L3 Communications Sampling PlanA

LANDERS LOGISTICS, INC. L3 COMMUNICATIONS SAMPLING PLAN

L3 Communications Sampling Plan

I. IntroductionLanders Logistics, Inc. understands that the collection of accurate and representative samples is

one the first and most critical steps towards the generation of accurate laboratory analytical data. Landers Logistics, Inc. has the experience and depth of resources to ensure that the samples we collect are representative and legally defendable. Our sampling programs are driven by established protocols and extensive Quality Assurance/Quality Control (QA/QC). Our mission is to improve the environmental quality of our community by partnering with area businesses, community leaders and neighbors to work together to create a clean and safe place to live and work for future generations.

A. PurposeThe purpose of this sampling plan is to define the requirements and procedures for collecting

samples of the industrial wastewater discharge from L3 Communications (L3) located at 3801 Campus Drive Waco, Texas 76705. Landers Logistics, Inc. has been contracted to collect samples to ensure that L3 is in compliance with effluent limitations determined by the Clean Water Act, Texas Commission on Environmental Quality (TCEQ) regulations and City of Waco local ordinance CH 26 Art. VI listed in the City of Waco Industrial Wastewater Discharge Permit TX-10494-520-13 of October 20, 2013 issued to L3 Communications.

B. Background Information L3 Communications site is located at 3801 Campus Drive in Waco, Texas. This site is on the

back half of the Texas State Technical College Campus and adjacent to the TSTC Airport. (See Appendix A: Entire L3 Communications Site Map)

Latitude: 31.630448/ DMS Latitude: 31o 37’ 49.6128” N Longitude: -97.078216/ DMS Longitude: 97o 4’ 41.5776” W

Originally, the facility was built in 1984 to serve as a one-hangar overflow facility for the Richardson, Texas-based Electrospace Systems, Inc. (ESI), which had been leasing space at Dallas' Love Field for aircraft modification. In the more than 20 years of operations, the Waco facility has modified hundreds of aircraft of many different types. From the nation's most advanced command-and-control aircraft to luxurious widebody jets for international heads-of-state, the L-3 facility in Waco has produced aircraft recognized throughout the world. The company employs more than 1,600 people, and also hosts several hundred other government and contractor employees who regularly work at the facility and live in the area. In 2002, Raytheon Aircraft Integration Systems sold to L-3 Communications, and the site was renamed L-3 Communications Integrated Systems.

Today the Waco site is the leading full service aircraft manufacturing center. Onsite, the following processes occur in different departments of the facility.

L3 COMMUNICATIONS SAMPLING PLAN 1


Manufacturing Services (See Appendix C) include:- Sheet metal fabrication

- Machining fabrication

- Finishing shop

- Mechanical assembly

- Electrical assembly

- Cable and harness assembly

- Electrical testing

- Fiberglass and composite fabrication

- Graphics fabrication

- Cabinet shop

- Rapid prototyping

Modification Hangar Services (See Appendix E) include:- Air craft component backshops

- Tool Storage

- Kit/material storage for work in progress

Widebody Hangar Services (See Appendix F) include:- General modifcication/maintenance facility

- Auxiliary paint hangar

- Government-furnished material storage

Prior to 1984, this site was James Connally Air Force Base, and was initially a basic pilot-training school. It opened as Waco Army Air Field on May 5, 1942, and became headquarters for the Army Air Force Central Instructors' School in February 1945. The base was inactive from late 1945 to 1948, when it was reactivated as a basic pilot-training school. On June 10, 1949, the name was changed to Connally Air Force Base. By 1951 the name had been changed to James Connally Air Force Base, and all pilot training had been discontinued. Training for navigators, radar operators, and bombardiers began in June. The Instrument Pilot Instructors School was subsequently moved to the base and trained instructor pilots from many allied nations. The school also trained officer pilots as radar operators and navigators to provide triple-rated aircraft commanders for the rapidly growing fleet of B-47s. That program was discontinued in 1962. In January 1966 the Tactical Air Command assumed control of the base for headquarters of the Twelfth Air Force. The base was purchased by the state of Texas after the Twelfth Air Force moved its headquarters to Bergstrom Air Force Base at Austin.

Texas State Technical College (TSTC) was established in 1965 as the James Connally Technical Institute (JCTI) of Texas A & M University at the former James Connally Air Force Base. In 1969, the college separated from Texas A&M University and became an independent state system, with the name Texas State Technical Institute (TSTI) and its own Board of Regents. In 1991, the Texas Legislature elevated the status of the institution by designating it a two-year technical college with



the name Texas State Technical College. Texas State Technical College is still located, and in operation on the front half of the property located at 3801 Campus Drive in Waco, Texas.

Quarterly sampling of industrial wastewater outfalls for compliance testing has been performed by Landers Logistics, Inc. since 2009 when the Platform Integration division and headquarters established in Waco, Texas. Previous results are available upon written request, with the expressed written permission of L3 Communications, or by a subpoena deuces cecum only. Landers Logistics, Inc. and L3 Communications have a legal binding contract to collect samples for testing of the following analytes:

Arsenic Biological Oxygen Demand (BOD) Cadmium Chromium Lead Nickel Oil and Grease Products Total Suspended Solids (TSS) Zinc

II. ObjectivesThe ultimate goal of this sampling plan is to ensure that L3 Communications is in compliance

with the Clean Water Act, TCEQ regulations, the effluent limitations of the City of Waco Industrial Wastewater Discharge Permit TX-10494-520-13 issued October 20, 2013, and the City of Waco Ordinance Chapter 26 Article 6.

Landers Logistics, Inc. is dedicated to reaching this goal through: Use grab samples from specific industrial wastewater outfall sites for sampling of

analytes. Following SW 846 EPA test methods for collection and preservation of liquid samples. Follow strict Quality Control measures to ensure the accuracy of all sampling test results

to within a +/- 0.05% level of accuracy or the level of accuracy defined within the SW 846 EPA test methods guidelines (whichever is more strict).

Accurate documentation of Chain of Custody forms. Prompt, accurate and confidential reporting of all laboratory results to L3

Communications and other regulatory agencies.

III. Sampling Sites and DescriptionsLanders Logistics, Inc. will send a field sampling technician to the following sites to collect grab

samples for the purpose of testing. No other outfall sites will be accessed by the field sampling technician. Any outfall site that is within the gated/secured area of the L3 Communications property will be accessed by first stopping at the security checkpoint at the main entrance to the facility. He/she shall be accompanied by an L3 escort at all times while collecting samples. The field



technician is not authorized to access any other area of the property. Unauthorized access to any area of the L3 Communications property by the Landers Logistics, Inc. field sampling technician will result in immediate legal and disciplinary action by Landers Logistics, Inc., L3 Communications, and the Department of Defense and could be seen as an act of treason.

Outfall Sites to be Accessed: A. Manufacturing/Maintenance Outfall Site (See Appendix B: L3 Manufacturing Services

Building Map) - GPS Latitude: 31.630329 Longitude: -97.079404. Outside of the security fence. Located west of the Manufacturing/Maintenance Hangar at the corner of 15th St. and Airline Drive. This outfall site is an elevated manhole with a concrete 5 inch pad surrounding the opening. The interior structure of the manhole is brick with a 12 foot drop from the surface opening to the collection channel.Analytes to be tested from this outfall site:

BOD Lead Nickel Oil and grease products TSS Zinc

B. Modification Hangar Outfall Site (See Appendix D: L3 Site Map of Other Buildings) – GPS Latitude: 31.628546 Longitude: -97.065180. Inside the secured area. Located in the southwest corner of the Modification Hangar-approximately 40 feet from the employee parking lot into the field adjacent to the hangar. This outfall site is an elevated manhole with a concrete 5 inch pad surrounding the opening. The interior structure of the manhole is brick with a 12 foot drop from the surface opening to the collection channel.Analytes to be tested from this site:

Cadmium Oil and grease products TSS

C. Widebody/Paint Booth Outfall Site (See Appendix D: L3 Site Map of Other Buildings) – GPS Latitude: 31.631040 Longitude: -97.065180. Inside the secured area. Located on the east side of the Widebody Hangar between the building and Maehr Road- approximately 20 feet from the building. This outfall site is an elevated manhole with a concrete 5 inch pad surrounding the opening. The interior structure of the manhole is brick with a 12 foot drop from the surface opening to the collection channel.Analytes to be tested from this site:

Arsenic BOD Cadmium Chromium



Lead Nickel Oil and grease products TSS Zinc

IV. Field Measurements and Analyte Testing

A. Field MeasurementsImmediately upon obtaining a grab sample from the outfall, specific measurements are to be

performed by the Landers Logistics, Inc. field sampling technician. These measurements are to be performed using the Hach sensION+ PH1 basic portable meter (see Fig.1).

This meter must be calibrated at the beginning of each shift by the Landers Logistics, Inc. field sampling technician. Calibration of this meter must be documented in the field logbook. The technician must collect sample readings for Temperature, pH, and Conductivity onsite. These results are to be recorded on the sample collection form, and the laboratory Chain of Custody form where indicated. Calibration instructions, proper use of the meter and troubleshooting techniques may be referenced in Appendix H: HACH User Manual.

B. Laboratory Analyte AnalysisIn order to ensure the legal validity of testing results, Landers Logistics, Inc. uses only EPA

approved testing methods for analysis of industrial wastewater sampling. These methods are approved procedures for measuring the presence and concentration of physical and chemical pollutants; evaluating properties, such as toxic properties, of chemical substances that are regulated under the authority of the Clean Water Act (CWA). L3 Communications has contracted with Landers Logistics, Inc. to test for specific analytes as required in the City of Waco Industrial Wastewater Discharge Permit TX-10494-520-13. These specific analytes, the EPA method used for testing, the permitted effluent limitations, and the outfall at which each analyte will be tested for are as indicated in Table 1.


Fig. 1 HACH sensION+ Portable Meter


Table 1.Analyte EPA Test Method Max. Effluent Limit Outfall

Arsenic 6020A 0.01 mg/L CBiological Oxygen Demand 5210B 65 mg/L A,CCadmium 6020A 0.05 mg/L B,CChromium 6020A 0.5 mg/L CLead 6020A 0.5 mg/L A,CNickel 6020A 0.5 mg/L A,COil and Grease Products 1664A 200 mg/L A,B,CTotal Suspended Solids 160.2 65 mg/L A,B,CZinc 6020A 0.05 mg/L A,C

V. Field DocumentationAll Landers Logistics, Inc. field sampling technicians are required to properly document all

aspects of the sample collection process. The goal of Landers Logistics, Inc. is to document effectively from start to finish and delivery of the sample to the receiving laboratory. Proper documentation ensures the legal validity of samples and the integrity of the company. Proper documentation includes all of the following:

Field Log Book - the day-to-day activities of all Landers Logistics, Inc. field sampling technicians are to be documented and maintained in their Log Book. This book must be a bound notebook with pre-printed lines and consecutively numbered pages. All entries must be in black ball-point pen (NO GEL INK). If the technician makes an error, a single line should be drawn through the entry and should be initialed. The following information is to be documented in the log book on a daily basis:

- Date in mm/dd/yyyy format

- Vehicle Mileage

- Time of entry using 24-hour (military time) format

- Project ID #

- Client information: Name, Address, Phone.

- Site of Collection

Site Name Site Address Site GPS Coordinates

- Sampling Point Information

Description of site including current weather conditions Site Sketch or Photographs Site Set-up Methods Site Clean-up Methods

- Samples Collected (Waste water, drum samples, sludge, soil…etc.)

- Field Measurement Calibration Record



- Field Measurements Taken (This is the list of the measurements that will be taken

by the technician onsite—not the test results).- List of the provided containers for sample collection with any preservatives

- Condition of samples after collection

- Transportation and shipping methods (i.e. placed in a cooler, rack, or shipping

container for transport to laboratory)- Delivery and transfer of custody to the receiving Laboratory information

Date Time Receiving Laboratory Receiving Personnel

Chain of Custody Forms - it is the policy of Landers Logistics, Inc. that a completed chain of custody form must accompany samples at all times. This is the process of tracking the samples possession from the time of collection to delivery at the receiving laboratory. This document must be signed by each person involved in the process. This document also ensures that the sample has not been tampered with or altered in any way. All collected samples are to be under lock and key or secure seal and in the custody of ONE person at all times. A copy of the required Chain of Custody form provided by the EMSL Analytical, Inc. contracted laboratory may be referenced in this document. (See Appendix I: Environmental Chemistry Chain of Custody).

Sample Collection Form - it is the policy of Landers Logistics, Inc. that a sample collection form accompany all samples delivered to the laboratory. The sampling technician must complete this form using the information documented in the field sampling Log Book as indicated on the form. A copy of the required Sample Collection Form may be referenced in this document. (See Appendix J: Sample Collection Form).

Sample ID Labels - it is the policy of Landers Logistics, Inc. that all samples must be immediately labeled upon collection. All labels must be affixed to the front of the collection container and completed in fine point black permanent maker. (See Fig.2).


Sample ID: ____________________________

Sample Location: _______________________

Test Method: __________________________

Preservative: __________________________

Date: ________ Time: ________ Init: _______Fig. 2 Sample ID Label


Label Requirements:

1. Size- 3” x 2”2. White Background3. 100 Labels per roll4. Peel-off, stick-on5. Writeable with permanent pen

VI. EquipmentAll Landers Logistics, Inc. field sampling technicians are required to have the necessary

equipment needed for site preparation, collection of the sample, site clean-up, equipment decontamination, spill clean-up measures, personal protection equipment and specimen preservation on-hand and on-site when collecting samples. All supplies must be properly maintained, stored, transported, and stocked on the Landers Logistics, Inc. sampling truck. It is the responsibility of Landers Logistics, Inc. to provide all the equipment necessary for the proper collection of samples from the L3 Communications outfall sites. The required equipment is as follows:

Hardware Solinist Model 410 Peristaltic Pump HACH sensION+ Portable Meter 1/4" OD x 0.17" ID LDPE Tygon Tubing (500 ft coil) Tubing weight 12 Volt Battery Industrial Strength Trash Bags Thermo Scientific Nalgene polypropylene wide-mouth bottle, 1 L

6 bottles/pk. 10’ Visqueen Plastic Roll, cut into 10’x10’ sections De-Ionized Water Manhole Puller Crowbar

Personal Protective Equipment Gloves 2-3 boxes of desired size (XS,S,M,L,XL) Face Shield Steel-Toed Work Boots Basic First Aid Kit Insect Repellant Sunblock 1 Case Bottled Drinking Water



Electronics Global Positioning System (GPS) Receiver Handheld 2-way Radio

Spill Kit Supplies 10 Gallon Bucket with a Lid 1.5 Cubic Foot Bag of Absorbent Small Broom and Dust Pan Set

Site Control Equipment 1 Roll of Yellow “CAUTION” tape 6 Orange Caution Triangles

Laboratory Provided Supplies Specimen Cooler Gel Ice Packs Shipping Container if needed Specimen Preservatives Specimen Security Seal Stickers

VII. Collection Method and EPA Requirements

A. Collection MethodThe Landers Logistics, Inc. field sampling technician should follow the following steps in order

to properly collect the samples from the L3 Communications outfalls for compliance testing.

Correctly enter the longitude and latitude coordinates of outfall A into the GPS. Follow the guided driving directions to the site.*

[* If the outfall site is inside the secured gated area of L3 Communications, the field sampling technician must stop at the main entrance security gate. Once at the gate, the technician must provide the security guard with proper Landers Logistics, Inc. identification. A copy of this sampling plan and the L3/Landers Logistics, Inc. Business Contract should also be available in case the security guard requests to see them.]

Park in a safe area that is not blocking the normal flow of traffic. Walk to the outfall site and visually inspect the area. Document observations. Laydown a 10’x10’ area of visqueen around the manhole opening. Use the manhole puller and crowbar to access the outfall by removing the cover. It is not

necessary to completely remove the cover. A opening that is large enough to visualize the collection stream and will allow the tygon tubing to easily be lowered into the manhole is all that is required.

Section off the laydown area into 4 areas. Working in a clockwise manner.



Fig.3 Site Setup Division

Position the following equipment in A Section: Solinist pump 100’ section of Tygon tubing and weight 12 V battery Collection bottles with any added preservatives needed. (see EPA Test Method

Collection Specifics). HACH sensION+ portable meter

Position the following equipment in B Section: Cooler with frozen ice inserts Security Seals Sample Collection ID Labels Chain of Custody form

Position the following equipment in C Section: Industrial trash bags De-Ionized water

Position the following equipment in D Section: All Spill Kit supplies Hand held 2-way radio Extra Gloves out of the box Industrial trash bags

Once the area is completely set-up and the outfall is accessed proceed with collecting the first sample.

1. Starting in the A Section: Insert the Tygon tubing into the pump as trained. Make sure that the tubing weight is securely inserted into the bottom end of the tubing.

2. DON ALL PERSONAL PROTECTIVE EQUIPMENT.3. Open the first required collection bottle. Make sure this bottle meets the

specifications of the required EPA test method for the analyte being tested.4. Connect the pump to the 12V battery using the battery connectors.


A Section

B SectionC Section

D Section


5. Turn on the pump. Check for proper suction by placing a gloved hand over the weighted end of the tubing. Once suction has been confirmed turn the pump off.

6. Lower the weighted end of the tygon tubing into the outfall. Once the end of the tubing is submerged in the collection channel, place the other open end of the tubing into the opening of the collection bottle.

7. Turn on the pump.8. Monitor the upward flow of the fluid through the tygon tubing, into the pump

chamber and out into the collection bottle.9. Once the required amount of fluid is collected, turn off the pump, and remove the

tygon tubing from the collection bottle. (If more than one bottle of fluid must be collected leave the tygon tubing in place and just set down on the laydown material. If no other collection bottles must be obtained proceed to step 10.)

10. Pull the tubing out of the pump, and allow the remaining fluid that is inside the tubing to return to the collection channel.

11. Pull the tubing out of the outfall. Place the tubing on the laydown material to be disposed of at a later time.

12. Remove the glove that is on your writing hand ONLY. Take the required field measurements using the HACH sensION+ portable meter and record the results where indicated. Handle the meter in your non-gloved hand and the probe with your gloved hand. Then place the meter on the laydown material to be decontaminated at a later time.

13. Place the collection bottle lid on the sample using your gloved hand and proceed to B Section.

14. Write all the requested information on a security seal in fine permanent ink and place over the top of the sample.

15. Complete the sample collection ID label and affix to the bottle.16. Place the sample in the cooler. Remove your other glove and face shield.17. Complete the Chain of Custody Form and complete a Field Log book entry for

this sample.18. At this point, if subsequent bottles must be filled for testing of other analytes, don

a new pair of gloves, your face shield and repeat steps 1-17 for each bottle. Once all the required bottles have been collected, close up the specimen cooler and return it to the truck to be secured while the site is cleaned up.

19. Don a new pair of gloves. Disconnect the pump from the 12V battery. Return the equipment to the truck.

20. If no spills occurred the spill kit and D Section supplies can be returned to the truck as well. If a spill did occur then the following procedure is to be followed.

o Open the spill kit bucket and remove everything.

o Don a new pair of gloves.

o Open the bag of spill absorbent.



o Cover the contaminated area in absorbent and allow it to completely soak

up the fluid.o Use the dust pan and broom to sweep up the absorbent.

o Empty into the bucket.

o Use DI water to clean the broom and dust pan and allow the water to be

collected in the spill kit bucket.o Close up and seal the absorbent bag if the entire product was not used.

o Take your gloves off and place in the bucket. Place the lid on the bucket.

Using a permanent marker label the top of the lid with the date, time, location of the spill, and sampling technician initials.

o Place the bucket in the back of the sampling truck.

o Place the broom, dust pan, and any unused portion of absorbent back in

the truck to be used in a new spill kit bucket.21. Rinse the probe end of the HACH sensION+ portable meter with DI water.

Allow the water to runoff the probe and into the outfall. 22. Allow the probe to air dry. Return the meter to the truck.23. Using the puller and/or the crowbar, return the cover to the outfall opening-

making sure it is securely in place. Then return the puller and crowbar to the truck.

24. Go to C Section and open an industrial trash bag. Keep this on the site.25. Return all unused supplies to the truck. Once all the unused supplies, equipment,

documents and samples have been returned to the truck, the laydown area is ready to be disposed of.

26. Set the open industrial trash bag over to the side, and off the laydown material. 27. Starting at one corner of the laydown material, begin to roll the entire area up.

Make sure that the used tygon tubing and all used gloves are INSIDE the material. Place all of this material into the trash bag.

28. Doff your gloves and place inside the trash bag. 29. Tie-up the open end of the trash bag.30. Place the trash bag in the back of the truck.31. Make one last visual inspection of the site to make sure nothing was left behind.

Document everything in the Field Log.32. Leave this site and proceed to the next outfall site.33. Repeat these steps at the next site.

B. EPA RequirementsThe EPA requires certain procedures be followed when collecting samples for testing. These

requirements are to ensure the validity of the testing results. Landers Logistics, Inc. has contracted the laboratory services of:



EMSL Analytical, Inc.200 Route 130 NorthWest, Texas 76649

Phone (254) 220-3675Fax (254) 220-3676

This laboratory is a NELAC accredited laboratory for the processing of soil, water, sludge, discharge, and chemical sample analysis. EMSL Laboratory has advised Landers Logistics, Inc. in the requirements for collection of the industrial discharge outfalls of the L3 Communications site in Waco, Texas. The sampling technician is to collect the samples for analyte testing using the following guidelines.

Table 2.

AnalyteTest

Method ContainerMin

VolumeType of Sample Preservatives

Holding Time

Max Regulatory

Holding time

Biological Oxygen Demand (5-Day) 5210B P or G 1000 ml G Refrigerate 6hr 48hrOil and Grease

Products 1664A

G- wide mouth

calibrated 1000 ml G

Add HCL or H2SO4

to pH <2 and Refrigerate 28d 28d

Total Suspended

Solids 160.2 P or G 200 ml G or C Refrigerate 7d 2-7dMetals:Arsenic

CadmiumChromiu

mLead

NickelZinc 6020A

P(A) or G(A) 1000 ml G or C

For Dissolved metals filter immediately.

Add HNO3 to pH<2 6 months 6 monthsContainer: P- Plastic G- Glass. P(A)/G(A)- Rinsed with 1:1 solution of HNO3. Type: G- Grab C- Composite 6020A- Method 6020 describes the multi-elemental determination of analytes by ICP-MS in environmental samples.

VIII. Quality Assurance and Quality Control Measures

A. Quality Assurance



The goal of the Landers Logistics, Inc. quality assurance program is to ensure that the hydrogeologic and analytical data collected are accurate, precise, representative, complete, and comparable. This is accomplished through strict adherence to sample collection protocols, and quality control duplicate sample collection and monitoring.

B. Quality Control MeasuresField QC samples will be collected and analyzed as part of all field sampling activities including

soil, ground-water, surface-water, and sediment sampling. Landers Logistics, Inc. uses the following quality control measures to ensure the validity of the data resulted.

Equipment blank - a blank solution that is processed through all equipment used for collecting and processing an environmental sample (similar to a field blank but normally done in the more controlled conditions of the office and not being transported to the field).

Field blank - a blank solution that is subjected to all aspects of sample collection, field processing, preservation, transportation, and laboratory handling as an environmental sample.

Preservation blank - a blank solution that is treated with the same preservatives used for an environmental sample.

Source solution blank - a blank solution sent to a laboratory to confirm that it is free of the analyte of interest.

Trip blank - a blank solution that is put in the same type of bottle used for an environmental sample and kept with the set of sample bottles both before and after sample collection.

Replicate (Duplicate) samples - A group of samples, collected in a manner such that the samples are thought to be essentially identical in composition. Replicate is the general case for which duplicate is the special case consisting of two samples. There are many types of replicate samples possible, each of which may yield slightly different results in a dynamic hydrologic setting, such as a flowing stream.

Spike sample - A sample to which known concentrations of specific analytes have been added in such a manner as to minimize the change in the matrix of the original sample. Every spiked sample analyzed should have an associated reference to the spike solution and the volume added.

IX. Health and Safety PlanThis Health and Safety Plan (HASP) has been prepared for employees of Landers Logistics, Inc.

employed in the collection of industrial discharge water samples at L3 Communications in Waco, Texas. All Landers Logistics, Inc. field sampling technician employees that are potentially exposed to the health and safety risks associated with this work are required to read, understand, and fully comply with all aspects of this HASP. This program is designed to comply with OSHA 1910.120(b) and to identify and evaluate the health and safety hazards which may be encountered, provide for appropriate training of personnel, inform personnel of potential hazards, establish an appropriate medical surveillance program, and establish certain work and safety procedures for personnel engaged in the above mentioned tasks. A copy of this HASP is to be maintained on site at all times while work is being performed.

The work activities covered under this HASP are as follows:



1. Accessing the L3 Communications assigned outfalls.2. Site assessment of the area.3. Set-up of the outfall area.4. Collection of the industrial discharge samples.5. Clean –up and decontamination of the site and equipment

A. Risk Analysis

1. Potential Chemical HazardsContaminants of concern in the water located on the site include arsenic, cadmium,

chromium, lead, nickel, zinc, and oil/ grease products. Potential chemical hazards may exist, including particulate inhalation, incidental ingestion, or dermal absorption of these contaminants from water samples. Hazardous chemicals are expected to be used during this work for the purpose of preserving samples. SDS will be maintained with this program in the event of accidental exposure to these chemicals. Only de-ionized water will be used for equipment cleaning onsite.

Table 3Contaminant of

Concern Acute Hazard SummaryChronic Hazard

Summary Exposure LimitArsenic Skin burning, itching,

and rash.Nose and throat irritation Eye redness, watering, and irritation.High exposure may cause poor appetite, nausea, vomiting, andmuscle cramps.High exposure may cause heart effects.

Cancer hazardReproductive hazardNerve damageSkin thickening, loss of pigmentLiver damage

OSHA PEL- 0.01 mg/m3 for 8-hour work period.

ACGIH TLV-0.01 mg/m3

Cadmium Flu-like symptoms of chills, headache, aching and fever.Lung damage including shortness of breath, chest pain, cough, and fluid buildup.High exposure may cause nausea, salivation, vomiting, cramps, and diarrhea.

Cancer hazardReproductive hazardPermanent kidney damage.Emphysema and lung scarring.Anemia, loss of sense of smell, and fatigue.

OSHA PEL- 0.005 mg/m3

for 8-hour work period.

ACGIH TLV- 0.01 mg/m3

(total particulate)

Chromium Intense gastrointestinal irritation or ulceration and corrosion.Epigastric pain, nausea, vomiting, diarrhea. Vertigo.

Lung cancer.Penetrating unhealing skin ulcers.Liver failure.Permanent Kidney damage.

OSHA PEL- 0.005 mg/m3



(for water soluble compounds)



Fever, muscle cramps.Toxic nephritis.Intravascular hemolysis.Acute multi-system organ failure.Coma and death.

Mucosal Polyps.

Lead High exposure may cause seizures

Reproductive hazard.Tiredness, sleeping difficulties, stomach problems, headaches, and moodiness.High levels may cause aching and weakness in arms and legs, trouble concentrating, and low blood count.Extremely high levels may cause kidney and brain damage.

OSHA PEL- 0.05 mg/m3 for 8-hour work period.

ACGIH TLV-0.05 mg/m3

Nickel Pulmonary fibrosisRenal edemaNausea, vomiting, diarrhea.Neurological deficits.

Eczema (rash, itching) of the fingers, hands, wrists, and forearms.AsthmaBronchitisImmunodeficiency

OSHA PEL- 1 mg/m3



Zinc Metal Fume Fever Decreased Pulmonary function.

OSHA PEL- 5mg/m3


ACGIH TLV- 2mg/m3

Hydrochloric Acid(Hydrogen Chloride)HCl

Corrosive to the eyes, skin, and mucous membranes.Coughing, hoarseness, inflammation and ulceration of the respiratory tract.Chest pain. Dermal burns, ulceration, and scarring

GastritisChronic bronchitis Dermatitis and photosensitization in workers.Prolonged exposure to low concentrations may also cause dental discoloration and erosion.

OSHA PEL- 5 ppm(7 mg/m3) Ceilingfor 8 hour work period

ACGIH TLV- 2 ppm(3 mg/m3) Ceiling

Sulfuric Acid(Hydrogen Sulfate)H2SO4

Corrosive to the eyes, skin, and mucous membranes.Coughing, hoarseness, inflammation and ulceration of the respiratory tract.

GastritisChronic bronchitis Dermatitis and photosensitization in workers.Prolonged exposure to low concentrations may

OSHA PEL- 1 mg/m3

for 8 hour work period




Chest pain. Dermal burns, ulceration, and scarring

also cause dental discoloration and erosion

Nitric Acid(Hydrogen Nitrate)HNO3

Severe burns, ulceration, scarring, dermatitis, and yellow staining of the skin.Headache, methemoglobinemia, vertigo, loss of coordination and mental facilities, and weakness.Renal failure.

Chronic bronchitis. Chemical pneumonitis, pulmonary fibrosis, and changes in pulmonary function.Discoloration and erosion of dental enamel.

OSHA PEL- 2 ppm(5 mg/m3)

ACGIH TLV- 2 ppm(5.2 mg/m3)

2. Potential Physical HazardsThe Landers Logistics, Inc. field sampling technician may be exposed to physical hazards in

the course of collecting the L3 Communications industrial discharge samples. A physical hazard is any factor within the environment that can harm the body without necessarily touching it.

The Environmental hazards include:- Traffic Hazards

- Extreme Heat

- Extreme Cold

- Rain, Sleet, Snow, High WindsAppropriate clothing and precautions should be taken for inclement weather and conditions.

The Occupational hazards include:- Noise-Hearing protection is required when continued exposure to extreme noise

exists.- Electrical-All equipment must maintain at least 10 feet of clearance from overhead

power cables. If this clearance cannot be maintained, the electric utility company must be contacted and requested to disconnect the cables from the power supply.

- Safety- Slip, trip, and fall hazards are commonly associated with this type of work. These hazards need to be recognized and corrected as soon as possible to avoid accidental injury.

- Weight of the manhole cover- Proper lifting techniques and body mechanics should be used to access and secure the manhole.

The Biological hazards include:- Insect bites-Bug spray is to be used and kept on the sampling truck at all times.- Snake bites- The Landers Logistics, Inc. field sampling technician should be aware

that snake bites are an associated hazard of this type of work.- Rodents- The Landers Logistics, Inc. field sampling technician should be aware that

contact with rodents and potential rodent bites and exposure to Hantavirus



- Pulmonary Syndrome (HPS) is an associated hazard of this type of work. Rodents carry this disease. In the event of rodent bite the Landers Logistics, Inc. field sampling technician is to immediately move to a safe area, contact Landers Logistics, Inc. and proceed to the nearest Emergency Room.

B. TrainingAll Landers Logistics, Inc. employees are required to have completed the 40-hour

Occupational Safety and Health Administration (OSHA) training course for hazardous waste operations as required under 20 CFR 1910.120. Furthermore, each worker is required to be current with the annual 8-hour refresher course requirement. Initial training is required upon employment prior to any assignment as a field sampling technician. Training will focus on the recognition of work related hazards, personal protective equipment, exposure control, basic first aid, and emergency response.

Work related hazards- refer to potential chemical, physical, and biological hazards section of this document.

Personal Protective Equipment (PPE)- refer to the required equipment section of this document for a list of the minimum required PPE.

Exposure Control- The Landers Logistic, Inc. field sampling technician assigned to the L3 Communications site is expected at all times to adhere to all policies and procedures in order to minimize the potential for exposure to a hazardous chemical or environment.

First Aid- All Landers Logistics, Inc. employees are required to obtain a certification in Basic First Aid, CPR, and AED use within 60 days of employment with the company. All work related accidents requiring first aid treatment must be reported to the Safety Coordinator within 2 hours of the incident and an accident report form must be completed within 5 working days.

Emergency Response- In the event of an emergency situation (such as accident, injury, or fire) the Landers Logistics, Inc. field sampling technician is instructed to immediately evacuate the site to a safe place. Then call 911. The location of the site and the nature of the incident should then be reported to the 911 operator. Personnel are further directed to stay on the line until released by the operator. After release by the 911 operator, the technician is to call the Landers Logistics, Inc. Safety Coordinator. The Safety Coordinator will then contact L3 Communications.

Reference Contact Information:TSTC Police Department (254) 867-3690Lacy Lakeview Police Department (254) 799-2458Lacy Lakeview Fire Department (254) 799-2479McLennan County Sherriff’s Department (254) 757-5000Texas Department of Public Safety (254) 759-7121ETMC EMS Ambulance (254) 799-7718Baylor/Scott & White Hillcrest Hospital (254) 202-2000



C. Medical Testing and Physical RequirementsAll employees are required to pass an annual physical performed by Dr. Natalie Lippe at

Providence Occupational and Family Medicine Clinic, 7401 New Sanger Avenue, Waco Texas 76712. This annual screening will be free of charge to employee. If the employee is expected to be required to don an SCBA respirator, a pulmonary function test will also be required, and the employee will be required to comply with Landers Logistics, Inc. Respiratory Program in accordance with the 1910.34 OSHA standards. If the employee is exposed to occupational noise at or above an 8 hour TWA of 85dB then the employee will be placed in the Landers Logistics, Inc. Hearing Conservation Program in compliance with the OSHA standard 1910.95 requirements. At that time an audiometric testing will be required. All employees will receive an annual vision screening at no cost to the employee. Any corrective lenses will be the responsibility of the employee to purchase.

D. Site ControlThe outfall site will be maintained in a clean fashion. Unnecessary debris, tools, tubing,

equipment, and other items will be properly stored on the truck and away from the sampling site such that the possibility of slip, trip, and fall injuries is minimized. If the field sampling technician must leave the outfall site for any reason prior to the completion of the sample collection process, the outfall opening must be covered prior to leaving the site unattended. All collected samples must be placed in the sample cooler or transport container and remain in the possession of the technician to maintain the integrity of the chain of command. The site must be blocked off using orange caution cones and yellow caution tape.

No unauthorized personnel are allowed at the outfall site during sample collection.

E. Spill Control and DecontaminationRefer to line 20 of the collection method section of this document for spill control and

decontamination procedures.

X. ConclusionIt is the goal of Landers Logistics, Inc. to provide L3 Communications with sample monitoring

of their industrial wastewater discharges in order to ensure that L3 communications is compliant with the Industrial Wastewater Discharge Permit TX-10494-520-13 issued October 20, 2013, and the City of Waco Ordinance Chapter 26 Article 6. Landers Logistics, Inc. is dedicated to providing reliable and complete analytical data to achieve this goal. Landers Logistics, Inc. is determined to provide the field sampling technician with all the required training, information, policies, and procedures in order to properly equip him with the skills required for the proper collection of the outfall site samples and ensure a safe working environment.



Appendices


Date post:	24-Jul-2015
Category:	Documents
Upload:	tristan-landers
View:	133 times
Download:	0 times

L3 Communications Sampling PlanA

Documents