NCD122263825_19941228_JFD Electronics - Channel Master_FRBCERCLA SPD_Treatability Study Work Plan Amendment II-OCR

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TREAT ABILITY STUDY WORK PLAN AMENDMENT II·
JFD/CHANNEL MASTER NPL SITE· ,'
Date prepared: December 28, 1994
Prepared for:
.· JFD/Channel Master
Prepared by:
.· Geraghty & Miller Company
Cross: Pointe II .
• 2840. Plaza Place, Suite 350
Raleigh, NC 27612
· Ai:urex ·Environmental. Corporation ·
4915 Prospectus Drive ·
. P:O .. Box 13109
Resea.rch Triangle Park; NC 27709.
McL~ren Hart/Environmental E~gine~ring Corporation . · ..
. National Remediation.Services Group·. · · Acurex.. .
· Environmental
9323 Stockport Place ' '
· . .Charlotie, NC 28273.
·.C O ·R P O .R A. T I :o N
A Geraghty·~ Muter ,Company'
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RECEIVED '
JAN O 6 1995
I suPERFUND SECTION
TREATABILITY STUDY WORK PLAN AMENDMENT II
JFD/CHANNEL MASTER NPL SITE
Date prepared: December 28, 1994
Prepared for:
JFD/Channel Master
Prepared by:
Geraghty & Miller Company
Cross Pointe II
2840 Plaza Place, Suite 350
Raleigh, NC 27612
Acurex Environmental Corporation
4915 Prospectus Ori ve
P.O. Box 13109
Research Triangle Park, NC 27709
McLaren Hart/Environmental Engineering Corporation
National Remediation Services Group
9323 Stockport Place
Charlotte, NC 28273
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TABLE OF CONTENTS
Section
1.0 Introduction
1.1 Site Description ...................................................... .
1.2 Summary of Results of Previous Treatability Study .......................... .
1.3 Need for Further Treatability Testing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
2.0 Objectives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
2. 1 Contaminant Concentration Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
2.2 Technology Feasibility_and Cost Effectiveness Evaluation .................... _. . 6
3.0 Description of Treatment Technologies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
3.1 Acidification, Volatilization and Recovery . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
3 .2 Thermal Desorption . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
3.3 Fenton's Reagent Oxidation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
4.0
5.0
6.0
7.0
8.0
9.0
Bench Scale Experimental Procedures ...................................... .
4.1 Sampling and Analysis .............................................. .
4.2 Acidification, Volatilization and Recovery ............................... .
4.3 Thermal Desorption ............................................... .
4.4 Fenton's Reagent Oxidation ......................................... .
Project Organization and Responsibility .................................... .
Project Schedule
Materials, Facilities and Equipment ....................................... .
Quality Assurance/Quality Control ........................................ .
Safety and Waste Disposal ............................................. .
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TABLE OF CONTENTS (concluded)
Section Page
I 0.0 Data Analysis and Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26
I 1.0 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26
Appendix A-McLaren Hart Safety Manual/Chemical Hygiene Plan . . . . . . . . . . . . . . . . . . . . . 29
Appendix B-Acurex Environmental Corporation Eastern Regional Office-Treatability Laboratory
Safety Manual/Chemical Hygiene Plan .................................. ·. 30
Appendix C-McLaren Hart Environment Engineering Low Temperature Thermal Desorption
Technology Description-Past and Prior Uses of Technology . . . . . . . . . . . . . . . . . . . 31
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Section 1. Introduction
Section 1.1 Site Description
A feasible techniques must be developed to treat approximately 3,000 cubic yards (CY) of soil and
sludge materials from the sludge drying beds at the JFD Electronics/Channel Master (Channel Master)
National Priorities List (NPL) site in Oxford, North Carolina. The purpose of this set of treatability studies
is to evaluate three technologies for the remediation of cyanide at this site. An estimated ten percent of
the (300 CY) of the overall volume is sludge, which is relatively discrete from the contaminated soil. The
contaminated materials (i.e., sludge and soil) are impacted by F006 category wastes, which are defined
as wastewater treatment sludges from electroplating operations except from: I) sulfuric acid anodizing
of aluminum; 2) tin plating on carbon steel; 3) zinc plating (segregated basis) on carbon steel; 4)
aluminum or zinc-aluminum plating on carbon steel; 5) cleaning/stripping associated with tin, zinc and
aluminum plating on carbon steel; and 6) chemical etching and milling of aluminum.
Section 1.2 Summary of Results of Previous Treatability Study
A previous treatability study was conducted during the implementation of the remedial design (RD)
to evaluate the effectiveness of alkaline chlorination, the cyanide destruction remedy specified in the
Record of Decision (ROD). This study was also designed to evaluate stabilization of metals and
chromium reduction, if necessary. This study was performed by Acurex Environmental Corporation
(Acurex) for Geraghty & Miller, Inc. (Geraghty & Miller), the supervising RD contractor. The chemical
analyses were performed by Savannah Laboratories, Savannah, Georgia, and the data validated by
Geraghty & Miller. The study was conducted in accordance with the Treatability Study Work Plan
prepared by OBG Laboratories, and approved by the U.S. Environmental Protection Agency (USEPA) -
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Region IV.
The results of this treatability study 12 indicated that additional treatability testing is required prior
to performing a full-scale demonstration or initiating implementation. The results for the amenable
cyanide concentration in the soils were near the performance requirement of 30 mg/kg. However,
additional analyses were suggested to verify these concentrations and to establish consistency in the
results. The total cyanide concentration of the treated and untreated soil was below the performance
requirement of 590 mg/kg. The unconfined compressive strength limit for the selected mixture of 90
percent soil combined with IO percent Type I portland cement was below the prescribed performance
standard of 20 psi; however, a longer curing timing or a higher reagent/soil ratio would be expected to
mitigate this limitation. This mixture did successfully stabilize nickel to below the TCLP based standard.
All other metals in the soil were below primary limits prior to treatment.
The cyanide destruction of sludge was not as successful. Total cyanide concentrations ranged from
4600 mg/kg to 5500 mg/kg before treatment and were 1400 mg/kg to 1900 mg/kg after treatment, well
above the performance requirement for total cyanide (590 mg/kg). The amenable cyanide concentrations
were 4600 to 5500 mg/kg before treatment and <3.1 mg/kg and 320 mg/kg after treatment, a broad range,
with the performance requirement established at 30 mg/kg. In addition, mixing and materials handling
difficulties were experienced with the sludge. Sodium hexametaphosphate was added as a dispersion agent
to improve the contact between the sludge and the oxidizing agent, without a significant advance in
performance. It was hypothesized that the clayey nature of the soil and the plasticity of the sludge may
have prevented good contact between these materials and the oxidizing agent.
A report addendum 13 was written to present additional results from later phases of this treatability
study. The results discussed in the addendum are from a second sludge oxidation experiment carried out
under a submitted but not yet approved work plan amendment. During this additional test of cyanide
oxidation by alkaline chlorination several modifications were made to improve the effectiveness of the
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process. The amount of sodium hypochlorite added was increased several fold over the amount used in
testing under the original workplan (the amount of oxidant used in testing under the original workplan was
regulated so as to maintain a measurable excess). A dispersing agent, sodium hexametaphosphate, was
used to break-up the sludge in solution. In the first sludge oxidation experiment, mixing was conducted ·
using a shaft and a 64 mm multi-paddle agitator or a heavier duty shaft and larger stirrer blade (134 mm).
During this second sludge oxidation experiment the bench scale oxidation was performed in the bowl
of a Hobart mixer (Model AS-200-F mixer, 1/3 HP) which has a complex stirring motion that covers a
large percentage of the vessel. Oxidation of the sludge in this experiment was by a two stage alkaline
chlorination process. Thus oxidation was performed at a pH of greater than 12 s.u. for an initial period
of two days, followed by a lowering of the pH to 8.5 -9.5 s.u., using sulfuric acid, and a further period
of 5 days of second stage oxidation.
The results presented in the addendum still indicated that additional treatability testing was required
prior to performing a full-scale demonstration or initiating implementation. The results for total cyanide
concentration in the sludges ranged from 550 mg/kg to 600 mg/kg, very near the performance requirement
of 590 mg/kg. However the concentration of amenable cyanide ranged from 25-150 mg/kg with the
performance standard at 30 mg/kg.
The stabilization and possibly reduction testing envisioned under the original workplan for the sludge
was not completed because the workplan provides that;
The treated sludge ( and soil, if treated) will be tested to confirm that the cya11ide co11tent is below the
treatme11t goals ... before proceeding with the remai11ing portion of the treatability program.
Thus, in accordance with the workplan, a more complete destruction of the total and amenable cyanide
than has been achieved in oxidation processes performed to date, will be needed before proceeding with
subsequent phases of the treatability study.
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Section 1.3 Need for Further Treatability Testing
These treatability studies of alkaline chlorination were reviewed for the EPA by PRC Environmental
Management14 who stated "It is likely that the cyanide cannot be completely oxidized because of
formation of iron and nickel cyanide complexes". Additional testing was recommended to evaluate
alternative treatment technologies. Geraghty & Miller has evaluated a large number of potential
technologies for cyanide destruction at this site through communication with vendors, and literature
reviews. Among the technologies evaluated were other oxidation techniques (hydrogen peroxide, ozone,
electrolytic, wet air, and potassium permanganate), thermal desorption, chemical fixation/stabilization, soil
washing, ex-situ vitrification, biodegradation, and acidification/volatilization/recovery. Geraghty & Miller
intends to conduct a series of up to three remedy screening level 15•16 treatability studies to evaluate
thermal desorption, acidification/volatilization/recovery and oxidation by Fenton's reagent (hydrogen
peroxide catalyzed with ferrous iron) since these appear to be the most promising technologies for this site.
Each of these technologies will be tested on two matrices; site soil only and homogenized soil/sludge
(approximately 10 parts soil to part sludge by volume). Thermal desorption and
acidification/volatilization/recovery will be tested first. It these technologies are not proved to be
promising, Fenton's reagent oxidation will be tested.
Section 2. Objectives
Section 2.1 Contaminant Concentration Criteria
The objectives, are to demonstrate treatment techniques for cyanide that are effective, and that can
be extrapolated to a full-scale field application. Specifically, the objectives are:
a) to reduce the total and amenable cyanide levels to the following maximum levels, either in
discrete or mixed materials:
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Total Cyanide (Sludge and Soil)
Amenable Cyanide (Sludge and Soil)
590 mg/L
3Q mg/L;
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Although treatment technologies for metals will not be a focus of this study, the site will eventually
require a set of related treatment technologies to meet these further objectives:
b) . to immobilize metals to meet the following leaching concentrations Toxicity Characteristic
Leaching Procedure (TCLP) extract:
Metals
Antimony
Arsenic
Barium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Vanadium
Zinc
Primary Limit (mg/Lj<l)
0.066
5:2
0.51
0.32
0.072
Secondary Limit(Z)
0.2
40
2
6
0.008
0.005
20
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(I) The primary limits apply unless the study demonstrates, to USEPA satisfaction, that the
limits cannot be achieved.
(2)
c)
The secondary limits may apply, through a Treatability Variance, if the primary limit
cannot be achieved."
to achieve an unconfined compressive strength of at least 20 pounds per square inch (psi)
for the stabilized material when tested in accordance with ASTM D2166 at 7 days of age.
Reduction of the hexavalent chromium component may be required due to oxidation that occurred
during the cyanide destruction (oxidation) process. The waste will be tested to measure the amount of
hexavalent chromium that is present. If a level greater than 100 mg/kg is found, the pretreatment step will
be completed based on the assumption that all or most of the hexavalent chromium will be leached from
the stabilized product. Based on this assumption and the TCLP dilution factor (20: 1 ), 100 mg/kg
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corresponds approximately with the TCLP extract treatment standard of 5.2 mg/1. While not a criterion,
penetration resistance and paint filter tests will also be perforrned on the stabilized material.
Section 2.2 Technology Feasibility and Cost Effectiveness Evaluation
In addition to evaluating these technologies for their ability to meet applicable or relevant and
appropriate requirements (ARARs) this set of remedy screening treatability studies will also be used to
evaluate these technologies for their implementability, cost, and generation of byproduct streams.
Section 3. Description of Treatment Technologies
Section 3.1 Acidification, Volatilization and Recovery
Grosse3 has described the historical, commercial practice of cyanide acidification/volatilization
which used acid, heat and high volumes of air to remove cyanide as hydrogen cyanide gas. This process
has been modified so that a caustic scrubber captures the volatilized cyanide. In this study McLaren/Hart
Environmental Engineering Corp;ration (McLaren/Hart) wishes to demonstrate its modified IRHV-200
Extraction System's applicability and effectiveness in removing cyanide from a soils or sludges matrix
when operated in an acidification/volatilization/recovery mode.
Section 3.2 Therrnal Desorption
Therrnal desorption has been described in an EPA document as "an ex-situ physical separation
technique that transfers contaminants from soil and water to the gas phase. The process uses heat to raise
the temperature of organic contaminants enough to volatilize and separate them from a bed of
contaminated solid waste. Temperatures are controlled to prevent widespread combustion since
incineration is not the desired result."17 A therrnal desorption device is generally followed by one or more
air pollution control devices to capture the volatilized contaminants as well as entrained particulate
matter16,17. Important design parameters in thermal treatment include treatment temperature, time at that
temperature, degree of mixing, sweep gas rate and the moisture content of the treated material 16. Most
thermal desorption devices require that feed material larger then 1.5 in. in size be rejected or crushed
before input. Thermal desorption has been shown to remove cyanides in at least one case 17. In this study
McLaren/Hart Environmental Engineering Corporation (McLaren/Hart) wishes to demonstrate its modified
IRHV-200 Extraction System's applicability and effectiveness in removing cyanide from a soils or sludges
matrix when operated in a therrnal desorption mode. The operating principles and design of this unit are
discussed more completely in Appendix C.
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Section 3.3 Fenton's Reagent Oxidation
Hydrogen Peroxide oxidation is generally perfonned in the presence of an activating agent such
as UV radiation 1, ozone9, UV radiation and ozone1, or catalytic metals such as iron (Fenton's reagent),
nickel or aluminum2. Hydrogen peroxide is one of the strongest available oxidizing agents2·18.
Hydrogen peroxide's application to cyanide in the literature appears to have been limited to dilute
waste streams2. Noyes goes on to state that limitations of hydrogen peroxide include "interference from
other oxidizable species, limited shelf life, inability to effectively oxidize cyanide beyond the cyanate level
and the need for catalysts"2 An EPA document states "Although hydrogen peroxide is considered a
relatively safe oxidant, proper storage and handling is required" 1 another EPA document reports that "The
reaction of hydrogen peroxide with high concentrations of some organic and inorganic wastes can be
strongly exothennic (heat-producing). Wastes containing amines, cyanides, fonnaldehyde, phenols, ferrous
ion or hypochlorite at much greater than 1000 ppm have shown rapid temperature increases and possible
splattering or explosion due to gas evolution"8.
Some insight into the reagent dosages and reaction times that may be necessary may be ·gained
from reports of hydrogen peroxide oxidations of other contaminants in soil and sludge matrices. The
Institute of Gas Technology has reported bench scale studies of hydrogen peroxide oxidation of soils and
sludges for PCB treatment. They found that 2.5-5% H2O2 with 10 mM ferrous sulfate was the most
effective treatment condition4. Oxidation was largely completed in one hour. Watts and coworkers5 used
Fenton's reagent to degrade Octachloro Dibenzo-p-dixoin in soil. They found that the most effective
degradation conditions were 35% hydrogen peroxide with 0.1 mM iron and slight heating (60-80 C).
Destruction efficiency was generally inversely proportional to total organic carbon content. The reaction
was largely complete in 30 minutes. Leung and coworkers6 studied PCE degradation by Fenton's reagent
in a silica sand matrix. Their initial concentrations were 2.1 M H2O2 and 5 mM ferrous sulfate. The
reaction was complete within 3 hours.
Watts and coworkers10 studied the pH dependance of PCP degradation by Fenton's reagent. The
first order rate constant for degradation of PCP spiked onto silica sand was about 0.04 min·1 at pH 2, was
relatively constant between 0.02-0.03 min'1 between pHs 3-5, and ranged between 0.004 and 0.01 min·1
between pHs 6-8. In contrast the first order rate constant for degradation of PCP spiked onto two natural
soils was nearly constant over the Ph range 2-6 but dropped off sharply at higher Phs. They attributed
the faster rates at lower Phs to the increased solubility of iron(II) at low pH and to the rates of reactions
that recycle iron (II). They stated that the preference for conducting the Fenton' s reagent reaction at pHs
of 2-3 is due to the reduced consumption of hydrogen peroxide that occurs at those pHs rather then
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absolute degradation rate of contaminant. Carberry 11 studied the degradation of two PCB isomers at pHs
3 and 6.5. The percent removal at pH 3 was generally at least twice as high as at pH 6.5. Although
Fen ton's reagent is considered to be most active in the pH range of 2.5-3.5 this may be highly problematic
for cyanide treatment due to the potential for the generation of volatile HCN5•6. On the basis of the
literature reports discussed above it appears likely that utilizing Fenton's reagent at pH 6 for the JFD soil
and sludge will yield acceptable oxidation rates while minimizing the risk of volatilizing HCN.
Section 4. Bench Scale Experimental Procedures
Section 4.1 Sampling and Analysis
The analysis methods that will be used are summarized in Table 4.1. Details of sampling and
analysis methods for inorganic parameters are included in the Sampling and Analysis Plan (SAP)
contained in Appendix A of the RD Work Plan. However, these analyses will be conducted at Geraghty
-. & Miller QNQC Level II for these remedy screening level studies. The planned analyses for all three
studies, their objectives and sample size requirements are summarized in Table 4.2.
Moisture Content
TCLP Metals
Cyanides (total, amenable)
Hexavalent Chromium
TCLP Metals
TABLE 4.1 ANALYTICAL METHODS
ASTM 2216
EPA SW-846 1311/60!0/7060/7470/7741
EPA SW-846 9010/9012
EPA SW-846 7195/7196
EPA SW-846 1311/6010/7060/7470/7741
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Table 4.2: Recommended Analyses in Remedy Screening Trcatability Studies per Matrix
Sample Analyzed # and Type of Analysis, Objective of Analysis SoiVSludgc Amount
Method# Sample Size of Soil
Requirement /Sludge
/mmlysl'> Sample
(based on 2x Needed
method (g)
minimum,
not standard
container
' size) (g)
Untn:atcd Soil/Sludge 2 cN· Total and Amenable: Characterize common baseline for all studies, 40 80
9010/9012 confirmation of previous results
Untreated Soil/Sludge 2 TCLP for 13 Metals: 1311 Characterize common baseline for all studies, 200 400
+6010+7470+7421+7740 confirmation of previous results
Untreated Soil/Sludge 2, Moisture Content Charac1erizc matrix used in studies 200 400
Thermal Desorption, Soil/Sludge Measurement every 1-5 Char..icterizc treatment conditions 0 0
During Treatment minutes during treatment.
Temperature, thermocouple
manufacturers instructions
Thermal Desorption, Soil/Sludge 2 CN. Total and Amenable Determine effectiveness of cyanide treatment 40 80
After Treatment 9010/9012
'n1ermal Desorption, Soil/sludge 2 er+<, 7196 Dctcnninc if this oxidative, thermal treatment 50 100
After Treatment system will require additional chromium reduction
as a further treatment step
ThermaJ Desorption, Offgas, after 2, CN. in off gas, Drager !Ube, Determine if the air pollution control device is 0 0
air pollution control device manufacturer's instructions sufficient to control cyanide emissions
Thermal Desorption, Offgas, after Drager tubes for vapor phase To determine if volatile mercury is released 0 0
air pollution control device mercury, manufacturers
instructions
Thermal Desorption, Offgas a total volatile organics Dctt:rmine if volatile organics are released and art: 0 0
before and after the pollution instrument: an OVA or a THC passed through the pollution control device,
control device CEM provide preliminary design/cost information for air
pollution control device
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Sample Am1lyzcd # nnd Type of Analysis, Objective of Anulysis Soil/Sludge Amount
Method# Sample Size of Soil
Rc<1uircmcnt /Sludge
/analysis Sample
(based on 2x Needed
method (g)
minimum,
not standard
container
size) (g)
Thermal Desorption, Air 2 CN. Total and Amenable The objective of this analysis would Pfimarily be 0 0
Pollution Control Device from each matrix 10 try 10 close a crude mass balance on cyanide.
Byproduct (i.e., scrubber liquid, This could potentiaJly be helpful since dependant
carbon trap) on now rates, interferences, emission limits and
other factors the proposed drager tube
measurements of cyanide in the off gas might not
be sufficient. This analysis would also provide an
indication of whether cyanide was breaking
through the scrubber into the carbon.
Acidification, Volatilization and Measurement every 1-5 Characterize treatment conditions 0 0
Recovery, soil/sludge during minutes during treatment,
treatment Temperature, thermocouple
manufacturers instructions
Acidification, Volatilization and 2 CN" Total and Amenable Determine effectiveness of cyanide treatment 40 80
Recovery, soil/sludge after 9010/9012
treatment
Acidification, Volatilization and 2 TCLP for 13 Metals: 1311 Determine if acid treatment successfully leaches 200 400
Recovery, soil/sludge after +6010+7470+7421+7740 out metals. Also will indicate whether acid
treatment treatment makes metals more mobile.
Acidification, Volatilization and 2 cr+6 7196 Determine if Cr+6 treatment will be required after 50 100
Recovery, soil/sludge after this treatment technology
treatment
Acidification, Volatilization and 2, CN" in offgas, Drager tube, Determine if cyanide emissions will occur as 0 0
Recovery, chamber headspace manufacturer's instructions sludge/soil batches are changed
after treatment
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Sample Analyzed # and Type of Analysis, Objective of Analysis Soil/Sludge Amount
Method# Sample Size or Soil
Requirement /Sludge
/analysis Sample
{based on 2x Needed
method (g)
minimum,
not standard
container
size) (g)
Acidification, Volatilization and 2 CN" Total and Amenable l11c objective of this analysis would primarily be 0 0
Recovery. air pollution control to try to dose a crude mass balance mi cyanide.
device (scrubber or impinger) 'ntis measurement might also provide insight 10
liquid the marketability/disposal cost of this stream.
Acidification, Volatilization and 2, total metals, appropriate this analysis will aid in estimating the disposal 0 0
Rccovery, acidic aqueous stream SW-846 methods cost of this stream
Acidification, Volatilization and 2, Volatile Organics: a total This will help determine if addition of acid causes 0 0
Recovery, chamber headspacc volatile organics instrument: a 1empcraturc increase and thus volatilization of
after treatment an OVA or a THC CEM organics that arc released and not captured by the
pollution control device.
Acidification, Volatili:,,ation and 2, Dr.iger Tubes for Mercury to determine if acidification converts mercury to 0 0
Recovery, chamber hcadspace vapor, manufacturer's more volatile forms and if this results in significant
after treatment instructions air emissions when sludge/soil batches arc changed
Acidification, Volatilization and 2. CN .. Drager tube, Determine if their are any residual cyanide air 0 0
Recovery, headspacc over manufacturer's instructions emissions after treatment
soil/sludge several hours after
neutralization
Fcnton's reagent oxidation, Measurement every 15 charactcri"J.t! treatment conditions 0 0
soil/sludge slurry during minutes during treatment
treatment unless determined to be nt:ar
constant, Temperature,
thermocouple manufacturers
instructions
Fcnton's reagent oxidation, 2 CN-Total and Amenable Dctennine effectiveness of cyanide treatment 40 80
soil/sludge slurry after treatment 9010/9012
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Sample Amilyzcd # and Type of Analysi,;, Objccth·c or Analysis SoiVSludgc Amount
Method# S111111,lc Size of Soil
Requirement /Sludge
/analysis Sample
(based on 2x Needed
method (g)
minimum,
not standard
container
size) (g)
Fenton's reagt:n! oxidation, 2 Cr+-6 7196 Determine if Cr+6 treatment will be required after 50 100
soil/sludge slurry after treatment this treatment technology 1
Fcnton's n:agt:nt oxidation, offgas 2, Drager tubes for hydrogen Determine if HCN is given off at the required pH 0 0
cyanide, manufacturer's
instructions
Total, Char.i.clcrization Stage 880
Total, Thermal Desorption 180
Study
Total, AcidiO<.·ution, 580
Volatilization and Recovery
Study
Total, Fcnton's Reagent Study 180
Grand Total 1820
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Section 4.2 Acidification, Volatilization and Recovery
The McLaren/Hart Environmental Engineering Corporation IRHV-200 Extraction system is a high
vacuum desorption system that is normally used to remove Poly-Chlorinated Biphenyls (PCBs) and
Chlorinated Pesticides from soils in a non-oxidative environment. For the purpose of cyanide removal,
a slight modification has been made to the system which will allow chemical dosing of the matrix which
is being treated.
The treatability unit is I/20th the normal size of the standard treatment system (a flow diagram
of this unit is presented as figure 4.1). Comparison charts (Tables 4.3 and 4.4) has been included to
illustrate how the system has been scaled down. The system consists of a vacuum chamber, pump and
sparger. In the treatment chamber or vacuum chamber one cubic foot of soil is loaded into the system
and sealed. The soil is contained inside the vacuum chamber in a tray that has a slotted screened bottom.
The tray sits on a gasketed seal. _ The chamber is pumped down to a vacuum of 29" of Hg and a purge
gas is forced downward through the soil and exits into a manifold. From this manifold this airstream is
forced through a liquid sparger or impinger trap which contains a water/caustic solution. 1.7 cubic feet
per minute (cfm) of sweep gas is moved through the system in this manner and sparged through the
caustic liquid. The gas stream re-enters the chamber and at no time during the treatment process itself
is it exhausted into the atmosphere. However, when soil batches are removed after treatment the reactor
headspace will be in contact with the atmosphere.
Once the soil to be treated is loaded into the system and the vacuum is exerted on the chamber,
a hydrochloric acid solution will be atomized directly over the soil to be treated. This acid mist will be
drawn downward through the soils and will thus change the pH condition inside the chamber. Once the
acidified soil starts releasing cyanide, the cyanide gas will be carried out of the chamber and into the
sparger which will trap and contain the cyanide. A Drager tube will be used to test the atmosphere inside
the chamber to verify that all the cyanide has been adsorbed into the trap. Once this procedure is done
an equivalent amount of a Sodium Hydroxide solution will be atomized over the soils to neutralize the
waste. Table 4.2 describes the samples to be collected from this process. Treatment times, volumes,
chemical usage and purge rates will also be recorded.
It is anticipated that the resulting sparging liquid can be treated to destroy or convert the cyanide
with nearly I 00% effectiveness due to the relative absence of interferences and low volume of solution.
This process however will not be demonstrated as part of this treatability study.
After the initial soil treatment and neutralization has occurred a subsample of the treated material
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14
will be withdrawn, weighed and placed into a sealed container. The sample will be held at room
temperature for I hour. A drager tube sample for hydrogen cyanide gas will then be withdrawn from the
headspace of the sample. The volume of headspace gas above the sample will also be estimated. This
will allow an evaluation of the effectiveness of the neutralization process.
Questions have been raised as to the disposition of excess HCl liquid that might bleed through the
soils. It is not expected that this will occur but if it does the liquid will be trapped in a depressed area
underneath the soil tray. Provision for the analysis of this liquid has been provided in Table 4.2 should
any be available. In the full scale process, any accumulated liquid can be pumped through a glass filter
for particulate removal using a peristaltic pump and the liquid reused as a primary dosing fluid.
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Table 4.3 Dimensional Comparison of Full-Scalerrest Units
8'xl6'x24' l'x2'x6'
12" 3.5"
28" of mercury 28" of mercury
Table 4.4 Functional Comparison of Full-Scalerrest Units
300
5 cubic yards or
135 cubic feet
1.5 million Btu/Hr
1.7
.8 cubic feet
8,000 Btu/Hr
15
-------------------
Temperature
Acid
Atomizer
Base
Atomizer
A
Deoorption
Untt
8
Row lndlca tor
1-ACFM
Figure 4.1
Acidification/ Volalization/ Recovery
Process Flow Diagram
Two Way Valves
Three Way Valve
SB/r4'.)le Loop
PreBBure Indicator
25' to 29' Hg.
Sparger
Carbon Vacuum
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Section 4.3 Thennal Desorption
The McLaren/Hart Environmental Engineering Corporation IRHV-200 Extraction system is a high
vacuum desorption system that is nonnally used to remove contaminants from soils in a non-oxidative
environment. The high vacuum desorption system has been scaled down to I/20th its nonnal size so that
it can be used for treatability studies (a flow diagram of this unit is presented in figure 4.2). A
comparison between the full scale and scaled down unit is presented Tables 4.3 and 4.4. The system
consists of a vacuum chamber, pump and Sparger. One (I) cubic foot of soil will be loaded into the
treatment or vacuum chamber. The system will then be sealed. The vacuum chamber will then be
pumped down to a final vacuum pressure of u 29 inches of mercury. 1.7 cubic feet per minute of sweep
gas will then be passed through the soil and into a caustic sparger. An 8,000 Btu/hr heater will bring the
temperature of the soil to 400° F and maintain it for IO minutes. This sparger will be maintained at 32°
F throughout the process. The air stream will then be passed through a 0.5 pound carbon canister and
exits through the pump.
Reducing the pressure reduces the boiling point of the cyanide compounds or promotes their
dissociation. This will allow the system to be operated at temperatures below 400° F. As the cyanide
becomes volatile it is swept from the vacuum chamber and adsorbed in the sparger liquids. This should
remove the hydrogen cyanide gas from the airstream but if breakthrough should occur any hydrogen
cyanide in the sparger off gas will be trapped on carbon.
After the treatment event the pre-treatment soils, post-treatment soils, condensate and carbon will
be tested for the presence of cyanide (see Table 4.2). The resulting analytical data will demonstrate the
units efficiency, and allow the calculation of an approximate mass balance for each compound. These
results will also demonstrate the effectiveness of the sparger and emissions control system.
-------------------
Temperature
T
Low Temperature
Desorption 8000 BTU'a oi Heat
Unit
F Flow lndcator
1-ACFM/ 20 ECFM
Prelll!lre Indicator
25" to 29" Hg.
Figure 4.2
Thermal Desorption
Process Flow Diagram
/ Three Way Valvr-re----,--,
Sample Loop Condenaor
Sparger Carbon Vacwm
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Section 4.4 Fenton' s Reagent Oxidation
Fenton's reagent will be tested at a pH of 6 ± 0.5 in order to generate acceptable reaction rates
while minimizing the generation of HCN gas. pH will be controlled with lime slurry or dilute sulfuric
acid additions. Oxidation will take place in a thick aqueous slurry phase in a Hobart (or equivalent) mixer
(see Figure 4.3 for a flow diagram). Initial reaction conditions of 10% peroxide and 10 mM ferrous
sulfate (prepared from laboratory grade reagents) for 2 hours will be used. An oxidation-reduction potential
electrode and starch paper will be used to monitor the course of the reaction and additional oxidant will
be added if it becomes depleted. The oxidation reaction will be performed once for each matrix on a 5 -
lO kg scale. The standard means of quenching the Fenton's reagent reaction after the reaction time
(acidification) is not useful in this case. Thus the reaction will be quenched by raising the pH to 8 and
chilling the sample. It may also be possible to avoid the addition of ferrous sulfate by measuring
speciated iron concentrations in the sludge and soil. Careful provisions will be made for the measurement
of hydrogen cyanide in the offgas.
The reactor used in the Fenton' s reagent study will be carefully shielded and vented. A
preliminary beaker scale oxidation will be performed for each matrix with hydrogen cyanide gas
measurement to insure that the reaction can be safely carried out at a larger scale.
The analyses to be performed as part of the Fenton 's reagent treatability study are shown in Table
4.2. The emission rate of hydrogen cyanide gas will be roughly estimated (as in the Treatability Study
Report Addendum of September 16th 13) from Drager tube measurements and the measured flow rate of
the fume hood.
-------------------
Drager Tube
HCN Gae Sampling
Redox
Potential
Meler
pH
Meter
Figure 4.3
Fenton's Reagent Oxidation
Process Flow Diagram
Temp. Measurement ---
Drager
Pump
Agitator
Slurry
Ferrous Suttate Solution
Base Solution
Acid Solution
~-Hydrogen Peroxide
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21
Section 5. Project Organization and Responsibility
Figure 5.1 shows the personnel that will be involved in this treatability study and their
responsibilities. William Doucette will oversee these studies for Geraghty & Miller the supervising RD
contractor and will review the final treatability study report. Christopher Lutes, Acurex Environmental
Corporation, will assist Mr. Doucette will assist Mr Doucette in overseeing all three studies, will conduct
the Fenton's reagent study and prepare the treatability study final report. Jeffrey O'Ham of McLaren Hart
Environmental Engineering will conduct the acidification/volatilization/recovery and thermal desorption
treatability studies and will aid in the preparation of final report sections relevant to these studies.
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Figure 5.1 Project Organization -
Treatability Study Work Plan Amemdment II -
JFD/Channel Master NPL Site
Mr. McKenzie Mallary
Responsible U.S. EPA
Remedial Project Manager Parties
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William H. Doucette Jr. Ph.D.
Geraghty and MIiier
Associate and Project Coordinator
--
Christopher Lutes
Acurex Environmental Corp.
Analytical Chemist
Treatability Laboratory Manager
I I
Acidification, Volitilization, Thermal Desorption Fenton's Reagent and Recovery Jeffrey O'Ham Oxidation Jeffrey O'Ham McLaren Hart Christopher Lutes McLaren Hart Environmental Engineering Acurex Environmental Corp. Environmental Engineering Technical Director Analytical Chemist Technical Director Treatibility Laboratory
I Manager
Charles Kiper, McLaren Hart, Charles Kiper, McLaren Hart, I
Research & Development Research & Development Peter Kariher Services and Execution Services and Execution Acurex Environmental Corp.
I Chemist
Todd Shuping, McLaren Hart Todd Shuping, McLaren Hart Bryant Harrison Treatability Laboratory Chemist Treatability Laboratory Chemist Acurex Environmental Corp.
Chemist
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23
Section 6. Project Schedule
Figure 6.1 outlines the projected treatability study schedule. It is important to note that the
Acidification, Volatilization and Recovery and Thermal Desorption Treatability Studies will be completed
approximately simultaneously. The Fenton's reagent study will be performed if results from these studies
indicate that neither technology is promising.
-------------------
Figure 6.1 Project Schedule -Treatability Study Work Plan
Ammendment II -JFD/Channel Master N.PL. Site
Work Plan Writing,
Review and Revision
Field
Sampling
0
Work Plan
1
Acidification,
Volatilization
and Recovery Testing
Thermal
Desorption Testing
Approval Weeks From Work Plan Approval
I Chemical Analyses
3 5
•
Fenton's
Reagent Testing :
(if needed)
ii Chemical Analyses I
Report Writing
& Data Analysis ''
'
5.5 7 9 10
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Section 7. Materials, Facilities and Equipment
The reagents that are likely to be used in these studies include:
• hydrogen peroxide
• ferrous sulfate
• calcium hydroxide (lime)
• sodium hydroxide
• hydrochloric acid
• sulfuric acid
The laboratory equipment will include, but not be limited to:
• Pilot scale thermal desorption/acidification/volatilization and recovery apparatus
( discussed above)
•
•
•
•
Rotameters
Drager tubes and associated sample pumps
Hobart mixer
Scales
Sample containers
Drying ovens
Health and safety equipment (emergency eyewash, protective clothing, fume
hoods, etc.)
Section 8. Quality Assurance/Quality Control
Data Management and Reporting
The Data Quality Objectives (DQO) will be in general accordance with the US EPA guidance
documents "Guide for Conducting Treatability Studies Under CERCLA"15•16.
QNQC information on the laboratory procedures is included in the Sampling and Analysis Plan
(Appendix A of the RD Work Plan).
Section 9. Safety and Waste Disposal
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The treatability laboratories involved will be responsible for managing all materials resulting from
testing. All treated and remaining untreated waste, and any additional materials (rinsates and residues)
generated during testing, will be stored, lab-packed, and disposed offsite or returned to the site in
accordance with applicable laws and regulations. Details of safety and waste disposal procedures for the
treatability laboratories involved are contained in Appendix A (McLaren/Hart) and Appendix B (Acurex
Environmental Corporation)
Section I 0. Data Analysis and Reporting
The Treatability Study Report will include all study data. It will indicate clearly the conclusions
regarding the selection of a cyanide treatment technology, and shall evaluate the various technology's
effectiveness, implementability, and cost. Conclusions regarding the need for chromium reduction and
stabilization steps after cyanide treatment shall also be clearly stated. The full-scale application of the
combined technologies shall be reviewed, together with discussion regarding key parameters whicfi could
affect full-scale performance.
Section 11. References
I. "Engineering Bulletin: Chemical Oxidation Treatment", USEPA, Office of Emergency and Remedial
Response, EPA/540/2-91/025.
2. Noyes, R. Ed. "Handbook of Pollution Control Processes", Noyes Publications, Park Ridge, NJ 1991.
3. Grosse, D.W. "Review of Treatment for Metal Hazardous Wastestreams" published in Cheremisinoff,
P.N. Ed. "Library of Environmental Science Vol III, Gold Publishers, August I 990.
4. "Superfund Innovative Technology Evaluation: Emerging Technology Bulletin: Institute of Gas
Technology (Chemical and Biological Treatment)" EPA/540/F-94/504, May 1994.
5. Watts, R.J., B.R. Smith and G.C. Miller "Catalyzed Hydrogen Peroxide Treatment of
Octachlorodibenzo-p-dioxin (OCDD) in Surface Soils", Chemosphere, 23(7):949-55, 1991.
6. Leung, S.W., R.J. Watts and G.C. Miller "Degradation of Perchloroethylene by Fenton's Reagent:
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27
Speciation and Pathway", J. Environ Qua!. 21 :377-81 ( 1992).
7. "Mobile Treatment Technologies for Superfund Wastes" EPA 540/2-86/003(f), September 1986.
8. "Systems to Accelerate In Situ Stabilization of Waste Deposits" EPA 540/2-86/002, September I 986.
9. Personnel Communication with Dave Fletcher, Ultrox International
10. Watts, R.J. et all. "Treatment of Pentachlorophenol-Contaminated Soils Using Fenton's Reagent",
Hazardous Waste & Hazardous Materials Vol 7(4):335-345, 1990.
11. Carberry, J.B. "Enhancement of Bioremediation by Partial Preoxidation" in Remediation of Hazardous
Waste Contaminated Soils, D.L. Wise and D.J. Trantolo Eds. Marcell Dekker: New York.
12. Treatability Study Report, JFD Electronics/Channel Master NPL Site, Oxford, North Carolina, July
22, 1994, Submitted by Acurex Environmental Corporation to Geraghty & Miller Inc.
13. Addendum To: Treatability Study Report, JFD Electronics/Channel Master NPL Site, Oxford, North
Carolina, September 16, 1994, Submitted by Acurex Environmental Corporation to Geraghty & Miller Inc.
14. Draft Preliminary Report on the Treatability Study for the JFD Electronics/Channel Master NPL Site,
Oxford, North Carolina, Submitted to Mr. McKenzie Mallary, Remedial Project Manager, North Superfund
Remedial Branch, USEPA, Atlanta Ga., October 13, 1994 by PRC Environmental Management.
15. Guide for Conducting Treatability Studies Under CERCLA, Final, USEPA, EPN540/R-92/071a,
PB93-i 26787.
16. Guide for Conducting Treatability Studies Under CERCLA: Thermal Desorption Remedy Selection,
Interim Guidance, USEPA, EPN540/R-92/074a, PB93-l26597.
17 SITE Technology Capsule: Clean Berkshires Inc. Thermal Desorption System, EPN540/R-94/507a,
August 1994.
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18. Dean, J.A. Ed. "Lange's Handbook of Chemistry", McGraw-Hill, Ns,w York, 1985.
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Appendix A:
McLaren Hart Safety Manual/Chemical Hygiene Plan
29
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MCLAREN/HART ENVIRONMENTAL ENGINEERING CORPORATION
NATIONAL REMEDIATION SERVICES GROUP
TREATABILITY LABORATORY
SAFETY MANUAL/CHEMICAL HYGIENE PLAN
Date Revised: December 1994
Prepared by:
McLaren/Hart Environmental Engineering Corporation
National Remediation Services Group
9323 Stockport Place
Charlotte, NC 28273
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TABLE OF CONTENTS
Section Page
1.0 INTRODUCTION
2.0 SAFETY POLICY
....................................... ' ' ..
...........................................
1
3
3.0 GENERAL SAFETY GUIDELINES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
3.1 PERSONAL PROTECTIVE EQUIPMENT . . . . . . . . . . . . . . . . . . . . . . . 4
3.1.1 Foot Protection (Safety Shoes) . . . . . . . . . . . . . . . . . . . . . . . . . 5
3.1.2 Eye Proteetion .................................. , . 5
3.1.3 Protective Clothing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
3.1.4 Hard Hats . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
3.1.5 Hearing Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
3.1.6 Respiratory Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
3.2 WORK ENVIRONMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
3.2.1 Unattended Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
3.2.2 Electrical Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
3.2.3 Proper Use of Signs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
3.2.4 Equipment Design . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
3.2.5 Selecting and Implementing Hazardous Material Control
Measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
3.2.6 Laboratory Fume Hoods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 O
3.2.7 Work Approval . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
3.3 MATERIAL HANDLING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
3.3.1 Chemicals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
3.3.2 Regulated Materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
3.3.3 Compressed Gas Cylinders . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
3.3.4 Radioactive Materials. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
3.3.5 Hazardous Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
3.3.6 Employee/Laboratory Monitoring . . . . . . . . . . . . . . . . . . . . . . . 14
3.3.7 Employee/Equipment Decontamination Procedures . . . . . . . . . . 14
(continued)
II
TABLE OF CONTENTS (concluded)
Section Page
3.4 PERSONAL HABITS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
3.4.1 Working Alone . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
3.4.2 Housekeeping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
3.4.3 Food . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
3.4.4 Smoking . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
3.4.5 Jewelry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
3.4.6 Hair . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
3.5 MEDICAL SURVEILLANCE ............................... ·. 16
3.5.1 Subpart Z-Toxic and Hazardous Substances . . . . . . . . . . . . . . . 17
3.5.2 Medical Consultation and Medical Examinations . . . . . . . . . . . . 17
3.6 SAFETY AUDITS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
3.7 PERSONNEL TRAINING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
3.8 EMERGENCIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
3.8.1 Flffi ............................................ ~
3.8.2 Employee Injury or Illness . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
3.8.3 Hazardous Chemical Spills . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
APPENDICES:
A-SAFETY CONTROL SHEET OUTLINE
B-SAFETY SHOE REQUEST FORM
C-SAFETY GLASSES REQUEST FORM
D-PROTECTIVE CLOTHING REQUEST FORMS
E-MCLAREN/HART RESPIRATORY PROTECTION PLAN
F-MCLAREN/HART LOCKOUT/TAGOUT PROGRAM
G-MCLAREN/HART HAZARD COMMUNICATION PROGRAM
H-PHYSICAL REQUEST FORM
I-MCLAREN/HART ACCIDENT INVESTIGATION REPORT
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SECTION 1
INTRODUCTION
Mclaren/Hart Environmental Engineering Corporation's National Remediation Services Group
(NRSG) operates offices and a soil Treatability laboratory at 9323 Stockport Place, Charlotte, NC. The
laboratory operation includes:
• Standardized, analytical procedures intended to screen soil samples to determine if they are
amenable to certain-treatment technologies, principally bioremediation
• Bench-and pilot-scale studies to test the effectiveness of various remediation technologies
The types of safety hazards encountered cover the spectrum of chemical hazards associated with
handling hazardous substances (including gases, liquids, and solids) to physical hazards associated with
electricity and broken glassware, as well as slips, trips, and falls.
Adherence to the safety policies and procedures presented herein is the responsibility of each
Mclaren/Hart staff member. Enforcement is shared by all levels of management with guidance from the
Safety Officer {Chemical Hygiene Officer). However, each supervisor is responsible for ensuring that the
employees he or she supervises understand and comply with this manual and other safety policies and
procedures enforced by Mclaren/Hart.
This document is written in general terms to apply to all laboratory activities performed within the
Treatability laboratory. Specific safety procedures for individual projects or classes of routine samples are
detailed in individual project-specific safety control sheets. The project-specific control sheets detail the
standard operating procedures relevant to safety and health considerations that Mclaren/Hart Environmental
employees will follow when working wrth hazardous substances in a laboratory setting. The level of detail
required for project safety control sheets (PSCSs) will be left to the discretion of the ERO Safety Officer.
Regardless of project specttics, all of the policies and guidelines discussed in Sections 2 and 3 will apply
to all work done at McLaren/Hart. The addttional information will supplement these basic concepts.
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SECTION 2
SAFETY POLICY
The safety of each McLaren/Hart staff member and of the general public is paramount. A
concentrated effort shall be made to ensure a safe and healthy work environment and compliance with state
and federal OSHA laws. Staff member compliance with health and safety regulations is a condition of
employment at McLaren/Hart.
3
•
SECTION 3
GENERAL SAFETY GUIDELINES
Safety depends on the people doing the work. Each staff member has the responsibility for his or
her own safety and a moral obligation to safeguard other workers and associates. Anyone who detects a
potential hazard is expected to personally take appropriate control action if the situation permits, or report
the potential hazard to his or her supervisor. Employees who direct the work of others have additional
responsibility for the safety of all -personnel under their direction as well as for themselves. This includes
responsibility for physical safety of facilities, equipment, and materials, use of protective equipment, and
attitude. Setting a good example is fundamental to fulfilling this responsibility.
3.1 PERSONAL PROTECTIVE EQUIPMENT
General McLaren/Hart policies for personal protective equipment (PPE) follow. For specific project
requirements, procedures; etc., refer to the appropriate project safety control sheet (PSCS), the Project Task
Officer, and/or the Safety Officer.
In general, areas requiring the use of protective equipment are clearly marked. It is the Task
Manager's responsibility to ensure that proper PPE is available and used appropriately. Each project shall
furnish necessary protective equipment to perform the job safely. The Safety Officer is available to assist
with the selection of appropriate equipment. It is also McLaren/Hart policy to exhaust all engineering
controls before relying on the use of respirators.
Whatever the protective equipment defined in this document or specific project safety sheets,
laboratory personnel will acquire and use specified PPE. An-inspection program will be implemented by
the Task Manager, and the check list will be maintained in a laboratory notebook and will include at
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least PPE and material storage. Treatability samples will be inspected at least once per week. All
inspection procedures and checklists must be included in the PSCS and approved by the Safety
Officer.
3.1.1 Foot Protection (Safety Shoes)
Safety shoes are provided by Mclaren/Hart on an as-needed basis. Each employee is responsible
for notifying his or her supervisor when replacement of safety shoes is required. A safety shoe request form
is included in Appendix B.
Steel-toe safety shoes are required for all facility operations and construction areas. They are
recommended for laboratory areas, but are required in laboratory areas when work performed involves the
handling of compressed gas cylinders or other heavy items. Open-top shoes or sandals are not permitted
in a laboratory area at any time. Electrical safety shoes are required in high-voltage areas or where electrical
shock is an imminent hazard. When handling cryogenics and/or extremely hot materials, feet and legs
should be protected with appropriate, substantial shoes and trousers or shields. Open-toe shoes, shorts,
and/or skirts are not adequate protection for laboratory work.
3.1.2 Eye Protection
Safety glasses with side shields will be considered the minimum level of eye protection for
"' Treatability Laboratory activities. Other eye protection requirements will be specified in the PSCS.
Safety glasses are provided on an as-needed basis. Goggles will be provided when appropriate.
Each employee is responsible for notifying his or her supervisor when replacement of safety glasses is
required. A safety glasses request form is included in Appendix C.
Visitor's eye protection will be made available at the entrance to the treatability lab. It is the project
Task Manager's responsibility to ensure an adequate and readily available supply.
3.1.3 Protective Clothing
Cloth laboratory coats are required in the Treatability Laboratory unless specified otherwise in the
PSCS. Specific information will be included in PSCSs. A protective clothing request form is included
in Appendix D.
5
Care must be taken to choose appropriate gloves for chemical handling. Laboratory safety control
sheets should include glove recommendations.
3.1.4 Hard Hats
Treatability Laboratory work will not require hard hats unless specttically indicated on the safety
control sheet.
3.1.5 Hearing Protection
McLaren/Hart provides a hearing conservation program in accordance with OSHA regulation 29
CFR 1910.95. The Treatability Laboratory is not a high noise area. As new equipment is added, it
should be evaluated for noise level. Treatability Laboratory workers should contact the Safety Officer
for a review if noise levels increase. The Safety Officer will review noise levels at least annually.
Audiometric testing is included in the health monitoring program.
3.1.6 Respiratory Protection
Respiratory protection is provided to McLaren/Hart employees as required by individual PSCSs
under the supervision of the Safety Officer. Treatability Laboratory personnel will have regular physical
exams to determine if their health level allows the use of respiratory protective equipment if it should be
necessary for a particular project.
As with most personal protective devices, selection of the proper type of respiratory equipment is
of primary concern. Equipment ranges from dust masks to air-purifying cartridge respirators to self-
contained breathing apparatuses. Specific recommendations are available through the Safety Officer.
Having chosen the correct type of respiratory protection. the next step is to ensure proper fit. Faces
are different sizes and shapes requiring different size masks to achieve a complete seal preventing material
from entering the mask. Beards and heavy sideburns make it difficult to achieve a complete seal of mask
to face. Fit tests will be performed by the Safety Officer. It is desirable to store filters and respirators
convenient to the area of use. Protect them from ambient dust and clean and inspect respirators once a
week and after each use. Replace defective respirators immediately. The McLaren/Hart Respiratory
Protection Plan is attached in Appendix E of this document. Employees required to wear respiratory
protection must be familiar with the entire contents of this program.
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3.2 WORK ENVIRONMENT
The following are procedures to help employees enhance the saiety of their work place. Designated
areas for hazardous material use is addressed in each individual safety control sheet.
3.2.1 Unattended Operations
Potentially hazardous equipment or operations shall not be left unattended at critical times. Areas
in which hazardous operations are being performed, including laboratory analysis or permitted facility
operations, must be clearly marked with a sign identifying the hazard, the person in charge of the operation,
and phone number the person can be reached at in case of emergency. Only the person who placed the
sign or someone designated by that person may remove it.
All operations that continue overnight must have posted the names and phone numbers of three
informed persons who may be contacted in case of emergency.
Equipment that may be operated overnight in the Treatability Laboratory includes the respirometer
and the drying oven. No failure modes can be anticipated for this equipment that would cause a signtticant
hazard.
3.2.2 Electrical Safety
Electricity is so pervasive in our world that we tend to ignore the hazards associated with it. These
hazards are increased in laboratory and research situations. Some simple rules help to minimize these risks:
• Use only grounded electrical equipment
• Protect cords from chemical and physical hazards
• Provide sufficient electrical outlets and avoid the use of extension cords
• Identify and label all breaker switches
• Replace frayed or damaged cords.
• Use only UL listed electrical equipment or electrical equipment inspected or built by a licensed
electrician.
Lockout/tagout procedures shall be addressed by each PSCS or in equipment standard operation
procedures. Project lockout/tagout procedures will follow the McLaren/Hart LockoutjTagout Program
7
contained in Appendix F. Employees engaged in lockout/tagout shall follow and understand the
McLaren/Hart program and the individual project requirements.
3.2.3 Proper Use of Signs
Proper use of signs informs transitory people as well as serving to remind others of dangers in their
normal work areas. Restrictive signs such as NO SMOKING, AUTHORIZED PERSONNEL ONLY, and
HEARING PROTECTION REQUIRED are posted where appropriate. Observe these signs. Use informative
signs such as WET FLOOR, PEOPLE WORKING, and TRIP HAZARD to warn personnel of imminent hazards
while implementing permanent solutions to the hazard. Avoid covering a door with signs. A few well-chosen
warning signs on a door are more effective than a collage. Whether or not signs were used to warn others
of a hazard or to warn personnel of the conditions to be met before working in an area, all McLaren/Hart
personnel must comply with warning signs. For example, not wearing safety glasses in an area marked
SAFETY GLASSES REQUIRED is a breech of company policy.
3.2.4 Equipment Design
All equipment must be operated with safety features in place and in working condition. When new
equipment that could potentially pose a significant hazard is designed and Its use could have safety
implications (i.e., could cause injury if improperly designed, installed or operated), a design review must
occur. It is the responsibillty of the Task Manager to notify the Safety Officer of any equipment change or
new design that may have safety implications. It is also his or her responsibillty to arrange for a design
review meeting. Design review meetings will be attended by at least the Task Manager, the Safety Officer,
and two staff members determined to have design background in the area of concern. The Task Manager
(or the designers) will present the design to the group. It will be critiqued, and recommendations will be
made by the attendees. The Safety Officer will approve the final design.
3.2.5 Selecting and Implementing Hazardous Material Control Measures
When preparing lo commence work with a hazardous material within a laboratory, a safety control
sheet defining the use, safety procedures, engineering controls, protective equipment, and hazards of the
hazardous material will be completed by the Task Manager and approved by the Safety Officer. These
control sheets will be prepared on a project-specific basis if an extreme hazard is expected or the nature
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of the contaminants in the sample are unknown. Otherwise generic control sheets standard operation
procedures will cover all analyses by a gNen procedure.
Control measures (e.g., engineering controls) for handling hazardous materials will be subjected to
a design review as discussed above. Extremely hazardous substances will undergo the same procedure.
All hazardous materials will be assigned a designated work area described in the laboratory safety control
sheet. All laboratory work wtth this material shall be limtted to the use and work area designated wtthin the
safety control sheet unless the control sheet is amended for the new use and approved by the Safety Officer.
3.2.6 Laboratory Fume Hoods
The McLaren/Hart Safety Officer will ensure that all laboratory fume hoods are functioning properly
by checking the physical condttion of fume hood internal parts and by conducting semiannual air face
veloctty readings. Treatabiltty Laboratory staff members will ensure that the fume hood is operating before
starting any operation in the hood and will report any problems to the Safety Officer.
3.2. 7 Work Approval
Before laboratory work begins, the Safety Officer-approved safety control sheet must be in place.
If changes in personnel, hazardous materials used, process/equipment, or location occurs, the Task
Manager shall revise the safety control sheet and seek approval from the Safety Officer before commencing
work (see Appendix A}.
3.3 MATERIAL HANDLING
The following sections present general, safe materials handling procedures for laboratory personnel.
lndNidua/ PSCSs should be referenced for hazardous material handling specifics.
3.3.1 Chemicals
It is important that each person working wtth or around chemicals understands the health hazards
associated wtth the use of those chemicals. Each laboratory will maintain material safety data sheets
(MSDSs) for the chemicals in that laboratory and develop safe handling procedures documented in the
PSCS which includes the following:
• Dangerous properties of the hazardous material (physical and chemical)
• Proper handling procedures
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• Toxicity (acute and chronic health effect and target organ[s])
• Appropriate PPE
• First aid procedures
• Spill clean-up procedures
• Waste disposal
A staff member must have approval from the Safety Officer before ordering a new chemical or
increased quanttties of existing chemicals.
The following list of precautions is general in nature and cannot possibly cover all hazards in all
laboratories or research faciltties.
• Read labels on chemical containers and understand all warning information
• Know the chemical and physical properties of the hazardous materials you use
• Understand the safety precautions necessary for the chemical you use and first aid procedures
in case of contamination
• Wear appropriate eye protection (i.e., safety glasses, goggles, face shield)
• Wear appropriate protective clothing, shoes, gloves, respirator, etc.
• Keep appropriate spill ktts available
• Clean chemical spills immediately and report them to your supervisor and the ERO Safety
Officer
• Allow no food or drink in chemical handling areas (e.g., laboratories)
• Never pipet by mouth-use a safety pipet bulb
• Add acid to water (never add water to acid)
• Label all chemical containers wtth proper information
• Dispose of waste promptly (see the Safety Officer)
• Know the location of safety equipment (showers, eye wash fountains, fire extinguishers, and
first aid ktts)
• Store chemicals in proper storage areas and according to compatibility groups
• Store and use compressed gases safely
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Emergency chemical handling information is available from Chemtrec 24 hours a day at
1-800-424-9300. This public service is maintained by the Chemical Manufacturing Association.
Included in Appendix G is the Mclaren/Hart Hazard Communication Program. If you handle
hazardous materials (requisition, receive, ship, store for use, or use) at Mclaren/Hart, you should be familiar
with the contents of the Hazard Communication Program.
3.3.2 Regulated Materials
Regulated materials are received, used, stored, and disposed of in accordance with applicable
federal, state, and local regulations and in accordance with good business and safety practices. If you do
not know, ask the Safety Officer.
All samples received by the Treatability Laboratory are stored in Suite D Warehouse in Building 1.
All treatability samples are logged in the treatability book. Materials removed from a treatability sample are
noted in the log book. The log must include the amount removed, the destination of the material, the date,
and name and signature of the responsible staff member. Staff members inspect the samples daily and
record the inspection in a log book. A member of the safety staff will review the facility weekly.
All waste or unwanted materials are handled through the safety office. Contact Karen Yates or her
designated alternate aboU1 any materials leaving the lab. This requirement includes samples, laboratory
waste, recycle material as well as RCRA regulated waste. All materials from a treatabillty study are wastes.
Each study should include enough information to estimate the kind and amount of waste that will be
generated. The final waste amounts will probably vary from the estimates. As soon as the laboratory staff
are aware of discrepancies, the safety office should be alerted. Whenever feasible, sample materials should
be returned to the origin. The laboratory manager should negotiate the return as part of the work
agreement. Leave an E-Mail message to notify the safety office of materials that are ready for disposal.
Complete a Chemical Adoption Waste Disposal Form to be picked up with the waste materials. The safety
office will pick up materials and place them in the Waste Storage Area.
3.3.3 Compressed Gas Cylinders
Compressed gas cylinders shall be stored and used in the upright position, individually secured and
separate from incompatible gas cylinders. When not in use, compressed gas cylinders shall be capped and
11
secured. When transporting gas cylinders, secure the cap and chain or strap the cylinder to the transport
cart. When the work day is completed, gas cylinder valves should be closed to prevent an unwanted release
of cylinder content.
A cylinder rack is located within the B-suite area being used for the treatability laboratory. Diligent
attempts will be made to minimize the number of cylinders stored on this rack. No flammables will be stored
on this rack.
3.3.4 Radioactive Materials
The McLaren/Hart Treatabiltty Laboratory will not accept radioactive material.
3.3.5 Hazardous Waste
Although the quantities generated are monitored very closely by the project task managers and the
Safety Officer, the generation of hazardous waste is unavoidable considering the type of work performed
at Mclaren/Hart. The methods of generation and disposal comply with all local, state, and federal
regulations and are specified individually with each project's safety control sheet.
The safety control sheet addresses PPE needed when handling hazardous waste, the containers
needed for generation, storage, limltations, and physical and health hazards associated with its generation
and other handling.
The McLaren/Hart protocol for purchasing hazardous materials requiring prior approval by the
Safety Officer has proven to limit the quantity of waste generated through McLaren/Hart operations.
3.3.6 Employee /Laboratory Monitoring
It is the policy of McLaren/Hart to use engineering and operational controls to prevent dangerous
levels of hazardous material in the work place. If a staff members's exposure to a hazardous substance is
believed to exceed published safe exposure levels for that substance or represents a hazard, a monitoring
and evaluation program will be initiated.
If initial monitoring reveals concentrations greater than the action level or in the absence of an action
level the PEL, Mclaren/Hart employees will comply with the exposure monitoring provision of the relevant
standard. If laboratory work involves the use of a hazardous substance covered by a health standard in
Subpart Z of 29 CFR 1910, monitoring provisions for this substance will be outlined in the individual safety
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control sheet for the laboratory in question. The task manager is responsible for ensuring compliance with
the health standard.
McLaren/Hart shall terminate exposure monitoring in accordance with the relevant standard unless
those parties involved (task manager, laboratory employees, and the Safety Officer) agree that exposure
monitoring should continue beyond the scope of the standard.
When a hazardous substance is not affected by an OSHA health standard or when the PEL exceeds
the TLV, the McLaren/Hart Safety Office requires exposure levels to be managed below the TLV.
The Safety Officer shall notify each monitored employee in writing within 15 working days of the air
monitoring results and shall also post the results in those areas where air monitoring was completed. The
Safety Officer will then file all results within the appropriate laboratory file for future reference.
3.3.7 Employee/Equipment Decontamination Procedures
If exposed to a hazardous material through contact, flush eyes or area of the body with water for
15 minutes while removing clothing that may restrict the flow of water to the area of contamination. Medical
attention should be sought through contacting the Safety Officer. If emergency medical attention is needed,
transport the victim to an emergency medical service or call 911 for emergency aid through the local
Fire Department, and then contact the Safety Officer. (See Section 3.6.2 for more information on employee
injury.)
Specttic equipment decontamination procedures are located in individual safety control sheets. All
materials used in the decontamination of equipment shall be disposed of according to local, state, and
federal regulations and EPA/ERC policy when work is performed at the EPA facility.
3.3.B Biological Hazards
No biohazardous waste will be accepted. The microbial populations to be evaluated are almost
without exception the indigenous microbial populations. Any exceptions will be dealt with in project-specttic
safety control sheets.
3.4 PERSONAL HABITS
Safety is everyone's responsibility and your personal habits affect the risks to yourself and those
you work with.
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3.4. 1 Working Alone
Working alone is strictly forbidden for all work with the exception of paperwork. Working alone is
defined as working out of contact with a co-worker (not necessarily a Mclaren/Hart employee). Much of
the work performed by Mclaren/Hart employees requires a "buddy system" to ensure prompt awareness
of safety problems. To work effectively, each employee must be aware of the location and activities of his
or her co-workers.
3.4.2 Housekeeping
Housekeeping is an important part of our safety program. Mclaren/Hart employees are expected
to spend time in cleaning up and maintaining a clean, organized work space. This improves safety, working
conditions, and the quality of work.
3.4.3 Food
· Food and beverages are prohibited in laboratories, pilot plant areas, or any area where chemicals
are stored. Food includes gum and tobacco.
3.4.4 Smoking
. Smoking is not permitted in laboratories, posted areas, areas of hazardous material use, or where
such activity might create an explosion or fire hazard or contribute to the risk of exposure of hazardous
materials.
3.4.5 Jewelry
Rings and jewelry can get caught in moving machinery, conduct electrical current, and interfere with
the removal of hazardous materials you contact. Remove jewelry when appropriate. Loose fitting jewelry
should be avoided. Rings can also tear chemically resistant gloves.
3.4.6 Hair ·
Long hair must be restrained (i.e., tucked into a cap or net or held by a clasp or rubber band) when
working with or around machinery with moving parts or around hazardous chemicals.
3.5 MEDICAL SURVEILLANCE
A Medical Surveillance program is provided through Duke Occupational Health Services for chemical
handlers and people who work in areas where they may potentially be exposed to hazardous materials. A
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baseline physical, scheduled by the Safety Office, will be performed by a licensed physician at the time of
initial employment. The baseline physical will serve as a background from which to monitor (through
periodic follow-up visits) changes in health and/or exposure to hazardous materials thereby alerting the
physician and staff member before permanent damage occurs. Follow-up medical visits will be performed
annually. The Safety Office will keep a record of all physicals and will schedule each employee for a follow-
up physical once per year. If a supervisor feels that an employee needs to have an examination more
frequently, or tt one is required because of a specific exposure incident, the supervisor will fill out the request
form in Appendix H and submit it to the Safety Officer.
3.5.1 Subpart Z-Toxic and Hazardous Substances
When the work performed by employees includes the use of hazardous materials listed in
29 CFR 1910 Subpart Z, medical monitoring will be conducted as listed in the individual health standard.
3.5.2 Medical Consultation and Medical Examinations
Mclaren/Hart shall provide all laboratory employees who work with hazardous chemicals an
opportunity to receive medical attention, including any follow-up examinations that the examining physician
determines to be necessary, under the following circumstances:
• Whenever an employee shows signs of acute or chronic exposure effects to a hazardous
chemical he or she has worked with
• Where air monitoring results reveal air contaminants routinely above the action level (or, in
absence of an action level, the PEL} McLaren/Hart shall establish medical surveillance for the
employee as prescribed for the particular health standard
• Whenever an event takes place (spill, leak, explosion, or other occurrence resulting in an
employee's possible exposure to a hazardous chemical), McLaren/Hart shall provide the
employee with the opportunity for a medical consultation. Such consultation shall determine
the need for a medical examination.
All medical examinations and consultations shall be performed by or under the direct supervision
of a licensed physician and shall be provided without cost to the employee, without loss of pay, and at a
reasonable time and place.
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The Safety Office will provide the physician wtth the following information in the event of employee
exposure:
• Hazardous chemical exposed to
• Condttions of exposure, including exposure data, lf available
• Description of signs and symptoms
When a physician consults or examines an employee, the Safety Officer shall obtain a written
opinion from the physician including the following information:
• Results of medical examination and testing
• Recommendation for further medical follow-up
• Any medical condition that may place employee at increased risk as a result of exposure to a
hazardous chemical in the work place
• Physician statement to the employee stating the findings of the consultation or medical
examination that may require further examination or treatment
The Safety Officer shall file all written physician opinions and medical examinations within the
employee's files. The written opinion shall not reveal speclfic findings of diagnosis unrelated to occupational
exposures.
It is important for all employees to alert his or her supervisor and the Safety Officer in the event of
an exposure or potential exposure or any adverse health effects from an exposure to a hazardous material.
A Mclaren/Hart Accident Investigation Report (see Form 19 in Appendix I) shall be completed by each
employee exposed or potentially exposed to hazardous materials (e.g., hazardous material spill).
3.6 SAFETY AUDITS
Safety walkthroughs are performed at least quarterly by the Safety Officer. Discrepancies found
during walkthroughs are pointed out to the responsible staff members. It is the responsibility of the
Project Officer to correct the discrepancies. 11 is the Safety Officer's responsibility to monitor progress
on the safety action items. A monthly check of safety equipment and materials storage will be
documented by the project staff.
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3.7 PERSONNEL TRAINING
Personnel training is essential to the McLaren/Hart safety program. The Safety Officer will meet with
each new staff member during the first 10 days of employment to discuss McLaren/Hart safety program
policies and procedures, including:
• The location of this manual
• 29 CFR 1910.1450 and Its appendices
• Specttic training requirements for laboratory work
The staff member's supervisor (or designated task manager} will provide relevant project-specttic
training when that staff member is assigned to a new area or task. This training will include, but is not
limlted to:
• Relevant reading (PSCS, pertinent instrument manuals, and standard operating procedures}
• Methods and observation used in detecting releases of hazardous materials used in the
laboratory (odor, taste, air monitoring devices, etc.}
• Signs, symptoms, and the PEL's of hazardous materials used in the laboratory
• Instruction by experienced staff member (where indicated}
• Location and availability of hazard information references, including MSDS
• Periodic reviews of safety procedures and protective equipment
• Physical and health hazards of materials used
• Measures employees can take to protect themselves when using hazardous materials
The Safety Officer will also organize and present monthly safety seminars throughout the year. They
will typically include instructions in such topics as chemical handling, fire prevention, electrical safety, etc.
Each McLaren/Hart employee who handles hazardous materials must attend eight hours of safety training
each year to be eligible for work requiring the use of hazardous. materials the following year.
Specific training programs/sessions may also be required in the PSCS. Special programs may
contribute to the required training.
3.8 EMERGENCIES
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Our goal is to prevent accidents and avoid emergency situations. However, when accidents do
occur, prior training and contingency planning can ·significantly reduce the impact of the accident on
personnel, facillties, and the work in progress.
3.8.1 Fire
Small fires can be safely extinguished by trained personnel with the proper extinguisher. While one
person attempts to extinguish the fire, another should call 911 and describe the situation to the fire
department. If there is any doubt of your ability to contain the fire, evacuate the building. Provide all the
information you can to the emergency response team from a safe location. Warning horns are mounted at
each exit. Staff meet on the berm west of our facility to take a head count and assure that all staff members
and visitors are safe.
3.8.2 Employee Injury or Illness
If you are the only person at the scene of an emergency, It is important that you call for help, then
lend appropriate assistance. Never attempt to rescue someone -before donning the proper protection
equipment and requesting the presence of another person. When other people are available, one person
should remain with the injured staff member, administering appropriate assistance. A second person
should call for appropriate help, ei1her through the Safety Officer or in urgent situations through 911,
and describe the situation. When reporting an injury or illness:
• Give your location
• Describe the situation
• Provide any other helpful information
• Stay on the phone until the respondent gives you permission to go
• At the first opportunity, notify the Safety Officer O (Page )
Accident reports (Form 19; see Appendix I) must be completed by the supervisor and submlt1ed
to the Safety Officer within 24 hours of an employee accident.
3.8.3 Hazardous Chemical Spills
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All chemical spills should be cleaned up immediately. Small containable spills may be handled by
personnel being careful to use appropriate personal protection (i.e., respirator, gloves, face shields). When
a chemical spill presents a hazard to people in an area or threatens fire or explosion:
• Evacuate the area
• Notify project Safety Officer
• Post and secure area
• lnttiate clean-up
• lnttiate appropriate post-clean-up monitoring
• Complete incident report (submit to project Safety Officer)
Proper spill response procedures will be included in each project's safety control sheet. MSDSs
also provide spill response information.
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I APPENDIX C
SAFETY GLASSES REQUEST FORM
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I APPENDIX D
PROTECTIVE CLOTHING REQUEST FORMS
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APPENDIX E
MCLAREN/HART RESPIRATORY PROTECTION PLAN
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I APPENDIX F
MCLAREN/HART LOCKOUT jTAGOUT PROGRAM
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APPENDIX G
MCLAREN/HART HAZARD COMMUNICATION PROGRAM
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APPENDIX I
MCLAREN/HART ACCIDENT INVESTIGATION REPORT
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MCLAREN/HART ENVIRONMENTAL ENGINEERING CORPORATION
EMPLOYEE RESPIRATORY PROTECTION PROGRAM
December 21, 1994
Prepared for:
Employees of McLaren/Hart Environmental Engineering Corporation
Prepared by:
McLaren/Hart Environmental Engineering Corporation
National Remediation Services Group
9323 Stockport Place
Charlotte, NC 28273
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TABLE OF CONTENTS
Section
1.0 Purpose ................................................................. .
2.0 Scope .................................................................. .
3.0 General ................................................................. .
4.0 Selection of Respirators . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
5.0 Air Ouallty and Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
5.1 Breathing Air Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
5.2 Compressed Air . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
5.3 Air Line Couplings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
5.4 Breathing Cylinder Markings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
6.0 Use of respirators . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
6.1 Fit-test . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
6.2 Respirator Selection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
6.3 Donning and Doffing Respiratory Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
7.0 Respirator user . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
8.0 Maintenance and care . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
8.1 Inspections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
8.2 Decontamination of the Respirator . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
8.3 Storage of the Respirator . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
8.4 Repairs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
9.0 Cartridges . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
10.0 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
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Appendix A:
Appendix B:
Appendix C:
Appendix D:
Appendix E:
LIST OF APPENDICES
Respiratory Protection Standard 29 CFR 1910.134
Respirator Certttication Form
Safety Protocol Outline
Monthly SCBA and APR Inspection Checklist
Cartridge Color !ind Selection Chart
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APR
CRZ
EOT
EZ
IDLH
OSHA
PEL
PPE
SAR
SCBA
TLV
Air-purifying respirators
Contamination reduction zone
Emergency operations team
Exclusion zone
Dangerous to \tte and health
UST OF TERMS
Occupational Safety and Health Administration
Permissible exposure limit
Personal protective equipment
Supplied-air respirator
Self-contained breathing apparatus
Threshold limit value
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•
McLaren/Hart ERO
EMPLOYEE RESPIRATORY PROTECTION PROGRAM
1.0 PURPOSE
The purpose of the Mclaren/Hart Employee Respiratory Protection Program is to establish
guidelines for and train employees on the use, care, and limitations of respiratory protection.
2.0 SCOPE
The McLaren/Hart Respiratory Protection Program establishes guidelines consistent with the
contents of the Mclaren/Hart Policies and Procedures Manual. The guidelines govern the use of all
respiratory protection by Mclaren/Hart employees. The Program will incorporate all aspects of the
Occupational Safety and Health Administration (OSHA) Respiratory Protection Standard-29 CFR 1910.134
(see Appendix A) and will cover all McLaren/Hart employees requiring respiratory protection. Determining
the need of respiratory protection will be based on and incorporated into each individual Safety Protocol.
3.0 GENERAL
All respiratory protective equipment used by McLaren/Hart employees will be approved by the
National Institute for Occupational Safety and Health and the Mine Safety and Health Administration. Only
those McLaren/Hart employees who are participating in the Medical Monitoring Program, deemed physically
fit by a licensed physician, and fit-tested by an authorized Mclaren/Hart Safety Office employee shall be
approved to wear respiratory protection. Only parts approved for a specttic respirator are to be used for
replacement. Respirators requiring repair must be brought to the attention of the Safety Office immediately.
All repairs will be conducted under the guidance of the Safety Office.
When personnel approach a task that involves hazardous materials and that requires respiratory
protective measures, they shall consider respirators as the last precaution. Engineering controls (e.g.,
chemical hoods or glove boxes) shall supersede the use of respiratory equipment. When respiratory
protection (respirator) is the only alternative, employees shall adhere to the following Mclaren/Hart
respiratory protection policies.
4.0 SELECTION OF RESPIRATORS
The Task Manager and Safety Officer will make the proper selection of respirators according to the
American National Standard Practices for Respiratory Protection 288.2-1969, NIOSH, and relevant exposure
indices for the material in question (PEL, TLV, odor threshold, etc.). The correct respirator is to be specttied
for each task. laboratory Safety and/or Task Protocols will establish the need for respiratory protection,
including the type of respirator, protection needed, and cartridge if air-purifying respirators are used.
5.0 AIR QUALITY AND SYSTEMS
5.1 Breathing Air Requirements
When respiratory protection involves the use of supplied air through a self-contained breathing
apparatus (SCBA) or supplied-air respirator (SAR), breathing air shall meet the requirements of Grade D
breathing air as described in the Compressed Gas Association Commodity Specification G-7.1-1966. At the
time of purchase. the supplier shall provide a certificate verifying the grade of all breathing air. Task
Managers must maintain a copy of this certtticate and must send the original to the Safety Office to be filed
with the task safety plan.
5.2 Compressed Air
Air compressors meeting breathing-air requirements shall not be used by Mclaren/Hart employees
without prior approval from the Safety Office.
5.3 Air Line Couplings
Air line couplings shall be incompatible with outlets from other gas systems to prevent inadvertently
filling breathing air cylinders with non-respirable gases or oxygen.
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5.4 Breathing Cylinder Markings
All breathing air cylinders shall be marked to identify the material contained. Proper markings are
"Federal Specification BB-A-1034a, June 21, 1968, Air Compressed for Breathing Purposes" or "Interim
Federal Specification GG-B-00675b, April 27, 1965, Breathing Apparatus, Self-Contained." Compressed gas
cylinders without one of these markings shall not be used for breathing air. If either of these statements is
accidentally removed from a cylinder, employees shall contact the Safety Office immediately.
6.0 USE OF RESPIRATORS
After passing the medical monitoring exam, and annually thereafter, employees must have a
successful flt-test before wearing an air-purifying respirator {APR). Fit-tests are not necessary when wearing
positive pressure air-supplied breathing apparatus, but use of these systems by McLaren/Hart employees
shall be authorized by the Safety Office.
6.1 Fit-test
A respirator fit-test includes a qualitative and/or quantitative exam. The qualitative fit-test includes
two separate steps, gently inhaling, while covering the cartridges with his or her hands and gently exhaling
while covering the exhalation valve with one's hand, noticing movement of the respirator toward and away
from the face, respectively. If leaks are present, adjustments should be made, and the device should be
retested until no leaks are detected, demonstrating a satisfactory face-piece-to-face seal. If no leaks are
detected, the employee will be placed into two controlled-test atmospheres, one consisting of lso-Amyl
Acetate and the other of irritant smoke. Only those persons not detecting the test atmospheres shall be
certified.
The quantitative flt-test calculates individual protection factors for respirators given to employees.
An example of quantitative fit-test equipment is a Portacount.
Either flt-test method is acceptable as long as the Safety Office administers the test and a Respirator
Certification Form is on file for each person passing the flt-test (see Appendix B).
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6.2 Respirator Selection
The type of respirator needed for a specttic task shall be determined by the Safety Office from
knowledge of the hazardous materials' chemical and physical properties, the manner in which the hazardous
material(s) is used, and any available air monitoring results, tt they exist. The decision also will consider the
range of other protective measures have been exhausted (e.g., engineering controls).
Because each compound is different in chemical and physical properties, specttic guidelines cannot
be set to determine the type of respiratory protection needed in every situation, although the following
general guidelines shall be adhered to by all McLaren/Hart employees:
• Air-purttying respirators {APR), supplied-air respirators (SAR), or self-contained breathing
apparatus (SCBA) shall be worn tt air concentrations for a specific compound exceed the
compounds Permissible Exposure Limit (PEL), or, in its absence, the Threshold Limit Value
(TLV). (Type of respirator selected will be determined by the Safety Office, which maintains
thorough knowledge of potential chemical or physical respiratory exposure based on air
concentration and respirator protection factors.)
• SARs shall be worn in oxygen-deficient atmospheres (containing less than 19.5 percent
oxygen).
• SARs shall be worn in Immediately Dangerous to Life and Health {IDLH} and unknown
atmospheres.
• SARs shall be worn when working with toxic components having poor warning properties (e.g.,
odorless).
It is important to remember that the use and type of respiratory protection selected shall be a
decision made by the Safety Office.
In the event of a toxic gas release at the EPA/RTP facility employees should take the following
steps:
1. Pull the fire alarm.
2. Call 2900 from a safe location to report the emergency.
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3. Describe the emergency to the Emergency Operations Team (EOT).
4. Leave the building following the facility's Employee Emergency Egress Plan.
The EOT will receive guidance on respiratory protection from. the EPA/ORD Health and Safety
Department. (Note: Unless given prior approval from the Safety Office;-Mclaren/Hart personnel shall not
enter a known toxic atmosphere with or without an air-supplied respirator.)
In the event of a toxic gas release at a McLaren/Hart facility or project site, employees should take
the following steps:
1. Pull fire alarm or engage employee emergency warning signal.
2. Leave the building as outlined in the McLaren/Hart or project site Employee Emergency Egress
Plan.
3. Wait for the Emergency Rescue Team to arrive and describe spill or release.
When using hazardous chemicals in the laboratory, respiratory protection guidance shall take the
form of comments or mandates by the McLaren/Hart Safety Office when reviewing Safety Protocols (see
Appendix C-Safety Protocol).
6.3 Donning and Doffing Respiratory Protection
When using respiratory protection in dangerous atmospheres, employees must be careful to don
and doff the respirators with extreme caution to prevent inadvertent contamination to the inside of the mask
or the user.
A clean area or contamination reduction zone (CRZ), adequately removed from the contaminated
area, shall serve as the location to don all personal protective equipment (PPE), including respiratory
equipment. At this time, a face-piece-to-face seal shall be performed by all personnel entering the
contaminated area or exclusion zone (EZ).
No fewer than two persons shall enter an EZ when respiratory protection is required. The use of
a "buddy" system shall require visual or voice communication at all times.
In IDLH atmospheres, personnel entering the EZ shall be equipped with a safety harness and line
to expedite removal of personnel in emergency situations. Personnel shall never enter an IDLH atmosphere
5
and/or confined space to rescue another employee unless support equipment and personnel are present
and the proper PPE has been selected for entry. Only SCBA or SAR with emergency egress bottle shall be
used to enter IDLH atmospheres. ,APRs and SARs without emergency egress bottles are prohibited in IDLH
atmospheres.
When doffing respiratory protection, employees should remove old gloves and don clean gloves to
prevent the transfer of hazardous materials from the old gloves to the face and the inside of the respirator.
Caution should always be used when doffing respiratory protection to ensure it is removed in a clean
atmosphere.
7.0 RESPIRATOR USER
All McLaren/Hart employees required to wear respiratory protection shall receive fitting instructions
at the time of his or her fit-test. These instructions shall include how to:
• Wear a respirator
• Adjust the respirator for a proper fit
• Determine whether the respirator fits properly
• Doff a respirator
• Decontaminate a respirator (see Section 8.2)
Other Items of importance include:
• Removal of all facial hair impeding a proper seal between the mask and the user's face
• Prohibition of .wearing contact lenses in contaminated atmospheres with a respirator (corrective
spectacles can be mounted inside a respirator)
• Retesting respirator fit following facial transfiguration (e.g., scars, dentures, surgery, etc. )
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8.0 MAINTENANCE AND CARE
8.1 Inspections
Employees assigned a respirator shall inspect ~ routinely before and after each use, or monthly,
whichever is most frequent. SCBA shall be inspected monthly by the Safety Office. (Refer to Appendix
D-SCBA and APR Inspection Checklist.)
Respirator inspections shall include checking the tightness of connections, the condition of the
face-piece, headbands, valves, connecting tubing, pliability, and signs of deterioration of rubber or elastomer
parts.
A record shall be kept in the Safety Office of respiratory inspection dates and outcomes for
respirators maintained for emergency use.
8.2 Decontamination of the Respirator
Daily or after each use, whichever occurs least frequently, respirators shall be cleaned and
disinfected. To accomplish respirator decontamination, employees must:
• Remove inhalation and exhalation valves on air-purifying respirators (APRs).
• Thoroughly scrub entire surtace area of respirator and parts in warm, soapy water.
• Rinse respirator and parts of all soap.
• Place respirator and parts in a 1 cup:1 gallon mixture of liquid bleach and water, respectively,
and let them stand for 5 minutes.
• Rinse respirator and parts adequately to remove the bleach solution.
• Thoroughly dry the surtaces of the respirator and parts completely. Do not air-dry respirators.
Use paper towels or a cloth to dry your respirator.
After the decontamination procedure is completed, and the parts and respirator are dry, reassemble
the respirator for storage.
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8.3 Storage of the Respirator
All respirators shall be stored to protect against dust, contaminants, sunlight, heat, extreme cold,
and excessive moisture. Minimum protection shall be an air-tight plastic bag. Emergency-use respirators
shall be stored according to manufacturer's recommendations.
Regardless of the respirator type, all respirator masks shall be stored face-down. Storing a mask
in this fashion prevents disfiguring the elastomer and maintains the manufactured shape for a proper fit.
8.4 Repairs
Only experienced persons shall attempt replacements or repairs to a respirator with parts designed
by the manufacturer specttically for the respirator. These repairs or replacements shall not go beyond the
manufacturer's recommendations. Reducing or admission valves or regulators shall be returned to the
manufacturer when needing repair.
9.0 CARTRIDGES
A variety of cartridges exists for APRs. The specific cartridge used depends upon the type of .
contaminant against which the user needs protection. Common cartridges include organic vapor, acid
gases, ammonia, particulate, and various combinations of the above. Employees can identify cartridges in
two ways: by color and wording. A color code chart is available in Appendix E.
When received from the supplier, cartridges shall be dated and shall not remain in storage longer
than four years. While in storage, the labeling must remain intact and the colors must not wear or fade.
If any such deterioration occurs, it must be reported to the Safety Office.
Before inserting cartridges, check the date and look for visible damage to the cartridge. A final test
is required before using chemical cartridges. This test includes shaking the cartridge vigorously while .
listening for any "rattling" noise. If a rattling noise occurs, the cartridge is damaged and must be discarded.
If no rattling occurs, the cartridge is ready for use.
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10.0 CONCLUSION
Not following the contents of this respiratory protection program is considered a breach of company
policy and may result in a serious accident to the user of respiratory equipment. This program is designed
for the safety of McLaren/Hart employees, and lack of compliance will result in disciplinary action.
It is important to understand the differences between respiratory equipment and their individual
limitations. It is also important to understand that respirators shall be the last line of respiratory protection
used after the Safety Office has determined that all engineering controls fail to provide the proper respiratory
protection.
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I APPENDIX A
I Respiratory Protection Standard
29 CFR 1910.134
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APPENDIX D
Monthly SCBA and APR Inspection Checklist
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I APPENDIX E
I Cartridge Color and Selection Chart
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MCLAREN/HART ENVIRONMENTAL ENGINEERING CORPORATION
LOCKOUT /TAGOUT
PROCEDURES PROGRAM
Prepared for:
Employees of McLaren/Hart Environmental Engineering Corporation
Prepared by:
Mcl.areQ/Hart Environmental Engineering Corporation
National Remediation Services Group
9323 Stockport Place
Charlotte, NC 28273
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TABLE OF CONTENTS
Section Page
1.0 Policy .................................................................. .
1.1 Purpose ........................................... , . . . . . . . . . . . . . . . . 1
1.2 Scope . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1.3 Definitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
2.0 Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
3.0 Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
3.1 LockoutjTagout Sequence . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
3.2 General Equipment Restoration Sequence . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
3.3 Equipment-Specttic Lockout(fagout Procedure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
4.0 Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
5.0 Inspections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
6.0 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
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MCLAREN/HART ENVIRONMENTAL ENGINEERING CORPO~ATION
LOCKOUT /TAGOUT
PROCEDURES PROGRAM
1.0 POLICY
All employees are required to comply with the restrictions and limitations imposed upon them
during the use of this lockout/tagout procedure. Only authorized employees are required to perform
lockout/tagout in accordance with the lockout/tagout procedure included in the Project or Task Safety
Protocol. Project and Task Supervisors are required to train authorized personnel in the methods used
to lock or tag out equipment according to established Safety Protocol procedures. All employees, upon
observing a machine or piece of equipment which is locked or tagged out, shall not attempt to start,
energize, or use that machine or equipment until the lock or tag is removed by the employee to whom it
belongs.
1.1 PURPOSE
This procedure establishes the minimum requirements for the lockout/tagout of hazardous
energy sources as they pertain to Mclaren/Hart's Charlotte employees and their work areas.
McLaren/Hart employees shall implement this program before performing service or maintenance on
equipment or machines where the unexpected energizing or start-up of the equipment or machinery or
release of stored energy could cause employee injury.
1.2 SCOPE
This procedure applies to all equipment that receives its energy from electrical power,
pneumatic, hydraulic fluid under pressure, compressed air or steam, energy stored in springs, potential
energy from suspended parts, or any other source that may cause unexpected movement when it is
necessary to perform maintenance on that system.
1.3 DEFINITIONS
Authorized employee: A person who locks out or tags out machines or equipment in order to
perform servicing or maintenance on that machine or equipment. An affected employee becomes an
authorized employee when that employee's duties include performing servicing or maintenance covered
under this section.
Energized: Connected to an energy source or containing residual or stored energy.
Energy isolating device: A mechanical device that physically prevents the transmission or
release of energy, including but not limited to the following: A manually operated electrical circuit
breaker; a disconnect swttch; a manually operated swttch by which the conductors of a circuit can be
disconnected from all ungrounded supply conductors, and, in addttion, no pole can be operated
independently; a line valve; a block; and any similar device used to block or isolate energy. Push
buttons, selector switches and other control-circutt-type devices are NOT energy-isolating devices.
Energy source: Any source of electrical, mechanical, hydraulic, pneumatic, chemical, thermal,
or other energy.
Lockout: The placement of a lockout device on an energy isolating device, in accordance wtth
an established procedure, ensuring that the energy isolating device and the equipment being controlled
cannot be operated until the lockout device is removed.
Lockout device: A device that utilizes a posttive means such as a lock, etther key or
combination type, to hold an energy isolating device in a safe posttion and prevent the energization of a
machine or equipment. Included are blank flanges and bolted slip blinds.
Servicing and /or maintenance: Workplace activtties such as constructing, installing, setting up,
adjusting, inspecting, modifying, and maintaining and/or servicing machines or equipment. These
activities include lubrication, cleaning or unjamming of machines or equipment and making adjustments
or tool changes, where the employee may be exposed to the unexpected energization or startup of the
equipment or release of hazardous energy.
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Taqout: The placement of a tagout device on an energy isolating device, in accordance with an
established procedure, to indicate that the energy isolating device and the equipment being controlled
may not be operated until the tagout device is removed.
Tagout device: A prominent warning device, such as a tag and a means of attachment, which
can be securely fastened to an energy isolating device in accordance with an established procedure, to
indicate that the energy isolating device and the equipment being controlled may not be operated until
the tagout device is removed.
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2.0 EQUIPMENT
All lockout/tagout equipment used by McLaren/Hart Environmental ERO employees shall be of
uniform size, shape, and color.
1. Locks: Locks must be equipped with a case-hardened steel shackle and enough
clearance for use with lockout hasps. Locks may be combination or key and must
be identttiable by employee. Color coding used in conjunction with an employee's
inltials stenciled or engraved onto the lock would be adequate. Each individual
Safety Protocol shall establish a method of differentiating between employee locks.
Locks used for this program must not be used for any other purpose.
2. Tags: Two tags will be used by McLaren/Hart Environmental ERO employees for tagging out
equipment/machinery for service or maintenance and shall be standardized throughout
the company.
• "DO NOT OPEN VALVE" tag will be used when de-energizing compressed air,
steam, water, or chemical material stored in pipes, lines, or hoses and for
hydraulic and pneumatic equipment. The tag shall have a designated location
for the employee's name and shall be of sufficient size not to be mistaken for
anything other than Its intended purpose. Tags and their printed warnings
shall be capable of withstanding the environmental conditions in which they
are used.
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• "DO NOT START --Equipment Locked Out" tag will be used when de-
energizing electrical and/or mechanical equipment where an energy isolating
swITch controls the start-up and shut-down of the equipment/machine. The
tag shall have a designated location for the employee's name and shall be of
sufficient size not to be mistaken for anything other than ITS intended purpose.
Tags and their printed warnings shall be capable of wIThstanding the
environmental conditions in which they are used.
3. Lockout Hasps:Lockout hasps shall be made of hardened steel capable of wIThstanding the
environmental condITions in which they are used. The hasp shall be
constructed to remain closed around the energy isolating switch until the last
lock is removed. Damaged or disfigured lockout hasps shall be removed and
replaced immediately upon recognition.
4. Chains:
5. Ties:
6. Blanks:
Chains used in the lockout process shall be steel alloy capable of resisting
forces IT may encounter. Each link's inner diameter shall be of adequate size
for use with the locks and lockout hasps.
Ties used to affix tags to the energy isolating swITch shall be of a non-reusable
type, attached by hand, self-locking and non-releasable WITh a minimum
unlocking strength of no less than 50 lbs and having a general design and
basic characteristics of being at least equivalent to one piece, all environment-
tolerant nylon cable tie.
Blanks used to block material contained wIThin pipe systems shall be of
sufficient thickness and size, and constructed of material compatible with the
contents of the pipe.
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3.0 PROCEDURES
3.1 LOCKOUT /TAGOUT SEQUENCE
1. Before locking or tagging out a piece of equipment/machine, an authorized employee shall give
notice to all employees in proximity not involved with the procedure. Proper notice shall include
the name and location of the equipmentjmachine to be locked/tagged out, date and time of the
lockout/tagout, the name of the authorized employee supervising the procedure, and adequate
notice signifying the lockout/tagout procedure is completed.
2. An authorized employee shall place signs around the equipment/machine alerting personnel not
to operate the equipment/machine until all signs, locks and/or tags are removed and an
authorized employee has inspected the equipment/machine for re-energization.
3. If the equipment/machine is operating, shut It down by the normal stopping procedure {depress
stop button, open switch, close valve, etc.). Refer to the equipment specttic lockout/tagout
procedure included in the Project/Task Safety Protocol to determine the shut-down steps
relevant to your operation.
4. Deactivate the energy isolating device(s) so the equipment/machine is isolated from the energy
source(s). Follow all emergency lines from their source to the equipment to ensure all sources
are isolated.
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5.
6.
7.
B.
Lock or tag out the energy isolating device(s) with assigned individual locks or tags. Locks and
tags are furnished separately through each Project and must meet the parameters of this
program. Lockout devices must be affixed in the "off' or "safe" position. Tagout devices shall
be used to clearly show energy isolating devices in the "off' or "safe" posttion and when used
where lockout devices could be used, the tag shall be fastened at the location made available
for the lockout device. Each employee involve in the servicing or maintenance of a piece of
equipment/machine covered under the lockout/tagout section of a Safety Protocol must attach
his/her lock or tag to each energy isolating device.
Release or restrain all stored or residual energy (such as that in capacitors, springs, elevated
machine members, rotating flywheels, hydraulic systems, air, gas, steam, or water pressure, etc.)
by methods such as grounding, reposttioning, blocking, bleeding down, etc. Where there is a
possibiltty of energy reaccumulation, authorized personnel shall verify periodically that energy
isolation is maintained until service or maintenance is completed.
Ensure the equipment is disconnected from the energy source(s) by first checking that no
personnel are exposed, then verify the isolation of the equipment by operating the push button
or other normal operating control(s) or by testing to make certain the equipment will not
operate. Remember to return operating controls to the "off' posttion after verifying and before
performing service or maintenance on the equipment/machine.
The equipment/machine is now locked or tagged out.
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3.2 GENERAL EQUIPMENT RESTORATION SEQUENCE
Alter all servicing or maintenance is completed, authorized personnel shall adhere to the
following general procedures when restoring energy to the equipment/machine. Specific energy
restoration procedures are located in the individual Safety Protocol established for each individual
Project or Task.
1.
2.
3.
4.
Inspect the equipment/machine and the immediate area around the machine or equipment to
ensure that all personnel and nonessential Items have been removed and that the
equipment/machine components are operationally intact.
Check the work area to ensure that all authorized employees, those involved in the
lockout/tagout, have been safely positioned and accounted for before proceeding further with
energy restoration.
Verify that the controls are in neutral.
Remove the lockout/tagout device(s) and signs and reenergize the equipment/machine. Each
authorized employee must remove his/her own lock(s) or tag(s). It is against company policy to
remove another employee's lock(s) or tag(s) unless:
• The employer or supervisor of the lockout/tagout task verffies that the authorized
employee who applied the device is not at the facillty
• All reasonable efforts have been made to contact the authorized employee informing
him/her that his/her lock/tag has been removed; and
• The authorized employee is knowledgeable about the fact his/her lock/tag was
· removed.
There must also be a method of ensuring that authorized employees have knowledge of his or
her lock(s)/tag(s) being removed before resuming work the following day.
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All methods one uses to locate and/or contact an authorized employee to remove, or about the
removal of, his/her lock(s) or tag(s) shall be documented and maintained in the Project/fask file.
Documentation shall include:
• Name of the authorized employee
• Date and time of contact
• Contact message and authorized employee reply
Note: The ERO Safety Office considers the act of permanently leaving a lockout/tagout site
without removing one's lock(s) or tag(s) and informing others of the status of the
equipment/machine previously locked or tagged out a serious breach of company
policy requiring disciplinary action.
5) Notify affected employees, those employees using the equipment/machine, that the
servicing or maintenance is completed and the equipment/machine is ready for use.
3.3 EQUIPMENT-SPECIFIC LOCKOUT /fAGOUT PROCEDURE
The following paragraphs outline lockout/tagout methods for specttic categories of
equipment/machines. This section, as is the entire McLaren/Hart Environmental ERO Lockout/fagout
Procedures Program, is designed to aid McLaren/Hart Supervisors and/or Task Managers in creating a
lockout/tagout procedures(s) as It pertains to equipment/machines utilized in their task(s). These
methods should not be confused as procedures but should be used in the procedural development.
1. Cord-or Plug-Connected Electrical Eguipment/Machines
Exposure to the hazards from the unexpected energization or start-up of equipment controlled
by the unplugging of equipment from Its energy source with the plug being under the exclusive
control of the employee performing the servicing or maintenance, is not applicable to
lockout/tagout requirements, tt:
• · The cord or plug must be secured to the equipment/machine to which It belongs and
• The cord or plug is in clear view of the authorized individual performing the service or
maintenance.
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2.
3.
If these two requirements cannot be met, the authorized individual shall initiate a
lockout/tagout procedures using a method, or combination of methods, located in the
section entltled "Electrical Equipment".
Electrical Equipment
Electrical equipment, other than plug or cord type, shall utilize one or a combination of
lockout/tagout devices authorized by this program when the servicing or maintenance of that
equipment involves electrical work or the insertion of body parts into the working assembly of
the equipment/machine. Methods of lockout/tagout include:
• Locking or tagging the entire electrical panel and/or individual switches;
• Locking/blocking internal moving parts in resting position; and
• both, tt the potential exists that performing one or the other above does not control all
energy sources
Whenever employees perform service or maintenance on electrical equipment, all electrical
sources/circuits must be locked or tagged out. Other methods may be used in conjunction with
electrical deenergization, but not in substitution.
It is signtticantly important to remember that a piece of equipment or machine capable of
being locked out, must utilize a lockout method as opposed to tagout unless approved by the
ERO Safety Office. When tagout is approved as an equally-safe method as lockout, authorized
employees shall place tagout devices at the same location designed for lockout devices.
Pneumatic and Hydraulic Equipment
Pneumatic-and hydraulic-driven equipment/machines pose significant safety hazards when not
locked or tagged out properly before performing service or maintenance. These systems tend
to build up pressure within their lines when locked/tagged out tt care is not taken to open
locking vents preventing pressure buildup and possible equipment movement during service or
maintenance.
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4.
The best method of locking/tagging out pneumatic and hydraulic equipment is by removing
the energy source when possible. This method should only be used when the
equipment/machine and all moving parts are in their resting position or lowest state of potential
energy.
Another method of controlling the energization of pneumatic and/or hydraulic
equipment/machines is to lock/tag out each individual valve and pressure bleed vent
capable of releasing and storing pressure respectively from or within the
equipment/machine, in conjunction with physically blocking or guarding all moving parts
within the unit capable of causing injury to those performing service or maintenance.
Process Lines
Process lines containing compressed air, water, steam, or hazardous materials must be shut,
drained, and blanked before authorized employees can provide service or maintenance. The
proper steps to follow when entering a process line include, in this order:
• Isolating the line by closing and locking/tagging all valves entering the line. Use a steel
alloy chain and lock meeting the requirements of this Program when locking out a valve
• Remove all free product by pumping or draining
• Insert a blank or blind in the line to block it completely. This step is important since valves
have been known to leak even when fully closed
Note: Entering or breaking a process line requires prior approval from the Safety Office.
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4.0 TRAINING
McLaren/Hart Environmental shall train all employees involved in lockout/tagout procedure. The
ERO Safety Office shall provide initial Program training to all employees involved, or potentially involved,
with the lockout/tagout procedure. This training will include:
• Recognition of applicable hazardous energy sources
• The contents of this program; and
• The location of individual lockout/tagout procedures.
Employee supervisors must provide training to their personnel involved with service or
maintenance of equipment/machines requiring the implementation of this program. Training must
include:
• · Type and magnitude of energy in the workplace
• Methods and means necessary for energy isolation and control
• Specific use and purpose of equipment/machine energy control procedures
• Procedures for restarting or reenergizing equipment/machines which are locked or
tagged out
When tagout systems are used, training shall include:
• Tags.provide warning and not the physical restraint of locks;
• Tags shall only be removed by the authorized person responsible for It and shall never
be by-passed, ignored, or otherwise defeated;
• Tags must be legible and must include the name of the authorized person and date
service or maintenance is being performed;
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• Tags and materials used for attachment must be capable of withstanding all
environmental conditions imposed on It;
• Tags shall be attached to the energy isolating device so as not to be inadvertently
detached; and
• Tags are valid for one shift only and must be replaced by the authorized employee ff
work should continue
Retraining of employees on lockout/tagout procedures shall occur whenever procedures change
or when routine or annual procedural and equipment/machine inspections reveal employee deviation
from the established procedure.
Training performed by supervisors shall include topics covered, each employee's name, and
date(s) given. Supervisors shall send the Safety Office a copy of all training immediately upon
completion and maintain a copy for the ProjectfT ask file.
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5.0 INSPECTIONS
Safety Office inspections on the lockout/tagout program will be performed annually. All
documentation will be filed in the Safety Office wtth the original lockoui/tagout program. The inspection
shall include a review between the supervisor and his/her authorized employees responsible for
implementing the lockout/tagout procedure.
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6.0 CONCLUSION
The contents of this program are mandatory, and therefore, complete understanding of this
program is essential in providing a safe and healthy workplace when attempting to service or
maintenance equipment/machines requiring the implementation of a lockout/tagout procedure meeting
this program's definttion.
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Appendix B:
Acurex Environmental Corporation
Eastern Regional Office -Treatability Laboratory
Safety Manual/Chemical Hygiene Plan
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ACUREX ENVIRONMENTAL CORPORATION
EASTERN REGIONAL OFFICE-TREATABILITY LABORATORY
SAFETY MANUAL/CHEMICAL HYGIENE PLAN
Date Revised: June 1993
Prepared by:
Acurex Environmental Corporation
4915 Prospectus Drive
P.O. Box 13109
Research Triangle Park, NC 27709
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TABLE OF CONTENTS
Section
1.0 INTRODUCTION
2.0 SAFETY POLICY
.............................................. I
3
3.0 GENERAL SAFETY GUIDELINES ................................ .
3.1 PERSONAL PROTECTIVE EQUIPMENT ........................ .
3.1. l Foot Protection (Safety Shoes) ............................ .
3.1.2 Eye Protection ....................................... .
3.1.3 Protective Clothing .................................... .
3.1.4 Hard Hats .......................................... .
3. 1.5 Hearing Protection .................................... .
3.1.6 Respiratory Protection ................................. .
3.2 WORK ENVIRONMENT .................................... .
4
4
5
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6
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7
3.2.1 Unattended Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
3.2.2 Electrical Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
3.2.3 Proper Use of Signs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
3.2.4 Equipment Design ......... ·-· . . . . . . . . . . . . . . . . . . . . . . . . . . 9
3.2.5 Selecting and Implementing Hazardous Material Control Measures . . . 9
3.2.6 Laboratory Fume Hoods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
3.2.7 Work Approval . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IO
3.3 MATERIAL HANDLING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
3.3.1 Chemicals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
3.3.2 Regulated Materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
3.3.3 Compressed Gas Cylinders . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
3.3.4 Radioactive Materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
3.3.5
3.3.6
3.3.7
Hazardous Waste ..................................... .
Employee/Laboratory Monitoring .......................... .
13
14
Employee/Equipment Decontamination Procedures . . . . . . . . . . . . . . . 14
( continued)
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TABLE OF CONTENTS (concluded)
Section
3.4 PERSONAL HABITS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
3.4.1 Working Alone . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
3.4.2 Housekeeping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
3.4.3 Food . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
3.4.4 Smoking . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
3.4.5 Jewelry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
3.4.6 Hair . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I 6
3.5 MEDICAL SURVEILLANCE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
3.5.1 Subpart Z-Toxic and Hazardous Substances . . . . . . . . . . . . . . . . . . . 17
3.5.2 Medical Consultation and Medical Examinations . . . . . . . . . . . . . . . . 17
3.6 SAFETY AUDITS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
3.7 PERSONNEL TRAINING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
3.8 EMERGENCIES ........................................... · 20
3.8.1 Fire . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
3.8.2 Employee Injury or Illness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
3.8.3 Hazardous Chemical Spills . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
APPENDICES:
A-SAFETY CONTROL SHEET OUTLINE
B-SAFETY SHOE REQUEST FORM
C-SAFETY GLASSES REQUEST FORM
D-PROTECTIVE CLOTHING REQUEST FORMS
E-ACUREX ENVIRONMENTAL ERO RESPIRATORY PROTECTION PLAN
F-ACUREX ENVIRONMENTAL ERO LOCKOUT/TAGOUT PROGRAM
G-ACUREX ENVIRONMENTAL ERO HAZARD COMMUNICATION PROGRAM
H-PHYSICAL REQUEST FORM
I-ACUREX ENVIRONMENTAL ERO ACCIDENT INVESTIGATION REPORT
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SECTION I
INTRODUCTION
Acurex Environmental Corporation's Eastern Regional Office (ERO) operates offices and a
soil and groundwater Treatability Laboratory at 49 I 5 Prospectus Drive, Durham, NC. The laboratory
operation includes:
• Standardized, analytical procedures intended to screen soil and groundwater samples to
determine if they are amenable to certain treatment technologies, principally
bioremediation
Bench-and pilot-scale studies to test the effectiveness of various remediation technologies
The types of safety hazards encountered cover the spectrum of chemical hazards associated
with handling hazardous substances (including gases, liquids, and solids) to physical hazards
associated with electricity and broken glassware, as well as slips, trips, and falls.
Adherence to the safety policies and procedures presented herein is the responsibility of each
Acurex Environmental ERO staff member. Enforcement is shared by all levels of management with
guidance from the ERO Safety Officer (Chemical Hygiene Officer). However, each supervisor is
responsible for ensuring that the employees he or she supervises understand and comply with this
manual and other safety policies and procedures enforced by Acurex Environmental.
This document is written in general terms to apply to all laboratory activities performed within
the Treatability Laboratory. Specific safety procedures for individual projects or classes of routine
samples are detailed in individual project-specific safety control sheets. The project-specific control
sheets detail the standard operating procedures relevant to safety and health considerations that Acurex
Environmental employees will follow when working with hazardous substances in a laboratory setting.
The level of detail required for project safety control sheets (PSCSs) will be left to the discretion of
the ERO Safety Officer. Regardless of project specifics, all of the policies and guidelines discussed in
Sections 2 and 3 will apply to all work done at ERO. The additional information will supplement
these basic concepts.
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SECTION 2
SAFETY POLICY
The safety of each Acurex Environmental staff member and of the general public is
paramount. A concentrated effort shall be made to ensure a safe and healthy work environment and
compliance with state and federal OSHA laws. Staff member compliance with health and safety
regulations is a condition of emEJloyment at Acurex Environmental.
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SECTION 3 I
GENERAL SAFETY GUIDELINES
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Safety depends on the people doing the work. Each staff member has the responsibility for his I
or her own safety and a moral obligation to safeguard other workers ·and associates. Anyone who
detects a potential hazard is expected to personally take appropriate control action if the situation
permits, or report the potential hazard to his or her supervisor. Employees who direct the work of
others have additional responsibility for the safety of all personnel under their direction as well as for
themselves. This includes responsibility for physical safety of facilities, equipment, and materials, use
of protective equipment, and attitude. Setting a good example is fundamental to fulfilling this
responsibility.
3.1 PERSONAL PROTECTIVE EQUIPMENT
General Acurex Environmental policies for personal protective equipment (PPE) follow. For
specific project requirements, procedures, etc., refer to the appropriate project safety control sheet
(PSCS), the Project Task Officer, and/or the ERO Safety Officer.
In general, areas requiring the use of protective equipment are clearly marked. It is the Task
Manager's responsibility to ensure that proper PPE is available and used appropriately. Each project
shall furnish necessary protective equipment to perform the job safely. The Safety Officer is available
to assist with the selection of appropriate equipment. It is also Acurex Environmental policy to
exhaust all engineering controls before relying on the use of respirators.
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Whatever the protective equipment defined in this document or specific project safety
sheets, laboratory personnel will acquire and uses specified PPE. An inspection program will be
implemented by the Task Manager, and the check list will be maintained in a laboratory
notebook and will include at least PPE and material storage. Treatability samples will be
inspected at least once per week. All inspection procedures and checklists must be included in
the PSCS and approved by the ERO Safety Officer.
3. I.I Foot Protection (Safety Shoes)
Safety shoes are provided by Acurex Environmental on an as-needed basis. Each employee is
responsible for notifying his or her supervisor when replacement of safety shoes is required. A safety
shoe request form is included in Appendix B.
Steel-toe safety shoes are required for all facility operations and construction areas. They are
recommended for laboratory areas, but are required in laboratory areas when work performed involves
the handling of compressed gas cylinders or other heavy items. Open-top shoes or sandals are not
permitted in a laboratory area at any time. Electrical safety shoes are required in high-voltage areas or
where electrical shock is an imminent hazard. When handling cryogenics and/or extremely hot
materials, feet and legs should be protected with appropriate, substantial shoes and trousers or shields.
Open-toe shoes, shorts, and/or skirts are not adequate protection for laboratory work.
3.1.2 Eye Protection
Safety glasses with side shields will be considered the minimum level of eye protection for
Treatability Laboratory activities. Other eye protection requirements will be specified in the PSCS.
Safety glasses are provided on an as-needed basis. Goggles will be provided when
appropriate. Each employee is responsible for notifying his or her supervisor when replacement of
safety glasses is required. A safety glasses request form is included in Appendix C.
Visitor's eye protection will be made available at the entrance to the treatability lab. It is the
project Task Manager's responsibility to ensure an adequate and readily available supply.
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3 .1.3 Protective Clothing
Cloth laboratory coats are required in the Treatability Laboratory unless specified otherwise
in the PSCS. Specific information will be included in PSCSs. A protective clothing request form
is included in Appendix D.
Care must be taken to choose appropriate gloves for chemical handling. Laboratory safety
control sheets should include glove recommendations.
3. I. 4 Hard Hats
Treatability Laboratory work will not require hard hats unless specifically indicated on the
safety control sheet.
3.1.5 Hearing Protection
Acurex Environmental provides a hearing conservation program in accordance with OSHA
regulation 29 CFR 1910.95. The Treatability Laboratory is not a high noise area. As new
equipment is added, it should be evaluated for noise level. Treatability Laboratory workers
should contact the Safety Officer for a review if noise levels increase. The Safety Officer will
review noise levels at least annually. Audiometric testing is included in the health monitoring
program.
3.1.6 Respiratorv Protection
Respiratory protection is provided to Acurex Environmental employees as required by
individual PSCSs under the supervision of the ERO Safety Officer. Treatability Laboratory personnel
will have regular physical exams to determine if their health level allows the use of respiratory
protective equipment if it should be necessary for a particular project.
As with most personal protective devices, selection of the proper type of respiratory equipment
is of primary concern. Equipment ranges from dust masks to air-purifying cartridge respirators to self-
contained breathing apparatuses. Specific recommendations are available through the ERO Safety
Officer.
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Having chosen the correct type of respiratory protection, the next step is to ensure proper fit.
Faces are different sizes and shapes requiring different size masks to achieve a complete seal
preventing material from entering the mask. Beards and heavy sideburns make it difficult to achieve a
complete seal of mask to face. Fit tests will be performed by the ERO Safety Officer. It is desirable
to store filters and respirators convenient to the area of use. Protect them from ambient dust and clean
and inspect respirators once a week and after each use. Replace defective respirators immediately.
The Acurex Environmental Respiratory Protection Plan is attached in Appendix E of this document.
Employees required to wear respiratory protection must be familiar with the entire contents of this
program.
3.2 WORK ENVIRONMENT
The following are procedures to help employees enhance the safety of their work place.
Designated areas for hazardous material use is addressed in each individual safety control sheet.
3.2.1 Unattended Operations
Potentially hazardous equipment or operations shall not be left unattended at critical times.
Areas in which hazardous operations are being performed, including laboratory analysis or permitted
facility operations, must be clearly marked with a sign identifying the hazard, the person in charge of
the operation, and phone number the person can be reached at in case of emergency. Only the person
who placed the sign or someone designated by that person may remove it.
All operations that continue overnight must have posted the names and phone number of three
informed persons who may be contacted in case of emergency.
Equipment that may be operated overnight in the Treatability Laboratory includes the
respirometer and the drying oven. No failure modes can be anticipated for this equipment that would
cause a significant hazard.
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3.2.2 Electrical Safetv
Electricity is so pervasive in our world that we tend to ignore the hazards associated with it.
These hazards are increased in laboratory and research situations. Some simple rules help to minimize
these risks:
• Use only grounded electrical equipment
• Protect cords from chemical and physical hazards
• Provide sufficient electrical outlets and avoid the use of extension cords
• Identify and label all breaker switches
• Replace frayed or damaged cords.
• Use only UL listed electrical equipment or electrical equipment inspected or built by a
licensed electrician.
Lockout/tagout procedures shall be addressed by each PSCS or in equipment standard
operation procedures. Project lockout/tagout procedures will follow the Acurex Environmental
Lockoutffagout Program contained in Appendix F. Employees engaged in lockout/tagout shall follow
and understand the Acurex Environmental program and the individual project requirements.
3.2.3 Proper Use of Si£ns
Proper use of signs informs transitory people as well as serving to remind others of dangers in
their normal work areas. Restrictive signs such as NO SMOKING, AUTHORIZED PERSONNEL
ONLY, and HEARING PROTECTION REQUIRED are posted where appropriate. Observe these
signs. Use informative signs such as WET FLOOR, PEOPLE WORKING, and TRIP HAZARD to
warn personnel of imminent hazards while implementing permanent solutions to the hazard. Avoid
covering a door with signs. A few well-chosen warning signs on a door are more effective than a
collage. Whether or not signs were used to warn others of a hazard or to warn personnel of the·
conditions to be met before working in an area, all Acurex Environmental personnel must comply with
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warning signs. For example, not wearing safety glasses in an area marked SAFETY GLASSES
REQUIRED is a breech of company policy.
3.2.4 Equipment Design
All equipment must be operated with safety features in place and in working condition. When
new equipment that could potentially pose a significant hazard is designed and its use could have
safety implications (i.e., could cause injury if improperly designed, installed or operated), a design
review must occur. It is the responsibility of the Task Manager to notify the ERO Safety Officer of
any equipment change or new design that may have safety implications. It is also his or her
responsibility to arrange for a design review meeting. Design review meetings will be attended by at
least the Task Manager, the ERO Safety Officer, and two staff members determined to have design
background in the area of concern. The Task Manager (or the designers) will present the design to the
group. It will be critiqued, and recommendations will be made by the attendees. The ERO Safety
Officer will approve the final design.
3.2.5 Selecting and Implementing Hazardous Material Control Measures
When preparing to commence work with a hazardous material within a laboratory, a safety
control sheet defining the use, safety procedures, engineering controls, protective equipment, and
hazards of the hazardous material will be completed by the Task Manager and approved by the ERO
Safety Officer. These control sheets will be prepared on a project-specific basis if an extreme hazard
is expected or the nature of the contaminants in the sample are unknown. Otherwise generic control
sheets standard operation procedures will cover all analyses by a given procedure.
Control measures (e.g., engineering controls) for handling hazardous materials will be
subjected to a design review as discussed above. Extremely hazardous substances will undergo the
same procedure. All hazardous materials will be assigned a designated work area described in the
laboratory safety control sheet. All laboratory work with this material shall be limited to the use and
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work area designated within the safety control sheet unless the control sheet is amended for the new
use and approved by the ERO Safety Officer.
3.2.6 Laboratory Fume Hoods
The Acurex Environmental ERO. Safety Officer will ensure that all laboratory fume hoods are
functioning properly by checking the physical condition of fume hood internal parts and by conducting
semiannual air face velocity readings. Treatability Laboratory staff members will ensure that the fume
hood is operating before starting any operation in the hood and will report any problems to the Safety
Officer.
3.2.7 Work Approval
Before laboratory work begins, the ERO Safety Officer-approved safety control sheet must be
in place. If changes in personnel, hazardous materials used, process/equipment, or location occurs, the
Task Manager shall revise the safety control sheet and seek approval from the ERO Safety Officer
before commencing work (see Appendix A).
3.3 MATERIAL HANDLING
The following sections present general, safe materials handling procedures for laboratory
personnel. Individual PSCSs should be referenced for hazardous material handling specifics.
3.3.1 Chemicals
It is important that each person working with or around chemicals understands the health
hazards associated with the use of those chemicals. Each laboratory will maintain material safety data
sheets (MSDSs) for the chemicals in that laboratory and develop safe handling procedures documented
in the PSCS which includes the following:
• Dangerous properties of the hazardous material (physical and chemical)
• Proper handling procedures
• Toxicity (acute and chronic health effect and target organs[sl)
• Appropriate PPE
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First aid procedures .
• Spill clean-up procedures
• Waste disposal
A staff member must have approval from the ERO Safety Officer before ordering a new
chemical or increased quantities of existing chemicals.
The following list of precautions is general in nature and cannot possibly cover all hazards in
all laboratories or research facilities.
Read labels on chemical containers and understand all warning information
• Know the chemical and physical properties of the hazardous materials you use
Understand the safety precautions necessary for the chemical you use and first aid
procedures in case of contamination
• Wear appropriate eye protection (i.e., safety glasses, goggles, face shield)
Wear appropriate protective clothing, shoes, gloves, respirator, etc.
• Keep appropriate spill kits available
Clean chemical spills immediately and report them to your supervisor and the ERO Safety
Officer
• Allow no food or drink in chemical handling areas (e.g., laboratories)
Never pipet by mouth-use a safety pipet bulb
Add acid to water (never add water to acid)
Label all chemical containers with proper information
• Dispose of waste promptly (see the ERO Safety Officer)
Know the location of safety equipment (showers, eye wash fountains, fire extinguishers,
and first aid kits)
Store chemicals in proper storage areas and according to compatibility groups
Store and use compressed gases safely
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Emergency chemical handling information is available from Chemtrec 24 hours a day at
1-800-424-9300. This public service is maintained by the Chemical Manufacturing Association.
Included in Appendix G is the Acurex Environmental ERO Hazard Communication Program.
If you handle hazardous materials (requisition, receive, ship, store for use, or use) at Acurex
Environmental, you should be familiar with the contents of the Hazard Communication Program.
3.3.2 Regulated Materials
Regulated materials are received, used, stored, and disposed of in accordance with applicable
federal, state, and local regulations and in accordance with good business and safety practices. If you
do not know, ask the Safety Officer ..
All samples received by the Treatability Laboratory are stored in Suite D Warehouse in
Building I. All treatability samples are logged in the treatability book. Materials removed from a
treatability sample are noted in the log book. The log must include the amount removed the
destination of the material, the date, and name and signature of the responsible staff member. Staff
members inspect the samples daily and record the inspection in a log book. A member of the safety
staff will review the facility weekly.
All waste or unwanted materials are handled through the safety office. Contact Karen Yates or
her designated alternate about any materials leaving the lab. This requirement includes samples,
laboratory waste, recycle material as well as RCRA regulated waste. All materials from a treatability
study are wastes. Each study should include enough information to estimate the kind and amount of
waste that will be generated. The final waste amounts will probably vary from the estimates. As
soon as the laboratory staff are aware of discrepancies, the safety office should be alerted. Whenever
feasible. sample materials should be returned to the origin. The laboratory manager should negotiate
the return as part of the work agreement. Leave an E-Mail message to notify the safety office of
materials that are ready for disposal. Complete a Chemical Adoption Waste Disposal Form to be
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picked up with the waste materials. The safety office will pick up materials and place them in the
Waste Storage Area.
3.3.3 Compressed Gas Cylinders
Compressed gas cylinders shall be stored and used in the upright position, individually secured
and separate from incompatible gas cylinders. When not in use, compressed gas cylinders shall be
capped and secured. When transporting gas cylinders, secure the cap and chain or strap the cylinder to
the transport cart. When the work day is completed, gas cylinder valves should be closed to prevent
an unwanted release of cylinder content.
A cylinder rack in located within the B-suite area being used for the treatability laboratory.
Diligent attempts will be made to minimize the number of cylinders stored on this rack. No
flammables will be stored on this rack.
3.3.4 Radioactive Materials
The Acurex Environmental Treatability Laboratory will not accept radioactive material.
3.3.5 Hazardous Waste
Although the quantities generated are monitored very closely by the project task managers and
the ERO Safety Officer, the generation of hazardous waste is unavoidable considering the type of
work performed at Acurex Environmental. The methods of generation and disposal comply with all
local, state, and federal regulations and are specified individually with each project's safety control
sheet.
The safety control sheet addresses PPE needed when handling hazardous waste, the containers
needed for generation, storage, limitations. and physical and health hazards associated with its
generation and other handling.
The Acurex Environmental protocol for purchasing hazardous materials requiring prior
approval by the ERO Safety Officer has proven to limit the quantity of waste generated through
Acurex Environmental operations.
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3.3.6 Employee/Laboratory Monitoring
It is the policy of Acurex Environmental to use engineering and operational controls to prevent
dangerous levels of hazardous matertal in the work place. If a staff members's exposure to a
hazardous substance is believed to exceed published safe exposure levels for that substance is or
represent a hazard, a monitoring and evaluation program will be initiated.
If initial monitoring reveals concentrations greater than the action level or in the absence of an
action level the PEL, Acurex Environmental employees will comply with the exposure monitoring
provision of the relevant standard. If laboratory work involves the use of a hazardous substance
covered by a health standard in Subpart Z of 29 CFR 1910, monitoring provisions for this substance
will be outlined in the individual safety control sheet for the laboratory in question. The task manager
is responsible for ensuring compliance with the health standard.
Acurex Environmental shall terminate exposure monitoring in accordance with the relevant
standard unless those parties involved (task manager, laboratory employees, and the ERO Safety
Officer) agree that exposure monitoring should continue beyond the scope of the standard.
When a hazardous substance is not affected by an OSHA health standard or when the· PEL
exceeds the TL V, the Acurex Environmental Safety Office requires exposure levels to be managed
below the TLV.
The ERO Safety Officer shall notify each monitored employee in writing within 15 working
days of the air monitoring results and shall also post the results in those areas where air monitoring
was completed. The ERO Safety Officer will then file all results within the appropriate laboratory file
fo(future reference.
3.3.7 Employee/Equipment Decontamination Procedures
If exposed to a hazardous material through contact, flush eyes or area of the body with water
for 15 minutes while removing clothing that may restrict the flow of water to the area of
contamination. Medical attention should be sought through contacting the ERO Safety Officer. If
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emergency medical attention is needed, transport the victim to an emergency medical service or
call 911 for emergency aid through the local Parkwood Fire Department, and then contact the
ERO Safety Officer. (See Section 3.8.2 for more information on employee injury.)
Specific equipment decontamination procedures are located in individual safety control sheets.
All materials used in the decontamination of equipment shall be disposed of according to local,
state, and federal regulations and EPA/ERC policy when work is performed at the EPA facility.
3.3.8 Biological Hazards
No biohazardous waste will be accepted. The microbial populations to be evaluated are almost
without exception the indigenous microbial populations. Any exceptions will be dealt with in project-
specific safety control sheets.
3.4 PERSONAL HABITS
Safety is everyone's responsibility and your personal habits affect the risks to yourself and
those you work with.
3.4.1 Working Alone
Working alone is strictly forbidden for all work with the exception of paperwork. Working
alone is defined as working out of contact with a co-worker (not necessarily an Acurex Environmental
employee). Much of the work performed by Acurex Environmental employees requires a "buddy
system" to ensure prompt awareness of safety problems. To work effectively, each employee must be
aware of the location and activities of his or her co-workers.
3.4.2 Housekeeping
Housekeeping is an important part of our safety program. Acurex Environmental employees
are expected to spend time in cleaning up and maintaining a clean, organized work space. This
improves safety, working conditions, and the quality of work.
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3.4.3 Food
Food and beverages are prohibited in laboratories, pilot plant areas, or any area where
chemicals are stored. Food includes gum and tobacco.
3.4.4 Smoking
Smoking is not permitted in laboratories, posted areas, areas of hazardous material use, or
where such activity might create an explosion or fire hazard or contribute to the risk of exposure of
hazardous materials.
3.4.5 Jewelry
Rings and jewelry can get caught in moving machinery, conduct electrical current, and
interfere with the removal of hazardous materials you contact. Remove jewelry when appropriate.
Loose fitting jewelry should be avoided. Rings can also tear chemically resistant gloves.
3.4.6 Hair
Long hair must be restrained (i.e., tucked into a cap or net or held by a clasp or rubber band)
when working with or around machinery with moving parts or around hazardous chemicals.
3.5 MEDICAL SURVEILLANCE
A Medical Surveillance program is provided through Duke Occupational Health Services for
chemical handlers and people who work in areas where they may potentially be exposed to hazardous
materials. A baseline physical, scheduled by the ERO Safety Office, will be performed by a licensed
physician at the time of initial employment. The baseline physical will serve as a background from
which to monitor (through periodic follow-up visits) changes in health and/or exposure to hazardous
materials thereby alerting the physician and staff member before permanent damage occurs. Follow-up
medical visits will be performed annually. The ERO Safety Office will keep a record of all physicals
and will schedule each employee for a follow-up physical once per year. If a supervisor feels that an
employee needs to have an examination more frequently, or if one is required because of a specific
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exposure incident, the supervisor will fill out the request form in Appendix H and submit it to the
ERO Safety Officer.
3.5.1 Subpart Z-Toxic and Hazardous Substances
When the work performed by employees includes the use of hazardous materials listed in
29 CFR 1910 Subpart Z, medical monitoring will be conducted as listed in the individual health
standard.
3.5.2 Medical Consultation and Medical Examinations
Acurex Environmental shall provide all laboratory employees who work with hazardous
chemicals an opportunity to receive medical attention, including any follow-up examinations that the
examining physician determines to be necessary, under the following circumstances:
Whenever an employee shows signs of. acute or chronic exposure effects to a hazardous
chemical he or she has worked with
Where air monitoring results reveal air contaminants routinely above the action level ( or,
in absence of an action level, the PEL) Acurex Environmental shall establish medical
surveillance for the employee as prescribed for the particular health standard
• Whenever an event takes place (spill, leak, explosion, or other occurrence resulting in an
employee's possible exposure to a hazardous chemical), Acurex Environmental shall
provide the employee with the opportunity for a medical consultation. Such consultation
shall determine the need for a medical examination.
All medical examinations and consultations shall be performed by or under the direct
supervision of a licensed physician and shall be provided without cost to the employee, without loss of
pay, and at a reasonable time and place.
The ERO Safety Office will provide the physician with the following information in the event
of employee exposure:
• Hazardous chemical exposed to
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Conditions of exposure, including exposure data, if available
Description of signs and symptoms
When a physician consults or examines an employee, the ERO Safety Officer shall obtain a
written opinion from the physician including the following information:
• Results of medical examination and testing
Recommendation for further medical follow-up
Any medical condition that may place employee at increased risk as a result of exposure
to a hazardous chemical in the work place
• Physician statement to the employee stating the findings of the consultation or medical
examination that may require further examination or treatment
The ERO Safety Officer shall file all written physician opinions and medical examinations
within the employee's files. The written opinion shall not reveal specific findings of diagnosis
unrelated to occupational exposures.
It is important for all employees to alert his or her supervisor and the ERO Safety Officer in
the event of an exposure or potential exposure or any adverse health effects from an exposure to a
hazardous material. An Acurex Environmental Accident Investigation Report (see Form 19 in
Appendix I) shall be completed by each employee exposed or potentially exposed to hazardous
materials (e.g., hazardous material spill).
3.6 SAFETY AUDITS
Safety walkthroughs are performed at least quarterly by the ERO Safety Officer.
Discrepancies found during walkthroughs are pointed out to the responsible staff members. It is
the responsibility of the Project Officer to correct the discrepancies. It is the ERO Safety
Officer's responsibility to monitor progress on the safety action items. A monthly check of
safety equipment and materials storage will be documented by the project staff.
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3.7 PERSONNEL TRAINING
Personnel training is essential to the Acurex Environmental safety program. The ERO Safety
Officer will meet with each new staff member during the first l O days of employment to discuss
Acurex Environmental safety program policies and procedures, including:
The location of this manual
29 CFR 1910.1450 and its appendices
• Specific training requirements for laboratory work
The staff member's supervisor (or designated task manager) will provide relevant project-
specific training when that staff member is assigned to a new area or task. This training will include,
but is not limited to:
Relevant reading (PSCS, pertinent instrument manuals, and standard operating procedures)
• Methods and observation used in detecting releases of hazardous materials used in the
laboratory (odor, taste, air monitoring devices, etc.)
Signs, symptoms, and the PEL's of hazardous materials used in the laboratory
Instruction by experienced staff member (where indicated)
Location and availability of hazard information references, including MSDS
Periodic reviews of safety procedures and protective equipment
• Physical and health hazards of materials used
Measures employees can take to protect themselves when using hazardous materials
The ERO Safety Officer will also organize and present monthly safety seminars throughout the
year. They will typically include instructions in such topics as chemical handling, fire prevention,
electrical safety, etc. Each Acurex Environmental employee who handles hazardous materials must
attend eight hours of safety training each year to be eligible for work requiring the use of hazardous
materials the following year.
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Specific training programs/sessions may also be required in the PSCS. Special programs
may contribute to the required training.
3.8 EMERGENCIES
Our goal is to prevent accidents and avoid emergency situations. However, when accidents do
occur, prior training and contingency planning can significantly reduce the impact of the accident on
personnel, facilities, and the work in progress.
3.8.1 Fire
Small fires can be safely extinguished by trained personnel with the proper extinguisher.
While one person attempts to extinguish the fire, another should call 911 (2600 if working at the EPA
ERC building) and describe the situation to the fire department. If there is any doubt of your ability
to contain the fire, evacuate the building. Provide all the information you can to the emergency
response team from a safe location. Warning horns are mounted at each exit. Staff meet on the berm
west of our facility to take a head count and assure that all staff members and visitors are safe.
3.8.2 Employee Injury or Illness
If you are the only person at the scene of an emergency, it is important that you call for help,
then lend appropriate assistance. Never attempt to rescue someone before donning the proper
protection equipment and requesting the presence of another person. When other people are available,
one person should remain with the injured staff member, administering appropriate assistance. A
second person should call for appropriate help, either through the Safety Officer or ·in urgent
situations through 911, and describe the situation. When reporting an injury or illness:
• Give your location
• Describe the situation
• Provide any other helpful information
.• Stay on the phone until the respondent gives you pennission to go
• At the first opportunity, notify the ERO Safety Officer (544-4535) (Page 956-0896)
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Accident reports (Form 19; see Appendix I) must be completed by the supervisor and
submitted to the ERO Safety Officer within 24 hours of an employee accident.
3.8.3 Hazardous Chemical Spills
All chemical spills should be cleaned up immediately. Small containable spills may be
handled by personnel being careful to use appropriate personal protection (i.e., respirator, gloves, face
shields). When a chemical spill presents a hazard to people in an area or threatens fire or explosion:
Evacuate the area
Notify project Safety Officer
Post and se·cure area
Initiate clean-up
• Initiate appropriate post-clean-up monitoring
• Complete incident report (submit to project Safety Officer)
Proper spill response procedures will be included in each project's safety control sheet.
MSDSs also provide spill response information.
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I APPENDIX A
SAFETY CONTROL SHEET OUTLINE
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I APPENDIX B
SAFETY SHOE REQUEST FORM
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I APPENDIX C
SAFETY GLASSES REQUEST FORM
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I APPENDIX D
PROTECTIVE CLOTHING REQUEST FORMS
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APPENDIX E
ACUREX ENVIRONMENTAL ERO RESPIRATORY PROTECTION PLAN
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APPENDIX F
ACUREX ENVIRONMENTAL ERO LOCKOUTffAGOUT PROGRAM
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APPENDIX G
ACUREX ENVIRONMENTAL ERO HAZARD COMMUNICATION PROGRAM
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I APPENDIX H
PHYSICAL REQUEST FORM
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APPENDIX I
ACUREX ENVIRONMENTAL ERO ACCIDENT INVESTIGATION REPORT
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ACUREX ERO ENVIRONMENTAL LOCKOUT/TAGOUT
PROCEDURES PROGRAM
Prepared for:
Employees of Acurex Corporation
Eastern Regional Office
Prepared by:
Acurex Corporation ERO
Environmental Systems Division
4915 Prospectus Drive
P.O. Box 13109
Research Triangle Park, NC 27709
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Section
1.0 Policy
1 .1
1.2
1.3
TABLE OF CONTENTS
Page
Purpose ......................................................... .
Scope .......................................................... .
1
1
1
Definitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
2.0 Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
3.0 Procooures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
3.1 Lockoutffagout Sequence . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
3.2 General Equipment Restoration Sequence . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
3.3 Equipment-Specific Lockoutffagout Procedure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
4.0 Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
5.0 Inspections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
6.0 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
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ACUREX ERO ENVIRONMENTAL LOCKOUT/TAGOUT
PROCEDURES PROGRAM
1.0 POLICY
All employees are required to comply with the restrictions and limitations imposed upon them
during the use of this lockout/tagout procedure. Only authorized employees are required to perform
lockout/tagout in accordance with the lockout/tagout procedure included in the Project or Task Safety
Protocol. Project and Task Supervisors are required to train authorized personnel in the methods used
to lock or tag out equipment according to established Safety Protocol procedures. All employees, upon
observing a machine or piece of equipment which is locked or tagged out, shall not attempt to start,
energize, or use that machine or equipment until the lock or tag is removed by the employee to whom it
belongs.
1.1 PURPOSE
This procedure establishes the minimum requirements for the lockout/tagout of hazardous
energy sources as they pertain to Acurex Environmental Systems Division/Eastern Regional Office
(ERO) employees and their work areas. Acurex Environmental ERO employees shall implement this
program before performing service or maintenance on equipment or machines where the unexpected
energizing or start-up of the equipment or machinery or release of stored energy could cause employee
injury.
1.2 SCOPE
This procedure applies to all equipment that receives its energy from electrical power,
pneumatic, hydraulic fluid under pressure, compressed air or steam, energy stored in springs, potential
energy from suspended parts, or any other source tha.t may caus~ unexpected movement when it is
necessary to perform maintenance on that system.
1 .3 DEFINITIONS
Authorized employee: A person who locks out or tags out! machines or equipment in order to I
perform servicing or maintenance on that machine or equipment. IAn affected employee becomes an
authorized employee when that employee's duties include perform'ing servicing or maintenance covered '
under this section.
Energized: Connected to an energy source or containing 'residual or stored energy. I
Energy isolating device: A mechanical device that physic1jlly prevents the transmission or
' release of energy, including but not limited to the following: A manually operated electrical circuit I
breaker; a disconnect switch; a manually operated switch by which the conductors of a circuit can be I
disconnected from all ungrounded supply conductors, and, in addition, no pole can be operated . I
independently; a line valve; a block; and any similar device used to block or isolate energy. Push I --
buttons, selector switches and other control-circuit-type devices are NOT energy-isolating devices.
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Energy source: Any source of electrical, mechanical, hydraulic, pneumatic, chemical, thermal, I
or other energy.
Lockout: The placement of a lockout device on an energy isolating device, in accordance with . I
an established procedure, ensuring that the energy isolating devic~ and the equipment being controlled I .
cannot be operated until the lockout device is removed.
Lockout device: A device that utilizes a positive means such as a lock, either key or I
combination type, to hold an energy isolating device in a safe position and prevent the energization of a I
machine or equipment. Included are blank flanges and bolted slip
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blinds. I
Servicing and/or maintenance: Workplace activities such as constructing, installing, setting up, I .
adjusting, inspecting, modifying, and maintaining and/or servicing fnachines or equipment. These
I activities include lubrication, cleaning or unjamming of machines_ or equipment and making adjustments I
or tool changes, where the employee may be exposed to the unexpected energization or startup of the I
' equipment or release of hazardous energy.
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Tagout: The placement of a tagout device on an energy isolating device, in accordance with an
established procedure, to indicate that the energy isolating device and the equipment being controlled
may not be operated until the tagout device is removed.
Tagout device: A prominent warning device, such as a tag and a means of attachment, which
can be securely fastened to an energy isolating device in accordance with an established procedure, to
indicate that the energy isolating device and the equipment being controlled may not be operated until
the tagout device is removed.
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2.0 EQUIPMENT
All lockouVtaggut equipment used by Acurex Environmental ERO employees shall be of uniform I
size, shape, and color.
1 . Locks: Locks must be equipped with a case-hardenbd steel shackle and enough I
2. Tags:
I clearance for use with lockout hasps. Locks may be combination or key and must I
be identifiable by employee. Color coding used in conjunction with an employee's I .
initials stenciled or engraved onto the lock would be adequate. Each individual I
Safety Protocol shall establish a method of differentiating between employee '
I locks. Locks used for this program must not be used for any other purpose.
I I Two tags will be used by Acurex Environmental ERO employees for tagging out I
equipmenVmachinery for service or maintenance and shall be standardized
throughout the company.
• "DO NOT OPEN VALVE" tag will be used when de-energizing compressed I
air, steam, water, or chemical material stored in pipes, lines, or hoses and for
hydraulic and pneumatic equipment. T~e tag shall have a designated location
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for the employee's name and shall be of sufficient size not to be mistaken for
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anything other than its intended purposk. Tags and their printed warnings
I shall be capable of withstanding the environmental conditions in which they
are used.
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• "DO NOT START --Equipment Locked Out" tag will be used when de-
energizing electrical and/or mechanical equipment where an energy isolating
switch controls the start-up and shut-down of the equipment/machine. The
tag shall have a designated location for the employee's name and shall be of
sufficient size not to be mistaken for anything other than its intended purpose.
Tags and their printed warnings shall be capable of withstanding the
environmental conditions in which they are used.
3. Lockout Hasps:Lockout hasps shall be made of hardened steel capable of withstanding the
environmental conditions in which they are used. The hasp shall be
constructed to remain closed around the energy isolating switch until the last
lock is removed. Damaged or disfigured lockout hasps shall be removed and
replace,! immediately upon recognition.
4. Chains:
5. Ties:
6. Blanks:
Chains used in the lockout process shall be steel alloy capable of resisting
forces it may encounter. Each link's inner diameter shall be of adequate size
for use with the locks and lockout hasps.
Ties used to affix tags to the energy isolating switch shall be of a non-
reusable type, attached by hand, self-locking and non-releasable with a
minimum unlocking strength of no less than 50 lbs and having a general
design and basic characteristics of being at least equivalent to one piece, all
environment-tolerant nylon cable tie.
Blanks used to block material contained within pipe systems shall be of
sufficient thickness and size, and constructed of material compatible with the
contents of the pipe.
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3.0 PROCEDURES
3.1 LOCKOUT/TAGOUT SEQUENCE
1 .
2.
3.
4.
Before locking or tagging out a piece of equipment/machi~e. an authorized employee shall give
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notice to all employees in proximity not involved with the Jrocedure. Proper notice shall include
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the name and location of the equipment/machine to be locked/tagged out, date and time of the . I
lockout/tagout, the name of the authorized employee sup~rvising the procedure, and adequate
I notice signifying the lockout/tagout procedure is completed.
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An authorized employee shall place signs around the equipment/machine alerting personnel not
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to operate the equipment/machine until all signs, locks ana/or tags are removed and an
' ' authorized employee has inspected the equipment/machirie for re-energization.
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If the equipment/machine is operating, shut it down by the normal stopping procedure {depress
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stop button, open switch, close valve, etc.). Refer to the equipment specific lockout/tagout
procedure included in the Project/Task Safety Protocol to 1determine the shut-down steps
relevant to your operation. I
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Deactivate the energy isolating device(s) so the equipmeAt!machine is isolated from the energy
source(s). Follow all emergency lines from their source th the equipment to ensure all sources
are isolated.
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5.
6.
7.
8.
Lock or tag out the energy isolating device(s) with assigned individual locks or tags. Locks and
tags are furnished separately through each Project and must meet the parameters of this
program. Lockout devices must be affixed in the "off" or "safe" position. Tagout devices shall
be used to clearly show energy isolating devices in the "off" or "safe" position and when used
where lockout devices could be used, the tag shall be fastened at the location made available
for the lockout device. Each employee involve in the servicing or maintenance of a piece of
equipment/machine covered under the lockout/tagout section of a Safety Protocol must attach
his/her lock or tag to each energy isolating device.
Release or restrain all stored or residual energy (such as that in capacitors, springs, elevated
machine members, rotating flywheels, hydraulic systems, air, gas, steam, or water pressure,
etc.) by methods such as grounding, repositioning, blocking, bleeding down, etc. Where there
is a possibility of energy reaccumulation, authorized personnel shall verify periodically that
energy isolation is maintained until service or maintenance is completed.
Ensure the equipment is disconnected from the energy source(s) by first checking that no
personnel are exposed, then verify the isolation of the equipment by operating the push button
or other normal operating control(s) or by testing to make certain the equipment will not
operate. Remember to return operating controls to the "off" position after verifying and before
pertorming service or maintenance on the equipment/machine.
The equipment/machine is now locked or tagged out.
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3.2 GENERAL EQUIPMENT RESTORATION SEQUENCE
I After all servicing or maintenance is completed, authorized personnel shall adhere to the
following general procedures when restoring energy to the equipm~nVmachine. Specific energy I restoration procedures are located in the individual Safety Protocoi established for each individual I
' Project or Task.
1. Inspect the equipmenVmachine and the immediate area a/ound the machine or equipment to
ensure that all personnel and nonessential items have beJn removed and that the
I equipmenVmachine components are operationally intact. I
2. Check the work area to ensure that all authorized employees, those involved in the ' .
lockouVtagout, have been safely positioned and accounted for before proceeding further with
energy restoration.
3. Verify that the controls ar_e in neutral.
4. Remove the lockouVtagout device(s) and signs and reenergize the equipmenVmachine. Each I
' ' authorized employee must remove his/her own lock(s) or tag(s). It is against company policy to
remove another employee's lock(s) or tag(s) unless:
• The employer or supervisor of the lockouVtagout task verities that the authorized I
•
•
employee who applied the device is not at the fa~ility ·
All reasonable efforts have been made to contact' the authorized employee informing
him/her that his/her lock/tag has been removed; Jnd
I The authorized employee is knowledgeable about the fact his/her lock/tag was I
removed.
There must also be a method of ensuring that authorized 1employees have knowledge of his or I I her lock(s)/tag(s) being removed before resuming work the follow·ng day.
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All methods one uses to locate and/or contact an authorized employee to remove, or about the
removal of, his/her lock(s) or tag(s) shall be documented and maintained in the Project/Task file.
Documentation shall include:
• Name of the authorized employee
• Date and time of contact
• Contact message and authorized employee reply
Note: The ERO Safety Office considers the act of permanently leaving a lockout/tagout site
without removing one's lock(s) or tag(s) and informing others of the status of the
equipment/machine previously locked or tagged out a serious breach of company
policy requiring disciplinary action.
5) Notify affected employees, those employees using the equipment/machine, that the
servicing or mainten~nce is completed and the equipment/machine is ready for use.
3.3 EQUIPMENT-SPECIFIC LOCKOUT/TAGOUT PROCEDURE
The following paragraphs outline lockout/tagout methods for specific categories of
equipment/machines. This section, as is the entire Acurex Environmental ERO Lockout/Tagout
Procedures Program, is designed to aid Acurex Supervisors and/or Task Managers in creating a
lockout/tagout procedures(s) as it pertains to equipment/machines utilized in their task(s). These
methods should not be confused as procedures but should be used in the procedural development.
1 . Cord-or Plug-Connected Electrical Equipment/Machines
Exposure to the hazards from the unexpected energization or start-up of equipment controlled
by the unplugging of equipment from its energy source with the plug being under the exclusive
control of the employee performing the servicing or maintenance, is not applicable to
lockout/tagout requirements, if:
•
•
The cord or plug must be secured to the equipment/machine to which it belongs and
The cord or plug is in clear view of the authorized individual performing the service or
maintenance.
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2.
3.
If these two requirements cannot be met, the authoriz1ed individual shall initiate a
I lockout/tagout procedures using a method, or combination of methods, located in the I
section entitled "Electrical Equipment".
Electrical Equipment
Electrical equipment, other than plug or cord type, shall utnize one or a combination of
lockout/tagout devices ~uthorized by this program when t~e servicing or maintenance of that
I equipment involves electrical work or the insertion of body parts into the working assembly of
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the equipment/machine. Methods of lockout/tagout includk:
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I • Locking or tagging the entire electrical panel and/or individual switches;
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• Locking/blocking internal moving parts in resting position; and
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• both, if the potential exists that performing one o/ the other above does not control all
energy sources I
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Whenever employees perform service or maintenanc~ on electrical equipment, all electrical
I sources/circuits must be locked or tagged out. Other methods may be used in conjunction with
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electrical deenergization, but not in substitution. I
It is significantly important to remember that a piece bf equipment or machine capable of
I being locked out, must utilize a lockout method as opposed to tagout unless approved by the I
ERO Safety Office. When tagout is approved as an equ~lly-safe method as lockout, authorized
employees shall place tagout devices at the same locatioh designed for lockout devices.
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Pneumatic and Hydraulic Equipment
Pneumatic-and hydraulic-driven equipment/machines po~e significant safety hazards when not
I locked or tagged out properly before performing service 6r maintenance. These systems tend . I
' to build up pressure within their lines when locked/tagged out if care is not taken to open
locking vents preventing pressure buildup and possible e~uipment movement during service or
I maintenance.
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4.
The best method of locking/tagging out pneumatic and hydraulic equipment is by removing
the energy source when possible. This method should only be used when the
equipment/machine and all moving parts are in their resting position or lowest state of potential
energy.
Another method of controlling the energization of pneumatic and/or hydraulic
equipment/machines is to lock/tag out each individual valve and pressure bleed vent
capable of releasing and storing pressure respectively from or within the
equipment/machine, in conjunction with physically blocking or guarding all moving parts
within the unit capable of causing injury to those performing service or maintenance.
Process Lines
Process lines containing compressed air, water, steam, or hazardous materials must be shut,
drained, and blanked before authorized employees can provide service or maintenance. The
proper steps to follow when entering a process line include, in this order:
• Isolating the line by closing and locking/tagging all valves entering the line. Use a steel
alloy chain and lock meeting the requirements of this Program when locking out a valve
• Remove all free product by pumping or draining
• Insert a blank or blind in the line to block it completely. This step is important since valves
have been known to leak even when fully closed
Note: Entering or breaking a process line requires prior approval from the Safety Office.
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4.0 TRAINING
Acurex Environmental shall train all employees involved in lockout/tagout procedure. The ERO ' I
Safety Office shall provide initial Program training to all employees involved, or potentially involved, with
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the lockout/tagout procedure. This training will include: I
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• Recognition of applicable hazardous energy sources
! • The contents of this program; and I
• I The location of individual lockout/tagout procedur,es .
-I Employee supervisors must provide training to their perso"nnel involved with service or
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maintenance of equipment/machines requiring the implementatiori of this program. Training must
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include: I
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• Type and magnitude of energy in the workplace 1
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• Methods and means necessary for energy isolation and control
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• Specific use and purpose of equipment/machine/energy control procedures
• Procedures for restarting or reenergizing equipment/machines which are locked or
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tagged out
I When tagout systems are used, training shall include: I
• Tags provide warning and not the physical restrlint of locks;
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• Tags shall only be removed by the authorized person responsible for it and shall never
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be by-passed, ignored, or otherwise defeated; 1
I Tags must be legible and must include the name of the authorized person and date •
service or maintenance is being performed;
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• Tags and materials used for attachment must be capable of withstanding all
environmental conditions imposed on it;
• Tags shall be attached to the energy isolating device so as not to be inadvertently
detached; and
• Tags are valid for one shift only and must be replaced by the authorized employee if
work should continue
Retraining of employees on lockout/tagout procedures shall occur whenever procedures change
or when routine or annual procedural and equipment/machine inspections reveal employee deviation
from the established procedure.
Training performed by supervisors shall include topics covered, each employee's name, and
date(s) given. Supervisors shall send the Safety Office a copy of all training immediately upon
completion and maintain a copy f_or the Project/Task file.
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5.0 INSPECTIONS
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I Safety Office inspections on the lockout/tagout program will be pertormed annually. All
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documentation will be filed in the Safety Office with the original lockout/tagout program. The inspection
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shall include a review between the supervisor and his/her authorized employees responsible for
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implementing the lockout/tagout procedure.
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6.0 CONCLUSION
The contents of this program are mandatory, and therefore, complete understanding of this
program is essential in providing a safe and healthy workplace when attempting to service or
maintenance equipment/machines requiring the implementation of a lockout/tagout procedure meeting
this program's definition.
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ACUREX ENVIRONMENTAL ERO
EMPLOYEE RESPIRATORY PROTECTION PROGRAM
September 23, 1991
Prepared for:
Employees of Acurex Corporation
Eastern Regional Office (ERO)
Prepared by:
Acurex Corporation (ERO)
Environmental Systems Division
4915 Prospectus Drive
P.O. Box 13109
Research Triangle Park, NC 27709
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TABLE OF CONTENTS
Section Page
1.0 Purpose . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
2.0 Soo~ ................................................................ .
3.0 General ............................................................... .
4.0 Selection of Respirators . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
5.0 Air Quality and Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
5.1 Breathing Air Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
5.2 Compressed Air . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
5.3 Air Line Couplings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
5.4 Breathing Cylinder Markings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
6.0 Use of respirators . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
6.1 Fit-test . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
6.2 Respirator Selection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
6.3 Donning and Doffing Respiratory Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
7.0 Respirator user . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
8.0 Maintenance and care . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
8.1 Inspections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
8.2 Decontamination of the Respirator . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
8.3 Storage of the Respirator . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
8.4 Repairs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
9.0 Cartridges . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
10.0 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
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Appendix A:
Appendix B:
Appendix C:
Appendix D:
Appendix E:
LIST OF APPENDICES
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Respiratory Protection Standard 29 CFR 1910.13,~
Respirator Certification Form
Safety Protocol Outline
Monthly SCBA and APR Inspection Checklist
Cartridge Color and Selection Chart
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APR
CRZ
EOT
EZ
IDLH
OSHA
PEL
PPE
SAR
SCBA
TLV
Air-purifying respirators
Contamination reduction zone
Emergency operations team
Exclusion zone
Dangerous to life and health
LIST OF TERMS
Occupational Safety and Health Administration
Permissible exposure limit
Personal protective equipment
Supplied-air respirator
Self-contained breathing apparatus
Threshold limit value
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ACUREX ERO
EMPLOYEE RESPIRATORY PROTECTION PROGRAM
1.0 PURPOSE
The purpose of the Acurex Environmental Systems Division/ERO Employee Respiratory
Protection Program is to establish guidelines for and train employees on the use, care, and limitations
of respiratory protection.
2.0 SCOPE
The Acurex ERO Respiratory Protection Program establishes guidelines consistent with the
contents of the ERO Policy and Procedures Manual. The guidelines govern the use of all respiratory
protection by Acurex employees. The Program will incorporate all aspects of the Occupational Safety
and Health Administration (OSHA) Respiratory Protection Standard-29 CFR 1910.134 (see Appendix
A) and will cover all Acurex Environmental ERO employees requiring respiratory protection.
Determining the need of respiratory protection will be based on and incorporated into each individual
Safety Protocol.
3.0 GENERAL
All respiratory protective equipment used by Acurex employees will be approved by the
National Institute for Occupational Safety and Health and the Mine Safety and Health Administration.
Only those Acurex Environmental Systems Division/ERO employees who are participating in the
Medical Monitoring Program, deemed physically fit by a licensed physician, and fit-tested by an
authorized Acurex Safety Office employee shall be approved to wear respiratory protection. Only parts
approved for a specific respirator are to be used for replacement. Respirators requiring repair must be
brought to the attention of the ERO Safety Office immediately. All repairs will be conducted under the
guidance of the ERO Safety Office.
When personnel approach a task that involves hazardous 1materials and that requires I
respiratory protective measures, they shall consider respirators asi the last precaution. Engineering
I controls (e.g., chemical hoods or glove boxes) shall supersede th'il use of respiratory equipment. When . I respiratory protection (respirator) is the only alternative, employees shall adhere to the following Acurex I
I respiratory protection policies.
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4.0 SELECTION OF RESPIRATORS
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I The Task Manager and ERO Safety Officer will make thejproper selection of respirators
according to the American National Standard Practices for Respirktory Protection 266.2-1969, NIOSH, I
and relevant exposure indices for the material in question (PEL, TLV, odor threshold, etc.). The correct
I respirator is to be specified for each task. Laboratory Safety and/or Task Protocols will establish the
I need for respiratory protection, including the type of respirator, protection needed, and cartridge if air-
purifying respirators are used.
5.0 AIR QUALITY AND SYSTEMS
5.1 Breathing Air Requirements
When respiratory protection involves the use of supplied air through a self-contained breathing
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apparatus (SCBA) or supplied-air respirator (SAR), breathing air ~hall meet the requirements of Grade
I D breathing air as described in the Compressed Gas Association Commodity Specification G-7.1-1966. '
At the time of purchase, the supplier shall provide a certificate vJrifying the grade of all breathing air. I
Task Managers must maintain a copy of this certificate and mus/ send the original to the Safety Office I
to be filed with the task safety plan. I
5.2 Compressed Air
I Air compressors meeting breathing-air requirements shall not be used by Acurex I
Environmental/ERO employees without prior approval from the ERO Safety Office.
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5.3 Air Line Couplings
Air line couplings shall be incompatible with outlets from other gas systems to prevent
inadvertently filling breathing air cylinders with non-respirable gases or oxygen.
5.4 Breathing Cylinder Markings
All breathing air cylinders shall be marked to identify the material contained. Proper markings
are "Federal Specification BB-A-1034a, June 21, 1968, Air Compressed for Breathing Purposes" or
"Interim Federal Specification GG-B-00675b, April 27, 1965, Breathing Apparatus, Self-Contained."
Compressed gas cylinders without one of these markings shall not be used for breathing air. If either
of these statements is accidentally removed from a cylinder, employees shall contact the Safety Office
immediately.
6.0 USE OF RESPIRATORS
After passing the medical monitoring exam, and annually thereafter, employees must have a
successful fit-test before wearing an air-purifying respirator (APR). Fit-tests are not necessary when
wearing positive pressure air-supplied breathing apparatus, but use of these systems by Acurex
employe_es shall be authorized by the ERO Safety Office.
6.1 Fit-test
A respirator fit-test includes a qualitative and/or quantitative exam. The qualitative fit-test
includes two separate steps, gently inhaling, while covering the cartridges with his or her hands and
gently exhaling while covering the exhalation valve with one's hand, noticing movement of the respirator
toward and away from the face, respectively. If leaks are present, adjustments should be made, and
the device should be retested until no leaks are detected, demonstrating a satisfactory face-piece-to-
face seal. If no leaks are detected, the employee will be placed into two controlled-test atmospheres,
one consisting of lso-Amyl Acetate and the other of irritant smoke. Only those persons not detecting
the test atmospheres shall be certified.
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I The quantitative fit-test calculates individual protection factors for respirators given to
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employees. An example of quantitative fit-test equipment is a Portacount.
Either fiHest method is acceptable as long as the ERO sdfety Office administers the test and a
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Respirator Certification Form is on file for each person passing the fit-test (see Appendix B).
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6.2 Respirator Selection I i
The type of respirator needed for a specific task shall be determined by the Safety Office from
knowledge of the hazardous materials' chemical and physical proderties, the manner in which the
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hazardous material(s) is used, and any available air monitoring results, if they exist. The decision also
will consider the range of other protective measures have been e~hausted (e.g., engineering controls).
Because each compound is different in chemical and phy4ical properties, specific guidelines
cannot be set to determine the type of respiratory protection needbd in every situation, although the -I
following general guidelines shall be adhered to by all Acurex employees:
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• Air-purifying respirators (APR), supplied-air respiratorb {SAR), or self-contained breathing
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apparatus (SCBA) shall be worn if air concentrations ifor a specific compound exceed the
I compounds Permissible Exposure Limit (PEL), or, in its absence, the Threshold Limit Value
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(TLV). (Type of respirator selected will be determined by the Safety Office, which
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maintains thorough knowledge of potential chemical br physical respiratory exposure based
I on air concentration and respirator protection factors.')
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• SARs shall be worn in oxygen-deficient atmospheres1 (containing less than 19.5 percent
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oxygen). I
• SARs shall be worn in Immediately Dangerous to Life and Health (IDLH) and unknown
I atmospheres.
• SARs shall be worn when working with toxic comportents having poor warning properties
(e.g., odorless). I
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It is important to remember that the use and type of resp\ ratory protection selected shall be a
I decision made by the ERO Safety Office.
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In the event of a toxic gas release at the EPA/RTP facility employees should take the following
steps:
1. Pull the fire alarm.
2. Call 2900 from a safe location to report the emergency.
3. Describe the emergency to the Emergency Operations Team (EOT).
4. Leave the building following the facility's Employee Emergency Egress Plan.
The EOT will receive guidance on respiratory protection from the EPA/ORD Health and Safety
Department. (Note: Unless given prior approval from the ERO Safety Office, Acurex personnel shall
not enter a known toxic atmosphere with or without an air-supplied respirator.)
In the event of a toxic gas release at an Acurex ERO facility or project site, employees should
take the following steps:
1. Pull fire alarm or engage employee emergency warning signal.
2. Leave the building as outlined in the Acurex or project site Employee Emergency Egress
Plan.
3. Wait for the Emergency Rescue Team to arrive and describe spill or release.
When using hazardous chemicals in the laboratory, respiratory protection guidance shall take
the form of comments or mandates by the Acurex ERO Safety Office when reviewing Safety Protocols
(see Appendix C-Safety Protocol).
6.3 Donning and Doffing Respiratory Protection
When using respiratory protection in dangerous atmospheres, employees must be careful to
don and doff the respirators with extreme caution to prevent inadvertent contamination to the inside of
the mask or the user.
A clean area or contamination reduction zone (CRZ), adequately removed from the
contaminated area, shall serve as the location to don all personal protective equipment (PPE), including
respiratory equipment. At this time, a face-piece-to-face seal shall be pertormed by all personnel
entering the contaminated area or exclusion zone (EZ).
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No fewer than two persons shall enter an EZ when respidtory protection is required. The use I
of a "buddy" system shall require visual or voice communication a) all times.
In /DLH atmospheres, personnel entering the EZ shall be bquipped with a safety harness and I
line to expedite removal of personnel in emergency situations. P~rsonnel shall never enter an IDLH
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atmosphere and/or confined space to rescue another employee unless support equipment and
personnel are present and the proper PPE has been selected for bntry. Only SCBA or SAR with . !
I emergency egress bottle shall be used to enter IDLH atmospheres. APRs and SARs without I
emergency egress bottles are prohibited in IDLH atmospheres. !
When doffing respiratory protection, employees should relnove old gloves and don clean gloves I
to prevent the transfer of hazardous materials from the old glove!i to the face and the inside of the
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respirator. Caution should always be used when doffing respiratory protection to ensure it is removed
in a clean atmosphere.
7.0 RESPIRATOR USER
I All Acurex employees required to wear respiratory protection shall receive fitting instructions at I
the time of his or her fit-test. These instructions shall include how to:
I • Wear a respirator
• Adjust the respirator for a proper fit
• Determine whether the respirator fits properly
• Doff a respirator
• Decontaminate a respirator (see Section 8.2)
Other items of importance include: I
I • Removal of all facial hair impeding a proper seal between the mask and the user's face '
• Prohibition of wearing contact lenses in contaminatJd atmospheres with a respirator I
(corrective spectacles can be mounted inside a respirator)
I Retesting respirator fit following facial transfiguration (e.g., scars, dentures, surgery, etc. ) I
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8.0 MAINTENANCE AND CARE
8.1 Inspections
Employees assigned a respirator shall inspect it routinely before and after each use, or
monthly, whichever is most frequent. SCBA shall be inspected monthly by the ERO Safety Office.
(Refer to Appendix D-SCBA and APR Inspection Checklist.)
Respirator inspections shall include checking the tightness of connections, the condition of the
face-piece, headbands, valves, connecting tubing, pliability, and signs of deterioration of rubber or
elastomer parts.
A record shall be kept in the ERO Safety Office of respiratory inspection dates and outcomes
for respirators maintained for emergency use.
8.2 Decontamination of the Respirator
Daily or after each use, whichever occurs least frequently, respirators shall be cleaned and
disinfected. To accomplish respirator decontamination, employees must:
• Remove inhalation and exhalation valves on air-purifying respirators (APRs).
• Thoroughly scrub entire surface area of respirator and parts in warm, soapy water.
• Rinse respirator and parts of all soap.
• Place respirator and parts in a 1 cup:1 gallon mixture of liquid bleach and water,
respectively, and let them stand for 5 minutes.
• Rinse respirator and parts adequately to remove the bleach solution.
• Thoroughly dry the surfaces of the respirator and parts completely. Do not air-dry
respirators. Use paper towels or a cloth to dry your respirator.
After the decontamination procedure is completed, and the parts and respirator are dry,
reassemble the respirator for storage.
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B.3 Storage of the Respirator
All respirators shall be stored to protect against dust, contaminants, sunlight, heat, extreme I
cold, and excessive moisture. Minimum protection shall be an airltight plastic bag. Emergency-use !
respirators shall be stored according to manufacturer's recommendations.
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Regardless of the respirator type, all respirator masks shall be stored face-down. Storing a
I mask in this fashion prevents disfiguring the elastomer and maint<1ins the manufactured shape for a
proper fit.
B.4 Repairs
Only experienced persons shall attempt replacements or fepairs to a respirator with parts
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designed by the manufacturer specifically for the respirator. These repairs or replacements shall not go
I beyond the manufacturer's recommendations. Reducing or admission valves or regulators shall be
I returned to the manufacturer when needing repair. I
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9.0 CARTRIDGES I
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A variety of cartridges exists for APRs. The specific cartridge used depends upon the type of
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contaminant against which the user needs protection. Common cartridges include organic vapor, acid
I gases, ammonia, particulate, and various combinations of the ab9ve. Employees can identify cartridges
I in two ways: by color and wording. A color code chart is available in Appendix E. ' I When received from the supplier, cartridges shall be dated and shall not remain in storage I
' longer than four years. While in storage, the labeling must remain intact and the colors must not wear I
or fade. If any such deterioration occurs, it must be reported to the ERO Safety Office.
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Before inserting cartridges, check the date and look for :visible damage to the cartridge. A final
I test is required before using chemical cartridges. This test inclu~es shaking the cartridge vigorously
I while listening for any "rattling" noise. If a rattling noise occurs, the cartridge is damaged and must be
discarded. If no rattling occurs, the cartridge is ready for use.
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10.0 CONCLUSION
Not following the contents of this respiratory protection program is considered a breach of
company policy and may result in a serious accident to the user of respiratory equipment. This
program is designed for the safety of Acurex Environmental Systems Division/ERO employees, and
lack of compliance will result in disciplinary action.
It is important to understand the differences between respiratory equipment and their individual
limitations. It is also important to understand that respirators shall be the last line of respiratory
protection used alter the ERO Safety Office has determined that all engineering controls fail to provide
the proper respiratory protection.
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I APPENDIX A
I Respiratory Protection Standard
29 CFR 1910.134
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I APPENDIX B
I Respirator Certification Form
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I APPENDIX C
I Safety Protocol Outline
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APPENDIX D
Monthly SCBA and APR Inspection Checklist
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I APPENDIX E
I Cartridge Color and Selection Chart
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Appendix C:
McLaren Hart Environment Engineering
Low Temperature Thermal Desorption Technology Description
Past and Prior Uses of Technology
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The low temperature vacuum desorption technology is now 4 years old and has been used in two forms.
The IRV-100 Hydrocarbon Extractor operates at I to 10 inches of mercury of vacuum pressure while
utilizing 3,000 cubic feet per minute (CFM) of air to strip the soils while they are heated with infrared
energy. This system has been used to treat chlorinated solvents, petroleum products ranging from gas to
crude oil, alcohols, polyaromatic hydrocarbons (PAHs) and phthalates.
The IRHV-200 system, which is to be used for this treatability study, operates at 25 to 29 inches of
mercury of vacuum with 300 CFM of purge air and infrared heating. The system will desorb and trap
organics and some inorganic constituents with boiling points of 1200° F or less. The desorption takes
place in an oxygen free environment so that undesirable breakdown products do not form. Technology
is applicable for pentachlorophenols, polychlorinated biphenyls (PCBs), mercury, mixed waste (low level
radionucleotides and organics), dioxins, furans, PAHs and pesticides.
A technical description follows.
General Process Description
The general operating parameters of the L TTDS are: (a) depression of the boiling points of the target
compounds by lowering the ambient pressure within the treatment chamber using a vacuum pump; (b) use
of infrared radiation to generate a thermal gradient in the top several inches of non-liquid material
contained within the treatment chamber and (c) use of a carrier gas to transport the desorbed contaminants
from the treatment chamber to a pollution control system as well as enhance the conveyance of thermal
energy through the non-liquid material. The overall effect of these parameters is a batch treatment system
that is capable of desorbing target contaminants from a non-liquid material under a non-oxidative
atmosphere and low temperature such that the desorbed contaminants do not degrade and generate thermal
or oxidative by-products. Essentially, the desorbed contaminants undergo a reversible phase change from
liquid to vapor in the treatment chamber and are condensed back to liquid in the pollution control system.
The following information will examine in further detail the dynamics of these system parameters.
Vacuum Conditions
One feature of the L TIDS is that the system operates! under less than atmospheric
pressure or vacuum conditions. Using a vacuum pumb, air is evacuated from the
I treatment chamber at approximately 300 cubic feet per minute (cfm) to create vacuum
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conditions within the treatment chamber; the strength of this vacuum is approximately 28
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column inches (Hg). The air is evacuated from the treatment chamber through four (4)
2" extraction tubes located along the bottom of the tre~tment chamber. In order to
maintain the vacuum conditions at a steady state, atmosbheric air is allowed into the
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treatment chamber through the top of the system. The flow of air is controlled by needle
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valves and monitored with an in-line vacuum gauge. i
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The benefit of operating the L TIDS under vacuum conditions is the amount of energy
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required to desorb the target contaminants is significantly reduced as compared to :
removing these contaminants at atmospheric pressure. For example, the boiling point of
Aroclor-1260 is approximately 750 degrees Fahrenheit I at atmospheric pressure; this
boiling point is reduced to approximately 475 degrees Fliirenheit at a vacuum pressure
I of 28 column inches of mercury. This represents la temperature differential of
approximately 175 degrees Fahrenheit for desorbing and equivalent mass of contaminant
from the soil. I
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A second benefit of operating the L ITDS under vacuum !conditions is the low operating
temperatures of the system, eliminating the potential of 'generating undesirable thermal
' degradation products such as dioxins or furans. Essentially, the contaminants undergo a
phase change from the liquid phase to a vapor stage; ther~ are no changes in the chemical
! structure of the compounds. I
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A third benefit of operating the L ITDS under vacuum .conditions is the atmosphere within
the treatment chamber is non-oxidative in that concentrJtion of available oxygen is less I I than 5% when compared to atmospheric conditions. As stated, the mass flow rate of air
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from the treatment chamber to the vacuum pump is approximately 300 cfm; however, this
flow rate is measured at a reduced pressure, approximately I psi. Therefore, the partial
pressure of available oxygen in the treatment chamber is approximately 0.20 psi as
compared to a partial pressure of 3.0 psi under atmospheric conditions. This equates to
a concentration of available oxygen in the treatment chamber of approximately I%.
Further, the mass flow rate of air (atmospheric) entering the treatment chamber and
exiting the discharge side of the vacuum pump is approximately 20 cfm. This number
is calculated using the ideal gas equation and steady-state conditions. Essentially, the
atmospheric air entering and exiting the L TTDS is compressed to approximately 15 psi.
The advantage of desorbing contaminants under non-oxidative conditions pertains to the
formation of thermal degradation by-products such as dioxins and furans. In addition to
energy, oxygen must be present in an appreciable amount during the treatment process in
order to form dioxins and furans. In the relative absence of oxygen at low operating
temperatures, the potential for forming dioxins and furans during thermal desorption is
essentially eliminated.
Infrared Radiation
A second feature of the L TTDS is that the system uses infrared radiation to generate the
thermal energy necessary to desorb the contaminants. The advantage of an infrared
system is efficiency of energy when compared to a "conventional" low temperature
thermal desorption system. In general, other systems use an indirect energy source,
usually a gas or oil fired burner, to heat the air contained within the desorption chamber
and convectively transfer the them1al energy to the non-liquid material using a counter-
current flow. The degree of energy transfer for the LTTDS's infrared system is
approximately 80% while the degree of energy transfer for a "conventional" air transfer
system is usually less than 50%. The lower efficiency in energy transfer for the
"conventional" system is largely due to the low thermal conductivity and specific heat
values for air.
The L TTDS 's thermal energy source utilizes a propane fired combustion chamber to
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directly heat an array of aluminized, steel tubes to a tempdrature of approximately 1100
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degrees Fahrenheit. At this temperature, the tubing emits electromagnetic energy in the
I infrared spectrum. This generated infrared energy is absorbed by the surface (top several
' inches) of non-liquid material and the target contaminants at the chemical bond level, I
primarily the carbon-hydrogen bond. The absorbed energy causes the affected chemical
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bonds to vibrate and essentially generate an internal thermal energy or heat. Within ten
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to fifteen minutes, the surface of the non-liquid material i,s heated to approximately 200
to 300 degrees Fahrenheit. The degree of heating is /dependant on several factors
' including the moisture content and the physical nature of/the non-liquid material.
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Subsequent to heating the top several inches of material with infrared energy, the
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remaining volume of material is heated by means of cbnductive and convective heat
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transfer. The conductive transfer of heat within the maierial proceeds from a zone of
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higher temperature to lower temperature in accordance with classical laws that govern
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thermodynamics and heat transfer. This rate of conductive transfer is regulated by the
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inherent matrix of the material, particularly the percenta~e of contained moisture, The
' convective transfer of heat within the material also proceeds from a zone of higher I
temperature to lower temperature by means of the evacuated air stream,
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Carrier Gas
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The third operating feature of the L TTDS is the use 6f a carrier gas to transport the
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desorbed contaminants from the treatment chamber to a pollution control system, The ' I source of this carrier gas is the air being evacuated from the treatment chamber during the
' ' generation of the operating vacuum; the rate of flow for the evacuated air is
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approximately 300 cfm, As noted, the primary function of the air flow is to convey the
desorbed contaminants from the treatment chamber t,~ the pollution control system,
particularly the condenser. Otherwise, the desorbed 6ontaminants would re-condense
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within the treatment chamber following cessation of treatrilent and re-contaminate the non-,
liquid material.
A secondary function
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of the carrier stream is to enhlnce the desorption
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of the target
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contaminants. Similar to reducing the pressure within the treatment chamber, evacuated
air cascading through the non-liquid material tends to reduce the boiling points of
contaminants with which the air stream contacts on a localized level; an effect referred
to as air stripping. The net result is further reduction in the energy requirements of the
L TTDS, resulting in shorter treatment times and lower energy costs.
A third function of the carrier stream is to enhance the transport of the infrared energy
through the non-liquid material. As noted in Section ( 4.1.2) of this document, the
downward flow of air helps to convey the thermal energy from the top several inches of
material to the underlying layers. Since this convective heat transfer will adhere to
classical laws, the parameters regulating the rate of this transfer to the underlying layers
is the temperature differential between the mediums and the velocity of the carrier gas.
System Components
35
The major components of the L TTDS necessary to effect the desorption and collection of contaminants
from non-liquid material are: a treatment chamber, an infrared source, a vacuum pump, a condenser, a
polishing carbon system and connecting piping and associated appurtenances. The following information
includes detailed descriptions of each of these major components, including drawings, manufacturer's
names and operating ranges.
Treatment Chamber
The treatment chamber is a rectangular bed measuring approximately sixteen feet long by
eight feet wide by two feet deep and is constructed of carbon steel. The chamber is
hinged along one of the long sides. In addition, the chamber is equipped with four (4)
2" diameter air screens that are located along the bottom, longitudal axis of the chamber
and measure approximately fifteen feet in length. Each screen is constructed of stainless
steel and has a series of slots measuring 0.01 inches each. The four (4) well screens are
connected at one end to a solid, header pipe that subsequently connects to the vacuum
pump. The treatment chamber is engineered and mahufactured by Beckley Steel
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Corporation located in Beckley, West Virginia.
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The LITDS has a total operating capacity of approximat~ly five (5) cubic yards. The
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contaminated material is loaded into two (2) square bins measuring approximately eight
feet by eight feet by eighteen inches in depth with an operiting capacity of approximately '
2.5 cubic yards per bin. The bin is constructed of carbon steel sidewalls and has a
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stainless steel, perforated base with 0.01 diameter holes to allow for the downward flow
of air through the soil and into the underlying screens. Inf order to support the weight of
the material within the perforated base, each bin is equipp.id within an underlying support
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system to provide maximum stability with minimum restriction to air flow.
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In order to accommodate the bins within the treatment' chamber, there is an internal
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support system situated ~bove the screens and around the perimeter of the treatment
I chamber. This support system is constructed of carbm1 steel and is equipped with a
temperature and pressure resistant gasket to limit the vo!u/ne of air short circuiting around
the bins rather than passing through the non-liquid mate~ial. . I
Each bin is loaded outside of the chamber with a buck,~t machine and placed into the
chamber using a wheel loader equipped with a set of m~terial handling forks. The bin
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is placed on top of the chamber's internal support system. Each charged bin has a total
I operating weight of approximately 8,500 pounds. I
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Finally, the hinged side panel separates at the middle an'd each eight foot section swings
away from the treatment chamber during loading operati~ns. The panel is equipped with
a temperature and chemical resistant gasket to allow for1an air tight seal when then panel !
is closed against the flanged side of the treatment chamber. Each panel is secured in
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place during the treatment cycle with a mechanical turf) buckle.
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Infrared Source
The infrared energy for the L ITDS is generated from 6ight (8) individual infrared units
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arranged in parallel rows. Each unit operates on supplied propane gas and generates
approximately 175,000 Btu/Hr of infrared energy for a total system output (infrared
energy) of approximately I .4 million Btu/Hr. Each unit consists of a control box, an
electronic ignition system (silicon carbide) and an infrared source. This infrared source
consists of a 16 gauge, 4" diameter aluminized steel tube that is approximately sixteen
feet in length. During operation, outside air and propane gas are fed into the tube and
combusted to reach an internal temperature of approximately 1100 degrees Fahrenheit.
At this temperature, the aluminized steel tube emits energy in the infrared spectrum at the
rate of approximately 175,000 Btu/Hr. All generated fumes and waste heat are exhausted
through the open end of the tube.
The infrared units are manufactured by Gas-Fired Products, Inc. Each unit is arranged
on a central panel into a parallel array. The control box and ignition system for each
infrared source are situated on top of the central panel; while, the steel tube penetrates the
surface of the central panel and is affixed to the underside of this panel. A reflector is
positioned between the infrared tubes and the underside of the central panel in order to
direct all generated infrared energy in a downward direction toward the bins containing
the contaminated material. The reflector has a rated reflectivity of approximately 95%.
Since combustion occurs within the aluminized steel tubes, the placement of these infrared
sources within the treatment chamber's oxygen deficient environment will not adversely
affect the operation of the infrared sources.
The central panel with the affixed infrared units is attached to the treatment chamber by
mounting the panel on a perimeter support flange located on top of the treatment chamber.
The flange is equipped with a heat and pressure resistance gasket. The panel is
mechanically secured in place with nuts and bolts.
Vacuum Pump and Condenser
Vacuum conditions of approximately 28 column inches (Hg) are created within the
treatment chamber using a liquid seal, conical vacuum pump. For this operation, the
liquid medium is water. The pump is manufactured by Nash Corporation, Model No.
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SC-4 and is powered by a twenty five (25) Hp motor thaqruns on 230 volt, three phase
electricity. At a vacuum pressure of 28 column inches (Hg), the stated pump is capable
of transferring approximately 300 cfm of air. I
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In order to maintain vacuum pressure within the treatment; chamber at approximately 28
column inches (Hg) as well as provide a continual soured of carrier gas, ambient air is
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allowed to enter the treatment chamber through vents situaied on top of the central panel.
These vents consist of 2 inch diameter carbon steel tubes e~uipped with ball valves. The
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ball valves are used to regulate the flow of outside air to maintain the desired vacuum ! .
pressure. There are two (2) ports in total.
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A shell and tube condenser is installed in-line between the treatment chamber and the
vacuum pump to remove and capture the majority of the d~sorbed contaminants from the
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carrier stream. The basis for positioning the condenser before the vacuum pump is to
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minimize the concentration of contaminants contacting !the seal water and becoming
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absorbed into this medium. The condenser is designed to accept an air stream with a
maximum temperature of approximately 350 degrees Flhrenheit and produce an exit
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temperature of approximately 50 degrees Fahrenheit. The low exit temperature is required
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because the entire condenser, inlet and exit, are under vacuum. In order to achieve these
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operating parameters, the condenser's process water is conditioned with a chiller. Please
note, this process water is non-contact relative to the c1arrier gas passing through the
i condenser and has no potential for contamination. I
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With respect to mass flow, the condenser is designed to receive a total mass (carrier gas)
of approximately 350 cfm; of which, up to 20% or 70 cfnl of this mass will be comprised
of water vapor and desorbed contaminants. Based bn the boiling point of most . I contaminants under vacuum and the operating temperatures of the condenser, only a
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minimal concentration of contaminants will pass through the condenser and be received
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by the vacuum pump. Although minimal contaminationl of the seal water is anticipated
due to the placement of the condenser as well as the lowlsolubility limit of contaminants
in water, the seal water will be tested for the presencl of target contaminants and if
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required, treated with carbon following completion of a 1treatment project.
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Finally, the condensable products are transferred, by gravity, from the condenser to a
5,000 gallon collection tank. The tank is equipped with a liquid level sensor capable of
interrupting the condenser's vacuum in order to prevent an influx of atmospheric air into
the system. Depending on the collected volume, these condensables are either transported
off-site for treatment and/or disposal or the desorbed contaminants are concentrated on-site
using something such as a reverse osmosis system to remove water from the collected
condensables. In turn, the concentrated contaminants are transported off-site for eventual
treatment and/or disposal.
Polishing Carbon System
The carrier gas will exit the vacuum pump from the discharge port of the pump on the
compression cycle, returning the air stream to atmospheric pressure conditions. At this
point, all contaminants should be removed from the carrier stream due to the in-line
condenser and the seal waier contained within the vacuum pump. However,the carrier gas
will be passed through a vapor phase carbon adsorption system prior to discharge of the
carrier gas to the atmosphere. The system is charged with approximately 600 pounds of
activated carbon and is able to receive a mass flow of up to 1,000 cfm. Based on a mass
flow rate of approximately 300 cfm, the carbon system has a safety factor relative to
retention time of approximately 60%.
In addition, a final condensate trap or "knock-out pot" may be installed in-line between
the exhaust port of the vacuum pump and the carbon polishing system when performing
a full scale remedial operation. The basis for installing a knock-out pot will be dependant
on the concentration levels of the contaminants in the non-liquid material and the initial
moisture content. The higher the concentration of contamination and entrained moisture,
the increased likelihood that a knock-out pot will be installed. Essentially, the return of
the carrier stream to atmospheric conditions will elevate the boiling points of the
contaminants as well as any entrained water significantly above the exhaust temperature
of the carrier gas, forcing any residual contaminants and/or water to condense. Any
collected condensate from a knock-out pot would be transferred to the main collection
tank associated with the primary condenser.
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Piping and Associated Appurtenances
Piping
The L TIDS is connected to the condenser, the vacuum phmp and the polishing carbon
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system with 4 inch stainless steel (201) piping. Since the ,influent and effluent plenums
on the condenser are both 8 inch in diameter, the condeJser is equipped with 4" x 8" '
couplings. The stainless steel piping itself is inter-connected using flanged ends,
I temperature resistant gaskets and bolts.
The condensate collected from the condenser and I knock-out pot (if applicable) is
transferred to various collection vessels using synthetic vacuum hose constructed primarily I .
of n-butyl rubber. The diameter of this hose is depend~nt on the flow rates and the
sections of hose are inter:connected using aluminum, cam~ lock type fittings.
Thermocouples
There are seven (7) thermocouples located I through-out; the L TIDS to monitor the
desorption process and insure that treatment conditions conform to design parameters
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necessary to effect the proper desorption and collection of the target contaminants.
(a) Treatment Chamber There are four (4) thermocouples located within the treatment
chamber. Two (2) units are located at the midpoint of eac~ material bin along the sixteen :
foot axis approximately four inches below the top surface of the installed non-liquid
material. Each unit is installed after the contaminated mat~rial is inserted into the bin and
the bin has been inserted into the treatment chamber. Each thermocouple is inserted into
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the contaminated material by means of a threaded conduit to a depth of approximately
twelve (12) inches. The threaded conduit serves to secure the thermocouple to the
I exterior shell of the treatment chamber as well as shield the thermocouple from fugitive
infrared radiation, avoiding erroneous readings. The registered temperature from each
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thermocouple is recorded on an indicator located on the outside of the treatment chamber.
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(b) Condenser There are two (2) thermocouples used in conjunction with the condenser
in which one unit is located on the influent side· and the second unit is located on the
effluent side. The thermocouples are installed into the 4 inch stainless steel conduit in
accordance with manufacturer's specifications to insure proper function. It is necessary
to measure the influent temperature of the carrier gas entering the condenser because this
temperature is directly proportional to the average temperature of the material inside the
treatment chamber. In addition, it is important to measure the influent temperature of the
carrier gas to assure this stream conforms to the influent operating parameters for the
condenser. Similarly, it is necessary to measure the temperature of the effluent carrier
stream in order to gauge the effectiveness of the condenser relative to the design
parameters and the target compounds.
(c) Carbon Polishing Svstem A final thermocouple is placed between the exhaust port of
the vacuum pump and the influent side of the carbon polishing system. The thermocouple
is installed into the 4 inch stainless steel conduit in accordance with manufacturer's
specifications to insure proper function. The primary reason for recording the temperature
of the carrier gas at this point is to insure that the temperature of the influent stream
conforms with the operating parameters for the carbon polishing system relative to the
target contaminants.
Vacuum Gauge
There is one (I) vacuum gauge for the L TTDS that is installed between the effluent
plenum on the treatment chamber and influent side of the condenser. The gauge is
installed within the 4 inch stainless steel conduit in accordance with manufacturer's
specifications to insure proper function. The purpose of this gauge is to measure the
strength of the vacuum between the treatment chamber and the vacuum pump. Since the
separation between the treatment chamber, condenser and vacuum pump is short and this
section of the system is a closed loop, a vacuum measurement at this point will reflect the
strength of the vacuum inside the treatment chamber as well as within this entire section
of the system.
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Flow Meter
There are two (2) flow meters installed for the LTIDS. The first unit is installed between
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the effluent side of the treatment chamber and the condenser while the second unit is
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installed between the discharge side of the vacuum pump and the influent side of the
' vapor phase carbon system. The meters are installed within the 4 inch stainless steel
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conduit in accordance with manufacturer's specifications (o insure proper function. It is
I important to monitor the flow rate of carrier gas exiting t,he treatment chamber because
I this rate is directly proportional to the efficient removal of target contaminants from the
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treatment chamber. Secondly, it is also important to monitor the flow rate of carrier gas
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entering both the condenser and the vapor phase carbon system to insure that the flow rate
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conforms to the design operating parameters from thest! systems relative to the target
contaminants.
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