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