NCD980602163_20010919_Warren County PCB Landfill_SERB C_Comments - Phase III Final Design, 1999 - 2001-OCR

Patricia M. Backus, PE
Division of Waste Management
401 Oberlin Road, Suite 150
Raleigh, NC 27605
Phone: [phone] ext. 308
Fax: [phone]
Fax
To:
Fax:
Phone:
Kathleen McNelis
Earth Tech
864-234-3069
NCDENR
From: Pat Backus
Pages: 3
Date: September 19, 2001
Re: Comments from Jim Bowyer CC:
□ Urgent 0 For Review □ Please Comment □ Please Reply □ Please Recycle
• Comments:
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Toxics Protection Branch
December 2, 1999
MEMORANDUM
To: Pat Backus
Division of Solid Waste
Through: Lori Cherry, Supervisor
Toxics Protection Branch, Division of Air Quality
From: Jim Bowyer, Ph.D. 'fl 'I-715 -7'1~'-/
Toxics Protection Branch, Division of Air Quality
Subject: General Comments on the Proposed Air Monitoring Plan for
the Warren County PCB Landfill Detoxification Project
The following are general comments on the proposed air monitoring plan for the
Warren County PCB landfill detoxification project. Pat Backus, Division of Solid
Waste requested this review through Booker Pullen, Division of Air Quality
(DAQ), Pe1mits Section to Jim Bowyer DAQ, Toxics Protection Branch (TPB).
There are several sections to this plan, which encompass three main areas of
monitoring. Those are ambient air sampling, stack sampling, and personal air
sampling. Jim Bowyer reviewed and commented only on the ambient air
sampling section of this plan. It is his recommendation that the appropriate
divisions or branches within the State of North Carolina review the other sections
of the plan dealing with the stack sampling and personal air sampling such as
DA Q's Stationary Sources (stack) and Department of Health and Human Services,
Division of Epidemiology (personal).
Comments are intended to give direction to subsequent revisions to the plan but
should not be construed as acceptance of the plan as written. That is, it was
understood by Dr. Bowyer from Ms. Backus that this was to be a cursory review
to determine if there were any glaring omissions and/or questionable methods
being proposed. Specific comments are listed by section number and page within
the Air Monitoring Plan.
1. In attempting to meet the first two stated objectives of the air monitming,
namely;
"1) Demonstrate protection of human health ( on-site and off-
site) and the surrounding environment and 2) Demonstrate
compliance with the emission limits established for the project
and the requirements contained in the State of North Carolina
Administrative Code"
the monitoring plan seems to address the exposure of the on-site personnel to the
compounds of concern (Appendix 3) by way of the Action Levels and the
monitoring devices (flame ionization detector, photoionization detector, and the
particulate monitor) listed in sections 2 and 3 fairly well. However, it does not
address the levels that may be experienced off-site and are regulated by the North
Carolina Administrative code (included in the plan). The monitoring devices
proposed may not give adequate results to satisfy the Administrative code
concentration requirements for the compounds of interest. The only indication of
any boundary air sampling is in Section 3.1.3 Baseline Monitoring and this
sampling does have some questions associated with it as well (see below).
It is therefore recommended that the plan include some means of monitoring the
air at the boundaries of the landfill not only before the detoxification begins but
also during the process, if stack sampling and/or modeling results indicate that
there may be a problem at the boundaries. If this air monitrning is deemed
necessary then the means of doing this sampling during the detoxification is
consistent with those described in Section 3.1.3 Baseline Monitoring. That is , air
monitoring of VOCs via SUMMA canisters, PCB/Dioxin/Furan via PUF sampler,
and dust via TSP samplers does seem adequate for the task. More detailed
information of how each of these would be carried out should be included in the
Air Monitoring Plan. Section 2 will need extensive additions to list all of the
pertinent equipment and to specify a monitoring protocol in order to conduct such
a monitoring effort.
2. Section 3.1.2 Meteorological Station, page 4
The plan indicates that there will be only one meteorological station at the site. It
is suggested that if there is more than one pe1manent site for ambient air
monitoring, that each site be set up with individual meteorological stations and
that the stations be equipped with data loggers for continuous data collection.
This will allow the micrometeorological conditions to be monitored continuously
and allow data to be downloaded for archiving and correlation to sample
collection.
3. Section 3.1.3 Baseline Monitoring, page 4
The statement "This information will form the background data against which
operational air monitoring results will be compared" assumes that the levels at the
site are not already above regulated or ambient levels. Therefore the data should
be compared to ambient levels and/or regulatory levels to determine whether this
data will in fact represent "background" levels. The data may more correctly refer
to "baseline" levels rather than "background" levels; these distinctions should not
necessarily be used interchangeably but should be better defined as to their
definition and use within the plan.
It is noted in this section that sampling will occur for VOC, PBC, Dioxin/Furans,
and TSP over an "extended period". This may be an argument for having
meteorological stations at each sampling location in order to correlate the specific
weather conditions at the sampling site with a specific sample during a specific
sampling period.
cc: Booker Pullen
JAMES B. HUNT JR.
GOVERNOR
BILL HOLMAN
SECRETARY
ALAN W. KLIMEK, P.E.
DIRECTOR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF AIR QUALITY
November 23, 1999
Ms. Patricia M. Backus, PE
North Carolina Department of Environment and Natural Resources
Division of Waste Management
401 Oberlin Road, Suite 150
Raleigh, North Carolina 27605-1350
Dear Ms. Backus:
Subject: Warren County PCB Landfill Detoxification Project
Warren County
Raleigh Regional Office
This letter is in response to your memo to me, received by this Division on October
29, 1999 in which you requested that I review a copy of the draft monitoring plan for the
Warren County Landfill Detoxification project. I sent the monitoring plan, along with a
memo, to the Division of Air Quality's Toxics Section and Stationary Sources Section on
November 5, 1999. I have not received a written response from the Toxics Section to date,
but did receive comments from the Stationary Sources Section. I have asked Mr. Jim Bowyer
of the Toxics Section to contact you directly. According to Ms. Jessica Bellas of the
Stationary Source Section, the test methods and procedures in the monitoring plan need to be
more specific to offer a proper assessment of the project. The enclosed Source Test
Notification Form should be properly filled out, and submitted along with the application for
this project to the Division of Air Quality.
If have any additional questions, please contact me at 9119-715-6248 or e-mail:
booker _pul [e-mail].
c: Raleigh, Regional Office
Sincerely,
~clb~? /4~
Booker T. Pullen, EIT
Environmental Engineer
Donald van der Vaart, PSD/Special Permits Branch
Central Files
Ulla MM•MM•M
PERMITS SECTION
1641 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLI NA 27699-1641
2728 CAPITAL BLVD., RALEIGH, NC 27604
PHONE [phone] FAX [phone] WWW.ENR.STATE.NC.US/ENR/
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/I 0% POST-CONSUMER PAPER
.., Source Test Notification Form
NC DENR -Division of Air Quality Page 1 of 2
Purpose: When.filled out completely and accurately, the Source Test Notification Form can provide the Division of Air Quality (DAQ) with
the necessary information to determine potential problem areas related to a proposed source testing project prior to the actual
test date. The primary goals of the Source Test Notification Form are to initiate communication between representatives of the
permitted facility, the testing consultants, and the DAQ and to identify and resolve any specific testing concerns prior to testing.
Initially, this form will be distributed on a trial basis and may not satisfy specific test protocol requirements in an air permit.
Instructions: All forms and additional information should be submitted to the DAO Regional Supervisor at least 45 days prior to testing.
Please type or print clearly. Complete one form for each sampling location. If this form does not supply sufficient space to
completely answer all questions or if additional relevant information is available, please attach additional documentation and/or
information to the original form. Questions and/or comments should be directed to Shannon Vogel of the Stationary Source
Compliance Branch by phone at (9/9)733-1472 or by e-mail at [e-mail]
This form is available from the DAQ website (http://daq.state.nc.us/OfficesffechnicaVStationary/Compliance/)
Facility Name: Testing Company:
Facility Address: Testing Company's Address:
Contact Person: Contact Person:
Phone: Fax: Phone: Fax:
Air Permit Number: Permitted Source Name and ID#:
Permitted Maximum Production Rate: Target Production Rate for Testing:
How will production data be documented during testing?
Please provide a brief description of the source (including control equipment) and attach source or process flow diagram:
Please provide a brief description of the sampling location, attach schematic of sampling location, and indicate whether concurrent testing
will be conducted at other sampling locations:
What is the specific purpose for the proposed testing ?
Will the test results be used for other regulatory purposes, e.g. emissions inventories, permit application, etc., beyond that stated above?
if so, explain.
Please list all state and federal regulations that apply to the proposed testing.
Source Test Notification Form
-IVISIOD 0 Ir ua 1ty a2e 0
.'7/IL 11 k' fi T Please provide the following information for each test parameter. fa
NCDENR ff .. fA" Q r p 2 f2
Target Proposed Number of Test Run # of Sampling Comments Pollutant Test Method Test Runs Duration Points
Is all testing to be conducted in strict accordance with the applicable test methods? If answer is no, please attach YES I NO
complete documentation of all modifications and/or deviations to the applicable test methods.
Does the proposed sampling location meet the minimum EPA Method I criteria for acceptable measurement sites? YES I NO
Please attach supporting documentation.
Has absence of cyclonic flow been verified as per EPA Method I (Section 2.4)? If answer is no, absence of cyclonic flow YES I NO
must be verified prior to testing. If answer is yes, please attach supporting documentation.
Do any of the proposed test methods require analysis of EPA audit samples? If answer is yes, please notify the regional YES I NO
office at least 45 days prior to testing to allow for audit sample preparation and shipment.
Has all testing equipment been calibrated within the past year? If answer is no, please explain. YES I NO
Have all calibration gases been certified by EPA Protocol I procedures? Please attach a summary of expected calibration YES I NO
gas concentrations for all proposed instrumental test methods. (Answer only as applicable)
What are the proposed test dates? If testing is anticipated to last more than one day or if all test methods will not be conducted
simultaneously, please attach detailed test schedule.
Additional Comments:
Signatures: Representatives from the permitted facility and the contracted testing company must provide signatures below certifying that
the information provided on this form and any attached information is accurate and complete.
I I Permitted Facility Representative Date Testing Company Representative Date
Name: Name:
Title: Title:
Company: Company:
L<.uesi nev1swn: June L:>, 1 :/::IY
Pat's Onnments
1. Add CLP -Contract Laboratory Program under the List of Acronyms.
2. Section 1.0, page l. There are three paragraphs in which you list items and in each case use a
different type of bullet. I would one type.
3. Section 1.0, page l. In the fourth paragraph, you use "decon" in first sentence and then use
"decontamination" in the last sentence. Use one or the other in both cases.
4. Section 1.0, page 1. In the fifth paragraph, I think it should be "Section 4 describes" instead of
"Section 4 described".
5. Section 3.1.3, page 4. In the second paragraph under this section, first sentence "S" in "Samples"
should be lower case.
6. Section 4.0. Questions. How do you monitor personnel for PCBs (oh yeah, "PCB's" in the
second paragraph should be "PCBs"), dioxins/furans, toxic organic compounds, and
particulate/dust? Also again, what specifically are ''toxic organic compounds"? (For example, in
a NPDES permit when you monitor for Total Toxic Organics, you sum the concentration of the
specific organics from the toxic pollutants list in 40 CFR 401 that are specifically listed in your
permit)
7. Appendix III. I would eliminate the references to the HASP shown on the page with the table of
contaminants of concern. For my own benefit (Dave said it looked fine), do you have a reference
for the dust exposure calculation and what the safety factor means?
~VA
NCDEMR
JAMES B. HUNT JR.
GoVERNOR ,b
WAYNE MCDEVITT
TO: Pat Backus
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
November 1, 1999
FROM: David Lilley DJ; L
RE: Comments prepared on the Draft Air Monitoring Plan for the
Warren County PCB Landfill
October, 1999
After reviewing the above mentioned document, I offer the following
comments:
1. Page 2, Section 2.3: Will the CGI/O2 meter be used ONLY when hot
work or confined space work is performed?
2. Page 4, Section 3.0, second paragraph: It is recommended the term
"personnel exposure limit" (PEL) be changed to avoid confusion with the
OSHA "Permissible Exposure Limit" (PEL). One suggestion would be the
generic term "exposure limit" (EL).
3. Page 4, Section 3 .1.3: Please refer the reader to Table 3-2 for a listing of
the analytical methods to be used to analyze the base line samples.
Note to Pat Bacus:
I recommend having someone familiar with stack sampling and the
associated analytical methodologies review Sections 3.5.1 to 3.5.3, and Table
3-2 of this report. Although this is not reall y my area, a red flag goes up when
they are talking about doing non-isokinetic and isokinetic sampling for
hydrogen chloride (I believe this is only done for particulate sampling).
DL/ dl/word/shsp/13
401 OBERLIN ROAD, SUITE I 50, RALEIGH, NC 27605
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/I 0% POST-CONSUMER PAPER
JAMES B. HUNT JR.
,• GoVERN0R
WAYNE MCDEVITT
SEc;:RETARY
Wll,.LIAM L. MEYER
DIRECTOR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
September 24, 1999
TO:
FROM:
Pat Backus
David Lilley
RE: Comments prepared on the Draft Health and Safety Plan for the
Warren County PCB Landfill
September, 1999
After reviewing the above mentioned document, I offer the following
comments:
1. Page 17, section 3.5.4, first paragraph, third line: Typo-change "price" to
"piece".
2. Page 19, section 3.5.6, first paragraph, next to last line: Typo-change
"dailies" to "daily".
3. Page 29, section 3.6: The reader disagrees with the assessment that the
nature and location of the operations are inside. If this statement is to
remain, please provide documentation to show the indoor nature of these
operations.
4. Table 6-2, Organic Vapors, Action Level Column: The entries that are
related to the PID should be in terms of "units", and the entries related to
Dreager Tubes should be in "ppm".
5. Table 6-3 , Preparation/Analytical Methods for Toxic Organic Compounds:
It is recommended that the analytical chemist conducting the analysis be
contacted prior to sample collection. The only chemicals listed on Table
3-3-1 that NIOSH 1500 and 1501 are used for (according to the analytical
methods) is benzene.
6. Table 9.1: The Poison Control Center is listed twice.
7. Table 9.1: It is recommended a map with the route to the hospital
highlighted be included in this document.
D L/ di/word/ shsp/ 12
v
✓
401 OBERLIN ROAD, SUITE I 50, RALEIGH, NC 27605
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/I 0% POST-CONSUMER PAPER
1. Who typically approves an Emergency Response Plan? Should the titles of people we would expect to approve
the Emergency Response Plan be listed under the signature lines?
2. Please include a table of abbreviations at the beginning of the document. Maybe some definitions if it is not
obvious. You have more experience than I do in these things, but my guess is that this may be a document that
more of the community will be browsing and maybe actually reading .. .it's shorter than any of the other
documents and an emergency response could potentially effect them. It needs to be clear and understandable.
3. When my reports, etc. have been edited in the past, I was told to indicate the abbreviation or acronym when first
referenced in the document and then to use the abbreviation or acronym thereafter. I don't know what you or
ETG usually does. I would just like to establish the rules for this and to be consistent throughout this an all
other documents. Let me know what the rule will be.
4. All the titles are confusing to me. Seems like everyone on site will be a coordinator, officer, or something.
Could you provide a chart or schematic that shows these different folks and their interactions?
5. "Periodically", "regular basis", "sufficient", etc. are ambiguous terms. Based on the project design that ETG is
developing, what would these be? If these have to be changed later, that's ok.
6. Some of these titles, such as Local Emergency Management Agency (EMA) seem generic. For example, would
this be Warren County EMA or Warrenton EMA? I don't see any "EMA"s on Table 3.1.
7. In 3.0, who are "adjacent personnel with the building"? This seems like a statement from a generic plan that
needs to me modified to the PCB landfill. Would nearby residents be evacuated?
8. Where did you get the directions to the hospital? They are different than the ones from the site investigation in
1997 (attached) and they don't match the maps we have (which could be outdated). I plan to drive the route
next time I go to the landfill.
9. Should EPA/TSCA be included on the emergency telephone list?
10. Do you have a local person that helped supply information that I could ask to review the final ERP?
11. Emergency response equipment? I wouldn't expect hydrogen cyanide or hydrogen sulfide for this project.
Why are these included? What would be the source of these emissions?
12. See attached pages from OSHA. I didn't see all the elements that they indicated that should be in the ERP.
£mergency Response Plan
1 of2
Subject: Emergency Response Plan
Date: Mon, 20 Sep 1999 14:54:00 -0400
From: Rick Shoyer <[e-mail]>
To: [e-mail]
Received your comments to the Emergency Response Plan. The following is a
qui ck response to your items:
1 . The Contractor-Any combination of the following : PD , PM, SM, SHSO , HSO .
The "client"-any combinati on of the following: PM, SM, HSO. Be more than
willing to put names and/or titles which ever you think works best.
2 . There was an acronym table that was accidentall y ommi tted. A Plan
specific acronym list will be provided with each Plan .
3 . Yes, will try to do better on other plans .
4 . Yes , though everyones' plan will be diffe rent. Also, on a 24 -hour
operation 7 days per week, there needs to be a lot of cross over to insure
proper coverage and implementation.
5 . Yes , we will make a recommendation. A side note; the document you faxed
used the same words in their "periodicall y ". Generally, these types of
plans are reviewed regularly in the beginning of the project as "actual "
work charts a nd procedures are finalized.
6 . North Carolina Divi s ion Of Emergency Management
7 . The adjacent personnel referred to the site structures (building-water
treatment) or trailers-office, decon, support , H&S, etc . Yes near by
--residences could be evacuated but it would not be by us, but by the County
hazmat response or a public department authorized to do so . We could make
a recommendation to an authority to do so.
8 . I believe I discussed the directions with Gary Robenolt-County hazmat
response, the hospital and local EMS, but they do need to be checked. I
haven 't made it back up there where i could do it. If you could that would
be great .
9. We can if you like. Too many names can be more confusing than a laundry
list. Certainly i f TSCA or EPA has involvement and especially, if they
have assigned a person the case then I would add them. This really come s
down to the organizational chart with the State .
10. Gary Robenolt County hazmat response I spoke to several times (phone
number 252-257-2666. He also forwarded to me the Emergency Operations
Plan For Multi-Hazards for Warren County North Carolina. You could try
him possible .
11. I do not expect them either, but they are generally standard emergency
response equipment to carry.
12. I believe we mentioned a security guard at the gate. The actual
decontamination specifics were not covered, other than the zones (
exclusion, contaminate reduction zone, and support zones). The mention
that decontamination procedures had to occur if removing someone from the
exclusion zone was mentioned. The anticipated highest level of protection
except for confined space entries and the like, will hopefully, be modified
level D, so decontamination will be minimal. Critic and followup was
mentioned as written reports to NCDENR. We could discuss processes like
"Y" tree investigations, lessoned learned. All accidents, near misses are
covered in the H&S report and SM/PM 's reports.
Maybe next week we can spend a few minutes and insert some of theses
9/20/99 3:31 PM
:Emergency Response Plan
comments or share ideas. Thanks Rick
2 of2 9/20/99 3:31 PM
... . t
Patricia M. Backus, P.E.
Division of Waste Management
401 Oberlin Road, Suite 150
Raleigh, NC 27605
Phone: [phone] ext 308
Fax: [phone]
Fax
To: Rick Shoyer
Fax: [phone]
Phone: [phone]
Re: Emergency Response Plan
NCDENR
From: Pat Backus
Pages: Js
Date: 09/20/99
CC:
□ Urgent ~rReview □ Please Comment □ Please Reply □ Please Recycle
• Comments:
Comments from Wendy Shepard and me. Thanks.
...
V I. Who typically approves an Emergency Response Plan? Should the titles of people we would expect to approve
the Emergency Response Plan be listed under the signature lines?
Please include a table of abbreviations at the beginning of the document. Maybe some definitions if it is not
obvious. You have more experience than I do in these things, but my guess is that this may be a document that
more of the community will be browsing and maybe actually reading .. .it's shorter than any of the other
documents and an emergency response could potentially effect them. It needs to be clear and understandable.
When my reports, etc. have been edited in the past, I was told to indicate the abbreviation or acronym when frrst
referenced in the document and then to use the abbreviation or acronym thereafter. I don't know what you or
ETG usually does. I would just like to establish the rules for this and to be consistent throughout this an all
other documents. Let me know what the rule will be.
4. All the titles are confusing to me. Seems like everyone on site will be a coordinator, officer, or something.
v ,8.
9.
Could you provide a chart or schematic that shows these different folks and their interactions?
"Periodically", "regular basis", "sufficient", etc. are ambiguous terms. Based on the project design that ETG is
developing, what would these be? If these have to be changed later, that's ok.
Some of these titles, such as Local Emergency Management Agency (EMA) seem generic. For example, would
this be Warren County EMA or Warrenton EMA? I don't see any "EMA"s on Table 3.1.
In 3.0, who are "adjacent personnel with the building"? This seems like a statement from a generic plan that
needs to me modified to the PCB landfill. Would nearby residents be evacuated?
Where did you get the directions to the hospital? They are different than the ones from the site investigation in
1997 (attached) and they don't match the maps we have (which could be outdated). I plan to drive the route
next time I go to the landfill.
Should EP NTSCA be included on the emergency telephone list?
I 0. Do you have a local person that helped supply information that I could ask to review the final ERP?
11. Emergency response equipment? I wouldn't expect hydrogen cyanide or hydrogen sulfide for this project.
Why are these included? What would be the source of these emissions?
12. See attached pages from OSHA. I didn't see all the elements that they indicated that should be in the ERP .
•
OSHA 3114 -Hazardous Waste Operations and Emergency Response http://www.osha-slc.gov/Publications/0SHA3114/osha3114.htm1 . . .
8 of22
symptoms, or illness that may have resulted from exposure to hazardous substances; and
• Members of hazardous materials (HAZMAT) teams.
All examinations must be performed under the supervision of a licensed physician, without cost to the
employee, without loss of pay and at a reasonable time and place. Examinations must include a
medical and work history with special emphasis on symptoms related to the handling of hazardous
substances and health hazards and to fitness for duty including the ability to wear any required
personal protective equipment under conditions that may be expected at the work site. These
examinations must be given as follows:
• Prior to job assignment and annually thereafter (or every 2 years if a physician determines that
is sufficient),
• At the termination of employment.ill
• Before reassignment to an area where medical examinations are not required, ill
• If the examining physician believes that a periodic followup is medically necessary, and
• As soon as possible for employees injured or becoming ill from exposure to hazardous
substances during an emergency, or who develop signs or symptoms of overexposure from
hazardous substances.
The employer must give the examining physician a copy of the standard and its appendices, a
description of the employee's duties relating to his or her exposure, the exposure level or anticipated
exposure level, a description of any personal protective and respiratory equipment used or to be used,
and any information from previous medical examinations. The employer must obtain a written opinion
from the physician that contains the results of the medical examination and any detected medical
conditions that would place the employee at an increased risk from exposure, any recommended
limitations on the employee or upon the use of personal protective equipment, and a statement that
the employee has been informed by the physician of the medical examination. The physician is not to
reveal, in the written opinion given to the employer, specific findings or diagnoses unrelated to
employment.
Decontamination Procedures
Decontamination procedures are a component of the site-specific safety and health plan and,
consequently, must be developed, communicated to employees, and implemented before workers
enter a hazardous waste site. As necessary, the site safety and health officer must require and
monitor decontamination of the employee or decontamination and disposal of the employee's clothing
and equipment, as well as the solvents used for decontamination, before the employee leaves the
work area. If an employee's non-impermeable clothing becomes grossly contaminated with hazardous
substances, the employee must immediately remove that clothing and take a shower. Impermeable
protective clothing must be decontaminated before being removed by the employee.
Protective clothing and equipment must be decontaminated, cleaned, laundered, maintained, or
replaced to retain effectiveness. The employer must inform any person who launders or cleans such
clothing or equipment of the potentially harmful effects of exposure to hazardous substances.
Employees who are required to shower must be provjded showers and change rooms that meet the
requirements of 29 CFR 1910.1 41, Subpart J --General Environmental Controls. In addition,
unauthorized employees must not remove their protective clothing or equipment from change rooms
unless authorized to do so.
Emergency Response
Proper emergency planning and response are important elements of the safety and health program
that help minimize employee exposure and injury. The standard requires that the employer develop
and implement a written emergency response plan to handle possible emergencies before performing
hazardous waste operations. The plan must include, at uncontrolled hazardous waste sites and at
treatment, storage, and disposal facilities, the following elements:@
9/20/99 9:22 AM
?SHA 3 ~ 14 -Hazardous Wa~te Operations and Emergency Response http://www.osha-slc.gov/Publications/OSHA3114/osha3114.html
9 of22
• Personnel roles, lines of authority, and communication procedures, v
• Pre-emergency planning, v @
• Emergency recognition and prevention, v (ij)
• Emergency medical and first-aid treatment,~
• Methods or procedures for alerting onsite employees,@ V
• Safe distances and places of refuge, (j)
7 • Site security and control,
7 • Decontamination procedures, ·
• Critique of response and followup,7
• Personal protective and emergency equipment, and 0
• Evacuation routes and procedures. ~
In addition to the above requirements, the plan must include site topography, layout, and prevailing
weather conditions; and procedures for reporting incidents to local, state, and federal government
agencies. --
The procedures must be compatible with and integrated into the disaster, fire and/or emergency
response plans of the site's nearest local, state, and federal agencies. Emergency response
organizations may use the local or state emergency response plans, or both, as part of their
emergency response plan to avoid duplication of federal regulations.
The plan requirements also must be rehearsed regularly, reviewed periodically, and amended, as
necessary, to keep them current with new or changing site conditions or information. A distinguishable
and distinct alarm system must be in operation to notify employees of emergencies. The emergency
plan also must be made available for inspection and copying by employees, their representatives,
OSHA personnel, and other governmental agencies with relevant responsibilities.
When deemed necessary, employees must wear positive-pressure self-contained breathing apparatus
and approved self-contained compressed-air breathing apparatus with approved cylinders. In addition,
back-up and first-aid support personnel must be available for assistance or rescue.
Other Provisions
As already indicated, as part of an effective safety and health program, the employer must institute
control methods and work practices that are appropriate to the specific characteristics of the site.
Such controls are essential to successful worker protection. Some control methods are described in
the following paragraphs.
Engineering Controls and Work Practices
To the extent feasible, the employer must institute engineering controls and work practices to help
reduce and maintain employee exposure at or below permissible exposure limits. To the extent not
feasible, engineering and work practice controls may be supplemented with personal protective
equipment. Examples of suitable and feasible engineering controls include the use or pressurized
cabs or control booths on equipment, and/or remotely operated materials handling equipment.
Examples of safe work practices include removing all non-essential employees from potential
exposure while opening drums, wetting down dusty operations, and placing employees upwind of
potential hazards.
9/20/99 9:22 AM
. . ,. .
MEMO
DATE:
TO:
FROM:
RE:
September 13, 1999
Pat
Wendy
Emergency Response Plan Comments
• Have they determined a HSO/Emergency Coordinator yet?
• Do they plan to meet with Division Safety Officers?
• I don't know if Warren County has a full time Fire Department, possibly only
volunteer???
Have they been notified?
JUST TO NOTE:
During the well installation, methane was detected numerous times delaying the well
installation process. I would also suggest a methane meter to monitor air levels. A
combustible gas meter has proven unreliable in the past when dealing with high methane
readings.
MEMO
DATE:
TO:
FROM:
RE:
September 13, 1999
Pat
Wendy
Emergency Response Plan Comments
• Have they determined a HSO/Emergency Coordinator yet?
• Do they plan to meet with Division Safety Officers?
• I don't know if Warren County has a full time Fire Department, possibly only
volunteer???
Have they been notified?
JUST TO NOTE:
During the well installation, methane was detected numerous times delaying the well
installation process. I would also suggest a methane meter to monitor air levels. A
combustible gas meter has proven unreliable in the past when dealing with high methane
readings.
JAMES B. HUNT JR.
l'"GoVERNOR -,
WAYNE MCDEVITT
TO: Pat Backus
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
September 2, 1999
FROM: David Lilley j) -S [__
RE: Comments prepared on the Draft Emergency Response Plan for
the Warren County PCB Landfill
August, 1999
After reviewing the above mentioned document, I offer the following
comments:
1. Page 3, third paragraph: Please define the terms "periodically" and "on a
regular basis" in terms of time (e.g. daily, weekly). Does the last sentence
belong in this paragraph? Does this refer to the annual HAZWOPER
training? Please clarify.
2. Page 4, Section 2.1, first bullet item: How will the scope of the daily and
weekly site inspections differ?
3. Page 4, Section 2.1, third bullet item: Job safety analyses should have
been conducted prior to mobilization in order to select the proper
personnel for each task. If you wait until you are at the site, it's too late.
4. General: Please spell out acronyms the first time they are used.
5. Table 3 .1: The Poison Control Center is listed twice.
6. Page 14, Section 5.4: The primary contaminants at the site (PCBs,
dioxins, furans) will not be directly detected with the proposed
instrumentation. The Occupational Safety and Health Administration
(OSHA) requires that, before using air purifying respirators, the airborne
chemicals be identified and the concentrations determined. Please explain
exactly how this will be done on this site using the proposed
instrumentation.
7. Page 15, Section 6.1, Life-Threatening Incident: An exact location for
the on-site person to meet the EMS should be specified in this plan.
401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER• 50% RECYCLED/I 0% POST-CONSUMER PAPER
..
8. General: No mention is made of the specific chemical contaminants
present at the site, or exactly what tasks will be performed at the site. This
document appears to be a pre-packaged generic template with only a small
amount of information (company names, the information in Table 3.1)
specific to this site. It is strongly recommended that before operations
start, a site specific emergency response plan and health and safety plan be
prepared.
DL/dl/word/shsp/9, 10