Health and Safety

Training/Certifications and Medical Monitoring

OSHA Hazardous Waste Operations and Emergency Response (HAZWOPER) training, First Aid/Cardiopulmonary resuscitation (CPR) training, and medical monitoring are required.

Site-specific Health and Safety Plan (HASP)

Required for field work.

Personal Protective Equipment (PPE)

Workers should have the correct PPE for intended tasks.

Transportation

Safety should be considered while driving to and from the site, and while onsite. Traffic control may be required to reduce risks when working in roadways. High visibility safety vests are recommended.

Dust

Mitigation may include control methods such as covering sources and misting sources with water.

Noise

Refer to 29 CFR 1910 for occupational noise exposure standards and specifics. Identify any local noise ordinances depending on jurisdiction and zoning.

Vapor

Mitigation may include minimizing exposure and monitoring potentially hazardous atmospheres for workers and the public. Engineering and construction practices to reduce vapor emissions may include removal of Light Non-Aqueous Phase Liquid (LNAPL), covering stockpiles and excavations, misting excavations or stockpiles with water, covering stockpiles or excavations with foam or other vapor-suppressing agents, and locating stockpiles away from and/or downwind of public receptors. Additionally, vapor mitigation may include emission controls on mechanical remediation systems.

Chemical Exposure

Chemical exposure can occur via inhalation, ingestion, and dermal contact. These pathways, potential exposure scenarios, and how to prevent them should be discussed in the HASP.

Underground Utilities and Infrastructure

Prior to ground disturbance, Colorado requires contacting Colorado 811 to mark public underground utilities. The following colors indicate the type of public utility:

• Red = Electric
• Yellow = Gas
• Blue = Potable water
• Orange = Communication lines such as cable TV or internet
• Purple = Reclaimed water, irrigation and slurry Lines
• Green = Sewers and drain lines
• Pink = Temporary survey markings
• White = Proposed excavations or drilling by consultants

In addition, and/or private utility locating may be utilized to locate underground utilities and infrastructure. Remote sensing methods such as ground-penetrating radar (GPR) and electromagnetic (EM) surveys may also be useful. Knowing expected depths of utilities or infrastructure is vital in determining the required depth of potholing or remote sensing. OPS requires retaining the results of utility location efforts in detailed measurements, maps, and photographs to minimize recurrent/redundant efforts to locate them.

Knowledge of the installation of fuel storage and delivery systems helps personnel identify where such infrastructure (USTs, product lines, vent lines, and cathodic protection systems) may be buried. Observation of pavement repairs, meter/valve boxes, and sprinkler system components are critical in identifying infrastructure.

Overhead Utilities

It is important to determine the voltage of electrical utilities within the work area. Controls may include de-energizing and line insulation. Best management practices (BMPs) recommend a 10-foot minimum clearance for overhead power lines. Some utilities may be able to temporarily cover overhead electrical wires to prevent grounding.

Local Construction Codes and Permits

Local and city jurisdictions may require additional permitting and code requirements.

Tank Removal

Know proper procedures to safely remove and dispose of a decommissioned petroleum storage tank. Coordinate with the local fire department. (EPA UST Regulations)

Open Excavation

Safety efforts may include benching, fencing and/or caution tape. Refer to state and local regulations for shoring or construction dewatering requirements.

Heavy Equipment Use

Operator visibility may be marginal. Workers approaching or working around heavy equipment should exhibit extreme care and always be aware of their surroundings.

Confined Space

OSHA permit and non-permit requirements are in 29 CFR 1910.146. In addition, OSHA Appendices A through F (examples include decision flow chart, atmospheric testing, and pre-entry check list) provide information and non-mandatory guidelines to assist employers and employees in complying with the appropriate requirements.

Division of Water Resources

Drilling and well construction requirements, permitting, and reporting.

Explosion and Fire Hazard

Work areas must be monitored to evaluate the potential for explosion or fire hazards. An explosive environment is one containing 20% or greater of the lower explosive limit (LEL). Note that LEL measurements assume a normal oxygen concentration is present. Spark and ignition sources should be avoided when an explosive environment is possible. Understanding of National Fire Protection Association (NFPA) codes 30 and 30A for flammable materials and National Electrical Code (NEC) Articles 500 through 516 are necessary for design and installation of powered equipment.

Spill Prevention, Control, and Countermeasure (SPCC) Plans

See 40 CFR Part 112 for pollution prevention at AST sites.

Stockpiled Soil

Management may include containing and covering soil stockpiles to prevent runoff and vapor or dust exposures, and locating stockpiles in secure areas. State and/or local stormwater management plans may be required.

Stormwater Management / Sewer Discharges

Implement BMPs to control surface runoff to prevent or minimize transport of pollutants to receiving waters. BMPs may include the use of hay bales, hay socks, sand bags, and high-density polyethylene plastic to cover inlets. In some cases, a National Pollutant Discharge Elimination System (NPDES) permit may be required.

Investigation-Derived Waste (IDW)

IDW can include soil, water, and sludge. Contaminated waste material must be handled properly to manage risk of future exposures. Refer to Section 9 of this guidance.

Waste Handling

Proper handling, storing, and labeling of hazardous materials and wastes under 29 CFR 1200 and Department of Transportation (DOT) regulations.

Additional Permitting

EPA Underground Injection Control (UIC) and Air Pollutant Emission Notice (APEN) regulations.