveralls/Clothing

~ Cartridges:

~ Fall Protection (Full Body Harness & Lanyard/Lifeline)

~ Supplied Air Respirator (Airline)

~ PFD (Personal Flotation Device) - USCG-Rated

~ SCBA

^ Face Shield

~ Other:

Page 1

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Sequence of Task Steps:

Potential Hazards:

Controls/Preventative Measures:

1. Traffic/Site Control

2. Set up truck, vacuum hose, and stinger
pipe (if needed)

3. Removal of liquids/sludge by use of stinger
pipe and/or vacuum hose

4. Clear hose, disengage vacuum, remove
hose

1. Traffic Visibility, Truck & Work Area
Security, Adjacent Operations

2. Back Injury (Sprains/Strains), Trip
Hazards, Spills, Static Electricity Discharge

3. Excessive tank pressure, obstacles in line

4. Trips, straining hazard, line clogging, tank
overfill

5. Injury from vacuum/suction

6. Exposure to Chemicals

1. Proper PPE (safety/reflective vest), safety
cone deployment with flags and barricades
(or caution tape), proper positioning of
vacuum truck, chock wheel, flashers, beacon
light at night, constant area observation.

2. Hoses can be heavy and awkard, utilize
proper lifting techniques and ask for help,
allow necessary space for adequate work
area, proper use of various fittings, utilize
good hose management to minimize trip
hazards, ensure spill pads are available,
secure camlock ears on hoses (ensure
gaskets are in place and in good condition),
ensure truck and hose connections are
bonded and grounded (<10 ohms).

3. Proper training in truck/pump operation is
critical, initial and constant monitoring of
vacuum pressure gauge (PSI), keep end of
hose clear of objects when opening inlet,
wear hearing protection and face shield,
proper training in vacuum hose operation
(break surface but don't touch bottom until
known or visible), monitor to assure proper
pressure and suction, proper lifting
techniques, monitor tank fill gauge closely—
stop and stick tank if uncertain.

4. Assure hose end is clear of product and
pulling air strongly prior to disengaging
vacuum (clear lines), keep work area clear-
be aware of surroundings.

5. Always use a suction handle connected to
the end of the hose to control the hose. The
handle should be of sufficient length to allow
the operator to stand in a full upright
position. The handle must be compatible with
the material being transferred. If the material
is combustible or flammable the handle must
be constructed of conductive material and

Page 2

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Page 3

bonded to the hoses and/or truck. Never
place hands, feet or other body parts in front
of the hoses. Never leave vacuum hoses
unattended or lying on the ground. For
vacuum trucks capable of producing greater
than 3,000 cfm of vacuum/suction, "Safety-
T" vacuum breakers or "dead man switches"
within immediate reach of the operator at the
end of the suction hose must be utilized.
These vacuum breaks must be capable of de-
energizing the suction to the hose
immediately upon activation.

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Job Hazard Analysis (JHA) Form

Description of Task/Work Activity:

Working around Waterways (Creeks/Streams)

Required PPE for Specific Task:

^Hard Hat

^Chemical-Resistant Boots/Boot Covers

^Safety Glasses (Clear/Indoor)

~Tyvek/MicroMAX Coveralls

^Safety Glasses (Tinted/Outdoor)

^Chemical Protective Clothing (CPC)

^Steel/Composite-Toe Boots

ISICPC Type :

^Hi-Visibility Vest/Clothing

^Chemical-Resistant Gloves:

~Gloves (Leather/General Use/Cut-Resistant)

^Glove Type: Nitrile (Solvex)/Outer PVC

^Hearing Protection (Ear Plugs/Earmuffs/Both)

^Air-Purifying Respirator

~ FR Coveralls/Clothing

^Cartridges: Organic Vapor (When Atmospheric Conditions Dictate)

^Fall Protection (Full Body Harness & Lanyard/Lifeline)

^Supplied Air Respirator (Airline)

^PFD (Personal Flotation Device) - USCG-Rated

~SCBA

^Face Shield

^Other: Chest Waders

Page 1

-------
Sequence of Task Steps:

Potential Hazards:

Controls/Preventative Measures:

Working in and around waterways

General emergency

Inclement weather

Lone working

Uneven terrain/Slopes
Slips trips and falls

Drowning / Hypothermia

Creek bank causing Slips trips
and falls

Submerged objects causing Loss of balance
Musculoskeletal injury

Exposure to contaminates/Microorganisms in
water

Supervisors to be aware of nearest
Accident and Emergency hospital; A first
aid kit must be on site at all times; A
mobile phone should be available at all
times (if no/poor signal, all supervisors
should know the location of the nearest
landline); A safety plan should be
completed; All incidents
and near misses must be reported to HEPACO
Supervisor/Management.

Appropriate clothing to be worn for the

weather (layers of warm, waterproof

clothing (waders); Suncream available; Drink

plenty of fluids and take regular breaks;

Stop activity if heavy rain/strong wind and

site/task becomes dangerous, or

participants experience discomfort. Monitor
lightning in the area and "cab up" if lightning
is observed within lOmi for at least 30
minutes past the last strike.

No lone working in or near water under
any circumstances.

Discuss the terrain during the tailgate safety
meeting; wear sensible, sturdy

Footwear (railroad compliant or waders)
Ensure unused

tools are left in a designated place, stored

neatly; Mark, or cordon off, any major trip

hazards that cannot be removed. Use
creekbank access points (Picket anchor point
systems)

Page 2

-------
Page 3

No lone-working when in/by water; Buddy
system in place so that anyone in the
water has a spotter on the bank;

; Only confident swimmers to
enter the water; Chest waders
to be worn as appropriate for water
level; Do not undertake work if water
levels abnormally high or fast; Check
depth of water along bed using a long
pole/stick before entering; No volunteer
tasks to be undertaken in water higher
than thigh height.

Participants briefed to be

cautious of uneven ground and vegetation

that may be a trip hazard.

Carry out a visual survey of the work area
beforehand to identify any potential
hazards in the water; Warn participants
about the possibility of finding something
alert supervisors if this is the case; Use a
long pole/stick to check for debris when
walking through waterway.

Avoid water contact, particularly around
the face/mouth; Cover all cuts with
waterproof dressing and wear gloves; If
contact is made, wash area thoroughly
with clean water before eating, drinking or
smoking and prior to leaving the site; Use
anti-bacterial gel after practical tasks;
Seek medical attention if symptoms occur.

-------
Job Hazard Analysis (JHA) Form

Description of Task/Work Activity:

Covering Spoils Piles (Manually handling and carrying sandbags on uneven terrain)

Required PPE for Specific Task:

^ Hard Hat

~ Chemical-Resistant Boots/Boot Covers

^ Safety Glasses (Clear/Indoor)

~ Tyvek/MicroMAX Coveralls

^ Safety Glasses (Tinted/Outdoor)

~ Chemical Protective Clothing (CPC)

^ Steel/Composite-Toe Boots

~ CPC Type:

^ Hi-Visibility Vest/Clothing

~ Chemical-Resistant Gloves:

^ Gloves (Leather/General Use/Cut-Resistant)

EH Glove Type:

~ Hearing Protection (Ear Plugs/Earmuffs/Both)

~ Air-Purifying Respirator

~ FR Coveralls/Clothing

~ Cartridges:

^ Fall Protection (Full Body Harness & Lanyard/Lifeline)

~ Supplied Air Respirator (Airline)

~ PFD (Personal Flotation Device) - USCG-Rated

~ SCBA

~ Face Shield

~ Other:

Page 1

-------
Sequence of Task Steps:

Potential Hazards:

Controls/Preventative Measures:

Preparing to move materials.
Moving materials.

Moving materials by hand
Moving materials with machinery.

Muscle strains, pulls and repetitive motion
injuries.

Injuries resulting from lack of
communication, or miscommunication.

Foot or leg injuries.

Finger or hand injuries.

Vehicle or machinery damage, operator
injury, or injury to others working around
machinery.

-Each employee will be given time on the job
to properly stretch and warm-up before and
during physical activity for a period of time
deemed appropriate by the crew

leader, or on-site supervisor.

-Employees will be encouraged to switch
hands often and vary the types of activities
performed to limit exposure to repetitive
motion injuries.

-The appropriate number of workers should
be used to move materials. This decision
may vary between individuals.

-Crew leaders will conduct tailgate safety
talks to provide orientation, discuss project,
safety concerns, assign work, etc.

-Good communication between crewmembers
should reinforce individual awareness of real
and potential hazards.

-Communication methods should be
discussed and agreed upon prior to moving
materials.

-The plan of attack should be discussed
before attempting to move materials.

-Instructions should come from one person
when working in teams of two or more.

-Workers need to maintain constant
awareness of their feet and foot placement

Page 2

-------
Page 3

in relation to objects being moved and avoid
placing them under materials or on material
that may slide, give way, crumble, etc.

-It is recommended that workers use
lifting techniques to minimize the potential
for injuries to hands.

-If hands are absolutely necessary use

extreme caution and 100% communication
with other workers should follow.

-Refer to JHA—Equipment Use and
Maintenance.

-------
Job Safety Analysis

General

JSAID

19445c

Status

(4) Revise

Job Name

Environment-Drilling and Soil Sampling Using
DPT Rig

Created Date

3/18/2023

Task Description

Soil Sampling Using DPT Rig

Completed Date

Template

FALSE

Auto Closed

FALSE

Client / Project

Client

Norfolk Southern Corporation

Project Number 30169714

Project Name

NS Hazmat-Palestine OH

PIC

Helmadollar, Rick

Project Manager Artrip, Jasori

User Roles

Role

Employee

Due Date

Completed Date Supervisor

Active

Developer

Moyers, Samuel

4/1/2023

McDonald, Andrew

HASP Reviewer

Matlock, Zachary

3/20/2023

3/20/2023 Matlock, Zachary

Job Steps

Job Step No.

Job Step Description

Potential Hazard

Critical Action

H&S Reference

Working around direct push
technology (DPT) rig

Slip, trip and falls from poor
housekeeping

Wear boots with good tread and ankle support.
Keep tools, drill rods, drum lids/rings off ground
and stage neatly. If plastic sheeting is placed on
ground, exercise caution while working if wet.

Struck by excavation equipment
near or in excavation areas,

Remain 25 ft from excavation equipment
including the extended reach of any portion of the
equipment unless establishing simultaneous
operations plan with the equipment operator(s).
Wear high visibility clothing and provide auxiliary
lighting at night if drilling near operating heavy
equipment.

Do not park project vehicles within 25 ft of parked
heavy equipment or within 50 ft of active railroad
tracks at arade crossina or within 7 ft of an active
track (not at grade crossings).

Struck by train or on-track
equipment.

If DPT soil sampling will occur within 25 ft of the
track, workers must be Roadway Worker
Protection trained and have eRAILSAFE. If track
is active, track protection is required.

Collecting soil sample using
DPT

Cuts or scrapes to hands
opening the sampler and DPT
liner

Wear hand protection (i.e.. leather gloves). Avoid
excessive force while attempting to remove soil
liner. Use correct cutting tool to open liners. DO
NOT USE FIXED BLADE KNIVES TO OPEN
SOIL LINERS.

Repetitive stress opening and
sampling tool

Use job rotation while opening and closing DPT
sampling tool to reduce stresses on arms and
wrists. Do not hurry through task.

Exposure to potentially
chemically impacted soil

Wear protective gloves while
handling/mixing/containing soils. Use air
monitoring in areas believed to be severely
impacted by site constituents. If 8 hr.- TLVs are
exceeded follow Level C requirements.

-------

Cleaning DPT sampling tool
rods

Wear protective gloves during cleaning. Avoid
awkward body positions and repetitive stresses if
manually washing DPT sampling tool and rods
manually. If using a pressure washer to clean
DPT tools and equipment wear face shield in
addition to safety glasses. Exercise caution and
use spoon or similar object without sharp (i.e.
knife)/puncturing (i.e. screwdriver) construction to
clear nose sampling tool to reduce potential for
hand/forearm injury.

Noise from drill rig while
sampling.

Wear hearing protection. Set up soil sample
logging, preparation and collection area away
from DPT rig to reduce noise hazards to
sampling workers. Avoid standing near DPT rig
while drill and sampling.

PPE

Personal Protective Equipment

Type

Personal Protective Equipment

Description

Required

Dermal Protection

Coveralls

Tyvek in severely impacted areas

Recommended

Sleeved shirt/long pants

Required

High visibility vest, coat

CLASPED

ANSI Class II minimum while working in or
around excavations, active track or in
public right of ways.

Required

Head Protection

Hard hat

standard hard hat in excavation areas

Required

Hand Protection

Protective gloves

Nitrile for chemical impacts, leather for
handling split spoon

Required

Eye Protection

Safety glasses

Required

Face shield

When using pressure washer

Recommended

Foot Protection

Boots

Steel-toe with defined heel, oil resistant
sole, and at least 6 inches in height for
ankle support. Lace up boots required.

Required

Supplies

Type

Supply

Description

Required

Communication Devices

Mobile phone

Required

Decontamination

Decon supplies (specify type)

Soap and water available for hand washing

Required

Miscellaneous

Auxiliary lighting

For night work

Recommended

First aid kit

Required

Flashlight

For night work in excavations

Recommended

Air monitoring in areas of high chemical
impacts

Photoionization or flame ionization
detector

Required

Eye wash (specify type)

Bottle

Required

-------
Job Safety Analysis

General

JSAID

19445d

Status

Job Name

Environment-Hand Auger Soil Sampling

Created Date

3/18/2023

Task Description

Collection of soil samples using hand augers
(including soil probes)

Completed Date

Template

Auto Closed

Client / Project

Client

Norfolk Southern Corporation

Project Number

30169714

Project Name

NS Hazmat-Palestine OH

PIC

Helmadollar, Rick

Project Manager

Artrip, Jason

User Roles

Role

Employee

Due Date

Completed Date

Supervisor

Active

Developer

Moyers, Samuel

4/1/2023

McDonald, Andrew

HASP Reviewer

Matlock, Zachary

3/20/2023

Roesler, Jerr

Job Steps

Job Step No. Job Step Description Potential Hazard

Critical Action

H&S Reference

1 Collecting soil sample using 1 Slip, trip and falls due to Wear boots with good tread and ankle support,

hand auger or soil probe uneven, wet or ice/snow Avoid carrying supplies in a manner that

covered walking surfaces obstructs view ahead.

2 Collecting soil samples with Wear hand protection. Avoid repetitive stress if
hand auger or soil probe using equipment that screws together by using

job rotation. Watch for pinch points at rod
connections or head/handle connections to rods
when assembling hand auger and probes.

Avoid excessive torque while advancing hand
auger or probe. Use job rotation to reduce
repetitive stress. Use buddy system to withdraw
hand auger from depth in wet clay or sand
environments.

When extracting soil from the hand auger
bucket, avoid using sharp edged (like knives) or
puncturing type (like screwdrivers) tools. Use of
spoons is preferred. Avoid reaching into he
nose of a hand auger to reduce risk of hand
injury from blades.

Avoid awkward body positions or excessive
twisting while cleaning hand augers and soil
probes. Do not hurry through tasks or create
unnecessary splash hazards by dropping
devices in washing containers.

3 Exposure to potentially
chemically impacted soil

4 Cleaning hand augers and soil
probes

-------
5 Struck by excavation Remain 25 ft from excavation equipment

equipment in excavation areas, including the extended reach of any portion of

the equipment unless establishing eye contact
with equipment operator and following
communication plan with the operator (hand
signals, radios, etc.). If working low to ground
consider spotter if excavation work continues in
proximity of sample site. Wear high visibility
clothing and provide auxiliary lighting at night if
moving around in excavation area with operating
heavy equipment.

Do not park project vehicle within 25 ft of parked
heavy equipment or within 7 ft of the track (50 ft
of track at rail grade crossings).

In excavation areas and off-site locations where
sampling will occur within 25 ft of the track
workers must be Roadway Worker Protection
trained and have eRAILSAFE. If track is active,
track protection is required.

Do not park project vehicle within 7 ft of the
track (50 ft of track at rail grade crossings).

PPE Personal Protective Equipment

Type

Personal Protective Equipment

Description

Required

Dermal Protection

Coveralls

Tyvek in severely impacted areas

Recommended

Sleeved shirt/long pants

Required

High visibility vest, coat - CLASPED

ANSI Class II minimum while working in or
around excavations, active track or in
public right of ways.

Required

Head Protection

Hard hat

Standard hard hat in excavation areas

Required

Hand Protection

Protective gloves

Nitrile for chemical impacts, leather also
suggested if soils are hard

Required

Eye Protection

Safety glasses

Required

Foot Protection

Boots

Steel-toe with defined heel, oil resistant
sole, and at least 6 inches in height for
ankle support. Lace up boots required.

Required

Supplies

Type

Supply

Description

Required

Communication Devices

Mobile phone

Required

Decontamination

Decon supplies (specify type)

Soap and water available for hand
washing

Required

Miscellaneous

Auxiliary lighting

For night work

Recommended

First aid kit

Required

Flashlight

For night work in excavations

Recommended

Air monitoring in areas of high chemical
impacts

Photoionization or flame ionization
detector

Required

Eye wash (specify type)

Bottle

Required

6 Struck by train or on-track
equipment.

-------
Job Safety Analysis

General

JSAID

19445b

Status

Job Name

Environment-Drilling and Soil Sampling Using
HSA Drill Rig

Created Date

3/18/2023

Task Description

Split Spoon Soil Sampling Using HSA Drill
Rig

Completed Date

Template

Auto Closed

Client / Project

Client

Norfolk Southern Corporation

Project Number

30169714

Project Name

NS Hazmat-Palestine OH

PIC

Helmadollar, Rick

Project Manager

Artrip, Jason

User Roles

Role

Employee

Due Date

Completed Date

Supervisor

Active

Developer

Moyers, Samuel

4/1/2023

McDonald, Andrew

HASP Reviewer

Matlock, Zachary

3/20/2023

Roesler, Jerr

Job Steps

Job Step No.

Job Step Description

Potential Hazard

Critical Action

H&S Reference

Working around hollow
stem auger (HSA) drill
rig

Slip, trip and falls from poor
housekeeping

Wear boots with good tread and ankle support.
Keep tools, drill rods/augers, drum lids/rings off
ground and stage neatly. If plastic sheeting is
placed on ground, exercise caution while
working if wet.

Struck by excavation
equipment near or in
excavation areas,

Remain 25 ft from excavation equipment
including the extended reach of any portion of
the equipment unless establishing simultaneous
operations plan with the equipment operator(s).
Wear high visibility clothing and provide auxiliary
lighting at night if drilling near operating heavy
equipment.

Do not park project vehicles within 25 ft of
parked heavy equipment.

Struck by train or on-track
equipment.

If drilling will occur within 25 ft of the track,
workers must be Roadway Worker Protection
trained and have eRAILSAFE. If track is active,
track protection is required.

Do not park project vehicles within 7 ft of the
track (within 50 ft of the track at rail grade
crossings).

Collecting soil sample
using split spoon
sampler

Cuts or scrapes to hands
opening and closing split
spoons

Wear hand protection (i.e.. leather gloves while
handling split spoon). Watch for pinch points
putting the spoon halves together. Avoid
excessive force while attempting to remove soil
from nose of spoon.

Repetitive stress opening and
closing split spoons

Use job rotation while opening and closing split
spoons to reduce stresses on arms and wrists.
Do not hurry through task.

Exposure to potentially
chemically impacted soil

-------

Exposure to potentially
chemically impacted soil

Cleaning split spoons

Wear protective gloves during split spoon
cleaning. Avoid awkward body positions and
repetitive stresses if manually washing split
spoons. If using a pressure washer to clean
split spoons where face shield in addition to
safety glasses. Exercise caution and use spoon
or similar object without sharp (i.e.
knife)/puncturing (i.e. screwdriver) construction
to clear nose of split spoon to reduce potential
for hand/forearm injury.

Noise from drill rig and while
driving split spoons

Wear hearing protection. Set up soil sample
logging, preparation and collection area away
from rig to reduce noise hazards to sampling
workers. Avoid standing near rig while drill and
sampling.

PPE

Personal Protective Equipment

Type

Personal Protective Equipment Description

Required

Dermal Protection

Coveralls

Tyvek in severely impacted areas

Recommended

Sleeved shirt/long pants

Required

High visibility vest, coat-CLASPED

ANSI Class II minimum while working in
or around excavations, active track or in
public right of ways.

Required

Head Protection

Hard hat

standard hard hat in excavation areas

Required

Hand Protection

Protective gloves

Nitrile for chemical impacts, leather for
handling split spoon

Required

Eye Protection

Safety glasses

Required

Face shield

When using pressure washer

Recommended

Foot Protection

Boots

Steel-toe with defined heel, oil resistant
sole, and at least 6 inches in height for
ankle support. Lace up boots required.

Required

Supplies

Type

Supply

Description

Required

Communication

Mobile phone

Required

Decontamination

Decon supplies (specify type)

Soap and water available for hand
washing

Required

Miscellaneous

Auxiliary lighting

For night work

Recommended

First aid kit

Required

Flashlight

For night work in excavations

Recommended

Air monitoring in areas of high chemical
impacts

Photoionization or flame ionization
detector

Required

Eye wash (specify type)

Bottle

Required

-------
Job Safety Analysis

General

JSAID

19445a

Status

Job Name

Environment-Surficial soil sampling

Created Date

3/18/2023

Task Description

Surficial soil sampling using spoon, spade,
trowel, scoop or similar hand tool.

Completed Date

Template

Auto Closed

Client / Project

Client

Norfolk Southern Corporation

Project Number 30169714

Project Name

NS Hazmat-Palestine OH

PIC

Helmadollar, Rick

(Project Manager Artrip, Jason

User Roles

Role

Employee

Due Date

Completed Date Supervisor

Active

I Developer

Moyers, Samuel

4/1/2023

McDonald, Andrew

| HASP Reviewer Matlock, Zachary

3/20/2023

3/20/2023 Roesler, Jerr

Job Steps

Job Step No.

Job Step Description

Potential Hazard

Critical Action

H&S Reference

Collecting soil sample using
spade, scoop, spoon, trowel or
other similar hand tool.

Slip, trip and falls due to
uneven, or ice/snow covered
walking surfaces

Wear boots with good tread and ankle support.
Avoid carrying supplies in a manner that
obstructs view ahead.

Collecting surficial soil sample

Wear hand protection. Avoid contact stress to
knees if kneeling by using padding. Avoid
squatting for extended periods. Avoid awkward
twists or body postures. If soils are hard with
embedded gravel also consider wearing leather
gloves to protect hands especially knuckles.

Exposure to potentially
chemically impacted soil

Cleaning soil sampling devices

Avoid awkward body positions or excessive
twisting while cleaning sampling devices. Do not
hurry through tasks or create unnecessary
splash hazards by dropping devices in washing
containers.

Struck by excavation
equipment near or in
excavation areas,

Remain 25 ft from excavation equipment
including the extended reach of any portion of
the equipment unless establishing eye contact
with equipment operator(s) and implementing a
communications plan (hand signals, radios, etc.).
Wear high visibility clothing and provide auxiliary
lighting at night. If working near to ground with
operating heavy equipment in vicinity of the
sampling area, consider using a spotter.

Do not park project vehicles within 25 ft of
parked heavy equipment.

Struck by train or on-track
equipment.

Do not park project vehicle within 7 ft of the
track (50 ft of track at rail grade crossings).

PPE

Personal Protective Equipment

Type

Personal Protective Equipment Description

Required

-------
Dermal Protection

Coveralls

Tyvek in severely impacted areas

Recommended

Sleeved shirt/long pants

Required

High visibility vest, coat - CLASPED

ANSI Class II minimum while working in or
around excavations, active track or in
public right of ways.

Required

Head Protection

Hard hat

Standard hard hat in excavation areas

Required

Hand Protection

Protective gloves

Nitrile for chemical impacts, leather also
suggested if soils are hard

Required

Eye Protection

Safety glasses

Required

Foot Protection

Boots

Steel-toe with defined heel, oil resistant
sole, and at least 6 inches in height for
ankle support. Lace up boots required.

Required

Supplies

Type

Supply

Description

Required

Communication Devices

Mobile phone

Required

Decontamination

Decon supplies (specify type)

Soap and water available for hand
washing

Required

Miscellaneous

Auxiliary lighting

For night work

Recommended

First aid kit

Required

Flashlight

For night work in excavations

Recommended

Air monitoring in areas of high chemical
impacts

Photoionization or flame ionization
detector

Required

Eye wash (specify type)

Bottle

Required

-------