taken; however, because lead had not been specifically identified during the RI/FS stage, no
requirements for such sampling had been incorporated into the SAHP. As a consequence,
these samples were taken at the contractor’s expense, which means that a disincentive had
been built into the system to discourage the contractor from exercising its judgment as on-site
conditions changed. Another example concerns the maintenance operation conducted about
once per week at the site that requires employees to enter the secondary kiln to chip away
slag that accumulates on the inner walls. Employees are provided with air-purifying
Tespiratory protection to conduct this operation. Despite the potential for exposure to silica,
personal samples for this substance have not been taken and are not required by contract, and

thus there is no confirmation that air-purifying respirators are appropriate.

D. TASK-SPECIFIC HAZARD ANALYSES MUST LEAD TO THE
DEVELOPMENT OF WRITTEN STANDARD OPERATING PROCEDURES
(SOPs) THAT SPECIFIED THE CONTROLS NECESSARY TO SAFELY
PERFORM EACH TASK.

Detailed hazard analyses conducted for each site task and operation provide the basis
for developing standard operating procedures to protect employees from safety and health
hazards, Written safety and health SOPs provide a mechanism for keeping employees aware
of procedures that ensure their safety and for management to ensure that hazard control
procedures are enforced. Requirements for written safety and health SOPs are included in
paragraphs (6)(4)(i) of the HAZWOPER standard. In general, the inspection team found that
written SOPs either lacks sufficient detail to be useful to employees and safety and health
personnel, or were not available for several important operations.

For example, the SAHP developed for Site B did not include written safety and health
procedures and protective measures to be used for the emergency shutdown of the
incinerator. Safety and health hazards may be present during automatic waste feed shutoff
(AWFSO), which can occur from a variety of causes, such as elevated stack temperature,
low furnace vacuum, low oxygen levels, failure of the furnace pilot light, failure of the brick
lining, low water pressure to the scrubber, or inappropriate flow of waste feed. Although

the site maintained written procedures for incinerator operation during AWFSO events, these

17


single site safety and health supervisor who had overall responsibility for the enforcement of
safety and health requirements for all personnel on site had been designated. Although it
may be appropriate for each contractor to develop its own SAHP, OSHA considered it
essential that both pians be integrated and enforced consistently to ensure uniformity and
clear understanding of expectations by on-site personnel, and particularly to ensure clear
lines of authority and an understanding of response actions during an emergency situation.
At this site, the emergency alerting schemes of the prime and subcontractor varied
considerably, a situation that could easily lead to confusion in crisis (See Section E below).
Another result of having two safety and health supervisors enforcing separate plans for their
own employees was that PPE requirements frequently varied for prime and subcontractor
employees. For example, some employees of one contractor expressed concern and were
confused about a requirement that they wear Level C protection in an area where employees
of the other contractor were permitted to wear Level D PPE. Allowing a situation of this
type to continue clearly undermines any effort to convey to employees the need to take

appropriate protective measures to guard against exposure to hazardous conditions.

Cc. THE SAFETY AND HEALTH PROGRAM MUST BE EFFECTIVE IN
ENSURING THAT ONGOING TASK-SPECIFIC HAZARD ANALYSES WERE
CONDUCTED SO THAT THE SELECTION OF APPROPRIATE PPE COULD
BE MADE AND MODIFIED AS CONDITIONS WARRANT.

The OSHA standard (29 CFR 1910.120) mandates that site safety and health
programs require task- and operation-specific hazard analyses to be conducted at the site;
these analyses are intended to ensure a comprehensive and systematic approach to hazard
anticipation, recognition, and evaluation at hazardous waste sites. Because work operations
and site conditions change as the remediation process progresses, hazard analyses must be
conducted on an ongoing basis; that is, the potential hazards associated with each operation
must be reevaluated periodically as conditions change to ensure that employees are being
afforded appropriate protection. For example, as work progresses, all information and data
on employee exposures obtained to date should be incorporated into the analysis to enhance
and refine the evaluation; the results of air monitoring are an important source of site-

specific information used for hazard analysis. The requirement to conduct task- and

ll


representative did report that procedures had been developed for tracking potentially
contaminated patients, however.

Site B’s Spill Control and Response Plan was not current, as evidenced by the
organization chart, which identified as responsible individuals, persons who were no longer
employed at the site. In addition, the written Spill Response Plan contained procedures for
conducting monthly meetings, drills, and periodic spill containment inspections; none of these
procedures were being implemented at the site. OSHA recommended that the program be
reevaluated to ensure that it addressed specific hazards at the site, including those locations
around the aqueous waste treatment area where hazardous materials were being stored.

Interviews with employees at Site B indicated that some were not familiar with the
meaning of the emergency signals identified in the SAHP, indicating the need to provide
more frequent training and practice drills. The site relied heavily on the use of small air
horns located strategically throughout the site to provide notification of emergency situations;
however, access to some of these horns was blocked by drums and equipment. In addition,
the main siren located at the site had not been tested periodically because of concerns about
alarming the surrounding community.

As was the case with Site B, employees at Site D were not familiar with all
emergency signals and procedures specified in the SAHP. In addition, the SAHP did not
specifically address procedures to be followed in the event of fire; it was the company’s
policy that employees not fight fires beyond the incipient stage.

At Site A, OSHA found that the emergency alerting procedures of the two on-site
contractors were inconsistent and were not clearly understood by site employees. The SAHP
for each contractor specified the use of air horns for emergency alerting, but personnel from
the subcontractor at the site indicated that they would actually rely on radio communication
in an emergency. Additionally, the two contractors had different alarm signals; for example,
one contractor planned to signal site evacuation using one long blast followed by one short
blast, while the other contractor’s plan mandated the use of continuous 30-second blast. Both
contractors also used different radio frequencies, which creates the potential for

miscommunication during an emergency.

21


samples of work surfaces in clean areas and employees’ skin; and a detailed review of each
site’s written safety and health plan (SAHP), emergency response plan, operation-specific
hazard analyses, and other relevant written safety and health programs and records.

The remainder of this report is presented in four sections. The overview of
incineration technology and associated occupational hazards is presented in Section II.
Section III provides a general description of Superfund TDF sites of the type inspected, as
well as brief descriptions of the five sites visited. Findings from each of the inspections are

presented in Section IV. Section V presents an overall summary of our findings.

II. GENERAL OVERVIEW ON INCINERATION TECHNOLOGY AND
ASSOCIATED OCCUPATIONAL HAZARDS
Incineration of hazardous waste involves the use of controlled flame combustion to
thermally destroy hazardous wastes; this method is one of the most frequently selected
technologies for treating hazardous contaminants at Superfund sites. Incineration has been
found to be suitable for the destruction of most organic materials (volatile and non-volatile),
pesticides, and cyanides found in sludges, soils, and liquids having a high organic content.

An on-site incineration system is comprised of several subsystems, including:

e Waste pretreatment (solids sizing, mixing, grinding);

° Waste feed (conveyors, augers, hoppers, chutes, pumps, ram feeders);

. Primary and secondary combustion units;

° Air pollution control equipment (secondary burners, scrubbers, precipitators,

quench systems, filters, spray towers); and

° Residue handling and disposal (solidification, stabilization of ash, use of ash as
backfill material, filtration, clarification, and neutralization of waste liquids).
Figure 1 is a diagram of these subsystems that shows the flow of waste feed, ash, and waste
gases through the system. Residues that are generated in the Operation of the incinerator
include fly ash, bottom ash, and scrubbing and quenching liquids.
Exposure to hazardous contaminants present on an incinerator site can occur both

within the area being remediated and near the waste pretreatment and incinerator feed area.


to apply professional judgment appropriately and to pay attention to meaningful details.
These problems were evidenced in several ways:
° Hazard analyses failed to consider all of the available data describing the
safety and health conditions at each site;

° Objective measures to evaluate the effectiveness of the site’s safety and health
program, particularly for PPE use, decontamination procedures, and heat
stress programs were lacking; and

. Exposure monitoring programs were targeted toward compliance rather than
toward the characterization of employee exposures.

In addition, these inspections identified several disincentives and obstacles that would
interfere with efforts to alter the safety and health culture at these sites. For example,
contractors are often not free to exercise independent judgment because contractual
provisions lock them into predetermined activities that do not permit them to respond to
changes in site conditions or to new information. Another obstacle that operates against
improved hazard recognition and evaluation skills is the training currently provided to safety
and health personnel. At present, most of the technicians at these sites are inadequately
trained to do more than foliow “cookbook” instructions. In summary, OSHA believes that
nothing short of rigorous program of on-going self-assessment, improved training in hazard
recognition and evaluation, enhanced management commitment, and sustained employee
involvement in the program will achieve the change in culture needed to move these sites
toward excellence in occupational safety and health.

32


procedures did not include the safety and health measures required to address the hazards
associated with each type of shutdown.

Many of the SOPs at Site B contained only broad and general statements such as “use
appropriate protective clothing". Thus, the SOPs did not convey specific information on
protective measures to be taken to address the types of hazards associated with each
operation or task. In addition, the inspection team felt that the site's SAHP and SOPs had
not been made readily available to employees; employee interviews indicated that some
employees were unaware of the existence and availability of these documents. To be
maximally useful, both documents should be available in the control zone where employees
can refer to them as needed.

The SOPs in Site B’s SAHP did not always address the specific PPE requirements of
each task or operation, as required by paragraph 1910.120(b)(4)(ii)(C). For example, the
site implemented a PPE program that separately identified the level of respiratory and dermal
protection required for each area of the site, although this requirement was not described in
the written SAHP. Despite the fact that this requirement reflected an improvement in the
site’s PPE program, it was not included in the most recent versions of the SAHP or in other
written safety and health procedures. The root cause of this deficiency derives from
contractual provisions requiring that any change to the SAHP be accompanied by the
issuance of a new edition of the SAHP; since issuance of a new edition is a major
undertaking, there is considerable reluctance to modify the SAHP as events on the site
unfold. As a consequence, changes in safety and health procedures are not being
incorporated into the SAHP. This practice has since changed at the site, and SAHP revisions
may now, be issued in the form of change notices; although these notices still require
approval by the oversight agency’s contracting officer, they are more quickly effected than
was the case formerly.

Deficiencies noted in the SAHP for Site C included the absence of addressing the
safety and health risk or hazard analysis for potentially hazardous operations, such as
incinerator operation, feeding waste to the incinerator, or cleaning of labels on excavated
barrels.

18


G. THE SAFETY AND HEALTH PROGRAMS MUST INCLUDE PROCEDURES
FOR MONITORING THE EFFECTIVENESS OF PPE, DECONTAMINATION
PROCEDURES, OR HOUSEKEEPING PROGRAMS.

Safety and health supervisors at hazardous waste sites need to evaluate the
effectiveness of their safety and health programs on an ongoing basis to ensure that SOPs are
warranted. Monitoring the effectiveness of the program is required under paragraph
(b)(4)(iv) of the HAZWOPER standard. In general, inspections uncovered the fact that
safety and health personnel have not established objective procedures for monitoring the
effectiveness of certain elements of their programs, in particular the use of PPE,
decontamination procedures, and housekeeping procedures. The effectiveness of these
program elements can be assessed in a variety of ways, such as by taking wipe samples on
decontaminated equipment and surfaces in clean areas, analyzing the final decontamination
Tinse water for the presence of contaminants, or visual inspection of PPE for signs of leakage
or failure. During these inspections, wipe samples of work surfaces in clean areas, as well
as skin wipes and hand washes, were collected to examine the effectiveness of PPE and
procedures for preventing contamination of clean areas. None of the sites inspected
employed methods such as these to evaluate the effectiveness of their programs.

At Site B, PCB surface contamination was found in the incinerator control room and
in a portable laboratory located in a Level D PPE area near the incinerator kiln. Also at this
site, inspection team members observed that overspray from the equipment decontamination
area presented a potential exposure hazard to personnel in an adjacent Level D PPE area;
thus, although the procedures used to decontaminate equipment at this site may have been
effective, the methods employed created another potential exposure hazard that was readily
apparent even on direct visual observation. Other sites avoided this problem by using
curtains to contain any overspray.

During the inspection at Site D, team members observed a number of employees
doffing potentially contaminated PPE in a manner inconsistent with the site’s SOPs; for
example, some employees were observed removing their inner gloves before removing their
potentially contaminated outer clothing. In addition, it was observed that cotton coveralls
wor under Tyvek protective clothing showed visible signs of contamination after employees

had finished using a high-pressure water wash to decontaminate large excavated items; this

24


local organizations that provide emergency response services (i.e., fire department, health
care facility, and local emergency response center), training employees in emergency
response alerting and evacuation procedures, and conducting drills to determine the
effectiveness of the emergency response plan. Requirements for developing and
implementing emergency response plans are contained in paragraph (1) of the HAZWOPER
standard.

All SAHPs of the incinerator sites that were inspected were deficient in the
emergency response training provided to employees. In addition the SAHPs of these same
sites had incomplete or outdated written emergency plans.

Inspection of Site B revealed a number of areas in which emergency planning needed
to be improved. In particular, the employees responsible for implementing the emergency
procedures associated with shutdown of the incinerator did not have direct access to or
training in the use of the PPE that might be necessary during shutdown, nor was emergency
SCBA or other respiratory protection available to employees in the incinerator control room.
In addition, the safety and health officer for the subcontractor charged with operating the
incinerator at Site B had difficulty locating the written emergency shutdown procedures when
OSHA requested them to do so.

At the time of the inspection, OSHA understood from employee and management
interviews that only one evacuation drill had been conducted at Site B, and that this drill had
not been very successful. In their response to OSHA’s findings, however, the prime
contractor reported that three drills had been concluded prior to the inspection and that two
of these had been deemed to be successful; the third was not considered adequate due to
missed communication among the parties regarding the execution of the drill. In no case
have the emergency drills at Site B involved other than on-site employees; according to
management personnel at Site B, this was due to difficulties encountered when attempting to
coordinate arrangements with community organizations through the oversight agency.

An OSHA inspector contacted several of the local emergency response organizations
in the area of Site B, and neither the county Emergency Response Center nor the local

hospital were able to locate copies of the site's written emergency response plan. A hospital

20


photoionization detector for total organic chemical vapors, a direct reading meter for toluene
diisocyanate (TDI), and a combustible gas meter.

Consequently, the PPE usage at Site C appeared to be more related to corporate
policy rather than on a site-specific evaluation of site hazards. The use of unnecessarily high
levels of PPE in itself may create a hazard due to restricted vision and mobility, and
increased potential for heat stress. Although Level B protection would always be necessary
during excavation and drum characterization operations, OSHA believes that certain areas of
the site in which Level B was being used, such as the feed hopper, can be sufficiently
characterized so as to permit the use of half-mask or no respirators most of the time. To this
end, direct reading instrumentation can be used on an on-going basis to determine the
appropriate level of respiratory protection after employee exposure has been adequately
characterized through the use of personal samples.

At Site E, personal air samples were routinely taken for benzene and vinyl chloride,
as mandated by the contract with the oversight agency; however, no program was in place at
this site to identify and quantify airborne levels of other hazardous substances present. This
deficiency was particularly important at this site because a number of employees reported
experiencing signs of respirator cartridge breakthrough or facepiece leakage, despite personal
sampling results indicating that exposures to benzene and vinyl chloride were low. In other
words, these employees were being exposed to concentrations of unknown contaminants
while working in the exclusion zone. In addition, management at Site E paid inadequate
attention to the monitoring program, as evidenced by the late submission of samples for
laboratory analysis. :

The SAHP for Site D contained provisions for real-time sampling for organic vapors
and dusts, personal air sampling for pentachlorophenol and polynuclear aromatic
hydrocarbons, and detector tube measurements for benzene, toluene, xylenes, and vinyl
chloride; however, only the real time organic vapor measurements were used to select the
appropriate level of PPE. Furthermore, the sampling program specified in the SAHP was
inconsistently implemented by safety and health personnel; direct-reading measurements were
not taken in accordance with the schedule outiined in the SAHP, and no personal air samples
for pentachlorophenol had been taken in a period of more than two months. Most of these

15


TABLE 1. DESCRIPTION OF SUPERFUND INCINERATOR SITES
INSPECTED BY OSHA (1992-1993)

=e ———
SUBCONTRAC- TONNAGE
GOVERNMENT TOR FOR TO BE
| NAME OF OVERSIGHT PRIME INCINERATOR INCINER-
SITE LOCATION AGENCY CONTRACTOR OPERATION ATED
Bridgeport Bridgeport, | EPA/U.S. EBASCO ENSCO 100,000
Rental and Oil | NJ Amny Corps of
Services Engineers
(BROS)
| Old Midland Ola, Arkansas Depi. Chemical Waste None less than
Products Arkansas of Pollution Management 25,000
Control and
Ecology
Rose Township | Oakland EPA Perland OHM less than
Demode Road County, MI | Region V/ARCS | Environmental Remediation 25,000
Technologies, Services Corp.
Inc.
Sikes Disposal Crosby, TX | Texas State TT-DAVY (Joint None 300,000
Pits Water Venture)
Commission
Big D Kingsville, Ohio- Fluor Daniel Containment 30,093
Campground Obio EPA/ARCS Inc. Treatment Inc. (As of 4/93)



maintenance was delegated to a single person (the lead engineer), who was familiar with
process maintenance and modifications that had been conducted up to that time, but
maintained no accurate historical record of these changes. Thus, the inspection team
believed that there was a need at this site to implement formal and systematic recordkeeping
procedures to ensure safe operation of the incinerator in the event of a personnel change. :

At four of the sites inspected, the inspection team noted a lack of any capability to
manually separate or disconnect the natural gas feed line from the incinerator in the event of
an emergency. Each site possessed the capability of stopping gas flow to the incinerator
through the use of electrically operated relays; however, it would not be possible to isolate
the natural gas supply from the TDF at the source. At Site A, the main shutoff valve of the
natural gas line was located just outside the main gate of the plant; this valve lacked either a
computer-controlled interlock or manually operated valve. The guard was instructed to
manually close the main gas valve in the event of an emergency, but no wrench or other
device was readily available to enable him to do so. At Sites B and C the main gas valve
lacked a handle that would enable an employee to isolate the TDF from the gas supply. The
main gas valve at Site D was located 300 feet from the site entrance and also lacked a
handle.

J. PROCEDURES TO MONITOR FOR AND REDUCE HEAT STRESS NEED TO
BE EFFECTIVE.

Perhaps the greatest health hazard facing hazardous waste site workers is that of heat
stress, which is exacerbated by the use of impermeable chemical protective clothing. Ideally,
a comprehensive heat stress program will include several elements, including environmental
and medical monitoring (i.e., measurements of pulse rate, oral temperature, and/or weight
loss), issuance of heat alerts, implementation of work-rest regimens when site conditions
warrant, provision for fluid intake and shaded rest areas in the exclusion zone, and regular
training of employees in recognizing the signs and symptoms of heat stress in themselves and
others. The inspection team found that heat stress programs varied considerably among the
sites inspected, and in no instance were all elements of a comprehensive heat stress program

present.

30


TABLE 3.

[Name of site

SUMMARY OF SAFETY AND HEALTH VIOLATIONS
IDENTIFIED ON HAZARDOUS WASTE INCINERATOR SITES

Description of Violation
Natural gas line was not protected from impact.

Certification of lockout/tagout inspections not provided.
Alloy chain slings were not properly identified by label.

Wire rope sling with broken wires was not removed
from service.

Bench grinder did not meet specifications for clearance
and guarding.

Barrier guards were not provided to protect employees
from rotating machine parts.

Belts and pulleys on compressor were unguarded.
Chain and sprocket wheels were not enclosed.
Open-sided floor platforms were guarded.

Employees were not protected from incidental welding
rays.

Flexible cords were used in lieu of permanent wiring.

Moving equipment had non-operating backup alarm.

Employee was within swing radius of backhoe.

High-voltage boxes were not properly secured or labeled.

1910.120(g)
1910.147(¢)(6)(ii)
1910.184(e)(1)

1910. 184(/)(5)(i)

1910.215(a),(b)

1910.219(c)(2)¢i)

1910.219(d),(e)
1910.219(f)
1910.23(c)(i)

1910.252(b)(2)

1910.305(g)(i)
1910.305(b),(g)
1926.602(a)

1910.65 1(e)

=

Site B
(Continued on next
Page)

Signs designating work zones have been moved by
equipment and not replaced on a timely basis.

Employees were not provided with separate clean and
dirty change areas. -

Building had unguarded plat form on three sides.

Workers were on elevated platform without benefit of
guardrail or safety beit.

Unguarded floor opening was located more than 6 feet
from ground.

27

1910. 120(d)(3)

1910. 120(n)(7)(2)

1910.23(c)

1910.23(c)

1910.23(a)(8)



Potential exposure to site contaminants or to their incomplete combustion products can occur
in the vicinity of the incinerator if it is not operating according to design parameters.

Deficient operating conditions may include:

. Short residence time;

. Low oxygen to fuel- or waste-ratio;

. Low-temperature operation;

. Soil/ash fallout creating steam pressure buildup in the combustion chamber;
. Incinerator slag buildup;

. Waste surges;

. Poor gas mixing in the combustion chamber due to low turbulence within the

chamber; and

e High halogen content of the waste feed.

In addition, poorly designed or malfunctioning air pollution control equipment will increase
particulate emissions, which often carry incomplete combustion products adsorbed onto the
particle’s surface.

Other occupational hazards commonly found on Superfund incinerator sites include
those associated with thermal stress, the use of heavy construction equipment, work in
confined spaces, excavation and trenching operations, storage and handling of flammable
materials such as motor fuels, walking and working surfaces, noise, hot or cold

environments, or marine operations.

Ul. DESCRIPTION OF SUPERFUND TDF SITES

All of the sites inspected utilized a transportable rotary kiln incinerator to destroy
hazardous materials at the site of contamination. In addition, contractors at each of the sites
also engaged in excavation activities designed to move contaminated soils and lagoon
sediments to the waste pretreatment area. All excavation, waste pretreatment, and waste feed

operations were conducted within a demarcated exclusion zone, entry into which required the

4


Figure 1. Schematic Diagram of a Typical Superfund Incineration Facility

Covered Storage Area

2

a
Classifier
Oy
eran) Feed Conveyor
Shredder |

Relief Vent
Sap

Rotary Kiln

3 NY
EP Lie Ash Cooler/
Conveyor
Temporary Ash

Storage Rin

Emergency

Relief

Ir

U

V

~

=

va

{

=

> oa

Recycle ~~~

Water

Secondary
Combustion Chamber

P|

Combustion
Air

Gas Cleaning
System

Z

Stack

Stack
Sampling

Fan

Water Treatment

Wastewater

Sump


difficulties were attributable to the absence of a designated site safety and health officer until
just prior to the inspection.

The exposure monitoring program at Site B was the most complex of the programs at
all sites inspected. This program called for frequent real-time measurements of organic
vapor and dust levels and personal air sampling for several indicator substances, including
PCBs, toluene, naphthalene, phenols, and trichloroethylene. Several personal air samples for
these materials were taken daily; however, not all were subject to analysis. According to the
contract between the oversight agency and the contractor, air samples were selected for
analysis only if real-time measurements indicated the potential for relatively high exposure or
the samples were selected for analysis by the oversight agency’s contracting officer. These
sample selection procedures were not described in the SAHP, nor were employees routinely
notified that air samples were not submitted for analysis, according to discussions with
Laborer’s representative. Instead, employees were interpreting the fact that they were not
being notified of the results of the sampling to mean that they were not being significantly
exposed, when in fact employees were not being notified because the samples had never been
analyzed.

OSHA performed a detailed analysis of the sampling results obtained by Site B
personnel for a 1-month period prior to the inspection. During this month, industrial hygiene
personnel coilected 79 air samples; of these, 30 were submitted for analysis. About half of
these were designated as area, rather than personal samples. The vast majority of samples
taken and analyzed represented exposures in two areas, the pug mill and an area in which the
lagoon was being dredged. Only 4 of the 30 samples analyzed were taken on employees
working in the feed preparation area or in the vicinity of the incinerator, and none were
taken in the ash handling area. Thus, despite the dedication of considerable time and
resources to sampling, OSHA concludes that employee exposures were not being adequately
characterized on an ongoing basis.

The situation at Site B reflects the fact that the site safety and health supervisor had
not been given adequate authority to design a sampling strategy that reflected changing work
or site conditions. For example, the company was concerned about potential lead exposures

to personnel operating at newly installed pug mill and ordered that personal samples be

16


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Other deficiencies in the emergency plan at Site A included the following:
. There was no emergency SCBA in the incinerator control room, despite the
potential for emergency conditions that may dictate the use of such equipment;

. The emergency response plan did not identify specifically where employees
were to assemble during an emergency evacuation. In addition, maps were not
readily available that showed the evacuation routes to pre-designated assembly
areas;

° The emergency response plan was not rehearsed regularly, according to
interviews with employees; and

° Emergency air horns and spares were not kept in the decontamination trailer,
as required by the SAHP.

The SAHP developed for Site E did not address all anticipated emergencies, including
procedures to be followed in the event of natural gas line rupture or fires. In addition,
alternate evacuation routes should have been established for employees working in the
exclusion zone; only one evacuation route was indicated in the SAHP. During the
inspection, the site had an evacuation drill that made it apparent that site personnel were
aware of evacuation routes; however, the emergency alarm siren could not be heard inside
the control zone trailer where inspection team members were reviewing records, and
personnel in this trailer had to be verbally instructed to evacuate. Thus, the emergency
alerting procedures did not conform to the requirements of 1910.120(1)(3)(vi) or 1910.165
regarding the use of emergency alarms.

The emergency response plan for Site C did not accurately describe the training
requirements for members of the on-site emergency response team. Additionally, the
deficiencies included team member names not being identified, as well as the level of
involvement the team is expected to have in an emergency response. Further, the SAHP for
this site failed to address the emergency response plan for chemicals brought onto the site
such as fuel or wastewater treatment plant chemicals, although the emergency response plan
did address spills of the identified landfill contaminants.

22


| SUMMARY REPORT
ON OSHA
INSPECTIONS
CONDUCTED AT
SUPERFUND

INCINERATOR SITES

Occupational Safety and Health Administration
Directorate of Compliance Programs

200 Constitution Avenue, N.W.

Washington, D.C. 20210

September 30, 1993


TABLE 2. SUMMARY OF FUNCTIONAL AREAS IN WHICH SAFETY
AND HEALTH PROGRAM DEFICIENCIES WERE FOUND AT
SUPERFUND INCINERATOR SITES

Safety and health supervisors at the site must be given the authority to

exercise their judgement in matters of employee safety and health.
Management decisions related to safety and health must reflect the
judgement of such individuals.

B. The site specific safety and health plan (SAHP) must include procedures
for the implementation and enforcement of safety and health rules for all
persons on site, including employers, employees, outside contractors, and
visitors.

Cc. The safety and health program must be effective in ensuring that ongoing
task-specific hazard analyses were conducted so that the selection of
appropriate personal protective equipment (PPE) could be made and
modified as conditions warrant.

D. Task-specific hazard analyses must lead to the development of written
standard operating procedures (SOPs) that specified the controls necessary
to safely perform each task.

E. Emergency response elements of the safety and health program must be
fully implemented as described in the program.

F. All site control elements of the safety and health program must be fully
implemented as described in the program.

G. The safety and health program must include procedures for monitoring the
effectiveness of PPE, decontamination procedures, or housekeeping
programs.

H. Self-audit site inspection and abatement tracking programs must be

formalized and effectively implemented.

I. Process safety management procedures for the incinerator facility need to
be improved.
J. Procedures to monitor for and reduce heat stress need to be effective.



A. SAFETY AND HEALTH SUPERVISORS AT THE SITE MUST BE GIVEN
THE AUTHORITY TO EXERCISE THEIR JUDGEMENT IN MATTERS OF
EMPLOYEE SAFETY AND HEALTH. MANAGEMENT DECISIONS
RELATED TO SAFETY AND HEALTH MUST REFLECT THE JUDGEMENT
OF SUCH INDIVIDUALS.

Perhaps the most essential component of the safety and health program at a hazardous
waste site is the development, management, and implementation of the program by a
competent site safety and health supervisor who has the authority to make decisions that
affect employee safety and health. Because worksite conditions that affect employee safety
and health can change rapidly, the safety and health supervisor needs to have sufficient
authority to make decisions in a timely manner to respond to dynamic conditions. In
addition, for an effective program, the safety and health supervisor must have the flexibility
to conduct any investigation deemed necessary to fully characterize the hazardous exposures
of employees and to ensure that the various elements of the safety and health program are
effective in mitigating these hazards. The need to grant appropriate authority to the site
safety and health supervisor is addressed in paragraph (b)(2)(i)(B) of 29 CFR 1910.120
(HAZWOPER).

At Site B, interviews with safety and health management personnel indicated that
some decisions regarding employee safety and health were made without input from safety
and health professionals. In addition, industrial hygiene personnel from the oversight agency
were not readily available to evaluate the recommendations made by the contractor's safety
and health personnel. Furthermore, the contractor was bound by contract provisions that
dictated specific procedures for employee exposure monitoring and the selection of PPE,
regardless of conditions occurring on site. For example, although the contractor was free to
upgrade the level of PPE when site conditions so warranted, downgrading the level of PPE
fequired the submission of a written justification to the Contracting Officer and the receipt of
written approval before a downgrade could be implemented. The time required to obtain
permission to downgrade PPE may place employees at unnecessary risk of heat stress and
other hazards associated with the use of PPE, such as restricted vision, impaired

communication, and increased fatigue. Contractor safety and health personnel concurred


TABLE 3. SUMMARY OF SAFETY AND HEALTH VIOLATIONS
IDENTIFIED ON HAZARDOUS WASTE INCINERATOR SITES

(Continued)
Site C A live electrical box on the east end of the lunch room 1910. 303(g)(2)(ii)
(Continued) trailer was not properly guarded from vehicle traffic.

The battery charging area located in the compressor shed | 1910.151(c)
was not provided with an acceptable emergency eyewash.

The handle for the main natural gas shut-off was 1910. 120(1)¢i)
removed from the valve stem.

| Site D Electrical extension cord lacked ground plug. 1926.300(a)
Drums used to transfer flammable liquids were not 1910. 106

grounded or bonded.

No fire watch was present during a welding operation. 1910.252(4)(2){ii)
HAZCOM program was deficient in that MSDS's were 1910.1200
missing and no hazard warning labels were used on

caustic tanks.

1910. 146(c)(1&2), (f)
Issuance, enforcement, and review of hot work and
confined space entry permits were not effectively
performed during welding operation.

Site E Standard operating procedures for decontamination and 1910.120(c¢)(5), (k)
PPE were not being adhered to.
Confined space entry permit did not address possible 1910. 146(c)(5)(C)
hazards.

1910. 157(e)

Record of fire extinguisher inspection was not available.

29


TABLE 3.

SUMMARY OF SAFETY AND HEALTH VIOLATIONS
IDENTIFIED ON HAZARDOUS WASTE INCINERATOR SITES

(Continued on next
| Page)

accuracy;

Labels on several containers including the caustic and
acid tanks in the water treatment plant had no hazard
warnings; other containers, such as fuel cans, had no
labels at all.

There were no methods to deal with the hazards of non-
routine tasks and no method for informing employees of
contents of unlabeled pipes.

There were no methods of informing employees of the
hazards associated with foreseeable emergencies.

The water treatment building had improperly guarded
platforms on two 13-foot starage tanks.

The elevated platform on a hopper near the baghouse had
a broken guardrail on the west side. The guardrail on
the truck into which the baghouse fines are loaded had
broken guardrails on ail sides.

An unguarded floor opening was located about 4 feet
from the ground on the platform neat the baghouse.

The step-up inspection platform on the drum crusher was
not adequately guarded.

(Continued)
Site B There was no means of safe egress from a second level 1910.36(6)(1)
| (Continued) platform.

Caution signs were not provided near high-voltage 1910.304(4)(2)
electrical sources.
Acid and caustic charging areas were not provided with 1910. 151{c)
emergency eyewash or shower.
Feed conveyor was unguarded, exposing employees to 1910.212(a)
nip-point hazard.
Ground plug was missing from electrical power tools. 1926.300(a)
Front-end loader had cracked front and side windshields. | 1926.601(b)(5)
Flexible electrical wire was used in lieu of fixed wiring. 19 10.305(g)(1)(iii)

Site C MSDSs were not routinely checked for completeness and | 1910.1200(g)(8)

1910. 1200(f)(5)Ci)

1910. 1200(e)(1)(ii)

1910. 1200(¢)(2)«ii)

1910.23)

1910.23(c)

1910.23(a)(8)

1910.212(a)(3),(4)

28



use of Level C or Level B personal protective equipment (PPE). With one exception, the
incinerator unit itself and associated pollution control equipment were located outside the
exclusion zone. Figure 2 shows the general layout common to each site visited.

In instances where EPA is unable to identify the responsible party, or where EPA
cannot reach an agreement with the responsible party, EPA conducts any necessary remedial
design and remedial action (RD/RA). When EPA takes the lead to conduct RD/RA, the
Agency can choose between two contracting mechanisms; EPA may provide direct oversight
of a RD/RA contractor under the Alternative Remedial Contracting Strategy, or EPA may
request that RD/RA be administered and implemented by the U.S. Army Corps of Engineers
(USACE) or Bureau of Reclamation (BUREC) under Interagency Agreements (IAG) with
EPA. In some instances, a State agency will assume responsibility for RD/RA, in which
case it will use any of its own contracting mechanisms. In any event, the Agency that issues
the competitively bid contract provides oversight of the clean-up activities being conducted
under the contract. The prime contractor is responsible for implementing cleanup procedures
in accordance with the terms of the contract and is responsible for developing and
implementing a safety and health program for the site. The prime contractor may procure
the services of a number of subcontractors that specialize in various aspects of the cleanup
activity; frequently, a subcontractor is hired to operate the TDF.

Table 1 identifies the locations of the sites investigated, the prime contractor, the
subcontractor responsible for incinerator operation, and the state or Federal government
agency responsible for remediation oversight. All sites were inspected between May of 1992
and April of 1993. For the remainder of this report, the identities of the sites are masked

and are referred to by a randomly assigned letter designation (Sites A through E).

IV. INSPECTION RESULTS

OSHA found several deficiencies in the design, management, and implementation of
safety and health plans at each site. These deficiencies fell into 10 functional areas, listed in
Table 2. With few exceptions, deficiencies in these 10 functional areas were common to all

§ sites; discussion of the findings specific to each functional area follows.


The SAHP developed for Site D did not include written site-specific safety and health
SOPs for the following operations: line breaking, hot work, confined space work, repairing
the primary valve on the caustic tank, and evaluating the thermal status of employees
working in the exclusion zone. The SAHP did incorporate, by reference, a series of
corporate SOPs covering certain of these topics, such as hot work and confined space entry
work, although these SOPs had not been revised as necessary to address site-specific factors,
despite a requirement in the corporate SOPs to do so. For example, the SOP for confined
space entry work did not identify the specific locations of confined spaces on site.

The SAHP used at this site also did not reflect the site’s practice of permitting
employees to wear Level C protection when performing tasks of short duration (i.e., less
than 15 minutes) in the closed waste feed preparation area (an area that normally requires

Level B PPE). Th

discussed in the SAHP, along with the supporting reasons that justify relaxing the PPE
requirement for short-duration tasks conducted in this area.

At Site A, the written SOPs for confined space entry lack detail. For example, the
SOP did not identify the specific locations of the confined spaces at the site. In addition, the
SOP did not explicitly require that the air quality be tested in confined spaces when air-
supplied respirators were being used, nor did it require the use of forced ventilation during
the conduct of hot work in confined spaces. In both cases, however, the safety and health
supervisor at the site expected both of these practices to be carried out.

Safety and health SOPs in the SAHP at Site A did not address the selection of PPE
for employees working in the excavation area. In addition, the site's SOPs did not specify
the procedures to be used by employees to decontaminate or dispose of PPE. Furthermore,
the SAHP contained no SOPs for the conduct of regular inspections/audits of the safety and
health program at the site or for delegating the authority to do so.

E. EMERGENCY RESPONSE ELEMENTS OF THE SAFETY AND HEALTH
PROGRAM MUST BE FULLY IMPLEMENTED AS DESCRIBED IN THE
PROGRAM.

The emergency response plan for a hazardous waste site is one of the key components

of a site’s SAHP. Major elements of the emergency response plan include coordination with

19


suggests that a more impervious type of protective clothing (such as double-seamed Tyvek)
should be used during this operation. Thus, the ineffectiveness of the protective clothing
wor during this operation was readily apparent, again by direct visual observation.

At Site C, workers in the materials preparation building and feed hopper areas were
required to wear Saranex coated Tyvek and level B respiratory protection. However, the
rationale for this level of protection was not stated in the SAHP. Because these workers
handled contaminated soil, it appeared unlikely that there was a potential for serious skin
exposure to liquid chemicals. Uncoated Tyvek clothing would have most likely provided
adequate skin protection for these workers. The use of the Saranex coated Tyvek greatly

increased the potential for heat stress among these workers.

ie SELF-AUDIT SITE INSPECTION AND ABATEMENT TRACKING

PROGRAMS MUST BE FORMALIZED AND EFFECTIVELY

IMPLEMENTED.

The overall effectiveness of the safety and health program must be evaluated, in part,
by conducting regular inspections and audits to ensure that the program is being properly
implemented. In addition, there should be a mechanism to follow-up on corrective actions
recommended by the site safety and health officer during safety inspections. All hazard
abatement action identified by the site safety and health officer should be tracked to ensure
that the corrective actions have been implemented and the hazard(s) have been eliminated.
The program shouid designate individuals to periodically inspect work areas and ensure that
hazard abatement has been accomplished. Paragraph (b)(4)(iv) of the HAZWOPER standard
contains the requirement that the site safety and health supervisor, or a knowledgeable
designee, perform periodic inspections to evaluate the effectiveness of the program.

Some of the program deficiencies discussed above’ point to the need for more rigorous
and formalized inspection and abatement tracking procedures on the sites inspected.
Examples demonstrating this include the instance at Site D where improper PPE doffing
procedures were being used, the inaccessibility of some of the emergency air horns at Site B,
and the lack of a system at Site C for ensuring that safety and health problems are corrected

in a timely manner. Documented instances in which safety and health standards were not

n
On


SUMMARY REPORT ON OSHA INSPECTIONS
CONDUCTED AT SUPERFUND INCINERATOR SITES

L INTRODUCTION

The Occupational Safety and Health Administration (OSHA) and the Environmental
Protection Agency’s (EPA’s) Office of Emergency and Remedial Response (OERR) recently
entered into an interagency agreement to participate jointly in activities that will ensure
vigorous occupational safety and health oversight of Superfund Thermal Destruction Facilities
(TDFs). These efforts are being coordinated by a joint EPA-Labor Superfund Safety and
Health Task Force. As part of this initiative, OSHA is conducting a number of in-depth
safety and health evaluations of Superfund incinerator facilities; this report summarizes the
findings of five such inspections conducted between 1992 and 1993.

Although a major objective of these inspections was to assess compliance with
OSHA's Hazardous Waste Operations and Emergency Response Standard (29 CFR
1910, 120), the investigations were also designed to evaluate the overall adequacy of each
facility’s safety and health program, as implemented by the contractors operating at each site,
and to identify any factors that were contributing to reduced program effectiveness.
Emphasis was placed on evaluating each employer's safety and health standard operating
procedures (SOP’s) and the adequacy of task- and operation-specific hazard analyses and
emergency response programs. However, because of the focus on safety and health program
design and implementation, the investigations went beyond the assessment of compliance with
these specific OSHA requirements and included such areas as the effectiveness of strategies
to mitigate heat stress, confined space programs and the use of process safety management
approaches in the operation of the TDF.

Inspections were conducted over a three- or four-day period by teams of from four to
six OSHA personnel. Activities undertaken by the inspection team included the conduct of
interviews with employees, safety and health personnel, union representatives, and site
management personne! to evaluate the effectiveness of safety and health program
implementation; a number of walkthrough inspections to observe and document site

conditions, operations, and safety and health program deficiencies; the collection of wipe


operation-specific hazard analyses and to incorporate the results of such analyses into the
site-specific SAHP is contained in paragraph (b)(4)(ii)(A) of the HAZWOPER standard.
Paragraph (h) of the standard also requires that the exposures of employees be monitored to
ensure adequate characterization of their exposures; the results of all exposure monitoring
should feed back into the hazard analysis process to ensure continuing improvement in site
planning and procedures.

Program deficiencies were identified in two related areas: the development of
operation-specific hazard analyses and conduct of monitoring programs designed to
characterize employee exposures to hazardous materials. These deficiencies are discussed in
more detail below.

Written Qperation-Specific Hazard Analyses: Three of the five sites inspected lacked

written hazard analyses for some tasks and operations that were being conducted on site. In
addition, some of the written analyses examined failed to include an appropriate level of
detail in describing the nature of the hazards or the protective measures to be taken in
performing the task or operation.

At Site B, for example, written hazard analyses were not available for two tasks:
cleaning the filter presses and charging chemicals into the aqueous waste treatment system.
Operation of the filter press cleaning operation, which involves spraying filter presses with a
stream of water, revealed that the employee engaged in the operation was exposed to splashes
of contaminated liquids on the back of his head and neck because the protective clothing he
was using was inadequate. OSHA believes that a hazard analysis of this operation would
have indicated the need for protective clothing of a different design. Also at this site, it was
noted that substantial overspray from an equipment decontamination operation was carried
into areas where Level D PPE was permitted, thus potentially exposing unprotected
personnel to contaminated aerosols. The written hazard analysis for this operation did not
identify this potential hazard, which was readily apparent to OSHA inspectors on direct
visual observation.

Site E lacked written hazard analyses for tasks and operations frequently performed
by employees; examples of these operations include working on or near moving equipment

such as conveyors, operating heavy equipment, relighting the pilot of the secondary

12


vapor concentrations exceed | ppm. This approach which is commonly used on hazardous
waste sites, was recommended by EPA’s Standard Operating Guides (1984). Relying on
real-time sampling results to guide PPE selection is certainly appropriate during the initial
site entry and characterization phases, where the nature and the extent of the hazards on the
site are largely unknown; however, by the time the sites are engaged in active remediation, a
considerable amount of data has been compiled that enables fuller and more accurate
characterization of employee exposures and therefore provides a sounder basis for the
selection of PPE. Four of the five sites inspected collected personal air samples for various
contaminants known to be present on site; the contaminants selected for monitoring
represented the principal contaminants identified in the preliminary Remedial
Investigation/Feasibility Studies (RI/FS) conducted before work began at the sites. However,
no site actually used these monitoring data to make decisions about the PPE to be worn by
employees or to determine whether employees were being exposed to other air contaminants.
As a result, OSHA concluded that employee exposures were not being characterized
sufficiently to permit the selection of the most appropriate level of protection.

Specifically, at Site A, no personal sampling for air contaminants had been conducted,
despite potential employee exposures to PCBs, arsenic, lead, organic solvents, diesel exhaust,
and carbon monoxide. The level of PPE assigned to employees was based primarily on the
location of the operation rather than on the concentration of the contaminants to which
employees were exposed. The safety and health supervisor at this site used a miniram real-
time dust analyzer to determine exposures to lead and PCBs but did not appear to factor the
results of this monitoring into the PPE selection process. In addition, the monitoring
equipment being used was not always properly calibrated to manufacturer’s specifications.

Similarly, the monitoring program implemented at Site C did not adequately
characterize the health risks associated with each site task or operation. No personal
monitoring had been performed to determine employee time-weighted-average exposures for
any work tasks conducted on this site. Specifically, the site did not have a program in place
to identify, evaluate, or monitor employee exposure to specific air contaminants that were
identified in the original site investigation such as lead, vinyl chloride, or specific organic

solvents. The only environmental monitoring conducted had been area sampling using a

14


L

TABLE OF CONTENTS

INTRODUCTION ..... 2... tee

GENERAL OVERVIEW ON INCINERATION TECHNOLOGY

AND ASSOCIATED OCCUPATIONAL HAZARDS ................-
DESCRIPTION OF SUPERFUND TDF SITES ...................-

INSPECTION RESULTS .. 1.2... 2... ee eee

A. Safety and health supervisors at the site must be given the authority to
exercise their judgement in matters of employee safety and health.
Management decisions related to safety and health must reflect the judgement

of such individuals... 2... 2... eee

B. The site specific safety and health plan (SAHP) must include procedures for
the implementation and enforcement of safety and health rules for all persons
on site, including employers, employees, outside contractors, and visitors. .....

Cc. The safety and health program must be effective in ensuring the ongoing task-
specific hazard analyses were conducted so that the selection of appropriate
personal protective equipment (PPE) could be made and modified as

conditions warrant. 2.6... 2 eee
D. Task-specific hazard analyses must lead to the development of written standard
operating procedures (SOPs) that specified the controls necessary to safely
perform each task. 2.2.2.2... ee et
E. Emergency response elements of the safety and health program must be fully
implemented as described in the program. ............-.-2-20200005
F. All site control elements of the safety and health program must be fully
implemented as described in the program. ............0-- 22 ee eee eeue
G. The safety and health program must include procedures for monitoring the
effectiveness of PPE, decontamination procedures, or housekeeping programs.
H. Self-audit site inspection and abatement tracking programs must be formalized
and effectively implemented. ............ 00.002 eee eee
I Process safety management procedures for the incinerator facility need to be
improved. 2... 1. ees
JI Procedures to monitor for and reduce heat stress need to be effective.........
SUMMARY .. 1.2.60. eee tee

8

19

23

24


F. ALL SITE CONTROL ELEMENTS OF THE SAFETY AND HEALTH
PROGRAM MUST BE FULLY IMPLEMENTED AS DESCRIBED IN THE
PROGRAM.

Inspection team members found that certain elements of each facility’s site control
program were not being rigorously implemented. In particular, this included the use of the
buddy system, which is required by paragraph (d)(3) of HAZWOPER. The purpose of these
requirements is to ensure that only properly trained and authorized individuals enter those
areas of the site where potential hazards are present, and that, in the event of an emergency,
rapid assistance can be rendered to employees working in the exclusion zone.

At four of the sites inspected, use of the buddy system for employees entering the
exclusion zone was required in the SAHP, but the systems were generally informal and, as a
result, were inconsistently implemented. For example, it was not evident from Site C’s
SAHP that the buddy system would be in place during all activities conducted in areas
requiring Level B PPE (these activities included trailer placement, surface soil sampling,
groundwater well installation, groundwater sampling, and surface water sampling).

In general, employees at these sites were instructed to watch for each other in the
exclusion zone, but no formal assignment of partners was made prior to entry into the
exclusion zone. Evidence of this deficiency could be seen in the exclusion zone entry/exit
logs, which contained numerous entries by single individuals who were not paired with a
buddy. Furthermore, employees wearing respiratory protection equipment were observed to
be working without the benefit of direct observation by a designated buddy.

Therefore, the health personnel on these sites need to reevaluate their criteria for
determining where the buddy system is necessary, and to formalize the use of the buddy
system in those areas so that employees have a clear understanding of the importance of
adhering to the buddy requirement.

Demarcation of different work zones on hazardous waste sites is another crucial
feature of the site control program. In general, the various work zones were clearly
identified and demarcated at Sites A, C, D, and E. Entry and egress of personnel and
equipment through the exclusion zone were accomplished on these sites via well-established
decontamination facilities. However, at Site B, demarcation of the various work areas was

less clear, due in large part to the movement of barricades by equipment.

23


SUMMARY REPORT ON OSHA
INSPECTIONS CONDUCTED AT
SUPERFUND INCINERATOR SITES

Occupational Safety and Health Administration
Directorate of Compliance Programs
200 Constitution Avenue, NW
Washington, DC 20210

September 30, 1993


Safety and health personnel at Site B conducted periodic environmental monitoring to
Measure wet-bulb-globe-temperature (WBGT) conditions; these were used to trigger work-
Test regiments in accordance with the site’s SAHP. In addition, pre- and post- shift body
weights were taken on employees assigned to work in the exclusion zone. No other medical
monitoring was routinely conducted, but the contractor was experimenting with the use of
remote pulse sensors at the time of the inspection. During the inspection, two workers
entered the decontamination trailer with signs of heat exhaustion; two health and safety
technicians were present at the time, but did not know what actions to take. Employees
interviewed during the inspection stated that they had complained of lack of shaded rest areas
in the exclusion zone, but none had been provided.

Safety and health personnel at Site D issued verbal warnings of potential heat stress
hazards when temperatures exceeded 70°F. Workers were trained to recognize signs and
symptoms on site, but there was no provision for medical or environmental monitoring of
heat stress condition. Employees stated during interviews that they believed their training
adequately protected them from heat stress.

Site E was the only one inspected that implemented routine medical monitoring for
heat stress. Pulse rates were determined after workers exited the exclusion zone, and these
fates were required to fall to predetermined levels before the workers were allowed to re-
enter. No heat stress program was described in the SAHP for Site A; the written program
included only an appendix containing information publications. Similarly, the SAHP for the
Site C did not provide for taking environmental measurements or otherwise characterizing the
potential for heat stress to determine when engineering controls, work practices, or other

control measures are to be instituted.

Vv. SUMMARY

The primary findings of this project to date point the need for a change in culture at
these sites. Despite the fact that these safety and health programs were generally
comprehensive in scope and were oriented toward compliance with HAZWOPER and other

applicable standards, our inspections revealed consistent deficiencies attributable to the failure

31


being complied with point to the need to strengthen self-inspection and abatement tracking at

these sites. These findings are summarized in Table 3.

I. PROCESS SAFETY MANAGEMENT PROCEDURES FOR THE
INCINERATOR FACILITY NEED TO BE IMPROVED.

Hazardous waste incineration is a complex process in which a number of upset
conditions can result in potential hazards to employees; these hazards are typically presented
when the upset condition causes a sudden increase in system pressure or a bypass of the
pollution control equipment. Transportable incinerators are equipped with several safety
interlock systems that trigger automatic equipment shutdown or interruption of waste feed
when operating parameters fall outside the normal range. However, safe operation of
incinerator equipment still relies heavily on the attention of the operator and the
implementation of proper maintenance and repair procedures that optimize the safety and
reliability of the incinerator and its associated equipment. Although the incinerator sites
inspected in this study do not generally fall within the scope of OSHA’s process safety
management standard (29 CFR 1910.119), the inspection team applied many of the principles
that formed the basis of that standard to evaluate each site’s management procedures for
ensuring the safe operation of the incinerator. Some of these principles include maintaining
accurate Piping and Instrumentation Diagrams (P&IDs), developing and implementing written
programs for regularly scheduled equipment maintenance, ensuring that safety equipment
such as pressure relief devices are properly installed and operating, and keeping accurate
records of repairs and modifications made to the system.

At three of the sites, production operations had been initiated only a few weeks prior
to the inspection; few repairs or process modifications had been undertaken. Each of these
sites had procedures in place to maintain accurate records of such activities. The inspection
team believed that, should there be any change in the supervisory personnel responsible for
incinerator operation, adequate information regarding system design and operation would be
available for their use. At Site B, however, only daily visual inspection and maintenance
logs were kept. No routine procedures were in place to ensure that records of process

modifications were maintained or that P&IDs were updated. Responsibility for incinerator

26


i
i
|

with this conclusion, and cited an example where employees engaged in installing a new pug
mill were required to wear Level C PPE, despite a low potential for exposure to
contaminants on the site.

Therefore, OSHA concludes that the on-site presence of a competent safety and health
professional from the oversight agency, coupled with the use of more flexible contractual
safety and health provisions, would lead to better and more responsive safety and health
decision making in the face of changing site conditions.

At the remaining four sites inspected, contractor safety and health personnel appeared
to have more latitude to make and implement changes to their respective SAHPs to respond
to changes in site conditions. However, a deficiency in this area was noted at Site D, where
no site safety and health supervisor had been designated for a period of about five months; as
a result, some aspects of the SAHP, in particular the monitoring program, had not been fully

implemented at this site.

B. THE SITE-SPECIFIC SAHP MUST INCLUDE PROCEDURES FOR THE
IMPLEMENTATION AND ENFORCEMENT OF SAFETY AND HEALTH
RULES FOR ALL PERSONS ON-SITE, INCLUDING EMPLOYERS,
EMPLOYEES, OUTSIDE CONTRACTORS, AND VISITORS.

This functional area is closely related to the first deficiency described above, because
it also involves the authority of the site’s safety and health supervisor. To maintain adequate
site control, the site safety and health supervisor must have the authority to enforce the
SAHP’s rules on any individual present at the site, whether employee or outside contractor.
At Site B, the safety and health supervisor feit that, because of the contractor/client
relationship between the contractor and the oversight agency, he had little authority over the
safety and health activities of oversight agency personnel. However, when shown the
deficiencies identified by OSHA, personnel form the oversight agency emphasized that they
expected the site safety and health supervisor to exercise authority over any person present
on site, including their own personnel, if necessary.

The authority of the safety and health supervisor was most at issue at Site A. At this
site, two of the contractors issued their own SAHPs, each with distinct safety and health

requirements. Interviews with safety and health personnel at these sites indicated that no

10


combustion chamber, and conducting air monitoring and surveying in the excavation area.
For example, although safety and health management personnel believed that industrial
hygiene technicians were among the most highly exposed individuals on the site because they
Spent so much time in the exclusion zone, no formal analysis of the hazards associated with
air monitoring in the exclusion zone had been conducted.

At Site A, written hazard analyses were not available for several operations,

including:

° Cleaning filter presses;

° Changing mix tanks with caustic and acid from 55-gallon drums;

. Changing and cleaning sand filters, which may be contaminated with lead and
other heavy metals;

° Procedures for incinerator operation/shutdown in emergency situations,
especially with respect to the use of emergency respiratory protection; and

° Decontamination of heavy equipment, especially with respect to containing

overspray to prevent contamination of the personne! decontamination trailer.
In contrast, hazard analyses were available for all tasks and operations at Site D. The site’s
approach to hazard analysis was unique in that it asked the employees who performed each
operation to conduct the analysis. The employee performing each task or operation
completed a standard form, and the information was reviewed and supplemented where
necessary by the safety and health supervisor. This approach minimized the potential for
operations to be overlooked during the hazard analysis and ensured that all important hazards
would be identified.

Employee Exposure Monitoring: As discussed above, the results obtained from a
site’s exposure monitoring program should be used to continually improve and refine the
ongoing process of operation-specific hazard analysis, which is designed, in turn, to identify
the appropriate kind and level of employee protection needed. Each of the sites inspected
relied primarily on the results of real-time monitoring for organic vapor and dusts to
characterize employee exposures. Selection of the appropriate level of PPE on these sites is
generally based on action level concentrations determined from real-time air sampling; for

example, Level C PPE is indicated when dust concentrations exceed 1 mg/m? or organic

13