Hazardous waste handbook for health and safety [3rd ed] 9780750671354, 0-7506-7135-1

Citation preview

Hazardous Waste Handbook for Health and Safety

Hazardous Waste Handbook for Health and Safety Third Edition William F. M artin John M . Lippitt Paul J. Webb

Boston Oxford Auckland Johannesburg M elbourne New Delhi

Copyright © 2000 by Butterworth–H einemann A member of the R eed E lsevier group A ll rights reserved. No part of this publication may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, electronic, mechanical, photocopying, recording, or otherwise, without the prior written permission of the publisher. R ecognizing the importance of preserving what has been written, Butterworth–H einemann prints its books on acid-free paper whenever possible. Butterworth–H einemann supports the efforts of A merican Forests and the G lobal R eLeaf program in its campaign for the betterment of trees, forests, and our environment. Library of Congress Cataloging-in-Publication D ata Martin, William F. H azardous waste handbook for health and safety / William F. Martin, John M. Lippitt, Paul Webb.—3rd ed. p. cm. Includes bibliographical references and index. ISBN 0-7506-7135-1 (alk. paper) 1. H azardous waste sites—Safety measures—H andbooks, manuals, etc. 2. H azardous waste sites—H ealth aspects—H andbooks, manuals, etc. 3. E nvironmental health— H andbooks, manuals, etc. I. Lippitt, John M. II. Webb, Paul. III. Title. TD 1052 .M38 2000 628.4¢2¢0289—dc21 00-023588 British Library Cataloguing-in-Publication D ata A catalogue record for this book is available from the British Library. The publisher offers special discounts on bulk orders of this book. For information, please contact: Manager of Special Sales Butterworth–H einemann 225 Wildwood Avenue Woburn, MA 01801–2041 Tel: 781-904-2500 Fax: 781-904-2620 For information on all Butterworth–H einemann publications available, contact our World Wide Web home page at: http://www.bh.com 10 9 8 7 6 5 4 3 2 1 Printed in the U nited States of A merica

Contents

Authors

vi

A ppendix A : A bbreviations

145

Preface

vii

A ppendix B: A cronyms

147

A cknowledgements

viii

A ppendix C: Chemical Formulas

149

A ppendix D : Glossary

151

A ppendix E: Sample Site Safety Plan

155

A ppendix F: Medical Occupational History

161

A ppendix G: Hazardous Substance D ata Sheet

165

A ppendix H: Chemical Protective Clothing Recommendations

169

A ppendix I: D econtamination Procedures for Three Typical Levels of Protection

175

A ppendix J: Health and Safety Checklist

179

A ppendix K: Chemical Hazard D ata—NIOSH Pocket Guide (Sample)

193

A ppendix L: Toxicology Review

239

Index

251

1 Introduction: Laws and Regulations

1

2 Hazards

9

3 Planning and Organization

21

4 Site Characterization

27

5 A ir Monitoring

35

6 Personal Protective Equipment

43

7 Site Control and Work Practices

77

8 D econtamination

93

9 Spills and Site Emergencies

101

10 Medical Monitoring Programs

113

11 Training

125

12 Monitoring Well Safety at Hazardous Sites

131

13 Hazardous Waste Transportation Safety

135

v

Authors

William F. M artin, P.E ., holds a civil engineering degree from the U niversity of Kentucky and a master’s degree in environmental health engineering from the U niversity of Texas. H e served twenty-two years as a commissioned officer in the U.S. Public H ealth Service. H e held positions with the Indian H ealth Service, U.S. Coast G uard, Federal Water Pollution Control A dministration, and National Institute for O ccupational Safety and H ealth. A registered professional engineer in Texas and Kentucky, he has presented and published numerous technical papers, both foreign and domestic. H e served on the Superfund steering committee made up of E PA , O SH A , NIO SH , and the U.S. Coast G uard. H e served as the NIO SH H azardous Waste Program D irector with primary responsibility for coordinating all Institute Superfund activities, including research projects and the production of comprehensive health and safety guidelines, worker bulletins, and training materials. Mr. Martin has consulted on environmental engineering and hazardous waste health and safety with Valentec International Corporation, E nvironmental Systems & Services, Inc., and G reenglobe E ngineering, Inc. John M . L ippitt, M .E n., is a R egistered Sanitarian with the O hio State Board of Sanitation R egistration. H e is currently employed as a Project Scientist for SCS E ngineers, a consulting engineering firm specializing

in hazardous and solid waste management. Mr. Lippitt provides expertise in health and safety management for SCS projects and has prepared several documents concerning methods of worker protection and costs of worker safety and health for NIO SH and the U SE PA . H is professional experience prior to joining SCS involved five years as a public health sanitarian, a year conducting carcinogen-testing research and development with the U SE PA H ealth E ffects R esearch Laboratory, and nine months as an on-site coordinator for the O hio E PA to monitor the activities of a licensed hazardous waste landfill. Paul J. Webb, C.I.H ., has experience including industrial hygiene positions with the North Carolina D epartment of Labor, D ivision of O ccupational Safety and H ealth, and within the pharmaceutical industry. H e is currently president of O ccu-H ealth Consultants, Inc., a R aleigh-based firm specializing in occupational health and safety. O ver the past several years, his firm has worked with clients in private industry and municipal government in the development and implementation of emergency response programs and personnel training. Mr. Webb received his B.S. in biology and his M.P.H . in industrial hygiene from the U niversity of South Carolina. H e is certified in the comprehensive practice of industrial hygiene by the A merican Board of Industrial H ygiene.

vi

Preface

course commonly referred to as the O ccupational Safety and H ealth A dministration (O SH A ) forty-hour or H azardous Waste O peration and E mergency R esponse (H A Z WO PE R ) training. The E nvironmental Protection A gency (E PA ), D epartment of D efense (D oD ), D epartment of E nergy (D oE ), U.S. Coast G uard (U SCG ), and O SH A regulations and contracts usually require this level of health and safety training for all onsite personnel. This training manual is a companion to the textbook Protecting Personnel at H az ardous Waste Sites, Third E dition (Butterworth-H einemann, 1999). H azardous waste management is a challenging endeavor in our national effort to protect the quality of our environment. The authors of this book feel that this challenge can be met without sacrificing the health of those individuals and companies called on to accomplish the task. This manual is an expanded version of the previous edition, with many updates of the NIO SH /O SH A / U SCG /E PA publication “O ccupational Safety and H ealth for H azardous Waste Site A ctivities” (1985) # 85-115, which the authors of this book helped to develop in 1983–1985.

Professionals in environmental health, occupational health, environmental management, and engineering have often noted the need for a well-referenced health and safety training manual to prepare new workers for hazardous materials and hazardous waste cleanup activities. This need is addressed in this third edition of H az ardous Waste H andbook for H ealth and Safety. These authors average over fifteen years each in professional experience in teaching, regulating, consulting, and handling of hazardous materials. A dditional field experience and new regulations have prompted this third edition. The third edition has expanded and updated material in every chapter. R eferences have been revised to reflect current sources. The main objective of this textbook continues to be its use as a resource book for training professionals in the practice of occupational safety and health in hazardous materials and waste activities. The authors feel strongly that anyone teaching or training hazardous waste workers should have thoroughly covered at least the content of this edition in an academic setting and have had considerable field experience under experienced supervision. This edition is considered a minimum of academic exposure for the hazardous waste health and safety

vii

Acknow ledgements

R ecognition is given to the U.S. Public H ealth Service, especially the National Institute for O ccupational Safety and H ealth (NIO SH ), the Center for D isease Control and Prevention (CD CP), the O ccupational Safety and H ealth A dministration (O SH A ), the U.S. E nvironmental Protection A gency (E PA ), the D epartment of E nergy (D oE ), the D epartment of D efense (D oD ), and the U.S. Coast G uard (U SCG ), for their efforts under the R esource Conservation and R ecovery A ct (R CR A ) and Superfund to gather, develop, and make publicly available health and safety guidelines, publications, and contractor reports. This practical hazardous waste health and safety handbook and training manual would not be possible without the previous work of many individuals, companies, and government agencies. D uring the past fifteen years, the authors have worked with a host of highly qualified professionals in the nation’s efforts to contain hazardous waste spills, clean up abandoned landfills, control hazardous chemical threats to the environment and public health, and adequately dispose of solid and hazardous waste. O utside reviewers contributed substantially to the quality and focus of this edition.A special thanks to Professor Joe Ledbetter, Ph.D., U niversity of Texas, for his specific review comments, which improved the quality of this edition. The South Carolina D epartment of H ealth and E nvironmental Control, through the reviews of Shannon Berry, R on Kinney, and H arold Seabrook, was very helpful in keeping this edition practical and current. A n extensive review by William Keffer, senior engineering advisor, was very helpful for the second edition, and also provided some excellent options for this edition. The NIO SH staff, especially

Stephen P. Berardinelli, Ph.D., A aron W. Schoppee, Ph.D., Jim Spahr, and D r. Belard in the D ivision of Safety R esearch, Morgantown, West Virginia, recommended a number of changes in the second edition relating to personal protective equipment that were incorporated into the present edition. The authors also recognize the following for their review comments on the first two editions, which have been incorporated into the present edition: James P. Kirk, William R . G outdie III, Steven J. Sherman, Vicki Santoro, Joseph A . G ispanski, and James B. Walters. The contributing authors of the third edition of Protecting Personnel at H az ardous Waste Sites provided the key items for updating this training manual: E dward Bishop, Ph.D., C.I.H .; Joanna Burger, Ph.D.; Leslie W. Cole, M.S.; D avid L. D ahlstrom, C.I.H .; D avid D yjack, D r.P.H ., C.I.H .; Michael G ochfeld, M.D., Ph.D.; D ennis G oldman, Ph.D.; R alph F. G oldman, Ph.D.; Larry L. Janssen, C.I.H .; Paul W. Jonmaire, Ph.D.; John M. Lippitt, M.E n.; William F. Martin, P.E .; James M. Melius, M.D.; R ichard C. Montgomery, Ph.D.; James P. Pastorick, B.A .; Lamar E . Priester, Jr., Ph.D.; L. E . “Chip” Priester III; Timothy G. Pothero, B.A .; Charles F. R edinger, C.I.H ., Ph.D.; Charles J. Sawyer, C.I.H ., P.E .; A rthur D. Schwope, M.A .; H . R andy Sweet; Lynn P. Wallace, Ph.D., P.E ., D.E .E .; and Paul J. Webb, C.I.H . The authors wish to thank Laurie G oodale of Priester & A ssociates for her desktop publishing skills in the production of this third edition. Thanks to A nn T. Kiefert, M.S., for her technical editing of the final draft. Ms. Kiefert’s experience with Florida’s environmental regulations and her graduate studies at Florida State U niversity contributed to her expert input.

viii

1 INTRODUCTION: LAWS AND REGULATIONS n the past tw o decades, industry, government, and the general public have become increasingly aw are of the need to respond to the hazardous w aste problem, w hich has grow n steadily over the past 100 years. In 1980, Congress passed the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)—the Superfund law —to provide for liability, compensation, cleanup, and emergency response for hazardous substances released into the environment and the cleanup of abandoned and uncontrolled hazardous w aste disposal sites. The Superfund Amendments and Reauthorization Act (SARA) of 1986 extended CERCLA and added new authorities under Title III of SARA that included Emergency Planning, Community Right-to-Know, and Toxic Chemical Release Reporting. The Resource Conservation and Recovery Act (RCRA) of 1976 sets the standards for w aste handling, storage, and disposal. The 1975 Hazardous M aterials Transportation Act provides regulation of hazardous materials labeling, packaging, placarding, manifesting, and transporting. This handbook is a training manual and guidance document for employees and supervisors responsible for occupational safety and health programs at hazardous w aste sites. It w as developed to give site supervisors specific instructions and guidelines on how to protect the safety and health of w orkers. A second goal of this handbook is to improve hazardous w aste operations efficiency through know ledge and training of the w ork force. A third goal is to reduce the cost of hazardous w aste cleanups through reduced law suits and liability losses of employers and individuals. Additional field experience and new regulations have prompted this third edition. Updated information has been added to address the 1990’s effort to clean up and convert to civilian use major Department of Defense (DoD) and

Department of Energy (DoE) lands and facilities. Occupational risk assessment and toxicology have been expanded because classroom experience at educational centers all across the United States indicated that many professional people w ere being trained for hazardous w aste occupations w ith very limited backgrounds in applied occupational health. This manual is intended for individuals w ho have direct responsibility to carry out hazardous w aste site cleanup and hazardous w aste emergencies. It can be used as:

The Codes of Federal R egulations (CFR s) provide the complete text of current regulations. Some of the CFR s of direct application to hazardous waste operations are as follows: 40 CFR 300, 29 CFR 1910, 40 CFR 260265, 30

CFR 11, and 49 CFR 100199. These federal publications can be located at major public libraries, university libraries, and most major federal and state offices. Many databases will provide access to these regulations. Two

I

• • • • •

a training manual a planning tool a management reference an educational textbook a technical reference document

It also serves as an applied industrial hygiene handbook for hazardous w aste activities and is a valuable sourcebook on hazardous w aste occupational safety and health. It should be used as a preliminary basis for developing a specific health and safety program. Consult other sources and experienced individuals as necessary for the details needed to design and implement occupational safety and health plans at specific hazardous w aste sites. Although this manual cites federal regulations, it is not a definitive legal document and should not be taken as such. Individuals w ho are responsible for the health and safety of w orkers at hazardous w aste sites should obtain and comply w ith the most recent federal, state, and local regulations. Several of the key hazardous w aste, health and safety–related regulations are briefly summarized in this chapter.

1

2 HAZARDOUS WASTE HANDBOOK of these are the Computer-A ided E nvironmental Legislative D ata System (CE LD S) and LE XIS. CE LD S contains abstracts of environmental regulations and is designed for use in environmental impact analysis and environmental quality management. The abstracts are written in an informative narrative style, with excessive verbiage removed. Characteristics of this system are as follows: 1. Legislative information is indexed to a hierarchical keyword thesaurus, in addition to being indexed to a set of environmental keywords. 2. Information can be obtained for federal and state environmental regulations, as well as regulatory requirements related to the keywords. 3. A ppropriate reference documents,such as enactment/ effective date, legislative reference, administrative agency, and bibliographical reference, are provided. The system is structured to satisfy the user agency’s (U.S. D epartment of D efense) specific needs for environmental regulations; consequently, the needs of other agencies may not be completely satisfied by this system.Augmentations to the system include regulations of concern to the U.S. E nvironmental Protection A gency (E PA ). LE XIS is a full-text system from Mead D ata Central. It is a database with a family of files that contain the full text of the following: 1. United States Code—a codification by major title of the body of U.S. statutes 2. Code of Federal R egulations—a codification by major title of current effective administrative agency regulations 3. Federal R egister—July 1980 to present 4. Supreme Court decisions since 1960 5. State court decisions—courts of last resort, intermediary courts, lower courts FEDERAL REGULATIONS SUPERFUND AM ENDM ENTS AND REAUTHORIZATION ACT (SARA) (42 U.S.C. 11001 ET SEQ.) Basic O bjective This act revises and extends CE R CLA (Superfund authorization). CE R CLA is extended by the addition of new authorities known as the E mergency Planning and Community R ight-toKnow A ct of 1986 (also known as Title III of SA R A ). Title III of SA R A provides for “emergency planning and preparedness, community right-to-know reporting, and toxic chemical release reporting.” Key Provisions There are key provisions which apply when a hazardous substance is handled and when

an actual release has occurred. E ven before any emergency has arisen, certain information must be made available to state and local authorities, and to the general public upon request. Facility owners and operators are obligated to provide information pertaining to any regulated substance present on the facility to the appropriate state or local authorities (Subtitle A ). Three types of information are to be reported to the appropriate state and local authorities (Subtitle B): 1. Material Safety D ata Sheets (MSD Ss), which are prepared by the chemical manufacturer of any hazardous chemical and are retained by the facility owner or operator (or if confidentiality is a concern, a list of hazardous chemicals for which MSD Ss are retained can be made available). These sheets contain general information on a hazardous chemical and provide an initial notice to the state and local authorities. 2. E mergency and H azardous Chemical Inventory Forms, which are submitted annually to the state and local authorities. Tier 1 information includes the maximum amount of a hazardous chemical that may be present at any time during the reporting year, and the average daily amount present during the year prior to the reporting year. A lso included is the “general location of hazardous chemicals in each category.” This information is available to the general public upon request. Tier II information is reported only if requested by an emergency entity or fire department. This information provides a more detailed description of the chemicals, the average amounts handled, the precise location, storage procedures, and whether the information is to be made available to the general public (allowing for the protection of confidential information). 3. Toxic chemical release reporting, which releases general information about effluents and emissions of any “toxic chemicals.” In the event a release of a hazardous substance does occur, a facility owner or operator must notify the authorities. This notification must identify the hazardous chemical involved; amounts released; time, duration, environmental fate; and suggested action. A multilayer emergency planning and response network on the state and local government levels is to be established (also providing a notification scheme for the event of a release). Enforcement R esponsibilities:Federal–State R elationship Local emergency planning committees or an emergency response commission appointed by the governor of the state are responsible for the response scheme. The primary drafters of the local response plans

INTRODUCTION: LAWS AND REGULATIONS

are local committees, which are also responsible for initiating the response procedure in the event of an emergency. E ach state commission will supervise the local activities. A ccomplishments and Impacts SA R A legislation, promoting emergency planning and providing citizen information at the local level, was a response to the Bhopal, India, disaster. A major intent is to reassure U.S. citizens that a similar tragedy will not occur in this country. The standardization of reporting and record keeping should produce long-term benefits and welldesigned response plans. Whether a high-quality emergency response involvement can be maintained indefinitely at the local level remains a question. COM PREHENSIVE ENVIRONM ENTAL RESPONSE, COM PENSATION, AND LIABILITY ACT (42 U.S.C. 9601 ET SEQ.) Basic O bjective The act, known as CE R CLA or “Superfund,” has four objectives. These are: 1. To provide the enforcement agency the authority to respond to releases of hazardous wastes (as defined in the Clean Water A ct, Clean A ir A ct, Toxic Substances Control A ct, Solid Waste D isposal A ct, and by the administrator of the enforcement agency) from “inactive” hazardous waste sites that endanger public health and the environment 2. To establish a H azardous Substance Superfund 3. To establish regulations controlling inactive hazardous waste sites 4. To provide liability for releases of hazardous wastes from such inactive sites The act amends the Solid Waste D isposal A ct. It provides for an inventory of inactive hazardous waste sites and for the appropriate action to protect the public from the dangers possible from such sites. It is a response to the concern for the dangers of negligent hazardous waste disposal practices. Key Provisions Key provisions of this act are: 1. The establishment of a H azardous Substance Superfund based on fees from industry and federal appropriations to finance response actions. 2. The establishment of liability to recover costs of response from liable parties, and to induce the cleanup of sites by responsible persons. 3. The determination of the number of inactive hazardous waste sites by conducting a national inventory. This inventory shall include coordination by the A gency for Toxic Substances and D isease R egistry within the Public H ealth Service for the purpose of implementing the health-related authorities in the act.

3

4. The provision of the authority for the E PA to act when there is a release or threat of release of a pollutant from a site that may endanger public health. Such action may include “removal, remedy and remedial action.” 5. The revision of the National Contingency Plan for the R emoval of O il and H azardous Substances (40 CFR , Part 300). This plan must include a section to establish procedures and standards for responding to releases of hazardous substances, pollutants, and contaminants as well as abatement actions necessary to offset imminent dangers. Enforcement R esponsibilities: Federal–State R elationship The E PA has responsibility for enforcement of the act as it pertains to the inventory, liability, and response provisions.The E PA is also responsible for claims against the H azardous Substance Superfund, which is administered by the President of the U nited States. The E PA is responsible for promulgating regulations to designate hazardous substances, reportable quantities, and procedures for response. The National R esponse Center, established by the Clean Water A ct, is responsible for notifying appropriate government agencies of any release. The following D epartment of Transportation agencies also have responsibilities under the act: 1. U.S. Coast G uard—responses to releases vessels 2. Federal Aviation A dministration—responses leases from aircraft 3. Federal H ighway A dministration—responses leases from motor carriers 4. Federal R ailway A dministration—responses leases from rolling stock

from to reto reto re-

States are encouraged by the act to participate in response actions. The act authorizes the E PA to enter into contracts or cooperative agreements with states to take response actions. The fund can be used to defray costs to the states. The E PA must first approve an agreement with the state, based on the commitment by the state to provide funding for remedial implementation. Before undertaking any remedial action as part of a response, the E PA must consult with the affected state(s). A ccomplishments and Impacts O n July 16, 1982, the E PA published the final regulations pursuant to Section 105 of the act, revising the National Contingency Plan for O il and H azardous Substances under the Clean Water A ct, reflecting new responsibilities and powers created by CE R CLA . The plan establishes an effective response program. Because the act requires a national inventory of inactive hazardous waste sites, the intent is to identify potential danger areas and effect a

4 HAZARDOUS WASTE HANDBOOK cleanup or remedial actions to avoid or mitigate public health and environmental dangers. In studying a sampling of these sites, the H ouse Committee on Interstate and Foreign Commerce (H ouse R eport No. 961016) found four dangerous characteristics common to all the sites. These characteristics are: 1. Large quantities of hazardous wastes 2. U nsafe design of the sites and unsafe disposal practices 3. Substantial environmental danger from the wastes 4. The potential for major health problems to people living and working in the area of the sites The intent of the act is to eliminate the above problems by dealing with the vast quantities of hazardous and toxic wastes in unsafe disposal sites in the country. The immediate impact of the act has been the identification of the worst sites where the environmental and health dangers are imminent. This priority list will be used to spend the money available in the H azardous Waste R esponse Fund in the most effective way to eliminate the imminent dangers.The long-term impact of the act will be to eliminate and clean up all the identified inactive sites and develop practices and procedures to prevent future hazards in such sites, whether active or inactive. A nother accomplishment of the act is to establish liability for the cost of cleanup to discourage unsafe design and disposal practices. The act has armed the E PA with the authority to pursue an active program of cost recovery for cleanup from responsible parties. RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) (42 U.S.C. 6901 ET SEQ.) Basic O bjective R CR A , as it exists now, is the culmination of a long series of pieces of legislation, dating back to the passage of the Solid Waste D isposal A ct of 1965, which address the problem of waste disposal. It began with the attempt to control solid waste disposal and eventually evolved into an expression of the national concern with the safe and proper disposal of hazardous waste. E stablishing alternatives to existing methods of land disposal and the conversion of solid wastes into energy are two important needs noted by the act. The R CR A of 1976 gives the E PA broad authority to regulate the disposal of hazardous wastes; encourages the development of solid waste management plans and nonhazardous waste regulatory programs by states; prohibits open dumping of wastes; regulates underground storage tanks; and provides for a national research, development, and demonstration program for improved solid waste management and resource conservation techniques. The control of hazardous wastes will be undertaken by identifying and tracking hazardous wastes as they are

generated, ensuring that hazardous wastes are properly contained and transported, and regulating the storage, disposal, or treatment of hazardous wastes. A major objective of the R CR A is to protect the environment and conserve resources through the development and implementation of solid-waste plans by the states. The act recognizes the need to develop and demonstrate waste management practices that are not only environmentally sound and economical but also conserve resources. The act requires the E PA to undertake a number of special studies on subjects such as resource recovery from glass and plastic waste and managing the disposal of sludge and tires. A n Interagency R esource Conservation Committee has been established to report to the president and the Congress on the economic, social, and environmental consequences of present and alternative resource conservation and resource recovery techniques. Key Provisions Some of the significant elements of the A ct follow. H azardous wastes are identified by definition and publication. Four classes or definitions of hazardous waste have been identified: ignitability, reactivity, corrosivity, and toxicity. The chemicals that fall into these classes are regulated primarily because of the dangerous situations they can cause when landfilled with typical municipal refuse. Four lists, containing approximately 1000 distinct chemical compounds, have been published. (These lists are revised as new chemicals become available.) These lists include waste chemicals from nonspecific sources, by-products of specific industrial processes, and pure or off-specification commercial chemical products. These classes of chemicals are regulated primarily to protect groundwater from contamination by toxic products and by-products. The act requires tracking of hazardous wastes from generation, to transportation, to storage, and to disposal or treatment. G enerators, transporters, and operators of facilities that dispose of solid wastes must comply with a system of record keeping, labeling, and manufacturing to ensure that all hazardous waste is designated only for authorized treatment, storage, or disposal facilities. The E PA must issue permits for these facilities, and the facilities must comply with standards issued by the E PA . The states must develop hazardous waste management plans and have them approved by the E PA . These plans will regulate hazardous wastes in the states and will control the issuance of permits. If a state does not develop such a plan, the E PA will develop one based on the federal program. Solid waste disposal sites are to be inventoried to determine compliance with sanitary landfill regulations issued by the E PA . O pen dumps are to be closed or upgraded within five years of the inventory.A s with haz-

INTRODUCTION: LAWS AND REGULATIONS

ardous waste management, states must develop management plans to control the disposal of solid waste and to regulate disposal sites. The E PA has issued guidelines to assist states in developing their programs. A s of 1983, experience and a variety of studies dating back to the initial passage of the R CR A legislation found that an estimated 40 million metric tons of hazardous waste escaped control annually through loopholes in the legislative and regulatory framework. Subsequently, Congress was forced to reevaluate R CR A , and in doing so found that R CR A fell short of its legislative intent by failing to regulate a significant number of small-quantity generators, regulate waste oil, ensure the environmentally sound operation of land disposal facilities, and realize the need to control the contamination of groundwater caused by leaking underground storage tanks. Major amendments were enacted in 1984 in order to address the shortcomings of R CR A . Key provisions of the 1984 amendments include:

• Notification of underground tank data and regulations for detection, prevention, and correction of releases

• Incorporation of small-quantity generators (which generate between 100 and 1000 kg of hazardous waste per month) into the regulatory scheme

• R estriction of land disposal of a variety of wastes unless the E PA determines that land disposal is safe from human health and environmental points of views

• R equirement of corrective action by treatment, storage, and disposal facilities for all releases of hazardous waste regardless of when the waste was placed in the unit

• R equirement of the E PA to inspect governmentowned facilities (which handle hazardous waste) annually, and other permitted hazardous waste facilities at least every other year

• R egulation of facilities that burn wastes and oils in boilers and industrial furnaces Enforcement R esponsibilities: Federal–State R elationship Subtitle C of the Solid Waste D isposal A ct, as amended by the R CR A of 1976, directs the E PA to promulgate regulations for the management of hazardous wastes. The hazardous waste regulations initially published in May 1980 from the R CR A control the treatment, storage, transport, and disposal of waste chemicals that may be hazardous if landfilled in the traditional way. These regulations (40 CFR 261265) identify hazardous chemicals in two ways, by listing and by definition. A chemical substance that appears on any of the lists or

5

meets any one of the definitions must be handled as a hazardous waste. Like other environmental legislation, R CR A enforcement responsibilities for hazardous waste management will eventually be handled by each state, with federal approval. E ach state must submit a program for the control of hazardous waste. These programs must be approved by the E PA before the state can accept enforcement responsibilities. The state programs will pass through three phases before final approval will be given. The first phase is the interim phase, during which the federal program will be in effect. The states will begin submitting their programs for the control of hazardous wastes. The second-phase programs will address permitting procedures. A final phase will provide federal guidance for design and operation of hazardous waste disposal facilities. Many states have chosen to allow the federal programs to suffice as the state program to avoid the expense of designing and enforcing the program. It should also be noted that the D epartment of Transportation has enforcement responsibilities for the transportation of hazardous wastes and for the manifest system involved in transporting. A ccomplishments and Impacts The 1980 regulations for the control of hazardous wastes were a response to the national concern over hazardous waste disposal. States have begun to discover their own “Love Canals,” and the impacts of unregulated disposal of hazardous wastes on their communities. While the Superfund legislation provides funds for the cleanup of such sites, R CR A attempts to avoid future Love Canals. TOXIC SUBSTANCES CONTROL ACT (TSCA) (15 U.S.C. 2601 ET SEQ.) Basic O bjective This act sets up the toxic substances program which is administered by the E PA . If the E PA finds that a chemical substance may present an unreasonable risk to health or to the environment and that there is insufficient data to predict the effects of the substance, manufacturers may be required to conduct tests to evaluate the characteristics of the substance, such as persistence, acute toxicity, or carcinogenic effects. A lso, the act establishes a committee to develop a prioritized list of chemical substances to be tested. The committee may list up to fifty chemicals that must be tested within one year. H owever, the E PA may require testing for chemicals not on the priority list. Manufacturers must notify the E PA of the intention to manufacture a new chemical substance. The E PA may then determine if adequate data are available to assess the health and environmental effects of the new chemical. If the data are determined to be inadequate, the E PA will require testing. Most important, the E PA may prohibit the manufacture, sale, use, or disposal of a

6 HAZARDOUS WASTE HANDBOOK new or existing chemical substance if it finds the chemical presents an unreasonable risk to health or the environment. The E PA can also limit the amount of the chemical that can be manufactured and the amount and manner in which the chemical can be used. The act also regulates the labeling and disposal of polychlorinated biphenyls (PCBs) and prohibits their production and distribution after July 1979. In 1986, Title II, “A sbestos H azard E mergency R esponse,” was added to address issues of inspection and removal of asbestos products in public schools and to study the extent of (and response to) the public health danger posed by asbestos in public and commercial buildings. Key Provisions Testing is required on chemical substances meeting certain criteria to develop data with respect to the health and environmental effects for which there are insufficient data relevant to the determination that the chemical substance does or does not present an unreasonable risk of injury to health or the environment. Testing shall include identification of the chemical and standards for test data. Testing is required from the following: 1. Manufacturers of a chemical meeting certain criteria 2. Processors of a chemical meeting certain criteria 3. D istributors or persons involved in disposal of chemicals meeting certain criteria Test data required by the act must be submitted to the E PA . The data must identify the chemical, list the uses or intended uses, and provide the information required by the applicable standards for the development of test data. The E PA will establish a priority list of chemical substances for regulation. Priority is given to substances known to cause or contribute to cancer, gene mutations, or birth defects. The list is revised and updated as needed. A new chemical may not be manufactured without notifying the E PA at least ninety days before manufacturing begins. The notification must include test data showing that the manufacture, processing, use, and disposal of the chemical will not present an unreasonable risk of injury to health or the environment. Chemical manufacturers must keep records for submission to the E PA as required. The E PA will use these reports to compile an inventory of chemical substances manufactured or processed in the U nited States. The act also regulates the disposal and use of and prohibits the future manufacture of PCBs, and requires the E PA to engage, through various means, in research, development, collection, dissemination, and utilization of data relevant to chemical substances.

Enforcement R esponsibilities: Federal–State R elationship The E PA has enforcement responsibilities for the act, but the act makes provisions for consultations with other federal agencies involved in health and environmental issues, such as O SH A and the D epartment of H ealth and H uman Services. Initially, the states could receive E PA grants to aid them in establishing programs at the state level to prevent or eliminate unreasonable risks to health or the environment related to chemical substances. A ccomplishments and Impacts TSCA has provided a framework for ensuring that chemical manufacturers take responsibility for testing the health and environmental effects of chemical substances. A lthough it requires the manufacturer to establish the safety of a chemical, it still gives the E PA the final authority to prohibit or severely restrict chemicals in commerce. Thus, it is an attempt to prevent significant health and environmental problems that may surface later on. The fact that when this legislation was initially passed, PCB effects were such an issue because of their widespread and uncontrolled use is reflective of public concerns over the number of other possible chemicals commonly used which could be carcinogenic. Public concern was so visible that an immediate need was perceived to regulate PCBs. Thus, PCBs are controlled and specifically prohibited by TSCA rather than R CR A . NATIONAL ENVIRONM ENTAL POLICY ACT (NEPA) (42 U.S.C. 4341 ET SEQ.) Enforcement R esponsibilities: Federal–State R elationship The President’s Council on E nvironmental Q uality (CE Q ) has the main responsibility for overseeing federal efforts to comply with NE PA . In 1978, CE Q issued regulations to comply with the procedural provisions of NE PA . O ther provisions of NE PA apply to major federal actions significantly affecting the quality of the human environment. A ccomplishments and Impacts The enactment of this act has added a new dimension to the planning and decision-making process of federal agencies in the U nited States.This act requires federal agencies to assess the environmental impact of implementing their major programs and actions early in the planning process. For those projects or actions that are either expected to have a significant effect on the quality of the human environment or are expected to be controversial on environmental grounds, the proponent agency is required to file a formal environmental impact statement (E IS). O ther accomplishments and impacts of the act are:

• It has provided a systematic means of dealing with environmental concerns and including environmental costs in the decision-making process.

INTRODUCTION: LAWS AND REGULATIONS

• It has opened governmental activities and projects to public scrutiny and public participation.

• Some projects have been delayed because of the time required to comply with the NE PA requirements.

7

FEDERAL AND STATE REGULATORY AGENCIES The following federal agencies and their parallel state agencies can be contacted for the latest regulations, training materials, and technical updates:

• Many projects have been modified or abandoned to balance environmental costs with other benefits.

• It has served to accomplish the four purposes of the act as stated in its text. FEDERAL INSECTICIDE, FUNGICIDE, AND RODENTICIDE ACT (FIFRA) (7 U.S.C. 136 ET SEQ.) Basic O bjective FIFR A is designed to regulate the use and safety of pesticide products within the U nited States. The 1972 amendments are intended to ensure that the environmental harm resulting from the use of pesticides does not outweigh the benefits. Key Provisions

Key provisions of FIFR A include:

• The evaluation of risks posed by pesticides (requiring registration with the E PA )

• The classification and certification of pesticides by specific use (as a way to control exposure)

• The restriction, suspension, or cancellation of the use of pesticides that are harmful to the environment

• The enforcement of the above requirements through inspections, labeling, notices, and state regulation Enforcement R esponsibilities: Federal–State R elationship The E PA is allowed to establish regulations concerning registration, inspections, fines, and criminal penalties, and to stop the sale of pesticides. Primary enforcement responsibility, however, has been assumed by almost every state. Federal law specifies only that each state must have adequate laws and enforcement procedures to assume primary authority. A s in the case for almost any federal law, FIFR A preempts state law to the extent that it addresses the pesticide problem. Thus, a state cannot adopt a law or regulation that counters a provision of FIFR A , but it can adopt laws which are more stringent. A ccomplishments and Impacts A lthough the volume of pesticides and related information is enormous, FIFR A has enabled the E PA to acquire additional information for analysis of risk and environmental degradation resulting from the use of pesticides. This information has been, and will continue to be, generally invaluable in such analyses. H owever, Congress continues to struggle with the balancing of benefits and detriments of the use of pesticides in its attempt to deal with the economic, scientific, and environmental issues involved in the regulation of pesticides.

National Institute for O ccupational Safety and H ealth (NIO SH )—Centers for D isease Control and Prevention 4676 Columbia Parkway Cincinnati, O H 45226 O ccupational Safety and H ealth A dministration (O SH A ) 200 Constitution Avenue, NW Washington, D C 20210 E nvironmental Protection A gency (E PA ) 401 M Street, SW Washington, D C 20460 Federal E mergency Management (FE MA ) 500 C Street, SW Washington, D C 20472

A dministration

U.S. Coast G uard (U SCG )—D epartment of Transportation 2100 Second Street, SW Washington, D C 20593 A gency for Toxic Substances and D isease R egistry 1600 Clifton R oad, NE A tlanta, G A 30333 A lthough this handbook was designed to assist supervisors at abandoned or uncontrolled hazardous waste sites, the information can be used in planning for and responding to emergencies involving hazardous materials. A short bibliography is provided at the end of each chapter to provide additional sources of technical information. BIBLIOGRAPHY “A ccreditation of Training Programs for H azardous Waste O perations: Notice of Public H earings.” Federal R egister 55 (210): 45616–8, 1990. A merican Conference of G overnmental Industrial H ygienists (ACG IH ). T hreshold L im it Values for Chem ical Substances and Physical A gents and B iological E xposure Indices. Cincinnati, O hio: ACG IH , 1988. ——. G uidelines for the Selection of Chem ical Protective Clothing. Cincinnati: ACG IH , 1983. A ndrews, L.P. Work er Protection D uring H az ardous Waste R em ediation. Center for Labor E ducation and R esearch. New York: Van Nostrand, R einhold, 1990.

8 HAZARDOUS WASTE HANDBOOK Blackman, W.C. Jr. B asic H az ardous Waste M anagem ent. 2nd ed. New York: Louis Publishers, 1996. Bretherick, L. H andbook of R eactive Chem ical H az ards. 3rd ed. Boston: Butterworth-H einemann, 1985. Cheremisinoff, P.N. H az ardous M aterials: E m ergency R esponse Pock et H andbook . Lancaster, PA : Technomic, 1988. Corbitt, R .A . Standard H andbook of E nvironm ental E ngineering. New York: McG raw-H ill, 1989. D yjack, D.T., S.P. Levine, et al. “Comparison of A IH A ISO 9001 . . . ” A IH A Journal 59:419–29, June, 1989. E PA . Standard O perating G uides. U.S. E PA (O E R R ), O SWE R D irective 9285.1–02, Washington, D C, 1988. ——. (1989). Work er Protection Standards for H az ardous Waste O perations and E m ergency R esponse: Final R ule. 40 CFR 311 54(120):26653–8 (July 23). G overnment Institutes, Inc. H az ardous M aterial Spills — Conference Proceedings. R ockville, MD : G overnment Institutes, Inc., yearly. ——. M anagem ent of Uncontrolled H az ardous Waste Sites— Conference Proceedings. R ockville, MD : G overnment Institutes, Inc., annually. Inhaber, H . Slaying the N IM B Y D ragon. New Brunswick, NJ: Transaction Publishers, 1998. Lave, L.B., and A .C. U pton. Toxic Chem icals, H ealth and the E nvironm ent. Baltimore, MD : Johns H opkins Press, 1987. Lindgren, G.F. G uide to M anaging Industrial H az ardous Waste. Boston: Butterworth-H einemann, 1983. Martin, W.F., and M. G ochfeld. Introduction and Federal Program s. Chapter 1 of Protecting Personnel at H az ardous Waste Sites. 3rd ed. Boston: Butterworth-H eineman, 2000.

National Institute for O ccupational Safety and H ealth (NIO SH ). O ccupational Safety and H ealth G uidance M anual for H az ardous Waste Site A ctivities. U.S. D epartment of H ealth and H uman Services Publication No. 85115. Washington, D C: G PO, O ctober, 1985. ——. Pock et G uide to Chem ical H az ards. Washington, D C: National Institute for O ccupational Safety and H ealth, 1997. ——. R egistry of Toxic E ffects of Chem ical Substances. Cincinnati: NIO SH , 1990. —— /O SH A /U SG G /E PA . O ccupational Safety & H ealth G uidance M anual for H az ardous Waste Site A ctivities. D ocument D H H S (NIO SH ) 85–115, 1985. O ccupational Safety and H ealth A dministration (O SH A ). 29 CFR 1910.120, Vol. 54 (42), March 6, 1989. Scannell, G.F. Inspection G uidelines for Post-E m ergency R esponse O perations Under 29 CFR 1910.120. U.S. D O L (O SH A ) D irectorate of Compliance Programs. CPL 2–2.51, 1990. Sullivan, T.F.P. D irectory of E nvironm ental Inform ation Sources. 3rd ed. R ockville, MD : G overnment Institutes, Inc., 1990. T he M erck Index. 11th ed. R ahway, NJ: Merck & Company, 1989. U.S. D epartment of Transportation (D oT). H az ardous M aterials E m ergency R esponse G uide B ook . D oT Publication No. 5800.5. Washington, D C: D oT, 1990. Wagner, Travis P. T he Com plete G uide to H az ardous Waste R egulation. 3rd ed. New York: John Wiley and Sons, 1999. Waxman, M.F. H az ardous Waste Site O perations. New York: John Wiley and Sons, 1996.

2 HAZARDS azardous w aste sites pose a multitude of health and safety risks, any one of w hich could result in serious injury or death (see Table 2.1). These hazards are due to the physical and chemical nature of the site as w ell as the w ork being performed. They include the follow ing:

• cold exposure • noise

H

• heat stress

Interaction among the substances may produce additional compounds not originally deposited at the site. Workers are subject to dangers posed by the disorderly physical environment of uncontrolled sites. The stress of w orking in protective clothing adds its ow n risk. Selection of protective equipment often is overly conservative due to many unknow ns (see Chapter 6, Personal Protective Equipment). In approaching a site, it is prudent to assume that all these hazards are present until site characterization has show n otherw ise. A site health and safety plan must provide protection against the potential hazards and specific protection against individual know n hazards. The safety plan must be continuously updated w ith new information and changing site conditions.

CHEM ICAL EXPOSURE

• Contact with groundwater and surface waters that

• chemical exposure • fire and explosion • oxygen deficiency • ionizing radiation • biologic (etiologic) hazards • physical safety hazards • electrical hazards

have been contaminated by direct contact with wastes and/or contaminated media

Preventing exposure to toxic chemicals is a primary concern at hazardous waste sites. Most sites contain a variety of chemical substances in gaseous, liquid, or solid form. These substances can enter the unprotected body by inhalation, direct skin contact, ingestion, or through a puncture wound (injection). A contaminant can cause damage at the point of contact or act systemically by causing a toxic effect at other points in the body. Workers on hazardous waste sites can be exposed to chemicals in a variety of ways, including:

• Contact with chemical contaminants released, often under pressure, from unplanned chemical reactions caused by mixing incompatible chemical in the wastes and contaminated media being cleaned up

• Contact with previously unknown wastes when containers are opened or ruptured during handling and/or uncovered during excavation and movement of bulk wastes and soils

• Contact with wastes released or media contaminated by spills, failure of containment, fires, explosions and other emergency situations

• D irect contact with wastes during sampling, loading and over-packing of containers, and handling of bulk wastes and waste containers

Preventing worker exposures is the primary objective of site controls, safe work practices, and use of personal protection equipment and clothing (see Chapter 7, Site Controls, and Chapter 6, Personal Protective E quipment). Chemical exposures are generally divided into two categories: acute and chronic. Symptoms resulting from acute exposures usually occur during or shortly after exposure to a sufficiently high concentration of a

• Cross-contamination of food, tobacco products, materials, and equipment caused by inappropriate practices (smoking or eating in contaminated areas) and/or inadequate decontamination of personnel and equipment upon exit from contamination areas

• E ntry into low-lying areas and confined spaces where air contaminants accumulate from waste containers and areas and piles containing bulk wastes

9

TABLE 2.1 Overview of Typical Hazards Encountered at Hazardous Waste Sites Hazard Type

Exposure Route or Cause

Symptom or Effect

M easurement or M easuring Device

Prevention

Personal Protection

Additional Comments

Chem ical exposure

Inhalation, eye/skin contact, ingestion, puncture.

Headaches, nausea, rashes, burning, coughing, cancer, liver dam age, kidney dam age convulsions, com a, death

TLV, PEL, IDLH, LD50, etc. Devices: OVA, HNU, air sam pling, detection tubes, personal m onitoring, fi eld GC

Follow SOP and safety procedures; use extra caution w hen w orking in hot zones. Use rem ote control devices w henever possible.

Protective clothing. Respiratory protection.

Rem ove person im m ediately and decontam inate if exposed to a chem ical.

Ionizing radiation

M olecular degradation releases gam m a, beta, and alpha radiation: gam m a is m ost serious; alpha is m ost hazardous in case of ingestion.

Radiation burns, m utagenicity, death

Radiation detection m eters, Geiger-M üller detector, gam m a scintillation m eter

Do radiation survey early investigation. Gam m a is detectable through thin m etal (e.g., drum s) so survey can be done w ithout disturbing chem ical w astes.

Protective clothing and dust m asks w ill protect against alpha and help lim it beta. Only lim ited protection against gam m a is available.

Consult health physicist if m easurem ents are above 10 m R/hr. At 1 m R/hr, back off and m ap the 1 m R/hr area.

Fire and explosion

Unstable chem icals; incom patible reactions; shocksensitive chem icals; vapor buildup in enclosed spaces or low -lying areas w ith sparks, open fl am es, or static electricity.

Burns, concussion, shock, dism em berm ent, death

Flash point: 25% LEL—Withdraw and reevaluate situation; w ill not read accurately in oxygendefi cient environm ent. >10% LEL—Stop all spark-producing operation.

Oxygen defi ciency

In enclosed spaces (e.g., buildings, tanks, m anholes) or low areas (e.g., trenches), oxygen is replaced by other gases; generally they are dangerous toxic gases and vapors.

Inattention, im paired judgm ent, reduced coordination, altered breathing and heart rate, nausea, brain dam age, unconsciousness, death

21% O2 is norm al.