Once AMI Environmental and the Emergency Response Team arrived in New Orleans, a plan was needed to be put in place in order to get the Department of Defense building up and running again. The only problem was the hazardous waste that needed to dealt with before any actions could be started.
In accordance with accepted industry practices and regulatory requirements, the Environmental Health and Safety team developed and implemented a site-specific Health and Safety Plan (HASP) to protect all persons entering the building and workers performing cleanup activities from environmental hazards. To expedite the cleanup process and to ensure that consistent standards were established and enforced throughout the project, all cleanup contractors agreed to follow and abide by the same HASP. The HASP was reviewed and approved by the facility management team. Elements of the HASP included an activity hazard analysis, work plans and specifications, and quality control procedures necessary for the proper abatement, cleanup and disposal of hazardous materials; proper decontamination of all surfaces, including heating and air conditioning system and associated ductwork; and to protect the facility from further contamination during cleanup operations. As with any working manual, the HASP was updated frequently with situation-specific work plans and specifications necessary for proper handling of the exceptional array of environmental hazards encountered – microbials, bio-hazards, radiation, asbestos, hydrocarbons and a variety of hazardous chemicals.
Work plans and specifications spelled out engineering controls and work practices, as well personal protective equipment and site safety precautions necessary to protect workers from the respective hazards. Engineering controls were implemented throughout the facility to protect clean areas from contamination or recontamination. Air scrubbing machines and drying equipment ran continuously, filtering and dehumidifying air and maintaining proper differentials in air pressure.
Once site condition assessments were completed, cleanup and decontamination objectives were identified. Priority was given to the needs of Leo A. Daly and facility engineers who needed access to various areas of the building, especially areas where key building systems are located. Work areas were demarcated according to potential environmental exposures and required work disciplines. Environmental remediation and restoration firms were contracted by facility officials to perform the work.
When actual remediation and cleaning operations began, continuous environmental quality and contractor compliance monitoring was conducted throughout the duration of the cleanup process to ensure and document that worker exposure levels were within acceptable ranges as determined by Occupational Safety and Health Administration (OSHA). Environmental Health and Safety representatives verified that worker training and certification requirements were current and met daily with project superintendents from each contracting company to prioritize immediate objectives and to provide support as needed. Daily safety meetings were conducted by onsite contractors and were often attended by an Environmental Health and Safety representative. Other duties included work activity coordination and schedule management; daily quality control and progress reporting; emergency response; and documentation of all aspects of the project.
The diversity of the waste stream generated from the facility required careful segregation according to hazard classification and packaging and disposal requirements. While disposal requirements in the region for certain demolition waste streams were relaxed to accommodate the desperate circumstances, care had to be given to ensure that all toxic and special wastes were packaged, stored, transported and disposed of properly.
As work in defined work areas was completed, visual inspections and clearance monitoring was performed to ensure acceptable cleanliness standards were achieved. Particular attention was given to the interior surfaces of the HVAC ductwork to prevent the dispersion of contaminants when the systems were brought back online. All clearance sampling results were incorporated in to the permanent project record.
The ultimate goal of the initial cleanup effort was to remove all disaster-related wastes and restore the interior environment of the facility to a safe and healthy state where respirators and disposable clothing were no longer needed to work at the site.