  EPA/OSHA study on health and safety at hazwaste incinerators


On May 23, 1991, EPA and OSHA released their joint report, 
"Evaluation of Compliance with On-site Health and Safety Require-
ments at Hazardous Waste Incinerators."  This special investigation 
was initiated in July 1990 after reports of serious worker exposure 
to toxic chemicals at the now-closed Caldwell Systems incinerator in 
Lenoir, NC.

The study reveals both the dangers of incineration for workers 
and the inability of incinerator operators to comply with regula-
tions.  Especially notable is the extraordinary frequency of 
emergency waste feed cut-offs and by-pass openings, which indi-
cates that upsets happen on a daily basis, at the very least.  
The facilities with the worst records had averages of as many 60 
cut-offs and 29 by-passes per day.

The report's executive summary reads as follows:

"Background.

"EPA and OSHA jointly established the Task Force to evaluate 
compliance with on-site health and safety requirements at select-
ed hazardous waste incinerators.  Unannounced inspections were 
conducted at 29 of the approximately 140 operating hazardous 
waste incinerators.  These inspections focused on determining 
compliance with worker health and safety training requirements, 
and preparedness prevention and emergency response requirements.  
Potential worker exposure routes from equipment and areas relat-
ing directly to the incinerator operations were also evaluated.

"Findings.

"1.  OSHA identified a total of 320 violations in five major 
areas of its regulations.  These violations include 111 in the 
health and safety training area; 22 in facility contingency 
plans; 19 in workplace surveillance and monitoring; 20 in poten-
tial chemical exposure to workers during incinerator and waste 
handling operations; and 148 in general health and safety (e.g., 
lighting, fall protection, materials storage, electrical, etc.) 
violations.

"2.  EPA identified a total of 75 violations of its standards at 
the 29 facilities inspected.  These violations include 14 for 
failure to provide adequate information and/or training to em-
ployees; 16 for noncompliance with the contingency plans and 
emergency response requirements; 29 for non-compliance with 
general inspections and preparedness and prevention requirements; 
and 16 for failure to comply with operational procedures require-
ments.  Of these 16 violations, only 5 related specifically to 
incinerator operations.

"EPA also noted a significant number of waste feed cut-offs and 
emergency by-pass openings.  The waste feed cut-off system is 
intended to stop waste entering the incinerator combustion unit 
when certain operating conditions are exceeded.  Emergency by-
passes are intended to prevent ground-level fugitive emissions 
and possible explosions from excessive pressure in the combustion 
unit.  While both devices are designed for safety purposes, the 
frequent use of these devices at some facilities may indicate a 
need to improve operating practices."


"Conclusions.

OSHA did not observe evidence of worker overexposure to chemicals 
that could cause serious harm.  However, EPA and OSHA are 
concerned with the widespread deficiencies in the area of worker 
health and safety training, which could potentially lead to 
operational and exposure problems.  EPA is also concerned about 
the apparent overuse of waste feed cut-offs and emergency by-
passes at some facilities."

                               ***
                      Facilities inspected

Pfizer                                 CT
Polaroid Corp.                         MA
Rollins Environmental                  NJ
BASF Corporation                       NJ
Occidental Chemical                    NY
General Electric Silicones             NY
Schenectady Chemicals                  NY
Allied Signal                          AL
S&S Flying Services                    FL
Olin Chemical                          KY
Atochem North America                  KY
LWD                                    KY
ThermalKEM                             SC
Thermal Oxidation Corp                 SC
CWM - Chicago                          IL
CWM - Sauget                           IL
Paxton Ave Lagoons Site                IL
Upjohn Company                         MI
Ross Incineration Services             OH
ENSCO                                  AR
Dupont Co.                             LA
Rhone-Poulenc                          LA
Rollins Env. Services                  LA
CWM                                    TX
Rhone-Poulenc                          TX
Rollins Env. Services                  TX
Blackfoot Pose and Pole Site           MT
Livermore National Labs                CA
Idaho Natl Engineering Lab             ID


                               ***

[Excerpts from the report]

"OSHA noted a total of 320 violations of its standards at the 27 
inspected sites....  Of the violations cited, 214 were serious 
and 106 other-than-serious.  The violation rate was 5.1 total 
violations and 3.4 serious violations per inspection.  To put 
this in context, OSHA's violation rate for all industries is 3.8 
total violations and 2.5 serious violations per inspection.

"The most frequently cited violations (which account for 
approximately one-third of the violations OSHA observed at the 27 
inspected hazardous waste incinerator facilities) were related to 
deficiencies in communicating to workers the hazards of the 
chemical substances present at their worksites and providing 
adequate health and safety information to minimize those 
hazards."

"[EPA] also noted a significant number of automatic waste feed 
cut-offs at about half of the hazardous waste incinerators 

inspected.  The automatic waste feed cut-off system is required 
by the regulation and is intended to stop hazardous waste 
entering the incinerator combustion unit when certain operating 
conditions as specified in the permit are exceeded.  It is not 
intended to be used as a routine measure to control operation of 
a hazardous waste incinerator.  EPA does not currently have data 
indicating that these cut-offs affect hazardous waste incinerator 
emissions; however, the Agency prefers steady uninterrupted 
operations, as good operating practice for minimizing the 
potential for harmful emissions."

"In addition, EPA identified the use of emergency by-pass 
openings at nine of the facilities.  The emergency by-pass is  
intended to prevent ground level fugitive emissions when pressure 
in the combustion unit builds up too high, and it also is 
intended to protect the air pollution control equipment when the 
exit gas temperature is too hot.  The use of emergency by-passes 
is of more serious concern to EPA because it results in direct 
venting to the air of emissions that normally are subject to air 
pollution control devices.  At a few facilities the number of 
emergency by-passes was excessive, in the Agency's judgment."

"Since the Task Force found worker training is inadequate in many 
of the facilities inspected, the two Agencies strongly believe 
that the hazardous waste incinerator industry must do more in the 
area of personnel training to prevent potential operational and 
exposure problems."

                               ***  



                           Appendix A.  
  Frequency of Wastefeed Cutoff and Emergency By-pass Openings

                        Wastefeed           Emergency
                        Cutoffs             By-pass openings
Facility                (30 day period)     (6 month period)
---------------------------------------------------------------
A                           -                   - **
B                           -                   -
C                           9                   9
D                        1800                   0
E                         268                   -
F                         350                   -
G                         142                   -
H                         103                   0
I                           -                   -
J                        1386 ***               0
K                          16                  24
L                           0                   0
M                         146                  47
N                      13,325 (4 units)       867
O                         605                   6
P                          63                  18 ***
Q                          24                  91 ***
R                           0                   -
S                         900                   1
T                           -                   -
U                         150 ***               -
V                           0                   -
W                           -                   -
X                           6                   -
Y                         465                   2
Z                         943                   -
AA                          0                   2
BB                          -                   -
CC                          0                   0


The facilities are listed in an arbitrary order

**  A "-" could mean that the facility does not have the emergency 
    by-pass equipment or that it has no bypasses.

*** Projected based on values observed for a shorter period of 
    time
