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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