Notice of completion and final report for Kennecott work activities related to the administrative order on consent for sludge removal action in Large Bingham Reservoir site no. R3 [part three]

Document issued December 16, 1991, by Kennecott, presenting a work plan for the excavation and relocation of sludge at its Bingham Creek Large Reservoir near Copperton, Salt Lake County, Utah, in advance of converting it into a storm water retention basin. The sludge and tailings in the reservoir were thought to be "nonhazardous." The plan was included as part of the 1994 document, "Notice of completion and final report for Kennecott work activities related to the administrative order on consent for sludge removal action in Large Bingham Reservoir site no. R3." Other parts are in Box 41, folders 4, 5, and 7. The administrative order is part of Box 42, folder 2. Site location maps may be found in Box 49, folder 1. This digital file contains the entire contents of folder 6 from box 37 of the Supefund Records Center records collection.

BINGHAM CREEK LARGE RESERVOIR SLUDGE WORK PLAN Submitted By: Kennecott December 16, 1991 TABLE 1.0 INTRODUCTION 2. 0 SCOPE OF WORK . Objective 2.2 criteria 2 Procedures 3 1 •. 2.1 • 2.3.1 CONTENTS OF . . • . . . . . . . . . . . . . . . . Types Area 3.0 • . . . .. . . . . - . . . . . . . . . . . . and Excavaton .. 2 ...• 2 . . . . .. . . .. 2 2 3 Loading 3 . Personal Protection 3 TRANSPORT PROCEDURES.. 3.1 3 • 2 Types of Haul Route 4 Equipment . . . .. . . Decontamination Procedures 3.4 Engineering Controls Emergency Spill contingency . 5816' WASTE ROCK . DISPOSAL . . SITE. . . .. 4 . . . . . .. 4 . . . . . .. 5 . . . . .. Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4.4 4.5 Personal . . . . Engineering Controls Emergency Spill contingency Plan . . Protection 5 .... . 4.3 SCHEDULE . . Decontamination Procedures . . . 4.2 . . . Placement Procedures. 6.0 . . Sludge AIR MONITORING . . 4.1 5.0 . .... 3.3 3.5 4.0 . of Equipment 2.3.2 Engineering Controls 2.4 . . ...•.. 5 .. 5 6 6 .. 6 . . 6 .. 6 6 ..... OF MAJOR MILESTONES FOR WORK PLAN 7 . APPENDICES: Appendix A: Appendix B: Air Sampling Health and and Safety Plan Analysis Plan . . . . . . . 14 8 1.0 INTRODUCTION The Bingham Creek Large Reservoir is located approximately one-half mile southeast of Copperton, Utah within the Bingham Creek drainage. It encompasses an area approximately one-half and one-quarter mile in width. mile in length (east-west) The Construction of the reservoir was completed in 1965. waters from excess leach reservoir collected previously Kennecott Utah Copper (KUC) mining operations but now collects only storm water runoff. The excess leach waters contained dissolved and suspended solids that have precipitated, forming Since April 1991 the leach sludge in the reservoir bottom. double-lined have been diverted to a waters smaller, impoundment referred to as the Small Reservoir. to occurred activities which prior m1n1ng operations resulted in the deposition of tailings Some in of these (bonification wastes) Bingham Creek. tailings were ultimately deposited at the mouth of the canyon Historical Kennecott's behind three small dams in the area of the current reservoir. Large Reservoir was constructed in 1965, those located tailings directly beneath the Large Reservoir dam were excavated and relocated. The excavation was necessary to a base solid for The dam provide stability. remaining and were material left undisturbed in the tailings underlying area which subsequently became the water reservoir behind the The dam. tailings deposit behind the dam of the Large Reservoir has a measured thickness of between 4 to 20 feet and is estimated to contain 800,000 to 1,000,000 cubic yards as determined by soundings and isopach mapping. At the time the thick, continuous copper tailings are found in broad, beneath the The the copper between sludge. deposits boundary and the is identifiable as is the tailings sludge clearly between the and the soils. The boundary tailings underlying are and and are medium tailings brown, copper orange grained (fine to medium sand). The sludge is yellowish-orange and extremely fine grained (clay to silt) with large amounts of The has a iron. low shear sludge very strength with approximately 10 to 20 percent solids. The The sludge contains runoff water. The zero to ten feet. and arsenic will safety metals precipitated thickness The of be used guidelines. The not data Lead indicator metals for health and Characterization Sludge Report, as demonstrating exhibit hazardous leach and storm from sludge layer varies average pH of the sludge is 3.0. submitted to the USEPA and State of Utah provides from the that the characteristics. 1 on October sludge and 15, 1991, tailings do 1991 completion of construction of the smaller Current plans are to drain the Large water reservoir. process the reline and the remove tailings, Reservoir, sludge reservoir base, and establish the reservoir as a storm water retention basin as part of the KUC stormwater control program. with the The stored water in the Large Reservoir is currently being Inflow is removed and added to the leach application circuit. being treated and disposed through the Copperton tailings Inflow water pumped to the tailings line is discharge line. adjusted to a pH of 8 with lime before mixing with the Concentrator UPDES activities These tailings. are wi thin KUC' s permit. small amount of sludge was removed from the Large Reservoir 1990 and a coffer-dam was constructed in that area to prevent Bingham Creek storm water from entering the Large Once sufficient water is removed, sludge removal Reservoir. and relining of the reservoir will begin. A during This work plan addresses removal of approximately 350,000 CY of nonhazardous sludge and underlying nonhazardous copper from the west end of the reservoir (Drawing No. 451tailings Removal the material will facilitate construction of T-377). of an HOPE lined storm water collection system scheduled to be Future completed at the end of the 1992 construction season. actions will address the remaining sludge and tailings in the eastern end of the will Kennecott of placement Large Reservoir. perform the reservoir and excavation, transport, sludge and associated underlying and health procedures, safety the Removal tailings. and air monitoring requirements, copper methods specified in this during removal consistent with those used Plan are actions conducted by KUC at similar sites. Work 2.0 SCOPE OF WORK work to be completed under this Work Plan includes the excavation, transport of sludge from the Large Reservoir, and placement at the 5816' level waste rock disposal site. The boundaries between the sludge and underlying copper tailings and between the copper tailings and the underlying soils are generally very definite, but due to the nature of excavation techniques and to ensure complete removal of all sludge and tailings, some portion of underlying soil will be removed. The material the 350,000 CY contain sludge, copper tailings, Therefore, of 2 and to some be excavated soils. will Work Plan allows essential field discretion for the on­ site specific site coordinators to adjust operations for circumstances. The 2.1 Objective The the objective of this work is to remove the western portion of facilitate and Reservoir tailings to sludge Large construction of 2.2 lined storm water collection basin. a criteria Based conducted excavated to and placed possible site. Approximately overexcavation sludge 2.3 and investigations can the on be 5816' level inches to the six and similar removal sludge and tailings will tailings/native soil interface the elsewhere, close as field of results on actions expected and waste will foot be removed as disposal rock one be soils with the of tailings. Procedures be removed The sludge and associated copper tailings will using appropriate excavation and transport equipment depending and the the characteristics of the underlying tailings on the time removal. of water- to-solids ratio of the sludge at Overly wet materials may require dewatering, stabilization, or other handling beyond that specified below. Types of Equipment 2.3.1 A dozer, excavator, an appropriate for removing and the front-end sludge push material into will loader and The tailings. loading area be dozer and the haul load the units. The dozer loader and/or excavator will haul traffic and build access the area for will prepare ramps. The excavator will be used to manipulate and stabilize the sludge and tailings and to load trucks in appropriate areas. The excavator and dozer will be used to recontour the area, as will be used to a necessary. such as a motor grader, will be employed to shallow material in broad, flat build and areas, and build containment haul maintain as roads, berms, site conditions allow more than one specific may appropriate. be excavation to of area This managed concurrently. be evaluated once will removal activities opportunity Other equipment, remove commence. The amount and type daily. 3 of equipment will be evaluated 2.3.2 Engineering Controls - Excavation and Loading Area The reservoir sludge contains a large amount of water, so the use of engineering measures to control waste dispersal during excavation and loading is anticipated to be minimal. If the to material does dry and becomes a threat air quality, be to controls will ensure that both engineering implemented and airborne emissions from the work occupational exposures and zone are below accepted levels for TSP, arsenic. The lead, levels for and arsenic, as indicator metals are 30 Permissible Exposure JJ.g/m and five JJ.g/m, respectively. Limit (PEL) for TSP is 15,000 jJ.g/m. Controls which may be used include water sprays, covers and shields, applications of Because cohesive agents, and materials handling restrictions. the within the contained excavation is Large completely Reservoir, there is no possibility of surface water runoff. Precipitation that may accumulate in the excavation will be removed daily to the Large Reservoir pool. acti§'n 2.4 lad 3The Protection Personal basic OSHA personal protective equipment (PPE construction safety equipment) will be appropriate for workers engaged in transportation activities. The reservoir sludge has an average pH of 3.0 and if splashed onto personnel in the work zone, may cause skin irritation on contact. The depressed The sludge and pH is the result of sulfuric acid formation. contain metals. Personnel also involved in heavy liquids and excavation in a closed activities (unless cab) will ground be required to wear Level D PPE supplemented with rubber rinseable rubber and coveralls, boots, gloves, goggles. be will Personal protective equipment upgraded based on Level D - results from air monitoring, if necessary. A site-specific Health and Safety Plan based on available information from all investigative activities completed to date is presented as Appendix 3.0 B. TRANSPORT PROCEDURES associated copper tailings will be hauled from within the work zone to the 5816' waste rock loading site using appropriate haul trucks. Haul truck size disposal due to space limitations at the dump and loading area may vary and other site access requirements, but will generally be 15 Sludge and areas - 20 CY dump trucks. consistency of the sludge at the time of removal may necessitate mixing of the sludge with the tailings to If required, the mixing will take place facilitate handling. within the excavation area. The 4 the short haul distance (less than one mile), the high content of the sludge, and because haul units will not leave KUC property, it is generally not necessary to tarp haul trucks. Haul trucks will be covered or tarped from the loading zone to the 5816' waste rock disposal site if release Due to moisture of 3.1 airborne particulates is evident. Types of Equipment of 15 to 20 CY will be used to load material from the loading zone to the 5816' waste Where access and feasibility permits, rock disposal site. transports will be loaded and will directly haul to the dump The site, eliminating the need to stockpile material. transports will have secured, water tight gates and will be Transports with capacities and haul tarped, if necessary. Smaller trucks with capacities of 8 to 10 CY may also be used to transport excavated material from constricted areas to the loading zone for off-haul by the larger transports. As conditions dictate, the size and types of equipment may be modified to match site conditions. 3.2 Haul Route Excavated directly material to 451-T-375). the will 5816' be transported Haul routes may from the reservoir site disposal (Drawing No. to address site require adjustment waste rock conditions. Dirt haul roads in the work zone will have berms on both sides to contain any spillage that may occur. Engineering controls will be implemented to control dust emissions from the haul as roads required. Once removal activities are complete, roads will be decontaminated, if necessary. haul unpaved 3.3 Decontamination Procedures loading and hauling procedures will be implemented to and tracking the material from the work zone. Construction of clean, dry access roads to the loading zone is planned. These access roads will prevent project vehicles from traveling over and tracking sludge. As the loading zone is Careful prevent spills moved to accommodate excavation, the access roads will be adjusted accordingly. Haul roads will be decontaminated if visual inspection of the the cessation roads at of haul the removal activities indicates spillage or tracking of waste materials. any Decontamination will consist of removing any material that may 5 have 5816' 3.4 spilled enroute. This material will be disposed of at the waste rock disposal site. Engineering Controls and dumping transportation, During excavation, loading, water as such controls application operations, engineering will be implemented as appropriate. Engineering controls will ensure that occupational exposures and airborne emissions are 3.5 levels below acceptable total airborne dust. the for contaminants of and concern Emergency Spill Contingency Plan Any accidental spills material of transportation will be responded following measures will be implemented: All • truck appropriate spill. notify will transports be personnel occur during may The Kennecott. by that to equipped with in the radios event of to an accidental All truck • transports carrying sludge and tailings will be equipped with secured gates to reduce the an accidental spill. Appropriate equipment will be available from the removal site to respond to any emergency spill situations. • 4.0 possibility of 5816' WASTE ROCK DISPOSAL SITE level waste rock disposal site is the easternmost Kennecott waste rock disposal area. The waste rock disposal site is contained within Kennecott's present leach collection system and a dirt haul road provides vehicle The 5816' bench of the access. 4.1 Sludge Placement Procedures waste rock disposal site will receive approximately 350,000 CY of sludge and associated copper tailings from the Large Reservoir. Sludge placement operations will progress from the back end of the designated disposal zone to prevent the haul units from traveling over the material that has been previously disposed. The haul units will be restricted to clean access roads at the disposal site to prevent tracking of The 5816' sludge and to keep physical decontamination procedures minimum. 6 to a that is placed at the 5816' waste rock disposal site will be graded and can be mixed with waste rock or other material to stabilize and prevent erosion if such mixing appears necessary. If necessary a crusting agent will also be used to control airborne emissions from the placed sludge. The material 4.2 Decontamination Procedures See 4.3 Engineering See 4.4 sections 2.3.2 and 3.4. section 3.5. Personal See 5.0 Controls Emergency Spill Contingency Plan See 4.5 Section 3.3. Protection section 2.4. AIR MONITORING Air monitoring will be conducted by Kennecott at the excavation site, along haul routes, and at the 5816' waste rock disposal site to assess levels of indicator metals and total airborne dust. Quantitative air monitoring will be project personnel appropriate monitoring equipment. conducted to document exposure levels using Samples of ambient air at the perimeter of work zones will occasionally be collected during excavation and placement work Air activities. samples will be collected and analyzed the to Sampling and Analysis Plan included in according A. Appendix 6.0 SCHEDULE Work will Removal months. MILESTONES FOR WORK within weeks MAJOR OF begin two of PLAN approval to proceed. of sludge and tailings is projected to require four Construction of the intermediate earthen embankment lining of the storm water reservoir bottom is projected to Unexpected adverse weather approximately 10 months. could extend this period of performance by as much as 3-4 and take months. Although not and tailings expected the this work plan, removal of sludge remainder of the Large Reservoir is subject of from the to take about 10 months, 7 assuming a similar disposal construction of the liner in the remainder of the scenario. Large Reservoir is projected to take an additional 10 months. 8 APPENDIX A AIR 1.0 SAMPLING AND ANALYSIS PLAN INTRODUCTION monitoring samples will be collected at the work zone and to monitor airborne emissions during site Dump and excavation and associated tailings copper sludge HFS 113 Gilian be conducted The will using sampling placement. 113A hi-flow and Gilian 520 AC hi-volume pumps to draw air through sampling media. Quantitative air sampling will be used Air the 5816' Level to monitor employee exposures, the dump site. perimeter The work zone boundaries, and the of monitoring is purpose of air • Document employee • Document work-zone exposure, and dump threefold: if any; site particulate emissions; and • 1.1 AIR BACKGROUND effectiveness the Evaluate SAMPLING of engineering controls; PROCEDURES Background air samples will be collected prior to any removal, hauling or placement activities. Hi-flow (2.0 L/min) and hi­ volume (20.0 L/min) samples will be collected at the removal work zone and at the 5816' Dump site. The background samples set to use be will concentrations. 1.2 PERSONAL AIR SAMPLING a datum for airborne particulate PROCEDURES monitoring will be performed with hi-flow personal sampling pumps drawing air through sampling media following National Institute for Occupational Safety and Health (NIOSH) methodologies. Sampling procedures may be altered at the field of discretion sampling personnel as Site-specific conditions warrant. NIOSH sampling results are quantitative Personal and will quality 1.3 WORK Air be to used document and worker exposures. SAMPLING PROCEDURES ZONE samples will be collected work at the air and dump site removal and placement zone determine possible) particulate emission and document work zone air quality. The samples will be collected with both hi-flow and hi-volume sampling pumps drawing air Institute for through sampling media following National occupational Safety and Health (NIOSH) methodologies. Sampling work zones to 8 procedures may be altered at the discretion of field sampling personnel as Site-specific conditions warrant. 2.0 AXR PROCEDURE SAMPLXNG The following standard operating procedure (SOP) followed for all quantitative sampling conducted. 2.1 AIR SAMPLING The following collected be for all SEQUENCE sequence of will events be followed air samples. at the beginning of the day; 1. Fill out 2. Calibrate 3. Unplug 4. Document initial information about the individual logbook header sampling cassettes calibrations, diagram; and pumps; and in conditions and start turn on pumps; field logbook, and locations times, required blank (1 per a sampling pump. placed 10 samples) is samples including a Ensure 5. will a map or opened and near At days end: off pumps, Turn 6. stop time in field log, record and plug cassettes; 7. Recalibrate pumps and record information in both the field logbook and the calibration documentation forms; 8. Place 9. Prepare chain of custody forms for all samples; 10 . Either the pumps securely including chain events Sequence are on charge overnight; store of or, package and and ship samples, in the following custodies. described in detail sections. 2.2 LOGBOOK HEADER up-to-date sampling field notebook will be maintained by project personnel during all sampling activities. The general An information recorded for each day's 9 sampling includes: • Date; • Name of overall sampling event; Sampling personnel; • Climatic conditions; and Equipment calibrations. • • 2.3 PUMP CALIBRATION a pumps will be calibrated using a graduated buret and standard available or solution primary commercially soap calibration device. with the first method, the pump is hooked mouth up to an inverted buret, air is drawn through the open is formed with the soap and a soap bubble of the buret, solution across the buret mouth. As the bubble moves across two pre-determined graduations on the buret, a stopwatch is Air elapsed time. From the graduated volume and the volume per time, or flow, can be calculated. as form calibration a data on calibration this Enter documentation. Pumps are calibrated both before and after used record to elapsed time, each sampling A rotameter, the against rotometer soap 2.4 day. secondary calibration device, a buret has the bubble-buret SAMPLE LOGBOOK then and used advantage of can calibrate to simplicity be calibrated each and pump. speed over The the technique. ENTRIES Quality assurance and quality control (QA/QC) procedures for air sampling require completion of a Field Sampling Log. For each sample collected (including blanks), the logbook must contain: • Sample number; • Sampling location; • stop calibrated air air flow; Average Start and stop time; • • • • • • Start and flows; Sampled volume; Sampling method (i.e. NIOSH)i Field observations; and A map or diagram. deviations Significant from sampling protocol shall be formally noted in the field log, along with visiting personnel and 2.5 unusual circumstances which might affect the sampling. QC BLANKS One QC blanks blank are should unsampled be submitted with cassettes 10 that each are 10 samples. returned to the The lab with 2.6 samples transport. sampling and CASSETTE LABEL To as test a for prevent sample misidentification, affixed with recorded on label. a The Sampling following pump identification cassette number; and Sample Chain-of-custody number. CHAIN OF each sample during is will. be cassette information sample collected; Date • • contamination sample container: the • • 2.7 other the number; CUSTODY documentation necessary to trace the sample a of the time from chain-of-custody collection, possession record will be filled out for each sample and accompany every The record will include the following: set of samples. To project number; analysis request; • The • Air sample • Sample number; rate; Length of sampling time; Signature of the collector; Sample date; in the chain involved of person(s) Signature and possession; Time(s) and date(s) of change(s) of possession. • • • • • • 2.8 establish Flow SAMPLE PACKAGING AND of SHIPPING be packaged in clean areas that are remote from sources. contaminant Packing material will be used potential to stabilize the cassettes during shipment. Samples will be delivered or shipped for analysis once a sufficient amount of Samples will cassettes 2.9 have been collected. ANALYTICAL METHODS samples collected using NIOSH methods will be analyzed (as indicator metals), and total airborne dust (see Appendix B, section 3.2). Samples collected early in the removal action may be analyzed for a suite of metals, determined at a later date. Samples will be analyzed using NIOSH standard methods. Samples for total airborne dust will be collected using cassettes containing pre-weighed filters, and will be analyzed gravimetrically. The air for lead and arsenic 11 3.0 QUALITY ASSURANCE AND QUALITY CONTROL The purpose of data quality assessment is to assure that data generated during the QA program is accurate and consistent be The quality of the data will with program objectives. a is assessed based on accuracy and completeness. Accuracy to true is the determination of how close the measurement value and will be assessed by the cleanliness of blanks. Completeness is a measure of the amount of valid data obtained, compared to the amount that was expected under normal conditions. Ninety (90%) percent completeness is the goal of this plan. The project data objectives for accuracy and completeness are consistent with guidelines established by NIOSH and OSHA. 3.1 SAMPLING CALIBRATIONS sampling pump flow will be calibrated following NIOSH The pumps will be calibrated at the beginning and cassette used for The of end pre­ sampling each day. calibration will also be used for post-calibration. The two Personal protocol. calibrations must for that sampling 3.2 be within 20% of each other pump will be invalidated. or the day's QC SAMPLES quality-control checks will be conducted to evaluate the quality of data based on field conditions and constraints. Internal QA/QC program will be conducted in addition to laboratory QA/QC. The following quality-control check will be The field performed: • Field Blank Opened but unsampled cassette placed near an active sampler and returned to the lab with the other - samples as transport. • Trip same test a for contamination during sampling returned to - the lab as handling and/or prior to a test for is subject to the trip blank is contamination during Unopened cassette that handling as sampled cassettes. Blank and The receiving the cassette from the lab. above internal QC samples will be evaluated to determine if the field and transport procedures are adequate to provide valid analytical data. The evaluation process for QC samples is outlined below. The One field blank for each 10 or trip blank will samples. 12 be collected and analyzed 3.3 DATA REDUCTION, VALIDATION AND REPORTING reported in appropriate units. All raw data will be reviewed and validated against calibration records to All data will that ensure be data are reliable and that the data are in copy of objectives. Upon completion, compliance be retained future will for the signed laboratory report and measurements data field reference. Raw from sample collection activities that are used in project reports will be with QA/QC a appropriately identified. QC records, showing accumulated prec1s10n and accuracy data, will be maintained in the laboratory and reported along with results. analytical problem 3.4 be Poor quality results require that the determined and corrected. QA REPORTS TO MANAGEMENT laboratory reports will be submitted to the review; issues requiring clarification will then be addressed. Following review by the QA/QC Officer, final field and laboratory reports will be submitted to the Final field and QA/QC Officer for Project Manager. 3.5 CORRECTIVE MEASURES detect conditions or data corrective action will be QC requirements, The nature action will depend on the initiated. of the circumstances of each situation and may include: If QC system or performance audits that do • and and Evaluating amending sampling analytical and procedures; Accepting data, acknowledging level of uncertainty. • not meet 13 APPENDIX B HEALTH AND 1.0 SAFETY PLAN INTRODUCTION All activities to be conducted will be in conformance with the Kennecott Utah Copper Environmental Response Health and Safety This appendix represents the Site-specific Health and Plan. Safety Plan, which applies to activities related to the sludge and associated tailings removal, haulage, and placement in the Rock Disposal site on Kennecott property, employees, contractors, and subcontractors of Kennecott. This plan will be available at all times at the for review work area contractors, employees, by or representatives subcontractors, agencies, regulatory thereof. All visitors and regulatory personnel are expected to be familiar with and comply with all aspects of this plan. 5816' Level conducted Waste by The Health and Safety plan is designed to identify, evaluate, and control health and safety hazards associated with this project. The plan is based upon existing information regarding the Site, similar work conducted elsewhere in the reservoir, and past experience at other sites. Specific safety and health hazards and conducting procedures the project necessary to protect the are addressed. of employees It is anticipated that site conditions may project. As actual site conditions change, vary during the sections of the and will be subject to Health and Safety Plan may change, approval by the Health and Safety Officer. Such changes will be 2.0 communicated to all employees. COMPREHENSIVE WORK PLAN comprehensive work plan for the operations to be conducted precedes this Health and Safety Plan. The work plan describes work tasks, objectives, personnel requirements, and methods for conducting excavation, haulage, and placement of sludge and associated copper tailings in the dump site. A 3.0 JOB HAZARD ANALYSIS potential hazards associated with site activities include chemical and physical hazards. Equipment operators and laborers directly involved in project activities have the greatest potential for exposure to these hazards. Haul truck operators have lower potential exposure to these hazards. The both 3.1 PHYSICAL This HAZARDS section describes construction-site physical normal hazards. Heat 3.1.1 Heat Stress stress is a potential hazard associated with elevated body temperatures caused by high ambient air temperatures, heavy physical labor, and/or any combination thereof. This hazard will be evaluated on a day-to-day basis. 3.1.2 Cold Exposure injury (frostbite and hypothermia) and impaired work ability are potential hazards at low ambient air temperatures Cold when the wind chill factor is evaluated on a day-to-day basis. or 3.1.3 low. hazards These will be Inclement Weather Heat stress and other heat related hazards are not anticipated to pose a threat as the project is expected to occur during January to March. Rain, snow, extreme low temperatures, or high winds may occur during scheduled work activities. All employees will be trained in the hazards of exposure to cold and/or wet conditions. Protective clothing for cold and/or wet conditions will be used when needed. Severe weather conditions may result in cessation of work activities at the discretion of the Project Manager, Construction Superintendent or Health and Safety Officer. 3.1.4 utility Lines Overhead utility lines should not pose hazard. when 3.1.5 working around are present near the work area Appropriate precautions will but be taken overhead utilities. Noise elevated noise is expected for heavy-equipment This hazard will be controlled by wearing hearing operators. Either ear plugs or muffs will be encouraged for protection. Exposure to heavy-equipment operators, laborers, working near the equipment. 3.1.6 and any other personnel Construction construction Sites, there is potential for personal American National Standards Institute (ANSI) approved injury. be will required. Hard hats, steel toe boots, and equipment safety glasses will be required to guard against head, foot, and eye injuries. Applicable MSHA and OSHA guidelines will be followed. As on all Suppression Dust 3.1.7 Dust be may of placement vehicles, generated during excavation, transportation and Water material. tarping of transport spray, as other controls will be used, or necessary, to reduce dust levels. Air monitoring will be conducted to ensure occupational exposures to emissions from the work zone of are below accepted safe levels. The OSHA Permissible Exposure Limit Particulates (TSP) for 3.1.8 Other time-weighted 8-hour any Physical for Total (PEL) Suspended micrograms per cubic meter in air is 15,000 average CFR (29 1910.1000). Hazards physical hazards such as construction occur during Other stings, etc. may operations. placement insect bites, and Precautions will be taken to prevent these hazards. 3.2 CHEMICAL HAZARDS Based on contaminants the information available Site, regarding and in the identified sludge tailings are lead, iron, barium, cadmium, copper, manganese, and zinc. In selenium, silver, nickel, sulphur, mercury, addition, the sludge has a low average pH. Arsenic and lead arsenic, indicators due to their low additional chemical hazards become evident, appropriate measures will be taken to protect the health and safety of personnel on the site and prevent off-site migration. All employees will be notified of any new selected as Levels (AL) and hazards 3.2.1 hazard been have Action as they PELs. If become known. Arsenic Arsenic is a solid material with irritation of system and skin. the cause hygiene personal problems and when inhalation Excessive such extreme eyes, of ingestion. Some mucous Dermatitis arsenic chest coughing, weakness preceding around a carcinogen: a respiratory result from these materials. result poor in respiratory pain, giddiness, headache, gastrointestinal symptoms. in loss, weight nausea, may can result exposure Prolonged of diarrhea, pigmentation skin, and considered membranes, also can working as Potential exposure Skin contact can arsenic compounds may odor. no routes are through inhalation or also result in adverse effects. loss of hair. cancer-causing Arsenic is substance. The OSHA AL for arsenic is 5.0 micrograms per cubic meter in air for an 8-hour time-weighted average (29 CFR 1910.1018). The OSHA PEL for arsenic is 10 micrograms per cubic meter in air for an 8-hour time-weighted average. 3.2.2 Lead Potential exposure solid material with no odor. or inhalation ingestion. The early effects through of overexposure to lead are nonspecific and are difficult to distinguish from the symptoms of minor seasonal illnesses, is Lead routes a are by laboratory testing. The symptoms are decreased physical fitness, fatigue, sleep disturbance, headache, aching except abdominal pains, and decreased appetite. include anemia, pallor, a "lead Line" on colic Lead hand and decreased the grip strength. gums, produces intense abdominal pain with nausea and vomiting. and bones muscles, More advanced effects convulsions, Headache, is Lead occur. classified as not coma, delirium, kidney damage can carcinogen but it is and a considered toxin and reproductive a a teratogen (fetal malformation). micrograms per cubic meter in air for an 8-hour time-weighted average (29 CFR 1910.1025). The OSHA PEL for inorganic lead is 50 micrograms per cubic meter in air for an 8-hour time weighted average. The 3.2.3 for OSHA AL lead is 30 pH pH is a measurement of the The level of the scale runs acidity from 1 or alkalinity strongly pH of 7 is neutral. A pH alkaline). (very strongly acidic) Substances that are strongly acidic or alkaline may cause irritation to burns when they contact human skin. There are no OSHA regulations for different pH levels. Obviously common is sense required when dealing with strongly acidic or alkaline materials and will be subject to approval by the of a substance. to 3.3 (very 14 Safety Officer. Health and Hazard Mitigation the above and identified in hazards sections, any additional hazards which arise or are identified during the work, will be mitigated by personal protective equipment (PPE), engineering controls, and other safety procedures. Physical hazards will be mitigated by the implementation and standard operating procedures described of enforcement in hazards will be identified through the 9.0. Chemical section air monitoring program described in Section 7.0 and mitigated by the use of engineering controls. The 4.0 PERSONAL PROTECTIVE EQUIPMENT exposures to arsenic, lead, and TSP are expected well below action levels specified in CFR 1910.1018, 1025, and 1000, respectively. The acidic nature of the sludge and associated tailings warrants protection for skin which might contact the sludge and tailings. The high iron content Occupational to be associated tailings gives them a strong staining ability. The stains are not physiologically hazardous but hands and clothing may be stained by this material. Therefore, the level of personal protection to be utilized for Level D personal all initial site activities is Level D. a hard hat of consist shall (ANSI protective equipment (PPE) boots (ANSI Z41 steel-toed Z89), safety glasses, (ANSI Z87), cotton 6-inch with sUbstantial leather gloves, uppers), of the and sludges coveralls, and hearing protection as necessary for workers who or in an enclosed machinery cab. in the work zone will be required to wear steel-toed, calf-high rubber boots, rubber work gloves latex liners inside a cotton or leather work gloves and or Work zone visitors will be required to washable coveralls. remain out of the work zone Workers who must be foot on gloves or coveralls, unless of The level material. sludge handling they results of to be will employee according adjusted protection monitoring, specif ic job functions, or as site exposure conditions change. wear the rubber boots but not the will 5.0 TRAINING All the be REQUIREMENTS project employees Hazardous Substance will receive Awareness as a Training. minimum All 8 hours of and employees in the excavation and placement of sludge associated and copper tailings will be required to have 40SUbstance hazardous hours of training. Employees will be to level a trained required by their job function and before being permitted to engage in field responsibility activities. Pre-employment safety information will include: supervisors working of and alternates responsible for site • Names • safety and health; Chemical and Physical Hazards present on the Site; Work practices by which risks from hazards can • personnel be minimized; • Detailed review of this Site-specific health and safety plan; • Safe use of engineering controls and equipment on the site; • • Use of Personal Protective Equipment; and Medical surveillance requirements, including recognition of symptoms and signs which might indicate overexposure to hazards. site safety meetings will be held at least weekly to notify personnel of specific hazards, air monitoring results, changes in Health and Safety Plan, or other topics determined by the site Health and Safety Officer. Specific meetings will be held initiation of new or different field activities and at time of any crew changes. the at the 6.0 DECONTAMINATION PROCEDURES Equipment decontamination will be conducted on site as of consist will decontamination appropriate. Equipment contact from contamination visible points physically removing at the equipment of completion of work tasks and before leaving the work area. removing and leaving good personal hygiene. Personal decontamination will consist of outer PPE the at work and zone Employees will be required to wash with soap break lunch and period A decontamination work area Outer zone. and at the end of will be set up at the PPE (rubber boots, and water at each the work shift. perimeter of the gloves and washable the remain in be removed and will will coveralls) area have decontamination will area. The decontamination facilities for washing exposed skin. Workers and visitors will be required to pass through exiting the work zone. and use the decontamination area when Decontamination procedures will be monitored by the Health and such If Safety Officer to determine their effectiveness. will be altered found to be are ineffective, they procedures to correct any deficiencies. 7.0 AIR MONITORING Air monitoring will be conducted to evaluate the potential for employee exposure and to determine the overall contribution of to air Prior to ambient activities work quality. any activities on Site, background air samples will be collected around the perimeter of the work zone and dump site areas. During placement activities, qualitative and quantitative air sampling will be conducted to determine employee exposures. All air samples will be collected and analyzed according to the appropriate National Institute of Occupational Safety and method for Health (NIOSH) determining concentrations of 7.1 arsenic, lead, Appendix A to and total the Work suspended particulates Plan). (TSP). (See Occupational Air Monitoring Quantitative personal samples will be collected using constant-flow pumps calibrated using a rotameter or tube" to draw between 1.0 and 2.0 liters of air per Gilian "bubble minute. be handled under will samples chain-of-custody procedures and delivered to a qualified laboratory for analysis. (See The Appendix A to the Employees with selected for activities Work the highest potential for exposure will be monitoring. At the start of field periodically thereafter, occupational air personal and Plan) samples will again be collected and analyzed for arsenic, lead Additional air monitoring will be conducted whenever there is a change in work conditions which can be expected to result in new or additional exposure levels or whenever an employee complains of symptoms which may be attributable to exposure to lead or arsenic. and TSP. Qualitative real-time effect of 8.0 MEDICAL air monitoring will be conducted zone which measure the using light-scattering particulates. PROGRAM SURVEILLANCE A medical of work instruments provides a means of selection physically able to safely perform the surveillance program who employees are assigned and monitor their health on a regular basis. medical surveillance program to be implemented for this project will comply with 29 CFR 1910.120(f). work The The program consists of a pre-employment medical evaluation to determine fitness for the job assignment, an annual evaluation based on and an end-of-employment length of assignment, a In addition, special evaluation is warranted employee indicates that they may have developed evaluation. when an resulting symptoms from a possible exposure to hazardous sUbstances. Medical surveillance will be conducted for all site personnel who may be exposed to arsenic and lead in excess of PELs, without regard to the use of respirators, for 30 days or more in the medical All participating personnel year. per surveillance program will have an examination which equals or exceeds • • • • • following: the Medical and occupational History; Examination; Physical Pulmonary Function Test; Six Frequency Audiogram; Urinalysis, with microscopic morphology • Complete • CHEM • SAM • • Blood and dipstick; Count; Chemistry Screen; Drug Screen; Chest X-Ray; and 20 10 Blood lead and 24-hour urine arsenic levels contractor personnel with the potential for chemical exposure are required to have medical monitoring which equals exceeds this program. Visitors and regulatory personnel or who will enter the work area may be required to demonstrate participation in a medical program which is equivalent to or this program. The Health and exceeds Safety Officer will All determine which personnel monitoring requirements. must meet training and medical­ all employees with evaluation baseline have a will exposure potential conducted for lead levels in blood and urine arsenic levels. These evaluations are to be repeated at the completion of work activities or end of employment, as deemed necessary by the Health and Safety Officer. project activities, Prior to the start of for Copies of the of the physician's individual to written opinion for the capability in areas with a potential for work arsenic and lead exposure and the ability to wear a respirator will be maintained by the Health and Safety Officer for all workers on site. 9.0 WORK PRACTICES STANDARD OPERATING Standard operating procedures and safe work practices for this PROCEDURES/SAFE project consist of Kennecott General Safety for Contractors in addition to the following: • alcohol, firearms, or illegal drugs will be allowed on Anyone reporting to work under the influence of be will alcohol discharged drugs and/or illegal No site. immediately. • Any under employee a prescribed medication Safety Officer. • Eating and drinking are and • never physician's care and/or taking notify the site Health and must allowed in the removal work only in designated areas or at the dump site. zone listen for All warning signals on personnel shall construction equipment and shall yield to construction equipment. • All equipment operators workers on the ground pay careful attention to in their path and may be All people before moving. shall who warning to these employees working regularly provide on the ground will wear orange vests with reflective tape. Operators shall also pay deliberate attention to all types of utility lines and • All by • sources. required to be familiar with and abide security rules, and emergency procedures. personnel the are All must vehicle personnel report any injuries, illnesses to their This accidents, and/or supervisor. includes minor • All slight injuries. prospective employees must pass a pre-employment and subsequent exams as required by this plan. physical Failure to submit to, for dismissal. • pass, any exam will be grounds the in air-quality personnel must participate monitors wearing personal program by monitoring exposure and the Health site devices or designated by sampling Safety Officer. Any personnel refusing to participate in or who the program, tamper with the sampling devices, will be subject to disciplinary action or expulsion from All the • or site. personnel must abide by all safety rules and rules work described the in as and/or procedures throughout the project. All