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208 lines
9.1 KiB
Plaintext
208 lines
9.1 KiB
Plaintext
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EPA/OSHA study on health and safety at hazwaste incinerators
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On May 23, 1991, EPA and OSHA released their joint report,
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"Evaluation of Compliance with On-site Health and Safety Require-
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ments at Hazardous Waste Incinerators." This special investigation
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was initiated in July 1990 after reports of serious worker exposure
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to toxic chemicals at the now-closed Caldwell Systems incinerator in
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Lenoir, NC.
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The study reveals both the dangers of incineration for workers
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and the inability of incinerator operators to comply with regula-
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tions. Especially notable is the extraordinary frequency of
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emergency waste feed cut-offs and by-pass openings, which indi-
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cates that upsets happen on a daily basis, at the very least.
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The facilities with the worst records had averages of as many 60
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cut-offs and 29 by-passes per day.
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The report's executive summary reads as follows:
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"Background.
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"EPA and OSHA jointly established the Task Force to evaluate
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compliance with on-site health and safety requirements at select-
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ed hazardous waste incinerators. Unannounced inspections were
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conducted at 29 of the approximately 140 operating hazardous
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waste incinerators. These inspections focused on determining
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compliance with worker health and safety training requirements,
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and preparedness prevention and emergency response requirements.
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Potential worker exposure routes from equipment and areas relat-
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ing directly to the incinerator operations were also evaluated.
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"Findings.
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"1. OSHA identified a total of 320 violations in five major
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areas of its regulations. These violations include 111 in the
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health and safety training area; 22 in facility contingency
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plans; 19 in workplace surveillance and monitoring; 20 in poten-
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tial chemical exposure to workers during incinerator and waste
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handling operations; and 148 in general health and safety (e.g.,
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lighting, fall protection, materials storage, electrical, etc.)
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violations.
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"2. EPA identified a total of 75 violations of its standards at
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the 29 facilities inspected. These violations include 14 for
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failure to provide adequate information and/or training to em-
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ployees; 16 for noncompliance with the contingency plans and
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emergency response requirements; 29 for non-compliance with
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general inspections and preparedness and prevention requirements;
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and 16 for failure to comply with operational procedures require-
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ments. Of these 16 violations, only 5 related specifically to
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incinerator operations.
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"EPA also noted a significant number of waste feed cut-offs and
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emergency by-pass openings. The waste feed cut-off system is
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intended to stop waste entering the incinerator combustion unit
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when certain operating conditions are exceeded. Emergency by-
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passes are intended to prevent ground-level fugitive emissions
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and possible explosions from excessive pressure in the combustion
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unit. While both devices are designed for safety purposes, the
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frequent use of these devices at some facilities may indicate a
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need to improve operating practices."
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"Conclusions.
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OSHA did not observe evidence of worker overexposure to chemicals
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that could cause serious harm. However, EPA and OSHA are
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concerned with the widespread deficiencies in the area of worker
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health and safety training, which could potentially lead to
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operational and exposure problems. EPA is also concerned about
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the apparent overuse of waste feed cut-offs and emergency by-
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passes at some facilities."
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***
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Facilities inspected
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Pfizer CT
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Polaroid Corp. MA
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Rollins Environmental NJ
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BASF Corporation NJ
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Occidental Chemical NY
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General Electric Silicones NY
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Schenectady Chemicals NY
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Allied Signal AL
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S&S Flying Services FL
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Olin Chemical KY
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Atochem North America KY
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LWD KY
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ThermalKEM SC
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Thermal Oxidation Corp SC
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CWM - Chicago IL
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CWM - Sauget IL
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Paxton Ave Lagoons Site IL
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Upjohn Company MI
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Ross Incineration Services OH
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ENSCO AR
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Dupont Co. LA
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Rhone-Poulenc LA
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Rollins Env. Services LA
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CWM TX
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Rhone-Poulenc TX
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Rollins Env. Services TX
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Blackfoot Pose and Pole Site MT
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Livermore National Labs CA
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Idaho Natl Engineering Lab ID
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***
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[Excerpts from the report]
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"OSHA noted a total of 320 violations of its standards at the 27
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inspected sites.... Of the violations cited, 214 were serious
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and 106 other-than-serious. The violation rate was 5.1 total
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violations and 3.4 serious violations per inspection. To put
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this in context, OSHA's violation rate for all industries is 3.8
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total violations and 2.5 serious violations per inspection.
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"The most frequently cited violations (which account for
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approximately one-third of the violations OSHA observed at the 27
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inspected hazardous waste incinerator facilities) were related to
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deficiencies in communicating to workers the hazards of the
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chemical substances present at their worksites and providing
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adequate health and safety information to minimize those
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hazards."
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"[EPA] also noted a significant number of automatic waste feed
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cut-offs at about half of the hazardous waste incinerators
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inspected. The automatic waste feed cut-off system is required
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by the regulation and is intended to stop hazardous waste
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entering the incinerator combustion unit when certain operating
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conditions as specified in the permit are exceeded. It is not
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intended to be used as a routine measure to control operation of
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a hazardous waste incinerator. EPA does not currently have data
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indicating that these cut-offs affect hazardous waste incinerator
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emissions; however, the Agency prefers steady uninterrupted
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operations, as good operating practice for minimizing the
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potential for harmful emissions."
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"In addition, EPA identified the use of emergency by-pass
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openings at nine of the facilities. The emergency by-pass is
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intended to prevent ground level fugitive emissions when pressure
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in the combustion unit builds up too high, and it also is
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intended to protect the air pollution control equipment when the
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exit gas temperature is too hot. The use of emergency by-passes
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is of more serious concern to EPA because it results in direct
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venting to the air of emissions that normally are subject to air
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pollution control devices. At a few facilities the number of
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emergency by-passes was excessive, in the Agency's judgment."
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"Since the Task Force found worker training is inadequate in many
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of the facilities inspected, the two Agencies strongly believe
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that the hazardous waste incinerator industry must do more in the
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area of personnel training to prevent potential operational and
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exposure problems."
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***
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Appendix A.
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Frequency of Wastefeed Cutoff and Emergency By-pass Openings
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Wastefeed Emergency
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Cutoffs By-pass openings
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Facility (30 day period) (6 month period)
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---------------------------------------------------------------
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A - - **
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B - -
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C 9 9
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D 1800 0
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E 268 -
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F 350 -
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G 142 -
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H 103 0
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I - -
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J 1386 *** 0
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K 16 24
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L 0 0
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M 146 47
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N 13,325 (4 units) 867
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O 605 6
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P 63 18 ***
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Q 24 91 ***
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R 0 -
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S 900 1
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T - -
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U 150 *** -
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V 0 -
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W - -
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X 6 -
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Y 465 2
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Z 943 -
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AA 0 2
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BB - -
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CC 0 0
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The facilities are listed in an arbitrary order
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** A "-" could mean that the facility does not have the emergency
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by-pass equipment or that it has no bypasses.
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*** Projected based on values observed for a shorter period of
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time
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