|
Full text of "Draft Final Chemical Warfare Material Sites Investigation Work Plan, Presidio of San Francisco, California"
 |
Anonymous User (login or join us) | style="text-shadow:#bbb 0px 1px 0; color:#fff !important" href="http://www.archive.org/create/">Upload |
Full text of "Draft Final Chemical Warfare Material Sites Investigation Work Plan, Presidio of San Francisco, California"
Draft Final
Chemical Warfare Material Sites Investigation Work Plan^ Presidio of San
Francisco, C aUfornia
March 2006
Prepared by:
U .S . A nny C orps of Engineers
Sacrameuto District
1325 J Street
SacrmneutD, California 95814
This page intentionally left blank
Table of Contents
Page
Table of Contents i
Tist of Tables ii
Tist of Figures ii
Tist of Appendices ii
Tistof Acronyms and Abbreviations iii
Chapter 1, Inlroduction 1
Chapter 2, Technical Management Plan 11
Chapter 3, Field Investigation Plan 14
Chapter 4, Quality Control Plan 20
Chapter 5, Fxplosives Management Plan (not used) 21
Chapter 6, Fxplosives Siting Plan (not used} 22
Chapter 7, Fnvironmental Protection Plan 23
Chapters, Property Management Plan (not used) 24
Chapter 9, Interim Holding Facility Siting Plan forRCWM Projects (not used) 25
Chapter 10, Physical Security Plan forRCWM Project Sites (not used) 26
Chapter 11, References 27
List of Tables
Page
Table 1 Chemical Warfare Material Sites 2
Table 2 Estimated Chemical Warf'are Training Period of Use 5
Table 3 Site Locations 7
Table 4 Summary of Data Acquisition Strategy 17
List of Figures
{all behind "Figure" Tab)
Figure 1 Chemical Warfare Material Investigation Areas
Figure 2 1918 West Cantonment Trench System Original Training Area
Figure 3 BakerBeach Area Sample Locations
Figure 4 Cavalry Stables Area Sample Locations
Figure 5 Main Post Area Sample Locations
Figure 6 1918 West Cantonment Trench System Investigation Area
Figure 7 1918 West Cantonment Trench System Vegetation Removal
L ist of A ppendices
A ppendix A Probability A ssessment for the D etennination of the A pplicability of the
Interim Guidance
Appendix B Unexploded Ordnance (UX 0) Work Plan
Appendix C Notification Procedures for Discovery of Recovered Chemical Warfare
Material (RCWM) During USACE Projects
Appendix D Sampling and Analysis Plan
Appendix E Site Safety and Health Plan
11
List of Acronyms and Abbreviations
ASR Archive Search Report
EEC BRAC Environmental Coordinator
BRAG Base Realignment and Closure
CAIS Cliemical Agent Identification Set
CESPD US Army Corps of Engineers, South Pacific Division
CG Phosgene
CN Chloroacetophenone (riot control agent)
CS Orthochlorobenzylidene Malononitrile (riot control agent)
GSM Conceptual Site Model
GWM Chemical Warfare Material
CWS Chemical Warfare Service
DA Department of the Army
DQO Data Quality Objective
EE/GA Engineering Evaluation/Cost A nalysis
EOD Explosive Ordnance Disposal
H Mustard
HD Distilled Mustard
IDW Investigation Derived Waste
ITSI Innovative Technical Solutions, Inc.
L Lewisite
MEG Munitions and Explosives of Concern
NCO Non Commissioned Officer
OE Ordnance and Explosives
PS Cliloropicrin
QM Quarter Master
RGWM Recovered Chemical Warfare Material
RI/ES Remedial Investigation/Feasibility Study
SAP Sampling and Analysis Plan
SI Site Inspection
TEU Technical Escort Unit (now the 20'^ Si^jport Command)
USAGE US Army Corps of Engineers
USAEG US Army Environmental Center
UXO Unexploded Ordnance
111
This page intentionally left blank
IV
CHAPTER 1, INTRODUCTION
a. Project Authorization
The Base Realignment and Closure (BRAG) office autliorized this project based on a
request from the Presidio Trust. The US Army Corps of Engineers, South Pacific
Division (CESPD) Range Support Center was tasked with the investigation.
b. Purpose and Scope
The purpose of this work is to confirm tliatno Chemical Agent Identification Set(CAIS)
materials or Chemical Warfare Material (CWM) residues are present witliin tlie Presidio
of San Francisco {hereinafter "Presidio"). The CAIS materials could include mustard,
lewisite, phosgene, and chloropicrin. However, mustard is the most persistent agent of
tliose commonly used for training and is therefore tlie focus of this investigation.
The Archive Search Report (ASR), completed in 2003, identified three CWM locations
for furtlier evaluation. These are the 1918 West Cantonment Trench System, tlie Baker
Beach Gas Chamber and the Building 672 Gas Chamber. Chemical warfare related
training apparently occurred at the 1918 West Cantonment Trench System as evidenced
by tlie discover^' of the four CAIS mustard bottles in 2002. This site is shown on Figure
1. The Baker Beach Gas Chamberfalls within what is referred to in tliis wort plan as the
"Baker Beach Study Area." The Building 672 Gas Chamber falls witliin the "Cavalry
Stables Study Area" and tliis area, as well as that associated with tlie Baker Beach Gas
Chamber, is also shown on Figure 1.
Additional consideration of CWM related activities, conducted since completion of the
A SR, suggests a number of additional buildings and possible training areas for further
evaluation. Before listing these it should be emphasized that tlie Presidio has a long
history and that most buildings and open spaces have had multiple uses as mission
requirements changed over time. In addition, tlie Presidio has implemented at least two
comprehensive building renumbering schemes, first in tlie 1930s and again in the 1940s.
Obviously as a result of these changes an individual building's use, designation, and
number vary over time. In this work plan each study site is referred to by the most
common CWM related use that is known and by the last known individual building
number if applicable. This is not to imply that tliese buildings or locations have been
used exclusively for CWM related activities. In addition some of tlie buildings have been
demolished, eillier because they were originally temporary in nature or due to periodic
redevelopment and other Presidio improvements.
Additional sites identified for furtlier evaluation are as follows:
In the Baker Beach study area:
鈥?Battery Chamberlin Gas Chamber
鈥?B aker B each training area
In the Cavalry Stables study area:
鈥?CWS (Chemical Warfare Service) Storeroom, Building 670
鈥?"Chemical Corps", Building 667
鈥?"Chemical Warfare", Building 681
鈥?Cavalty Stables training area
In the Main Post study area:
鈥?CWS Warehouse, Building 94
. CWS Office, Building 219
. "CWS Emerg/Office", Building 222
Some of these locations are known only from references found on Presidio maps. These
locations include "Chemical Corps" atBuilding 667, "Chemical Warfare" atBuilding
681 and "CWS Emerg/Office" at Building 222. The exact nature of the CWM related
activities at these locations is not known and can only be inferred from a general
understanding of events occurring at tlie Presidio during the period when chemical agents
were potentially used during training {the 1920s tlirough the 1950s).
The following table summarizes all sites of interest (those originally designated in the
ASR for further study and tliose added after additional evaluation):
Table 1. Chemical Warfare Material Sites
Name
Most Recent Bldg#
CWM Related Use
Earlier Bldg ^s
1918 West
Cantonment Trench
System
Not applicable
Training
Not applicable
Baker Beach Gas
Chamber
Not applicable
Training
Not applicable
Battery ChamberUn
Gas Chamber
Bldgl621
Training
None
Baker Beach Training
Area
Not applicable
Training
Not applicable
Bldg672Gas
Chamber
Bldg 672
TrBJning
None
CWS Storeroom
Bldg 670
Storage
Bldg 141 and 174
"Chemical Corps"
Bldg 667
? Training/Storage
Bldg 62 and 164
"Chem Warfare"
Bldg 681
? Training/Storage
Bldg 26 and 83
Cavalry Stables
Training Area
Not applicable
Training
Not applicable
CWS Warehouse
Bldg 94
Storage
Bldg 25 and 151
CWS Office
Bldg 219
Office
Bldg 42 and 181
CWS Emerg/Office
Bldg 222
Storage
Bldg 198 and 187
Attlie 1918 West Cantonment Trench System the woit will involve selective removal of
vegetation, raking forest duff out of trenches, foxholes, etc (hereinafter "trenches"},
check for CAIS material, excavations of latrine pits, and soil sampling for chemical agent
break-down product analysis. At the other locations the work will involve checking tlie
area for evidence of CAIS material and sometimes, as described below, surface wipe or
soil sampling forCWM analysis.
c. Work Plan Organization
The oiganizational structure of tliis wort plan is based on tlie Type 1 Work Plan outline,
Number MR-001 developed by the U.S. Anny Engineering and Support Center,
Ordnance and Explosives Directorate in Huntsville Alabama. This work plan outline
contains eleven chapters, not all of which are applicable to this project. Those chapters
not used are shown below in italics:
Chapter 1. Introduction
Chapter 2. Technical Management Plan
Chapters. Eield Investigation Plan
Chapter 4. Quality Control Plan
Chapters. Explosives Management Plan - notused
Chapters. Explosives Siting Plan - notused
Chapter?. Environmental Protection Plan
Chapters. Property Management Plan - notused
Chapter 9. Interim Holding FaciliUj Siting Plan for RCWM Projects - notused
ChapterlO. Physical Security Pian for RCWM Project Sites- notused
Chapter 11. References
Specific sections witliin some chapters are also not applicable to this project and will be
so noted in the wort plan. Chapter 1 provides an introduction and scope of tlie project.
Management aspects of the project are detailed in Chapter 2, while the detailed project
planning and Data Quality Objective (DQO) development is presented in Chapter 3. The
Quality Control Plan is found in Chapter 4 and the Environmental Protection Plan at
Chapter 7. References are listed in Chapter 1 1 .
d. Project Location
The project is located at the former Presidio of San Francisco, within the City of San
Erancisco, at the northern tip of tlie San Erancisco Peninsula. The Presidio is
approximately 1,416 acres in size. The sites to be addressed during this work are
distributed across the Presidio as shown on Figure 1.
e. Site Description
Meteorological Conditions. The Pacific Ocean and San Erancisco Bay have a strong
influence on the climate of the Presidio. The temperature is moderate; rain and mild
temperatures characterize the winter months, and spring is usually sunny and mild. Fog
often occurs in summer when wann, moist air is cooled by cold ocean water along the
coast. The average annual rainfall is 19.5 inches. Ninety percent of the rainfall in the
San Francisco area occurs from November to April (USAEC, 1997).
Topography. Elevations at the Presidio range from sea level along tlie northern and
western boundaries to approximately 400 feet above seal level. The topographic high
point is located adjacent to the Presidio Golf Course in the south-central portion of tiie
Presidio. The northern area along San Francisco Bay is flat low-lying area developed on
fill material. Before filling operations of the early 1900s, much of this area consisted of
interior marshlands with a sand spit. In contrast, tlie western boundary along the Pacific
Ocean is very steep with slopes of about 50 percent. Baker Beach, at the baseof tliese
steep slopes, is a relatively narrow strip of land. The interior portions of the Presidio,
including the eastern and southern boundaries, are characterized by gently rolling to hilly
topography. Slopes in the western half of the Presidio are typically about 20 percent.
Slopes in tiie eastern half, where most buildings are located, are typically about five
percent (USAFC, 1997).
Geology. Unconsolidated deposits of sand, silt, and clay cover much of the Presidio.
These unconsolidated deposits overlie the geologically complex Franciscan Formation,
an assemblage of mafic volcanic rocks, metamorphic rocks, graywacke sandstone, shale,
and siltstone. The geology reflects the Presidio's location between two major fault
systems, tlie San Andreas and Hayward/Rodgers Creek. Artificial fill deposits are
present at numerous locations, particulariy along the San Francisco Bay. Dune sand
fonns tlie surficial deposits throughout most of the southwestern and central Presidio.
Beach deposits and artificial fill form the surficial deposits along San Francisco Bay and
at Baker Beach along tlie Pacific Ocean. Beach deposits consist of well- sorted, medium-
to coarse-grained sand with some gravel (USAEC, 1997).
Vegetation. Much of the vegetation seen today at the Presidio results from years of
planting by the A nny in a program that began in tlie 1 880s. These plantings provided
botli windbreaks and scenic beauty. Vegetation is dense in tlie soudi-central area of the
Presidio and locally in many other parts of the former post. A golf course lies along the
southwestern part of the Presidio (USAEC, 1997). Isolated enclaves of endangered
plants, such as Presidio Clarkia and San Francisco lessingia, are found at tlie Presidio.
f. Site History
The Presidio was established in 1 776 as a military garrison by tlie government of Spain,
which it held until the formation of the Mexican Republic in 1822. The Presidio was
fonnally ceded to the United States from Mexico in 1848. The Presidio has served as a
mobilization and embaitation point during several overseas conflicts, a medical
debarkation center, and provided coastal defense for tlie San Francisco Bay area. Prior to
transfer of the property to tlie D epartment of the Interior and Presidio Trust, the Presidio
was a multi- mission installation witli various military activities conducted under separate
commanders stationed as tenants or satellites (USAEC, 1997; USAGE, 2003).
General notes on chemical warfare training. Chemical warfare training in the United
States began with the mobilizationduring World War 1 (approximately 1917). Troops
were trained to protect themselves from exposure to tiie chemical agents used at that time
{such as chlorine, phosgene, and mustard}. Training included familiarization with the
eguipment, test fitting of the gas mask, decontamination training, and tactical exercises in
which simulated or training chemical agents were employed. Chemical Warfare
Materials were stored at the Presidio and this included statically used munitions filled
witli smoke, riot control agents and simulants, in addition to CAIS material and bulk
mustard agent (the bulk mustard container was apparently used in the 1920s).
Dynamically used munitions, such as rifle grenades and hand grenades, which could be
filled with riot control agents and simulants, were also present in military unit
inventories. Chemical warfare items included candles, capsules, grenades, pots, bombs,
smoke generators and land mines. Some of these items would were stored for use in the
event of combat deployment while other items were used for routine training. CA IS sets
were used from tlie early 1930s to the late 1950s. Estimated periods of use fortlie sites
considered in this work plan are shown in Table 2. The term "gas chamber" refers to a
Table 2. Estimated Chemical Warfare Training Period of Use
Time Period
1920s 1930s 1940s 1950s 1960s 1970s 1980s 1990s
Building/Area
1918WestCantonment < >
Trench System
Baker Beach Study Area:
Baker Beach Gas Chamber ^ ^
Battery Chamberlin Gas
Chamber, Bldg 1621
Baker Beach Training Area
Cavalry Stables Study Area:
Gas Chamber, Building 672 < >
CWS Storeroom, Building 670 <=^
"Chemical Corps", Building 667
"Chem Warfare", Building 681
Cavalry Stables Training Area
Main Post Study Area:
CWS Warehouse, Building 94 <:
CWS Office, Building 219 C
CWS Emerg/Office, Building 222 ^=>
Army-wide CAIS use .er ^
small room in which simulants or riot control agents are used to create conditions in
which to test the fit of gas masks as well as to instill confidence that the masks are
protective.
General notes on Chemical Warfare Material terminology. Confusion may arise from tiie
term "Chemical Warfare Material" (CWM), as current practices define CWM differently
tliantlie U.S. Army did in the first part of the twentieth Century. This wort plan utilizes
tlie definition as currently put fortli by the U.S. Army Corps of Engineers Safety Office
which states: "CWM is an item configured as a munition containing a chemical
substance that is intended to kill, seriously injure or incapacitate a person through
physiological effects". These items include V-and G-series nerve agent, H-series blister
agent (mustard) and lewisite {abbreviated "L") in other tlian munitions configurations.
Due to tlieir prevalence and military unigue application. Chemical Agent Identification
Sets (CAIS) are also considered CWM. Some CMS sets (K941 and K942} contained
only mustard (H, HD), while others (sets Ml, K951, K952, K953, K954) included a
combination of mustard (H, HD), lewisite (L), phosgene (CG), and chloropicrin (PS).
The current definition of CWM does not include: riot control agents, chemical
herbicides, smoke and flame producing items, or soil, water, debris or other media
contaminated with chemical agent.
In October 2002 Presidio Trustvolunteers found fourglass bottles from aK941 CAIS
set. The U.S. Army 20'^ Support Command (formerly the Technical Escort Unit ( IhiU))
fioperly removed tlie bottles, however concerns remained regarding soil and organic
forest material, or "duff/' tliat was stoclq^iled or placed in two roll-off bins. Persomiel
from the U.S. Am^ Engineering and Support Center performed a geophysical check of
an area centered on die trench and ^proximately 50' by 100' as a part of the removal of
Ihebotdes. No metal objects were found. The area of the discovery was fenced to
jHBvent access by the pubhc (still in place as of die date of this work plan). In 2003,
limovative Technical Solutions, Inc. (TISI), under the direction of the Corfs of
Engineers, Sacramento District, paepared a work jian to check the soil and leaves for die
presence of additional CAIS materials (TISI, 2003b). The work plan included a
Probability Assessment (USAGE, 2003b) that addressed die possrlihly of finding
additional CAIS material in the stoclq^iles orroU-off bins. The assessanent concluded
that the probaMity of encoimtering additional CAIS material was "remote" (for the
botdes) or "inprobaWe" (forlhe Rg orcanisters). The Health and Safety Plan included
the contingency to stop all work and secure the area in the event that additional CAIS
material was discovered. The on-site Corps of Engineer Ordnance and Explosives (OE)
Specialist would make an initial prehminary assessment as to the possible presence of
Chemical Warfare Material. This would be followed, as required by Am^ Regulation
50-6, for either Explosive Ordnance Disposal (EOD) or the 2Cf'' Siqport Command to
make a preliminary assessment, widi the 2& Si^port Command ni^ng the detailed
assessment on discovery of unknown filler (\\Iiich requites testing to determine if it is
Recovered Chemical Warfare Material (RCWM)) . The soil and leaves were investigated
in October 2003 using procedures documented in die work plan (ITSl, 2003b) .
AppaDximately 137 cubic yards of material were investigated and no CAIS materials
were found. The Army contractor fiaoed the soil in roU-off bins diat were later removed
by tiie Presidio Trust. The field activities aiid results were documented in a report (ITSI,
2003a).
The twelve individual sites tliat are the subject of this work plan (Table 1) are located in
four general areas of the Presidio. This is shown in Table 3.
The 1918 West Cantonment Trench System (Figure 2). This area was used for tactical
training (assumed to be at the platoon and sguad level) from World War 1 to the 1930s.
Evidence for this comes from aerial photos (overhead and oblique), showing a network of
trenches and individual foxholes. No plans or reports documenting tliis use, or chemical
training activities, have been identified to date. It was along the southern edge of tliis
former training area, near Inspiration Point, that tlie four CA IS bottles were discovered in
2002. The exact boundaries of tliis training area are unknown, but it appears to lie along
two parallel ridges to the south of the Main Post, in the soutli central area of the Presidio.
The backstop fora small arms firing range (identified in the ASR as the West
Cantonmenl/Bamard Avenue Protected Range) was located in the valley between the two
ridges. The highest density of trenches and foxholes were located along or near the crest
Table 3. Site Locations
Name
Most Recent Bldg #
Status
General Area
1918WestCantonment
Trench System
Not applicable
Open area that is
partially
developed,
partially forested
South Central Presidio
Baker Beach Gas
Chamber
Not applicable
Building no longer
present
West Presidio - Baker
Beach
Battery Chamberlin Gas
Chamber
Bldg 1621
Present, historical
battery
Baker Beach training
area
Not apphcable
Open area
Bldg 672 Gas Chamber
Bldg 672
Building no longer
present
North Central Presidio
- Cavalry Stables
CWS Storeroom
Bldg 670
Present, not
currently in use
Chemical Corps
Bldg 667
Present, Archive
Office
C hem Warfare
Bldg 681
Present, not
currently in use
Cavalry Stables training
area
Not applicable
Open area
CWS Warehouse
Bldg 94
Building no longer
present
North East Presidio -
Main Post
CWS Office
Bldg 219
Building no longer
present
CWS Emerg/Office
Bldg 222
Present, not
currently in use
of the ridges. Approximately half of the eastern most ridge has been redeveloped with
residential housing and this part of tlie site will not be included in tlie investigation.
Construction of tlie walking trail that runs along the crest of the western ridge may
overlie the trenches/foxholes in that area. The remaining part of this former training area
is forested and contains trails popular with local residents.
Baker Beach Gas Chamber (Figure 3). This name has been given to a small structure that
appears in a 1 954 site map, however the building is no longer present. The structure is
identified on the map as a "gas chamber" and lies very close to a former radar tower and
otlier communication related infrastructure. The building was about 1 6 by 19 feet in size
and was approximately 475 f eet Nortlieast of Battery Chamberlin. No other information
is available on tliis site. This site may have been used as a gas chamber during the 1950s.
Battery Chamberlin Gas Chamber (Figure 3). Beginning after World War 1, some of the
Presidio coast defense batteries were taken out of service. This made these fortifications
and support buildings available for other uses. Battery Chamberlin, located at B aker
Beach, remained partially active as a coastal defense battery until just after World War II
{National Park Service, 1997). Historical documents indicate tliat chemical training
activities occurred at this location and tlie A SR suggests that B attery Chamberlin was the
primary location for chemical warfare training, particularly afterWorld Warll. Two
rooms at B attery Chamberiin have markings above the doors indicating that they were
used as a, "CS gas chamber" and a "CN gas chamber," respectively. CS (orthochloro-
benzylidene malononitrile) and CN (chloroacetoplienone) are botli riot control agents
used in gas chambers for mask fit and mask confidence training. Fach room is estimated
to be approximately 15 by 30 feet in size.
Baker Beach training area (Figure 3). No specific map references were found for this
site, but historical documents suggest that chemical training activities were conducted in
open ground in the vicinity of the BakerBeach Gas Chamber and tlie Battery Chamberlin
Gas Chamber. The estimated limits are shown on Figure 3, however the specific location
for individual training activities was not found in the historical documents.
Building 672 Gas Chamber (Figure 4). This building appears only on base maps from tlie
1940s. It may have been a temporary building tliat was taken down after Worid Warll.
The building was approximately 1 3 by 15 feet in size. This site was apparently used as a
gas chamber during World War 11.
CWS Storeroom, Building 670 (Figure 4). This building was originally constructed as a
chemical storehouse in 1921 (National Park Service, 1997) and was later used as a
magazine. The building is not currently in use. B uilding lists from 1 940 show the
building used for District Recruiting Officer Storage and in 1942 as "Storeroom
Chemical Warfare". The building is single story and approximately 25 by 34 feet in size.
"Chemical Corps", Building 667 (Figure 4). This building was constructed in the 1920s
as part of the cavalry stable complex. When no longer needed for their original purpose
tliese large buildings were used for storage and other activities. Building 667 is currently
used as die National Park Service Archives Office. Site maps from tlie 1950s and 1960s
label this building as "Chemical Corps". The building may liave been used forcliemical
warfare office, training, storage, or a combination of tliese activities. Tlie building lias
two stories and is approximately 55 by 172 feet in size.
"Chem Warfare", Building 681 (Figure 4). This building appears in the early 1900s and
was originally partof aNon Commissioned Officer (NCO) Bachelor Quarters complex.
This is south of, and adjacent to, the cavalry stable complex. The building has had
multiple uses, most recently as a religious center, however it is not currently in use. Site
maps from the 1950s and 1960s label this building as "Cliem Warfare". Cliemical
warfare related use of tliis building may be similar to the Chemical Corps, Building 667,
witli the most likely use as CWS troop barracks and classroom. The building has two
stories and is approximately 22 by 93 feet in size.
Cavalry Stables training area (Figure 4). Additional chemical training activities may
have been conducted in open space in the immediate vicinity of the gas chamber. The
estimated boundaries of the training area are sliown on Figure 4.
CWS Warehouse, Building 94 (Figure 5). This building appears in the early 1900s and
building lists from 1935 identify it as a supply company office. Building lists from 1939
and 1940 identify the building as "Chemical Warfare Serv Whse" and "Reg Supply &
Ordnance Officer Ch. to CWS Storeroom, Courts Martial Room & School 30"^ Infaritiy."
The building was demohslied by the 1950s and was ^proximately 56 by 140 feet in size.
CWS Office, Building 219 (Figure 5). This building appears in the early 1900s and
building lists from 1935 and 1939 identify it as a "Post Q.M. Office" (QM stands for
"Quartermaster," a branch of the Army related to logistical activities). The 1940 building
lists identifv the building as "Post Q.M. Office Chemical Warfare - officer HQ Air
NCA" and "Post Q.M. Office & C.A. Air, C.W.S. Office." The building was demolished
by tlie 1970s and was approximately 50 by 95 feet in size.
CWS Emerg/Office, Building 222 (Figure 5}. This building appears on maps from the
1930s and the 1935 and 1939 building lists identify it as a "Paint Shop- Plumbing Shop-
Tin Shop" and "Ordnance Office," respectively. The 1939 building list also includes a
hand written note adding "Shops; Chem Warfare & (illegible) Office." The 1940
building list identifies the building as "Post Ordnance Shop & Shops C.W. & Engineers
Office." The building still exists and is unoccupied. The building is one story and
approximately 42 by 88 feet in size.
g. Current and Projected Land Use
Both current and projected land use is to preserve the historical former military
installation through a strategy of leasing existing buildings, combined with leasing land
for limited new construction. This strategy is intended to generate sufficient funds for
maintenance and upkeep of the former Army post.
h. Previous Investigation of the Site
The Presidio has been tliorouglily investigated by the Army, and later by the National
Park Service and the Presidio Trust, for the presence of hazardous waste. The Army
investigations began in the 1980s and culminated in the Final Remedial Investigation
Report, Presidio Main Installation, Presidio of San Francisco, prepared by Dames &
Moore in January 1997.
CWM related investigations began with tlie Installation Assessment of Presidio San
Francisco, prepared by Environmental Science and Engineering, Inc., in 1983. No use of
CWM was noted, however a CS gas chamberwas identified in Batterv Dynamite
(Building 1399).
International Technology Corporation (IT) conducted a records review in 1999 tliat
included consideration of Unexploded Ordnance (UXO) and CWM. This was
documented in tlie Project Memorandum titled Additional Sites of Potential
Environmental Concern: In-Depth Historical Research Results dated Eebruaiy 17, 1999.
The results of tliis records search areconsistentwith the ASR prepared in 2003.
The 2002 discovery of CAIS bottles prompted the preparation of the ASR by the US
Anny Corps of Engineers, St. Louis District, in October 2003. This report confinned that
die Army had trained with CWM on post. CWM training included limited quantities of
bulk mustard agent and all three types of CAIS (i.e. instructional, detonation, and toxic
sets). The chemical warfare training facilities at tlie Presidio consisted of a number of
gas chambers and training areas used over tlie years, some of which were clearly
identified and others, which were not. The ASR did not identify any overt indication of a
CWM hazard at tlie Presidio.
i. InitialSummary of Risk from Munitions and Explosives of Concern (MEC)
No Munitions and Explosives of Concern (MEC) has been found in tlie investigation
areas. OE Safety Specialists will provide "Construction Support" oversight during this
investigation. The Probability Assessment for this project is included at Appendix A,
while tlie Unexploded Ordnance (UXO) Work Plan is found at Appendix B.
10
CHAPTER 2, TECHNICAL MANAGEMENT PLAN
a. Project Objectives
The objective is to collect sufficient information and data at each site to confirm that no
CWM is present.
b. Project Organization
Army organization: This project is conducted by the Corps of Engineers under the
direction of tlie BRAC Environmental Coordinator (BEC).
Presidio Trust: The Presidio Trust is represented on this project by their environmental
management office.
National Park Service: The National Park Service will be represented by their
environmental restoration staff.
Regulatory Agency: The State of California is represented by the Department of Toxic
Substances Control, Berkeley Office.
c. Project Personnel
Anny personnel:
BEC - Roger Caswell, 510.909.4804
U.S. Army Corps of Engineers, South Pacific Division Range Support Center:
Project Manager- Bruce Handel, 916.557.7906
Technical Team Leader- Brad Call, 916.557.6649
OE Safet\' SpeciaUst- Tom Knapp, 916.557.7313
Industrial Hygenist- DaveElskamp, 916.557.7903
Project Chemist- PamWerhmann, 916.557.6662
Environmental Engineer- Jennifer Payne, 916.557.7521
U.S. Army Engineering and Support Center, Ordnance and Explosives Directorate in
Huntsville Alabama:
Military Munitions Center of Expertise- HankHubband, 256.895.1586
CWM Design Center Operations Officer- Wilson Walters, 256.990.1512
Presidio Trust:
Environmental Program Manager- Craig Cooper, 415.561.4259
Environmental Remediation Specialist- JenniferYata, 415.561.4272
Presidio Police - 415.561.5656
National Park Service:
Remediation Manager - Brian UUensvang, 415.561.4439
11
Deparhiient of Toxic Substances Control:
Hazardous Substances Engineer- Robert Boggs, 510.540.3751
d. Project C ommunication and Reporting
The Corps of Engineers Project Manager will have responsibility to inform the project
team regarding project status, changes to the work plan, as well as any CWM or MEC
discoveries. This will take the form of personal communication, e-mails and written
correspondence. Details regarding notification procedures upon discovery of CWM or
MEC are found at Appendix C.
e. Project Deliverables
The deliverable for this project is a report documenting the site investigation activities,
data, quality control measures, and conclusions. The report; will contain excerpts from
the field notebook as well as copies of tlie laboratory analytical reports.
f. Project Schedule
The project schedule will be provided to all stakeholders under separate cover. This
worii plan provides the flexibility to conduct the investigation in phases, should this be
necessary due to site or funding constraints.
g. Periodic Reporting
The Corps of Engineers Project Manager will provide monthly status updates to the
project team during tlie course of the investigation.
h. C osting and BUImg
Not applicable to this project.
1. Project Public Relations Support
The Corps of Engineers, Sacramento District Public Relations Office will provide
support, if necessary, for this project.
j. Subcontractor Management
The Corps of Engineers, Sacramento District project team will manage all contractors.
Contractors will be used forchemistrv' analysis, the vegetation removal, and excavation
of potlioles.
k. Management of Field Operations
The Corps of Engineers, Sacramento District project team will manage tlie field
operations unless CWM or MEC is discovered. Should this occur the investigation will
12
stop aiid the appropriate agency will respond and take control of the site as detailed in
Appendix B. OE Safety Specialists will been site during all field activities to provide
tlie "Constmction Support" level of oversight
In the event that there is a CWM or MEG discovery the site will be secured initially by
the Army field investigation team until the local law enforcement agency, the Presidio
Police, can respond and take control of the site. Access to the item and site will be
restricted and non-essential personnel will be denied entry. Additional information on
tliis subject is provided in Appendices B and C.
13
Chapters. Field Investigation Plan
a. verall A pproach to M unitions Response A ctivities
(1) Site Characterization Goals
The goal is to confirm that neither CAIS materials nor CWM residues are present at tlie
study sites.
(2) Data Quality Objectives
The Data Quality Objective (DQO) process is listed below:
1. State the problem.
2. Identify the decisions.
3. Identify the inputs to tlie decision.
4. Define the boundaries of the study.
5. Develop decision rules.
6. Specify limits on decision errors.
7. Specify limits on uncertainty.
8. Optimize tlie design for obtaining data.
The following describes tlie specific application of the DQO process to this investigation.
(a) Project Rationale and Desired Outcome. CAIS materials and/or CWM residue may
be present on the Presidio. If tliis condition exists, it represents a hazard to residents,
woiters and visitors. The goal of tliis investigation is to confirm tliat neither CAIS
materials nor CWM residues are present at the study sites.
(b) Goals and Decisions.
i. For existing buildings tliat have been renovated . Buildingsrenovated within tlie
last 20 years will be checked for the presence of CAIS training materials in likely
storage locations. No testing for agent breakdown products will be conducted.
ii. For existing buildings that have not been renovated . Determine if CAIS materials
are present in likely storage locations. Collect wipe samples from likely storage
locations for agent breakdown product analysis.
iii. For former building locations . Determine if CAIS materials are present in
exposed soil in the immediately surrounding area. Collect shallow soil samples
for agent breakdown product analysis.
iv. For known training areas . Establish the location of trenches, foxholes, and
latrines. Determine if CAIS materials are present in these locations buried under
vegetation. Determine if CWM residues are present in shallow soils by sampling
a subset of the locations. Determine if CAIS materials were abandoned in latrine
holes by excavating a subset of the locations, examining the excavated soil for
CAIS materials, and collecting soil samples.
14
V. For possible training areas (no exact location} . Visually check for the presence of
CAIS materials. Detennine if CWM residues are present by collecting shallow
soil samples. A 11 soil samples to be analyzed for chemical agent breakdown
products.
(c) The Conceptual Site Model. The Conceptual Site Model (CSM) summarizes wliat is
known or can be surmised regarding CWM at the sites. The CSM for this investigation
begins with the introduction of CWM related training during World War 1 . Such training
would liave included procedures to decontaminate CWM as well as the use of individual
protective measures (donning the gas mask after detecting tlie characteristic odors) .
Mustard agent was a common persistent chemical agent in use during World War 1, and
was therefore a part of these chemical training exercises. Initially the mustard agent was
stored in a bulk container prior to the distribution of smaller guantities for a specific
training exercise. Later (1930s) the CAIS sets became available and replaced tlie larger
bulk mustard container. The CAIS sets contained mustard (H, HD), lewisite (L),
phosgene (CG), and cliloropicrin (PS). Both phosgene and chloropicrin are volatile and
would not persist if released from their sealed containers. Mustard was the most
prevalent persistent agent used during CWM training and the most likely to be identified
tlirough investigation sampling. Generally tlie training would be conducted outdoors,
near related chemical training such as the gas chamber, but some distance from otlier
military or civilian activities. In addition, CWM training was also conducted at the 1918
West Cantonment Trench System. The empty vials and bottles from the CAIS sets would
normally be collected and properly disposed of or buried after the training to prevent
accidental exposure to mustard or other CWM present in the kits. However occasionally
tlie vials or bottles were not properly disposed of as evidenced by tlie discovery near
Inspiration Point in 2002. Laige scale chemical training activities would not have taken
place at tlie Presidio, due to tlie limited space available for training and the high level of
otlier military activities (headquarters, major hospital, coast defense, etc.). The amounts
of mustard used in training was small and in most cases would either volatilize over the
years, or be completely hydrolyzed by exposure to tlie weather. However it is possible
tliat some mustard or breakdown products may be present in training area soil or witliin
unrenovated buildings. Most of the remaining mustard, if any, would be present as
"breakdown" products due to the time since the potential release (50 to 70 years).
Characteristic mustard breakdowns products are 1,4-oxathiane, 1,4-difhiane, and, to a
lesser extent, thiodiglycol (Munrow et at, 1999). The CAIS metal shipping container
and related packing materials were under the control of the Chemical Warfare Service
officer and were supposed to be recycled (sent back to Edgewood Arsenal) or properly
disposed of when tlie training CWM was completely expended, however in some
instances the shipping containers may have been abandoned or buried at the training site.
(d) Data Acquisition Strategy. The Sampling and Analysis Plan (SAP) is provided at
Appendix D . The components of the strategy are as follows:
i. For existing buildings tliat have been renovated . Conduct a through walk through
with emphasis on possible storage areas. Individuals knowledgeable about CWM
15
in general, and CAIS sets in particular, will conduct tlie walk tlirougli. Check the
entire building for the presence of discarded CAIS materials.
ii. For existing buildings that have not been renovated . Conduct tlie walk through as
for renovated buildings. Supplement this will collection of wipe samples from the
floor of likely storage locations. Collect one such wipe sample from each
building in tliis category. Analyze the wipe samples for chemical agent
breakdown products as described in the SAP
iii. For former building locations . Check tlie immediate area to confirm the absence
of CAIS materials. Collect a single shallow soil sample directly beneath
buildings used for training, storage, or maintenance of chemical warfare related
activities. All soil samples to be analyzed for chemical agent breakdown
products.
iv. For known training areas (Figure 6) . Use aerial photos and visible depressions
on the ground to identify trenches, foxholes and latrines. Seek concurrence in
these locations from stakeholders. Vegetation may need to be removed ortliinned
for access or to visually see the ground surface. Once agreement has been
reached regarding the trenches, foxholes and latrines, rake out forest duff to
confirm the absence of CAIS materials. Next collect one shallow soil sample
from every 30,000 sguare feet of the site containing trenches and foxholes. The
samples will be collected from within tlie trenches or foxholes. Select up to three
depressions identified as "latrine holes" for excavation with a backhoe. Conduct
the excavation in accordance with the UXO work plan (Appendix B). Check the
excavated soil to confirm the absence of CAIS materials. Collect two soil
samples from each excavated latrine hole (one from tlie sidewall and one from the
floor of the excavation}. All soil samples to be analyzed for chemical agent
breakdown products.
V. For possible training areas (no exact location} . Use all available information and
best professional judgment to best estimate where the training area might have
been located. Visually check the area to confinn the absence of CAIS materials.
Then collect at least one shallow soil sample in each possible training area (or one
for every 60,000 square feet of area}. All soil samples to be analyzed for
chemical agent breakdown products.
A summary of the data acquisition strategy is shown on Table 4 on the following page.
(e} Acceptable Level of Uncertainty. Visual surface checks for CAIS materials will be
considered adequate if all known trenches, foxholes and latrines are raked to remove
duff. Visual surface checks within buildings will be considered adequate if access is
available and knowledgeable team members conduct the search. The absence of CWM
residues in soil or from surface wipes shall be considered confirmed if tlie samples are
collected as described in this work plan and the analytical quality control measures
(defined in Appendix D} are deemed acceptable by the project chemist.
16
(f) Related Field Tasks.
Field Personnel. The field work will be accomplished by Corps of Fngineers and
contractor personnel.
Table 4. Summary of Data Acquisition Strategy
Location
Status
Visual
Check
Soil
Sample
Wipe
Sample
Pothole
1918 West Cantonment
Trench System
known training
area
Rake and
check
12
none
3
Baker Beach Gas Chamber
former location
check
1
none
none
Battery Chamberlin Gas
Chamber
present
check
none
2
none
Baker Beach Training
Area
possible
training area
check
2
none
none
Bldg 672 Gas Chamber
former location
check
1
none
none
CWS Storeroom, Bldg 670
former location
check
none
1
none
Chemical Corps, Bldg 667
renovated
check
none
none
none
Chem Warfare, Bldg 681
present
check
none
1
none
Cavalry Stables training
area
possible
training area
check
2
none
none
CWS Warehouse, Bldg 94
former location
check
1
none
none
CWS Office, Bldg 219
former location
check
1
none
none
CWS Emerg/Office, Bldg
222
present
check
none
1
none
Healtli and Safely. All work will be conducted in aoooidanoe with the Site Safety and
Healtli Plan (see Appendix E). Tlie Site Safety and Health Plan will address san^e
collection, vegetation removal, jJ^sical, insect, poison oak, and other hazards.
Digging Permits. Prior to conducting any excavations in the 1918 West Cantonment
Trench System, digging permits will be obtained from the Presidio Trust, the National
Park Service or other organizations.
Vegetation Removal. Vegetation removal will be necessary in the 1918 West
Cantonment Trench System. The purpose of the removal is to provide visibihty to allow
identification of trenches and also to provide access to the trenches for duff raking. No
more vegetation will be removed tlian is necessary. The Presidio Trust has notified the
Anny tliat vegetation removal cannot occur between March 1 and August 15, due to bird
nesting season. In addition, the Presidio Trust has confirmed that there are no wetlands
or endangered species within tlie 1918 West Cantonment Trench System study area.
Figure 7 shows the plan for initial vegetation removal. Presidio Trust biologists will be
invited to observe the vegetation removal activities.
17
Vegetation removal will be accomplished using small power tools such as chainsaws,
weed-wackers, and similar field portable equipment. Only equipment accepted by the
OE Safety Specialists will be used for vegetation removal. This will be supplemented
with hand tools such as shears and handsaws. The vegetation will initially be cut to a
height of no lower than six inches. OE Safety Specialists will be on hand to examine any
potential MEG or CWM item discovered during vegetation removal. Once trenches have
been identified additional vegetation will be removed to tlie ground surface, if necessary,
to allow unimpeded duff raking from within the trenches. The vegetation will be moved
to the stockpile location with a combination of wheelbarrows, small tractors, and all-
terrain vehicles equipped with trailers.
The vegetation removed from the site will initially be stockpiled near Pops Field ortlie
southern end of Quarry Road (possible locations are shown on Eigure 7). The stockpile
location(s) will be coordinated with the Presidio Trust to avoid inconveniencing the
public or local residents, as well as to prevent damage to infrastructure or vegetation.
The Presidio Trust mulching facility, if available, will be used to recycle cut vegetation.
If the on-site mulching facility is not available tlien the vegetation will either; 1) be
mulched attlie stockpile location and shipped off site, 2} be hauled off site to a recycleror
3) be hauled to a disposal facility. Hauling will be accomplished with either a small
truck, a small dump truck, or with a trailer. Presidio Trust trails and roads, and stockpile
locations, will be returned to their original condition after tire conclusion of vegetation
removal activities.
Site Control. Temporary barricades will be installed during the work in the 1918 West
Cantonment Trench System to prevent tlrose using hiking trails from exposure to physical
hazands such as vegetation clearing and potholing. The barricades will direct hikers to
detour around the site. Open excavations will be covered with plywood or otlrer material
when not under the direct control of the field team.
(3) Data Incorporated into SI, RI/ES, EE/CA Reports. Not Applicable to this Project
(4) MEC Exposure Analysis. NotApplicable to this Project
(5) Use of Time Critical Removal Actions During the Munitions Response project. Not
Applicable to tlris Project
(6) Eollow-on Activities. Not Applicable to this Project
b. Identification of Areas of C oncern
The study areas were selected based on evaluation of infonnation provided in the ASR.
c. G eophysical Prove ut Plan and Report, including C ontracting ff icer A pproval
Letter.
NotApplicable to this Project
18
d. G eophysical Investigation Plan
Not Applicable to this Project
e. Geospatial Information and Electronic Submittals
Not Applicable to this Project
f. Intrusive Investigation
Up to three excavations will be conducted within the 1918 West Cantonment Trench
System at suspected field latrine locations. These excavations will be performed using a
backlioe. OE Safety Specialists will oversee the latrine excavations using the procedures
set forfJi in Appendix B .
g. Investigation Derived Waste Plan
Investigation Derived Waste (IDW) generated during this investigation will be minimal
and consists of disposable sample collection equipment. In addition non hazardous waste
shall be generated. All of this waste will be property disposed of in municipal trash
receptacles.
h. Risli Characterization and Analysis
Not Applicable to this Project
i. Discussion on the Analysis of Institutional Controls
Not Applicable to this Project
j. Discussion on the preparation of the Recurring Review Plan
Not Applicable to this Project
19
C hapter 4. Q uality C ontrol Plan
a. Chemistry
The chemistry Sampling aiid Analysis Plan (SAP) is found at Appendix D.
b. CAIS Material Visual Checks
Training areas and building locations will be visually checked for the presence of CA IS
materials.
In the 1918 West Cantonment Trench System, a multi-phase process will be used to
ensure that all trenches have been evaluated. The process begins witli the selective
removal of vegetation to allow for tlie identification of the training positions (trenches
and foxholes). The Army will physically mark all training positions using survey stakes
and brightly colored tape. Concurrence will be sought with all stakeholders regarding the
selection of tlie positions. Once this has been achieved tlie next step will be to remove
vegetation from the training positions to allow forraking-outand checking of the forest
duff. To ensure completeness of the raking process the field team leader will check
100% of the training positions. This check will be documented in the field notebook.
All other locations will be visually checked for CAIS materials prior to sample collection
activities. This check will be documented in the field notebook.
c. Survey Data
Survey control will be established in the 1918 West Cantonment Trench System to allow
for identification of trenches, foxholes and latrine pits, and documentation of the
investigation. The horizontal and vertical accuracy of the survey will be no less than +/-
1.0 feet, as checked using appropriate quality' control procedures. The survey reference
will be Nortli American Datum, 1927, State Plane Zone 111 (feet).
20
Chapter 5. Explosives Management Plan
Not Applicable to this Project
21
Chapter 6. Explosives Siting Plan
Not Applicable to this Project
22
Chapter 7. Environmental Protection Plan
a. Sensitive receptors and resources
The Presidio Trust has confimied that while endangered species and wetlands do exist at
tlie Presidio, they are not located within the 1 91 8 West Cantonment Trench System study
area or the Baker Beach study area. Presidio Trust biologists will be invited to observe
all phases of the wort to ensure that no endangered species are inadvertently disturbed.
As discussed in Section 4, vegetation will be removed witliin the 1918 West Cantonment
Trench System study area to provide access and a clear view of the ground. Figure 7
shows the proposed initial vegetation removal.
b. Mitigation Measures
AU engine- powered equipment tliat is to be used shall be checked for leaks. Leaking
equipment will not be used until repaired or replaced. Equipment and sorbent materials
shall be on hand to collect any spills as soon as they occur. Plastic fencing or survey tape
will be used to identify vegetation or areas not to be disturbed during the field activities.
Every effort wiU be made to minimize disturbance to the study sites. The limited
potlioling will occur in areas with moist soil, so no dust generation is anticipated.
However should this become an issue, water spray will be used to minimize dust
generation. Equipment will be stored in areas selected to avoid unnecessary damage to
vegetation and to minimize inconvenience to local residents.
c. Post investigation clean-up activities
AU cut vegetation will be removed from the site or used as per direction from the Presidio
Trust. Forest duff raked-out of the trenches will be spread out at the original location and
will not be removed from the site. Trash and other debris generated during the
investigation will be collected on a daily basis and properly disposed. Investigation
equipment will be promptly removed from the Presidio after the conclusion of the field
wort.
23
Chapter 8. Property Management Plan
Not Applicable to this Project
24
Chapter 9. Interim Holding Facility Siting Plan for RCWM Projects
Not Applicable to this Project
25
Chapter 10. Physical Security Plan for RCWM Project Sites
Not Applicable to this Project
26
Chapter 11. References
Bowen, Robert W., 2005. Images of America, San Francisco' s Presidio . Arcadia
Publishing: CharlestDii, South Carolina.
Departmentof the Anny (DA), 2000. Army Regulation 385-10, Subject: Army Safety
Program. 29 February.
DA, 1998. Memorandum, DACS-SF, Subject: Applicability of Biological Warfare
Material and N on- Stockpile Chemical Warfare Materiel Response Activity Interim
Guidance. 19 March.
DA, 1997. Memorandum, D ASA (I, L&E), Subject: Interim Guidance for Biological
Warfare Materiel (BWM) and Non- Stockpile Chemical Warfare Materiel (CWM)
Response Activities. 5 September.
Innovative Technical Solutions, Inc. (ITSI), 2003a. Final Investigation Summary Report,
Investigation of Soil Piles, Presidio of San Francisco, ITSI, December.
ITSI, 2003b. Final WorkPlan, Investigation of Soil Piles, Quarry Road, Presidio of San
Francisco, California, ITSI, September.
International Technology' Corporation (IT), 1999. Project Memorandum, Presidio of San
Francisco, Additional Sites of Potential Environmental Concern: In-depth Historical
Research Results. Prepared forthe US Army Corps of Fngineers, Sacramento District.
February 17.
Munrow, Nancy B., Sylvia S. Talmage, Guy D. Griffin, Larry C. Water, AnnettaP.
Watson, Joseph F. King, and Veronique Hauschild, 1999. The Sources, Fate, and
Toxicit\' of Chemical Warfare A gent D egradation Products." Environmental Health
Perspectives, vol. 197, no. 12, pages 933-974. December.
National Park Service, 1997. D efender of the G ate: The Presidio of San Francisco, A
History from 1846 to 1995, Historical Resource Study, Volume I. Golden Gate National
Recreation Area, California. July.
U.S. Army Corps of Engineers (USAGE), 2004. Engineer Pamphlet 75-1-3, Subject:
Recovered Chemical Warfare Materiel (RCWM) Response Process. November.
USAGE, 2004. Memorandum, CEMP-CE, Subject: Interim Guidance-Notification
Procedures for Discovery of Recovered Chemical Warfare Materiel (RCWM) During
USAGE Projects. 23 April.
27
USAGE, 2003a. Final Archive Search Report, Presidio of San Francisco. St. Louis
District. October 6.
USAGE, 2003b. Memorandum, CESPK-DE, Subject: Probability Assessment for
Inspiration Point, Presidio of San Francisco, CA. 17 March.
USAGE, 2000. Engineer Pamphlet 75-1-2, Subject: Unexploded Ordnance (UXO)
Support During Hazardous, Toxic, and Radioactive Waste (HTRW) and Construction
Activities. 20 November.
U.S. Army Environmental Genter(USAEG), 1997. Final Remedial Investigation Report,
Presidio Main Installation, Presidio of San Francisco. Dames & Moore. Januaiy.
28
HGURES
N
A
Cavalry Stables Study Area
-immrr
750 1,500
3,000
4,500
I Feet
6,000
Figure 1
Chemical Warfare Material
Investigation Areas
Presidio of San Francisco
San Francisco, California
March 2006
Legend
Possible CWM Training Area
/
Battery Cliamberlin
(Building 1621
Figi
// Baker Beach Area "^
/=' Sample Locations ^
I ^/ r/>-- v ^ n
'' Presidio of San Francisco
J San Francisco, California ^^
V/^. March 2006
J 1 11 iH 11 n
Presidio of San Francisco
' San Francisco, California
March 2006
H
Wipe Samples
Soil Samples -V,
-V. 鈻?lt;鈻?gt;
^-::)
0,
JL
^^ ^i ^.
Jb
,^^ //CWS Office / A^
-."^(Building 21 9 / ^O
No Longer Present) ^
"CWS Emerg/Office"
'|^> (Building 222) 鈻?
Parade Field /
X._
鈧?gt;
/-鈻犫枲
,//
Xi^
/
y
-^鈻燸
./ /
'v:
"CWS Wareliouse'
/ (Building 94
// . No Longer P
^
^
^
鈻燩
^
-^
_y/
r
400
600
^ ff^-^
/
y'-^' Figure 5
/[A.-- Main Post Area
)// Sample Locations /
J^/ A-xx, //
'^'''-'^ Presidio of San Francisco
San Francisco, California '
l\/larcli 2006 '\J/ '--
Figure 7
1918 West Cantonment
Trench System
Vegetation Removal
Presidio of San Francisco
San Francisco, California
March 2006
APPENDIX A
CWM Sites Investigation Wort Plan, PSF - Appendix A
Probability A ssessment For
The Determination of the Applicability
of file Interim Guidance
1. PROJECT LOCATION: Presidio of San Francisco, San Francisco, CA
2. DATF: 14 November 2005
3. REFFRENCFS:
a. Memorandum, DASA (I, L&E), subject: Interim Guidance forBiological Warfare Materiel
(BWM) and Non-Stockpile Chemical Warfare Materiel (CWM) Response Activities, 5
September 1997.
b. Memorandum, DACS-SF, subject: Applicability of Biological Warfare Material and Non-
Stockpile Chemical Warfare Materiel Response Activity Interim Guidance, 19 March 1998.
c. Army Regulation 385-10, subject: Army Safety Program, 29 February 2000
d. Engineer Pamphlet 75-1-2, subject: Munitions and Explosives of Concern (MFC) Support
During Hazardous, Toxic, and Radioactive Waste (HTRW) and Construction Activities, 01
August 2004
e. Memorandum, CESPK-DE, subject: Probability A ssessment for Inspiration Point, Presidio
of San Francisco, CA, 17 March 2003.
f. Archive Search Report, USAGE, St. Louis District, subject: Presidio of San Francisco, 6
October 2003
g. Memorandum, CEMP-CF, subject: Interim Guidance-Notification Procedures for
Discovery of Recovered Chemical Warfare Materiel (RCWM) During USAGE Projects, 23 April
2004
h. Engineer Pamphlet 75-1-3, subject: Recovered Chemical Warfare Materiel (RCWM)
Response Process, Nov 2004.
4. BACKGROUND:
a. The Presidio of San Francisco (PSF) consists of 1400 acres on a point at the entrance to San
Francisco Bay in San Francisco, CA . The PSF sensed as a military post for the United States
from 1846 until 1995. Thousands of troops camped in tent cities awaiting shipment to tlie
Philippines in 1898. Later, the wounded soldiers returning from tlie war were treated at
Lettemian Army General Hospital that was established in 1898. By 1905 twelve coastal defense
batteries and accompanying anti-aircraft emplacements were located along the coast of PSF.
During WWII PSF became headquarters for the Western Defense Command and in 1946 PSE
became the headquarters for the Sixtli U.S. Army. PSE, a former Base Realignment and Closure
(BRAG) site, is presentiy managed joindy by the National Part Service and tlie "Presidio Trust".
Appendix A 1 March 2006
CWM Sites Investigation Wort Plan, PSF - Appendix A
A 1999 Memorandum of Agreement stipulates that the Army retains sole responsibility for
remediation of Ordnance and Explosives (OE) and Chemical Warfare Materials (CWM).
b. In early October 2002, volunteer woiters at PSF conducting a native plant restoration
projectwithin tlieareaof the 1918 West Cantonment Trench System located four vials marked
"HS Toxic Gas Set Ml". Three vials were unsealed but a fourth had a lid and contained a
crystallized black residue. On 22 October a team from theU.S. Anny Technical Escort Unit
arrived and subsequentiy removed tlie vials. A naly sis testing confirmed tliat each bottle
contained mustard agent residue. The vials were from a Chemical A gent Identification Sets
(CAIS) Toxic Gas Set, Ml, K941 typically used in Chemical Warfare detection and
decontamination field exercises. Although tlie vials were removed, concerns remained regarding
possibility of additional vials being concealed in tlie 137-cubic yards of soil and organic forest
material (hereinafter "leaves") tliat had been gathered and stockpiled or gathered and placed in
bins.
c. CESPK prepared a work plan to investigate tlie soil and leaves for tlie presence of
additional CAIS materials. The woit plan included a Probability Assessment (reference 3e)
relative to finding additional CAIS material in stockpiles/bins. Results of the Probability
Assessment are as follows:
ITEM
AR 385-10 (15 Oct. 1979)
AR 385-10 (29 Eeb. 2000)
K941 PIG
Improbable
Unlikely
K941 Can
Improbable
Unlikely
K941 Bottle
Remote
Seldom
In October 2003 tlie remaining soil and leaves were investigated and no CAIS materials were
found.
d. An Archives Search Report (ASR), detailing OE and CWM military training activities on
the Presidio of San Francisco, was finalized on 6 October 2003 (reference 3f). According to tlie
ASR the only CWM (discounting irritants, smokes, and simulants) utilized for training on PSF
were Chemical A gent Identification Sets (CAIS) and one- 100 pound container of bulk mustard
agent, the bulk agent was never loaded into munitions. All three types of CAIS were used at
PST: instructional, detonating, and toxic sets. These sets and tlie bulk agent were most likely
utilized between 1930 and 1950. K941 CAIS contained glass vials of Mustard (H) or Distilled
Mustard (HD). K951/K952 CAIS contained Pyrex vials of Mustard (H), Tewisite (T),
Chloropicrin (PS), and Phosgene (CG). Witliin the ASR three sites are listed as possible CWM
training sites: 1918 West Cantonment Trench System, BakerBeach Gas Chamber, and Gas
Chamber Building 672. CEHNC-OE-CX reviewed tlie ASR on 18 November 2003 and
recommended further investigation of tlie three sites. The A SR also noted the presence of
several other buildings historically appearing to have connection to CWM activities (storage,
offices, classrooms or training facilities). However, overtime and to accommodate changing
missions and activities, the initial purpose of these buildings transitioned to purposes apparently
unrelated to CWM activities. The ASR provided no recommendations relative to these historical
"CWM" buildings. The CEHNC-CW Design Center did conduct a ranking of tlie site using tiie
Scoping and Security Study protocols for determining residual risk and hazard assessment. The
Appendix A 2 March 2006
CWM Sites Investigation Wort Plan, PSF - Appendix A
CEHNC-CW Design Centerconcurredwitii the Probability Assessment for the Detennination of
Applicability.
5. SCOPE OF PROPOSED SITE ACTIVITIES:
At the reguest of the Presidio Trust, the U.S. Army Corps of Engineers, Sacramento District
proposes to investigate for the presence/non- presence of CAIS vials and/or Agent Breakdown
Products (ABP) by conducting investigative activities within the following areas and sites:
a. 1918 West Cantonment Trench System :
(1) Identify the locations of all trenches and foxholes. The general boundaries of the site
are known however, prior to field activities, aerial photographs will be studied in an attempt to
more closely delineate the exact location of tlie trenches. Tocations of trenches and foxholes will
be transposed to the PSF Geographical Information System (CIS) map. Limited brush removal
activities, within designated lanes, may be employed to enable visual identification of tlie
trenches and foxholes. Once the trenches are located, hand-rake the leaves from
trenches/foxholes then visually inspect the trenches/foxholes for tlie presence of discarded CAIS
vials.
(2) Preparatory to returning the area to its natural state i.e., native plant restoration, the
USACE may be requested to confirm/deny the presence of CAIS vials over the entire West
Cantonment Trench area versus just tlie trenches. This effort would involve mechanically
mowing or shredding the non-native plant species and then raking and removing the debris along
with approximately two to four-inches of detritus organic forest materials. Limited geophysical
technology may be employed to assist with the visual surface sweep of the area.
(3) Investigate for presence of discarded CAIS materials/vials in the pre- 1950 "latrines".
The exact location of tlie latrines is unknown however it is known they are near die trenches.
Utilizing heavy equipment (backhoe or similar mechanical excavator), excavate to native soil
depth and visually inspect the spoils for the presence of CAIS materials. Limited soil sampling
of the excavation sidewalls and spoils for ABP may be incorporated for assurance purposes.
b. Baker Beach Gas Chamber : The general location of the facility is known however the
exact location is unknown. USA CE will visually reconnoiter tlie area {including B attery
Chamberlin and Baker Beach) in an attempt to ascertain tlie facility's previous location. Shallow
surface soil sampling or wipe sampling may occur within any of the locations to confirm/deny
the existence of agent breakdown products or agent- in- soil. NOTE: Agent in soil is not
considered CWM but will he identified, handled, and managed lAW 29 CFR 1910.120, 40 CFR
260-279, and/or 40 CFR 300, AR 50-6, and other applicable laws and regulations. Limited
geophysical technology may be employed to assist in locating tiie gas chamber's structural
footings.
c. Gas Chamber Building 672 : The general location of the facility is known however tlie
exact location is unknown. USA CE will visually reconnoiter tlie area in an attempt to ascertain
the facibty ' s previous location. Shallow surface soil sampling may occur to confirm/deny the
Appendix A 3 March 2006
CWM Sites Investigation Wort Plan, PSF - Appendix A
existenceof agent breakdown products or agent-in-soil. NOTE: Agent in soil is not considered
CWM but will be identified, handled, and managed lAW 29 CFR 1910.120, 40 CFR 260-279,
and/or 40 CFR 300, AR 50-6, and other applicable laws and regulations. Limited geophysical
technology may be employed to assist in locating tlie gas chamber' s structural footings.
d. Otlier buildings and structures witli historical CWM association:
(1) Building 670 (post-1943 #174): This structure was originally constructed in 1921 as a
"Chemical Warehouse". It has also been tided the "Communication Switch Board Room" but in
1934 was turned over to "other uses". The location of tlie facility is known. Shallow surface soil
sampling may occur to confirm/deny the existence of agent breakdown products or agent-in-soil.
NOTE: Agent in soil is not considered CWM but will he identified, handled, and managed lAW
29 CFR 1910.120, 40 CFR 260-279, and/or 40 CFR 300, AR 50-6, and other applicable laws
and regulations. Limited geophysical technology may be employed to assist in locating the
structure's foundation.
(2) Building 94 (earlier bldg, fe: 25 & 151A) was noted on 1939-1940 historical
documents as a "CWS (Chemical Warfare Service) Warehouse". By 1942 tliis building was no
longer listed as being used by the CWS. This building has been demolished however die general
location of the structure is known (comer of A nza Ave. and Sheridan Ave.) USA CE will
visually reconnoiter the area in an attempt to ascertain the structure' s previous location. Shallow
surface soil sampling may occur to confirm/deny tlie existence of agent breakdown products or
agent-in-soil. NOTE: Agent in soil is not considered CWM but will be identified, handled, and
managed lAW 29 CFR 1910.120, 40 CFR 260-279, and/or 40 CFR 300, AR 50-6, and other
applicable laws and regulations. Limited geophysical technology may be employed to assist in
locating tlie structure's foundation.
(3) Building 219 (earlier bldg. #s: 42 & 181) was noted on a May 11 1940 document as
"C.W.S Office". By 1942 this building was no longer listed as being used by the CWS. The
building has been demolished however the general location (next to tlie existing fire house) is
known. USA CE will visually reconnoiter the area in an attempt to ascertain the structures
previous location. Shallow surface soil sampling may occur to confirm/deny the existence of
agent breakdown products or agent-in-soil. NOTE: Agent in soil is not considered CWM but
will be identified, handled, and managed lAW 29 CFR 1910.120, 40 CFR 260-279, and/or 40
CFR 300, AR 50-6, and other applicable laws and regulations. Limited geophysical technology
may be employed to assist in locating the structure's foundation.
(4) Building 222 (earlier bldg. #s: 187 & 198) was noted in 1942 as being the "CWS
Emeig." building. This building was in close proximity to buildings 94 and 219 (mentioned
above). This building presently exists and is maintained to historical building standards.
USACE will visually reconnoiter tlie building and surrounding area in an attempt to ascertain the
presence or non- presence of CWM or ABP. Shallow surface soil sampling orwipe sampling
may occur to confirm/deny the existence of agent breakdown products or agent-in-soil. NOTE:
Agent in soil is not considered CWM but will be identified, handled, and managed lAW 29 CFR
1910.120, 40 CFR 260-279, and/or 40 CFR 300, AR 50-6, and other applicable laws and
regulations.
Appendix A 4 March 2006
CWM Sites Investigation Wort Plan, PSF - Appendix A
(5) Building 667 (earlier bldg #s: 62 & 164) and building 681 (earlier bldg #s: 26 & 83) are
noted as "Multi Use" buildings. Records from the 1940's indicate tlie Chemical Warfare Service
used the buildings however tlie specific use remains unknown. These buildings are present
today. Because these buildings existed in close proximity to a known gas chamber (building
672) there may have been a CWM relationship. The USACE will visually reconnoiter the
buildings and tlie surrounding areas in an attempt to ascertain the presence or non- presence of
CWM or ABP. Shallow surface soil sampling orwipe sampling may occur to confirm/deny the
existence of agent breakdown products or agent- in- soil. NOTE: Agent in soil is not considered
CWM but will be identified, handled, and managed lAW 29 CFR 1910.120, 40 CFR 260-279,
and/or 40 CFR 300, AR 50-6, and other applicable laws and regulations.
6. PROBABILITY ASSESSMENT:
The following table summarizes tlie probability of encountering CWM at each site:
AREA
PROBABILITY PER
AR 385-10 (29 Eeb. 2000)
1918 West CantDnnient Trench System
SELDOM. Remotely possible; could occur at some time
BakerBeachGas Chamber
UNLIKELY. Can assume will notoccur, butnot
impossible
Gas ChamberBuilding 672
UNLIKELY. Can assume win notoccur, butnot
impossible
Building 670 (Chemical Warehouse)
UNLIKELY. Can assume will not occur, butnot
Impossible
Building 94 (CWS Warehouse)
UNLIKELY. Can assume will notoccur, butnot
impossible
Building 219 (CWS Office)
UNLIKELY. Can assume win not occur, butnot
impossible
Building 222 (CWS Emergency Bldg.)
UNLIKELY. Can assume will not occur, butnot
impossible
Building 667 (Multi-use Bldg./CWS connection)
UNLIKELY. Can assume will notoccur, butnot
impossible
Building 681[Multi-use Bldg./CWS connection)
UNLIKELY. Can assume win not occur, butnot
impossible
a. 1918 West Cantonment Trench System .
(1) According to the Archive Search Report the only CWM (discounting irritants, smokes,
and simulants) utilized for training on PSE were Chemical Agent Identification Sets (CAIS) and
one- 1 00 pound container of bulk (in a container but not in a munitions) mustard agent. A II three
types of CAIS were used at PST: instructional, detonating, and toxic sets. These sets and bulk
agent were most likely utilized between 1930 and 1950. The ASR site inspection team located
no physical evidence of CAIS or containerized agent. The October 2002 incident confirms CAIS
were present on PSE however in October 2003, when the remaining soil and leaves were
investigated, no other CAIS materials were found.
(2) In concurrence with the ASR, it remains believable, based on area size and
configuration, that the 1918 West Cantonment Trench System was a training area for a squad
versus a platoon. Historically a squad, based on tlieir size, would be issued a single can
Appendix A
March 2006
CWM Sites Investigation Wort Plan, PSF - Appendix A
containing 4-vials versus an entire CAIS set containing 12-viaIs. This thought process effectively
limits the issued amount of vials for any given training day.
(3) The ASR's "Textual References" section contains historical documents, including
monthly activity and training reports, that identify CWM training of various types {gas mask, gas
defense, trench warfare, gas employment and effect, anti-gas instruction, chemical clouds, etc.)
occurred from as early as 1918 and continued through 1950. AMiough not specifically
documented {within iJie ASR), training would also have included the hazards associated with tlie
CAIS. Given troops were CAIS trained, it is unlikely tliey would discard CAIS vials (in the
trench training area) because this act would knowingly be hazardous to their fellow soldiers who
would also be trained in tlie area. Additionally the ASR notes that PSF elements such as the
"School of Gas Defense" and "Chemical Warfare School" conducted CWM troop training. The
ASR also notes a "Chemical Warfare Officer" was assigned on PSF. These notes suggest
knowledgeable staff personnel supervised trench area evolutions hence abandonment (in this
area) of CAIS vials would have been prohibited. The ASR also mentions "lack of funding for
training" so abandonment of vials would have also been monetarily prohibitive.
{4) The ASR made no mention of the latrines located within the 1918 West Cantonment
Trench System area. Historically OF and otlier items have been discarded in latrines and found
years later either accidentally or during the process of environmental restoration. The same
principles mentioned above {troop training, supervision of personnel, and cost) would prevent
intentional discarding of CAIS material within tlie latrines, however it remains remotely possible
for OF to be discarded within the latrines hence it is recommended excavation of latrines be
undertaken utilizing UXO personnel to provide safety support.
{4) Conclusion. Based on tlie above analysis it is credible the four vials located in 2002
were accidentally left behind on a "one-time" occasion versus vials being intentionally discarded
on a routine bases. Additionally, a large part of this area has in the past and continues today to
receive thousands of visitors on an annual basis. Visible CAIS vials most certainly would have
been discovered and shallow buried CAIS vials would have been stepped on and broken thereby
reducing the effective persistency of the agent. It is however remotely possible for CAIS vials
to remain below a shallow depth of organic forest material or within the latrines hence {per
reference 3c) the probability of CWM encounter on this site is considered to be: SELDOM,
Remotely possible; could occur at some time.
b. BakerBeach Gas Chamber .
{!) The ASR could not confirm nor deny that CAIS vials were used at tliis site nor in the
area surrounding the site, including Baker Beach and Battery Chaniberlin. The ASR site
inspection team located no physical evidence of CAIS presence at the probable location of the
gas chamber or at Baker Beach and Battery Chamberlin. The USA C, Sacramento District has
previously conducted visits over this entire area and located no physical evidence of CAIS
presence. The entire area has in the past and continues today to receive thousands of visitors on
an annual basis. The area remains void of most vegetation so if by chance a bottle were disposed
of it appears likely it would have been discovered.
Appendix A 6 March 2006
CWM Sites Investigation Wort Plan, PSF - Appendix A
(2) The ASR didconfinn tlieuseof CS and CN witliin Gas Chamber operations at Battery
Chamberiin however these agents do notfall within the CWM realm. Gas clianiber operations
do not lend themselves to disposal of CAIS vials. Typically chamber activities would be very
controlled hence issuance of an agent bottle would be limited by what was actually needed and
that amount would be used versus discarded.
(3) Shallow surface sampling may be conducted over the entire area of BakerBeach,
Battery Chamberiin and tlie suspected gas chamber's location. Although there is no evidence of
previous use of CAIS materials, sampling personnel will nonetheless be trained to collect
samples gently and to halt sampling activities should an obstacle impede tlie sampling effort.
The obstacle will be considered to be a CAIS botde and will be investigated only to tlie point tliat
renders a positive identification of tlie obstacle.
(4) Conclusion . There is no evidence to suggest CAIS materials were used at this site
however there is evidence that CAIS materials were utilized on the PSF. The incorporation of
protective sampling processes will prevent breakage of a botde in the unlikely event one is
encountered hence the possibility of personal contamination is very greatiy minimized. Based on
this infonnation and in accordance with reference 3c the probability of CWM encounter is
UNLIKELY. Can assume (agent encounter) will not occur^ but not impossible.
c. Gas Chamber Building 672 .
(1) The ASR could not confirm nor deny that CAIS vials were used at or near this site. The
ASR site inspection team located no physical evidence of CAIS presence at the probable location
of the gas chamber. The USAC, Sacramento District has previously conducted visits to this site
and they located no physical evidence of CAIS presence. The entire area has in the past and
continues today to receive thousands of visitors on an annual basis. The area remains void of
most vegetation so if by chance a bottle were disposed of it appears likely it would have been
discovered.
(2) The ASR didconfinn the use of CS and CN witliin Gas Chamber operations however
these agents do not fall within the CWM realm. Gas chamber operations do not lend tliemselves
to disposal of CAIS vials. Typically chamber activities would be very controlled hence issuance
of an agent bottle would be limited by what was actually needed and tliat amount would be used
versus discarded.
(3) Shallow surface soil sampling to a depth of 12-inches may be conducted in this area.
Although there is no evidence of previous use of CAIS materials, sampling personnel will
nonetheless be tinned to collect samples gently and to halt sampling activities should an obstacle
impede the sampling effort. The obstacle will be considered to be a CAIS bottle and will be
investigated only to the point that renders a positive identification of the obstacle.
(4) Conclusion . There is no evidence to suggest CAIS materials were used at this site
however there is evidence that CAIS materials were utilized on the PSF. The incorporation of
protective sampling processes will prevent breakage of a botde in the unlikely event one is
encountered hence the possibilily of personal contamination is very gready minimized. Based on
Appendix A 7 March 2006
CWM Sites Investigation Wort Plan, PSF - Appendix A
this infonnation and per reference 3c the probability of CWM encounter is UNLIKELY. Can
assume will not occur, but not impossible.
d. Other buildings and structures with historical CWM association.
(1) Very limited infonnation is available as to the historical use of these buildings. There is
no evidence to suggest CATS or CWM materials were ever used or stored witliin these structures
but tliere is also no evidence to the contrary. Throughout the years building numbers changed,
buildings were assigned different usages, and buildings were demolished. What is apparent from
comparison of historical maps to present day maps is that all of the structures with perceivable
CWM association existed within areas that have continuously undergone marked increases of
personnel (tourists, PSF woiters, contractors). Additionally, and over the past years,
rejuvenation and maintenance of historical buildings within these areas has been substantial.
(2) There are two areas tliat generally encompass the historical CWM structures/locations.
(a) The first area, encompassing buildings 670, 667 and 681, is located in the north-
central portion of PSF. Building 667 is presently the Park Archives and Record Center and
houses a staff of individuals. Building 681 remains as a historical building and is maintained to
historical standards. Building 670 also exists today as a historical structure and is located in
close proximity to the Park Archives and Record center.
(b) The second area, encompassing buildings 94, 219 and 222 is located in the
northwest portion of PSF generally in the "Main Post" area. Tlie Main Post area presently
consists of numerous occupied buildings (National Park Service Visitor Center, bowling center,
Presidio Trust offices, Chapel, Post Office), historical buildings, parking lots, and manicured
grounds.
(2) Conclusion . Considering botli general areas and buildings within those areas are
consistently maintained for historical purposes by the Presidio Trust and given the high volume
of tourist traffic the two areas generate, it is considered extremely unlikely CA IS materials could
possibly remain undiscovered. Certainly the one container of bulk mustard agent could not
remain undiscovered. Based on this and per reference 3c the probability' of encounter is
UNLIKELY. Can assume (agent encounter) wiU not occur, but not unpossible. There is a
possibility that shallow surface soil sampling will detect the existence of agent breakdown
products. Agentin soil is notconsidered CWM but will be identified, handled, and managed
lAW 29 CFR 1910.120, 40 CFR 260-279, and/or40 CFR 300, AR 50-6, and other applicable
laws and regulations.
7. RECOMMENDATIONS:
a. Based on review of listed references and the conclusions above it is recommended
proposed site activities proceed as Non-CWM (i.e., the Interim Guidance, reference 3a, will not
be implemented).
b. In accordance with reference 3b, tlie Site Safety and HeaMi Plan for the proposed site
activities will include contingency plans providing for a safe and expeditious response in the
Appendix A 8 March 2006
CWM Sites Investigation Wort Plan, PSF - Appendix A
event an item of unknown fill is encountered. The plan shall include the requirement for daily
safety briefings covering hazards associated with CATS. If during work activities a suspect
CWM item is located, all work will immediately cease, project personnel will withdraw along
cleared patli upwind from the discovery, and two personnel will secure the site to prevent
unauthorized access. An Explosive Ordnance Disposal (EOD) or a 20'^ Support Command
(formeriy TEXJ) response will be requested. The notification procedures for discovery of
Recovered Chemical Warfare Materiel sliall be in accordance witli reference 3g. Once CWM is
located work may not resamie without reevaluation of the ate.
c. The ASR identified the 1918 West Cantonment Trench System as an area that, in addition
to CWM activities, could have been a training area for "grenades and possibly other munitions".
To date no Munitions or Explosives of Concern (MEC) have been discovered in this area hence,
lAW reference 3d, tlie probability of encounter is considered to be "Low". Therefore it is
recommended tlie proposed activities be conducted utilizing UXO qualified personnel to provide
"Safety Support" during construction (hand- raking, mowing, mulching, brush cutting, excavation
of latrine) activities.
d. The ASR did not identify the other sites as possible MEC sites however it is considered
prudent to provide UX qualified personnel to provide "Safety Support" during sampling
activities within these areas.
A.R.Smith
Chief, Safety and Occupational Health Office
Appendix A 9 March 2006
APPENDIX B
CWM Sites Invesligalion Work Plan, PSF - Appendix B
Uieqioded Onlmnoe (UXO) Wcrk Flan
Appendix B March 2006
CWM Sites Investigation Wort Plan, PSF - Appendix B
APPENDIX B - TABLE OF CONTENTS
1.0 INTRODUCTION- - -1
1.1 Location 鈥?1
1.2 Facility Histon' 1
1.3 Previous Investigations 1
1.4 Topography/Geology 2
1.5 Climate- - - - - - 2
2.0 TECHNICAL MANAGEMENT PLAN鈥?- - 2
2.1 General - - - 2
2.2 Chemical Warfare Material (CWM) 3
2.3 UXO/MEC 鈥?
2.4 UXO/MEC Safety Support Plan -6
2.5 Operations Seguence of Tasks - 8
3.0 REPORTS/LOGS 9
3.1 Daily Log -9
3.2 After Action Report- - 鈥?
3.3 Report of Suspect CWM 10
4.0 SAFETY 10
Appendix B i March 2006
CWM Site Investigation Work Plan, PSF - Appendix B
1.0 INTRODUCTION
This Unexploded Ordnance (UXO) Work Plan (WP) was prepai'ed by the U.S. Army Corps of
Engineers, Sacramento District (CESPK) to describe procedui'es and protocols to be followed
during investigative efforts to determine the presence/non-presence of Chemical Agent
Identification Sets (CAIS) vials and/or Agent Breakdown Products (ABP) at the Presidio of San
Francisco (PSF), California. The work required under tliis project uivolves UXO Safety Support
during brush cutting, raking, shallow surface sampling, swipe-sampling and excavation
activities.
1.1 Location
The Presidio of San Francisco (PSF) consists of 1400 acres on a point at the entrance to San
Francisco Bay in San Francisco, CA. The following areas will be investigated: 1918 West
Containment Trench System, Gas Chamber Building 672, Baker Beach Gas Chamber, Storeroom
Building 670, Multi-use Buildings 62 and 26, CW/Emergency Building 1 87, Office Building
181, and Storeroom Building 151A,
1.2 Facility History
The PSF served as a military post for the United States from 1846 until 1995. Thousands of
troops camped in tent cities awaiting sliipment to die Philippines m 1 898. Later, the wounded
soldiers returning from die war were treated at Letterman Aimy General Hospital that was
established m 1 898. By 1 905 twelve coastal defense batteries and accompanying anti-aircraft
emplacements were located along die coast of PSF. Dming WWII PSF became headquarters for
the Western Defense Command and in 1 946 PSF became the headquarters for the Sixth U. S.
Army. The PSF, a former Base Realignment and Closure (BRAC) site, is presently managed
jomtly by die National Park Seivice and tlie "Presidio Tnist". A 1 999 Memorandmn of
Agreement stipulates tliat the Army retains sole responsibility for remediation of Ordnance and
Explosives (OE) and Chemical Warfare Materials (CWM).
1.3 Previous Investigations
In early October 2002, volunteer workers at PSF conducting a native plant restoration project
witlim the area of the 1 91 8 West Cantonment Trench System located four vials marked "HS
Toxic Gas Set Ml". Tliree vials were vmsealed but a foui'th had a lid and contained a crystallized
black residue. On 22 October a team from die U.S. Army Technical Escort Unit aiTived and
subsequently removed die vials. Analysis testing confirmed tliat each bottle contained mustard
agent residue. The vials were from a Chemical Agent Identification Sets (CAIS) Toxic Gas Set,
Ml, K941 typically used in Chemical Warfare detection and decontamination field exercises.
AMiough the vials were removed, concerns remamed regarding possibility of additional vials
being concealed in the 1 37-cubic yards of soil and organic forest material diat had been gathered
and stockpiled or gatliered and placed in bins.
CESPK prepai'ed a work plan to investigate die soil and forest material for the presence of
additional CAIS materials. The work plan included a Probability Assessment relative to finding
additional CAIS material in stockpiles/bins. In October 2003 tlie remaining soil and leaves were
investigated and no CAIS materials were found.
Appendix B 1 January 06
CWM Site Investigation Work Plan, PSF - Appendix B
1.4 Topography/G eology
1 .4.1 Topography of the Presidio is higlily variable wMi elevations ranging from sea
level along the northern and western bomidaries to approximately 400 feet above Presidio lower
low water (feet LLW). The topographic high point is located adjacent to the Presidio Golf
Course in the south central portion of tlie Presidio.
The noitliem boundary along San Francisco Bay is a low flat area developed on fill material. In
contrast, the western boundary along die Pacific Ocean is very steep with slopes averaging 50
percent. Baker Beach, at tlie base of these steep slopes, is a relatively naiTow strip of land. The
interior portions of die Presidio, including the eastern and southern bomidaiies, are characterized
by gently rolling lulls. Slopes in the western half of tlie installation typically average 20 percent.
Slopes in the eastern half, where most buildings are located, typically average 5 percent.
1 .4.2 For a detailed report on die geologic setting refer to USAGE, Presidio of San
Francisco, California Draft Basewide Groundwater Monitoring Plan, July 1 996.
1.5 Climate
Summertime m San Francisco is chai'acterized by cool marine air and persistent coastal
stratus and fog, witli average maximum temperatures between 6O0F and TOoF, and
minima between 5O0F and SSoF. The mornings typically find the entu'e city overcast
followed by clearing on the warmer bay side, but only partial clearing on die cooler ocean
side. Westerly winds are chamieled dirough tlie Golden Gate reaching a maxiniLim
during tlie afternoon widi speeds between 20 and 30 miles per hour being typical.
Rainfall from May through September is relatively rare, witli an aggregate of less than an
inch, or only about 5 percent of the yearly average total of approximately 21 .5 inches.
Winter temperatui'es in San Francisco are temperate, with highs between SSoF and 6O0F
and lows in the 450F to SOoF range (Null, 1978). Wmtertmie fog is less common than
that of summer, but is typically much denser and has a greater impact upon transportation
systems due to greatly reduced visibilities. Over 80 percent of San Francisco's seasonal
ram falls between November and March, occurring over about 1 days per month. Wmter
thimderstonns occur on the average only twice per season.
Sprmg and fall are transition periods for San Francisco. These seasons usually produce
the most cloud-free days. San Francisco's hottest days are typically during the spring and
fall. The occuri'ence of rainfall during the early spring and fall is infrequent, widi only
about 5 days per month on the average. While most storms dui'mg these periods produce
light precipitation, the occasional storm can produce heavy ramfall events.
2.0 TECHNICAL MANAGEMENT PLAN
2.1 General
2.1 .1 UXO support activities shall be conducted in full compliance with United States
Army Coips of Engineers (USAGE), Department of Army (DA), and Depai'tment of Defense
Appendix B 2 January 06
CWM Site Investigation Work Plan, PSF - Appendix B
(DoD) requirements regarding personnel, equipment, and procedures. (All UXO operations shall
emphasize anomaly avoidance, whenever possible, and be performed m a maimer consistent with
the Comprehensive Envu'onmental Response, Compensation, and Liability Act [CERCLA] and
the National Contingency Plan [NCP]. Therefore, the adminish'ative requirements of Federal,
state, or local permits are not requu'ed for implementation of any UXO procedm'es, including on-
site destruction of UXO, if required, but the substantive permit requirements must be fulfilled.)
2.1 .2 The provisions of 29 CFR 1910.120 shall apply to all UXO-related actions taken
at tins site. In addition, UXO personnel involved in perfoiming UXO tasks will be limited to a
1 0-hour workday and a 40-hour workweek. Two consecutive workweeks shall be separated by a
minimum of 48 hours of rest.
2.2
Chemical Warfare Material (CWM)
2.2.1 Chemical Warefare materiels have been used on the PSF. The Archive Seai'ch
Report noted Chemical Identification Sets and bulk agents (One 1 GO pomid container of Mustard
agent) as having been present on tlie PSF. The October 2003 location of CAIS vials confirms
that m fact CAIS were trained with on tlie PSF. Because CWM materials were discovered a
CWM Probability Assessment for all ai'eas of tlie planned investigative work was conducted and
tlie Sacramento District Commander authorized work to proceed as "non-CWM activities". The
conclusions of the CWM Probability Assessment are as follows:
AREA
PROBABILITY PER
AR 385-10 (29 Eeb. 2000)
1918 West Cantonment Trench System
SELDOM. Remotely possible; could occur at
some tune
Baker Beach Gas Chamber
UNLIKELY. Can assume will not occm; but
not impossible
Gas Chamber Building 672
UNLIKELY. Can assume will not occur, but
not impossible
Building 670 (Chemical Warehouse)
UNLIKELY. Can assume will not occLir, but
not impossible
Bmldmg 94 (CWS Warehouse)
UNLIKELY. Can assume will not occm", but
not impossible
Buildmg 219 (CWS Office)
UNLIKELY. Can assume will not occur, but
not impossible
Bmldmg 222 (CWS Emergency/Office)
UNLIKELY. Can assume will not occur, but
not impossible
Building 667 (Multi-use Bldg.)
UNLIKELY. Can assume will not occur, but
not impossible
Building 681 (Multi-use Bldg.)
UNLIKELY. Can assume will not occLir, but
not impossible
In addition to actual CWM agent, tlie following items were also known to exist on the PSF;
smoke pots, generators, riot control agents (CS, CN), and simulants.
Appendix B
January 06
CWM Site Investigation Work Plan, PSF - Appendix B
2.2.2 In tlie event suspect CWM is encountered, all work will immediately cease and
project persomiel will be evacuated along cleared patlis upwind from the discoveiy. The OE
Safety Specialists shall access tlie need to notify or evacuate any additional ai'eas within
proximity of the discovery. A team consisting of a minimum of two USAGE persomiel shall
immediately secure the area to prevent unauthorized access. Personnel should position
themselves as far upwind as possible wliile still maintaining secui'ity of tlie area. USAGE
personnel will continue to secui'e the site until relieved by Officers from the Presidio Tiiist Police
Department.
2.2.3 The USAGE has been requested to initiate the appropriate response actions in the
event Recovered Chemical Warfare Materiel (RGWM) is discovered (at tins BRAG site). The
OE Safety Specialist will immediatelY initiate response actions and sunultaneously notify
appropriate autlionties per the following table:
RCWM REPORTING POINTS OF CON
rTACT
POC
PHONE
PURPOSE
Presidio Tiust Police Depaitment
(415)561-5656
Dept. persomiel will provide a
secmity force to prevent
unauthorized access to the
discoveiy. They will notify their
Law Enforcement Chain of
Command
Ml. Wilson Walteis (primaiy POC)
(256)895-1290
Mr. Walters or Mr. Hubbard will
CEHNC-OE-CW
contact appropriate response
authorities (i.e., EOD oi 20*
Ml. Hank Hubbard (secondary POC)
(256)895-1586
Suppoit Command (Foimerly
CEHNC-OE-CX
TEU) and witliin 3-hours notify:
Army Operation Center
Director of Army Safety
HQ USAGE
and
FORSCOMEOC
Mr. A. R. Smitli
(916)557-6973
District Safety Office will notify
CESPK-SO
District Commander, PAO, and
State Local
Govermnent/C or^r essional
Authorities. Coordinate
w/District Commander for media
release.
Mr. Bmce Handel (piimary POC)
(916)557-7906
Mr. Handel or Mr. Call will
CESPK-PM-M
Inform the USAGE Project Team
Ml. Brad Call
CESPK-ED-GE (secondary POC)
(916)557-6649
Ml. Rogei Caswell
(510)909-4804
Notify BRAC colleagues
BRAC Enviromnental Coordinatoi (BEC)
Mr. Craig Cooper
(415)561-4259
Presidio responsibilities and
Presidio Trust
colleagues
Ml. Robert Boggs
(510)540-3751
Notify DTSC colleagues
DTSC
Appendix B
January 06
CWM Site Investigation Work Plan, PSF - Appendix B
The USAGE shall also prepare a Chemical Event Report per the guidelines presented in
paragraph 3.3 however initial reporting shall be by telephone and shall transmit as much Event
Report information as is available.
2.3 UXO/MEC
2.3.1 There have been no reported discoveries of MEC/UXO on these sites however die
ASR noted "Training witli grenades and possibly other munitions" occuiTed within die area of
the "1 91 8 West Cantonment Trench System". Because tliere "may" be MEC present at this
location, the USACE will, lAW EP 75-1-2, provide MEC standby support dui'ing all
investigative processes at this site (1 91 8 West Cantomnent Trench System). At this site two-
USACE OE Safety Specialists will provide tlie required standby support. Altliough not required
the USACE will provide one-USACE OE Safety Specialist dui'ing the conduct of investigative
activities at the other sites.
2.3.2 MEC/UXO Identification and Disposition
2.3.2.1 If sui'face or subsiii'face MEC is encountered, the USACE Safety Specialists will
make every effort to identify tlie item dii'ough visual examination of the item for markings and
otlier identifying featm'es such as shape, size, and external fittings. Items will not be moved
during the inspection mitil the fuze condition can be ascertained. If the condition is questionable,
consider die fuze to be aimed. The fuze is considered the most hazardous component of a UXO
regardless of type or condition.
2.3.2.2 Any MEC/UXO that cannot be positively identified or MEC/UXO that contains
energetic material or possible energetic residue requires a disposal response.
2.3.2.3 On tlie PSF, USACE personnel are not autliorized to desti-oy MEC/UXO. In the
event MEC/UXO is encomitered that due to fuzing or CLiri'ent condition presents an eminent
hazard the USACE has been requested to initiate response actions and notify appropriate
audiorities. The OE Safety Specialists will initiate response actions and notify appropriate
audiorities per the followmg table:
Appendix B 5 January 06
CWM Site Investigation Work Plan, PSF - Appendix B
MEC REPORTING POINTS OF CONTACT
POC
PHONE
PURPOSE
Presidio Tiiist Police Department
(415)561-5656
Dept. personnel will provide a
security force to prevent
unauthorized access to tlie
discovery. They will notify
their Law Enforcement Chain
of Command
Mr. Bill VeMi
CEHNC-OE-CX (primary POC)
Mr. Hank Hubbard (secondary POC)
CEHNC-OE-CX
(256)895-1592
(256)895-1586
Mr. Veith or Mr. Hubbard will
contact appropriate EOD
response authorities
Mr. A. R. Smith
CESPK-SO
(916)557-6973
District Safety will notify
District Commander, PAO (if
required)
Mr. Bruce Handel (primary POC)
CESPK-PM-M
Mr. Brad Call
CESPK-ED-GE (secondary POC)
(916)557-7906
(916)557-6649
Mr. Handel or Mr. Call will
Infomi the USACE Project
Team
Mr. Roger Caswell
BRAC Envu-oiimental Coordinator (BEC)
(510)909-4804
Will notify BRAC colleagues
Mr. Craig Cooper
Presidio Tnist
(415)561-4259
Presidio responsibilities and
notify colleagues
Mr. Robert Boggs
DISC
(510)540-3751
Notify DTSC colleagues
While awaiting airival of Presidio Police personnel, tlie USACE Team will ensure site security is
maintamed, ensure access to the item(s) is restricted and ensm'e non-essential personnel are
denied entiy. At the request of the responding EOD unit, tlie USACE Safety Specialists may
provide assistance to tlie response team.
2.4 MEXAJXO Safety Support Plan
2.4.1 Personnel Qualifications.
Two qualified USACE OE Safety Specialists, one bemg a UXO Technician III, shall provide
safety support during mvestigation and construction activities within tlie area of tlie "1 91 8 West
Cantonment Trench System". This area is potentially contaminated with CWM/MEC/XJXO.
Qualifications standards are defined m "DDESB Teclinical Paper #1 8". One USACE OE Safety
Specialist (UXO Technician III) shall provide safety support at all other sites to be investigated.
Appendix B
January 06
CWM Site Investigation Work Plan, PSF - Appendix B
2.4.2 Method of Work Accomplishment.
2.4.2. 1 The USAGE Safety Specialists should physically preview tlie actual constn.iction
footprint with the on-site management of the construction contractor and discuss visual
observations and potential areas of concern. In the event MEC/UXO is discovered, the USAGE
Safety Specialists shall place flaggmg adjacent to the discoveiy for subsequent visual reference,
select a coLirse around the item, and lead project personnel out of the area.
2.4.2.2 Undergromid utility clearance and/or excavation permits, if required, must be
obtained prior to commencement of any excavation activities. The Safety Specialists are
responsible for verifymg that all necessary excavation permits are on-site prior to commencing
operations. The USAGE Project Manager is responsible to ensLire the appropriate agencies or
companies mark tlie location of all subsmTace utilities in tlie construction area. In the event
subsurface utilities are suspected in the excavation area, tlie USAGE Team must attempt to
verify tlieir location. All located utilities should be marked by paint, pin flags, or otlier
appropriate means to visually delmeate their approximate subsurface routing.
2.4.2.3 Dming mechanical excavation by backlioe or other capable machineiy, one OE
Safety Specialists will monitor all excavation activities in areas potentially contaminated with
GWM/MEG/UXO. The mdividual should be positioned to the rear and upwind of the excavation
equipment for continuous visual obseivation of activities. If the constn.iction contractor uneai'ths
or otheiwise encounters suspect GWM/MEG/UXO, all excavation activities will cease. The
Safety Specialists will assess the condition of the MEG/UXO to determme if disposal action is
required. If disposal is required, no fui'ther excavation is allowed at tliat location Lmtil an EOD
response team has destroyed or removed die MEG/UXO item. In tlie event GWM is discovered
tlie response process of paragraph 2.2 shall apply.
Mechanical excavation will be accomplished by a series of "lifts". Approximately six to eight
inches of soil should be removed during each lift. Upon completion of each lift the spoils shall
be spread of the ground and the OE Safety Specialists will visually investigate the spoils for
MEG/UXO/GAIS vials. A combmation of hand tools and magnetometer may be utilized dming
visual mvestigation of die spoils. The "lift" process will be repeated until native soil is reached.
* Excavations less than 5 feet in deptii and wliicii a competent person examines and
determines tliere to be no potential for cave-in do not require protective systems.
2.4.2.4 An exclusion zone (EZ) for GWM/MEG/UXO is not required as the probability of
encountermg MEG/UXO is assessed as "Low" and die probability of encoLmtering GWM is
"Seldom" or "Unlikely". However, a safety work zone for heavy equipment operations will be
established. Tliis safety work zone is defined as a 50-foot radius aromid any heavy equipment
tliat IS operatmg. Dming excavation activities only die Safety Specialists, essential persomiel
and equipment operators will be permitted within die safety work zone.
Appendix B 7 January 06
CWM Site Investigation Work Plan, PSF - Appendix B
2.5 Operations Sequence of Tasks
**In addition to the hazards posed by potential MEC AJXO, all personnel must remain
alert for signs of HTW/C WM contamination. Suspicious odors, stained or discolored soils
and unknown substances require immediate termination of excavation activiti^. The
USA C E team and equipment operator shall evacuate to a position upwind of the
excavation. The USAGE team wiU evaluate and notify appropriate authorities as the
situation dictates.
2.5.1 1918 West Cantonment Trench System
鈥?Area Preparation
鈥?The OE Safety Specialist will inspect and approve all hand and power tools to
ensm'e the tools may be safely operated witliin a MEC enviromnent.
鈥?Dming brush cutting, either manual or mechanical, the OE Safety Specialists will
monitor all activities and visually access all areas were brusli/vegetation removal is to occm".
The Safety Specialists may utilize hand-held magnetometers to assist during the visual
assessment. Prior to field use of magnetometers, tlie OE Safety Specialists shall follow the
guidelines of the manufactui'er's operatmg manual for setup and test out procedures-
鈥?Individuals utilizing hand tools or power tools (weed whackers, chain saws, etc.)
may trun bn.ish to a level not below SDC-mches above tlie surface level. Mechanized brush
cutting may trim bush to a level not below 12-inches above die SLirface level.
鈥?If suspect material is encountered the Safety Specialists will immediately halt
operations and investigate the nature of the suspect item. If MEC/UXO is discovered all
operations shall cease. UXO Technicians shall follow die guidance provided in previous
pai'agraphs.
鈥?L atrine excavation.
鈥?The backhoe or other suitable excavator will be positioned up-wind of the
excavation point. Streamers, attached to a stationary object, is a field expeditious method to
monitor wind du'ection diii'mg excavation operations.
鈥?The OE Safety Specialists will ensm'e all non-essential personnel ai'e outside the
perimeter of the 50-foot radius safety work zone.
鈥?One OE Safety Specialists should be positioned to die rear and upwind of
the excavation equipment for contmuous visual obseivation of activities. Additionally the Safety
Specialist will be positioned to ensui'e tlie swing arm radius of die backhoe is not a hazard to
himself
鈥?If suspect material is encomitered the Safety Specialists will immediately halt
operations and investigate the nature of the suspect item.
Appendix B 8 January 06
CWM Site Investigation Work Plan, PSF - Appendix B
鈥?The equipment operator and tlie Safety Specialist will ensLire commLinication
signals are in place prior to starting excavations. The signals must include a "Stop Excavation"
signal. The equipment operator must maintain visual contact witli tlie OE Safety Specialist.
鈥?Mechanical excavation will be accomplished by a series of "lifts" (Refer to
paragraph 2.4.2.3).
鈥?If MEC/UXO is discovered all operations shall cease. The OE
Safety Specialists shall follow the guidance provided in previous paragraphs.
鈥?Removal of organic forest material from trenches.
鈥?The OE Safety Specialists will continuously monitor all raking and removal activities.
Specifically the Safety Specialists shall be alert to any signs of MEC/UXO/ CAIS vials.
鈥?If suspect material is encomitered the Safety Specialists will immediately halt
operations and investigate the nature of tlie suspect item. If MEC/UXO/CWM is discovered all
operations shall cease. The OE Safety Specialists shall follow tlie guidance provided in previous
paragraphs.
2.5.2 Shallow surface soil sampling and investigation of G as Chambers and other
structures of historical CWM association
鈥?It is not anticipated MEC/UXO/CAIS vials ai'e present in tliese areas as these
areas are high tourist areas. However the OE Safety Specialist will remain vigilant and observe
all sampling and reconnaissance activities.
2 5 3 MECAJXO Documentation
The type of item, location (to include depth located), condition, amounts, and disposition of all
MEC/UXO Items will be recorded by the USACE OE Safety Specialists. All MEC/UXO
containii:^ energetic material or energetic residue will be photographed and all photographs will
be provided to the USACE Project Manager or tlie USACE Project Team Leader.
3.0 REPORTS/LOGS
3.1 Daily Log
The USACE Safety Specialists shall maintain a daily log describing weather conditions,
equipment on site, personnel and visitors on site, work perfonned, field problems encountered, a
photograph log, and any otlier relevant field notes.
3.2 After Action Report
After Action Report will be prepai'ed at tlie request of tlie Govermnent Designated Authority.
Appendix B 9 January 06
CWM Site Investigation Work Plan, PSF - Appendix B
3.3 Report of Suspect CWM
The USAGE Team shall prepare a "Discovery of Recovered Chemical Warfare Materiel
(RCWM). Reporting format is at Appendix C of the main WP. This format will be provided to
CEHNC-OE-CW (Walters).
4,0 SAFETY
Prior to field activities commencing, a Site Safety and Health Plan (SSHP), prepared by the
USAGE, specifically addressmg UXO/MEG/CWM activities must be submitted to GESPK-SO
for review and approval.
Appendix B 10 January 06
APPENDIX C
CWM atES Investigation Woik Plan PSF - Apperi卤x C
Notification Procedures for Discovery of Recovered Ciiemical Warfare Materiel
(RCWM) During USAGE Projects
Appendix C 1 January 2006
CWM atES Investigation Woik Plan PSF - Apperi卤x C
Notification Procedures for Discover^' of Recovered Chemical Warfare Materiel
(RCWM) During USAGE Projects
RCVUM NOTIFICATION FORMAT
CHEMICAL EVENT REPORT
FOUO
THIS IS ACATEGROY X CHEMICAL EVENT REPORT, RCS: CSGPO-453
1. Date, time and eventnumber. (i.e,31Mar04, 1100 hrs) (event number-acronym of the
organization doing the report locally (e.g., district acronym), year of the event and
sequent number assigned locally (i.e., SPL 04-01) ).
2. ProjectTitle, Number/Location, (i.e.. Big Mountain Manufacturing Facilitv,
CA1234567, Big Mountain, CA).
3. Quantity and type of munitions/container and chemical agents involved. (Number of
discovered items, markings (e.g., identification fixtures), condition of the item, is it
leaking, concentration of agent and detection methods for both initial detection and
confirmation. Include as much information available at the time of report), (i.e..
pieces of crockery, one large piece witti a small amount of liquid).
4. Description of what has happened. (Tell us why or how the item was found. Include
as much detail as possible atthe time of report), (i.e.. Workers were removing a root
ball from an arsenic contaminated area next to BIdq 384. Manufacturing Facility, Biq
Mountain, CA. Grid XXX-XX. This work was beinq accomplished underttie Time
Critical Removal Action for arsenic contamination from the Manufacturinq Facilitv
qrounds. Workers were using a backhoe and hand held equipment to remove the
root ball from a previous cut tree so they could remove the arsenic. At approximately
18 inches, pieces of crockery similar to that used durinq WWII was discovery. Team
immediately covered the site with plastic and secured the area. Team also recovered
a large piece of crockery and a grab soil sample before covering the hole. Personnel
were wearing gloves and rubber boots; no respiratory (arsenic levels were beinq
monitored) protection was beinq worn. Personnel were sent to Chemical Event
Hospital (8 personnel). EOD was called to the site. EOD and TEU responded within
5 hrs. TEU was in Tyvek and approved respirators. Telephonic notification made to
the Army Operation Center, USATCES and HO USAGE. DA MINICAM reading
indicated H (mustard) and L (Lewisite) contamination. DAAMS tubes were taken and
are being sent to Edqewood Arsenal for processing. THIS IS AN UNCONFIRMED
UNTIL DAAMS TUBES ARE PROCESSED).
5. Emergency notification level. (Non-surety emergency, limited area emergency, post
only emergency, community emergency. If not applicable, so state). ( I.e.. Non-surety
emergency (informational)).
6. Description of property damage, (i.e., None.) Atch.
Appendix C 2 January 2006
CWM atES Investigation Woik Plan PSF - Apperi卤x C
7. Personnel deaths and/or injuries, (i.e. 8 personnel were sent to CA National Hospital
for medical check, No injuries have been reported).
8. Whether medical services and/or facilities were required, (i.e., See 7 above).
9. State if Service Response Force (SRF) commander is required, (i.e., None required).
10, Assistance required, (i.e., None required).
11, Any other pertinent information, (e.g., if news release was issue, safety and security
measures taken, amountof agent release, weather patterns and/or conditions atttie
time of the event), (i.e. This work was being accomplished under a TCRA HTW
contract. Area had been soil sampled and geophysical mappinq accomplished.
There was no indication of CWM but hiqh arsenic readinq. Excavation has been
backfilled and construction fencing putaround the site. Itwill be excavated underthe
Chemical Safety Submission when the other suspect CWM grids are excavated.
Weather was normal).
12, Commander's assessment of the situation. (i,e No additional assistance is reguired.
Situation is under control).
13, In reporting emergency destruction of the hazardous munitions (e.g,, suspected
chemical munitions or materials), reporting agencies must add the following; (i.e.,
N/A]
a. Type of air samples and test kits used and results obtained.
b. Type and amountof explosives used to destroy each munition.
14. Elements of media release. ( i,e., None, as advised buy the district PAQ until
additional information is known).
15. Notification of senior government officials. ( i,e.. None made).
16, Points of Contact, (HNC and DistrictPOC, names, telephone numbers, mail
address and/or Email).
(NOTE: Info in (} contains directions/guidance on information reguired and when
accompanied by _ is information regarding the sample).
AR50-6, Figure 11-1 (USAGE edited format 23 Apr 2004)
Appendix C 3 January 2O06
APPENDIX D
Ci\M^tEsInvestigation\\bHiPlan,PSF-AfpeniSxD
Sampling and Analysis Plan
Appendix D 1 March 2006
CMM Sites InvestigationmiiliPlaixPSF-AppaTaxD
APPENDIX E - TABLE OE CONTENTS
INTRODUCTION 3
1 FIELD SAMPLING PLAN 4
1 . 1 General Sampling Procediu'es 4
1.2 Soil Sampling Smnmary 5
1 . 3 Quality Conti'ol Samples 5
1.3.1 Field Duplicate Samples 6
1.3.2 Equipment Blank Samples 6
1 .4 Quality Assurance Samples 6
1 .5 Sampling Equipment and Procediii'es 6
1.5.1 General Information 6
1 .5.2 Sui'face Soil Samples 6
1.5.3 Building Wipe Samples 7
1 .6 Equipment Decontammation Procedui'es 8
1.7 Site Restoration 8
1 .8 Sample Containers and Preservation 8
1 .9 Sample Docmnentation and Handling 8
1 . 9. 1 Sample Numbermg and Labels System 8
1 . 9. 2 Sample Packaging and Shippmg 9
1 . 9. 3 Chain-of-Custody Procedui'es 10
1.10 Investigation Derived Waste 10
2 QUALITY ASSURANCE PROJECT PLAN 12
2 . 1 Analytical Metliods Requirements 12
2 . 2 Sample Preparation and Analysis 13
2.2.1 Analytical Method 13
2.2.2 Method Calibration and Quality Control Requirements 13
2 . 3 Analytical Data Reduction and Review 15
2.4 Quality Assui'ance and Quality Control Procedures 15
2.4.1 Field QC Checks 15
2.4.2 Analytical QA/QC Checks 16
2.5 Data Quality Indicators (DQI) 16
2.5.1 Precision 16
2.5.2 Accuracy 16
2.5.3 Representativeness 17
2.5.4 Completeness 17
2.5.5 Comparability 18
2.6 Data Reporting 18
2.7 Data Deliverables 18
2.8 Data Validation Requirements 19
3 REFERENCES 20
Appendix D 2 March 2006
Ci\M^tEsInvesagation\\bHiPlan,PSF-AfpeniSxD
INTRODUCTION
This Sampling and Analysis Plan (SAP) consists of two sections, one the Field Sampling
Plan(FSP) and the second section consisting of the Quality Assurance Project Plan (QAPP). The
SAP presents functions, procedui'es, and specific QA and QC activities to ensure that all project
samples are collected and analyzed to generate data that will meet the project data quality
objectives, defined in Chapter 3 of tlie Work Plan. It is necessary to defme die sampling and
analytical processes and procedures to support data of sufficient quality for the types of decisions
that will be made. Tliis site chai'acterization effort is designed to assess that no Chemical Agent
Identification Set (CAJS) materials or Chemical Warfare Material (CWM) residues are present
witlim the Presidio of San Francisco (PSF).
When evaluatmg chemical agent contamination in die environment, it is necessary to realize
that under many, if not most, environmental conditions, tlie agent will break down quickly.
Therefore it will be necessary to determme the presence or absence of the chemical agent
breakdown product (ABP) of the primary agent in the environment. The CAJS materials used and
found previously at PSF were of tlie type tliat contained HD. WlienHD hydrolyzes in tlie
environment, the breakdown products of 1 ,4-dithiane and 1 ,4-oxathiane.can persist. The presence of
these agent breakdown products in soil can be used as an indicator of past HD contammation. The piesence
of 1 ,4-ditliiaiie and 1 ,4-oxathiane will be used for diis site investigation to evaluate possible release
of HD from die CAIS materials used m militaiy framing at PSF.
Appendix D 3 March 2006
Ci\M^tEsInvestigation\\bHiPlan,PSF-AfpeniSxD
1 FIELD SAMPLING PLAN
1.1 General SampUnq Procedures
The site-specific field activities will include surface soil sampling at die sites specified in
Table 2-1 . All of the samples will be submitted for chemical analysis. All sample and/or grid
locations will be identified by, 1 ) a Trimble Global Positioning System (GPS), 2) a ground suiTey,
or 3) by field measurement from a known building or similai" reference point. The reference grid is
Noitli American Datum (NAD) 1 927, State Plane, California Zone VI (feet).
Table 1-1
General Sample Locations'^ and Sanple Type
General Area
Name
Building
Number
Type of Samples
West Presidio -
Baker Beach (Figme 2)
Baker Beach Gas Chamber
NA
shallow soil sample
Battery Chamberlin Gas Chamber
Bldg 1621
wipe sample(s)
Baker Beach training area
NA
shallow soil samples
North Central Piesidio -
Cavaliy Stables (Figme 3)
Bldg 672 Gas Chamber
Bldg 672
shallow soil sample
CWS Storeroom
Bldg 670
wipe sample
Chemical Corps
Bldg 667
bldg. present and
renovated no sample
Chem Waifare
Bldg 681
shallow soil sample
wipe sample
Cavalry Stables training area
NA
shallow soil samples
North East Piesidio -
Main Post (Figure 4)
CWS Warehouse
Bldg 94
shallow soil sample
CWS OfQce
Bldg 219
shallow soil sample
CWS Emerg/Office
Bldg 222
wipe sample
South Central Presidio -
(Figure 5)
1918 West Cantomuent Trench System
NA
shallow soil samples
Notes: Proposed sample locations are indicated on Figures 2-5 (as listed above) of the SI Work Plan
NA - not applicable
Discrete soil samples will be collected from each of the site locations indicated in Table 1 -1 .
All samples will be collected from shallow surface depths.
Appendix D
March 2006
Ci\M^tEsInvestigcaion\\bifiPlan,PSF-AfpeniSxD
Wipe samples will be collected to detennine residual ABPs that may remain on building
structures that have not under gone renovation. The field team leader will use professional
judgment in determining when and where to collect wipe samples at tlie remaining building
locations mdicated m Table 1-1.
1.2 Soil Sampling Summary
A summaiy of die soil samples planned for collection and the required QC samples is foLmd
in the table below
Table 1-2
Summary of Planned SoU Samples for Analysis
Sample Locations
Planned Number
of Soil Samples
Planned Number
of Wipe Samples
Field Duplicate
Soil Samples
Baker Beach Gas Chamber
1
-
-
Bldg 1621 Battery Chamberlin Gas Chamber
-
2
NA
Baker Beach training area
2
-
-
Bldg 672 Gas Chamber
1
-
Bldg. 670 CWS Stoieioom
-
1
NA
Bldg. 667 Chemical Corps (renovated bldg.)
-
-
-
Bldg. 681 Chem Warfare
-
1
NA
Cavaliy Stables haining area
1
-
-
Bldg. 94 CWS Warehouse
1
-
Bldg. 219 CWS OfQce
1
-
-
Bldg 222 CWS Emerg/Office
-
1
NA
1918 West Cantomnent Trench System
12
-
2
Notes:
N/A - Not applicable
13 ualitv C ontrol Samples
The foUowmg QC samples will be collected to assess precision and accuracy.
Appendix D
March 2006
Ci\M^tEsInvesagation\\bHiPlan,PSF-AfpeniSxD
1.3.1 Field Duplicate Samples
Duplicate field samples provide information regarding precision for the entire measurement
system including sample acquisition, homogeneity, handling, shipping, storage, preparation, and
analysis. Field duplicates will be collected at a rate of approximately 10% of the primary soil
samples. Due to the nature of a wipe being a single collection sample, field duplicate samples are
not applicable for wipe samples.
1.3.2 Equipment Blank Samples
All lion- disposable sampling equipment will be decontaminated using a standard protocol of
potable water rinse, laboratoiy-grade detergent wash, potable water rinse and fmal rinse with
deionized water. All decontammated equipment will be placed in a clean area to air-diy.
To ensui'e that the sampling equipment has been successfully decontaminated, one
equipment rinsate sample will be collected for eveiy 20 enviromnental samples collected using non-
disposable equipment. The equipment rinsate samples will be analyzed for ABP following the same
protocols as the associated field samples collected during the sampling event. If all disposable
equipment is used, no equipment blanks will be collected.
1.4 QuaUty Assurance Samples
Quality assurance samples, also known as split samples, will not be collected dviring this
field effort. In the event that a remedial action such as soil removal is dictated, QA samples will be
collected at the same time as the confmnation samples.
1.5 Samplinq Equipment and Procedures
1.5.1 G eneral Information
All fieldwork will be performed in accordance with tlie Work P and tlie Site Safety and
Health Plan (SSHP). Records of the fieldwork will be kept in a bound notebook unique to tliis
study. Photographs will be taken of each portion of tlie site before and during sampling activities to
document site conditions. All sample locations will be recorded using GPS. The coordinates for
each location will be used for mapping of tlie sample areas in the final report.
1.5.2 Surface Soil Samples
Discrete sui'face soil samples will be collected from the areas and deptlis identified in Table
1 -2. These surface soil samples will be collected using a stainless sleeve either pushed or pounded
TM
into the ground to extract a sample. Samples collected in sleeves will be capped with Teflon
Appendix D 6 March 2006
Ci\M^tEsInvestigcaion\\bifiPlan,PSF-AfpeniSxD
squares and plastic caps. Soil will not be removed from the sleeve in the field. Alternatively,
samples may be collected witli disposable trowels and/or spoons, collected on pre-cleaned jars witli
Teflon lined lids. Regardless of collection method used, the samples will be labeled, placed in
zippered plastic bags, stored in stored in coolers witli temperature preservation, and sent to the
laboratoiy via Federal Express under chain-of-custody protocol.
A backhoe will be used to dig a hole to tlie desired depth. The soil sample will be collected
directly from the bucket of flie backhoe using a stainless steel sleeve. Sleeves will be pushed mto
the soil in the bucket, then capped with Teflon squares and plastic caps. Samples will be labeled,
placed in zippered bags, stored in coolers with temperature preservation, and sent to the laboratory
via Federal Express under chain-of-custody protocol. See sections 1 .9.2 and 1 .9.3 for packing and
chain of custody requirements.
1.5.3 Building Wipe Samples
Surface wipe samples will be collected from wall areas in buildings. Using a 4 "x 4" cotton
gauze, sterile, pre-packaged wipe moistened witli 10 mL of distilled water in a 4-oz. sampling jar.
The wipe solvent may be modified based on the analytical method requirements for sample
exti'action and technical recommendations of tlie chemists in the surety lab processing the samples
for analysis. The sampler perfonns flie followmg steps:
鈥?Prepare a 1 cm X 1 cm template wipe template.
鈥?Identify specific sampling sites using the 1 cm X 1 cm template. Note due to die natui'e of a
wipe being a single collection sample, no matt'ix spike, matt'ix spike duplicate, and field
duplicate samples will be collected.
鈥?Wearing clean disposable gloves, remove the distilled water moistened wipe from the jar, imfold
the gauze material, and place it over die sampling site.
鈥?With small movements, wipe the gauze material gently on die surface, remaining within the
template 1 cm X 1 cm area. Do not touch edge of template.
鈥?Fold tlie gauze wipe m two by bringmg the two opposed parallel sides togedier, keeping the
contammated area to the inside, and wiping horizontally, wipe tlie same template site with the
2" X 4" gauze wipe, then,
鈥?Fold the gauze wipe m two agaui by bringing the top and bottom together, keeping the
contammation to the mside, wipe the same template site vertically wMi the resulting 2" X 2"
gauze wipe.
鈥?Replace the gauze wipe in the 4-oz. sampling jai", cap tightly and place in a cooler for transport
to the laboratory under cham of custody procedures.
Samples will be labeled, placed in zippered bags, stored in coolers widi temperature
preservation, and sent to the laboratoiy via Federal Express under chain-of-custody protocol. See
sections 1 .9.2 and 1 .9.3 for packing and chain of custody requirements.
Appendix D 7 March 2006
Ci\M^tEsInvestigcaion\\bifiPlan,PSF-AfpeniSxD
1.6 Equipment Decontamination Procedures
All hand soil sampling equipment will be decontaminated using a non-phosphate detergent
wash, tap water rmse, and deionized water rinse. Decontammation will be executed immediately
prior to equipment use. Clean disposable gloves will be worn wliile decontaminating sampling
equipment and tools.
1.7 Site Restoration
Upon completion of soil sampling using the backhoe, the excavation will be backfilled using
the excavated soil. The soil will be compacted usmg the backhoe bucket and by driving the
backlioe over the site.
1.8 Sample Containers and Preservation
Soil samples will be collected as described in Section 2.5.2. No chemical preservation will
be required. Temperature preservation is required for all samples. The samples will be sealed,
labeled, and stored m ice filled coolers. Temperatm'e blanks will be used for all coolers with
samples to detennine adequacy of tlie temperatm'e preseiTation. A summary of sample contamer
and temperature preservation requirements is presented in the table below.
Table 1-3
Sample Size and Preservation
Method/Analysis
Sample Size and
Container Requirements
Chemical
Preservation
Temperature
Preservation
SW8270D
Stainless steel sleeve or
4oz glass jar wATeflon lid
None
Cool 4掳 卤 2掳C
1.9 Sample Documentation and HandUnq
1.9.1 Sample Numbering and Labels System
A unique identification nmnber will be assigned to each sample. Each sample will be
numbered and include the following infonnation:
鈥?project name (PSF)
鈥?specific area of site using an initial designation (BBSA = Baker Beach Study Area) or
applicable building number ((667, 670, 681 etc.)
Appendix D
March 2006
Ci\M^tEsInvestigcaion\\bHiPlan,PSF-AfpeniSxD
鈥?deptii (in feet)
All information pertaining to a particular sample is referenced by its identification nmnber.
It is recorded on the sample container, in the field sampling log, and on the sample chain-of-custody
form.
鈥?Each sample collected at the site will be labeled witli the following mfonnation:
鈥?Project Name
鈥?Sample identification number,
鈥?Sample location;
鈥?Date and time of collection,
鈥?Name of person(s) collecting the sample;
鈥?Analysis requested;
鈥?Preservation; and
鈥?Any other information pertment to the sample.
1.9.2 Sample Packaging and Shipping
Samples will be transported to the laboratoiy for analysis as soon as possible after sample
collection and preparation. The following procedui'es ai'e to be used when packing and hansporting
samples to the laboratory:
鈥?Use metal or equivalent strengtli plastic coolers or sturdy shipping containers,
鈥?Package samples and temperature blank in mdividual plastic bags and place in container;
鈥?Put papei'work (chain-of-custody record) in a wateiproof plastic bag and tape it to die inside of
the container,
鈥?Tape die contamer lid and any drain shut widi fiber-reinforced tape,
鈥?Place at least two numbered and signed custody seals on container, one at the front right and one
at tlie back left of cooler or contamer,
鈥?Attach completed shippmg label to tlie top of container and ship following tlie carrier's
inshiictions.
Sample containers will be shipped via Federal Express for overnight deliveiy to the
laboratoiy. A copy of tlie bill of ladmg (air bill) is to be retained and becomes part of the sample
Appendix D 9 March 2006
Ci\M^tEsInvesagation\\bifiPlan,PSF-AfpeniSxD
custody documentation. The laboratoiy will be notified in advance of all shipments by telephone on
the day of shipment and by advanced scheduling.
1.9.3 C hain-of-C ustody Procedures
All samples will be accompanied to the laboratory by a chain-of-custody foim (COC) foim.
The COC contams the following information:
Project name;
Sample nmnbers;
Sample collection pom.t;
Sampling date;
Time of collection of samples;
Sample matrix description;
Analyses requested for each sample,
PreseiTation metliod;
Number and type of containers used;
Any special handlmg or analysis requirements;
Signature of person collecting the samples;
Signature of persons mvolved in the chain of possession.
The COCs will be filled out witli ink. All information on the COCs shall match the
information found on tlie label. When the samples ai'e transferred from one party to anotlier, tlie
individuals will sign, date, and note tlie time on tlie form. A separate form will accompany each
delivery of samples to the laboratoiy. The COC will be included in the contamer used for transport
to the laboratory and the sampling personnel will retain a copy.
1.10 InvestiqatioD Derived Waste
It is anticipated that investigation derived waste consistmg of decontamination water,
personal protective equipment, and empty containers will be generated during die com'se of tlie
fieldwork. Due to the low volume of decontamination water tliat will be generated (less tlian 5
gallons) and the low concentration of metals in tlie decontamination water from dilution with tap
and deionized water, the decontamination water will be placed on the ground witliin the sampled
Appendix D 10 March 2006
Ci\M^tEsInvestigcaion\\bifiPlan,PSF-AfpeniSxD
ai'eas. Although not anticipated, if greater than 5 gallons are generated, decontamination water will
be sampled for analysis and alternate disposal procedm'es will be followed. All other wastes will be
disposed of m a trash receptacle.
Appendix D 11 March 2006
Ci\M^tEsInvesagation\\bifiPlan,PSF-AfpeniSxD
2 QUALITY ASSURANCE PROJECT PTAN
This QAPP presents functions, procedures, and specific QA and QC activities to ensure that
all analytical data are consistently produced and of known quality in order to achieve tlie data
quality objectives defined in Section 2.0. The QAPP provides data specifications for all anticipated
analyses and establishes procedvires for data review and assessment. The QAPP fonnat and
elements were derived following EPA QA/G-5, Guidance for the Preparation of Quality Assurance
Project Plans (EPA, 2002).
The puipose of tliis QAPP is to ensure that the data collected are of known and documented
quality and useful for tlie pLirposes for which fliey are intended. The procedui'es described are
designed to obtain data quality indicators for each field procedure and analytical metliod. Data
quality indicators include following parameters including Precision, Accuracy, Representativeness,
Compai'ability, and Completeness (PARCC). To ensure that quality data continues to be produced,
systematic checks must show tliat test results and field procedures remain reproducible and tlrat flie
analytical metliodology is actually measuring the quantity of analytes in each sample.
The reliability and credibility of analytical laboratoiy results can be corroborated by tlie
inclusion of a program of scheduled replicate analyses, analyses of standard or spiked samples.
Regularly scheduled analyses of known duplicates, standards, and spiked samples are a routine
aspect of data reduction, validation, and reporting procediires.
2.1 Analytical Methods Requirements
Table 3-1 provides a summary of tlie required analytical methods, parameters, and
associated holding times required for this project.
Table 2-1
Summary of Analytical Method Requirements
Analytical Method
Analyte
Holding Time
SW8270D
1,4-oxatliiaiie (CASRN 15980-15-1)
1,4-dithiane (CASRN 505-29-3)
1 4 days to extiaction
40 days to analysis
If, diiring tlie coui'se of a project, it becomes necessary to change analytical methods in order
Appendix D
12
March 2006
Ci\M^tEsInvestigcaion\\bifiPlan,PSF-AfpeniSxD
to reduce matrix interferences or increase analyte sensitivity, the USAGE Project Chemist will be
notified and approval will be obtained. Unless authorized by the USAGE Project Ghemist, metliod
quality control will be equivalent to the most current published version of the analytical method
from SW-846, Test Metiiods for Evaluating Solid Waste, Physical/Gliemical Methods (EPA, 2004),
shall be used including all published updates.
2.2 Sample Preparation and Analysis
2.2.1 Analytical Method
The project soil samples will be analyzed by a modified SW-846 8270 at an off-site
laboratoiy. Samples will be analyzed by a sui'ety lab that is qualified to report analysis of botli the
parent agent and the breakdown products for that parent agent. The receiving laboratory will be
capable of accepting all of the samples (none will be retained on-site) and will process them
according to tlieir laboratory protocols for analyzing samples containing potential GWA. A
description of tlie required analytical calibration and metliod QG requu'ements are provided in
Section 3.2.3 below.
2.2.2 Method Calibration and Quality Control Requirements
The analytical laboratoiy will provide analytical data for project samples following both the
published method criterion and project specific quality control requirements and corrective action
procedures. If a conflict is noted between the method's published criteria and tlie project specific
criteria documented m Table 4-2 below, tlie project specific requirements and corrective actions as
documented in this QAPP have precedence.
Appendix D 13 March 2006
Ci\M^tEsInvestigation\\bHiPlan,PSF-AfpeniSxD
Table 2-2
C aljbratioii and Internal Q uality C ontrol Procedures G C /M S M ethod
Quality Control Check
Minimum Frequency
Acceptance Criteria
Lab Corrective Action
1 nstru merit tune - Ul- 1 Mf
Prior to initial calibration
Ion abundance criteria as
Rettine instrument and verify. Remn
( decaf 1 uorotriphenyl-
and every 12 hours of
described in SW8270D
affected samples.
phosphine)
analysis time
Five- pointcalibration
When daily calibration
1. Avaaqe RRF for SPCCs:
Correct problem then repeat initial
verification fails or
> 0.050.
calibration.
following major
2. %RSDforRRFsfor
instrument maintenance
CCCS: <30%
or repair
3. Calibration:
Option 1: RSD for each
analyte <15%
Option 2: linear regression,
r> 0.995
Option 3: non-linear
regression - COD r^ >
0.990 (6 points 2' order, 7
points 3'' order)
Second source calibration
Once after each initial
% Difference from
Correct problem and verify second source
verification
calibration
expected value < 25% for
standard. If tliat fails, then repeat initial
all anaiytes.
calibration.
calibration verification (CV)
Daily, prior to sample
1. Average RRF for SPCCs:
Correct problem, rerun CV. If that fails.
analysis and every 12
> 0.050
then repeat initial calibration.
hours of analysis time
2. %Differenc^driftfor
CCCS: <20%D
Calibration verification
With every CV
Retention time卤 30
1 nspect mass spectrometer and GC for
internal standards (IS)
seconds from retention
malfunctions. Take appropriate corrective
time of midpoint standard
actions. Reanalyze samples analyzed
in the initial calibiation.
while system was matfiinctioning.
Ouantitation ion peak area
within 2 times area of initial
calibration midpoint
standard
Method Blank (MB)
1 per preparation batch
All anaiytes < V2 MQL
1 nvestigate possible contamination
For common laboratory
source.
contaminants, all anaiytes
Take appropriate corrective action.
< MQL.
Reprepare and reanalyze all samples
piDcessed with a contaminated blank,
unless analyte is not detected in
associated samples or present at greater
than lOx blank concentration.
Laboratory Control Standard
1 per preparation batch
Recovery limits: 50-120%
Correct problem, then reprepare and
(LCS)
reanalyze LCS and all samples in the
associated preparatory batch for failed
anaiytes.
Matrix Spike and Matrix Spike
1 MS/ MSD per 20 project
Recovery limits: 50-120%
Evaluate for supportable matrix effect.
Duplicate (MS/ MSD)
samples v\^en identified
on the Chain-cff-Custody
and RPD <35 %
Surrogate spike
All field and quality
Recovery limits: 50-120%
Evaluate for supportable matrix effect.
control samples
See Table D-3 of the DOD
If no interference is evident reprepare
OSM for specific surrogates
and reanalyze affected samp!e(5).
and recovery requirements.
Appendix D
14
March 2006
Ci\M^tEsInvesagation\\bifiPlan,PSF-AfpeniSxD
Quality Control Check Minimum Frequency Acceptance Criteria Lab Corrective Action
Method Quantitation Limit
standard (lowest
concentration on initial
calibration curve)
Verify at least once for
every matrix and field
effort
MQLs be no higher than the
lowest five point calibration
standard.
MQLs that exceed established criteria
shall be submitted to USAGE Prciject
Chemist for approval prior to analysis of
any praject samples.
Notes:
All corrective actions associated with USAGE project work shall be documented and the records maintained by the laboratory.
Test Methods for Evaluating Solid Waste. SW-846, USEPA, rev. 6, Nov. 2004.
GCV - Continuing Calibration Verrfication
COD - Coefficient of Determination
ICV- Initial Calibration Verification
LCS - Laboratory Control Sample
MQL - Method Quantitation Limit
RF - Response Factor
RED- Relative Standard Deviation
USAGE - US Army Corps of Engineers
2.3 Analytical Data Reduction and Review
The selected laboratory will be responsible for providing complete documentation of all
analytical test results and QA/QC sample results m a comprehensive certificate of analysis.
2.4 uailty A ssurance and uality C ontrol Procedures
Different types of replicate and blank samples ai'e collected as part of the QA/QC program.
Several QC samples will be analyzed for this project to provide a means to assess both field and
analytical perfonnance. The following sections describe the different types of QC samples and how
tliey are assessed to evaluate data quality.
2.4.1 Field QCClieclis
Field QC samples are discussed in Section 3.6and consist of field duplicate samples
collected at a rate of 10% of the primary samples collected. Field QC samples undergo the same
preservation, analysis, and reporting procedures as the related environmental samples. The
followmg table summarizes the field QC sample collection frequencies and acceptance limits.
Table 2-3
Field QC Sample Collection Frequencies and Acceptance Limits
QC Sample Type
Mimmum Collection Frequency
Acceptance Limits
Field Duplicate
1 per 10 mvestigative samples (10%)
RPD < 50 %
Tempeiature Blank
1 per cooler
4掳 C 卤 2掳 C
Notes:
QC - Quality Control
Appendix D
15
March 2006
Ci\M^tEsInvestigation\\bHiPlan,PSF-AfpeniSxD
RPD - Relative Percent Difference
2.4.2 Analytical QA/QC Checks
The laboratory will have a QA/QC program that monitors data quality with internal QC
checks. Those specific internal QC checks and frequency of checks are provided in Tables 4-2 and
4.3 and m the method-specific laboratoiy QA/QC procedui'es. These laboratory QC checks include
blank samples, control samples, duplicate analyses, and matrix spikes / matrix spike duplicates.
2.5 Data Quality Indicators (DPI)
The DQI parameters are qualitative and quantitative statements regarding tlie quality
characteristics of tlie data used to support project objectives and ultimately, environmental
decisions. These parameters are presented in the remamder of tins section.
2.5.1 Precision
Precision is a measure of tlie degree to which two or more measurements are in agreement,
and describes the reproducibility of measurements of the same parameter for samples analyzed
Linder similar conditions. A fimdamental tenet of usmg precision measurements for QC is that
precision will be bounded by known limits. Results outside tliese predeteimined limits higger
coiTective actions. Precision will be evaluated from field duplicate data, laboratoiy duplicate data,
and MS/MSD data. Acceptable precision is achieved when RPD values are within the acceptance
criterion.
2.5.1.1 Field Precision
Field precision objectives are met by collecting and measuring field duplicates at a rate of
one duplicate per 10 environmental samples. The acceptance limit for field duplicate precision is <
50 RPD. This precision estimate encompasses the combined uncertamly associated with sample
collection, homogenization, splitting, handling, laboratory and field storage (if applicable), sub-
sampling, sample preparation by digestion or exh'action, and analysis.
2.5.1.2 Laboratory Precision Objectives
Laboratory precision QC samples (i.e., MS/MSD) will be analyzed with a minimum
frequency of five percent. Acceptance limits for laboratory precision is < 35 RPD.
2.5.2 Accuracy'
Accui'acy is the degree of agreement between an obseiTed value and an accepted reference
Appendix D 16 March 2006
Ci\M^tEsInvesagation\\bifiPlan,PSF-AfpeniSxD
value. This pai'ameter is assessed by measming spiked samples or well-characterized samples of
certified analyte concentrations (e.g., LCS). Acciii'acy measm'ements are designed to detect biases
resulting from the sample handling and analysis processes.
2.5.2.1 Field Accuracy' Objectives
Field accuracy is maintained by monitormg adherence to procedui'es that prevent sample
contamination or degradation. Accuracy also shall be improved qualitatively through adherence to
all sample handling, preservation, and holding-tune requirements.
2.5.2.2 Analytical Accuracy' Objectives
Analytical accuracy is measured through the comparison of a spiked sample or LCS result to
a known or calculated value and is expressed as a percent recovery (%R). MS/MSD analyses
measLire the combined accLiracy effects of the sample mah'ix, sample preparation, and sample
measui'ement. LCSs are used to assess the accui'acy of laboratory operations with minimal sample
matrix effects. Each spiked sample shall be spiked with lepresentative target analytes for the
analysis being performed to ensure tliat accui'acy measures are obtained for each target analyte.
Spiking concentrations shall be at of near the lowest standai'd of the calibration curve. Laboratory
accuracy is assessed via comparison of calculated percent recovery values to accuracy control limits
2.5.3 Representativeness
Representativeness is an expression of the degree to wluch tlie data accui'ately and precisely
represents a characteristic of a population or envu'onmental condition existing at die site.
Adlierence to this work plan and use of standardized samplmg, handling, preparation, analysis, and
reporting procedui'es ensui'e tliat tlie final data accui'ately represent the desired populations.
Representativeness will be evaluated during data assessment to evaluate whetlier each datum
belongs to the obsei'ved data distribution through outlier testing. Any anomalies will be
investigated to assess their impact on statistical computations as part of the report.
2.5.4 Completeness
Completeness is a measui'e of the amount of valid data obtained from a measLirement system
compared to the amomit expected under nonnal conditions. Completeness is expressed as a
percentage. Technical completeness is a measure of the amount of usable, valid laboratory
measurements per matrix obtained for each target analyte. Usable, valid results are those that are
judged, after data assessment, to represent tlie sampling populations and to have not been rejected
Appendix D 17 March 2006
Ci\M^tEsInvesagation\\bHiPlan,PSF-AfpeniSxD
for use through data validation or data assessment. Analytical completeness objectives are 90
percent for each critical target analyte. The analytical completeness objective is 100 percent for
sample holding times. Qualifications on tlie use of data caused by incomplete data sets will be
documented in the report.
2.5.5 Comparability
Comparability is defined as tlie confidence wMi which one data set can be compared to
another (e.g., between sampling pomts, between sampling events). Comparability is achieved by
using standardized sampling and analysis methods and data reporting formats (including use of
consistent units of measurement), and by ensuring tliat reporting and detection limits are sufficiently
low to satisfy project detection and quantitation criteria for the duration of tlie project.
2.6 Data Reporting
All data shall be reported at the method detection limit (MDL) value where detects between
the MDL and QL ai'e qualified as estimated values. All positive results must be confirmed through
evaluation of mass spectra.
At the conclusion of all analytical work for this project, the laboratory will report all
analytical data m the form of comprehensive certificates of analysis. The actual MDLs and RLs for
tlie instruments used for analysis will be provided m the analytical reports. The final certificates of
analysis will be submitted no later than 21 days after collection of the last field sample.
2.7 Data Deliverables
The project laboratory shall provide sample data and all associated quality control data in
hard copy and electronic data deliverable (EDD) fonnat. The EDD will be submitted in the USAGE
Automated Data Review (ADR) format consistent with ADR version 4.0 specifications.
All electronic data submitted by the project laboratory is requu'ed to be eiTor free, and in
agreement with the hard copy data. Data files are to be delivered on a compact disk (CD)
accompanied by the hard copy data reports. The CD must be submitted with a hansmittal letter
from the laboratory that certifies that die file is in agreement witli tlie hard copy data reports, and
has been found to be free of eiTors using tlie latest version of tlie compliance checking software
Appendix D 18 March 2006
Ci\M^tEsInvesagation\\bifiPlan,PSF-AfpeniSxD
provided to the laboratory. Only the laboratoiy responsible for the generation of electronic data will
be permitted to edit or alter the electronic results after they have been submitted.
2.8 Data ValidaHoii Requirements
The project team will review 100% of the data generated for the project. Data qualifiers will
be assigned for tlie following QC outliers: contammated blanks, LCS outliers, and MS/MSD
outliers. Additionally, approximately 10 percent of tlie data will be validated at the raw data level
(EPA level IV) to verify aiialyte detection and quantitation. Criteria evaluated in tlie full (level IV)
validation of analytical data mclude the surrogate recoveries, spike recoveries (LCS, MS/MSD,
preparation blanks, metliod blanks, mstrument tuning, mstrument calibration (including re-
calculation verification of response factors), continuing calibration verifications, internal standard
response, comparison of duplicate samples, and sample holdmg times.
Appendix D 19 March 2006
CMM Sites InvesdgationmiiliPlanPSF-AppaTaxD
3 REFERENCES
U.S. Army Center for Health promotion and Preventative Medicine (USACHPPM), 1999, Primary
Breakdown Products of Chemical Agent, Derivation of Health-Based Environmental
Screening Levels for Chemical Warfare Agent, March.
U.S. Environmental Protection Agency (EPA), 2002. Guidance for the Preparation of Quality
Assurance Project Plans, EPA QA/G-5, Final, December.
U.S. Environmental Protection Agency (EPA), 2000. Guidance on the Data Quality Objectives
Process, EPA QA/G-4, Fmal, September.
U.S. Enviromnental Protection Agency (EPA), \999, National Functional Guidelines for Organic
Data Review, EPA 540/R-94/012.
Department of Defense (DoD), 2006, Quality System Manual for Environmental Laboratories, rev3,
January.
Appendix D 20 March 2006
APPENDIX E
Prepared by:
i'l
SITE SAFETY AND HEALTH PLAN
Chemical Warfare Materiel Site Investigation
Presidio of San Francisco
San Francisco, CA
Approved by:
A.R. Smith
Chief, Safety and Occupational Health
David E Elskamp, CIH
Industrial Hygienist
Bruce Handel
Project Manager
Bradley Call, P.E.
Technical Team Leader
Date:
Date:
Date:
Date:
Date:
Thomas Kuapp
OE Safety Specialist
U.S. Army Corps of Engineers
Sacramento District
March 2006
This document was prepared using die guidance of ER 385-1-92 and Data Item
Description MR- 005- 06. It is prepared for the sole use of tlie U.S. Army Corps of
Engineers, Sacramento District
Appendix E - 1
1.0 INTRODUCTION
This Site Safety and Health Plaii (SSHP) establishes the responsibilities, requirements,
and procedures forthe protection of U.S. Army Corps of Engineers (USACE)
Sacramento District (SPK) field personnel during site investigative activities (investigate
for the presence of chemical agent identification set [CAIS] materials or chemical
warfare materiel [CWM] residues} within tlie Presidio of San Francisco, San Francisco,
CA.
1.1 Policy Statement
SPK ' s policy is to provide a safe and healthful work environment for site employees.
Field personnel will receive the appropriate training, equipment, medical, and o^er
resources necessary to complete assigned tasks in a safe manner.
1.1.1 Safetv / Health Responsibilities
The Project Manager (PM), Technical Team Leader (TTL), SPK'sCliief of Safety and
Occupation HeaMi (SO), Industrial Hygienist (IH), and OE Safety Specialist/ Site Safety
and HeaMi Officer (SSHO) will cooperatively implement tlie requirements of this SSHP.
1.2 Purpose
The purpose of this SSHP is to heighten awareness of the hazards present, enhance the
safety and lieaMi of SPK's field personnel, and provide guidelines foremeigency
response. This SSHP is written to meet the safety and health requirements in EM 385-1-1
and ER 385-1-92 as well as OSHA requirements (29 CER 1926.65 / 29 CFR 1910.120).
This SSHP describes the safety and health guidelines to protect on-site personnel, off-site
receptors, and the environment. The procedures and guidelines contained herein are
based upon the best available infonnation regarding the physical, chemical, biological,
radiological, and safety hazards known, or suspected to be present on the project site at
tlie time of this SSHP's preparation. Specific requirements may be revised if new
information is received or site conditions change. Any revisions to this plan will be made
with the knowledge and concurrence of the TTL, SO, IH, and OF Safety Specialist. This
SSHP will supplement any contractor's (TBD) Accident Prevention Plan (APP) in
support of this project.
Based upon site history, anticipated chemicals of concern, and planned activities, a
"LevelD" site will be maintained. As work activities progress, site conditions may
require a change in the level of PPF. Any PPE changes will be addressed in the tailgate
safety meeting.
1.3 Compliance
SPK personnel will comply with this SSHP and any contractor prepared APP, applicable
Federal, state and local occupational safety" and health regulations.
Appendix E - 2
1.4 AppUcahility
SPK field personnel are responsible for reading, understanding and abiding by this SSHP
and documenting such understanding through signing tlie Employee Acknowledgment
Form.
1.5 References
This SSHP and subsequent activities will comply with the following referenced
documents, at a minimum:
a. Title 29 Code of Federal Regulations (CFR) 29 CFR 1926.65 / 29 CFR 1910.120,
Hazardous Waste Operations and Emergency Response.
b. USACF, Safety and Health Requirements Manual, FM 385-1-1.
c. USACF, Safety and Occupational Health Document Requirements for Hazardous,
Toxic and Radioactive Waste (HTRW) Activities. FR 385-1-92.
d. USACF, Munitions and Explosives of Concern (MEG) Support During Hazardous,
Toxic, and Radioactive Waste (HTRW) and Construction Activities, FP 75-1-2.
e. CEHNC-ED-SY-S, Data Item D escription (DID), MR-005-06.
f. USACF, Archive Search Report, Presidio of San Francisco, (2003)
g. Interim Guidance, Interim Guidance forBiological Warfare Materiel (BWM) and
Non-Stockpile Chemical Warfare Materiel (CWM) Response Activities,
September 4, 1997; and Memorandum, Applicability of Biological Warfare
Materiel and Non- Stockpile Chemical Warfare Materiel Response Activity Interim
Guidance, March 19, 1998.
h. NIOSH/OSHA/USCG/FPA, Occupational Safety and Health Guidance Manual
for Hazardous Waste Activities.
1.5.1 SPK-OM-385-1-1
In addition to the information contained in this SSHP, SPK's Safety and Occupational
Health Policy and Procedures Manual {OM 385-1-1) will be implemented for this project.
1.6 Activity Hazard Analyses (AHAs)
The attached A ctivity Hazard Analyses (AHAs) becomes a part of this SSHP. The
analyses identify the specific hazards anticipated, the control measures to be implemented
to eliminate or reduce each hazard to an acceptable level and contingency planning in tlie
event of an emergency. Before activities begin, the SSHO and contractor will conduct a
safety and heaMi tailgate meeting to discuss tlie AHAs.
1.6.1 SPK Tasks
Detailed descriptionof work tasks is described in tlie Work Plan (WP). Work will
involve selective removal of vegetation, raking forest duff out of trenches, check for
CAIS material, excavation of latrine pits, soil sampling for chemical agent break-down
products, and UXO construction support. Hand tools, small tractors, and all-terrain
vehicles may be used. The OF Safety Specialist will monitor all activities and visual
access all areas where brush/vegetation removal is to occur. The OF Safety Specialists
may utilize hand-held magnetometers to assist during the investigation. Appendix B of
the Work Plan contains the Unexploded Ordnance (UXO) Work Plan.
Appendix E - 3
1.6.2 Contractor Tasks
The contractor's wort task includes vegetation removal and excavating potholes.
Vegetation removal cannot occur between March 1 and August 15 (bird nesting season).
Vegetation removal will be accomplished using small power tools such as chainsaws,
weed-wackers, and similar field portable equipment. This will be supplemented with
hand tools such as shears and handsaws.
2.0 SITE DESCRIPTION AND CONTAMINATION CHARACTERIZATION
A detailed discussion of the site background and history is included in the Work Plan
(WP). Site background tliatis gennane to the development of this SSHP is discussed in
tliis plan.
2.1 Location
The project sites are located at the former Presidio of San Francisco (Presidio), within tlie
City of San Francisco, at the nortliem tip of the San Francisco Peninsula. The Presidio is
approximately 1,416 acres in size.
2.2 History
The Presidio was established in 1776 as a military garrison by tlie government of Spain,
which it held until the formation of the Mexican Republic in 1822. The Presidio was
formally ceded to the United States from Mexico in 1848. The Presidio has served as a
mobilization and embarkation point during several overseas conflicts, a medical
debarkation center, and coastal defense for the San Francisco Bay area. From 1933 to
1937, the Golden Gate Bridge was build, increasing public use of tire Presidio. In 1994,
the Presidio became part of the Golden Gate National Recreation Area (GGNRA). Prior
to transfer of the property to the Department of tire Interior and Presidio Trust, the
Presidio was a multi-mission installation with various military activities conducted under
separate commanders stationed as tenants or satellites. The Presidio of Sair Francisco is
presently managed jointly by tire National Park Service and the "Presidio Trust".
2.3 Proximity to the Public
Field personnel should be cognizant of public access to the sites.
2.4 Meteorological Conditions
The Pacific Ocean and San Francisco Bay have a strong influence on the climate of the
Presidio. The temperature is moderate; r^n aird mild temperatures characterize the
winter months, and spring is usually sunny and mild. Fog often occurs in summer when
warm, moist air is cooled by cold ocean water along the coast. The average annual
rainfall is 19.5 inches. Ninety percent of the rainfall occurs from November to April.
2.5 Topography
Elevations at the Presidio range from sea level along dre nortlrem and western boundaries
to approximately 400 feet above seal level in the south-central portion of the Presidio.
Appendix E - 4
BakerBeach is at the base of steep slopes. The interior portions of the Presidio are
characterized by gendy rolling to hilly topography.
2.6 Vegetation
Much of the vegetation at the Presidio results from years of planting by the Army in a
program that began in tlie 1880s to provide botli windbreaks and scenic beauty. Isolated
enclaves of endangered plants are found at the Presidio.
2.7 Previous InvestiQations
The Archive Search Report (A SR) identifies three CWM locations for furtlier evaluation.
These are the 1918 West Cantonment Trench System, the Baker Beach Gas Chamber and
the Building 672 Gas Chamber. A number of additional buildings and possible training
areas will be included in this investigation: Battery Chamberlin Gas Chamben Baker
Beach training area; Chemical Warfare Service (CWS) Storeroom (Building 670);
Chemical Corps (Building 667); Chemical Warfare (Building 681); Cavalry Stables
training area; CWS Warehouse (Building 940; CWS Office (Building 219); and CWS
Emerg/Office (Building 222). The exact nature of the CWM related activities is not
known and can only be inferred from a general understanding of events occurring during
tlie period when chemical agents were potentially used during training (the 1920s through
tlie 1950s). The locations of the ten individual sites that are the subject of this project
are identified in Figure 1 of the WP.
In October 2002 Presidio Trust volunteers found four glass bottles from aK914 CAIS at
the 1918 West Cantonment Trench System. The U.S. Anny Technical Escort Unit (TEU)
removed the bottles. Subsequent analyses by the U.S. Anny of the residue contents of
the botdes indicated the presence of tfD, a type of CWM. HD, also commonly called
mustard agent, mustard gas, or sulfur mustard, is a non-volatile, colorless to pale yellow
liquid witii a garlic or horseradish odor, and was developed as a blistering agent. The
area of the discovery was fenced to prevent access by the public.
The 2002 discovery of CAIS botdes prompted the preparation of the A SR. This report
confinned that the Army had trained with CWM on post. CWM training included limited
quantities of bulk mustard agent and all three types of CAIS (i.e., instructional,
detonation, and toxic sets). The chemical warfare training facilities at the Presidio
consisted of a number of gas chambers and training areas used over the years, some of
which were clearly identified and others, which were not. The A SR did not identify any
overt indication of a CWM hazard at the Presidio.
The October 2002 location of CAIS vials confinnstirat in fact CAIS were trained with on
thePSF. Because CWM materials were discovered, a CWM Probability Assessment for
all areas of the planned investigative work was conducted and the Sacramento District
Commanderautirorized worii to proceed as "non-CWM activity". The conclusions of the
CWM Probability Assessment are attached to tire WP.
Appendix E - 5
2.7.1 General Notes on Chemical Warfare Training
Chemical warfare training in the United States began with the mobilization during World
Warl {approximately 1917). Troops were trained to protect tliemselves from exposure to
the chemical agents used at that time (e.g., chlorine, phosgene, and mustard). Training
included familiarization with the equipment, test fitting of the gas mask, decontamination
training, and tactical exercises in which simulated or training chemical agents were
employed. Chemical warfare materials were stored at the Presidio and this included
statically used munitions filled with smoke, riot control agents and simulants, in addition
to CAIS material and bulk mustard agent (the bulk mustard containers were apparenfly
used in the 1920s). Dynamically used munitions, such as rifle grenades and hand
grenades, which could be filled with riot control agents and simulants, were also present
in military unit inventories. Chemical warfare items included candles, capsules,
grenades, pots, bombs, smoke generators and land mines. Some of tliese items were
stored for use in the event of combat deployment while other items were used for routine
training. CAIS sets were used from the early 1930s to the late 1950s. The estimated
periods of use at the Presidio's sites are included in Table 2 of the WP. The tenn "gas
chamber" refers to a small room in which simulants or riot control agents are used to
create conditions to test the fit of gas masks as well as to instill confidence that tlie masks
are protective.
3.0 HAZARD/RISK ANALYSIS
This SSHP identifies the chemical, physical, biological, radiological, and safety hazards
tliatmay be encountered.
3.1 Chemical Hazards
Contaminants of Concern (COCs) include chemical warfare agents, chemical warfare
agent's break-down products and simulants.
Between 1928 and 1969, the U.S. Military fielded a number of Chemical Agent
Identification Sets (CAIS) containing toxic agents for training. All three types of CAIS
were used at Presidio (instructional, detonating and toxic sets). Although the CAIS kits
included toxic agents such as the H-series mustard, lewisite, phosgene, and chloropicrin,
tliey never contained nerve agents (i.e. V- or G series). Mustard and Lewisite are
blistering agent that causes injury based upon direct contact witli the material or
inhalation of mist. Phosgene is a choking agent used as a delayed- casualty agent
resulting in fluid buildup in tlie lungs. Chloropicrin is a tear agent that cause severe
respiratory irritant. Exposure to CWM is expected to be minimized tlirough proper work
practices, tlie use of PPL and proper personal hygiene. All materials will be handled with
rakes and shovels or other devices, as appropriate.
A ppendii E -
Table 3-1 - Occupational Health Exposure lor COCs
coc
OSHA PEL
PPM
ACGIHTLV
PPM
IDLH
PPM
Phyacal
Description/Health Effecl^Svmptonis
ChloDDac^DfJiGncaie
(CN)
0.05
0.32 mg'm^
0.05
15 m^m'
Riot control a^nl (tear ageiit). Coloriess oystalline solid
witii a pimgait apjie hJossom fragrance. Initates eyes
and skin
o-Chlorobenzylideaie
malonitrile(CS)
0.05
(cdling)
(skirO
0.05
((禄ling) (skin)
2m^m'
WhitQ, ciystallina riotcontrol a^nt wilhapq^Def-like
odor Hi^y irhtatiiigbutnottasdc toeyes, skin, and
respiratory sysl^ii. Causes painful and burning eyes,
tearing, corgimctivitis, twitdiingeydids, initalEdlhreiat
cou^iig, chest ti^ilness, headaches, and red and
Ui steed skin Muta^n
Gasoline
NA
300
NA
Cleai/amljei: flaiiimatJq, volatile liquid witii a
chaiacteistic odDr. Initates eyes, skin, and mucous
mejntaBiies. Causes cfennatitis, headaches, fatigie.
Uuned vision, dizziness, sluned speech, confusion,
convulsions, chemical ptiejmonia and passiUe liva: and
kidney damage.
Mu拢4ard(HD)
0.003
(cdling)
?<A
NA
Blister agait YeJlow, oily liquid Gariic odDr.
Redcfening of sldn or ^^:earance of tJistas may occur
seva.Bl horns after exposura
Lewisite (L)
0.003
(cdling)
NA
NA
Blister agait Daric oily liquid witii ga^nium-like odor
Affects eyes, lungs, and tJistas skin Acts as a systemic
poison, causing pulmonary edaiia diarrhea restlessness,
weakness, siiaioniial temperature, aixl low tJood
[xessura Expeimaital terato^n.
HiosgEneCCG)
0.1
0.1
2
Coloriess gas (fuming liquid) with a suffocating odar
like musly h^ or green com. Choking a^nt. Irritates
^es, sldn, and respiratory system. Causes dry and
burning tiiroat coii^ vomiting, chest pain, frolhy
sputum, shortness of Ixealh, pulmonary ecfema
pieumonia blue sldn, and frosttate (liquid).
Chloropicrin (PS)
NA
im
NA
Coloriess, oily liquid widia stinging pun^ntodar
Chloropicrin is a poweifiil irritant whose v^Dors cause
lun^ sldn, eyq, nose and tiiKjat irritation, cou^ngand
vomiting. As an eye iiritant, it pioduces immediate
burning pain and tearing.
l,4rC!!(alhiar禄
NA
NA
NA
MiistaidtgBakdawnpgodiKt Healtii affects not
availatJe.
l,4rDiliiiane
NA
NA
NA
Miistaidtg芦akdDwnpgi3diKt Heallii affects not
availatJe.
Thiodi^col
NA
NA
NA
Miistaid tg^akdawn poditct May cause eye and skin
irritation M^ be haniiful ty inhalatiou ingestion, or
skin absorption
N/A - Not applicable or available
3.1.1 Chemical Infomiation and Material Safety Data Sheets (MSDS)
Prior to the commencement of work, all available information concerning the chemical,
physical, and toxicological properties of each substance known or expected to be present
on site will be made available to the affected employees. MSDS will be provided for
chemicals brought to the site.
3.2 Physical Hazards
Potential hazards from physical agents include noise, heat and cold stress, solar radiation,
weatlier, lifting, working around heavy equipment, slipping, tripping, or falling,
imdeiground and overhead utilities, being struck by or caught between moving parts, and
fire from flammable materials.
Appendix E - 7
3.3 Biological Hazards
Biological hazards include poisonous plants (poison oak), domesticated animals, insects
{brown recluse and black widow spiders, ticks, and flying insects), snakes and rodents.
a. Snakes and insects are found throughout the site. Possible cover and habitat for
these shall be minimized in the field operations area (i.e., weed control, organized
storage).
b. Poison Oak is present throughout tlie area. This deciduous perennial plant may
develop bush, creeper or climbing branch structures and may produce dermal
allergic reactions resulting from contact with any part of the plant.
Workers should also be aware that if there is evidence of the presence of rodents, hazards
associated with exposure to Hantavirus may also be present. Site personnel must avoid
direct contact with dead rodents or dried fecal material.
Site personnel will wear leather work gloves whenever moving debris; and to watch for
an avoid spiders, snakes, or rodents.
3.4 Radiological Hazards
There is no evidence of ionizing radiation sources or radioactive waste disposal at this
site; therefore, no specific radiation screening is planned.
3.5 Safety Hazards
Safely hazards include slips, trips, and falls on same surface, electrical, equipment and
machinery, and weather. SPK will ensure that the controls implemented to address these
safety hazards comply with applicable sections of EM 385-1-1.
3.5.1 Heat Stress, Cold Stress and Solar Radiation
D ue to local variability in weather patterns, it is likely that weather conditions varying
from cold to hot may be encountered. Wind and moisture may combine with low or high
temperatures to create unfavorable working conditions. The SSHO will observe the site
conditions and, should adverse conditions occur, implement appropriate work/rest
regimes to provide for the comfort and safety of personnel. In addition, the SSHO will
routinely check with site personnel to verify that they are not uncomfortably cold or hot.
3.6 Ordnance and Explosives (OE)
There have been no reported discoveries of MEC/UXO on these sites however the A SR
noted "Training with grenades and possibly other munitions" occurred witliin the area of
the 1918 West Cantonment Trench System. Because there may beMEC present at this
location, the USACE will, in accordance with EP 75-1-2, provide MEC standby support
during all investigative process. Two USA CE OE Safety Specialists will provide tlie
required standby support during investigative activities witliin tlie 1918 West Cantonment
Trench System. Although notrequired the USACE will provide one-USA CE OE Safety
Specialist during tlie conduct of investigative activities at the other sites.
A ppendii E -
3.7 Hazard Analysis
This SSHP address the specific means of controlhng and mitigating the safety, chemical,
physical, and biological hazards. The IH conducted the hazard analysis/hazard
assessment.
3.7.1 Heavy Eguipment Operations
Prudent care will be exercised when moving about machinery of any kind. Personnel
will be aware tliat the use of certain protective equipment may limit dexterity and
visibility", and may increase the difficulty in performing certain tasks. The equipment
will be operated by contractor persons trained in its use and safety precautions.
3.7.2 Vehicle Traffic
Employees may be exposed to vehicle accidents; safety procedures will be strictly
enforced.
3.7.3 Heavy Liftinq
During manual lifting tasks, all personnel will lift with the force of the load suspended on
their legs and not their backs. They are to maintain a straight back and hold the object
close to tlie body. Mechanical lifting devices or help from a fellow field team member
will be sought when the object is too heavy for one person to lift.
3.7.4 Slip/Trip/Fall
A II field members are to be vigilant in providing clear footing, identifying obstructions,
holes or other tripping hazards, and maintaining an awareness of uneven terrain and
slippery surfaces. If necessary, shoes providing more elaborate tread will be worn to
minimize slip, trip, and fall hazards. Good housekeeping will be maintained to minimize
slip and fall hazards.
3.7.5 Noise
Excessive noise from the on-site equipment is not expected to occur. All field personnel
are required to wear hearing protective devices having a Noise Reduction Rating (NRR)
adequate to attenuate noise below 85 dBA in all active areas where normal
commuirication cannot be understood when field personnel are within tlrree feet from one
another.
3.7.6 Pinch/Crush Injuries
Eield members will be vigilant and avoid pinching/cmshing injuries. Heavy work gloves
and steel-toed boots are required. OE Safety Specialists are not required to wear steel-
toed boots as the steel toe imparts unwanted magnetic influences to the magnetometer.
3.8 Hazard Communication Program
SPK will implemeirt a hazard communication program for this project. D etails regarding
tlris program are found in 29 CER 1926.59 and OM 385-1-1.
A ppendii E -
4.0 STAFF ORGANIZATION. QUALIFICATIONS. AND RESPONSIBILITIES
Each person assigned specific safety and liealtii responsibilities is identified. The
organizational structure, with lines of autliorit^' and overall responsibilities for safety and
health will be discussed. Qualified and competent safety and health professionals will
undertake the operational and safety and lieaMi responsibilities.
4.1 Chain of Command
Mr. Bruce Handel is the Project Manager, Mr. Bradley Call is tlie Technical Team
Leader, Mr. Thomas Knapp is the OE Safety Specialist and designated Site Safety' and
Health Officer, and Mr. David Elskamp is the IH.
4.2 General
SPK personnel are responsible for performing functions in a safe and healthful maimer,
preventing unnecessary risk of hazardous exposure to other site personnel, the public, or
tlie environment. Each individual is responsible for acknowledging and following
applicable safe work; rules and guidelines in this SSHP and the contractor's SSHP, and
using best professional judgment in minimizing the potential for injury or adverse health
associated witli activities governed by this SSHP.
4.3 Project Manager
A s tlie senior management representative, the PM is responsible for defining project
objectives, allocating resources, determining the project delivery team, and evaluating
project outcome. The PM is responsible for contacting tlie client should a health and
safety issue arise.
4.4 Technical Team Leader
A s tlie senior management representative on site, the TTL has overall responsibility for
implementation of die field activities. He will execute all activities in accordance witli
tlie Work Plan and SSHP.
4.5 OE Safety Specialist / Site Safety and Health Officer
Day-to-day safety and health support, including OE construction support, initiate
emergency procedures and notifications, training, daily site safety inspections, will be
provided by the OE Safely Specialist / SSHO who will report activities to the IH.
4.6 Field Personnel
All persons covered by this plan will sign a personal acknowledgment form signifying
thattliey have read and will abide by the plan. Additionally, all personnel will attend a
project-specific briefing conducted by the OE Safety Specialist/ SSHO. This briefing is
used to orient site personnel to tlie nature of the site, the scope of work, the contents of
the SSHP and any unique site conditions that warrant explanation.
4.7 Industrial Hygienist
The IH is responsible for the development, technical assistance, and oversight of this
SSHP. The IH will ensure that all lieaMi and safety' program documents comply witli
Appendix E - 10
Federal, state aiid local liealtli and safety requirements. If necessary, the IH will modify
the SSHP to adjust for on-site changes that affect safety and/or health. The IH will
coordinate with tlie OE Safety Specialist/ SSHO on all modification to the SSHP and
will be available for consultation when required. The IH may visit the site periodically
during tlie project to evaluate the effectiveness of the health and safety program and
compliance with the SSHP.
4.8 Chief, Safety and Occupational Health Office
The Chief, SO is responsible for verifying that SPK personnel are current participants in
the medical surveillance program, have current respiratory fit test (if applicable},
complete safety and lieaMi training; and providing quality assurance for consistency witli
Corps policy and procedure. The SO may conduct a site safely audit.
4.9 Other Key Safety and Health Personnel
a. SPK will utilize tlie services of Dr. Tee Wugofski, MD, of the Division of Federal
Occupational HeaMi (DFOH) unit. Dr Wugofski is certified in occupational
medicine.
b. SPK will utilize laboratories which are proficient to conduct personnel, area, and
environmental analysis as required; fully equipped to analyze the required NIOSH,
OSHA, and FPA analyses; and currentiy participating in the American Industrial
Hygiene Association (AIHA) Proficiency Analytical Testing (PAT) Program and is
certified by A IHA.
4.10 Key Personnel
U.S. Army Corps of Fngineers, South Pacific Division Range Support Center
ProjectManager Bruce Handel (916) 557-7906
Technical Team Teader Bradley Call (916) 557-6649
OF Safetv Specialist/ SSHO Thomas Knapp (916) 557-7313
Cell Phone (916)752-0354
Chief SO ArthurR Smith (916)557-6973
Industrial Hygienist David F FIskamp (916) 557-7903
Project Chemist PamWerhmann (9160 557-6662
Fnvironmental Fngineer Jennifer Payne (916) 557-7521
U.S. Army BRAC Fnvironmental Coordinator:
BFC RogerCaswell (510)909-4804
U.S. Army Fngineering and Support Center, Ordnance and Explosives Directorate in
Huntsville Alabama:
MM CX Hank Hubbard (256) 895- 1 586
MFC Design Center Bill Veith (256) 895-1592
CWM Design Center Operations Officer Wilson Walters (256) 895-1290
Presidio Trust:
Fnvironmental Program Manager Craig Cooper (415) 561-4259
Appendix E - 11
Environmental Remediation Specialist JenniferYata (415) 561-4272
National Park Service:
Environmental Engineer Brian Ullensvang (415) 561-4439
4.11 Site Visitors
V isitors may be present at tlie project site during field activities. These individuals may
include SPK staff, regulatory agency personnel, client personnel, and visitors. Providing
a general viewing area at a safe location in the support zone most likely can
accommodate these visitors. The OE Safety Specialist / SSHO will provide a brief
overview of the field activities to the site visitors. Any visitor wishing to enter the
regulated area must provide verification to the OE Safety Specialist / SSHO that shows
they meettlie 29 CER 1926.65 / 29 CER 1910.120 standard. The OE Safely Specialist
will escort visitors in the regulated area.
5.0 TRAINING
5.1 General
All personnel who enter this site must recognize and understand the potential hazards to
health and safety. It is the intent of this SSHP to provide every person a level of healdi
and safety training consistent with tlieirjob function and responsibility. SPK on-site
personnel have completed formal hazardous waste operations (HAZWOPER) training
and will complete an on-site briefing on this SSHP, die AHAs, PPE, heavy equipment
operation, and hazard communication. SPK personnel perfonning on-site activities wdl
be familiar with die contents of this SSHP along widi the Contractor's SSHPs.
5.2 Additional Training
In addition to die OSHA hazardous waste operations and emergency response
regulations, there are other ancillary safety' and health regulations that may govern certain
training aspects for this project. These additional training requirements include:
a. Respiratory Protection (29 CER 1910.134).
b. Hearing Conservation (29 CER 1910.95).
c. Hazard Communication (29 CER 1910.1200/29 CER 1926.59).
5.3 Initial HAZWOPER TraininQ
Eield personnel have completed 40 hours of off-site instruction, and a minimum of three
days actual field experience under the direct supervision of a trained, experienced
supervisor.
5.4 Supervisory Training
The OE Safety Specialist/ SSHO responsible for supervising personnel engaged in site
work has at least 8 additional hours of specialized training on managing such operations.
Appendix E - 12
5.5 Refresher Training
All site woiters will complete 8 hours of off- site refresher training annually on the items
covered in the 40- hour initial HAZWOPER training program.
5.6 Site-Specific Training
The OE Safety Specialist/ SSHO will conduct initial site- specific training to ensure that
employees have a thorough understanding of tlie SSHP, standard operating procedures
(SOPs), and physical, safety, biological, and chemical hazards of the site.
5.7 Daily Tailgate Safety Meetinas
All personnel who enter the regulated area will attend the daily tailgate safety meeting.
This meeting, conducted by the OE Safety Specialist/ SSHO and contractor, will cover
specific lieaMi and safety issues, site activities, changes in site conditions, review topics
covered in tlie initial health and safety meeting as they apply to daily activities.
5.8 Respiratory Protection
Respiratory protection training is provided in the HAZWOPER training.
5.9 Hazard Communication
In accordance witli the OSHA Hazard Communication standard {29 CFR 1910.1200 / 29
CFR 1926.59), copies of all material safety data sheets (MSDS), container labeling, and
chemical heaMi hazards for hazardous chemical materials brought onto any project site
and used during site operations will be available. Site-specific training on the COCs will
be provided. General hazard communication training will be conducted during the
HAZWOPER training.
5.10 CPR/FirstAid
The OE Safety Specialist/ SSHO will provide CPR/FirstAid if the event of an injury.
5.11 Hearing Conservation
Hearing conservation is included in the initial 40- hour and 8- hour HAZWOPER training
classes.
5.12 Emergency Response Procedures
All employees will be aware of the project emergency assistance netwoit and the most
probable route of evacuation from a site in the event of an emergency. Emergency phone
numbers and hospital route map will be maintained in each field vehicle.
5.13 Site-Specific Rules
Prior to the initiation of site activities, employees will be instructed in specific safety
rules. Employees will be instructed in the use of the "buddy" system; the buddy system
will be used at all times when employees are within a regulated area.
Appendix E - 13
5.14 Documentation ofTraininq
Documentation of training is the responsibility of SO. The SO will keep documentation
of each woiter's current training credentials.
6.0 PERSONAL PROTECTIVE EQUIPMENT
6.1 Personal Protective Equipment ProQram
This site- specific PPE program supplements SPK's Protective Clothing and Equipment
Program (Appendix J of CESPK OM 385-1-1}. Tliis program address the elements of 29
CFR 1926.65(g)(5) / 29 CFR 1910.120(g)(5), 29 CFR 1910.132 (General Requirements)
and 29 CFR 1910.134 (Respiratory Protection).
6.2 Site- Specific Personal Protective Equipment
Based on tiie hazard assessment, site history, previous site activities, anticipated
chemicals of concern, planned activities, and potential heat stress and associated safety
hazards; a Level D PPE site will be maintained. The U.S. Environmental Protection
Agency terminology of Levels D is used to describe tlie general PPF ensembles.
6.2.1 Level D
Level D consists of the following:
a. Sleeved shirt with collar, and long pants. When working in areas witii poison oak,
breatliable Ty vek庐 coveralls wiU be used for added protection. Reld personnel
should avoid contact with poison c^ and use barrier creams when exposure is
possible. Exposed skin and/or contaminated tools and equipment sliould be
washed carefully with detoxification/wasli solutions at tlie end of each workday.
b. Safety boots/shoes meeting the specifications of American National Standards
Institute (ANSI) Z41.
c. Safety glasses with side shields, goggles, face shield or other approved eye
protection. All approved eye protection must meet the specifications of ANSI
Z87.1.
d. Wort gloves with the addition of impervious gloves (butyl rubber) during site
activities that could result in direct contact with potentially contaminated soil,
water, poison oak or other items.
e. Hearing protection (if required) . The protective device must have a noise
reduction rating capable of providing tlie wearer with enough protection so as to
reduce the received noise level to below 85 dBA.
f . Reflective traffic vests if working in high traffic areas.
g. Hardhat when an overhead hazard exists. All approved hand hats must meet tlie
specifications of ANSI Z89.1 .
The use of respiratory protection is not anticipated during site activities.
Appendix E - 14
6.2.2 Level C
Level C protective equipment is not anticipated. If atmospheric conditions indicated the
use of Level C protection is needed, the site work will stop pending an evaluation by the
IH.
6.3 Fit-For-Duty
Site workers will have a current medical "fit-for-duty" clearance to use respiratory and
otlierPPE.
6.4 Respirator Protective Pro aram
All respiratory protective equipment will be National Institute for Occupational Safety
and Health (NIOSH) approved. SPK maintains a written respiratory protective
equipment program (Appendix to SPK OM 385-1-1}, detailing selection, fit testing,
use, cleaning, maintenance, and storage of respiratory protective equipment, as well as
medical approval for individual use.
6.5 PPE StoroQe
Clothing and respirators will be stored properly to prevent damage or malfunction due to
exposure to dust, moisture, sunlight, damaging chemicals, extreme temperatures, and
impact. Potentially contaminated PPE will be stored separately from new PPE and street
clothing.
7.0 MEDICAL SURVEILLANCE
7.1 General
Personnel performing on-site HTRW activities participate in an ongoing medical
surveillance program meeting the requirements of 29 CFR 1910.120 / 29 CFR 1926.65
and ANSI Z-88.2.
7.2 Medical Surveillance Coordinator
SO has contracted the services of a Board-Certified Occupational Physician at DFOH to
provide tlie bi-annual {more frequent on physicians recommendation) medical
surveillance exams. The physician will review all medical examinations and will be
available for medical consultation on an "as-needed" basis.
7.3 Medical Examinations
Eield personnel have successfully completed a pre-placement or periodic/updated
physical examination. The medical surveillance includes a judgment by tlie medical
examiner of the ability of the employee to use negative- pressure respiratory equipment.
A ny employee found to have a medical condition, which could directly or indirectly be
aggravated by exposure to the COCs or by tlie use of respiratory equipment will not be
assigned to the project.
Appendix E - 15
7.3.1 Contents of Medical Examination
SO in consultation with the DFOH has established the minimum content of the medical
examination based upon probable HTRW site conditions, potential occupational
exposures and required protective equipment.
7.3.2 CertificatJon of Participation
SO will maintain the certification of employee participation in the medical surveillance
program and the written opinion from the attending physician.
7.4 Medical Records
Personnel Medical records will be maintained by DFOH.
7.5 Medical Evaluation
a. Occupational History
b. Personal History
c. Physical Examination
d. Laboratory Blood Tests
e. OtherBiological Tests
f . Pulmonary Function Tests
g. Vision Tests
h. Hearing Test
i. X-Ray (as specified)
j. EKG
7.5.1 Special Ciroumstances
There are no additional medical specific criteria for tliis project.
7.6 Emergency Medical Assistance and First Aid
Prior to work start-up, an emergency medical assistance network will be established. The
Fire Department, ambulance service, and clinic or hospital emergency room are
identified. A vehicle will be available on-site to transport injured personnel to the
identified emergency medical facility. A first aid kit, including necessary protection
against bloodbome patliogens, will be available. An adequate supply of fresh potable
water for emergency eye wash purposes or portable emergency eyewash will be
available. The emergency response number "9-1-1" will be used to expedite transport in
tire event of an emergency incident. A map and directions indicating die fastest route to
San Francisco General Hospital (Figure -1) is located at the end of tlris document. A
copy of the map will be posted in each vehicle.
8.0 RADIATION DOSIMETRY
Radiological hazards are not anticipated for this project.
Appendix E - 16
9.0 EXPOSURE MONITORING/AIR SAMPLING PROGRAM
9.1 Exposure Monitoring
Based on tiie hazards anticipated during this project, no real-time or time- integrated
monitoring will be conducted. The limited potholing will occur in areas with moist soil,
so no dust generation is anticipated. However should tliis become an issue, water spray
will be used to minimize dust generation.
9.2 Heat or Cold Stress
Heat or cold stress will be monitored qualitatively.
10.0 HEAE / COED SERESS MONIEORING
10.1 General
Heat and /or cold stress monitoring protocols will be implemented, as appropriate.
10.2 Heat Stress
The stress of working in a hot environment can cause a variety of illnesses including heat
exhaustion or heat stroke; tlie latter can be fatal. Use of personal protective equipment
can significantly increase heat stress. To reduce or prevent heat stress, SPK will, as
required when ambient temperatures exceed 70 degrees Fahrenheit, implement scheduled
rest periods and require controlled beverage consumption to replace body fluids and salts.
10.2.1 Monitoring for Heat Stress
Personnel will be trained to recognize the symptoms of heat stress and the appropriate
action to take upon recognition. Even though physiological monitoring is not always
necessary, it is essential tliat personnel understand tlie significance of heat stress and its
recognition. The NIOSH/OSHA/USCG/EPA, Occupational Safety and HeaMi Guidance
Manual for Hazardous Waste Site Activities, as well asthe ACGIH庐Tlne5lioldLimit
Values and Biological Exposure Indices publication, provides protocols for prevention of
heatsliess.
10.3 Cold Stress
Cold stress may be an occupational stress. Frostbite and hypothermia are tlie primary
concerns. To reduce or prevent cold stress, worii practices will be implemented to reduce
tlie risk of injun' due to frostbite or hypothermia when ambient temperatures are below
40 degrees Fahrenheit. Personnel will be trained to recognize the symptoms of cold
stress and take appropriate action.
11.0 STANDARD OPERATING SAEEEY PROCEDURES. ENGINEERING
CONTROES AND WORK PRACTICES
Appendix E - 17
SPK will develop and implement applicable and feasible engineering and worii practice
controls to reduce safety and health hazards. SPK will develop and implement, as
applicable, standard operating procedures (SOP), to include but not limited to:
a. Site niles/prohibitions (buddy system, eating/drinking/smoking restrictions).
b. Worii permits requirements (none anticipated)
c. Material handling procedures (duff).
d. Drum/container handling procedures and precautions (not anticipated).
e. Confined space entry procedures (not applicable).
f. Hotwork, sources of ignition, fire protection/prevention (not applicable).
g. Electrical safety (ground-fault protection, overiiead power line avoidance),
h. Excavation and trenching safety.
i. Guarding of machinery and equipment.
j. Lockout/Tagout.
k. Eall protection, (not anticipated).
1. Hazard Communication.
m . Illumination (work will be conducted during daylight hours) .
n. Sanitation (existing facilities).
0. Engineering controls.
p. Process Safety' Management (not applicable).
q. Signs and labels.
11.1 Drugs and Alcohol
No consumption of alcoholic beverages or illegal drugs will be allowed on site.
11.2 Field Safety Requirements
Field safety requirements and procedures applicable to this project include safe work
practices, work zones, site control, safety meetings, safety inspections, accident reporting
and investigations, sanitation, and housekeeping.
11.2.1 Excavation
Entry into an excavation deeper than four feet is not permitted under this SSHP.
11.2.2 Confined Space
Confined space entry is not permitted under tliis SSHP. The storage rooms at Battery
Cliamberline are not considered confined spaces but will be ventilated prior to entry.
11.2.3 Hearing Conservation
A hearing conservation program will be implemented when noise exposures equal or
exceed an 8-liourTWA of 85 A-weighted decibels (dBA). Audiometric testing is partof
the medical surveillance program. Personnel working witliin 25 feet of heavy equipment
will wear hearing protection.
11.2.4 Sanitation
Existing batliroom facilities are located near the sites. Work breaks, eating, and drinking
will be in the field vehicle or other suitable location outside the restricted area.
Appendix E - IJ
11.2.5 Fire Prevention and ProtectioD
Smoking is not permitted in the restricted work area. The UX Safety' Specialist will
designate a smoking area. A fire extinguisher will be available in the Corps of Engineers
vehicle.
11.2.6 Manual Material Lifting
Material handling tasks pose a significant injury hazard to workers. Care will be taken
when lifting and handling heavy or bulky items to prevent back injuries.
11.2.7 Weather
A ctivities will be suspended during severe weather conditions.
11.2.8 Slips, Trips. Falls
These potential hazards are likely due to slippery surfaces and uneven terrain. SPK
personnel will watch where tiiey walk.
11.2.9 Cuts and Scrapes
The potential for jagged-edged objects and general cuts and scrapes exist. SPK personnel
will wear appropriate PPE.
11.2.10 Illumination
Work will be conducted during the daylight hours.
11.2.11 Heavy Equipment Operation
The hazards associated with the operation of heavy equipment include injury to
personnel, equipment damage, and/or property damage. All heavy equipment will be
operated in the manner in which it was intended and according to manufacturer' s
instructions. Only authorized personnel will be allowed near operating of heavy
equipment and will maintain visual communication with the operator. Personnel will
approach operating equipment only from the operator' s angle of view and only after
making eye contact with the operator. Personnel will wear reflective traffic vests.
12.0 SITE CONTROL MEASURES
12.1 Work Zones
Temporary barricades will be installed during the work in the 1918 West Cantonment
Trench System to prevent tiiose using hiking trails from exposure to physical hazards
such as vegetation clearing and potholing. The barricades will direct hikers to detour
around the site. The field team will cover open excavations with plywood or other
material when not under the direct control of the field team. Excavations will be
identified and protected in accordance with EM 385-1-1 . Streamers, attached to a
stationary object, will be used to monitorwind direction during excavation operations.
Presidio Trust biologists will be invited to observe all phases of work to ensure that no
endangered species ar^ inadvertentiy disturbed.
Appendix E - 19
An exclusion zone for CWM/MEC/UX is not required as tlie probability of
encountering MEC/UXO is assessed as "Low" and the probability of encountering CWM
is "Seldom" or "Unlikely". However, asafety wort zone for heavy equipment operations
will be established. This safety work zone is defined as a 50-foot radius around any
heavy equipment that is operating. During excavation activities only the OE Safety
Specialist, essential personnel and equipment operators will be permitted in tlie safety
zone.
In addition to the hazards posed by potential MEC/UX 0, all personnel must remain alert
for signs of HTRW/CWM contamination. Suspicious odors stained or discolored soils
and unknown substances require immediate termination of excavation activities. The
USAGE team and equipment operators shall evacuate to a position upwind of the
excavation. The USAGE team will evaluate and notify appropriate authorities as tlie
situation dictates.
12.2 Site Security
The TTL will coordinate wort activities with tlie BEG, Presidio Trust and National Park
Service.
12.3 Authorized Personnel
Only authorized personnel will enter regulated areas associated witli the field activities.
The OE Safety Specialist/ SSHO will establish tlie bounds of the regulated areas. All
woiters entering the regulated areas will be subject to the provisions of the SSHP. A site
Visitor's Logbook will be maintained.
12.3.1 Public Access
The site is accessible to tlie public (heavily trafficked by joggers and hikers}; work will
stop if the general public enters the regulated area.
12.4 Communication Systems
The OE Safety Specialist/ SSHO will have a cell phone for off-site emergency
responders.
12.5 Contingencies for Presence of CWM
In the event suspect GWM is encountered (item with "unknown filler"), all work will
immediately cease and project personnel will be evacuated along cleared patlis upwind
from tlie discover^'. A continuous, uninterrupted vehicle horn will be sounded for
approximately 15 seconds to designate a site evacuation. The OE Safety Specialist/
SSHO will access the need to notify or evacuate any additional areas witliin proximity of
tlie discovery. A team consisting of a minimum of two personnel shall immediately
secure the area to prevent unauthorized access. Personnel should position themselves as
far upwind as possible while still maintaining security of the area. Two personnel will
continue to secure the site until relieved by an LCD or tlie 20*^^ Support Command
(Formeiiy Technical Escort Unit [TEU]) . The OE Safety Specialist / SSHO will
immediately initiate respDiise actions and simiiltaneoiisly notify appopaiate aufliorities.
Appendix E - 20
a . AH work will stop.
b . The OE Safety Specialist / SSHO wiU dear all personnel from the site and notify
the U.S. Am^ Chemical Warfare Design Center at Himtsville, Alabama. Tlie
Chemical Warfare Design Center will notify the closest Exfiosives Ordnance
Detachment (EOD) to tlie Presidio, i.e., tlie 787'^ EOD at Moffett Field, Cahfomia
(650) 603-8301, or the next closest EOD, tlie60f^ EODatTmvisAirEorceBase
(707) 424-2(>i0.
c. EOD will mate a preliminary assessment of tlie discovery of CWM.
d. EOD will notify the 20^" Support Command. The 2d'' Support Command wiU
make the detailed assessment regarding the discovery of CWM.
e. The 2d'' Support Command aiid other appropriate U.S. Army offices will
coordinate on implementing the Interim Guidance forNon-Sotckpile Chemical
Warfare Materiel Response Activities.
f . Should CWM be confirmed, tlie U.S. Army Chemical Warfare Design Centerwill
submit a Chemical Event Report
Work will resume only after The 20^'' Support Command has conducted a full
investigation or removal of CWM in the area.
13.0 PERSONAL HYGIENE AND DECONTAMINATION
D isposahle wipes will he available to wash hands, face, other exposed skin surfaces, and
hand tools. A formal decontamination station is not applicable for Level D activities, but
PPE, in particular Tyveks used for poison oak protection, will he removed when tlie
woiker leaves the regulated areas. Disposable PPE will be placed in trash hags and
disposed of in trash receptacles. Should the hazard conditions change and formal
decontamination become necessary, the OE Safety Specialist/ SSHO will notify the IH
and an amendment to this SSHP will he required. Emergency decontamination is not
anticipated.
14.0 EOUIPMENT DECONTAMINATION
Equipment that may require decontamination includes tools and sampling equipment.
Any equipment used during the investigation will he hmsh-cleaned and wiped-down with
disposable wipes. Disposable clotliing, tools, buckets, brushes, and other equipment that
is contaminated, as well as materials and equipment used for decontamination will be
secured in appropriate containers.
14.1 Decontamination of Heavy Equipment
SPK will not use heavy equipment on this project.
Appendix E - 21
15.0 EMERGENCY EQUIPMENT AND FIRST AID REQUIREMENTS
Potential on-site emergencies are expected to be restricted to minor fires or injuries to site
personnel. On-site conditions are expected to be within the limits of measures that can be
taken by on-site personnel. Any emergency tliat poses a potential threat to the public will
be considered a situation requiring outside assistance from emergency response agencies.
During any on-siteemeigency, work will cease until the emergency is brought under
control.
The following items, as appropriate, will be available for on-site use:
a. First aid equipment and supplies.
b. Emergency eyewashes (ANSI Z-358.1).
c. Fire extinguishers.
16.0 EMERGENCY RESPONSE AND CONTINGENCY PROCEDURES (ON-
SITE AND OEE-SITE)
16.1 General
Emergency response procedures specific to this project, including telephone numbers for
the closets medical facilities capable of providing emergency service for hazardous waste
site workers, a map showing the locations of these medical facilities. Additionally,
telephone numbers for the Poison Control Center, local police, fire department (including
emergency rescue squad), and SPK management contacts have been provided. The OF
Safely Specialist/ SSHO will be responsible for taking necessary action and contacting
the appropriate emergency contacts and SPK personnel in case of emergency. SPK
personnel will be prepared to respond and act quickly in the event of an emergency. Pre-
planning measures will include employee training, fire and explosion prevention and
protection, chemical spill and discharge prevention and protection, and safe work
practices to avoid personal injury or exposure.
16.2 Local Fire / Police / Rescue
Local fire/police/rescue authorities having jurisdiction and nearby medical facilities that
could be utilized for emergency treatment of injured personnel will be contacted to notify
them of upcoming site activities and potential emergency situations, to ascertain their
response capabilities, and to obtain a response commitment.
16.3 Spill and Discharge Control
Not applicable for this project.
16.4 Fire Prevention Program
Smoking is not allowed in the regulated area at any time. SPK site personnel will be
trained in die general principles of fire extinguisher use and die hazards involved widi
Appendix E - 22
initial stage fire fighting. No fires will be fought where SPK personnel may be in
imminent dangei^ the local fire department will be immediately notified.
16.5 Personnel Roles/Lines of Authority
The OE Safety Specialist/ SSHO will direct all emergency response activities, assure all
emergency contacts and notifications are made, and complete an incident report. The
PM, IH and SO will be notified immediately in the event of an emergency.
16.5.1 Medical Emerxjencv Response
In the event of severe physical orclremical injury, tire OE Safety Specialist/ SSHO will
contactor emergency responders. The emergency medical responders will be utilized to
provide care to severely injured personnel. Hospital location maps will be posted in each
vehicle prior to tire initiation of on-site activities. Any potential RCWM exposures will
be treated at San Francisco G eneral Hospital, other injuries can be treated at California
Pacific Medical Ctr.
16.5.2 Emernency Response Contacts
Project Manager
Teclrnical Team Leader
OE Safety Specialist/ SSHO
Industrial Hygienist
Chief SO
Public Health Service (DFOH)
Occupational Physiciair (DFOH)
San Francisco General Hospital
1001 Poti:eroAve.
San Francisco, CA
(415) 206-8000
California Pacific Medical Ctr.
3700 California St
San Francisco, CA
(415) 600-6400
Poison Control Center
Eire/Police Emergency
National Response Center Oil/Chemical Spills
Bruce Handel
Bradley Call
Thomas Knapp
Cell Phone
David F Flskamp
A.R. Smitir
Marion Conley, RN
Dr. LeeWugfoski, MD
(916)557-7906
(916)557-6649
(916)557-7313
(916)752-0354
(916)557-7903
(916)557-6973
(916)930-2290
(415)556-2975
(800) 222-1222
911
1-800-424-8802
Appendix E - 23
16.5.3 Personal Exposure or Injury
The OE Safety Specialist/ SSHO will call foremergency assistance if needed. As soon
as practical, tlie OE Safety' Specialist/ SSHO will contact the Section Supervisor. Staff
assigned to this project will be briefed on procedures.
17.0 ACCIDENT PREVENTION
17.1 Daily Safety and Health Inspections
Daily safety and heaMi inspections will be conducted to determine if site operations are
in accordance with the approved SSHP, OSHA, and USAGE requirements.
17.2 Accident or Incident
In the event of an accident or incident, the OE Safety Specialist/ SSHO will immediately
notify the PM and the employee's supervisor. Within tliree working days of any
reportable accident/injury /illness, the employee and their supervisor will complete and
submit to the SO and or Human Resources (HR) an Accident Report on ENG Form 3394,
CA-1 and/or GA-2, and otiier applicable forms. The PM will complete and submit DA
Eonn 285 for all Class A and B accidents.
17.3 Accident Investiaations
All injuries, occupational illnesses, vehicle accidents, and incidents with potential for
injuty or loss will be investigated and appropriate corrective measures taken to prevent
recurrence.
18.0 TOGS. REPORTS. AND RECORDKEEPING
The following logs, reports, and records will be developed, retained, and submitted to the
PM:
a. Training logs {site- specific and visitor).
b. Daily safety inspection logs (may be part of the Daily QC Reports).
c. Employee/visitor register.
d. Environmental and personal exposure monitoring/sampling results.
18.1 Record Keeping
The PM will maintain reports generated by the TTL or OE Safety Specialist/ SSHO.
18.2 Accident Reporting and InvestiQation
SPK personnel are required to report all near misses, injuries, illnesses, and accidents to
tire OE Safety' Specialist/ SSHO and their immediate supervisor.
Appendix E - 24
Figure - 1
Sail Francisco General Hospital
1001 Potrero Ave
(415)206-8000
California Pacific Medical Ctr.
3700 California St
(415) 600-6400
Directions to San Francisco General Hospital:
Depart Presidio of San Francisco on Lincoln Blvd
Left onto Presidio Blvd {0.1 mile)
Left onto Lombard St (0.4 mile)
Right onto US- 101 (Lombard St) (0.1 mile)
Right onto Divisadero St (1.1 mile)
Left onto Geary Blvd (0.8 mile)
Road name changes to O'Farrell St (0.2 mile)
RightoiitoUS-101 (Van NessAve) (0.6 mile)
Left onto Fell St (0.1 mile)
Road name changes to 1 0"^^ St (0.8 mile)
Rightonto Potrero Ave (1.0 mile)
Leftonto23"'St(0.1niile)
Left onto Local roads (s) (0.1 mile)
Appendix E - 25
ACTIVITY HAZARD ANALYSIS
ACTIVITY : Contractor Oversight and Project QA
Aiucipdl St^s
Fot^itial Hazards
Recommended Caatrols
1. Site investigation
Chaiiical HazanJs: CliEaiiicat Warfare
Chaaical Hazards
for Ihe [xeseice
Malmd
in particular HD. chemical warfare
1.
Levd D PPE.
of chanical agE9it
agsait Ixeak-down products, and simulante.
2.
MS DSs for fuels for small equipnent:
idaitification s^
Radioloc[ical Hazards: None anticipated
no sanifie preservatives anticipated
malmal or
Bioiociical Hazards: Snakes, coison oak.
3.
If CWM is encounta^i or suspected, all
chemical warfare
insects, spsdeis, tics
work will stop.
malmd residiKS.
Physical Hazards:
Radiological Hazards: Nane
Sdective removal
1.
Cute, scr^ies, ard pinch pointe
Bioloaical Hazaids: Beawaieof envirormient
of venation
from equipmait
PPE. and insect repdlanb.
raking forest duff
2.
Slip^tiip'fall on slippejy surfaces
Hiysical
hazards
oiit of lienches.
and uneven tesiain
1.
Guards must be pi ace around moving
check for CA IS
3.
Heat/cold sti^ss. sun bums
eqiripmait parts.
malmal, soil and
i.
Noise from heavy eqiiipmeait
2.
Watch wha:e you step, be awaie tiiat
swipe saiiifiiitg
5.
Struck t|y or against a pece of
leaves and grass, causingyou to tap.
forcfonical
heavy equipmait
can conceal sticks, rocks or otha" itaiis.
agait treak-down
6.
Contact with overhead and
3.
Only qualified and trained peisonneJ
pitxlucts, OE
undHgriDund utilities.
will operate equipnait
constnKtion
7.
Excavation wall coll^Dse.
4.
EqiripEoeait must be inspected by a
sn^Mrt
8.
Struck 1^ backhoe.
competait pesson and operated in
2. A Conhactor
accordance wi Ih Ihe maiuf actura"' s
may assist with
instructions.
venation
5.
Moving equipment must have pupaly
raDovaland
functioning back-i^ alarms.
excavations of
6.
Equipmait shall not run unattaided
pDlhoies (usiiig a
7.
Hearing ixotecrtion will be worn at 85
backhoe).
dBA.
3. Ovasi^ and
8.
Frequesit Ixeaks and refJacement fluids
Project QA
9.
10.
11.
12.
13.
to prevent heat stress.
Never walk or woik directiy in back or
to the side of heavy equipnait without
the operator's knowledge.
Practice safe liftirtg
Drivers will liave a vdid drives license
and will wear a seat beJt at all times.
Use Ihe correct tools for the j ob.
Woiteis will not enter excavations at
any time
Equipment to be Used
laspectioQ Requironents
Trainiaq Requirem^its |
1. Tlie conti'actor
1.
The SSHO will conctict daily site
1.
HAZWOPER 40-hour initial tiBining
may use a
saf^ inspections.
pj us 8-hour r^resher wilhin the past 12
backhoe.
months.
2. Hard tools, small
2.
Initial site indacliination training.
pawEi: tools such
3.
Daily tailgate safdy medings.
as chainsa\vs arxl
i.
Hazard Communication Iraining for ar^r
weed-wackeis.
Ivrmrdous materials brou^ to the
small tractor.
jobsite.
TheOESafe^
5.
FiistAid/CPR
Specialist may
useahand-hdd
iiiagnEfometo'.
Appendix E - 26
EMPLOYEE ACKNOWLEDGMENT
This projectrequires the following: that you be provided with and complete fonnal and
site-specific training; that you be supplied with proper personal protective equipment
including respirators; that you be trained in its use; and that you receive a medical
examination to evaluate your physical capacity to perform your assigned work tasks,
under the environmental conditions expected, while wearing the required personal
protective equipment. These tilings are to be done at no cost to you. By signing this
certification, you are acknowledging that tlie Corps of Engineers has met these
obligations to you.
I have reviewed, understand and agree to follow this Site Safely and Health in addition to
the Contractor's SSHPs.
Printed Name
Signature
Organization
Date
Appendix E - 27
TRAINING ACKNOWLEDGMENT EORM
By signing this certificate, you are acknowledging that you have completed the following
formal training:
SITE-SPECIFIC TRAINING: 1 have completed tlie SPK /contractor site- specif ic training
Employee Initials
RESPIRATORY PROTECTION: 1 have been trained in accordance witli SPK's
Respiratory Protection Program, SPK OM 385-1-1. I have been trained in the proper
woit procedures and use and limitations of tlie respirator(s) I will potentially wear. I
have been trained in and will abide by the facial hair policy. SPK employees will
evacuate the site if conditions require an upgrade to EPA/OSHA Level B or A PPE
(which includes respiratory protection).
Employee Initials
MEDICAL EXAMINATION: 1 have had a medical examination within the last [twelve
months] [two yearsl, which was paid for by the Corps of Engineers. The examination
included: IreaMr history, pulmonary function tests and may have included an evaluation
of a chestx-ray. A physician made a determination regarding my physical capacity to
perform work tasks on the projectwhile wearing protective equipment including a
respirator. I was personally provided a copy and infonned of the results of that
examination. The Chief of SO Office evaluated tire medical certification provided by the
physician. The physician determined that there:
a. Were no limitations to perfonning the required wort tasks;
Employee Initials
b. Were identified physical limitations to performing the required work tasks?
Employee Initials
Employee' s Signature D ate
Employee's Name
(Printed)
Appendix E - 28
U.S. Army Center for Health Promotion and Preventive Medicine
Detailed Facts About Tear Agent 2-
Ch loroacetoph enone
(CN)
218-19-1096
Physical Properties of Tear Agent 2-Chloroacetophenone
Chemical Structure
<^
O
--C--CH,--C1
Chemical Formula
Description
Molecular Weight
Boiling Point
Vapor Pressure (mm Hg)
Q H, COCH, CI
CN is a colorless-to gray crystalline solid with a sharp,
irritating floral odor. The odor threshold for CN is
0.1 mg/m\
154.60
247 掳C
0.0026 @ 0掳C
0.0041 @ 20''C
0.152 @ 51.7掳C
Freezing Point
Density
Solubility
Flash Point
54='C
Solid = 1.318 @ 20掳C
Liquid = 1.187 @ 58''C
Vapor = 5.3 (air = 1)
Insoluble in water
118掳C
Agent CN - The chemical chioroacetophenone. Chemical AbslracI Service Registry No. 532-27-4.
2.36 mg/m^
@ 0掳C
34.3 mg/m'
@ 20掳C
1060 mg/m-
' @ 5[.l'
C
ICt,鈥?
LCt,鈥?
RfC (inhalation)
Volatility
Toxicity Values ICtj^ = 80 mg-min/m'
= 7,000 mg-min/m' from solvent
= 14,000 mg-min/m3 from grenade
= 0.00003 mg/m*
Exposure Limits
Workplace Time- Weighted Average - 0.3 mg/m'
General Population Limits - 0.00003 mg/m'
Toxic Properties of Chloroacetophenone
The United States considers agent CN (popularly known as mace or tear gas) and its mixtures
with various chemicals to be obsolete for military deployment. It is highly toxic by inhalation
and ingestion.
Overexposure Effects
Alpha-chloroacetophenone vapors may cause a tingling or runny nose, burning and/or pain of the
eyes, blurred vision, and tears. Burning in the chest, difficult breathing, and nausea may also
occur as well as sicin irritation, rash, or burns. It can also cause difficulty if swallowed.
Emergency and First Aid Procedures
Inhalation: remove the victim to fresh air immediately : perform artificial respiration if breathing
has stopped; keep victim warm and at rest; seek medical attention immediately .
Eye Contact: wash eyes immediately with copious amounts of water, lifting the lower and upper
hds occasionally; do not wear contact lenses when working with this chemical; seek medical
attention immediately .
Skin Contact: wash the contaminated skin using soap or mild detergent and water immediately ;
remove the contaminated clothing immediately and wash the skin using soap or mild detergent
and water; seek medical attention immediately when there are chemical burns or evidence of skin
irritation.
Ingestion: induce vomiting by having victim touch the back of the throat with finger or by giving
victim syrup of ipecac as directed; do not induce vomiting if victim is unconscious; seek medical
attention immediately.
Protective Equipment
Protective Gloves:
Eye Protection:
Other:
Reactivity Data
Stability:
Incompatibility;
Hazardous Decomposition:
Wear impervious gloves.
Wear dust- and splash-proof safety goggles where there is
any possibihty of solid CN or liquids containing CN may
contact the eyes; wear face shield; wear appropriate
protective mask.
Wear a complete set of protective clothing to include
gloves and lab coat, apron, boots, plastic coveralls; other
protective clothing and equipment should be available
to prevent contact with skin or clothing; remove
contaminated clothing immediately; do not wear
clothing until it has been properly laundered.
Stable in closed containers at room temperature under
normal storage and handling conditions.
Water or steam.
Toxic and corrosive vapors are produced when combined
with water or steam.
Persistency
Short because the compounds are disseminated as an
aerosol.
References
1. Code of Federal Regulations, Part 1910.1000, Title 29, (29 CFR 1910.1000), Air
Contaminants, 1994.
2. Department of the Army Field Manual (DA FM) 3-9, Potential Military Chemical/Biological
Agents and Hazardous Chemicals, 1990.
3. Department of the Army Technical Manual (DA TM) 3-250, Storage, Shipment, Handling,
and Disposal of Chemical Agents and Hazardous Chemicals, 1969.
4. Threshold Limit Values for Chemical Substances and Physical Agents and Biological
Exposure Indices for 1995-1996, American Conference of Governmental Industrial
Hygienists (ACGIH), Cincinnati, Ohio.
5. Genium's Reference Collection, Material Safety Data Sheet No. 603, 2-Chloroacetophenone,
Genium Publishing Corporation, Schenectady, New Yorlc, 1986.
6. U.S. Army Chemical Command Materiel Destruction Agency, Site Monitoring Concept
Study, 15 September 1993.
For more information, contact:
Kenneth E. Williams
USACHPPM
Aberdeen Proving Ground, MD 21010-5422
Commercial (410) 671-2208, DSN: 584-2208
email: kwilliam@aehal.apgea.army.mil
U.S. Army Center for Health Promotion and Preventive Medicine
Detailed Facts About Tear Agent
O-Chlorobenzylidene Malononitrile
(CS)
218-23-1096
Physical Properties of Tear Agent
O-Chlorobenzylidene Malononitrile
Chemical Structure
CI
\,
H
鈥--C-C---C=N
N
Chemical Formula
Description
Molecular Weight
Boiling Point
Vapor Pressure (mm Hg)
Freezing Point
Density
Solubility
C,o Hs CI N,
CS is a white crystalline solid; burnt to create a colorless
gas with an acrid pepperlike smell.
188.5
310掳Cto 315掳C
3.4 X 10-' @ 20掳C
93掳Cto95''C
Solid = 1.04 g/cc
Vapor - several times heavier than air
Soluble in hexane, benzene, methylene chloride,
acetone, dioxane, ethyl acetate, and pyridine; insoluble in
water and ethanol.
Flash Point
197掳C
Agent CS - The chemical o-chlorobenzylidene malononitrile, Chemical Abstract Service Registry No. 2698-41-
I.
Volatility 0.71 mg/m' @ 25掳C
Toxicity Values ICtj^ = 10 to 20 mg-min/m'
LCti鈥?= 61,000 mg-min/m'
Exposure Limits
Workplace Time-Weighted Average - 0.4 mg/m'
General Population Limits - No standard identified
Toxic Properties of O-Chlorobenzylidene Malononitrile
CS was developed in the late 1950s as a riot-control substance. It is a more potent irritant than
chloroacetophenone but less incapacitating. In the late 1960s, stocks of CS replaced CN.
Presently, the U.S. Army uses CS for combat training and riot control purposes.
Overexposure Effects
CS is disseminated by burning, explosion, and aerosol formation. It is immediately irritating to
the eyes and upper respiratory tract. Warm vapors mix with human sweat to cause a burning
sensation to the eyes, nose, and mouth. Conjunctivitis and pain in the eyes, lacrimation, erythema
of the eyelids, runny nose, burning throat, coughing and constricted feeling in the chest are the
effects which will occur immediately and will persist 5 to 20 minutes after removal from the
contaminated area.
It is immediately dangerous to life and health at a concentration of 2 mg/m' It is not an
accumulative agent in the human body, although it accumulates in the landscape. CS is the most
persistent of the tear agents, absorbing into the most porous surfaces including soil and plaster.
Emergency and First Aid Procedures
Inhalation: remove the victim to fresh air immediately : perform artificial respiration if breathing
has stopped; keep the victim warm and at rest; seek medical attention immediately .
Eye Contact: wash eyes immediately with copious amounts of water for at least 15 minutes;
apply an ophthalmic corticosteroid ointment after decontamination; treat delayed erythema with a
bland shake lotion (such as calamine lotion) or a topical corticosteroid depending on severity; do
not wear contact lenses when working with this chemical; seek medical attention immediately .
Skin Contact: wash the contaminated skin thoroughly using soap and water; remove the
contaminated clothing immediately : if irritation persists after washing, seek medical attention
immediately .
Ingestion: give victim copious amounts of water immediately : induce vomiting by having victim
touch the back of throat with finger; do not make an unconscious person vomit; seek medical
attention immediately .
Protective Equipment
Protective Gloves:
Eye Protection:
Other:
Wear impervious gloves; rubber gloves.
Wear face shields or dust- and splash-proof safety goggles
to prevent any possibility of skin contact.
Wear protective mask and overclothing in confined spaces;
use a chemical cartridge respirator with organic vapor
cartridges in combination with a high efficiency particulate
filter; wear a self-contained breathing apparatus with a full
face piece or an air purifying, full-face piece respirator with
an organic vapor canister.
Do not use standard decontaminants or detergents that contain chlorine bleach because the
materials can react to form compounds more toxic than CS. Contaminated surfaces should be
decontaminated using a solution of equal parts (by volume) methanol and water with 18 percent
(by weight) sodium hydroxide or commercial lye added to the solution. Also, an aqueous solution
containing 10 percent monoethanolamine anionic detergent can be used as a decontaminant.
Reactivity Data
Stability:
Incompatibility;
Hazardous Decomposition:
Hydrolysis Products:
Persistency
References
Stable in storage.
Incompatible with strong oxidizers.
When heated to decomposition, CS emits very toxic fumes.
AQ Alkahne.
Varies, depending upon amount of contamination.
1. Department of the Army Field Manual (DA FM) 3-9, Potential Military Chemical/Biological
Agents and Compounds, 1990.
2. The Merck Index, An Encyclopedia of Chemicals, Drugs, and Biologicals, Eleventh Edition,
Merck & Co., Inc., Rahway, New Jersey, 1989
3. Hazardous Substances Data Bank, January 1996.
For more information, contact:
Kenneth E. Williams
USACHPPM
Aberdeen Proving Ground, MD 21010-5422
Commercial (410) 671-2208, DSN: 584-2208
email: kwilliam@aehal.apgea.army.mil
U.S. Army Center for Health Promotion and Preventive Medicine
1'-
BZ
HI^" I
PS
鈩?(|
CG
Detailed Facts About Sulfur Mustard Agents
HandHD
218-08-1096
Physical Properties of Sulfur Mustard HD
Chemical Structure
Chemical Formula
Description
Molecular Weight
Vapor Pressure {mm Hg)
CICH.CH-S-CHiCHjCl
C4(Hb)Ci:(S)
Mustard agent liquid is colorless when pure, but it is
normally a yellow to brown oily substance. Mustard agent
vapor is colorless with a sUght garhc- or mustard-hke odor.
159.08
0.072 @ 20''C
0.11 @ 25掳C
Boiling Point
Freezing Point
Density
Solubility
215-217掳C; slowly vaporizes at ordinary temperatures.
14.5掳C
Liquid = 1.27
Vapor = 5.4 (air = 1)
Very spai'ingly soluble in H;0; freely soluble in animal
oils, fats, organic solvents.
Agent HD - The chemical Distilled mustard or bis(2-chloroethyl) sulfide; HD isH that has been purified by washing
and vacuum distillation to reduce sulfur impurities, Chemical Abstract Service Registry No. 505-60-2.
Flash Point
Volatility
105掳C
75 mgW @ 0掳C (soUd)
610mg/m- @ 20掳C (liquid)
2,860 mg/m' @ 40掳C
Toxicity Values
ICtso (eyes)
ICtso (inhalation)
ICtjo (skin)
LCtso (inhalation)
LCL[) (inhalation,
10 min)
LD50 (skin)
LD50 (oral)
1% Lethality
No Deaths Level
NOAEL
(inhalation)
200 mg-min/m
1,500 mg-min/m
2,000 mg-min/m' @70'* to 80掳F
(humid environment)
1,000 mg-min/m^ @ 90^*0
(dry environment)
1,500 mg-min/m'
1,496 mg-min/m'
100 mg/kg
0.7 mg/kg
150 mg-min/m
100 mg-min/m'
1 .4 mg-min/m
Exposure Limits
Workplace Time-Weighted Average - 0.003 mg/m'
General Population Limits - 0.0001 mg/m
Toxic Properties of Sulfur Mustard
Mustard agents stored in the unitary stockpile are in ton containers, artillery shells, and other
munitions. Stockpiled at Aberdeen Proving Ground, MD; Anniston Army Depot, AL; Blue Grass
Army Depot, KY; Pine Bluff, AR; Pueblo Depot Activity, CO; Tooele Army Depot, UT; and
Umatilla Depot Activity, OR.
Overexposure Effects
HD is a vesicant (bhster agent) and alkylating agent producing c34otoxic action on the
hematopoietic (blood forming) tissues, which are especially sensitive. The rate of detoxification
of HD in the body is very slow, and repeated exposures produce a cumulative effect. The
physiological action of HD may be classified as local and systemic. The local action results in
conjunctivitis or inflammation of the eyes, erythema which may be followed by blistering or
ulceration; inflammation of the nose, throat, trachea, bronchi, and lung tissue. Injuries produced
by HD heal much more slowly and are more susceptible to infection than burns of similar intensity
produced by physical means or by most other chemicals. Systemic effects of mustard may include
malaise, vomiting, and fever, with onset time about the same as that of the skin erythema.
With amounts approaching the lethal dose, injury to bone marrow, lymph nodes, and spleen may
result. HD has been determined to be a human carcinogen by the International Agency for
Research on Cancer.
Emergency and First Aid Procedures
Inhalation: remove victim from the source immediately ; administer artificial respiration if
breathing has stopped; administer oxygen if breathing is difficult; seek medical attention
immediately .
Eye Contact: speed in decontaminating the eyes is absolutely essential; remove person from the
liquid source, flush the eyes immediately with water by tilting the head to the side, pulling the
eyehds apart with the fingers, and pouring water slowly into the eyes; do not cover eyes with
bandages; but if necessary, protect eyes by means of dark or opaque goggles; seek medical
attention immediately .
Skin Contact; don respiratory protective masks and gloves; remove victim from agent source
immediately ; flush skin and clothes with 5 percent solution of sodium hypochlorite or liquid
household bleach within 1 minute; cut and remove contaminated clothing; flush contaminated skin
area again with 5 percent sodium hypochlorite solution; then wash contaminated skin area with
soap and water; seek medical attention immediately .
Ingestion: do not induce vomiting; give victim milk to drink; seek medical attention immediatel y.
Protective Equipment
Protective Gloves:
MANDATORY - Wear Butyl toxicological agent protective
gloves (M3, M4, gloveset).
Eye Protection:
Wear chemical goggles as a minimum; use goggles and
face shield for splash hazard.
Other;
Wear gloves and lab coat with M9 or M17 mask readily
available for general lab work.
In addition, wear daily clean smock, foot covers, and head
cover when handling contaminated lab animals.
Reactivity Data
Stability:
Incompatibihty:
Stable at ambient temperatures; decomposition
temperatures is HQ^'C to m掳C; can be active for at least
three years in soil; stable for days-week, under normal
atmospheric temperature; slowly hydro lyzed by water;
destroyed by strong oxidizing agents.
Rapidly corrosive to brass @ 65'*C; will corrode steel at
.001 in. of steel per month @ 65掳C.
Hazardous Decomposition: Mustard will hydrolyze to form HCI and thiodiglycol.
Hazardous Polymerization: Will not occur.
Persistency Depends on munition used and the weather; heavily
splashed liquid persists 1 to 2 days in concentration to
provide casualties of military significance under average
weather conditions, and a week to months under very
cold conditions.
References
1. Department of the Army Pamphlet (DA PAM) 40-173, Occupational Health Guidelines for
the Evaluation and Control of Occupational Exposure to Mustard Agents H, HD, and HT,
30 August 1991.
2. Department of the Army Field Manual (DA FM) 3-9, Potential Military Chemical/Biological
Agents and Compounds, 1990.
3. Institute of Medicine, National Academy of Sciences, CM. Pechura and D.P. Rail, eds..
Veterans at Risk: The Health Effects of Mustard Gas and Lewisite, National Academy Press,
Washington, D.C., 1993.
4. Papirmeister, B., et al.. Medical Defense Against Mustard Gas: Toxic Mechanisms and
Pharmacological Implications, Boca Raton, Florida: CRC Press, 1991.
5. U.S. Army Chemical Command Materiel Destruction Agency, Site Monitoring Concept
Study. 15 September 1993.
For more information, contact:
Kenneth E. Williams
USACHPPM
Aberdeen Proving Ground, MD 21010-5422
Commercial (410) 671-2208, DSN: 584-2208
email: kwilliam@aehal.apgea.army.mil
U.S. Army Center for Health Promotion and Preventive Medicine
General Facts About Blister Agent Lewisite
(L)
218-38-1096
General
Synonyms
L is a vesicant (blister agent); also, it acts as a systemic poison,
causing pulmonary edema, diarrhea, restlessness, weakness,
subnormal temperature, and low blood pressure. In order of
severity and appearance of symptoms, it is: a blister agent, a toxic
lung irritant, absorbed in tissues, and a systemic poison. When
inhaled in high concentrations, it may be fatal in as short a time as
10 minutes. L is not detoxified by the body. Common routes of
entry into the body include ocular, percutaneous, and inhalation.
Arsine, (2-chlorovinyi) dichloro-;
Arsonous, dichloride, (2-chloroethenyl)-;
Chlorovinylarsine dichloride;
2-Chlorovinyldichloroarsine;
beta-Chlorovinyldichloro arsine;
Dichloro (2-chlorovinyl) arsine;
L;
EA1034.
Description
Overexposure Effects
Pure Lewisite is a colorless, oily liquid with very little
odor. The plant sample (war gas) has a geranium-like
odor and is an amber to dark brown liquid.
Lewisite presents both a vapor and liquid hazard and may damage
the eyes, skin, respiratory tract, and circulatory system. Exposure
to L causes immediate (within 30 seconds) irritation or pain. The
vapor may be inhaled into the respiratory tract, causing the
immediate onset of burning pain, irritation of the nose, and reflex
coughing and chest tightness. The vapor also affects the eyes,
with the immediate onset of pain, redness, uncontrollable
blinking, and swelling of the eyelids. The vapor or a hquid splash
of L on the skin may cause immediate stinging pain and
destruction of tissue, following by blistering within 12 hours.
Lewisite - The chemical chlorovinyldichloroarsine. Chemical Abstract Service Registry No. 541-25-3.
Emergency and First Aid Procedures
Inhalation: remove from the source immediately ; give artificial respiration if breathing has
stopped; administer oxygen if breathing is difficult; seek medical attention immediately .
Eye Contact: speed in decontaminating the eyes is absolutely essential; remove person from the
liquid source; flush the eyes immediately with water for 10-15 minutes by tilting the head to the
side, pulling eyelids apart with fingers, and pouring water slowly into the eyes; do not cover eyes
with bandages, but if necessary, protect eyes by means of dark or opaque goggles; seek medical
attention immediately .
Skin Contact: remove victim from source immediately and remove contaminated clothing;
immediately decon affected areas by flushing with 10 percent sodium carbonate solution; wash off
with soap and water after 3 to 4 minutes to protect against erythema; seek medical attention
immediately .
Ingestion: do not induce vomiting; give victim milk to drink; seek medical attention immediately .
Storage ofL
L is stored in ton containers (heavy steel cyhnders) at one military installation on the continental
United States - Tooele Army Depot, Utah.
For more information, contact;
Kenneth E. Williams
USACHPPM
Aberdeen Proving Ground, MD 21010-5422
Commercial (410) 671-2208, DSN: 584-2208
email: kwilliam@aehal.apgea.army.mil
U.S. Army Center for Health Promotion and Preventive Medicine
General Facts About Choking Agent Phosgene
(CG)
218-25-1096
General
Synonyms
Description
Overexposure Effects
CG, normally a chemical agent with a short duration, was used
extensively in World Wai' I. More than 80 percent of
World War I chemical agent fatalities were caused by CG.
Carbonyl chloride:
Carbon oxychloride;
Carbon dichloride oxide;
Carbon dichloride;
Carbonic acid dichloride;
Chloroformyl chloride.
CG is a severe eye, mucous membrane, and skin irritant. It is
highly toxic by inhalation. Two parts per million in air is
immediately dangerous to life and health. Being a gas, it is
primarily atoxic hazard by inhalation exposure. CG is foglike in
its initial concentration but becomes colorless as it disperses. It
has an odor of newly mown hay.
Phosgene is a corrosive, highly toxic gas used as a delayed-casualty
agent resulting in fluid buildup in the lungs ("dryland drowning"').
It affects the upper respiratory tract, skin, and eyes and causes
severe respiratory damage as well as burns to the skin and eyes.
Acute inhalation may cause respiratoiy and circulatory failure with
symptoms of chills, dizziness, thirst, burning of eyes, cough,
viscous sputum, dyspnea, feeling of suffocation, tracheal rhonchi,
burning in throat, vomiting, pain in chest, and cyanosis. CG is a
severe mucous membrane irritant. Chronic inhalation may cause
irreversible pulmonary changes resulting in emphysema and
fibrosis. Acute skin contact may result in lesions similar to those
of frostbite and burns; it is a severe skin imtant. Chronic skin
contact may result in dermatitis. Acute eye contact may result in
conjunctivitis, lacrimination, lesions similar to those of frostbite,
and burns; chronic eye contact may result in conjunctivitis.
Agent CG - The chemical carbonyl chloride. Chemical Abstract Service Registry No. 0075-44-5.
Emergency and First Aid Procedures
Inhalation: rennove victim to fresh air; keep individual calm and avoid any unnecessary exertion
or movement; maintain airway and blood pressure; trained persons should administer oxygen
if breathing is difficult; give artificial respiration if victim is not breathing; seek medical attention
immediately .
Eye Contact: flush eyes immediately with running water or normal saline for at least 15 minutes;
hold eyelids apart during irrigation; do not delay rinsing to avoid permanent eye injury; seek
medical attention immediately .
Skin Contact: unlikely that emergency treatment will be required; gently wrap affected part in
blankets if warm water is not available or practical to use; allow circulation to return naturally; if
adverse effects occur, seek medical attention immediately .
Ingestion: treat symptomatically and supportively; if vomiting occurs, keep head lower than hips
to prevent aspiration; seek medical attention immediately .
For more information, contact:
Kenneth E. Williams
USACHPPM
Aberdeen Proving Ground, MD 21010-5422
Commercial (410) 671-2208, DSN: 584-2208
email: kwilliam@aehal.apgea.army.mil
U.S. Army Center for Health Promotion and Preventive Medicine
General Facts About Tear Agent Chloropicrin
(PS)
218-46-1096
General
Synonyms
PS was used in large quantities during World War I; it was
stockpiled during World War II and is no longer authorized for
military use. PS is more toxic than chlorine but less toxic than
phosgene (CG). PS is a severe respiratory irritant. Persons with
impaired pulmonary function may be at increased risk from
exposure. It is a possible but unconfirmed tumorigenic agent
that decomposes to form toxic chlorine gas and nitrogen oxides
near oxygen fires.
Nitrotrichloromethane;
Trichloronitromethane;
Nitrochloroform.
Description
Overexposure Effects
Emergency and First Aid
Procedures
PS is a colorless, oily liquid with a stinging pungent odor.
Chloropicrin is a powerful irritant whose vapors cause lung, skin,
eye, nose and throat in'itation, coughing and vomiting. As an eye
irritant, it produces immediate burning, pain and tearing. In high
concentration, PS damages the lungs, causing pulmonary edema.
Exposure to liquid PS can cause severe burns on the skin that
generally result in blisters and lesions. The lowest irritant
concentration is 9 mg-min/m"^ for 10 minutes, and the median lethal
concentration is 2,000 mg-min/m'.
Inhalation: remove the victim to fresh air immediately : perform
artificial respiration if breathing has stopped; keep the victim warm
and at rest; seek medical attention immediately .
Eye Contact: wash eyes immediately with copious amounts of
water, lifting the lower and upper lids occasionally; do not wear
contact lenses when working with this chemical; seek medical
attention immediatelv.
Agent PS - The chemical chloropicrin, Chemical Abslract Service Registry No. 0076-06-2.
Skin Contact: wash the contaminated skin using soap or mild detergent and water; remove the
contaminated clothing immediately ; wash the skin using soap or mild detergent and water; if
irritation persists after washing, seek medical attention immediately .
Ingestion: give victim copious amounts of water immediately : induce vomiting by having victim
touch the back of his throat with his finger; do not make an unconscious person vomit; seek
medical attention immediately.
For more information, contact;
Kenneth E. Williams
USACHPPM
Aberdeen Proving Ground, MD 21010-5422
Commercial (410) 671-2208, DSN: 584-2208
email: kwilliam@aehal.apgea.army.mil
| ALL PAGES On Chemical Property IN THIS GROUP | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
|
HBCChem,Inc
Chemical Information Net chemcas.orgCopyright Reserved
Trading Lead
Leputech HPLC Laboratory
Trading Lead
Leputech HPLC Laboratory