|
|
U. S. Department of Labor
Occupational Safety and Health Administration
Directorate of Enforcement Programs
Office of Health Enforcement |
Remediation Technology Health and Safety Hazards: Thermal Desorption
|
Safety and Health Information Bulletins |
|
SHIB 02-03-03 |
Purpose
Thermal desorption is a common treatment process used at hazardous waste sites to
separate organic contaminants from feedstock like soil or sludge. Operating
these units can expose site workers to safety and health hazards such as
chemical exposure from site contaminants and process chemicals, fire or
explosion, noise, heat stress, confined space entry, and physical injury from
pinching or crushing. This bulletin was written to help employers recognize these hazards and control
them in a manner consistent with OSHA requirements and other industry
standards (e.g., ANSI standards).
To guide an employer in identifying technology-related
hazards and implementing controls, this bulletin offers a sample format called
a Technology Safety Summary or TSS. Ideally, an initial TSS will be prepared by the technology manufacturer and will be
completed by the employer. A well-prepared TSS should increase worker protection by improving the quality
and completeness of job hazard assessments, the site-specific health and
safety plan, implemented controls, and employee training information. Routine
use of TSSs may also result in improved technology designs that reduce worker
hazards.
This is the first of a series of
bulletins about the health and safety hazards associated with treatment
technologies used on hazardous waste sites. It includes a sample format called
a Technology Safety Summary (TSS) to help manufacturers and employers document
these hazards and the recommended controls. OSHA developed this bulletin as part of its role within the Office of
Solid Waste and Emergency Response (OSWER)/Labor Union Health & Safety
Task Force to improve worker protection during site remediation. For more information about the Task Force and its work, including the
field audit program, visit the Task Force website at http://www.ertresponse.com/health_safety/index.htm |
Background
A Thermal desorption unit treats contaminated feedstock such as soil, sludge,
sediments or debris by heating the feedstock directly or indirectly (see Figures on page 3).The heating process separates the contaminants from the feedstock by
volatilizing them. This part of the process takes place in the primary treatment
unit (PTU) and usually does not destroy the molecular structure of the
contaminant.
To meet the size and moisture requirements for
effective heat transfer, feedstock is manipulated by pretreatment equipment
before entering the PTU.
Treated feedstock is transferred to a stockpile
area and tested for residual contamination. Depending on the site requirements,
treated feedstock will be further treated, disposed of off-site, or used to
backfill site excavations. Volatilized contaminants are removed from the primary
treatment unit in the off-gas stream and are destroyed or eliminated using air
pollution controls (e.g., afterburners, baghouses, scrubbers, carbon adsorption
units).
This Safety and Health Information Bulletin is not
a standard or
regulation, and it creates no new legal obligations. It is advisory in nature, informational in content, and is intended to
assist employers in providing a safe and healthful workplace
The
Occupational Safety and Health Act requires employers to comply with
hazard-specific safety and health standards as issued and enforced by either the
Federal Occupational Safety and Health Administration (OSHA), or an OSHA-approved
State Plan. In addition, employers
must provide their employees with a workplace free from recognized hazards
likely to cause death or serious physical harm under Section 5(a)(1), the
General Duty Clause of the Act. Employers
can be cited for violating the General Duty Clause if there is a recognized
hazard and they do not take steps to prevent or abate the hazard. However, failure to implement these recommendations is not in itself, a
violation of the General Duty Clause. Citations
can only be based on standards, regulations, and the General Duty Clause. |
Technical Information
Types of Thermal Desorption Units
Thermal desorption units are
commonly divided into high temperature and low temperature units. Low temperature units operate between 200oF and 600oF
and are used to treat halogenated and nonhalogenated volatile organic
compounds (VOCs), and petroleum hydrocarbons.
High temperature units operate between 600oF and 1,000oF
and are used to treat VOCs, semi-volatile organic compounds (SVOCs),
polyaromatic hydrocarbons (PAHs), polychlorinated biphenyls (PCBs),
pesticides, coal tar wastes, creosote, paint wastes, and mixed wastes.
The
configuration of a unit–including the primary treatment unit, pretreatment
equipment and air pollution controls–will vary according to the contaminants
and the type of material being treated. The unit may be operated under a
vacuum and/or low oxygen conditions to lower heat requirements and reduce the
likelihood of forming dioxins, furans, and flammable conditions.
Thermal desorption units can also be grouped into three process
types: directly-heated units, indirectly-heated units, and in-situ units.
The
process type is based on the primary treatment unit used in the system.
Directly-heated units use a fuel burner (internal or external to the
primary treatment unit), a fluidized bed, or an irradiation source to heat the
contaminated feedstock or the air/gas coming in contact with the feedstock. Indirectly-heated units use a fuel burner to heat a transfer medium,
which heats a surface (generally metal) that comes in contact with the
contaminated feedstock. In-situ
units heat contaminated soil in place using vertical wells installed in the
ground and filled with steam, hot air or a mechanical heater.
Directly- and indirectly-heated desorption systems use pretreatment and material handling systems to size and
condition feedstock prior to entering the PTU. Equipment like vibrating screens, rock crushers, hammer mills,
shredders and mixers are used to screen, separate, and size the feedstock. Conditioning generally refers to
removing excess water. Equipment like drying beds, belt filter presses, centrifuges, and blending equipment
can be used to dewater and condition feedstock. Material handling equipment is used to move feedstock into,
through, and out of the entire treatment system. Material handling equipment can include feed hoppers, augers,
and conveyors.
All three systems require air pollution control devices to remove contaminants from the water and air emitted.
Dust and particulate can be controlled with cyclones, baghouses, or venturi scrubbers. Small amounts of acid
vapor might require scrubbing. Residual organic compounds can be condensed and/or captured in activated carbon
adsorption units or oxidized in a thermal oxidizer or afterburner.
Directly-heated desorption systems:
Common primary treatment units for this type of system include rotary kilns
(dryers), aggregate dryers, and conveyor furnaces.
In each of these units, contaminated feedstock enters a heating chamber
and is heated (flame or hot air/gas) while passing through. Both the rotary and aggregate units agitate the feedstock by revolving,
and most have internal mechanisms (flights) that lift and move the feedstock.
Conveyor furnaces use a conveyor or belt to move the material through
the unit while exposing it to heated air/gas. Directly heated desorption systems can be used for both low and high
temperature applications.
Indirectly-heated desorption systems:
Common primary treatment units for this type of system are rotary kilns
(dryers) and thermal screws. Indirectly-heated
rotary kilns are similar to their directly heated counterparts, but the
surface of the heating chamber drum is heated rather than the chamber itself.
The thermal screw has hollow augers that are filled with hot oil,
molten salt or steam, and are used to mix, move and heat the feedstock.
Indirect heating produces a lower volume of off-gas, resulting in lower
loading for the off-gas treatment and air pollution control systems. Indirectly-heated desorption systems can be used for both low- and
high-temperature applications, although thermal screw systems are typically
limited to low temperature applications.
In-situ steam extraction: This technology is
most applicable for contaminants near the surface, where vacuum extraction is
less effective. With this type of
system, vertical wells are installed with heaters or are injected with steam
or hot air to heat contaminated soil in place and volatilize contaminants. The volatiles are collected under vacuum in a shroud at the surface.;
Some removal of semivolatiles may also take place. |
Typical High Temperature Thermal Desorption Process
Source: Federal Remediation Technologies Roundtable
|
Typical Low Temperature Thermal Desorption Process
Source: Federal Remediation Technologies Roundtable |
Residual Material and Waste Streams
The operation of thermal desorption units can create different residual streams:
- treated material,
- oversized material rejected during pre-treatment,
- condensed contaminants and water,
- dust from particulate control system,
- clean off-gas, and
- spent carbon (if used).
Several of these streams may be recycled or reused in the process. For example, systems often recycle contaminant free condensed water
and use it to suppress dust emitted from the treated feedstock exiting the system. Scrubber purge water that has been treated in a site
wastewater treatment facility (if available) may also be used to suppress dust or can be discarded into the sewer. Often, the concentrated
condensed organic contaminants are containerized for further treatment and recovery. The dust collected from a baghouse or cyclone can be
mixed with the contaminated feedstock for conditioning. Alternatively, this dust can be mixed with the treated feedstock and backfilled
onsite if it is free of contaminants. Spent carbon can be recycled by the supplier or other processor. Finally, the clean off-gas is
released to the atmosphere.
Site Requirements
Mobile thermal desorption units are usually transported on specially adapted flatbed trailers. Space requirements typically are less than
50 feet by 150 feet, exclusive of materials handling and decontamination areas. Standard 440V, three-phase electrical service is required,
and water must be available at the site. Storage is needed to hold the process residuals until they are tested to determine their acceptability
for disposal or release. An area to accumulate and store contaminated waste for treatment may also be necessary. Often, on-site laboratory
analysis must be available to determine the organic components in the treated medium for performance assessment. These data can also be used to
evaluate decontamination effectiveness and PPE performance.
Description of Hazards
Thermal desorption units, like many types of industrial equipment, pose hazards to workers. If these hazards are properly evaluated and controlled,
the technology can be used safely. However, Task Force site evaluations indicated that hazards associated with treatment technologies were often
overlooked, particularly during maintenance operations. As a result, workers are often exposed to unanticipated safety hazards and receive unexpected
exposure to site contaminants while working in and around treatment technology.
Common health and safety hazards associated with thermal desorption
are highlighted in Table 1. The hazards listed are associated with the technology
itself, with site-specific contaminants, and with related work operations. Table 1 also lists possible control measures and identifies related health
and safety standards.
To minimize or eliminate the hazards of thermal desorption operations, an employer should evaluate each phase of unit operation: installation,
operation, maintenance, and disassembly. The employer should also evaluate how the equipment hazards may vary with a site-specific unit configuration
and set of contaminants. If the thermal desorption unit is part of a process covered under the Process Safety Management of Highly Hazardous Chemicals
(PSM) standard, 29 CFR 1910.119, the employer must compile written process safety information to identify and evaluate the specific hazards associated
with the process. The employer must also develop a process hazard analysis (PHA), develop and implement written operating practices for safely
conducting process work activities, and provide process-specific employee training. Regardless of the standard’s applicability, the hazard analysis
techniques described in the PSM standard could help an employer write the technology-specific operating practices and improve worker protection. Another
possible approach to organizing technology hazard information is the Technology Safety Summary, described in the next section.
Table 1. COMMON THERMAL
DESORPTION HAZARDS,
CONTROLS & RELATED STANDARDS |
Hazard |
Sources of Exposure |
Control Methods |
Related OSHA and
Industry Standards |
Process Chemicals |
- Splashing or leaking caustic while transferring it to the air pollution scrubber, from pipelines and storage containers,
or while unloading it
- Leaking fuel (propane, fuel oil) from pipelines, storage containers (outside and inside unit), or while unloading it
into a storage container
- Responding to an emergency release of process treatment chemicals or fuel
|
- Use and store smaller quantities of process chemicals
- Use proper storage containers, and inspect both the containers and pipelines for leaks and damage
- Install eye wash and emergency shower
- Prepare and train for spill containment
- Ensure use of PPE when necessary
|
OSHA Standards: 29 CFR 1910.1000 to
1910.1052, 1926.55, 1926.62, 1926.1100 to 1926.1152 (Air Contaminants);
29 CFR 1910.132 to 1910.138, 1926.28, 1926.95, 1926.96, 1926.100 to
1926.107, (Personal Protective Equipment); 29CFR 1910.1200, 1926.59
(Hazard Communication)
See Fire and Explosion for OSHA Standards and Consensus Standards
addressing Flammable Materials, like fuel.
Industry Standards: ACGIH -
2002 Threshold Limit Values (TLVs) and Biological Exposure Indices (BEIs) |
Site Contaminants |
- Off-gassing or releasing contaminants as feedstock is loaded, sized,
blended, and moved Releasing emissions from
treatment process
- Releasing or coming in
contact with contaminants in feedstock while working on equipment
- Releasing or coming in contact with
contaminants (metals, excluding mercury) that are not desorbed while
sampling, handling or backfilling treated feedstock
- Releasing or coming in contact with contaminants that are not
desorbed while removing and containerizing waste from air pollution
controls
|
- Use negative pressure in the unit to decrease fugitive emissions
- Work "up-wind" of disturbed soil,
when possible
- Segregate treated
feedstock until tested
- Routinely monitor work
areas; some contaminants require an initial assessment of exposure
(e.g., lead)
- When possible,
spray-off or remove feedstock and slag before working on equipment; do
not use compressed air
-
Contain treated feedstock
- Ensure workers use proper
PPE, when necessary
|
Same as above |
Process Waste
Materials |
- Removing and containerizing waste materials from an air pollution
control device
|
- Use the applicable controls listed for Process Chemicals, Site
Contaminants, and Dusts
|
Same as above |
Dust |
- Moving feedstock to load and unload unit
- Releasing dust while
working on air pollution equipment
- Releasing untreated
and treated feedstock, or blending material (sand), from stockpiles or
bins
- Sizing, blending, and
moving untreated feedstock using vibrating screens, crushers, shredders
or other pretreatment equipment
- Removing and containerizing dust from air
pollution equipment
-
Releasing dust while working
on/replacing refractory material in the firebox or desorber
|
- Spray water or use dust suppressants on storage piles and exposed
feedstock
- Do not operate earth moving equipment during high winds Cover untreated and
treated feedstock or keep the quantity to a minimum
- Where possible, enclose sizing, blending, and moving equipment like
screens, crushers, shredders, and conveyors
- Clean surfaces before doing maintenance
- Ensure workers use proper personal protective equipment (PPE), when
necessary
|
Same as above |
Ergonomic Risks |
- Lifting or performing any other movement with too much force and/or
in an awkward position, or repeating the lift/movement too often.
|
- Provide conveniently located equipment for the job, like carts,
adjustable work stations (operators), and correctly sized tools
- Train workers on ergonomic risks and
prevention
|
OSHA Standard: No Related Standard
Industry Standards: ACGIH -
2002 Threshold Limit Values (TLVs) for Hand/Arm Vibration, draft ANSI
Z365: Management of Work-Related Musculoskeletal Disorders |
Thermal Burns |
- Coming in contact with slag that appears to be cool
- Coming in contact with hot surfaces on high-temperature equipment
- Coming in contact with high temperature steam from an In-situ Steam Extractor
- Coming in contact with hot ash/residue that is removed from the desorber
- Coming in contact with the containers used to store treated feedstock or residue
|
- Perform a Job Hazard Analysis
- Ensure use of engineering controls (e.g., guards), lockout/tagout
procedures, work practices (e.g., wait until cooled to certain
temperature) and/or personal protective equipment (e.g., heat resistant
clothing, face shields, gloves, boots, hard hat) to prevent burns
- Insulate accessible
surfaces of high-temperature equipment
- Label hot surfaces and
identify them during training
|
OSHA Standards: 29 CFR 1910.132/1926.21
& 1926.28, 29 CFR 1910.138(PPE); 29 CFR 1910.145
(Specifications for Accident Prevention Signs and tags); 29 CFR 1910.147
(Lockout/Tagout)
Industry Standards: equipment-specific standards exist |
Electrical Hazards |
- Working with standard 440V, three-phase electrical service
- Using ungrounded or unguarded electrical
equipment
- Working on or testing
an electrical system or any electrically powered equipment without
properly locking/tagging out energy sources
- Touching (worker or
equipment operated by worker) underground and aboveground utilities
|
- Implement lockout/tagout procedures
- Allow live testing only by employees that are properly trained and
qualified
- Ensure workers use
proper electrical work practices (i.e., those in 1910.333)
- Ensure workers use proper electrical
protective equipment and insulated tools while working live
- Locate and mark any underground utilities
- Ensure proper clearance
between power lines and elevated equipment (e.g., crane or drill rig
booms, scaffolding, etc.) and designate an observer
- De-energize utilities, when necessary
- Install ground-fault circuit interrupters (GFCI) when feasible
- Routinely inspect
electrical cords and equipment
|
OSHA Standards: 29 CFR 1910.137 (PPE); 29
CFR 1910.333 (b)(2)/1926.417 (Lockout/Tagout); 29 CFR 1910.301 to
1910.399/1926.400 to 1926.449 (Electrical Safety); 1910.269/1926 Subpart
V (Electrical Power Generation, Transmission, and Distribution)
Industry Standards: ANSI
Z244.1-1982 Personal Protection Lockout/Tagout of Energy Sources; NFPA
70: National Electric Code |
Confined Space Entry |
Entering heating chamber, fuel burner, bag house, or other
equipment on the unit that is a permit-required confined space. Note: Spaces that may
contain a hazardous atmosphere (e.g., oxygen deficient, explosive), have
physical hazards (e.g., falling material, heat, entrapment), and/or have
mechanical hazards (e.g., moving parts) are considered Permit Required
Confined Spaces. |
- Require a permit for entry
- Test atmosphere (oxygen first)
- Lockout/tagout any electrical and
mechanical equipment and isolate any chemical/steam lines
- Provide natural or forced ventilation
- Ensure use of PPE, like heat resistant and
flame retardant materials Train employees to recognize
and control the hazards of a permit-required confined space
- Make sure employees understand the permit
system
- Plan and prepare for
rescue
|
OSHA Standards: 29 CFR 1910.146/1926.21 and
1926.353 (b) (Permit-Required Confined Spaces)
Industry Standards: ANSI Z117.1-1995 Safety Requirements for
Confined Spaces |
Fire and Explosion |
- Leaking or emitting stored fuel from damaged storage containers or
pipelines, or while transferring it to a storage container
- Overheating fuel tanks
- Leaking or emitting stored flammable
liquids recovered from the desorber or pollution controls
- Operating without using a proper vapor
inerting system or inert purge gas, or when these systems fail
- Operating the heating chamber at
temperatures above its rated temperature
- Mixing feedstock containing flammable contaminants with enough air
to reach the lower explosive limit
|
- Forbid smoking and open flames in the area
- Prevent combustibles (e.g., paper, trash) from accumulating
- Routinely monitor the area if highly
flammable materials are present in the feedstock
- Use controls to prevent unit from operating above a set temperature
or without the inerting gas
- Provide appropriate fire suppression systems and/or equipment
- Train workers in fire prevention
|
OSHA Standards: 29 CFR 1910.106/1926.152
(Flammable and Combustible Liquids); 29 CFR 1910 Subpart L and 1926
Subpart F (Emergency Action, Fire Protection and Prevention); 29 CFR
1910.110/1926.153 (Liquefied Petroleum Gas); 29 CFR 1910.119/1926.64
(Process Safety Management)
Industry Standards: NFPA 1(Fire Prevention
Code); NFPA 10 (Portable Fire Extinguishers); NFPA 30 (Flammable and
Combustible Liquids Code); NFPA 55 (Storage, Use and Handling of
Compressed and Liquefied Gases in Portable Cylinders); NFPA 58 (Storage
and Handling of Liquefied Petroleum Gases); NFPA 325 (Fire Hazard
Properties of Flammable Liquids, Gases, and Volatile Solids) |
Mechanical |
- Contacting or becoming entangled in moving/ unguarded equipment
like conveyor, hollow screw mixer, belts, chains, gears, moving parts
with protrusions, etc.
- Working on any of this
moving equipment without isolating the energy source
|
- Place guards during operation
- Train workers on hazards, use of guards,
who may remove guards, and how to remove guards
- Ensure use of lockout/tagout procedures for maintenance
|
OSHA Standards: 29 CFR 1910 Subpart O
(Machine Guarding); 29 CFR 1910.147 (Lockout/Tagout)
Industry Standards: equipment-specific standards exist |
Flying Particles and Falling Material |
- Getting dust into the air from moving equipment or from high winds
- Falling slag or
loosened refractory material in unit
- Falling feedstock, from conveyors and other moving equipment
|
- Perform a Job Hazard Analysis
- Ensure workers use proper PPE, if necessary
- Spray water or use dust suppressants on
feedstock piles and exposed soil
- If possible, remove
slag and loose material before working on or in unit
- Where possible, enclose sizing, blending, and moving equipment
like screens, crushers, shredders, and conveyors
|
OSHA Standards: 29 CFR 1910.132/1926.21
& 1926.28, 29 CFR 1910.133/1926.102, 29 CFR 1910.135/1926.100, 29
CFR 1910.136/1926.96 (PPE)
Industry Standards: ANSI
Z87.1-1989 (R1998): Practices for Occupational and Educational Eye and
Face Protection (reaffirmation); ANSI Z89.1-1997: Industrial Head
Protection (revision of ANSI Z89.1-1986); ANSI Z41-1991: Foot Protection |
Noise |
- Working near feedstock sizing/blending equipment, material handling
equipment and air pollution control devices
- Working near air blowers, pumps and fuel burners
- Using powered hand tools, compressed air,
welding equipment or any other equipment that creates noise while maintaining process equipment
|
- Locate noisy operations away from other workers
- Isolate or insulate
noisy equipment components
- Identify and mark
areas requiring hearing protection
- Implement a Hearing Conservation Program
|
OSHA Standards: 29 CFR 1910.95; 29 CFR
1926.52 and 1926.101 (Occupational Noise Exposure and Hearing
Protection)
Industry Standards: ACGIH - 2002 TLVs and BEIs |
Slips, Trips and
Falls |
- Storing construction materials or other unnecessary items on walkways and in work areas
- Creating and/or using wet, muddy, sloping, or otherwise irregular walkways and work surfaces
- Constructing and/or using improper walkways, stairs, or landings or damaging these surfaces
- Creating and/or using uneven terrain in and around work areas
- Working from elevated work surfaces and ladders
- Working in confined spaces
- Using damaged steps into vehicles
|
- Keep walking and working areas free of debris, tools, electrical
cords, etc.
- Keep walking and
working areas as clean and dry as possible
- Install handrails, and
guardrails on work platforms
- Clean and inspect
ladders and stairs routinely
- Perform a Job Hazard
Analysis
- Ensure workers use
proper PPE, including fall arrest systems
- Train workers on fall hazards and use of
ladders
- Use an observer (spotter or signal person) when visibility is limited
|
OSHA Standards: 29 CFR 1910.22, 1926.25
(Housekeeping); 29 CFR 1910.23 to 1910.30, 1926.104 to 1926.105, 1926
Subpart M, 1926.1050 to 1926.1053 (Work surfaces, Stairways and
Ladders); 29 CFR 1910.132/1926.21 & 1926.28, 1926.500 to 1926.502 (PPE,
Fall Protection)
Industry Standards: equipment-specific standards exist. |
Moving Vehicles |
- Moving and stockpiling untreated and treated feedstock using earth
moving equipment
- Loading and unloading unit using heavy equipment
- Receiving and
transferring process chemicals and other materials from commercial
vehicles
- Establish vehicle inspection
schedules and procedures
|
- Train affected employees on limitations of equipment and drivers
- Train equipment and
vehicle operators in safe operation
- Set acceptable speed
limits and traffic patterns Ensure that equipment
has, and workers use, back-up alarms, mirrors, and seat-belts
- Set parking brake and if on incline, chock
wheels
- Ensure equipment has required roll-over equipment
- Do routine maintenance
|
OSHA Standards: 29 CFR 1910.176, 1910.178
to 1910.184 (Materials Handling and Storage); 29 CFR 1926.600 to
1926.604 (Motor Vehicles, Mechanized Equipment, and Marine Operations).
Industry Standards: equipment-specific standards exist |
Recommendations
Use Table 1 (Common Thermal Desorption Hazards, Controls & Related Standards) to identity hazard controls applicable to your
site and thermal desorption unit. Evaluate operation and maintenance tasks planned for the unit, identify the hazards site workers
may encounter, and implement the recommended controls appropriate. Consider developing a TSS, described below, to document the hazards
and controls, and communicate them to site workers.
Developing a Technology Safety Summary (TSS)
The TSS provides a format for documenting and communicating a technology’s health and safety hazards and their control. In its most
complete form, the TSS contains a blend of manufacturer and site-specific information. For example, the manufacturer would document
the components of the technology and its method of operation, identify key shut-off and emergency procedures, and list the hazards
from operating and maintaining the equipment such as hazardous energy sources, confined spaces, pinch points, elevated work platforms,
and noise sources. The manufacturer would also identify the installed or recommended controls. Using a manufacturer’s
TSS, the end
user (a site employer) would add site-specific information, including hazards that may arise from a particular configuration of the
equipment, from site contaminants and from other chemical and physical hazards present at that location. The resulting document should
be an accurate description of the hazards inherent in the technology and specific to its operation on site, and the controls used to
reduce or eliminate these hazards for worker protection. Please see the sample TSS format and instructions attached to this bulletin.
By preparing an accurate TSS, a manufacturer can provide an end user with the information necessary to operate and maintain a technology
safely. In addition, the manufacturer may be able to identify and reduce hazards before a technology is marketed, providing safer
technology to consumers. Ultimately, however, the employer is responsible for evaluating and controlling worksite hazards and
communicating this information to employees. In the event that a manufacturer does not provide a TSS or its equivalent for site
remediation technology, the employer should assume full responsibility for documenting a technology’s hazards and their control,
and for communicating this information to employees. The information in the TSS is essential for the completion of several elements
of the site-specific health and safety plan, including the job hazard analysis, personal protective equipment program, air monitoring
procedures, site control, emergency response plan, and procedures for confined space entry and spill containment,
identified in 29 CFR 1910.120(b)(4)(ii)(A-J) or 29 CFR 1926.65 (b)(4)(ii)(A-J). This information is also a key element of site-specific
employee training.
For Comments and More Information
For assistance in understanding the regulatory information presented, please contact a local OSHA Area Office.
For assistance evaluating thermal desorption unit hazards, implementing suggested controls, or completing the sample
TSS, please contact a local Consultation Office.
These offices provide free services to small businesses and are separate from OSHA’s inspection and enforcement effort.
To comment on the TSS format, please contact
Rundman.Sven@dol.gov.
For more information about EPA/OSHA safety and health audits of hazardous waste remediation sites, please see the audit report posted on OSHA’s website.
SOURCES
de Percin, Paul L. 1991. Thermal Desorption Attainable Remediation Levels. In: Remedial Action, Treatment, and Disposal of Hazardous Waste:
Proceedings of the Seventeenth Annual RREL Hazardous Waste Research Symposium. EPA/600/991/002.
Sudnick, John J. 1993 Thermal Treatment Makes Its Mark. Pollution Engineering. October.
U.S. Environmental Protection Agency. 1991. Engineering Bulletin: Thermal Desorption Treatment. Office of Emergency and Remedial Response and
Office of Research and Development. EPA/540/2-91/008.
U.S. Environmental Protection Agency. 1991. Innovative Treatment Technologies: Overview and Guide to Information Sources. Office of Solid Waste
and Emergency Response. EPA/540/9-91/002.
U.S. Environmental Protection Agency. 1997. Engineering Forum Paper: Soil Vapor Extraction Implementation Experiences. Office of
Emergency and Remedial Response. EPA/540/F-95/030.
Online Resources
OSHA Standards and Compliance Information and Tools. http://www.osha.gov.
U.S. Army Corps of Engineers. 1996. Thermal Desorption. Hazardous, Toxic, Radioactive Waste Division ETL1110-1-173
http://www.usace.army.mil/inet/usace-docs/eng-tech-ltrs/etl1110-1-173/toc.html
U.S. Army Corps of Engineers. 1999. Engineering and Design - Safety and Health Aspects of HTRW Remediation Technologies, Chapter 22,
Low-Temperature/High-Temperature Thermal Desorption. EM1110-1-4007. http://www.usace.army.mil/inet/usace-docs/eng-manuals/em1110-1-4007/toc.htm
Federal Remediation Technology Roundtable. Home Webpage. http://www.frtr.gov/
U.S. Environmental Protection Agency. Technology Innovation Office. Hazardous Waste Clean-Up Information
(Clu-in) Webpage. http://www.clu-in.org/
U.S. Environmental Protection Agency. Technology Innovation Office. Remedial and Characterization Innovation Technologies (REACH-IT)
Webpage. http://www.epareachit.org/index3.html
[Insert Technology Name] Technology Safety
Summary
|
SECTION 1: TECHNOLOGY IDENTITY |
Manufacturer's Name and Address: |
Emergency Contact Name and Phone Number: |
Technology Information: |
Prepared by: |
Date Prepared: |
SECTION 2: MOST SERIOUS HAZARDS |
1) Fire/Explosion:
2) Physical Injury or Death:
3) Acute and Chronic Illness:
|
SECTION 3: HAZARDOUS CHEMICALS |
SECTION 4: EMERGENCY RESPONSE INFORMATION |
Fuel: |
Fire and Explosion Sources: |
Purge Gas: |
Ignition Sources and Shut-off Locations: |
Treatment Chemicals: |
Special Fire Fighting Procedures: |
Feedstock Contaminants: site specific
information |
Chemical Release Sources: |
Fugitive Emissions: |
Chemical Incompatibilities: |
Residual Contaminants in Treated Feedstock:
site specific information |
Chemical Shut-off
Valve Locations: |
Waste Streams (liquid and particulate): |
SECTION 5: TECHNOLOGY INFORMATION |
1) Technology Treatment Process Description:
2)Technology Components:
3) Process Chemicals and Wastes: |
SECTION 6: TECHNOLOGY HAZARDS AND
RECOMMENDED CONTROLS |
CHEMICAL HAZARDS |
Hazard
|
Source
|
Recommended Controls
|
Related Regulatory Standards:
|
Reference Consensus Standards
|
PHYSICAL HAZARDS |
Hazard
|
Source
|
Recommended Controls
|
Related Regulatory Standards:
|
Reference Consensus Standards
|
BIOLOGICAL HAZARDS |
|
Hazard
|
Source
|
Recommended Controls
|
Related Regulatory Standards: |
|
RADIOLOGICAL HAZARDS |
|
Hazard
|
Source
|
Recommended Controls
|
Related Regulatory Standards:
|
Reference Consensus Standards
|
OTHER HAZARDS |
Hazards |
Source |
SECTION 7: POTENTIAL MODIFICATION TO SITE
HEALTH AND SAFETY PLAN |
Element |
Site Health and Safety Plan Modification |
|
|
|
Instructions for Completing the Technology Safety
Summary |
The
TSS can be prepared by the technology manufacturer and the technology end user
(employer). A
manufacturer-prepared TSS will be very useful to the employer, who can then
add site-specific information. The
TSS format is designed to place most critical health and safety information at
the beginning of the document.
Title Bar: Insert the name of the technology your TSS describes, the date the
TSS was prepared, and the name of the person who prepared it.
Section 1: Manufacturer Information - Fill in the manufacturer contact information.
Section 2: Most Serious Hazards - Identify specific serious hazards associated with this
technology. Consider the
categories of hazards listed and describe the specific nature of the hazard
and its source. Some of the
information may be site-specific.
Section 3: Hazardous Chemicals - Identify all of the hazardous chemicals associated with this
technology. Some of this information will be site-specific.
Section 4: Emergency Response Information - Fill in
system information that is critical to emergency response planning and training.
Some of the information will be site-specific.
Section 5: Technology Description - Some of the information will be site-specific.
- Process Description: Describe how this technology treats contaminants. Include the technical aspects of the treatment process and identify the
contaminants it will effectively treat. If
applicable, describe the general flow of the feedstock through the technology
components and critical outcomes for each step. Provide a schematic
illustration of the treatment process, labeling the components and identifying
the feedstock flow.
- Technology Components: Identify the individual technology components. List critical
operating parameters for each component. Include equipment required to support the technology such as air
scrubbers or waste storage tanks.
- Process Chemicals and Wastes: Identify the chemicals used in treatment process and the
types of waste streams generated during treatment. Include information about how the waste streams are recycled back into
the technology or discarded.
Section 6: Technology Hazards and Hazard Controls
- For each hazard associated with this technology, provide the following type of
information. Much of this information will be site-specific.
- Hazard: List specific chemical, physical, biological, and radiological hazards in the
appropriate sections of the TSS. For
chemical hazards, identify the appropriate chemical name and any common name
referenced in other technology-specific documents.
- Source: Identify technology components and/or related activities that may create the
hazard identified and could result in potential exposure to employees. For chemical hazards, identify the technology components where the
chemical is used, stored, created or may be emitted by the technology and/or
related activities that could result in a potential exposure to the employees.
- Controls: Identify the specific engineering controls, work practices and PPE that are
used or will be implemented to reduce exposure to the chemical, physical,
biological, and radiological hazards listed.
Include appropriate equipment-specific procedures like chemical
pipeline isolation procedures or ventilation requirements.
- Related OSHA Standards: Identify the relevant Occupational Safety and Health
Administration (OSHA) standards that cover listed hazards and controls.
- Related Industry Standards: Identify other industry standards (e.g., ANSI, ASTM) that
cover the listed hazards and controls.
- Other Hazards: Identify any other hazards that may be commonly associated with
operating and maintaining this equipment, but are not specifically related the
technology (e.g., using heavy equipment).
Section 7: Potential Modifications to Site-Specific Health and Safety Plan (HASP) - Identify the sections of the HASP that may need
to be modified to address the information in the TSS. List the specific element of the plan that could be affected
and the information that must be addressed. For example, potential emergencies associated with the technology must
be included in the site emergency response plan. That is plan element (H) in the list of HASP elements found
in 29 CFR 1910.120 (b)(4)(ii) or 29 CFR 1926.65(b)(4)(ii). |