ZS-SA-01 ZION RESTORATION PROJECT HEALTH ...Have the courage to speak up when you see or believe...

ZS-SA-01

ZION RESTORATION PROJECT HEALTH & SAFETY PLAN

Revision 6

Authored By: Signature on File 04 May 2015 Gregg W. Tulley, CSP, RRPT

Manager, Industrial Safety & Hygiene Date

Reviewed By: Signature on File 05 May 2015 James Ashburner

VP of Construction and D&D Date

Reviewed By: Signature on File 05 May 2015 Donald (Nick) Williams

VP Radiological and Environmental Controls Date

Reviewed By: Signature on File 04 May 2015 Tony Orawiec

Decommissioning Plant Manager Date

Approved By Signature on File 12 May 2015 John Sauger

Executive VP and General Manager Date

New Title Change X Revision Rewrite Cancellation

Effective Date: 21 May 2015

ZS-SA-01 Zion Restoration Project Health & Safety Plan Revision 6

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2 MINUTE DRILL AT THE WORK LOCATION Am I on the correct Unit / Train / Component? Are our planned dose reduction techniques appropriate? (Every

Millirem Counts) Are the appropriate Safety barriers in place / available? Are the work conditions as discussed in the Pre-Job Briefing? Are there any operational plant components within 2 feet of my work

area? Do I have the proper PPE? How could I get hurt? What hazards are in the work area? What else could go wrong?

Hazard Assessment Body Positioning – Avoid Line of Fire Environment

Any Adjacent Work Activities in Progress Chemical Spills Falling / Dropped Objects / Suspended Loads Lifting Angle Acceptable Live Electrical Pinch Points / Clearances Projectiles (system under pressure, sprung piping) Sharp Surfaces Spotters used when appropriate

Adequate Means to Enter & Exit Adequate Lighting & Ventilation Fall Hazards Good Housekeeping Noise Levels Interfere with Work Obstructions (pipes, beams, etc.) Sharp, Hot, or Wet Surfaces Slip / Trip Hazards Thermal Stress (hot or cold)

Key Fundamental Behaviors

ALWAYS wear seat belts when operating heavy equipment. ENSURE equipment is in a safe condition prior to starting work. NEVER leave equipment in a raised position, and SET the parking brake. NEVER proceed when faced with uncertainty. Always STOP work and PLACE equipment

in a safe condition. SEEK guidance and assistance from Supervision. STOP and CORRECT unsafe behaviors or conditions. STOP and REPORT equipment abnormalities.


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To: All ZionSolutions Employees and Subcontractors

From: John Sauger, Senior Vice President and General Manager

Subject: Safety Policy

I am responsible and accountable for establishing and maintaining a safe work environment at Zion. Sounds pretty basic and you might interpret it as management speak. Let me explain what this means in practical terms:

Working with the management team

I must provide training for every individual that works on this site that addresses and manages the hazards you may encounter by working here. I recognize that our bargaining unit employees receive excellent general and specific training at the halls. We have to take the next step and expand on this training and make it specific to Zion.

I must develop goals and objectives for safety performance that are realistic and measurable.

I must foster and support an environment where any employee is empowered to stop and ask questions without fear of retribution.

I must support a culture that has a passion for improvement in safety. Specifically, we must investigate and learn from every safety event in an effort to prevent recurrence.

We seek to deliver a clear and consistent message around safety. We care about outcomes but more importantly we care about each and every one of you that work on this site.

This HASP booklet is intended to give you specific information about the safety plan at Zion. Refer to it often and ask questions when you are unsure of what you should do. Do not proceed in the face of uncertainty.

I ask that you do one thing for yourself and your work crew. Care enough to act. Care enough for not only your safety performance but also that of your work mates and everyone that works at Zion. Have the courage to speak up when you see or believe that we could do some task with a higher degree of safety added in.


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TABLE OF CONTENTS

1.0 PURPOSE AND SCOPE ....................................................................................................... 8

1.1 Purpose ......................................................................................................................... 8 1.2 Site History ................................................................................................................... 8 1.3 Scope of Work .............................................................................................................. 9 1.4 Site Description ............................................................................................................ 9

2.0 REFERENCES........................................................................................................................ 9

3.0 GENERAL ............................................................................................................................. 12 3.1 Definitions .................................................................................................................. 12 3.2 Industrial Safety & Hygiene Program Responsibilities ............................................. 15 3.3 Precautions and Limitations ....................................................................................... 18 3.4 Document Control and Records ................................................................................. 19

4.0 REQUIREMENTS AND GUIDANCE .............................................................................. 20

4.1 OSHA Regulations ..................................................................................................... 20

4.2 ZionSolutions Industrial Safety & Hygiene Job Aids, Policies, and Procedures ...... 21

4.3 Resolution of Conflicting Requirements .................................................................... 21

4.4 Work Planning ............................................................................................................ 21

4.5 Stop Work Authority .................................................................................................. 21

4.6 Incident Reporting ...................................................................................................... 22

4.7 Aerial Platforms and Scissor Lifts .............................................................................. 23

4.8 Asbestos ...................................................................................................................... 26

4.9 Bird and Bat Droppings .............................................................................................. 29

4.10 Bloodborne Pathogens ................................................................................................ 29

4.11 Buddy System ............................................................................................................. 30

4.12 Carbon Monoxide ....................................................................................................... 30

4.13 Caulks, Mastics, Paints, and Coatings ........................................................................ 31

4.14 Changing Conditions, Eyes on Path ........................................................................... 32

4.15 Compressed Gasses .................................................................................................... 33

4.16 Concrete ...................................................................................................................... 35

4.17 Confined Spaces ......................................................................................................... 36


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4.18 Contact Lenses ............................................................................................................ 36

4.19 Contractor Control ...................................................................................................... 37

4.20 Cryogenic Liquids ...................................................................................................... 39

4.21 Demolition Engineering Surveys ............................................................................... 41

4.22 Diving ......................................................................................................................... 41

4.23 Dropped Objects ......................................................................................................... 41

4.24 Drugs and Alcohol ...................................................................................................... 43

4.25 Drums ......................................................................................................................... 43

4.26 Electrical Safety ........................................................................................................ 44

4.27 Emergency Eyewash Stations .................................................................................... 46

4.28 Excavations and Trenching ........................................................................................ 47

4.29 Fire Prevention and Emergency Egress Protocols ..................................................... 48

4.30 First Aid / Medical Care for Injuries – Occupational Health Services ...................... 50

4.31 Flammable and Combustible Liquids and Aerosols .................................................. 52

4.32 Floor / Wall Openings ................................................................................................ 54

4.33 Forklifts (Powered Industrial Trucks) ........................................................................ 55

4.34 Hazard Communication (Right to Know) .................................................................. 56

4.35 Hazardous Substances ................................................................................................ 59

4.36 Hazards, Biological .................................................................................................... 59

4.37 Hearing Conservation ................................................................................................. 59

4.38 Heat Generating Equipment and Appliances ............................................................. 60

4.39 Heavy Equipment ....................................................................................................... 61

4.40 Hexavalent Chromium ............................................................................................... 62

4.41 Hoisting and Rigging .................................................................................................. 63

4.42 Hot Work .................................................................................................................... 65

4.43 Housekeeping ............................................................................................................. 68

4.44 Hydrolazing ................................................................................................................ 68

4.45 Industrial Hygiene ...................................................................................................... 69

4.46 Isocyanates .................................................................................................................. 69

4.47 Ladders ....................................................................................................................... 70


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4.48 Lead ............................................................................................................................ 73

4.49 Line of Fire – Pinch Points ......................................................................................... 74

4.50 Lockout/Tagout ......................................................................................................... 75

4.51 Material Handling and Storage................................................................................... 76

4.52 Medical Exposure Records ......................................................................................... 77

4.53 Medical Examination Program ................................................................................... 78

4.54 Mercury....................................................................................................................... 79

4.55 Mold ............................................................................................................................ 80

4.56 Office Safety ............................................................................................................... 81

4.57 Outdoor Hazards ......................................................................................................... 83

4.58 Overhead Power Lines ............................................................................................... 88

4.59 Paper Insulated Lead Covered Cables (PILC) ........................................................... 89

4.60 Personnel Platforms .................................................................................................... 89

4.61 Personal Protective Equipment (PPE) ........................................................................ 89

4.62 Poly-Chlorinated Bi-Phenyls (PCBs) ......................................................................... 98

4.63 Post Fuel Transfer Operations (FTO) Changes .......................................................... 99

4.64 Pre-Job Briefings / Post Job-Critiques ..................................................................... 100

4.65 Railcar Safety............................................................................................................ 100

4.66 Refractory Ceramic Fiber (RCF) .............................................................................. 101

4.67 Remotely Operated Demolition Tools ..................................................................... 102

4.68 Rescue Team............................................................................................................. 105

4.69 Respiratory Protection .............................................................................................. 105

4.70 Safety Barriers and Postings ..................................................................................... 107

4.71 Safety Committee ..................................................................................................... 109

4.72 Sanitation .................................................................................................................. 109

4.73 Scaffolding ................................................................................................................ 109

4.74 Severe Weather ......................................................................................................... 112

4.75 Silica ......................................................................................................................... 113

4.76 Space Heaters ........................................................................................................... 113

4.77 Stuck Equipment ...................................................................................................... 114


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4.78 Task Hazard Analysis / Job Hazard Analysis / Job Safety Analysis ....................... 115

4.79 Thermal Stress (Heat and Cold Stress) .................................................................... 116

4.80 Tool Safety................................................................................................................ 118

4.81 Training Requirements ............................................................................................. 122

4.82 Transient Combustibles ............................................................................................ 123

4.83 Vehicles and Transportation ..................................................................................... 124

4.84 Welding..................................................................................................................... 125

4.85 Wind Sock ................................................................................................................ 125

4.86 Winter Safety ............................................................................................................ 125

4.87 Working at Heights (Fall Protection) ....................................................................... 127

4.88 Working Over Water ................................................................................................ 128

4.89 Zinc ........................................................................................................................... 128

ATTACHMENTS

Attachment 1 – Spill Prevention Control and Countermeasure (SPCC) .......................................... 130

Attachment 2 – Universal Waste ....................................................................................................... 131

Attachment 3 – Restrictions to Pouring Liquids Down Drains ........................................................ 132

Attachment 4 – Asbestos Technical Information .............................................................................. 133

Attachment 5 – Substance Data Sheet for Occupational Exposure to Lead ..................................... 136

Attachment 6 – Background Information on Silica .......................................................................... 140

Attachment 7 – ZionSolutions Refractory Ceramic Fiber Information Sheet .................................. 146

Attachment 8 – Guidance for Stuck Vehicles ................................................................................... 147

Attachment 9 – Radiation Protection / Radiation Safety .................................................................. 148

Attachment 10 – Unconditional Release Surveys / Final Status Surveys ........................................ 154

Attachment 11 – Emergency Contact Information (typical)............................................................. 155

TABLES

Table 1 – Illinois Underground Utility Flag Color Codes .................................................................. 48

Table 2 – Minimum Approach Distance to Energized Overhead Power Lines ................................. 88


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1.0 PURPOSE AND SCOPE

1.1 Purpose

The safety of ZionSolutions employees, subcontractors, and the public is our principal core value. ZionSolutions will perform all work activities in a safe and professional manner that will not create a hazard to health, property, or the environment. All ZionSolutions employees and subcontractors are responsible for full compliance with ZionSolutions procedures and OSHA regulations.

ZionSolutions employees may report their safety or health concerns to OSHA and the Nuclear Regulatory Commission (NRC) without fear of reprisal. Safety and health concerns may also be reported via:

Reference 2.8 - AD-8: Corrective Action Program.

Reference 2.62 - ZS-LS-115: Employee Concerns Program.

ZionSolutions Employee Concerns Hotline (888) 995-9939.

EnergySolutions Silent Whistle Program, phone number (877) 874-8416.

ZionSolutions employees may also report their safety or health concerns to OSHA and the Nuclear Regulatory Commission (NRC) without fear of reprisal.

Employees are responsible for following ZionSolutions Industrial Safety and Hygiene (IS&H) policies and procedures. We exercise this responsibility by complying with ZionSolutions policies and procedures and ensuring that safety is a key consideration for every action taken. Employees are expected to support all Industrial Safety and Hygiene Programs and Safety Committee actions.

The ZionSolutions Industrial Safety & Hygiene Program establishes the program activities required to provide a safe working environment for our employees and subcontractors and improve safety performance while complying with regulatory requirements.

1.2 Site History

The initial construction of the Zion Nuclear Station was authorized on December 26, 1968. Unit 1 and Unit 2 achieved initial criticality on June 19, 1973 and December 24, 1973 respectively. Next, Unit 1 was synchronized to the grid for the first time on June 28, 1973 and Unit 2 on December 26, 1973. Finally, Unit 1 and Unit 2 began commercial operation on December 31, 1973 and September 19, 1974 respectively.

Both units were valuable providers of electricity to the northern Illinois grid for twenty-four years. On January 15, 1998 ComEd announced the permanent shutdown of both Zion reactors.


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1.3 Scope of Work

ZionSolutions will perform the decommissioning of the Zion Nuclear Station and release the site for unrestricted use, except for the spent nuclear fuel and Greater Than Class C (GTCC) waste, which is stored at the Independent Spent Fuel Storage Installation (ISFSI) constructed on site.

1.4 Site Description

The Zion Nuclear Station is located in Northeast Illinois on the West shore of Lake Michigan. The site comprises approximately 250 acres owned by Exelon Nuclear. The site is approximately 40 miles north of Chicago, Illinois, and 42 miles south of Milwaukee, Wisconsin.

The station is comprised of two Westinghouse pressurized water reactors with supporting facilities; the electrical output was 1,085 Megawatts electric (MWe) for each Unit.

The containment structure at Zion is cylindrical, with a shallow dome roof and a flat foundation slab. The cylindrical portion is pre-stressed by a post-tensioning system consisting of horizontal and vertical tendons. The entire structure is internally lined with welded steel plate, which acts as a leak-tight membrane. The containment completely encloses the primary coolant system, consisting of the pressurized water reactor, steam generators, reactor coolant loops, and portions of the auxiliary and engineered safety systems and features.

2.0 REFERENCES

Compliance with the following references ensures that ZionSolutions performs their work activities in a manner that is protective of the environment, ensures the safety and health of its employees, subcontractors, and the general public; and complies with the applicable federal and state regulations; and ZionSolutions procedures and requirements.

Regulations and procedures not identified below that are applicable to ZionSolutions work activities shall be incorporated into the work activity and included below upon notification to the ZionSolutions Manager, Industrial Safety & Hygiene.

2.1 §10 CFR 20: Standards for Protection Against Radiation

2.2 §29 CFR 1910: Occupational Safety and Health Standards

2.3 §29 CFR 1926: Safety and Health Regulations for Construction

2.4 §40 CFR 61: Subpart M; National Emissions Standards for Asbestos

2.5 ACGIH Guide to Occupational Exposure Values (Latest Edition)

2.6 ACGIH TLVs® and BEIs® (Latest Edition)

2.7 AD-23: Nuclear Security Medical Examination


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2.8 AD-8: Corrective Action Program

2.9 ANSI A10.14-1991: American National Standard for Construction and Demolition Operations – Requirements for Safety Belts, Harnesses, Lanyards and Lifelines for Construction and Demolition Use.

2.10 ANSI/ASSE A10.6-2006: Safety and Health Requirements for Demolition Operations

2.11 AOP 4.5: Plant Fire Alarm

2.12 EPA 402-K-01-001, March 2001: Mold Remediation in Schools and Commercial Buildings

2.13 HU-ZN-1211: Pre-Job, Heightened Level of Awareness, and Post-Job Briefings

2.14 NIOSH Pocket Guide to Chemical Hazards

2.15 OSHA Directive Number CPL 03-00-007: National Emphasis Program – Crystalline Silica

2.16 OSHA Technical Manual Section II: Chapter 1 – Personal Sampling for Air Contaminants

2.17 OSHA Technical Manual Section III: Chapter 4 – Heat Stress

2.18 OSHA Technical Manual Section III: Chapter 5 – Noise Measurement

2.19 OSHA Technical Manual Section V: Chapter 1 – Demolition

2.20 OSHA Technical Manual Section V: Chapter 2 - Excavations: Hazard Recognition in Trenching and Shoring

2.21 OSHA Technical Manual Section V: Chapter 3 - Controlling Lead Exposures in the Construction Industry: Engineering and Work Practice Controls

2.22 OSHA Technical Manual Section VIII: Chapter 2 – Respiratory Protection

2.23 SAF-02: Chemical Control

2.24 SAF-03: Respirator Surveillance Exam

2.25 SAF-04: Hearing Conservation Program and Examination

2.26 SAF-05: Purchase and Administration of Automatic External Defibrillators (AED’S)

2.27 SAF-06: Use of Personnel Platforms

2.28 SAF-07: Respiratory Protection Program

2.29 SAF-08: Evaluation and Selection Process for Radiological Respirator Use

2.30 SAF-09: Evaluation and Selection of Respiratory Protection for Non-Radiological Use

2.31 SAF-10: Heat Stress Control

2.32 SAF-12: Confined Space Entry


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2.33 SAF-14: Excavation, Trenching, and Shoring

2.34 SAF-15: Heavy Detector Shield Handling

2.35 SAF-16: Handling and Storage of Compressed Gas Cylinders/Portable Tanks and Cryogenic Containers/Dewars

2.36 SAF-17: Lead Removal & Exposure Control

2.37 SAF-18: Powered Industrial Truck Operation

2.38 SAF-19: Electrical Safety

2.39 SAF-20: Site Safety Committees

2.40 SAF-21: Management & Control of Hexavalent Chromium during Welding, Cutting, and Grinding Activities

2.41 SAF-22: Use and Control of Ventilation for Welding, Cutting, and Grinding Activities

2.42 SAF-23: Scaffold and Portable Ladder Use

2.43 SAF-24: Quantitative Respirator Fit Testing

2.44 SAF-25: Use and Care of the 3M™ L-905, L-905SG, and L-905SG-F PAPRs

2.45 SAF-26: Use and Care of the 3M™ 7500 Half Facepiece Respirator

2.46 SAF-27: Use and Care of the 3M H-412 PAPR

2.47 SAF-28: Case Management of Occupational Injuries

2.48 SAF-29: Hoisting and Rigging Program

2.49 SAF-30: Training and Qualification of Personnel

2.50 SAF-31: Safe Use and Inspection of Rigging Equipment

2.51 SAF-32: Eyewash and Shower Tests & Checks

2.52 SAF-33: Flammable and Combustible Liquids

2.53 SP-19: Fitness For Duty Program

2.54 ZAP 530-01: Hazardous Material (HAZMAT) Response, Incidental Chemical Spills & Reporting

2.55 ZAP 900-01: Station Fire Protection Program

2.56 Zion Station Historical Site Assessment, Version 1 – August 1999

2.57 ZS-AD-101: Management and Oversight of Supplemental Work Force

2.58 ZS-AD-102: Construction Management

2.59 ZS-AD-103: Control of Systems, Structures, or Components (SSCs) Turnover from ZionSolutions to Demolition Contractor

2.60 ZS-AD-14: Stop Work Order/Authority


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2.61 ZS-AD-18: Protective Footwear Reimbursement Policy

2.62 ZS-LS-115: Employee Concerns Program

2.63 ZS-RP-106-001-004: Control, Use, and Quality Assurance of Modesty Garments

2.64 ZS-WC-100: Decommissioning Work Control Process, initiating and Screening Work Requests

2.65 ZS-WC-101: Lockout Tagout

2.66 ZS-WM-112: Polychlorinated Biphenyl Management

2.67 ZS-WM-131: Chain of Custody Protocol

2.68 ZS-WM-134: Trackmobile Operations

3.0 GENERAL

3.1 Definitions

3.1.1 ACGIH - American Conference of Governmental Industrial Hygienists: an organization of professionals in governmental agencies or educational institutions engaged in occupational safety and health programs. ACGIH develops and publishes recommended occupational exposure limits for chemical substances and physical agents.

3.1.2 Administrative Controls - The practice of limiting employee exposure by job rotation (unless prohibited by regulations), work practices, or medical restriction.

3.1.3 Audiometric Testing - Hearing evaluation performed by a licensed or certified audiologist, physician, or technician that measures a person’s hearing at different frequencies.

3.1.4 Bloodborne Pathogens - Microscopic organisms present in human blood and other body fluids that can cause disease in humans. These pathogens include, but are not limited to, Hepatitis B virus (HBV) and human immunodeficiency virus (HIV).

3.1.5 Buddy System – A system of organizing employees into work groups in such a manner that each employee of the work group is designated to be observed by at least one other employee in the work group. The purpose of the buddy system is to provide rapid assistance to employees in the event of an emergency. The use of portable radios may be an acceptable equivalent to the Buddy System in low-risk applications, i.e., Operator rounds, Security tours, housekeeping, etc.

3.1.6 Competent Person - A person who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are


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hazardous or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.

3.1.7 Demolition - The wrecking or taking out of any load-supporting structural member of a facility together with any related handling operations or the intentional burning of any facility.

3.1.8 Engineering Controls - Engineering controls minimize employee exposure by either reducing or removing the hazard at the source or isolating the worker from the hazards.

3.1.9 Excavation - Any man-made cut, cavity, trench, or depression in an earth surface, formed by earth removal.

3.1.10 Floor Opening - A gap or void twelve inches or more in its least dimension in a floor, roof or other walking/working surface.

3.1.11 Hazardous Chemical - A Hazardous Chemical is a substance that presents a significant health or physical hazard. The term includes chemicals that are toxic, corrosive, sensitizing, irritating, flammable, combustible, reactive, explosive, oxidizing, or carcinogenic, and those that have target-organ effects.

3.1.12 High Efficiency Particulate Air (HEPA) Filter - Filter with a minimum efficiency of 99.97% of 0.3-micron particles at rated airflow.

3.1.13 Hot Work Permit - The written authorization to perform operations (for example, grinding welding, cutting, burning, and heating) capable of providing a source of ignition.

3.1.14 Job Hazard Analysis (JHA) - Carefully studying and recording each step of a job, identifying existing or potential job hazards (both safety and health hazards), and determining the best way to perform the job to reduce or eliminate these hazards. Also known as a Job Safety Analysis (JSA).

3.1.15 Near Miss - An event where no property / equipment was damaged and no personal injury sustained, but where, given a slight shift in time or position, damage and/or injury could easily have occurred.

3.1.16 NESHAP – 40 CFR 61, Subpart M: National Emission Standard for Asbestos

3.1.17 Permissible Exposure Limit (PEL) - The maximum amount or concentration of a chemical that a worker may be exposed to under OSHA regulations. In general, PEL's refer to substances that may be

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inhaled, although some can be absorbed through the skin or eyes. PEL's can be defined in two different ways:

3.1.17.1 Ceiling values - at no time should this exposure limit be exceeded; sometimes denoted with the letter C.

3.1.17.2 8-hour Time Weighted Averages (TWA) are an average value of exposure over the course of an 8 hour work shift.

3.1.18 Physical Agent - Physical agents are non-chemical hazards such as noise, heat, lasers, microwaves, or ultraviolet radiation. For the purposes of this HASP, this term does not include ionizing radiation.

3.1.19 Regulated Asbestos-Containing Material (RACM) - Regulated Asbestos-Containing Material (RACM) is (a) friable asbestos material, (b) Category I non-friable ACM that has become friable, (c) Category I non-friable ACM that will be or has been subjected to sanding, grinding, cutting or abrading, or (d) Category II non-friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations.

3.1.20 Safety Can - An approved container of not more than 5 gallons capacity, having a spring-closing lid and spout cover designed so it will safely relieve internal pressure when subjected to fire.

3.1.21 Safety Data Sheet (SDS) - A document, provided by the manufacturer or importer of a chemical substance, that presents hazard and safety information on that substance in a standard format. Previously referred to as a Material Safety Data Sheet (MSDS).

3.1.22 Task Hazard Analysis (THA) – A document included in approved Work Packages that identifies known or expected hazards and the appropriate controls to reduce or eliminate these hazards.

3.1.23 TLV (Threshold Limit Value) - Refers to airborne concentrations of substances or levels of physical agents, and represents the conditions under which it is believed that nearly all workers may be repeatedly exposed day after day without adverse effect. These guidelines are established by ACGIH.


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3.2 Industrial Safety & Hygiene Program Responsibilities

ZionSolutions employees and subcontractors have specific responsibilities to the Industrial Safety & Hygiene Program, which are detailed below.

3.2.1 Executive VP and General Manager

3.2.1.1 Development, implementation, & maintenance of the ZionSolutions Industrial Safety & Hygiene Program.

3.2.1.2 Direction of Industrial Safety & Hygiene Program applications.

3.2.1.3 Ensure that all ZionSolutions employees and subcontractors perform their work activities in accordance with the References in Section 2.0, as applicable.

3.2.1.4 Ensure that there are adequate resources available to support the Industrial Safety & Hygiene Program.

3.2.1.5 Industrial Safety & Hygiene Program regulatory reporting & safety statistic management.

3.2.1.6 Perform a review of Reference 2.65 - ZS-WC-101: Lockout Tagout on an annual basis, to verify compliance with OSHA regulations. This may be delegated to another individual who is not directly involved with the Lockout / Tagout Process.

3.2.1.7 Performance of all ZionSolutions work activities, including subcontractor work activities, in a safe manner.

3.2.2 VP of Construction and D&D

3.2.2.1 Ensures all field personnel operating specialized machinery, such as forklifts, cranes, drilling equipment, or earthmoving equipment, have demonstrated competency and have received documented training.

3.2.2.2 Ensures performance of a Hazard Assessment of the Project prior to commencing decommissioning work activities.

3.2.2.3 Ensures Pre-Job Briefings for ZionSolutions and subcontractor employees are conducted and documented.

3.2.2.4 Ensuring that all employees who are required to use respiratory protection have been medically certified.


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3.2.2.5 Evaluate adverse weather conditions to determine if the site is safe for operations.

3.2.2.6 Verifying that D&D personnel have current certification of the applicable training and medical surveillance requirements identified in this HASP.

3.2.3 Manager, Industrial Safety & Hygiene

3.2.3.1 Conducting safety briefings and, as necessary, informing site personnel of potential hazards due to revised tasks and/or site conditions.

3.2.3.2 Coordinate with emergency responders and medical service organizations to establish provided services and verify that Attachment 11 – Emergency Contact Information (typical) is current, accurate, and posted in prominent locations in the workplace.

3.2.3.3 Development of Industrial Safety & Hygiene procedures specific to Project work activities, as needed.

3.2.3.4 Evaluate and approve engineering controls used to open drums.

3.2.3.5 Industrial Safety & Hygiene regulatory compliance for all ZionSolutions and subcontractor work activities.

3.2.3.6 Maintain first aid and Occupational Safety and Health Administration (OSHA) illness/injury logs, report accidents and injuries through the appropriate channels, and conduct accident/incident investigations and documentation as required.

3.2.3.7 Maintaining Industrial Safety & Hygiene related field project records.

3.2.3.8 Perform a Hazard Assessment of the work area for hazardous substances and biological hazards prior to commencing work activities.

3.2.3.9 Perform Industrial Safety & Hygiene surveillances of ZionSolutions and subcontractor work activities. The surveillances monitor Industrial Safety & Hygiene performance and implementation of the References in Section 2.0.


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3.2.3.10 Post and keep current all employee right-to-know information.

3.2.3.11 Provide Competent Person functions as required by OSHA regulations.

3.2.3.12 Review and approve all Work Packages prior to commencing work in accordance with Reference 2.64 - ZS-WC-100: Decommissioning Work Control Process, initiating and Screening Work Requests.

3.2.4 Work Supervisors

3.2.4.1 Adhere to the regulatory and procedural requirements of the References in Section 2.0.

3.2.4.2 Ensure that all necessary permits (Excavation, Hot Work, Confined Space, etc.) are obtained prior to commencing the work activity.

3.2.4.3 Ensure that their employees perform a Job Safety Analysis (JSA) for work activities where a Job Hazard Assessment (JHA) or Task Hazard Assessment (THA) has not been developed in accordance with Section 4.78.

3.2.4.4 Ensure the availability of workplace instructions, work packages, and procedures that are clear and appropriate for the potential risks (produced, where practicable, with the involvement of those undertaking the actual work activity).

3.2.4.5 Evaluate and address employee safety and health concerns with the involvement of Industrial Safety & Hygiene.

3.2.4.6 Perform a Task Hazard Analysis (THA) when required and ensure that it is incorporated into the approved Work Package.

3.2.4.7 Perform Pre-Job Briefings shiftly, or more frequently, as applicable, for work activities.

3.2.5 ZionSolutions Employees and subcontractors

3.2.5.1 Contact Industrial Safety & Hygiene if compliance with Safety requirements is not possible or applicable for specific work activities.


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3.2.5.2 Exercise Stop Work authority when health or safety concerns occur.

3.2.5.3 Notify their Supervisor and Occupational Health Services if they are taking any prescription and/or non-prescription medications that could affect their safety or the safety of others while performing their work activities in accordance with Reference 2.53 - SP-19: Fitness For Duty Program.

3.2.5.4 Notify their Supervisor or Industrial Safety & Hygiene if they require any accommodations to safely perform their work activities.

3.2.5.5 Notify their Supervisor or Industrial Safety & Hygiene of any conditions or concerns, which are not addressed by the protective measures specified in this HASP, or which are addressed but the employee does not understand.

3.2.5.6 Participate in initial site orientation/training and provide any required documentation, medical clearance, respirator fit test, certification, etc., prior to starting work on the site.

3.2.5.7 Perform only those tasks authorized by ZionSolutions management and that they have been trained and feel competent to complete safely.

3.2.5.8 Practice good housekeeping by keeping the work areas neat, clean and orderly.

3.2.5.9 Properly use PPE specified by the Radiation Work Permit (RWP), Work Package, the Pre-Job Briefing, this HASP, and direction from ZionSolutions Management.

3.2.5.10 Take all reasonable precautions to prevent injury to themselves and to their fellow employees, and being alert to potentially harmful situations.

3.3 Precautions and Limitations

Nothing in this Health and Safety Plan (HASP) shall be interpreted to conflict with or supersede federal, state, and local regulations, including EnergySolutions and ZionSolutions procedures. Information in this HASP incorporates selected information from the References located in Section 2.0 and is for information only; the specific procedure shall be referenced to identify all safety requirements associated with a specific safety topic.


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3.4 Document Control and Records

3.4.1 Employee industrial hygiene exposure data shall be maintained for the monitored employee’s duration of employment plus 30 years. This shall include:

3.4.1.1 Analytical procedure (i.e., NIOSH method).

3.4.1.2 Any additional observations, which may help to characterize the survey.

3.4.1.3 Any identifying numbers (i.e., employee badge number, equipment model number, etc.).

3.4.1.4 Blank sample (known or blind) documentation for each batch of industrial hygiene samples.

3.4.1.5 Calibration data if applicable.

3.4.1.6 Industrial Hygiene Chain-of-Custody.

3.4.1.7 Industrial Hygiene Monitoring Results.

3.4.1.8 Industrial Hygiene Sample Results.

3.4.1.9 Industrial Hygiene Sampling Record.

3.4.1.10 Industrial Hygiene Survey Report.

3.4.1.11 Industrial Safety & Hygiene Surveillances.

3.4.1.12 Laboratory Analysis Results.

3.4.1.13 Material Safety Data Sheets / Safety Data Sheets

3.4.1.14 Medical examination records.

3.4.1.15 Respirator Fit Testing.

3.4.1.16 Training certificates.

3.4.2 Original industrial hygiene exposure records will be maintained onsite, and transferred to the EnergySolutions Corporate Director, Safety and Health, at the completion of the Zion Restoration Project. A copy of exposure records may be provided to the ZionSolutions Medical Review Officer for physical examinations.


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4.0 REQUIREMENTS AND GUIDANCE

4.1 OSHA Regulations

ZionSolutions is committed to performing all work activities in accordance with the applicable OSHA regulations detailed in Reference 2.2 - §29 CFR 1910: Occupational Safety and Health Standards and 2.3 - §29 CFR 1926: Safety and Health Regulations for Construction.

4.1.1 §29 CFR 1910.5: Applicability of Standards

4.1.1.1 1910.5(c)(1) - If a particular standard is specifically applicable to a condition, practice, means, method, operation, or process, it shall prevail over any different general standard which might otherwise be applicable to the same condition, practice, means, method, operation, or process.

4.1.1.2 1910.5(c)(2) - On the other hand, any standard shall apply according to its terms to any employment and place of employment in any industry, even though particular standards are also prescribed for the industry, as in subpart B or subpart R of this part, to the extent that none of such particular standards applies. To illustrate, the general standard regarding noise exposure in 1910.95 applies to employments and places of employment in pulp, paper, and paperboard mills covered by 1910.261.

4.1.2 General Duty Clause – Section 5 of the OSH Act of 1970: Duties - Each employer:

4.1.2.1 Shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees;

4.1.2.2 Shall comply with occupational safety and health standards promulgated under this Act.

4.1.3 Under the Occupational Safety and Health Act of 1970, federal or designated state OSHA agencies are authorized to conduct workplace inspections to determine whether employers are complying with standards issued by the agencies for safe and healthful workplaces.

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9701

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=3359&p_table=OSHACT

https://www.osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=OSHACT&p_toc_level=0&p_keyvalue=&p_status=CURRENT


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4.2 ZionSolutions Industrial Safety & Hygiene Job Aids, Policies, and Procedures

4.2.1 ZionSolutions will develop project-specific job aids and procedures as required to support decommissioning work activities.

4.2.2 It is the responsibility of the job aid / procedure user to verify that the current job aid / procedure revision is used to perform their work activity.

4.2.3 This Health and Safety Plan should be updated on an annual basis.

4.3 Resolution of Conflicting Requirements

Conflicting requirements will be resolved by the Manager, Industrial Safety & Hygiene and VP of Construction and D&D prior to commencing work activities, so that only one approved method of performing work is incorporated into the Work Package. Controlling the interpretation of requirements is necessary so that clear and unambiguous direction is provided to the workforce.

If conflicting requirements are identified during the performance of the Work Package, the affected work activity shall be placed in a safe condition and immediately cease. The Manager, Industrial Safety & Hygiene and VP of Construction and D&D shall be promptly notified. The source of the conflicting requirements shall be investigated and resolved before the work activity is allowed to resume.

4.4 Work Planning

ZionSolutions will perform industrial safety & hygiene planning for each Work Package developed to support the work scope. Industrial Safety & Hygiene requirements including engineering controls, administrative controls, and PPE will be identified in the Work Package.

4.5 Stop Work Authority

All project personnel have the authority and the responsibility to stop work when health or safety concerns occur as per Reference 2.60 - ZS-AD-14: Stop Work Order/Authority. The affected work activity shall immediately cease, be placed in a safe condition, and then promptly reported to the Work Supervisor. The Work Supervisor, Manager, Industrial Safety & Hygiene, and VP of Construction and D&D shall promptly investigate and resolve the health or safety concern, enlisting the assistance of additional personnel as appropriate.

4.5.1 The Manager, Industrial Safety & Hygiene will ensure that the necessary actions to resolve health and safety concerns are implemented prior to resuming affected work activities, including identification of causal


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factors, development and implementation of corrective actions, and training of applicable personnel.

4.5.2 A Condition Report shall be generated for all Stop Work orders in accordance with Reference 2.8 - AD-8: Corrective Action Program.

4.6 Incident Reporting

4.6.1 All ZionSolutions employees and subcontractors are responsible for promptly reporting events that may injure personnel, damage equipment, or impact the environment, regardless of the perceived severity.

4.6.1.1 All falls, to the same level or to another level, regardless of cause, perceived severity, or injury, shall be promptly reported to IS&H. Falls to the same level are defined as the act of losing one’s balance and striking the level below with any part body with the exception of the feet alone.

4.6.1.2 Reports shall be made to their immediate supervision and the Manager, Industrial Safety & Hygiene, who will report the event to the Executive VP and General Manager.

4.6.2 Some events may not meet the criteria of Reference 2.47 - SAF-28: Case Management of Occupational Injuries for reporting purposes; however may be documented for tracking purposes as determined by the Executive VP and General Manager.

4.6.3 Personnel shall call 5-2211 if calling from an onsite phone or (847) 379-2211 if calling from an outside (i.e., cell) phone for any event that requires immediate response (i.e., fire, medical emergency, etc.). Calling the Emergency Number informs the ISFSI Shift Supervisor of the Emergency, who will:

4.6.3.1 Contact offsite support (i.e., Fire Department, Ambulance) as required.

4.6.3.2 Contact Security to authorize the Emergency Vehicle to come on site.

4.6.3.3 Dispatch an escort to meet the Emergency Vehicle to guide the Emergency Vehicle to the proper location.

4.6.4 Near Misses are incidents where no property / equipment was damaged and no personal injury sustained, but where, given a slight shift in time or position, damage and/or injury could easily have occurred. Near Misses shall also be reported to supervision and Industrial Safety & Hygiene for


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investigation and implementation of applicable Lessons Learned to prevent future recurrences.

4.6.5 Prompt investigation of accidents / injuries is essential to identify Lessons Learned to ensure that good practices and opportunities for improvement are identified and adopted. The investigation should be initiated the day of the event and completed within 48 hours. The Supervisor will contact Industrial Safety & Hygiene to assist with the investigation and reporting on the event to the Management Review Committee.

4.7 Aerial Platforms and Scissor Lifts (§29 CFR 1926.453)

Aerial platforms and scissor lifts will be used to support the Zion Restoration Project to provide access to elevated areas.

4.7.1 A shiftly inspection of the aerial platform / scissor lift shall be performed and documented when in use. Aerial platforms / scissor lifts requiring maintenance shall not be operated until repairs have been made.

4.7.2 An annual inspection of the aerial platform / scissor lift shall be performed and documented. Aerial platforms / scissor lifts requiring maintenance shall not be operated until repairs have been made.

4.7.3 Scissor lifts shall not be moved while the platform is elevated. If you need to relocate the platform to allow reaching an elevated work area, the scissor lift shall be fully lowered, repositioned, and then re-elevated to access the work area.

4.7.4 Aerial platforms / scissor lifts shall NOT be used as a crane.

4.7.4.1 All loads shall be carried inside of the platform basket.

4.7.4.2 Loads shall NOT be carried on the platform basket rails.

4.7.5 An ABC fire extinguisher shall be readily available and in operable condition at a location determined by the Work Supervisor.

4.7.5.1 An annual maintenance inspection of the fire extinguisher shall be performed by the Industrial Safety & Hygiene Department. The 2015 annual inspection is denoted by a purple-colored dot on the fire extinguisher.

4.7.5.2 A monthly (periodic) inspection of the fire extinguisher shall be performed by personnel operating the aerial platform / scissor lift. The periodic inspection criterion is designated on



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a sticker affixed to the fire extinguisher. The periodic inspection is documented on the shiftly inspection sheet.

4.7.6 Operators of aerial platforms shall be trained on the same model of aerial platform or one having similar characteristics and controls consistent with the aerial platform. This training shall be documented and maintained in the Operator’s Training File.

4.7.7 Fall restraint is designed to restrict the user’s movement to prevent being exposed to a fall hazard. Fall restraint consists of a maximum four-foot length, non-shock-absorbing lanyard, properly attached to a body harness and the manufacturer’s approved anchorage point. A 6-foot self-retracting lifeline (SRL) may also be used if approved by Industrial Safety & Hygiene.

4.7.7.1 Operation of aerial platforms (from the elevating platform) requires the use of fall restraint at all times, including movement of the aerial platform with the platform lowered.

4.7.7.2 Fall restraint is not required for operation of scissor lifts as the guardrail system provides fall protection.

4.7.7.3 Climbing onto, sitting, or standing on the midrail or toprail of an aerial lift or scissor lift is prohibited.

4.7.8 The travel path must be evaluated for stability by the operator prior to movement of the aerial platform / scissor lift. Evaluation points include:

4.7.8.1 Does the travel path cross storm drains, underground utility covers, grates, etc.? If so, seek an alternate travel path so that the weight of the aerial platform / scissor lift is not imposed on these coverings.

4.7.8.2 Is the travel path stable, level, and on solid ground?

4.7.8.3 Is there adequate clearance to prevent contact with structures, overhead lines, personnel, other vehicles, etc.?


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4.7.9 Egressing an elevated aerial platform basket

Specific circumstances may require personnel to exit an elevated aerial platform basket to perform their work activities. This practice is considered exceptional in nature and shall be performed in accordance with the following protocols:

4.7.9.1 The Work Supervisor shall verify that there are no other feasible means of accessing the elevated work area (i.e., ladder, scaffold, etc.).

4.7.9.2 The aerial platform basket shall be landed on a firm, level surface which is wide enough to fully support the basket.

4.7.9.3 The aerial platform will be secured to prevent inadvertent operation of the aerial platform while personnel are disembarked from the elevated aerial platform basket.

4.7.9.4 The alighting area shall allow personnel to climb in and out of the elevated aerial platform basket easily and safely.

4.7.9.5 Personnel shall exit / enter the elevated aerial platform basket one at a time.

4.7.9.6 Fall prevention (i.e., elevated positioning of the aerial platform basket to serve as a fall prevention barrier) or fall protection used in accordance with an approved Fall Protection Plan shall be utilized to ensure that personnel are not working at heights unprotected. Personnel SHALL NOT use the elevated aerial platform basket as a fall protection anchorage when disembarked from the elevated aerial platform basket.

4.7.10 Storage - aerial lifts may be stowed in the elevated position to conserve space using the protocols below:

4.7.10.1 The aerial lift is stored indoors.

4.7.10.2 A spotter is used to help guide the operator who is raising the boom from the ground. The spotter will make sure the basket and arm do not strike any interference as it is being raised. The spotter will also keep personnel from walking underneath the basket as it is being raised.


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4.7.10.3 The area underneath the boom and basket are barricaded and signs placed warning personnel not to walk beneath the elevated aerial platform basket.

4.7.10.4 The boom and basket must be lowered prior to entering the basket to perform the pre-use inspections.

4.7.11 Wind Speed Operating Criteria

4.7.11.1 Aerial platforms and scissor lifts shall not be operated if wind speed exceeds 25 mph. Wind speed monitoring shall be performed if elevated wind speeds are forecast or present. Wind speed anemometers are available from Industrial Safety & Hygiene.

4.8 Asbestos (§29 CFR 1926.1101)

Asbestos is the name given to a number of naturally occurring, fibrous silicate minerals mined for their useful properties such as thermal insulation, chemical and thermal stability, and high tensile strength. Asbestos was commonly used as an acoustic insulator, and in thermal insulation, fireproofing and other building materials. Asbestos is made up of microscopic bundles of fibers that may become airborne when asbestos-containing materials are damaged or disturbed. When these fibers get into the air they may be inhaled into the lungs, where they can cause significant health problems.

4.8.1 Asbestos Containing Material (ACM) is defined as any material containing >1% asbestos by weight as determined by records, manufacturer’s specifications, laboratory analysis, or some other means. Presumed Asbestos Containing Material (PACM) is material that has not been analyzed and has the possibility of containing asbestos. The four work classifications involving ACM and PACM are:

4.8.1.1 Class I - Activities involving the removal of thermal system insulation (TSI) and surfacing ACM and PACM.

4.8.1.2 Class II – Activities involving the removal of ACM which is not TSI or surfacing material. This includes, but is not limited to, the removal of asbestos containing wallboard, floor tile and sheeting, roofing and siding shingles, and construction mastics. Additionally, Class II is designated for any Class III type activity in which the quantity exceeds that to be contained by one standard glove or waste bag (60” by 60”).



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4.8.1.3 Class III – Repair and maintenance operations where ACM, including TSI and surfacing ACM and PACM, is likely to be disturbed and can typically be contained in one standard size glovebag or waste bag. Examples of Class III asbestos work include, but are not limited to disturbance of gaskets, valve packing, wiring insulation and brake linings containing asbestos.

4.8.1.4 Class IV - Maintenance and custodial activities during which employees contact, but do not disturb, ACM and PACM; and activities to clean up waste and debris containing ACM and PACM following Class I, II, or III asbestos work.

4.8.1.5 All ZionSolutions employees and subcontractors will receive Asbestos Awareness training upon hire and annually thereafter; Attachment 4 – Asbestos Technical Information provides information that is included in Asbestos Awareness training.

4.8.2 Known or presumed asbestos containing materials include:

4.8.2.1 Bitumen roofing material and buried concrete structure coating.

4.8.2.2 Caulks.

4.8.2.3 Ceiling tile.

4.8.2.4 Chemical Laboratory counter-tops and fume hoods.

4.8.2.5 Crane and elevator brake shoes.

4.8.2.6 Electrical cable insulation (i.e., Rockbestos cables manufactured prior to 1977 contained an asbestos tape under the neoprene jacket.).

4.8.2.7 Electrical Installation air seals and fire stops – ComEd Drawing 22E-0-3130 dated 12/03/97.

4.8.2.8 Fire door sealant / mastic.

4.8.2.9 Floor tile and mastics.

4.8.2.10 Furmanite

4.8.2.11 Gaskets.

Note: Based on the amount of Aux Building electrical cables confirmed to contain asbestos, D&D has taken the proactive measure of treating and disposing of all Aux Building electrical cables as asbestos. To ensure that proper asbestos handling protocols are implemented, personnel who cut Aux


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Building electrical cables are required to have 14-hour asbestos Operations & Maintenance (O&M) training or possess an IDPH (Illinois Department of Public Health) asbestos license. The waste containers that the asbestos cables are loaded into shall be marked as per Waste Operations direction to indicate the presence of asbestos waste.

4.8.2.12 Seals at base of Motor Control Centers (MCC) and/or switchgear with lower cable entry.

4.8.2.13 Structural steel fire barrier material.

4.8.2.14 Thermal system insulation (TSI).

4.8.2.15 Transite boards inside of circuit breakers, motor control centers (MCC), and electrical distribution panels.

4.8.2.16 Transite panels for exterior building cladding.

4.8.2.17 Unit 2 Containment on the concrete wall surrounding the Equipment Hatch, the steel liner plate, RCFC ductwork, the Equipment and Emergency Hatches, and vent stop valves number S18875A and S18875B, located outside Missile Barrier 592’ by Columns Z22 and Z29.

4.8.2.18 Valve packing.

4.8.2.19 Ventilation duct (rigid) sealants.

4.8.2.20 Wall and floor penetration Fire barrier material.

4.8.2.21 If you should encounter a material that you believe contains asbestos, do not contact or disturb the material and notify your supervisor. ZionSolutions has dedicated personnel to perform asbestos work.

4.8.3 Reference 2.4 - §40 CFR 61: Subpart M; National Emissions Standards for Asbestos regulates demolition of facilities that may contain asbestos. Prior to demolition of any building an asbestos inspection (NESHAP Inspection) of the building shall be performed and all Regulated Asbestos-Containing material (RACM) will be removed.

4.8.4 A minimum of 10-working days notification will be made to the Illinois EPA (IEPA) prior to commencing asbestos abatement or building demolition.


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4.9 Bird and Bat Droppings

There are three infectious diseases that are a concern when performing work activities that involve disturbing bird and/or bat droppings. These three are:

4.9.1 Cryptococcus – Cryptococcus neoformans is the infectious agent of the fungal disease Cryptococcus. The incidence of Cryptococcus has increased in recent years because of its frequent appearance in AIDS patients. Cryptococcus neoformans uses the creatinine in avian feces as a nitrogen source. It gains a competitive advantage over other microorganisms and multiplies exceedingly well in dry bird manure accumulated in places that are not in direct sunlight.

4.9.2 Histoplasmosis is an infectious disease caused by inhaling the spores of the fungus Histoplasma Capsulatum. The organism can be carried on the wings, feet, and beaks of birds and infect soil under roosting sites or manure accumulations inside or outside buildings. Bird droppings on surfaces such as sidewalks have not been shown to present a health risk for histoplasmosis because birds themselves do not appear to be infected by H. Capsulatum. Bird manure is primarily a nutrient source for the growth of H. Capsulatum already present in soil. Unlike birds, bats can become infected with H. Capsulatum and consequently excrete the organism in their droppings.

4.9.3 Psittacosis is caused by the bacterium chlamydia psittaci rather than a fungus, it is another infectious disease that can develop after disturbing and inhaling contaminated bird manure. The symptoms of psittacosis include fevers, chills, headaches, muscle aches, lethargy, anorexia, encephalitis, and a dry cough. Pneumonia is often evident on a chest x-ray. Psittacosis may be associated with sick or healthy-looking birds.

4.9.4 ZionSolutions has protocol for evaluating and decontaminating (as appropriate) areas where bird and bat droppings are present to ensure that the potential health hazard has been abated prior to allowing decommissioning work activities to be performed.

4.10 Bloodborne Pathogens (§29 CFR 1910.1030)

4.10.1 All blood and body fluids should be considered potentially infectious. Please notify your supervisor immediately if an exposure has occurred.

4.10.2 Personnel who reasonably anticipate occupational exposure to blood or other potentially infectious material that may result from the performance of designated duties shall receive Bloodborne Pathogen training prior to assignment of these duties and annually thereafter. These personnel includes:



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4.10.2.1 Confined Space Rescue Team Members.

4.10.2.2 First Responders.

4.10.2.3 Fitness For Duty (FFD) collectors.

4.10.2.4 Occupational Health Providers.

4.11 Buddy System

ZionSolutions uses a buddy system for high hazard work activities, including confined space entries and work activities involving potential heat stress, hot work, Lockout/Tagout, fall protection, working over or near water, and operation of powered equipment. The purpose of the buddy system is to provide rapid assistance to employees in the event of an emergency.

4.11.1 Use of fall protection, ladders, and scaffolds requires an independent verification by a co-worker to verify that the ladder / scaffold is safe to use, the travel pathway is free of hazards, and fall protection equipment is donned properly in accordance with the approved Fall Protection Plan.

4.11.2 Individuals may be allowed to work alone under limited and low hazard circumstances as approved by the Work Supervisor. Examples include:

4.11.2.1 Housekeeping.

4.11.2.2 Incipient fire responder and Security work activities as they have established an effective communication system with scheduled and regular check-ins with each other via radio and/or phone to ensure that they are okay.

4.11.2.3 Radiation Protection Technicians performing routine surveys in accordance with approved Radiological Survey JHA’s.

4.12 Carbon Monoxide

Carbon monoxide (CO) is a colorless, odorless, toxic gas which interferes with the oxygen-carrying capacity of blood. Carbon monoxide is non-irritating and can overcome persons without warning. Carbon monoxide is a byproduct of incomplete combustion and requires special monitoring equipment to determine its presence. Work activities that produce carbon monoxide include operation of internal combustion engines and hot work (i.e., oxygen-fuel gas and plasma arc cutting). Safety requirements for carbon monoxide producing work activities include:

4.12.1 Carbon monoxide monitoring of work activities that produce carbon monoxide until representative CO monitoring data verifies acceptable CO levels.


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4.12.2 Ensuring that internal combustion engines are not operated in the vicinity of building air intakes.

4.12.3 Evaluation and implementation of alternate work practices, as appropriate, to eliminate or minimize the production of carbon monoxide.

4.12.4 If use of an internal combustion engine is required indoors (other than intermittently, i.e., bringing a forklift indoors), a carbon monoxide scrubber will be installed on the internal combustion engine or the exhaust will be hard-piped and routed outdoors.

4.13 Caulks, Mastics, Paints, and Coatings

4.13.1 Caulks and mastics are used to seal joints in components, windows, and structures for noise mitigation, thermal insulation, and water penetration. The versatility of caulks and mastics allows them to be used in numerous applications over a wide range of temperatures. The physical properties of caulk and mastics are dependent upon the materials used by the manufacturer; over time caulk and / or mastic may remain soft and pliable, or may become brittle and crumble easily.

4.13.1.1 Some of the materials commonly used in caulks and mastics include asbestos, lead, and PCBs. Sampling caulks and mastics should be performed prior to disturbing the caulk and mastic, and to implement the appropriate work controls to handle and properly dispose of caulks and mastics if asbestos, lead, and/or PCBs are present.

4.13.1.2 If your work activity involves disturbing caulk and / or mastics, the Work Package will identify if asbestos, lead, and/or PCBs are present and the appropriate controls to disturb the caulk and/or mastic. If you should encounter caulk and/or mastic that is not identified in your Work Package, STOP and inform your Supervisor and Industrial Safety & Hygiene. IS&H will perform an evaluation of the caulk and/or mastic to determine the appropriate actions to properly handle the caulk and/or mastic.


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4.13.2 Paints and coatings are used to protect a substrate (i.e., metal, concrete, any material that the paint or coating is applied to) from corrosion and to present a visually pleasing appearance. Paints and coatings are presumed to contain lead until laboratory analysis of the paint has been performed. In addition, the primer in the Unit 1 and Unit 2 Containments are presumed to contain asbestos.

4.13.2.1 Asbestos was used in paints and coatings as it provided a unique combination of strength, flexibility, and insulation.

4.13.2.2 Lead was used in paints and coatings because it increased durability, made colors more vibrant, and helped paint dry faster.

4.13.2.3 PCBs were used in paints and coatings as a plasticizer to allow for flexing of the substrate without cracking of the paint, and water and chemical resistance.

4.13.2.4 If your work activity involves disturbing paint or coatings, the Work Package will identify if asbestos, lead, and/or PCBs are present and the appropriate controls to disturb the paint. If you should encounter paint that is not identified in your Work Package, stop and inform your Supervisor and Industrial Safety & Hygiene. Safety will perform an evaluation of the paint to determine the appropriate actions to properly handle the paint.

4.14 Changing Conditions, Eyes on Path

All personnel are responsible for maintaining their “Eyes on Path” as conditions will change on a continuous basis for the duration of the Zion Restoration Project as Structures, Systems, and Components (SSC’s) are removed. These changes can occur at any time, and require you to constantly evaluate your work area to ensure that conditions are acceptable for you to perform your work safely. Items to evaluate include:

4.14.1 Are there any floor or wall openings that present a fall or trip hazard?

4.14.2 Has anything changed since the last time you were in the work area?

4.14.3 Has changing conditions reduced or eliminated the safety controls required to perform the work activity?

4.14.4 Has removal of any SSC’s created a fall hazard?

4.14.5 In the event of an emergency, how do you safely exit the work area?


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4.14.6 Is my walkway free of hazards (debris, snow / ice / water, overhead work in progress, staged equipment blocking the walkway, safety barriers, etc.) that require selecting an alternate walkway?

4.14.7 Two-Minute Drill – What else can go wrong?

If any unsafe condition is identified, promptly notify your Supervisor for resolution. Implement measures to keep personnel out of the work area until the unsafe condition has been resolved.

4.15 Compressed Gasses (§29 CFR 1910.101)

Compressed gases present a unique hazard. Depending on the particular gas, there is a potential for simultaneous exposure to both mechanical and chemical hazards. If the gas is flammable, flash points lower than room temperature compounded by high rates of diffusion present a danger of fire or explosion. Additional hazards of reactivity and toxicity of the gas, as well as asphyxiation, can be caused by high concentrations of even normally benign gases such as nitrogen. Since the gases are contained in heavy, highly pressurized metal containers, the large amount of potential energy resulting from compression of the gas makes the cylinder a potential rocket or fragmentation bomb.

Compressed gasses will be used in accordance with Reference 2.35 - SAF-16: Handling and Storage of Compressed Gas Cylinders/Portable Tanks and Cryogenic Containers/Dewars. General safety requirements include:

4.15.1 Employees who may use, store, or handle a portable compressed gas cylinder, container, tank, or Dewar should be knowledgeable of Reference 2.35 - SAF-16: Handling and Storage of Compressed Gas Cylinders/Portable Tanks and Cryogenic Containers/Dewars.

4.15.2 Review Safety Data Sheet (SDS) before using any compressed gas or cryogenic liquid.

4.15.3 Do not store or use grease, cleaning solvents, or other flammable material with an oxygen valve, oxygen regulator, or oxygen use piping.

4.15.4 Elevator transport of compressed gasses

4.15.4.1 Personnel shall not ride on an elevator while > 80 cubic feet of compressed gases are being transported (not to include breathing air).

4.15.4.1.1 Compressed gas cylinders larger than 32” tall x 7” diameter will exceed 80 cubic feet.



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4.15.4.2 IF > 80 cubic feet of compressed gas is being transported, then place a WARNING sign just inside the elevator reading: “DO NOT Enter - Compressed Gas in Transit.”

4.15.5 Store and use acetylene cylinders in the upright position at all times.

4.15.6 Compressed gas cylinder valves shall be isolated and hoses shall be depressurized when equipment is unattended and not in use, (i.e., during breaks, lunch, end of day, etc.).

4.15.7 If it is reasonably anticipated that gas will not be drawn from an oxidizing or fuel-gas cylinder within 24 hours (overnight hours included), then:

4.15.7.1 Remove the regulators and install the cylinder protective caps.

4.15.7.2 Separate oxygen cylinders from fuel-gas cylinders (i.e., acetylene, gasoline, petroleum gas, and propane, etc.) or other combustible material by:

4.15.7.2.1 A non-combustible barrier at least 5-feet high having a fire resistance rating of at least one-half hour;

4.15.7.2.2 A minimum of 20 feet distance.

4.15.8 Do not lift compressed gas cylinders by the cap, valve, or with magnets. Compressed gas cylinders shall only be lifted in approved storage carts or other rigging configurations authorized by the Master Rigger or manufacturer.

4.15.9 Do not use slings, ropes, or chains to handle compressed gas cylinders, unless retrofitted with appropriate lifting attachments.

4.15.10 Ensure compressed gas cylinder caps are installed properly (i.e., the correct cap for the cylinder and hand-tightened).

4.15.11 Use hand-trucks, cylinder carts, or motorized trucks when transporting cylinders.

4.15.12 Post approved storage areas with the hazard class or the name of the gases stored. Post “No Smoking” signs where appropriate.

4.15.13 Secure all compressed gas cylinders, including empties, by one of the following options to prevent cylinders from falling while in use, being transported, or in storage. Position the securing device above the center


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of gravity (e.g., about 1/3 down from top), in front of or around the cylinder(s).

4.15.13.1 A minimum 1/4 -inch wire cable.

4.15.13.2 A substantial metal chain.

4.15.13.3 Substantial straps that include a fastening mechanism (e.g., buckle). Velcro is not a suitable fastening mechanism.

4.15.13.4 Clamps, chains, or straps that are designed as part of a manufactured system for the purpose of securing cylinders.

4.15.14 Use approved flash arrestors on gas welding and cutting equipment in both the fuel-gas and oxygen lines at the torch end of the hose.

4.16 Concrete

During the course of the Zion Restoration Project, concrete dust may be generated by the work process. Different concretes have different ingredients, some that can be hazardous like silica, lime, gypsum, nickel, cobalt, and chromium compounds. Engineering Controls, PPE, and approved Work Practices will be defined in the Work Package to minimize dust release and keep the dust levels low.

4.16.1 The potential health risks from breathing concrete dust include:

4.16.1.1 Cancer - from the small amounts of chromium compounds found in some cements.

4.16.1.2 Chronic bronchitis.

4.16.1.3 Silicosis - from the crystalline silica (quartz) used in many cements (please see Attachment 6 – Background Information on Silica.

4.16.2 The potential health risks from direct contact with wet concrete include:

4.16.2.1 Allergic reactions that may develop slowly over a long period of time.

4.16.2.2 Burns, rashes, and other kinds of skin irritation. Lime, found in most concrete, is often the cause.

4.16.2.3 Eye irritation.


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4.17 Confined Spaces (§29 CFR 1910.146)

4.17.1 A Confined Space is defined as an area that:

4.17.1.1 Is large enough and so configured that an employee can bodily enter and perform assigned work.

4.17.1.2 Has limited or restricted means for entry or exit (tanks, vessels, silos, storage bins, pipes, heat exchangers, vaults, pits, etc.).

4.17.1.3 Is not designed for continuous employee occupancy.

4.17.2 ZionSolutions work activities may require entry into confined spaces, which shall be performed in accordance with Reference 2.32 - SAF-12: Confined Space Entry. ZionSolutions shall perform atmospheric monitoring prior to entering a confined space. Entry into a confined space requires a Confined Space Evaluation Permit.

4.17.3 Demolition of existing structures may create or allow access into previously inaccessible spaces. ZionSolutions employees and subcontractors shall be vigilant for the presence of confined spaces and will notify their Supervisor and Industrial Safety & Hygiene if such a space is found. Do not enter such spaces until a Confined Space Evaluation Permit is obtained.

4.17.4 ZionSolutions intent is to minimize entry into Permit-Required Confined Spaces, i.e., our intent is to eliminate any hazards to allow reclassification to a Non-Permit Confined Space.

4.17.4.1 Prior to any bodily entry into a Permit Required Confined Space (PRCS), a Confined Space Rescue Team (CSRT) shall be available on-site. This service will likely be supplied by a third party entity as ZionSolutions does not currently maintain an on-site Rescue Team. Third Party CRSTs contracted to perform confined space rescue shall meet the requirements listed in §29 CFR 1910.146(k) in addition to any additional requirements put forth by ZionSolutions.

4.18 Contact Lenses

Contact lenses may be worn in an industrial environment at Zion:

4.18.1 In combination with appropriate industrial safety eyewear, except where there is likelihood of injury from intense heat, massive chemical splash, or highly particulate atmosphere.



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4.18.2 With approval of the Respirator Program Administrator, contact lenses may be worn with respiratory protection equipment provided the wearer has demonstrated successful experience in wearing such lenses, e.g., by wearing the contacts during respirator fit testing.

4.19 Contractor Control

Contractors will be utilized to perform specific work activities. ZionSolutions is the Controlling Employer at the Zion Nuclear Station and retains the ultimate responsibility to ensure that work performed by contractors is performed per contract requirements, in accordance with References 2.57 - ZS-AD-101: Management and Oversight of Supplemental Work Force, 2.58 - ZS-AD-102: Construction Management, and 2.59 - ZS-AD-103: Control of Systems, Structures, or Components (SSCs) Turnover from ZionSolutions to Demolition Contractor and meets ZionSolutions standards and expectations.

4.19.1 Safety Expectations - The subcontractor shall be aware of and comply with the ZionSolutions focus on safety.

4.19.2 Subcontractor shall bring no materials on site that contain asbestos greater than 1% or contains any refractory ceramic fiber (RCF).

4.19.3 Subcontractor shall develop a Project-Specific Health and Safety Plan (HASP) for their Zion work activities. Based on the Contractor’s work scope, the ZionSolutions Manager, Industrial Safety & Hygiene, may waive this requirement. In the event that a Project Specific Health and Safety Plan is not required, the Contractor shall comply with the ZionSolutions Health and Safety Plan.

4.19.4 Subcontractor shall make their tools and equipment available for inspection to the ZionSolutions Industrial Safety & Hygiene Department prior to usage. ZionSolutions reserves the right to prohibit the use of specific tools and equipment based on safety, quality, or technical considerations.

4.19.5 Subcontractor shall promptly notify their ZionSolutions Designated Manager of all injuries, near misses, spills, equipment failures, and safety concerns; and conduct safety investigations in accordance with their approved Health and Safety Plan. The ZionSolutions Designated Manager is responsible for reporting these occurrences to the Manager, Industrial Safety & Hygiene.


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4.19.6 Subcontractor shall provide copies of applicable employee training records, licenses, respirator fit tests, and medical clearances (i.e., Physician’s Written Opinion) supporting their work activities to the ZionSolutions Manager, Industrial Safety & Hygiene. These include:

4.19.6.1 AED/CPR/First Aid (Energized Electrical)

4.19.6.2 Asbestos Abatement Plans (Class I or Class II)

4.19.6.3 Crane Operator Physical (Physician’s Written Opinion)

4.19.6.4 Crane Operator training / certification

4.19.6.5 Excavation Competent Person training / certification

4.19.6.6 Fall Protection / Rescue Plan

4.19.6.7 Forklift Operator Training / Certification

4.19.6.8 Respirator fit tests (quantitative only, qualitative fit tests are not allowed)

4.19.6.9 Respirator Physicals (Physician’s Written Opinion)

4.19.6.10 Respirator Training

4.19.6.11 Riggers Training / Certification

4.19.6.12 Scaffold Builder Training / Certification.

4.19.6.13 Subcontractor shall submit Safety Data Sheets for all chemicals to the ZionSolutions Manager, Industrial Safety & Hygiene a minimum of 7 days prior to bringing the chemical on site. ZionSolutions reserves the right to prohibit the use of any specific chemical.

4.19.6.14 Subcontractors shall submit their Confined Space Program to the ZionSolutions Manager, Industrial Safety & Hygiene a minimum of 7 days prior to use for evaluation and approval in accordance with Reference 2.52 - SA-ZN-114: Confined Space Entry if the Subcontractors work activities require entry into a confined space.

4.19.6.15 Subcontractors shall submit their Respiratory Protection Program to the ZionSolutions Manager, Industrial Safety & Hygiene a minimum of 7 days prior to use for evaluation and approval in accordance with Reference 2.28 - SAF-07:


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Respiratory Protection Program if the Subcontractors work activities require the use of respiratory protection.

4.20 Cryogenic Liquids

Cryogenic liquids are liquefied gases that are kept in their liquid state at very low temperatures. All cryogenic liquids are gases at normal temperatures and pressures. These gases must be cooled below room temperature before an increase in pressure can liquefy them. Different cryogens become liquids under different conditions of temperature and pressure, but all have two properties in common: they are extremely cold, and small amounts of liquid can expand into very large volumes of gas, displacing the oxygen required to sustain life. The vapors and gases released from cryogenic liquids also remain very cold. They often condense the moisture in air, creating a highly visible fog. Cryogenic liquids shall be handled in accordance with Reference 2.35 - SAF-16: Handling and Storage of Compressed Gas Cylinders/Portable Tanks and Cryogenic Containers/Dewars.

4.20.1 There are three groups of health hazards associated with cryogenic liquids:

4.20.1.1 Asphyxiation.

4.20.1.2 Extreme cold.

4.20.1.3 Toxicity.

4.20.2 Handle and store cryogenic containers in an upright position and in a well-ventilated area to prevent hazardous concentrations of the gas.

4.20.3 Wear a face shield, and safety glasses or safety goggles, when there is a potential for exposure to cryogenic liquids.

4.20.4 Wear hand protection, such as insulated gloves, to prevent contact with cold liquid, cold gas, and cold equipment or piping. Gloves should be loose fitting so that they can be readily removed in the event liquid is splashed into them.

4.20.5 When filling Dewars or other containers with liquid nitrogen, use of an oxygen meter that is within required calibration and has been bump-tested is recommended. Follow manufacturer's instructions for using the meter.

4.20.6 Liquid oxygen is used for thermal cutting (oxygen-acetylene, oxygen-gasoline, etc.).

4.20.6.1 The hazards associated with liquid oxygen are exposure to extreme cold temperatures; over-pressurization due to expansion of liquid into large volumes of gas; oxygen


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enrichment of the surrounding atmosphere; and combustion reactions if the oxygen is permitted to contact combustible materials.

4.20.6.2 Required PPE is a full faceshield over safety glasses; clean, loose-fitting, thermal-insulated or leather gloves; long-sleeved shirt; and pants without cuffs. Never allow any unprotected part of the body to come in contact with uninsulated pipes or equipment containing liquid oxygen.

4.20.6.3 Liquid oxygen containers (Dewars) are equipped with pressure-relief valves and rupture disks to protect the Dewar from internal pressure buildup. Do not plug, remove or tamper with any pressure relief device.

4.20.6.4 Materials ignite more easily and also burn more vigorously in the presence of increased oxygen. All fittings, valves, tubing must be oil and grease free. Oxygen must be separated from flammables and combustibles by at least 20 feet or a half-hour fire wall. Do not permit smoking or open flames in any areas where liquid oxygen is stored or handled. Post "No Smoking" and "No Open Flames" signs. Keep all valves closed and outlet caps in place when not in use.

4.20.6.5 Clothing saturated with oxygen is readily ignitable and will burn vigorously. Any clothing that has been splashed or soaked with liquid oxygen or exposed to high oxygen concentrations should be removed immediately and aired for at least an hour. Personnel should stay in a well-ventilated area and avoid any source of ignition until their clothing is completely free of any excess oxygen.

4.20.6.6 Dewars must be stored and used in the upright position. Never slide or roll Dewars on their side. Dewars may be moved in a tipped position on dollies or carts designed for that purpose, but must be returned to an upright position for storage and use. Clear the planned travel path before moving the Dewars. Do not ride the elevator with the Dewar. Place a warning sign just inside the elevator reading, "DO NOT Enter Liquid Oxygen in Transit."

4.20.6.7 Avoid mechanical and thermal shock. Open valves on Dewars slowly to avoid accelerating any debris to high speeds that could generate heat and sparks.


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4.20.6.8 Do not remove or interchange connections. Use only the properly assigned connections. Do not use adaptors.

4.20.6.9 For skin contact with liquid oxygen, immediately contact Occupational Health Services. Remove any clothing that may restrict circulation to the frozen area. Do not rub frozen parts as tissue damage may result.

4.20.7 Liquid nitrogen is required for the proper operation of some radiological instruments. In addition, other work processes (i.e., welding) may require the use of cryogenic liquids.

4.21 Demolition Engineering Surveys (§29 CFR 1926.850)

Reference 2.10 - ANSI/ASSE A10.6-2006: Safety and Health Requirements for Demolition Operations requires that prior to commencing demolition operations, a Demolition Engineering Survey shall be made, by a Competent Person, of the structure to determine the condition of the framing, floors, and walls, and possibility of unplanned collapse of any portion of the structure.

4.21.1 Any adjacent structure where employees may be exposed shall also be similarly checked.

4.21.2 The Demolition Engineering Survey requirements shall be incorporated into the Work Package or the Subcontractor’s Work Plan.

4.21.3 Demolition of structures shall be performed in accordance with Reference 2.19 - OSHA Technical Manual Section V: Chapter 1 – Demolition and the applicable Work Package.

4.21.4 A minimum of 10 working days notification will be made to the Illinois EPA (IEPA) prior to commencing building or structure demolition.

4.22 Diving (§29 CFR 1910 Subpart T)

Diving activities will be performed to support the Zion Restoration Project and shall be performed in accordance with Subpart T – Commercial Diving Operations of Reference 2.2 - §29 CFR 1910: Occupational Safety and Health Standards.

4.23 Dropped Objects

Decommissioning work activities requires work to be performed at heights, with the potential for dropped objects. Anything that is not on the ground or floor possesses potential energy (positional energy). If it is dropped or inadvertently knocked from a surface in the overhead and falls to a level below, it changes this potential energy to kinetic energy (energy of motion). Dropped objects have the potential to cause

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10795&p_table=STANDARDS



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equipment damage, personnel injury, or death. Methods to prevent dropped objects onto personnel may include:

4.23.1 The Pre-job briefing should include a discussion of dropped object risks including an evaluation of the work environment work method, tools, equipment, and material to be used.

4.23.2 Establishing barricades below overhead work to keep personnel out of the drop zone.

4.23.3 If working from an elevated position, post signs warning of the hazards below the elevated work. Consider clearing personnel from the area below and temporarily re-routing walkways.

4.23.4 Ladders

4.23.4.1 Loose items removed from pockets and nothing shall be hand carried when ascending / descending ladders.

4.23.4.2 Only one person at a time is allowed on ladders.

4.23.4.3 For permanent ladders, personnel shall remain distant from the ladder lower access and potential drop zone when another individual is ascending / descending the permanent ladder.

4.23.5 NOTHING shall be tossed or thrown to anyone under any circumstances.

4.23.6 Proper housekeeping to minimize accumulation of objects that could be dropped.

4.23.7 Scheduling work activities such that overhead work is not in progress concurrently with personnel working below the overhead work.

4.23.8 Use of reinforced containers (i.e., canvas-reinforced electrician’s bag) to vertically transport tools and material; buckets and pails are prohibited for this purpose.

4.23.9 Use of restraining lanyards on tools and equipment.

4.23.10 Use of toeboards and netting (i.e., Pearlweave™) on overhead scaffolding and walkways.

4.23.11 Use slip resistant coverings on grating and floor penetrations to prevent small items from falling through the openings.


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4.23.12 Where tools, equipment or other objects are placed next to guardrails, containment sheets (solid or mesh) that are high enough to ensure that objects cannot fall should be installed.

4.24 Drugs and Alcohol

ZionSolutions has zero tolerance for the use or abuse of alcohol or controlled substances. Reference 2.53 - SP-19: Fitness For Duty Program is designed to provide reasonable assurance that ZionSolutions employees and subcontractors are free of any substance that may adversely affect work performance.

For Cause testing should be performed for all employee and subcontractors involved in an injury requiring medical treatment, accident, near miss, or negligent or careless act in accordance with Reference 2.53 - SP-19: Fitness For Duty Program.

4.25 Drums

Pressurized drums pose a serious hazard to employees. When a drum lid or ring from a pressurized drum is released in an uncontrolled fashion, it can become a dangerous projectile, causing serious injury or death to the worker or other workers in the vicinity. Drums that appear to be in acceptable condition may still contain enough pressure to cause injury. Work activities that entail opening drums shall be performed in accordance with the requirements listed below.

4.25.1 Engineering controls are required to ensure workers are protected from the potentially serious hazards of removing lids on all drums, empty and full. This includes drums that do not exhibit signs of overpressurization. The engineering controls to remove lids must include one of the following:

4.25.1.1 A process which removes the lid remotely, or de-pressurizes the drum remotely, thus removing the projectile exposure potential to workers.

4.25.1.2 A barrier system that allows manual opening of drums, but does not allow the lid to become a projectile.

4.25.2 The engineering controls shall be evaluated by the Manager, Industrial Safety & Hygiene to ensure the chosen methods provide adequate protection for employees. In addition, the evaluation shall ensure new hazards are not introduced to the process.

4.25.3 The approved engineering controls should be incorporated into the Work Package and/or Task Hazard Analysis, as appropriate.


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4.25.4 Engineering controls approved for removing drum lids are:

4.25.4.1 Operation of a vent valve installed on the drum lid.

4.25.4.2 Positioning (lowering) forklift tines on top of the drum lid to restrain the drum lid.

4.25.4.3 Slowly loosening the bung (if the drum lid has bungs) to allow pressure to vent past the loosened bung threads. Once venting is complete the bung may be removed from the drum lid.

4.25.4.4 Use of the Drum Web 5585 to restrain the drum lid to prevent the drum lid becoming a projectile during removal if pressure is inside of the drum. Training is required for personnel using the Drum Web 5585.

4.26 Electrical Safety (§29 CFR 1926 Subpart K)

4.26.1 Work activities that require working on or near electrical equipment and electrical power sources shall be performed by Qualified Individuals in accordance with Reference 2.38 - SAF-19: Electrical Safety.

4.26.2 Only Electricians shall connect or disconnect 480 volt equipment.

4.26.3 Electrical Equipment – The working space in front of electrical equipment (i.e., switchboards, panelboards, or motor control centers, breakers, temporary electrical distribution panels, etc.) shall be maintained free and clear to permit ready and safe operation and maintenance of such equipment. The minimum dimensions of the work space are:

4.26.3.1 At least the width of the electrical equipment or 30 inches, whichever is greater,

4.26.3.2 At least 6.25 feet high from the grade, floor, or platform, and

4.26.3.3 At least 3 feet deep.

4.26.4 Entry into the Transmission and Substation switchyard will require wearing flame resistant clothing PPE.

4.26.5 Extension cords must be inspected prior to use to ensure the cord, plug, and receptacles are free of damage.



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4.26.6 Flexible cords and cables may not be routed through holes in walls, ceilings, or floors where openings are not designed to protect the cord and/or cable.

4.26.6.1 Movement of the flexible cord and cable may result in damage to the insulation with subsequent electrical arcing and shorting.

4.26.6.2 Temporary protection (i.e., wrapping the flexible cords and cables) may be used if the protection is adequate to prevent damage to the flexible cord and cable.

4.26.7 Flexible cords and cables passing through doorways that are protected from damage of the closing door are allowed.

4.26.8 Flexible cords and cables should be run in the overhead whenever possible (after verification with Radiation Protection that radiological conditions are acceptable), and protected from damage.

4.26.9 Ground Fault Circuit Interrupter (GFCI)

4.26.9.1 GFCI’s shall be visually inspected and tested by the user before each day’s use.

Note: Equipment, that by design will not operate properly when connected to a GFCI (Ground Fault Circuit Interrupter) are exempt from this requirement.

4.26.9.2 Use a GFCI (plug in or fixed) at the power on all 120/240 volt A/C receptacle circuits when:

4.26.9.2.1 Using an extension cord, portable electrical tools and temporary lighting (e.g., drop lights),

4.26.9.2.2 In wet environments,

4.26.9.2.3 Used outdoors, and

4.26.9.2.4 Used inside Confined Spaces.

4.26.9.3 Test GFCI units/circuits prior to use. GFCI’s may be tested by a GFCI tester, in accordance with the manufacturer’s instructions, or in the following manner:

4.26.9.3.1 Push the "Reset" button of the GFCI receptacle to prepare the unit for testing,


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4.26.9.3.2 Plug a piece of electrical equipment (a light is suggested) into the GFCI outlet and TURN it on. The equipment should be ON,

4.26.9.3.3 Push the "Test" button of the GFCI receptacle. Equipment should go OFF,

4.26.9.3.4 Push the "Reset" button again. Equipment should go ON.

Note: If the equipment remains on when the “Test” button is pushed, either the GFCI is not working properly or has not been correctly installed. Clearly mark to prevent re-use and remove from workplace, and CONTACT Industrial Safety for further guidance.

4.26.9.3.5 Do not expose GFCI units to rain or accumulated water, unless specifically designed for that purpose.

4.27 Emergency Eyewash Stations

4.27.1 Emergency eyewash stations are required to be located within 10 seconds unobstructed walking time from work activities where the eyes or body of a person may be exposed to injurious corrosive materials.

4.27.2 Emergency eyewash stations shall be inspected and maintained in accordance with Reference 2.51 - SAF-32: Eyewash and Shower Tests & Checks.

4.27.3 If you should notice that an eyewash station has low pressure or inadvertently discharge the eyewash station, contact the Fix-It Now (FIN) Team on DD 1 radio channel or the Facilities radio channel to notify so that the eyewash station can be inspected and recharged.

4.27.4 The protective dust caps on emergency eyewash stations are designed to prevent dust accumulation in the eyewash nozzles that could then be flushed into the users' eyes. There is sufficient pressure in the emergency eyewash station to "blow off" the protective dust caps when the emergency eyewash station is activated; the protective dust caps are not to be removed from the eyewash nozzles.


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4.28 Excavations and Trenching (§29 CFR 1926 Subpart P)

ZionSolutions work activities may involve trenching, digging, excavating, penetrating, or disturbing soils. These work activities shall be performed in accordance with Reference 2.20 - OSHA Technical Manual Section V: Chapter 2 - Excavations: Hazard Recognition in Trenching and Shoring and Reference 2.33 - SAF-14: Excavation, Trenching, and Shoring.

4.28.1 Any man-made cut, cavity, trench, or depression in an earth surface formed by earth removal is an excavation.

4.28.2 An Excavation Permit is required for all excavation work, which is defined as the use of powered equipment, explosives, or hand digging in the movement of earth, rock or other material.

4.28.2.1 Excavation work includes but is not limited to anchoring, auguring, backfilling, boring, digging, ditching, drilling, driving-in, grading, plowing-in, pulling-in, ripping, scraping, trenching, and tunneling.

4.28.3 All excavations must utilize soft dig technologies unless otherwise approved by the Manager, Industrial Safety & Hygiene, and VP of Construction and D&D.

4.28.4 A Competent Person shall be on site whenever excavation work activities are performed.

4.28.4.1 The Competent Person shall perform and document a Daily Inspection of the Excavation in accordance with Reference 2.33 - SAF-14: Excavation, Trenching, and Shoring.

4.28.4.1.1 Competent Person Daily Inspections are not required for holes drilled for soil sampling purposes, i.e., geoprobe sampling.

4.28.4.2 Subcontractors performing excavation work activities should designate their own Excavation Competent Person to manage the excavation work activities.

4.28.5 The State of Illinois requires notification to JULIE, Inc. (Joint Utility Locating Information for Excavators) at least 48 hours (excluding weekends and holidays) in advance of the start of excavation at 1-800-892-0123 or 811. JULIE will only accept requests for underground mapping from the Work Supervisor or Contractor performing the excavation work activity.



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4.28.5.1 JULIE serves as a message handling, notification service for underground facility owners, taking information about planned excavations and distributing this information to its membership. It is then the responsibility of each underground facility owner to mark the location of their underground facilities at the excavation site using marking flags color-coded as per Table 1 – Illinois Underground Utility Flag Color Codes. Soft excavation technologies and / or hand digging shall be performed in the vicinity of identified underground utilities.

4.28.5.2 If JULIE declines to provide these services, ZionSolutions will review site drawings and self-perform or subcontract underground mapping for buried utilities.

4.28.6 Damage to underground utilities is credible if penetration of the earth is required, i.e., exploratory digging, installation of tent stakes, environmental monitoring, etc., even if an excavation is not required.

Table 1 – Illinois Underground Utility Flag Color Codes Red Electric

Orange Telephone; Cable TV; Fire and Police Communications

Yellow Gas, Oil, Petroleum

Green Sewer

White Proposed Excavation

Blue Water

Purple Reclaimed Water

Pink Temporary Survey

4.29 Fire Prevention and Emergency Egress Protocols

4.29.1 24-hour incipient fire responder shall be in place. The incipient fire responder on duty shall perform periodic (at least every 6 hours) walk through of the plant and immediately report any indication of fire to the ISFSI Shift Supervisor who shall implement protocols described in Reference 2.11 - AOP 4.5: Plant Fire Alarm. The incipient fire responder shall be a trained firewatch and shall only attempt to extinguish a fire if it is first reported to the ISFSI Shift Supervisor and the incipient fire responder determines it is safe to do so per their fire watch training.

4.29.2 A minimum 20-pound ABC fire extinguisher shall be available at each elevation within 100 feet of where work is being performed. At least one


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fire extinguisher shall be located at each stairway at each elevation of a building. In certain circumstances, a single fire extinguisher may satisfy both aforementioned requirements. These fire extinguishers shall not be used for hot work activities. Additional fire extinguishers per the hot work permit shall be stationed where required.

4.29.3 Supervisors shall determine assembly areas in the event of a fire evacuation and communicate those to the work crews in the pre-job brief.

4.29.4 Air horns shall be placed at the stairway of each floor in buildings where the fire alarm system has been taken out of service. Personnel shall be trained to only sound the air horn(s) in the event of a local emergency and an evacuation in the immediate area is necessary. When an air horn is sounded, personnel shall put their work area in a safe condition and immediately evacuate the area to the predetermined assembly location area. The ISFSI Shift Supervisor Emergency Number (5-2211 or 847.379.2211) shall be called or OPS-1 shall be radioed anytime an air horn is sounded with an explanation of the emergency. The ISFSI Shift Supervisor shall put out over the radio the nature of the emergency, if additional evacuations are necessary, and when it is safe to return the work areas. Instructions shall be posted by each air horn location.

4.29.5 Active elevators shall remain in compliance with the elevator use permit.

4.29.6 Hot work permits shall continue to be required for hot work activities; Hot Work shall be performed in accordance with Reference 2.55 – ZAP 900-01: Station Fire Protection Program.

4.29.7 Housekeeping shall be maintained and combustible materials not allowed to accumulate in excess in accordance with Reference 2.55 – ZAP 900-01: Station Fire Protection Program.

4.29.8 At least one stairway shall be left open for egress in each building. The location of the work shall take into account the stairway location(s). The egress stairway shall not be blocked by the work activities. All personnel on that elevation shall be made aware of the open stairway(s) location during the pre-job brief.

4.29.9 Stairways shall be lit by temporary lighting. All lighting shall be inspected and maintained by site electricians.

4.29.10 At least one radio shall be available per work crew per level when personnel are working on each level. The “EMERGENCY ALL CHANNEL” call shall be used by the ISFSI Shift Supervisor to alert personnel of an emergency and prompt an evacuation if necessary.


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4.29.11 In the event of a power failure, personnel shall use their hardhat lights for illumination where backup lighting may not be available. Hardhat lights are mandatory for all personnel who enter Power Block Buildings. Where work is being performed, photo-luminescent arrows or sign boards are painted, stuck, or placed on the floors and walls along walkways indicating exit route(s). If an exit route is changed, the exit route markings shall be covered or removed and then reapplied showing the new exit path. It is the responsibility of the Superintendent in charge of the work in the building to verify that exits are properly marked and information is disseminated to the work crews.

4.29.12 Battery operated smoke alarms shall be used in office locations outside the Power Block Buildings. D&D Maintenance Crew shall mount the smoke alarms in areas identified by IS&H, test them on a monthly basis, and change out the batteries on a minimum annual basis.

4.29.13 During winter weather months, the roadway completely around the Turbine Building and two Containments shall be plowed of snow by at least two plow widths so emergency responders can have access as necessary. Access to standpipes/fire department connections (FDCs) shall also be clear of snow and debris so they can be accessed in the event of a fire. The FDCs are located outside U1 and U2 trackways.

4.29.14 On at least an annual basis, the Zion Fire Department shall tour the Zion Restoration Project to evaluate emergency response effectiveness during the changing conditions during demolition.

4.30 First Aid / Medical Care for Injuries – Occupational Health Services (§29 CFR 1926.50)

ZionSolutions maintains an Occupational Health Services Medical Staff, including a Nurse and First Responders that are certified in First Aid, Automated External Defibrillators (AED) and CPR. All injuries, no matter how slight, shall be promptly reported to immediate supervision and the Manager, Industrial Safety & Hygiene. ZionSolutions shall:

4.30.1 Ensure that there are first aid supplies at the jobsite and that the supplies are readily accessible.

4.30.2 Ensure the availability of medical personnel for advice and consultation on matters of occupational health.

4.30.3 Provide proper equipment for the prompt transportation of an injured person to a physician or hospital and a communication system for contacting the necessary emergency service. The telephone numbers of a physician, hospital, or emergency service shall be conspicuously posted




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at prominent locations in the workplace (Attachment 11 – Emergency Contact Information (typical).

4.30.4 First aid kit supplies shall be sealed in individual packages, stored in a weatherproof container, and checked by the Occupational Health Nurse before commencing work activities and at least weekly to ensure that expended items are replaced.

4.30.5 Automatic External Defibrillators (AEDs) are pre-staged in various locations and shall be operated by trained personnel in accordance with Reference 2.26 – SAF-05: Purchase and Administration of Automatic External Defibrillators (AED’S).

4.30.6 Individuals shall report the use of prescription or over-the-counter medication, other than aspirin, aspirin substitute, anti-bacterial, and birth control, to their Supervisor and Occupational Health Services if they believe that the prescription or over-the-counter medication may impair their alertness, judgment or any other ability to safely perform their job duties in accordance with Reference 2.53 – SP-19: Fitness For Duty Program.

4.30.6.1 The name of the medication should not be disclosed to the Supervisor and the employee should be sent to Occupational Health Services (OHS) to fill out a Medication Information Form.

4.30.6.2 The Medical Review Officer (MRO) must evaluate the medication(s) the individual is taking to determine if the medication will impair alertness, judgment, or any other ability to perform their job duties and could result in job restriction.

4.30.6.3 Individuals must consult with the MRO for guidance on any job restriction recommendation.

4.30.6.4 Individuals must notify the ZionSolutions Access Authorization/Fitness for Duty Supervisor and the individual’s Supervisor when it is determined that the medication will impair alertness, judgment or any other ability to perform their job duties and a job restriction is recommended.

4.30.7 Sharps

4.30.7.1 Sharps containers have been installed in restrooms on-site. These have been placed so they are easily accessible to all


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personnel and close to areas where sharps could potentially be used. All contaminated sharps shall be discarded immediately or as soon as possible after use into the Sharps containers which are closable, puncture resistant and leak-proof on the sides and bottom. The locking system maintains them in an upright position. The containers are clearly labeled with the appropriate biohazard symbol. They can be closed and secured for transport and disposal with our medical waste handler.

4.30.7.2 Broken glassware should never be directly picked up with your hands. Use tongs, forceps or a brush and dustpan. Never reach into a container where contaminated sharps have been placed. The Sharps containers will be checked on a regular basis. If you note a container is nearing capacity and ready for replacement, please contact Occupational Health Services at (224) 789-4079.

4.31 Flammable and Combustible Liquids and Aerosols (§29 CFR 1926.152)

Flammable and combustible liquids and aerosols shall be handled in accordance with Reference 2.55 – ZAP 900-01: Station Fire Protection Program. Specific controls include:

4.31.1 Gasoline is used for the Petrogen cutting torch.

4.31.1.1 In the Aux Building, the Petrogen gasoline container should be filled in a location as determined by the Fire Marshall, Radiation Protection, and IS&H. The Petrogen gasoline can must be filled from either:

4.31.1.1.1 An approved safety can of no more than two gallon capacity; or

4.31.1.1.2 An approved portable, wheeled tank of larger capacity provided a manual, non-sparking pump is used.

4.31.1.2 If transporting gasoline container(s) by elevator, then:

4.31.1.2.1 Personnel shall not ride on an elevator while gasoline container(s) are being transported.

4.31.1.2.2 Place a WARNING sign just inside the elevator reading, “DO NOT ENTER – Gasoline in Transit.”



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4.31.2 Flammable and combustible liquids or aerosols, when taken into the plant, should be limited to only the quantity necessary to perform the job activity, or the amount that can be used in one shift.

4.31.3 In areas where flammable liquids and aerosols are to be used, a check of the area (above, below, and adjacent) shall be made for possible ignition sources (welding, cutting, open flames, smoking, electrical or mechanical sparks, hot equipment, etc.).

4.31.4 Flammable/Combustible Liquids Storage Cabinets

4.31.4.1 Flammable/Combustible Liquids Storage Cabinets are stationed in various areas of the plant. They contain fluids (flammable aerosols, oil, etc.) that must be isolated and segregated from less volatile, everyday items and heat/ignition sources. The cabinets are easily identifiable by their color (yellow) and labeling which identifies them.

4.31.4.2 Do not store any items within 2 feet or on top of any Flammable/Combustible Liquids Storage Cabinet.

4.31.4.3 Storage of flammable/combustible liquids outside of a Fire Marshal approved Flammable/Combustible Liquids Storage Cabinet in the plant is prohibited, unless otherwise approved by the Fire Marshal/designee.

4.31.4.4 Any flammable storage cabinets that are placed in the plant need to be communicated to the Fire Marshall so that they may be added to the periodic inspection list. This is required by NFPA (National Fire Protection Association) Code as well as NEIL (Nuclear Electric Insurance Limited) Standards. In addition, flammable storage cabinets require a Chemical Storage Permit.

4.31.4.5 Flammable/Combustible Liquids Storage Cabinet shall be inspected semi-annually in accordance with Reference 2.52 – SAF-33: Flammable and Combustible Liquids.

4.31.5 Safety Cans

4.31.5.1 Safety cans shall only be used for the liquid for which they are identified. Contamination of a liquid may result in a change of classification.


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4.31.5.2 Flammable and combustible liquids shall be transported in approved safety cans per Reference 2.55 – ZAP 900-01: Station Fire Protection Program.

4.31.5.3 Liquids stored in approved safety cans must be identified.

4.31.5.4 Safety cans for “flammable” liquids shall be painted red with either:

4.31.5.4.1 A yellow band around the can, and a tag identifying the contents, or

4.31.5.4.2 The name of the contents stenciled on the can with yellow paint.

4.31.5.5 Safety cans for “combustible” liquids shall be painted blue, and the contents identified.

4.32 Floor / Wall Openings

The decommissioning of the Zion Nuclear Station will create floor and wall openings that may not have been present since construction due to the removal of plant components, piping, structures, etc. A floor opening is a gap or void twelve inches or more in its least dimension in a floor, roof or other walking/working surface.

4.32.1 The priority for control of floor and wall openings is to eliminate the hazard when feasible, followed by protection from the fall hazard. The preferred order for accomplishing this is:

4.32.1.1 Install midrail / guardrail prior to component removal (the guardrail must be positioned at 42” ± 3”, the midrail must be positioned halfway between the guardrail and the floor);

4.32.1.2 Install cover as component is removed (ensuring that no part of the body is placed under or near a suspended load); or

4.32.1.3 Install cover once component has been removed, utilizing fall protection / fall restraint if applicable to ensure personnel are adequately protected from the fall hazard while installing the cover.

4.32.2 Additional controls include:

4.32.2.1 All covers shall be marked with the word “HOLE” or “COVER” to provide warning of the hazard.


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4.32.2.2 All covers shall be secured when installed so as to prevent accidental displacement by the wind, equipment, or employees.

4.32.2.3 Covers shall be capable of supporting without failure, at least twice the weight of employees, equipment, and materials that may be imposed on the cover at any one time. ¾” plywood is only acceptable for floor openings <24”, additional plywood sheets are required if the floor opening is ≥24” in any dimension.

4.32.2.4 Protect each employee on walking/working surfaces from falling through holes more than 6 feet above lower levels by the use of a guardrail system, cover, or personal fall arrest system.

4.32.2.5 Protect each employee working on, at, above, or near a wall opening where the outside bottom edge of the wall opening is 6 feet or more above Lower Levels, and the inside bottom edge of the wall opening is less than 39 inches above the walking/working surface, from falling by the use of a guardrail system or personal fall arrest system.

4.33 Forklifts (Powered Industrial Trucks) (§29 CFR 1910.178)

Forklifts shall be operated in accordance with Reference 2.37 – SAF-18: Powered Industrial Truck Operation.

4.33.1 An ABC fire extinguisher shall be readily available and in operable condition on each forklift.


4.33.1.2 A monthly (periodic) inspection of the fire extinguisher shall be performed by the forklift operator. The periodic inspection criteria is designated on a sticker affixed to the fire extinguisher. The periodic inspection shall be documented on the shiftly inspection sheet.

4.33.2 Attachments installed on the forklift shall be provided by the manufacturer. Use of non-manufacturer attachments requires the written approval of the manufacturer. The written approval shall be included in the Work Package prior to use of the attachment.



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4.33.3 “Free Rigging” (the direct attachment to or placement of rigging equipment, i.e., slings, shackles, rings, etc. onto the tines of a forklift for a below the tines lift) is prohibited unless written approval from the manufacturer is provided.

4.33.4 A shiftly inspection of the forklift shall be performed and documented when in use. Forklifts requiring maintenance shall not be operated until repairs have been made.

4.33.5 An operable backup alarm is required on all forklifts.

4.33.6 Drive the forklift in reverse with the load trailing; using Signal Persons and spotters, whenever the load being carried obstructs forward view.

4.33.7 Lower forks, neutralize controls, shut-off power and set brakes whenever leaving forklift unattended.

4.33.7.1 A powered industrial truck is unattended when the operator is 25 feet or more away from the vehicle which remains in his view, or whenever the operator leaves the vehicle and it is not in his view.

4.33.8 The operator shall remain in the forklift whenever a load is elevated.

4.33.9 Never allow personnel to stand or pass under the elevated portion of any forklift, whether loaded or unloaded.

4.33.10 Personnel operating forklifts shall be trained and authorized to operate the specific make / model. Training shall be performed initially / prior to operation and on a triennial basis.

4.33.11 Seat belts (if so equipped) shall be worn when operating the forklift.

4.33.12 Wheel chocks shall be installed on all forklifts when parked unattended on an incline.

4.34 Hazard Communication (Right to Know) (§29 CFR 1910.1200)

4.34.1 ZionSolutions is committed to eliminating or minimizing personal exposure to chemical hazards in accordance with Reference 2.23 – SAF-02: Chemical Control. Chemical hazards are managed by proper housekeeping, establishing barriers with appropriate postings, training, monitoring of the chemical hazard, and compliance with the applicable procedures and regulations.

4.34.2 Safety Data Sheets (SDSs, previously known as Material Safety Data Sheets) shall be available in a readily accessible location at the work site



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for all hazardous chemicals; the current location is the Industrial Safety Office located in the NGET Building. SDSs are also available on the O Drive at O:\ZIIL\Safety Data Sheets.

4.34.3 Hazard Communication Training shall be provided to all ZionSolutions employees and subcontractors as part of NGET training.

4.34.4 Engineering controls are the preferred method for chemical hazard management, followed by administrative controls (unless prohibited by regulations, i.e., asbestos, hexavalent chromium, etc.). PPE shall be utilized if engineering controls and administrative controls do not provide the required personal protection.

4.34.5 As appropriate, ZionSolutions should perform chemical hazard monitoring via surveillances and with the use of specific monitoring instruments, entering the monitoring results into a database. The results of the chemical hazard monitoring shall be provided to personnel monitored, entered into the employee’s Medical Exposure File, posted in a prominent location in the workplace, and filed with the appropriate Work Package.

4.34.6 As required, air monitoring should be performed in accordance with Reference 2.16 – OSHA Technical Manual Section II: Chapter 1 – Personal Sampling for Air Contaminants. An American Industrial Hygiene Association (AIHA) Accredited Laboratory shall analyze air-sampling media requiring offsite laboratory analysis.

4.34.7 The chemical hazard monitoring results will be used to modify engineering controls, administrative controls, and PPE as warranted. The chemical hazard monitoring results will also be used to develop adequate controls for future work activities and will be referenced in the Work Package.

4.34.8 The Threshold Limit Values (TLV) that are established in Reference 2.5 - ACGIH Guide to Occupational Exposure Values (Latest Edition) have been adopted where a regulatory Permissible Exposure Limit (PEL) does not exist or where the TLV is less than the OSHA Permissible Exposure Limit (PEL).

4.34.8.1 PEL’s and TLV’s are based on the employee working an eight-hour workday.

4.34.8.2 ZionSolutions shall adjust PEL’s and TLV’s lower if working greater than an eight-hour workday, as appropriate (i.e., lead).


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4.34.9 All chemical products must be reviewed and approved by the: (1) Manager, Industrial Safety & Hygiene, (2) Environmental Manager, and (3) Manager Waste Operations prior to bringing onto Zion Station Property. This review shall be performed in accordance with Reference 2.23 – SAF-02: Chemical Control.

4.34.10 Chemical Labels

4.34.10.1 The Shipping/Receiving Department, or designee, ensures new chemical products arrive with the presence of the following basic Hazard Communication information on the labels:

4.34.10.1.1 Product brand name or scientific chemical products name.

4.34.10.1.2 Appropriate chemical product precautions or warnings.

4.34.10.1.3 Name and address of manufacturer or distributor.

4.34.10.2 If a chemical product is received that does not contain the required label information, then the Shipping/Receiving Department shall notify the requester of the chemical product who will notify the supplier, manufacturer, importer, or distributor of this deficiency and request a proper label.

4.34.10.3 The Shipping/Receiving Department will not release chemical products without proper labels.

4.34.10.4 Each worker is responsible for the proper labeling, storage, and control of the chemical product containers they are creating or using. These responsibilities include the following:

4.34.10.4.1 Ensure the container labeling is not defaced or removed.

4.34.10.4.2 Ensure that the container is properly labeled.

4.34.10.4.3 If discrepancies are noted, workers shall contact their supervisor to resolve their concerns prior to using the chemical product.


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4.34.10.4.4 Ensure the container is properly sealed when not in use.

4.34.11 Report a spill or potential release of chemicals to 5-2211.

4.34.11.1 If the material is continuously spilling and can be safely stopped, proceed to stop further spillage.

4.34.11.2 If volume of spilled material is large enough that runoff is possible or material can enter a floor drain, dike the area surrounding the spill.

4.34.11.3 Chemical spills not classified as HAZMAT incidents per Reference 2.54 – ZAP 530-01: Hazardous Material (HAZMAT) Response, Incidental Chemical Spills & Reporting will be cleaned up as directed by the Environmental Manager.

4.34.12 Spill response shall be in accordance with Reference 2.54 – ZAP 530-01: Hazardous Material (HAZMAT) Response, Incidental Chemical Spills & Reporting.

4.35 Hazardous Substances

Hazardous substances are substances, which by reason of being explosive, flammable, poisonous, corrosive, oxidizing, irritant, or otherwise harmful is likely to cause injury (i.e., lead, cadmium, chromium, mercury, zinc, PCBs, etc.). Industrial Safety & Hygiene shall perform a Hazard Assessment of the work area for hazardous substances prior to commencing work activities.

4.36 Hazards, Biological

Biological hazards include plants and animals/insects that when present or contacted present a potential hazard to ZionSolutions employees or subcontractors. Industrial Safety & Hygiene shall perform a Hazard Assessment of the work area for biological hazards prior to commencing work activities.

4.37 Hearing Conservation

The ZionSolutions Hearing Conservation Program has been established to protect employees from the adverse effects of excessive noise. The Hearing Conservation Program is detailed in Reference 2.25 – SAF-04: Hearing Conservation Program and Examination. Elements of the Hearing Conservation Program include:

4.37.1 Audiometric testing.


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4.37.2 Implementation of administrative controls (such as job rotation, re-assignment to tasks with less exposure to noise, and establishment of quiet zones for work breaks) to minimize worker exposure whenever engineering controls are not feasible.

4.37.3 Noise monitoring performed in accordance with Reference 2.18 – OSHA Technical Manual Section III: Chapter 5 – Noise Measurement.

4.37.4 Training upon hire at NGET and annually thereafter.

4.37.5 Use of hearing protection in posted areas, operating power tools, and whenever noise levels are equal to or exceed 85 dBA.

4.38 Heat Generating Equipment and Appliances

Proper controls are required for the temporary use of heat generating equipment to protect against losses, minimize fire hazards to structures, systems and components important to safety and buildings, and prevent inadvertent actuation of fire suppression systems.

4.38.1 Heat generating equipment includes, but is not limited to, heat lamps, portable heaters, shrink tubing guns, glow rings, extension lights, high power halogen lights, salamander heaters, roofing tar buggies, electric irons used for soldering or brazing, etc. If the equipment is capable of generating temperatures sufficient to ignite the combustible or flammable materials located in the area, or the equipment is capable of generating smoke, fumes, or other products of combustion, then the provisions of Reference 2.55 – ZAP 900-01: Station Fire Protection Program are applicable.

4.38.2 The Manager, Industrial Safety & Hygiene shall approve the use of all heat generating appliances intended for personal use, comfort or convenience that during normal use could ignite combustible materials such as paper and cardboard. Examples of heat generating appliances include portable space heaters (please see Section 4.76: Space Heaters), hot plates (other than coffee warmers), toasters, toaster ovens, microwave ovens, broiler ovens and similar devices.


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4.39 Heavy Equipment

Heavy equipment (backhoes, skid steers, mobile cranes, flatbed trucks, roll-on/roll-off trucks, etc.) are required to support the Zion Restoration Project. Operators of heavy equipment shall be trained on the same model of heavy equipment or one having similar characteristics and controls consistent with the heavy equipment to be used.

4.39.1 A shiftly inspection of the heavy equipment shall be performed and documented when in use. Heavy equipment requiring maintenance shall not be operated until repairs have been made.

4.39.2 An ABC fire extinguisher shall be readily available and in operable condition on each piece of heavy equipment at a location determined by the Work Supervisor.


4.39.2.2 A monthly (periodic) inspection of the fire extinguisher shall be performed by personnel operating the heavy equipment. The periodic inspection criteria is designated on a sticker affixed to the fire extinguisher. The periodic inspection shall be documented on the shiftly inspection sheet.

4.39.3 An operable backup alarm is required on all heavy equipment. In the event that the backup alarm is not operational, a spotter may be used pending repairs of the backup alarm.

4.39.4 Care shall be taken to ensure that heavy equipment is not parked such that it blocks access to fire hydrants, emergency equipment, or exit routes.

4.39.5 Heavy equipment operators shall be alert for personnel at all times; personnel shall be alert for heavy equipment operations at all times.

4.39.6 Every effort shall be made by all personnel to maximize their distance from operating heavy equipment including:

4.39.6.1 As necessary, establishing safety barriers or assigning dedicated spotters to keep personnel out of the pathway of operating heavy equipment.


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4.39.6.2 Evaluate alternate pathways to maintain adequate distance from the heavy equipment operating area.

4.39.6.3 If personnel entry / passage through a heavy equipment operating area is required:

4.39.6.3.1 When safe (i.e., not during a crane lift), establish eye/verbal contact with the heavy equipment operator.

4.39.6.3.2 Indicate where you need to pass through and obtain permission from the heavy equipment operator prior to entry.

4.39.6.3.3 Enter and pass through the heavy equipment operating area after verification that heavy equipment movement has ceased.

4.39.6.3.4 After passing through the heavy equipment operating area, establish eye/verbal contact with the heavy equipment operator to signal him/her that you have cleared the area.

4.39.7 Heavy equipment should be lowered when practical and if inclement weather is predicted.

4.39.8 Seat belts (if so equipped) shall be worn when operating heavy equipment.

4.39.9 Wheel chocks shall be installed on all wheeled heavy equipment when parked unattended on an incline.

4.40 Hexavalent Chromium (§29 CFR 1910.1026)

Chromium is a naturally occurring element found in rocks, soil, plants, animals, and in volcanic dusts and gasses. Chromium compounds are stable and occur naturally in the environment. Hexavalent chromium and its compounds are more toxic than other chromium compounds; potential exposure to hexavalent chromium includes work activities involving welding, cutting and grinding on metal containing chromium (i.e., stainless steel, chrome moly steel, Inconel, etc.).

4.40.1 Hexavalent chromium is a toxic form of the element chromium. Exposure to hexavalent chromium can cause the following health effects:

4.40.1.1 Hexavalent chromium has been classified as a carcinogen.



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4.40.1.2 Breathing in high levels of hexavalent chromium can cause irritation to the nose and throat. Repeated or prolonged exposure can cause sores to develop in the nose and result in nosebleeds.

4.40.1.3 Breathing small amounts of hexavalent chromium even for long periods does not cause respiratory tract irritation in most people.

4.40.1.4 Some employees can also develop an allergic skin reaction, called allergic contact dermatitis.

4.40.2 Personnel who may be exposed to hexavalent chromium at or above the Action Level for 30 or more days per year shall participate in a hexavalent chromium medical examination. The responsible Department Head is responsible for tracking the number of days personnel are performing work activities involving hexavalent chromium.

4.40.3 Work activities with potential exposure to hexavalent chromium shall be controlled in accordance with Reference 2.40 – SAF-21: Management & Control of Hexavalent Chromium during Welding, Cutting, and Grinding Activities. The Work Supervisor shall incorporate Attachment 1 (Hexavalent Chromium) into the shiftly Pre-Job Brief.

4.40.4 Potassium Dichromate was used in the Component Cooling System until the early 1990’s. Industrial Safety & Hygiene shall identify the engineering controls and PPE for system breaches of the Component Cooling System in the Work Package.

4.41 Hoisting and Rigging (§29 CFR 1926 Subpart CC)

Decommissioning of the Zion Nuclear Plant will involve significant hoisting and rigging of components, equipment, and structures. Hoisting and rigging shall be performed in accordance with the following References:

2.48 – SAF-29: Hoisting and Rigging Program

2.49 – SAF-30: Training and Qualification of Personnel

2.50 – SAF-31: Safe Use and Inspection of Rigging Equipment

Specific hoisting and rigging requirements include:

4.41.1 Access to the lift area or any openings created shall be strictly controlled by a watch person, barriers, or both.



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4.41.2 Approved subcontractor lift plans may be used in lieu of the above procedures for engineered lifts (i.e., spent fuel, major components, etc.).

4.41.3 Mobile Crane Operation

4.41.3.1 A Dedicated Spotter shall be stationed in addition to establishing a physical safety barrier to keep personnel and equipment out of the mobile crane’s superstructure / counterweight swing radius (the hazard area).

4.41.3.2 The physical safety barrier can be control lines, warning lines, railings, orange cones, or similar barriers to mark the boundaries of the hazard areas.

4.41.3.3 If it is not feasible to erect a physical safety barrier, the hazard area must be clearly marked by a combination of warning signs (such as “Danger – Swing / Crush Zone”) and high visibility markings on the mobile crane that identify the hazard areas.

4.41.3.4 In addition, the Lift Supervisor shall train each employee to understand what these markings signify.

4.41.3.5 Before an employee goes to a location in the hazard area that is out of view of the Mobile Crane Operator, the employee (or the Dedicated Spotter) must ensure that the Mobile Crane Operator is informed that he / she is going to that location.

4.41.3.6 Where the Mobile Crane Operator knows that an employee has entered the hazard area, the Mobile Crane Operator must not rotate the superstructure until informed in accordance with a pre-arranged system of communication that the employee is in a safe position.

4.41.4 No one will allow any portion of his or her body underneath a suspended load for any reason. Employees may stand beside a suspended load and guide it into place with their hands when, in view of the height of the load, actual and potential swing of the load and trip hazards, the employees are not at risk of being struck by the load if it were to fall.

4.41.5 Pre-Lift Briefs shall be performed for all crane lifts.

4.41.6 Softener Requirements

4.41.6.1 Softeners are required for all lifts using slings (of any construction, i.e. nylon, Kevlar, wire rope, etc.) where the


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softener is used to protect against a sharp edge or a potentially sharp edge.

4.41.6.2 Softeners used, shall be a softener specifically designed for that purpose. Job-built softeners shall be of sufficient design and construction to provide protection for lifting slings.

4.41.6.3 Where necessary, softeners shall be secured in place to prevent slippage and eventual damage to slings or other rigging components.

4.41.7 The designated Signal Person shall wear an orange vest so that the Signal Person can be clearly identified.

4.41.8 Polar crane spotters are assigned by the Work Group Supervisor (e.g., Foreman / Superintendent) to support polar crane movement. Spotter responsibilities include:

4.41.8.1 Ensure personnel and equipment are clear of the crane travel path.

4.41.8.2 Keep personnel not directly involved in the work activity outside of the yellow line boundary of the polar crane travel path.

4.42 Hot Work (§29 CFR 1926 Subpart J)

ZionSolutions work activities will involve Hot Work, which is defined as welding, cutting, grinding, open flame work, elevated temperature (i.e., pre/post weld heat treatment), or any other work activity that produces sparks. Hot work will require a Hot Work Permit and trained Firewatch personnel. Fire extinguisher training is provided to all Firewatch personnel prior to performance of Firewatch duties and annually thereafter.

4.42.1 Hot Work shall be performed in accordance with the requirements of Reference 2.55 – ZAP 900-01: Station Fire Protection Program.

4.42.2 At least one additional fully charged fire extinguisher must be moved into the area where cutting and welding is to take place.

4.42.2.1 The additional fire extinguisher shall not be one that is already assigned to a Permanent Fire Area.

4.42.2.2 If during the course of hot work the Firewatch fire extinguisher is used (i.e., to control sparks or cool slag) an additional, fully charged fire extinguisher is required to be



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brought into the area. This requirement is to ensure the fire watch always has a fully charged fire extinguisher in their possession per the requirements of NFPA codes.

4.42.2.3 Personnel performing Firewatch duties shall be trained in Fire Prevention and the use of fire extinguishers.

4.42.2.4 Personnel performing Firewatch duties shall have fire extinguishing equipment readily available.

4.42.2.5 Permanent plant fire extinguishers are for emergency situations only and ARE NOT to be used to support Hot Work.

4.42.2.6 Fire extinguishers partially or completed discharged shall be removed from service until they are recharged and inspected.

4.42.3 Firewatches shall perform no duties unrelated to the responsibilities of the Firewatch.

4.42.4 Firewatches may remain in a low dose area for the 30 minute period after the completion of Hot Work provided:

4.42.4.1 There is a camera that allows for the Firewatch to perform sufficient continuous observation of the work area, and

4.42.4.2 The Firewatch performs a physical entry into and throughout the entire work area at 15 minutes and 30 minutes after completion of the Hot Work to ensure satisfactory conditions (i.e., no fire, smoldering materials, etc.) prior to securing the Firewatch.

4.42.5 When cutting and welding operations are performed above grating decks, cable trays, or near floor or wall openings, then the deck or openings below the operation shall be covered with suitable noncombustible material.

4.42.6 When hot work activities are performed on multiple levels or hot work at one level has the potential to cause fire at another level (sparks, falling material, etc.), then a fire watch shall be placed at each level.

4.42.7 Metal slag is created when torch cutting metal and is NOT considered a fire; use of a water extinguisher will cool the slag (spot cooling) to where it cannot set combustible materials on fire.


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4.42.7.1 If a fire occurs, the Firewatch has failed to take adequate precautions to prevent the fire. A fire of any sort, of any duration, shall be promptly reported to the ISFSI Shift Supervisor, the Work Supervisor, and Industrial Safety & Hygiene.

4.42.8 Particular care shall be taken so large pieces of hot slag are not allowed to remain on surfaces long enough to cause combustion or damage.

4.42.9 If hot work is to be performed from an elevated aerial platform / scissor lift, then the following additional requirements shall be met:

4.42.9.1 A Firewatch shall be present on each aerial platform / scissor lift where hot work is being performed, or

4.42.9.2 A Firewatch shall be present and have the ability to communicate via voice, phone or radio with personnel on the aerial platform and the Firewatch extinguisher agent is capable of reaching the aerial platform hot work. The Firewatch must have an unobstructed view of the entire aerial platform / scissor lift basket.

4.42.10 Personnel performing hot work and Firewatch duties shall wear appropriate protective clothing as determined by Safety and Radiation Protection.

4.42.11 Scrubs and Hot Work

4.42.11.1 Scrubs are to be worn in accordance with Reference 2.63 – ZS-RP-106-001-004: Control, Use, and Quality Assurance of Modesty Garments.

4.42.11.2 Non-Flame Retardant Synthetic modesty garments, such as OREX or DisolvTech, are not to be worn when performing hot work (e.g. welding, burning, grinding) or work on energized electrical equipment.

4.42.11.3 Flame Retardant Synthetic modesty garments, such as Pyrolon or 100% cotton, may be approved for some low energy electrical or hot work (e.g., welding, burning, grinding) when appropriate outer protective clothing is worn and applicable safety procedures are followed.

4.42.12 Local exhaust ventilation should be evaluated as an Engineering Control for hot work activities in accordance with Reference 2.41 – SAF-22: Use and Control of Ventilation for Welding, Cutting, and Grinding Activities.


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4.42.13 Weld screens or an equivalent substitute should be used when welding, cutting, grinding, etc., to protect adjacent personnel from sparks, flying debris, and/or the weld flash.

4.42.14 Where Hot Work activities are being performed on multiple levels, or Hot Work at one level has the potential to cause fire at another (sparks, falling material, etc.), a Firewatch should be placed on each level.

4.43 Housekeeping (§29 CFR 1926.25)

Housekeeping shall be performed on an ongoing basis and at the end of each shift to maintain a safe working environment. At the completion of the work activity the work area should be returned to a condition equivalent to, or better, than when work commenced. Housekeeping includes:

4.43.1 Break Rooms

4.43.1.1 Remove dirty coveralls before entering break rooms.

4.43.1.2 Do not put hard hats or gloves on tables.

4.43.2 Combustible scrap and debris shall be removed in a safe manner from the work area at reasonable intervals.

4.43.3 Garbage capable of rotting or becoming putrid shall be placed in a covered container. Container contents shall be disposed of at frequent and regular intervals.

4.43.4 Material which may be dislodged by wind and that could create a hazard when left in an open area shall be secured.

4.43.5 Materials, including scrap and debris, shall be piled, stacked, or placed in a container in a manner that does not create a hazard to an employee.

4.43.6 The floor of a work area or aisle shall be maintained in a manner that does not create a hazard to an employee.

4.44 Hydrolazing

Hydrolazing is a process whereby a stream of pressurized water (up to 50,000 psi) is aimed at undesirable materials adhering to a substrate, such as the inside of a metal tank or paint on steel, concrete, or other material. The water stream is set at the minimum pressure to remove the unwanted material while at the same time minimize damage to the substrate material. Hydrolazing may be performed to support the Zion Restoration Project.



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4.44.1 PPE specifically designed for users of high-pressure water systems shall be worn, as appropriate.

4.44.2 A Job Hazard Analysis (JHA) is required for hydrolazing as per Section 4.78.3.

4.45 Industrial Hygiene

Prior to commencing decommissioning work activities, a Hazard Assessment shall be performed to determine if there if is potential exposure to air contaminants listed in Appendix A, Subpart Z of Reference 2.3 - §29 CFR 1926: Safety and Health Regulations for Construction or Reference 2.6 – ACGIH TLVs® and BEIs® (Latest Edition).

4.45.1 If the OSHA Permissible Exposure Limit (PEL) differs from the ACGIH Threshold Limit Value (TLV), ZionSolutions will use the lower of the two values as the Zion Restoration Project Exposure Limits. Appropriate Engineering Controls, Administrative Controls, and/or PPE will be identified and implemented to protect our employees and subcontractors.

4.45.2 As required, Industrial Hygiene (IH) monitoring shall be performed of work activities in accordance with Reference 2.16 – OSHA Technical Manual Section II: Chapter 1 – Personal Sampling for Air Contaminants.

4.45.3 Industrial Hygiene samples shipped offsite for analysis shall be processed using the Chain of Custody protocols specified in Reference 2.67 – ZS-WM-131: Chain of Custody Protocol.

4.46 Isocyanates (OSHA Directive CPL 03-00-017)

4.46.1 Isocyanates are highly reactive chemicals used in the production of foams (i.e., Great Stuff®), coatings, and insulating materials. Isocyanates cause severe skin and eye irritation, inflammation, nasal congestion, sore throat, cough, shortness of breath, and wheezing. Isocyanate exposure can cause fluid collection in the lungs, or pulmonary edema, and respiratory sensitization.

4.46.2 People who are sensitized to Isocyanates, on subsequent exposure, have severe asthmatic reactions, causing constriction of the airways and extreme difficulty breathing. These reactions have, on occasion, been fatal.

4.46.3 The work we have onsite that could cause Isocyanate exposures is the spray-foaming process. When spraying Isocyanate-containing materials, the potential for exposure comes from vapors, mist droplets, and tiny flakes of curing foam which become airborne due to the compressed air

https://www.osha.gov/OshDoc/Directive_pdf/CPL_03-00-017.pdf


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used and overspray. It is essential to prevent inhalation and skin and eye contact. The appropriate engineering controls and PPE, including respiratory protection, will be specified in the approved Work Package.

4.47 Ladders (§29 CFR 1926.1053)

4.47.1 Ladders shall be used in accordance with Reference 2.42 – SAF-23: Scaffold and Portable Ladder Use.

4.47.2 Perform a pre-use inspection. Ladders with suspected or actual defects shall be taken out of service and rendered unusable.

4.47.3 The Maximum Weight Capacity (Duty Rating) is the weight that a ladder can safely carry. To figure out the total amount of weight your ladder will be supporting, add:

4.47.3.1 Your weight; plus

4.47.3.2 The weight of your clothing and protective equipment; plus

4.47.3.3 The weight of tools and supplies you are carrying; plus

4.47.3.4 The weight of tools and supplies stored on the ladder.

4.47.3.5 There are five categories of ladder Duty Ratings:

4.47.3.5.1 Type IAA (Extra Heavy Duty) 375 pounds

4.47.3.5.2 Type IA (Extra Heavy Duty) 300 pounds

4.47.3.5.3 Type I (Heavy Duty) 250 pounds

4.47.3.5.4 Type II (Medium Duty) 225 pounds

4.47.3.5.5 Type III (Light Duty) 200 pounds

4.47.3.6 The Duty Rating of the ladder can be found on the specifications label. Safety standards require a Duty Rating sticker to be placed on the side of every ladder. Do not assume that a longer ladder has a higher weight capacity. There is no relationship between ladder length and weight capacity.

4.47.4 A-Frame (or step) ladders shall not be leaned against a structure or surface (as you would a straight ladder).

4.47.5 Ascend no higher than the third rung from the top on straight or extension ladders, no more than the second step from the top on A-frame ladders.



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4.47.6 All material shall be raised or lowered using a line or other hoisting method. Never ascend or descend a ladder while hand carrying any object.

4.47.7 Do not move, shift, or extend ladder while employee is on it.

4.47.8 Do not use in a horizontal position as platform, walkway or scaffold, or as a support for other material.

4.47.9 Face the ladder and maintain three points of contact at all times while ascending and descending.

4.47.10 Portable ladders in use shall be blocked, tied, or otherwise secured to prevent movement or displacement.

4.47.10.1 A stepladder setup on a firm level surface with its spreader bars locked, used in accordance with the manufacturer’s labels or technical manual, is an approved method to prevent movement or displacement.

4.47.11 Portable ladders shall have sufficient length to extend a minimum of 3 feet above the platform or landing.

4.47.12 Portable ladders shall not be placed in doorways, aisles, passageways or other locations where the ladder could be displaced by other work activities, unless protected by barriers or guards.

4.47.13 Portable ladders used on smooth surfaces shall have a non-slip base or be otherwise secured.

4.47.14 Portable straight ladders shall be placed so the distance of the bottom of the ladder is not less than one-quarter of the vertical distance to the top support (an extension ladder reaching a height of 16 feet would need to have its base 4 feet away from the vertical support surface).

4.47.15 Use of portable metal ladders in areas with exposure to energized equipment is prohibited.

4.47.16 Temporary ladders left in the Fuel Building shall be secured / stored as follows:

4.47.16.1 Lay ladder on its side, out of the way, and tie-off to plant structural steel member (not instrument supports).

4.47.16.2 If ladder is to remain erected in place, then tie-off the ladder at the base and at the top to assure that it cannot fall over and cause injury or damage.


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4.47.17 Working from Ladders

4.47.17.1 Work is not allowed to be performed by personnel standing on permanent plant fixed ladders.

4.47.17.2 Work may be performed at height using a ladder without fall protection provided that:

4.47.17.2.1 No other safe means of access is available,

4.47.17.2.2 The work activity does not involve hazardous chemicals, or pressurized equipment (i.e., air or water hoses, etc.), and

4.47.17.2.3 The user is responsible for reviewing and complying with the ladder safety requirements as listed on the manufacturer’s label affixed to the ladder. If the sticker is missing or illegible, the ladder shall be removed from service.

4.47.17.3 Body Positioning

4.47.17.3.1 Always keep three parts of your body in contact with the ladder when climbing, holding on with either two hands and a foot or two feet and a hand, or as specified by the ladder manufacturer.

4.47.17.3.2 Always face the ladder as you climb, work or descend.

4.47.17.3.3 Keep your belt buckle and shoulders positioned between the rails and do not overreach or lean beyond the side rails while working.

4.47.17.4 Personnel may work on a straight or extension ladder using both hands to perform the work activity provided they are in accordance with the ladder usage requirements as identified on either the manufacturer’s label or technical manual.

4.47.17.5 Personnel may work on an stepladder using both hands to perform the work activity provided that the stepladder is adequately secured from movement (i.e., held by a co-worker), the user is not on the top step(s) and provided they


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are in accordance with the with the ladder usage requirements as identified on either the manufacturer’s label or technical manual.

4.47.17.6 Use of power tools on any ladder type requires fall protection worn in accordance with a task-specific Fall Protection Plan developed by IS&H.

4.47.17.7 Fall protection is not required above 6 feet while working from a ladder if an employee can maintain three points of contact for the duration of the work task

4.48 Lead (§29 CFR 1926.62)

Lead is a naturally occurring bluish-gray metal found in small amounts in the earth’s crust. The negative health effects of lead are the same whether it enters the body through breathing or swallowing. Lead can affect almost every organ and system in your body. The main target for lead toxicity is the nervous system.

Lead work is any activity that disturbs lead-containing materials (i.e., cold-cutting, grinding, torch cutting, drilling, chemical removal, abrasive blasting, handling of exposed elemental lead, etc.).

4.48.1 Lead (Pb) work activities will be managed in accordance with Reference 2.36 – SAF-17: Lead Removal & Exposure Control.

4.48.1.1 Personnel who perform lead work activities shall participate in a lead medical examination. The responsible Department Head is responsible for tracking the number of days personnel are performing work activities involving lead.

4.48.1.2 Reference 2.36 – SAF-17: Lead Removal & Exposure Control has Lead Compliance Plans for most lead work activities.

4.48.1.3 A task-specific Lead Compliance Plan shall be developed and implemented to perform lead work activities where the existing Lead Compliance Plans do not provide sufficient controls. Reference 2.21 – OSHA Technical Manual Section V: Chapter 3 - Controlling Lead Exposures in the Construction Industry: Engineering and Work Practice Controls should be used to develop the Lead Compliance Plan.

4.48.1.4 Respiratory Protection is required for thermal cutting (hot work) of any painted system, structure, or component.



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4.48.2 Personnel who perform work activities that disturb lead-containing materials (i.e., cold-cutting, grinding, torch cutting, drilling, chemical removal, abrasive blasting, handling of exposed elemental lead, etc.) will receive Lead (Pb) Worker training prior to disturbing the lead-containing material and annually thereafter.

4.48.2.1 Attachment 5 – Substance Data Sheet for Occupational Exposure to Lead provides information that is included in Lead Worker training.

4.48.3 Potential sources of lead include:

4.48.3.1 Caulk.

4.48.3.2 Expansion units used to anchor bolts to concrete, brick, mortar, and other rigid building materials.

4.48.3.3 Lead-based paint in the soil at the small metal shed west of the Waste Water Treatment Facility (Survey Unit ID 10101 of Reference 2.55 – Zion Station Historical Site Assessment, Version 1 – August 1999.

4.48.3.4 Paints and coatings. Representative sampling has been performed throughout Zion Station; lead has been confirmed to be present in all paints and coatings.

4.48.3.5 Radiation shielding, either encapsulated to prevent contact with the elemental lead or exposed (i.e., lead bricks) where contact with the exposed lead is possible via handling, physical contact, etc.

4.48.3.5.1 High Rad System Sampling Sink – 592’ Aux. Building

4.48.3.5.2 Post-Accident Sample Sink (PASS) – 592’ Aux. Building

4.48.3.5.3 Primary Sample Sink – 592’ Aux. Building

4.48.3.6 Roof flashing.

4.49 Line of Fire – Pinch Points

Line of Fire – This can also be called “Struck By”. Anytime you are not aware of where tools or equipment might be after you perform some action on them, you may be putting yourself into a “line of fire” situation. Don’t forget that line of fire can be horizontal as well as vertical. Look up and down AND side to side for line of fire


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potentials. Stop – Think – Act – Review (STAR) is a good defense against being “struck by”.

4.50 Lockout/Tagout (§29 CFR 1910.147)

Lockout/Tagout is the adoption and implementation of practices and procedures to shut down equipment, isolate it from its energy sources (i.e., mechanical, hydraulic, pneumatic, chemical, thermal, or other energy), and prevent the release of potentially hazardous energy while maintenance and servicing activities are being performed.

Lockout/Tagout is the preamble for decommissioning work activities supporting the Cold and Dark progression. Cold & Dark is the process when a building or system has been isolated from all external energy sources allowing dismantlement without implementation of the Lockout/Tagout process.

4.50.1 Lockout means to install a locking device that locks the switch, valve, or other mechanism in the required position to support the work activity.

4.50.2 Tagout means to put a tag on the locking device. The tag indicates DANGER or WARNING, along with a brief message.

4.50.3 Lockout / Tagout shall be performed in accordance with Reference 2.65 – ZS-WC-101: Lockout Tagout.

4.50.3.1 NEVER remove a component with a danger tag affixed to it.

4.50.3.2 NEVER manipulate a device with a danger tag attached to it.

4.50.3.3 NEVER remove a danger tag from a component.

4.50.3.4 If during the course of your work you find yourself in a situation addressed above, stop and contact your Supervisor for assistance.

4.50.4 On an annual basis, an independent review will be conducted of Reference 2.65 – ZS-WC-101: Lockout Tagout to verify compliance with OSHA regulations. This review will be performed by the Executive VP and General Manager or designee, which satisfies the OSHA requirement to have a person not directly involved with the Lockout / Tagout process perform this review.



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4.51 Material Handling and Storage (§29 CFR 1926 Subpart H)

Material handling is defined as the movement, either manually or with equipment, of material from one location to another for use and/or storage.

4.51.1 Personnel should not lift weights greater than 50 pounds or lifts that require awkward body positioning without assistance.

4.51.2 Personnel shall not move large or bulky objects that obstruct forward vision without use of an additional spotter.

4.51.3 Movement of a Heavy Detector Shield (HDS, i.e., Small Article Monitor [SAM]) presents specific challenges due to its weight (approximately 3,800 pounds) and the high center of gravity of the HDS. HDS movement requires:

4.51.3.1 Implementation of Reference 2.34 – SAF-15: Heavy Detector Shield Handling;

4.51.3.2 The approval of the Director – Radiation Protection and the Manager, Industrial Safety & Hygiene; and

4.51.3.3 Use of a Spotter to communicate with employees moving the HDS to maintain safe distances from interferences and remind personnel to stay clear of the Line of Fire.

4.51.4 Proper manual material handling requirements include:

4.51.4.1 Plan the work in advance. Consider the size, shape, and weight of materials to be handled and determine the most efficient and safest method to accomplish the task.

4.51.4.2 Avoid hazards such as sharp edges, odd sizes or shapes of loads, hazardous or fragile material, uneven weight distribution, and obstructed routes of travel while lifting and carrying.

4.51.4.3 Consider alternate methods to reduce the risk of injury.

4.51.4.4 Consider stretching exercises before lifting loads to reduce the risk of injury.

4.51.4.5 Ensure that proper personal protective equipment is available and worn.

4.51.4.6 Ensure that the proper tools are available for the work to be performed.



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4.51.4.7 Ensure that when more than one person is involved in lifting, that they move materials in unison. Each employee should be alert for what the others are going to do and when.

4.51.4.8 Review unusual or high-risk operations to ensure that hazards are mitigated.

4.51.4.9 Select employees so that work assignments match the worker to the job in terms of knowledge and physical abilities.

4.51.5 Proper material storage requirements include:

4.51.5.1 Ensure proper storage is facilitated and hazards are reduced through the use of bins and racks.

4.51.5.2 Ensure that both temporary and permanent storage areas are neat and orderly.

4.51.5.3 Ensure that material/equipment is placed in a stable, secure manner so as not to fall or become inadvertently displaced where it could cause personnel injury. This is especially important when positioning tools/material/equipment in overhead areas where personnel are working below.

4.51.5.4 Ensure that materials are stored with adequate clearance / separation from energized lines and equipment.

4.51.5.5 Ensure that unobstructed access to fire hoses and extinguishers are maintained, and that exits and aisles are kept clear.

4.51.5.6 Maintain 18 inches clearance under sprinklers.

4.51.5.7 Tools and material shall not be stored on top of electrical panels, distribution panels, junction boxes, transformers, etc., whether energized or de-energized.

4.52 Medical Exposure Records (§29 CFR 1910.1020)

ZionSolutions maintains medical exposure records for ZionSolutions employees who must be medically evaluated to perform their work activities and/or who are monitored to assess potential exposures to workplace hazards.

4.52.1 ZionSolutions maintains medical exposure records on site. These shall be transferred to the EnergySolutions Vice President EHSQS at the completion of the Zion Restoration Project.



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4.52.2 Medical exposure records are confidential. Each employee has the right to examine and copy these records. The individual responsible for maintaining and providing access to these records is the Occupational Health Services Nurse.

4.53 Medical Examination Program

ZionSolutions employees and contractors may be required to participate in medical examinations to verify that the individual is medically fit to work in an occupational environment.

4.53.1 Medical examinations are required for personnel who are:

4.53.1.1 Crane Operators in accordance with Reference 2.48 – SAF-29: Hoisting and Rigging Program.

4.53.1.2 Hexavalent chromium workers in accordance with Reference 2.3 - §29 CFR 1926: Safety and Health Regulations for Construction, Part 1126(i): Medical Surveillance.

4.53.1.3 Lead (Pb) workers in accordance with Reference 2.3 - §29 CFR 1926: Safety and Health Regulations for Construction, Part 62(j): Medical Surveillance.

4.53.1.4 Licensed asbestos personnel in accordance with Reference 2.3 - §29 CFR 1926: Safety and Health Regulations for Construction, Part 1101(m) – Medical Surveillance.

4.53.1.5 Members of the Security Organization (MSO) in accordance with Reference 2.7 – AD-23: Nuclear Security Medical Examination.

4.53.1.6 Personnel who are or may be exposed to noise levels equal to or greater than 85 dBA on an eight-hour Time Weighted Average in accordance with Reference 2.25 – SAF-04: Hearing Conservation Program and Examination or equivalent.

4.53.1.7 Respirator users in accordance with Reference 2.24 – SAF-03: Respirator Surveillance Exam or equivalent.

4.53.1.8 Performing work activities that require medical evaluation in accordance with OSHA regulations.

4.53.2 The medical examination may include some or all of the following:

4.53.2.1 Audiogram


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4.53.2.2 Blood work

4.53.2.3 Fitness For Duty

4.53.2.4 Medical and occupational history questionnaire

4.53.2.5 Physical examination

4.53.2.6 Pulmonary Function Test

4.53.2.7 Urinalysis

4.53.2.8 Visual acuity

4.53.2.9 Follow-up tests at the discretion of the physician.

4.53.3 The Physician or Licensed Health Care Professional (PLHCP) will provide a letter to ZionSolutions confirming the individual’s fitness for work and the ability to wear a respirator (if required).

4.53.4 Medical surveillance records shall be retained for the duration of the individual’s employment plus thirty years. Occupational Health Services shall establish an Employee Medical Exposure File to maintain these records for each individual in the Medical Surveillance Program.

4.54 Mercury

Mercury, sometimes referred to as quicksilver, elemental, or metallic mercury is a shiny, silver-white metal and is liquid at room temperature. When dropped, elemental mercury breaks into smaller droplets, which can go through small cracks or become strongly attached to certain materials. Mercury releases present a serious environmental and health problem. Inhaling mercury vapors – which are colorless and odorless – can cause irreversible damage to the brain and kidneys.

4.54.1 Mercury is known to have been present or is presumed in the following locations / components:

4.54.1.1 Crib House by Unit 1 Traveling Screens (Survey Unit ID 08210 of Reference 2.55 – Zion Station Historical Site Assessment, Version 1 – August 1999.

4.54.1.2 Crib House Unit 1 Screen Wash Control Panel (Survey Unit ID 08210 of Reference 2.55 – Zion Station Historical Site Assessment, Version 1 – August 1999.

4.54.1.3 Electronic circuit boards.

4.54.1.4 Fire Deluge Valves.

4.54.1.5 Fluorescent light bulbs.


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4.54.1.6 Hydrogen Purity Meters (Survey Unit ID 06310, 06505, 06710, and 07102 of Reference 2.55 – Zion Station Historical Site Assessment, Version 1 – August 1999.

4.54.1.7 Manometers.

4.54.1.8 Mercoid switches located on the Unit 1 and 2 Stator Cooling Water Panels 617’ Turbine Building.

4.54.1.9 Mercoid switches located on the Unit 1 and 2 Turbine Front Standard 642’ Turbine Building.

4.54.1.10 Mercury spills have been documented in the 617’ Laboratory Area; subsequent remediation was performed. Mercury contamination is likely in piping, sink, and vent areas (Survey Unit ID 05512 of Reference 2.55 – Zion Station Historical Site Assessment, Version 1 – August 1999.

4.54.1.11 Mercury spills have been reported (but not documented) in the Instrument Maintenance Shop (Survey Unit ID 06710 of Reference 2.55 – Zion Station Historical Site Assessment, Version 1 – August 1999.

4.54.1.12 Plant Announcing System electronic circuit boards in the 642’ Unit 1 and 2 Auxiliary Electric Room.

4.54.1.13 Thermostats.

4.54.2 Contact Industrial Safety & Hygiene if mercury or mercury-containing components are identified in your work area.

4.54.3 Mercury or mercury-containing components will be disposed of as per Waste Operations direction.

4.55 Mold (OSHA Safety and Health Information Bulletin 03-10-10)

Molds are part of the natural environment. Outdoors, molds play an important role in nature. Indoors, mold growth should be avoided. Molds can grow on virtually any substance, as long as moisture or water, oxygen, and a nutrient source are present. When excessive moisture or water accumulates indoors, mold growth often will occur.

Mold may be present in structures where ZionSolutions employees or subcontractors work. Currently, there are no federal standards or regulations (i.e., OSHA, NIOSH, and EPA) for airborne concentrations of mold or mold spores. Scientific research on the relationship between mold exposures and health effects is ongoing.

https://www.osha.gov/dts/shib/shib101003.html


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Most typical indoor air exposures to mold do not present a risk of adverse health effects. However, molds can cause adverse effects by producing allergens (substances that can cause allergic reactions). The onset of allergic reactions to mold can be either immediate or delayed. Allergic responses include hay fever-type symptoms such as runny nose and red eyes.

Molds may cause localized skin or mucosal infections but, in general, do not cause systemic infections in humans, except for persons with impaired immunity, AIDS, uncontrolled diabetes, or those taking immune-suppressive drugs. Molds can also cause asthma attacks in some individuals who are allergic to mold. In addition, exposure to mold can irritate the eyes, skin, nose and throat in certain individuals.

Symptoms other than allergic and irritant types are not commonly reported as a result of inhaling mold in the indoor environment. Healthy individuals are usually not vulnerable to opportunistic infections from airborne mold exposure.

4.55.1 Depending upon the as-found conditions, mold remediation may be required to protect the health and safety of building occupants.

4.55.2 A Mold Remediation Plan will be developed if mold remediation is required. Reference 2.12 – EPA 402-K-01-001, March 2001: Mold Remediation in Schools and Commercial Buildings will be used to develop the Mold Remediation Plan.

4.56 Office Safety

Office work activities present safety challenges different than decommissioning work activities that must be properly managed.

4.56.1 Fire Prevention Strategies and Emergency Preparedness:

4.56.1.1 All individuals should familiarize themselves with the location of fire escape routes, means of activating the fire alarm, and methods of reporting fires.

4.56.1.2 In the event of a fire, do not collect personal / company belongings, leave the area immediately and exit to the designated gathering area.

4.56.2 Furniture and Equipment:

4.56.2.1 Furniture and equipment should be arranged to allow for quick and unobstructed egress under emergency conditions.

4.56.2.2 Operation and maintenance of equipment should be down in accordance with manufacturers’ instructions.


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4.56.2.3 File cabinet drawers should be opened one at time to prevent them from tipping.

4.56.2.4 Close drawers after use.

4.56.3 Heat-producing devices (coffee pots, toaster ovens):

4.56.3.1 Heat-producing devices shall only be used in kitchen areas or other areas as approved by the Manager, Industrial Safety & Hygiene.

4.56.3.2 Coffee pots:

4.56.3.2.1 Shall be turned off at the end of the shift.

4.56.3.2.2 Shall have an integral timer or connected to a timer that DOES NOT automatically re-energize. Industrial Safety & Hygiene has these timers available for issue upon request.

4.56.3.3 Toaster (and microwave) ovens shall have an integral timer that secures cooking after the user-determined pre-set time.

4.56.4 Food Safety: Proper handling of food products is essential to prevent transmission of food-borne disease, and to prevent attracting insects / vermin.

4.56.4.1 Food preparation areas shall remain clean. Promptly wipe up any spills.

4.56.4.2 Keep all food tightly covered.

4.56.4.3 Do not leave perishable food unrefrigerated for more than 2 hours maximum.

4.56.4.4 Dispose of food products / utensils / serving dishes promptly. If your trash bag has been emptied for the day, dispose of these in the outside trash dumpsters.

4.56.5 Refrigerator Safety

4.56.5.1 Get rid of unwanted or unused food promptly. Recognize that many items, such as dairy (yogurt, milk, etc.) and meats have an expiration date.


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4.56.5.2 If you see something moldy in a container, remove the container from the refrigerator. Dispose of the container with the moldy food still sealed inside of the container.

4.56.5.3 If you throw food away, take the trash bag to the dumpster to prevent problems with bacteria, odors, insects, or vermin.

4.56.5.4 Keep your food tightly sealed. Chopped onions or other strong foods will probably require two baggies to contain the strong odor.

4.56.5.5 Store only one day’s food at a time to ensure adequate space for others.

4.56.5.6 Wipe up spills promptly.

4.57 Outdoor Hazards

Some work on the Zion Restoration Project may require personnel to work in areas with significant brush. Working in brush areas has certain biological hazards including animals, plants (poison ivy, poison oak), and insects.

4.57.1 Bats can be present in old trees or site buildings. Bats are a concern due to the potential for carrying rabies. If you should find a bat on site, live or dead, DO NOT HANDLE OR TOUCH IT! If a dead bat is found, please contact the ISFSI Shift Supervisor at 5-4242, who will contact the City of Zion Police for disposition.

4.57.2 Birds – Contact the Environmental Department if you should encounter dead birds in your work area for proper handling and disposition instruction. Dead animals will be dispositioned as per Waste Operations direction.

4.57.3 Bees and Wasps

4.57.3.1 Bees can be a major problem for personnel working in the field. If you are stung, promptly report to Occupational Health Services for evaluation.

4.57.3.2 Some, but not all, stings can be prevented. It is especially important that people known to be allergic to certain insects make an effort to avoid those insects.

4.57.3.3 Ways to avoid stings include the following:

4.57.3.3.1 Take a minute to review the job site looking around the area for the presence of bees.


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4.57.3.3.2 Avoid known areas of concentration such as hives and nests, and do not disturb hives and nests.

4.57.3.3.3 If flying insects are around, leave the area and refrain from swatting at them.

4.57.3.3.4 Nests can be found in ground cover, cabinets, trees or eaves on the exterior of a building. Report nests to your Supervisor; bee / wasp spray is available to eradicate the nests.

4.57.3.3.5 Take care with motorized equipment such as lawnmowers as they may provoke the insects.

4.57.3.3.6 Wearing pants and long-sleeved shirts can also provide some protection.

4.57.4 Coyotes – If you encounter a coyote den, back off and immediately tell your Supervisor, Industrial Safety, or the Environmental Department. Do not attempt to confront the coyote or the pups.

4.57.5 Poison Ivy

4.57.5.1 Poison ivy is present at Zion Station. Contact with any part of the poison ivy may result in allergic contact dermatitis, appearing up to three days after initial contact.

4.57.5.2 Poison ivy bears dark green leaves composed of three oval-shaped leaflets, which may be slightly or entirely toothed along the edges. The leaves have an oily appearance. This, plus their green color and three-leaf grouping, serves as an easy mark of identification. When mature, the plants bear a white waxy berry that, if touched, also may cause allergic dermatitis. The leaves turn scarlet early in the fall.

4.57.5.3 If you identify poison ivy in your outdoor work location, notify your Supervisor and Industrial Safety & Hygiene.


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4.57.5.4 Protective wipes for poison ivy are available from Industrial Safety & Hygiene.

4.57.5.5 If you should contact poison ivy, notify Occupational Health Services for evaluation and treatment.

4.57.6 Raccoons

4.57.6.1 Raccoons carry a variety of diseases that can affect humans. In addition to rabies, raccoon feces and urine can also spread disease. A parasitic roundworm frequently found in raccoons can cause a rare but potentially very serious neurologic disease. In addition, a bacterial disease can be spread through contact with the urine of infected animal. The diseases can range from mild symptoms to severe affects, including blindness, paralysis, seizures, kidney damage, meningitis, liver failure, and respiratory distress. Untreated, either disease can be fatal.

4.57.6.2 The key to prevention is avoiding inhalation of or skin contact with contaminated droppings, soil, or other debris. Contact Industrial Safety & Hygiene if you should identify known or suspected raccoon feces / urine in your work area. Wear gloves and respiratory protection (N-95 or better) when cleaning up raccoon waste. Wash hands and face after cleanup work prior to eating, drinking, smoking, or chewing tobacco. If you have a cut on your hand, cover it in addition to wearing gloves.

4.57.7 Snakes

4.57.7.1 The eastern massasauga is the only venomous snake found in northern Illinois, and is reclusive and usually inhabits wet prairies, marshes and low areas along rivers and lakes. The eastern massasauga is very uncommon and is considered a state endangered species. Note that many non-venomous snakes will vibrate their tail as a defense mechanism if they are feeling threatened.

4.57.7.2 Venomous snakes tend not to be aggressive. It is unlikely that they’ll bite unless stepped on, picked up, or cornered; however, their bite is a serious matter. These snakes should be avoided and precautions should be taken when entering an area that they typically inhabit. If there is a snake in your work area, contact your Supervisor, Industrial Safety, or the Environmental Department immediately.


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4.57.8 Spiders

4.57.8.1 Spiders are very beneficial to humans, particularly through insect control. More than 630 species of spiders have been identified in Illinois.

4.57.8.2 Most spiders do not bite humans. Although some spiders are large enough to puncture human skin, the bite in most cases causes no problems at all. There are only two spiders in Illinois considered to have a dangerous bite, the Brown Recluse and the Black Widow.

4.57.8.3 The Brown Recluse may live indoors. Bites generally occur when clothing, bedding, or towels containing the spider come into contact with human skin. Some bites show no severe side effects. Others may cause a red welt to rise, followed by a crust that falls off. It may take several months for the wound to heal; this long-legged spider has a dark brown marking in the shape of a violin on its back (cephalothorax).

4.57.8.4 The Black Widow builds a web under objects in buildings, trash piles, and other similar locations. Male black widow spiders roam about and do not bite, but the female generally stays at the web and will bite if provoked. The bite may not be noticed, but severe abdominal pain, sweating, swollen eyelids, muscle pain, and other symptoms will arise. The person usually recovers within a few days. Antivenin is available. The female Black Widow is about a half-inch long with black coloration and a red hourglass shape on the abdomen.


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4.57.8.5 If bitten by any spider, try to catch the spider and preserve it. Do not pick up the spider. Put a container over it to entrap it. Once the spider is settled inside of the container, turn the container over, add rubbing alcohol to kill and preserve the spider for later identification, and cover the container with a lid. Contact Industrial Safety & Hygiene to evaluate the trapped spider, and promptly report the spider bite to Occupational Health Services.

4.57.8.6 ZionSolutions has an exterminator treat buildings on a monthly basis. If you should notice an area with spiders, notify Industrial Safety & Hygiene to add that location to the Exterminator’s application areas.

4.57.9 Ticks

4.57.9.1 Ticks wait for host animals from the tips of grasses and shrubs. When brushed by a moving animal or person, they quickly let go of the vegetation and climb onto the host. Ticks can only crawl; they cannot fly or jump. Ticks can be active when the temperatures are about 450 Fahrenheit.

4.57.9.2 Wear protective clothing such as long-sleeved shirts, long trousers, boots or sturdy shoes, and a head covering. (Ticks are easier to detect on light-colored clothing.) Tuck trouser cuffs in socks. Tape the area where pants and socks meet so ticks cannot crawl under clothing.

4.57.9.3 Apply insect repellent containing 10-30% DEET primarily to clothes. Apply sparingly to exposed skin. Do not spray directly to the face; spray the repellent onto hands and then apply to face. Avoid sensitive areas like the eyes, mouth, and nasal membranes. Be sure to wash treated skin after coming indoors. Use repellents containing permethrin to treat clothes (especially pants, socks and shoes) but not skin. Always follow label directions; do not misuse or overuse repellents. Repellants are available from the Industrial Safety & Hygiene.

4.57.9.4 Walk in the center of trails so weeds do not brush against you. Avoid sitting on the ground or disturbing dead plants and leaves.

4.57.9.5 Check yourself and other workers every two to three hours for ticks. Most ticks seldom attach quickly and rarely transmit


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disease organisms until they have been attached four or more hours.

4.57.9.6 Immediately report any tick bites to Occupational Health Services.

4.58 Overhead Power Lines

Energized overhead power lines are present on the Zion Restoration Project. Work activities performed on or in the vicinity of energized overhead power lines shall be performed in accordance with Reference 2.38 – SAF-19: Electrical Safety.

4.58.1 Maintain the required clearance distances when work must be performed in locations containing exposed energized overhead power lines or parts that are not guarded, isolated, or insulated.

4.58.2 Exercise care when extending metal ropes, tapes, or wires within the minimum approach distances because of induced voltages. The preference is a non-conductive measuring device. Prior to such work, a briefing shall be conducted with hazards and safe work practices reviewed.

4.58.3 Prior to working within 50 feet of energized overhead lines with heavy equipment or machinery, a briefing shall be conducted with hazards and safe work practices reviewed. As a minimum, USE a 2/0-insulated cable to ground equipment while work is being performed.

4.58.4 Operate any vehicle or mechanical equipment capable of having parts of its structure elevated near exposed energized overhead lines so that a clearance of 10 ft. is maintained for 50 kV or less. If the voltage is higher than 50kV, the clearance shall be increased 4 in. for every 10kV over that voltage; refer to Table 2 – Minimum Approach Distance to Energized Overhead Power Lines. Additional requirements are specified in Reference 2.38 – SAF-19: Electrical Safety.

Table 2 – Minimum Approach Distance to Energized Overhead Power Lines

Voltage Minimum Distance (Feet) 0 – 750 Volts 4’ 750 V – 4 kV 6’

13 kV 8’ 33 kV 10’ 69 kV 11’


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4.59 Paper Insulated Lead Covered Cables (PILC)

Paper-insulated lead-covered (PILC) cable have been widely used in urban underground network systems and is constructed of copper conductors wrapped with (presumed asbestos) paper, impregnated with dielectric fluid (presumed to contain PCBs). The cable is jacketed with a lead covering to keep out moisture, and may also have a plastic or rubber outer jacket.

It is not definitively known if PILC is present at the Zion Nuclear Station. The Work Supervisor shall notify Industrial Safety & Hygiene if underground electrical cables are uncovered that are suspected to be PILC, or if any electrical cables are observed to be leaking oil.

4.60 Personnel Platforms (§29 CFR 1926.1431)

OSHA allows hoisting personnel with crane or derrick-suspended personnel platforms (manbaskets) when no safe alternative is possible. Suspended personnel platforms may be utilized to support the Zion Restoration Project and shall be operated in accordance with Reference 2.27 – SAF-06: Use of Personnel Platforms.

Hoisting personnel by crane shall be considered only after all conventional means of access (e.g. scaffolding, aerial lifts, ladders, etc.) to an elevated worksite have been considered but deemed not feasible or more hazardous.

The use of personnel platforms simply for practicality or convenience reasons is prohibited. Employee safety – not practicality or convenience must determine the choice of method.

4.61 Personal Protective Equipment (PPE) (§29 CFR 1926 Subpart E)

With the completion of the Dry Fuel Campaign, the entire Zion Restoration Project is now a Construction Area. As such, PPE is required at all times on the Zion Restoration Project, including visitors, except in areas identified in Section 4.61.2 below or where a specific PPE Exemption has been issued. ZionSolutions will provide PPE to our employees, other than prescription safety glasses and standard protective footwear.

PPE is obtained from your Supervisor or the Warehouse Manager.

4.61.1 Required PPE includes:

4.61.1.1 Gloves and hearing protection should be with the person at all times and used as appropriate;

4.61.1.2 Hardhat, ANSI Z89.1 compliant;

4.61.1.3 Long pants;




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4.61.1.4 Protective footwear (steel or composite toe), ANSI Z41 or ASTM F-2413-11 compliant;

4.61.1.5 Safety Glasses, including sideshields, ANSI Z87.1 compliant;

4.61.1.6 Spikees if snow and / or ice is present in your travel pathway.

4.61.2 Provided no work activities are in progress and no hazard exists, PPE is not required in the following areas:

4.61.2.1 Classrooms;

4.61.2.2 East / West Parking Lot;

4.61.2.3 Inside enclosed cabs of vehicles or mobile equipment;

4.61.2.4 Locker rooms, change rooms, break rooms, or covered hallways;

4.61.2.5 Offices;

4.61.2.6 Warehouse administrative areas including Issue Counters; and

4.61.2.7 When traveling between the ENC and NGET Buildings or between either of these buildings and the North Gate.

4.61.3 General PPE Requirements

4.61.3.1 A U.S. Coast Guard-approved life jacket or buoyant work vest shall be worn when working over or near water where the danger of drowning exists. Life jackets/vests need not be worn if guardrails or fall protection systems protect the worker.

4.61.3.2 Chainsaw usage – PPE required for chainsaw usage includes chaps certified by Underwriter’s Laboratories for chainsaw usage, hard hat, faceshield, safety glasses, hearing protection, and protective footwear.

4.61.3.3 Kevlar sleeves shall be worn when handling sharp objects, i.e., mirror insulation.

4.61.3.4 Minimizing exposed skin is expected. Sleeved shirts that cover the entire torso area (no half shirts, tank tops, or cut-off sleeves) and long pants are required.


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4.61.3.5 Personnel handling chemicals or who may be exposed to chemicals shall refer to the chemical Safety Data Sheet (SDS, also referred to as MSDS) for minimum PPE requirements including respiratory protection.

4.61.3.6 Personnel performing hot work or who may be exposed to ignition sources shall wear clothing made from 100% natural fiber or are flame-resistant.

4.61.3.7 PPE shall be inspected by the user prior to use; defective or damaged PPE shall be destroyed to prevent further use.

4.61.3.8 Prior to being issued any PPE, employees will be trained on how to properly inspect, don, doff, adjust, and wear PPE; the limitations of PPE; and care and maintenance of PPE. This training is provided in NGET.

4.61.3.9 Specific PPE requirements for work activities will be disseminated via the Task Hazard Assessment (THA), approved Work Package, Pre-Job Briefing, Radiation Work Permit, and/or by direction of the Work Supervisor.

4.61.3.10 Visitors will comply with all PPE requirements.

4.61.3.10.1 Slip on protective footwear designed to fit over serviceable shoes is available if the visitor needs to enter an active work area; please contact Industrial Safety & Hygiene to obtain this protective footwear.

4.61.4 Faceshields – Faceshields are required to be worn in combination with safety glasses if you are performing work activities that create airborne face and eye hazards such as:

4.61.4.1 Drilling or chipping masonry, concrete, paint, pipe coatings, or metal, which generate a flying particle hazard.

4.61.4.2 Flame welding, cutting, or burning. Use approved tinted lenses.

4.61.4.3 Flying particles caused by other workers.

4.61.4.4 Inspecting or maintaining wet cell batteries.

4.61.4.5 Power grinding, buffing, or wire brushing.

4.61.4.6 Transferring chemicals which would be harmful if splashed.


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4.61.4.7 Using power tools like saws, sanders, jackhammers, etc., which generate a flying particle hazard.

NOTE: Faceshields are classified as Secondary Protection, and may only be worn in conjunction with Primary Protection (safety glasses). A Z87.1 label or identifier on a faceshield confirms that the faceshield meets the criteria for Secondary Protection, and DOES NOT mean that the faceshield may be worn without safety glasses.

4.61.5 Hand Protection (gloves)

4.61.5.1 Gloves SHALL BE worn for all work activities, including waste handling, tool usage, material handling, pushing a cart, carrying cardboard boxes, performing radiological surveys, etc.

4.61.5.2 Everyone SHALL have their gloves with them so that you are prepared if the need for gloves should arise.

4.61.5.2.1 Personnel do not need to have gloves with them when walking to / from their Office / Lunch Room / Break Area to the RCA Access; pick up a pair of yellow Kevlar gloves when you enter the RCA.

4.61.5.3 Yellow Kevlar gloves are to be used inside of the RCA only. Yellow gloves SHALL NOT be used outside of the RCA.

4.61.5.4 Personnel may still wear other work gloves in the RCA as required by the THA, RWP, Work Package, or their Supervisor. These work gloves require a radiological survey prior to release from the RCA.

4.61.5.5 Wearing gloves when working on or near rotating machinery may present a risk of hand injury should a glove become entangled in the machinery. In this case, an assessment of this risk compared with the risk of not wearing gloves shall be performed by the Work Supervisor to determine if gloves are appropriate for the planned work.

4.61.5.6 Work gloves worn outside of the RCA shall be as required by the THA, Work Package, or Supervisor’s direction.


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4.61.6 Hard hats

4.61.6.1 Hard hats shall be of a “full brim” or “front brim” style.

4.61.6.2 Ball caps are not to be worn under hard hats. Winter liners, hoods, welder’s caps, heat stress devices, sweat bands, or anti-contamination hoods may be worn under a hard hat as long as they are worn smoothly and not “bunched up.”

4.61.6.3 Hard hat shells shall be replaced every five years from date of issue.

4.61.6.4 Hard Hats worn inside Power Block buildings shall have a hard hat light to illuminate dark areas and to aid exiting the building in the event of loss of electrical power.

4.61.6.5 Hard hat suspensions shall be replaced on an annual basis. Replacement suspensions are available in the NGET Training classroom to facilitate ready replacement during annual NGET training.

4.61.6.6 Hard hats shall be worn with the brim facing forward at all times.

4.61.6.7 Nametags are required on hard hats:

4.61.6.7.1 Professional stickers shall be placed a minimum of ½-inch from the helmet edge, not to cover the existing manufacturer-applied markings.

4.61.6.7.2 Labels, paint or magic marker, etc., are prohibited on hard hats. Logos applied by the hard hat manufacturer are acceptable.

4.61.6.7.3 Personnel who have successfully completed AED / CPR training may wear a CPR Trained / Certified sticker on their hardhat.

4.61.7 Hearing Protection

4.61.7.1 The use of hearing protection is required during any exposure to noise levels above 85 decibels as measured on the “A-weighted” scale (dBA).


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4.61.7.2 Inside Containment, the preferred hearing protection is earplugs inserted prior to entering Containment.

4.61.7.2.1 If it will be necessary to repeatedly remove and replace the hearing protection, canal caps mounted on a band that is placed around the neck are available. These should remain inside the hood and be handled from outside the hood to prevent contamination. Do not reach inside the hood to handle the canal caps or band with potentially contaminated gloves.

4.61.7.3 In areas where noise levels can be reasonably expected to reach 100 dBA, double hearing protectors, i.e., earplugs and ear muffs, should be worn.

4.61.7.3.1 Ear muffs are to be attached to the helmet prior to entering Containment whenever possible. Ear muffs must be attached under the hard hat cover.

4.61.7.3.2 Protective hoods that cover the ears interfere with the seal of the ear muffs around the ears. If a hood must be used (instead of a skull cap) and must cover the ears, then the use of hard hat-mounted ear muffs is not feasible. Use ear muffs with a wire support behind the neck instead of a headband to reduce the possibility of contamination. These ear muffs are to be used only when the use of hard hat-mounted ear muffs is not feasible.

4.61.7.3.3 If ear muffs must be adjusted or removed and replaced inside containment, contact an RP Technician for assistance. The ear muffs should remain inside the hood and be handled from outside the hood to prevent contamination. Do not reach inside the hood to handle the ear muffs or band with potentially contaminated gloves.

4.61.7.3.4 Exiting Containment, workers will keep the ear muffs attached to the hard hats.


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4.61.8 Protective Footwear

4.61.8.1 Protective footwear with a leather upper is required for Hot Work.

4.61.8.2 Protective footwear should be in good condition, i.e., the protective cap should not be visible, sole tread is not worn smooth, laces / eyelets functional, etc.

4.61.8.3 Specialty protective footwear (i.e., spiked shoe treads for ice/snow, metatarsal foot protection, rubber boots with steel toes, shoe-cover toe caps and metatarsal guards, and radiological shoe covers) will be provided by ZionSolutions at no cost to the employee.

4.61.8.4 Personnel who are required to wear protective footwear but have a medical condition that prevents them from wearing such footwear must receive a medical exemption from Occupational Health Services. These employees must wear serviceable work shoes and should not be assigned work where there is a risk of foot injury.

4.61.8.5 Where protective footwear is not required as per Section 4.61.2, serviceable shoes shall be worn. Serviceable shoes shall have slip-resistant soles and shall protect against penetration hazards. Shoe types which are not permitted include, but are not limited to, canvas sport shoes, clog style shoes, open-toed shoes, moccasins, high heels, and sandals.

4.61.8.6 ZionSolutions employees are eligible for reimbursement for purchasing protective footwear in accordance with Reference 2.61 – ZS-AD-18: Protective Footwear Reimbursement Policy.

4.61.9 Reflective Safety Vests

4.61.9.1 Reflective, or high visibility safety vests provide additional visibility and are required for personnel engaged in specific work activities such as:

4.61.9.1.1 Crane Signal Person (the color orange is reserved exclusively for Signal Persons),

4.61.9.1.2 Spotters,


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4.61.9.1.3 Working in close proximity to operating heavy equipment, and

4.61.9.1.4 When required by the approved Work Package, or if signs are posted at the work area requiring the use of high visibility safety vests.

4.61.9.2 A high visibility shirt or jacket may be substituted for a high visibility safety vest.

4.61.10 Safety Glasses

4.61.10.1 All personnel who wear prescription glasses are required to wear an overglass over their prescription glasses or wear prescription Safety glasses whenever protective eyewear is required

4.61.10.2 Fogging of Safety Glasses

4.61.10.2.1 Safety glasses are required to be worn in conjunction with the 3M L-905 PAPR. The faceshield on the 3M L-905 PAPR is ANSI-rated as a faceshield, but does not provide the ANSI-required eye protection for safety glasses. During hot / humid weather, fogging of the safety glasses has been experienced.

4.61.10.2.2 While wearing fogged safety glasses clearly presents an unacceptable hazard, removing the safety glasses also places your eyes at risk. In the event of fogging, the expectation is that the user will don UVEX 3001 OTG (over the glass) safety glasses as they provide the necessary eye protection, while also increasing the air gap (and hence the air flow) between your face and the safety glasses which should prevent fogging.

4.61.10.2.3 If combined use of the 3001 OTG and the 3M L-905 PAPR still results in fogging of the safety glasses, contact Industrial Safety & Hygiene for implementation of a PPE Exemption that identifies the approved protocols to protect your eyes while wearing the 3M L-905 PAPR.


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4.61.10.3 Tinted Safety Glasses

4.61.10.3.1 Safety glasses with indoor-outdoor mirrored lenses are permitted.

4.61.10.3.2 Tinted glasses are not approved for indoor use (other than Hot Work)

4.61.10.3.3 Glasses that automatically darken when entering darker areas (photo-gray, Transitions, etc.) ARE permitted indoors. The wearer should pause when coming indoors to allow time for the lens to lighten.

4.61.10.4 ZionSolutions employees are eligible for reimbursement for purchasing prescription safety glasses; please contact Occupational Health Services for additional information.

4.61.10.5 ZionSolutions has made arrangements with Safety Rx Services for individuals to obtain prescription Safety glasses at a competitive price. Please contact Occupational Health Services for additional information.

4.61.10.6 Spikees

4.61.10.6.1 Spikees are required to be worn on site if snow and / or ice is present in your travel path.

4.61.10.6.2 Each employee should be aware of changes in weather that could result in the required use of spikees while on-site.

4.61.10.6.3 An aggressive (or open) block tread on protective footwear is not a substitute for wearing spikees.

4.61.10.6.4 IS&H may approve other types of snow/ice traction devices on a case by case basis.

4.61.10.6.5 Spikees shall NOT be worn through any portal monitors except for the PM-7’s at the NGET Building.

4.61.10.7 PPE Exemptions – In specific circumstances, the use of PPE may present a greater hazard than not using the PPE. The


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Work Supervisor may request a PPE Exemption from Industrial Safety & Hygiene using the following guidelines:

4.61.10.7.1 Requests for PPE exemptions shall not be made based solely on worker comfort.

4.61.10.7.2 The Work Supervisor has determined that wearing PPE creates a greater hazard or is not feasible.

4.61.10.7.3 The hazard requiring the PPE has been mitigated.

4.61.10.7.4 If approved, the Work supervisor shall post a copy of the approved PPE Exemption Request Form at the job site and maintain a copy in the field copy of the work package for the duration of the task covered by the exemption.

4.62 Poly-Chlorinated Bi-Phenyls (PCBs)

Polychlorinated biphenyls are mixtures of up to 209 individual chlorinated compounds (known as congeners). PCBs are either oily liquids or solids that are colorless to light yellow. Some PCBs can exist as a vapor in air. PCBs have no known smell or taste. Many commercial PCB mixtures are known in the U.S. by the trade name Aroclor. PCBs have been used as coolants and lubricants in transformers, capacitors, and other electrical equipment because they don’t burn easily and are good insulators. The EPA has classified PCBs as a probable human carcinogen.

4.62.1 PCBs are known or presumed to be present in:

4.62.1.1 Caulks.

4.62.1.2 Electrical Equipment (i.e., cable, capacitors, circuit breakers, electric motors, electromagnets, reclosers, switches, voltage regulators and voltage regulator enclosures) as listed in Reference 2.66 – ZS-WM-112: Polychlorinated Biphenyl Management.

4.62.1.3 Fluorescent light ballasts.

4.62.1.4 Heat transfer and hydraulic systems.


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4.62.1.5 Paints and coatings. Representative sampling has been performed throughout Zion Station; PCBs have been confirmed to be present in some paints and coatings.

4.62.1.6 Transformer oil.

4.62.1.7 Voltage Regulators.

4.62.2 PCB-containing caulk should be abated in accordance with Reference 2.66 – ZS-WM-112: Polychlorinated Biphenyl Management.

4.63 Post Fuel Transfer Operations (FTO) Changes

With the completion of the Spent Fuel Campaign, all 2,241 spent fuel assemblies have been placed into Monitored Dry Storage at the Independent Spent Fuel Storage Installation (ISFSI). Numerous changes to the Zion Restoration Project have occurred as we enter the demolition phase, including:

4.63.1 Emergency Egress for Decommissioning Work Areas – Demolition work activities may occasional block exit locations, requiring personnel to exit at an alternative location. When these situations occur, it is the expectation of management that the exit pathways be marked. Pathways can be marked using visible paint along with luminescent painted signs above or below the visible paint, with luminescent exit signs, and or folding luminescent exit signs. In any case exit routes shall be marked so they can be read in the light or the dark. Exit signs directing personnel to a blocked exit shall be covered or removed. When the normal exit is no longer blocked, alternative signs shall be removed and the original exit signs restored.

4.63.2 Fire Prevention and Emergency Egress Protocols as defined in Section 4.29.

4.63.3 Personal Protective Equipment (PPE) is now required to be worn onsite (past the North Gate) at all locations except as defined in Section 4.61.2.

4.63.4 Site Emergency’s / Fires and Defueled Emergency Plan Announcements

4.63.4.1 Two ten second varying tones will be used to identify a site Emergency/Fire Announcement which would in the event of an actual occurrence be followed by instructions on the event, location and evacuation/assembly information as required.

4.63.4.2 Two (2) ten-second steady tones will be used to identify a site Defueled Emergency Plan Announcement which would in the event of an actual occurrence be followed by instructions on


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the event, location and evacuation/assembly information as required.

4.63.4.3 It is essential that all work groups have radio communications present with them either individually or through a designated individual responsible for monitoring radio traffic within the scope of work being performed.

4.63.4.4 The radio communications system replaces the previous Take Shelter cell phone notification system.

4.64 Pre-Job Briefings / Post Job-Critiques

Pre-Job Briefings are performed prior to performing work activities to ensure that personnel fully understand how to perform the work activity in a safe manner. The Work Supervisor is responsible for performing the Pre-Job Briefing with all personnel directly involved in the work activity.

4.64.1 Pre-Job Briefings shall be performed shiftly for all decommissioning activities in accordance with Reference 2.13 – HU-ZN-1211: Pre-Job, Heightened Level of Awareness, and Post-Job Briefings.

4.64.2 Supervisors may exempt certain tasks based on worker familiarity with the task and lack of exposure to hazards. These may include:

4.64.2.1 Administrative tasks.

4.64.2.2 Housekeeping activities performed in areas where no other decommissioning activity is being conducted.

4.64.2.3 Management walkdowns and tours in areas where no other decommissioning activity is being conducted.

4.64.3 Post-Job Critiques, including Lessons Learned, should be performed in accordance with Reference 2.13 – HU-ZN-1211: Pre-Job, Heightened Level of Awareness, and Post-Job Briefings.

4.65 Railcar Safety

ZionSolutions will ship radioactive waste produced from the Zion Restoration Project via railcar to the disposal facility in Clive Utah. The existing rail lines on the Zion property have been upgraded and additional rail lines installed to support railcar operations. Safe rail operations will be performed in accordance with Reference 2.68 – ZS-WM-134: Trackmobile Operations.

4.65.1 When moving railcars around site, the Waste Operations Group uses the Trackmobile and escorts them. Be aware that even though the rail cars


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are moving slowly around site, they need a lot of space and time to stop. When a railcar approach the road or pedestrian walkway, stop and allow the railcar to pass, as the railcar has the right of way.

4.65.2 Do not step on the rail. Slips due to moisture on the track, uneven footing etc., can lead to accidents/injuries.

4.65.3 Cross rail lines only at designated crossings. The only rail crossings currently designated for pedestrian traffic are at the following locations:

4.65.3.1 Between the east and west employee parking lots (currently marked with orange paint and concrete crossing).

4.65.3.2 In front of the ENC building (currently marked with orange paint and concrete crossing).

4.65.3.3 The heavy haul crossing at the Unit 1 and Unit 2 spur.

4.65.3.4 The dirt road crossing at the end of the rail line near the far south east corner of the property.

4.65.3.5 There are also several areas that have been paved between the tracks that are acceptable to be used as crossings.

4.65.4 If you are not part of the Waste Operations Group, are not supporting waste operations activities, and have not attended a pre-job brief concerning working around the railcars, then you must remain at least 10’ distant from all rail sidings. Permission may be obtained from the Waste Operations group on a case by case basis.

4.66 Refractory Ceramic Fiber (RCF)

Refractory ceramic fibers (RCF) are used as insulating materials and flame retardants because of their ability to withstand high temperatures. They come in the form of blankets, boards, felts, bulk fibers, vacuum-formed or cast shapes, paper, and textiles. One of the RCF-containing products that are present at Zion is Cerafiber®. Other trade names for RCF-containing products include Ultrafelt, Pyro-Blanket, Cerablanket, Cer-Wool, and Kaowool RT, among others.

4.66.1 Products that contain RCF’s can release those fibers into the environment when they are pulled apart, stuffed into pipe or cable chases, pulled back out of those areas, or otherwise disturbed. Some of the fibers are small enough to be inhaled deeply into the lungs.

4.66.2 Refractory ceramic fibers have been identified by a number of organizations worldwide as possibly causing cancer. These concerns are based on animal exposure studies, including inhalation studies. RCF’s


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are classified as “suspected carcinogens” because there is evidence available from animal studies, but there is not adequate data from human experience to confirm that the material causes cancer in people.

4.66.3 As a safety precaution we will avoid the use of RCF’s wherever possible. RCF’s are known to have been used at Zion as a Fire Barrier material in floor / wall penetrations. When working with products containing RCF, the Work Package will address exposure controls, personal protective equipment (PPE), and worker training requirements.

4.66.4 Additional information may be found in Attachment 7 – ZionSolutions Refractory Ceramic Fiber Information Sheet.

4.67 Remotely Operated Demolition Tools

4.67.1 Brokk

The Brokk is a remotely-controlled demolition machine used for many demolition applications, including demolition of concrete walls and piping. Two attachments commonly used on the Zion Restoration Project are the BCS10 (saw) and the BCS35 (chisel). Specific safety requirements for operating the Brokk include:

4.67.1.1 Body Positioning – Where feasible, everyone must maintain a minimum 30-foot distance while the chisel attachment is in use. A minimum 50-foot distance is required during work with the saw attachment. Individuals shall never stand directly behind the Brokk while in use. The operator must position him/herself as far outside the direct line of the saw blade as possible. Where maintaining the specified distance from the work location is not feasible, physical protection, such as screens, mesh, netting, etc. should be used to protect against flying objects.

4.67.1.2 Communications – Due to elevated noise levels from operating the Brokk, the use of a high powered strobe light shall be used to signal the Brokk operator to shut off power to the Brokk.

4.67.1.3 Line of Fire – Line of Fire pinch points exist due to the moving Brokk body, arm, treads, and outriggers. Safety barriers shall be established as per Section 4.70 – Safety Barriers and Postings to keep non-essential personnel out of the work area. Prior to setting the outriggers, the operator must verify that no one is in the line of fire. Warning using 3-


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way communication shall be given to all in the immediate area prior to setting outriggers.

4.67.1.4 PPE – The Operator, tender, and anyone else working in the immediate area shall wear a hardhat, safety glasses, double hearing protection (plugs and muffs), gloves, coveralls, and faceshield. All individuals on the same floor or elevation as the Brokk are required to wear hearing protection. Depending on proximity to the Brokk, double hearing protection may be required.

4.67.1.5 Silica – Elevated levels of silica dust are expected with the use of the BCS35 attachment. All personnel in the work area must use respiratory protection as required by the approved Work Package THA. In order to prevent silica dust becoming airborne while sawing or breaking concrete walls, water shall be used when possible and with RP approval if work is performed in the RCA. If RP prohibits water usage, additional ventilation as specified by Industrial Safety & Hygiene shall be used.

4.67.1.6 Spotters – The Spotter’s duties must be established and discussed in the pre-job brief. In addition to tending electrical cords and other equipment needs, the Spotter shall watch to prevent personnel from entering the swing radius of the body of the Brokk or the moveable arm.

4.67.2 Diamond Wire Saw

This is a modular machine used for cutting a variety of materials throughout the facility. The hydraulic motor allows for variable speeds in either direction. The electrical panel has a power switch, a low voltage monitor, circuit breakers, and overload protection. Specific safety requirements for operating the Diamond Wire Saw include:

4.67.2.1 Body Positioning – The operator should maintain a safe distance away from the point of contact to avoid potential safety hazards while performing work. Per the operations manual, the danger zone is twice the distance of the cable to the point of contact. No one should be inside the danger zone during operations.

4.67.2.2 PPE – The operator shall wear a hard hat, hearing protection (plugs or muffs), safety glasses, gloves, coveralls, steel toe boots, and faceshield.


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4.67.2.3 Spotter – The spotter’s duties must be established and discussed in the pre-job brief. In addition to tending electrical cords and other equipment needs, the Spotter shall watch to prevent personnel from entering the danger zone while the saw is in operation.

4.67.3 Husqvarna

The Husqvarna DXR300 is a fixed arm remotely controlled demolition robot used for many demolition applications, including demolition of concrete walls and piping. Specific safety requirements for operating the DXR300 include:

4.67.3.1 Body Positioning

4.67.3.1.1 The operator should maintain a safe distance away from the point of contact to avoid potential safety hazards while performing work.

4.67.3.1.2 Nobody is permitted to be within the machine’s risk area when work is underway. When feasible everyone including the operator shall maintain a minimum distance of 20 feet during operation of the Husqvarna.

4.67.3.1.3 Where maintaining the specified distance from the work location is not feasible, physical protection, such as screens, mesh, netting, etc. should be used to protect against flying objects

4.67.3.2 Line of Fire – Line of Fire pinch points exist due to the moving body, arm, treads and outriggers.

4.67.3.2.1 Before operation, a safety barrier shall be put the place to section off the work area.

4.67.3.2.2 Prior to setting the outriggers, the operator must verify no one is in the line of fire. Warning using 3-way communication shall be given to all in the immediate area prior to setting outriggers.

4.67.3.3 PPE – The operator, tender, and personnel in the immediate area shall wear a hard hat, double hearing protection (plugs


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and muffs), safety glasses, gloves, coveralls, protective footwear, and faceshield.

4.67.3.4 Spotter – The spotter’s duties must be established and discussed in the pre-job brief. In addition to tending electrical cords and other equipment needs, the Spotter shall watch to prevent personnel from entering the swing radius of the moveable arm.

4.68 Rescue Team

4.68.1 Rescue of injured personnel will be performed by the City of Zion Fire Department.

4.68.2 Rescue Plans are developed by Industrial Safety & Hygiene for all Fall Protection Plans developed for all unprotected work performed at height ≥6 feet above the lower elevation, as detailed in Section 4.87.2.

4.69 Respiratory Protection (§29 CFR 1910.134)

Respiratory protection may be required for specific work activities. Respiratory protection will be worn only after evaluation of engineering controls and administrative controls as a means of reducing employee exposure.

The Manager, Industrial Safety & Hygiene is the Respirator Program Administrator (RPA) for both radiological and non-radiological respirator usage.

4.69.1 Respiratory protection shall be worn in accordance with Reference 2.28 – SAF-07: Respiratory Protection Program.

4.69.2 The specific respiratory protection worn shall be selected in accordance with Reference 2.22 – OSHA Technical Manual Section VIII: Chapter 2 – Respiratory Protection, Reference 2.29 – SAF-08: Evaluation and Selection Process for Radiological Respirator Use, and Reference 2.30 – SAF-09: Evaluation and Selection of Respiratory Protection for Non-Radiological Use.

4.69.3 If workers may be potentially exposed to both radiological and non-radiological hazardous atmospheres, then the selection and authorization of respiratory protection shall be a joint decision of the Respirator Program Administrator and Director – Radiation Protection.

4.69.4 Respirators are issued for one shift and then returned to the issuer (Radiation Protection for respirators worn in a Radiologically Controlled Area (RCA) or Industrial Safety & Hygiene for respirators worn outside of the RCA).



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4.69.5 Respirator users shall be qualified to use the respiratory protection device selected. This qualification includes the following:

4.69.5.1 Current fit-test for the device to be worn (tight-fitting respirators only).

4.69.5.2 Current Level 1 Respirator User Training.

4.69.5.3 Current respirator medical certification.

4.69.5.4 Training for the device to be worn.

4.69.5.4.1 3M 7500 Half-Facepiece Respirator – Reference 2.45 – SAF-26: Use and Care of the 3M™ 7500 Half Facepiece Respirator.

4.69.5.4.2 3M H-412 Powered Air Purifying Respirator (loose-fitting) – Reference 2.46 – SAF-27: Use and Care of the 3M H-412 PAPR.

4.69.5.4.3 3M L-905 Powered Air Purifying Respirator (loose-fitting) – Reference 2.44 – SAF-25: Use and Care of the 3M™ L-905, L-905SG, and L-905SG-F PAPRs.

4.69.6 Personnel who require (tight-fitting) respiratory protection to perform their work activities shall be quantitatively fit tested on the make, model, and size of the respirator to be worn.

4.69.6.1 Respirator fit tests shall be performed in accordance with Reference 2.43 – SAF-24: Quantitative Respirator Fit Testing.

4.69.6.2 Quantitative fit testing shall be performed only after the successful completion of respirator training and a respirator physical.

4.69.7 Voluntary Usage

4.69.7.1 Voluntary use of single-use disposable filtering face pieces (dust masks) is permitted with the approval of the Respirator Program Administrator and use is considered to be in accordance with the provisions of OSHA program requirements.

4.69.7.2 Voluntary use of single-use disposable filtering face pieces (dust masks) are prohibited for radiological protection.


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4.69.7.3 Respirators used on a voluntary basis must be NIOSH certified and no credit may be taken for their use in estimating intake or dose.

4.69.7.4 Voluntary users of disposable filtering face pieces (dust masks) are exempt from medical screening and fit testing.

4.69.7.5 Voluntary users of disposable filtering face pieces (dust masks) shall receive awareness training (provided in NGET).

4.69.7.6 Voluntary use of respiratory devices other than disposable filtering face pieces (dust masks) is permitted with the approval of the Respirator Program Administrator and if the users have been trained, fit tested, and medically certified as applicable in accordance with the qualification requirements of this procedure.

4.69.7.7 Voluntary use of tight-fitting respirators (i.e., the 3M-7500 series half-face respirator) shall be clean shaven.

4.69.7.8 The voluntary usage of filtering facepieces is allowed for all approved Work Packages, unless entering Asbestos, Hexavalent Chromium, or Lead Regulated Areas and other work areas where respiratory protection is required as per Attachment 1 of Reference 2.30 – SAF-09: Evaluation and Selection of Respiratory Protection for Non-Radiological Use.

4.70 Safety Barriers and Postings (§29 CFR 1910.145)

Safety barriers, barricades, and warning systems (signs) shall be established by the Work Supervisor to notify personnel of safety hazards in the work area.

4.70.1 Safety Barriers

4.70.1.1 Entry into safety barricaded areas should be performed at designated entry points. Stepping over or ducking under a safety barrier to gain access is PROHIBITED.



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4.70.1.2 The Work Supervisor has the responsibility to keep personnel not directly involved in their work out of their work area as appropriate and out of harm’s way. Examples of ways to block off a Work Area are dependent on the type of work and hazards, and include barricades, tents, cones, spotters, and/or appropriately colored rope or ribbon.

4.70.1.2.1 Red DANGER or yellow CAUTION ribbon may be used for short duration activities.

4.70.1.2.2 Yellow and black safety rope is recommended for longer duration safety barriers.

4.70.1.2.3 Yellow and black safety rope shall not be used for any other application (i.e., taglines, hanging tools and/or equipment, etc.)

4.70.1.3 Safety barriers must be sufficient to prevent inadvertent entry into the Work Area from any approach.

4.70.1.4 Safety barriers should be established at approximately waist height so as not to present a tripping hazard.

4.70.1.5 Safety signs and barricades should be promptly removed once the safety hazard has been eliminated.

4.70.2 Safety Signs

4.70.2.1 Post safety signs in areas with safety barricades indicating the type of hazards.

4.70.2.2 The Work Supervisor should obtain safety signs from Industrial Safety & Hygiene.

4.70.2.3 Safety signs should identify the hazard, responsible Work Supervisor (or designee), and a contact phone number.

4.70.2.4 Yellow – Caution – sign will be posted to indicate a potentially hazardous situation that if not avoided, may result in minor or moderate injury identifying hazard.

4.70.2.5 Orange – Warning – sign will be posted to indicate a potentially hazardous situation, which, if not avoided, could result in death or serious injury.


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4.70.2.6 Red – Danger – sign indicates an imminently hazardous situation, which, if not avoided, will result in death or serious injury.

4.70.2.7 Replace the sign(s) if faded, illegible, or damaged.

Note: Absence of a safety sign on a safety barrier does not mean the Work Area is free of hazards and that unrestricted access is allowed into the Work Area. If you have not participated in the Pre-Job Brief to enter the Work Area, DO NOT ENTER. Contact your Supervisor to determine who the responsible Work Supervisor is so that the Safety Barrier can be properly posted or removed if the hazard has been eliminated.

4.71 Safety Committee

The ZionSolutions Safety Committee will operate in accordance with Reference 2.39 – SAF-20: Site Safety Committees. It is the responsibility of the Safety Committee to advise and assist in the implementation of the Safety Program to ensure employees are carrying out their responsibility to provide a safe workplace free from hazards that cause or threaten to cause physical harm.

4.72 Sanitation (§29 CFR 1926.51)

Proper sanitary facilities will be provided for ZionSolutions employees and subcontractors. These facilities include:

4.72.1 Potable water.

4.72.2 Toilets.

4.72.3 Washing facilities.

4.73 Scaffolding (§29 CFR 1926 Subpart L)

Scaffolding is used to provide safe access to elevated work areas. Inspections or limited work activities approved by the Work Supervisor may be performed using a ladder to provide safe access to the elevated work area. Work activities that will require more than limited access to the work area, involve the use of power tools, etc., should use a scaffold to provide safe access to the elevated work area. An aerial platform and/or scissor lift may also provide safe access to the elevated work area if the acceptable floor loading is sufficient for the additional weight of the aerial platform and/or scissor lift.

4.73.1 Scaffolding and ladders shall be used in accordance with Reference 2.42 – SAF-23: Scaffold and Portable Ladder Use.

4.73.2 Each employee, contractor, or visitor who is involved in erecting, disassembling, moving, operating, repairing, maintaining, or inspecting a




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scaffold shall be trained by a Competent Person to recognize any hazards associated with the work in question.

4.73.3 Scaffolding shall be inspected each shift prior to use by a Competent Person or Scaffold Inspector. This inspection shall be documented on the Scaffold Inspection Tag.

Note: The scaffold inspection shall include the Competent Person physically accessing all scaffold platforms; scaffolding shall not be inspected visually from the ground looking up.

4.73.4 Scaffold Tags

4.73.4.1 Red “Do Not Use” – Scaffold is not approved for use.

Note: The absence of a tag is considered the same as a red tag – the scaffold is not approved for use.

4.73.4.2 Yellow – The yellow tag signifies the scaffold is safe for use, but may have missing components. Examples could be missing decking or safety rails because of equipment being moved or fixed plant components obstructing their installation. Fall protection may be required as well as other safety requirements as noted on the scaffold tag.

4.73.4.3 Green – Scaffold is approved for use.

4.73.5 Scaffold Modifications

4.73.5.1 Scaffold modifications include removing any non-load bearing structure such as a midrail or guardrail to support immediate work activities (i.e. removing mirror insulation). All modified scaffold structures shall be replaced immediately following the completion of the task at hand.

4.73.5.2 Modifications shall not be made in such a manner as to create an unprotected edge on any side of the scaffold not facing the work activity.

4.73.5.3 A Modifier cannot leave a scaffold amidst modification without replacing all scaffold components or without hanging a Red Scaffold Tag. If work activities change the existing safety boundaries, such as removing mirror insulation and creating a gap greater than 14 inches between the plank and the wall, a Competent Person shall be consulted in order to implement any required structural changes to the scaffold.


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4.73.6 All personnel who require access to scaffolding shall receive scaffold user training upon hire at NGET and annually thereafter, and are designated as a Scaffold Competent User.

4.73.6.1 Competent Users shall verify that a yellow or green tag and a Scaffold Inspection Tag are present on the scaffold prior to use.

4.73.6.1.1 Competent Users shall also perform a visual inspection of scaffold prior to use. Attachment 5: Scaffold User Checklist of Reference 2.42 – SAF-23: Scaffold and Portable Ladder Use should be attached to the scaffold to aid this inspection.

4.73.6.1.2 If scaffold integrity is in doubt, the scaffold shall not be used until evaluated by a Competent Person.

4.73.7 A swing gate should be used at the access ladder on all accessible scaffold platforms to provide a fall prevention barrier to lower elevations.

4.73.7.1 Swing gates shall be installed so that they provide a safety barrier at the access ladder, i.e., the swing gate shall not open outwards from the scaffold platform, i.e., towards the access ladder.

4.73.7.2 A chain may be used if a swing gate is not feasible; however a chain is not an acceptable safety barrier. Fall protection will be required if the scaffold platform is greater than six feet above the next lower elevation and users are not otherwise protected by an approved guardrail system or equivalent.

4.73.7.3 Use of scaffold tubing that restricts access/egress from the access ladder to the scaffold platform is prohibited as a safety barrier.

4.73.8 Scaffold platforms are located at the proper height to allow the Scaffold Competent User to perform their work activity. Personnel shall not climb on the midrail and/or guardrail to reach heights inaccessible from the scaffold platform.

4.73.9 Tygon tubing or equivalent means should be installed on exposed scaffold clamp bolt threads to provide impact protection to exposed skin.


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4.74 Severe Weather

4.74.1 Severe weather conditions may require the suspension of outdoor work activities. As severe weather approaches, the affected work activity shall be placed in a safe condition and immediately cease.

4.74.2 When lightning is visible, and thunder is audible, all ZionSolutions employees and subcontractors working outdoors shall leave high points (i.e., roofs, ladders, etc.).

4.74.2.1 Personnel in an exposed area (open field, top of a cell, etc.) shall go inside a building or an enclosed vehicle with rubber tires.

4.74.2.2 The distance of the lightning from the work area may be estimated by applying a distance of one mile for every five seconds between seeing the lightning and hearing the thunder.

4.74.2.3 Outdoor work activities may resume when lightning and/or thunder has ceased for a minimum of 30 minutes.

4.74.2.4 Personnel should minimize their time spent outdoors if walking to / from buildings and / or the parking lot in severe weather.

4.74.3 Missile Hazards

4.74.3.1 Tools, equipment, and materials used to support the Zion Restoration Project could become an airborne missile hazard during inclement weather such as high winds, potentially causing injury to personnel or damage to plant equipment, including electrical distribution equipment, compressed gas cylinders, and Dry Fuel Storage Casks.

4.74.3.2 Tools, equipment, and materials such as cardboard boxes, items covered with a tarpaulin, light-weight items with a large surface area such as plywood, unsecured PVC piping, etc., should be stored at all times to ensure that they do not become missile hazards. Proper storage methods could include:

4.74.3.2.1 Bring the material indoors where it is not exposed to the wind.

4.74.3.2.2 Place a heavy weight on top to prevent it from becoming airborne.


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4.74.3.2.3 Practice proper housekeeping to prevent accumulation of potential missile hazards.

4.74.3.2.4 Use additional restraining straps to secure tarpaulins to prevent wind from getting underneath the tarpaulin.

4.75 Silica

OSHA issued Reference 2.15 – OSHA Directive Number CPL 03-00-007: National Emphasis Program – Crystalline Silica in 2008 with two goals: 1) Eliminate employee overexposure to silica, and 2) Control health hazards associated with silica overexposure. Work activities that are potential sources of silica exposure include demolition, drilling, cutting, and scabbling of concrete.

4.75.1 Crystalline silica is a basic component of soil, sand, granite, and many other minerals. Quartz is the most common form of crystalline silica. Cristobalite and tridymite are two other forms of crystalline silica. All three forms may become respirable size particles when workers chip, cut, drill, or grind objects that contain crystalline silica.

4.75.2 Crystalline silica has been classified as a human lung carcinogen. Additionally, breathing crystalline silica dust can cause silicosis, which in severe cases can be disabling, or even fatal.

4.75.3 Additional information regarding silica is contained in Attachment 6 – Background Information on Silica.

4.75.4 Silica Engineering Controls implemented on the Zion Restoration Project include use of shrouded scabbling tools to capture silica dust, water directed at the point of operation to wet down silica dust, and local exhaust ventilation to capture silica dust at the point of generations.

4.76 Space Heaters

The requirements identified in Reference 2.55 – ZAP 900-01: Station Fire Protection Program shall be followed when using a portable electric space heater in the workplace.

4.76.1 Do not run electrical cord under carpets, mats, rugs, or in high traffic areas.

4.76.2 Heater must be capable of automatically shutting off if it is tipped or knocked over.


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4.76.3 Heater must be placed on a level surface located a minimum of 3 feet from combustible materials (e.g.: plastic waste baskets, paper, cardboard, clothing, cloth interior finishes, office furniture).

4.76.4 Heater must have a thermostat control.

4.76.5 Heater must have a wire grill or guard to prevent contact with the element.

4.76.6 Heater must only be plugged directly into a 110 Volt AC outlet. Extension cords should only be used if the manufacturer allows their use, then only the type extension cord allowed by the manufacturer is to be used.

4.76.7 Inspect the heater for broken/frayed electrical wire, cracked insulation, and damage to the heater. Never operate a defective heater.

4.76.8 Locate the heater in plain sight where it is clearly visible, not under workstations or desks. NOTE: This excludes installed floor finishes (e.g., tile, carpet) that the heater would be sitting on.

4.76.9 Never leave the heater turned on when you are away from your workplace. The heater must be turned off and unplugged when you leave for lunch, if you are away for extended periods (meetings, etc.), and at the end of the workday.

4.76.10 Never place anything on top of or touching the heater.

4.76.11 Only Underwriters Laboratories (UL) or Factory Mutual (FM) listed heaters may be used.

4.76.12 Read and follow the manufacturer’s operation and maintenance instructions prior to use.

4.76.13 To prevent electrical shocks or electrocutions, keep the heater away from water and never touch the heater if you are wet.

4.77 Stuck Equipment

Performed improperly or without the right equipment, the seemingly simple task of pulling equipment out of the mud or a vehicle with a loaded trailer over a small hump can result in costly damage and, possibly, physical injury or death. Please refer to Attachment 8 – Guidance for Stuck Vehicles for freeing stuck equipment.


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4.78 Task Hazard Analysis / Job Hazard Analysis / Job Safety Analysis

A Task Hazard Analysis (THA) is included in approved Work Packages to identify known or expected hazards and the appropriate controls to reduce or eliminate these hazards.

A Job Hazard Analysis (JHA) will define minimum requirements and responsibilities to identify, analyze and control potential hazards or risks associated with specific work activities and equipment operation with the goal of preventing occupational injuries and illnesses. A JHA shall be conducted (or have been conducted) for work that is considered potentially hazardous, high risk, or complex, including:

4.78.1 Any work conducted within 3 feet of a fence constructed with razor mesh or razor coil material that is not protected with a permanent barrier to prevent inadvertent contact.

4.78.2 Work with potential exposure to harmful chemicals (i.e., bulk chemical offload, etc.).

4.78.3 Work on “in-service” high-energy systems (i.e., water, steam, hydrolazing, air, pneumatic, etc., systems pressurized greater than 150 psi).

4.78.4 Work on chlorine systems.

4.78.5 Work near (i.e., within arm’s reach) or on unguarded operating rotating equipment.

NOTE: If the results of a previously conducted JHA have been incorporated into a routine procedure or Work Package and is considered by the Supervisor to still bound the work activity, then a new separate JHA is not required.

4.78.6 A JHA should also be considered for:

4.78.6.1 Newly established jobs: where, due to lack of experience in these jobs, hazards may not be evident or anticipated.

4.78.6.2 Modified jobs where new hazards may be associated with changes in job procedures.

4.78.6.3 Infrequently performed jobs where workers may be at greater risk when undertaking non-routine jobs and a JHA provides a means of reviewing hazards.

4.78.7 A Job Safety Analysis (JSA) should be developed each shift for work activities:


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4.78.7.1 Not bounded by a THA or JHA;

4.78.7.2 When there is a change in the work scope that does not require a revision to the approved Work Package; or

4.78.7.3 Where changing / unplanned conditions reduce or eliminate the effectiveness of established Safety controls.

4.79 Thermal Stress (Heat and Cold Stress)

4.79.1 Heat Stress

The permanent cessation of plant operations in 1998 eliminated many heat stress sources (operating plant equipment, reactor and steam plant operation, etc.). The potential for heat stress remains primarily in the summer months, working in areas with limited ventilation, wearing of impermeable coveralls, operation of heat-producing equipment, etc.

Only personnel who have received Heat Stress Awareness upon hire at NGET and annually thereafter shall be authorized to work under heat stress conditions.

4.79.1.1 Causal Factors

4.79.1.1.1 Age, weight, degree of physical fitness, degree of acclimatization, metabolism, use of alcohol or drugs, and a variety of medical conditions such as hypertension all affect a person’s sensitivity to heat. However, even the type of clothing worn must be considered. Prior heat injury predisposes an individual to additional injury.

4.79.1.1.2 It is difficult to predict just who will be affected and when, because individual susceptibility varies. In addition, environmental factors include more than the ambient air temperature. Radiant heat, air movement, conduction, and relative humidity all affect an individual’s response to heat.

4.79.1.2 Additional Heat Stress Safety Issues

4.79.1.2.1 In addition to heat stress, heat tends to promote accidents due to the slipperiness of sweaty palms, dizziness, or the fogging of safety glasses. Wherever there exists molten metal, hot surfaces,


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steam, etc., the possibility of burns from accidental contact also exists.

4.79.1.2.2 The frequency of accidents tends to be higher in hot environments than in more moderate environmental conditions. One reason is that working in a hot environment lowers the mental alertness and physical performance of an individual. Increased body temperature and physical discomfort promote irritability, anger, and other emotional states which sometimes cause workers to overlook safety procedures or to divert attention from hazardous tasks.

4.79.1.3 The Work Supervisor should evaluate the heat stress potential and coordinate with Industrial Safety & Hygiene to develop and implement heat stress reduction measures. Work activities involving potential heat stress should be performed in accordance with Reference 2.31 – SAF-10: Heat Stress Control.

4.79.1.4 Heat stress monitoring should be performed, as required, in accordance with Reference 2.17 – OSHA Technical Manual Section III: Chapter 4 – Heat Stress.

4.79.1.5 Drinking water may be provided in Radiologically Controlled Areas (RCA) when allowed by the Director – Radiation Protection.

4.79.2 Cold Stress

4.79.2.1 Four factors contribute to cold stress: cold air temperatures, high velocity air movement, dampness of the air, and contact with cold water or surfaces. A cold environment forces the body to work harder to maintain its temperature. Cold air, water, and snow all draw heat from the body. Wind chill is the combination of air temperature and wind speed.

4.79.2.2 Causal Factors – workers are at increased risk when:

4.79.2.2.1 They have predisposing health conditions such as cardiovascular disease, diabetes, and hypertension.

4.79.2.2.2 They take certain medication (check with your doctor, nurse, or pharmacy and ask if any


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medicines you are taking affect you while working in cold environments).

4.79.2.2.3 They are in poor physical condition, have a poor diet, or are older.

4.80 Tool Safety

Power and hand tools shall not be used for other than their designed purpose. Important safety requirements include:

4.80.1 All power tools shall be equipped with a three-wire (ground) system and three-pole plug, or be double-insulated. Always inspect the plug to ensure the third (ground) prong has not been cut off when using the three-wire system.

4.80.2 Avoid “line-of-fire” type risks by anticipating what could be struck during the normal course of tool use (e.g., wrenching) or when the tool suddenly slips or breaks free, and use body positioning, alternate tools, and/or teamwork to avoid injury if the tool slips or something (e.g., a bolt) suddenly breaks.

4.80.3 Ensure articles of loose clothing (e.g., sleeves, hoods, draw strings, etc.), long hair, jewelry and lanyards are properly secured and kept away from moving parts.

4.80.4 Inspect tools prior to use. Defective or damaged tools shall be removed from service and not used until repaired by qualified personnel.

4.80.5 Operate power tools or machines in accordance with manufacturer’s instructions. If you are not familiar with the proper operation, then contact your Supervisor.

4.80.6 Power tools should be unplugged or disconnected from the power supply when not in use and if performing maintenance / inspection of the power tool. The triggering device (control switch) shall not be considered an appropriate shut off.

4.80.7 The ignition wire shall be disconnected from the spark plug prior to performing maintenance on any gasoline-powered equipment. A minimum 20-pound ABC fire extinguisher is required to be available in the area when operating gasoline-powered tools.

4.80.8 Use Ground Fault Circuit Interrupters (GFCI) for all portable 120/240 VAC electrical tools and equipment.


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4.80.9 Use the proper tool for the job that is being performed. Makeshift tools or use of a tool beyond its capability is prohibited (i.e., a knife is not a pry bar; scissors are not a knife, etc.).

4.80.10 Chainsaw usage – PPE required for chainsaw usage includes chaps certified by Underwriters Laboratories for chainsaw usage, hard hat, faceshield, work gloves, hearing protection, safety glasses, and protective footwear.

4.80.11 Gasoline-Powered Tools

4.80.11.1 A minimum 20-pound ABC fire extinguisher is required to be available in the area when operating gasoline-powered tools.

4.80.11.2 Do not use gasoline powered tools in confined or enclosed spaces. Ensure exhaust gases do not flow into a confined work area or into the intake of a ventilation unit; contact IS&H for assistance.

4.80.11.3 The ignition wire shall be disconnected from the spark plug prior to performing maintenance on any gasoline-powered equipment.

4.80.12 Grinders

4.80.12.1 Grinding wheels, discs, or wire brushes ≥ 2 inches in diameter shall have an installed protective guard.

4.80.12.2 Grinding wheels, discs, or wire brushes shall have a speed rating that meets or exceeds the speed rating of the tool being used.

4.80.12.3 Verify the grinder attachment has come to a complete stop before setting the grinder down.

4.80.13 Impact Sockets

4.80.13.1 Use of a standard socket on an impact wrench is prohibited. Use of a standard socket with an impact wrench could result in the standard socket shattering, sending fragmenting pieces in all directions. This can injure you and the people around you. You may also lose control of the impact wrench, causing it to fly off the bolt.


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4.80.13.2 Impact sockets are made from a softer, more malleable material designed to handle the torque and flexibility of an impact wrench without the socket failing or shattering.

4.80.13.3 Most impact sockets are dull gray in color or a black finish that looks like chrome; a standard socket has a shiny chrome finish.

4.80.14 Knives – the improper use of knives can cause serious injury.

4.80.14.1 Box cutters shall not be used unless they are designed with self-retracting blades or are the enclosed blade type.

4.80.14.2 Cut-resistant gloves should be worn when using a knife.

4.80.14.3 Fixed blade knives should be sheathed when not in use.

4.80.14.4 Knife blades should be maintained in a sharp condition. A dull blade presents greater risk due to the additional force required to cut through the material.

4.80.14.5 Knives designed so that blades are not exposed should be used for opening boxes or cutting packaging material.

4.80.14.6 Knives shall not be used for cutting tie-wraps, cables, or similar objects. Pliers, end cutters, or other “scissor-type” tools shall be used for this.

4.80.14.7 Knives shall only be used when appropriate and when they are the correct tool for the job.

4.80.14.8 Personal knives are allowed provided that the knife has a fixed or locking blade and the blade length does not exceed 2.5 inches.

4.80.14.9 Razor knives should have automatic self-retracting blades.

4.80.14.10 When cutting an object with an open blade knife, ensure object is secure before cutting.

4.80.14.11 When using a knife always cut away from your body. Keep hands out of “line of fire”.


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4.80.15 Pneumatic tools shall have multiple independent restraint methods to prevent the uncontrolled whipping of the air hose in the event of a hose malfunction. These are:

4.80.15.1 Retaining clips (pins) installed as applicable (i.e., Chicago fittings) to prevent inadvertent separation of the hose fittings.

Note: Retaining clips are also required for water / fluid hose Chicago fittings to prevent inadvertent separation.

4.80.15.2 Safety excess flow valve (air fuse) at the air header connection to secure the air flow of air in the event of a significant increase in air flow, i.e., failed air hose.

4.80.15.3 Whip restraint at each air hose connection and at the tool air hose connection to prevent the uncontrolled whipping of an air hose.

4.80.16 Metal Banding (Band-It)

4.80.16.1 Installing and removing steel straps or banding can be dangerous if not performed with caution and the proper PPE:

4.80.16.1.1 Safety glasses

4.80.16.1.2 Face shield

4.80.16.1.3 Kevlar gloves

4.80.16.1.4 Kevlar sleeves

4.80.16.2 Consider and eliminate the hazards:

4.80.16.2.1 Am I and is everyone in a safe position?

4.80.16.2.2 Is the load under pressure?

4.80.16.2.3 Will the load shift?

4.80.16.2.4 Never leave straps lying around to create a tripping hazard.

4.80.17 Portable power equipment (welding machines, aerial platforms, Brokk, chainsaw, etc.) and tools should be inspected prior to use. If the equipment is damaged or needs repair, then:

4.80.17.1 Remove the equipment from service and inform your Supervisor of the deficiency.

4.80.17.2 Record the deficiency on the Defective Equipment Tag Log in the Safety Office.


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4.80.17.3 Attach a DANGER – DO NOT OPERATE tag (available from the Safety Office).

4.80.17.4 Remove the DANGER – DO NOT OPERATE tag from the equipment and return to service once repaired.

4.80.17.5 Close out the entry on the Defective Equipment Tag Log after the equipment has been repaired, removed from site, or disposed of.

4.80.17.6 This is NOT a substitute to the Lockout Tagout procedures which are in place to keep people safe while working on installed plant equipment. This is a means to notify personnel that portable power equipment requires maintenance / repairs and shall not be operated until repaired.

4.81 Training Requirements

The proper training is required to perform work on the Zion Restoration Project. The ZionSolutions Training Manager shall establish a Training Record for ZionSolutions employees and subcontractors to document base competency, prior training that is transferable to ZionSolutions, and to track completion of the project-specific specific training.

4.81.1 All ZionSolutions employees and subcontractors will receive a pocket-sized copy of this HASP. The expectation is that the HASP is readily available to the user.

4.81.2 All ZionSolutions employees and subcontractors will receive Project Awareness training regarding site hazards, site-specific safety requirements, and required PPE upon hire at NGET and annually thereafter. Periodic retraining, as determined to be necessary by the Executive VP and General Manager, will be held to address changes in field conditions or the introduction of new activities or equipment.

4.81.3 ZionSolutions, or another qualified training provider may provide any other Industrial Safety training required to perform work activities.

4.81.4 The VP of Construction and D&D shall ensure that all personnel operating specialized machinery, such as forklifts, cranes, drilling equipment, or heavy equipment, have demonstrated competency and have undertaken documented training.


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4.82 Transient Combustibles

4.82.1 Transient combustibles are considered to be any material (gas, liquid, or solid i.e. aerosols, oil, fire retardant wood), not identified and accounted for in the Station’s Fire Hazard Analysis (FHA) as fixed loading.

4.82.2 Prior to moving major transient combustibles that will be left unattended into the plant from normal storage areas, the responsible work group supervisor SHALL obtain approval from the Fire Marshal/Shift Supervisor by completing Attachment A, Transient Fire Load Permit and following the approval process as specified in Reference 2.55 – ZAP 900-01: Station Fire Protection Program.

4.82.3 Lumber and other combustibles (e.g. plastics, tarps, etc.) used in the plant SHALL be fire retardant, except for special applications as approved by the Fire Marshal/designee.

4.82.3.1 The use of “paint on” fire retardant is not permitted in the plant except in certain applications permitted by the Fire Marshal/designee.

4.82.4 All non‑fire retardant lumber used inside any building at Zion Station SHALL be identified as being non‑fire retardant.

4.82.4.1 Non‑fire retardant lumber is identified by florescent orange spray paint, AND is listed on the fire load permit.

4.82.5 Lumber and other combustible material required for use in the plant for maintenance and operating activities SHALL be located to minimize the potential exposure of fire hazards to critical equipment.

4.82.5.1 The material should NOT block access to fire protection equipment.

4.82.6 Although no transient Fire Loading Permit will be required, the Fire Marshal should be notified prior to storage of any combustible material outside plant buildings, but within the Security Restricted Area.

4.82.6.1 In these instances, the Fire Marshal SHALL review and approve the storage location, AND, if necessary, assign additional compensatory or protective measures.

4.82.7 For work areas within the plant (Auxiliary Building, Turbine Building, Crib House, etc.), excess combustible materials (e.g. scrap, unused materials, etc.) resulting from work activity in an area must be removed


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following completion of the activity, or at the end of the work shift, whichever comes first.

4.82.7.1 Excess combustible materials required for continuation of the work activity may remain in the area, provided prior approval has been obtained from the Fire Marshal/designee.

4.82.8 The quantity of flammable liquid that may be left unattended in any one fire zone, without a compensatory measure, SHALL be limited to 5 gallons.

4.82.8.1 Flammable liquids shall be in approved containers at all times.

4.82.9 Transit combustibles controls are not a replacement for proper housekeeping and safe, common sense practices such as putting excess combustibles in metal boxes at the end of your work day, taking trash directly out to proper receptacles at the end of the work day, etc. In the end, thoughtful and overt housekeeping practices = fewer fires = fewer safety hazards = better working conditions which should always be our desired state.

4.83 Vehicles and Transportation

4.83.1 All vehicles on site (personal or company) shall be operated in a safe manner.

4.83.2 Cell phone usage while operating a vehicle on Zion Station property is prohibited.

4.83.3 Drivers are responsible for ensuring that all passengers are belted prior to moving the vehicle.

4.83.4 Pedestrians have the right of way.

4.83.5 Seat belts are required when driving vehicles (personal or company) at any time on Zion Station property.

4.83.6 The maximum speed limit at Zion is 14 mph, which begins at the first Security Jersey barrier on Shiloh Boulevard. Lower speeds are prudent in parking lots, if personnel are present, or work activities are in progress in the vicinity of the roadway.


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4.84 Welding

Local exhaust ventilation should be evaluated as an Engineering Control for welding activities in accordance with Reference 2.41 – SAF-22: Use and Control of Ventilation for Welding, Cutting, and Grinding Activities.

4.85 Wind Sock

4.85.1 Wind socks are located south of the NGET building (adjacent to the Heavy Haul Path), in the South Parking Lot, and just outside the Security Restricted Area northeast corner fence. The wind sock provides for quick visual determination of wind speed and direction. The wind sock normally begins to extend at 3 mph and is fully extended at 17 mph.

4.85.2 If your work activity is limited by wind speed (such as heavy equipment operations involving a crane, aerial platform, or scissor lift), and the wind sock is fully extended, please contact Industrial Safety & Hygiene to monitor the precise wind speed. Please remember that wind whipping around building structures can vary considerably and result in localized gusts that may exceed heavy equipment wind speed limitations.

4.86 Winter Safety

Cold weather presents challenges that must be recognized and properly managed to ensure the safety of our employees. Proper control measures include:

4.86.1 Be alert for icy patches underneath snow, black ice, or hazards caused by frost.

4.86.2 Be cautious when approaching snowplows as snow and windy conditions may limit the snowplow driver’s vision with snowy / foggy windows or backup mirrors.

4.86.3 Be cautious when walking on ice and snow, especially in the gravel parking lot. Take small steps and keep your body weight centered over your feet; do the “penguin shuffle”.

4.86.4 Dress properly for cold weather.

4.86.5 Ice melt is located in strategic areas. Please use and apply liberally as required in walk areas, and let your Supervisor know if you use the last of the ice melt so that it can be replenished.

4.86.6 New employees may not be familiar with current walk paths or rapidly changing weather conditions from Lake Michigan, therefore report any


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areas that need additional snowplow cleaning, snow blower or shovel cleaning, and unsafe driving/walking areas.

4.86.7 Place your full attention to the surface you are walking on. Focusing on anything else while walking on a slippery surface is dangerous.

4.86.8 Practice safe walking skills when conditions are slippery.

4.86.9 Significant accumulations of snow / ice may accumulate on building roofs; presenting a potential dropping hazard to personnel walking / working below. Please look at the building roofs / overhangs in your work / walking areas, if a drop hazard is identified:

4.86.9.1 Contact the Fix-It Now (FIN) Team on DD 1 radio channel or the Facilities radio channel to notify them of the drop hazard area.

4.86.9.2 Remain outside the drop hazard area or post barriers to keep personnel out of the drop hazard area until the FIN Team can either clear the snow / ice off of the roof or establish safety barriers with signs identifying the drop hazard.

4.86.9.3 Sunlight is sufficient to start the melting process. This means that conditions may change on sunny days and that areas that were safe earlier may now present a drop hazard. Continuously evaluate your work / walk areas, don’t presume that an area safe in the morning will remain safe in the afternoon.

4.86.10 Slow down while driving on-site and give pedestrians the right of way.

4.86.11 Slow down. Walk, do not run. Do not be in a hurry.

4.86.12 Spikees (slip-on foot traction devices):

4.86.12.1 Spikees are required to be worn onsite anytime snow and / or ice is present in your travel pathway including parking lots. Please see your Supervisor to obtain spikees.

4.86.12.2 When installing Spikees either sit, or lean against a hard surface for support. DO NOT FREE STAND ON 1 FOOT TO APPLY SPIKEES.

4.86.13 Use the clearest, salted and/or sanded pathways whenever available, even if this means taking a longer route.


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4.86.14 WARNING – Tile floors and stairs can be very slippery when wet. Wipe your feet before walking on them.

4.86.15 Wear boots or overshoes with clean grip soles.

4.87 Working at Heights (Fall Protection) (§29 CFR 1926 Subpart M)

ZionSolutions is committed to provide safe access to elevated work areas to minimize the use of fall protection. The decommissioning process will remove components and structures creating fall hazards that have not been present since construction, requiring thorough evaluation of decommissioning work activities to identify these hazards and implement the proper controls prior to removing the components and structures.

4.87.1 Fall protection is required anytime personnel are working unprotected at heights greater than 6 feet. Fall protection is not required for employees erecting or dismantling supported scaffolds at height less than or equal to ten feet if there is not an acceptable anchorage available.

4.87.2 The Work Supervisor shall notify Industrial Safety & Hygiene if working at heights requiring the use of fall protection under any circumstances to assist with the development of a Fall Protection Plan, which shall include:

4.87.2.1 Acceptable anchorages,

4.87.2.2 Identification of the fall hazard,

4.87.2.3 Rescue Plan,

4.87.2.4 Specific fall protection equipment to be used, and

4.87.2.5 Task-specific fall protection training at the work location.

4.87.3 Fall protection equipment shall be inspected prior to use by the user and annually by a Competent Person.

4.87.3.1 A purple tie-wrap shall be affixed to the fall protection equipment to signify that the 2015 annual inspection has been performed.

4.87.3.2 Damaged fall protection equipment shall be removed from service and provided to Industrial Safety & Hygiene for disposition.

4.87.4 Rigging equipment (i.e., slings, wire ropes, etc.) SHALL NOT be used for fall protection.



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4.88 Working Over Water (§29 CFR 1926.106)

Working over or near water (i.e., the Crib House, Reactor Cavity, Spent Fuel Pool, etc.) where the danger of drowning exists shall be performed in accordance with Section 106 of Reference 2.3 - §29 CFR 1926: Safety and Health Regulations for Construction and requires implementation of the Buddy System (i.e., no one is alone in a work area that requires a Personal Floatation Device).

4.88.1 U.S. Coast Guard Approved Personal Floatation Devices (PFDs) are required any time personnel are working over or near water, where the danger of drowning exists. This includes:

4.88.1.1 The Crib House adjacent to the Forebay if the guardrail system is not present.

4.88.1.2 The Spent Fuel Pool when inside the Plexiglas wall area.

4.88.1.3 Working in these areas is considered a high hazard work activity and requires use of the Buddy System.

4.88.2 Orange PFDs shall not be worn unless that person is the designated crane Signalman.

4.89 Zinc

Zinc is a natural component of the earth’s crust and an inherent part of our environment. Zinc is present not only in rock and soil, but also in air, water and the biosphere – plants, animals and humans.

Zinc is an essential trace element for humans, animals and plants. It is vital for many biological functions and plays a crucial role in more than 300 enzymes in the human body. The adult body contains about 2-3 grams of zinc. Zinc is found in all parts of the body: it is in organs, tissues, bones, fluids and cells. Muscles and bones contain most of the body’s zinc (90%).

Zinc coating (galvanization) is applied to steel to enhance the longevity and performance of steel. Zinc coatings provide the most effective and economical way of protecting steel against corrosion.

4.89.1 ZionSolutions work activities will involve dismantlement of galvanized steel. Cold demolition methods (i.e., unbolting, shearing, etc.) do not present health risks.

4.89.2 Hot demolition methods (i.e., torch cutting) require proper management to ensure that health risks are minimized.




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4.89.2.1 Zinc oxide fumes cause flu–like illness called Metal Fume Fever. Symptoms of Metal Fume Fever include headache, fever, chills, muscle aches, thirst, nausea, vomiting, chest soreness, fatigue, gastrointestinal pain, weakness, and tiredness. The symptoms usually start several hours after exposure; the attack may last 6 to 24 hours. Complete recovery generally occurs without intervention within 24 to 48 hours.


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Attachment 1 – Spill Prevention Control and Countermeasure (SPCC)

SPCC refers to a federal law that requires ZionSolutions to have a plan to prevent, control and clean up oil spills.

Responding to an oil spill at the Zion Station:

#1 If safe, stop the spill at its source, i.e. plug the hole, pick up the drum, and close the valve.

#2 If safe, and if you can immediately locate spill response material, put on personal protective equipment (safety glasses, protective gloves) and determine if you have enough spill response material to clean up the spill:

If yes, place the spill response material on the out-side edge and work toward the center of the pooled oil.

If no, use the spill response material to protect storm drains, bodies of water, vegetation, permeable surfaces, wetlands, ignition sources, etc.

#3 Call the ISFSI Shift Supervisor (847) 379-2211 as soon as possible and report:

Your name, location and time of the spill The type of oil spilled High risk conditions: near water, drain or ignition source If you have stopped and contained the spill The estimated quantity of spilled oil


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Attachment 2 – Universal Waste

Universal wastes are hazardous wastes that are generated in a wide variety of material that contain substances hazardous to human and environmental health. TYPES

There are four (4) categories of Universal Waste: • Lamps (i.e. Fluorescent lamps, High intensity lamps); • Batteries (non-Alkaline); • Pesticides; and • Mercury-containing equipment.

Universal Waste contains hazardous elements, and when broken, leaking, or spilled it becomes “HAZARDOUS” Material/Waste.

DISPOSAL and SEGREGATION

Lamps and Mercury-containing equipment MUST be stored in a container that is: • Closed; • Structurally sound; • Compatible with the contents; • Must lack evidence of leakage, spillage, or damage that could cause leakage; and • Must Label each the Box with the Contents and Dated (i.e., “Universal Waste Lamps”

or “Universal Waste – Mercury Containing Material”) Universal waste batteries that are in good condition and do not show evidence of leakage spillage or damage are not required to be stored in a container.

Note: Alkaline batteries are non-hazardous and can be recycled. Tape both ends of used batteries. Containers for recycling alkaline batteries are located in the Rad. Office and the Warehouse Annex. DISPOSAL LOCATIONS

Become familiar with the designated Universal Waste disposal location at the site:

o 592’ Elevation Level, South West side of Turbine Building (Column and Row F 34).

o Inside Warehouse Annex in the Designated Area. EMERGENCY SPILL RESPONSE The following are steps that need to be taken in the event of a release of any universal waste:

1) Remove yourself from the area and ensure other personnel cannot come in contact with the release.

2) Call ISFSI Shift Supervisor at (847) 379-2211. 3) Provide as much information as possible including but not limited to contents of

spill and scope of release. Any questions, contact the IS&H Department at 224-789-4067


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Attachment 3 – Restrictions to Pouring Liquids Down Drains

Just because a substance disappears when it goes down the drain doesn’t mean it is no longer impacting the environment. First, you must know exactly where the drain goes. Some site drains go to the North Shore Sanitary District (NSSD), others to our site Waste Water Treatment Facility (WWTF). Some site drainage feeds into the Oil Water Separators, which drains into Lake Michigan.

Pouring chemicals into site drainage is prohibited. When in doubt, don’t do it.

Excessive amounts of soap or high concentration of cleaning material may cause Foam production in the WWTF and create operational problems.

Q. How do I know what I can – and what I cannot – pour down the drain?

A. Ask your Supervisor and/or contact the Environmental Department to know what’s permissible.

If you have any questions, please contact the Environmental Department at 224-789-4072.


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Attachment 4 – Asbestos Technical Information

• Part Number: 1926 • Part Title: Safety and Health Regulations for Construction • Subpart: Z • Subpart Title: Toxic and Hazardous Substances • Standard Number: 1926.1101 App H • Title: Substance Technical Information for Asbestos – Non-Mandatory

5. Substance Identification

A. Substance: “Asbestos” is the name of a class of magnesium-silicate minerals that occur in fibrous form. Minerals that are included in this group are chrysotile, crocidolite, amosite, anthophyllite asbestos, tremolite asbestos, and actinolite asbestos.

B. Asbestos is and was used in the manufacture of heat-resistant clothing, automotive brake and clutch linings, and a variety of building materials including floor tiles, roofing felts, ceiling tiles, asbestos-cement pipe and sheet, and fire-resistant drywall. Asbestos is also present in pipe and boiler insulation materials and in sprayed-on materials located on beams, in crawlspaces, and between walls.

C. The potential for an asbestos-containing product to release breathable fibers depends largely on its degree of friability. Friable means that the material can be crumbled with hand pressure and is therefore likely to emit fibers. The fibrous fluffy sprayed-on materials used for fireproofing, insulation, or sound proofing are considered to be friable, and they readily release airborne fibers if disturbed. Materials such as vinyl-asbestos floor tile or roofing felt are considered non-friable if intact and generally do not emit airborne fibers unless subjected to sanding, sawing and other aggressive operations. Asbestos-cement pipe or sheet can emit airborne fibers if the materials are cut or sawed, or if they are broken.

D. Permissible exposure: Exposure to airborne asbestos fibers may not exceed 0.1 fibers per cubic centimeter of air (0.1 f/cc) averaged over the 8-hour workday, and 1 fiber per cubic centimeter of air (1.0 f/cc) averaged over a 30 minute work period.

II. Health Hazard Data

A. Asbestos can cause disabling respiratory disease and various types of cancers if the fibers are inhaled. Inhaling or ingesting fibers from contaminated clothing or skin can also result in these diseases. The symptoms of these diseases generally do not appear for 20 or more years after initial exposure.

B. Exposure to asbestos has been shown to cause lung cancer, mesothelioma, and cancer of the stomach and colon. Mesothelioma is a rare cancer of the thin membrane lining of the chest and abdomen. Symptoms of mesothelioma include shortness of breath, pain in the walls of the chest, and/or abdominal pain.

III. Respirators and Protective Clothing

A. Respirators: You are required to wear a respirator when performing tasks that result in


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asbestos exposure that exceeds the permissible exposure limit (PEL) of 0.1 f/cc and when performing certain designated operations. Air-purifying respirators equipped with a high-efficiency particulate air (HEPA) filter can be used where airborne asbestos fiber concentrations do not exceed 1.0 f/cc; otherwise, more protective respirators such as air-supplied, positive-pressure, full facepiece respirators must be used. Disposable respirators or dust masks are not permitted to be used for asbestos work. For effective protection, respirators must fit your face and head snugly. Your employer is required to conduct a fit test when you are first assigned a respirator and every 6 months thereafter. Respirators should not be loosened or removed in work situations where their use is required.

B. Protective Clothing: You are required to wear protective clothing in work areas where asbestos fiber concentrations exceed the permissible exposure limit (PEL) of 0.1 f/cc.

IV. Disposal Procedures and Clean-up

A. Wastes that are generated by processes where asbestos is present include:

1. Empty asbestos shipping containers.

2. Process wastes such as cuttings, trimmings, or reject materials.

3. Housekeeping waste from wet-sweeping or HEPA-vacuuming.

4. Asbestos fireproofing or insulating material that is removed from buildings.

5. Asbestos-containing building products removed during building renovation or demolition.

6. Contaminated disposable protective clothing.

B. Empty shipping bags can be flattened under exhaust hoods and packed into airtight containers for disposal. Empty shipping drums are difficult to clean and should be sealed.

C. Vacuum bags or disposable paper filters should not be cleaned, but should be sprayed with a fine water mist and placed into a labeled waste container.

D. Process waste and housekeeping waste should be wetted with water or a mixture of water and surfactant prior to packaging in disposable containers.

E. Asbestos-containing material that is removed from buildings must be disposed of in leak-tight 6-mil plastic bags, plastic-lined cardboard containers, or plastic-lined metal containers. These wastes, which are removed while wet, should be sealed in containers before they dry out to minimize the release of asbestos fibers during handling.

V. Access to Information

A. Each year, your employer is required to inform you of the information contained in this standard and appendices for asbestos. In addition, your employer must instruct you in the proper work practices for handling asbestos-containing materials, and the correct use of protective equipment.

B. Your employer is required to determine whether you are being exposed to asbestos. Your employer must treat exposure to thermal system insulation and sprayed-on and troweled-on


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surfacing material as asbestos exposure, unless results of laboratory analysis show that the material does not contain asbestos. You or your representative has the right to observe employee measurements and to record the results obtained. Your employer is required to inform you of your exposure, and, if you are exposed above the permissible exposure limit, he or she is required to inform you of the actions that are being taken to reduce your exposure to within the permissible limit.

C. Your employer is required to keep records of your exposures and medical examinations. These exposure records must be kept for at least thirty (30) years. Medical records must be kept for the period of your employment plus thirty (30) years.

D. Your employer is required to release your exposure and medical records to your physician or designated representative upon your written request.

[59 FR 40964, Aug. 10, 1994; 60 FR 33972, June 29, 1995]


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Attachment 5 – Substance Data Sheet for Occupational Exposure to Lead

• Part Number: 1926 • Part Title: Safety and Health Regulations for Construction • Subpart: D • Subpart Title: Occupational Health and Environmental Controls • Standard Number: 1926.62 App A • Title: Substance Data Sheet for Occupational Exposure to Lead

I. SUBSTANCE IDENTIFICATION

A. “Substance”: Pure lead (Pb) is a heavy metal at room temperature and pressure and is a basic chemical element. It can combine with various other substances to form numerous lead compounds.

B. “Compounds Covered by the Standard”: The word “lead” when used in this interim final standard means elemental lead, all inorganic lead compounds and a class of organic lead compounds called lead soaps. This standard does not apply to other organic lead compounds.

C. “Uses”: Exposure to lead occurs in several different occupations in the construction industry, including demolition or salvage of structures where lead or lead – containing materials are present; removal or encapsulation of lead – containing materials, new construction, alteration, repair, or renovation of structures that contain lead or materials containing lead; installation of products containing lead. In addition, there are construction related activities where exposure to lead may occur, including transportation, disposal, storage, or containment of lead or materials containing lead on construction sites, and maintenance operations associated with construction activities.

D. “Permissible Exposure”: The permissible exposure limit (PEL) set by the standard is 50 micrograms of lead per cubic meter of air (50 ug/m3), averaged over an 8-hour workday.

E. “Action Level”: The interim final standard establishes an action level of 30 micrograms of lead per cubic meter of air (30 ug/m (3)), averaged over an 8-hour workday. The action level triggers several ancillary provisions of the standard such as exposure monitoring, medical surveillance, and training.

II. HEALTH HAZARD DATA

A. “Ways in which lead enters your body”. When absorbed into your body in certain doses, lead is a toxic substance. The object of the lead standard is to prevent absorption of harmful quantities of lead. The standard is intended to protect you not only from the immediate toxic effects of lead, but also from the serious toxic effects that may not become apparent until years of exposure have passed. Lead can be absorbed into your body by inhalation (breathing) and ingestion (eating). Lead (except for certain organic lead compounds not covered by the standard, such as tetraethyl lead) is not absorbed through your skin. When lead is scattered in the air as a dust, fume, or mist it can be inhaled and absorbed through you lungs and upper respiratory tract. Inhalation of airborne lead is generally the most important source of occupational lead absorption. You can also absorb lead through your digestive system if lead gets into your mouth and is swallowed. If you handle food, cigarettes, chewing tobacco, or make-up which have lead on them or handle them with hands


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contaminated with lead, this will contribute to ingestion. A significant portion of the lead that you inhale or ingest gets into your blood stream. Once in your blood stream, lead is circulated throughout your body and stored in various organs and body tissues. Some of this lead is quickly filtered out of your body and excreted, but some remains in the blood and other tissues. As exposure to lead continues, the amount stored in your body will increase if you are absorbing more lead than your body is excreting. Even though you may not be aware of any immediate symptoms of disease, this lead stored in your tissues can be slowly causing irreversible damage, first to individual cells, then to your organs and whole body systems.

B. “Effects of overexposure to lead” – (1) “Short term (acute) overexposure”. Lead is a potent, systemic poison that serves no known useful function once absorbed by your body. Taken in large enough doses, lead can kill you in a matter of days. A condition affecting the brain called acute encephalopathy may arise which develops quickly to seizures, coma, and death from cardiorespiratory arrest. A short term dose of lead can lead to acute encephalopathy. Short term occupational exposures of this magnitude are highly unusual, but not impossible. Similar forms of encephalopathy may, however, arise from extended, chronic exposure to lower doses of lead. There is no sharp dividing line between rapidly developing acute effects of lead, and chronic effects which take longer to acquire. Lead adversely affects numerous body systems, and causes forms of health impairment and disease which arise after periods of exposure as short as days or as long as several years.

(2) “Long-term (chronic) overexposure”. Chronic overexposure to lead may result in severe damage to your blood – forming, nervous, urinary and reproductive systems. Some common symptoms of chronic overexposure include loss of appetite, metallic taste in the mouth, anxiety, constipation, nausea, pallor, excessive tiredness, weakness, insomnia, headache, nervous irritability, muscle and joint pain or soreness, fine tremors, numbness, dizziness, hyperactivity and colic. In lead colic there may be severe abdominal pain. Damage to the central nervous system in general and the brain (encephalopathy) in particular is one of the most severe forms of lead poisoning. The most severe, often fatal, form of encephalopathy may be preceded by vomiting, a feeling of dullness progressing to drowsiness and stupor, poor memory, restlessness, irritability, tremor, and convulsions. It may arise suddenly with the onset of seizures, followed by coma, and death. There is a tendency for muscular weakness to develop at the same time. This weakness may progress to paralysis often observed as a characteristic “wrist drop” or “foot drop” and is a manifestation of a disease to the nervous system called peripheral neuropathy. Chronic overexposure to lead also results in kidney disease with few, if any, symptoms appearing until extensive and most likely permanent kidney damage has occurred. Routine laboratory tests reveal the presence of this kidney disease only after about two-thirds of kidney function is lost. When overt symptoms of urinary dysfunction arise, it is often too late to correct or prevent worsening conditions, and progression to kidney dialysis or death is possible. Chronic overexposure to lead impairs the reproductive systems of both men and women. Overexposure to lead may result in decreased sex drive, impotence and sterility in men. Lead can alter the structure of sperm cells raising the risk of birth defects. There is evidence of miscarriage and stillbirth in women whose husbands were exposed to lead or who were exposed to lead themselves. Lead exposure also may result in decreased fertility, and abnormal menstrual cycles in women. The course of pregnancy may be adversely affected by exposure to lead since lead crosses the placental barrier and poses risks to developing fetuses. Children born of parents either one of whom were exposed to excess lead levels are more likely to have birth defects, mental retardation,


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behavioral disorders or die during the first year of childhood. Overexposure to lead also disrupts the blood – forming system resulting in decreased hemoglobin (the substance in the blood that carries oxygen to the cells) and ultimately anemia. Anemia is characterized by weakness, pallor and fatigability as a result of decreased oxygen carrying capacity in the blood.

(3) “Health protection goals of the standard”. Prevention of adverse health effects for most workers from exposure to lead throughout a working lifetime requires that a worker’s blood lead level (BLL, also expressed as PbB) be maintained at or below forty micrograms per deciliter of whole blood (40 ug/dl). The blood lead levels of workers (both male and female workers) who intend to have children should be maintained below 30 ug/dl to minimize adverse reproductive health effects to the parents and to the developing fetus. The measurement of your blood lead level (BLL) is the most useful indicator of the amount of lead being absorbed by your body. Blood lead levels are most often reported in units of milligrams (mg) or micrograms (ug) of lead (1 mg=1000 ug) per 100 grams (100g), 100 milliliters (100 ml) or deciliter (dl) of blood. These three units are essentially the same. Sometime BLLs are expressed in the form of mg percent or ug percent. This is a shorthand notation for 100g, 100 ml, or dl. (References to BLL measurements in this standard are expressed in the form of ug/dl.)

BLL measurements show the amount of lead circulating in your blood stream, but do not give any information about the amount of lead stored in your various tissues. BLL measurements merely show current absorption of lead, not the effect that lead is having on your body or the effects that past lead exposure may have already caused. Past research into lead – related diseases, however, has focused heavily on associations between BLLs and various diseases. As a result, your BLL is an important indicator of the likelihood that you will gradually acquire a lead – related health impairment or disease.

Once your blood lead level climbs above 40 ug/dl, your risk of disease increases. There is a wide variability of individual response to lead, thus it is difficult to say that a particular BLL in a given person will cause a particular effect. Studies have associated fatal encephalopathy with BLLs as low as 150 ug/dl. Other studies have shown other forms of diseases in some workers with BLLs well below 80 ug/dl. Your BLL is a crucial indicator of the risks to your health, but one other factor is also extremely important. This factor is the length of time you have had elevated BLLs. The longer you have an elevated BLL, the greater the risk that large quantities of lead are being gradually stored in your organs and tissues (body burden). The greater your overall body burden, the greater the chances of substantial permanent damage. The best way to prevent all forms of lead – related impairments and diseases – both short term and long term – is to maintain your BLL below 40 ug/dl. The provisions of the standard are designed with this end in mind.

Your employer has prime responsibility to assure that the provisions of the standard are complied with both by the company and by individual workers. You, as a worker, however, also have a responsibility to assist your employer in complying with the standard. You can play a key role in protecting your own health by learning about the lead hazards and their control, learning what the standard requires, following the standard where it governs your own actions, and seeing that your employer complies with provisions governing his or her actions.

(4) “Reporting signs and symptoms of health problems”. You should immediately notify your employer if you develop signs or symptoms associated with lead poisoning or if you desire medical advice concerning the effects of current or past exposure to lead or your ability to have a healthy


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child. You should also notify your employer if you have difficulty breathing during a respirator fit test or while wearing a respirator. In each of these cases, your employer must make available to you appropriate medical examinations or consultations. These must be provided at no cost to you and at a reasonable time and place. The standard contains a procedure whereby you can obtain a second opinion by a physician of your choice if your employer selected the initial physician.

[57 FR 26627, May 4, 1993, as amended at 58 FR 34218, June 24, 1993]


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Attachment 6 – Background Information on Silica

OSHA Instruction CPL 03-00-007 National Emphasis Program – Crystalline Silica

Appendix A: Background Information on Silica

This appendix provides an overview of the following silica-related topics: the forms and sources of silica; common industrial uses of silica and workplaces with silica exposure; history of silicosis; and health effects associated with exposure. The reference list at the end of this appendix, as well as the expanded bibliography in Appendix J, provide many sources that may prove useful to those interested in a more in-depth treatment of these topics.

Introduction “Silica,” is a term which refers broadly to the mineral compound silicon dioxide (SiO2). Silica can be crystalline or amorphous. Crystalline silica is significantly more hazardous to employees than amorphous silica. In addition to causing the disabling and irreversible lung disease known as silicosis, crystalline silica has been classified as a human carcinogen by the International Agency for Research on Cancer (IARC) [IARC, 1997]. As it is typically used in this document, silica” refers specifically to crystalline silica. Crystalline silica is characterized by a large scale, repeating pattern of silicon and oxygen atoms, as distinguished from the more random arrangement found in amorphous silica. Abundant in the earth’s crust, crystalline silica is a basic component of most classes of rock. Naturally-occurring forms of amorphous silica include diatomaceous earth (the skeletal remains of marine organisms) and vitreous silica or volcanic glass [Markowitz and Rosner, 1995; Davis, 1996].

Forms and Sources of Crystalline Silica Crystalline silica occurs in three primary mineralogical forms, or polymorphs–quartz, cristobalite, and tridymite. Silica is also called “free silica,” to distinguish it from the silicates, which are minerals containing silicon dioxide bound to one or more cations [Beckett et al., 1997]. Quartz is by far the most common form of naturally-occurring silica [Davis, 1996; IARC, 1997]. Cristobalite and tridymite, which are molecularly identical to quartz, are distinguishable by their unique crystalline structures. They are less stable than quartz, thus accounting for the dominance of the quartz form. Quartz itself exists as either of two sub-polymorphs, alpha-quartz (also known as low quartz), and beta-quartz (high quartz). Alpha-quartz is the thermodynamically stable form of crystalline silica and accounts for the overwhelming portion of naturally-occurring crystalline silica [IARC, 1997]. Quartz is a major component of soils and is readily found in both sedimentary and igneous rocks, although the quartz content varies greatly from one rock type to another. For instance, granite contains on average about 30 percent quartz, and shales contain about 20 percent quartz. Natural stone, such as beach sand or sandstone, may be nearly pure quartz [IARC, 1997; Davis, 1996].


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Cristobalite and tridymite are natural constituents of some volcanic rock, and man-made forms result from direct conversion of quartz or amorphous silica that has been subjected to high temperature or pressure. Diatomaceous earth, composed of amorphous silica, crystallizes during heating (calcining), yielding a calcined product that contains as much as 75 percent cristobalite. Cristobalite is also found in the superficial layers of refractory brick that has been repeatedly subjected to contact with molten metal [Markowitz and Rosner, 1995; Ganter, 1986; Cheng et al., 1992; Bergen et al., 1994].

Major Industrial Sources of Crystalline Silica Exposure Crystalline silica is an important industrial material and occupational exposure occurs across a broad range of industries, including mining, manufacturing, construction, maritime, and agriculture (see Appendix B for a listing of industries and Standard Industrial Classifications with potential for significant occupational exposure). Processes associated historically with high rates of silicosis include sandblasting, sand-casting foundry operations, mining, tunneling, and granite cutting. Crystalline silica, in the form of finely ground quartz sand as an abrasive blasting agent, is used to remove surface coatings prior to repainting or treating, a process that typically generates extremely high levels of airborne respirable crystalline silica. A 1992 report published by the National Institute for Occupational Safety and Health (NIOSH) estimates that there are more than one million U.S. employees who are at risk for developing silicosis, and of these employees, more than 100,000 are employed as sandblasters. Abrasive blasting is performed in a wide variety of different industries; the construction industry employs the largest number of employees as abrasive blasters, concentrated in the special trades [NIOSH 92-102; CDC, 1997]. In addition to abrasive blasting, construction employees perform numerous other activities that may result in significant silica exposure, including tunnel and road construction, excavation and earth moving, masonry and concrete work, and demolition [IARC, 1997]. Foundry employees, primarily in iron and steel foundries, may be exposed to crystalline silica throughout the metal casting process, including the production of sand-based molds and cores, shakeout and knockout, and finishing and grinding operations. Crystalline silica, primarily as quartz, is a major component of the sand, clay, and stone raw materials used to manufacture a variety of products, including concrete, brick, tile, porcelain, pottery, glass, and abrasives. The powdered form of quartz, also called silica flour, is used in the manufacture of fine china and porcelain. Finely ground crystalline silica is also used as a functional filler in the manufacture of paints, plastics, and other materials. The rock crystal form of quartz is of great value to the electronics industry. Agricultural employees perform activities, including plowing and harvesting, that may generate elevated silica levels. However, OSHA does not regulate crystalline silica exposure on farms with fewer than ten employees and exposure data for this population is lacking [Linch et al., 1998]. On the other hand, OSHA does regulate crystalline silica exposure in the agricultural services sector, and crystalline silica exposures have been documented in the sorting, grading, and washing areas of food processing operations for crops such as potatoes and beans.


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Cristobalite, as calcined diatomaceous earth, is used as a filler in materials such as paints and as a filtering media in food and beverage processing. Maintenance and trades personnel who repair and replace refractory brick linings of rotary kilns and cupola furnaces may be exposed to significant levels of quartz, as well as cristobalite and tridymite. These kilns and furnaces are found in glass, ceramics, and paper manufacturing facilities as well as foundries [Markowitz and Rosner, 1995]. The industries described above, (see Appendix B) represent the major industrial sources of crystalline silica exposure. However, there are numerous other operations in which silica may be used or otherwise encountered, and it is important to be aware of the risk of silicosis in industries not previously recognized to be at risk.

History of Silicosis Silicosis is one of the world’s oldest known occupational diseases; reports of employees with the disease date back to ancient Greece. By 1800, there were numerous common names for the lung disease now known as silicosis. The names frequently referred to the affected laborers’ trade, such as grinders’ asthma, grinders’ rot, masons’ disease, miners’ asthma, miners’ phthisis, potters’ rot, sewer disease, and stonemasons’ disease. Despite its different names through the centuries, silicosis is a single disease with a single cause–exposure to respirable crystalline silica dust. During the 1920s, the health risks of the “dusty” trades, in particular the granite industry, emerged as a significant public health concern, and by 1930 silicosis was considered the most serious occupational disease in the United States. During the 1930s and 1940s, the granite industry was the focus of a major effort to alleviate dusty conditions and create a safer working environment [Rosner and Markowitz, 1994]. However, as the more extreme silica hazards were brought under control, attention shifted away from silica to other occupational health hazards. Nonetheless, as the studies described below indicate, in recent decades silicosis has continued to pose a significant health threat to employees in a variety of occupations, including but not limited to construction, foundries, and sandblasting. It is important to be aware of the possible risk of silicosis in workplaces not previously recognized to be at risk.

Silicosis was listed as the underlying cause of death in 6,322 fatalities in the United States from 1968 through 1990, according to a study reviewing multiple-cause-of-death data from the National Center for Health Statistics. The total number of U.S. deaths with mention of silicosis for that period was 13,744. The study found that 69 percent of the deaths due to silicosis were concentrated in 12 states: California, Colorado, Florida, Illinois, Michigan, New Jersey, New York, Ohio, Pennsylvania, Virginia, West Virginia, and Wisconsin. The construction industry accounted for more than 10 percent of the total silicosis-related deaths, and iron and steel foundries accounted for another 5.4 percent [Bang et al., 1995].

Death certificates for approximately 868 men and 46 women listed silicosis as the underlying

cause of death in non-mining occupations, according to a study that reviewed death certificates for the period 1985 to 1992. The researchers focused on death certificates that provided an entry for indicating the potential for substantial silica exposure, reviewing a total of 411,404 death certificates for men and 30,563 for women [Walsh, 1999].


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A ten-year study (1985 to 1995) of Michigan employees found that nearly 80 percent of the

577 confirmed cases of silicosis occurred in industries in the Standard Industrial Classification (SIC) 3300, Primary Metals, which encompasses iron and steel foundries [Rosenman et al., 1997]. In another study, foundry employees whose lungs exhibited radiographic changes consistent with silicosis were concentrated in four primary job assignments: core making, mold making, core knockout, and cleaning/finishing. The study was conducted at a Midwestern gray iron foundry that has produced automotive engine blocks since 1949; the researchers analyzed medical records and silica exposure data for 1,072 current and retired employees with at least five years of employment as of June 1991. Radiographic readings consistent with silicosis were also correlated with the number of years at the foundry, smoking habits, and silica exposure levels [Rosenman et al., 1996].

In the mid-1990s, there were two cases of accelerated silicosis in relatively young

sandblasters following short periods of extremely high crystalline silica exposures. In 1995, a 36-year-old man who had sandblasted oil field tanks in Western Texas for 36 months died from respiratory failure, eleven years after his initial exposure to crystalline silica. A second sandblaster at the same facility, a 30-year-old man who had worked as a sandblaster from 1986 to 1990, died in 1996, ten years after his initial exposure [CDC, 1998]. Both of these sandblasters died from progressive massive fibrosis, an advanced stage of silicosis.

Adverse Health Effects of Crystalline Silica Exposure Pulmonary silicosis has historically been the disease most well-known as being caused by the inhalation of respirable crystalline silica particles. Additionally, there is evidence that exposure to crystalline silica-containing dusts causes or is associated with the following conditions: lung cancer, tuberculosis, chronic obstructive pulmonary disease (including emphysema and bronchitis), autoimmune diseases or immunologic disorders, chronic renal disease, and subclinical renal changes [NIOSH, 2002].

Silicosis Silicosis is a fibrotic disease of the lungs caused by the inhalation of crystalline silica dust. It is a type of pneumoconiosis, which is a general term for chronic lung disease that occurs when certain particles are inhaled and deposited deep in the lung. There are two main types of silicosis, chronic silicosis (also called “classical” or “nodular” silicosis) and acute silicosis, medically referred to as silico-proteinosis or alveolar lipoproteinosis-like silicosis. Chronic silicosis, by far the most common form of the occupational disease, typically appears 20 to 40 years after initial exposure and tends to progress even after exposure ceases. Accelerated silicosis is a variant of chronic silicosis but develops after more intense exposure to crystalline silica; it is characterized by earlier onset (within 5 to 15 years of initial exposure) and more rapid progression of disease than chronic silicosis [Weill et al., 1994].


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Acute silicosis results from an overwhelming exposure to silica and the symptoms become manifest in as little time as a few weeks after exposure. Acute silicosis appears to be distinct from the other forms of silicosis, possibly involving an immune mechanism not associated with either accelerated or chronic silicosis. This disease, though rare, is invariably fatal. Outbreaks of acute silicosis have occurred among sandblasters and silica flour mill employees [Peters, 1986]. The development of silicosis is dependent on the size of the crystalline silica dust particle, the dust concentration, and the duration of exposure. Crystalline silica particles smaller than 10 micrometers (m) in diameter, so-called respirable particles, are particularly hazardous, because they easily pass through the tracheobronchial tree and are deposited in the deepest recesses of the lungs, the alveolar structures. Particles larger than 10 m in diameter are trapped in the nose or the mucous lining of the airway and are removed by the mucociliary escalator. Chronic silicosis has an early manifestation of a dry or non-productive cough when there is continued exposure to the inhaled irritant. The cough then becomes prolonged and distressing, with sputum production as the disease advances. Initially, breathlessness occurs while exercising, but progresses to shortness of breath during normal activity [Porth, 1994]. Wheezing typically only occurs when conditions such as chronic obstructive bronchitis or asthma are also present. Advanced states of silicosis include pneumothorax and respiratory failure. Respiratory symptoms increase with the progression of silicosis [Wang, 1999]. A rapid increase in the rate of synthesis and deposition of lung collagen has also been seen with the inhalation of crystalline silica particles. The collagen formed is unique to silica-induced lung disease and is biochemically different from normal lung collagen [Olishifski and Plog, 1988]. Silicosis in all its forms is incurable and causes significant impairment or death. Therefore, eliminating or controlling occupational exposure to respirable crystalline silica is critical to prevention of the disease.

Lung Cancer The International Agency for Research on Cancer [IARC, 1997] classifies crystalline silica inhaled in the form of quartz or cristobalite from occupational source as “carcinogenic to humans (Group 1).” However, in making the overall evaluation, the IARC Working Group noted “that carcinogenicity in humans was not detected in all industrial circumstances studied.” The Working Group also stated: “Carcinogenicity may be dependent on inherent characteristics of the crystalline silica or on external factors affecting its biological activity or distribution of its polymorphs.” The IARC analysis included studies of U.S. gold miners, Danish stone industry employees, U.S. granite shed and quarry employees, U.S. crushed stone industry employees, U.S. diatomaceous earth employees, Chinese refractory brick makers, Italian refractory brick makers, U.K. pottery makers, Chinese pottery makers and cohorts of registered silicotics from North Carolina and Finland. Most of these studies found a statistically significant association between occupational exposure to crystalline silica and lung cancer.


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Tuberculosis Epidemiologic studies have firmly established the association between TB and silicosis. Some studies have indicated that employees who do not have silicosis but who have had long exposures to silica dust may also be at increased risk of developing TB [NIOSH, 2002]. Individuals with chronic silicosis are more susceptible to developing active tuberculosis than the general population. However, it is not clear whether low-level exposure to silica, in cases where silicosis has not developed, also predisposes employees to tuberculosis [Davis, 1996].

Chronic Obstructive Pulmonary Disorder Epidemiologic studies have shown that occupational exposure to respirable crystalline silica is associated with chronic obstructive pulmonary disease, including bronchitis and emphysema. The findings from some of these studies suggest that emphysema and bronchitis may occur less frequently or not all in nonsmokers. Epidemiologic studies have also found significant increases in mortality from nonmalignant respiratory disease, a category that includes silicosis, emphysema, and bronchitis, as well as some other related pulmonary diseases [NIOSH, 2002].

Immunologic Disorders and Autoimmune Diseases Several epidemiologic studies have found statistically significant increases in mortality from or cases of immunologic disorders and autoimmune diseases in employees exposed to silica. These disorders and diseases include scleroderma (a rare multisystem disorder characterized by inflammatory, vascular, and fibrotic changes usually involving the skin, blood vessels, joints, and skeletal muscle), rheumatoid arthritis, systemic lupus erythematosus (lupus), and sarcoidosis (a rare multisystem granulomatous disease characterized by alterations in the immune system) [NIOSH, 2002].

Renal Disease Epidemiological studies report statistically significant associations between occupational exposure to silica dust and several renal diseases or effects, including end-stage renal disease morbidity (including that caused by glomerular nephritis, chronic renal disease mortality, and Wegener’s granulomatosis (systemic vasculitis often accompanied by glomerulonephritis) [NIOSH, 2002].

Stomach and Other Cancers There is some evidence from studies of various occupational groups exposed to crystalline silica of statistically significant excesses of mortality from stomach or gastric cancer. However, most of these studies did not adjust for confounding factors and possible exposure-response relationships were not assessed. Similar issues with confounding and lack of exposure-response assessment exist for the infrequent reports of statistically significant numbers of excess deaths or cases in silica-exposed employees of other nonlung cancers such as nasopharygeal or pharyngeal, salivary gland, liver, bone, pancreatic, skin, esophageal, digestive system, intestinal or peritoneal, lymphopoietic or hematopoietic, brain, and bladder [NIOSH, 2002].

Summary As these health findings indicate, crystalline silica exposure is associated with a number of diseases, in addition to silicosis. Silica exposure continues to pose substantial risks to employees, centuries after it was first identified as an occupational hazard. The only way to prevent disease is to eliminate exposure to crystalline silica or reduce crystalline silica exposure to safe levels.


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Attachment 7 – ZionSolutions Refractory Ceramic Fiber Information Sheet

Refractory ceramic fibers (RCF) are used as insulating materials and flame retardants because of their ability to withstand high temperatures. They come in the form of blankets, boards, felts, bulk fibers, vacuum-formed or cast shapes, paper, and textiles. (See picture below.) One of the RCF-containing products that is present here at Zion Station is Cerafiber®. Other trade names for RCF-containing products include Ultrafelt, Pyro-Blanket, Cerablanket, Cer-Wool, and Kaowool RT, among others. Products that contain RCFs can release those fibers into the environment when they are pulled apart,

stuffed into pipe or cable chases, pulled back out of those areas, or otherwise disturbed. Some of the fibers are small enough to be inhaled deeply into the lungs. Refractory ceramic fibers have been identified by a number of organizations worldwide as possibly causing cancer. These concerns are based on animal exposure studies, including inhalation studies. RCFs are classified as “suspected carcinogens” because there is evidence available from animal studies, but there is not adequate data from human

experience to confirm that the material causes cancer in people. Because of these health concerns, the American Conference of Governmental Industrial Hygienists (ACGIH) has recommended an exposure limit (Threshold Limit Value, or TLV) of 0.2 fibers per cubic centimeter of air (f/cc) as an 8-hour time-weighted average (TWA). This is similar to the TLV and OSHA limit for asbestos, which is 0.1 f/cc. As a safety precaution, at Zion Station, we will avoid the use of RCFs wherever possible. If we find that we must use these products, we will do so using protective measures, such as the use of local exhaust ventilation, protective clothing, and respiratory protection to minimize exposures. When we need to remove these materials, we will specify the Engineering Controls, PPE, and training requirements to perform this work in a safe manner in the approved Work Package.


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Attachment 8 – Guidance for Stuck Vehicles

1. Know the size and weight of the stuck vehicle so the proper extraction rigging can be chosen. This includes the weight of vehicle, payload, and mire resistance (how deep in the muck the vehicle is stuck)

A. Wheel Depth – Equal to the weight of the vehicle, plus cargo

B. Fender Depth – Equal to twice the total weight of the vehicle, plus cargo.

C. Cab depth – Equal to three times the total weight of the vehicle, plus cargo.

2. Ensure the towing vehicle is large enough by reviewing owner’s manuals or consulting with engineering to safely extract the stuck vehicle.

3. Make certain your chains, cables, straps, or ropes are rated to exceed the weight they will pull and are in good condition.

4. Keep the tailpipe of the vehicles uncovered.

5. Keep a fire extinguisher nearby as a bottomed out vehicle can start dry materials on fire.

6. Disconnect trailers and unload to reduce weight if warranted. Dig around the tires if necessary.

7. Get the towing vehicle as close as possible.

8. Position the towing vehicle on higher ground when possible.

9. Try to make only two attachments points; avoid hooking multiple chains, straps, or ropes together.

10. Make sure the attachment point will hold under pressure; do not hook to a bumper

11. If using nylon straps, use softeners if straps are around sharp edges.

12. Hook from the bottom of the attachment point.

13. When using shackles, strap should pull on shackle pin. Do not pull from side of shackle.

14. Protect windshields in the event something snaps and there is flying debris.

15. Personnel shall stay out of the line fire. Personnel shall be a minimum 100 feet back when extraction is in progress.

16. Get the stuck vehicle to help.

17. Make sure everyone understands the signals (especially STOP) and how far towing vehicle will pull once vehicle is out from being stuck.

18. Use the lowest gear available.

19. Pull straight ahead to maximize towing power.


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Attachment 9 – Radiation Protection / Radiation Safety

RP Contact numbers

224-789-4190 or 5-4190

Or security at

224-789-4203 or 5-4241

Definitions

2. Radiological controlled area – Any area to which access is controlled and posted because of the presence of radiation or radioactive materials. Radiologically Controlled Areas include areas where licensed Radioactive Materials may be present, Contaminated Areas, Radiation Areas, High Radiation Areas, Locked High Radiation Areas, Very High Radiation Areas, and Airborne Radioactivity Areas. The term communicates the potential for radioactive material to be present, not a specific radiological posting.

3. All RCAs require dosimetry for entry. Personnel exit monitoring is required for handling of exposed radioactive material not in a sealed strong tight container or entry into rooms or containers where radioactive contamination may be present.

4. Radiation – energy in the form of particles or waves emitted from an unstable atom.

5. Radioactive material – any material that is made up of unstable atoms which are emitting radiation, which is contained in a desired location

6. Radioactive contamination – any material that is made up of unstable atoms (emitting radiation) in a location that it is not desired.

7. Dose/dose rate – measurement of amount/rate of radiation a person is exposed to.

8. Rem/MilliRem – unit of measure of dose

9. TEDE – Total Effective Dose Equivalent – sum of internal and external dose.

a. External Dose/Internal Dose – internal hazard indicates it is a hazard if the decaying atom is inside the body. An external hazard is if the decaying atom is outside the body.

Calculating Total Dose

1. Dose rate X time in area = total dose

2. If a person spent 4 hours in an area of with a dose rate of 15 mRem/hour, what is their total dose?

15 mRem/hour X 4 hours = 60 mRem


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Federal Dose limits

1. 5 Rem/year – Total Effective Dose Equivalent (TEDE) – (Sum of the internal dose and external dose)

2. 15 Rem/year – Lens Dose Equivalent (LDE) dose to the lens of the eye.

3. 50 Rem/year – Shallow Dose Equivalent (SDE) external exposure of the skin or extremities (elbows, lower arms, wrists, hands, knees, lower legs, ankles, and feet).

4. 50 Rem/year – Total Organ Dose Equivalent (TODE) the sum of the external exposure and internal exposure to the organ receiving the highest dose.

Zion Station Administrative limits

1. 2 Rem/year – Total Effective Dose Equivalent (TEDE)

2. 3 Rem/year – Lens Dose Equivalent (LDE) dose to the lens of the eye.

3. 10 Rem/year – Shallow Dose Equivalent (SDE) external exposure of the skin or extremities (elbows, lower arms, wrists, hands, knees, lower legs, ankles, and feet).

4. 10 Rem/year – Total Organ Dose Equivalent (TODE) the sum of the external exposure and internal exposure to the organ receiving the highest dose.

5. Contact your supervisor if you are approaching an administrative limit.

Pre-Natal Radiation Exposure Limit – VOLUNTARY DECLARATION

1. FEDERAL LIMITS

a) 500 mRem for the entire Gestation Period

b) 50 mRem uniform monthly exposure

2. ZION ADMINISTRATIVE LIMITS

a) 100 mRem for the entire Gestation Period

b) 10 mRem uniform monthly exposure

Stay Time – Used to ensure that you do not exceed a dose limit.

Dosimetry – Determines the amount of external dose received by the worker and is used to document your Occupational Exposure History. You are required to wear a TLD and ED whenever you are in a Radiological Controlled Area.


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Thermoluminescent Dosimeter (TLD) - TLDs detect gamma, beta and may be set up to detect neutron radiation. TLD’s are obtained through the Dosimetry Section of the Radiation Protection Department when processing in to the plant and must be returned to Dosimetry upon termination.

You may bring your TLD home however you must observe the following to ensure your TLD is only indicating your occupational dose (dose you receive from this nuclear site):

1. Do not send your TLD through any x-ray machine. (airport, dentist etc.) 2. Do not wear your TLD if you have been given medical treatment involving any radioactive

isotope (contact RP). 3. Do not leave your TLD on your dashboard in direct sunlight. 4. Do not bring your TLD on an airplane 5. Do not bring your TLD to other nuclear sites. 6. Do not disassemble your TLD. If it is damaged, turn it in to Dosimetry. 7. Ensure you turn in your TLD quarterly as directed by RP for processing. 8. Ensure you are properly wearing your TLD when you enter radiologically

controlled areas.

Electronic Dosimeter (ED) The ED detects gamma radiation, is worn in close proximity to TLD and provides a real-time estimate of dose received.

Wearing your dosimetry – Dosimeters will normally be worn on the front of the body in the chest area. Based on the location of the highest dose rate, Radiation Protection or the RWP may require relocation of your TLD or additional dosimetry. Read your ED frequently while in a radiological controlled area by looking at the digital readout. Obtaining a ED/TLD – TLDs are issued through Dosimetry (part of Radiation Protection). You must complete this training prior to being issued a TLD. Eds are obtained at the RP access point. You will need to log into a RWP when you pick up your ED.

Radiological Postings – Radiological postings are signs, ropes, tape and tags that have a yellow background and a Magenta (purplish-pink) letters and symbols. A three blade Tri-foil is often used on these to communicate a non-verbal warning that radioactive material is present. Never enter areas marked with these unless you have received Radiation Worker Training, have the proper dosimetry and have consulted with RP personnel to inform them of your need to enter the area. Never move, remove or alter the position of any radiological posting without the assistance of RP.

1. Radiation Area – An area where dose rates are 5 mRem/hour to 100 mRem/hour

2. High Radiation Area – An area where dose rates are greater than 100 mRem/hour


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3. Radiological Rope – Yellow and Magenta rope used to barricade some radiological areas

4. Swing Gate – A spring loaded radiological barrier used to denote the entry into a high radiation area. Personnel may pass through a swing gate without an RP present as long as they are on the correct RWP and Task, have the proper PPE, dosimetry and have received a specific High Radiation Area briefing from RP. Personnel are responsible for ensuring that the swing gate is returned to its proper position after they pass through the gate.

Radiation Work Permit (RWP) – A RWP is required for working in an RCA or with packages greater than 5 mRem/hour on contact. A general RWP is used for routine tasks. It is used for repetitive tasks with a relatively low radiological risk. A specific RWP is used for a specific task. It is used for a single task which may have elevated radiological risk.

An RWP contains the following information:

1. RWP Number

2. General Description

3. Description Of Work

4. Radiological Conditions

5. Anti-Contamination Clothes Requirements

6. Dosimetry Requirements

7. Briefing Requirements

8. Training Requirements

9. Work Steps

10. Special Instructions

You must read and sign the proper radiation work permit for your work prior to entering a RCA. When you sign the RWP you are verifying that you have read the RWP, understand it and agree to comply with the requirements and limitations specified in the RWP. Internal Radiation Exposure - Radioactive material that has entered the body. Internal radiation exposure contributes to your TEDE.

There are four primary methods that allow radioactive material to enter the body.

1. Inhalation – breathing it in


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2. Ingestion – eating, drinking, chewing or swallowing 3. Absorption – absorbing it through the skin 4. Open wounds – entering through an open wound or sore. Make sure all wounds are identified to

RP prior to entering RCA.

Methods to limit internal deposition of radioactive materials: 1. No eating, drinking, smoking or chewing within the RCA unless specifically allowed by RP. 2. Engineering and workplace controls should be the primary mechanisms for maintaining internal

radiation doses to workers as low as reasonably achievable (ALARA).

There are three primary ways to determine the amount of internal radioactivity:

1. Whole Body Count

2. Bioassays

3. Whole Body Screen/Passive Monitoring

The mouth and nose are the most common pathways for the intake of radioactive material.

Potential airborne radioactivity hazards in the RCA that can increase the amount of airborne radioactivity and your potential internal exposure are:

1. Brushing or sweeping

2. Fans blowing in dusty areas

3. Sanding, grinding, or welding on a contaminated pipe

4. A wet contaminated area that is drying out

5. Breaching contaminated systems

Methods for Preventing the Spread of Contamination:

1. Plan the job

2. Use protective clothing

3. Use the nearest contamination monitor

4. Avoid water

5. Secure hoses or cords

6. Use containments or absorbent material

7. Use step-off-pads and warning signs

Exit a Contaminated Area if:

1. Cut or torn Protective Clothing

2. Cuts, abrasions, open wound

3. Protective Clothing wet

4. Directed to leave by RP

5. Lost or damaged dosimetry

6. Alarm


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Worker Rights and Responsibilities

1. Adhere to instructions provided by RP personnel (including stop work orders), written policies and procedures, radiation work permits, and posted warnings, signs, and labels.

2. If your work scope or location changes notify RP Prior to starting the work.

3. Maintain awareness of your current accumulated dose for the job, day, and for the year.

4. Keep your accumulated dose within federal limits and obtain all required approvals prior to exceeding site administrative exposure control levels.

5. Maintain your accumulated dose ALARA.

6. Identify the actions and reporting responsibilities when abnormal radiological conditions and/or violations of radiological requirements are encountered.

7. Request and review your radiation dose records.

8. Notify RP prior to receiving nuclear medicine testing. RP may take away your TLD, RCA access may be restricted, and RP may give you a pass to exit the station when the Portal Monitor alarms.


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Attachment 10 – Unconditional Release Surveys / Final Status Surveys

Formal surveys performed on Secondary Side structures or structures inside of the Radiologically Restricted Area. These surveys include the structure interior and exterior surfaces and materials/equipment (M&E) to verify contamination levels are “not detectable” or indistinguishable from background.

Surveys are performed by the Site Characterization/License Termination Group PRIOR TO DEMOLITION.

Demolition debris is “Clean” waste which may be disposed of:

As Beneficial Reuse of concrete (staged in South Parking),

Salvage or recycle of M&E, and/or

To a Landfill Formal Isolation and Control Measures are utilized to control access to specific areas or structures as soon as possible following completion of pre-demolition activities.

It is absolutely essential that access be controlled at the time of and following the Unconditional Release Survey up to the start of actual demolition. Isolation and Control Postings

Obtain authorization from SC/LT (Site Characterization / License Termination) Supervision PRIOR to entering a posted area

Obtain approval from the SC/LT Manager, or designated alternate for exception to these controls in non-emergency situations (e.g. routine inspections).

NOTICE

AN UNCONDITIONAL RELEASE SURVEY

IS IN PROGRESS OR HAS BEEN COMPLETED IN THIS AREA

NO

DECOMMISSIONING/DEMOLITION ACTIVITIES ARE TO BE

PERFORMED IN THIS AREA WITHOUT

PRIOR APPROVAL

THE USE, MOVEMENT OR STORAGE

OF RADIOACTIVE MATERIAL IS PROHIBITED IN THIS AREA

ENTRY OF PERSONNEL IN THIS AREA IS PROHIBITED WITHOUT THE AUTHORIZATION OF SITE CHARACTERIZATION/LICENSE TERMINATION SUPERVISION


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Attachment 11 – Emergency Contact Information (typical)

POST IN PROMINENT LOCATIONS IN THE WORKPLACE

NAME TELEPHONE NUMBER

Zion Station Emergency 5-2211(Onsite Phone)

(847) 379-2211 (Outside Phone)

ADDITIONAL EMERGENCY NOTIFICATION NUMBERS

ORGANIZATION NAME 24-HOUR NUMBERS

Executive VP and General Manager John T. Sauger (860) 218-0989 Decommissioning Plant Manager Tony Orawiec (847) 727-9170 VP of Construction and D&D Jim Ashburner (860) 227-7324 VP of Radiation Safety Nick Williams (407) 314-5414 Manager, Industrial Safety & Hygiene Gregg W. Tulley (865) 773-4294 Occupational Health Services Nurse Tom Fuller (847) 660-9394 ES LP&D Director Safety and Health Morris Elkins (801) 718-1099

OTHER EMERGENCY NOTIFICATION NUMBERS

ORGANIZATION ADDRESS 24-HOUR NUMBERS

Vista Medical Center East 1324 N Sheridan Rd Waukegan, IL 60085

(847) 249-3900

WorkCare (24/7 On-Call Physician) (888) 449-7787 Zion Fire Department 1303 27th Street

Zion, IL 60099 (847) 746-4040

Zion Police Department 2101 Salem Blvd. Zion IL 60099

(847) 872-8000

Safety may be reached at “11111 from any ZionSolutions VOIP Phone (do NOT dial “5” before dialing 11111)

ZS-SA-01 ZION RESTORATION PROJECT HEALTH ...Have the courage to speak up when you see or believe...

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Transcript of ZS-SA-01 ZION RESTORATION PROJECT HEALTH ...Have the courage to speak up when you see or believe...