FOUR WINDS PLAZA
WESTERN AUTO
ST. THOMAS, USVI
Removal/Closure Plan for Two
Underground Storage Tanks
ENSR Environmental Consulting
August 1993
Document Number 7218-001
*64500*
64500
FOUR WINDS PLAZA
Western Auto
Tank Removal and Closure Plan
for USVI DPNR
TABLE OF CONTENTS
1.0 
INTRODUCTION
1.1 
SITE DESCRIPTION
1.2 
PURPOSE & SCOPE
2.0 
CLOSURE PLAN ACTIVITIES
2.1 
PIPING CLOSURE
2.2 
CONTENTS ANALYSIS
2.3 
NON-HAZARDOUS WASTE, CLOSURE ACTIVITIES
2.4 
HAZARDOUS WASTE, CLOSURE ACTIVITIES
2.5 
GENERAL REMOVAL/CLOSURE ACTIVITIES
2.6 
SAMPLING PROCEDURES
3.0 
ADDITIONAL SAMPLING PLAN
4.0 
REPORTS
5.0 
QUALITY ASSURANCE/QUALITY CONTROL (QA/QC)
6.0 
SCHEDULE
APPENDIX A - STANDARD OPERATING PROCEDURES
APPENDIX B - HEALTH AND SAFETY PROGRAM
Four Winds Plaza
Western Auto
Removal/Closure Plan
August, 1993
Page 1
1.0 
INTRODUCTION
This closure plan includes a detailed description of the activities to be performed during the
removal and closure of the two (2) tanks on the Four Winds Plaza Property (see Figure 1),
behind the Western Auto Store, as identified in Figure 2. This removal/closure plan for the
two underground storage tanks (USTs) is based on information provided to ENSR by Western
Auto and other sources.
1.1 
SITE DESCRIPTION
Four Winds Plaza is a private group that owns and operates the Four Winds Plaza and leases
out store space to a large variety of clients including electronics stores, furniture stores, shoe
stores, food stores, and drug stores among others. Western Auto, is a commercial enterprise
that leases property on the Four Winds Plaza, in the business of selling automotive parts and
accessories. In some cases these parts and accessories are installed in the Western Auto
Store garage bays.
The two UST's of concern. Tank 1 and Tank 2, are located on the property of Four Winds
Plaza in St. Thomas, United States Virgin Islands (USVIMsee Figures 1 & 2). The two USTs
are classified as "out of service" underground storage tanks. All use of USTs, by any and all
parties that have previously used the tanks have been discontinued. The date of discontinued
use of the USTs is not known.
1.2 
PURPOSE AND SCOPE
Four Winds Plaza and Western Auto desire to have these two USTs removed and the soil
underneath them tested to determine what contamination, if any, has come from these tanks
and most importantly to remove any future potential source of groundwater contamination.
This change will in effect, reduce the potential for environmental problems to its site the
surrounding property, the people who work or visit the area and the surrounding community.
This closure plan was prepared by ENSR for Western Auto for the purpose of fulfilling the
obligations of proper removal and closure of these two USTs. This includes the: determination
of the tank contents by sampling and analysis; the proper handling, treatment, disposal of the
contents; and determination of the final disposition of the tanks, the contents of each tank
and/or any soil brought up with the tanks.
Proper closure of these two tanks consists of implementation of the procedures detailed in
this removal and closure plan. In addition, the recording, documenting and reporting of our
findings will assure compliance with the applicable Federal and local laws, regulations, and
guidance (including NFPA), and provide protection of the human health and the environment.
Four Winds Plaza
Western Auto
Removal/Closure Plan
August, 1993
Page 2
2.0 
DESCRIPTION OF CLOSURE PLAN ACTIVITIES
Following is a description of the activities to be carried out during the implementation of the
closure of two USTs.
2.1 
PIPING CLOSURE
Each of the USTs piping will be drained and flushed with water, if necessary, removed where
possible, and then plugged and sealed to avoid any future use for any purpose. The removal,
plugging and sealing of the piping will be documented in the closure report. A bucket will be
placed at the end of any exposed pipe during flushing to catch any liquid used. Any piping
adjacent to, sealed within, or underlying concrete or building walls will not be removed, but
will be sealed with cement.
2.2 
CONTENTS ANALYSIS
One (1) sample of the contents of each tank will be collected and analyzed for the Toxicity
Characteristic Leaching Procedure (TCLP) following 40 CFR 261, Appendix II, Method 1311.
This sampling and analysis will determine if the contents of the tanks will be classified as
hazardous or non-hazardous. This testing is important to determine the handling of the tank
and its contents. If the contents are determined to be non-hazardous based on these results
then the procedures outlined in Section 2.3 will be followed. If the contents are determined
to be hazardous waste based on these results then the procedures outlined in Section 2.4 will
be followed.
2.3 
NON-HAZARDOUS WASTE CLOSURE ACTIVITIES
After the laboratory TCLP results are received and evaluated, confirming that the tank
contents are classified as non-hazardous, the contents will be taken out and transported to
an authorized facility for final disposal in St. Thomas or Puerto Rico. Prior to final disposal of
the waste to an authorized facility, a letter of acceptance from such company will be
submitted to Four Winds Plaza and Western Auto. When possible, a vacuum truck will be
used to remove material from the tanks. The vacuum truck will be located upwind from the
tank and outside the probable path of vapor dispersion, where possible. The area of operation
of the vacuum truck will be maintained "vapor free" by the use of an appropriate (away and/or
above roof lines) exhaust gas hose downwind of the truck and tank area. Explosion proof
pumps will be used, if necessary, to remove any excess liquid remaining in the tanks. All
hoses, motors or pumps will be grounded to prevent electrostatic ignition hazards.
Four Winds Plaza
Western Auto
Removal/Closure Plan
August, 1993
Page 3
2.4 
HAZARDOUS WASTE CLOSURE ACTIVITIES
In case the contents of one or both of the tanks is classified as hazardous waste by the
results of the TCLP analysis, the tanks contents will be handled as a hazardous waste. The
contents of the tank will be removed, manifested and transported to an authorized hazardous
waste facility for treatment and final disposal. 
The requirements established for the
transportation, management, treatment and disposal of hazardous waste will be strictly
adhered to.
2.5 
GENERAL WASTE CLOSURE ACTIVITIES
A qualified contractor or its sub-contractor will perform the work necessary for the proper
removal of the two tanks under ENSR oversight, specifically following this closure plan. The
name of the qualified contractor selected and its OSHA training certifications will be presented
to the DPNR and U.S. EPA 30 days before work will begin. The selected qualified contractor
will in addition to following ENSR's Health & Safety Plan (Attachment B) will have a site
specific contractor Health & Safety Plan.
2.5.1 
Initial Activities
Before any tank removal activities are initiated, flammable or combustible vapor
concentrations will be measured using a combustible gas indicator. When readings of the
lower explosive limit (LED in the tanks are 10% or less, then the tank will be considered safe
for removal. If the LEL is determined to be above 10%, after the tanks contents are removed
the tanks headspace will be vented at a minimum of 12 feet above grade and 3 feet above
any adjacent roof lines and purged with C02 using the dry ice procedure to prevent fires or
explosions during removal operations. Crushed dry ice will be evenly distributed over the area
to ensure rapid evaporation in the amount of 1.5 pounds per 100 gallons of tank capacity.
The dry ice procedure used for this sites two tanks will be performed by the selected qualified
contractor. The combustible gas measurements will be continually conducted of the tank
removal area and the tanks atmosphere with readings at the "bottom, middle, and upper"
portions before, during and after all removal phases, wherever possible, using a combination
combustible gas indicator/oxygen meter.
The tanks will then be purged with high pressure water. The wash waters will be pumped
out by the vacuum trucks and will be properly disposed of as non-hazardous waste to a local
wastewater treatment plant (WWTP) or other appropriate alternative.
Before discharge of waste water to a local WWTP, the approval for discharge will be obtained
from the USVI, Department of Public Works (DPW).
If the tank contents analysis determines that the contents are hazardous waste, then the
wash waters are classified as hazardous waste and will then be handled, stored, transported.
Four Winds Plaza
Western Auto
Removal/Closure Plan
August, 1993
Page 4
treated and disposed off-site as hazardous waste in accordance with all applicable USVI and
Federal hazardous waste regulations.
The contractor will, where necessary, plug any holes and leave a 1/8 inch vent hole located
at the top of the tank before and during removal of the tank from the ground. The contractor
will then place lifting lugs on the tanks and remove the tanks from their graves following
ENSR and Contractor Site Specific Health and Safety Plans. While the tank is temporarily
stored, it will be placed on plastic sheeting, chocked and labeled "Gas Free" and "Danger".
After removal from the ground and insurance that the LEL is consistently below 10% and
inspection determines that there are no liquid, solid or vapor residues, each end of each tank
will be punctured to prevent reuse. The 1/8 inch vent hole will remain at the top of the tank
until final its disposition. The tanks will be secured to a tractor trailer bed for transportation.
The tanks then will be removed, cut up to prevent re-use and the scrap metal will be sold
and/or properly disposed of at an approved site depending upon the condition of the metal.
2.5.2 
Health And Safety
A site specific Health and Safety Plan for the underground storage tank removal project is
presented in Attachment B. Non-sparking tools will be used as discussed in the Health and
Safety Plan. Combustion level action levels have been presented as discussed above and in
the Health and Safety Plan. Assessment of the chemical and physical hazards, requirements
for Personal Protective Equipment (PPE), action levels, decontamination procedures, and
emergency information including safety training are included in the Health and Safety Plan.
More specific details will be addressed in the Contractor Health and Safety Plan. In addition,
weather parameters including temperature, rainfall, wind direction will be monitored and
recorded in the field.
2.5.3 
Soil Screening
Soil from the tank excavations will be continually screened with a HNu. Soil will be placed
in a wide mouth jar and aluminum foil will be placed over each jar. After approximately 15
minutes, the HNu probe will be placed inside the jar to measure the headspace. 
Soil
containing concentrations of VOC's higher than those allowable for on-site reuse will be
stockpiled on top of 10 mil plastic sheeting (visqueen), on-site (as illustrated in Figure 2} and
characterized for treatment/disposal options. The screening measurement (trigger) level to
be used to determine whether the UST excavation areas can be immediately back-filled will
be 25 units (equivalent to PPM) on the HNu.
No "background" soil sampling will be performed during this UST closure. Any additional
sampling beyond that discussed in this closure plan would not facilitate the proper closure of
these two tanks. The soil beneath each tank, and any soil above 25 units on the HNu will
already be analyzed for organic compounds which are presumed not to be present in
Four Winds Plaza
Western Auto
Removal/Closure Plan
August, 1993
Page 5
background samples. If in the course of the UST removal, the field leader judges it necessary
for additional sampling due to unusual circumstances, this additional sampling will be
performed. Other additional analysis will be performed if necessary as mentioned in Sections
2.6 and 3.0 of this closure plan.
If stockpiling of soil with HNu measurements above 25 units is necessary, the stockpiled soil
will be secured and left open for natural venting of organic compounds. The stockpiled soil
will be analyzed, on a expedited basis, for the volatile organics: benzene, toluene, ethyl
benzene and xylene (BTEX) isomers, and TPH. If the analytical results of this stockpiled soil
are below the following proposed limits, the soil will be used as fill material.
BTEX <10ppm
TPH <150ppm
If the stockpiled soil is found to be above the proposed limits listed above, then the soil will
be analyzed for TCLP analysis to determine final treatment/disposal options. Clean borrow
fill, as necessary, will be brought onto the site as needed to immediately place clean fill, so
as not to leave open holes on site.
After the tanks have been removed from the site and all analytical work completed, the tank
area fill material will be brought up to final grade and compacted before the pavement is
replaced.
2.5.4 
Tank Tightness
Tightness testing will not be performed on the tanks. There is no apparent reason to test the
tanks for "tightness" due to the fact that they are not being used, will not be used in the
future. Tank tightness testing is usually performed on existing, in use tanks or tanks that
were "mothballed" and plan to return to service. Tank testing can only be performed if all of
the tanks existing valves and piping can be assured to be sealed. For this case, the tanks
would have to be removed to assure this. Only after the tanks are removed from their graves
could a tightness test be properly conducted. At this point there remains no reason to
conduct this test because the soil beneath the tanks will be analyzed for constituents of
concern.
2.6 
SAMPLING PROCEDURES
Three (3) soil samples beneath each tank (for a total of six (6) samples, will be analyzed for
Target Compound List (TCL) for Volatile Organic Compounds (which include BTEX), Semi-
Volatile Organic Compounds, metals, and Total Petroleum Hydrocarbons (TPH) following the
U.S. EPA methods and Contract Laboratory Procedures (CLP).
Four Winds Plaza
Western Auto
Removal/Closure Plan
August, 1993
Page 6
Three (3) soil borings will be taken in a triangular arrangement for each tank (see Figure 2) all
beneath the tank, no more than 2 feet deep. An additional sample will be taken of any
existing water if apparent during the tank removal process. This would be a maximum of two
(2) additional water samples, one for each tank area. Any water samples(s) will be analyzed
for TCL volatile, semi-volatile, metals and TPH.
To provide any regulatory agency or involved party a spilt sample, a request for a spilt sample
must be presented five (5) days in advance of the sampling procedure. A split sample of any
sample taken by ENSR shall then be made available.
ENSR will take the soil samples using a stainless steel auger from the surface to the bottom
of the grave depending on the depth. If it is not possible to collect a sample from the surface,
ENSR will enter the vacated tank area to sample the underlying soil. If discolored soil is
apparent, one additional sample, for each tank, of this discolored soil will be sampled and sent
to a laboratory for analysis.
Four Winds Plaza
Western Auto
Removal/Closure Plan
August, 1993
Page 7
3.0 
ADDITIONAL SAMPLING PLAN
The laboratory analysis results will be evaluated and reported. If the results demonstrate
contamination in the area, ENSR will propose additional sampling to identify the potential
source and extent for proper closure of these USTs.
Four Winds Plaza
Western Auto
Removal/Closure Plan
August, 1993
Page 8
4.0 
REPORTS
If the contents of the tank are determined to be hazardous, a preliminary closure activities
report will be submitted to DPNR summarizing the conditions and evaluating the results of the
laboratory analysis.
A report will be submitted to DPNR discussing all work performed, summarizing and
evaluating the results of the laboratory analysis. This report will also document all of the
tanks closure procedures and provide any other relevant information.
Four Winds Plaza
Western Auto
Removal/Closure Plan
August, 1993
Page 9
5.0 
QUALITY ASSURANCE/QUALITY CONTROL (QA/QC)
A field logbook, photographs and a chain-of-custody record will be used to document the
removal, sampling and tank closure activities at this site. The chain of custody record will be
filled out to track the sample from the time of collection until completion of the analysis (see
Attachment A). Photographs will be taken by ENSR to document that the procedures were
followed and completed. Each sample container will have a legible label specifying the ID,
date of sample and initials of collector. Samples will be sent, at 4°C for sample preservation,
the same day that they are sampled to the laboratory for analysis. Sample seals will be used
to protect the integrity of the sample while being transported to the laboratory.
All equipment used for sampling will be cleaned and decontaminated following standard
procedures (see Attachment A) prior to the start of work and between each sampling event,
when necessary.
Four Winds Plaza
Western Auto
Removal/Closure Plan
August, 1993
Page 10
6.0 
SCHEDULE
The following schedule exhibits the estimated performance duration times, starting (at 0) on
the date ENSR receives Western Auto's written authorization to proceed with this removal and
closure plan. A 30 day advance notice of implementation of this removal/closure plan will
be made to all regulatory agencies and other involved parties. This schedule assumes
standard laboratory turnaround time of 3 weeks.
ACTIVITIES
1. 
Initial Closure Activities
a) Closure Plan & Earth Movement
Application Approval by DPNR
b) Notice to all relevant agencies and parties
c) Pipe plugging & sealing
2. 
Health & Safety Plan
3. 
Tank Contents Sampling & Analysis
4. 
Tank Removal & Closure Activities
a) removal of tank contents
b) tank contents and wash water disposal
c) soil (& water, if needed) sample analysis
d) tank area remedial action, if necessary
e) removal, cutting up and disposal of tanks
5. 
Documentation Reports
DURATION (Week)
-0 to 5
0 (Attachment B)
0 to 5
6 to 10
- 10 to 13
APPENDIX A
ENSR STANDARD OPERATING PROCEDURES
STANDARD OPERATING PROCEDURE 
Page: 1 of 10
Date: 2nd Otr. 1990
TITLE: Decontamination of Field Equipment 
Number: 7600
Revision: 2
1.0 General Applicability
This SOP describes the methods to be used for the decontamination of
all field equipment which may become contaminated or act as a
contamination source during a sample collection task. The equipment
may include split-spoon samplers, bailers, trowels,_shipping coolers,
drill rigs, backhoes, or any other type of equipment used during field
activities.
Decontamination is performed as a quality assurance measure and a
safety precaution. Improperly decontaminated sampling equipment can
lead to misinterpretation of environmental data due to interference
caused by cross-contamination. Decontamination protects field
personnel from hazardous materials and protects the community by
preventing uncontrolled transportation of contaminants from a site.
Decontamination is accomplished by manually scrubbing, washing, or
spraying equipment with detergent solutions, tap water,
distilled/deionized water, steam, or solvents. Equipment will be
allowed to air dry after being decontaminated or may be wiped dry with
chemical-free paper towels if immediate use is necessary. The
decontamination method and agents are to be determined on a
project-specific basis and must be stated in the Quality Assurance
Project Plan (QAPP).
The frequency of equipment use dictates that most decontamination be
accomplished at each sampling site between collection points.
Decontamination waste products such as liquids, solids, rags, gloves,
etc., will be collected and disposed of as specified in the QAPP. All
cleaning materials and wastes should be stored in a central location so
as to maintain control over the quantity of materials used or produced
throughout the study.
2.0 Definitions
Not applicable
3.0 Health and Safety Considerations
Decontamination procedures may involve chemical exposure hazards
associated with the medium being explored or solvents employed and may
involve physical hazards associated with decontamination equipment.
When decontamination is performed on equipment which has been in
contact with hazardous materials or when the quality assurance
objectives of the project require decontamination with chemical
solvents, the measures necessary to protect personnel must be addressed
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0894J 9899-999-030
STANDARD OPERATING PROCEDURE 
Page: 2 of 10
Date: 2nd Qtr. 1990
TITLE: Decontamination of Field Equipment 
Number: 7600
Revision: 2
in the project Health and Safety Plan. This plan must be approved by
the project Health and Safety Officer before work commences, must be
distributed to all personnel performing equipment decontamination, and
must be adhered to as field activities are performed.
4.0 Quality Assurance Planning Considerations
The decontamination method, solvent, frequency, location on site and
the method of containment and disposal of decontamination wash solids
and solutions are dependent on site logistics, site-specific chemistry,
the nature of the contaminated media to be studied and the objectives
of the study. In addition, some state and local agencies have specific
requirements for decontamination. Each topic must be considered and
addressed during the formulation of a decontamination strategy and
should be outlined in the Quality Assurance Project Plan (QAPP).
The ideal situation would be to have all sampling equipment such as
bailers, trowels and shovels laboratory decontaminated and dedicated to
one sampling location for each day of sampling. Laboratory
decontamination may not be a practical option, however, depending on
the scope of the project. It may be to expensive to obtain laboratory
decontaminated sampling devices for short-term projects or projects
which have numerous sampling locations. Sampling equipment such as
split-spoon samplers or hand augers are too large to have laboratory
cleaned. Finally, it may be difficult to schedule the necessary
laboratory procedures.
There are several factors which need to be considered when deciding
upon a decontamination solvent. Obviously the solvent should not be an
analyte of interest. It must be relatively stable so that it can be
handled and stored in the field without special jhandling requirements.
All sampling equipment must be resistant to the solvent. The solvent
must be evaporative or water soluble or preferably both. State or
local agencies may have specific requirements regarding decontamination
solvents.
The analytical objectives of the study must also be considered when
deciding upon a decontamination solvent. Methanol is the solvent of
choice for general organic analyses. It is relatively safe and
effective. A 10% nitric acid in deionized water solution is the
solvent of choice for general metals analyses._Nitric acid can be used
only on Teflon, plastics and glass. If used on metal equipment, nitric
acid will eventually corrode the metal and_lead tp_the introduction of
metals to the collected samples. If it is necessary to use metal
sampling equipment for metals sampling, the procedure for
decontamination will be a non-phosphate detergent wash followed by a
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0894J 9899-999-030
STANDAKD OPERATING PROCEDURE
TITLE: Decontamination of Field Equipment
Page: 3 of 10
Date: 2nd Qtr. 1990
Number: 7600
Revision: 2
tap water rinse and then a double distilled/deionized water rinse. •
State or local agencies may take exception to this procedure and
require an acid wash. If this is the case, it must be recognized that
the use of nitric acid on metal sampling equipment may lead to
analytical interferences.
If it is determined that methanol or nitric acid are not adequate
decontamination solvents for a particular project, it is strongly
recommended that the local Regional QA Officer be consulted when
selecting an alternative solvent.
Decontamination should be performed far enough away from the source of
contamination so as not to be affected by the source but close enough
to the sampling site to keep handling to a minimum. If heavy equipment
such as drill rigs or backhoes are to be decontaminated, then a central
decontamination station should be considered. Power may be required to
run steam generators or high pressure water pumps. A source of water
may also be necessary.
Depending on the nature of the contaminated media or the
decontamination solvents utilized, it may be necessary to collect, and
dispose of all particulate matter and wash solutions. If containment
is necessary it may be achieved by performing the decontamination in
large galvanized tubs or over plastic sheeting. If heavy equipment is
involved it may require the construction of a sealed concrete pad with
drains and walls, or other suitable temporary structure, to contain
sprays and splashes. Rinse and wash solutions should be collected and
contained in 55 gallon metal or plastic drums. Upon review of tie
analytical data generated from the samples, the proper method of
disposal of these waste products will be determined.
Procedures for Quality Control checks are outlined in Section 9.C.
5.0 Responsibilities
It is the responsibility of the project manager to ensure that the
proper decontamination procedures are followed and that all waste
products of decontamination are properly stored and disposed.
It is the responsibility of the project safety officer to design and
effect safety measures which provide the best protection for all
persons involved directly with sampling and/or decontamination.
It is the responsibility of any subcontractors (i.e., drilling
contractors) to follow the proper, designated decontamination
procedures that are stated in their contracts and outlined in the
project QA and/or Health and Safety Plan.
ENSR Consulting and Engineering
0894J 9899-999-030
STANDARD OPERATING PROCEDURE 
Page: 4 of 10
Date: 2nd Qtr. 1990
TITLE: Decontamination of Field Equipment 
Number: 7600
Revision: 2
It is the responsibility of all personnel involved with sample
collection or decontamination to adhere to the decontamination
requirements and procedures in this SOP and in project specific Health
and Safety Plans and QA plans, to maintain a clean working environment
and to ensure that contaminants are not negligently introduced to the
environment.
6.0 Training/Qualifications
All field technicians performing decontamination procedures for an ENSR
project must be properly trained in the decontamination procedures
employed, the project data quality objectives, health and safety
procedures and the project QA procedures. Specific training or
orientation will be provided for each project to ensure that personnel
understand the special circumstances and requirements of that project.
7.0 Required Materials
• 
Decontamination agents may include: LIQUI-NOX or other
phosphate-free biodegradable detergent solutions, tap water,
distilled/deionized water, nitric acid, methanol, isopropanol,
acetone or other appropriate solvent as specified in the QAPP.
• 
Personal protective equipment (defined in project Health and
Safety Plan)
• 
Chemical-free paper towels
• 
Disposable gloves
• 
Waste storage containers: drums, boxes, plastic bags
• 
Cleaning containers: plastic buckets, galvanized steel pans,
plastic (nalgene or equivalent) upright cylinder
• 
Cleaning brushes
• 
High pressure water or steam generator (if necessary)
• 
Plastic sheeting
• 
Plastic water storage containers
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STANDARD OPERATING PROCEDURE 
Page: 5 of 10
Date: 2nd Qtr. 1990
TITLE: Decontamination of Field Equipment 
Number: 7600
Revision: 2
8.0 Methods
8.1 General Procedures
8.1.1 The purpose of decontamination is three-fold. The first is
to ensure that any compounds or contaminants which have
been determined through chemical analyses to be present in
a sample are in fact native to the sample. All sampling
equipment such as bailers/ trowels, shovels, tape measures/
split-spoon samplers, dredges, sample containers, sample
shipment coolers, etc., must be decontaminated before use
to ensure that contaminants have not been introduced to the
sample during the sampling process.
The second purpose of decontamination is to minimize the
exposure of sampling personnel to hazardous materials.
The third purpose of decontamination is to prevent the
introduction of new contaminants to a sampling site or
prevent the transportation of_cpmpounds_ or contaminants
from the site. Heavy equipment such as trucks, drilling
rigs and backhoes should be decontaminated upon arrival at
the site to prevent the introduction of road chemicals or
contaminants from a previous site. Monitoring well riser
pipes, screens and drilling augers must also be
decontaminated to prevent the introduction of contaminants.
It should be assumed that all sampling equipment, including
gloves, are contaminated until the proper decontamination
procedures have been performed on them and that
contaminated equipment can lead to invalid analytical
results.
8.1.2 Unless the decontaminated equipment or construction
materials are to be used immediately/_they should be
wrapped in aluminum foil, shiny side out, and stored in a
designated "clean" area. Field equipment can also be
stored in plastic bags to eliminate the potential for
contamination. Field equipment should be inspected and
decontaminated prior to use if the equipment has been
stored for long periods of time. Unless customized
procedures are stated in the QAPP (see Section 4.0), the
standard procedures specified below shall be followed.
ENSR Consulting and Engineering
0894J 9899-999-030
STANDARD OPKBATZMG PROCEDURE 
Page: 
6 
of 
10
Date: 
2nd Otr. 1990
TITLE: Decontamination of Field Equipment 
Number: 7600
Revision: 2
8.2 Decontamination for Organic Analyses
8.2.1 Determine from the QAPP the method of containment for the
particulate and wash solution products of decontamination.
Typically, smaller, more manageable equipment will be
decontaminated in a plastic or galvanized tub. The brush
and container used for the decontamination process should
be treated in the same manner as sampling equipment in
steps 8.2.2 through 8.2.10.
8.2.2 Decontamination is to be performed before sampling events
and_between sampling points.
8.2.3 Remove all solid particles from the equipment or material
by brushing and then rinsing with available tap water.
This initial step is performed to remove gross
contamination. Depending on the size of the equipment
being decontaminated, this may be preceded by a steam or
high pressure water rinse to remove solids and/or residual
oil or grease. See Section 8.5 for decontamination of
heavy equipment.
8.2.4 Wash the equipment or sampler with LIQUI-NOX or other
phosphate-free detergent solution.
8.2.5 Rinse with tap water or^ distilled/deionized water until all
detergent and other residue is washed away. Rerinse if
necessary or repeat previous steps as necessary.
8.2.6 Rinse with methanol or other appropriate solvent. The
solvent to be used should be~specified in the QAPP.
8.2.7 Rinse with deionized water to remove any residual solvent.
8.2.8 Allow the equipment or material to air-dry in a clean area
or wipe with chemical-free paper towels before use.
8.2.9 Dispose of soiled materials and wash solutions in the
designated disposal containers.
8.3 Decontamination for Metals Analyses
8.3.1 For plastic and glass, follow Jthe procedures outlined in
8.2, however, use a 10% nitric^acidjsolution as the solvent
rinse in step 8.2.7.
ENSR Consulting and Engineering
0894J 9899-999-030
STANDARD OPERATING PROCEDURE 
Page: 7 of 10
Date: 2nd Qtr. 1990
TITLE: Decontamination of Field Equipment 
Number: 7600
Revision: 2
8.3.2 For metal equipment, follow steps 8.2.1 through 8.2.6 and
allow the equipment or material to air dry in a clean area
or wipe with chemical-free paper towels before use.
8.4 Decontamination of Submersible Pumps
8.4.1 This procedure will be used to decontaminate submersible
pumps before and between ground-water sample collection
points as well as the end of each day of use. If different
pumps are used, consult the QAPP for specific
decontamination procedures.
8.4.2 During decontamination the submersible pump will be placed
on a decontaminated surface, such as a plastic sheet.
8.4.3 When removing the submersible pump from each well the power
cord and discharge line will be wiped dry using
chemical-free disposable towels. Should the pump be fitted
with a disposable discharge line, disconnect the line and
dispose of it.
8.4.4 Clean an upright plastic-nalgene cylinder first with a
methanol, 10% nitric acid or other specified solvent and
then a distilled/deionized water rinse, wiping the free
liquids after each.
8.4.5 For reversible pumps, reverse the pump to backwash all
removable residual water present in the pump tubing. The
pump should be shut off as soon as intermittent flow is
observed from the reverse discharge.
8.4.6 Rinse the stainless steel submersible down hole pump
section with a detergent solution followed by a water rinse
and a liberal application of the specified solvent.
8.4.7 Place the submersible pump section upright in the cylinder
and fill the cylinder with tap water, adding 50-100 ml of
specified solvent for every one liter of water.
8.4.8 Activate the pump in the forward mode, withdrawing water
from the cylinder.
8.4.9 Continue pumping until the water in the cylinder is pumped
down and air is drawn through the pump. At this time air
pockets will be observed in the discharge line. Shut off
the pump immediately.
ENSR Consulting and Engineering
0894J 9899-999-030
STANDARD OPERATING PROCEDURE 
Page: 8 of 10
Date: 2nd Qtr. 1990
TITLE: Decontamination of Field Equipment 
Number: 7600
Revision: 2
8.4.10 Remove the pump from the cylinder and place the pump in the
reverse mode to discharge all removable water into a
disposal container.
8.4.11 Using the water remaining in the cylinder, rinse the sealed
portion of the power cord and discharge tube by pouring the
water carefully over the coiled lines.
8.4.12 On reaching the next monitoring well, place the pump in the
well casing and wipe dry both the power and discharge lines
with a chemical-free paper towel as the pump is lowered.
8.5 Decontamination of Heavy Equipment
8.5.1 Upon arrival and prior to leaving a sampling site, all
heavy equipment such as drill rigs, trucks, and backhoes
should be thoroughly cj.eaned and then the parts of the
equipment which come in contact or in close proximity to
sampling activity should be decontaminated. This can be
accomplished in two ways, steam cleaning or high pressure
water wash and manual scrubbing. Following this initial
cleaning, only those parts of the equipment which come in
close proximity to the sampling activities must be
decontaminated in between sampling events^ This would
include items such sthe backhoe bucketand extension arm,
8.5.2 Consult the QAPP for instruction on the location of the
decontamination station and the method of containment of
the wash solutions. Depending on the scope of the project
it may be necessary to construct a sealed cement pad with
draining capabilities and walls, or other suitable
temporary structure, to contain splashes and sprays. A
water supply and power source would also be required.
9.0 Quality Control Checks and Acceptance Criteria
9.1 These decontamination procedures are to be executed as part of a
project sampling plan. Necessary quality control checks and
acceptance criteria are dependent on site specific chemistry, the
nature of the media sampled and the objectives of the study.
These checks shall be determined on a project specific basis and
shall be outlined in the QAPP or project work plan.
General guidelines for the quality control checks for
decontamination_of field equipment shall be the collection of at
least one field blank from the decontaminated equipment per day.
For the sampling of soils and other solids, decontamination
ENSR Consulting and Engineering
0894J 9899-999-030
STANDARD OPERATING PROCEDURE 
Page: 9 of 10
Date: 2nd Qtr. 1990
TITLE: Decontamination of Field Equipment 
Number: 7600
Revision: 2
rinsate samples should be collected as a substitute for field
blanks. If the samples are to be analyzed for volatile organic
constituents, then one shipping blank should accompany each
shipping container. In this manner, a qualitative, and in the
case of field blanks, quantitative assessment of potential
contamination, and of effectiveness of the decontamination process
is obtained.
9.2 Field blanks for water sampling are made by pouring laboratory
supplied deionized water into or over the freshly decontaminated
sampling equipment (bailer, water level measurement tape, etc. )
and then transferring this water into a sample container. Field
blanks should be collected in the same location that samples _are
collected_to determine if ambient VOCs are impacting the samples.
Sample containers should be filled to the same levels as the
samples the blanks are intended to represent. Field blanks should
then be labeled as a sample and submitted to the laboratory to be
analyzed for the same parameters as the associated sample. Field
blank sample numbers, as well as collection method, time and
location should be recorded in the field notebook.
9.3 Field blanks should also be collected following the
decontamination_of submersible pumps. The pump should be used _to
withdraw laboratory supplied deionized water from the container
and fill a sample container.^ Sample containers should be filled
to the same levels as the samples the blanks are intended to
represent. These field blanks should then be labeled as a sample
and submitted to the laboratory to be analyzed for the same
parameters as the associated samples. Field blank sample numbers,
as well as collection method, time and location should be recorded
in the field notebook.
9.4 For soil samples^ a true field blank is generally not obtainable.
Instead decontamination rinsate samples should be collected.
Immediately following the decontamination of the soil sampling
equipment (trowel, shovel, split-spoon samplers, dredge, etc.),
laboratory supplied^ deionized water shall be applied to the entire^
sampler with a squirt bottle and then collected in a sample
container. Sample containers should be filled to the same levels
as the samples the rinsates are intended to represent.
Decontamination rinsates should then be labeled as a sample and
submitted to the laboratory to be analyzed for the same parameters
as the associated samples. Decontamination rinsate sample
numbers, as well as collection method, time and location should be
recorded in the field notebook.
ENSR Consulting and Engineering
0894J 9899-999-030
STANDARD OPERATING PROCEDURE 
Page: 10 of 10
Date: 2nd Qtr. 1990
TITLE: 
Decontamination of Field Equipment 
Number: 
7600
Revision: 
2
9.5 Shipping blanks are used to identify errors introduced by
cross-contamination of samples during shipping, sample bottle
preparation and blank water quality. Shipping blanks are sample
containers which are filled with deionized water in the laboratory
and^ placed in the sample shipping coolers when the sampling Jcits
are assembled. They remain in the coolers in the field and are
jaot opened. They are returned to the laboratory with the
collected samples and analyzed. The volume of each shipping blank
should be the same as the volume of the samples with which it is
shipped and it should be in the same type of container as the
samples. Analysis of shipping blanks is restricted to volatile
compounds because these compounds demonstrate the greatest
capacity for migration.
10.0 Documentation
Comprehensive documentation of decontamination is accomplished by
completion of the following:
10.1 Field notebook entries
• 
Date, time and location of each decontamination event
• 
Equipment decontaminated
• 
Method
• 
Solvents
• 
Notable circumstances
• 
Identification of field blanks and decontamination rinsates
• 
Method of blank and rinsate collection
• 
Date, time and location of blank and rinsate collection
10.2 Field blank and decontamination rinsate sample labels
• 
Blanks and rinsates should be labeled as samples
10.3 Chain-of-custody forms
• 
Instructions for lab analyses of blanks and rinsates
ENSR Consulting and Engineering
0894J 9899-999-030
STANDARD OPERATING PROCEDURE 
Page: 1 of 6
Date: 3rd Qtr. 1986
Title: Packaging and Shipment of Samples 
Number: 7510
Revision: 1
1.0 Applicability
This Standard Operating Procedure (SOP) is concerned with procedures
associated with the packaging and shipment of samples. Two general
categories of samples exist: environmental samples consisting of air,
water and soil; and waste samples which include non-hazardous solid
wastes and hazardous wastes as defined by 40 CFR Part 261.
2.0 Responsibilities
It is the responsibility of the project manager to assure that the
proper packaging and shipping techniques are utilized for each
project. The site operations manager shall be responsible for the
enactment and completion of the packaging and shipping requirements
outlined in the project specific sampling plan. The site operations
manager shall be responsible to research, identify and follow all
applicable U.S. Department of Transportation (DOT) regulations
regarding shipment of materials classified as waste.
3.0 General Method
The objective of sample packaging and shipping protocol is to identify
standard procedures which will minimize the potential for sample
spillage or leakage and maintain field sampling program compliance with
U.S. EPA and U.S. DOT regulations.
The extent and nature of sample containerization will be governed by
the type of sample, and the most reasonable projection of the sample's
hazardous nature and constituents. The EPA regulations (40 CFR Section
261.4(d)) specify that samples of solid waste, water, soil or air,
collected for the sole purpose of testing, are exempt from regulation
under the Resource Conservation and Recovery Act (RCRA) when all of the
following conditions are applicable:
A. 
Samples are being transported to a laboratory for analysis;
B. 
Samples are being transported to the collector from the laboratory
after analysis;
C. 
Samples are being stored (1) by the collector prior to shipment
for analyses, (2) by the analytical laboratory prior to analyses,
(3) by the analytical laboratory after testing but prior to return
of sample to the collector or pending the conclusion of a court
case.
Qualification for categories A and B above require that sample
collectors comply with U.S. DOT and U.S. Postal Service (USPS)
regulations or comply with the following items if U.S. DOT and USPS
regulaLions are found not to apply:
ERT
696 Virginia Road, Concord, Massachusetts 01742
090ft..1 
"
STANDARD OPERATING PROCEDURE 
Page: 2 of 6
Date: 3rd Qtr. 1986
Title: Packaging and Shipment of Samples 
Number: 7510
Revision: 1
The following information must accompany all samples and will be
entered nn a sample specific basis on chain of custody records:
• 
sample collector's name, mailing address and telephone number,
• 
analytical laboratory's name, mailing address and telephone number,
• 
quantity of sample,
• 
date of shipment,
• 
description of sample, and
in addition, all samples must be packaged so that they do not leak,
spill or vaporize.
4.0 General Methods
4.1 Place plastic bubble wrap matting over the base and bottom corners
of each cooler or shipping container as needed to manifest each
sample.
4.2 Obtain a chain of custody record as shown in Figure 1 and enter
all the appropriate information as discussed in Section 3.0 of
this SOP. Chain of custody records will include complete
information for each sample. One or more chain of custody records
shall be completed for each cooler or shipping container as needed
to manifest each sample.
4.3 Wrap each sample bottle individually and place standing upright on
the base of the appropriate cooler, taking care to leave room for
some packing material and ice or equivalent. Rubber bands or tape
should be used to secure wrapping, completely around each sample
bottle.
4.4 Place additional bubble wrap and/or styrofoam pellet packing
material throughout the voids between sample containers within
each cooler.
4.5 Place ice or cold packs in heavy duty zip-lock type plastic bags,
close the bags, and distribute such packages over the top of the
samples.
4.6 Add additional bubble wrap/styrofoam pellets or other packing
materials to fill the balance of the cooler or container.
4.7 Obtain two pieces of chain of custody tape as shown in Figure 2
and enter the custody tape numbers in the appropriate place on the
chain of custody form. Sign and date the chain of custody tape.
ERT
696 Virginia Road, Concord, Massachusetts 01742
0908J 
; 
04 ocv.
STANDARD OPEEATIHG PROCEDURE 
Page: 3 of 6
Date: 3rd Qtr. 1986
Title: Packaging and Shipment of Samples 
Number: 7510
Revision: 1
4.8 To complete the chain of custody form enter the type of analysis
required for each sample, by container, under the "ANALYSES"
section. Under the specific analysis enter the quantity/volume of
sample collected for each corresponding analysis.
If shipping the samples where travel by air or other public
transportation is to be undertaken, sign the chain of custody
record thereby relinquishing custody of the samples.
Relinquishing custody should only be performed when directly
transmitting custody to a receiving party or when transmitting to
a shipper for subsequent receipt by the analytical laboratory.
Shippers should not be asked to sign chain of custody records.
4.9 Remove the last copy from the chain of custody record and retain
with other field notes. Place the original and remaining copies
in a zip-lock type plastic bag and place the bag on the top of the
contents within the cooler or shipping container.
4.10 Close the top or lid of the cooler or shipping container and with
another person rotate/shake the container to verify that the
contents are packed so that they do not move. Improve the
packaging if needed and reclose.
When transporting samples by automobile to the laboratory, and
where periodic changes of ice are required, the cooler should only
be temporarily closed so that reopening is simple. In these
cases, chain of custody will be maintained by the person
transporting the sample and chain of custody tape need not be
used. If the cooler is to be left unattended, then chain of
custody procedures should be enacted.
4.11 Place the chain of custody tape at two different locations on the
cooler or container lid and overlap with transparent packaging
tape. For coolers with hinged covers, if the hinges are attached
with screws, chain of custody tape should also be used on the
hinge side.
4.12 Packaging tape should be placed entirely around the sample
shipment containers. A minimum of one to two full wraps of
packaging tape will be placed at at least two places on the
cooler. Shake the cooler again to verify that the sample
containers are well packed.
4.13 If shipment is required, transport the cooler to an overnight
express package terminal or arrange for pickup. Obtain copies of
all shipment records as provided by the shipper.
4.14 If the camples are to travel as luggage, check with regular
baggage.
ERT
696 Virginia Road, Concord, Massachusetts 01742
0908J 
"~
STANDARD OPERATING PROCEDURE 
Page: 4 of 6
Date: 3rd Qtr. 1986
Title: Packaging and Shipment of Samples 
Number: 7510
Revision: 1
4.15 Upon receipt of the samples, the analytical laboratory will open
the cooler or shipping container and will sign "received by
laboratory" on each chain of custody form. The laboratory will
verify that the chain of custody tape has not been broken
previously and that the chain of custody tape number corresponds
with the number on the chain of custody record. The analytical
laboratory will then forward the back copy of the chain of custody
record to the sample collector to indicate that sample transmittal
is complete.
5.0 Documentation
As discussed in Section 4.0 the documentation for supporting the sample
packaging and shipping will consist of chain of custody records and
shipper's records. In addition a description of sample packaging
procedures will be written in the field log book. All documentation
will be retained in the project files following project completion.
ERT
696 Virginia Road, Concord, Massachusetts 01742
0908J
STAHDAHD OPERATIHG PROCEDURE
Title: Packaging and Shipment of Samples
Page: 5 of 6
Date: 3rd Qtr. 1986
Number: 7510
Revision: 1
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ERT
696 Virginia Road, Concord, Massachusetts 01742
0908J
ff 
4
STANDARD OPERATING PROCEDURE 
nJ:ate' 
1st Qtr 1984
: " 
Sampling Liquid Waste Materials 
Number: 
SQp 7150
Revision: 
,
1.0 General Applicability
This SOP describes the methods used for obtaining liquid waste materials from
buried and/or exposed tanks and from waste lagoons.
This SOP also describes the methods for proper use of the Coliwasa-type sampler,
bailer type sampler or Alpha-type vertical sampler.
The Coliwasa-tube and bailer allow for collection in profile through a vertical
section of the waste material. The Alpha-type vertical sampler allows that
samples be collected at distinct depths within the liquid phase waste material.
All three types of samplers are generally constructed of chemically inert
materials.
9 0 Equipment Descriptions
2.1 Coliwasa-type sampler: The Coliwasa sampler consists of basically two
parts a sample tube and a sample containment system. The tube itself is
generally one(l) to two(2) inches in diameter and approximately five (5)
feet in length. The containment system consists of a T-handle which is
attached to a rod extending through the sample tube and is connected to a
stopper at the opposite end. Verticle rotation of the T-handle against the
x_ 
sample tube itself causes the stopper to be drawn up flush against the tube
effectively closing the bottom of the sampler.
2.2 Bailer-type sampler: The bailer consists of a hollow tube of approximately
the same dimensions as the Coliwasa sampler but utilizes a flap or
ball-type valve for sample containment. The valve is opened by fluid
pressure when the sampler is inserted into the waste container. When the
sampler is withdrawn, differential hydrostatic pressure closes the valve
entrapping the sample within it.
2.3 Alpha-type vertical sampler: The Alpha vertical unit provides a sample
from a distinct depth within a tank. The Alpha vertical sampler is lowered
through the waste material to the desired depth and is then mechanically
activated from the surface. When activated, the rubber seals spring closed
and contain a sample from a distinct depth. The Alpha type is often used
to collect samples from a few depths which are then subsequently composited
to obtain one data point for chemical analyses.
0882J
ENVIRONMENTAL. RESEARCH & TECHNOLOGY. INC. 
696 VIRGINIA ROAD. CONCORD MASSACHUSETTS 01742
• M2/78I
Page 
of
STANDARD OPERATING PROCEDURE
"e' 
. 1st Qtr 1984
-•ling Liquid Waste Materials 
£umDcr: 
SQp
0 
* 
Revision:
.esponsibilities
t .s the responsibility of the person performing the sampling to maintain the
q^pment so that it is in proper working order throughout the sampling phase.
he field sampler shall also be responsible for the collection, labelling,
a; 11ing and storage of all samples until further chain of custody procedures
ri enacted. Decontamination procedures are also the responsibility of the
Leld sampler. Specific documentation procedures can be found in SOP 7600,
3' mtamination.
upporting Materials
project specific sampling plan
weighted measuring tape
sample containers/labels
sample log sheets
chain of custody forms
decontamination materials
nylon rope or other material for lowering samplers
rags for wiping the sampler each time it is removed
deionozed water dispenser bottle.
= x^ .3 or Protocol for Use
.3 General Procedures
5.1.1 Check to make sure the type of waste material will not react
chemically with the sampler. Choose the sampler that will be best
suited for the type of sample that is to be collected.
5.1.2 Check to make sure that the sampler is in proper working condition
and that the valve(s) or stoppers completely close.
5.1.3 Verify that the sampler has been properly decontaminated.
5.1.4 Maintain proper personal safety measures designated in the project
specific health and safety plan.
.2 Standard Procedures
5.2.1 Measure the total depth to the bottom of the liquid phase waste
material.
5.2.2 Place the sampler in the open position if it is the Coliwasa or Alpha
type. The bailer opening is controlled by a ball check or flap valve
which will have to be checked to see that it is not sticking.
IENTAL RESEARCH & TECHNOLOGY. INC. 
696 VIRGINIA ROAD. CONCORD. MASSACHUSETTS 01742
3f 
4
STANDARD OPERATING PROCEDURE 
n t
Date: 
ist Qtr 1984
Sampling Liquid Waste Materials 
Number: 
S0p 7150
Revision: 
i
5.2.2 Slowly lower the sampler into the container allowing for the
collection of a representative sample.
5.2.3 When the desired depth is achieved activate the sample
containerization system.
5. 2. A Slowly withdraw the sampler making sure the closure system is
properly set. The exterior of the sampler should be wiped on removal
to avoid the contamination of other materials.
5.2.5 Slowly discharge the sample into the appropriate waste container
taking care to minimize spillage.
5.2.6 Cap the sample container; wipe clean the exterior of container.
attach label and seal the container if necessary: record all
observations in the field log book; complete sample logs, chain of
custody records; and utilize the proper sample storage procedures.
5.2.7 Perform proper decontamination procedures as specified in SOP 7600,
Decontamination.
5.2.8 Initiate proper procedures for delivery of the sample to the
^^ 
designated laboratory. This includes packaging, sealing shipping
with appropriate forms such as chain of custody documents.
.0 Documentation
Various forms are required to ensure that adequate documentation of each sample
is followed and will include:
- 
sample logs
chain of custody forms
shipping forms
In addition, a field log book will be kept to document all samples collected
throughout the study. These documents will be retained in the project files.
7 . 0 References
7.1 EPA Samplers and Sampling Procedures for Hazardous Waste Streams
600/2-80-018
0882J
ENVIRONMENTAL RESEARCH & TECHNOLOGY. INC. 
696 VIRGINIA ROAD. CONCORD. MASSACHUSETTS 01742
:t> n 2/78)
1st Qtr 1984
Sampling Liquid Waste Materials 
SOP 7150
1
WASTE-SAMPLING LOG
PROJECT NO. _________________________ 
PROJECT NAME
DATE ____________________________________________
SITE TYPE ________
(Lagoon, Tank, Drum)
SITE LOCATION _____
SAMPLE COLLECTION:
EQUIPMENT USED
NO. OF SAMPLES COLLECTED _________ 
SHIPPING BOX NO.
TYPE OF 
SIZE OF 
FIELD ANALYSIS/ 
ANALYSIS
SAMPLE NO. 
DEPTH 
MATERIAL 
CONTAINER 
HNU, OVA RDNG. 
REQUEST
COMMENTS
LAB DESIGNATION
COLLECTOR'S NAME
STANDARD OPERATING PROCEDURE
Title: Operation/Calibration of HNU Photoionization
Analyzer
Page: 1 of 7
Date: 2nd Qtr. 1987
Number: 7315
Revision: 1
1.0 Introduction
The HNU is primarily used by ERT personnel for safety and survey
monitoring of ambient air, determining the presence of volatiles in
soil and water, and detecting leakage of volatiles.
Personnel responsible for using the HNU should first read and
thoroughly familiarize themselves with the factory operator instruction
manual.
2.0 Principle of Operation
The HNU is a non-specific vapor/gas detector. The hand-held probe
houses a photoionization detector (PID), consisting of an ultraviolet
(UV) lamp and two electrodes, and a small fan which pulls ambient air
into the probe inlet tube. All organic and inorganic vapor/gas
compounds having ionization potentials (IP) lower than the energy
output of the UV lamp are ionized; and the resulting potentiometric
change is seen as a needle deflection, proportional to vapor
concentration, on the potentiometer of the readout/control box.
3.0 Specifications
Detection range*:
Linear range*:
Response time:
0.1 to 2,000 ppm.
0.1 to 400 ppm.
3 seconds to 90% full scale
deflection.
Operating temperature:
Operating time on
battery, continuous
use, without recorder:
Recharge from full
discharge:
-10°C to 40"C.
approximately 10 hours; at lower
temperatures time is reduced.
full recharge 12-14 hours.
* When equipped with 10.2 eV probe with SPAN set at 9.8 and measuring
benzene. Values may vary for other compounds and conditions.
4.0 Required Materials
• 
Calibration Gas: Compressed gas cylinder of isobutylene in air or
similar stable gas mixture of known concentration. The selected
gas should have an ionization potential similar to that of the
ERT
696 Virginia Road, Concord, Massachusetts 01742
1743J J0060
STANDARD OPERATING PROCEDURE 
Page: 2 of 7
Date: 2nd Qtr. 1987
Title: Operation/Calibration of HNU Photoionization 
Number: 7315
Analyzer 
Revision: 1
vapors to be monitored, if known. The concentration should be at
50-75% of the range in which the instrument is to be calibrated.
• 
Regulator for calibration gas cylinder
• 
Approximately 3-4 feet of teflon tubing
• 
"Magic Marker"
5.0 Preliminary Steps
Preliminary steps (battery charging, check-out, calibration,
maintenance) should be conducted in a controlled or non-hazardous
environment.
The sensor probe is carried separately in the instrument carrying
case. For most safety and survey work, the 10.2 eV probe is used, as
it detects more compounds than the 9.5 eV probe and is more durable
than the 11.7 eV probe. Unclamp the cover from the readout/control box
and remove the inner lid from the cover. Screw the inlet tube onto the
sensor probe. Attach the probe cable plug to the 12 pin keyed socket
on the readout panel by matching the alignment slot in the plug to the
key in the connector, and screwing down the probe connector until a
distinct snap and lock is felt.
Turn the function switch to the BATT (battery check) position. The
meter needle will deflect to the green zone if the battery is fully
charged. If the needle is below the green arc or if the low battery
indicator comes on, the battery must be recharged (Section 9.0) before
the analyzer is used.
Turn the function switch to the STANDBY position and allow the
electronics to warm up for five minutes. Next turn the ZERO adjustment
knob until the meter needle is at zero.
6.0 Operation
Turn the function switch to the appropriate range. Check to see if the
intake fan is functioning; if so, the probe will vibrate slightly and a
distinct sound will be audible when holding the probe casing next to
the ear. Also, verify that the UV lamp is on by briefly looking into
the probe from a distance greater than six inches to observe a purple
glow.
ERT
696 Virginia Road, Concord, Massachusetts 01742
1743J J0060
STANDARD OPERATING PROCEDURE 
Page: 3 of 7
Date: 2nd Qtr. 1987
Title: Operation/Calibration of HNU Photoionization 
Number: 7315
Analyzer 
Revision: 1
WARNING: 
Continued exposure to ultraviolet energy generated by
the light source can be harmful to eyesight.
At the beginning of each day, check the calibration (Section 7.2) and
make adjustments if necessary (Section 7.3). Record the calibration
information in the field log book.
The instrument is now operational. Readings should be taken on the
lowest possible scale and recorded in the field log book.
When the HNU is not being used or between monitoring intervals, the
function switch should be set on the STANDBY position to conserve
battery power and UV lamp life.
At the end of each day, recheck calibration (Section 7.2) and record
the information in the field log book.
To shutdown the HNU, turn the function switch to OFF.
Recharge the battery after each use (Section 9.0).
When transporting, disconnect the probe cable connector from the
control panel and return the instrument to its stored condition.
7.0 Calibration Procedures
7.1 Start-Up
Battery Check (Section 5.0).
Zero Set (Section 5.0).
For measurement on the 0-20 or 0-200 ranges only one calibration
gas standard is required. Calibration on the 0-200 range will
provide accurate values on the 0-20 range as well. Connect the
probe tip to the gas cylinder regulator, observing safety
precautions, in order that the gas is delivered to the probe at
atmospheric pressure (Figure 7-1). A t-fitting and plastic tubing
can be used. Adjust the regulator so that the gas is delivered at
150-200 cubic centimeters per minute. The fan inside the probe
draws approximately 100 cc/min.
7.2 Calibration Check
Set the function switch to the proper range setting, based on the
calibration gas used, and record the meter reading in the field
log book. Also record the calibration gas composition and
concentration, the date and the time.
ERT
696 Virginia Road, Concord, Massachusetts 01742
1743J J0060 
! 
:: :
STANDARD OPERATING PROCEDURE 
Page: 4 of 7
Date: 2nd Qtr. 1987
Title: Operation/Calibration of HNU Photoionization 
Number: 7315
Analyzer 
Revision: 1
7.3 Calibration Adjustment
If adjustment is necessary, turn the span as required to read the
ppra concentration of the gas standard, or the equivalent
concentration of benzene if the HNU is being calibrated to benzene.
Recheck the zero setting (Section 5.0)
If reajustment of the zero setting is necessary, repeat the span
adjustment. Record the span setting and the new meter reading.
Whenever the span is changed, the zeroing procedure should be
repeated.
If calibration cannot be achieved or if the span setting resulting
from calibration is 0.0, then the lamp must be cleaned (Section
10.0).
7.4 Alternate Calibration Technique
It may be more convenient in certain circumstances to employ the
use of a Tedler bag filled with calibrant instead of a calibration
cylinder. In that case, the bag (usually 3-10 liter capacity)
should be filled with the appropriate calibrant and brought to the
HNU. The HNU probe should be connected to the discharge fitting
on the bag using a piece of flexible tubing. Allow the HNU to
draw the calibrant from the bag and follow the instructions as
indicated in 7.2, 7.3.
8.0 Troubleshooting Tips
One convenient method for periodically confirming instrument response
is to hold the sensor probe next to the tip of a magic marker. A
significant needle deflection should be observed within 3 seconds with
the function switch set at 0-20 (after shave lotion or cologne also
will make the needle deflect).
Air currents or drafts in the vicinity of the probe tip may cause
fluctuations in readings.
A fogged or dirty lamp (Section 10.0), due to operation in a humid or
dusty environment, may cause erratic or fluctuating readings.
Moving the instrument from a cool or air-conditioned area to a warmer
area may cause moisture to condense on the UV lamp and produce unstable
readings (Section 10.0).
ERT
696 Virginia Road, Concord, Massachusetts 01742
1743J J0060
STANDARD OPERATING PROCEDURE 
Page: 5 of 7
Date: 2nd Qtr. 1987
Title: Operation/Calibration of HNU Photoionization 
Number: 7315
Analyzer 
Revision: 1
A zero reading on the meter should not necessarily be interpreted as an
absence of air contaminants. The detection capabilities of the HNU are
limited to those compounds which will be ionized by the particular
probe used.
Many volatile compounds have a low odor threshold. A lack of meter
response in the presence of odors does not necessarily indicate
instrument failure.
If a negative deflection of the HNU meter is noted the ion chamber is
dirty and needs cleaning. The chamber may be soaked in a solvent such
as methanol in a soil bath air dried and then baked for two to four
hours at a temperature of 100°C and not exceeding 105°C.
When high concentrations of hydrocarbons enter the ionization chamber
in the HNU a "quenching" effect takes place. Typically, it is noted by
a sharp needle movement once the flow of gas is pierced by the HNU
probe. Within one to two seconds the needle fades to zero point. To
check whether or not the quenching effect is taking place, move the HNU
probe to just outside the hole created in the foil. Get another
reading after five to ten seconds. If quenching is taking place a very
eradic needle movement will occur. Once an operator has seen this
phenomena it is fairly easy to recognize.
9.0 Battery Charging
The battery charger is stored inside the instrument cover. To charge
the battery, first insert the mini plug of the charger into the jack on
the side of the meter, with the function switch in the OFF position.
Next, insert the charger plug into a 120VAC single phase, 50-60 HZ
outlet. To ensure that the charger is functioning, turn the function
switch to BATT. The meter should deflect full scale. The sensor probe
cable must be connected to the control panel for a battery check
response. For normal battery charging, leave the function switch in
the OFF position. The battery is fully charged after 14 hours of
charging. The charger can be left on indefinitely without damage.
Disconnect the charger from the electrical outlet before disconnecting
the mini plug from the instrument.
With the function switch turned to the appropriate range setting, the
HNU may be operated while recharging.
10.0 Probe Cleaning
During periods of operation, moisture, dust, or other foreign matter
can be drawn into the probe and form deposits on the surface of the UV
lamp and ion chamber. This causes interference with the ionization
ERT
696 Virginia Road, Concord, Massachusetts 01742
1743J J0060
STANDARD OPERATING PROCEDURE 
Page: 6 of 7
Date: 2nd Qtr. 1987
Title: Operation/Calibration of HNU Photoionization 
Number: 7315
Analyzer 
Revision: 1
process and produces erroneous readings. This condition is indicated
by meter readings that are low, erratic, unstable, non-repeatable, or
drifting. In most cases, the following field cleaning procedure is
sufficient to correct this condition.
Turn the function switch to the OFF position. Disconnect the probe
cable connector at the readout panel. Unscrew the probe inlet tube
from the end cap and clean the inside of the tube making sure that the
tube is dry and lint-free when finished. A pipe cleaner, or a kirn-wipe
and piece of wire, can be used. Keeping the probe upright, remove the
two screws holding the end cap in place and remove the cap and ion
chamber. Place one hand over the top of the lamp housing and tilt
slightly. The light source will slide out of the housing. Take care
not to lose or misplace o-rings or other parts. Do not touch the
internal parts of the probe, particularly the UV lamp, with the bare
hand during cleaning or reassembly. Surgical gloves are recommended.
Clean the internal parts with a non-abrasive, lint-free paper towel
(e.g., kirn-wipe) and reassemble the probe.
11.0 Documentation
Safety and survey monitoring with the HNU will be documented in a bound
field log book and retained in the project files.. The following
information is to be recorded:
• 
Project name and number.
• 
Operator's signature.
• 
Date and time of operation.
• 
Calibration gas used.
• 
Calibration check at beginning and end of day (meter readings
before adjustment).
• 
Span setting after calibration adjustment.
• 
Meter readings (monitoring data obtained).
• 
Instances of erratic or questionable meter readings and corrective
actions taken.
• 
Instrument response verifications - magic marker (Section 8.0) or
similar test.
ERT
696 Virginia Road, Concord, Massachusetts 01742
1743J J0060
STANDARD OPERATING PROCEDURE
Title: Operation/Calibration of HNU Photoionization
Analyzer
Page: 7 of 7
Date: 2nd Qtr. 1987
Number: 7315
Revision: 1
Figure 7-1
R E G U L A T O R
T-FITTING
TEFLON'
TUBING
PROBE
C A L I B R A T I O N
G A S CYLINDER
ERT
696 Virginia Road, Concord, Massachusetts 01742
1743J J0060
Page 
tM 
5
STANDARD OPERATING PROCEDURE
Date: 
1st Qtr 19
Title: 
Test Pits/Trench Subsurface Exploration 
Number: 
SOP 7230
Revision: 
1
1.0 General Applicability
This SOP describes the methods for excavating and logging test pits or
trenches dug for purposes of determining subsurface soil and rock
conditions.
2.0 Responsibilities
It is the responsibility of the geologist or engineer to determine the
location, total depth and overall size of each test pit/trench. It is
also his or her responsibility to collect representative samples from
the test pit/trench. It is the responsibility of subcontractors to
construct test pits/trenches according to ERT project-specific
requirements.
3.0 Supporting Materials
stakes
sample containers: bags, jars, boxes, labels
measuring tape
compass, Brunton type
camera for photographing sections
sample cutting/extracting equipment: knifes, trowels, shovels
fluorescent flagging tape
*
4.0 Methods for Digging Test Pits/Trenches
4.1 General Procedure - Construction
4.1.1 
Notify all utilities (electric, water, sewer, etc.) who
may have equipment or transmission lines buried in the
vicinity of proposed test pits. Many regions have
organizations which represent all utilities for these
notification purposes. Allow enough time after
notification (typically 3 working days) for the utilities
to respond and provide locations of any equipment which
may be buried on-site.
4.1.2 
General locations for test pits or trenches may be
documented by survey or by using topographic maps and/or
plans.
4.1.3 
The elevation of the ground surface at the test pit or
trench location shall be determined by a topographic
survey. It may be necessary, as determined by geologist
or engineer, to obtain elevations at several points where
sloping surfaces are encountered. Topographic survey work
will be performed by a survey subcontractor.
0904J
ENVIRONMENTAL RESEARCH & TECHNOLOGY. INC. 696 VIRGINIA ROAD. CONCORD. MASSACHUSETTS 01742
12845 (12/78)
Paec 
o ;
2
STANDARD OPERATING PROCEDURE
T- i .
 
lst Q
tr 1C
1 
Test Pits/Trench Subsurface Exploration 
£umber. 
sop 723C
Revision: 
..
4.1.3 
Test pits/trenches shall be excavated to the depth
determined by the geologist or engineer. The test pits or
trenches shall be excavated in compliance with applicable
safety regulations. Walls should be cut as near vertical
as possible to facilitate stratigraphic mapping. The size
and depth of test pit/trench shall be receorded in the
Test Pit Log shown in Figure 1.
4. 1.4 
When necessary to determine the boulder content of test
pits or trenches, the boulders shall be separated from the
soil matrix, measured and counted, and the data recorded
by the project geologist or engineer on the approved log
sheets.
4.1.5 
For test pits, a preliminary log shall be prepared in the
field by the geologist or engineer. A sketch may be
necessary to depict the strata encountered.
4.1.6 
Trenches shall be mapped by the geologist or engineer.
All information shall be recorded in a log book designated
for the trench, or directly on a sketch map of the
trench. The data shall be transferred at a later date to
^ 
profiles at a scale to be determined by the geologist or
engineer.
4.1.7 
Before measuring the depth to the ground-water table in
test pits, if encountered, the geologist or engineer will
allow sufficient time for stabilization of the
ground-water table.
4.2 General Procedure - Collecting Samples
4.2.1 
Requirements for sampling shall be determined by the
geologist or engineer and specified in the project
sampling plan.
4.2.2 
Representative samples shall be collected by the geologist
or engineer.
4.2.3 
The samples shall be placed in wide-mouth, approximately
16-ounce jars with screw top. Each jar shall be labelled
with the following information:
- client/project name
- project number
- test pit/trench number
- sample number/identification
- horizontal/vertical location
- date of collection 
m 
•-<:: ;
0904J
ENVIRONMENTAL RESEARCH & TECHNOLOGY, INC. 
696 VIRGINIA ROAD. CONCORD. MASSACHUSETTS 01742
1284b (12/781
Page 
of
STANDARD OPERATING PROCEDURE
Date:
Title: 
Number: lst
Test Pits/Trench Subsurface Exploration 
Revisi • 
SOP 
723
These data shall be similarly recorded onto the sample log
sheets and field notebook. Each jar cap shall be
similarly marked. A soil sample container label is shown
in Figure 2.
4.2.4 
All jars shall be placed into a marked box for their
protection.
4.2.5 
Larger bulk (disturbed) samples shall be placed in cloth
bags with plastic liners. Sample bags shall be marked
with client's name, project number, site number, test
pit/trench number, sample number, horizontal/vertical
location, and date.
4.2.6 
Test pit locations shall be referenced onto the site map.
Sample locations shall be referenced onto a plan
view/vertical section of each test pit/trench.
4.2.7 
Photographs_of specific geologic features may be required
for documentation purposes. A scale or an item providing
a size perspective shall be placed in each photograph.
Frame number/picture location shall also be documented in
the field log book.
4.3 General Procedure - Backfilling
4.3.1 
Prior to backfilling, the test pit/trench shall be
inspected to ensure that all the appropriate and/or
required data and samples have been collected.
4.3.2 
After inspection, backfilling and compaction of test
pit/trenches shall be accomplished according to contract
specifications.
4.3.3 
All tesjt_pits_/trenches will be backfilled to original
grade.
4.4 Specific procedures pertaining to the handling and shipment of
samples shall be followed according to SOP 7510.
5.0 Documentation
test pit log
sample log sheets
field log book
chain of custody forms 
n 
; 
now:-;
shipping receipts
All documentation shall be placed in the project files and retained
following completion of the project.
ENVIRONMENTAL RESEARCH &TECHNOLOGY, INC. 
696 VIRGINIA ROAD. CONCORD. MASSACHUSETTS 01742
0904J
1284b (12/78)
Prc
Da
Toi
Eq
Rei
.p~* 
sitp 
TEST PIT 
<?n 
nf
to 
Location 
G'ound Elevation
tal De
jipme
narks
p»h 
Contractor
ntlUaH 
Logged by
> «
° 9
LU U.
_L
'a. •
5" o
Q^
-
Sample
Type
& No.
Depth
Range
•
Test Pit Plan
"*~ 
~~ *! 
North
L)
Soil & Rock Description & Comments
Groundwater
D«e 
A Jinle (H°,Ur* , 
Depth (Feet)
After Completion)
A
T-! m.r-o 1 
Tocr PS r
JOB:____
LOCATION:.
BORING/TEST PIT NO.:.
SAMPLE NO.: ______
DEPTH:__________
BLOWS:__________ PEN:__________ REC:
DATE:_____________________________
REMARKS:
L ENVIRONMENTAL RESEARCH & TECHNOLOGY. INC..
Figure 2 
Soil Sample Lable
Tide:
STANDARD
Surface Soil Sampling
OPERATING PROCEDURE
Date:
Number:
Revision:
1st Qtr
7110
1
1.0 General Applicability
This SOP describes the methods used for obtaining surface soil samples for
physical analysis or quality/chemical analysis. This SOP also describes the
procedures for using the various types of sampling equipment, which include
shovels, trowels, and hand augers. The equipment may be constructed of special
materials (for example, stainless steel, inert plactics) according to specific
project requirements.
2.0 Equipment Descriptions:
2.1 shovel - long or short handle type. Used for penetrating the upper surface
and/or obtaining soil samples directly.
2.2 trowel - basic garden variety, which resembles a small shovel. Constructed
of steel or polypropylene (plastic)*. The blade of a trowel is generally
flat and 5 to 6 inches in length. A scoop (blade has curved edges versus
flat) may be substituted if necessary. Both can be purchased with volume
calibrations.*
2.3 Hand auger - This tool consists basically of a short spiral-bladed metal
rod (Auger) attached to a handle. Clockwise rotation of the T handle
initiates the cutting process. Most of the loose soil is discharged
upwards as the auger moves downwards. However, if the soil is cohesive
some of it will stick to the auger flight providing a collectable sample at
a measurable depth. Samples of surface soil can also be collected using a
tube sampler which will be attached to the end of the auger rods and
advanced into the soil to extract a sample.
3.0 Responsibilities
The project geologist/engineer will be responsible for the proper use and
maintenance of all types of equipment used for obtaining surface soil samples;
and the collection, labelling, handling and storage of all samples until further
chain of custody procedures are undertaken.
4.0 Supporting Materials
Sample containers/Labels
Sample Logs/Boring Logs
Decontamination materials (if required)*
Field notebook
Six-foot folding rule or tape measure for depth measurement
"Requirements for inert materials, decontamination, or calibrated sampling tools may
be required depending upon the purpose of the sampling. These requirements will be
detailed in a project-specific sampling plan.
, 
0887J
ENVIRONMENTAL RESEARCH & TECHNOLOGY. INC. 
696 VIRGINIA ROAD. CONCORD. MASSACHUSETTS 01742
!284b (12/781
Page 
ol'2
STANDARD OPERATING PROCEDURE
_. . 
Date:- 
1st Qtr 1
lltje: 
Surface Soil Sampling 
Number: 
mo
Revision:
5.0 Method or Protocol
5.1 General Procedures
Specific sampling equipment and methodology will be dictated by the
characteristics of the soil to be sampled, the type of soil samples required by
the project and the analytical procedures to be employed. Soil samples obtained
at the surface may be collected using a shovel or trowel. The type of analysis
requested (e.g., grain-size distribution, physical, chemical) may require
specific soil amounts or the use of specialized sampling equipment. Sampling to
obtain uniform coverage within a specified area will require the use of an area
grid. These considerations will be followed based upon specific project
requirements defined in the project sampling plan.
A hand auger can be used to extract shallow soil samples up to three (3) feet
below the surface. Representative samples will be collected directly from the
auger flight as it is withdrawn from the ground, or from the tube sampler
attached to the end of the rods and advanced into the soil.
The location of sample points will be determined on a project specific basis.
5.2 Standard Procedures
5.2.1 Select the specific sampling location. Construct a sampling grid if
necessary. Remove all surface materials that are not to be included
samples, for example, rocks, twigs, leaves.
5.2.2 Select type of sampler required to obtain the correct sample. At the
surface, use a shovel, trowel or tube sampler; below surface, use a
hand auger or tube sampler.
5.2.3 Obtain a sufficient quantity of soil for the desired chemical or
physical analyses.
5.2.4 When using the hand auger, auger the hole to the required depth, then
slowly remove the auger and collect the soil sample from the auger
flight itself at the point corresponding to the required depth.
Reinsert and continue augering if deeper samples are required. In
addition, a tube sampler can be attached to the auger rods after
augering to the desired depth, inserted into the open bore, and then
advanced into the deposits at the base of the boring. If sampling is
needed in sandy or non-cohesive soil, a shovel may be necessary to
obtain samples.
0887J
ENVIRONMENTAL RESEARCH & TECHNOLOGY. INC. 
596 VIRGINIA ROAD CONCORD MASSACHUSETTS 0174?
:284b 112/78)
STANDARD OPERATING PROCEDURE
_. . 
Datc: 
lit Qtr 19
iitle: 
Surface Soil Sampling 
Number: 
7110
Revision: 
,
5.2.5 Cap the sample container; attach label; seal container (if analysis
for volatile chemical species is anticipated). Record all
observations such as visual soil description in a field book or on a
surface soil sample log. Complete chain of custody records. Utilize
proper storage procedures (see SOP 7510).
5.2.6 Decontaminate the sampler between collection points. Decontamination
procedures will be performed as identified in SOP 7600
Decontamination unless otherwise specified.
5.2.7 Initiate proper procedures for delivery of the samples to the
designated laboratory. This includes packaging, and shipping with
chain of custody forms (see SOP 7510).
6.0 Documentation
Various forms are required to ensure that adequate documentation is made of the
sample collection activities. These forms include:
field log books
sample logs
chain of custody forms
shipping forms
The field book will be maintained as an overall log of all samples collected
throughout the study. These documents will be retained in the appropriate
project files.
0887J
ENVIRONMENTAL RESEARCH & TECHNOLOGY. INC. 
696 VIRGINIA ROAD. CONCORD. MASSACHUSETTS 01742
T284b (12/78)
SURFACE SOIL SAMPLE LOG
PROJECT NO. _________________________ 
PROJECT LOCATION
SAMPLE POINT NO.
DATE _______________________________ 
TIME
SAMPLE POINT DESCRIPTION/DESIGNATION ____
SAMPLE COLLECTION:
EQUIPMENT USED
NO. OF SAMPLES COLLECTED _________ 
CONTAINER SIZE
TYPE OF
SAMPLE NO. 
DEPTH 
MATERIAL 
ANALYSIS
COMMENTS
LAB DESIGNATION
SHIPPING BOX NO.
COLLECTOR'S NAME
0887J
APPENDIX B
HEALTH AND SAFETY PLAN
Health and Safety Plan
for
Tank Removal and Closure
Four Winds Plaza
Western Auto
United States Virgin Islands
Prepared by:
Approved by:
Approved by:
Kathleen Harvey
Project Manager
Date: 
July 1993
/ffj
Date:
<u
0
7218-001-200
08/03/93 (T"*> « 58pm
TABLE OF CONTENTS
Page
1.0 INTRODUCTION
1.1 HASP REQUIREMENTS 
1-1
1.2 RESPONSIBILITIES 
1-1
1.3 MODIFICATIONS TO HASP 
1 -4
2.0 SITE DESCRIPTION/HISTORY 
2-1
3.0 SCOPE OF WORK 
3-1
4.0 HAZARD ASSESSMENT
4.1 POTENTIAL CHEMICAL HAZARDS 
4-1
4.2 POTENTIAL PHYSICAL HAZARDS 
4-2
4.2.1 Heat Stress 
4-2
4.2.2 Back Safety 
4-3
4.2.3 Operation of Drill Rig 
4-4
4.2.4 Utility Installations 
4-5
4.2.5 Hot Work 
4-5
4.2.6 Confined Space Entry 
4-5
4.2.7 Rigging 
4-5
4.2.8 Open Excavations 
4-5
4.2.9 Static Electricity 
4-6
4.2.10 Use of a Vac-Truck 
4-6
4.2.11 Flammability Concerns 
4-6
4.2.12 Entry into Tank Grave 
4-7
5.0 AIR MONITORING 
5-1
6.0 PERSONAL PROTECTIVE EQUIPMENT
6.1 PROTECTIVE CLOTHING 
6-1
6.2 RESPIRATORY PROTECTION 
6-2
6.3 OTHER SAFETY EQUIPMENT 
6-2
7.0 SITE CONTROL
7.1 WORK ZONES 
7-1
7.2 PROTECTIVE MEASURES 
7-2
8.0 DECONTAMINATION 
8-1
9.0 MEDICAL MONITORING^TRAINING REQUIREMENTS
9.1 MEDICAL 
9-1
9.2 TRAINING 
9-1
9.3 PRE-ENTRY BRIEFING 
9-2
10.0 
EMERGENCY RESPONSE 
10-1
7218-001-200 
08/03/93 (Tut) 5:35pm
ATTACHMENTS
Attachment A 
HASP Sign-Off Sheet
Attachment B 
Material Safety Data Sheets
Attachment C 
Pre-Entry Briefing Attendance Sheet
Attachment D 
Accident/Investigation Report
7218-001-200 
08/03/93 (Tu«) 4:S8poi
1.0 INTRODUCTION
1.1 
HASP Applicability
This site-specific Health and Safety Plan (HASP) has been developed by ENSR Consulting and
Engineering (ENSR) to establish the health and safety procedures required to minimize any
potential risk to personnel who will perform the tasks associated with the closure of two
underground storage tanks (USTs) at the Four Winds Plaza behind the Western Auto store
located in St. Thomas, United States Virgin Islands (USVI). The provisions of this plan apply to
all ENSR personnel and ENSR subcontractor personnel who may potentially be exposed to safety
and/or health hazards related to activities described in Section 3.0 of this document.
Although the proposed scope of work is not covered by the Occupational Safety and Health
Administration (OSHA) Hazardous Waste Operations and Emergency Response Standard (29
CFR1910.120), this HASP has been written to comply with the requirements of that standard. All
activities covered by this HASP must be conducted in complete compliance with this HASP and
with all applicable federal, state and local health and safety regulations. Personnel covered by
this HASP who cannot or will not comply will be excluded from site activities.
Subcontract personnel who choose to follow ENSR's plan must distribute a copy of this plan to
each employee who will work at the site. Each employee must sign a copy of the attached health
and safety plan sign-off sheet (see Attachment A). Subcontractors to ENSR may develop their
own HASP related to their specific on-site activities. This HASP must minimally be as protective
as ENSR's and must be submitted for ENSR review at least two weeks prior to the start of on-site
activities.
Please note that this HASP only pertains to the proposed activities associated with the
removal/closure of the two USTs and does not cover any extended soil and/or groundwater
investigations that may be necessary. Tasks covered by this HASP are listed in Section 3.0 of this
document. A task specific HASP or addenda to this HASP will be developed at a later date for
any other subsequent investigative/remedial activities at the site.
1.2 
Responsibilities
The implementation of health and safety at this site will be the shared responsibility of the ENSR
Project Manager (PM), the ENSR Regional Health and Safety Manager (RHSM), the ENSR Project
Site Safety Officer (SSO), and all other ENSR and ENSR subcontractor site personnel.
7218-001-200 
1-1 
08/03/93 fTu») 4:S8pm
The ENSR PM (Robert Fuhrer) is, by designation, the individual who has the primary
responsibility for ensuring the overall health and safety of this project. The PM therefore has the
primary responsibility for ensuring the implementation of the requirements of this HASP. Some
of the PM's specific responsibilities include:
• 
Assuring that all personnel to whom this HASP applies, including ENSR subcontractors,
have received a copy and have submitted a completed copy of the HASP sign-off form;
• 
Assuring that all personnel to whom this HASP applies have attended a pre-entry
briefing prior to entering a restricted area;
• 
Assuring that all ENSR subcontractor personnel submit documentation of the medical
surveillance and training requirements specified in Sections 9.1 and 9.2 of this HASP;
• 
Maintaining a high level of health and safety consciousness among employees at the
work site;
• 
Maintaining regular communications with the SSO and, if necessary, the RHSM; and,
• 
Contacting the RHSM as soon as the analytical data is received for the septic tank
sludge.
The ENSR RHSM (Kathleen Harvey) is the individual responsible for the preparation,
interpretation and modification of this HASP. Modifications to this HASP which may result in less
stringent precautions cannot be undertaken by the PM or the SSO without the approval of the
RHSM. Specific duties of the RHSM include:
• 
Writing, approving and amending the HASP for this project;
• 
Advising the PM and SSO on matters relating to health and safety on this site;
• 
Recommending appropriate personal protective equipment and air monitoring
instrumentation to protect personnel from potential site hazards;
• 
Performing site audits to monitor the effectiveness of this HASP and to assure
compliance with it;
• 
Conducting accident investigations; and,
7218-001-200 
1-2 
08/03/93 (T"») *:5Bpm
• 
Maintaining regular contact with the PM and SSO to evaluate site conditions and new
information which might require modifications to the HASP.
The ENSR SSO (to be appointed by the PM) will be on-site during all the investigative activities
covered by this HASP. The SSO is responsible for enforcing the requirements of this HASP once
on-site work begins. By design, the SSO has the authority, and the responsibility, to immediately
correct all situations where noncompliance with this HASP is noted and to immediately stop work
in cases where an immediate danger is perceived. Some of the SSO's specific responsibilities
include:
• 
Procuring and distributing the PPE needed for this project for ENSR personnel;
• 
Procuring the air monitoring instrumentation required and performing air monitoring;
• 
Verifying that all PPE and health and safety equipment is in good working order;
• 
Setting up and maintaining the contamination reduction zone within the restricted areas
and assuring proper decontamination of all site personnel and equipment;
• 
Notifying the PM and RHSM of all noncompliance situations and stopping work in the
event that an immediate danger situation is perceived;
• 
Monitoring and controlling the safety performance of all personnel within the established
restricted areas to ensure that required safety and health procedures are being followed
and correcting any deficiencies;
• 
Conducting the required pre-entry briefing;
• 
Assisting with accident/incident investigations and preparing accident/incident
investigation reports; and
• 
Initiating emergency response procedures in according with Section 10.0 of this HASP.
All ENSR and subcontractor field personnel covered by this HASP are responsible for following
the health and safety procedures specified in this HASP and for performing their work in a safe
and responsible manner. Some of the specific responsibilities of the field personnel are as
follows:
• 
Reading the HASP in its entirety prior to the start of on-site work;
7218-001-200 
1 -3 
08/03/93 fTue) 4:S8pm
• 
Submitting a completed HASP Acceptance Form and documentation of medical
surveillance and training to the ENSR PM prior to the start of work;
• 
Attending the required pre-entry briefing prior to beginning on-srte work;
• 
Bringing forth any questions or concerns regarding the content of the HASP to the PM
or the RHSM prior to the start of work;
• 
Reporting all accidents, injuries and illnesses, regardless of their severity, to the ENSR
SSO; and
• 
Complying with the requirements of this HASP and the requests of the SSO.
Additionally, subcontractors are responsible for:
• 
Providing ENSR with Standard Operating Procedures (SOP) for the specific tasks
they will perform;
• 
Issueing hot work and/or confined space entry permits, if necessary, to their
employees or procuring those permits from the facility,
• 
Providing ENSR with copies of material safety data sheets (MSDS) for all hazardous
materials brought on-site; and,
• 
Providing all the required personal protective equipment for their employees
1.3 
Modification to the HASP
The procedures in this HASP have been developed based on current knowledge regarding the
specific potential chemical and physical hazards which are currently known or anticipated for the
operations which are to be conducted at this site. All proposed modifications to this HASP must
be reviewed and approved by the ENSR RHSM before such modifications are implemented.
Any significant modifications must be incorporated into the written document as addenda and
the HASP must be reissued. The ENSR PM will ensure that all personnel covered by this HASP
receive copies of all issued addenda. Sign-off forms will accompany each addendum and must
be signed by all personnel covered by the addendum. Sign-off forms will be submitted to the
ENSR PM. The HASP addenda should be distributed during the daily safety meeting so that they
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can be reviewed and discussed. Attendance forms will be collected during the meeting.
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2.0 SITE HISTORY
Four Winds Plaza is a private group that owns and operates the Four Winds Plaza and leases
out store space to a large variety of clients including electronics stores, furniture stores, shoe
stores, food stores and drug stores, among others. Western Auto is a commercial enterprise that
leases property on the Four Winds Plaza (see Figure 2-1). Western Auto sells automotive
materials and equipment. In some cases, this equipment is installed in the Western Auto Store.
The two USTs of concern, Tank 1 and Tank 2, are located behind the Western Auto Store. The
tanks are classified as "out of service" (see Figure 2-2) All use of the USTs, by any and all parties
that have previously used the tanks has been discontinued.
One tank is an approximately 200-gallon tank originally filled with diesel fuel and now contains
a water and waste oil mixture. The other tank is an approximatley 2,000-gallon tank that originally
held waste oil. The tank is now filled with sand.
Four Winds Plaza and Western Auto want to remove these two USTs and to test the soil
underneath the tanks to determine what contamination, if any, has resulted from the tanks.
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3.0 SCOPE OF WORK
The overall scope of work associated with the removal and closure of these tanks includes:
• 
determining the tank contents by sampling and analysis
• 
properly handling, treating and disposing of the tank contents
• 
determining the final disposition of the tanks, tank contents and any soils brought up
with the tanks
The specific tasks associated with the proposed removal/closure of the two USTs includes the
following:
• 
Drain and flush with water each of the USTs piping
• 
Plug and seal the piping
• 
Collect samples of tank contents for subsequent laboratory analysis
• 
Pump the contents of the tank for ultimate transport and disposal
• 
Clean the tank using high pressure water
• 
Pump out generated wash waters for ultimate disposal
• 
Sample wash waters if original analyses indicates that tank contents are hazardous
• 
Remove the tanks from their graves
• 
Puncture each end of the tank after removal and remove tank from the site
• 
Screen soils in tank excavation
• 
Stockpile soils with elevated HNu readings
• 
Sample and analyze stockpiled soils
• 
Advance three (3) soil borings beneath each tank to a depth of no more than two (2)
feet
• 
Collect samples from borings
• 
Collect sample of any existing water if apparent during tank removal process
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4.0 
HAZARD ASSESSMENT
The following chemical and physical hazard assessment applies only to the proposed activities
covered by this HASP.
Constituents of Potential Concern
4.1 
Chemical Hazards
The following list of constituents of potential concern has been developed for this project.
• 
Waste Oil
Potential Routes of Exposure
Dermal contact with materials in the piping and tanks during the removal of piping/tank
contents, cleaning of the piping/tanks and sampling of the tank contents
Dermal contact with residual contamination in soils and wash waters during sampling
Inhalation of particulates during tank removal and soil boring
Splash hazard during the removal of tank contents and/or wash waters
Other Chemicals
Material Safety Data Sheets for the solutions (methanol) that ENSR will use to decontaminate
sampling equipment are presented in Attachment B. The most likely exposure route to the decon
solutions is dermally, although a splash hazard does exist. The SSO must ensure that all bottles
and containers of decon solutions brought on-site are property labeled in accordance with the
OSHA Hazard Communication Standard. Subcontractors are required to submit copies of MSDSs
to ENSR for those hazardous materials they bring on-site.
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4.2 
Physical Hazards
4.2.1 
Heat Stress
Heat related problems include heat fatigue, heat rash, fainting, heat cramps, heat exhaustion and
heat stroke. Heat rash occurs because sweat isn't evaporating, making the skin wet most of the
time. Standing erect and immobile in the heat allows blood to pool to lower parts of the body.
As a result, blood does not return to the heart to be pumped to the brain. Fainting may then
occur.
Heat cramps are painful spasms of the muscles due to excessive salt loss associated with
profuse sweating. The loss of large amounts of fluid and excessive loss of salt results in heat
exhaustion. The skin will be clammy and moist and persons exhibit extreme wetness, giddiness,
nausea and headache.
Heat stroke occurs when the body's temperature regulatory system has failed. Skin is hot, dry,
red and spotted. The affected person may be mentally confused and delirious. Convulsions
could occur. EARLY RECOGNITION AND TREATMENT OF HEAT STROKE ARE THE ONLY
MEANS OF PREVENTING BRAIN DAMAGE OR DEATH. A person exhibiting signs of heat stroke
should be removed from the work area to a shaded area. The person should be soaked with
water to promote evaporation. Fan the person's body to increase cooling.
Increased body temperature and physical discomfort also promote irritability and a decreased
attention to the performance of potential hazardous tasks.
Early Symptoms of Heat-Related Health Problems:
• 
decline in task performance 
• 
excessive fatigue
• 
incoordination 
• 
vigilance
• 
decline in alertness 
• 
muscle cramps
• 
unsteady walk 
• 
dizziness
Susceptibility to Heat Stress Increases due to:
• 
lack of physical fitness 
• 
obesity
• 
lack of acclimation 
• 
drug or alcohol use
• 
increased age 
• 
sunburn
• 
dehydration 
• 
infection
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People unaccustomed to heat are particularly susceptible to heat fatigue. First timers in PPE
need to gradually adjust to the heat
Measures to Avoid Heat Stress:
• 
Establish work-rest cycles (short and frequent are more beneficial than long and seldom).
• 
Identify a shaded, cool rest area.
• 
Rotate personnel, alternative job functions.
• 
Water intake should be equal to the sweat produced. Most workers exposed to hot
conditions drink less fluids than needed because of an insufficient thirst. DO NOT DEPEND
ON THIRST TO SIGNAL WHEN AND HOW MUCH TO DRINK. For an 8-hour work day, 50
ounces of fluids should be drunk.
• 
Eat lightly salted foods or drink salted drinks such as Gatorade to replace lost salt.
• 
Save most strenuous tasks for non-peak heat hours such as the early morning or at night.
• 
Avoid alcohol during prolonged periods of heat. Alcohol will cause additional dehydration.
• 
Avoid double shifts and/or overtime.
The implementation and enforcement of the above mentioned measures will be the joint
responsibility of the project manager, on-site field coordinator, and health and safety officer.
Potable water and fruit juice will be available each day for the field team.
Site personnel should monitor their heart rate as an indicator of heat strain by the following
method:
Radial pulse rates should be checked by using fore and middle fingers and applying light
pressure top the pulse in the wrist for one minute at the beginning of each rest cycle. If the pulse
rate exceeds 110 beats/minute, the next work cycle will be shortened by one-third and the rest
period will be kept the same. If, after the next rest period, the pulse rate still exceeds 110
beats/minute, the work cycle will be shortened again by one-third.
4.2.2 
Back Safety
To avoid potential back injury, drums of pumped tank contents and/or rinsate water and drums
of soil boring cuttings should not be moved or handled manually.
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4.2.3 
Operation of Drill Rig
Use of a drill rig to advance soil borings will require all personnel in the vicinity of the operating
machinery to wear steel-toed footwear, hardhats, hearing protection and safety eyewear.
Personnel should not remain in the vicinity of operating equipment unless it is required for their
work responsibilities.
Additionally, the following safety requirements will be adhered to:
• 
All drill rigs and other machinery with exposed moving parts must be equipped with an
operational emergency stop device. Drillers and geologists must be aware of the
location of this device. This device must be tested prior to job initiation and periodically
thereafter. The driller and helper shall not simultaneously handle augers or drill rods
unless there is a standby person to activate the emergency stop.
• 
The driller must never leave the controls while the tools are rotating unless all personnel
are kept clear of rotating equipment.
• 
A long-handled shovel or equivalent must be used to clear drill cuttings away from the
hole and from rotating tools. Hands and/or feet are not to be used for this purpose.
• 
A remote sampling device must be used to sample drill cuttings if the tools are rotating
or if the tools are readily capable of rotating. Samplers must not reach into or near the
rotating equipment. If personnel must work near any tools which could rotate, the driller
must shut down the rig prior to initiating such work.
• 
Drillers, helpers and geologists must secure all loose clothing when in the vicinity of
drilling operations.
• 
Only equipment which has been approved by the manufacturer may be used in
conjunction with site equipment and specifically to attach sections of drilling tools
together. Pins that protrude excessively from augers shall not be allowed
• 
No person shall climb the drill mast while tools are rotating.
• 
No person shall climb the drill mast without the use of ANSI-approved fall protection
(approved belts, lanyards and a fall protection slide rail) or portable ladder which meets
the requirements of OSHA standards.
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4.2.4 
Utility Installations
The estimated location of utility installations, such as sewer, water, gas and process lines and
other underground installations that may be encountered during drilling, will be confirmed with
a representative of the facility prior to drilling.
Be particularly aware of overhead lines in the work area. Any vehicle or mechanical equipment
capable of having parts of its structure elevated (drill rig, crane etc.) near energized overhead
lines shall be operated so that a minimum clearance of 10 feet is maintained.
4.2.5 
Hot Work
If the tank is cut up on-site, a hot work permit may be required. Issueing this permit and meeting
the requirements of the permit is the responsibility of the subcontractor.
4.2.6 
Confined Space Entry
ENSR personnel will not enter the tanks. If it is necessary for the subcontractor to enter the tank
to clean it, the entry must be performed in strict accordance with OSHA's new confined space
entry standard and their company's standard operating procedures for confined space entry. It
is the sole responsibility of the subcontractor to meet the requirements for safe entry into a
confined space, including the appropriate air monitoring.
4.2.7 
Rigging
ENSR personnel are to remain clear of this activity until the tank has been set on the ground and
securely blocked to prevent rolling. UNDER NO CIRCUMSTANCES ARE PERSONNEL TO PASS
UNDER THE SUSPENDED TANK WHILE IT IS BEING RIGGED OUT OF THE EXCAVATION. While
the tank is temporarily stored, it will be placed on plastic sheeting , chocked and labeled "Gas
Free" and "Danger".
4.2.8 
Open Excavations
After the tank is removed, the tank grave should be immediately backfilled. If the tank grave is
left open overnight, the perimeter of the opening must be conspicuously identified with "Caution-
Open Excavation" tape.
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4.2.9 
Static Electricity
When transferring, a metal-to-metal bond must be established between the tank being emptied
and the drum being filled through the use of grounding cables to prevent discharge sparks of
static electricity. Pump motors and suction hoses must also be bonded to the tank (or otherwise
grounded) to prevent electrostatic ignition hazards.
4.2.10 
Use of a Vac-Truck to Pump Tank Contents
If a vacuum truck is used to remove the tanks contents, it must be operated in a vapor-free area.
The vac-truck should be Icoated upwind from the tank and outside of the path of vapor
dispersion. The vacuum pump exhaust gases should be discharged through a hose of adequate
size and length, downwind of the truck and tank area.
If it becomes necessary to remove residual liquids from the tank with a hand pump, the pump
must be either air-driven or approved for use in Class 1, Division 1 atmospheres.
4.2.11 
Flammability Concerns
Although not flammable, waste oils are combustible liquids (flash point greater than 100°F). As
a precautionary measure, the inside of the tank will be monitored using a combustible gas
indicator (CGI) for the presence of explosive atmospheres (see Section 5.1). After the tank
contents have been removed, the tank will be screened using the CGI. Since waste oil vapors
are heavier than air, the tank must be screened at the top, middle and bottom portions. Readings
of 10% or less of the lower explosive limit (LEL) must be obtained before the tank can be
removed from the ground. If the atmosphere within the tank exceeds 10% of the LEL, dry ice will
be introduced into the tank to inert it. Successful inertion is defined as an oxygen level of less
than 10%. By displacing the oxygen with the carbon dioxide given off by the dry ice, the
atmosphere becomes incapable of sustaining a flame. The atmosphere will be oxygen-deficient
which is important to remember if employees plan to enter the tank after it is inerted. The CGI
used on this project will be a combination unit that contains an oxygen meter to determine
successful inertion. The tanks atmosphere will be monitored continuously for explosive
concentrations.
All vapors must be vented at a minimum height of 12 feet above grade and 3 feet above any
adjacent roof lines.
In addition to the monitoring, only spark-proof tools will be used during the removal of the piping
7218-001-200 
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and the tanks.
4.2.12 
Entry into a Tank Grave
If possible, ENSR will use remote sampling techniques or equipment (long-handled soil scooper)
to collect samples from the bottom of the tank graves. If entry into a tank grave is necessary the
following entry precautions must be implemented:
If entry into the tank grave that is greater than 4 feet in depth is required, a ladder or similar
means of egress must be located in tank grave so as to require no more than 25 feet of lateral
travel for employees. No person shall enter a tank grave greater than five feet in depth unless
the walls of the excavation have been sloped back to an angle of 34 degrees, the excavation is
free of accumulated water and the excavation has been tested for hazardous atmospheres
(oxygen deficient, toxic and explosive atmospheres).
The tank grave can be entered only if the following criterion have been met:
O2 level 
> 19.5%
LEL 
< 10%
total organics 
< 25 units on HNu
If the first two criterion are met but the total concentration of organic compounds exceeds 25
units, respiratory protection, as described in Section 6.2, can be donned. Under no
circumstances will the tank grave be entered if an oxygen deficient atmosphere exists.
If personnel enter a tank grave, all materials shall be placed at least two feet from the edge of
the excavation to prevent the material from rolling into the excavation. All personnel should
remain two feet away from the edge of the excavation.
If the contractor chooses to use temporary shoring instead of sloping the sides of the excavation,
the shoring must comply with the provisions of the new OSHA standard.
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5.0 AIR MONITORING
Instrument 1: HNu Photoionization Detector with a 10.2 ev lamp
An HNu photoionization detector (PID) equipped with a 10.2 ev lamp will be used to screen the
soils in the tank graves for the presence of total organic vapors.
If the instrument does detect the presence of organic vapors in the soils, the breathing zone of
employees will be screened. If organic vapors are sustained (15 minutes) in the breathing zone
of employees at levels of 25 units above background, Level C respiratory protection, as defined
in Section 6.2 will be donned.
Instrument 2: Combustible Gas Indicator/Oxygen Meter
A combination combustible gas indicator/oxygen meter will be used to detect the presence of
a potentially explosive atmosphere inside the tanks. If the lower explosive limit (LEL) measured
in the tank is greater than 10%, the vapors must be allowed to dissipate before contents removal
and cleaning can begin. If the vapors do not dissipate, the tank may need to be ventilated or an
inert gas such as carbon dioxide (dry ice) or nitrogen may have to be pumped into the tank to
displace the oxygen. Displacing the oxygen will prevent explosion hazards, but creates an
oxygen deficient atmosphere that could only be entered by an employee equipped with supplied-
air respiratory protection. Successful inertion is indicated by an O2 level of less than 10%.
It is important to monitor the top, middle and bottom portions of the tank, since the vapors of
waste oils are heavier than air and are likely to settle in the bottom of the tank.
The atmosphere inside the tanks will be monitored with the CGI on a regular basis before
removal and while the tank remains on-site.
If entry into the tanks is necessary, it is the responsibility of the subcontractor to provide and
perform the necessary air monitoring to allow for safe entry into a confined space.
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6.0 
PERSONAL PROTECTIVE EQUIPMENT
Personal protective equipment (PPE) will be donned as described below for the tasks covered
by this HASP to protect employees from coming in direct contact with septic tank contents.
It is the responsibility of the subcontractor to identify the necessary PPE if entrv into the tanks
is necessary.
6.1 
Protective Clothing
1. Hard Hat
2. Safety Glasses or Faceshield
3. Steel-toed boots
4. Poly coated Tyvek coveralls (if product saturated materials are encountered)
5. Latex gloves
6. Nitrite gloves
Pumping of Tank Contents/Sampling Tank Contents/Cleaning of Tank Interior
Items: 2,3,4,5,6
Items 4,5, and 6 may not be necessary during the pumping of the tank if a closed-loop pumping
system is used. In this case the potential to come into contact with the tank contents is greatly
minimized. Any time there is a potential to come into direct contact with the tank contents
(changing valves, hoses, etc), the above listed items should be worn.
A faceshield offers more protection from splash hazards than safety glasses.
Soil Boring/Sample Collection
Items: 1,2,3,5,6
Sample Equipment Decontamination
Items: 2,5,6
If operating equipment is steam cleaned, a rain suit, rubber boots or boot covers and faceshield
7218-001-200 
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08/03/93 (Tue) 4:58pm
should be worn to protect from splashing.
6.2 
Respiratory Protection
Level C: 
Half mask air purifying respirators with organic vapor cartridges
This level of protection will be worn when the following concentrations are sustained in the
breathing zone of employees:
• 
25 units on the HNu
Employees who are expected to wear respiratory protection must have successfully passed a
qualitative or quantitative fit-test within the past year for the brand, model and size respirator they
plan to wear on this project.
Respiratory protection can be donned at any time that odors become objectionable.
It is the responsibility of the subcontractor to define the level of respiratory protection
required if entry into the tank is necessary.
6.3 
Other Safety Equipment
ENSR will bring the following additional safety equipment to the site:
• 
First aid kits
• 
Portable, hand-held eyewash bottle (in the event of splashing during decontamination
of sample equipment or foreign object gets into the eye)
• 
Type A-B-C fire extinguisher
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7.0 SITE CONTROL
To prevent potential exposure of unprotected personnel to the physical hazards associated with
the tank closure, work areas and associated personal protective equipment requirements will be
clearly identified.
7.1 
Work Zones
ENSR designates work areas or zones as suggested in the "Occupational Safety and Health
Guidance Manual for Hazardous Waste Site Activities," NIOSH/OSHA/USCG/EPA, November,
1985. They recommend the areas surrounding each of the work areas to be divided into three
zones:
o Exclusion or "Hot" Zone
o Contamination Reduction Zone (CRZ)
o Support Zone
Exclusion Zone
Each of the two tanbk removal areas will be considered exclusion zones. These areas will be
demarcated with Caution tape or red traffic cones to alert employees and patrons of the plaza.
All personnel entering the exclusion zones must wear the prescribed level of protective
equipment for the task they are performing.
Contamination Reduction Zone
One CRZ will be established in an area that is central to both tank removal locations. Employees
will remove contaminated, disposable clothing (if worn) in these areas before getting into field
vehicles or leaving the site for lunch or the end of the day. Clothing will be placed in plastic bags
and left in the CRZ until disposed of. A container of wash water and liquid soap will also be
available in CRZ for clean-up by employees.
Support Zone
This area will be used to store extra sampling equipment and personal protective equipment. The
zone shall be set up in an area of the plant that will not interfere with the normal operations of
the facility.
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7.2 
Protective Measures
The following measures are designed to augment the specific health and safety guidelines
provided in this plan.
• 
The "buddy system" will be used at all times by all field personnel. All sampling
team members must be intimately familiar with the procedures for initiating an
emergency response.
• 
Eating, drinking, chewing gum or tobacco, smoking or any practice that increases
the probability of hand-to-mouth transfer and ingestion of materials is prohibited in
the exclusion and decontamination zones.
• 
Hands and face must be thoroughly washed upon leaving the work area and before
eating, drinking or any other activities.
• 
Beards or other facial hair that interfere with respirator fit are prohibited.
• 
The use of alcohol or illicit drugs is prohibited during the conduct of field
operations.
• 
All equipment must be decontaminated or properly discarded before leaving the
site.
• 
Safety equipment described in Section 6.0 will be required for all field personnel
unless otherwise approved by the Regional Health and Safety Manager (RHSM) or
the Site Safety Officer (SSO).
• 
Ground fault circuit interrupters will be used in conjunction with all power cords on-
site.
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8.0 DECONTAMINATION
Proper decontamination is required of all personnel and equipment before leaving the site.
Personnel decontamination will be accomplished by following a systematic procedure of
removing personal protective clothing (PPE).
The central CRZ will be set up as described in Section 7.0. Disposable PPE, such as Tyvek
coveralls, gloves, etc. will be disposed of in plastic-lined garbage cans and labeled "PPE". Bags
will be disposed of in accordance with the work plan and client requirements.
A cooler of potable water will be available in the CRZ and will be dedicated for hand and face
washing. Liquid soap and hand towelettes will be available. This water can also be used to rinse
respirator facepieces. If worn, respirators will be cleaned after each use and stored in plastic
bags after cleaning.
The decontamination procedure is as follows:
1. Remove hard hat, safety glasses and wipe clean
2. Remove Tyvek coverall (if worn)
3. Remove outer pair of gloves
4. Remove respirator (if worn)
5. Remove inner pair of gloves
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9.0 MEDICAL MONITORING/TRAINING REQUIREMENTS
9.1 
Medical Monitoring
All personnel performing activities on this site covered by this HASP must be active participants
in ENSR's Medical Monitoring Program. Each ENSR individual must have completed an annual
surveillance examination and/or an initial baseline examination within the last year prior to
performing any work on the site covered by this HASP. All subcontract employees must minimally
participate in a medical monitoring program that meets the requirements of OSHA's respiratory
protection standard, 29 CFR 1910.134.
9.2 
Training
Additionally, all personnel performing activities on this site covered by this HASP must have
completed the appropriate training requirements specified in 29 CFR 1910.120(e). Each ENSR
individual must have completed an annual 8-hour refresher training course and/or initial 40-hour
training course within the last year prior to performing any work on the sites covered by this
HASP. Also, onsite ENSR managers and supervisors directly responsible for supervising
individuals engaged in hazardous waste operations must have completed the specified 8-hour
managers training course. (Note that ENSR corporate policy requires that whenever three or
more ENSR employees are performing work on the same site, at least one of these individuals
must have completed the manager's training course.)
Although not required under 29 CFR 1910, it is recommended that one person qualified in First
Aid and CPR be present during all site work.
If confined space entry is to be performed, the subcontractor must provide documentation
indicating proper employee training.
Subcontractors to ENSR will be required to provide to the ENSR Project Manager (PM) specific
written documentation that each individual assigned to this project has completed the medical
monitoring and training requirements specified above. This information must be provided prior
to their performing any work on site.
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9.3 
Pre-Entry Briefing
Prior to the commencement of closure activities, a site safety meeting will be conducted by the
SSO to review the specific requirements of this HASP. HASP sign-off sheets will be collected at
this meeting. Short safety refresher meetings will be conducted, as needed, throughout the
duration of the project. Attendance of this meeting will be documented. An attendance sign-in
form is presented in Attachment C.
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10.0 
EMERGENCY RESPONSE
OSHA defines emergency response as any "response effort by employees from outside the
immediate release area or by other designated responders (i.e., mutual-aid groups, local fire
departments, etc.) to an occurrence which results, or is likely to result in an uncontrolled release
of a hazardous substance." According to ENSR policy, ENSR personnel shall not participate in
any emergency response where there are potential safety or health hazards (i.e., fire, explosion,
or chemical exposure). ENSR response actions will be limited to evacuation and medical/first aid
as described within this section below. As such this section is written to comply with the
requirements of 29 CFR 1910.38 (a).
The basic elements of an emergency evacuation plan include employee training, alarm systems,
escape routes, escape procedures, critical operations or equipment, rescue and medical duty
assignments, designation of responsible parties, emergency reporting procedures and methods
to account for all employees after evacuation.
Employee Training: General training regarding emergency evacuation procedures are included
in the ENSR initial and refresher training as described above in Section 9.2 of this Health and
Safety Plan (HASP). Also as described above in Section 9.3, employees must be instructed in
the specific aspects of emergency evacuation applicable to the site as part of the site safety
meeting prior to the commencement of all on-site activities. On-site refresher or update training
is required anytime escape routes or procedures are modified or personnel assignments are
changed.
Alarm Systems/Emergency Signals: An emergency communication system must be in effect
at all sites. The most simple and effective emergency communication system in many situations
will be direct verbal communications. Each site must be assessed at the time of initial site
activity and periodically as the work progresses. Verbal communications must be supplemented
anytime voices can not be clearly perceived above ambient noise levels (i.e., noise from heavy
equipment; drilling rigs, backhoes, etc.) 
and anytime a clear-line-of-sight can not be easily
maintained amongst all ENSR personnel because of distance, terrain or other obstructions.
Verbal communications will be adequate to warn employees of hazards associated with the
immediate work area.
Escape Routes and Procedures: ENSR will confirm with facility representatives how ENSR
personnel should evacuate from the property and where ENSR personnel should assemble after
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evacuating the site.
Rescue and Medical Duty Assignments: 
The phone numbers of the police and fire
departments, ambulance service, local hospital, and ENSR representatives are provided in the
emergency reference sheet which will be posted in the site vehicle. In the event an injury or
illness requires more than first aid treatment, the SSO will accompany the injured person to the
medical facility and will remain with the person until release or admittance is determined. The
escort will relay all appropriate medical information to the victim's supervisor and the RHSM.
If the injured employee can be moved from the accident area, he or she will be brought to the
CRZ where their PPE will be removed. If the person is suffering from a back or neck injury the
person will not be moved and the requirements for decontamination do not apply. The SSO must
familiarize the responding emergency personnel about the nature of the site and the injury. If the
responder feels that the PPE can be cut away from the injured persons body, this will be done
on-site. If this not feasible, decontamination will be performed after the injured person has been
stabilized.
Designation of Responsible Parties: The SSO is responsible for initiating emergency response.
In the event the SSO can not fulfill this duty, the alternate SSO will take charge. All personnel
onsite are responsible for knowing the escape route from the site.
Employee Accounting Method: The on-site project manager is responsible for identifying all
ENSR personnel on-site at all times. On small, short duration jobs this can be done informally
as long as accurate accounting is possible. On all other sites a formal log-in and log-out
procedure must be implemented. In the event of a terminal emergency, the SSO shall report to
the person in charge of evacuation that all ENSR and subcontract employees have left the work
area.
Accident Investigation and Reporting: Any incident (other than minor first aid treatment)
resulting in injury, illness or property damage requires an accident investigation and report. The
investigation should be conducted as soon as emergency conditions are under control. The
purpose of the investigation is not to attribute blame but to determine the pertinent facts so that
repeat or similar occurrences can be avoided. An ENSR accident investigation form is presented
in Attachment D of this HASP. The injured employee's supervisor and the RHSM should be
notified immediately of the injury.
7218-001-200 
10-2 
08/03/93 (Tue) 4:58pm
EMERGENCY REFERENCE
Ambulance Rescue Service: to be determined by PM
Fire: 
to be determined by PM
Police: 
to be determined by PM
Hospital: 
809-774-1321
St. Thomas Hospital and Community Health Service
Hospital Line
Charlotte Amalie, USVI
Directions to the Hospital: 
To be determined upon arrival to the site
NATIONAL RESPONSE CENTER: 
1 -800-424-8802
ENSR REPRESENTATIVES:
ENSR/SAN JUAN, PUERTO RICO 809-753-9509
-Robert Fuhrer(PM)
ENSR/ACTON, MA 
508-635-9500
-Kathleen Harvey (RHSM) 
x 3325
7218-001-200 
10-3 
08/03/93 (Tue) 4:58pm
ATTACHMENT A
HASP SIGN-OFF SHEET
7218-001-200 
08/03/93 (Tu«) 4:58pcn
Health and Safety Plan
for
Removal/Closure of Two Underground Storage Tanks
Four Winds Plaza
Western Auto
St.Thomas, United States Virgin Islands
ENSR PROJECT NUMBER: 7218-001-200
I the undersigned have received a copy of the above referenced document. I have read this
document and understand its contents and requirements. I agree to abide by the requirements
of this health and safety plan.
Signature
Date
Representing
7216-001-200 
06/03/93 (Tu«) 4:58fxn
ATTACHMENT B
MATERIAL SAFETY DATA SHEETS
7218-001 -200 
08/03/93 (Tu«) 4;58pm
ATTACHMENT C
PRE-ENTRY BRIEFING ATTENDANCE SHEET
7218-001-200 
08/03/93 (Tu») 4:58pfn
ENSR HEALTH AND SAFETY PLAN PRE-ENTRY BRIEFING ATTENDANCE FORM
FOR THE
Tank Removal and Closure
Four Winds Plaza
Western Auto
United States Virgin Islands
Briefing Conducted
Date Performed:
Printed Name
Signature
Representing
7218-001-200
08/03/93 (Tu«) 4:58pm
ATTACHMENT D
ACCIDENT INVESTIGATION FORM
7218-001-200 
08/03/93 (Tu«) 4:58pfn
H&SSOPNO: 4.2
ENSR Consulting and Engineenng
ATTACHMENT 8.1 - SUPERVISOR'S ACCIDENT INVESTIGATION REPORT
injured Employee ____________________ Job Title _______________
Home Office ________________ Division/Department _________________
Date/Time of Accident
Location of Accident
Witnesses to the Accident ________
injury Incurred? ____ 
Nature of Injury
Engaged in What Task When Injured?
Will Lost Time Occur?
How Long?
Date Lost Time Began
Were Other Persons Involved/Injured?
How Did the Accident Occur?
What Could Be Done to Prevent Recurrence of the Accident?
What Actions Have You Taken Thus Far to Prevent Recurrence?
Supervisors Signature
Reviewer's Signature _
Title
Date
Title
Date
NOTE: IF THE SPACE PROVIDED ON THIS FORM is INSUFFICIENT, PROVIDE ADDITIONAL
INFORMATION ON SEPARATE PAPER AND ATTACH. THE COMPLETED ACCIDENT INVESTIGATION
REPORT MUST SUBMnTED TO THE REGIONAL HEALTH AND SAFETY MANAGER WTTHIN FIVE
DAYS OF THE OCCURRENCE OF THE ACCIDENT.
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H«vwwnO: MareftlS. 1991