HAZARDOUS WASTE SITE
INVESTIGATION TRAINING
Washington, D.C.,
May 28-30, 1981
This.manual.has been prepared by the FIT National "Project .-Management
•pff.ice4::iEcbipgy. and Environment, Inc., Arlington,,-Va., under .EPA
Contract No. .68-01-6056. (Reference TDD: HQ-8008>04::)
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AGENDA
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DAY 1
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Name (optional) Key
5 - Outstanding
Affiliation 4 - Very Good
3 - Adequate
2 - Poor
1 - Inadequate
EVALUATION FORM
HAZARDOUS WASTE SITE
INVESTIGATION TRAINING
LECTURE CONTENT PRESENTATION COMMENTS
Orientation 12345 12345
Approach to Field Investigations
Hazardous Wastes
Toxicology
Personnel Protection
Ambient Air Characterization
Site Safety Plan Development
12345 1234
12345 1234
12345 1234
12345 1234
12345 1234
12345 1234
5
5
5
5
5
5
Site Safety Considerations and
Personnel Decontamination 12345 12345
Station Operation Procedures
Emergency Preparedness 12345 12345
Orientation to Respiratory 12345 12345
Protection Equipment
Explanation of Parts of the SCBA 12345 12345
and Demonstration of Equipment Use
1 of 3
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LECTURE
CONTENT PRESENTATION COMMENTS
Checkout Procedures for SCBA and 12345 12345
Demonstration of Donning
Equipment Exercise: Wearing
SCBA
12345 12345
Orientation to Field Exercise
12345 12345
Field Exercise - Overall
12345 12345
Station #1: Location and Setup
of Command Post; Dress Out; 12345 12345
Evacuation
Station #2: Equipment Operations 12345
Station #3: Downrange 12345
Considerations
Station # 4: Personnel 12345
Decontamination Procedures
Station #5: Health & Safety 12345
Rights and Responsibilities
Station #6: Air-Purifying 12345
Respirators; Fit Testing
Overall Course 12345
12345
12345
12345
12345
12345
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GENERAL REMARKS
1. Did this training course meet your needs? Please give reasons for your
answer.
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2. What, if anything, should be added to the course?
3. What, if anything, should be deleted from the course?
4. Please comment about the length of the course. Right amount of time?
Too long? Too short?
5. Did you find the course manual adequate? Any recommendations for additions
or deletions? Format changes?
6. Please add any other comments that you wish to make. (Use other side)
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COURSE ORIENTATION
I. INTRODUCTIONS
2. COURSE GUIDE
Contents. The Course Guide is intended to provide a summary of the
course. The guide contains an outline of the various presentations,
copies of handouts, and biographical sketches of speakers.
3. COURSE MECHANICS
A. Style of Presentation. The course will be a combination of
classroom lectures, and hands-on exercises. Students will be
given the opportunity to practice what is taught during he
lectures.
B. Breaks. Breaks are scheduled for both morning and afternoon.
Because the agenda is very tight, please try to be punctual at
break time.
C. Lunch.
D. Field Exercises. Sessions on Tuesday and Thursday will
require some running around with SCBA's and protective
clothing. All participants should wear old casual clothes and
shoes.
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E. Course Evaluation Form. It is important that we get feedback
on the course and recommendations on additions, deletions,
changes in emphasis, etc. This information will be helpful
for structuring the course in other Regions.
4. COURSE OBJECTIVES
A. Primary Objective. To prepare participants to undertake waste
site investigations in a safe and resource-efficient manner.
B. Objectives Statement
C. "One Approach" Concept
5. COURSE AGENDA
Review highlights of the five days.
6. NATURE AND SCOPE OF THE PROBLEM
Background. Uncontrolled hazardous waste disposal sites have
been a problem for many years. However, the problem became a
major public concern and political issue in 1977/1978 with the
discovery of Love Canal. Since that time, uncontrolled
hazardous waste disposal sites have been discovered in almost
every state of the country. Several studies have been
conducted in an attempt to determine the scope of the
problem:
1) A study conducted by Fred C. Hart Associates for EPA
estimated that 30,000 to 50,000 sites may exist around the
country and that 2000 of them may pose serious health
hazards.
2) A study conducted by the Office of Solid Waste in 1977
estimated that 90% of the potentially hazardous wastes
generated in this country are disposed in an environmentally
inadequate manner. The report also assesses damages caused by
the disposal practices. See Tables 1 and 2.
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Table 1
DISPOSAL PRACTICES FOR POTENTIALLY HAZARDOUS WASTES GENERATED IN THE U.S.*
Quantity of Hazardous Wastes Disposed
(metric tons)
Disposal Practice
Dry Weight
Wet Weight
i
OJ
of the Hazardous Wastes
Disposed (Wet Weight)
Environmentally Inadequate
Unlined surface impoundments
Land disposal (dumps, non-secure
landfills, land storage)
Uncontrolled incineration
Deep well injection
Landspreading
Use on roads
Sewered
Environmentally Adequate
Controlled Incineration
Secure Landfills
Recovery
Lined surface impoundments
Waste water treatment
Autoclaving
SUBTOTALS
Environmentally Inadequate
Environmentally Adequate
TOTALS
*Annually during the period
5,183,658
3,251,785
1,037,907
182,427
32,193
10,187
300
600,936
246,813
182,427
1,003
1,356
8
9,698,457
1,032,543
10,731,000
FROM: The
13,922,454
8,743,257
2,794,667
481,787
86,433
10,187
450
1,613,416
662,653
489,787
4,152
1,432
325
26,039,235
2,771,765
28,811,000
National Potential For Damage
48.3
30.3
9.7
1.7
.3
.1
.1
5.6
2.3
1.7
.1
.1
.1
90.4
9.6
100
1973-1975
From Improper Waste Disposal (EPA-OSW, 1977)
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Table 2
MECHANISMS INVOLVED IN INCIDENTS OF DAMAGE BY DISPOSAL METHOD3/
Disposal Method
Number of Cases
Damage Mechanism
(number of cases)
Groundwater
(259)
Surface Water
(170)
Air
(17)
Fires, Explosions
(14)
Direct Contact Poisoning
(52)
Wells Affected0/
(140)
Surface
Impoundments
89
57
42
3
-
1
32
Landfills,
Dumps
99
64
49
5
11
6
28
Other Land
Disposal b/
203
117
71
9
3
40
74
Smelt ings,
Storage Slag, Mine
of Wastes Tailings
15 15
10 11
8
-
-
5
4 2
a) The tabulation refers to 421 cases studied thus far. The numbers in the matrix add up to more than 421,
because several damage incidents involved more than one damage mechanism.
b) Haphazard disposal on vacant properties, on farmland, spray irrigation, etc.
c) Not included as a damage mechanism.
Note: The data presented in this table have been derived solely from case studies associated with land
disposal of industrial wastes.
FROM: The National Potential for Damage
from Improper Waste Disposal (EPA-OSW, 1977)
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3) A study conducted by the Environment, Energy and Natural
Resources Subcommittee, US House of Representatives in 1980
provides the following information on groundwater
utilization:
30 trillion gallons of groundwater withdrawn yearly.
Use of groundwater growing at 25% each decade.
Groundwater provides 41% of all water used for
irrigation.
- Groundwater is used by 95% of all rural Americans.
Reports now indicate well closures due to contamination
in 25 states.
B. Typical Sites. The following are typical of sites currently
being investigated around the country:
1) Verona, Missouri - Denny Farm Site 1
a) The Denny Farm is a 160-acre site in rural Verona,
Missouri
b) A chemical facility was operational in Verona from the
1960's through 1971. From 1969-1971 the facility was
used to manufacture hexachlorophene. This generated
several process waste streams with dioxin contamina-
tion.
c) In 1979, Region VII received an anonymous complaint
about waste disposal on the Denny Farm.
d) Investigation revealed the following:
- Between 30 and 150 drums of waste were disposed in
to a 10 foot by 70 foot trench in June 1971.
- The drums were dumped from the back of a truck and
were left as they fell.
- The drums were covered with from one to three feet
of soil.
- Samples were taken from the trench and found to
contain between 65 and 100 mg/kg (pptn) of 2, 3, 7,
8 tetrachlorodibenzo-p-dioxin.
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- Geological and geophysical studies demonstrated that
the area was in a classical karst topography
characterized by sinkholes, linear and right-angle
valley formation, pinnacle weathering, disappearing
streams, springs and caves.
e) These characteristics were considered to be a serious
threat to the health and welfare of area residents.
2) Riverside, California - Stringfellow Site
a) Stringfellow was operated as a Class- 1 disposal site
from 195Vto 1972.
b) The 14-acre site is located in Pyrite Canyon, a box
canyon in the Jarupa Mountains. The canyon is part of
the natural watershed of the Santa Ana River.
c) The site received an estimated 32 million gallons of
hazardous liquid wastes including spent acids
(sulfuric and chromic acids), organics (pesticides and
solvents) and heavy metals.
d) The wastes were contained in four primary ponds and 12
smaller containments with a combined capacity of 20
million gallons.
e) The site was abandoned in 1974.
f) During dry weather the site poses no serious threat.
However, during heavy rains the ponds overflow their
banks.
- 1969 - unmonitored overflow
- 1978 - 800,000 gallons bypassed to prevent a col-
lapse of the entire system
- 1979 & 1980 - only intensive removal operations pre-
vented a discharge
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g) Discharges from Che sice could enter Che Santa Ana
River, which is used for irrigation and public
recreation.
3) Seymour, Indiana - Seymour Recycling
a) Indiana's version of Chemical ConCrol
b) Approximately 60,000 drums and more than 80 bulk tanks
containing hazardous wastes are at the site. Possi-
bility of buried wastes must be confirmed.
c) The bulk tanks have been shown to contain combinations
of toluene, xylene, phenol and cresol.
d) Studies indicate that a plume of petroleum-related
aromatic hydrocarbons extends from the site and is
discharging into surface waters at Heddy Run, a
tributary of the White River.
e) The site is located in primarily an agricultural area
with corn fields adjacent on three sides. A small
industrial park is nearby and a water well is within
3,000 feet. Seymour is approximately four miles
away.
f) Primary threat from the site include:
- Explosion
- Fire
- Groundwater contamination
- Surface water contamination
- Irritating odors and fumes
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4) Mantua Township, N.J. - LiPari Landfill
a) The LiPari Landfill is on a 45-acre site which started
as a sand and gravel business.
b) The site began receiving solid and liquid wastes in
1958. The site was operated as a sand and gravel yard
and a landfill until 1971.
c) The site is surrounded primarily by private property.
An apple and peach orchard is -adjacent and a—housing
development was built nearby. Chestnut Branch flows
adjacent to the site and subsequently flows into
Alcyon Lake. A public park has been built around the
lake.
d) The volume of wastes disposed at the site is unknown
but is estimated at 12,000 cubic yards of solid wastes
and 2.9 million gallons of liquid wastes. Liquid
wastes were generally disposed uncontained.
e) Waste products include cleaning solvents, paint thin-
ners, dirty waste solvents, and phenol or amines
wastes.
f) The primary problem at LiPari is leachate being dis-
charged from the site into the groundwater and subse-
quently into Chestnut Branch. Contamination has also
been detected in Alcyon Lake.
5) We can see from these examples that each site presents a
set of unique problems based on the following parameters.
a) Waste Characteristics
b) Disposal Scheme
c) On-Site Conditions
d) Geology/Hydrology
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e) Meteorological Conditions
f) Pathways of Contamination
g) Proximity of Receptors
Each of these elements must be evaluated to determine the
relative level of risk (or severity of problem) posed by the
site.
C. Current Situation. In summary, the current situation can be
characterized as follows:
1) The Problem - Hazardous waste disposal is a pervasive,
complex, and serious problem warranting the prompt
attention of all levels of government.
2) The Victims - The victims are scared, and they perceive
that government is often unresponsive. The victim's
grievances remain unresolved.
3) The Solutions - The solutions are expensive, and we have
little practical experience to assess their effectiveness.
Many of the projects undertaken to date have been designed
on the basis of cost and have generally been rated as
unsuccessful. We have a lot to learn.
4) Your Role - We are in the early stages of development of
this program, and with the passage of Superfund, EPA will
be expected to assume the lead for solving this problem.
The success or failure of the program hinges on how well
you do your jobs.
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7. EPA SITES MANAGEMENT STRATEGY
A. Program Characteristics
1) Very Large Problem
2) Multidisciplinary Approach
3) Enforcement Element
4) Limited Resources
5) Political and Media Pressures
6) Elements of Risk in Conducting Work
7) Mistakes Could Result in Serious Consequences
B. EPA Response
1) Highest priority
2) Goals. Various stated goals include early detection
ofpublic health problems, minimizing environmental
impact, and minimizing costs to society.
3) Organization
- Enforcement Task Force
- Oil & Special Materials Control Division
- Office of Hazardous Emergency Response
4) Management Plan (Figure 1)
5) Scope of Activities. The scope and complexity of
activitiesandtherequired resources illustrate the
need for a standard approach. (Figure 2)
6) Applicability to State Activities. States need to
developapproachesfordatamanagement, setting
priorities, worker health and safety, and other
elements of the Federal program.
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SITE RESPONSE MANAGEMENT PLAN
I
I
M
M
•n
M
n
w
Voluntary
Action byA\«
FINAL
RCHEOIAL
OESIiiN
IHPLCHENTATIOH
V
1 '
1
POSr-CLOSURC
HONIIORlNTi
COST
RECOVERY
OCT281980
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NUMBER
OF
SITES
25.000-
20,000-
15.000-
10.000-
5,000-
PRELIMINARY
ASSESSMENT
INVESTIGATION OF HAZARDOUS
WASTE SITES (FY 1981-84)
TOTAL EXPENDITURES
(CONTRACTS)
IN $ MILLIONS
PRELIMINARY ASSESSMENTS 39 1
INSPECTIONS 95.B
HELD INVESTIGATIONS 112.4
n
G
INSPECTIONS
FIELD
INVESTIGATIONS
20k
40k
60k 80k
COST PER SITE (CONTRACTOR)
100k
200k
220k
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7} Training. This course is intended to assist the Regions
in managing this program by providing instruction in the
following areas:
a) Systematic approach to investigating sites, including
setting priorities
b) Appreciation for the hazards involved
c) Strict adherence to safety policies and
procedures
d) Good understanding of the capabilities and
Limitations of field investigation techniques and
procedures
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8. SITE PLANNING AND SETTING PRIORITIES
A. Introduction
1) Objectives. In stating objectives, identify emergencies,
screen out sites with a low probability of causing prob-
lems, sort the remaining sites according to seriousness,
and provide support for follow-up activities.
2) Scope. When do you stop?
B. Example (Note that the following is not a comprehensive list.)
1) Citizens' Letters
2) Newspaper Clippings
3) State Regulatory Agency
4) EPA Files
5) Aerial Photography
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6) Scientific Studies
C. Evaluating the Information (Specific example continued.)
1) Air Pollution
2) Surface Waters
3) Groundwater (Compare air photos with topo map.)
4) Human Exposure
D. Conclusions
9. PLANNING FOR INSPECTIONS (Specific example continued.)
A. Purpose and Objectives. The reasons for conducting the in-
spection should be clearly stated, e.g., "Test domestic water
supplies; visually confirm spills and leaking containers; ob-
tain environmental samples to discover composition of wastes."
Inspections vs. Field Investigations.
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B. Sketch Map. A map should be provided that shows command post
area, site boundaries, landmarks, surface features, buildings,
sample points, etc.
C. Background. A summary should be prepared that gives informa-
tion concerning possible hazards to inspectors and the public,
and a history of site operation.
D. Work Plan. The Work Plan lists major tasks to be accomp-
lished.
E. Safety Plan. The Site Safety Plan must address the following:
1) Protective Equipment
2} Emergency Facilities
3) Monitoring Equipment
4) Contingency Plans
F. Team Assignments. The number of personnel required is a func-
tion of the mix of expertise required to do the job, safety
and decontamination requirements, and communication needs.
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G. Logistics Planning. Determining the necessary logistical
plans includes:
1) Travel and Accommodations
2). Equipment (in addition to safety equipment)
3) Sample Handling
4) Shipment
H. Legal Entry Requirements. This may include obtaining any
necessary warrants.
10. DATA MANAGEMENT
A. Purpose. For any site management system, it is necessary to
have a data management system for: information storage (to
maintain continuity), enforcement purposes, program manage-
ment, and regulations.
B. Forms
1) Identification and Preliminary Assessment
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2) Inspection
3) Log
4) Tentative Disposition
11. SETTING PRIORITIES
A. Rationale. The setting of priorities is critical in order to
deal effectively with the workload and political pressures.
B. Existing Guidance
C. Specific Example
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LIN HUVEN x
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SAN FRANCISCO CA 9U107
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PRESIDENT JIMMY CARTED
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CHESTER L. BROOKS
1065 Tommy Street
N. Canton, Ohio
UJ20
Sunday Mar. U. 1979
Junes F, MoAvoy - Director
Ohio » EPA
Box 10U9
361 E. Broad Street
Columbus Ohio, U3216
Subjects Dumps at Deerfield Ohio in Portage Cftunty
Dear Sirs
I was at the residence of Doris Carver yesterday and talked with some other people
in this area.- see inclosed photo copies* I have known about this area for years
and prefer to let sleeping dogs alone unless it bothers me » I am supersensativa to
a whole range of toxic chemicals and have been this way long before EPA was ever thougt
of.
The eleven acre dump shown in the picture belonging to Hr« Oeorgeoff I am of the
opinion is but a drop in the bucket as far as toslc chemicals that are buried in
the area, I have made effort to get a good arial map of the area but the Akron
office that has the maps of Portage County are of little value.
Yesterday there was a fire in progress in this area but it was In the area between
where a whitish substance was being dumped and where there waa a derrick like they
were drilling a well and whether this was on Gergsoffs property or the dump Just
south of it I do not know as I will not even get out of tho car and walk on thia
contaminated area. This was approximately UsOO ?.H. and the smoke was low to the
ground and going Northward toward the Skating Rink on U.S. 22li and it had a stinking
chemical odor.
What has really presented a challenge to ma is the, go to hell attitude of the dump
operators and their , health be darned and environment be darned attitude* Its time
to find if there is any teeth in the Toxic Substances Control Act* Last year your
boss Qov. Rhodes claimed he was the Ho. 1 EPA fighter in Ohio . He also made much
todo about using Ohio Coal but he has changed his position. He might change his
position on this environmental fester of national proportions too.
I expect to write this up to Mr. Costle at Washington in the ners future and will
send you a copy of the letter. Might mention that I was in pour office during the
afternoon of January 25th and talked about this situation among other things with
a Mr. Johnson , I believe his name was.
Very truly yours,
l-A-22
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i
ro
OJ
y IticbnrdG. Ellcrs • '
. Stall wrlicr • '
SNA — One of Portage
County's least attractive, but
posiiLJy most dangerous sites is an
11-ccrj: dump in en old strip mine
v/ost vf Ocrerfield Center at U.S. '
224 an,: Chio 225.
Suni.iiU National Liquid Services
Dump, .i.vned and operated by Dan
Gcorc; ?/{ of Haiti, is the last stop
for tl.iv. :,,inus of rusted, dented,
tople^. 55-rpllon metal barrels
• containing chemicals that arc
though!, to bs dangerous.
DJCI field residents and health
officials1 jiavc been complaining
abouti^inolrc and odors from the
durnp^fcix; it opened in 1073 and
fear i1 1 leaking chemicals may
coiitai.iiiiitc \vatcr supplies.
The* township fire chief said the
dump ii.ay be a ticking time bomb
bccsusD inrrcls of hirj'nly flamma-
ble chemicals arc improperly
stored' :::'jd a fire there would be
hard to .io
Las]" June, the Ohio Environ-
menttj tVotection Agency ordered
Georg'-of f lo stop burning llic waste
chcmi^.'.Ji and to file plans for an
ofiluly/ safe clean'-.p of t\is
[,: opt/Ly. The agency I, jliovcj somj
of tlic'jJicmKVtb :ire io^iicldis «ind
chemicals which the agency said
Gcorgcoff cannot burn and for
which he docs not have a permit
to handle or store.
Georgeoff has appealed the order
to the slate FnyironjncplaI Kqnpj
, of_Rcyiew_ with a licarjnR 'scTfor
Gcorgcoff has applied to the Oldo
EPA for a larger incinerator to
, burn waste oils and solvents.
Georgeoff could not be contacted
''and his 'lawyer in Al:ron said he
. would, not allow him to comment
• while hearings are pending. .
At a hearing last week in which
Gcorgcoff was to give a deposition
before'the county.prosecutor,
Georgeoff repeatedly refused to
identify any of the sources or ship-,
pcrs of the estimated ^jaiUJojj
is ol waste chemicals at th'a
Asst County Prosecutor Louis
Myers then filed contempt charges >
Tuesday against Gcorgcoff for his
refusals. ' . '
Records of the Ohio EPA district '
of/ice in Twmsburg show that soon
after he started operations in 1073,
Georgeoff had been rcpcr.leilly
waiT.Ld fibsnt his failure to correct
I'«s operations and to cicja vp Lis
diijnp.
'h«' order provided for Hie
ovul of h^::i.'.v3
n::; Lc..-, an
EPSi cr:»J-
:»!:,v; c. lac
t>S
never lulfllls them.
said the Stale Fire Marshal's office
lias never held a hearing on a fire'
code violation ami a cleanup order
lie (Fclinly) j&ucd lo Gcorgcoff last
summer. • •
"The fire marshal accepted
Gcorgcoff's appeal of my order'
even though it was late. And except
for a couple of visits by inspectors,
the state hasn't done anything lo
niova the case clone," Felmly said.
'If \ve ever have a fire at the
dump, those barrels of oils and
solvents will crack in the heat and
lake off like rockets spewing fire
all the way," he warned.
• Felmly said he-is annoyed by-
the slate's failure to act on his fire
cede violation charge because three
of the violations will make the place
very dangerous to Itis men in the
evont oi a fJre there. ; , •
,••'•'
lie said the access road is barely
fIij required 12' feel wide in.rnsny
places and always pocked' V:\.'
chucklio'ts, some two feet deep. The
ro.Kl i; liuod on belli side:; with
ifc.^s 01 iliiruiiiciblc chemical:;, al-
~(li>ju<,ii fcleilo c'lia H-qwircB
al^iji.v.al lt.s lo fcs Lioroc) .no clojor
t!'.i« ::3u kiii to a fire Ir.no, l:-o
t
touring so that chemical spills flow
to a pool where they can be pumped
ouL"
ftons Carver, who jivos nrx«^
JUL&SrfroiTi the dump, organized
and is president of the Concerned
Citizens of Dcerfield. She said
residents met last fall when it
seemed state action might not
. really be getting anywhere.
"We met with Mr. (Ned E.) Wil-
. liams (former director of the Ohio
EPA) after months of him avoiding
us. And he made me mad xvhcn be
kept telling me we had to forget
the past and only take care of the
future.
' Mrs. Carver said she was annoyed
and worried "when Mr. Williams
told us that we cannot push
.Gcorgcoff too hard or he might
tlrow up his hands, put his corpo-
ration in bankruptcy and abandon
the mess," she said.
The group hired a _Colu;iibu.s
lawyer specializing in cnvironmcn;
nnjp'r'otcsiiqn "and have been, ac-
cSjiled as a party to the board of
review case.
But, Mrs. Carver said, their law-
yer warned the citizens group at a
meeting last week Ui.it even '? they
v.';n the case before the fcjan' of
loview, Gcorgcoff's appaa' nf'tjlit
d'.ive the fight U'rcugh r^'u- for
i^vcral years.
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CiHzsns skate to fund cleanup u.,u
I -• • ' 10 j J
chemical waste facility at the in-
tersection of U.S. 224 and Ohio
225 in Deerfield Twp.
Admission is $1.25 and skates
may be rented for 50 cents. The
rink is located at 8153 Waterloo
lid. and the party will be from
4:30 to 6:30 p.m.
There will also be a bake sail
during the skating party.
D —TheConcern-
ed'Citizens ofDeerfield Commit-
tee will sponsor another "skate
to clean up the/liimn" Sunday at
the Starlight Roller Rink in At-
\\aier
Procc-eds from the skating
party will go toward the citizens'
ongoing fight against the Sum-
mil Nation Liquid Services Inc.
toxc wastes
AKRON (*P> — Michigan Atty.
Gen. Frank Kelley said yesterday he
is concerned about a plan to ship
toxic wastes from a company here
into Michigan.
Ohio officials forced the Summit
National Services Co., a commercial
waste disposal operation in Deerfield
• Township near Akron, to close its
• waste incineration furnaces about a
year ago. The company then began
storing drums of toxic pollutants on
its 11-acre lot.
The Ohio Environmental Protec-
tion Agency discovered the situation
in January and began negotiating
with Summit about cleaning it up.
.One of the proposed solutions was
that the company send all of the toxic
materials back to the companies that
produced them.
Federal law suggests the producer
of a pollutant is ultimately responsi-
ble for its disposal.
Among the materials on the Sum-
mit lot are 4i5JL0_gaHo_ns_of_CJ361 a
toxic compound of ~ plastics and
pesticides manufactured until re-
cently by the Hooker Chemical Co.", in
Montague, Mich. There also* ere
quantities of thtojet. and eytrolane.
deadly pesticides then produced by
Lakeway Chemicals Inc., of Muske-
gon, Mich.
When Howard Tanner, director of
the Michigan Department cf Natural
Resources learned of the Ohio plan,
he had his staff draft a letter to the
Ohio EPA warning that Michigan
would cake legal action to block the
shipments.
1 --A-24
-------
~^~^\^3^-- - l§ •:
S«aa*iiSM
° 1 •'i^'^Z - V~X/ .'W .1 V
si-MM^T1*^ >** ^iUT . J^_\ ^
.•• O
l-A-25
-------
/^^^;T^£^^^
:-• n:&-^'V^rv.^r^.^^^ -^..^'^.•^^j^.^v^i.L^^^^ ui...^-
1978^
BE SURE NAME, BUSINESS AND |
ADDRESS nATCH YOUR FILE.
ANSWERING
INQUIRY
SUBSCRIBER: 061-002511R
I '£ ADDRESS MATCH YOUR FILE. IN2UIRY |
• flgigfflgi^^
i -i:--;--v, FULL REVISION i -L-/.;\,-^-- • ;." •; ^.-ir-j^v--.:'- nr-;'°^--v-7:j"V-^;^V;r-\vV..-.r/v;^"
DUNS: 07-67^-9373
SUMMIT NATIONAL SERVICES
BOX 1531
18 ANACONDA RD
AKRON OH 44310
TEL 216 633-0110
MAR 27 1978
LI2UID WASTE
DISPOSAL SERVICE
SIC NOS.
49 53
SUMMARY
RATING
STARTED
PAYMENTS
EMPLOYS
HISTORY
1973
SEE BELOW
2
CLEAR
OWNER
PAYMENTS (Amounts may be rounded to nearest figure in prescribed ranges)
REPORTED PAYING HIGH NOW PAST SELLING " LAST SALE
RECORD CREDIT OWES DUE TERMS WITHIN
3/78
1/78
FINANCE
Slow 90
Ppt-Siow 20
250
2500
-0-
-0-
-0-
-0-
6-12 Mos
6-12 Mos
ON 03/27/78
off stated slowness caused by slou receivables
On Mar 21 1978 Donald Georgaoff, owner, declined financial information,
HISTORY
Business started 1973. Initial
acknowledged ownership Oct 20
Company,
wi th FranK
Ohio. 1955
1961 became
DONALD MOaBBMF, OWNER
Style unregistered. Used for business purposes.
ivestmant or starting capital not learned. Georgeoff
1976.^
tJBSHBMBF, born 1932, married. 1951-52 with Goodyear Tire & Rubber
factory worker. 1952-54 ervied in United States Array. Jun 1954 partner
Zimmerman, operating service station at 1924 Bailey Road, Cuyahoga Falls
purchased partner's interest and continued individually until 1961. • Mar
par-cner in Georqeoff's Cafe at 303 E Tallmadge Avenue, Akron Ohio, continuing until
Har 1962 when btAS-ujess discontinued. 1962-late 1964 self-employed in automotive
repair work. QT.964^formed Summit National Jgjif_yse Co, operating individually until
being ^nrraorlori by -a* eof aeLLa^i tiii^n Aar ^triqzXaL I"he company was engaged in refuse
flg.niP"al "ofvigo- Effective Mar 1 1972, reruse collect i on routes and equi pnan b soT3~
closed. The equipment consisted of four packer trucks and one straight truck. Tha
purchase price was not disclosed, but included a cash down payment, with an addft'or-aJ
payment to be made on Jan 1 1973. As far as can be determied, there are no
outstanding loans on the equipment and the sale was profitable for Summit National
Refusa Co (Inc) . In^Ti^his sale Summit National Services came into existanc_a to
ERnTION
Liquid waste disposal service 1002. Terms are net 30. Sells to industrial
concerns. Territory general area.
EMPLOYEES: 2 including owner.
LOCATION: Owns 1 story brick and steel building in good condition. Located in
secondary business section on side street. Premises nsat.
05-16(179 /91 )0000/00 11502 2 012
l-A-26
- TP ,,-.,7=A^T pj-i TKi tjfLUSii'E US= C.T TH= CU'taCniqET 43 0"I6 c^c-T^q Ti (.O'T ^CP
,;- -^-I'.-.T JUS.rJEs"; -3FCr,IO-S CONTAINS .•li--saWar.:iMCOM^LE3 FROM SOU-Ct5WHICI' uj>4 ?. SSAO<5.F.CE
ir---r>' i 'ri'|.|<-M'DINrreBSi"3<'' V=M.'rti'-'i..-Hi-l:3 i'i- q f. -„,),, 'i.cp^S'O^r DLiN*
-.;,,',.,. ~ -,., ">.e<." om nis<= m%- O'li^i'irFC If^ ..CCUItAUi CO\.3| erstcc- r-- . «•-- -- -
CVM' ~Cf!C: V/ITH CiTEJI*
IMC DCS'. MOT .ONTSOl ,«SP
,VK I . ilC I A
-------
lj.5
C< 5b
n
l-A-27
-------
I
I
CD
/"'
i , ,.'i.v.« :> ,1'joono rrri
I. ,....•;
vey
•'». ' ( " .,'" i •; i AV ' -§
] 'o '""fj f>> ^> __J-^
<94 IALLIAN<.:C> JQ5
SCAI.I: ] .;.'.-! ooo
1 1
i i ' i i i i i i
L. \r-
•% 2
\ Mil
" I
y
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1
"l II I M II ,1 I 4,1 I' Hi !( IIH I M I I
I _ - I I I
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CON I ()!IK' in I I KVAI ID I I I. I
Al l,| i)lil III. '/I I'llCAI. liAHIM OK I'll")
OMIO )
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"^ ".ff
'WHAii/.i.i L'ji.'>!:(...;.
-------
POTENTIAL HAZARDOUS WASTE SITE
IDENTIFICATION AND PRELIMINARY ASSESSMENT
PEGION
SITE NL.»3ER (to t»
s lined by Hii)
HOTS: Tr.is form is cotr.ple'.ed for each potential hazardous waste site to help set priont.es for site inspection. The info-r-.rtion
suxnr.ed on this fora is bdsod on available records and rr.aj be updated on Subsecuent forms as a result of additional inquiries
ar.d on-site inspections.
CS'-I'^AL INSTRUCTIONS: Corrplete Sections I and III through X as cor-.pletely as possible before Section II (Prelirnim-y
Ass ssaient). File this fom in '.he Regional Hazardous Waste Log File and sub-ait a copy to: U.S. Environmental Protection
4.cepcj; Site Tracking Systecs; Hazardous fi'aste Enforcs-aent Task Force fEiV-335); 401 M St., SW, ft'ashi-igton. DC 204CO.
I. SITE IDENTIFICATION
A. SITE NAME
-i (\/*n O.
3. STREET for other identifier)
C. CITY
D. STATE
E. ZIP CODE
F. COUNTY NAME
G. CV-MER/OPERATOR (il kno*n)
1. NAME
2. TELEPHONE NUMBER
H. TYPE OF OWNERSHIP — J
\ |l FEDERAL Qz. STATE ! |3 COUNTY
4. MUNiC'PAL
E I J6. UNKNOWN
i. SITB DESCRIPTION^
S '
t-,.ljp,v
'' l" -
rg s
J. HOW IDENTIFIED (i.e., citizen's coixplamts, OSHA citations, etc.) $.jr (• £\
K. DATE IDENTIFIED
(mo., day, & yr.)
l_. PRINCIPAL STATE CONTACT
1. NAME
2. TELEPHONE NUMBER
II. PRELIMINARY ASSESSMENT (complete tHis section last)
A. APrARFST SERIOUSNESS OF PROBLEM
1 jl HIGH j 12. MEDIUM | J3. LOW 1 14 NONE i JS UNKNOWN
. RECOMMENDATION
I I 1. NO ACTION NEEDED (no hazard)
I I 3. SITE INSPECTION NEEDED
> TEKTAT VELY SCHEDULED FOR
b. WILL BE PERFORMED BY
I I 2. IMMEDIATE SITE INSPECTION NEEDED
• TEMTATIVE_V SCHEDULED FOB
b. WIUL BE PERFORMED BY
I I «. SITE INSPECTION NEEOEO (low priority)
C. PREPARER INFORMATION
1 . NAME
2. TELEPHONE NUMBER
3. DATE (mo., day, & yr.)
III. SITE INFORMATION
A. SITE STATUS
I I I. ACTIVE fThoie industrial or
municipal sltem which are bunt used
for waste treatment, atorafe, or disposal
on a continuing basia, even il /n/r«—
quenlly.)
I I 2. INACTIVE (Those
af(e« which no longer receive
r&l. OTHER l-aneei/v); O lf\Jes\-
(Those sites that include such incidents like "midnlfht dumping" where
no regular or continuing use ol the site lor waste disposal has occurred.)
3. IS GENERATOR ON SITET
ITn NO
I 2. YES (specify generator's lour—digit SIC Code)
C. AREA OF SITE (In acres)
0. IF APPARENT SERIOUSNESS O^ SITE IS HIGH. SPECIFY COORDINATES
1. LATITUDE (deg—mm.—sec.) 2. LONCI TUOE (deg.— mm.— sec.)
00
E. ARE THERE BUILDINGS ON T"E SITET
I I I NO r~&(2- YHS (specify)-
T2070-2 (1C-79)
Continue On Reverse
l-A-29
-------
Continued From Front
IV. CHARACTERIZATION OF SITE ACTIVITY
Indicate the major site aetivityftesj and details relating to each activity by narking 'X' in the appropriate boxes.
X1
A. TRANSPORTER
X
8. STORER
C. TREATER
O. DISPOSER
1. PILE
1 . FILTRATION
I. LANDFILL
. SURFACE IMPOUNDMENT
2. INCINERATION
2. LANOFARM
3. BARGE
3. DRUMS
3. VOLUME REDUCTION
1. OPEN DUMP
4. TRUCK
4. TANK. ABOVE GROUND
4. RECYCLING/RECOVERY
«. SURFACE IMPOUNDMENT
S. PIPELINE
TANK. BELOW GROUND
3 CHEM /PHYS. TREATMENT
9. MIDNIGHT DUMPING
8. OTHER
OTHER (opacity):
f
•.f
«. B'OLOGICAL TREATMENT
6. INCINERATION
7. WASTE OIL REPROCESSING
'. UNDERGROUND INJECTION
6. SOLVENT RECOVERY
J. OTHER (tptcily):
9. OTHER (tfoelty):
E. SPECIFY DETAILS OF SITE ACTIVITIES AS NEEDED
V. WASTE RELATED INFORMATION
A. WASTE TYPE
C] 1. UNKNOWN [\?2. LIQUID Qa. SOLID I 14. SLUDGE
I |5. GAS
B. WASTE CHARACTERISTICS ~ ~~~~ "~—
. UNKNOWN n]2. CORROSIVE 03. IGNITABLE Q«. RADIOACTIVE I J5. HIGHLY VOLATILE
. TOXIC I I? REACTIVE I la. INERT H79. FLAMMABLE
I llO. OTHER (specify)-
C. WASTE CATEGORIES
1. Are records of wastes available' Specify items such as manifests, inventories, etc. below.
2. Estimate the anountfspecify unit of measurejof waste by category; mark 'X' to indicate which wastes are present.
a. SLUDGE
b. OIL
e. SOLVENTS
d. CHEMICALS
e. SOLIDS
f. OTHER
AMOUNT
AMOUNT ,
£ } (RT>O d-
AMC'INT
AMOUNT
UNIT OF MEASURE
UNIT_OF-MEASURE
UNIT OF MEASURE
UNIT OF MEASURE
UNIT OF MEASURE
UNIT OF MEASURE
(il PAINT.
PIGMENTS
(IIOILY
WASTES
X1
(IIHALOGENATEO
SOLVENTS
X1
111 ACIDS
(II FLYASH
X1
(II
LABORATORY
PHARMACEUT.
(Z)METALS
SLUDGES
(ZIOTHERftpecifrJ
I2INON-HALOGNTD
SOLVENTS
(21 PICKLING
LIQUORS
(2) ASBESTOS
(2IHOSPITAL
OIPOTW
<3)OTHERf»pec//y;:
(3ICAUSTICS
(3IMILLING/
MINE TAILINGS
(31 RADIOACTIVE
(41 ALUMINUM
SLUDGE
(41 PESTICIDES
I... FERROUS
(4)
SMLTG. WASTES
(4) MUNICIPAL
1(5) OTHERfapecf/y/'
(5IOYE3/INKS
,-. NON-FERROUS
101 SMLTG. WASTES
(8)OTHERf«pae
-------
,o-\tinued Fro-n page 2
V. \\ - /• /- ,•
-\ ,-... . , i -~,.i • ' ;
1 ' ^i ^i
Of •/ ^x—*A. ^V
6
•
,-"-±v^- :• . »-3 .-• / • • • • J
.1 ' • ••
fr> ' i/jf
i
ir^w f \ . o.v^ ' ' '-' ^ ' '' '
.,//' '
-/-
AO Cf?f*JJiF&'*~-1 ~ -,-•••' ^ •' '
EPA Form T2070-2 (10-79) PAGE 3 OF 4 Continue On Reverse
-------
Conrmueef From Front
VII. PERMIT INFORMATION
A.. INDICATE ALL APPLICABLE PERMITS HELD BY THE SITE.
Q 1. NPOES PERMIT f~l 2. SPCC PLAN PCfTsTATE PERMITfapee/fxJ:
{ | 4 AIR PERMITS f~1 5. LOCAL PERMIT I I 6. RCRA TRANSPORTER
I | 7. RCRA STORER I I 8. RCRA TREATER I 1 9. RCRA DISPOSER
I | 10 OTHER (specify)-
/
A /
3. IN COMPLIANCE?
~| 1. YES
2. NO | | 3. UNKNOWN
4. WITH RESPECT TO (lift regulation name & ruaiber):
VIII. PAST REGULATOR-Y ACTIONS
A. NONE
I I B. YES (summarize be/ow)
IX. INSPECTION ACTIVITY (past or on-goin4)
^S]^A. NONE I 1 3. YES fcomp/e(» Item* 1.2,3, & 4 baiow)
1. TYPE OF ACT'V'TY
Z DATE OF
PAST ACTION
(010,. day, & yr.J
3 PERFORMED
BY
(EPA/ State)
4 DESCRIPTION
X. REMEDIAL ACTIVITY (past or on-going)
^j^f A. NONE I I 8. YES (complete Items I, 3,3. * 4 below)
^
I.TYPE OF ACTIVITY
•
2. DATE OF
PAST ACTION
fsio., day, it yr.)
3. PERFORMED
BY
(EPA/State)
4. DESCRIPTION
NOTE: Based on the information in Sections El I through X, fill out the Preliminary Assessment (Section II)
information on the first page of this form.
EPA Form T2070-2 (10-79)
PAGE 4 OF 4
l-A-32
-------
TES
ft ; T I X « FORK FOR „' A S T E DISPOSAL SI
• • £ o ? s f - i —^tAyiM'T fS/g'v'T 1-—^g^ViCes ACTIVE: [ACTIVE (CIRCLE WE)
> c A T i o H \Jgo -X^rV^X JL , ^ * ~"
T o s
ll
SATING
= i C T n 3
SOURCE AND 3ASIS
S I
R 1 T
7 1 !
T E
i H r-
t 1 s
rtJLTIPUE*
•g^ifloa, ;i jf^jBgraattCg
SITE
s c o 5 £
G^&ecssaKuKjsssno
MAXIUM
= CSSi3L£
tl-s c-^rr i
U*™-"'*' "Tifc.. -^^«9«-> t '
'-^'> i i TV O HAZA.-.iX^jS MAS i =S
TCXICITY
PtRSISTEfJCs
9.11^. T —
ISNITA21LITY
PSACTIVI7Y
CO^RCSIVITY
r^ECTieja'IcSS
SOL13 ! LI TY
VOLATILITY
PHYSICAL STAT=
VASTS C 1 * s A
C T
s ?
I S
-£.
7~
T T
3
3
T
c s
7
5
5
3
3
3
3
4
4
4
0 T A L S
•2.1
/s
b
^
^
~*^
*^"
-
S
2.|
13
_ -
/ '.'" i
_
^_^
^
.
/ _
vy. ponirs FCS LASCE
9 !l
«3IT:Cf«y. rOI.'.'TS FOR CTKES j
1 •— j
POPU^TICKI IN 1,000 FEET !
ISTA'CH TO r:=#?=ST DfiltlKlPG-
WATS V;Q_!.
0!a.A.-Ct TO f-'EASEST OFF-SITE
suiLDira
ZONIf.a/LA.'G USE
E.'CAVj£=,ED 5=EC'.=S C=
^1
-3
0
5
±>
T
1 2
8
8
5
5
0 T A L S
r i
..
;: ^ •
• ^
.
•
' j ~
.ODmcy.il_ PC'.MTS FOR OTr-sR
o
\ 3 0
it •.•3stoSKrii:iS!«.2ir &r*
l-A-33
-------
EVIIiVIE Cr
1 2
DISTANCE 70 MV-iST
3£?7H T3
SOIL PES-EABILITY
PCS orr^:
TOTALS
2 0
A s rr
SITE ScOFITY
t!JCaPA7isLE WASTES
KATiO C? WUAnDOUS TO f.0(<-
WLi-JCUS 'riioTE CUWrtTIES
SE A.'O CaOITiOl Or CCCTAtKERS
.£ Cr LEAC-ttTS COLLECTION SYSTET
use OP Lirsss
3
8
5
5
1
4
0
TOTALS
H
.
:: <• ,
- —
_
. - — .
^i
'J.L FOltrS FOR OTHER
2-0 2_0
«3r^^'J^K-jpgf.^/.yj^^^ •-r^^.-.-. w^v; yiaj>^.»'J» < -.>i-7^AJ-.~y-T.^r^sgi?==7
--^. -^-'-^'S.—^^-^^.f^-^-.^.-^-^^
2'0
NUMBER CF MISSI.'iG OR ASSUMED
VALUES - OUT OF 29.
PERCCNTA35 OF HISSING OR
ASSUMED VALUES = I
TOTAL SITE SCORES.
TOTAL ADDITIONAL POINTS.
TOTAL SCORE £
(SITE SCORES PLUS ADDITIONAL POINTS)
TOTAL MAXIMUM POSSI2L& SITS SCORE-
NORMALIZED SCORE ' **
{TOTAL SCORE DIVIDED BY MAXIMUM SCORE AND MULTIPLIED SY ICO)
PREPARED 3Y:
ON.
l-A-34
-------
en
Mean annual precipitation in (lie United Suits, in inches. (U.S. t'tifiniiuiifnlnl Duln Si-rrire.)
'if.ure A-l Maps for liv;iluntiii); Nc't I'mc I p i I a L i on (M.ip No. ])
-------
I
3=
i
OJ
CTl
mxm
W » _J, >;, ,0 „. ,,, „
-------
Sc=£ ?rc?er:ies of 7er:^rsl Classes
S_iad: Sond is loase and single-grained. T-.e individual grains caa readily
be seen cr felc. Sqjeeied la t-a hi-d -.neT dry it vill fall asert vi-ea the
press-re is released. Sq.±s:ed -.—.en =oiat, 1: .-ill fcra a cist, but vill cr--=^la
vr.es tcuc^ed.
Sa-dv loa=! A sancy lca= is a soil cor.teini.-.s =uch sar.d bi.c v.Mcb has
enough silc ar.d clay Co =_a'».e it Ec=a---3t cchere-.c. The iadividual sand gralas
can readily be sees ar.d fell. Squeezed v.-.en dry, it will fcr= a cast vhlch trill
readily fall epsr:, but if squeezed then -oisc a case can be forced chat .-111
bear careful '-iar.dlir.3 •.•!:>.=•_ t breaxi=g.
Silt Leas; A sil: Icsa la a soiL havir.g a =odera:e e=si=c of the fine
grades o: sir.C erd o-.ly e. s=ill e=oin; ci clay, ever half of Eve ;ar:iclea beitg
of the size colled 'silc'. Vhen t^Y 1E =ay i??«ar cloddy buc tve l-=os cu be
readily brc'.: poir'i ccr-ciponci.-1 10 .v« pc-se-aic» of i.l uvi clij
prne-.i « i he vail u-^i- ee-i Jsranor uc levied on i\e nil mi tiy lj-
-------
Table A-l Waste Characteristics Ratings for Several Common Chemical
Co.T-.pour.ds
AC- . M i ,)r.
ACci:i. -C-'J
AC~0'.i
ALD'.I.N
AMMCSIA
CASIO-: T—i
CXLCSC:-'
CiC:.Cr.EX.V.E
ODT
?os.":c
?C3
j sn.rv?.:c
. Tun. •' E
2 . 3
1 • I
2 i 0
3 3
I
3
l|
3 i
3 :
2!
2
li
3
! 0
!«
: 3
i o
I 3
0
, 0
, 1
1 ' 3
0 . 2
0 ' 2
j 0
0 0
1 ! 3
1
3
: 3
1
I ~
, 0
i:
jo
1°
0
1°
I
0
0
0
0
0
0
0
! 0
.0
io
I
;o
: 0
0
0
0
1
! °
i
3
3
0
0
1
^
3
1
3
0
3
i
j 3 : o
i 2 j 0
. 0 2
i, !o
>!>
0
i °
I o
I
: 3
2
| 2
: o
o
i 0
j°
I o
i C
. 3
0
. 2
3
! 0
0
| 0
; 0
0
. 0
2
. 1
I 0
' 1
i 0
I 0
li
I 1
i 3
3 :
0 -
o ;
o
i j
3
2 :
i
3 .
; 3:
{ 0 .
2
;°
i 1
1
l-A-38
-------
Table A-2 Persistence (3icde~radability)of Sone Organic Compounds'*
LEVEL 3: HIGHLY PERSISTENT COMPOUNDS
aldrin
benzcpyrer.e
benzothiazole
benzothiophene
benzyl butyl phthalate
bronochlorobenzene
bromofom butanal
brorccphenyl phenyl ether
chlordane
chlorohydroxy bensophenone
bis-chloroisopropyl ether
in-chlorcni:robenzer.e
DDE
DDT
i
dibror.cb =nz
dibucyl phthalace
1 , 4-dichlorober.zene
dichlorodif luoroethar.e
dieldrin
diechyl phthalate
di (2-e thy Ihexyl) phthalate
dihexyl pnchalace
di-isobuzyl phthalate
dine thy 1 phthalate
!* , 5-dinitro-2-arr.inophep.ol
cipropyl phthalate
endrin
heptachlor
heptachlor epoxice
1,2,3,^,5,7,7-hep t ach loronorborr.ene
hexachlorobenzer.e
hexachloro-1, 3-butadiene
hexachlorocyclohexane
hexachloroethar.e
methyl benzothiazole
pentachlorobiphenyl
pentachlorophenol
1.1,3,3-tstrachlorcacetone
tetrachlorobiphenyl
thionethylbenzochiazole
trichlorober.zene
trichlorobiphenyl
tr ichlor of luorcr:.e thane
2, t-, 6-trichlorophenol
tripher.yl phosphate
brcnocichlorc-iethar.e
broaofora
carbon tetrachloride
chloroform
chlorcnochloronie thane
dibrcrriodichloroe thane
tetrachloroethane
1,1,2-trichloroethane
'•Fro-.: Abrans, E.F. et al., Identification of Organic Compounds in
Effluents fro-n: Industrial Sources, ZPA-560/3-75-002, April, 1973
1-A-39
-------
Table A-2 Persistence (Bicdegradability) of
(Continued)
—Q Organic Compounds
LZVEL 2: PERSISTENT COMPOUNDS
acenaphthylene
atrazine
(diethyl) acrazine
barbital
borneol
bronober.zer.a
camphor
chlorobenzene
1,2-bis-chloroethoxy ethane
b-chloroethyl methyl ether
chloronechyl ether
chloroisethyl ethyl ether
3-chloropyridine
di-t-butyl-p-betizoquinone
dichloroethyl ether
dihydrocarvone
dimethyl su if oxide
2,6-dinitrotoluene
cis-2-ethyl—4-nethyl-l,3-dioxolar.e
trans-2-ethyl-4-nethyl-l,3-dioxolane
guaiacol
2-hydroxyad iponi tr ile
isop'norone
indene
isoborneol
isopropenyl-^-isopropyl benzene
2-nethoxy biphenyl
nethyl biphenyl
aethyl chloride
methyiindene
^lethylene chloride
nitroanisole
nitrobenzene
tetrachloroechyler.e
1,1,2-trichloroethylene
trinethy1-trioxo-hexahydro-triazine
isobar
l-A-40
-------
Table A-2 Persistence (Biodegradability) of Seme Organic Compounds
(Continued)
LEVEL 1: SOMEWHAT PERSISTENT COMPOUNDS
acetylene dichloride
behenic acid, methyl ester
benzene
benzene sulfonic acid
butyl benzene
butyl broaide
e-caprolactaa
carbon disulfide
o-cresol
decane
1,2-dichloroethane
•1,2-dinethoxy benzene
1,3-dimethyl naphthalene
1,4-diinethyl phenol
dioctyl adipate
n-dodecane
ethyl benzene
2-ethyl-n-hexar.e
o—ethyltoluene
isodecane
isopropyl benzene
liaonene
methyl ester of lignoceric acid
methane
2--ethyl-5-ethyl-pyridine
methyl naphthalene
methyl palaitate
r.ethyl phenyl carbinol
methyl stearate
naphthalene
nonane
octane
octyl chloride
pentane
phenyl benzoate
phthalic anhydride
propylbenzene
1-terpineol
toluene
vinyl benzene
xvlene
l-A-41
-------
Table A-2 Persistence (Bioce^radabilicy) of Some Organic Ccrspoun;
(Continued)
I
LEVEL 0: XCd'PERSISTEST CCCIPCUXDS
acetaldehyde
acetic acid
acetone
acetophenone
j benzoic acid
j di-isobutyl carbinol
docosane
eicosane
ethanol
ethylaraine
hexadecane
methanol
methyl benzoate
3-^ethyl butanol
methyl ethyl ketone
2-raethylpropanol
octadecane
pentadecane
pentanol
propanol
propylanine
tetradecane
n-tricecane
n-undecane
l-A-42
-------
B
-------
HAZARDOUS WASTE
1. OBJECTIVES
A. To present federal definitions of solid wastes and hazardous
wastes.
B. To develop an awareness of existing and potential hazards
posed by wastes on a hazardous waste site.
2. SOLID WASTE (40 CFR 261.2)
A. The term "solid" is not to be construed as reference to a
physical state. The waste may be a "solid, liquid, semi-
solid, or contained gaseous material."
The sources of the waste may include "industrial, commercial,
mining, or agricultural operations or community activities."
This encompasses the industrial sector as well as the public
which may utilize pesticides, insecticides, drain cleaners,
solvents, etc.
C. Something must be done with this waste.
1) Discarded or abandoned waste is defined as any of the
following:
a) Discharged wastes may be directed to lagoons, holding
ponds, etc.
1-B-l
-------
b) Deposited wastes may be placed in an orderly fashion
in an assigned area.
c) Deep-well injection may be used.
d) Wastes are sometimes spilled, whether accidentally or
intentionally onto the ground or into sewer lines,
storm drains, catch basins, trenches, etc.
e) Storage containers, either because of lack of
integrity or faulty connections, may release waste
over periods of time into the air, surface water, or
groundwater.
2) The waste may be burned or incinerated.
3) The waste may undergo treatment.
a. Physical. Other than burning or incineration, the
waste may be encapsulated, containerized, solidified,
etc.
b. Chemical. This treatment may involve reactions, u.v.
photolysis, structural changes, etc.
l-B-2
-------
c) Biological. Mutant organisms are currently employed
either in lieu of or prior to disposal.
4) The waste may also be collected at transfer facilities
where compatible wastes are accumulated in bulk storage
tanks prior to treatment and/or transport.
5) The wastes may also be stored because of lack of treatment
and/or disposal facilities, supplies exceeding capabil-
ities of treatment/destruction (Chemical Control-
Elizabeth, N.J.), or economics.
3. HAZARDOUS WASTE (40 CFR 261.3)
There are certain criteria that must be met for a solid waste
to be classifed as a hazardous waste.
A. Solid Waste. The waste must first be classified as a solid
waste(not covered by exemptions).
B. Preclassifed Wastes.
1) Specific Types/Sources
a) Inorganic pigments (chrome yellow, orange, molybdate
orange, zinc yellow, iron blue) and waste waters
treatment sludge present toxicological problems via
leaching, fugitive emissions, etc.
b) Organic chemicals. These are products or byproducts
found in still bottoms, residues, stripping processes,
etc. Wastes of this nature were identified in Aurora,
Mo. (dioxin-contaminated still bottoms).
l-B-3
-------
c) Pesticides. These toxic compounds may contain highly
toxic contaminants from their manufacture. Therefore,
process wastes streams are classified. An example is
the Vertac site in Arkansas.
d) Leather tanning industry. Many toxic organic
(benzene, toluene)andInorganic (chrome, mercury)
compounds are employed in the process.
2) Nonspecific Sources
a) Degreasing operations. The spent halogenated sol-
vents, still bottoms from recovery, and sludges from
these operations contain: methylene chloride, carbon
tetrachloride, 1,1,1-trichloroethane, chlorinated
fluorocarbons. These wastes are found in metal
processing industries and airports. Military install-
ations have experienced groundwater contamination
problems (New Hampshire).
b) Electroplating operations. These employ degreasing
solutions,acid baths(metals), caustic baths (soaps),
and cyanide baths. Waste sludges may contain high
levels of heavy elements such as cadmium, lead,
selenium, etc. Air emissions and groundwater contam-
ination are frequent concerns.
c) Metal heat treating process. The salt bath pot
cleanings and treatment sludges may contain high
concentrations of contaminants.
3. Discarded commercial chemical products, off-specification
species, containers and spill residues are also considered
l-B-4
-------
hazardous waste. Included in this definition are all
chemical intermediates for the products as generically
identified by EPA.
a) Drums or their liners may contain sufficient quant-
ities of waste to pose a hazard to the field team--
especially those containers with sharp or jagged edges
which may inflict wounds and thus provide access for
wastes.
b) Tank trailers, bulk storage tanks, and pond liners may
be considered in this area.
4) Any solid waste generated from the treatment, storage, or
disposal of hazardous wastes is considered hazardous.
This may involve leachate, contaminated soil, clothing,
equipment, vehicles, etc. Conceivably, field clothing may
be declared hazardous waste if discarded.
a) During investigations, clothing, equipment, sample
containers will have to be discarded as hazardous
waste or decontaminated.
b) Decontamination solutions are then classified as haz-
ardous waste.
5) Waste Exhibiting the Characteristics of a Hazardous
Waste.
l-B-5
-------
4. CHARACTERISTICS OF HAZARDOUS WASTES (40 CFR 261.2)
A. Ignitability (40 CFR 261.21)
1) Aqueous solutions containing 24% or greater alcohol by
volume. Although these materials may flash without sus-
taining combustion, they may be the ignition sources for
other wastes (e.g., alcoholic beverages and latex paints).
2) Liquids other than an aqueous solution containing less
than 24% by volume and a closed cup flash point less than
140°F. These wastes would be covered by NFPA classes I
and II (e.g.,.xylene, toluene).
3) A thermally unstable non-liquid solid which, under
standard temperature and pressure, is capable of causing
fire through friction, absorption of moisture, or
spontaneous chemical changes.
4) Ignitable compressed gas (49 CFR 173.3). The gases may be
classifed by their absolute pressures, absolute vapor
pressures (for flammable liquids) and defined test
methods.
5) Oxidizer (49 CFR 173.151). An oxidizer is a substance
such as chlorate, permanganate, inorganic peroxide, or
nitrate that yields oxygen readily to stimulate the com-
bustion of organic matter.
l-B-6
-------
Corrosivity (40 CFR 261.22). Two barometers have been chosen
Co define this characteristic: pH and corrosion rate. EPA
has concluded that the great majority of wastes are presumed
to be liquid or semi-liquid, and therefore there is no need to
address corrosive solids. This view does not preclude the
existence of these solids.
1) pH. An aqueous waste having a pH less than or equal to 2
or greater than or equal to 12.5 is considered hazardous
based upon the potential for damage to human tissue, the
tendancy to promote solubilization of heavy metals, and
the tendancy to promote harmful reaction. These ranges
indicate acids or bases.
2) Corrosion rate. Measures the capacity of a waste to cor-
rode(steel)at given rates.
C. Reactivity (40 CFR 261.23). These wastes are extremely un-
stable, have a tendancy to react violently or explode, and
liberate toxic fumes.
1) Reactions with water. This is not only concerned with the
actual violent reaction, but the formation of potentially
explosive mixtures and those products of the reaction such
as toxic gases, vapors, or fumes.
a) Metal anhydrides liberate heat and hydrogen in the
presence of moisture and thus the potential for fire.
These conditions existed at a site in Coventry, RI
where some 17 drums of sodium aluminum anhydride stored
in benzene/toluene were discovered.
b) Pure metals such as sodium and potassium may react
violently with water.
l-B-7
-------
2) Detonation and/or explosion. This covers those wastes
which will detonate or explode with or without an intiat-
ing force. Also included are: forbidden explosives (49
CFR 173.51), Class A explosives (49 CFR 173.53) or Class B
explosives (49 CFR 173.88)
D) EP Toxicity. The Extraction Procedure (EP) is designed to
identify wastes likely to leach hazardous concentrations of
particularly toxic constituents into the groundwater under
conditions of mismanagement. The scenario involved co-dis-
posal of toxic wastes in an actively decomposing municipal
landfill. Extract is analyzed for those toxic contaminants
identified in the National Primary Drinking Water Standards.
This test should not be construed as a direct method of
measuring toxicity—such as biological testing.
l-B-8
-------
-------
TOXICOLOGY
1. OBJECTIVE
The objective of Che toxicology lectures is to provide a basic
understanding of the interactions of chemical substances with
the human body and to teach the basic principles and termin-
ology of toxicology. In addition, the objective is to relate
these principles and concepts to field investigations of haz-
ardous waste sites.
2. PRINCIPLES AND CONCEPTS OF TOXICOLOGY
A. Acute Toxicity
B. Delayed Toxicity
C. Chronic Toxicity
D. Dose-Response Realtionships
3. CHEMICAL-INDUCED DISEASES
NOTE: See Appendix A for a detailed discussion of Toxicology
1-C-l
-------
A. Target Organs
B. Mechanisms
C. Carcinogenicity
D. Mutagenicity
E. Teratogenicity
4. ENTRY OF CHEMICALS INTO THE BODY
A. Absorption
B. Biotransformation
C. Excretion
l-C-2
-------
5. COMPARATIVE TOXICOLOGY
6. CHEMICAL TOXINS
A. Corrosive/Caustics
B. Metals
C. Chlorinated Hydrocarbons
D. Hydrocarbons
E. Aldehydes
F. Alcohols
G. Nitrogen-Containing Compounds
l-C-3
-------
H. Gases
I. Airborne Particles
7. HEALTH HAZARD ASSESSMENT
A. Toxicity Testing
B. Toxicity Data Management
C. Risk Analysis
8. HAZARDOUS SUBSTANCE CLASSIFICATION
l-C-4
-------
ALL SUBSTANCES ARE POISONS; THERE IS NONE WHICH
IS NOT A POISON. THE RIGHT DOSE DIFFERENTIATES
A POISON AND A REMEDY.
PARACELSUS
(1493-1541)
l-C-5
-------
DEFINITIONS
DOSE - THE AMOUNT ADMINISTERED
WEIGHT/UNIT BODY WEIGHT, MG/KG
RESPONSE - ANY GIVEN OBSERVATION
BIOLOGICAL VARIATION
AVERAGE RESPONSE
HYPOSENSITIVE HYPERSENSITIVE
IDIOSYNCRASY
ABNORMAL TYPE OF RESPONSE
o*
s
l-C-6
-------
k.
THRESHOLD
A DOSE LEVEL BELOW WHICH AN EFFECT OF A GIVEN AGENT
IS NOT DETECTABLE
PHYSIOLOGICAL VSTOXICOLOGICAL EFFECTS
ONE-MOLECULE THEORY
DEFENCE MECHANISMS
MARGIN OF SAFETY
NO-ADVERSE-EFFECT DOSE LEVEL IN ANIMALS
HUMAN EXPOSURE LEVEL
HOW MUCH IS'ADEQUATE?
10.100.500.1000. ETC.
l-C-7
-------
100
M
C
UJ
Q
I
til
CC
50
UJ
o
CC
ED50
LOG DOSE
l-C-8
-------
NUMBER OF
INDIVIDUALS
MAJORITY OF
INDIVIDUALS
AVERAGE EFFECT
RESISTANT
INDIVIDUALS
LITTLE
EFFECT
SENSITIVE
INDIVIDUALS
GREAT EFFECT
AVERAGE EFFECT OF DOSE
INCREASING
DEGREE OF RESPONSE
TO SAME DOSE
l-C-9
-------
GENERAL RESPONSES OF BODY TISSUES TO AN INSULT
• DEGENERATION
• NECROSIS
• INFLAMMATION
• ATROPHY
• HYPOPLASIA
• HYPERTROPHY
• HYPERPLASIA
• METAPLASIA
• NEOPLASIA
**
l-C-10
-------
CARCINOGENICITY - INDUCTION OF MALIGNANT NEOPLASMS
NEOPLASM - "NEW GROWTH" OF TISSUE
TUMOR - ANY SWELLING; NEOPLASM
BENIGN NEOPLASM - LOCALIZED, DOESN'T SPREAD
MALIGNANT NEOPLASM - EXTENDS OR SPREADS
(METASTASIS)
ONCOGEN -AGENT INDUCES EITHER BENIGN OR MALIGNANT
NEOPLASMS
l-C-ll
-------
THE "ALARM WORDS" OF TOXICOLOGY
CARCINOGENICITY
MUTAGENICITY TERATOGENICITY
l-C-12
-------
CARCINOGENESIS (NEOPLASIA)
A CARCINOGEN IS A SUBSTANCE THAT CAUSES AN INCREASED INCIDENCE OF MALIGNANT
TUMORS IN EXPERIMENTAL ANIMALS AS COMPARED WITH A CONTROL SERIES OF UN-
TREATED ANIMALS.
l-C-13
-------
TERATOLOGY
THE STUDY OF THE TOXIC EFFECT OF PHYSICAL. CHEMICAL. AND
INFECTIOUS AGENTS ON THE DEVELOPING EMBRYO AND FETUS.
l-C-14
-------
TERATOGENIC SUSCEPTIBILITY IS GREATEST DURING EARLY ORGANOGENESIS
FUNCTIONAL MATURATION-
EMBRYONIC PERIOD
FETAL PERIOD
ENTIRE DEVELOPMENTAL SPAN
\
l-C-15
-------
INTERRELATIONS BETWEEN
TERATOGEN1CITY MUTAGENICJTY CARCINOGENICITY
1. INSIDIOUS NATURE
(CAUSE IS MILD
RELATIVE TO THE
EFFECT)
2. DURATION & TIME
BETWEEN CAUSE &
EFFECT
3. IRREVERSIBLE
4. GREATER SUSCEPTI-
BILITY OF IMMATURE
TISSUES
5. DIFFERENCES
YES
WEEKS
YES
YES
ALTERED DEVELOP-
MENT AT TISSUE/
ORGAN LEVEL
YES
GENERATIONS
YES
NO
ALTERED NUCLEO-
T1DE SEQUENCE -
MOLECULAR
LEVEL; ON A
YES .
YEARS
YES
YES/NO
UNCONTROLLED
PROLIFERATION
AT CELLULAR
LEVEL
l-C-16
-------
MUTATION
CELL DEATH
LIVING CELL WITH ALTERED
GENETIC FUNCTION
SOMATIC
GERMINAL
NONCANCEROUS CANCER TERATOGENIC
INHERITED MUTATION
I
GENETIC DEFECTS
IMPERCEPTIBLE
INCONSEQUENTIAL
LETHAL
\
l-C-17
-------
ANTICIPATED EFFECTS OF MUTAGENS IN HUMANS
• INCREASED FETAL WASTAGE
ABOUT 33% OF ALL PREGNANCIES ARE ABORTED
ABOUT 50-75% OF THESE HAVE CHROMOSOMAL
ABNORMALITIES
• MENTAL RETARDATION
• INCREASED SUSCEPTIBILITY TO DISEASE
\
l-C-18
-------
EXTENT OF GENETIC "DISEASE" PROBLEM (U.S.)
• 35-40% OP SPONTANEOUS ABORTIONS ARE CAUSED BY GROSS
CHROMOSOMAL EPPECTS
• 40% OF INFANT MORTALITY RESULTS FROM GENETIC FACTORS
• GENETIC DEFECTS ARE PRESENT IN ABOUT 5% OF ALL LIVE
BIRTHS
• ABOUT 80% OF MENTAL RETARDATION IS GENETIC
• ABOUT ONE-THIRD OF ADMISSIONS TO PEDIATRIC WARDS ARE
FOR GENETIC REASONS
• EACH NEW BIRTH HAS A 3% RISK OF BEING GENETICALLY
DEFECTIVE
• ABOUT 2000 IDENTIFIABLE GENETIC DISEASES
u1
l-C-19
-------
CHEMICALS KNOWN TO BE MUTAGENIC IN HUMANS
l-C-20
& a^k -^
-------
CHRONOLOGY OF TESTING
EARLY ACUTE TOX - HANDLING HAZARDS
1ST SCREEN - MUTAGEN/CARC1NOGEN
SUBCHRONIC TOX - TARGET ORGAN, TOXIC DOSE - RODENT
BIRTH DEFECTS - TERATOLOGY
2ND LEVEL SCREEN - MUTAGEN/CARCINOGEN
A8SOR8./DIST./METAB./EXCRETION - LAB ANIMALS
(METABOLISM/PHARMACOKINET1CS)
SUBCHRONIC TOX - NON-RODENT SPECIES
REPRODUCTION STUDY
BEHAVIORAL TESTS
SYNERGISM/POTENTIATION
RESIDUE EVALUATION
LONG-TERM STUDIES - CARCINOGENESIS - RODENTS
DEFINITIVE TEST FOR MUTAGENESIS - RODENTS
METABOLISM/PHARMACOKINETICS - HUMANS
LATE EPIDEMIOLOGY
\
01
•J
r
l-C-21
-------
YEARS
2ND STAGE MUT/CARCIN '
REPRODUCTION-
3RD STAGE MUTAGENESIS-
LDSO. LC50. DERMAL & EYE IRRITAT ION
1ST STAGE MUT/CARCIN TESTS
SKIN SENSITIVITY
j 90-OAY STUDY - RATS. MICE
-META8OLISM/PHARMACOKINETICS - ANIMALS
-TERATOLOGY
-90-180-OAY STUDY - DOGS OR MONKEYS
-4—CHRONIC TOX. CARCINOGENESIS
RATS. MICE
l-C-22
-------
LEVELS OF SOPHISTICATION
TOXICOLOGISTS ANALYTICAL CHEMISTS
COUNT # DEAD PERCENT
GROSS ORGAN CHANGES PPM
LIGHT MICROSCOPY, PPB
BIOCHEMICAL CHANGES
PPT
ELECTRON MICROSCOPY,
MOLECULAR CHANGES PP?
AT WHAT LEVEL IS IT NO LONGER IMPORTANT*
"NORMAL" PHYSIOLOGICAL ADAPTATION TOXICITY
l-C-23
-------
BENEFICIAL
HARMFUL
USE OF THE ALARM WORDS
IGNORE
OVEREMPHASIS
l-C-24
-------
D
-------
FIELD OPERATIONS - CONSIDERATIONS/STRATEGIES
1. INTRODUCTION
A. Objective. To present an overview of the field investigation
operation and to give in some detail, the procedures and
equipment used by a field team.
1) Scope of Effort. To conduct investigations of abandoned
and uncontrolled hazardous waste sites.
2) EPA Series 2070 Form Review*
a) 2070-8 Potential HWS Identification
Used upon notification by any means of any suspected
hazardous waste site (HWS)
b) 2070-1 Potential HWS Log
Use continues throughout duration of investigation;
all following forms serve to augment
c) 2070-2 Preliminary Assessment
Use to consolidate initial data, correspondence, site
visits and previous sampling data.
*See page l-D-14 for copies of EPA forms
1-D-l
-------
d) 2070-3 Site Inspection
Use tends to vary with regions; some used for any site
visit, including windshield inspection. Other regions
use only for actual on-site work, including sampling.
e) 2070-4 Tentative Disposition
Usedto makeinitial assessment of further action re-
quired, can be used to direct full field investiga-
tion
f) 2070-5 Final Strategy Determination
Used to directfinal effortsin case; can lead to en-
forcement action, remedial action or no further
action. Closes out 2070-1.
B. Phases of the Field Investigation
1) Identification Phase
Site discovery comes from a number of sources such as,
public complaints, state investigations and the EPIC.
Minimal effort is currently been spent in this phase due
to the backlog of existing sites.
2) Preliminary Assessment Phase
Includes all actions up to and including site visit. Data
sources include aerial photos, historical records, conver-
sations with other agencies at all levels, and literature
search. Some sites may be eliminated based on this work;
other sites may be declared emergencies; most sites will
require a site visit.
3) Inspection Phase
Sometimes combined as part of preliminary assessment
phase, but most often not. Can range from windshield in-
spection to walk through to full field investigation to
environmental sampling only.
l-D-2
-------
4) Full Field Investigation
Discussed separately because of risks and effort involved.
Often requires sampling of hazardous waste, to include
opening of closed containers.
5) Closed Out Phase
Involves final action on case. Constitutes major portion
of work in some regions, especially serving as expert wit-
ness and technical support during case development plan.
2. SITE INSPECTION STRATEGY DEVELOPMENT
A. Data Collection to Assess Magnitude of Problem
1) Environmental Sampling
2) Mapping, Photography
a) EPIC
b) Enviropod
c) Soil Conservation Service
d) Handheld photos from light plane.
e) Flood Insurance Studies Photos
f) Mapping can be accomplished by sketch maps, by updat-
ing of Mylar overlay transfer of topographic maps, or
by actual third-order mapping done from photos.
l-D-3
-------
3) Data Assessment
Best accomplished using a small number of specialists re-
porting to a chief analyst. One approach to the analysis
needed for complete data assessment is through the use of
a modified Delphi Board. Alternatively, each specialist
can be asked to review the assessments given by the other
team members. The validity of the assessment is affected
by the amount, type and reliability of data gathered. One
prime factor to be included in data assessment is the
political situation. In some cases, consideration of pub-
lic opinion may lead to further investigations that may
not be justified by the data.
B. Site Disposition. Data assessment is an ongoing process that
results in the ultimate judgement affecting the disposition of
the site. Deciding what course of action to take regarding a
site is an EPA decision that involves all sections:
1) No Action
2) Enforcement Action
a) Case Development
b) Expert witness
3) Remedial Action
4) Further Investigation
l-D-4
-------
3. FULL FIELD INVESTIGATION
A. Definition. The full field investigation involves a total
commitment of personnel and equipment in order to adequately
define the hazards associated with a site. The investigation
usually involves sampling of hazardous waste, and definitely
involves exposure of the team members to a hazardous environ-
ment.
B. Procedures.
1) Site Safety Plan.
2) Site Sampling Plan.
3) Site Safety Considerations and PDS Operation.
C. Methods and Equipment. The equipment used to identify the
hazards associated with a site, and to protect the team mem-
bers from those hazards.
l-D-5
-------
TABLE 1
Government Contacts
1. EPA Regional Office
a. Solid Waste
b. Toxic Substances
c. Water Supply
d. Water Qua!i ty
e. Air Resources
f. Radiation
g. Enforcement
2. Federal EPA Offices
a. National Enforcement Investigation Center (NEIC),
Denver, Colorado
b. Environmental Monitoring System Laboratory
(EMSL), Las Vegas, Nevada
c. Environmental Photograpnic Interpretation Center (EPIC),
Warrenton, Virginia
3. US Geological Survey
a. National Cartographic Information Center, Reston,
Virginia
b. Distribution Branch, Arlington, Virginia
4. US Department of Agriculture
a. Soil Conservation Service
b. Agricultural Extension Service
5. US Department of Interior
a. Bureau of Recreation
b. Fish and Wildlife Bureau
6. State Offices
a. Solid Wastes
b. Water Supply
c. Water Quality
d. Air Resources
e. Highway Department
g. Enforcement
l-D-6
-------
TABLE 1 (continued)
7. Local Offices
a. Town Clerk's office
b. Town Selectman's office
c. Local tax or properly assessment office
d. Local zoning board
e. Local/regional planning board
f. Local polfee and fire departments
l-D-7
-------
TA3LE 2
Environmental 3=:a
1. Geology
Information
a. Local bedding type
b. Thickness of strata
c. Bedding planes
d. Solution channels
e. Fracture zones
f. Depth to bedrock
g. Geologic anomolies
h. Bedrock outcrops
Source
a. US Geological Survey Maps
b. US Geological Survey reports and files
c. Soil Conservation Service
d. State Geological Survey
e. Local university geology or engineering.departments
f. Local well driller logs
2. Soils and Overburden
Information
a. Soil type
b. Soil texture
c. Soil chemistry
d. Permeability
e. Depth
f. Erosion potential
g. Presence of clays
Source
a. US Geological Survey
b. Soil Conservation Service
c. Agricultural Extension Service
d. State geologic survey
e. Local university
f. Local well drillers
g. Local construction company
l-D-8
-------
TABLE 2 (continued)
3. Flora ana Fauna
Information
a. Soecies type
b. Sensitivity
c. Presence of endangered species
d. Presence of indicator species
Source
a. Department of Interior - Office of Endangered Species, Fish and
Wildlife Bureau
b. State wildlife office
c. State Museum of Natural History
d. State Botanical Society
e. USDA Extension Service
f. Local wildlife and botanical groups
g. State/local field guides
h. Local university botany/zoology department
a. Climate and Air Resources
Information
a. Precipitation
b. Evaporation
c. Evapotransoiration
d. Mass-balance
e. Flooding history or potential
f. Air quality
g. Wind patterns
h. Wind velocity
i. Inversion potential
j. Air basis delineation
Source
a. National Climatic Center
b. State meteorological bureau
c. Local weather bureau
d. Local university
e. Local airports
f. Local companies/utilities
g. State Bureau of Air Resources
l-D-9
-------
TABLE 2 (continued)
5. Geohydrology
Information
a. Depth of water table
b. Aquifer type
c. Characteristics of confining layers
d. Piezomettic data
e. Director of flow
f. Presence of perched aquifer
g. Interchange with surface water
h. Extent of drainage basis
i. Background groundwater quality
j. Depth of local wells
k. Pumping rates
1. Local water use
Source
a. US Geological Survey
b. State Geological Survey
c. State Water'Ouality Office
d. State Water Supply Office
a. Local universities
f. Local well drillers
g. Local water resource boards
h. State/local planning board
6. Surface Water
Information
a. Location of surface waters
b. Location of dry stream beds
c. Surface gradients
d. Stream flow rates
e. Surface water quality
f. Surface water uses
g. NPDES permit
Source
a. US Geological Survey
b. State Geological Survey
c. State Water Quality Office
d. State Department of Recreation
e. State Department of Fisheries
f. Local universities
g. Local water resource boards
h. State/local planning board
l-D-10
-------
TA3L5 2 (continued)
7. Sensitive Environments
Information
a. Floodplains
b. Wetlands
c. Sole source aquifer recharge zone
d. Karst topography
e. Fault zone
f. Potential for long-term disruption
g. Special designation
Source
a. Department of Housing and Urban Development
b. Department of Fish and Wildlife
c. US Geological Survey
d. State Geological Survey
e. State Department of Water Resources
f. Department of Recreation
g. Nature Conservancy
h. State/local planning office
i. Local university
1-D-ll
-------
Table 3
AERIAL PKOTCGRrPHS
Inrorrnanon*
Investigative Parameters Logis- Invest!-
tical gation
Safety Suoport Design
SITE DISCOVERY AND IDENTIFICATION
Geographic Location (County Roads, Lat./ a a
Long.)
Boundaries/Property Lines a
Area/Dimensions a
Surrounding Land Use a
Accessibility a a
Ownership/Management c
ENVIRONMENTAL FEATURES AND CHARACTERISTICS
OF THE SITE
Type a
Population Density/Proximity/At Risk a
Structures a
Utilities/Easements
Environmentally Sensitive Areas c
Topography a a
Flood Plain/Watershed Value c
WASTE TYPES AND QUANTITIES
Type and Quantity £ a
Source/Origins
Container Type and Condition
Waste Compatibility
Disposal Method/Organization a
Fire/Explosion Hazard
FIELD EVALUATION FACTORS
Soil or Groundwater Contamination a
Potential
Surface Water Contamination Potential a
Gradient/Erosion/Orainage Patterns a
Ponding/Water Courses a
Vegetation/Wildlife Stress Potential
Evidence of Charred Areas or Source
Existing Containment Structures c
Evidence of Leakage or Overflow c
Meteorology/Climate/Prevailing Winds c c
Air Emissions
Odors
On or Near Site Wells c c
Geologic Outcroppings/Soi1 Permeability
Land Alteration/Excavation a
l-D-12
-------
Table 3 Cont.)
inror-.at ion*
Investigative Parameters
Logis- Investi-
tical gation
Safety Support Design
INVESTIGATIVE/REMEDIAL ACTIVITIES
Perimeter/Exclusion Area Establisnment
Monitoring/Sampling (Air, Water, Soil)
Procedures (Safety, Operational)
Segregation Techniaues/"Housekeeping"
Containment/Diversion Structures
Traffic Control
Site Access/Control
Equipment (Safety, Hygiene)
Earth-Moving Equipment
Communications/Power Availabi1ity
DOCUMENTATION
Photographs
Violation Documentation/Record Keeping
* a - Apparent
c - Clue, unconfirmed or deduced presence; observations requiring
further investigation
l-D-13
-------
PCTE/TIAf. HAZARDOUS WASTC SITS
INSTRUCTIONS FOR PREPAOItC SITC TRACXKC FOPMS
(EPA Fora 2070-1, 2, 3, 4, 5, & 6)
The following six rajor forr\s and six supplen-entai forr-s are used for
tracking potential hazardous waste sices:
FO?.M. TITLE
ICEOTIFICATICN AND PRELIM-
INARY ASSESSMENT
(EPA Fora 2070-2)
SITS INSPECTION REPORT
(EPA 5OSM 2070-3)
TENTATIVE DISPOSITION
(EPA Forn 207C-4)
FINAL STRATEGY CSTE?
(EPA Fern 207C-5)
LCG
(EPA Fcm 2070-1)
REMARKS
Prepare for each known or suspected site, no
natter hew identified. Scurcas of Lcentifica-
ticn include citizen's ccnTpir.ints, nev;s media,
state files, ecc.
JS.H1. out. for eacn. site .which has_recsived_a.
site inspection. There are five preprinted
supple-Tencal reports associated with this
form:
Storace (EPA Fcrr. 2070-3D)
Incir.eracors (EPA Forsi 2070-33)
Landfills (EPA ?ona 207C-2E)
Surface Iirpcundmer.uS (EPA Form 2070-3C)
Lancfanrs "(EPA Form 207C-3A)
c'O'IaF'ahcal infcrrs-icn fcr deep well
injectors, trarspc—crs , recyclars/reciai-Tars,
chemical, physical, or biological treansrs,
or open dunr:s should also ca =u -icted -=s
appropriate.
rill cut as socn as the results of a si-e
inspacticn are a
Fill cut as scon as a cour.--* of action is
csterTii.-.ed as a result of tr.a Tentative
Disposition.
Update this cr.a pare SLI—ary with the !
-------
su.Tr-.arv Log foist be updated wut-n each c-.ancG o: the other focrs. At: a
minium, each known or potential site-must have a Prelj.nur.eicy Assess-
ment rom ar.d a Log fora filled out.
These forrrs have been designed by the Hazardous Waste Enforcement Task
Force ard the Oil and Special Macs rials Control Division with the assis-
tance of regional and contractor personnel . They -ay be rtxiified with
use. The Task Force welcomes suggest ions for sign if icant improvements to
the forrs and the instructions for preparing trie forns.
The information sunr.tt ted to the Hazardous Waste Enforcement Task Force
will be ccirpucerized. As soon as the information is entered into the
Site Tracking System, management reports will be available co the regions
and. to Headquarters. These -snagerent reports include sugary milestone
information as well as detailed sits reports.
These for^s have been designed to be self-explanatory as rnucn as possible.
If there are clarifications needed on the Corns or on the instructions,
call the Task Force at (202) 472-3620.
GEMEPAL INSTRUCTIONS FOR ALL rC?^S
Where information is unavailable for any part o£ any com, indicate that
tr.e inforracicn is urjcr.cwn or ncc applicable. ^~r.ar5_ sore infcrraticn is
krkc~Ti, -a:-;e the bast sstins-ss pcssisle.
Consult the following sources for information on the fields belcw:
DATA FIZZJ SCUfeeS" OF" IMPOSS-IVTICN
Site Nu.T.ber Dun and Brsdstreet idsntifiers vill be
assicr.ed at Headquarters. Eacr. site must
have a unique nace, strsec, and city to
receive a D i 3 ru-Tcer.
Ccur.ry Nare State Highway Maps.
Owner Tcwn or Councy Lard Records.
SIC Cedes Tne Standard Industrial Classif i'catis:i
Manual puolished by the C.'-3.
Waste Characteristics Proposed RC?A Rec^latior^. See Secticr. 3C01
for definitions.
Latifjca/Lcr.cituce U.S.G.S. Tcpograpr, ical Maps.
Wa,t2r/Hvcro logical Data Corsult the local 2G3 Agency, TCWTT Health
or Zcr.irg Scares, U.S. Geological Surveys,
Corzs c£ £r.= i.-.=er3, CS^A So;.! Corsar/stion
Services, u!s. ?isn a '.iiiclife Serr/ica , H-J3
Flood :»ass, State ard I?A fiias, etc.
PACE 2 CF 5
-------
TPL'CTi'.Tis PC?. THE ICC.TIF:G\TIC-N /::o pp£L£:-'i:/u<^
FGHM (2Q70-2)
PAGE L
I.A Site Nanc
1.3 Street
I.I Sits Description
III.C Area of Site
PAGE 2
IV. Characterization of
Site Activity
PAGE 3
V. Hazard inscription
PAGE 4
Use a company nane, mjnicipal site name, or
a geographic name as appropriate. Be sure
to use the same spelling and aboreviaticr.s
on all subsequent forrs.
If no street name and nusrber is available,
give other geographic information to insure
positive identification. If one ccrapany
has several .sites in one city, this field is
critical.
Provide a generic description of the site,
e.g. landfill with 1000 druns of unidentified
content.
Estimate. Use ceciirals if needed.
Leave olank if unkr.c-*Ti. Cheese as many as
applicable.
Check off as many iteirs as are applicable.
Indicate specific caras of alleged incidents
wherev r ccssiale.
VI11. ?ast Regulator/ Actiors List all 'c-.o-v-n orders, fines, etc. frcn 5?A
and State files.
IHSTFUCTICrS ?OR TKS SITS INSPSCTIQ! REPOPT PCSTl (2070-3)
PAGE 2
III.D Ger.eratcr Info era ticn Sxanir.e operator's recorcs, markircs on
dr^.T3, etc. Inter/iew era levees, past and
present, res idents, e tc.
II I. J Weacr.er
Note prcblsns v,hich ray not be evident
because of axtrera cold, sncw ccverirc, etc.
PACC 3 Cf 6
l-D-16
-------
PAGE 3
IV. £ Latitude/Longitude
Use the coordinates of the approximate
center o£ the site.
PAGE 4
VI1.0 Substances of
Greatest Concern
VTI.D.3S4 Toxicity and CAS
Nuneer
PAGE 3
IX.C Acorcxi.Tate Nurcer
of People Affected
- Witr.in Unit Area
IX.A.3 Publicly Travellec
Areas
X.A Deotn to Gccundwater
X.3 Direction of Flew
X.C Grour.dwater Use in
Vicinity
X.D Poter.tial Yield of
Aquifer
PAGE 10
XIII. Soil Permeability
Use Trace Marres or the most corr.-nn chemical
names of these sucsta.-.ces wnicr. are of the
greatest concern on the site. (This is
net intended to be a ccralete listing of
all substances found on the site).
Consult Table 26, Physical, Chemical Hazard,
and Analytical Data of Industrial Chemicals,
CHC Hancacok of Analytical Toxicology.
Generally a 1 mile radius is the apprcpriat
unit area.
Estimate nurroer of pecple exposed per cay.
Interview local residents, well.driller,
USG3, etc.
Exa.-.ir.e tccograpny.
Drinking water, process water, irrigation,
etc.
Corsult the USC-3 for an accroxirata value
in callers/day.
3. Very high - clear gravel, caverr.ous
li-.astcne, colccita.
C. High - clear sane, sandstone, fractured
igr.ecus and Tetanorsr.ic rcclcs.
D. Moderate - fine sand.
E. Lew - silt, clay, la-T.i.-.atsd sarc's—r.e,
snile, .Tuds—ne.
?. Ver/ lew - trassive clay, nassive igr.ecus
arc Tetarorcnic rcc'-cs.
PACE -J C" 6
l-D-17
-------
iN3T?.-cr:cc:s TOR IV:E SITE INSPECTION REPORT (2070-3) (Continued)
Xiri.G Recharge Area
XIII.H Discharge Area
PAGE 10
XIV. Pecait Information
XV. Past Regulatory oc
Enforcement Actions
Generally uplands.
Generally valleys.
Consult state, local, and EPA files.
Consult state, local, and EPA files.
iMS7?rcr:ctis =OR TE.TATIVE
FORi-S (2070-4&5)
KEY WC?£S
for Remedial Actions
(use these terrs in
cctrpleting forris)
IV.A.I SHORT TE?M ACTION
Water Supply Closed
Provide Terra Wtr Sup
Provide Pern Wtr Sup
Evacuate Area
Rstrt Access to Site
Ernrg Dkg/Surf Wtr Dv
Rerove Spilld Matrl
Repackage Wastes
Repair 3uJJc Tankage
Remove Wastes
Waste Disposal
Gas Control
Fire Control
Sucsurf Cutoff Wall
ESverg Wste Treatrent
IV.3.1 LCC5G TEK-1 ACTIONS
Analytical Support
C-eonycrolcgLc Sur/ay
Oti-.er Er.virr.tl Srr/
Er.gi.-.eering Reports
Repackaging
Renoval of v/astes
DISPOSITION AND FINAL STPATEGY CETEFMIMATICN
Full description of Key Words
Provide Temporary Water Supply
Provide Permanent via tar Supply
Restrict Access to Si-e
Emergency Diking/Surface Water Diversion
Spilled Material
Subsurface Cutoff Wall
Eirergenc/ Was we Treatrenc
Otl".er Er.viror.Ter.tai Sur/avs
Divers ion S tructures/Recrad:re
PAGE 5 OF 5
l-D-13
-------
WORCS =X}S LC.NJG T=:?M ACTCCriS
In-situ Cr.em Trt-Tr.::
In-situ 3io Tr-~nc
^n-sicu ?hys Trtrnc,
EncapsuLatiun
Cn-sice Cncinerncion
disposa
td Soil DLSpsL
ncir.c/Gas Ccr.troi
Cs.cc ir.c/Ccve rir.c
Cuta if "wails
Cutsff Trer.cr.ss/Sc.-^:
Gccuc Carrain
Bcttcrti 'Sealira
Barrier Wails
Chemical Fixation
Chemical Ir.jsciion
Leacr.aca Treacrap.c
p.itcrinq Weils
In-situ Chemical Treatrent
In-situ Bioiqccial Treatment
In-sicu Physical Treawent
Cor.tarrar.3tsd Soil Disccsal
PAGE 5 C? 5
l-D-19
-------
&EPA
POTENTIAL HAZARDOUS WASTE SITE IDENTIFICATION
REGION SITE NUMBER
NOTE: The initial identification of a potential site or incident should not be interpreted as a finding of illegal
activity or confirmation that an actual health or environmental threat exists. All identified sites will
be assessed under the EPA's Hazardous Waste Site Enforcement and Response System to determine if
a hazardous waste problem actually exists.
A. SITE NAME
C. CITY
9. STREET for other identifier)
O STATE
E ZIP CODE
F COUNTY NAME
OWNER/OPERATOR (it known)
I. NAME
I 2 TELEPHONE NUMUER
H. TYPE OF OWNERSHIP (il known)
Ql FEDERAL Q 2. STATE Q 3. COUNTY
4. MUNICIPAL
5. PRIVATE [~| 6. UNKNOWN
. SITE DESCRIPTION
J. HOW
IDENTIFIED (i.o.
, citizen's complaints.
OSHA citations, etc.;
(mu
TE IOEN
, day. It
TIFIEO
yr >
L. SUMMARY OF POTENTIAL OR KNOWN PROBLEM
M. PREPARER INFORMATION
1. NAME
2 TELEPHONE NUMBER
3 OA TE (mo., day, & yr )
E PA Form 2070-8 (5-80)
l-D-2.0
-------
^^ ^^ SITE NUMBER
WEF^\ POTENTIAL HAZARDOUS WASTE SITE LOG
NOTE: The initial identification of a potential site or incident should not be interpreted as a finding of illegal activity or confirm-
ation that an actual health or environmental threat exists. All identified sites will be assessed under the EPA's Hazardous
Waste Site Enforcement and Response System to determine if a hazardous waste problem actually exists.
CITY STATE ZIP CODE
SUMMARY OF POTENTIAL OR KNOWN PROBLEM
ITEM
1. IDENTIFICATION OP POTENTIAL PROBLEM
2. PRELIMINARY ASSESSMENT
APPARENT SERIOUSNESS OF PROBLEM
3. SITE INSPECTION
4 EPA TENTATIVE DISPOSITION
(check appropriate itom(t) below)
1 I a. NO ACTION NEEDED
! 1 b. INVESTIGATIVE ACTION NEEDEO
! I c. REMEDIAL ACTION NEEDED
1 I d. ENFORCEMENT ACTION NEEDED
- EPA FINAL STRATEGY DETERMINATION
9* (check appropriate !lem(ij belaur)
' I a. NO ACTION NEEDED
I j b. REMEDIAL ACTION NEEDED
n REMEDIAL ACTION NEEDED BUT.
c- NO RESOURCES AVAILABLE
| | d. ENFORCEMENT ACTION NEEDED
[~~| (1) CASE DEVELOPMENT PLAN PREPARED
n,,, ENFORCEMENT CASE FILED OR
lz' ADMINISTRATIVE ORDER ISSUED
6. STRATEGY COMPLETED
DATE OF
DETERMIN-
ATION OR
COMPLE-
TION
1 1 HIGH
w- ;"*j ~«*r""
e
•
'. -" X. '.V
-«
.
\
[ __
I
^ *
RESPONSIBLE ORGANIZATION
OR INDIVIDUAL
(EPA, Slate, Contractor, Other)
PERSON MAKING
ENTRY
TO LOG FORM
DATE
ENTERED
ON LOG
'010, day, yr)
I | MEDIUM I I LOW (~~| NONE I I UNKNOWN
'
r~ || TT'***3- 4QS£fc. *Sft . ->^»--|, y a^|
. — :
_^_ ^-«_ ««-~ — •»
' '' V '
L
— —
— —
EPA Form T2070-1 (R.I 2-79) PREVIOUS EDITION MAY BE USED
l-D-21
-------
POTENTIAL HAZARDOUS WASTE SITE
IDENTIFICATION AND PRELIMINARY ASSESSMENT
SITE NUMBER (to b*
a tared by HoJ
NOTE: This form is completed for each potential hazardous waste site to help set priorities for site inspection. The information
submitted on this form is based on available records and may be updated on subsequent forms as a result of additional inquiries
and on-aite inspections.
GENERAL INSTRUCTIONS: Complete Sections I and in through X as completely as possible before Section II (Preliminary
Assessment). File this form in the Regional Hazardous Waste Log File and submit a copy to- U.S. Environmental Protection
Agency; Site Tracking System; Hazardous Waste Enforcement Task Force (EN-33S); 401 M St., SW; Washington, DC 20460.
I. SITE IDENTIFICATION
A. SITE NAME
B. STREET (or other identifier)
C. CITY
O. STATE
E. ZIP CODE
f. COUNTY NAME
G. OWNER/OPERATOR (It known)
1. NAME
2. TELEPHONE NUMBER
H. TYPE OF OWNERSHIP
[ |l FEDERAL I 12. STATE I U COUNTY I 14. MUNICIPAL I 15. PRIVATE I \S. UNKNOWN
I. SITE DESCRIPTION
J. HOW IDENTIFIED (I.e., citizen's complaints. OSHA citations, ate.)
K. DATE IDENTIFIED
(mo., day, 6t yr.)
L. PRINCIPAL STATE CONTACT
1. NAME
2. TELEPHONE NUMBER
II. PRELIMINARY ASSESSMENT (complete, this section lest)
A. APPARENT SERIOUSNESS OF PROBLEM
1 |l. HIGH I 12. MEDIUM I 13 LOW | U NONE I U UNKNOWN
B. RECOMMENDATION
I I I. NO ACTION NEEDED (no hazard;
I I 3. SITE INSPECTION NEEDED
a. TENTATIVELY SCHEDULED FOR
b. WILL BE PERFORMED BY
I~H2. IMMEDIATE SITE INSPECTION NEEDED
a. TENTATIVELY SCHEDULED FOR
b. WILL BE PERFORMED BY
I I 4. SITE INSPECTION NEEDED (low priority)
C. PREPARER INFORMATION
1 . NAME
2. TELEPHONE NUMBER
3 DATE (mo., day. tt yr.)
III. SITE INFORMATION
A. SITE STATUS
I I 1. ACTIVE (Those industrial or
municipal aitea which are being used
for waste treatment, storage, or disposal
on a continuing basis, even if in fre-
quently,)
I I 2. INACTIVE
sites which no longer receive
wastes.)
(Th:
3. OTHER (specily)-
oae sites that include such incidents like "midnight dumping" where
no regular or continuing use of the site for waste disposal has occurred,)
B. IS GENERATOR ON SITE?
O 1. NO
I I 2. YES (specily generator's lour—digit SIC Code)
C. ARC A OF SITE (In acres)
O. IF APPARENT SERIOUSNESS OF SITE IS HIGH. SPECIFY COORDINATES
1. LATITUDE (dog.—mm.—sec.; 2. LONGITUDE (deg,— aim.—sec.)
E. ARE THERE BUILDINGS ON THE SITE'
CH I. NO I I 2. YES (specily)
T2070-2 (10-79)
l-D-22
Continue On Reverse
-------
Continued From Front
IV. CHARACTERIZATION OF SITE ACTIVITY
Indicate the major site activityfiesj and details relating to each activity by marking 'X' in the appropriate boxes.
A. TRANSPORTER
X
B. STORER
C. TREATER
X'
O. DISPOSER
I PILE
I . FILTRA TION
1. LANDFILL
2. SURFACE IMPOUNDMENT
2. INCINERATION
2. LANOFARM
3. BARGE
3 DRUMS
3. VOLUME REDUCTION
9. OPEN DUMP
4. TRUCK
4. TANK. ABOVE GROUND
4. RECYCLING/RECOVERY
4. SURFACE IMPOUNDMENT
5. PIPELINE
8. TANK. BELOW GROUND
0. CHEM./PHYS. TREATMENT
8. MIDNIGHT DUMPING
O. OTHER (specify)
e. OTHER (apeclfy).
«. BIOLOGICAL TREATMENT
«. INCINERATION
7. WASTE OIL REPROCESSING
J. UNDERGROUND INJECTION
8 SOLVENT RECOVERY
8. OTHER
9. OTHER (apecity):
E. SPECIFY DETAILS OF SITE ACTIVITIES AS NEEDED
V. WASTE RELATED INFORMATION
A. WASTE TYPE
Q7] 1 UNKNOWN I \Z. LIQUID
[~~|3 SOLID
[ 14. SLUDGE
IS. GAS
B. WASTE CHARACTERISTICS "~~~~
OZj1'- UNKNOWN Q2. CORROSIVE O3-'aNITABLE OI]*- RADIOACTIVE I l». HIGHLY VOLATILE
I Is. TOXIC ! |7 REACTIVE I Is INERT | \s. FLAMMABLE
033 10. OTHER (specify) ^
C. WASTE CATEGORIES
1 Are records of wastes available' Specify items auch a« mamtaati, mventona>, etc. below.
2. Estimate the amountfspecify unit at measurejof waste by category; mark 'X' to indicate which wastes are present.
a. SLUDGE
b. OIL
c. SOLVENTS
d. CHEMICALS
e. SOLIDS
(. OTHER
AMOUNT
AMC'INT
UNIT OF MEASURE
UNIT_OF-M6A3URE
UNIT OF MEASlTRE
UNIT OF MEASURE
UNIT OF MEASURE
UNIT OP MEASURE
(t) PAINT.
PIGMENTS
X1
•X1
WASTES
(I)HALOGENATED
SOLVENTS
•x
(II ACIDS
II) FLYASH
X1
,LABORATORY
' PHARMACEUT.
(2) METALS
SLUDGES
(2)OTHERfapeei/jr;-
(2) NON-H ALOGNTD
SOLVENTS
12IPICKLING
LIQUORS
121 ASBESTOS
(2IHO3PITAL
(3JCAUSTICS
13) MILLING/
MINE TAILINGS
(31 RADIOACTIVE
(4) ALUMINUM
SLUDGE
(41 PESTICIDES
,FERROUS
SMLTG. WASTES
(4IMUNICIPAL
I'"' OTHERfapac/fyJ
(BJOYES/INK3
(51
NON-FERROUS
SMLTG. WASTES
(8) OTHERfspac/fyJ:
(SI CYANIDE
(7) PHENOLS
(81 HALOGENS
(9) PCB
(10IMETALS
III) O THERfapecifyJ
EPA Form T2070-2 (10-79)
PAGE 2 OF 4
l-D-23
Continue On Page 3
-------
mttnued From Page 2
V. WASTE RELATED INFORMATION (continued)
3. LIST SUBSTANCES OF GREATEST CONCERN WHICH MAY BE ON THE SITE (place in descending order of hazard).
4. ADDITIONAL COMMENTS OR NARRATIVE DESCRIPTION OF SITUATION KNOWN OR REPORTED TO EXIST AT THE SITE.
VI. HAZARD DESCRIPTION
A. TYPE OF HAZARD
1 NO HAZARD
2 HUMAN HEALTH
, NON-WORKER
'• INJURY/EXPOSURE
4. WORKER INJURY
. CONTAMINATION
°' OF WATER SUPPLY
- CONTAMINATION
9 OF FOOD CHAIN
. CONTAMINATION
'• OF GROUND WATER
CONTAMINAT'ON
81 OF SURFACE WATER
. DAMAGE TO
FLORA/FAUNA
10. FISH KILL
, . CONTAMINATION
1 OF AIR
12. NOTICEABLE ODORS
IS. CONTAMINATION OF SOIL
14. PROPERTY DAMAGE
18. FIRE OR EXPLOSION
., SPILLS/LEAKING CONTAINERS/
'"• RUNOFF/STANDING LIQUIDS
,, SEWER. STORM
*'• DRAIN PROBLEMS
IB. EROSION PROBLEMS
19. INADEQUATE SECURITY
20. INCOMPATIBLE WASTES
21. MIDNIGHT DUMPING
22. OTHER (specify).
B.
POTEN-
TIAL
HAZARD
(mark 'X')
C.
ALLEGED
INCIDENT
(mark 'X')
*"
D. DATE OF
INCIDENT
(mo.,day,yr.)
•
E. REMARKS
.:.• ' ' • • "-'-">"•,' -;:r '. " -..•*7'.^" •
EPA Form T2070-2 (10-79)
PAGE 3 OF 4
l-D-24
Continue On Reverse
-------
Continued From Front
VII. PERMIT INFORMATION
A. INDICATE ALL APPLICABLE PERMITS HELD BY THE SITE.
O 1 NPDES PERMIT d Z. SPCC PLAN |~1 3. STATE PERMITf.p«e//y;-
[""I 4. AIR PERMITS I I S. LOCAL PERMIT I I 6. RCRA TRANSPORTER
I I 7 RCHA STORER I I 8. RCHA THEATER l"~l 9 RCRA DISPOSER
I I 10. OTHER (meetly)
B. IN COMPLIANCE'
1. YES d| 2. NO
C~l 3. UNKNOWN
4 WITH RESPECT TO (liml regulation name & number; _
. PAST REGULATORY ACTIONS
I | A. NONE
I | a. YES (summarize below)
IX. INSPECTION ACTIVITY Coast or on-rtoind)
I | A. NONE 1 1 8. YES (complete Item, 1,3,3, & 4 below)
1 TYPE OF ACTIVITY
2 DATE OF
PAST ACTION
(mo,, day, by r.)
3 PERFORMED
BY
(EPA./ State)
4. DESCRIPTION
X. REMEDIAL ACTIVITY (past or on-going)
\ 1 A. NONE 1 1 B. YES (complete Items I. 2,3, it 4 below)
I.TYPE OF ACTIVITY
2. DATE OF
PAST ACTION
(mo., day, & yr,)
3 PERFORMED
BY
(EPA/State)
4 DESCRIPTION
NOTE: Based on the information in Sections HI through X, fill out the Preliminary Assessment (Section 11)
information on the first page of this form.
EPA Form 72070-2 (10-79)
PAGE 4 OF 4
l-D-25
-------
&EPA
POTENTIAL HAZARDOUS WASTE SITE
SITE INSPECTION REPORT
REGION SITE NUMBER (to bo aaalfn-
eU oy HoJ
GENERAL INSTRUCTIONS: Complete Sections I and HI through XV of this form as completely as possible. Then use the informa-
tion on this form to develop a Tentarve Disposition (Section //;. File this form in its entirety in the regional Hazardous Waste Log
Pile. Be sure to include all appropriate Supplemental Reports in the file. Submit a copy of the forms to: U.S. Environmental Pro-
tection Agency; Site Tracking System, Hazardous Waste Enforcement Tack Force (EN-335), 401 M St., SW, Washington, DC 20460.
I. SITE IDENTIFICATION
A. SITE NAME
C. CITY
B. STREET (or other Identlller)
D. STATE E. 7TP' COtJE
G. SITE OPERATOR INFORMATION
1 NAME
3. STREET
1 NAME
4 CITY
3. CITY
F. COUNTY NAME
2. TELEPHONE NUMBER
8. STATE 1 8. ZIP CODE
2. TELEPHONE NUMBER
t. STATE | B. ZIP CODE
1. SITE DESCRIPTION
J. TYPE OF OWNERSHIP
1 1 1 FEDERAL 1 1 2. STATE I I 3. COUNTY | | 4. MUNICIPAL I I 5. PRIVATE
A. ESTIMATE DATE OF TENTATIVE
DISPOSITION (mo., day. a, yr.)
C. PREPARER INFORMATION
1 NAME
II. TENTATIVE DISPOSITION (complete this section last)
B. APPARENT SERIOUSNESS OF PROBLEM
1 1 1. HIGH | | 2. MEDIUM ! I 3. LOW 1 1 4. NONE
2. TELEPHONE NUMBER
3. DATE (mo., day, 4 yr,.)
III. INSPECTION INFORMATION
A. PRINCIPAL INSPECTOR INFORMATION
1. NAME 1 t TITLE
3 ORGANIZATION
B. INSPECTION PARTICIPANTS
1 i«AME
4. TELEPHONE NO. (area coae & no.J
2. ORGANIZATION
3. TELEPHONE NO.
C. SITE REPRESENTATIVES INTERVIEWED (corporate olflclala. workers, reildanla)
1. NAME
2 TITLE & TELEPHONE NO. 3. ADDRESS
•
EPA Form TJ070-3 (10-79)
Continue On Reverse
-------
Continued From Front
IE. INSPECTION INFORMATION (continued)
O. GENERATOR INFORMATION (sources of or ana)
1 . NAME
2. TELEPHONE NO.
3. ADDRESS 4.. WASTE TYPE GENERATED
E. TRANSPORTER/HAULER INFORMATION
1 . NAME
2. TELEPHONE NO.
3. ADDRESS *. WASTE TYPE TRANSPORTED
F. IF WASTE IS PROCESSED ON SITE AND ALSO SHIPPED TO OTHER SITES. IDENTIFY OFF-SITE FACILITIES USED FOR DISPOSAL.
1. NAME
G. DATE OF INSPECTION
(aio., day, * yr.)
2. TELEPHONE NO.
H. TIME OF INSPECTIOK
3 ADDRESS
1. ACCESS GAINED 9Y (credentials must bo shown in all cases)
(""I 1. PERMISSION n 2- WARRANT
J. WEATHER fdoscri&M
IV. SAMPLING INFORMATION
A. Mark 'X* for the types of samples taken and indicate where they have been sent e.g., regional lab, other EPA Lab. contractor,
etc. and estimate when the results will be available.
1. SAMPLE TYPE
a. SROUNDWATER
b. SURFACE WATER
e. ,;*STE
d. AIR
0. RUNOFF
£. SPILL
g. SOIL
h. VEGETATION
I. OTHERfspoofy)
9. SAMPLE » DATE
TAKEN 3. SAMPLE SENT TO ' RESULTS
fmarlt'X') ' AVAILABLE
B. FIELD MEASUREMENTS TAKEN fa.g., radioactivity, expfosivity, PH. ate.)
1 . TYPE
2. LOCATION OF MEASUREMENTS 3 RESULTS
EPA Form T2070-3 (10-79)
Continue On Page 3
-------
Continued From Page 2
IV. SAMPLING INFORMATION (continued)
C PHOTOS
1 TYPE OF PHOTOS 2 PHOTOS IN CUSTODY OF
f~~l a OROUND 1 1 b. AERIAL
D SITE MAPPED*
! 1 YES. SPECIFY LOCATION OF
MAPS
E. COORDINATES
1 LA TlTUDE (deg.-min.-sec.)
2 LONGITUDE (dea -mm. -sec. )
V. SITE INFORMATION
A SITE STATUS
, I 1. ACTIVE (Those industrial or
on a continuing basts, even it infre-
quently.)
1 I 2 INACTIVE (Those
1 3 OTHERfspeci/yJ
("Those sites that include such incidents like "midnight dumping"
has occurred.)
B. IS GENERATOR ON SITE'
1 ~1 1 NO 1 I 2. YESCspeci/x generator's four-digit SIC Code)
C. AREA OF SITE Cm acresj
D ARE THERE BUILDINGS ON THE SITE'
L] 1 NO I 1 2. YESfspec.fyJ
VI. CHARACTERIZATION OF SITE ACTIVITY
Indicate the major site acuvityfies.) and details relating to each activity by marking 'X.' in the appropriate bo Yes.
— A TRANSPORTER —
1 .RAIL
2. SHIP
3 BARGE
4 TRUCK
5. PIPELINE
a. O THER (specify)
B. STORER
1 PILE
2. SURFACE IMPOUNDMENT
3 DRUMS
4 TANK, ABOVE GROUND
9 TANK, SEUOW GROUND
8 OTHER (specify.)
X1 X1
C TREATER D. DISPOSER
1 FILTRATION 1 LANDFILL
2. INCINERATION 2 LANDFARM
3 VOLUME REDUCTION 3 OPEN DUMP
4 RECYCLING/RECOVERY 4 SURFACE IMPOUNDMENT
S C HEM./PH YSr/TREA TMENT 5 MIDNIGHT DUMPING
E. BIOLOGICAL TREATMENT 6 INCINERATION
7 WASTE OIL REPROCESSING 7 UNDERGROUND INJECTION
8 SOLVENT RECOVERY 8 O T HE R ( specllv)
9 OTHERfspeci/y;
1
E. SUPPLEMENTAL REPORTS ?f the site falls within any of the categories listed below, Supplemental Reports must be completed. Indicate
which Supplemental Reports you have filled out and attached to this for..
1 1 1. STO-- [~| 2. INCINERATION [~1 3. LANDFILL | | 4. f« PO ^DM E N T ! 1 5- °EEP WELL
Q 6. pHYS^REATMENT 1 1 1 LANOFARM Q 8. OPEN DUMP | | 9 TRANSPORTER I I 10. RECYCLOR/ RECLAIMER
YD. WASTE RELATED INFORMATION
A. WASTE TYPE
1 j 1. LIQUID I I 2. SOLID 1 1 3. SLUDGE I I 4 GAS
8. WASTE CHARACTERISTICS
I | 1. CORROSIVE | | 2. IGNITABLE | | 3. RADIOACTIVE I I 4. HIGHLY VOLATILE
1 I S. TOXIC | | 6. REACTIVE | | 7. INERT | | 8. FLAMMABLE
1 I 9. OTHERfspec/fyJ
C. WASTE CATEGORIES
1. Are records of wastes available) Specif y items such as manifests, inventories, etc. below.
EPA Form T2070-3 (10-79)
PAGE 3 OF 10
l-D-28
Continue On Reverse
-------
Continued From Front
VII. WASTE RELATED INFORMATION (continued)
2. Estimate the amount (specify unit of measure) of waste by category, mark 'X' to indicate which wastes are present.
a. SLUDGE
AMOUNT
UNIT OF MEASURE
LI PAINT.
PIGMENTS
METALS
* SLUDGES
13) POTW
ALUMINUM
'SLUDGE
\(S>OTHea(»paeify)
b. OIL
AMOUNT
UNIT OP MEASURE
X
(1I°"-V
1 WASTES
12) OTHERfapeei/y.)
c. SOLVENTS
AMOUNT
UNIT OF MEASURE
X
... HALOGENATED
SOLVENTS
NON-H ALOGNTO.
SOLVENTS
(3) OTHER (specify.)
d. CHEMICALS
AMOUNT
UNIT OF MEASURE
X
II) ACIDS
PICKLING
LIQUORS
131 CAUSTICS
(4) PESTICIDES
(5) DYES/INKS
(6) C Y ANIDE
<7> PHENOLS
(3> HALOGENS
I9> PCS
IIO) METALS
(M) OTHERf specify;
e. SOLIDS
AMOUNT
UNIT OF MEASURE
X '
[] 1 FLY ASH
(2) ASBESTOS
MILLING/ MINE
3 TAILINGS
FERROUS SMELT
ING WASTES
NON-FERROUS
5MLTG. WASTES
1(81 OTHEHfspeci/yJ
f. OTHER
AMOUN T
UNIT OF MEASURE
__ ... LABORATORY
PHARMAC EUT
12) HOSPITAL
(3) RADIOACTIVE
(4) MUN1C IP AL
1 (SI OTHER (specify.)
D. LIST SUBSTANCES OF GREATEST CONCERN WHICH ARE ON THE SITE (place in descending order of hazard)
1. SUBSTANC
2. FORM
(mark -X')
L l. SO-
LID
b. c. v A-
LIQ. POR
3. TOXICITY
(mark 'X')
a.
HIGH
b c. d. ~ -
MED. LOW NONE
AS NUMBER 5. AMOUNT 6 UNIT
Vin. HAZARD DESCRIPTION
FIELD EVALUATION HAZARD DESCRIPTION Place an 'X' in the box to indicate that the listed hazard exists. Describe the
hazard in the space provided.
| | A. HUMAN HEALTH HAZARDS
EPA Form T2070-3 (10-79)
PAGE - OF 10 l-D-29
Continue On Page 5
-------
Continued From Page 4 •
. HAZARD DESCRIPTION (continued)
II 9. NON-WORKER INJURY/EXPOSURE
I I C. WORKER INJURY/EXPOSURE
I I O. CONTAMINATION OF WATER SUPPLY
I I E. CONTAMINATION OF FOOD CHAIN
I I F. CONTAMINATION OF GROUND WATER
| | G. CONTAMINATION OF SURFACE WATER
EPA Form T2070-3 (10-79) PACE 5 OF 10 Continue On Reverse
1-D-3Q
-------
Continued Front Front
HAZARD DESCRIPTION (continued)
I I H. DAMAGE TO FLORA/FAUNA
I. FISH KILL
| | J. CONTAMINATION OF AIR
! I K. NOTICEABLE ODORS
L. CONTAMINATION OF SOIL
I | M. PROPERTY DAMAGE
EPA Form T2070-3 (10-79)
PAGP « OF 10
l-D-31
Continue On Page 7
-------
Continued From Page 6
VIII. HAZARD DESCRIPTION (continued)
I I N. FIRE OR EXPLOSION
I I O. SPILLS/LEAKING CONTAINERS/RUNOFF/STANDING LIQUID
I | P. SEWER. STORM DRAIN PROBLEMS
0. EROSION PROBLEMS
R. INADEQUATE SECURITY
I | S. INCOMPATIBLE WASTES
EPA Form T2070-3 (10-79) PAGE 7 OF 10 Confmue On Reverse
l-D-32
-------
VIII. HAZARD DESCRIPTION fcontmued)
. MIDNIGHT DUMPING
I | U. OTHER (tpeclfy)
IX. POPULATION DIRECTLY AFFECTED BY SITE
A. LOCATION OF POPULATION
B. APPROX. NO.
OF PEOPLE AFFECTED
APPROX. NO. OF PEOPLE
AFFECTED WITHIN
UNIT AREA
D. APPROX. NO
OF BUILDINGS
AFFECTED
E. DISTANCE
TO SITE
(specify units)
I.IN RESIDENTIAL. AREAS
IN COMMERCIAL
OR INDUSTRIAL AREAS
3.
IN PUBLICLY
TRAVELLED AREAS
PUBLIC USE AREAS
'(parka, schools, ale,)
X. WATER AND HYDROLOCICAL DATA
GROUNDWATER USE IN VICINITY
A. DEPTH1TO GROUNDWATER(«p«e»x
3. DIRECTION OF FLOW
D. POTENTIAL YIELD Or AQUIFER
E. DISTANCE TO DRINKING WATER SUPPLY
(specify unit of measure)
F DIRECTION TO DRINKING WATER SUPPLY
G. TYPE OF DRINKING WATER SUPPLY
[""I I. NON-COMMUNITY (~1 2. COMMUNITY (apeeily fowmj
< 15 CONNECTIONS* > IS CONNECTIONS
I | 3. SURFACE WATER I I 4. WELL
EPA Form T2070-3 (10-79)
PAGE 8 OF 10
Continue On Page 9
l-D-33
-------
Confirmed From Page 8
X. WATER AND HYDROLOGICAL DATA (continued)
H. LIST ALL DRINKING WATER WELLS WITHIN A 1/4 MILE RADIUS OF SITE
2 DEPTH
(specify unit)
3 LOCATION
(proxim'tv to population/buildings)
N ON-COM-
MUNITY
(•mark -X')
COMMUN-
ITY
(mark 'X')
I. RECEIVING WATER
1 NAME'
II 2 SEWERS
I I 3 STREAMS/RIVERS
F I 4 I_A
-------
Continued From Front
XIV. PERMIT INFORMATION
List all applicable permits held by the site and provide the related information.
A. PERMIT TYPE
a.g..fiCKA,Stata.NPDES.<>tc.)
B. ISSUING
AGENCY
C. PERMIT
NUMBER
D. DATE
ISSUED
(mo.,tlay,ifyr.)
E. EXPIRATION
DATE
(mo,,day,Ayr.;
F. IN COMPLIANCE
(mark "X")
1
YES
2
NO
3 UN-
KNOWN
XV. PAST REGULATORY OR ENFORCEMENT ACTIONS
I | NONE I I YES f«ummari»» in this apace)
NOTE: Based on the information in Sections III through XV, fill out the Tentative Disposition fSecfion
on the first page of this form.
information
EPA Form T2070-3 (10-79)
PAGE 10 OF 10
l-D-35
-------
LANDFILLS SITE INSPECTION REPORT
(Supplemental Report)
INSTRUCTION
Answer and Explain
as Necessary.
1. EVIDENCE Of SITE INSTABILITY (Erosion, Sfilling. Sink Holes, tie)
( I YES l~~l NO
2. EVIDENCE OF IMPROPER DISPOSAL OF BULK LIQUIDS. SEMI-SOLIDS AND SLUDGES INTO THE LANDFILL
l~1 YES d] NO
3. CHECK RECORDS OF CELL LOCATION AND CONTENTS AND BENCHMARK
[ I YES l~~l NO
4. WASTES SURROUNDED BY SORBENT MATERIAL
C3 YES I I NO
5. DIVERSION STRUCTURES ARE EFFECTIVELY CONSTRUCTED AND PROPERLY MAINTAINED
(~"1 YES C] NO
6. EVIDENCE OF PONDING OF WATER ON SITE
1 I YES I I NO
7. EVIDENCE OF IMPROPER/INADEQUATE DRAINING
O YES CD NO
8. ADEQUATE LEACHATE COLLECTION SYSTEM (II "yea", specify Type)
CD YES I I NO
3a. SURFACE LEACHATE SPRING
CD YES CD NO
9. RECORDS OF LEACHATE ANALYSIS
CD YES Cl NO
10. GAS MONITORING
C~l YES CD NO
It. GROUNOWATER MONITORING WELLS
I I YES f~| NO
12. ARTIFICIAL MEMBRANE LINER INSTALLED
I 1 YES I I NO
13. SPECIFIC CONTAINMENT MEASURES (Clay Bottom, Sides,etc)
II YES II NO
14. FIXATION (Stabilization) OF WASTE
II YES II NO
IS. ADEQUATE CLOSURE OF INACTIVE PORTION OF FACILITY
I | YES f~l NO
IS. COVERfType;
I6a. THICKNESS
16b. PERMEABILITY
16c. DAILY APPLICATION
i i YES r~i NO
EPA Form T2070-3E (10-79)
l-D-36
-------
STORAGE FACILITIES SITE INSPECTION REPORT
(Supplemental Report)
INSTRUCTION
Answer and Explain
as Necessary.
I. 5TOPAGE A = £A IAS CONTINUOUS IMPERVIOUS 3.ASE
i~~! YES [""I NO
2. STORAGE ASEA MAS A CONflNEMENT STRUCTURE
,~~! YES Q] NO
3. EXIGENCE Or L £ *< AC E / O V£=> ? LOW C
l~~j YES f~~j NO
nd how muc/i 'unotf ti oyari/oKing or J«aKing jrom concainme-irj
4. iS7IMAT£ TYPS AND
OF 3ASREL3/ CONTAINERS
s. GLASS OR PLASTIC STORAGE CONTAINERS
I I rss I ! NO
6. ESTIMATE NUMBER AND CAPACITY OF STORAGE TANKS
7 SO" LABELING ON CONTAINERS
9. EVIDENCE Or LEAKAGE COa=OSIOM O^ 3ULGr
-------
INCINERATORS SITE INSPECTION REPORT
(Supplemental Report)
. INSTRUCTION
Answer and Explain
as Necessary.
1. INCINERATION OF ALL SUBSTANCES APPROVED BY REGULATORY AGENCY
O YES Q NO
LIST ALL MJB3TAMCEI INCINERATED. INDICATING WHETHER OR NOT APPROVAL EXIST*.
2. COMBUSTION Ei rICIENCY MONITORED
d] 1ES [3 NO (Explain)
3.TEMPERATURE,GAS FLOW, RETENTION CALCULATIONS. AND COMBUSTION ZONE MONITORED
r~i rEs i i NO
4. MONITORING EQUIPMENT FUNCTIONING PROPERLY
l~~l YES | | NO
5. ADEQUATE MAINTENANCE OF EMISSION CON TROL EQUIPMEN T
1 I YEJ I I NO
6. MONITORING PORTS IN I NCINERATOR f/ndicnie Position)
I I YES [ 1 NO
7. WASTE FLOW RATE MONITORED
[ I YES |~~| NO
8. CUT-OFF DEVICE FUNCTIONING PROPERLY
CD YES CD NO
9. STACK TEST
CD YES NO
9o. EPA METHOD
9b. AGENCY CONDUCTING TEST
9c. DATE
10. ADEQUATE METHOD FOR DISPOSAL OF SCRUBBER LIQUOR WASTEWA TER (Describe)
[ I YES PI NO
II. ADEQUATE METHOD FOR DISPOSAL OF ASH OJENCHING WASTEWATER OR ASH (Deterlbt)
CD YES I 1 NO
12. TYPE OF SCRUBBER MEDIUM
13. TYPE OF SCRUBBER
14. MIST ELIMINATOR
CU YSS O NO
EPA Form T2070-3B (10-79)
l-D-38
Continued on reverse
-------
IS. OPACITY READING TAKEN
I 1 VCS I 1 NO VALUE
16. MET STACK
|~1 VES (~~l NO
7. STACK HEIGHT
is. STACK DIAMETER
19. CONSTRUCTION MATERIAL OF STACK
2O. PERMIT LIMITS
EMISSION UIMI TS
21. TYPE OF EQUIPMENT
Zla. MAKE
Zlb. AGE
ZIC. CONDITION
EPA Form T2070-36 <1 0-79) (R.«.n«)
l-D-39
-------
LAND FARM SITE INSPECTION REPORT
(Supplemental Report)
STATs. =EHM1T
2. AREA (Cimanaiani of
3. APPVICAiiON A A i E
4. IMPROPER DISPOSAL OP UNAUTHORIZED MATERIALS l« LANO -ARM
i~~! "SS i""5 NO
S. OIVE3SION STRUCT'JSES ASE £F?SCT1VSLY CONSrSUCTaO ANO ?9aPS^l.v MAINTAtNEO
f"~ VSS I ! NO
S. EVICEMCE OF PONCING OF LIQUID ON SITE
L~Jj "SS l~*l NO
T. OCORS (ftpfciflly hyorog«n sultiao) (II YSS. indicate)
C YSS i~"l -NO
S OF SOU.
9. VEGETATION ON LANO FARM
10. pH
E ?A Farm T1070-3A (1-3-791 1-0-40
-------
SURFACE IMPOUNDMENTS SITE INSPECTION REPORT
(Supplemental Report)
INSTRUCTION
Answer and Explain
as Necessary.
I. TYPE OF IMPOUNDMENT
2. STABILITY/CONDITION OF EMBANKMENTS
3. EVIDENCE OF SITE I NST ABI U T Y (Erosion, Settling. Sink Holes, etc.)
I I VES I [ NO
4. EVIDENCE OF DISPOSAL OF IGNITA8LE OR REACTIVE WASTE
I I VES I I NO
S. ONLY COMPATIBLE WASTES ARE STORED OR DISPOSED OF IN THE IMPOUNDMENT
r~i VES o NO
6. RECORDS CHECKED FOR CONTENTS AND LOCATION OF EACH SURFACE IMPOUNDMENT
l~i YES Q NO
7. IMPOUNDMENT HAS LINER SYSTEM
1 I YES r~| NO
7a. INTEGRITY OF LINER SYSTEM CHECKED
O VES II NO
7b. FINDINGS
B. SOIL STRUCTURE AND SU BSTRUCTURE
9. MONITORING WELLS
r~l YES d NO
10. LEMGTH, WIDTH, AND DEPTH
LENGTH WIDTH
11. CALCULATED VOLUMETRIC CAPACITY
12. PERCENT OF CAPACITY REMAINING
13. ESTIMATE FREEBOARD
14. SOLIDS DEPOSITION
CD YES D NO
IS. DREDGING DISPOSAL METHOD
16. OTHER EQUIPMENT
EPA Fwm T2070-3C (10-79)
-------
^ F"B^5\
oEPA
POTENTIAL HAZARDOUS WASTE SITE
TENTATIVE DISPOSITION
REGION SITE NUMBER
File this form in the regional Hazardous Waste Log File and submit a copy to U S. Environmental Protection Agency, Site Tracking
System. Hazardous Waste Enforcement Task Force (EN-335), 401 M St., SW, Washington, DC 20460.
I. SITE IDENTIFICATION
A. SITE NAME
C. CITY
Indicate the recommended actionfs;
8. STREET
D. STATE
II. TENTATIVE DISPOSITION
and agencyfies.) that should be involved by marking 'X' in the
RECOMMENDATION
MARK'X' EP«
A. NO ACTION NEEDED -- NO HAZARD
B. INVESTIGATIVE ACTION(S) HEEDED (I I yes, complete Section III.)
C. REMEDIAL ACTION NEEDED (II yes, complete Section IV.)
ENFORCEMENT ACTION NEEDED
D. be primarily managed by the EPA or
is anticipated.)
(il yes, specify in Pan £ whether the case will
the State and what type of enforcement action
E. RATIONALE FOR DISPOSITION
F. INDICATE THE ESTIMATED DATE OF FINAL DISPOSITION
(mo., day, & yr.)
H. PREPARER INFORMATION
1 . NAME
E ZIP CODE
appropriate boxes.
ACTION AGENCY
STATE LOCAL PRIVATE
G. IF A CASE DEVELOPMENT PLAN IS NECESSARY. INDICATE THE
ESTIMATED DATE ON WHICH THE PLAN WILL BE DEVELOPED
(mo., day, & yr.)
2 TELEPHONE NUMBER
3. DA TE (mo., day, & yr.)
III. INVESTIGATIVE ACTIVITY NEEDED
A. IDENTIFY ADDITIONAL INFORMATION NEEDED TO ACHIEVE A FINAL DISPOSITION.
3. PROPOSED INVESTIGATIVE ACTIVITY (Detailed Information)
1 METHOD FOR OBTAINING
NEEDED ADDITIONAL INFO.
a. TYPE OF SITE INSPECTION
(1)
<2>
(3)
b. TYPE OF MONITORING
II)
(2)
c. TYPE OF SAMPLING
II)
(21
2.SCHEDULED
DATE OF
ACTION
(mo,day,ie yr)
3. TO BE
PERFORMED BY
(EPA, Con-
tractor, State, etc.)
.
4
ESTIMATED
MANHOURS
_
5. REMARKS
I
EPA Form T2070-4 (10-79)
Continue On Reverse
l-D-42
-------
Continued From Front
HI. INVESTIGATIVE ACTIVITY NEEDED and PART B-PROPOSED INVESTIGATIVE ACTIVITY (Continued)
d. TYPE OF L.AB ANALYSIS
(1 )
(21
e. OTHER (specify)
111
121
C ELABORATE ON ANY OF THE INFORMATION PROVIDED IN PART 3 foil Iron t aucve) AS NEEDED TO IDENTIFY ADDITIONAL
INVESTIGATIVE WORK
D. ESTIMATED
MANHOURS BY ACTION AGENCY
Z TOTAL ESTIMATED 2 TOTAL ESTIMATED
MANHOURS FOR MANHOURS FOR
1 ACTION AGENCY INVESTIGATIVE 1 ACTION AGENCY INVESTIGATIVE
AfTIV/ITIFS ACTIVITIPS
a. EPA
b. STATE
d. OTHER (specify)
C. EPA CONTRACTOR
IV. REMEDIAL ACTIONS
A. SHORT TERM/EMERGENCY STRATEGY (On Site & Oil-Site) List all emergency actions needed to bring site under immediate control, e.g.. re-
strict access, provide alternate water supply, etc. See instructions for a list of Key Uords for each of the actions to be used in the space below.
1 ACTION
2 EST.
START
DATE
(mo.day.tsyr)
B. LONG TERM STRATEGY (On Site & Oil-Site)
See instructions for a list of Key Words for eac
i. ACTION
C. ESTIMATED
i ACTION
AGENCY
a. EPA
C PRIVATE
PARTIES
2 EST
START
DATE
fmo,d«y,&vO
3 EST
END
DATE
fmo.day.&yrj
4
ACTION AGENCY
(EPA, Slate,
Private Party)
5 ESTIMATED COST
S
S
S
S
S
S
6 SPECIFY 311 OR OTHER ACTION,
INDICATE THE MAGNITUDE OF
THE WORK REQUIRED
L II 1 1
h of the actions to be used in the spaces below.
3. EST
END
DATE
fmo.dax.&yr)
t
ACTION AGENCY
(EPA, State
Pri vale ParlyJ
5 ESTIMATED COST
5
S
5
S
S
S
6 SPECIFY 311 OROTHER ACTION,
INDICATE THE MAGNITUDE OF
THE WORK REQUIRED
MANHOURS AND COST 9Y ACTION AGENCY
2 TOTAL EST.
MANHOURS FOR
REMEDIAL
ACTIVITIES
2 TOTAL EST
3 TOTAL EST COST MANHOURS FOR 3 TOTAL EST COST
= OR I. ACTION AGENCY REMEDIAL FOR
R = MEDIAL ACTIVITIES ACTIVITIES RFM^niAL ATTIV1T1E5
b. STATE
d. OTHER (specify)
EPA Form T2070-4 (10-79) REVERSE
l-D-43
-------
** CDA POTENTIAL HAZARDOUS WASTE SITE REO.ON S.TE NUMB«
^^CrVA FINAL STRATEGY DETERMINATION
File this form in the regional Hazardous Waste Log
System., Hazardous Waste Enforcement Task Force
File and submit a copy to U.S. Environmental Protection Agency. Site Tracking
(EN-335). 401 M St., SW, Washington, DC 20-160.
I. SITE IDENTIFICATION
A. SITE NAME
C. CITY
a STREET
O. STATE E. ZIP CODE
II FINAL DETERMINATION
ndicate the recom-n ended actionfsj and agencyfies) that should be involved by marking 'X' in the appropriate boxes.
RECOMMENDATION
A. NO ACTION NEEDED
REMEDIAL ACTION NEEDED. BUT NO RESOURCES AVAILABLE
(If yes, complete Section III-)
C. REMEDIAL ACTION (II yet, complete faction IV.)
- ENFORCEMENT ACTION (11 yes, specify in Part E whether the case will be primarily
u* nanagad by tha EPA or the Slate end whet type ol enforcement action is anticipated.)
ACTION AGENCY
WAFJK'X EPA STATE LOCAL. IpRIVATE
•_: ;!:._
„
E. RATIONALE FOR FINAL STRATEGY DETERMINATION
*. IF A CASE DEVELOPMENT PLAN HAS BEEN PREPARED. SPECIFY G. IF AN ENFORCEMENT CASE HAS SEEN FILED, SPECIFY TH£
THE DATE PREPARED (mo., day.'k yr.) DATE FILED (mo,, day, & yr.)
H. PREPARES INFORMATION
1 NAME
2. TELEPHONE NUVISEB a.OATEfmo., day, 4 yr.;
in. REMEDIAL ACTIONS TO BE TAKEN WHEN RESOURCES BECOME AVAILABLE
List all renedial acuons, such as excavation, removal, etc. to be taken as soon as resources become available. See instructions
for a list of Key Words for each of the actions to be used in the spaces below. Provide an estimate of the'approxiirrate cost of the
remedy.
A. REMEDIAL ACTION
D. TOTAL ESTIMATED COST S
B. ESTIMATED COST
S
S
S
S
JS
S
S
S
C. REMARKS
EPA Form T:j;0-5 (10-79)
Continue On Hever^e
l-D-44
-------
IV. REMEDIAL ACTIONS
SHORT TERM/EMERGENCY ACTIONS (On Site and Oil-Site) List all emergency actions token or planned to bring the site under
immediate control, e.g., restrict access, provide alternate water supply, etc. See instructions for a list of Key Words for each of
the actions to be used in the spjces below.
1 ACTION
2. ACTION
START
DATE
(mo. day. Sty't
3. ACTION
END
DATE
rmo,day.atyr)
4.
ACTION AGENCY
(EPA, Slotc,
Private Party)
5. COST
s
s
s
s
.s . .
s
6. SPECIFY 311 OR OTHER ACTION.
INDICATE THE MAGNITUDE OF
THE *ORK REQUIRED.
. LONG TERM STRATEGY (On Site and Oil-Site) List all long term solutions, e.g., excavation, removal, ground water monitoring
wells, etc. See instructions for a list of Key Words for each of the actions to be used in the spaces below.
1. ACTION
2. ACTION
START
CATE
(mo.iiav.ftyr)
3. ACTION
END
DATE
(nofdav,4cyrt
«.
ACTION AGENCY
(EPA, State
Private Parly)
S. COST
S
s
s
s
s
s
6. SPECIFY 311 OR OTHE" ACTION.
INDICATE THE MAGNITUOE OF
THEJWORK REQUIRED.
MANHOURS AND COST BY ACTION AGENCY
t. ACTION AGENCY
I. EPA
1. STATE
:. PRIV* TE PARTIES
1. OTHER (spcctty)
2. TOTAL MAN-
HOURS FOR
REMEDIAL ACTIVITIES
3. TOTAL COST FOR
REMEDIAL ACTIVITIES
S
s
s
s
Forn T2370-5 (10-77) REVERSE
l-D-45
-------
HAZARDOUS WASTE SITE ENFORCEMENT AND RESPONSE SYSTEM
MONTHLY STATISTICAL SUMMARY"17
REGION
MONTH
YEAR
-'THE INITIAL IDENTIFICATION OF A POTENTIAL SITE SHOULD NOT BE INTERPRETED AS A FINDING OF ILLEGAL
ACTIVITY OR CONFIRMATION THAT AN ACTUAL HEALTH OR ENVIRONMENTAL THREAT EXISTS, ALL IDENTIFIED SITES
WILL BE ASSESSED UNDER THE EPA HAZARDOUS WASTE SITE ENFORCEMENT AND RESPONSE SYSTEM TO DETERMINE
IF A HAZARDOUS WASTE PROBLEM ACTUALLY EXISTS.
NOTE: This form covers actions up to the Last day of a given calendar month and is submitted to the Hazardous Waste Enforcement
Task Force (EN-33S) by the 10th day of the following -nonth.
-
1 NUMBER OF POTENTIAL WASTE SITES OR PROBLEMS ON THE REGIONAL LOG. — '
2. PRELIMINARY ASSESSMENTS COMPLETED.
3. SITES INSPECTED.
4. TOTAL NUMBER OF SITES FOR WHICH A TENTATIVE DISPOSITION HAS BEEN MADE.
TENTATIVE DISPOSITIONS HAVE BEEN MADE BY THE FOLLOWING CATEGORIES
a. NO ACTION NECESSARY 3ECAUSE NO IMMINENT HAZARD EXISTS.'2/
2/
h INVESTIGATIVE ACTION NEEDED. ~
'(to determine whether remedial ami/at amercement action appropriate;
e. REMEDIAL ACTION NEEDED.
d ENFORCEMENT ACTION NEEDED. *f
fcasa development plan to tie prepared)
5. FINAL STRATEGY DETERMINATION (by category)- TOTAL
a. NO ACTION NEEDED.
b. REMEDIAL ACTION TO BE TAKEN 3Y
(1) EPA OR EPA CONTRACTOR.
(2) STATE OR LOCAL GOVERNMENT.
(31 THIRD PERSONS.
e. REMEDIAL ACTION NEEDED. BUT NO RESOURCES AVAILABLE.
d. ENFORCEMENT ACTION TO BE TAKEN 3Y
(I) EP»
12) STATS
6. ENFORCEMENT CASES FILED (ludicial actions only).
a. EPA
b. STATE
7 ADMINISTRATIVE ORDERS ISSUED.
a. EPA
b. STATE
8. PREPARES OF INFORMATION
a. NAME b. TELEPHONE NUMBER
CUMULATIVE
-
THIS VIONTH
c. OATS
~ The "Investigative Action Needed" block should be used only where there is inadequate information to support any other tentative
disposition. If any other categories are chosen Che "Investigative Action Needed" category should not be useo — regardless of
whether or not additional fact-finding will be needed to reach a "Final Strategy Determination".
E PA Form T2070-6 (1 1 -79)
i-n-46
-------
IDENTIFICATION PHASE
FINAL
ACTION
v y
f<
r
STATE
ACTION
REGION
EPA
MONITOR
POTENTIAL
HWS
IDENTIFICATION
(2070-8)
POTENTIAL
HWS LOG
OPENED
(2070-1)
FIT
ACTION
l-D-47
-------
PRELIMINARY ASSESSMENT PHASE
EPA
EMERGENCY
ACTION
REQUIRED
SITE
INSPECTION
REQUIRED
NO FURTHER
ACTION
REQUIRED
(2070-5)
l-D-48
-------
INSPECTION PHASE
EPA
EMERGENCY
ACTION
REQUIRED
SITE
INSPECTION
STRATEGY
DEVELOPMENT
CONDUCT
SITE
INSPECTION
I2070-3A-E)
(2070-31
EPA
COMPLETE
TENTATIVE
FURTHER
INSPECTION
REQUIRED
(SAMPLING)
NO FURTHER
ACTION
REQUIRED
(2070-5)
l-D-49
-------
FULL FIELD INVESTIGATION PHASE
CLOSE-OUT PHASE
PREPARATION
FOR
SAMPLING
FULL FIELD
INVESTIGATION
(SAMPLING)
»
SAMPLE ANALYSIS
AND
REPORT
HWS
INVESTIGATION
LOG CLOSED
12070-1)
HWS
SAMPLING
PLAN
EPA
APPROVAL
NO FURTHER
ACTION
REQUIRED
EPA
FINAL
STRATEGY
DETERMINATION
(2070-5)
PRCK«
l-D-50
-------
DAY 2
-------
RESPIRATORY PROTECTION
1. INTRODUCTION
A. Objective. The-objective of the respiratory protection por-
tion of the course is .to provide an understanding of the
operation, capabilities, and limitations of respiratory
equipment and to teach proper donning and wearing.
1) Self-contained breathing apparatus (SCBA)
2) Air-purifying masks
3) Escape packs
B. Legal Requirements
1) Williams and Steiger Occupational Safety and Health Act
of 1970 established standards which state that "approved
or accepted respirators shall be used when they are
available".
2) 29 CFR 1910.134 gives legal requirements for selection
and use of respiratory equipment as promulgated by OSHA
and based on ANSI standard Z88.2.
3) 30 CFR Part 11 describes tests for permissibility of res-
piratory protective apparatus used by NIOSH.
2-1
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2. THE USE OF RESPIRATORY EQUIPMENT
A. Respirators are used when engineering controls are impossible
in hostile environments.
B. Respirators are used in conjunction with proper procedures
and the following:
1) Adequate equipment
2) Proper maintenance of equipment
3) Well-trained personnel
4) Continual adherence to above
C. Employer will supply suitable approved respirators and estab-
lish a respiratory protection program including the following
items (see 29 CFR 1910.134 for details). (Exclusive used of
respirators is suggested but not required).
1) Standard operating procedures for selection and use of
respirators.
2) Proper selection of respirators based on hazard
3) Training of personnel in use and limitations
2-2
-------
4) Regular cleaning and maintenance
5) Proper storage
6) Routine monthly inspections and before and after use
7) Constant monitoring of work area for adverse conditions
and worker stress
8) Continual evaluation of. respiratory compliance program
once in operation.
9) Determination of medical fitness of potential user
D. Only NIOSH-MSHA approved equipment can be used after proper
fit testing has been performed.
3. APPROVAL SCHEDULES
A. NIOSH Certified Equipment List gives all approved respiratory
apparatus by approval number.
1) An example of an approval designation is TC-13 F-69.
"13" is the schedule for SCBA, and "F" indicates the
number of revisions the schedule has been through, and
"69" is the approval number.
2) 30 CFR Part 11 lists testing schedules for all respira-
tory equipment and updates or deletes approvals.
2-3
-------
a) Subpart H - SeIf-Contained Breathing Apparatus -
Schedule 13
b) Subpart I - Gas Masks - Schedule 14
c) Subpart J - Supplied Air Respirators - Schedule 19
d) Subpart K - Dust, Fume, and Mist Respirators
Schedule 23
e) Subpart L - Chemical Cartridge Respirators - Schedule
23 '
3) Any equipment which is altered, hybridized or changed in
any unapproved way loses its approval by NIOSH-MSHA.
4. EQUIPMENT CLASSIFICATION
A. Air-Purifying Respirators
1) Employ fitering of air by the use of mechanical filters
and/or sorbents
2) May not be used in atmospheres which are oxygen deficient
(19.5% 02).
2-4
-------
3) May not be used in atmospheres which are IDLH (immediate-
ly Dangerous to Life or Health).
4) May not be used for vapors or gases which do not have ad-
equate warning properties which would indicate the
exhaustion of the cartridge filtering capability.
5) Use cartridges which are specific for particle or gas
hazard and its concentration.
B. Atmosphere-Supplying Respirators
1) Only positive-pressure-demand units may be used in IDLH
atmospheres.
2) Atmosphere-supplying respirators may be used in oxygen-
deficient atmospheres.
3) Regulators must be maintained by manufacturer-trained and
certified personnel.
5. RESPIRATOR FIT
A. The best fitting respirator will fit only 60% of the normal
working population.
B. Leaks in respirator seal will allow toxic gases or vapors to
enter mask.
2-5
-------
C. The biggest cause of leakage is facial hair.
D. Fit of respirators changes with growth of facial hair, weight
loss/gain, dental work, etc.
E. All users must be properly fit-tested.
6. AIR-PURIFYING RESPIRATORS
A. Disposable Dust Respirators
1) These are unapproved but widely used and ineffective due
to lack of good facial seal.
2) Approved paper or cloth respirators are approved only for
non-toxic particles which cause fibrosis. and pneumocon-
iosis. There are two types:
a) Single use
b) Reusable
B. Mouthbit Respirator
1) Mouthpiece is held in teeth and the nose clamped closed
2) Used for escape only, not for entry
2-6
-------
3) Used in situations where hazard is identified and respir-
ator is approved for that hazard.
C. Quarter-Mask Respirator (Type B half mask)
1) Fits from nose to top of chin with high breathing resis-
tance
2) Approved for toxic/non-toxic dusts only
3) Uses two- or four-point suspension with rubber or elastic
bands and approved only when worn properly.
D. Half-Mask Respirator (Type A half mask)
1) Fits under chin and over the nose
2) Uses one or two disposable chemical cartridges (there is
one fully disposable half-mask respirator).
3) Requires four-point suspension for approval
4) Specific cartridges are available such as organic vapor,
pesticide, dusts, spray paints, etc.
5) Remotely mounted cartridges on back or belt are available
to help minimize the exposure of the cartridges, which
last longer as a result.
2-7
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E. Full-Face-Mask Respirators
1) Cover entire face from under Che chin to above the eyes.
2) Provide much better protection than previously mentioned
respirators.
3) May be made of neoprene or silicone rubber.
a) Neoprene does not tear but will break down especially
when attacked by ozone.
b) Silicone rubber tears when nicked and will allow some
acids and organics to permeate; however, is more
durable in ozone.
4) Parts have specific requirements
a) Exhalation valve must give proper seal.
b) Inhalation valve is only a check valve.
c) Lens may be polycarbonate or acetate.
F. Powered Air Purifying Respirators
1) Give no breathing resistance.
2-8
-------
2) Work even when moCor fails.
3) Approved for dusts only.
G. Gas Masks
1) Consist of full-face mask with hose-mounted or chin-
mounted canisters.
2) Give high resistance to breathing.
3) Not approved in IDLH atmospheres although canisters ap-
proved for concentrations many times the TLV limits
4) High humidity will decrease canister life.
5) Beware of shelf life of canister; if seal is broken, dis-
card within a year or by the shelf date, whichever is
sooner.
6) Approved only for hazards with good warning properties
H. Particulate Filters
1) Large particulates dust filter - low toxicity, not less
than .05 mg/trH
2) Small particulates fume filter - low toxicity, not less
than .05
2-9
-------
3) High efficiency filters for large and small particles
down to 0.3 microns in size with toxicity less than 0.05
tng/m-^. Such small particles are impacted on filter
due to Brownian Movement. The lung defense mechanisms
will scavenge any particles less than 0.3 microns.
7. ATMOSPHERE-SUPPLYING EQUIPMENT
A. Hose Mask
1) Uses full face-mask
2) User draws clean atmospheric air by blower or lung power
3) Not approved in IDHL atmospheres
4) No more than 75 feet of hose is. permissible
5) User can overbreathe supply
B. Airline Respirators
1) Use full face-mask
2) Atmospheric air supplied by a compressor or large air
cylinder
2-10
-------
3) Deliver continuous low-positive-pressure flow of air
A) Source of air cannot be expendable
5) Require flow of 4 cfm for tight-fitting'mask and 6 cfm
for loose-fitting mask; must be checked before use.
6) Maximum pressure allowed if 15 cfm
7) Maximum 300 feet of hose is allowed
8) Flow rate must be controlled by the compressor only
C. Modes of Operation
1) Demand
a) Negative pressure from inhalation opens demand valve
to draw clean air.
b) Because of negative pressure, contaminated air will
also be drawn in along face-piece seal.
c) This mode is air-conserving.
2-11
-------
2) Pressure Demand
a) Demand valve is spring-loaded to keep valve open.
b) Exhalation valve is spring-loaded at a pressure
slightly greater than the demand valve.
c) Pressure builds up inside face piece enough to close
demand valve and exhalation valve.
d) Upon inhalation, pressure is reduced, the demand
valve opens, and air is forced into the face piece.
e) If the face piece leaks, the demand valve will remain
open and the unit will run continuously.
f) If the face piece should leak for a moment during in-
halation, none of the contaminated atmosphere will
leak into the mask because the air in the mask will
rush out of the mask as opposed to being drawn into
the mask in the demand mode.
g) This mode is air-conserving.
8. ESCAPE DEVICES - NOT FOR ENTRY
A. Belt-mounted bottle of compressed air
2-12
-------
B. Plastic hood with stainless steel tubing filled with com-
pressed air.
C. Give 5 to 15 minutes of air supply
9. SELF-CONTAINED BREATHING APPARATUS (SCBA)
A. Closed Circuit (uses oxygen rebreathing)
1) Oxygen generators - Navy Type
a) Air is very warm.
b) Will explode with water contact.
2) Compressed oxygen supply type
a) Approved only as demand apparatus,
b) Warm air is inhaled.
c) Recirculates air, purifies C02 and replenishes
oxygen supply.
3) Available in 30 to 60 minute supplies
2-13
-------
4) Not approved in IDLH atmospheres
B. Open Circuit
1) All approved units supply 30 minutes of air.
2) All approved only in the positive-pressure mode of oper-
ation.
3) Approved in IDLH atmospheres.
4) Requires training and many hours of practice to use an
SCBA efficiently.
5) Beware of quality of air put into the 45 cu. ft., 2200
psi cylinders. Must be at least Grade D.
6) Parts include:
a) Back pack and harness for weight suspension on hips
b) Regulator which can be maintained by persons certi-
fied in regulator maintenance. The high pressure
hose should never be tightened or loosened with a
wrench when the hose is attached to the cylinder.
c) Face piece and breathing tube, which must be clean
and the valves of which must be in proper order.
2-14
-------
7) The cylinder is marked as follows (see attachment)
a) DOT TYPE RATED PRESSURE
b) CYLINDER NUMBER
c) MANUFACTURER'S SYMBOL, MONTH, YEAR
d) Cylinder also indicates that it can be filled an
additional 10%.
8) Do not trust the person who fills the cylinder. Use an
oxygen meter, a carbon monoxide indicator, etc., to check
the air in your tank.
10. CHECK OUT PROCEDURE - (Attached)
A. Record all inspections.
B. Inspections must be made monthly and before each use.
11. MAINTENANCE
A. Face piece must be sanitized.
1) Do not use water higher than 120°F.
2-15
-------
2) Sterilization of face piece will destroy it,
3) Do not use household bleach.
B. Sanitization - obtain sanitizer from manufacturer.
1) Use quaternary ammonium salt solution 50 ppm, hypochlo-
rite solution 50 ppm, or iodine solutions 50 ppm.
2) Immerse for two minutes.
3) Use nothing harder than a bristle brush.
4) Jet action dishwasher may be used without the drying
cycle.
5) All parts including headbands and exhalation valve must
be removed in cleaning.
12. FIT TESTING (required by 29 CFR 1910.134)
A. Qualitative Test
1) Test atmosphere uses isoamyl acetate or irritant smoke
(MSA 5645 ventilation smoke tube, stannic chloride) with
proper cartridges.
2-16
-------
2) Allow user Co move around in atmosphere in a suspended
plastic bag (open at bottom) and ask if he detects the
test atmosphere with respirator having proper cartridges
in place.
3) Irritant smoke works well because it elicits an involun-
tary reaction.
4) This test can be very subjective but is cheap and quick.
5) Positive-pressure SCBA require no fit testing.
B. Quantitative Test
1) Required when using demand apparatus such as closed
circuit SCBA and gas masks.
2) Test is very accurate.
13. PROTECTION FACTORS
A. Each respirator has a given protection factor derived from
quantitative fit tests:
PF= concentration of test atmosphere outside
concentration of test atmosphere inside
B. The PF times the TLV gives the maximum allowable concentra-
tion for use of that particular respirator.
2-17
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ATTACHMENT 1
CHECKLIST FOR INSPECTION OF PRESSURE DEMAND
SELF-CONTAINED BREATHING APPARATUS WITHOUT MODE SELECT LEVER
Note: Any discrepancy found should be cause to set unit aside until
repair can be done by a certified repair-person
1. PRIOR TO BEGINNING INSPECTION:
1) Check to assure that high pressure hose connector is tight on
cylinder fitting
2) Bypass valve closed
3) Mainline valve closed
4) No cover or obstruction on regulator outlet
2. BACK PACK & HARNESS ASSEMBLY
A. Straps
1) Visually inspect for complete set
2) Visually inspect for frayed or damaged straps that may
break during use
B. Buckles
1) Visually inspect for mating ends
2) Check locking function
C. Backplate & Cylinder Lock
1) Visually inspect backplate for cracks and for missing
rivets or screws.
2-18
-------
2) Visually inspect cylinder hold down strap and physically
check strap tightener and lock to assure that it is fully
engaged.
3. CYLINDER & CYLINDER VALVE ASSEMBLY
A. Cylinder
1) Physically check cylinder to assure that it is tightly
fastened to back plate
(M) 2) Check hydrostatic test date to assure that it is current.
(M) 3) Visually inspect cylinder for large dents or gouges
in metal
B. Head & Valve Assembly
(M) 1) Visually inspect cylinder valve lock for presence
(M) 2) Visually inspect cylinder gauge for condition of face,
needle, and lens
3) Open cylinder valve and listen or feel for leakage around
packing. (if leakage is noted, do not use until
repaired.) Note function of valve lock.
4. REGULATOR & HIGH PRESSURE HOSE
A. High Pressure Hose & Connector
1) Listen or feel for leakage in hose or at hose-to-cylinder
connector. (Bubble in outer hose covering may be caused
by seepage of air through hose when stored under pressure.
This does not necessarily mean a faulty hose.)
B. Regulator & Low Pressure Alarm
1) Cover outlet of regulator with palm of hand. Open main-
line valve and read regulator gauge (must read at least
1800 PSI and not more than rated cylinder pressure).
2) Close cylinder valve and slowly move hand from regulator
outlet to allow slow flow of air. Gauge should begin to
(M) Done on a monthly inspection only.
2-19
-------
show immediate Loss of pressure as air flows. Low
pressure alarm should sound between 650 and 550 PSI.
Remove hand completely from outlet and close mainline
valve.
3) Place mouth onto or over regulator outlet and blow. A
positive pressure should be created and maintained for
5-10 seconds without any loss of air. Next suck a slight
negative on regulator and hold for 5-10 seconds. Vacuum
should remain constant. This tests the integrity of the
diaphragm. Any loss of pressure or vacuum during this
test indicates a leak in the apparatus.
4) Open cylinder valve.
5) Place hand over regulator outlet and open mainline valve.
Remove hand from outlet and replace in rapid movement.
Repeat twice. Air should escape when hand is removed each
time, indicating a positive pressure in chamber. Close
mainline valve and remove hand from outlet.
6) Ascertain that no obstruction is in or over the regulator
outlet. Open and close bypass valve momentarily to assure
flow of air through bypass system.
5. FACEPIECE & CORRUGATED BREATHING TUBE
A. Facepiece
1) Visually inspect head harness for damaged serrations and
deteriorated rubber. Visually inspect rubber facepiece
body for signs of deterioration or extreme distortion.
2) Visually inspect lens for proper seal in rubber facepiece,
retaining clamp properly in place, and cracks or large
scratches.
3) Visually inspect exhalation valve for visible deteriora-
tion or foreign materials build-up.
B. Breathing Tube & Connector
2-20
-------
1) Stretch breathing tube and visually inspect for
deterioration and holes.
2) Visually inspect^ connector to assure good condition of
threads and for presence and proper condition of "0" ring
or rubber gasket seal.
NOTE: Final test of facepiece would involve a negative pressure
test for overall seal and check of exhalation valve. If
monthly inspection, mask may now be placed against face
and following tests performed. If preparing for use, don
backpack, then don facepiece and use following procedure.
Negative Pressure Test on Facepiece
1) With facepiece held tightly to face or facepiece properly
donned, stretch breathing tube to open corrugations and
place thumb or hand over end of connector. Inhale. Nega-
tive pressure should be created inside mask, causing it
to pull tightly to face. This negative pressure should be
maintained for 5-10 seconds. If negative pressure leaks
down, the facepiece assembly is not adequate and should
not be worn.
6. STORAGE OF UNITS
1) Cylinder refilled as necessary and unit cleaned and
inspected.
2) Cylinder valve closed
3) High pressure hose connector tight on cylinder
4) Pressure bled off high pressure hose and regulator
5) Bypass valve closed
6) Mainline valve closed
7) All straps completely loosened and laid straight.
8) Facepiece properly stored to protect against dust, sunlight,
heat, extreme cold, excessive moisture, and damaging
chemicals
(M) would be done only on monthly inspection.
NOTE: Any discrepancy found should be cause to set unit aside until
repair can be done -by a certified repair-person.
2-21
-------
-------
-------
PERSONNEL PROTECTION LEVEL DETERMINATION
1. INTRODUCTION
The Project Team Leader is responsible for insuring the health,
safety and efficiency of the team. The level of personal protec-
tion necessary for the health and safety of the team will be det-
ermined by the Leader based on many criteria, some of which are
also used in boundary determinations. These factors include
surface air and wind characteristics, types and amounts of hazar-
dous waste present at the site based on historical data (or lack
of it), the location of the site relative to human traffic, and
overt signs of hazards to life and health. Any Team member can
seek to upgrade the level of protection established by the Leader.
This will be accomplished through consultation with the Leader and
the Site Safety Officer, and an agreement will be reached before
the Team member enters the exclusion area. The Team members will
not arbitrarily upgrade their protections. Under no circumstances
will the Team members downgrade the level of personal protection
selected. The constituents of various levels of personal protec-
tive clothing are attached.
2. LEVEL A
Level A protection will always be worn when the Team enters an en-
closed building or warehouse, when know percutaneous hazards
exist, or when there is no known historical data on the site.
Note that historical data can include observations in and around
the area from the off-site investigation. Since Level A provides
maximum protection against all known toxic hazards, the decision
NOT to use Level A should be noted and justified by the Leader in
the site log. Consideration of the stress that can arise from
wearing Level A protection should also enter into the Leader's
decision, but team comfort is NOT a decision factor. The MSA 401
respirator worn with Level A protection has a wear time of 30
minutes. Therefore, Team members will be brought to the "half-
dress" condition approximately every 20 to 30 minutes for air tank
changes and heat relief. After three air tanks, Team members will
be rotated to reduce the possibility of fatigue or excess stress.
3-A-l
-------
LEVEL B
In the absence of known percutaneous hazards, the use of Level A
will be at the discretion of the Leader. Level B protection will
be the preferred alternative in the absence of evidence that the
maximum degree of protection is necessary, but care must be exer-
cised in wearing Level B to avoid percutaneous contamination.
4. LEVEL C
The Level C protection may be worn only when the hazards present
have been identified and continuous monitoring is occurring.
Level C protection necessitates carrying an emergency air supply
(i.e., Robertshaw escape mask). The PTL is responsible for sel-
ecting the proper cartridge to be worn with the Ultra-Twin air
purifying respirator.
LEVEL D
Level D is the basic work uniform of the team. Team members will
not be permitted on-site in civilian clothes. Level D with a
slung Robertshaw escape mask is the minimum protection allowed on
any identified hazardous waste site; this level of protection will
be worn only on those sites tentatively identified as presenting
no hazards to life or health.
3-A-2
-------
LEVELS OF PROTECTION
LEVEL A
Equipment
1. SCBA-MSA 401
2. CP2000 East Wind encapsulated suit
3. Coveralls, cotton, white
4. Underwear, cotton
5. Gloves, surgical
6. Boots, neoprene, steel toe and shank
7. Booties, butyl rubber or PVC
8. Gloves, disposable* (additional pair)
9. Booties, disposable* (additional pair)
10. Hard Hat*
When to Use
1. Confined facilities
2. Sites containing known percutaneous hazards
3. No established history
4. IDLH atmosphere
5. Site exhibiting signs of acute mammalian toxicity, i.e., dead
animals, illnesses associated with past entry into site by humans
Used By
Initial entry team or work party as needed
*0ptional
3-A-3
-------
LEVEL B
Equipment
1. SCBA-MSA 401
2. Apron, butyl rubber, ankle length with sleeves
3. Gloves, butyl rubber or neoprene
4. Gloves, surgical
5. Boots, neoprene, steel toe and shank
6. Booties, butyl rubber
7. Coveralls, chemical resistant
8. Underwear, cotton
9. Booties, disposable* (additional pair)
10. Gloves, disposable* (additional pair)
11. Hard hat with face shield*
When to Use .
1. 02 deficient atmosphere
2. No known percutaneous hazards
3. IDLH atmosphere
4. Sites containing unknown but detectable levels of ambient organic
chemicals.
Used By
1. Initial Entry Team
2. Work Parties
3. Emergency Response Team
4. Safety Officer
5. PDS Operators
*0ptional
3-A-4
-------
LEVEL C
Equipment
1. Ultra-Twin respirator*
2. Robertshaw escape mask
3. Apron, butyl rubber, ankle length with sleeves
4. Gloves, butyl rubber
5. Gloves, surgical
6. Boot, neoprene, steel toe and shank
7. Booties, butyl rubber
8. Coveralls, chemical resistant
9. Underwear, cotton
10. Booties, disposable** (additional pair)
11. Gloves, disposable** (additional pair)
12. Hard hat with face shield**
When to Use
1. Open areas, no IDLH conditions
2. Well-documented history of site
3. Well-documented patterns of prior entry to site
4. Proximity to populated area
5. No evidence of chronic health effects
6. Continuous monitoring must take place
Used By
1. PDS Operators
2. Safety Officer
3. Work Parties
*Appropriate cartridge must be selected
**0ptional
3-A-5
-------
LEVEL D
Equipment
1. Coveralls, cotton
2. Underwear, cotton
3. Boots/shoes, safety
4. Safety glasses
5. Hard hat with optional face shield
6. Ultra twin (readily available)
7. Robertshaw escape mask (readily available)
8. Work gloves
When to Use
1. Site set-up operations in support area
2. On sites that have been investigated and characterized as having no
toxic hazards but Robertshaw escape mask will'be slung
Used By
Team members working in the support area
3-A-6
-------
B
-------
AMBIENT AIR CHARACTERIZATION
1. INTRODUCTION
A. The explosimeter, oxygen detector, Draeger tubes, radiation
detector, HNU photoionizer, and organic vapor analyzer (OVA)
are used to determine initially the level of safety at each
new site. The OVA in the gas chromatographic • (GC) mode, as
well as charcoal and tenax tubes, Mylar bags, and
intrinsically safe pumps, are used to characterize and
identify the chemical compounds present in the air at a given
site.
B. There are several objectives for this portion of the course:
1) To discuss the philosophy, use, and limitations of the
above-mentioned pieces of analytical equipment as used in
hazardous waste site investigations.
2) To describe the general operation of the equipment.
3) To develop a strategy for determining the level of safety
upon the initial site entry, using the explosimeter, 02
meter, radiation detector, and Draeger tubes.
4) To develop a strategy for ambient air characterization,
"hotspot" location, and sample screening using the HNU and
the OVA.
3-B-l
-------
2. EQUIPMENT USED TO DETERMINE THE LEVEL OF SAFETY UPON INITIAL SITE
ENTRY
The initial perimeter characterization equipment used to determine
the level of safety at each new site includes:
A. Exolosimeter
1) Description and Use. The explosimeter determines the
level of organic vapors and gases present in an atmosphere
as a percentage of the lower explosive limit (%LEL) by
measuring the change in electrical resistance in a Wheat-
stone bridge circuit.
2) Limitations. The explosimeter cannot be used in atmos-
pheres where the oxygen level is below 19.5%. Si lanes,
silicones, silicates, and leaded gasoline vapors can des-
troy the instrument's sensitivity. The explosimeter does
not indicate if a given atmosphere is toxic. The instru-
ment must be calibrated frequently.
B. Oxygen Detector
1) Description and Use. The oxygen detector measures the
atmospheric (>2 concentration directly by means of a gal-
vanic cell.
2) Limitations. The sensing cell in the oxygen detector has
a lifespan of approximately one year. Care must be taken
to protect the sensor from immersion or damaging blows.
C. Draeger Tubes
3-B-2
-------
1) Description and Use. The Draeger tubes and pump measure
the concentrations of specific inorganic and organic
vapors and gases which cause a discoloration that is pro-
portional to the amount of material present.
2) Limitations.. The pump must be frequently checked for
leaks. Response time is relatively slow.
D. Radiation Survey Meter
1) Brief Introduction to Health Phvsics
2) Description and Use. The radiation survey meter is a
pulse count rate meter. With the pancake detector probe,
it acts as a survey meter for alpha-beta-gamma radiation.
The Rad-Tad is used to give an audible warning in areas
containing dangerous radiation levels. The dosimeter
gives an indication of the total amount of radiation
encountered over a period of time.
3) Limitations. The radiation survey meter must be used only
by persons who have been trained in the proper interpreta-
tion of its readings. It must be frequently calibrated
and checked. The detector cannot be disconnected while
the instrument is in operation.
3. EQUIPMENT USED TO LOCATE "HOTSPOTS"
A. HNU Photoionizer
3-B-3
-------
1) Description and Use. The HNU photoionizer is used to
determine the -concentration of organic and inorganic
vapors and gases with an ionization potential (IP) of less
than 11.7 ev.
2) Limitations. The HNU photoionizer does not respond to
methane (CH/^ or hydrogen cyanide (HCN). The
instrument's sensor cannot be immersed.
B. Organic Vapor Analyzer (OVA)
1) Description and Use. The OVA provides a continuous read-
out of the total concentration of organic vapors and gases
by the use of a flame ionization detector.
2) Limitations. The OVA can be used only by specially train-
ed operators. It does not respond to inorganic vapors,
most importantly HCN.
4. EQUIPMENT USED FOR AMBIENT AJ.R CHARACTERIZATION AND SAMPLE
SCREENING
A. OVA in the Gas Chromatographic (GC) Mode
1) Description and Use. In the GC mode, the OVA is used to
characterize and identify specific organic compounds on-
site. It can be operated in conjunction with gas-tight
syringes, Mylar bags, and air sampling pumps. In this
mode it is also used to screen samples prior to submitting
them to the laboratory for analysis.
3-B-4
-------
2) Limitations. The OVA can be used only by personnel
trained in gas chromatography.
B. Charcoal and Tenax Tubes, Mylar Bags, Air Sampling Pumps
1) Description and Use. Charcoal and tenax tubes chemically
absorb organic vapors for subsequent laboratory analysis.
Mylar bags are used to collect samples of ambient air for
subsequent laboratory analysis. Intrinsically safe air
sampling pumps are used to pump ambient air into the
absorption tubes and Mylar bags.
2) Limitations. There is the possible loss of organic mater-
ial due to temperature changes, absorption on container
walls, desorption, etc.
5. STRATEGIES FOR DETERMINING THE LEVEL OF SAFETY AND CHARACTERIZING
THE AMBIENT AIR
A. Initial Site Entry
Explosimeter, 02 Meter, Radiation detector, Drager tubes
for HCN. Action levels (Refer to Table 1).
B. Ambient Air Characterization
OVA and HNU.
3-B-5
-------
FOUR HEALTH PHYSICS TRAINING OBJECTIVES:
o CHARACTERIZING RADIATION
0 USE OF SURVEY INSTRUMENTS
- PERSONNEL MONITORING
• ACTION LEVEL FOR FIELD INVESTIGATIONS
• RADIATION PROTECTION PROGRAM FOR FIT
3-B-6
-------
EXTERNAL RADIATION
I
\
\
g>
3-B-7
-------
EXTERNAL RADIATION
Some radiation goes
through the body like X-Rays...
INTERNAL RADIATION
We can receive radiation by swallowing or breathing
radioactive materials....
USB
-------
CONTAMINATION (Radioactive)
vs.
EXPOSURE
(~f or X—ray)
Roentgen (R)
' or
mill!Roentgen (mR)
I
Exposure rate (mR/hr)
3-B-9
-------
MONITORING
EQUIPMENT
EXPLOSIMETER
HAZARD
LEVEL
OXYGEN METER
EXPLOSIVE <20% LEL
ATMOSPHERE
>20% LEL
>50% LEL
OXYGEN <19.5%
RADIATION
DETECTOR
RADIATION OOMR/HR
10MR/HR
DRAEGER TUBES
HNU
PHOTOIONIZER
ORGANIC
VAPOR
ANALYZER
Arctic'
ORGANIC AND
INORGANIC
VAPORS AND
GASES
ORGANIC AND
INORGANIC
VAPORS AND
GASES
ORGANIC
VAPORS AND
GASES
>10MR/HR
SPECIES
DEPENDENT
SPECIES
DEPENDENT
SPECIES
DEPENDENT
ACTION
COMPLETE ON-SITE INSPECTION.
COMPLETE ON-SITE INSPECTION
WITH CONTINUOUS MONITORING.
EXPLOSION HAZARD; EVACUATE
IMMEDIATELY.
COMPLETE INSPECTION WITH SC8A
WITH CONTINUOUS MONITORING.
NOTE THE EXPLOSIMETER READINGS
ARE NOT VALID IN ATMOSPHERES
WITH .1l>;% OXYGEN.
COMPLETE INSPECTION.
COMPLETE INSPECTION.
COMPLETE INSPECTION WITH
CONTINUOUS MONITORING.
RADIATION HAZARD; EVACUATE
IMMEDIATELY.
CONSULT "DANGEROUS PROPERTIES
OF INDUSTRIAL MATERIALS, "BY
N. IRVING SAX.
COMPLETE INSPECTION WITH
CONTINUOUS MONITORING.
COMPLETE ON-SITE INSPECTION
WITH CONTINUOUS MONITORING.
\
o
3-B-10
-------
Federal Standard for Radiation Workers:
5 rem/yr or 3 rem/calendar quarter
whole body exposure
rern (Rem) = unit of dose equivalent
For /radiation 1 Roentgen—1 Rem
Action level = 10 mR/hr
Site Investigation — 'Worst' Case:
10 mR/hr£i10 mrem/hr
10 mrem/hr x 6 hr/da x 5 workdays/wk^SOO mrem/wk
If you worked at this level all month,
your dose equivalent—1.2 rem
—3.6 rem/quarter
>Federal Standard
3-B-ll
-------
-------
SITE SAFETY PLANS
1. INTRODUCTION
A. Rationale for a Written Safety Plan
1) A written safety plan is an indelible outline of the steps
that are to be followed. It eliminates the uncertainties
of memory and provides a checklist for preparing to go on
site.
2) A written report, prepared for someone else's review,
forces you to identify and organize the available data and
then construct a logical, coherent, and workable plan
based upon these data.
B. Levels of Safety Plan
There are four basic levels which have been described: A, B,
C, and D. All except Level A can and should be tailored to
the conditions.
1) Level A. This is rarely modified. It is used in confined
facilities or sites where there are known percutaneous
hazards. It is also used on a site where there is abso-
lutely no established history.
2) Level B. The primary piece of equipment here is the 3CBA-
MSA 401 unit. The other items listed for Level B can be
mixed, matched, added to, or eliminated as the site re-
quires. However, any change requires a justification.
3-01
-------
This level is used whenever there is any danger of a res-
piratory problem. This could mean a possible lack of
oxygen, such as the replacement of oxygen by heavier eases
generated on landfills, or the potential presence of gases
that are hazardous to breathe. This level will be used on
any site where you have enough information to eliminate
the possibility of cutaneous damage but do not have the
information necessary to identify or quantify gases which
can cause respiratory damage.
3) Level C. The most important point here is the use of the
Ultra-twin respirator. Due to the inherent liabilities of
the Ultra-twin, the Robert Shaw Escape Pack must be car-
ried at all times. The other portions can be mixed and
matched, as in Level B. The use of Level C must be just-
ified. That means, among other things, that all potential
vapors in the area must be identified and quantified.
Furthermore, Level C requires constant air monitoring in
order to justify its continued use.
4) Level D. This level is basically the use of safety shoes
and clothing that are suitable for covering the terrain
being examined. Again, this level is flexible and should
be tailored to .the individual case.
Modification of Safety Plans
Safety plans are subject to modifications by the personnel on-
site. In those cases where the danger appears to be greater
than had originally been anticipated, the site safety officer
has the option of withdrawing the team immediately or increas-
ing the level of safety immediately. Underestimating the
danger should occur very rarely. If the danger has been over-
estimated and the site can be examined at a lower level of
protection, the site safety officer has this prerogative.
However, in order to lower the safety level, the site safety
officer or the Team Leader must obtain permission. This can
be accomplished with a telephone call justifying the modifica-
tion.
3-C-2
-------
2. RESOURCES FOR DEVELOPING SITE SAFETY PLANS
A. State Agencies
The name of the relevant agency varies in different states.
Basically, however, those agencies that are concerned with
hazardous wastes and/or health will be the best source of
materi al.
B. Local Agencies
1) The local health department
2) Any county agency involved with waste management
C. Company Officials
3. DEVELOPMENT OF A SAFETY PLAN
A. Standardized Safety Floor Plan Format
Use of cover memo to explain rationale for choices in the
format.
B. Examples of Various Safety Plans, Methods of Development, and
Pertinent Information
1) Level D - "Dial-a-Safety Plan"
3-C-3
-------
a) Correlate desk information (cf. #2 above)
b) Visit State offices
c) Visit company officials
d) If a site visit is desired on a preliminary assess-
ment, decide if Level D is appropriate (by using the
above information), then call your safety officer and
explain your reasoning for entering at Level D. If
the safety officer is agreeable, then go on site. If
the safety officer is not agreeable, then scratch the
site•visi t.
e) Prepare a report detailing reasons for entry (or no
entry) and results.
2) Level B reconnaissance —"Mine Sweeping"— with a
downgrade to Level P if possible
a) Background search
b) Work plan
c) Field procedures
3-C-4
-------
d) Downgrading to Level D
e) Use of safety ropes
3) Level A - "Moonsuits"
a) Background search
b) Reconnaissance visit
c) Development of work plan and safety plan
d) Field procedures
e) Sampling
f) Cleanup
4. SUMMARY AND CONCLUSIONS
3-C-5
-------
D
-------
SITE SAFETY CONSIDERATIONS AND PERSONNEL DECONTAMINATION
STATION OPERATION PROCEDURES
1. INTRODUCTION
A. Objective
To provide an understanding of how to organize for hazardous
waste site investigations, safe entry and return from the
site, and personnel decontamination station (PDS) operations.
B. Sequence of Presentation
o Organization of the field investigation area
o Organization for work
o Entry to the hazardous site
o Site safety procedures
o Exit from the hazardous site
o Decontamination procedures
o Closing the personnel decontamination station
2. EXPLANATION
A. Organization of the Field Investigation Area
1) Hazardous waste site
a) Definition
3-D-l
-------
b) Perform reconnaissance
c) Determine boundaries
2) Exclusion (control) area
a) Buffer zone around hazardous site
b) Contain gross contamination within the area
c) Always treat as contaminated
d) Size may be adjusted
3) Hot Line
a) Upwind of hazardous site
b) Arbitrary line on ground
3-D-2
-------
c) Should be visually obvious
d) Deliberate attempt to control contamination
e) Location may be adjusted
4) Access Control Points
a) Points to control entrv and exit from hazardous site
b) Proper protective equipment required
5) Contamination Reduction Area
a) Every effort made to remove all contamination
b) Set up in clean and clear area
c) Contains the Personnel Decontamination Station (PDS)
3-D-3
-------
6) Contamination Control Line
a) Separates contaminated zone from clean area
b) Arbitrary line on ground
7) Administrative area
a) Houses command post and all support functions
b) Located unwind of PDS
B. Organization for Work
1) One example of how to organize for a worst-case
situation.
2) Team Leader - Duties and responsibilities
3) Equipment Man/PDS Operator - Duties and responsibilities
4) Safety Officer - Duties and responsibilities
3-D-4
-------
5) Work Party - Duties and responsibilities
C. Entrv to the Hazardous Site
1) Brief work party
2) Check wind direction
3) Check and bag equipment
4) Check protective equipment
5) Communication checks
6) Entry
7) Maintain contact
3-D-5
-------
D. Site Safety Procedures
1) Observe buddy system
2) Be deliberate in actions
3) Maintain contact
4) Practice contamination avoidance
5) Follow predesignated routes
6) Characterize site
a) Radiation
b) Oxygen levels
c) Explosive hazard
3-D-6
-------
d ) Buried metal
7) Monitoring weather conditions
E. Exit from the Hazardous Site
1) Exit time is pre-planned based upon air suoply available
2) Leave contamination at site
3) Be deliberate in actions
4) Observe buddy system
F. Decontamination Procedures
(Refer to graphic representation provided.)
G. Closing the Personnel Decontamination Station
1) Hot-line personnel perform equipment decon
3-D-7
-------
2) DisDose of expendable wastes and decon solutions on site
3) Decontaminate protective clothing so that it's ready for
future use
3-D-8
-------
SEQUENCE OF PRESENTATION
FIELD OPERATIONS AND DECONTAMINATION PROCEDURES
• ORGANIZATION OF THE FIELD INVESTIGATION AREA
HAZARDOUS WASTE SITE
EXCLUSION AREA (CONTROL AREA)
CONTAMINATION REDUCTION AREA
SUPPORT AREA {ADMINISTRATION AREA)
« ORGANIZATION FOR WORK
• ENTRY TO THE HAZARDOUS SITE
• SITE SAFETY PROCEDURES IN HAZARDOUS AREA
• EGRESS FROM THE HAZARDOUS SITE
• PDS PROCEDURES (DECONTAMINATION)
• CLOSING THE PDS
3-D-9
-------
ORGANIZATION OF THE FIELD INVESTIGATION AREA
N
HOTLINE-
\
CONTAMINATION-
CONTROL LINE
ESTIMATED
BOUNDARY
DISTANCE VARIES
ACCESS
CONTROL
POINT
ACCESS
CONTROL
POINT
PERSONNEL DECON STATION
(PDS)
EXCLUSION AREA
(CONTROL AREA)
"HOT-
HOTLINE
—^
-=i40M-
CONTAMINATION ^^.
CONTROL LINE '
CONTAMINATION
REDUCTION AREA
IHOT7)
WIND DIRECTION
200
20°
COMMAND POST
(CP)
3-D-10
-------
SITE SAFETY PROCEDURES
OBSERVE BUDDY SYSTEM
PLAN YOUR ACTIONS BE DELIBERATE
MAINTAIN CONTACT WITH SAFETY OFFICER
PRACTICE CONTAMINATION AVOIDANCE
DONT SIT OR KNEEL ON GROUND
DON'T GROUND EQUIPMENT
AVOID OBVIOUS CONTAMINATION
DON'T CLIMB OVER BARRELS OR OBSTACLES
FOLLOW PREDISIGNATED ROUTES
MONITOR (AS REQUIRED) FOR
RADIATION
O2 LEVELS
EXPLOSIVE HAZARD
BURIED METAL
MONITOR WEATHER CONDITIONS
HEAT STRESS
COLD (FROSTBITE)
ELECTRICAL STORMS
WIND DIRECTION
p
• 3
3-D-13
-------
EGRESS FROM THE HAZARDOUS SITE
• EGRESS IS A PLANNED ACTION NOT A NECESSITY
• DECONTAMINATE KNOWN CONTAMINATION (I.E., GLOVES) AT
THE SITE
• MAINTAIN CONTACT WITH SAFETY OFFICER
• BE DELIBERATE
• DON'T LEAVE THE SITE ALONE
3-D-14
-------
TYPICAL LAYOUT OF THE PDS
(LEVEL A PROTECTION)
WIND DIRECTION
EQUIPMENT
DROP
1
H
PLASTIC
SHEET
TANK CHANGE-OVER POINT
B X C 0 E F
DECON
OUTER
GARMENT
REMOVE DSCON R,NSE JL "BE^B
-^ nnnr R^OTS BOOTS /\>A^ ^Mn
COvlL AND AND -Q9^ OUTER "*"
GLOVES GLOVES GARMENTS
Uj ^ ^ \^
DECON™' '^/VATER t| Srf.. ^^ ^^ > — /
SOLUTION CAN DECON SOLUTION WATER CAN
M10 GALLON) (10 GALLON) (10 GALLON) (32 GALLON)
(WASH TUBS) •
G H I J
REMOVE
11 INNER RFDRF«
_. ^ REMOVE GLOVES, FIELD ImcT
SC8A SOCKS, AND SHOWER *" Am
COTTON AID
CLOTHES
PLASTIC
SHEET
b
FIELD
EXPEDIENT
CAN
(32 GALLON)
\m
\
—
a
r
' ^
3-D-15
-------
CLOSURE OF PDS
• HOT LINE PERSONNEL PERFORM EQUIPMENT DECON
• DISPOSE OF EXPENDABLE WASTE AND DECON SOLUTIONS
ON-SITE
• DECON PROTECTIVE EQUIPMENT FOR FUTURE USE
•i
3-D-16
-------
-------
FIELD SAMPLING
1. OBJECTIVE
The objective of this discussion is to present an overview of pro-
cedures and equipment for field environmental and hazardous waste
sampling.
2. SAMPLING PLAN
A. General Considerations
1) The uniqueness of many sites calls for imagination in ob-
taining samples.
2) A sampling plan should be developed for the number, types,
and potential locations of samples.
3) Development of a plan makes it possible to anticipate the
sample containers and preservation techniques needed.
B. Criteria for Plan Development
1) Objectives of field investigation
3-E-l
-------
2), Personnel safety
3) Background information on the site
4) Potential for off-site migration of contaminants
5) Constraints of laboratory availability and cost-
effectiveness .
C. Case Study - Surface Water Sampling Plan
D. Determination of Sampling Location
1) Surface Water
a) Rivers, brooks, or streams running through or adjacent
to the leach stream
b) Site surface impoundment
c) Upstream sample for background
2) Soil
a) Stains from spills or leaks
3-E-2
-------
b) Low-running or non-running leachate seeps
c) Subsurface samples
3) Groundwater
a) Existing monitoring wells on site
b) Residential, municipal, or commercial wells close to
site
4) Air
a) Upwind
b) Downwind
5) Hazardous Samples
a) Open drums or containers
b) Closed drums or containers
3-E-3
-------
c) Surface impoundments
d) Saturated soil
3. WATER QUALITY SAMPLING
A. Surface Water
1) Surface Water Parameters/Equipment
a) pH meter - used to help establish general water
quality, e.g., pH can affect solubility of agents mi-
grating off site
b) Conductivity meter - used to indicate presence of sus-
pended/dissolved agents migrating off site
2) Surface Water Sampling Equipment
a) Containers - For purgeable organics, use 40-ml vials
with Teflon-backed septa; must be laboratory cleaned
and dried. For metals, use high-density linear poly-
ethylene wide-mouth 8 oz. bottles. For priority pol-
lutant analysis, use half-gallon bottles. 500 ml
polyethylene bottles and 16 oz. wide mouth iars can be
used for other parameters.
3-E-4
-------
b) Glass cubing - Lengths of 6 to 8 mm glass tubing can
be used with a pi pet bulb to obtain samples from
streams with low flow; must be lab cleaned and dried.
c) Pond/lagoon sampler - Teflon container attached to
telescoping aluminum handle or wooden dowel for safely
obtaining samples form the shore of a pond or lagoon.
3) Sampling Methods
a) Most surface water samples for hazardous waste site
are grab samples.
b) For stream samples, container may be inznersed direct-
ly. For low-flowing leachate stream, glass pi pet may
be used.
For .pond/lagoon sampling, divide surface area into
grids. Try to obtain samples fro-n several depths and
from the sediment.
d) Sample preservation is best accomplished by placing in
cooler. Bi©degradation may be a problem with organ-
ics. Mercuric chloride may be used if long holding
time is anticipated.
e) Field blanks of organic-free water should be used for
quality control.
3-E-5
-------
B. Groundwater Sampling
1 ) Groundwater Parameters
a) Water depth indicator equipment - to establish static
level of well for determining well volume.
b) Well logs, if available from driller, may be used to
provide information about depth of well - again to
help determine well volume.
2) Groundwater Sampling Equipment
a) Air drive pump - Used to discharge well.
b) Bailers - Used to obtain samples; must be chemically
i nert.
c ) Multi-level sampling devices (Bar-Cad) - May be used
to obtain samples for vertical profiles of groundwater
contamination.
3) Sampling Methods
a) Important to discharge static water in well to obtain
true groundwater sample. Discharge of 2 or 3 volumes
is perferable. Extensive sampling programs may in-
volve longer pumping periods.
3-E-6
-------
b) Chemically inert bailers (teflon/copper) must be used
for organics. Rinse with methanol prior to obtaining
s ample.
4. SOIL SAMPLING
A. Soil Sampling Parameters/Equipment. Type of soil determines
type of equipment.
B. Soil Sampling Equipment
1) For surface soil samples of obviously stained areas, dis-
posable scoops or tongue depressors may be used.
2) A Cu/Be shovel may be. used to obtain a quick subsurface
s amp 1e.
3) A trier may be used to obtain a core sample.
4) Augers may be used to obtain deep soil samples.
C. Soil Sampling Methods
1) Divide surface area into grids; sample from each grid to
obtain composite soil, sample. 40 ml VOA vials or wide-
mouth 8-oz. glass jars may be used.
3-E-7
-------
2) Non-disposable items must be decontaminated.
5. CONCENTRATED HAZARDOUS WASTE SAMPLES
A. Liquid Samples from Drums (open), Lagoons, Tanks, Manholes, etc
1) Sampling Equipment
a) Glass tubing with pi pet bulbs
b) Evacuated sidearm flask attached to plastic tubing
c) Non-sparking hand vacuum pumps to withdraw samples
from containers
d) Sample containers attached to a long handle
e) For open containers, use 8 oz. glass bottle with bake-
lite caps, teflon liners. Leave 10% ullage.
f) Use 40 ml septum vial for closed container
B. Solid Hazardous Waste Samples
3-E-8
-------
1) Parameters - material exposed to air, water may be stabi1-
i zed.
2) Equipment and methods for obtaining solid samples are
similar to those for obtaining soil sample, i.e., grid
system, triers, disposable scoops.
6. PACKAGING, LABELING AND SHIPPING SAMPLES
A. DOT Regulations
B. Packaging Equipment
1) Sample bottles - small glass bottles, teflon-lined caps,
10% ullage to allow for expansion
2) Metal 1 gallon paint cans packed with zonolite or vermicu-
lite to absorb shock or absorb spills.
3) Coleman coolers to contain paint cans.
4) Steel gas cylinders with zonolite/vermiculite for hazar-
dous samples from closed containers; lower sample con-
tainer into cylinder with string.
5) Affix appropriate labels and enclose chain of custody
form.
3-E-9
-------
61-100 en:.
(24-40")
0
1.27-2.5^ en (%-!")
101.6 cm (40")
z- a
5.08 en (2")
Soil auser.
3-E-10
-------
-Varirrip cla~p
Bolt hole
Beaker, polyprop-
ylene, 250 nl
'(1 qt)
J L
7
Pole, telescoping, aluminum, hesvy
duty, 250-^50 CIE (96-180")
.-.-. snar
Eve let
Pin
lOOC-ml (1 -quart) weighted
bottle catcher
Weizhced bottle sanoler.
3-E-ll
-------
0510
,73
'••'-'•
"'
^_
••Cj
,
"
t f
-5'
-s
~sy
^
n
dh/
cf.—chiin ^.hich inc'non i*pp! g^i; a-d cr<;i'.r; ir r,-.-,r
:: -su-r c^ .;r;-i: rod
uv—L;:C: val.c
STRUCTURAL FEATURES OF MODIFIED KEKKERER SAMPLER
(P.S. Welch, L'-nolocical Methods, p. 200. Figure 53.)
3-E-12
-------
,< s. f
r .,
jL 3 41
"
'I1-
'-^ "i
'. - ~ - ->' 'i 1 S .'•' Or Ali - . ~ •— i ~ ,
3-E-13
-------
RANDOM SA:-!?LING
03
97
16
12
55
16
84
63
33
57
18
26
23
52
37
70
56
99
16
31
-10W 1C
L. 3a
sa
I. Nu
Su
3. De
47
74
76
56
59
22
42
01
21
60
IS
62
42
. 36
85
29
62
49
OS
1 n
L'SE
sed
cks ,
S ~ T-
arti
cice
43
24
62
85
56
77
17
63
12
86
07
38
40
2.8
94
17
18
57
15
93
TKF
on av
etc.
^i
per f r
1 ' o * -
on h
73 86
67 • 62
27 66
99 26
35 64
94 39
53 31
78 59
34 29
32 44
92 46
97 75
64 74
19 95
35 12
12 13
37 35
22 77
04 72
32 43
TABLE OF
ailable
) accord
con^~a"*ne
om 01.
ow many
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lance sa—Dling, the collection of one or tvo sarypies is -.'.sur-lly
adequate. In this case, randon: sa-pling is not necessary. But for
regulatory or research p-urpcses, mere samples (such as one sa~pie for
every group of five containers) taken at random will generate -.ore
statistically valid data. Hence if there were 20 drums containing
the same type of vasue, 5 drums have to be sampled.
Using the set of random numbers above, choose any number as a starting
point.
From this number, go dovn the column, then to the next column to the
right, or go in 'any predetermined direction ••.inc.il you havei selected
five numbers between 01 and 20, with no re^eti vi ns. Larger numbers
are ineligible. - -
Example: If vou were to choose 19 as the stsrcirsg point on column
four, the next eligible numbers as you go down this
column are 12 and 04. So far you have chosen only three
bl& numbers. Proceed to the next column to the right.
down "and starting from the top of this column, the
next eligible numbers are 12 and 13. But 12 is already
chosen. Proceeding to the sixth column, the next eligible
••-••-.r.ber" is 16. Your five random numbers, therefore, are
19, 12, 04, 13 and 16. Thus the drums with corriiponding
numbers have to be sampled. 3-E-14
-------
-------
EMERGENCY PREPAREDNESS
1. INTRODUCTION
A. Need for Emergency Preparedness
Murphy's Laws are always in effect
B . Advanc ed P1 jmni_n g
1 ) Use of Safety Plan
2) Training of Individual Team Members
3) Medical Surveillance and Information on Team Members
A) Availability of Emergency Equipment
C. Anticipation of Problems: Use of preliminary assessments to
determine potential physical problems that the Team Members
will face.
2. TYPES OF EMERGENCIES
A. Medical Emergencies
3-F-l
-------
5) Heat Exhaustion
6) Frost Bite
7) Stroke
B. Accidents
1) Broken bones
2) Burns
3) Sprains
4) Puncture wounds
C. Equipment Problems
1) Leaks in the Eastwind butyl rubber suit
3-F-2
-------
2) Failure of the MSA 401 SCBA
3) SCBA failure when in butyl rubber suit
4) Failure of the Ultra Twin respirator
3. ADVANCED PLANNING
A. Escape Routes
1) On-site escape - rapid evacuation from hot area to safe
area.
2) Off-site escape - best means for evacuation from site
in case of catastrophe.
B. Line of Sight
A continuous line of sight must be maintained between work
party at advanced oortions of hot area and the PDS Operator or
the Safety Officer.
1) If men are stationed beyond the PDS in order to maintain
the line of sight with the work party, they must be
appropriately dressed.
3-F-3
-------
2) Safety Officer must be dressed to same degree as the work
party in order to provide an extra man for any needed
rescue effort.
C. Rapid Communication between Work Party and Safety Officer
Work party members must have system for rapid and clear
distress call back to Safety Officer.
D. Telephone Numbers and Location of Emergency Services
1) Local Police Department
2) Local Ambulance Service
3) Local Hospital
4) Local Fire Department
5) Poison Control Center
E. Adequate and Clear Directions to the Site from the Locality of
the Local Fire Department, Police Department, and Hospital
3-F-4
-------
F. Safety Training
1) First Aid Training
2) CPR
3) Rapid removal of incapacitated team member
4) Special treatment in decontaminating procedures to be used
on injured persons.
4. ANTICIPATION OF PROBLEMS
A. Thorough Knowledge of Site
B. Thorough Knowledge of Expected Weather Conditions
C. Thorough Understanding of Task to be Performed
D. Thorough Briefing of ALL Team Members on ALL Aspects of the
Tasks
3-F-5
-------
5. SUMMARY AND'CONCLUSIONS
3-F-6
-------
DAY 4
-------
-------
STATION #1
LOCATION AND SETUP OF COMMAND POST;
DRESS OUT
1. INTRODUCTION
Objectives . The objectives of Station I of the Field Exercise
are. to briefly discuss and present the equipment carried on
the FIT Van, to discuss the method by which levels of
protection are arrived at, to discuss on-site communications,
to dress out in the various levels of protection; to disc uss
the layout on the Command Post (CP), and to discuss and
practice emergency evacuation.
2. CP Layout The FIT Van serves as the primary piece of
equipment in the Command Post (CP) and is the nerve center for
on-site operations. Criteria for selecting a CP location
include:
a. Wind direction
b. Terrain (line-of-si ght, avenues of approach,
Ingress and Egress)
c. Site location (ownership)
d. Location of roads, power lines, and developed areas.
e. Location of water and power
f. Location of inhabitants
3. FIT VAN EQUIPMENT
This will consist of a rapid overview of the equipment contained
on and in a FIT Van. The equipment will be displayed and avail-
able for hands-on use as times permits.
4-A-l
-------
4. COMMUNICATIONS
A. Equipment
1) CB and UHF Radios
2) Other methods (horn, bell, flags, boards). Limited only
by your imagination and the resources available.
B. Procedures
1) Radio
2) Hand Signals, etc.
5. PERSONNEL AND PERSONAL PROTECTION
A. Level D - (Demonstration)
B. Level C - (Dress out of 1 individual by attendees)
C. Level B - (Dress out of 1 individual by attendees)
D. Level A -
1) Dress Out Procedures - 1 Individual
2) Airtank Change
3) Stress Factors
4) Attendees Dress Out in Modified Level A
4-A-2
-------
6. EMERGENCY EVACUATION
A. SITUATIONS
1) Physical Injury
2) Equipment Failure
3) Panic or Distress
B. METHODS
1) Safety Officer
2) Emergency Response Team
3) Buddy System
C. EQUIPMENT
1) Wheelbarrow
2) Stretcher
3) Field Expedient Stretcher
4) Boards
5) Blanket
6) One-Man Carry/Drag
7) Harnesses
8) . Swiss Seat
4-A-3
-------
ATTACHMENT TO STATION #1
GENERAL SITE SAFETY PROCEDURES
1. INTRODUCTION
General site safety procedures are intended to protect individuals
engaged in on-site activities. Compliance with established safety
procedures is unquestionably one of the primary responsibilities
of on-site personnel.
2. GENERAL SITE SAFETY PROCEDURES LIST
A. Plan site activities thoroughly ahead of time: Enter the site
only to get to a designated point by a designated route for a
specific purpose.
B. Always observe the buddy system: Never enter or exit a site
alone, and never work alone in an isolated area.
C. Always maintain contact with the Site Safety Officer and Com-
mand Post.
D. Practice contamination avoidance: Never sit down or kneel;
never ground equipment; avoid obvious sources of contamina-
tion such as puddles; avoid unnecessary contact with on-site.
objects.
E. Decontaminate known sources of contamination (such as gloves
and boots) at the site.
F. Keep track of weather conditions and wind direction.
G. Never climb over or under refuse or obstacles.
H. Never assume that a situation is as safe as it appears to be.
I. Be alert to any unusual behavior on the part of other team
members which might indicate distress, disorientation, or
other ill effects.
J. Be alert to any unusual changes in your own condition; never
ignore warning signs or hesitate to report them at once.
4-A-4
-------
K. No eating, drinking or smoking pass the Contamination Control
Line. This includes team members at the Personnel Decontamin-
ation Station and members of the Emergency Response Team.
Avoid all hand to mouth contact while contamination of your
clothing or body is possible (i.e., until after showering).
Any open wounds must be covered with an air tight bandage;
ideally, someone with an open wound should not enter the site.
Persons with lesions or sores in the mouth will not enter the
site.
4-A-5
-------
COMMUNICATION PROCEDURES
1. GENERAL CONSIDERATIONS
A. Do not use CB lingo
B. Use standard procedures and nomenclature.
1) .Begin each transmission by identifying the party you are
trying to reach; then identify yourself.
2) Wait for acknowledgement.
3) Talk plainly, enunciate each word.
4) End each transmission with "over".
5) Phonetic alphabet is given on the following page.
2. RECOMMENDED CALL SIGNS
A. Command Post (CP) - EAGLE LEADER
B. Safety Man/PDS - EAGLE SAFETY
C. Work Parties - RECON ALPHA, RECON BRAVO, etc.
3. TYPICAL TRANSMISSIONS
A. "Recon Alpha, this is Eagle Leader. Over."
"Eagle Leader, this is Recon Alpha. Over."
B. "Recon Alpha, you have been at the site 10 minuites. Begin
your exit in 5 minutes. Over."
C. "Eagle Leader, I understand your transmission and will
comply. Over."
D. "Recon Alpha, this is Eagle Leader. Out."
NOTE: The party that originated the first transmission is the
only party that can terminate the discussion.
4-A-6
-------
PHONETIC ALPHABET
Letters
A — Alpha
B — Bravo
C — Charlie
D — Delta
E — Echo
F — Foxtrot
G — Golf
H — Hotel
I — India
J — Juliet
K - Kilo
L — Lima
M — Mike
N — November
0 — Oscar
P — Poppa
Q — Quebec
R — Romeo
S — Sierra
T — Tango
U — Uniform
V — Victor
W — Whiskey
X — X-ray
Y — Yankee
Z — Zulu
Numbers
1
2
3
4
5 (say Fiver)
6
7
8
9 (say Niner)
0 (say Zero)
4-A-7
-------
B
-------
STATION #2
EQUIPMENT OPERATIONS
1. OBJECTIVE
To demonstrate the problems associated with the field use of the
instruments discussed in Tuesday's lecture on air characteriza-
tion and field sampling.
2. DESCRIPTION OF EXERCISE
A. The participants will dress in tyvec suits, with disposable
rubber gloves, and will wear the SCBA. Following a brief.
review of the operation of the instruments each person will
receive one or more pieces of the equipment.
B. The following exercises will be performed:
1) The response of the explosimeter, Draeger tubes, the HNU
photoionizer, and the OVA to methane and acetone.
2) The response of the oxygen meter to methane (oxygen defi-
ciencv)
3) The response of the thyac to a radiation source.
4) Differentiation between methane and an industrial solvent
(acetone)
5 ) Operation of the metal detector
6) Operation of the resistivity meter
4-B-l
-------
MSA MODEL 2A. EXPLOSIM5TER
1. GENERAL DESCRIPTION AND APPLICATION OF THE INSTRUMENT
The instrument is used to test an atmosphere for concentration of
flammable gases and vapors, so that the appropriate decisions can
be made about personnel safety on a site. Tests are made with the
instrument by drawing a sample of the atmosphere over a heated
catalytic filament which forms part of a balanced electrical
circuit. Combustibles are burned on the filament which raises its
resistance in proportion to the concentration of combustibles in
the sample. The resulting unbalance of the circuit cases a
deflection of the meter pointer which indicates on the scale the
concentration of combustible gases or vapors in the sample. The
scale is graduated in percent of the lower explosive limit.
2. OPERATING INSTRUCTIONS
In an area known to be free of combustible gases or vapors,
prepare the explosimeter for operation as follows:
A. Lift the end of the rheostat on/off bar and turn the rheostat
knob one quarter turn clockwise. The meter pointer will move
rapidly upscale and then return to zero or less than zero.
B. Flush fresh air through the instrument by squeezing the
aspirator blub five times.
Adjust the rheostat knob until the meter pointer rests at
zero. Clockwise rotation of the knob causes the meter pointer
to move up scale. Avoid clockwise turning which results in
moving the pointer much above zero, as this may shorten the
life of the detector filament.
D. Place the end of the sampling line at the point where the
sample is to be taken.
E. Aspirate the sample through the instrument until the highest
reading is obtained. Five squeezes of the bulb are usually
sufficient to give maximum deflection.
4-B-2
-------
The graduations on the scale of the meter are in percent of
the lower explosive limit. A deflection of the meter pointer
between zero and 100% shows how closely the atmosphere being
tested approaches the minimum concentration required for the
explosion. *When a test is made and the pointer is deflected
to the extreme right side of the scale and remains there, then
the atmosphere under test is explosive. *If the pointer moves
rapidly across the scale and on continued aspiration quickly
returns to a position within the scale range or below zero, it
is an indication that the concentration of flammable gases or
vapors may be above the upper explosive limit.
F. Do not turn the instrument off until you have left the
atmosphere being tested and you have flushed the instrument
with fresh air.
LIMITATIONS AND WARNINGS
A. The instrument is not designed to work in an oxygen-enriched
environment (02 above 25%) nor will it function properly in
an oxygen-deficient atmosphere (below 19.5%). Therefore it
should be used in conjunction with the oxygen meter to monitor
the oxygen concentration.
B. The instrument will not indicate the presence of explosive or
combustible mists or sprays such as lubrication oil or
explosive dusts such as grain or coal dusts.
C. Care should be taken when sampling over liquids. Do not draw
liquids into the instrument.
D. The following substances may "poison" the detection filament:
leaded gasoline, silanes, silicones, silicates, or any silicon
containing compound.
E. The relative humidity must be in the range of 10-90%.
F. The instrument has a tolerance of +40%. For example, a
reading of 20% LEL could be as high as~28% or as low .as 12%.
4-B-3
-------
G. Do not switch the instrument on or off unless you are in a
known combustible-free atmosphere.
H. The explosive limits for many gases and vapors are way above
the TLV1s for those substances.
I. Fuming acids will also "poison" the detection filament.
4. STANDARD OPERATING PROCEDURE GUIDELINES
A. If the % LEL is ^20% - complete on site inspection.
B. If the % LEL is >20% - conduct careful survey to determine the
source if possible
C. If the . % LEL is >50% - withdraw immediately and notify the
fire department.
4-B-4
-------
DRAEGER TUBE AIR GRAB SAMPLER
1. GENERAL DESCRIPTION AND APPLICATION OF THE INSTRUMENT
The Drager Tube Air Grab Sampler consists of a bellows pump for
drawing air and detector tubes which are chosen as a function of
the measurement to be carried out. The detector tubes are
available for a variety of gases and concentration ranges, but
this may be best described as a semi-quantitative method. There
are detector tubes available for gases which are not detected by
the organic vapor analyzer and which would actually poison the
filament of the explosimeter and oxygen indicator. Some examples
would be hydrogen sulfide, sulfur dioxide, sulfur trioxide
hydrogen chloride, hydrogen cyanide and chloride. The presence of
any of these would obviously affect the level of protection needed
on site. However, there must be sufficient background information
available which would help determine the identity of the
substances so that the proper tube could be selected.
The test is performed by drawing air through the detector tube and
observing a color change or stain in the tube. . Scale markings on
the tube enable determinations of subsurface concentration.
2, OPERATION OF THE INSTRUMENT
A. Break off both tips of the Draeger tube in the break-off
eyelet or in the break-off hust.
B. Insert the tube tightly into the pump head with the arrow
pointing toward the pump.
C. Fully compress the bellows.
Straighten the fingers. The suction process takes place
automatically and is completed when the limit chain is taut.
(The bellows is calibrated to draw in 100 cm^ of air per
stroke. Since the suction of the pump is caused only by the
relaxation of the springs, any subjective influence is
excluded. )
Repeat the suction process as often as specified in the Tube
Operating Instructions. (The nature of the tube filling will
vary the resistance of the air coming through the tube, and
the "opening time" of the bellows is therefore affected.
Range of time is 3 - 40 seconds.)
4-B-5
-------
F. Evaluate the indication as decribed in the tube operating
instructions.
G. Remove the spent tube and dispose of it on site.
H. .Before putting the bellows pump away, flush it out with air,
making a few strokes without a detector tube in a clean
environment.
3. LIMITATION AND WARNINGS
A. Try to establish from background information (interviews,
etc.) the nature of the site contaminants so that an
intelligent selection of a Draeger tube may be made.
When drawing air into a tube, keep your eyes on the tube to
note any color change or stain development. For example, if
you have selected a hydrogen sulfide tube with a sensitivity
range of 0.5 to 1.5 ppm, requiring 10 strokes, and you are in
an atmosphere of much higher concentration, the tube will
quickly become fully developed after only one or two strokes.
C. Read the tube immediately upon completion of the last stroke.
Elapsed time may affect the true reading.
D. Some tubes require that an ampule within the tube be broken to
release a reagent before air is drawn through.
E. Because the tubes contain silica gel, high humidity may affect
results.
F. Many types of tubes have cross sensitivities to other
substances and. will therefore give incorrect readings in
atmospheres containing substances other than the gas being
measured. These cross sensitivities are the result of several
interactions.
4-B-6
-------
MSA MODEL 245R OXYGEN INDICATOR
1. GENERAL DESCRIPTION AND APPLICATION OF THE INSTRUMENT
The oxygen indicator provides a quick and simple way to determine
the concentration of atmospheric oxygen on site, which is essen-
tial to consider in making a decision about the level of respira-
tory protection required for site inspection personnel. Its use
in conjunction with the explosimeter also renders information
about the explosivity of the site atmosphere., i.e., as the upper
explosive limit is reached in an atmosphere, the oxygen level
decreases. The oxygen indicator also establishes the limits of
oxygen concentration in which the explosmeter can function proper-
. ly, i.e., 19.5% - 25%.
The actual sensing device consists of an oxygen specific perme-
able membrane which allows oxygen to pass into the sensor until
the partial pressures equalize on both sides of the membrane.
Once the oxygen is inside the sensor, there is an electrolyte
solution which surrounds two electrodes. An oxidation-reduction
reaction occurs in which the amount of current generated is di-
rectly proportional to the oxygen concentration. The change in
current is detected by the meter circuit and the needle is cali-
brated to indicate oxygen concentration in percent which is read
out directly.
2. CALIBRATION
The sensor is temperature-compensated from 32°F to 104°F. The
indicator response time is increased in temperatures beyond the
compensated range, partially below 32°F.
To calibrate, press the button on the right side of the case and
expose the sensor to fresh air, allow the sensor to be exposed to
fresh air until the meter reading stablizes, then set the meter at
the 20.8% mark by rotating the calibration screw at top of the
indicator case. The calibration is quite stable over long periods
of time and will not require large connections until the end of
the useful life of the sensor is reached. A need for more fre-
quent and larger calibration is indicative of the need for sensor
replacement.
OPERATION
After checking the reading of the indicator with fresh air, place
the sensor in the atmosphere to be tested, press the button on the
right side of the case, and read the oxygen concentration. In
sample areas were the temperature is not constant (changes by more
4-8-7
-------
than 30°F) or in sampling atmospheres that differ in temperature
from that of calibration air (by more than 30°F) the fresh-air
reading should be rechecked every hour to obtain the greatest
accuracy possible.
LIMITATIONS AND WARNING
A. Condensation of moisture on the sensor face will cause low
02 readings. To avoid this problem, allow the sensor to
reach ambient temperature before taking readings.
B. Strong oxidants such as fluorine, chlorine, and ozone will
lead to erroneously high oxygen readings when these are
present in concentrations exceeding 5,000 ppm or 0.5%.
C. Concentrations of C02 greater than 1% will reduce sensor
life.
Changes in barometric pressure due to altitude will also have
an effect on the meter reading. The instrument is calibrated
for 20'.8% 02 at sea level (1 atmopshere). At higher alti-
tudes, the meter will therefore indicate a lower percentage of
oxygen by volume; however, adequate oxygen to sustain life is
dependent on partial pressure rather than percentage by volume
and a lower reading at a higher altitude, is acceptable. We
will anticipate this situation by consulting topographical
maps of sites prior to inspection and inform the staff of
necessary compensation for the oxygen indicator.
E. Relative humidity operating range is 10 - 90%.
F. Avoid touching sensor with hand or sharp objects, the membrane
is easily damaged.
G. Acid mists or other corrosive atmospheres poison the probe.
H. Check atmosphere for explosivity before activating oxygen
indicator.
4-B-8
-------
5. STANDARD OPERATING PROCEDURES GUIDELINES
If the oxygen level is ^19.5%, continue inspection with SCBA and
identify oxygen-deficient area.
If the oxygen level is >19.5%, continue inspection; cartridge
respirator may be allowed if other parameters permit.
4-B-9
-------
FISHER M-SCOPE MODEL TW-5 METAL DETECTOR
1. GENERAL DESCRIPTION
The detector consists of the instrument itself, a carrying case, and
an aluminum handle. It detects the presence of buried metal objects
through the use of an induced electromagnetic field. The instrument
consists of two principal components: (1) a directional radio-type
transmitter and (2) a directional radio-type receiver. The function
of the transmitter is to generate an electromagnetic field in a buried
metal object, either through inductive or conductive methods. The
directional radio receiver locates the metal object by detecting and
tracing this field.
2. USE AND OPERATION
Refer to the operating manual for detailed instructions on assembly
and maintenance. To locate a buried metal object such as a drum, the
suspected area should be traversed systematically at intervals of
three to seven feet. The object will be indicated by elevation in
speaker' tone and meter reading. Once the object has been
approximately located, it may be pinpointed by holding the instrument
in normal horizontal operating position and, while standing in one
spot, slowly rotating the instrument through a 360° horizontal
circle. If the operator's feet are directly over the object,
variations in speaker tone and meter reading will be minimal. If not
directly over the object, the operator will get a fluctuating
reading.
3. MAINTENANCE
Batteries should be checked at least monthly. Spare batteries (type
NEDA 1603 9-volt, paperclad) should be obtained.
Before each use, the unit should be checked out over some known buried
object.
4-B-10
-------
VICTOREEN MODEL 490 THYAC III SURVEY METER
1. GENERAL DESCRIPTION
The Model 490 is a pulses-count ratemeter and power supply. With the
pancake detector probe, it acts as a survey meter for aIpha-beta-gamma
radiation. Operation range is 0-80,000 cpm or 0-20 mr/hr approximate
radiation intensity with appropriate detector.
2. USE AND OPERATION
This instrument should be used only by persons who have been trained
in the proper interpretation of its readings and the appropriate
safety procedures to be followed in the presence of radiation.
Failure to follow instructions may result in inaccurate readings
and/or user hazard. Indicated battery and operational (checksource)
tests must be performed prior to each use to assure that the instru-
ment is functioning properly. Failure to conduct periodic performance
tests in accordance with ANSI N323-1978, paragraphs 4.6 and 5.4, and
to keep records thereof in accordance with paragraph 4.5 of the same
standard, could result in erroneous readings of potential danger. Do
not connect or disconnect any detector while the instrument is on.
Wait two minutes after it is turned off before connecting or discon-
necting any detector. Failure of transistors will occur if the in-
structions are not followed.
The ratemeter is designed for 100 hours continuous use on two "D"
cells and longer with intermittent use. It requires trained personnel
to interpret readings. Be sure to read the instruction manual before
using. The instrument is in a weather proof case, which contains the
twooperating controls on top, the function switch, and response
switch.
A low-intensity beta checksource is provided on the case. Temperature
limits are -30° to +50°C (limit's for batteries may be different).
May be used with headset or audio speaker. May be put in plastic bag
when appropriate to prevent contamiantion.
3. MAINTENANCE
Do not store with batteries in instrument. Replace batteries as indi-
cated during the battery check done before each use. Recalibrate
periodically.
4-B-ll
-------
-------
STATION #3
DOWNRANGE CONSIDERATIONS
1. OBJECTIVE
The objective of the Downrange Considerations practical ex-
ercise is to provide an opportunity to experience the
problems associated with operations in a toxic atmosphere.
Through participation in an actual sampling exercise under
simulated toxic conditions, the attendees will develop an
appreciation for the planning, organizing, equipping, and
physical hardships of operations in a toxic environment.
2. DEMONSTRATION
A. Using an attendee, the limitations associated with the wearing
of protective equipment will be demonstrated.
B. Identification of an individual dressed in protective clothing
is difficult.
1) Positive identification of entry party members is essen-
tial for control and safety.
2) Identify by system such as:
a) Marking with colored tape
b) Masking tape with name marked by felt tip marker
c) Names marked on hard hats
d) Names written on protective clothing
3) Be sure to put marking in spot visible even when all gear
is being worn.
4-C-l
-------
C. Demonstration of simple problems associated with protective
clothing.
D. Demonstration of visual acuity problems encountered while
wearing a protective mask.
E. Demonstration of dexterity problems encountered while wearing
protective gloves.
F. Summary of teaching point for the class.
1) As you increase the use of protective equipment you:
a). Decrease the ability of the individual to perform
simple tasks.
b) Decrease individual dexterity and mobility.
o Ability to carry equipment
o Ability to turn knobs and adjust equipment
c) Present vision problems.
o Visual acuity
o Field of vision
o Ability to ue optical equipment
2) Because of the encumbrance of protective clothing:
a) Keep tasks simple
b) Plan fewer tasks per individual
4-C-2
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3) Wearing of protective equipment will require:
a) More time than normal to do a task
b) More people than normal to do a given task
3. DISCUSSION AND ORGANIZATION OF THE ENTRY PARTY PRACTICAL EXERCISE
A. this practical exercise is based upon an actual sampling mis-
sion conducted by the Region II Technical Assistance Team fol-
lowing the explosion and fires in the Chemical Control Corp.
site, Elizabeth, N.J.
B. Before entering a site, you need to know:
1) The toxic hazards associated with the site.
2) The specific mission or tasks to be performed in the site.
3) This information then is used to develop the level of pro-
tection to be used and the organization of the team.
C. For this exercise, it is assumed that:
1) Air monitoring of the site has revealed:
a) Toxic concentrations above TLV
b) A broad mixture of toxic agents
c) No percutaneous agents.
2) Based upon the air monitoring, personal protection is pre-
scribed as follows:
a) Self-contained breathing apparatus
4-C-3
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b) Disposable coveralls
c) Boots
d) Gloves
D. The mission of the entry', party will be to take two samples:
one soil sample and one water sample.
E. The instructor now selects members of the class for each team
position and describes the team member's duties and responsi-
bilities as he selects them.
1) Entry Party Team Captain
a) In charge of the entry party while downrange.
b) Responsible for the overall safety of the party,
c) Acts as the recorder for the sample data.
d) Carries the radio and maintain communications with
the hot line party.
e) Stays in the rear of the entry party to observe all
operations and safety practices.
f) Monitors the time remaining on air tanks to determine
the time required for exiting the site.
g) Carries a clipboard, ball point pen, and radio.
2) Photographer
a) Takes photographs of sample locations and procedures
as documentation for subsequent report.
4-C-4
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b) Places himself in the middle of Che party when
entering the site.
c) Instructor issues the team member a Polaroid camera
and ball point pen.
3) Monitor
a) Monitors for explosive atmosphere and oxygen content
of the air." If the oxygen content is below 19.5% or
above 25%, the explosimeter will not operate.
b) Serves at the lead member as the team proceeds down
range.
c) Instructor issues the team member an explosive gas
meter and an oxygen meter.
4) Sampler
a) Takes one soil sample and one water sample.
b) Places himself in the middle of the party when enter-
ing the site.
c) Issued a spatula for taking the soil sample and a
glass tube for taking the water sample.
5) Sample carrier
a) Carries the sample bottles.
b) To uncap the bottles, hold them while the sample is
put in them, and recap.
c) Wears a double set of gloves for a demonstration to be
conducted at the sample point.
d) Places himself in the middle of the party when enter-
ing the site.
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e) Instructor issues the team member the two sample bot-
tles.
F. Consideration for Other Team Members
1) Use of guides to avoid special hazards which might be pre-
sent in the site.
2) If entry party will be out of direct line of site of the
hot line:
a) Observers stationed on tall buildings, hill tops,
or other high observation point.
b) Observers placed within the site at intermediate
points where they are in site of the hot line and can
still observe the work party.
3) A seoarate safety observer
4) Additional equipment carriers
G. General Considerations
1) Team entry and exit routes should be planned.
2) A detailed work plan should have been developed and prac-
ticed if necessary.
3) There should be an emergency evacuation signal established
such as portable air horns, beating a wrench on a con-
tainer, etc.
H. Dress Out
l) Care must be taken during SCBA checkout to prevent damage
to the units.
2) As soon as the entry team is ready, they should be ar-
ranged in the proper order and taken to the hot line.
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4. DOWNRANGE OPERATIONS
A. Entry
1) Team members hook up air masks.
2) Team captain conducts check of team members and arranges
members in proper entry sequence.
3) Team crosses hot line and proceeds toward sample area.
4) Appropriate team members operate the oxygen and explosive
gas monitoring equipment.
B. Soil Sample
1) Sample carrier uncaps bottle and holds it out to receive
sample.
2) Sampler uses spatula to dig sample and put in bottle.
3) Photographer takes picture (2) of process.
4) Sample carrier recaps bottle.
5) Team captain records time, type of sample, and sample
point.
6) Incorrect Techniques
a) Kneeling on ground
b) Squatting in such a manner as to transfer contaminate
from boots to clothing.
c) Leaning or sitting on trees, drums, or equipment.
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7) Use ground cloth for kneeling or placement of equipment.
C. Water Sample
1) Sample carrier uncaps bottle and holds it out to receive
sample.
2) Sampler uses glass tube to take water sample and put it in
bottle.
NOTE: Dexterity problems usually occur causing the water sample
to flow on the outside of the bottle and over the gloves
of the sample carrier.
3) -Photographer takes picture of process.
4) Sample carrier recaps bottle.
5) Team captain records time, type of sample, and sample
point.
6) Sample holder changes outer gloves.
a) Change of outer gloves avoids contaminating a next
sample that might be taken.
b) Change of gloves would be appropriate to prevent con-
taminating equipment.
c) Gloves could be changed to either a heavier or lighter
weight to perform a different operation.
D. Exit
1) The team with the team captain in trail moves from the
sample point to the hot line.
2) Samples are deposited for processing by hot line oper-
ators .
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E. Packaging of Water Sample
1) One team member opens a plastic bags and holds it out to
receive the sample.
2) Second team member affixes label to waste sample bottle
and drops bottle into plastic bag.
3) First team member seals the plastic bag and puts it into a
metal paint can.
4) Can void is filled with vermiculite.
5) Lid is attached to can and secured with metal clips.
6) Can containing the water sample is then put in a cooler
filled the vermiculite.
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5. SPECIAL CONSIDERATIONS
A. Team Members Feel:
1) Fatigue from Che wearing of the mask and equipment.
2) Thirst from minor dehydration.
3) Hot from a temperature buildup due to the protective
clothing.
B. Hot Weather Operations
1) Danger of:
a) Heat stroke
b) Heat prostration
c) Dehydration
2) Provide:
a) Fluid replenishment
b) Frequent rest periods
c) Work crew changes
3) Consider starting work earlier in the morning to avoid the
hottest part of the day.
4) Establish temperature limits at which operations will be
terminated.
C. Cold weather operations
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1) Danger of:
a) .Frost bite
b) Malfunction of equipment
2) Provide:
a) Frequent rest periods
b) Warming tents or areas
c) Frequent protection equipment checks
d) Work crew changes
D. Prolonged Operations:
1) Problems:
a) Accumulated work crew fatigue
b) Increased danger of accidents
c) Logistics problems associated with air tanks, pro-
tective clothing changes, food, and equipment
2) Consideration
a) Larger crews
b) Larger support element
c) More supervisors
d) Multiple work, crews
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6. SUMMARY
A. Operations in a Toxic Environment Require:
1) More time Chan normal
2) More people than normal
B. When Planning an Operation:
1) Keep tasks simple
2) Plan every detail of the downrange operation
3) Provide adequate logistical support.
4) Take into consideration any special conditions such as
temperature or length of operation.
4-C-12
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D
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STATION #4
PDS OPERATIONS
1. INTRODUCTION
A. Objective To provide the student practical training in Set-
ting up a Personnel Decontamination Station (PDS), processing
contaminated personnel through the PDS, and properly closing
the PDS.
B . Presentation of Scenario
1) Worst case situation
2) One work party to be decontaminated
3) Hot line to be moved back because of inadvertent contamin-
ation of 'former areas.
4) Safety Officer is designated. He is to take charge and
direct actions of other team members.
2. PRACTICAL EXERCISE
A. Two of the students are dressed in Level A protection. Air
supplies are reduced to approximately 6 minutes.
B. Remaining students reestablish PDS
C. Students in Level A exit area
D. PDS operators (dressed in modified Level B) perform step-by-
step decontamination procedures.
E. Emphasis placed on proper undressing procedures
4-D-l
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F. PDS operators decon equipment and each other (as required)
and then close down site.
G. Protective gear is made ready for future use.
3. CRITIQUE
A. Attendees briefed on all deficiencies and shortcomings
B. Attendee questions discussed.
4-D-2
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HEALTH AND SAFETY RIGHTS AND RESPONSIBILITIES
1. OBJECTIVES
A. To provide an understanding of EPA's Occupational Medical Mon-
itoring Program guidelines and their importance and limita-
tions regarding employees engaged in hazardous waste site in-
vestigation.
B. Explain the standards, Agency requirements, and availability
and use of protective clothing.
C. Explain the personnel rights and responsibilities under
Occupational Health and Safety Act and Agency guidelines.
2. OCCUPATIONAL MEDICAL MONITORING PROGRAM
A. Legal Requirements
1) The Occupational Safety and Health Act of 1970, Section 19
states, "It shall be the responsibility of the head of
each Federal Agency to establish and maintain an effective
and comprehensive occupational safety and health program
consistent with the standards promulgated under Section
6." Section 6 C(7).
2) OSHA Safety and Health Standards, 29 CFR 1910 promulgated
under Section 6 of the Act specifically requiring medical
4-E-l
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examinations or medical surveillance.
a) 1910.134(b)(10) - Respiratory Protection
b) 1910.441 - Medical Requirements, Commercial Diving
Operations
c) 1910.1000 - Toxic and Hazardous Substances
3) The proposed rule on Basic Program Elements for Federal
Employee Occupational Health and Safety Programs, 29 CFR
1960.7(c) (7) requires that the agency provide funding for
medical surveillance programs for employees.
B. EPA's Occupational Medical Monitoring Program
1) Memorandum of 1/13/77 issued guidelines for establising
the Agencywide Health and Monitoring Program
a) Designed basically for laboratory employees
b) Did include employees who collect various types of
polluted samples, i.e. , stacks, sewage, highly toxic
effluents.
4-E-2
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c) Maintenance and custodial personnel who occasionally
could be exposed to unexpectedly high concentrations
of toxicants.
2) Memorandum of 3/6/78 issued Interim Guidelines for the
Continuation of the Medical Monitoring Program.
a) Continue baseline examinations for new employees under
the 1977 guidelines.
b) Provide screening medical monitoring for employees who
had already received the baseline examination.
Minimum:
o Internal medical and occupational history
review
o Basic blood and urine laboratory tests
3) Guidelines for FY 1980-81 were issued by Memorandum of
10/29/79.
a) Designed basically for laboratory and field workers
b) Recommended inclusion of part time and temporary
employees
4) The Agency pays all costs of the Occupational Medical
Monitoring Program.
4-E-3
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5) The Program is voluntary with the exception of a few
persons whose jobs require examinations as a condition of
employment.
6) Frequency of examinations or screenings is still annual
unless special testing is required because of a particular
exposure.
7) Proposed Agency policies are expanding the number of job
categories that will require preplacement and periodic
health assessment examinations.
a) Employees required to wear respiratory protection
b) Employees engaged in field activities whose duties
pose a possibility of exposure to toxic or hazardous
substances.
8) Types of Examination we have discussed
a) Baseline (preplacement or pre—employment)
o Should consist of a complete medical examination
o Provides a reference point for evaluating
subsequent examination findings.
4-E-4
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b) Screening Medical Monitoring
o Detects whether an employee is suffering harmful or
potentially harmful effects from work exposure,
particularly toxic substances.
To determine if environmental controls (personal
protective clothing and equipment) are effectively
controlling the health hazards from job exposure
8) Types of examination not a part of an Occupational Medical
Monitoring Program
Fitness Examinations - Must be reasonable and cannot
be used to discriminate against an individual.
o Return to work examinations.
o "Safety" examinations
o Examinations at the Request of the Supervisor
b) Health Promotion Examinations
o Over 40 employees
4-E-5
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o Employees in stress positions
c) Health Screening
o Diabetis
o Glaucoma
o TB
9) The EPA Occupational Medical Monitoring Program is not a
substitute for a general health care program.
10) Although - Medical conditions noted during medical
monitoring examinations not occupationally related are
discussed and employee referred to personal physician is
warranted.
11) The records established by the Medical Monitoring Program
must meet the requirements of the Privacy Act of 1974.
12) OOHS recruiting for a medical doctor to handle the
4-E-6
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Agency's medical monitoring program.
13) The Agency Occupational Health and Safety Manual will
contain a chapter on the Occupational Medical Monitoring
Program.
14) Participation in the Agency's Occupational Medical
Monitoring Program is not a guarantee of good health.
C. Quest ions/Discussion
3. PERSONAL PROTECTIVE CLOTHING
A. Legal Requirements
1) Occupational Safety and Health Act of 1970, Section 6C(7)
establishes the requirement for protective equipment.
2) 5 USC 7903 (1966) Clothing and equipment for protection of
Federal employees
3) EPA Order 3100.1, Uniforms, Protective Clothing, and
Protective Equipment
4-E-7
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B. EPA's Protective Clothing and Equipment Program
1) Order 3100.1 established Agency policy "....will be
prescribed for use, at Government expense, only where
the wearing of such items is necessary because of the
nature of the employee's duties."
2) Protective Clothing and Equipment
a) Employees and visitors required to wear protective
clothing and equipment while performing hazardous
duties.
b) Employees responsible for care of protective clothing
and equipment, except disposable items.
c) Personal protective equipment and clothing provided by
the Agency.
3) Two ways to provide employees protective equipment and
clothing.
a) Direct issurance
b) Payment of an allowance to employees
4-E-8
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4) The 1972 EPA Order is broad enough to justify the
purchase and use of any type of personal protective
equipment and clothing required to protect employees
involved in hazardous duties.
5) Proposed Chapter in Occupational Health & Safety Manual on
Hazardous Waste Site Investigations and Environmental
Spill Responses.
a) Establishes levels of protection
b) Makes recommendations for protective clothing and
equipment at each level.
o Level A
o Level B
o Level C
o Level D
D. Personnel Rights and Responsibilities
4-E-9
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1) Agency Responsibilities
a) Employment and place of employment free from
recognized hazards
b) Comply with OSHA standards
Develop, implement, and evaluate an occupational
safety and health program.
d) Promote employee awareness
e) Acquire, maintain, and require use of personal
protective equipment and clothing.
f) Ensure that money is available for training, personal
protective equipment, medical surveillance, etc.
g) Provide for evaluation of Agency management officials
and supervisors in meeting requirements of the
Agency's health and safety program.
h) Discrimination.
4-E-10
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2) Supervisory Responsibilities
a) Furnish employees employment free of hazards to the
extent of their authority.
b) Comply with all health and safety standards
c) Comply with all rules and regulations issued by the
Agency.
Functions under the responsibilities:
Keep records, report injuries and illnesses,
investigate accidents and exposure to hazardous
conditions, identify and eliminate hazards,
conduct inspections, communicate information to
their employees, provide training, assure that
employees use all required personal protective
equipment.
3) Employee Responsibilities
a) Comply with all standards, rules, regulations and
orders
b) Use personal protective equipment and clothing
c) Right to report unsafe or .unhealthful working
conditions
4-E-ll
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d) Right to request an inspection
e) Authorized time to participate in health and safety
activities
f) Access to OSHA and Agency standards, injury and
illness statistics, and procedures.
g) Right to appeal to the Department of Labor
h) Right to choose not to perform assigned task
o Reasonable apprehension of risk
o Reasonable belief no alternative action is
available
o Disciplinary actions
i) On-the-job conduct regarding health and safety
4-E-12
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o Observe all rules, signs and instructions
o Failure to report accidents
o Failure to use protective clothing and equipment
o Endangering the safety or causing injury to
personnel or property through negligence.
E. Comments/Discussion
4-E-13
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OBJECTIVES OF THE COURSE
• PROVIDE UNDERSTANDING OF
EPA'S OCCUPATIONAL MONITORING
PROGRAM
• EXPLAIN STANDARDS, AGENCY
REQUIREMENTS, AVAILABILITY AND
USE OF PROTECTIVE CLOTHING
• EXPLAIN PERSONNEL RIGHTS AND
RESPONSIBILITIES
4-E-14
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OCCUPATIONAL MEDICAL
MONITORING PROGRAM
4-E-15
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LEGAL REQUIREMENTS
• OSH ACT OF 1970, SECTION 19
• 29 CFR 1910, OCCUPATIONAL
SAFETY AND HEALTH STANDARDS
« AGENCY REQUIREMENTS
4-E-16
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OCCUPATIONAL
MEDICAL
MONITORING
FITNESS
EXAMINATION
HEALTH
MAINTENANCE
EXAMINATIONS
PRE-EMPLOYMENT
PRE-PLACEMENT
EXAMINATIONS
BASELINE
SCREENING
EXAMINATIONS
SAFETY
EXAMINATIONS
HEALTH
SCREENING
PROGRAMS
4-E-17
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ERA'S OCCUPATIONAL MEDICAL
MONITORING PROGRAM
• AGENCY PAYS ALL COSTS
• • PARTICIPATION IS VOLUNTARY EXCEPT
WHERE EXAMINATIONS ARE A CONDI-
TION OF EMPLOYMENT
• FREQUENCY-ANNUALLY
• PARTICULAR EXPOSURE MAY REQUIRE
SPECIAL TESTING
4-E-18
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ERA'S MEDICAL MONITORING PROGRAM
DOES NOT
• SUBSTITUTE FOR A GENERAL HEALTH CARE PROGRAM
• GUARANTEE YOUR GOOD HEALTH
DOES
• DETECT HARMFUL OR POTENTIALLY HARMFUL EFFECTS
FROM WORK EXPOSURE
• DETERMINE IF CONTROLS ARE EFFECTIVE
4-E-19
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PROTECTIVE CLOTHING AND
EQUIPMENT PROGRAM
PRO'
4-E-20
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ERA'S PROTECTIVE CLOTHING AND
EQUIPMENT PROGRAM
LEGAL REQUIREMENTS
5 USC 7903 - CLOTHING AND EQUIPMENT
FOR PROTECTION OF FEDERAL EMPLOYEES
OCCUPATIONAL SAFETY AND HEALTH ACT
OF 1970, SECTION 6{C) (7)
EPA ORDER 3100.1 - UNIFORMS, PROTECTIVE
CLOTHING, AND PROTECTIVE EQUIPMENT
4-E-21
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LEVELS OF PROTECTION
LEVEL A - HIGHEST AVAILABLE LEVEL OF BOTH RESPIRATORY AND
SKIN CONTACT IS NEEDED.
LEVEL B - HIGHEST LEVEL OF RESPIRATORY PROTECTION IS NEEDED
BUT ADVERSE EXPOSURE TO EXPOSED SKIN AREAS IS UN-
LIKELY.
LEVEL C - AIR-PURIFYING RESPIRATORY PROTECTION AND SKIN
CONTACT PROTECTION. EMERGENCY ESCAPE RESPIRATOR
REQUIRED.
LEVEL D - BASIC WORK UNIFORM. AIR-PURIFYING RESPIRATOR
AVAILABLE.
4-E-22
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LEVELS OF PROTECTION
LEVEL A
PROTECTIVE EQUIPMENT
• SCBA, OPEN CIRCUIT, PRESSURE-DEMAND
• TOTALLY ENCAPSULATED SUIT
• GLOVES
INNER - (SURGICAL)
OUTER - (CHEMICAL PROTECTIVE)
• BOOTS, STEEL TOE AND SHANK, CHEMICAL PROTECTIVE
• BOOT COVERS - CHEMICAL PROTECTIVE
CRITERIA
• KNOWN HAZARDS
REQUIRE THE HIGHEST LEVEL OF RESPIRATORY
PROTECTION
WILL CAUSE ILLNESS AS A RESULT OF PERSONAL
EXPOSURE
REASONABLE DETERMINATION THAT PERSONAL
EXPOSURE COULD OCCUR TO ANY PART OF THE BODY
• UNKNOWN HAZARDS
REASONABLE DETERMINATION THAT THE SITE MAY
CONTAIN SUBSTANCES LISTED UNDER CRITERIA FOR
KNOWN HAZARDS ABOVE
\
4-E-23
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LEVELS OF PROTECTION
LEVEL B
PROTECTIVE EQUIPMENT
• SCBA, OPEN CIRCUIT, PRESSURE-DEMAND
• CHEMICAL PROTECTIVE
OVERALLS AND LONG-SLEEVED JACKET, OR
COVERALLS
• GLOVES
INNER - (SURGICAL)
OUTER - (CHEMICAL PROTECTIVE)
• BOOTS, STEEL TOE AND SHANK, CHEMICAL PROTECTIVE
• BOOT COVERS, CHEMICAL PROTECTIVE
CRITERIA
o KNOWN HAZARDS
REQUIRE THE HIGHEST LEVEL OF RESPIRATORY-
PROTECTION
WILL CAUSE ILLNESS AS A RESULT OF PERSONAL
EXPOSURE
REASONABLE DETERMINATION THAT PERSONAL
EXPOSURE TO AREAS OF THE BODY NOT COVERED
IS UNLIKELY
• UNKNOWN HAZARDS
REASONABLE DETERMINATION THAT THE SITE
MAY CONTAIN SUBSTANCES LISTED UNDER
CRITERIA FOR KNOWN HAZARDS ABOVE
\
4-E-24
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LEVELS OF PROTECTION
LEVEL C
PROTECTIVE EQUIPMENT
• AIR-PURIFYING RESPIRATOR, FULL FACEPIECE
« EMERGENCY ESCAPE RESPIRATOR (CARRIED)
e CHEMICAL PROTECTIVE
OVERALLS AND LONG-SLEEVED JACKET
COVERALLS
• GLOVES
INNER - (SURGICAL)
OUTER - (CHEMICAL PROTECTIVE)
• BOOTS, STEEL TOE AND SHANK, CHEMICAL PROTECTIVE
• BOOT COVERS, CHEMICAL PROTECTIVE
CRITERIA
• KNOWN HAZARDS
DO NOT REQUIRE A LEVEL OF RESPIRATORY
PROTECTION GREATER THAN THE LEVEL
AFFORDED BY AIR-PURIFYING RESPIRATORS
WILL CAUSE ILLNESS AS A RESULT OF PERSONAL
EXPOSURE
REASONABLE DETERMINATION THAT PERSONAL
EXPOSURE TO AREAS OF THE BODY NOT COVERED
BY PROTECTIVE CLOTHING IS UNLIKELY
• UNKNOWN HAZARDS
REASONABLE DETERMINATION THAT THE SITE MAY
CONTAIN SUBSTANCES LISTED UNDER CRITERIA FOR
KNOWN HAZARDS ABOVE
4-E-T5T
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LEVELS OF PROTECTION
LEVELD
PROTECTIVE EQUIPMENT
• COVERALLS, COTTON
• BOOTS/SHOES, SAFETY
• SAFETY GLASSES
• HARD HAT WITH OPTIONAL FACESHIELD
• AIR-PURIFYING RESPIRATOR (READILY AVAILABLE)
CRITERIA
• REASONABLE DETERMINATION THAT HAZARDS DUE TO
EXPOSURE TO HAZARDOUS MATERIALS IS UNLIKELY
4-E-26
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PERSONNEL RIGHTS AND
RESPONSIBILITIES
4-E-27
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AGENCY RESPONSIBILITIES
• WORK AND WORKPLACE FREE OF RECOGNIZED HAZARDS
• COMPLY WITH OSHA STANDARDS
• DEVELOP, IMPLEMENTED EVALUATE A HEALTH AND
SAFETY PROGRAM
• PROMOTE EMPLOYEE AWARENESS
• ACQUIRE, MAINTAIN, AND REQUIRE USE OF PERSONAL
PROTECTIVE EQUIPMENT AND CLOTHING
• PROVIDE SUFFICIENT FUNDS
• PROVIDE FOR EVALUATION OF MANAGEMENT OFFICIALS AND
SUPERVISORS
• PROVIDE DISCRIMINATION SAFEGUARDS
4-E-28
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SUPERVISORY RESPONSIBILITIES
• FURNISH EMPLOYEES EMPLOYMENT FREE OF
HAZARDS TO THE EXTENT POSSIBLE
• COMPLY WITH ALL HEALTH AND SAFETY
STANDARDS
• COMPLY WITH ALL RULES AND REGULATIONS
ISSUED BY AGENCY
4-E-29
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SUPERVISORY FUNCTIONS
• KEEP RECORDS
• REPORT INJURIES AND ILLNESSES
• INVESTIGATE ACCIDENTS AND
EXPOSURES
• IDENTIFY AND ELIMINATE HAZARDS
• CONDUCT INSPECTIONS
• COMMUNICATE INFORMATION TO THEIR
EMPLOYEES
• PROVIDE TRAINING
• ASSURE THAT EMPLOYEES USE
PERSONAL PROTECTIVE CLOTHING AND
EQUIPMENT
4-E-30
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EMPLOYEE RESPONSIBILITIES
• COMPLY WITH ALL STANDARDS, RULES, REGULAT1ONS.AND ORDERS
• SHALL USE PERSONAL PROTECTIVE EQUIPMENT AND CLOTHING
• RIGHT TO REPORT UNSAFE OR UNHEALTHFUL WORKING CONDITIONS
• RIGHT TO REQUEST AN INSPECTION
• AUTHORIZED TIME TO PARTICIPATE IN HEALTH AND SAFETY ACTIVITIES
e ACCESS TO OSHA AND AGENCY STANDARDS, INJURY AND ILLNESS
STATISTICS, AND PROCEDURES
• RIGHT TO APPEAL TO THE DEPARTMENT OF LABOR
• RIGHT TO CHOOSE NOT TO PERFORM ASSIGNED TASK
- REASONABLE APPREHENSION OF RISK
- REASONABLE BELIEF NO ALTERNATIVE ACTION IS AVAILABLE
- DISCIPLINARY ACTIONS
4-E-31
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EMPLOYEE CONDUCT AND DISCIPLINE
• OBSERVE ALL RULES, SIGNS.AND INSTRUCTIONS
• FAILURE TO REPORT ACCIDENTS
• FAILURE TO USE PROTECTIVE CLOTHING AND
EQUIPMENT
• ENDANGERING THE SAFETY OR CAUSING INJURY TO
PERSONNEL OR PROPERTY THROUGH NEGLIGENCE
j
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AIR PURIFYING RESPIRATORS
1. INTRODUCTION
A. Objective
1) Discuss the use and applicability of air purifying respir-
ators for use during the investigation of chemical waste
sites.
2) Fit-test students with the MSA Ultratwin respirator.
B. Limitations of Air Purifying Respirators
1) Most are negative pressure
2) Not usable in 02 deficient atmospheres
3) Cannot be used in IDLH atmospheres
4) Materials must exhibit good warning properties
5) Used where contaminants are known
6) Previous characterization and/or background research
usually necessary
C. Application
1) Useful1 within the aforementioned constraints
2) Many facilities scheduled for investigation do not exhibit
the chemical, nightmarish complexity typically associated
with a classic definition of a hazardous waste site, or do
many sites pose significant atmospheric or contact hazards
4-F-l
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to investigators in well-ventilated areas during a site
walk-through or other activity that does not disturb the
soil or containers.
3) Other decision-making factors include a) -historical re-
search to confirm the presence of nonexotic chemicals b)
determination that those chemicals likely to be encoun-
tered have a low odor threshold in comparison to their
IDLH values, gradual does response curve, and minor, acute
or chronic physiologic impact.
4) An air purifying respirator should be used for
applications only when there is a compatible cartridge
available and in areas that have demonstrated ambient
ventilation.
5) At anytime there is reason to suspect a concentration re-
motely approaching an IDLH value, or the prospect of out-
gassing or heavier than air organic vapors, use of an air
purifying respirator should be severely limited.
6) One must also confirm that the concentrations to be en-
countered do not exceed the recommendations of the manu-
facturer for that particular cartridge or canister.
7) After weighing these and other factors and deriving satis-
factory answers, you may wish to consider use of an air
purifying respirator.
2. AIR-PURIFYING RESPIRATORS
A. Type
1) 1/4 mask - covers mouth and nose
2) 1/2 mask - covers chin, mouth, and nose
3) Full face mask - covers entire face
4-F-2
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4) Powered air purifying respirators
5) Chin mount canisters
6) Belt mount canisters and containers
7) Single use
B. Manufacturers
1) MSA, Willson, Pulmosan, Scott, Norton, Cesco, U.S. Safety,
American Optical, 3-M
2) Most manufacture NIOSH-certified equipment, a factor that
you should always consider. The bottom-of-line respira-
tors (i.e., single use) may or may not be NIOSH cert-
ified.
2.3 MSA Ultratwin
1) MSA selected because of its national availability/distri-
bution network, accessibility of parts, and excellent fit
efficiency.
2) Same mold, cheek holes, modified exhalation valve assembly,
and speaking diaphragms of MSA 401 SCBA.
3) Important parts include exhalation valve cover (rubber
valve, air retention concept, examples of leak rates).
4) Inhalation valves; which cartridges are damaged by water
vapor.
5) Cartridge gaskets
6) Options - glasses; Fog Pruf (P and regular); nose cup;
cover lens.
4-F-3
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3. CARTRIDGES/CANISTERS
A. Concept
1) Cartridges function on three basic principles according to
the contaminant: adsorption, absorption, catalytic.
2) Different sorbents are used in each cartridge or canister
depending upon manufacturer.
ADSORBENTS
organic vapors - activated charcoal
mercury vapor - activated charcoal with iodine
acid gas - activated charcoal with metal oxides
ammonia - activated charcoal with metal salts.
ABSORBENTS
acid gases - sodium or potassim hydroxide with
lime or caustic silicates
CATALYST
carbon monoxide - hopcalite (porous granules of
manganese.and copper oxides)
MECHANICAL
dusts, mists, fumes, ) synthetic wools or simi-
radionuclides, fibers) lar mechanical filter
B. Protection Factors
1) Definition
2) PF x TLF = crude estimate of maximum exposure
3) Note that cartridges will sorb contaminants in excess of
recommended limit but for a proportionately shorter period
of time
4-F-4
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4) Breakthrough for organics
5) Different respirators illustrate different protection
factors (e.g.j full face positive-pressure SCBA = 10,000+;
full-face air purifying respirators = 100. Note addition-
al protection afforded by SCBA)
C. Types
1) Canisters vs. cartridges (advantages, disadvantages; uni-
versal canisters)
2) Plastic vs. metal cartridge bodies; screw-on replaceable
vs. non-replaceable filter.
3) Application and limitations discussed on each box and
cartridge.
4) MSA manufactures nearly 20 different variations
5) Demonstration acid gas, pesticide, organic, HEPA (Note
efficiency difference between HEPA and regular dust), Com-
bination, and ammonia/methyl amine cartridges.
D. Useful Life of Cartridges
1) In traditional industrial use, cartridges are changed
whenever the individual begins to smell the material or
notice increased resistance to breathing. If you judi-
ciously follow the criteria discussed earlier, this proce-
dure is probably a safe rule of thumb. However, in our
practice, even though we would never select an air purify-
ing respirator in a situation even remotely approaching
the limitations of a chartridge or in an IDLH atmosphere,
we change the filters after each work shift (i.e., daily)
or as deemed necessary by the safety officer.
2) Do not use if bent, distorted, or wet.
3) Useful life of generic organic cartridge is strongly de-
pendent on the organic compound encounterd.
4. CLEANING/SANITIZING
4-F-5
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RESPIRATOR FIT TESTING
OSHA regulations (29 CFR Part 1910.134) require that each person
who wears a respirator shall have it properly fitted, test the
facepiece for face seal, and wear it in a test atmosphere. In
order to wear a respirator, the person must go through a fit
test to determine whether the person can obtain a satisfactory
fit with a "negative pressure" air-purifying respirator. The
results of the fit test will be used to select the specific
type, make, and model of "negative pressure" air-purifying res-
pirator for use by the wearer.
The following policies should be adhered to in the fitting and
use of the respirators:
A. A person must have passed the fit test in order to use any
NIOSH/MSHA approved respirators.
B. If it is found that a person cannot obtain a good respir-
ator-to-face seal because of facial or medical characteris-
tics, the person should not use and/or enter an atmosphere
that will require the use of a respirator.
C. Facial hair such as beards, sideburns, or certain mustaches
which may interfere with the fit test are not allowable.
D. Persons requiring corrective lenses shall be provided with
specially mounted lenses inside the full-face mask. Under
no circumstances will contact lenses and/or glasses be worn-
while using full-face respirators.
E. Although fit testing for positive pressure SCBAs is not re-
quired as described in ANSI Z88.2 (draft revision 1978), a
less than acceptable respirator-to-face seal will increase
the use of air via leakage and therefore reduce effective
breathing time. Such leaks may pose a hazard to the user if
sufficient air supply is not available to reach an uncontam-
inated air supply.
F. A person may only use the specific make(s) and model(s) of
full-face, air-purifying respirators for which the person
has obtained a satisfactory fit via the qualitative fit-
testing procedures. Under no circumstances shall a person
be allowed to use any make or model respirator not previous-
ly fit tested or having failed a fit-test period.
4-F-6
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Fit-testing by use of a two-stage, cross-checking procedure pro-
vides the necessary quality assurance that the user of an air-
purifying, cartridge/canister respirator is properly fitted and
has a good facepiece-to-face seal.
A. Stage I
1) Negative Pressure-Sealing Checks for Air-Purifying Res-
pirators
The wearer can perform this test by himself or. herself
in the field or office after donning the air-purifying
respirator. It consists of closing off the inlet of the
cartridge(s) to prevent the passage of air. This test
is performed by closing off the inlet opening of the
respiratory cartridge(s) by covering with the palm of
the hand(s) so that it will not allow the passage of
air, inhaling gently, and holding the breath for at
least ten seconds. If a facepiece collapses slightly
and no inward leakage of air into the facepiece is
detected, it can be reasonably assumed that the fit of
the respirator to the wearer is satisfactory.
This test is made only as a gross determination of fit
when the respirator is to be used in relatively toxic
atmospheres. Nonetheless, this test shall be used just
prior to entering any toxic atmosphere.
20 Positive Pressure-Sealing Check for Air-Purifying Res-
pirators
This test is very much like the negative pressure-
sealing check. This test is preferred after donning the
air-purifying respirator which contains an exhalation
and .inhalation valve. The test is conducted by closing
off the exhalation valve and exhaling gently. The fit
of a respirator equipped with a facepiece is considered
to be satisfactory if a slight positive pressure can be
built up inside the facepiece for at least ten seconds
without detection of any outward leakage of air between
the sealing surface of the facepiece and the respirator
wearer's face.
This test is also to be used only as a gross determina-
tion of fit when the respirator is to be used in rela-
tively toxic atmospheres. This test shall be used just
prior to entering any toxic atmosphere.
Note: Both the positive and negative pressure-sealing checks
can be used on the MSA Model 401 air mask to determine
the gross fit characteristics.
4-F-7
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B. Stage II
A person wearing an air-purifying respiratorwill be ex-
posed to two test agents: isoamyl acetate Can odorous
vapor) and stannic chloride (an irritant smoke). The
air-purifying respirator will be equipped with an air-
purifying cartridge which effectively removes the test
agents from respired air. If the respirator wearer is
unable to detect penetration of the-test agent into the
respirator, he has achieved a satisfactory fit.
1) Procedures for the Isoamyl Acetate Test
Isomayl acetate or banana oil is a chemical which pro-
duces a pleasant banana-smelling organic vapor. It is
an easily detectable odor. The isoamyl acetate fit test
will beconducted by using a plastic garbage bag as a
test hood hung from the ceiling over a coat hanger sus-
pended by twine. Inside the plastic bag, a piece of
cloth saturated with isoarayl acetate is to be attached
to the top portion of the bag. This procedure will pro-
duce a rough concentration of approximately 100 ppm in
the test atmosphere inside the plastic bag. Most people
can detect isoamyl acetate at 1-10 ppm. The permissible
exposure is 100 ppm.
The isoamyl acetate fit test will be performed as
follows:
o The wearer puts on the respirator in a normal man-
ner. If it is an air-purifying device, it must be
equipped with a cartridge(s) specifically designed
for protection against organic vapors.
o The wearer enters the test enclosure, so that the
head and shoulders are well inside the bag.
o If the wearer smells banana oil, he returns to
clean air and readjusts the facepiece and/or ad-
justs the headstraps without unduly tightening
them.
o The wearer repeats the second step. If he does not
smell banana oil, he is assumed to have obtained a
satisfactory fit. If he smells the vapor, an at-
tempt should be made to find the leakage point. If
the leak cannot be located, another respirator of
the same type and brand should be tried. If this
leaks, another brand of respirator with a facepiece
of the same type should be tried.
4-F-8
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o After a satisfactory fit is obtained, if the .respira-
tor is an air-purifying device, it must be equipped
with the correct filter(s), cartridgesCs), or can-
ister for the anticipated hazard.
Note: During the test, th'e subject should make movements that
approximate a no,rmal working situation. These may
include, but no;t necessarily be limited to, the
following:
o Normal breathing.
o Deep breathing, as during heavy exertion. This
should not be done long enough to cause hyperventil-
ation.
o Side-to-side and up-and-down head movements. These
movements should be exaggerated, but should approxi-
mate those that take place on the job.
o Talking. This is most easily accomplished by reading
a prepared text and/or reciting the alphabet loudly
enough to be understood by someone standing nearby.
o Other exercises may be added depending upon the situ-
ation. For example, if the wearer is going to spend
a significant part of his time bent over at some
task, it may be desirable to include an exercise ap-
proximating this bending.
The major drawback of the isoamyl acetate test is that
the odor threshold varies widely among individuals.
Furthermore, the sense of smell is easily dulled and may
deteriorate during the test so that the wearer can
detect only high-vapor concentrations. .Another
disadvantage is that isoamyl acetate smells pleasant,
even in high concentrations. Therefore, a wearer may
say that the respirator fits although it has a large
leak. Therefore, check out these test results
carefully and move on to the next atmosphere.
2) Procedures for the Irritant Smoke (Stannic Chloride)
Test.
This qualitative test is similar to the isoamyl test in
concept. It involves exposing the respirator wearer to
an irritating smoke produced by commercially available
smoke tubes. These are sealed glass tubes, approxi-
mately 12 cm long by 1 cm in diameter, filled with
pumice inpregnated with stannic chloride. When the tube
ends are broken and air is passed through it, the mate-
rial inside reacts with the moisture in the air to pro-
duce a dense, highly irritating smoke.
4-F-9
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As a qualitiative means of determining respirator fit,
this test has a distinct advantage in that the wearer
usually reacts involuntarily to leakage by coughing or
sneezing. The likelihood of his giving a false indica-
tion of proper fit is reduced.
The irritant smoke test will be conducted by using a
plastic garbage bag as a test hood. The bag will be
hung from the ceiling over a coat hanger suspended by
twine. A small hole is made in the top portion of the
bag so that the irritant smoke can be dispensed into the
bag when the test subject has entered the bag.
The irritant smoke fit test will be performed as
follows:
o ! The wearer puts on the respirator normally, taking
care not to tighten the headstraps uncomfortably.
Once the respirator is on, the subject is to enter
the suspended bag so that the head and shoulders
are well inside the bag hood.
o Once the subject is inside the bag, the tester will
begin to add the irritant smoke in small quantities
at first, pausing between puffs from the applica-
tor, listening for a reaction.
o If the wearer detects no leakage, the tester may
increase the smoke density, still remaining alert
to his reactions.
o At this point, if no leakage has been detected, the
wearer may cautiously begin the head movements and
exercises mentioned in the isoamyl acetate test.
The tester should remain especially alert and be
prepared to stop producing smoke immediately and
remove the subject from the bag.
o If a leakage is detected at any time, the tester
should stop the smoke and let the wearer out of the
bag to readjust the facepiece or headstrap tension.
The tester should then start the test at the second
step.
o If at the end of all the movements and exercise the
wearer is unable to detect penetration of the ir-
ritant smoke into the respirator, the respirator
wearer has a satisfactory fit.
o Remove the subject from the test atmosphere.
4-F-10
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PAYS
-------
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ENFORCEMENT
1. INTRODUCTION
A. Objectives of RCRA
1) Provide technical and financial assistance.
2) Regulate management of hazardous waste.
B. Legislative Authority to Conduct Inspections - 3007 (a)
1} Purposes of inspection.
2) Guidelines governing conduct of inspection.
2. ROLE OF ENFORCEMENT PROGRAM
A. Administrative System
1} Screening reports.
5-A-l
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2) Analyzing applicable reports.
3) Tentative disposition of cases.
4) Final strategy determination.
B. Inspection System
1) Enforcement functions of inspection.
2) Overriding criteria that guide the conduct of an
inspection.
3. PREPARATION FOR INSPECTION
A. Objectives of Inspection Preparation
B. Responsibility of the Inspector
C. Administrative Preparation
1) Compliance file.
5-A-2
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2) Sampling plan.
D. Notification
1) Suspicion of illegal discharges or dumping.
2) Desire to speak with specific individuals.
3) Methods of notification.
4) Information to be conveyed by inspector during
notification.
E. Inspection Equipment
4. CONDUCTING THE INSPECTION
A. Scope of Inspection
1} Compliance evaluation.
2) Compliance sampling.
5-A-3
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3) Types of inspections.
B. Entry Into a Facility
1) Introduction as EPA inspector.
2) Present proper EPA credentials.
3} Document entry in log book.
4) Consent may be withdrawn.
a) Equivalent of refused entry.
b) Warrant may be secured.
5) Consent not required for an inspection to observe and
report on things in plain view.
a) Includes during presentation of credentials.
b) Inspector's access may be limited without warrant.
5-A-4
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C. Pre-Inspection Discussion
1) Discuss provisions of the Act.
2) Furnish copy, if requested.
3) Outline objectives of inspection and order in which
operation will be inspected.
4) Advise of right to request and receive split samples.
D. Sampling
1) Sampling plan checklist,
2) Sampling plan of action.
3) May be appropriate to conduct preliminary survey
collection.
4) Sampling plan should include:
5-A-5
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a) Telephone numbers, addresses and directions to nearest
medical facility.
b) Ambulance service.
c) Fire department.
d) Police department.
e) EPA office contact.
5} Sampling points for enforcement purposes.
6) Volume of sample dependent on laboratory protocol and
whether splits will be taken.
E) Document Control
1} Serialized documents.
2) Project logbooks.
5-A-6
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3) Sample identification documents.
4) Chain of Custody.
a) Splits aliquoted into similar sample containers.
b) Identical sample tags.
c) Possession of samples traceable.
d) Sample custody.
e) Field custody considerations.
f) Transfer of custody and shipment,
5) Evidence audit.
5-A-7
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F. Quality Assurance
1) Duplicate samples
2) Split samples.
3) Spiked samples.
4) Sample preservative blanks.
5) Precision, accuracy and control charts.
5. POST-INSPECTION PROCEDURES
A. Post-Inspection Discussion
1) Discussion limited to specific findings.
2) Certain precautions.
B. Report Preparation
5-A-8
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6. REFERENCES
Draft RCRA Inspection Manual, Fred C. Hart Associates, Inc., July
8, 1980.
Draft Enforcement Considerations for Evaluations of Uncontrolled
Hazardous Waste Disposal Sites by Contractors. National
Enforcement Investigations Center, EPA. April 1980.
Draft Guidance Manual for Investigation of Hazardous Waste Dis-
posal Site. Office of Special Control Materials Division, EPA.
NEIC Policies and Procedures Manual. National Enforcement Inves-
tigations Center, EPA. May 1978.
5-A-9
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SLIDE 1.
Objectives of RCRA
o Provide techncial and financial assistance for the development
of management plans and facilities for the recovery of energy
and other resources from discarded materials and for the safe
disposal of discarded materials.
o Regulate the management of hazardous waste.
5-A-10
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SLIDE 2
Purposes of Inspection
o Regulation development
o Enforcement (evaluation or sampling)
Compliance (§3007(a)}
Imminent hazards (§7003)
5-A-ll
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SLIDE 3.
Guidelines for Conduct of Inspection
o Request Access
o Enter at reasonable times
o Conduct inspections with reasonable promptness
o Give sample receipts and, if requested, sample portions equal
in volume or weight to the portion retained
o Furnish analytical results; and
o Make inspection results, unless found to be confidential,
available to the public
5-A-12
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SLIDE 4.
Enforcement Funtions of Inspection
o Detect and document violations and discover imminent hazards
o Support enforcement actions (evidence gathering)
o Determine conformance with compliance and other enforcement
orders
5-A-13
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SLIDE 5.
Overriding Criteria of an Inspection
o Technical integrity of the inspection must be correct
o Legal requirements concerning the conduct of inspections must
be scrupulously adhered to
5-A-14
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SLIDE 6.
Objectives of Inspection Preparation
To obtain and review all Agency information essential to
conducting an effective inspection
To permit completion of the scheduled number of inspections
in a timely manner
To minimize inconvenience to facility owners and operators
by not requiring them either to explain or produce information
which is already in the hands of the regulatory agency
5-A-15
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SLIDE 7.
Preparation Materials
o A listing and copies of the RCRA and applicable state permits
as well as TSCA, NPDES, CAA, and UIC requirements applicable
to the facility
o A sketch or a copy of the survey map (U.S.G.S.) showing the
waste facility location and environmental and geographical
features
o Air photos with a scale of 1" = 100'
o A summary of names, titles, locations and phone numbers of
the responsible persons (operators, municipal or industrial
officials) involved with the facility's hazardous waste
program. This information will be contained in the ADP
(Automatic Data Processing) system to be developed
o A flow chart or design features of the present and planned
facilities (if appropriate, include industrial production
processes)
o Inspection reports from previous inspections, containing the
compliance history of the site
o The permittee's most recent Monitoring Report
o A letter of notification of inspection to the facility and
the response to the letter (if applicable)
o Any other recent correspondence and/or regulatory action,
noting the status of requested actions/and or compliance with
enforcement actions
o Previous EPA studies, consultant's reports, and laboratory
reports describing non-routine analyses
o Citizen's complaints filed against the site
o Annual and other reports submitted by the facility
o State's and/or Region's enforcement history at the site
5-A-16
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SLIDE 8.
Responsibility of the Inspector
o Knowledge of permit conditions, compliance file, monitoring
requirements, etc., before on-site visits
o Knowledge of applicable EPA policies and procedures
o Knowledge of what to look for in terms of environmental
legislation other than RCRA
o Inspection Scheduling
o Adequate pre-inspection planning
o Checking to see that a "Letter of Notification" of inspection
has been sent to the facility if appropriate (not required by
RCRA but may be useful in certain situations)
5-A-17
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SLIDE 9.
Methods of Notification
o Annual notification letter establishing requirement for inspections
but not specifying a date
o Letter notifying of an inspection within a month
o Advance notification scheduling specific appointments
o Unannounced, surprise entry
5-A-18
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SLIDE 10.
Information Conveyed in Notification
o Inspector's name
o Organizational or agency affiliation
o Purpose of the inspection
o Authority under which the inspection is conducted
o Procedures of the inspection
o Where inspection to be conducted
o With whom inspector needs to confer
5-A-19
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SLIDE 11.
Inspection Equipment
o Credentials
o Safety equipment
o Facility's compliance file and monitoring schedule
o Camera (35mm, Polaroid)
o Pocket tape recorder (for recording field notes)
o Pocket calculator
o Tape measure (engineer's tape — 100 ft.)
o Checklists
o Sampling equipment
o Documentation equipment
o Level
o Range finder/Optical tape measure
o Compass
o Stopwatch
o Wind meter or Admiral Beauford Wind Scale
o Square
o Tools
5-A-20
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SLIDE 12.
Scope of Inspection
o Record review — an examination of facility records of tests
and analyses performed, self-monitoring conducted, sampling
performed, amounts and types of waste handled, manifests for
wastes transported from or to the site, etc. The main purpose
is to determine compliance with the Agency's recordkeeping
and reporting requirements. The record review also will
indicate evidence of incompatibility of wastes
o Cursory inspection — a visual inspection documented briefly
(grab samples might be taken). This is a possible mechanism
for flagging violations under other programs as well as under
RCRA, or for dealing with a specific aspect for a restraining
order
o Preliminary survey — an initial visual inspection. During the
inspection sampling needs and locations may be identified
and a general characterization of the site may be determined
o Comprehensive inspection — a thorough visual and sampling
inspection. This inspection often is preceded by a preliminary
survey
o Sampling inspection — an inspection consisting only of
taking samples. This inspection may be triggered by a cursory
inspection or preliminary survey in response to indications
of potential violations. It is used mostly for enforcement
purposes (i.e., case development)
5-A-21
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SLIDE 13.
Entry into a Facility
All inspections should be conducted at reasonable times
or during normal working hours.
Official agency credentials must be presented to the plant
representative authorized to give consent to an inspection
of the facility.
Consent must be given by the owner of the premises or the person
in charge of the premises at the time of the inspection. The
person giving consent may be presented with a statement to sign
acknowledging his consent which will"be retained by the inspector
and included in his inspection report.
Consent must be secured without any behavior which couj.d be
characterized as coercive (either in a verbal or physical sense),
such as threats of punitive action.
The inspector should document the entry in the logbook and note
date, time, and name of facility personnel encountered.
Consent to the inspection may be withdrawn at any time. That
segment of the inspection completed before the withdrawal of
consent remains valid. Withdrawal of consent is equivalent to
refused entry. A warrant should be secured to complete the
inspection.
Consent is not required for observation of things that are in
plain view, i.e., that a member of the public could be in a
position to observe, including observations made while on private
property in areas that are not closed to the public, e.g., matters
observed while the inspector presents his credentials. However,
a warrantless inspector's access to any portion of the facility
may be limited at the discretion of the owner of the facility.
Consent may be given with "conditions". When such "conditional"
consent is proposed, guidance should be sought from the DPO,
Enforcement Director, or other appropriate Regional authority,
prior to further activity. "Conditions' must be accurately
recorded.
5-A-22
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SLIDE 14.
Sampling Plan Checklist
o Background research concerning waste
o Identify safe sampling equipment
o Identify safe sampling procedures
a. proper location(s)
b. volume of samples
c. collection procedure
d. containment and handling
o Review chain of custody procedures
o Review packaging, labelling and shipping requirements
a. identify samples
b. protect from tampering
c. fill out field notebook
d. complete sample analysis request sheet
e. complete receipt of sample form
o Arrange for sample delivery
5-A-23
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SLIDE 15.
SAMPLING POINTS FOR MOST WASTE RECEPTACLES
Receptacles
Samolinc Point
Crum, bung en ona and
3ru.7., bung on si da
Sarral, fiberdrus,
buckets, sacks, bags
Vacuum truck and similar
containers
Pond, pit, lagoons
Wasta pi la
Storage t
Soil
Withdraw sample through ths bung opening.
Saraole drums only if they ara laying on sfda
with bung up. Withdraw sample through tha
bung opening.
Withdraw samples through ths top of barrels,
fiberdrums, buckets, and similar racactaclas.
Withcraw samples tnrcugn fill openings of bags
and sacks. Withdraw samaiaa through zha
cantar of the racastaclas and to differenc
points diagonally opposita tha pcin- of ar.-ry.
Withdraw sample through ooan hatch. Sor.pla
all othar ha-ccnas.
Oivida surface araa into an imaginary arid*1.
Taka thrae samples, if possible; c.-.a sar.sla
near tha surfaca, one sanpla at mid-cssth or
at cantar, and ona sacola at tha bottom.
Repeat the sampling at aac.n eric section ovsr
tha entira pond or sita.
Withcraw sair-oles through at laast thras dif-
ferent points naar the ten of pila to pointj
diagonally opposite tha point of entry.
Sanpla from the top through tha sampling hoi a.
Divide tha surfaca araa into an imaginary
grid*. Sasiple sach grid saction.
of
3 Tha nu-bar of grid sections is datarnined by the das i red nuccar
saraplas to be collected W.TIC.I, whan co.T.binad, should give a rspras;---
tativa S£.Tipla of tha wastas.
Scurca: da Vera at a1., "Sairpling Procaduras for Hazardous Wastastraazs11;
nodifiad slightly by Frad C. Hart Asscciatas,. I.ic.
5-A-24
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SLIDE 16.
SAMPLE IDENTIFICATION TAG
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UNITED STATES ENVIROiJMENTAL PROTECTION A&NCY
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5-A-25
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SLIDE 17.
Sample Custody Considerations
o A sample is under custody if:
a. it is in the sampler's actual possession; or
b. it is in the sampler's view, after being in his/her
physical possession; or
c. it was in the sampler's physical possession and then
he/she locked it up to prevent tampering; or
d. it is in a designated and identified secure area
o Field Custody Considerations
a. As few people as possible should handle the samples.
b. The field sampler is personally responsible for the care
and custody of the samples until they are transferred or
properly dispatched.
o Tranfer of Custody and Shipment
a. Samples must be accompanied by a Chain-of-Custody Record.
When transferring the possession of samples, the individuals
relinquishing and receiving will sign, date, and note
the time on the Record. This Record documents transfer of
custody of samples from the sampler to another person, to a
mobile laboratory/ or to the permanent laboratory.
b. Whenever samples are split with a facility or government
agency, a -separate Chain-of-Custody Record is prepared
for those samples and marked to indicate with whom the
samples are being split.
c. All packages will be accompanied by the Chain-of Custody
Record showing identification of the contents. The
original Record will accompany the shipment, and a copy
will be retained by the inspector.
d. If sent by a common carrier, a Bill of Lading should be
used. Receipts of Bill of Lading will be retained as
part of the permanent documentation.
5-A-26
-------
SLIDE 18.
Chain of Custody Secsrd
Instructions
The Chain of Custody Saccrd will ba filled out by providing tha infor-
mation re^aestsd. Thas'e information requirements ars dssc.-i'bs'. bsic'.-/.
1. Project Number. The facility's EPA Identification nun-car.
2. Project »far,9. The na.7,e and address of the facility.
3. SaaoleKs). The EPA inspactor(s) paraas.
4 Station Number. Tha number of the station frora which c sample
was taken.
5. Data. The data a saapla was taken.
S. Time. The tima a sample was taken.
7. Composite. Indicata if tha saffiple/^as a cotnposica senpTa.
3. Grab. Indicate if the sample was a grab sample.
9. Station Location. Tha direction (nor;.1!, south, aic.J and prax-
imity of the s.anple station tc a ber.cr.3ark.
10. Number of Containers. Humber of saippla containers til.an fro-
staticn and by aach method of sar.pl irg.
11. Analysis CasireJ. Type of analysis dasired to ba perfcnns'.! on
tha waste, i.e. 500, metals, ins'acticida casting.
12. Remarks. Additional information about tha sasr.plas such as the
type cf nedia sampled or type of container sampled.
13. P.alinquished by: (Signatura). The signature of tha ss.7ipla-(s).
14. Qate/Tias. Tha dat= and tisa the sampU was relinquished.
15. deceived by: (Signature). Whoever rscsivas tha sacaU, .T.CSX
likely a shipper, must sign for it.
16. Received for Laboratory fay: (Signature). The s;'gnatu*3 of a
perscn at tha lab who officially accapts tha sepias.
17. Oaca/Time. The data and tfaa tha sample is race*-.'ad by t.ia lati-
oratory.
13. Remarks. Final raaarkj about the samplas after accapts.-ca by tho
laboratory.
Mota: Chain of Custody must co.itir.ua for handling or" tha sar.pls a: tha iw
oratory.
5-A-27
-------
SLIDE 19
iiECEI
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=2sc'jrc2 Cor.ssrva-lon ar.d Rsccvsr-y Ac:, Sacs-fen 2G07(a)
ana/or dccursricja/ C2:;:r-!:r:
15
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f'.ata: This fc.Ti is 'jr.car^ci
. at « liter d;t2, £cc~
'.g A?2r;y ravlsw. A final form v.i'71 23
rsinis-: sy a sap^.'ata transsi""
5-A-28
-------
SLIDE 20.
Inspection Precautions
o The inspector must:
1. Remember that his/her function is to observe and evaluate
compliance while on Compliance Inspections. The overall
compliance or noncompliance status of the facility is
determined by the Enforcement Division upon review of the
Inspection Report. Statements regarding compliance status
anJ any legal effects or enforcement consequences should not
be discussed with the permittee or facility operating per-
sonnel.
2. Realize that it is an unacceptable practice to recommend a
particular consultant or consulting firm even if asked to do
so. However, it is not unethical to suggest that the permit-
tee, operator, or agent contact a professional society for
advice concerning this matter.
3. Make no attempt to substitute his/her own judgment for that
of plant operating personnel regarding details of operation.
5-A-29
-------
I. Right of Entry
A. Statutory Background
1. Clean Air Act
2. Clean Water Act
3. TSCA
4. RCRA (with recent amendments)
B. Case Law
1. Marshall v. Barlows
2. Contractor cases
C. How to get a warrant
1. Contact regional enforcement attorney
2. Preparation of affidavit
II. Witness for Enforcement Cases
A. Expert witness or fact witness
B. What you should expect '
C. Example of examination of a witness
5-A-30
-------
-------
AN INTRODUCTION TO SOME SURFACE GEOPHYSICAL
METHODS FOR HAZARDOUS SITE ASSESSMENTS
1. INTRODUCTION
A. This section provides a brief introduction to some surface
geophysical methods which can be used to assist and enhance
site evaluations.
B. Geophysical methods may be:
1) Airborne
2) Surface
3} Downhole
C. They often may be applied equally as well to problems on or
under water (fresh or salt) as well as terrestrial sites.
This presentation will deal with selected terrestrial
applications.
D. Geophysical measurements are generally considered an indirect
as opposed to a direct measurement.
5-B-l
-------
1) Coring or augering to evaluate subsurface strata is a
direct measurement.
2) Seismic refraction or resistivity soundings are indirect
measurements in that subsurface strata are inferred as a
result of interpretation of geophysical data.
E. By their nature, these methods respond to changes of physical
and/or chemical parameters at some depth. Hence, they can be
considered remote sensing methods.
F. Some geophysical methods can provide virtually continuous
data coverage along a survey line. Other methods provide
station-by-station measurements.
2. REASONS FOR CONSIDERING GEOPHYSICAL OR REMOTE SENSING METHODS
A. To improve confidence levels in site assessments
1) Additional information provides increased confidence.
2) Some geophysical methods can provide details and spatial
coverage unattainable by other means.
B. To provide a means of site assessment in cases where drilling
could be harmful to the site (karst) or dangerous to personnel
(drilling into unknown buried materials).
5-B-2
-------
*3. METHODS TO BE CONSIDERED
A. Ground Penetrating Radar (GPR)
B. Electromagnetics (EH)
C. Resistivity
D. Seismic Techniques
E. Metal Detectors
F. Magnetometers
Each method will be discussed separately, outlining basic
concepts, advantages and limitations.
4. GROUND PENETRATING RADAR (GPR)
A. GPR produces subsurface information as a result of
electromagnetic radar waves being reflected from soil and rock
horizons or man-made objects. Data are often presented as a
continuous graphic cross-section.
5-B-3
-------
Radar reflections occur as a result of changes in the complex
dielectric constant, which is an electrical property of
materials. The complex dielectric constant varies with many
physical and chemical parameters such as cementation, clay
content, and moisture.
C. Considerable detail can be obtained by radar such as buried
pipes, cables, buried materials, soil horizons and soil
piping, rock surface, bedding, fractures and cavities.
D. Interpretation of radar data can assist in understanding
complex geologic settings, permeable zones, and direct
detection of hydrocarbons.
Depth of penetration is often limited and ranges from less
that 1 meter to more than 20 meters. Shallow penetrations of
2 meters often can reveal significant information about deeper
structures or activity. Example: Piping and deep-seated
karst often manifest themselves in shallow data.
Degradation of radar performance (depth of penetration) will
be caused by increased electrical conductivity (free ions).
Performance also seems to be degraded in finer grained
materials. Shallow radar performance is not necessarily
degraded by increased moisture or even saturated soils and
rock. Often, good quality data is obtained in saturated soils
and rock.
5-B-4
-------
G. Radar performance is highly site-specific. With few
exceptions, at this time no reasonably reliable prediction of
performance can be made without on-site testing. Radar
performance is also frequency-sensitive, and the optimum
antenna (frequency) must be selected based upon depth of
penetration and resolution requirements (low frequency
antennas provide better penetration and higher frequency
antennas provide better detail).
H. A radar antenna can be manually towed over a site or pulled by
vehicle to produce a continuous section. Other specialty
approaches are available such as common depth point (C.D.P.),
static measurements, and even downhole measurements.
I. Radar data can be used "raw" as direct output from a graphic
recorder, or it may require computer processing before an
interpretation can be made.
5. ELECTROMAGNETICS (EM)
EM produces a measurement of bulk electrical conductivity of
the subsurface. The measurement is somewhat analogous to
resistivity measurements; however, no electrode contact is
necessary as current is induced inductively (by coils) into
the ground.
Data from the EM technique are obtained as a continuous strip
chart record or as discrete values from station-by-station
measurements. In use, continuous measurements to 6 meters
depths may be made by a field team traversing the site; or up
to 15 meters depth by vehicle.
5-B-5
-------
A change in electrical conductivity can occur as a result of
changes in pore space, pore fluids, cementation, soil or rock
types, or contamination. Therefore, EM is effective in mapping
changes in the natural geohydrologic setting and mapping
subsurface plumes from dumps and spills.
D. The continuous coverage of EM methods from less than a meter
to 15 meters depth provides significant benefits.
1) Provides excellent spatial resolution
2) Can provide continuous surface coverage
3) Is relatively rapid and very cost effective
4) Raw field data can often be directly interpreted for first
approximation results.
E. Station EM measurements are slower but can provide data in
areas which cannot be traversed by continuous methods.
F. By carrying out multiple parallel passes, one can approach
continuous two-dimensional spatial coverage. Three-
dimensional coverage can often be obtained by utilizing
multiple depth surveys.
5-B-6
-------
G. Generally, EM techniques are most cost-effectively applied to
profiling, lateral coverage at a fixed depth, although some
sounding information (determination of the vertical changes)
can be obtained.
H. EM performance is degraded by dense cultural features such as
buried pipes, cables, fences, etc. Even in the most difficult
situation, however, some data can usually be obtained.
I. Although raw EM data can often be utilized for preliminary
assessment, there are significant benefits to data processing.
Examples:
1) Spatial corrections of data
2) Removal of cultural features
3) Filtering
4) Obtaining statistical trends
5) Plotting of composite sets of data
5-B-7
-------
6) Plotting in three-dimensional perspective views
7) Plotting contour maps
6. RESISTIVITY
A. As with EM techniques, resistivity measures bulk electrical
properties of the subsurface. This technique requires direct
electrical contact with the earth via four probes driven into
the soil. Therefore, measurements can only be obtained on a
station-by-station basis and are slow compared to the EM
technique.
B. Data can be obtained by spatially sampling at a "fixed
depth"— a technique called profiling; or by sounding, using a
sequence of variable sampling depths.
C. This technique responds to changes in electrical resistivity*
as a result of changes in pore space, pore fluids, cementa-
tion, soil or rock type, or contamination (as with the EM
technique).
*resistivity (OHM-Meters) = 1 (Mhos/Meter)
conductivity
5-B-8
-------
While the EM technique provides a much more effective tool for
profiling, resistivity will generally provide more detailed
sounding data. When used together in this way, the two
methods provide a powerful, cost-effective combination of
analytical tools.
Sounding data must be plotted vs. electrode spacing, which is
related to sampling depth. This data can then be interpreted
manually by use of master curves or by computer models for a
multilayer earth. The results reveal the changes in
resistivity with depth.
As with the EM method, resistivity is subject to cultural
influences. In addition, near-surface variations can
significantly influence results (small inhomogeneities near
the potential electrodes). The technique is much slower than
EM and therefore more costly, but does provide sounding data
and can be adapted for measurements in unique situations.
7. SEISMIC REFRACTION & REFLECTION
The refraction method is traditionally applied to shallow
problems to define thickness and depths of soil/rock layers as
well as provide a measure of density or hardness. The method
responds to a change in acoustic impendance from one layer
to another, resulting in refraction of seismic waves. The
measured value is travel time or velocity (Vp) of the seismic
wave.
B. The refraction method has two inherent limitations:
5-B-9
-------
1) Thin layer problem
2) Inverted velocities (high-velocity overlaying lower-
velocity material)
C. While shallow surveys up to 50 feet in depth are often accom-
plished using a sledge hammer source, deeper surveys require
larger energy sources.
As with the resistivity technique, measurements are made on a
station-by-station basis and results must be plotted and
interpreted. First-order results may be obtained in the
field. Higher-order analysis may be obtained by computer
processing.
The use of shallow reflection methods is relatively new.
While it avoids some of the problems of refraction, there must
be a sufficient reflection contrast to be seen, and at present
the method is best used with reflectors at depths of about 10
meters and greater. The data will usually require more
processing and interpretation than does refraction work.
However, reflection does provide some unique possibilities to
obtain solutions not reached by the refraction method.
8. METAL DETECTORS
5-B-10
-------
Metal detectors are used to detect any type of metallic item.
A variety of detector models can be found in the commercial
market, which are mostly intended for use in the location of
pipes and cables. The small hand-held treasure hunter models
are generally intended for shallow targets.
B. Metal detectors respond to the high electrical conductivity of
metallic targets.
C. Unfortunately, metal detectors are relativety near-field
devices. Their sensitivity falls off as:
1
(distance) exp 6
As a result, standard commercial devices can detect a single
55-gallon drum at a maximum distance of about 8 feet. This
distance can be extended to about 10 to 12 feet with special
systems.
Generally, metal detectors with larger coils will have greater
detection distances, and targets with increased surface areas
can be detected farther away. It is the surface area that
makes the difference, not the mass of a target. This makes a
55-gallon drum a good target for a metal detector. In
practice, reliable detection distances may be much less than
the distances quoted above due to geologic and cultural noise.
E. Many detection systems are sensitive to capacitative effects
(proximity to the operator, weeds, brush, etc.) as well as
magnetic (iron oxides) content of soils or to conductive
fluids associated with a dump site.
5-B-ll
-------
Besides improved detection distances, some special systems can
provide a measure of target identification. They also provide
for continuous recording of the detector output, which is
invaluable in detailed site analysis if more than a yes or no
answer is required of the detection survey.
G. Most detectors will fail to perform if lateral metallic objects
such as fences are nearby. Special systems are available to
cope with such problems and can be operated within 12 inches
of chain link fences with full vertical sensitivity.
H. Detection surveys are made by the field crew walking over the
site, or the system may be vehicle-mounted for coverage of
large open areas.
In some simple cases, data may be analyzed in the field. In
complex situations, data should be computer processed so that
all data is spatially corrected as a minimum. Other
processing such as performed on EM data may be used to enhance
the data and its presentation.
9. MAGNETOMETRY
A. Magnetic surveys as used herein are intended for locating iron
or steel (ferrous) objects such as steel drums, as opposed to
geologic surveys.
5-B-12
-------
B. A magnetometer responds to changes (distortions) in the
earth's magnetic field caused by the presence of ferrous
objects. A magnetometer will not detect non-ferrous metal
such as aluminum, copper, tin, etc.
C. Compared to a metal detector, magnetometers can detect objects
at much greater distances depending upon the specific system
and its sensitivity. For example, a total field magnetometer
can detect a single 55-gallon steel drum at approximately 30
feet or more.
D. A magnetometer's sensitivity for a discrete target such as a
drum falls of as:
total field instruments
(distance) exp 3
1 gradiometers
(distance) exp 4
E. Even though it has a lower sensitivity, the gradiometer has
considerable advantage in mapping and interpretation, as well
as in reducing "noise" in the measurements.
5-B-13
-------
Since a magnetometer responds to the presence of any ferrous
object, operation near cultural features such as steel fences
or near roads with passing cars may be an insurmountable
problem. Special instruments and techniques are available to
cope with these problems.
G. Many magnetometers (Proton) operate on a periodic sampling
basis. Such systems should be avoided in favor of
continuously sampling and recording systems. As with a metal
detector survey, continuous recorded data is vital in
assessing complex sites.
H. As with metal detectors, the survey team may walk a traverse
or equipment may be vehicle-mounted or towed.
I. In simple cases, data can be directly interpreted in the
field. On complex surveys or those requiring a semi-
quantitative analysis, data is best processed by a computer.
10. COMPOSITE SURVEYS
Confidence levels are usually significantly improved by
combining the results of geophysical and/or other methods. If
for example, both the results of a seismic and resistivity
survey indicate top of rock at a 20-foot depth, then we have a
high level of confidence in the interpretation, even without
drilling.
5-B-14
-------
The results of a combined metal detector and magnetometer
survey for buried drums can yield considerable information.
For example, if no metal detector response is obtained and a
reasonable magnetometer response is, then we may conclude that
the drums are buried beyond the range of the metal detector.
We now know something about the depth to the top of drums.
The magnitude of the magnetic anomaly can then give us an
estimate of the number of drums.
11. SUMMARY
A. The geophysical methods can provide many details on subsurface
features. In certain cases, some types of geophysical surveys
can provide details which would require enough drilling to
make swiss cheese of the site. In others, extensive spatial
coverage would require both a costly and time-consuming
drilling project.
B. In cases where drilling can create problems such as in karst
settings or be potentially dangerous such as drilling into
explosive materials, the remote-sensing geophysical methods
may provide the answers in a safe and cost-effective manner.
C. Geophysics is not a substitute for drilling or direct
sampling, but when suitably combined with drilling, produces a
far superior site evaluation.
Generally, maximum benefit is obtained from geophysical
methods if they are used early in the site assessment phase.
Often the optimum placement of drill holes is clearly shown by
such data. Sometimes this optimum scheduling cannot be
achieved. Then the geophysical results can be used to
evaluate the placement of existing drill holes to assure they
are in representative locations.
5-B-15
-------
The geophysical methods are not a panacea in themselves. They
need to be properly selected and applied by experienced per-
sonnel. Further, they require interpretation by incorporating
sound professional geologic and hydrologic knowledge of the
site blended with other geophysical and direct approaches.
5-B-16
-------
-------
APPENDICES
A. Toxicology
B. Chain-of-Custody and Packaging, Marking, Labelling, and Shipping
of Hazardous Waste Site Samples
C. EPA Occupational Health and Safety Policy
D. Setting Priorities for Activities Relative to Hazardous Waste
Sites
E. Enforcement
F. Open
-------
-------
Toxicology
Objectives
Toxicology is the study of the harmful actions of
chemicals on biologic tissues. To judge impending or po-
tential toxicity requires an understanding of chemical
reactions and interactions and an understanding of biologic
mechanisms. The vastness of the subject and the rapid day-
by-day increase in knowledge precludes the possibility that
any one mind could absorb and retain more than a small
fraction of this knowledge. However, certain principles of
toxicology are applicable to a large number of chemicals and
an understanding of these principles is essential for the
:
development of insight into toxicological judgments.
It is the objective of this course to provide a concise
description of the principles involved in human toxicology
to prepare students to make reasonable judgments regarding
potential and imminent risks of chemical-biologic inter-
actions.
Our strategy will be to present general concepts as a
foundation on which to discuss the specifics of the des-
ignated hazardous substances.
A-l
-------
PRINCIPLES OF TOXICOLOGY
A-2
-------
.PRINCIPLES OF TOXICOLOGY
I. HISTORY
The word "Poison" maybe used- to describe materials or chemicals that
are distinctly harmful to the body. In contrast, the word "food" is the
term used for materials beneficial and necessary for body function. Ex-
perience has shown that there are decrees of hannfulness and degrees of
safeness for any chemical. AITi_ _ir.i;ior_var.t factor that determines the degree
of hanafulness of a compound is eh-, close of that compound.
The word "Toxic" may be considered synonomous with harmful in regard
to the effects of chemicals. Toxicc-Icgy, defined as the study of the harm-
ful actions of chemicals on biologic mechanisms, has developed into three
principal areas. Environmental roxlcology is concerned with harmful ef-
fects of chemicals encountered by -an either incidentally in the atoraosphere,
by contact during occupational or recretional activities, or by ingestion.
Economic toxicology deals with harmful effects of chemicals administered to
biologic tissue for the purpose of achieving a specific drug effect. For-
ensic toxicology deals with medical and legal aspects of harmful effects of
chemicals on humans.
II. PHARMACODYNAMICS
Introduction of chaziicals ir.tc hiologic organisms.
A. Inhalational route; The hazari following exposure to chemicals via the
respiratory tract are particularly evident in industrialized urban areas of
high-density population. The ntno?r:v'ere in which people work is contaminated
with a variety of chemicals. ~.« American Conference of Governmental In-
dustrial Hygienists has cocpiled a list of Threshold Limit Values (TLV's).
These TLV's refer to airborne concer.cratiions of substances under vhich it
is believed that nearly all Iranians inay be repeatedly exposed, day after day,
without adverse effects.
TLV's are expressed as: ppai (parts per million par.ts of air by volume
at 25°C and 760 mm Kg pressure) or as mg of particulate matter per cubic
meter of air.
TLV's for respirable dusts, such as talc, cement, or asbestos, which
are suspended in the air, are in terrr.s of ni.p.p.c.f. (millions of particles
per cubic foot of air).
TLV's represent the average concentration over the period of time of
measurement. A maximal value of contamination that should not be exceeded,
is called the m.a.c. (maximal allowable concentration).
B. Oral route; Another common vay by which a chemical enters the body
is by mouth. Although it is within the body, the gastrointestinal contents
are essentially exterior to the body fluids. Orally ingested chemicals can
have a systemic effect on the organism only after absorption. Under ordinary
conditions, the first site from which orally ingested chemicals can be ef-
fectively translocated is the stomach.
A-3
-------
C. Enterohepatic circulation: This is a cycle involving trans location of
the chemical from the intestine to the liver, and back to the intestine via
the bile. The liver may biotransform or conjugate a chemical and excrete
the conjugate vhich is then carried to the intestine and reabsorbed into the
portal circulation. Both molecular size and degree of conjugation influence
the biliary excretion*of the compounds.
D. Parenteral route; This is the introduction of chemicals into the or-
ganism by means of injection of the chemical from a syringe through a hol-
low needle at specific sites.
III. TYPES OF TOXICITY
A. Nonspecific Action
Nonspecific action is caused by all caustic or corrosive chemicals
and involves partial-to-coraplete destruction of all parts of biologic cells.
Generalized destruction of cells can be produced by any chemical that is
sufficiently soluble in tissue fluids to gain access to the cells in high
concentrations.
B. Selective Action
Within the body normal molecular components of cells are capable of
reacting with foreign chemicals. Such components may be referred to as tar-
gets for the foreign chemical. If the target chemical reaction alters the
function of the cell, such targets are given the general term of "specific
receptors". The same chemical may at the same time combine with, react with,
or be adsorbed on other sites, but the function of the cells is not influences
by the product which is formed. Such combining sites are referred to as
"silent receptors".
IV. BIOLOGIC FACTORS THAT INFLUENCE TOXICITY OF CHEMICALS
Factors that influence toxicity of chemicals are:
(A) Absorption and distribution
(B) Storage
(C) Tolerance
(D) Rate of metabolism
(E) Rate of excretion
A. Absorption and distribution of Chemicals
A chemical agent must come in contact with a reactant chemical in
the biologic system if a chemical interaction or physical effect Is to'occur.
Membranous barriers influence transport of any chemical from the
exterior to the interior of a cell.
Absorption across membranous barriers involves a series of steps
and exposes the chemical to large endogenous molecules, such as proteins,
which may effectively bind or functionally alter the chemical. During this
process the chemical is subject to storage by some tissues, as well as ex-
cretion by the kidneys, respiratory tract, liver or secretory glands of the
body.
A-4
-------
.Following absorption the chemical can be:
1. Bound to plasma protein
2. Altered (biotransforr.-.ed") by specific or nonspecific enzymatic
systems present in various organs
3. Deposited in storage tissues
4. Excreted
Any chemical that is taker, into the organism is immediately sub-
jected to mechanisms that ci;vy clear its distribution within the organism
oc terminate its existence us z. free chemical. (Figure 1)
(B) Storage of Chemicals in thr- Bc^y
The same mechanisms thr.t .ire involved in the uptake of a chemical
agent are involved in the elimination of the agent from the cell. The
rate of elimination depends en the nature of the chemical and the
mechanisms that are used to terminate the presence of the chemical in
the body. Generally, chemicals that are metabolically converted by the.
body to derivatives will have short lives within the body. A chemical
that is both metabolized and deposited in fat has a short lifespan in
the blood and the nonfatty tissues (e.g. thiopental).
Many chemicals are selectively absorbed or combined with proteins or
enzymes or even cosponenti of ione.
Examples;
Ninety-eight per cent of bishydroxycoumarin (dicumarol) is carried
in the blood cor.bir.ed v?ith albumin where it is hot free either to
produce an effect on calls nr to be subject to metabolic attack.
Quinacrine (Atsbrine) is distributed so that the liver concentration
of the drug after £ single dose may be as much as 2,000 times
greater than tha concentration in the plasma.
Tetracyclines combine with components of newly-formed bone so that
reabsorptior. of bone rust take place before the drug can be
eliminated.
Chlorophenothane (DDT) is stored in fat and remains in the body
for months. .
Sites of deposition, cbsorption, or reaction of chemicals within the
body act as effective storage copots for chemicals that otherwise may
be effectively metabolized or excreted. These sites of storage also
effectively prevent high concentrations of the free chemical so that
toxic concentrations arc not normally achieved until the storage sites
have become saturated.
The toxicity of a chemical is therefore influenced by the availability
of efficient nonspecific binding sites, or the presence or absence of
efficient biotransformation mechanisms.
Toxicity is directly related to the available active concentration
of a chemical. Only the free form of a chemical is available for
exerting a toxic action.
A-5
-------
OUTSIDE
EXPOSURE TO
CHEMICAL OR
DRUG
DRUGS A.-0 CHEMICAL PASSAGE
IN THE MAM^LIAM ORGANISE
HUCOSAL
v7
STORAGE
DEPOTS
\
KLMBRAJJE -CA PILLARY
MEMB KANE-CEIL
MEMBRAXE-
CAPIULARY
CELL
V7
URINE
BIOTKANSKORMATION
SITES
/
CILJ
TEARS
SALIVA
\7
A
I
S
0
I
p
r
i
o
N
T
it
A
N
S
w
0
c
X
C
t
I
T
I
0
H
FECES
A-6
-------
The rate of elimination of a chemical is influenced by the binding
and storage of that chemical within the body. Repeated exposure to a
chemical, in which the interval between exposures is less than the life
of the chemical within the body, would lead to accumulation of that
chemical in Che organism.
(C) Tolerance
Tolerance occurs when a scalier response results from a fixed dose
of a chemical than was obtained on a prior exposure to the same dose.
Tolerance is a descriptive tern and could be defined as the result of a
failure in translocation of th-? chemical, such as impaired absorption
or distribution, or an enhanced termination, i.e. enhanced excretion or
metabolic alteration of the chemical in the organism.
A-7
-------
CORROSIVES
A-8
-------
Acids and acid-like corrosives
Legend: .
1 - Mild irritation
& reddening
2 - Strong irrita-
tion and blis-
tering
3 - Superficial
destruction of
skin or mucous
membrane
4 - Complete destruc-
tion of skin or
mucose membrane
Acetic acid (glacial)
Acetic anhydride
Acetyl chloride
Amy Urichlorocyc lane
Boron trifluoride
Threshold Limit
Value (ppm)
Estimated Fatal Dose
(g or ml)
Corrosive Effect
10 20 3
5 10 .1
5 1 4
1 4
1 | 1- 4
Bromine U.I j 1 4
Calcium chloride j | 30 i 2
Chlorine I i -4
Chlorine dioxide j 0.1 j 4
Cnlor:ne triHuorido
CMorosulfonic acid
L-Hh.yl chlorocarbon.ito
h ormic acid
Kuroyl chloride
Hydrazoic acid
Hydriodic acid
Hydronro:nic acid
Hydrochloric acid
Hydrogen brotnalc
Hydrogen iodato
Lactic acid
Maleic anhydride
Nitric acid
Osmic acid
Peracclic acid
Perchloric acid
Fcrsulfalu salts
Phnnylmngncsium chloride
Phosphoric acid
Phosphorus trichloride
Platinum salts
Sodium acid sulfnte
.Sodium hvdrosuLfitc
Sodium sulfite
Stannic chloride
O.I i -I
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Sulfur monochloride
Sulfur pentaOuoride
Sulfuric acid
Sulfurous acid
Tartaric acid •
Titanium tetrachloride
Trichloroacetlc acid
1 1 4 i 4
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A-9
-------
CORROSIVES
Oxalic Acid
Formula: COOH - COOH; soluble in water; fumes when heated to 100 C.
Oxalic acid and oxalates are used as bleaches and metal cleaners in industry
and in household products. The leaves of garden rhubarb (Rheum sp) contain a high
concentration of oxalate.
The fatal dose by ingestion is_ estimated to be 5 - 15 g.
Oxalic acid is a corrosive acid. Oxalates combine with serum calcium to form
insoluble calcium oxalate. The reduction in available calcium leads to muscular
stimulation with convulsions and collapse.
In deaths following oxalic acid poisoning, calcium oxalate crystals are found in
the kidney and in other tissues. The kidneys show cloudy swelling, degeneration, and
destruction of the tubules. Corrosive changes may be found in the mouth, esophagus,
and stomach. Cerebral edema also is a frequent finding.
Signs and Symptoms -
The principal manifestation of oxalic acid poisoning is kidney failure.
Symptoms following ingestion, begin with local irritation and corrosion of the
mouth, esophagus^ and stomach, with pain and vomiting. These symptoms are followed
shortly by muscular tremors, convulsions, weak pulse, and collapse. Death may occur
within minutes. After apparent recovery or if oxalate is ingested, acute kidney failure
may occur from blocking of kidney tubules of calcium oxalate.
Prolonged skin contact may cause cyanosis and gangrene by local corrosive effect.
Prolonged inhalation of fumes produced by boiling oxalic acid solutions leads to oxalic
acid poisoning with kidney impairment.
Calcium oxalate crystals, red blood cells, and protein are found in the urine
following oxalate intoxication.
Prevention:
Avoid prolonged skin contact. Avoid fumes from boiling oxalic acid.
A-10
-------
2
Emergency measures - Following ingestion, precipitate oxalate by giving calcium
in any form orally, such as milk, lime water, chalk, calcium gluconate, calcium
chloride, or calcium lactate. Remove skin contamination by washing skin with soap
and water and by continuous flushing with water. Remove from further exposure.
Seek immediate medical attention.
Prognosis:
If calcium antidotes can be given promptly, recovery is likely.
A-ll
-------
MISCELLANEOUS ACIDS
Substances Hydrolyzed to Acids
Some commonly used acids and acid-like corrosives listed in the table are used
for cleaning metals and other products and in a variety of chemical reactions.
Ingestion of 1 ml of a corrosive acid has caused death. Death may occur up to 1
month after exposure to corrosive fumes such as nitrogen oxide, as in silo gas
poisoning.
Corrosive acids destroy tissues by direct chemical action. The tissue protein is
precipitated and coagulated in concentrated acid. The intense stimulation by
acid also causes loss of vascular tone.
Findings are those of corrosion and irritation.
A-12
-------
The principal manifestation of acid poisoning is corrosion.
Ingestion - Severe, burning pain in the mouth, throat, and .abdomen followed by
vomiting and diarrhea of dark precipitated blood. The blood pressure falls
sharply. Brownish or yellowish stains may be found around or in the mouth.
Asphyxia occurs from edema of the throat.
After initial recovery, onset of fever indicates perforation of the esophagus
or the stomach.
Inhalation of acid fumes or irritating gases causes coughing, choking, and
variable symptoms of headache, dizziness, and weakness followed after a 6-8 hour
latent period by lung edema with tightness in the chest, air hunger, dizziness,
frothy sputum, and cyanosis, bloody sputum, and shortness of breath to chlorine
or other corrosive vapor.
Skin contact may produce severe pain and brownish or yellowish stains. Burns
usually penetrate the full thickness of the skin, have sharply defined edges, and
heal slowly with scar formation.
Eye contact produces edema and corneal destruction from even dilute acids in the
eyes. The symptoms are pain, tearing, and photophobia.
Long exposure from inhalation to acid fumes may cause erosion of the teeth followed
by jaw necrosis. Bronchial irritation with chronic cough and frequent attacks of
bronchial pneumonia are common. Gastrointestinal disturbances are also noted.
After inhalation of corrosives, diffuse mottling of the lung fields may be seen
on x-ray.
Prevention:
The TLV must always be observed. Water bubbler eye fountains and showers must be
available where skin or eye contact with acids is possible.
Tight-fitting goggles, rubber aprons, and rubber gloves must be worn when handling
acids. Employees must be drilled in the constant use of safety equipment.
A-13
-------
Enclosed spaces containing corrosive gases should be thoroughly ventilated before
being entered. Use of proper breathing apparatus is advisable.
Emergency measures -
Following ingestion, dilute the acid within seconds by drinking quantities of
water or milk. If vomiting is persistent, administer fluids repeatedly. Ingested
acid must be diluted approximately 100 times to render it harmless to tissues.
Following ,Eye Contact:
Flood affected area with quantities of water in a shower or by means of a water
bubbler eye fountain for at least 15 minutes. The eyelids must be held apart during
the washing. Do not use chemical antidotes. The heat liberated in the chemical
reaction may actually increase injury. Eye burns require the immediate attention
of an ophthalmologist. If an ophthalmologist is not immediately available, wash
the eyes and apply sterile bandages without any medication. Then take the victim
to an ophthalmologist.
Following Skin Contact:
Remove acid by flooding with water for at least 15 minutes. If the clothing is
contaminated, a stream of water must be directed under the clothing while the
clothes are being removed in order to remove the acid rapidly. Do not use chemical
antidotes. Treat damaged areas as forthermal burns. Seek immediate medical
attention.
Following inhalation:
Use respiratory resuscitation measures. Administer oxygen and use artificial respira-
tion. Remove from further exposure.
Prognosis:
In one series, 32 of 105 persons who ingested acid died. Damage to the esophagus
and stomach after ingestion may progress for 2-3 weeks. Death may occur as late as 1
month after ingestion. Approximately 95% of those who ingest acid and recover from
immediate effects have persistent damage.
A-14
-------
Skin burns from acid are followed by extensive scarring. Skin grafting is
required if a good cosmetic effect is desired. Eye damage almost always results in
blindness.
After inhalation of corrosive atmospheres, convasescence may be prolonged and
frequent relapses may occur. Death may occur 30 days or more after exposure to such
corrosive atmospheres.
NITROGEN OXIDES
The nitrogen oxides important in air contamination and in reactions that form
atmospheric oxidants include nitric oxide (NO, colorless), nitrogen dioxide (N02,
brown color), nitrogen trioxide (N203, colorless), nitric acid (HN03), and nitrogen
pentoxide (N205, colorless). Nitrous oxide (N20, laughing gas, colorless) and
nitrogen tetroxide (N204, colorless) do not occur in the atmosphere in significant
amounts.
Nitrogen oxides are emitted into the atmosphere as a result of combustion of any
nitrogen-containing substances. Thus, missile fuels, explosives, cigarettes, and
agricultural wastes liberate nitrogen oxides. Nitrogen dioxide also occurs during
the rapid decomposition of plant material, as happens in silos. In an enclosed silo,
the concentration of nitrogen dioxide may reach as high as 1500 ppm. In addition,
combustion at high temperatures of nitrogen-free fuels in the presence of air oxidizes
the nitrogen of the air to nitric oxide (N2 + 02= 2NO). At 1800 K, 1% of the reactants
will be converted, and at 2675 K, 5% of the reactants will be converted. Unmodified
auto or diesel exhaust contains 1100 ppm of nitric oxide, producing an emission of
0.13 Ib/gallon of fuel or 4 g/mile for a vehicle consuming 1 gallon of fuel each 15
miles. For 1977 and after, federal regulations limit all new automobiles to emission
of 0.31 g/mile of nitrogen oxides. Cigarette smoke contains 200-650 ppm of nitrogen
oxides, and pipe smoke contains 1100 ppm.
On reaching the air, nitric oxide oxidizes spontaneously to nitrogen dioxide,
which gives smog its brown color. This reaction is slow if the concentration of nitric
A-15
-------
oxide is below 1 ppm, but is speeded by the presence of other contaminants in the air,
especially ozone. This color can be seen most clearly by looking into an air-polluted
basin from above the temperature inversion boundary on any day with low wind velocity.
The TLV for industrial exposure to nitrogen dioxide is 5 ppm and for submarines
in the US Navy 0.5 ppm. The TLV for nitric acid is 1 ppm. A maximum for nitrogen
oxides in community air of 0.25 ppm was exceeded for a total of 487 hours in San
Francisco in 1967 and for 2594 hours in the same year in Burbank, California.
The taste and odor of threshold for nitrogen dioxide is 1 ppm. Chest discomfort
occurs at a concentration of 15 ppm for 1 hour, the sensation becoming unpleasant at
20 ppm. After 1 minu-te at 50 ppm, chest pain may be felt. Longer exposure at this
concentration has caused inflammatory changes in the lungs which ordinarily are
reversible. Higher concentrations have been fatal.
Effects seen on the lungs include hemorrhage and irreversible fibrous replacement
of functional tissue.
The principal manifestation of nitrogen dioxide poisoning is difficult breathing.
From inhalation, progressive weakness, difficult breathing, cough, and cyanosis
begin 1-3 weeks after single or repeated exposure to concentrations of 50-300 ppm.
Concentrations above 300 ppm cause lung edema or pneumonia with onset within hours or
days.
Lung function tests reveal reduction in inspiratory capacity, reduction in vital
capacity, and impaired diffusion capacity. These findings improve as the inflammatory
process subsides, but some impairment of function may be permanent.
Prevention:
Wear breathing apparatus or thoroughly ventilate area before entering.
Emergency measures:
Give oxygen for difficult breathing. Seek immediate medical attention.
Prognosis:
Recovery may require 1-6 months. Permanent changes may persist depending on the
severity of the original damage.
A-16
-------
ATMOSPHERIC OXIDANTS
Atmospheric oxidants are substances with an oxidizing power sufficiently great to
liberate iodine from a solution of potassium iodide. One oxidant, ozone (03),
accelerates the cracking of rubber, a property that can be used to measure the total
exposure to ozone over a period of time. These oxidants make up the eye irritants in
photochemical smog resulting from the action of sunlight on air containing nitrogen
dioxide and certain organic compounds.
Reactions which initiate the formation of oxidants depend on the absorption of
light energy. Light in the ultraviolet spectrum is more important since it has greater
energy. The following reactions are considered to be important in the absorption of
light energy (hv) and the production of monatomic oxygen (0) and free organic radicals (R)
N02 + light energy = NO + 6 RONO + light energy = RO + NO
RCHO + light energy = R + HCO RONO + light energy = R + NO.
RCHO.R + light energy = R + RCO
Other reactions may occur in the dark:
6 + 02 = 03 CH300 + 02 = CH36 + 03
03 + NO = 02 + N02 CH36 + NO = CHgONO
0" + C4H = CH3 + C3H50 CH36 + 02 = H2CO + HOO
CH3+ 02 = CH300 03 +2N02= NgOg + 02
The following reaction scheme from ethylene (C2H4) to peroxyacetylnitrate (PAN) has
been proposed:
C2H4 + 03 = C2H403
2 C2H403 = HCHO + CH30 + CH3CO + 03
CH3CO + 02 = CH3C03
CH3C03 + N02 = CH3CO.O.ON02 (PAN)
The concentration of ozone does not begin to rise until nitric oxide (NO) has been
completely converted to nitrogen dioxide (N02). Although nitrogen dioxide alone contri-
butes to the formation of a small amount of ozone, the levels found in urban atmospheres
do not occur unless some of the carbon compounds indicated in the above schemes are
A-17
-------
present. These include aldehydes, ketones, and unsaturated hydrocarbons. The
reactivity of these substances in atmospheres forms the basis for the restriction
of their use in various solvents for paints, lacquers, and other finishes. Methane
(CH4), which makes up about half of the organic compounds in the atmosphere, does
not react. Some of the reaction intermediates are possible contributors to eye
irritation, but they are so unstable that analysis or experimental testing has not
been possible. PAN has been tested and found to be eye-irritating at concentrations
of 0.5 ppm. This concentration is higher than that which is likely to occur in the
atmosphere. Combinations of reactants may be more irritating than individuals.
At the peak of oxidant concentration in the atmosphere (shortly after midday),
ozone makes up more than 90% of the total. By nightfall ozone falls to a low level,
but oxidants may still be present. The chemical make-up of all the dark-reaction
oxidants has not been defined. One compound has been identified as PAN.
Electrical discharges such as lightning and intense ultraviolet light also produce
ozone. At an altitude of 75,000 feet, the concentration of ozone is raised to
16 ppm by the direct action of sunlight. Unless some means is used to decompose
the ozone, the concentration inside pressurized aircraft flying between 30,000 and
40,000 feet reaches 0.3 - 0.4 ppm. Some ozone found at ground level is brought down
to this level by atmospheric mixing, but this amount does not exceed 0.01 - 0.03 ppm
except during lightning storms.
A standard for community air of 0.1 ppm oxidants has been set in California.
In 1967, San Jose, California, exceeded this level for 272 hours, Burbank for 1191
hours, and Pasadena for 1245 hours. In the same year, a level of 0.05 ppm was
exceeded for 1032 hours in San Jose, 2198 hours in Burbank, and 2243 hours in Pasadena
while San Francisco had 129 hours above 0.05 ppm and 25 hours above 0.1 ppm. The
industrial TLV for ozone is 0.1 ppm.
The odor threshold for ozone in insensitive persons is 0.01 ppm, but it is only
recognized by all persons at 0.05 ppm. At a concentration of 0.1 ppm of ozone or
oxidants, more than 5% of individuals will have symptoms of eye irritation.
A-18
-------
Persons with lung diseases such as asthma or emphysema, when exposed to an
ambient atmosphere containing 0.1 - 0.15 ppm of oxidants, show increased breathing
resistance, increased oxygen consumption , and decreased blood oxygen concentration.
Recovery from the effects of oxidant-contaim'ng ambient air requires several days.
Experiments have shown that exposure to ozone, 0.2 ppm for 3 hours, reduces
visual acuity, increases peripheral vision, decreases night vision, and alters
the balance of the muscles controlling the position of the eye.
Asthmatic patients report more attacks when the daily peak of oxidants goes
over 0.25 ppm. A level of 0.3 ppm ozone causes cough and some respiratory tract
irritation after 30 minutes of exposure. Progressively higher concentrations are
more irritating, and lung function is distinctly impaired at concentrations of 0.6
ppm ozone.
Ozone and other oxidants produce their irritant action as a result of their
chemical reactivity at the point of contact. These oxidants may be absorbed into
the blood stream.
Treatment
The use of activated charcoal adsorbers in rooms has been suggested as a means
of lowering air contaminant concentrations.
SULFER OXIDES
The following sulfur oxides occur as atmosphere contaminants: sulfur dioxide
(S02), sulfur trioxide (S03), sulfurous acid (H2S03), and sulfuric acid (H2S04).
Sulfur dioxide reduces visibility by taking part in reactions between organic
compounds and nitrogen oxides to form particulates. Oxidation to sulfur trioxide,
which then combines with water to form small droplets of sulfuric acid, also
reduces visibility.
Sulfur oxides come from fuel oil and co'al combustion, from petroleum refining,
and from the chemical and metal-lurgic industries.
California has established a maximum of 0.1 ppm sulfur dioxide concentration
A-19
-------
for 24 hours with no 1-hour value to exceed 0.5 ppm for community air. For
industrial exposures, the TLV for sulfur dioxide is 5 ppm; for sulfur trioxide,
2 ppm; for sulfuric acid, 1 mg/cu m; and for sulfurous acid, 10 ppm.
Trained observers can recognize the presence of sulfur dioxide at a concentration
of 0.3 ppm, but concentrations up to 1 ppm have little effect on lung function
except for possible increase in respiratory rate. Increased resistance to breathing
begins to occur at 1.6 ppm in normal individuals and possibly at 0.7 ppm in persons
with respiratory disease. Concentrations in air pollution disasters such as occurred
in Donora, Pennsylvania, and London, England, have ranged from 1-3 ppm. The eye
irritation level is 10 ppm.
The principal manifestation of sulfer dioxide poisoning is difficult breathing.
From inhalation, progressive weakness, difficult breathing, cough, lung edema or
pneumonia may occur. Lung function tests reveal reduction in inspiratory capacity.
Prevention:
Wear breathing apparatus or thoroughly ventilate area before entering.
Emergency measures:
Give oxygen for difficult breathing. Seek immediate medical attention.
Prognosis:
Recovery may require 1-6 months. Permanent changes may persist depending on
the severity of the original damage.
ALKALIES & PHOSPHATES
These agents are used in the manufacture of soaps and cleansers and in chemical
synthesis.
The alkalies combine with protein to form proteinates and with fats to form soaps,
thus producing soft, deep destruction areas on contact with tissues. The solubility
of these products allows further penetration which may continue for several days.
Sodium and potassium hexametaphosphates, polyphosphates, tripolyphosphates,
pyrophosphates, and other phosphates form complexes with calcium and are capable
of "seriously reducing the blood serum calcium. They also have a corrosive effect
A-20
-------
on mucous membranes and skin.
Findings include gelatinous destruction of tissues at sites of contact.
The principal manifestation of poisoning with the alkalies is corrosion.
Alkali corrosives
Legend:
1 - Mild irritation
& reddening
2 - Strong irrita-
tion and
blistering
3 - Superficial
destruction
of skin or
mucous mem-
brane.
4 - Complete destruc
tion of skin or
mucous membrane.
-Amlnobutane
2 - Amlnopropane
Bulylamme
Calcium carbide
Calcium oxide
Cement (Portland)
Diothanolaminc
Diclhylaminc
Dirthvlenc triammo
Dimelhvlammc
l.lliannlammc
l.thv In mine
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Lithium hjdi-Klc
Lithium h>dro\ido
Mc'.hylamme
Potassium carhonali*
Potassium hydrox-de
Sorlium rarhonat"
Sodium hydroxide fLyS^
bodium pho.sphales '
Sodium silicate
Tricthanolaminc
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Ingestion of alkali is followed by severe pain, vomiting, diarrhea, and collapse.
The vomitus contains blood and fragments of stomach and intestine. If death does not
occur in the first 24 hours, the patient may improve for 2-4 days and then have a
sudden onset of severe abdominal pain, board-like abdominal rigidity, and rapid fall of
blood pressure indicating delayed stomach or esophageal perforation.
Even though the victim recovers from the immediate damage, swallowing may be
A-21
-------
difficult due to constriction of the esophagus.
Ingestion of hexametaphosphate, tripolyphosphate, and other phosphates cause a
shock-like state, fall of blood pressure, slow pulse, cyanosis, coma, and sometimes
tetany as a result of reduction in ionic calcium.
Eye contact with concentrated alkali causes edema and cornea! destruction.
Alkalies penetrate skin slowly. Extent of damage therefore depends on duration
of contact.
A chronic rash may follow repeated contact with alkalies.
Prevention:
Store corrosive alkalies safely. Water bubbler eye fountains and showers must
be available where skin or eye contact with alkalies is possible. Tight-fitting
goggles, rubber aprons, and rubber gloves must be worn when handling alkalies in
concentrated solutions. Handlers must be drilled in the constant use of safety
equipment.
Emergency measures:
Following ingestion, dilute the alkali by giving water to drink immediately and
allowing vomiting to occur.
Following eye contact, wash eyes with running water for 30 minutes. Apply sterile
bandage and take victim to an opthamologist.
Following skin contact, wash skin with running water until skin is free of alkali
as indicated by disappearance of soapiness. Seek immediate medical attention.
Prognosis:
Approximately 25% of those who ingest strong alkali die from the immediate effects.
Death may occur as late as 1 month after ingestion. Approximately 95% of those who
ingest strong alkali and recover from the immediate effects have persistent constriction
of the exophagus.
Cornea! damage is almost always permanent.
Skin damage is persistent.
A-22
-------
AMMONIA AND AMMONIUM HYDROXIDE
Ammonia (NH3) is a gas at ordinary temperatures. Ammonium hydroxide
(NH4OH) is a liquid containing 25-29% NH3; vapor pressure at 27C: 500 mm Hg.
Ammonia is used in organic synthesis, as a refrigerant, and as a
fertilizer. Ammonium hydroxide is used in organic synthesis and as a cleaner.
The TLV of ammonia is 25 ppm. The fatal dose of ammonium hydroxide by
ingestion is about 30 ml (1 oz) of a 25% concentration.
Ammonia and ammonium hydroxide injure cells directly by alkaline caustic
action and cause extremely painful irritation of all mucous membranes.
The pathologic findings in inhalation poisoning are lung edema, lung
irritation, and pneumonia. After ingestion, the findings are the same as
with alkalies.
The principal manifestation of acute poisoning with these compounds is
extreme irritation.
Ingested ammonia causes severe pain in the mouth, chest, and
abdomen, with cough, vomiting, and shock-like collapse. Gastric
or esophageal performation may occur later with abdominal pain,
fever, and rigidity. Lung irritation edema may appear after
12-24 hours' delay.
Ammonia fumes (1000 ppm) cause irritation of the eyes and upper
respiratory tract, with cough, vomiting, and redness of the
mucous membranes of the lips, mouth, eyes, nose, and throat.
Higher concentrations cause swelling of the lips and eye,
temporary blindness, restlessness, tightness in the chest,
frothy sputum indicating lung edema, cyanosis, and rapid, weak
pulse.
If skin contact is prolonged more than a few minutes it causes
severe burning pain and corrosive damage.
A-23
-------
Following eye contact, concentrated ammonia causes immediate
and severe eye pain followed by edema and cornea! clouding.
Later, cataract formation and destruction of the renina and
iris may occur.
Prevention:
Employees working in areas where ammonia is used must be trained in
escape methods and in the use of safety equipment, including goggles, breath-
ing equipment, showers, eye fountains, water hoses, exits, and first aid
equipment. Ammonia equipment must be constantly inspected to prevent
accidents. All valves should be labeled to prevent accidental opening.
If a contaminated area must be entered, a full-face airline mask or
self-contained oxygen mask must be worn. Protective clothing is also
necessary if the concentration is above 10,000 ppm.
Emergency Measures
1. Dilute ingested poison by giving water or fruit juice.
2. Eye contamination - Wash eyes in a water bubbler eye
fountain for at least 15 minutes. The victim should
be taken to an ophthalmologist for further treatment.
3. Inhalation - Remove patient, from contaminated area and
keep at bed rest.
4. Skin contamination - Wash skin for at least 15 minutes.
Antidote; Fruit juice or vinegar may be given by mouth or
used externally.
Seek medical attention for lung damage or skin burns or gastro-
intestinal damage following ingestion.
Prognosis:
Patients who survive 48 hours are likely to recover. Eye contact is
frequently followed by permanent blindness.
A-24
-------
FLUORINE, HYDROGEN FLUORIDE, AND DERIVATIVES
Both fluorine and hydrogen fluoride are gases at normal temperatures.
Fluorine is used in organic synthesis. Hydrogen fluoride is used in
the petroleum industry and in etching glass. Cryolite (sodium aluminum
fluoride) is used in many industrial processes. Fluoride salts are used in
the prevention of dental caries and in rodenticides. Methyl sulfonyl
fluoride is used as a fumigant.
The TLV in air for fluorine is 0.1 ppm. The TLV in air for hydrogen
fluoride is 3 ppm. The TLV in air for fluoride salts is 2.5 mg/cu m. The
fatal dose of sodium fluoride is 1-4 g. The fatal dose of fluorosilicates
is about the same as for fluorides, but that of cryolite is much higher
(above 10 g). The LD5Q for methyl sulfonyl fluoride in experimental animals
is 3.5 mg/kg.
Fluorine and fluorides act as direct cellular poisons by interfering
with calcium metabolism and various enzymes. Fluorides form an insoluble
precipitate with calcium and lower plasma calcium. Hydrogen fluoride
(hydrofluoric acid) is directly corrosive to tissues.
Skin or mucous membrane contact with hydrogen fluoride produces deeply
penetrating skin burns.
Neutral fluorides in 1-2% concentrations will cause inflammation and
damage of mucous membranes. After death, rigor mortis sets in rapidly.
Postmortem findings are brain edema, lung edema, and degeneration of liver
and kidneys.
In fatalities from inhaling hydrogen fluoride or fluorine, lung edema
and bronchial pneumonia are the most prominent findings.
In deaths following prolonged absorption of fluoride, the bone
structure shows thickening with calcification in the ligaments. Bone
marrow space is greatly reduced.
A-25
-------
The principal manifestation of fluorine and fluoride poisoning is
corrosion.
Inhalation of hydrogen fluoride or fluorine causes coughing,
choking, and chills lasting 1-2 hours after exposure. After
an asymptomatic period of 1-2 days, fever, cough, tightness in
the chest, rales, and cyanosis indicate pulmonary edema.
These symptoms progress for 1-2 days and then regress slowly
over a period of 10-30 days.
Ingestion of neutral fluorides such as sodium fluoride causes
salivation, nausea, vomiting, diarrhea, and abdominal pain.
Later, weakness, tremors, shallow respiration, and convulsions
occur. Death is by respiratory paralysis. If death does not
occur immediately, jaundice and urine suppression may
appear.
Skin or mucous membrane contact with hydrogen fluoride solution
results in damage depending on the concentration. Concentrations
above 60% result immediately in severe, extremely painful burns.
Such burns are deep and heal slowly. Concentrations less than
50% may cause slight immediate irritation of the skin or none
at all. The acid penetrates readily, however, and a deep-seated
ulceration results if contact continues for more than a few
minutes.
Intake of more than 6 mg of fluorine per day results in chronic
fluorosis. Symptoms are weight loss, brittleness of bones,
anemia, weakness, general ill health, stiffness of joints,
and discoloration of the teeth when exposure occurs during
tooth formation.
In chronic exposure, x-ray evidence of bonethickening
and calcification of ligaments is indicative of fluorosis.
A-26
-------
In severe fluorosis, both red and white blood cell
counts may be diminished.
Fluorine workers should have urine fluoride determi-
nations at 6-month intervals.
Prevention:
Hydrogen fluoride workers must be carefully instructed in the dangers
of skin contact with hydrogen fluoride and in the necessity for immediate
removal of even dilute solutions by prolonged washing. Showers and water
bubbler eye fountains must be available where hydrogen fluoride is being
used. Processes utilizing hydrogen fluoride must be totally enclosed.
Workers should wear long rubber gauntlets, long rubber aprons, high
rubber boots, and a wide plastic face shield while handling hydrogen
fluoride. Forced-air face masks should be worn if the air concentration
of hydrogen fluoride is sufficiently high to cause nasal irritation.
Tools and benches must be decontaminated immediately by washing with
ammonia or lye solutions after hydrogen fluoride is spilled.
Emergency Measures
Wash contaminated area thoroughly with water for 15-45
minutes. Do not wait until symptoms appear before washing.
Following inhalation, remove patient to fresh air and keep
at complete rest. Seek immediate medical attention.
Following ingestion of neutral fluorides, give soluble
calcium in any form: milk, calcium gluconate solution, or
calcium lactate solution. For calcium salts, the concentra-
tion should be 10 g in 250 ml of water. Give calcium gluco-
nate, 10 g, and Fleet's Phospho-Soda, 30-60 ml diluted 1:4
in water orally to precipitate and remove fluoride from the
intestine.
A-27
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Give milk and cream every 4 hours to relieve irritation
of esophagus and stomach.
Seek medical attention following ingestion, as soon as
possible.
Prognosis:
After ingestion of neutral fluoride, survival for 48 hours is followed
by recovery. After inhalation, survival for 3-4 days is usually followed
by recovery. Skin burns require 1-2 months to heal.
In fluorosis from chronic exposure, removal from exposure for a year or
more may be necessary before joint stiffness begins to reverse.
A-28
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PESTICIDES
A-29
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11-26
PESTICIDES
I. HISTORY:
Rodents, insects, nematodes, f^ngi, weeds and other pests compete
with man for food and other supplies, and they also transmit certain di-
seases to man or his domestic animals. The development of chemical pesti-
cides has created a revolution in the control of these pests. Pesticides
have accounted for about 10 percent of deaths from all solid and liquid
substances. All pesticides are capable of producing harm to man if ingested
or absorbed through the skin in sufficient quantities. Therefore, if spill-
age occurs, all soiled clothing should be removed immediately and the body
promptly washed with water.
II. INSECTICIDES
A. Inorganic. Highly toxic arsenic occurs in oany formulations as an in-
secticide. Arsenic occurs in rcany formulations as an insecticide.
In addition, fluorides, berates and fluorosilicates are used in in-
secticidal formulations.
B. Botanical.
1. Nicotine is a relative toxic material not frequently used today as
an insecticide. The symptoms of nicotine poisoning appear rapidly
and result in paralysis of the respiratory muscles and death.
2. Pyrethrum extracts are used as household insecticides because of
their rapid action. These conrpounds are not absorbed through the
skin and are rapidly broker, down in the intestinal tract. Toxic
doses cause excitation, cor.vulsions, tetanic paralysis and death
due to respiratory failure.
C. Chlorinated Hydrocarbon Insecticides. These highly stable compounds
are valued for their residual action against insects, and feared
because of their prolonged storage in aaamals.
1. Chlorophenothane [2.2-bis(p-chloroohenyl) 1,1,1-tnchloroethane,
DDT]. Its main use is for control of typhus, malaria, and other
vectorborne diseases. DDT is valued for its persistent or residual
action.
(a) Toxicity. The principal action of DDT (nervous system) is
characterized by paresthesia of the tongue, lip, face,
extremities, and disturbance of equilibrium, confusion and
(most characterised) tremor. Death from DDT is attributed
to respiratory arrest. Chlorinated hydrocarbons also have a
tendency to sensitize the myocardium to epinephrine and may
result in ventricular fibrillation. DDT can produce liver
injury and deplete liver glycogen. It is stored in body fat
and eliminated very slowly.
(b) Treatment is restricted to efforts to remove the poison and
control tremors, convulsions and other central nervous system
effects.
A-30
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11-27
2. Chlordane (1,2,4,5,6,7,8,8 - ocachloro - 3a4,7,7cv-tetrahydro-4,7-
tnethanoindnne) contains A nnd R chlordane, hepcachlor and trichlor.
Chlordane has caused clench In man at doses as low as 104 nig/kg and
is more dangerous than DDT.
Toxicity. Signs and symptom of acute chlordane intoxication arc
similar to those produced by DDT. Liver damage may result from
chronic intoxication. Chlordane is rapidly absorbed through the
skin.
3. Dieldrin. aldrtn. isodrin. and endrin are four isomers used as an
insecticide. All four isomers have similar pharmacological activity,
although endrin and isodrin are two and three times more poisonous
than dieldrin and aldrin.
Toxic ity. These compounds produce convulsions. Some patients com-
plain of headache, nausea, vomiting, dizziness, or myoclonic jerk-
ing and may not suffer convulsions until later. Hyperthermia fol-
lowing poisoning by chlorinated hydrocarbons is frequently followed
by death.
D. Anticholinesterase Insecticides
1. Organic phosphorus compounds are a group of highly toxic organic
esters of phosphoric acid which have pharmacological effects resem-
bling those of physostigmine. They are among the more toxic of all
chemicals, due to irreversible inhibition of both plasma and red
blood cell cholinesterase. Parathion, tetraethylpyrophosphate,
(TEPP), and malathion are common examples of such compounds now in
use. They are readily adsorbed and symptoms begin promptly and
progress rapidly. Respiratory symptoms are usually the first to
appear after inhalation of vapor or aerosol, gastrointestinal
symptoms usually appear first after ingestion, and localized sweat-
ing and muscle fasiculation are usually the first signs observed
after cutaneous exposure.
(a) Toxicity. The organic phosphate compounds inhibit cholinesterase
throughout the body resulting in the accumulation of acetylcholine
at various receptor sites. Excessive acetylcholine produces nau-
sea, vomiting, abdominal cramps, diarrhea, sweating, increased
bronchial and salivary secretions, and bradycardia. When accumula-
tion of acetylcholine occurs near the ends of motor nerves to skel-
etal muscles, the result is first a stimulation (producing muscu-
lar fasciculation), followed by muscle weakness and finally a flac-
cid paralysis. Until the activities of blood and tissue cholin-
esterase are restored to normal levels (by partial reversal of in-
hibition or regeneration of new enzymes), there is an increased sus-
ceptibility of the individual to the effects of another exposure to
any such compound. The effect of repeated exposures is cumulative.
Exposure produces papillary constriction, nasal secretions, tight-
ness in the chest, bronchorrhea, and salivation. If the concen-
tration is high, the patient may show severe respiratory distress,
collapse, convulse, and become comatose with intermittent feeble
respiratory effects. Death may be produced by sudden arrest of
A-31
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11-28
central respiratory function, peripheral neuromuscular weakness
or paralysis of the muscles of respiration, airway obstruction
by excessive salivary and bronchial secretions and bronchocon-
striction.
(b) Treatment.
1. Remove the victim from toxic environment and immediately
remove clothing and any liquid contamination. Flood and
wash the exposed skin areas thoroughly with water. In the
non-breathing victim, immediately institute artificial
respiration.
2. Administer atropine, 2 mg, intramuscularly or intravenously
as soon as any local or systemic signs or symptoms of an
intoxication are noted. Repeat the dose every 3-8 minutes
until signs of atropinization (mydriasis, dry mouth, rapid
pulse, hot and dry skin) occur.
3. Watch the respiration and remove bronchial secretions if
they appear to be obstructing the airway. Incubate if
necessary.
4. Administer pralidoxime (2-PAM chloride; Protopam) 2.5 grams
in 100 ml of sterile water or 5 percent dextrose and water,
intravenously, slowly in 15 to 20 minutes. For infants or
children, give 15 mg/kg. If sufficient fluid is not avail-
able, give 1 gram of 2-PAM in 3 ml of distilled water by
deep intramuscular injection. Repeat every half hour if
respiration weakens or if muscular fasciculations or con-
vulsions reoccur.
2. Carbaryl (sevin) is a typical carbamate insecticide. Carbamates are
reversible inhibitors of choliiiesterase. Reversal is very rapid and
carbaryl is rapidly metabolized. A single oral dose of approximately
2.8 mg/kg has resulted in moderately severe poisoning in an adult.
(a) Toxicity. Signs and symptoms of carbaryl poisoning are similar
to those seen with other cholinesterase inhibitors.
(b) Treatment. Treatment of poisoning by carbamates is the same as
that for organic phosphorus compounds, except that 2-PAM and
other oximes are not recommended for routine use.
III. FUMIGANTS. Fumigants are gases or volatile liquids used for control of in-
sects, rodents, and soil nemaCodes.
A- Hydrogen Cyanide (HCN, Prussic acid). Toxicity and treatment are dis-
cussed elsewhere. Many persons are unable to smell the characteristic
burnt-almond odor of hydrogen cyanide (inability is an inherited charac-
teristic). Most proprietary fumigants contain a "warning" lacrimatory
material or pungent gas with a readily identifiable odor.
A-32
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11-29
B. Methyl Bromide (CH.jBr, raonobroraomechane) is supplied as a compressed
gas and is also used as a refrigerant or fire extinguishing material.
The gas is usually sold containing chloropicrin. (See below).
Toxicitv. Methyl bromide causes severe burns of the skin. Respiratory
exposure produces pulmonary o.J«jma as a result of direct irritant actions
and may be the immediate cause of death. Symptoms of serious poisoning
include headache, disturbance of vision, nausea, vomiting and tremors
progressing to convulsions.
IV. RODENTICIDES
A. Warfarin is an anticoagulant rodenticide. It is generally used at a
concentration of 0.25%. Warfarin is mixed with cereal or in water.
1. Toxicity. All signs and symptoms are caused by hemorrhage.
2. Treatment. Vitamin K preparations are indicated for treatment.
B. Sodium Monofluoracetate (FCHj-COONA - "1080") is a white powder with a
faint smell of vinegar.
1. Toxiclty. Signs and symptoms usually begin with nausea and appre-
hension and are followed by convulsions. Pulsus alternans may
occur, and may be followed by ventricular fibrillation and severe
depression. The poison acts by interfering with acetate metabolism.
(a) Control the convulsions and evaluate the cardiac status.
Following gastric lavage, administer glycerol monoacetate
(monoacetin).
C. Phosphorus is used as a bait rodenticide. A dose of IS mg may be toxic
and 50 mg may be fatal. Acute poisoning produces gastrointestinal
irritation after ingestion and the patient may die of cardiovascular
failure within 12 hours.
1. Treatment. Copper salts form a semimetallic coating of Cu,P2 over
the phosporus particles and prevent their further absorption.
Potassium permanganate or a hydrogen peroxide solution oxidizes the
phosphorus to harmless phosphates. Mineral oil minimizes absorption,
but other fats and oils promote absorption.
V. HERBICIDES are chemicals used for controlling weeds.
A. Metallic Poisons. A variety of arsenic, lead, mercury, copper, iron,
zinc and boron salts are used as herbicides. In addition, organic
compounds of arsenic, mercury and tin are also used.
B. Substituted Phenols. A number of substituted dinitrophenols are used to
kill plants along roadsides and rights-of-way. All of these compounds
increase oxidative metabolism.
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Pesticides
BARIUM
Absorbable salts of barium such as the carbonate, hydroxide, or chloride
are used in pesticides. The fatal dose of absorbed barium is approximately 1 g.
Barium ion induces a change in permeability of the cell membranes which results
in stimulation of all muscle cells indiscriminately. This effect is not anta-
gonized by atropine but is antagonized by magnesium ions. No specific histologic
changes are seen.
Clinical Findings
The principal manifestations of barium poisoning are tremors and convulsions.
Symptoms and Signs: (From ingestion or, rarely, from inhalation.) Symptoms
and signs include tightness of the muscles of the face and neck, vomitting,
diarrhea, abdominal pain, muscular tremors, anxiety, weakness, difficulty in
breathing, irregularity of the heart, convulsions, and death from cardiac
respiratory failure.
Emergency Measures: If respiration is affected, give artificial respiration,
using oxygen if available, until a sulfate antidote can be given and normal
respiration has returned.
Antidote: sodium sulfate.
Prognosis:
If a soluble sulfate (e.g., magnesium sulfate or sodium sulfate) is given
before symptoms become severe, then recovery will occur. Survival for more than
24 hours has always been followed by recovery.
Gould DB, Sorrell MR, Lupariello AD: Barium sulfide poisoning. Arch Intern
Med 132:891, 1973.
A-34
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- 2 -
Dinitrophenol pesticides
DINITROPHENOL. DINITRO-tf-CRESOL
NO, NO,
-NO, HjC
I I
OH OH
2.4-Dvtilrophnol 44-D[nl(m«
-------
- 3 -
Chronic Poisoning: Chronic poisoning has not been reported following
agricultural exposure. Toxicity may include skin eruptions, nerve damage,
liver damage, kidney damage, and decrease in white blood cell count.
In exposed workers, blood concentrations of dinitro derivatives should not
exceed 10 yg/g. Take white blood count if exposed person has unexplained
fever.
White blood count should be repeated at monthly intervals during
exposure.
Emergency Measures: Remove ingested poison by given syrup of ipecac
to induce emesis. Remove skin contamination by scrubbing with soap and
water after removal of clothing. If the body temperature is elevated,
reduce to 37 C by immersion in cool water or by applying cold packs. If
the body temperature is above 40 C, ice water is necessary. Oxygen
inhalations should be used for respiratory distress or cyanosis. Feed
readily digestible food for increased metabolism.
Prognosis
Recovery from severe poisoning is likely if body temperature can be kept
below 40 C and if adequate nutrition is supplied.
FLUOROACETATE
The sodium salt of fluoroacetic acid (CHgFCOONa) is a water-soluble,
synthetic chemical used as a rodenticide.
The fatal dose is estimated to be 50-100 mg. At least 13 deaths from
sodium fluoroacetate have occurred. Fluracetamide has similar toxicity.
Fluoroacetate in the body blocks cellular metabolism. The relationship
between this metabolic effect and poisoning has not been elucidated. All body
cells, and especially those of the brain, are affected by fluoroacetate as
shown by depression of oxygen consumption.
A-36
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- 4 -
No specific tissue changes are seen in fluoroacetate poisoning. Findings
include lung and brain edema, congestion of the kidneys and lungs.
The principal manifestations of acute fluoroacetate poisoning from ingestion
or inhalation are vomiting and convulsions. Chronic poisoning does not occur.
Symptoms begin within minutes to 4-5 hours, with vomiting, excitability,
convulsions, irregularity of the heart and respiration, exhaustion, coma,
and respiratory depression. Death is from respiratory failure associated with
pneumonia.
Emergency Measures: Ingested poison may be removed by emesis; give
syrup of ipecac.
Specific Antidote: Monoacetin (glyceryl monoacetate)
Prognosis
Complete recovery may follow repeated convulsions. Rapid progression of
symptoms within 1-2 hours after poisoning is likely to result in death.
Survival for more than 24 hours indicates a favorable outcome.
NICOTINE
Exposure to nicotine occurs during processing or extraction of tobacco;
during the mixing, storage, or application of insecticides containing
nicotine; or during smoking. Nicotine is available in concentrations as a free
base, which is volatile, or as the sulfate. Both are liquids, even in pure form.
In addition to concentrates, nicotine is also present in a large number of
insecticide mixtures in concentrations of 1% or more. Additional less toxic
compounds with similar actions are anabasine, nornicotine, and lobeline.
The fatal dose of pure nicotine is about 40 mg (1 drop), a quantity contained
in 2 g of tobacco (2 cigarettes). However, tobacco is much less poisonous than
would be expected on the basis of its nitocine content. When smoked, most of the
nicotine is burned; when ingested, nicotine is poorly absorbed from the tobacco.
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- 5 -
Nicotine first stimulates, then depresses and paralyses the cells of the
brain and spinal cord. Skeletal muscle, including the diaphragm, is paralyzed.
No specific tissue changes are found after nicotine poisoning. After
ingestion, the mouth, pharynx, esophagus, and stomach may show evidence of the
caustic effect of nicotine.
The principal manifestations of nicotine poisoning are respiratory stimulation
and stomach and intestinal cramps.
Acute Poisoning:
1. Small doses - (From skin contamination or inhalation of tobacco smoke,
tobacco dust, or insecticide sprays.) Respiratory stimulation, nausea,
vomiting, dizziness, headache, diarrhea, elevation of blood pressure,
sweating, and salivation. Gradual recovery follows a period of weakness.
2. Large doses - (From ingestion or skin contamination with insecticide
concentrates.) Initially there is burning of the mouth, throat, and
stomach, followed by rapid progression of the above symptoms, proceeding
to weakness, convulsions, respiratory slowing, heart irregularity,
and coma. Death occurs within 5 minutes to 4 hours.
Chronic Poisoning: No cumulative effect from exposure to small amounts of
nicotine insecticides has been noted.
Acute Poisoning:
Emergency measures -
a. Wash skin - Remove nicotine from the skin by flooding with water
and scrubbing vigorously with soap.
b. Give artificial respiration, using oxygen if available.
Antidote - Atropine.
Chronic Poisoning: Remove from further exposure to dust or smoke.
A-38
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- 6 -
Prognosis
Survival for more than 4 hours is usually followed by complete recovery.
THALLIUM
Thallium has been used as a rodenticide and as ant killer. Its use as a
pesticide is now prohibited. Poisoning has most frequently resulted from the
accidental ingestion of thallium rodent or ant baits, which consisted of thallium
sulfate or acetate mixed with grain, cookie crumbs, cracker crumbs, honey, or
sweetened water.
The most commonly available salts of thallium are the sulfate, acetate, and
carbonate. Thallium sulfide and iodide are appreciably less soluble than the
other salts.
The fatal dose is approximately 1 g of absorbed thallium.
The principal manifestations of thallium poisoning are loss of hair and pains
in the extremities.
A. Acute Poisoning: (From ingestion or skin absorption.)
Evidences of poisoning appear in 1-10 days and include pains of the
extremities, dizziness, loss of hair, fever, abdominal pain, and
nausea and vomiting. Progression of poisoning is indicated by the
appearance of lethargy, jumbled speech, tremors, convulsions, and
cyanosis. Signs of lung fluid accumulations and pneumonia may
precede death in respiratory failure. Kidney damage has also been
reported.
B. Chronic Poisoning: (From ingestion or skin absorption.) If
absorption of thallium occurs over an extended period, the earliest
indications of poisoning are loss of hair, changes in the skin, and
occasionally salivation and blue line on the gums. Stomach and
intestinal cramps are also common.
A-39
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- 7 -
Acute Poisoning
1. Emergency measures - Remove skin contamination by scrubbing with
soap and water. There are no effective antidotes for thallium
intoxication.
Chronic poisoning: Remove from further exposure.
Prognosis:
If the progression of signs of brain damage (lethargy, delirium, and
muscular twitchings) can be halted, recovery is possible. Complete recovery
may require 2 months or more.
THIOCYANATE INSECTICIDES:
THANITE, LETHANE
Thiocyanate insecticides are ordinarily available in mixtures as concen-
trated solutions in an organic solvent, as emulsion concentrates, or in
combination with other insecticides.
The toxicity of these compounds is moderate compared with that of
nicotine. One adult patient died after ingesting a mixture containing
approximately 5 g of Lethan-384 and 14 g of lauryl thiocyanate. Other
fatalities have been reported following ingestion of similar quantities.
The toxicities of ethyl and methyl thiocyanate are considerably greater,
reaching 10 mg/kg in experimental animals, because they are converted to cyanide
in the body. Thanite has an LD5Q in rats of 1600 mg/kg.
The thiocyanate insecticides induce coma, cyanosis, and convulsions in
rats at doses ranging from 90 mg/kg (Lethane-384) to 1 g/kg (Thanite).
Examinations of animals poisoned by thiocyanate insecticides have not
revealed organ damage.
The principal manifestations of acute poisoning with the thiocyanate
insecticides is convulsions. Chronic poisoning does not occur.
A-40
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- 8 -
Symptoms and Signs: (From Ingestion or excessive skin contamination.)
Convulsions with respiratory difficulty.
Emergency Measures: Remove skin contamination by scrubbing with soap
and water. Remove swallowed poison by giving syrup of ipecac, 15 ml, and
500 ml of tap water or milk. Maintain artificial respiration during
convulsions or respiratory difficulty.
Prognosis
If adequate gastric lavage and catharsis can be accomplished before
onset of symptoms, recovery is likely. Progression of symptoms after removal
of insecticide indicates a poor outcome.
2,4-DICHLOROPHENOXYACETIC ACID
2,4-Dichlorophenoxyacetic acid (2,4-D), its esters and acetates,
2,4,5-T), esters and acetates of 2,4,5-T, 2-methyl-4-chlorophenoxyacetic acid
(MCPA), salts and esters of MCPA, and the propionate or butyrate analogs
(MCPB, MCPP, 2,4-DB, butyrac, Embutox, tropotox, silvex) of these compounds
are used as herbicides. Herbicides with similar actions include erbon,
Natrin, and fenac.
Tetrachlorodibenzo-p-dioxine (TCDD) is a potent mutagen in experimental
systems and is suspected of being mutagenic in human beings at extremely low
doses. It causes chloracne and has been a contaminant in 2,4,5-T.
One fatality has occurred from an amount of 2,4-D not less than 6.5 g.
Other fatalities have occurred from varying amounts up to 120g. The ID™
DU
for these compounds in animals ranges from 300-700 mg/kq.
The mechanism of poisoning has not been elucidated. No specific tissue
changes have been reported.
The principal manifestations of 2,4-D poisoning are weakness and fall of
blood pressure.
A-41
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- 9 -
Emergency Measures: Remove skin contamination by scrubbing with soap
and water.
Antidote: For muscle and cardiac irritability, give quinidine sulfate.
Prognosis
Survival for more than 48 hours has been followed by complete recovery.
Impotence may persist for several months.
PARAQUAT & DIQUAT
Paraquat or methyl viologen (1 ,l'-dimethyl-4,4-dipyridylium dichloride),
diquat, and difenzoquat (Avenge) are water-soluble herbicides supplied in
concentrations of 20-25%. They are inactivated by contact with soil presumably
as a result of combination with clay particles in the soil.
More than 10 fatalities from paraquat have been reported in the literature.
One individual died after ingesting 3/4 tsp of 19% solution, or an amount less
than 10 mg/kg. The fatal dose for human beings has been estimated to be as
small as 4 mg/kg, although the oral LD5Q in rats is 120 mg/kg. The oral LD5Q
for diquat for rats is 200-300 mg/kg, and for difenzoquat it is 470 mg/kg. No
fatalities in human beings from diquat have been reported.
Although the mechanism of poisoning has not been elucidated, pathologic
findings after paraquat fatalities include heart damaqe, lung hemorrhages
and edema. Damage of the adrenal cortex, kidney damage, and biliary stasis
also occur. In experimental studies, diquat has not produced the lung lesion
found after paraquat.
Clinical Findings
The principal manifestations of paraquat poisoning are respiratory
distress and cyanosis.
A-42
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- 10 -
Symptoms and Signs: (From ingestion.) Ingestion of paraquat causes burning
in the mouth and throat and vomiting. After 2-5 days, bloody sputum, decreased
urine output, and ulceration of the tongue, pharynx, and esophagus appear.
After 5-8 days, severely poisoned patients show jaundice, fever, increased
heart rate, respiratory distress, and cyanosis.
Laboratory identification of paraquat: To 5 ml of neutral fluid, add
0.1 g of sodium bicarbonate followed by 0.1 g of sodium hydrosulfite
(dithionite). A blue color develops almost immediately. Absorption
maximum is at 625 nm, and 20 ug/ml gives an absorbance of 0.7.
Treatment:
Emergency Measures: Give activated charcoal.
Antidote: No antidote is known.
Prognosis:
Patients have died of lung dysfunction up to 3 weeks after poisoning.
A-43
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Halogenated Insecticides
Halobenzene derivatives and analogs are synthetic chemicals used as
insecticides that are stable for weeks to months after application.
They are soluble in fat but not in water. They bioaccumulate in food
chains and in body fat.
Commercial insecticide formulas consist of insecticides in technically
pure form, dry mixtures of several insecticides, or solutions of one or
more insecticides in various organic solvents, especially kerosene,
toluene, or other petroleum derivatives. These organic solvents are them-
selves toxic.
DDT seems to be one of the most toxic of these chemicals, at least in
experimental animals. In humans, ingestion of 20 g of DDT in the form of
a 10% dry mixture with flour has induced severe symptoms which persisted
for more than 5 weeks, with gradual recovery. Virtually all fatalities
reported in the literature have resulted from ingestion of DDT in various
solvents. The toxicity of tnese solutions is greater than that of DDT or
the solvent alone.
The tolerance of chlorobenzene derivatives in most foods is 0.005-
7 ppm, with the exception of methoxychlor (14 ppm) .
Fatal doses of the various halobenzene derivative insecticides as
estimated on the basis of animal experiments are shown in Table 1 below.
The mechanism of poisoning by these agents is not known. The toxic
action does not require metabolic alteration of their chemical structure.
DDT acts chiefly on the brain causing a characteristic hyperexcita-
bility, tremors, muscular weakness, and convulsions. The heart becomes
sensitizied so that, at least in experimental animals, injection of epine-
phrine may induce ventricular fibrillation. Ovotran has caused skin
irritation or skin sensitization in human beings.
Inasmuch as most deaths from DDT are complicated by the presence of
other insecticides and of solvents, data obtained at autopsy are not reliable.
In DDT-poisoned animals, the findings are liver damage and brain damage, as
well as heart and kidney damage. The most characteristic finding in experi-
mental animals exposed to the other halobenzene derivatives is liver damage.
Halobenzene derivative insecticides
_
Amiben (3-amino-2,5-dichlorobenzoic acid) 3.5
Bromopropylate, Acarol 5
Chlorbenside (p-chlorobenzyl-p-chlrophenyl sulfide) 0.3
Chi orobenzi late (ethyl-4,4'-dichlorobenzilate) 1
Chloromethyl-p-chlorophenyl sulfone 1
Chloroneb, Demosan 11
p-Chlorophenylbenzenesulfonate, fenson 1.5
Chloropropylate, Acaralate 5
Chloroxuron, Tenoran 3.7
ODD, TDE (Rhothane, mitotane) 3
A-44
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Halobenzene derivative insecticides (cont'd.)
LD50
(g/kg)
DDT (dichlorodiphenyltrichloroethane) 0.4
Dimite, DMC, chlorfenethol 1
Fluorbenside (p-chlorobenzyl-p-fluorophenyl sulfide)
Kelthane (bis[p-chlorophenyl]-trichloroethanol) 0.5
Methoxychlor (trichloro-bis[p-methyoxy-phenyl]ethane) 5
Perthane (di-[p-ethylphenyl]dichloroethane) 8
Tedion (tetrachlorodiphenylsulfone) 8
Signs and Symptoms of Intoxication
The principal manifestations of poisoning with these agents are
vomiting, tremors, and convulsions.
A. Acute Poisoning:
1. Ingestion of 5 g or more of dry DDT-Severe vomiting begins within
30 minutes to 1 hour; weakness and numbness of the extremities have
a more gradual onset. Apprehension and excitement are marked, and
diarrhea may occur.
2. Ingestion of more than 20 g of dry DDT-Twitching of the eyelids
begins within 8-12 hours; this is followed by muscular tremors,
first of the head and neck and then the extremities followed by
convulsions. The pulse is normal; respiration is accelerated
early and slowed later.
3. The organic solvents present in many commercial insecticides
decrease the convulsive effects of DDT and increase the depression
of the brain. Onset of slow, shallow breathing within 1 hour
after inhaling, ingesting, or absorbing a DDT solution through
the skin implicates the solvent rather than the DDT.
B. Chronic Poisoning: Workers with a history of many months' exposure
to DDT and having up to 648 ppm of DDT in their body fat have remained
completely well, whereas most persons have body fat levels of halogenated
insecticides below 15 ppm. These insecticides are all stored for long
periods in the body fat, but not in sufficient quantity to induce symptoms
on starvation. Liver damage from DDT exposure might be expected from
evidence obtained in experimental animals, but no such reports have appeared.
Chronic poisoning has not been substantiated in human beings after any
halobenzene derivatives.
C. Laboratory Findings:
1. A high urine level of organic chlorine or especially of bis(p-
chlorophenyl)acetic acid (DDA) indicates exposure to DDT or to
one of the analogous compounds and is indicative of the severity
of the exposure.
2. In suspected poisoning, analysis of serum or a fat biopsy is useful
for diagnosis. A sample of fat can be taken from subcutaneous
tissue. The sample should weigh at least 50 mg. Place sample in
previously weighed glass-stoppered vial or vial with Teflon-lined
cap and weigh to the nearest 0.1 mg. Prepare at least 5 ml serum
A-45
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from blood taken after overnight fast. The container should be
carefully labelled with the patient's name, weight of sample, date
of collection, ana name and address of physician. Send frozen
sample to Toxicology Laboratory, Pesticides Program, Food & Drug
Administration, US Public Health Service, Atlanta 30333. Containers
and further directions are obtainable fromthesame source. Also,
the local health department may be able to arrange for analysis.
Treatment of Halogenated Insecticide Poisoning (Acute)
A. Emergency Measures:
1. Following oral ingestion seek medical attention immediately; syrup
of ipecae may be used to induce vomiting if ingested material is not
dissolved in a petroleum hydrocarbon. Do^not give fats or oils.
2. Scrub skin with soap and water to remove skin contamination.
3. Give artificial respiration with oxygen if respiration is slowed.
Medical care may necessitate use of anticonvulsants to control convulsions.
Stimulants are contraindicated.
Prognosis
Recovery has occured except when DDT was ingested dissolved in an
organic solvent. If convulsions are severe and protracted, recovery is
questionable. If symptoms progress only to tremors, recovery is complete
wtthin 24 hours. After convulsions, recovery may require 2-4 weeks.
Deichman, W.B.: Toxicology of DDT and related chlorinated hydrocarbon
pesticides. J. Occup. Med. 14:285, 1972.
Morgan, D.T., Roan, E.G.: The metabolism of DDT in man. Essays Toxicol
5:38, 1974.
Siyali, D.S.: Hexachlorobenzene and other organochloride pesticides in
human blodo. Med. J. Aust 2:1063, 1972.
BENZENE HEXACHLORIDE
(Gamma Isomer = Lindane)
Benzene hexachloride (hexachlorocyclohexane) is stable for 3-6 weeks
after application. It is soluble in fat but not in water.
Wettable powders, emulsions, dusts, and solutions in organic solvents
are available for use as insecticides. Both the technical preparation and
the gamma isomer (lindane) are used in vaporizers, and serious poisoning
has occurred from vapor exposure.
Ingestion of 20-30 g of technical benzene hexachloride will produce
serious symptoms, but death is unlikely unless this amount was dissolved in
an organic solvent. In the case of lindane, the gamma isomer, 3.5 g/70 kg
is considered a dangerous dose. In a girl aged 2 1/2 years, ingestion of
50 or 100 mg/kg caused convulsions with recovery in 24 hours. The tolerance
of benzene hexachloride or lindane in food is 10 ppm or less.
A-46
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Reported instances of serious poisoning have been rare and have
resulted from accidental or suicidal ingestion.
Technical benzene hexachloride and lindane stimulate the central
nervous system (CiNS) to cause hyperirritability, dizziness, and convulsions.
Pulmonary edema and vascular collapse may also be of neurogenic origin.
Effects of lindane on experimental animals have their onset within 30 minutes
and last up to 24 hours; with the technical product, onset of effects may
be delayed 1-6 hours and then persist up to 4 days.
Benzene hexachloride is stored in the body fat, being slowly lost
through metabolism or excretion in urine, feces, or milk. Of the various
isomers of benzene hexachloride, lindane is excreted most rapidly.
Signs and Symptoms of Intoxication
The principal manifestations of poisoning with benzene hexachloride
or lindane are vomiting, tremors, and convulsions.
A. Acute Poisoning: (From ingestion or massive skin contamination with a
concentrated solution in an organic solvent.) Symptoms begin 1-6 hours
after exposure. Vomiting and diarrhea appear first and progress to
convulsions. Recovery is likely unless the material contains an
organic solvent, in which case difficult breathing, cyanosis, and
circulatory failure may progress rapidly.
Exposure to smaller amounts by skin contamination or by ingestion
leads to dizziness, headache, nausea, tremors, and muscular weakness.
In addition to these symptoms, exposure to vaporized benzene hexa-
chloride or lindane produces irritation of tne eyes, nose, and throat.
Such symptoms disappear rapidly upon removal from exposure.
not been
B. Chronic Poisoning: True systemic chronic poisoning has n
reported from any of the isomers of benzene hexachloride.
Dermatitis from skin contamination with benzene hexachloride has
occurred but has improved rapidly upon elimination of exposure.
C. Laboratory Findings: Liver function may be impaired. Specific exami-
nation of feces, urine, or fat may reveal presence of benzene hexachloride.
Collection and analysis of the fat specimens has been previously
described.
Treatment
Treat as for halogenated insecticide poisoning.
Prognosis
A. Acute Poisoning: In acute poisoning not complicated by ingestion of
an organic solvent, complete recovery occurs in 1-2 weeks. Progression
of symptoms to pulmonary edema and vascular collapse following inges-
tion of benzene hexacnloride or lindane in an organic solvent may make
recovery unlikely.
B. Mild Exposure: Symptoms from slight exposure to benzene hexachloride
or lindane vaporizers or ingestion of small amounts of benzene hexa-
chloride have lasted not more than 2 weeks.
A-47
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Solomon, L.M., Fahrner, L., West, D.P.:
toxicity: A review. Arch Dermatol.
Starr, H.G., Jr., Clifford, N.J.: Acute
Environ. Health 25:374, 1972.
Gamma benzene hexachloride
113:353, 1977.
lindane intoxication. Arch.
TOXAPHENE
(Chlorinated Camphenes)
Toxaphene consists of chlorinated terpenes with chlorinated camphene
predominating._ It is stable for 1-6 months after application and is fat-
soluble and water-insoluble. Toxaphene is available for insecticidal use
in the form of wettable powders, dusts, emulsion concentrates, and concen-
trated solutions in oil.
The fatal dose of toxaphene for an adult is estimated to be around
2 g. Several members of one family were nonfatally poisoned after eating
greens contaminated with toxaphene to the extent of 3 q/kg of greens. The
maximum dose ingested by one person was thought to be in the neighborhood
of 1 g. Several fatalities in children have followed ingestion of larger
but undetermined amounts. The tolerance of toxaphene in foods is 7 ppm.
At least 3 fatalities from toxaphene ingestion have been reported.
Toxaphene induces convulsions, salivation, vomiting, and excitability.
Pathologic findings in acute poisoning are hemorrhages and congestion
in the brain, lungs, spinal cord, heart, and intestines. Pulmonary edema
and degeneration in the brain and spinal cord are also present. In experi-
mentally induced chronic poisoning, degenrative changes were found in the
liver and kidney.
Signs and Symptoms of Intoxication
The principal manifestations of toxaphene poisoning are vomiting and
convulsions.
A. Acute Poisoning: (From ingestion or skin absorption.)
Confulsions frequently begin without symptoms but may be preceded by
nausea and vomiting. In fatal poisoning, convulsions occur at de-
creasing intervals until respiratory failure supervenes, almost always
within 4-24 hours after poisoning. In nonfatal poisoning, cessation
of convulsions is followed variably by a period of weakness, lassitude,
and amnesia.
B. Chronic Poisoning: (From ingestion, inhalation, or skin absorption.)
Instances of chronic poisoning have not appeared in the literature.
Experiments in animals indicate that toxaphene is less apt to cause
chronic toxicity than DDT but that similar changes in the liver and
kidneys are possible.
C. Laboratory Findings: Liver function may be impaired. Analysis of body
fat or serum for toxaphene indicates severity of exposure.
Treatment
Treat as for halogenated insecticide poisoning.
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Prognosis
In acute poisoning, recovery is likely unless convulsions are progres-
sive and cannot be controlled by barbiturates. Most dangerous is the interval
from 4-24 hours after poisoning.
POLYCYCLIC CHLORINATED INSECTICIDES:
CHLORDANE, HEPTACHLOR, ALDRIN,
DIELDRIN, ENDRIN, MITREX,
THIODAN, & KEPONE
These compounds are synthetic fat-soluble but water-insoluble chemicals.
Aldrin is stable for 1-3 weeks after application. The others are stable
for months to a year or more.
These chemicals, either singly or in mixtures in the form of dusts,
wettable powders, or solutions in organic solvents, are used as insecticides
for the control of flies, mosquitoes, and field insects.
The toxicity of these polycyclic derivatives for. rodents is considerably
greater than that of the chlorobenzene derivatives. For example, the
experimental fatal dose (LDsg) in rats for aldrin or endrin is 10 mg/kg;
for dieldrin, it is 40 mg/kg; for heptachlor, 90 mg/kg; for Kepone, 65 mg/
kg; for chlordane, 200 mg/kg; for mi rex, 300 mg/kg; and for endosulfan
(Thiodan), 110 mg/kg. In an average adult, severe symptoms follow ingestion
of or skin contamination with 15-50 mg/kg or 1-3 g of chlordane. Other
indane derivatives are probably more toxic. In one instance, accidental
skin contamination with 30 g of chlorodane as a 25% solution in an organic
solvent was fatal to an adult in 40 minutes.
Polycyclic chlorinated insecticides,
A-49
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Allowable residual tolerance of theseindane chemicals in food range
from 0-0.1 ppm.
Convulsions from the inaane derivatives originate in the central nervous
system (CNS).
Pathologic changes include congestion, edema, and scattered hemor-
rhages in the lungs, kidneys, and brain. The kidneys also show damage.
Signs and Symptoms of Intoxication
The principal manifestations of poisoning with the indane derivatives
are tremors and convulsions.
A. Acute Poisoning: (From ingestion, inhalation, or skin contamination
of any indane derivative, even in the absence of solvent.) Symptoms
of hyperexcitability, tremors, dizziness, and convulsions begin within
30 minutes to 6 hours and are followed by central nervous system (CNS)
depression which may terminate in respiratory failure. In one person
who ingested 25 mg/kg of chlordane, evidence of kidney damage was
indicated.
B. Chronic Poisoning: (From ingestion, inhalation, or skin contamination.)
Prolonged exposure to Kepone has caused neurologic symptoms. Both
Kepone and mirex have been shown to be carcinogenic in animal experi-
ments. Occasional epileptiform convulsions have occurred in workers
from dermal absorption of endosulfan in powder form. EEG findings in
poisoning have been suggestive of epilepsy but have reverted to normal
when exposure was discontinued. Symptoms may persist for more than 1
week after exposure is discontinued or after acute poisoning.
C. Laboratory Findings: Liver function may be impaired. A fat biopsy
or serum test may reveal the presence of indane derivatives.
Treatment
Treat as for halogenated insecticide poisoning. Personnel involved in
therapy should wear Neoprene gloves as protection against contamination.
Prognosis
If the liver has previously been damaged, the toxicity of the polycyclic
halogenated insecticides is greatly increased. Recovery is likely if onset
of convulsions is delayed more than 1 hour and if convulsions are readily
controlled.
REFERENCES
Black, A.M.S.: Self-poisoning with dieldrin: A case report and pharmaco-
kinetic discussion. Anesth. Intes. Care 2:369, 1974.
Furie, B., Trubowitz, S.: Insecticides and blood dyscrasias. JAMA
235:1720, 1976.
Glass, W.I.: Dieldrin poisoning: Case report. NZ Med. J. 81:202, 1975.
Harmon, G.E., Reigart, J.R., Sandifer, S.H.: Long-term follow-up of
survivors of acute pesticide poisoning. J. SC. Med. Assoc. 71:253, 1975.
Sterrett, F.S., Boss, C.A.: Careless Kepone. Environment 19:30, March 1977.
Zavon, M.R.: Poisoning from pesticides: Diagnosis and treatment. Pediatrics
54:332, 1974.
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METALLIC POISONS
A-51
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METALLIC POISONS
ANTIMONY AND STIBINE
Antimony is used in alloys, type metal, foil, batteries, ceramics,
textiles, safety matches, ant paste, and medicinals such as tartar emetic
(antimony potassium tartrate). Acid treatment of metals containing antimony
releases the colorless gas, stibine (SbH-).
The TLV in air for antimony is 0.5 mg/cu m. The TLV in air for stibine
is 0.1 ppm. The fatal dose of antimony compounds by ingestion is 100-200 mg.
Fatalities from antimony poisoning are rare.
The mechanism of poisoning is similar to that of arsenic poisoning,
presumably by inhibition of enzymes through combination with sulfhydryl (-SH)
groups.
Antimony is strongly irritating to mucous membranes and to tissues.
Stibine causes hemolysis and irritation of the central nervous system.
Pathologic findings include degeneration of the liver and other organs.
The gastrointestinal tract shows marked congestion and edema.
The principal manifestations of antimony poisoning are gastrointestinal
disturbances. Stibine causes hemolysis.
Following ingestion, the symptoms are nausea, vomiting,
and severe diarrhea with mucus and later with blood.
Kidney and liver damage may also occur.
Following inhalation (of stibine) headache, nausea,
vomiting, weakness, jaundice, anemia, and weak pulse
may occur.
Chronic poisoning from fume and dust exposure pro-
duces itching skin pustules, bleeding gums, conjuncti-
vitis, laryngitis, headache, weight loss, and anemia.
The red blood cell count may be diminished and urine
shows hemoglobin and red cells.
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Prevention:
Adequate fume and dust control is necessary to prevent the TLV from
being exceeded.
Emergency measures include removal of ingested antimony compounds by
emesis and remove patient from further exposure. Seek immediate medical
attention.
Prognosis:
Survival for 48 hours indicates that recovery is probable.
ARSENIC AND ARSINE
Arsenic is used in ant poisons, insecticides, week killers, paint,
wallpaper, ceramics, medicines, and glass. The action of acids on metals
in the presence of arsenic forms arsine gas. Alloys such as ferrosilicon
may release arsine upon contact with water since the ferrosilicon may be
contaminated with arsenic.
The fatal dose of arsenic trioxide is about 120 mg. The allowable
food residue is limited by federal law to 0.65 mg/lb. The TLV in air for
arsine is 0.05 ppm; for arsenic, arsenic acid, arsenates, arsenites, and
other compounds of arsenic, it is 0.5 mg/cu m. Reduction to 0.002 mg/cu
m has been proposed. Organic arsenicals, such as arsphenamine, acetarsone,
methane arsonic acid, and dimethylarsinic (cacodylic) acid, release arsenic
slowly and are therefore less likely to cause acute poisoning. The fatal
dose for these compounds is estimated at 0.1-0.5 gAg.
Arsenic presumably causes toxicity by combining with sulfhycryl (-SH)
containing enzymes and interfering with cellular metabolism.
If death occurs within a few hours, the stomach mucosa shows inflamma-
tion but other pathologic changes are absent. If death occurs more than a
few hours after poisoning, pathologic examination shows inflammatory changes
and partial degeneration of intestinal mucosa. In immediate deaths from
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arsine poisoning, hemolysis is found. If death is delayed for several days
after arsenic in any form, the liver and kidneys show degenerative changes.
The principal manifestations of arsenic poisoning are gastrointestinal
disturbances. The principal manifestation of arsine poisoning is hemolysis.
After ingestion of overwhelming amounts of arsenic (10
times the MLD), initial symptoms are those of violent
gastroenteritis: burning esophageal pain, vomiting,
and copious watery or bloody diarrhea containing shreds
of mucus. Later, the skin becomes cold and clammy, the
blood pressure falls, and weakness is marked. Death is
from circulatory failure. Convulsions and coma are the
terminal signs. If death is not immediate, jaundice and
cessation of urine output appear after 1-3 days.
Doses approaching the MLD cause restlessness, nausea,
vomiting, headache, dizziness, chills, cramps, irrita-
bility, and variable paralysis which may progress over
a period of several weeks.
Inhalation of arsenic dusts may cause acute pulmonary
edema, restlessness, difficult breathing, cyanosis,
cough with foamy sputum, and rales.
Exposure to arsine causes burning and stinging of the
face and, after 3-4 hours, tightness of the chest,
nausea, altered speech, hemolysis, bloody urine, bronz-
ing of the skin, and enlargement and tenderness of the
liver and spleen.
Chronic poisoning from ingestion or inhalation produce
damaging of the nervous system, skin bronzing, loss of
hair, localized edema, dermatitis, cirrhosis of the
liver, nausea, vomiting, abdominal cramps, salivation,
anemia, and weight loss. Damage of cardiovascular
system and kidneys may also occur. Arsenic and its
compounds are carcinogenic.
Following acute poisoning, urine may show red blood
cells, protein, and cell casts. Arsenic compounds may
appear as barium-like radiopaque material after inges-
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tion. In fatal arsenic poisoning, the blood level has
ranged from 0.1-1.5 mg/lOOg. After therapeutic adminis-
tration of arsenic, the blood level has ranged from
0.01-0.025 mg/lOOg. After arsine inhalation, the urine
contains hemoglobin.
Following chronic poisoning, arsenic can be identified
in hair, nails, urine, feces, and vomitus by state or
county toxicologic laboratories. Liver or kidney function
may be impaired. Blood counts reveal as anemia.
Prevention:
Store arsenic safely. The TLV of arsine in air must be observed at all
times. Acid treatment of metals or dilution of acid sludge must be done with
adequate fume control.
Emergency Measures
Following ingested arsenic, immediate removal should be
by emesis. Seek immediate medical help.
Following chronic poisoning, remove from further exposure
and seek medical help.
Prognosis:
In acute arsenic poisoning, survival for more than 1 week is usually
followed by complete recovery. Complete recovery from chronic arsenic poison-
ing may require 6 months to 1 year.
BERYLLIUM
Beryllium is used in alloys for electrical equipment. It is present in
some fluorophors used in cathode ray tubes and fluorescent lights, but the
use of these fluorophors in fluorescent lamps has been discontinued by most
manufacturers.
The fatal dose of beryllium is not known. The TLV in air for beryllium
is 0.002 mg/cu m.
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Between 1941 and 1966, 760 cases of berylliosis were recorded in a
national registry (Massachusetts General Hospital, Boston). Between 1966
and 1973, 76 new cases were recorded. Beryllium appears to inhibit certain
magnesium-activated enzymes. The relation between this effect and the
pathologic changes induced by beryllium is not understood.
Soluble beryllium salts are directly irritating to skin and mucous
membranes and induce acute pneumonitis with pulmonary edema. At least part
of the changes present in acute pneumonitis and chronic pulmonary inflamma-
tion develop as a result of hypersensitivity to the beryllium in the tissues.
At pathologic examination, fibrous tissue growth is found at the site
of beryllium localization. In deaths from acute pneumonitis, the lung
alveoli are filled with cells.
The principal manifestation of beryllium poisoning is difficult breath-
ing.
Following inhalation, acute pneumonitis, with chest pain,
bronchial spasm, fever, difficult breathing, cyanosis,
cough, blood-tinged sputum, and nasal discharge may be
seen. Onset of symptoms occurs 2-5 weeks after an
exposure of 1-20 days.
Following skin contact, cuts from beryllium-contaminated
objects form deep ulcerations which are slow to heal.
Acute dermatitis from contact with dust simulates first
and second degree burns.
Following eye contact, dust contamination causes acute
conjunctivitis with corneal damage and diffuse irrita-
tion.
Following inhalation in chronic pulmonary berylliosis,
weight loss and marked difficult breathing begin 3
months to 11 years after first exposure. The disease
may pursue a steady downhill course or may be marked
by exacerbations and remissions. Right heart failure
may occur as a result of increased pulmonary resistance.
Fever is variable.
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Following chronic skin contact, dermatitis and rash
appear in a large percentage of exposed workers. In
such persons, patch tests with dilute beryllium
solutions show positive reactions.
In chronic pulmonary beryllosis, ex-ray examination
reveals a "snowstorm" appearance of the lungs.
Prevention:
Dusts and fumes from beryllium processes must be rigidly controlled.
No beryllium is allowable in air.
X-ray examinations of the chest are not useful in controlling exposure
or in case-finding. X-ray examination of the chest may become positive
without any symptoms, or positive x-ray findings may occur only at the onset
of symptoms. Workers may be asymptomatic and have normal x-ray examinations
of the chest during exposure to beryllium, and yet they may develop symptoms
and positive chest x-ray findings many years after discontinuing exposure.
Emergency measures include complete bed rest, supplemental oxygen for
difficult breathing and immediate medical attention. Skin ulcers may require
surgical removal.
Prognosis:
Recovery from acute pneumonitis requires 2-6 months. Deaths have been
rare. Approximately 2% of those with chronic pulmonary berylliosis die.
CADMIUM
Cadmium is used for plating metals in the manufacture of bearing alloys
and silver solders. Cadmium plating is soluble in acid foods such as fruit
juices and vinegar. Heating products containing cadmium above the melting
point (321 C) releases cadmium fumes.
The fatal dose by ingestion is not known. Ingestion of as little as
10 mg will cause marked symptoms. The TLV in air for cadmium oxide fumes
is 0.1 mg/cu m; for cadmium metals and dusts, it is 0.2 mg/cu m. Cadmium
A-57
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is damaging to all cells of the body.
The pathologic findings in cases of fatal cadmium ingestion are severe
gastrointestinal inflammation and liver and kidney damage. In fatal acute
poisoning from the inhalation of cadmium fumes, pathologic examination reveals
inflammation of the lung. Pathologic examination in fatalities following
prolonged exposure to cadmium fumes reveals emphysema.
The principal manifestations of cadmium poisoning are gastrointestinal
and lung irritation.
Following ingestion, nausea, vomiting, diarrhea, head-
ache, muscular aches, salivation, abdominal pain, shock,
liver damage, and kidney failure may occur.
Inhalation of cadmium fumes causes a metallic taste in
the mouth, shortness of breath, pain in the chest, cough
with foamy or bloody sputum, weakness, and pains in the
legs. Chest examination reveals bubbling rales. Urine
formation may be diminished later. Progression of the
disease is indicated by onset of fever and by develop-
ment of signs of lung consolidation.
Chronic poisoning from inhalation produces loss of sense
of smell, cough, difficult breathing, weight loss, anemia,
irritability, and yellow-stained teeth. The liver and
kidneys may be damaged.
After inhalation, early chest x-ray shows a diffuse in-
crease in lung density; later findings are those of
bronchial pneumonia. Bloody urine may be seen.
Prevention:
The TLV of cadmium fumes in air must always be observed. Acid foods
should never be stored or prepared in cadmium-plated cooking utensils.
Emergency measures should be to remove victim from further exposure.
Give milk or beaten eggs every 4 hours to alloy gastrointestinal irritation.
Seek immediate medical treatment.
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Prognosis:
Symptoms from cadmium ingestion usually last no more than 24 hours.
In fume inhalation, the mortality rate has been approximately 15%. Survival
for more than 4 days is followed by recovery, but complete recovery may take
6 months.
CHROMIUM
Chromium is used in chemical synthesis, steel-making, electroplating,
leather tanning, and as a radiator anti-rust.
The fatal dose of soluble chromate such as potassium chromate, potassium
bichromate, or chromic acid is approximately 5 g. The TLV in air for chromium
(determined as chromic oxide) is 0.1 mg/cu m. Up to 20% of chromium workers
develop dermatitis.
Chromium and chromates are irritating and destructive to all cells of
the body. In fatalities from acute poisoning, kidney damage is found.
The principal manifestation of chromium poisoning is irritation or
corrosion.
Following ingestion, dizziness, intense thirst, abdominal
pain, vomiting, shock, and kidney damage may occur.
Death is from uremia.
Repeated skin contact leads to incapacitating dermatitis
with edema, and ulceration which heals slowly. Breathing
chromium fumes over long periods causes painless ulcera-
tion, bleeding, and perforation of the nasal septum
accompanied by a foul nasal discharge. Conjunctivitis,
lacrimation, and acute hepatitis with jaundice have
also been observed.
The incidence of lung cancer is increased up to 15 times
normal in workers exposed to dusty chromite, chromic
oxide, and chromium ores.
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Prevention:
The TLV in air must always be observed. Chromic mist, fumes, and dust
must be controlled. Chromate solutions must not come in contact with the
skin.
Emergency measures should be to remove victim from further exposure.
Seek immediate medical attention.
Prognosis:
In acute poisoning, rapid progression to kidney failure indicates a
poor outcome. Dermatitis and liver damage will respond to removal from
further exposure.
LEAD
Lead is used in type metal, storage batteries, industrial paint, solder,
electric cable covering, pottery glaze, rubber, toys, gasoline (tetraethyl
lead), and brass alloys. Other sources include plastic beads or jewelery
coated with lead to give a pearl appearance, bootleg whisky, home-glazed
pottery, leaded glass making, the dust in shooting galleries, ashes and
fumes from the burning of old painted wood, and artists' pain pigments.
The amount of lead in circulation or that has been lost from use is enormous.
From 1720-1970, 47,303,551 tons of lead were added to the supply in the USA.
In 1968, net imports were 435,000 tons, and 390,000 tons were added from
mining. In this same year, 260,000 tons of lead were used in gasoline
additives.
The fatal dose of absorbed lead has been estimated to be 0.5 g.
Accumulation and toxicity occur if more than 0.5 mg/day is absorbed. The
TLV of lead in air is 0.15 mg/cu m. The TLV of lead in food is 2.56 mg/kg.
The TLV for tetraethyl lead should not exceed 117 ug/cu m of lead.
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The US Public Health Service has estimated that at least 400,000 child-
ren in the USA have increased blood levels, and 16,000 of these require
treatment each year. Each year, there are 200 deaths from lead encephalo-
pathy; 800 children have permanent brain damage; and 3200 have temporary
mental impairment. Most of these fatalities are in children who lived in
homes built before 1940. Most of the cases have been discovered in a few
hospitals, and it is possible tha the incidence of lead poisoning may be
considerably higher.
The most serious toxic effects result from effects of lead on the brain
and peripheral nervous system. The brain and liver lead levels may be 5-10
times the blood level. The lead in these tissues is only slowly removable
by de-leading agents. Since only uncombined lead is removed effectively
by de-leading agents, the increased excretion of lead brought about by
such agents is only temporary. The de-leading agent only becomes effective
again when further lead has been released from combination.
In acute poisoning, pathologic findings include inflammation of the
gastrointestinal mucosa and kidney degeneration. In chronic lead poisoning,
cerebral edema and degeneration of nerve and muscle cells occur. The liver
may also show damage.
Any symptoms suggestive of brain damage should be considered an emer-
gency. A rapid presumptive diagnosis can be based on the presence of the
following: urine, porphyrins above 0.5 mg/liter; blood lead above 80 pg/
100 ml; erythrocyte protoporphyrin greater than 190 ng/100 ml of whole
blood, or — in the presence of anemia (38% Hgb) — erythrocyte proto-
porphyrin greater than 500 yg/100 ml of erythrocytes; erythrocyte 6-amino-
levulinic acid dehydratase less than 50% of normal, increased protoporphyrin
fluorescence of whole blood; and the appearance of radiopaque material on a
plain film of the abdomen and radiopaque lead lines in the wrists and knees.
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Any positive finding in addition to suggestive symptoms is sufficient
indication to start therapy. Any child who has minor symptoms of poison-
ing can develop acute encephalopathy suddenly if blood lead is above
80 yg/100 ml.
The principal manifestations of lead poisoning are gastrointestinal
or central nervous system disturbances and anemia.
For ingestion or rapidly absorbed compounds of lead,
metallic taste, abdominal pain, vomiting, diarrhea,
black stools, kidney damage, collapse, and coma may
be seen.
From chronic ingestion, skin absorption, or inhala-
tion or particulate or organic lead the following may
be observed: 1) Early — loss of appetite, weight
loss, constipation, irritability, occasional vomiting,
fatigue, headache, weakness, metallic taste, lead
line on gums, loss of recently developed skills, and
anemia. 2) More advanced — Intermittent vomiting,
irritability, nervousness, incoordination; vague
pains in arms, legs, joints, and abdomen; sensory
disturbances of extremities, paralysis of extensor
muscles of arms and legs with wrist and foot drop,
disturbance of menstrual cycle, and abortion.
3) Severe — Persistent vomiting, ataxia, periods of
stupor or lethargy, encephalopathy (with visual
disturbances), elevated blood pressure, paralysis,
delirium, convulsions, and coma. Severe symptoms
occur most frequently in lead poisoning in children
or in adults exposed to tetraethyl lead. 4) Exposure
to tetraethyl lead or tetramethyl lead causes in-
somnia, disturbing dreams, emotional instability,
hyperactivity, convulsions, and even toxic psychosis.
The following findings are suggestive of lead poison-
ing: 1) Blood — Hemoglobin below 13 g/100 ml
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blood. Blooa lead about 20 yg/100 ml indicates exposure to lead
above 40 yg/100 ml suggests the need for a search for source of
lead and its elimination. Levels above 60 yg/100 ml should be
reduced with de-leading agents. Risk of encephalopathy is great
at blood lead level over 80 yg/100 ml; level over 100 yg/100 ml
should be treated as an emergency. 2) Urine lead excretion greater
than 0.08 mg/day or urine coproporphyrin above 0.15 mg/24 hours.
Prevention
Lead-containing paint should not be used indoors. Painters and lead workers
must change clothing and bathe before eating. Precautions must be taken to keep
lead in air below the TLV. Children must not be allowed to play with lead toys.
Emergency measures should include removal of acutely ingested lead by emesis
and medical treatment for acute and chronic lead poisoning.
Prognosis
Until recently, the death rate in patients with lead encephalopathy was about
25%. About half of those who survived had permanent mental deterioration. The
effect of calcium disodium edetate on the prognosis in lead encephalopathy has
not been determined as yet.
Complete recovery from other forms of lead poisoning takes up to 1 year.
MANGANESE
Manganese is used in the manufacture of steel and dry cell batteries.
The TLV in air of manganese is 5 mg/cu m.
The toxic amount of inhalation is not known. Fatalities are rare.
The mechanism of manganese poisoning is not known. Inhalation of manganese
fumes or dusts produces progressive deterioration in the brain. Large oral doses
of manganese compounds are without systemic effect in experimental animals.
The findings in one death suspected to be from ingesting manganese-contaminated
drinking water were atrophy and disappearance of cells of the brain. Experimental
animals show inflammatory changes in brain.
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The principal manifestations of poisoning with these compounds are brain
disturbances.
Ingestion of manganese-contaminated well water caused lethargy,
edema, and symptoms of brain damage.
Inhalation of manganese dusts caused acute bronchitis, naso-
pharyngitis, pneumonia, headache, itching, numbness of the extremities,
impairment of libido, sleep disturbances, dermatitis, and liver
enlargement. Later, there are gradually progressive signs which
simulate parkinsonian syndrome. These include weakness in the legs,
increased muscle tone, hand tremor, slurred speech, muscular cramps,
spastic gait, fixed facial expression, and mental deterioration.
Prevention
Workmen should change clothing and bathe on leaving work. Quarterly physical
examinations of all exposed workers will aid in the discovery of early changes.
Batteries must not be buried near water supplies.
Emergency measures include removal from further exposure and immediate medical
attention.
Prognosis
While liver and respiratory system damage from manganese are reported to
respond to calcium disodium edetate, this antidote has no effect on the symptoms
of brain deterioration. If exposure is discontinued when brain symptoms first
appear, recovery is possible.
MERCURY
Mercury is a liquid. Air saturated with mercury at 20 C contains about
15 mg/cu m. At 40 C, saturated air contains 68 mg/cu m.
Mercury and its salts are used in the manufacture of thermometers, felt,
paints, explosives, lamps electrical apparatus, and batteries. The volatile
diethyl and dimethyl mercury compounds are used in treating seeds. Mercurous
chloride (calamel) and organic mercurials are used medicinally.
The fatal dose of mercuric salts such as mercuric chloride (corrosive
sublimate) is 1 g. Ingested metallic mercury is not toxic since it is not absorbed,
A-64
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Mercurous chloride, ammom'ated mercury, mercury protoiodide, and organic
antiseptic mercurials such as acetomeroctol, merbromin, mercocresol, nitromersol,
phenylmercuric salts and esters, and thimerosal (Merthiolate) are not likely to
cause acute poisoning because they are poorly absorbed. The single fatal dose
of these compounds is 2-4 times the fatal dose of soluble inorganic mercury salts.
The mercurial diuretics (mersalyl, meralluride, mercurophylline, mercumatilin,
mercaptomerin, chlormerodrin, and merethosylline) are almost as toxic as mercuric
chloride in experimental animals in comparison to mercury content. The TLV in air
of mercury or mercury compounds is 0.05 mg/cu m as mercury. Volatile alkyl
mercury compounds such as methyl mercury chloride, methyl mercury cyanide, methyl
mercury hydroxide, methyl mercury pentachlorophenate, methyl mercury toluene sulfonate,
ethyl mercury chloride (Ceresan), ethyl mercury phosphate, and ethyl mercury
toluene sulfonate are twice as toxic as mercuric chloride and the TLV is 0.01
mg/cu m. Other organic mercury compounds, such as hydroxymercuriphenol and
cyano-methyl-mercuri-guanidine, are as toxic as an equivalent amount of mercury
in mercuric chloride.
Environmental contamination from industrial discharge of organic mercury
compounds has resulted in organic mercurial poisoning from eating fish from the
discharge area. Seed grains treated with organic mercury fungicides have caused
poisoning when used as food. Cencentration of alkyl mercury compounds (methyl
mercury) should not exceed 0.5 mg/g, in food; for foods at tnis level, intake
should be limited to not more than 0.5 kg/week.
Mercury depresses cellular enzymatic mechanisms by combining with sulfhydryl
(-SH) groups; for this reason, soluble mercuric salts are toxic to all cells.
The high concentrations attained during kidney excretion lead to specific damage
to kidney.
In fatalities from mercury poisoning, the pathologic findings are acute
kidney damage. The mucosa of the gastrointestinal tract shows inflammation,
congestion, coagulation and corrosion.
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Prevention
The TLV must be observed at all times; frequent air sampling is necessary.
Floors in rooms where mercury is used must be impervious and free from
cracks. Spilled mercury should be picked up immediately by water pump suction
or by a wet sweeping compound. After handling mercury or mercury compounds,
the skin must be thoroughly cleaned.
Emergency measures should include removal of ingested mercury by ernes is
-and immediate medical assistance sought. Remove from furtner exposure.
Prognosis
In acute and chronic poisoning, recovery is likely if dimercaprol treat-
ment is given for at least 1 week. Recovery from mental deterioration caused by
chronic mercury poisoning may never be complete. Brain damage from alkyl mercury
compounds is more likely to be permanent. Improvement requires 1-2 years.
NICKEL CARBONYL
Nicked carbonyl is formed by passing carbon monoxide over finely divided
metallic nickel. Nickel carbonyl is a liquid which boils at 43 C. It is impor-
tant in the Mond process for refining nickel. It is also used in petroleum
refining.
The TLV in air of nickel carbonyl is 0.001 ppm. Inhaled nickel carbonyl
decomposes the metallic nickel, which deposits on the epithelium of the lung.
This finely divided nickel is rapidly absorbed and damages the lung and brain.
Postmortem examinations in deaths caused by nickel carbonyl inhalation reveals
edema and congestion of the lungs and brain. Areas of necrosis and hemorrhage
are found in the brain and lungs.
The principal manifestation of nickel carbonyl poisoning is difficult
breathing.
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The principal manifestation of mercury salt poisoning is kidney damage.
Ingestion of mercuric salts causes metallic taste, thirst, severe
abdominal pain, vomiting, and bloody diarrhea. Diarrhea of mucus
shreds and blood may continue for several weeks. One day to 2
weeks after ingestion, urine output diminishes or stops. Death
is from uremia. Esophageal, gastric, or intestinal damage may
occur after mercuric chloride.
Inhalation of a high concentration of mercury vapor will be
followed within 1-2 days by stomach damage, salivation,
metallic taste, diarrhea, pneumonitis, and kidney damage with
shutdown. Inhaling volatile organic mercurials in high concen-
trations causes metallic taste, dizziness, clumsiness, slurred
speech, diarrhea, and sometimes fatal convulsions.
Alkyl mercury compounds are concentrated in the brain with ataxia,
tremors, and convulsions. Damage tends to be permanent.
Inhalation of mercury vapor, dusts, or organic vapors, or skin
absorption of mercury or mercury compounds over a long period
causes mercurial ism. Findings are extremely variable and include
tremors, salivation, stomach pain loosening of the teeth, blue
line on the gums, pain and numbness in the extremities, kidney
damage, diarrhea, anxiety, headache, weight loss, loss of appetite,
mental depression, hallucinations, and evidences of mental deterioration,
The lowest concentrations of methyl mercury in blood associated with
identifiable symptoms is 0.2 mg/liter. A tentative blood standard
not to exceed 0.1 mg/liter has been set.
Urinary excretion of more than 0.3 mg of mercury/24 hours indicates
the possibility of mercury poisoning. An average excretion above
0.1 mg/24 hours urine in a group of mercury workers indicates the
need for corrective measures for the work situation. An individual
who shows over 0.2 mg/24 hours in urine should be removed from
exposure until his urinary concentration falls below 0.05 mg/24 hours.
Workers using organic mercury compounds should be removed from further
exposure if the urinary excretion goes above 0.05 mg/24 hours. The
county or state health department will make arrangements for mercury
analyses.
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Inhalation of nickel carbonyl immediately causes cough, dizziness,
headache, and .malaise, which ordinarily can be relieved by removal
to fresh air. Progressive dyspnea, cough cyanosis, fever, rapid
pulse, nausea, and vomiting may follow in 12-36 hours, and death from
respiratory failure within 4-12 days.
Workers exposed to nickel carbonyl show a high incidence of lung cancer.
Some workers develop dermatitis following chronic exposure.
Prevention
The TLV for nickel carbonyl must always be observed. No person with chronic
pulmonary disease should work where nickel carbonyl exposure can occur. Contami-
nated atmospheres can only be entered by using a positive pressure breathing mask.
Emergency measures should include giving 100% oxygen by mask to treat cyanosis
and difficult breathing and medical attention immediately sought. Victim should
be removed from further exposure.
Prognosis
Survival for more than 14 days is followed by recovery. Cyanosis and
difficult breathing are indices of the severity of poisoning.
PHOSPHORUS, PHOSPHINE, PHOSPHIDES
Phosphorus exists in 2 forms: a red, granular, non-absorbed, and non-
poisonous form, and a yellow, waxy, water-insoluble and fat-soluble, highly
poisonous form which will burn on contact with air. Red phosphorus is sometimes
contaminated with yellow phosphorus. The striking surface of a safety match
contains 50% red phosphorus. Yellow phosphorus is used in rodent and insect
poisons, fireworks, and fertilizer manufacture. The action of water or acids on metals
will liberate phosphine if phosphorus is present as a contaminant. Phosphine may
also be present in acetylene. Phosphides, used as rat poisons, release phosphine
on contact with water. Phosphorus sesquisulfide (tetraphosphorus trisulfide) has
low toxicity. The heads of 20 large wooden matches contain 220 mg.
The fatal dose of yellow phosphorus or phosphides is approximately 1 mg/kg.
The TLV in air of yellow phosphorus is 0.1 mg/cu m. The TLV in air of phosphine
is 0.3 ppm. A-68
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Phosphorus causes tissue destruction, with disturbance in carbohydrate,
fat, and protein metabolism in the liver. Deposition of glycogen in the liver
is inhibited; deposition of fat is increased.
Chronic absorption of phosphorus increases bone formation. These changes
lead to destruction of bone; they occur most frequently in the mandible.
The pathologic findings in yellow phosphorus poisoning are jaundice, fatty
degradation of the liver and kidneys, and hemorrhages, congestion, and erosion
of the gastrointestinal tract. Pathologic findings from phosphine inhalation
are pulmonary edema. Zinc phosphide ingestion causesxboth fatty degeneration and
necrosis of the liver and pulmonary edema.
The principal manifestations of poisoning with these compounds are liver
damage and collapse.
Ingestion of yellow phosphorus is followed within 1-2 hours by
nausea, vomiting, diarrhea, cardiac abnormalities and a garlic
odor of breath and excreta. Death in coma or cardiac arrest may
occur in the first 24-48 hours, or symptoms may improve for 1 or 2 days
i
and then return, with nausea, vomiting, diarrhea, liver damage,
prostration, fall of blood pressure, tetany, kidney damage, hypoglycemia,
and hemorrhages. Respiration abnormalities followed by convulsions,
coma, and death may occur up to 3 weeks after poisoning. Phosphide
ingestion causes liver damage, jaundice, and pulmonary edema with
difficult breathing and cyanosis. Death may occur up to a week after
poisoning.
Yellow phosphorus allowed to dry on the ski! will ignite and cause
second to third degree burns surrounded by blisters. These burns
heal slowly.
Inhalation of phosphorus is followed, after 1-3 days, by the symptoms
of acute phosphorus poisoning. Phosphine or phosphide inhalation
causes fall of blood pressure, difficult breathing, pulmonary edema,
collapse, vomiting, cardiac abnormalities, convulsions, and coma.
Death usually occurs within 4 days; it may be delayed 1-2 weeks.
Kidney damage may appear after several days from chronic ingestion
or inhalation of yellow phosphorus, phospine, or phosphides. The
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first symptom is toothache, followed by swelling of the jaw and
then destruction of the mandible (phossy jaw). Other findings are
weakness, weight loss, loss of appetite, anemia, and spontaneous
fractures.
Prevention
The TLV of phosphorus, phosphine, and phosphides in the air must be observed
at all times. Special clothing, to be changed daily, should be provided phosphorus
workers. Workers must bathe on leaving work and must be educated in the hazards
of phosphorus exposure. Safety showers and eye fountains must be provided where
yellow phosphorus is being used. Dental examinations should be made frequently,
depending on exposure.
Emergency measures should include removal of victim from further exposure.
Medical attention should be sought immediately.
Prognosis
In poisoning from ingestion of phosphorus, the fatality rate is about 50%.
In phosphine inhalation, survival for 4 days is ordinarily followed by recovery.
ZINC FUMES AND METAL FUME FEVER
Zinc fumes are produced in welding, metal cuttings, and smelting zinc
alloys or galvanized iron. Zinc fumes are most often responsible for metal fume
fever, but other metal fumes will also cause the disease. Soluble zinc salts,
such as zinc chloride, are used in smoke generators.
The TLV in air for zinc oxide fumes is 5 mg/cu m. No fatalities from breathing
zinc oxide or zinc chloride fumes have been reported in recent years.
Fumes from zinc or soluble zinc salts irritate the lungs. Other physiologic
changes are not known,
The pathologic findings in fatalities from zinc chloride or zinc fume
inhalation are pulmonary edema and damage to the respiratory tract.
Clinical Findings
The principal manifestations of acute zinc fume or other metal fume poisoning
are muscular aches and fever. Chronic poisoning does not occur.
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Inhalation of zinc oxide or other metal oxide fumes causes fever, chills,
nausea, vomiting, muscular aches, and weakness. Inhaling fumes of soluble zinc
salts such as zinc chloride may cause pulmonary edema with cyanosis and
difficult breathing.
Prevention
Zinc chloride smoke generators should not be operated in such a way that
workers will be exposed. Fumes from melting zinc must be controlled by proper
air exhaust.
Emergency measures should include removal of victim from fumes and
immediate medical attention.
Prognosis
In zinc fume fever, recovery occurs in 24-48 hours. In pulmonary edema
from zinc chloride fumes, the fatality rate has been 10-40%.
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GASES
AIRBORNE POISONS
A-72
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AIR30RN3 ?OI30NS. PARTTCULATES AND GASES
I. HISTORY
Pulmonary diseases can be caused by inhalation of insoluble dust
particles vhich indues production of connective tissues. These pul-
monary diseases are che pr.eumoconioses. The dust particles increase
the amount of connective tissue and encroach upon the breathing space
of the lung, ultimately resulting in respiratory embarrassment As
fibrosis advances, ecphysema develops to embarrass further respiration.
Silicosis is cha most frequent disease of this group.
II. PHARMACODYMAMICS
Most irritant gases are corrosive by nature, and when inhaled act
primarily to produce acute, local irritation of the upper respiratory
tract, bronchi, or alveoli. A mild action produces increased secretion
of mucous. A ssora intense action produces an inflammatory reaction with
edema and cellular e::udation. Some gases az'fect primarily the nasal mu-
cosa (ammonia); others act more severely on bronchi (chlorine or hydrogen
chloride fumes); and socie affect the alveoli (phosgene). Exposure to
irritant gases may produce either acute pulmonary disease or an illness
seen only after long e:cposure (weeks). In these chronic cases, the
period of illness is also prolonged.
III. TOXICITY
(A) Nonabaorbable dusts
1. Berylli'jm; Beryllium is one of the most toxic metals used in
industry and research. Ij causes sicin and eye lesions as well as pul-
monary damage.
2. Silicon: Silicon does not exist free in nature, but as silica
(Si02) or combined as metallic silicates (granite, clay, mica, asbestos,
feldspar). Quartz is the most comson fora and the form of clinical im-
portance. Wide industrial use of crystalline silica have resulted in
exposure of many individuals to silica dust through inhalation.
Silicosis; T"nis is the condition resulting from the inhalation
of crystalline silica. This disease usually requires lOt to 25 years to
develop and is characterized by nodules of fibrosis scattered uniformly
throughout both lungs. Silicosis is clinically characterized by short-
ness of breath. With advanced silicosis, half of the individuals develop
tuberculosis.
3. Asbestos; Asbestos is a hydrated magnesium silicate which occurs
in nature in a nuinber of forms and ia associated with a number of other
metal silicates. Aabestosis is a progressive, diffuse, normodular fibrosis
of the lungs resulting frcia the prolonged ir.halacion of asbestos fibers.
The principal syrrptoir^ are dyspnea, loss of weight and coughing. Asbesto-
sis may produce a predisposition to lung cancer.
4. Vegetable duscs: Son-.e vegetable dusts contain spores of fungi.
A-73
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Workers exposed to cotton dusts over a period of more than 20 years de-
velop a slowly, progressive dyspnea, bronchitis and emphysema. These
individuals have a predisposition to respiratory tract infections. The
disease is thought to be the result of organisms present on cotton
fibers and not by a toxic action of the fiber per s_e. This disease is
called byssinosis.
Pulmorary disorders are also described following contact with moldy
hay and grain. This disorder is known as farmer's lung. It is not often
fatal, but may cause a high morbidity.
After sugar has been expressed from sugar cane, che remaining
material is called bagasse. A pulmonary disease, bagassosis, may follow
inhalation of bagasse fibers. The disease is characterized by inflamma-
tory and fibrotic lesions of the lung. Again, the disease is not often
fatal but may produce a high morbidity.
(B) Noxious Gases a.id Vapors
1. IRRITATING GASEj; The toxicity of irritating gases is the result
of their caustic or corrosive nature. In huaans the toxicity is manifested at
the site of exposure, i.e. or. the skin or respiratory tract. Such agents are re-
ferred to as "primary irricants" and may cause inflammatory responses or extensive
tissue necrosis. The reaction is nonspecific and occurs on all cells regardless of
type. Methylbromide, a refrigerant, will produce chemical burns of an intensity
directly related to exposure concentration. Gases encountered in smog, such as
sulfur dioxide and nitrogen dioxide are converted to sulfurous and nitrous acid in
the presence of water (at -embrares or in the air) producing a primary irritation.
Aldehydes, such as acrolain (silyl aldenyde) and formaldehyde, are strong irritants
when inhaled and may cauje pulaonary ede=a rasulting in loss of air space and im-
paired transfer o£ respiratory gases. In patier.cs with lung diseases mild exposure
to primary irritants may lead to serious impairment of pulmonary function.
2. CARBON MONOXIDE (CO); Carbon monoxide is a. colorless, tasteless, and
nonirritating gas. There era over 5,000 CO deaths annually in the U.S., making
CO the most common cause of death by gas poisoning.
Reaction with hemoglobin; Carbon monoxide combines reversibly with
hemoglobin forming carboxyhenogiobin, (COHb), in such a manner as to prevent this
blood pigment from transporting the normal blood gases 02 and C02- The COHb combin-
ation diminishes the 02-releasing ability of the re^aaining hemoglobin, which has
not combined with CO.
Carbon monoxide accumulates (reversibly) in che blood because the af-
finity of human hemoglobin for CO is about 200 times greater than its affinity for
oxygen. There is a rapid removal of CO from the plasma into the red blood cell to
combine with hemoglobin. Continued formation of COHb keeps the plasma CO tension
at a low level and maintains a steep CO gradient from the alveolus to the blood.
COHb, lilo oxyh^ac^lobin, ia a dissociable compound. When exposure
to the gas is terminated, CO diasociauas from the hemoglobin and escapes from the
blood. COHB dissociation is greatest in che presence of pure oxygen, which dis-
places CO on the hemoglobin molecule and converts COHb to oxyhesnog lob in. The
average half-life for COHb in tne circulation is 250 minutes. If oxygen is sub-
stituted for air the naif-life is reduced to 40 minutes.
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11-21
Factors Governing CO Tjxictty are; (a) CO concentration in inspired
air; (b) Duration of exposure; (c) Respiratory minute volume; (d) Cardiac output;
(e) Oxygen demand of tissues; (f) Hemoglobin concentration of the blood.
Acidosis; Tissre acidosis is associated with CO poisoning. Since
tissue cells are forced to operate at lover $2 tensions, anaerobic metabolism
increases lactic acid production. COKb does not transport C02 and impairs this
function in the residual intact hemoglobin, and C02 accumulates at cellular sites.
Acute CO Poisoning;
Diagnosis; The victim is commonly found under circumstances that
leave little doubt as to the cause of his condition, e.g. in a closed car. The
appearance of the patient also assists in the diagnosis. COKb is bright red in
color. This results in the unusual combination of hypoxia associated with a bright
red color of the fingernails, mucous membranes and skin ("cherry-red cyanosis").
Final diagnosis depends upon demonstration of COHb in the blood.
Treatment; Transfer the patient to fresh air and administer
artificial respiration and pure oxygen. The patien; should be kept warm and remain
absolutely quiet to keep tissue demands for oxygen at a minimum.
Pathology; The changes that result in tissues are brought about
by hypoxia. Tissues most seriously affected are the most sensitive to oxygen de-
privation, such as the brain. CO poisoning is sometimes followed by permanent
damage to the central nervous system. The heart is also sensitive to hypoxia.
Pathological lesions that occur in the heart, brain ana other organs are primarily
vascular, i.e., small hemorrhages and perivascular infiltration with local necrosis.
Chronic CO Poisoning! Illness may develop (headache, dyspepsia,
weakness, dizziness, and polycythemia) as a result of tissue injury induced by re-
peated exposure to toxic concentrations of CO. The illness may persist and pro-
gress long after the noxious agent has disappeared from the body. The m.a.c. is
100 ppm.
3. KYDROCYAiNIC ACID OR CYANIDE; Hydrocyanic acid (HCN) vapors produce
severe toxic effects and death within a few minutes. The action of HCN is due to
the cyanide ion. The toxic properties of the gas are shared by all the soluble
inorganic cyanide salts. All the pharmacological actions of cyanide result from
the cytotoxic hypoxia that it produces.
Pharmacodynaicics; Cyanide reacts with iron only in the ferric (tri-
valent) state. It reacts with iron of cytochrome oxidase to form a cytochrome
oxidase-CN complex and with the iron of raethemoglobin to form cyanmethemoglobin.
Cytochrome oxidase is particularly reactive with cyanide, and when the two combine
cellular respiration is inhibited, i.e. a cytotoxic hypoxia. The cytochrotne-CN
complex is dissociable. Hhodanese, a tissue enzyme, mediates the transfer of sul-
fur from thiosulfate to cyanide ion to form thiocyanate. The respiratory enzyme
is thus freed and cell respiration is restored. Tissue rhodanese is adequate to
handle relatively large aaouncs of cyanide, but the reaction is limited by the
endogenous supply of thiosulfate. Formation of cytochrome oxidase-CN complex is
minimal in the presence of high concentrations of methemoglobin. Cyanide ion
stimulates respiration and depresses brain function. The actions on the myocardium
produce cardiac slowing and characteristic changes in the electrocardiogram.
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11-22
Cyanide is readily absorbed after oral, topical, or parenteral
administration. Part of the absorbed cyanide is excreted unchanged by the lungs.
The larger portion is converged by the enzyme rhodanese to the relatively non-
toxic thiocyanate ion.
Cyanide Poisoning; SyapCorns of hyperpnea, cyanosis and uncon-
sciousness following cyanide poisoning occur within seconds to minutes following
ingestion or exposure to vapors.
Treatment; Treatment of cyanide poisoning is specific and must
be given rapidly if it is to be effective. Diagnosis can be made by characteristic
cyanide odor ("bitter almonds") on the breath. This sign in association with
asphyxia and cyanosis is pathognomonic. The objective of treatment is to produce
a high concentration of methemoglobin (Hb-Fe4"4"1") by administration of nitrite.
Methemoglobin competes with cytochrome oxidase (Cyt. -re"*""") for the cyanide ion.
Detoxification of cyanmethemoglobin is achieved by administration of thiosulfate,
which, under the influence of rhodanese, reacts with cyanide to form thiocyanate
(SON). Sodium nitrite is one of the best producers of methemoglobin. Immediate
therapy with amyl nitrite inhalations followed by slow intravenous injection of
sodium thiosulfate should be administered. If symptoms reappear, the above pro-
cedure should be repeated with half doses.
IV. REFERENCES
The Pharmacological Basis of Therapeutics, Ed. L.S. Goodman and A. Gilman
Chapter 44, pp 930-936.
Drill's Pharmacology in Medicine. Ed. J.R. DiPalma. Chapter 61. pp. 983-988
and Chapter 58, pp. 932-944.
A-76
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11-23
METHEMOGLOBIN
Oxidation of ferrous (Fe2+) hemoglobin to the ferric
-------
11-24
Acute poisoning - Symptoms are referable to Che central nervous system.
There is a preliminary period of excitement and restlessness followed by central
nervous system depression and death from respiratory failure.
Chronic Poisoning - The major toxic manifestations result from the action
of benzene on the bone marvow. Gastrointestinal symptoms such as anorexia and
nausea are common. Benzene may first stimulate leukocyte formation and then
cause inhibition of production of the precursors of all of the formed elements
of the peripheral blood, resulting in aplastic anemia.
Treatment - Once poisoning has developed it is important to prevent further
exposure. Therapy is symptomatic treatment.
GASOLINE
Gasoline is a petroleum distillate containing the distillate fractions of
petroleum ether, naphtha and benzene.
Toxicity - Gasoline vapors can sensitize the myocardium to catecholamines
so that small amounts of circulating epinephrine may precipitate ventricular
fibrillation and lead to sudden death. High concentrations of gasoline vapors
lead to rapid central nervous system depression and death from respiratory
failure.
Treatment - Treatment consists of svr.ptonatic and supportive measures.
KEROSENE
Kerosene is a common cause of accidental poisoning in children. Approximately
23,000 nonfatal poisonings due to petroleum distillate products occur annually
in children under 5 years of age.
Toxicity - The fatal oral dose for an adult is about 3 to 4 ounces. Chief
pathological findings are chemical pnetisionitis, explicated by bacterial penumonia,
and pulmonary edema. Ingestion of Isrga amounts -ay also damage parenchymatous
organs, i.e. liver, kidney and splaen. Signs and symptoms include tinnitus,
muscular incoordination, disoriencasLon, rfrcwsinass and eventually coma. Ingestion
of kerosene produces local irritation of oropharynx and esophogeal surfaces.
Vomiting may result in aspiration of kcrosane into the lungs. (The usual clinical
course is quite benign, unless lars;£ quantities have been ingested, or the
kerosene has been aspirated into the lungs).
Treatment - Emetics are definitely contraindjcated. Gastric lavage should not
be employed unless the risks involved are justified by the excessive quantity
ingested or the condition of the patient. Vegetable oil (olive oil) may be
administered to dilute the kerosene and decrease its rate of absorption.
CARBON TETRACHLORIDE
Carbon tetrachloride is used as a solvent, cleaner, ingredient in fire-
extinguisher fluid and insecticide sprays.
Absorption, Fate and Excretion - Carbon tetrachloride is readily absorbed
from the respiratory tract. Absorption is slow following oral ingescion, but the
presence of fats or alcohol enhance absorption of carbon tetrachloride.
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11-25
Toxlcitv - Applied locally, carbon tecrachloride is an irritant and
rubefacient. It depresses the central nervous system and sensitizes the
myocardium to cardiac arrhythmias. Carbon tetrachloride is hepacotoxic and
nephrotoxic.
Acute Intoxication - Acute exposure produces irritation of the eyes, nose,
and throat, nausea and vomiting, dizziness and headache. Continued exposure
produces central nervous system depression, coma and death. Sudden death may
occur from ventricular fibrillation of the sensitized myocardium.
Chronic Intoxication - Chronic intoxication is usually the result of
industrial exposure. The threshold-limit value is 25 ppm. Signs and symptoms
are nausea, vomiting, anorexia, central nervous system depression, hepatic and
renal damage.
Intoxication by Ingestion - Gastrointestinal symptoms are seen, including
hematemesis, abdominal pain, and liver damage. The fatal oral dose is 2 to 4
milliliters.
Treatment - Emergency treatment should be to move the patient to fresh
air if exposed to vapors. Empty the stomach immediately by inducing vomiting or
gastric lavage and give a laxative to minimize absorption if ingested. If
advanced central nervous system depression has occurred, every effort should be
made to prevent hypoxia by administration of 0, and artificial respiration. Do
not attempt to elevate blood pressure by use of sympaEhomimetic drugs because of
sensitized myocardium. Renal function and liver function should be observed.
Administer glucose and maintain the volume and composition of the body fluids.
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B
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VIII-1
FROM: "Enforcement Considerations for Evaluations of Uncontrolled
Hazardous Waste Disposal Sites by Contractors," NEIC, April/ 1980.
VIII. CHAIN-OF-CUSTODY
After collection and identification, the samples are maintained under
the Chain-of-Custody procedures. If the sample collected is to be split
with the owner or operator of the site, or other regulatory agencies, it
should be aliquoted into similar sample containers. Sample tags with
identical information are attached to each of the samples and are marked as
"Company Split" or "Split". If air samples are to be given to the Company,
then duplicate samples must be collected. The requesting official is to be
notified that the Company must reimourse the Government for the materials
used in sampling.
Each person involved with the sample must know Chain-of-Custody proce-
dures. The procedures should be included in the Project Plan or be published
and available to all personnel. Due to the evidentiary nature of sample-
collecting investigations, the possession of samples must be traceable from
the time the samples are collected until they are introduced as evidence in
legal proceedings. To maintain and document sample possession, Chain-of-
Custody procedures are followed.
1. Sample Custody
A sample is under custody if:
a. It is in your actural possession, or
b. it is in your view, after being in you physical possession,
or
c. it was in your physical possession and then you locked it
up to prevent tampering, or
d. it is in a designated and identified secure area.
2. Field Custody Procedures
a. When collecting samples for evidence, collect only that
number which provides a fair representation of the media
being sampled. To the extent possible, the quantity and
types of samples and sample locations are determined prior
to the actual field work. As few people as possible should
handle the samples.
B-l
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VIII-2
b. The field sampler is personally responsible for the care
and custody of the samples until they are transferred or
properly dispatched.
c. Sample tags shall be completed for each sample, using
waterproof ink unless prohibited by weather conditions.
d. During the course and at the end of the field work, the
FIT Leader determines whether these procedures have
been followed, and if additional samples are required.
3. Transfer of Custody and Shipment
a. Samples are accompanied by a Chain-of-Custody Record (see
following pages). When transferring the possession of
samples, the individuals relinquishing and receiving will
sign, date, and note the time on the Record. This Record
documents transfer of custody of samples from the sampler
to another person, to a mobile laboratory, or to the per-
manent laboratory.
b. Samples will be properly packaged for shipment and
dispatched to the appropriate laboratory for analysis,
with a separate signed Custody Record enclosed in each
sample box or cooler. Shipping containers will be pad-
locked or custody-sealed for shipment to the laboratory.
Preferred procedure includes use of a custody seal*
wrapped across filament tape that is wrapped around the
package at least twice. The custody seal is then folded
over and stuck to itself so that the only access to the
package is by cutting the filament tape or breaking the
seal to unwrap the tape. The seal is then signed. The
"Courier to Airport" space on the Chain-of-Custody Record
shall be dated and signed.
c. Whenever samples are split with a facility or government
agency, a separate Chain-of-Custody Record is prepared
for those samples and marked to indicate with whom the
samples are being split.
d. All packages will be accompanied by the Chain-of-Custody
Record showing identification of the contents. The
original Record will accompany the shipment, and a copy
will be retained by the Project Leader.
e. If sent by common carrier, a Bill of Lading 'should be
used. Receipts of Bill of Lading will be retained
as part of the permanent documentation.
* Custody Seals. Custody seals should be made of 1" x 6"-U.L. lutho tape
with security slots. This tape is backed with a very strong self adhesiv
so that once stuck to itself it will not come apart without breaking the
seal.
B-2
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0" "c ol Enforcement
CHAIN OF CUSir RECORD
PlO| NO
Project Name
f'\f.'iH EHt'> i.s yi
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STATION LOCATION
NO
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CON-
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REMARKS
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Dale/Time
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Date/Time
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Received by.
Relinquished by
Relinquished by.
Received lor Laboratory by
(Signature}
Date/Tune
Disiiinuiion Original Accompanies Shipment. Copy to Coordinator Field Files
Dale/Time
Date/Time
Received by
Received by:
Remarks
M-0001
-------
X-l
X. PACKAGING, MARKING, LABELING, AND SHIPPING OF
HAZARDOUS WASTE SITE SAMPLES
A. GENERAL PROVISIONS
Samples that are judged to be environmental samples may be shipped
according to letters of understanding granted EPA by DOT [Appendix D].
Other specific exemptions may also apply (e.g., use of Labelmaster, Inc.
package #38, or Dow Chemical Co. Imbiber Pack for shipment of Poison B,
n.o.s. by United Parcel Service).
The following procedures apply to samples collected from a hazardous
waste site (HWS), ana which in the judgment of the Project Leader cannot be
considered to be "environmental" samples.
Unanalyzed HWS samples may not be fixed with any preservative
or preserved with ice or dry ice.
If a material identified in the Department of Transportation
(DOT) Hazardous Material Table (49 CFR 172.101) is known to be
contained in an HWS sample, that sample should be transported
as prescribed in the table.
Unanalyzed HWS samples may be transported by rented or common
carrier truck, bus, railroad, and by Federal Express Corporation*
(air cargo); but they may not be transported by any other common
carrier air transport, even "cargo only" aircraft. Those samples
taken from closed drums or tanks, however, must not be transported
by Federal Express. (See 1 and 2 in "Packaging, Marking and
Labeling Requirements for Unanalyzed Hazardous Waste Site Samples
Taken From Closed Containers" on p. X-5).
If samples are transported by any type of government-owned
vehicle, including aircraft, DOT regulations are not applicable.
However, EPA and FIT personnel will use the packaging procedures
described below except that the Bill of Lading with certification
form does not have to be executed (see "Shipping Papers" on p. X-4),
These procedures are designed to enable shipment by entities like Federal
Express,- however, they should not be construed as an endorsement by EPA
of a particular commercial carrier.
B-4
-------
X-2
Irrespective of type sample or container, after completion of the
analyses the contractor will repackage the original sample bottles
in the coolers or containers received, and return them to the
originating Regional office. The packages will be sealed and
shipped under custody procedures as they were received. Each
originating office should make arrangements with the contractor
through the Sample Management Office (VIAR) for the method of
return and payment for shipping charges within 30 days after
sample shipment. Organic extracts from the samples will be
shipped by the analytical contractors to EPA's EMSL/Las Vegas
office for archival storage.
B. PACKAGING. MARKING AND LABELING REQUIREMENTS FOR UNANALYZED HAZARDOUS
WASTE SITE SAMPLES, EXCLUDING CLOSED CONTAINER SAMPLES
1. Collect sample in a 8-ounce* or smaller glass container with
nonmetallic, teflon-lined screw cap. Allow sufficient ullage
(approximately 10% by volume) so container is not liquid full at
130°F. If collecting a solid material, the container plus con-
tents shall not exceed one pound net weight.
2. Attach properly completed Sample Identification Tag (see following
page) sample container.
3. Seal sample container and place in 2-mil-thick (or thicker)
polyethylene bag, one sample per bag. (Tags should be positioned
to enable them to be read through bag.)
4. Place sealed bag inside a metal can with incombustible, absorbent
cushioning material (e.g., vermiculite or earth) to prevent
breakage, one bag per can. Pressure-close the can and use clips,
tape or other positive means to hold the lid securely, tightly
and effectively.
* Large quantities, up to one gallon, taken from wells may be collected
if the flash point of the sample can be determined to be 73°F or higher.
In this case, such should be marked on the outside container (carton,
etc.) but only a single (one gallon or less) bottle may be packed in
an outside container. Ten percent ullage and requirement 2.5,6, and
7 below must also be followed. On the shipping papers state that
"flash point is 73°F or higher".
B-5
-------
X-3
SAMPLE IDENTIFICATION TAG
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
(Appropriate Address)
(reverse)
B-6
-------
5. Mark and label this container as indicated in No. 8 below.
6. Place one or more metal cans (or a single 1-gallon bottle; see
footnote on p. X-2), surrounded with incombustible packaging
material for stability during transport, into a strong outside
container, such as a metal picnic cooler or a fiberboard box.
7. Mark and label the outside container and complete shipping papers
as described below.
8. Marking and Labeling: Use abbreviations only where specified.
Place the following information on a metal can (or bottle),
either hand printed or in label form: laboratory name and address
and "Flammable Liquid, n.o.s", (if not liquid, write "Flammable
Solid, n.o.s.").* Place the following labels on the outside of
the can (or bottle).
"Cargo Aircraft Only"; "Flammable Liquid"; if not
liquid, "Flammable Solid" ("Dangerous When Wet" label
should be used if the solid has not been exposed to
wet environment).
•NOTE: If the cans are placed in an exterior container, both
that container and inside cans must have the same markings and
labels as above. "Laboratory Samples" and "THIS SIDE UP" or
"THIS END UP" should also be marked on the top of the outside
container, and upward pointing arrows should be placed on all
four sides of the exterior container.
Shipping Papers: Use abbreviations only where specified below.
Complete the carrier-provided Bill of Lading and sign the certification
statement (if carrier does not provide, use standard industry form)
with the following information in the order listed. One form may be
used for more than one exterior container.
* Using "Flammable" does not convey the certain knowledge that a sample
is in fact flammable, or how flammable, but is intended to prescribe
the class of packaging in order to comply with DOT regulations; "n.o.s"
means not otherwise specified.
B-7
-------
X-5
"Flammable Liquid, n.o.s." (or "Flammable Solid, n.o.s", as
appropriate); "Cargo Aircraft Only"; "Limited Quantity" or
"Ltd. Qty."; "Laboratory Samples"; "Net Weight
or "Net Volume ." (of hazardous contents), by item,
if more than one metal can is inside an exterior container.
The net weight or net volume must be placed just before or
just after the "Flammable Liquid, n.o.s." or "Flammable Solid,
n.o.s." description.
A Chain-of-Custody Record form [see SECTION VIII] should also be
properly executed, and included in the exterior container.
9. Unless samples are driven to the laboratory, a team member must
accompany shipping container(s) to the transport carrier and, if
required, open outside container(s) for freight inspection.
C. PACKAGING. MARKING AND LABELING REQUIREMENTS FOR UNANALYZED HAZARDOUS
WASTE SITE SAMPLES TAKEN FROM CLOSED CONTAINERS
1. This packaging, marking, labeling and shipping method provides
a worst-case procedure for materials classed as "Poison A"
(49 CFR 173.328). In the absence of reliable data which exludes
the possibility of the presence of "Poison A" chemicals or com-
pounds, these procedures must be followed.
2. These samples may not be transported by Federal Express Corpora
tion (air cargo) or other common carrier aircraft, or by rental,
non-government aircraft. (Samples may be shipped by ground
transport or government aircraft).
3. Collect sample in a polyethlylene or glass container which is of
an outer diameter narrower than the valve hole on a DOT Spec.
3A1800 or 3AA1800 metal cylinder. Fill sample container allowing
sufficient ullage (approximately 10% by volume) so it will not be
liquid-full at 130°F. Seal sample container.
4 Attach properly completed Sample Identification Tag (see p. X-3)
to samole container.
B-8
-------
X-6
5. With a string or flexible wire attached to the neck of the sample
container, lower it into a metal cylinder which has been partial-
ly filled with incombustible, absorbent, loose packaging material
(vermiculite or earth). Allow sufficient cushioning material
between the bottom and sides of the container and the metal
cylinder to prevent breakage. After the cylinder is filled with
cushioning material, drop the ends of the string-or wire into the
cylinder valve hole. Only one sample container may be placed in
a metal cylinder.
6. Replace valve, torque to 250 ft-lb (for 1 inch opening) and
replace valve protector on metal cylinder, using teflon tape.
7. Mark and label cylinder as described below.
8. One or more cylinders may be placed in a strong outside container.
9. Mark and label outside container and complete shipping papers as
descrioed below.
10. Marking and Labeling: Use abbreviations only where specified.
Place the following information on the side of the cylinder, or
on a tag wired to the cylinder valve protector, either hand-
printed or in label form.
"Poisonous Liquid or Gas, n.o.s"; laboratory name and address.*
Place the following label on the cylinder: "Poisonous Gas". (Poisonous
Liquid" label not acceptable here, even if liquid.)
* Using "Poisonous" does not convey the certain knowledge that a sample
is in fact poisonous, or how poisonous, but is intended to prescribe
the cl^3s of packaging in order -s cr^nly with DOT regulations.
B-9
-------
X-7
Note: If the metal cylinders are placed in an outside container,
both the container and cylinders inside must have the same markings
and labels as above. In addition, "Laboratory Sample", and "Inside
Packages Comply With Prescribed Specifications" should be marked on
the top of the outside container. "THIS SIDE UP" marking should be
placed on the outside container and upward pointing arrows on four
sides.
Shipping Papers: Complete the shipper-provided Bill of Lading and
sign the certification statement (if carrier does not provide, use
standard industry form) with the following information in the order
listed. One form may be used for more than one exterior container;
use abbreviations only as specified:
"Poisonous Liquid, n.o.s."; "Limited Quantity" or "Ltd. Qty.";
"Laboratory Samples"; "Net Weight " or "Net Volume
(of hazardous contents), by cylinder, if more than one cylinder
is inside an exterior container. The net weight or net volume
must be placed just before or just after the "Poisonous Liquid,
n.o.s" marking.
A Chain-of-Custody Record form [see SECTION VIII] should also be
properly executed and included in the container, or with the cylinder.
11. Unless samples are driven to the laboratory, a team member will accompany
shipping containers to the transport carrier and, if required, open
outside container(s) for freight inspection.
B-10
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EPA OCCUPATION- HEALTH
"IT IS THE POLICY OF THE ENVIRONMENTAL PROTECTION AGENCY TO ADMINISTER ITS
PROGRAMS IN A MANNER WHICH ASSURES SAFE AND HEALTHFUL WORKING CONDITIONS FOR ALL
EMPLOYEES. EVERY EMPLOYEE IS RESPONSIBLE FOR IDENTIFYING AND NOTIFYING THE
APPROPRIATE SUPERVISOR OF RISKS. HAZARDS. OR UNHEALTHFUL AND UNSAFE CONDITIONS."
. ADMINISTRATOR
EACH EPA EMPLOYEE IS A KEY ELEMENT IN EFFECTIVE IMPLEMENTATION OF THE EPA
OCCUPATIONAL HEALTH AND SAFETY PROGRAM OUR NATIONAL HEALTH AND SAFETY LEGISLATION
RELIES IMPORTANTLY ON EMPLOYEE INVOLVEMENT: NOT ONLY INVOLVEMENT IN FOLLOWING BASIC
RULES AND REGULATIONS. BUT INVOLVEMENT IN DEVELOPING THOSE REGULATIONS; INVOLVEMENT
IN HEALTH AND SAFETY COMMITTEE ACTIVITIES. AND MOST IMPORTANTLY - INVOLVEMENT IN
BRINGING TO MANAGEMENT'S ATTENTION UNSAFE OR UNHEALTHFUL CONDITIONS AT THEIR
WORKSITES.
PLEASE TAKE THE TIME TO PROTECT YOURSELF AND YOUR CO-WORKERS. COMPLETE DETAILS
ON THE EPA OCCUPATIONAL HEALTH AND SAFETY PROGRAM ARE CONTAINED IN THE EPA
OCCUPATIONAL HEALTH AND SAFETY MANUAL. WHICH IS AVAILABLE FROM YOUR SUPERVISOR.
PLEASE CALL FTS-755-4390 IF WE CAN HELP.
ASSISTANT ADMINISTRATOR FOR PLANNING
AND MANAGEMENT
DESIGNATED AGENCY SAFETY AND HEALTH
C-l
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Occupational Health & Safety Letter, September 8, 1980 5
* More than 50 percent of the workers were looking down when struck; about 30 percent were look-
ing straight ahead. Most of the blows were to the top front of the head, usually the forehead, and to a
lesser degree to the top center and to the top side and back of the head.
* Cuts and bruises of the scalp were the most prevalent type of injuries (50 percent) with cuts and
bruises of the forehead next (35 percent), followed by concussions (25 percent) and neck sprain (10 per-
cent).
Of the workers who were wearing hard hats, the survey showed that more than one-half were fur-
nished them by their employer without cost; two-fifths of the workers said their firm required the wearing
._• of hard hats for certain types of work at specific locations; 12 percent said their employers did not require
but encouraged the use of hard hats.
WHIRLPOOL CASE SAID TO ILLUSTRATE WORKER "SELF-HELP" RIGHT:
The recent Supreme Court decision upholdingjhejight of Whirlpool Corp. emplQyees_tojgfuse_dan^
gerous work assignments while at the same time denying them the righTto strike over the tssue^r_gven to
-Bfevenrdts"mTssal iran"empT6yeTdisag~reea^Bou"nHe danger (OCCUPATIONAL HEALTH & SAFETY
jnrr7£^Ma~rcrT8)Tlfustrates the court's endorsement of the concept of worker "self-help" in the Occupa-
tional Safety & Health Act.
That view was expressed by Dr. William J. Curran, Frances Glessner Lee Professor of Legal Medicine
at Harvard School of Public Health, in his commentary in the American Journal of Public Health (Sept.
1980). Dr. Curran is an attorney and industrial hygienist.
In the Whirlpool case, two maintenance workers refused to crawl out on a screen from which a co-
worker had plunged to his death nine days previously. A District court ruled that the Secretary of Labor
had exceeded his authority in 1973 in saying that the law gave workers the right to refuse hazardous duties.
But an appeals court in Cincinnati upheld the workers1 right to do so, and the Supreme Court unanimously
affirmed the appeals court ruling.
In his analysis, Dr. Curran noted that Supreme Court Justice Potter Stewart, who wrote the opinion,
refused to go beyond merely affirming the right of workers to refuse hazardous assignments. He would
not order that the workers be paid for the hours they had refused to work, sending this issue hack to the
lower court for a decision. Whirlpool had sent the two men home for the day and docked them for six
hours pay (about S25 each).
Justice Stewart also warned that the Supreme Court ruling should not be interpreted too broadly,
observing: *X.
x-**"*The employees have no power under the regulations to order their employer to correct the hazardous \
/condition or to clear the dangerous workplace of others. Moreover, any employee who acts in reliance on )
/ the regulations runs the risk of discharge or reprimand in the event a court subsequently finds he acted >/
[ unreasonably or in bad faith." ^
N, Dr. Curran commented:
"In these piecautions, Justice Stewart was apparently recognizing that the legjalaliYgJiLstory of the
Act in 1970 had indicated that Congress was against the use of the Act to provide 'strike_wijlu>ay' to pro-
ie3t.jn_aiTorganjzed manner against dangerous work conditions. Tfie~Supreme Court was attempting to
make it clearJn7rirritiost'insta>ices7f'wouldT?e"up to workers to notify OSHA, and then for OSHA itself
to seckjnj.unctjons" in court to require action by employers to cdrfecTaTIeged hazards?
"We can judge, therefore, that the'Supreme Court was endorsing 'seirnelp* ami immediate preventive
action against imminent danger to life or serious personal injury, but it was not willing to supplant all regu-
lar recourse to order law enforcement and court review in labor-management disputes over working con-
ditions."
W.H.O. REPORT RECOMMENDS NOISE EXPOSURE LIMITS, MORE RESEARCH:
The World Health Organization has published the report of its Task Group on Environmental Health
Criteria for Noise saying that any level above 75 dB(A) for an eight-hour workshift must be considered as
entailing some "predictable" risk which must be taken into account in setting occupational noise standards.
C-2
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Federal Register / Vol. 45. No. 129 / Wednesday. July 2.1980 / Presidential Documents 45333
Presidential Documents
Executive Order 12223 of June 30, 1980
Occupational Safety and Heallh Programs for Federal Em-
ployees
By the authority vested in me as President by the Constitution and statutes of
the United Slates of America, including Section 7902(c) of Title 5 of the United
Slates Code, and in accord with Section 19 of the Occupational Safety and
Health Act of 1970. as amended (29 U.S.C. 668). and in order to provide
sufficient time for the development of adequate implementing instructions
which will govern the new occupational safety and health programs for
Federal cmpldyees. Section 1-704 of Executive Order No. 12196 of February 26.
1980, is hereby amended to read. 'This Order is effective October 1. 1980.".
7 Doe. 80-30100
td 7-1-80; 10:91 am)
Jn| code 319.%-01-M •
THE WHITE HOUSE,
June 30, 1980.
**,
,. >S.
- f
C-3
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Federal Register
Vol. 45. No. 40
Wednesday, February 27. I960
12769
Presidential Documents
Titles—
The President
Executive Order 12196 of February 26, 1980
Occupational Safety and Health Programs for Federal
Employees
By the authority vested in me as President by the Constitution and statutes of
the United States of America, including Section 7902(c) of Title 5 of the United
States Code and in accord with Section 19 of the Occupational Safety and
Health Act of 1970, as amended (29 U.S.C. 668], it is ordered:
1-1. Scope of this Order.
1-101. This order applies to all agencies of the Executive Branch except
military personnel and uniquely military equipment, systems, and operations.
1-102. For the purposes of this order, the term "agency" means an Executive
department, as defined in 5 U.S.C. 101. or any employing unit or authority of
the Federal government, other than those of the judicial and legislative
branches. Since section 19 of the Occupational Safety and Health Act ("the
Act") covers all Federal employees, however, the Secretary of Labor ("the
Secretary") shall cooperate and consult with the heads of agencies in the
legislative and judicial branches of the government to help them adopt safety
and health programs.
1-2. Heads of Agencies.
1-201. The head of each agency shall:
(a) Furnish to employees places and conditions of employment that are free
from recognized hazards that are causing or are likely to cause death or
serious physical harm.
(b) Operate an occupational safety and health program in accordance with the
requirements of this order and basic program elements promulgated by the
Secretary.
(c) Designate an agency official with sufficient authority to represent the
interest and support of the agency head to be responsible for the management
and administration of the agency occupational safety and health program.
(d) Comply with all standards issued under section 6 of the Act. except where
the Secretary approves compliance with alternative standards. When an
agency head determines it necessary to apply a different standard, that
agency head shall, after consultation with appropriate occupational safety and
health committees where established, notify the Secretary and provide justifi-
cation that equivalent or greater protection will be assured by the alternate
standard.
(e) Assure prompt abatement of unsafe or unhealthy working conditions.
Whenever an agency cannot promptly abate such conditions, it -shall develop
an abatement plan setting forth a timetable for abatement and a summary of
interim steps to protect employees. Employees exposed to the conditions shall
be informed of the provisions of the plan. When a hazard cannot be abated
without assistance of the General Services Administration or other Federal
lessor agency, an agency shall act with the lessor agency to secure abatement
(0 Establish procedures to assure that no employee is subject to restraint.
interference, coercion, discrimination or reprisal for filing a report of an unsafe
or unhealthy working condition, or other participation in agency occupational
safety and health program activities.
C-4
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1U770 Fi-dural Register / Vol. 45. No. 40 / Wedncsdjy. February 27. 1900 / Prcsidenliul Document
(g) Assure that periodic inspections of all agency workplaces arc performed
by personnel with equipment and competence to recognize hazards.
(h) Assure response to employee reports of hazardous conditions and require
inspections within twenty-four hours for imminent dangers, three winking
days for potential serious conditions, and twenty working days for other
conditions. Assure the right to anonymity of those making the reports.
(i) Assure that employee representatives accompany inspections of agency
^workplaces.
(j) Operate an occupational safety and health management infonnnlion
system, which shall include the maintenance of such records as the Secretary
may require.
(k) Provide safety and health training for supervisory employees, employees
responsible for conducting occupational safety and health inspection*, all
members of occupational safety and health committees where established.
and other employees.
(1] Submit to the Secretary an annual report on the agency ocqupational safety
and health program that includes information the Secretary prescribes.
1-3. Occupational Scfety and Health Committees.
1-301. Agency heads may establish occupational safely and health commit-
tees. If committees are established, they shall be established at both the
national level and, for agcr.Jes with field or regional offices, other appropriate
levels. The committees shall be composed of representatives of rrmnHgemcnt
and an equal number of nonmanagement employees or their representatives.
Where there are exclusive bargaining representatives for employees ul the
national or other level in an agency, such representatives shall scloet the
appropriate nonmanagement members of the committee.
1-302. The committees shall, except where prohibited by law.
(a) Have access to agency information relevant to their duties, including
information on the nature and hazardousness of substances in agency work-
places.
(b) Monitor performance, including agency inspections, of the agrncy safety
and health programs at the level they are established.
(c) Consult and advise the agency on the operation of the program.
1-303. A Committee may request the Secretary of Labor to conduct an
• evaluation or inspection pursuant to this order if half of a Committee is not
substantially satisfied with an agency's response to a report of hazardous
working conditions.
1-4. Department of Labor.
1-401. The Secretary of Labor shall:
(a] Provide leadership and guidance to the heads of agencies to nssisl them
with their occupational safety and health responsibilities.
(b) Majntain liaison with the Office of Management and Budget in m.itlrrs
relating to this order and coordinate the activities of the Department vcllh
those of other agencies that have* responsibilities or functions related to
Federal employee safety and health, including the Office of Personnel Man-
agement, the Department of Health. Education, and Welfare, and the General
Services Administration.
(c) Issue, subject to the approval of the Director of the Office of Management
and Budget, and in consultation with the Federal Advisory Council on Occu-
pational Safety and Health, a set of basic program elements.. The pre-gram
elements shall help agency heads establish occupational safety and health
committees and operate effective occupational safety and health proxmnis.
and shall provide flexibility to each agency head to implement a program
consistent with its mission, size and organization. Upon request of an fluency
head, and after consultation with the Federal Advisory Council on Oinipa-
C-5
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Federal Register / Vol. 45. No. 40 / Wednesday. February 27, 1980 / Presidential Documents 12771
tional Safety and Health, the Secretary may approve alternate program ele-
ments.
(d) Prescribe recordkeeping and reporting requirements.
(e) Assist agencies by providing training materials, and by conducting training
programs upon request and with reimbursement.
(f) Facilitate the exchange of ideas and information throughout the govern-
ment about occupational safety and health.
(g) Provide technical services to agencies upon request, where the Secretary
deems necessary, and with reimbursement. These services may include stud-
ies of accidents, causes of injury and illness, identification of unsafe and
unhealthful working conditions, and means to abate hazards.
(h) Evaluate the occupational safety and health programs of agencies and
promptly submit reports to the agency heads. The evaluations shall be con-
ducted through such scheduled headquarters or field reviews, studies or
inspections as the Secretary deems necessary, at least annually for the larger
or more hazardous agencies or operations, and as the Secretary deems
appropriate for the smaller or less hazardous agencies.
(i) Conduct unannounced inspections of agency workplaces when the Secre-
tary determines necessary if an agency does not have occupational safety and
health committees; or in response to reports of unsafe or unhealthful working
conditions, upon request of occupational safety and health committees under
Section 1-3; or. in the case of a report of an imminent danger, when such a
committee has not responded to an employee who has alleged to it that the
agency has not adequately responded to a report as required in 1-201 (h).
When the Secretary or his designee performs an inspection and discovers
unsafe or unhealthy conditions, a violation of any provisions of this order, or
any safety or health standards adopted by an agency pursuant to this order, or
any program element approved by the Secretary, he shall promptly issue a
report to the head of the agency and to the appropriate occupational safety
and health committee, if any. The report shall describe the nature of the
findings and may make recommendations for correcting the violation.
(j) Submit to the President each year a summary report of the status of the
occupational safety and health of Federal employees, and, together with
agency responses, evaluations of individual agency progress and problems in
correcting unsafe and unhealthful working conditions, and recommendations
for improving their performance.
(k) Submit to the President unresolved disagreements between the Secretary
and agency heads, with recommendations.
(1) Enter into agreements or other arrangements as necessary or appropriate
with the National Institute for Occupational Safety and Health and delegate to
it the inspection and investigation authority provided under this section.
1-5. The Federal Advisory Council on Occupational Safety and Health.
1-501. The Federal 'Advisory Council on Occupational Safety and Health.
established pursuant to Executive Order No. 11612, is continued. It shall
advise the Secretary in carrying out responsibilities under this order. The
Council shall consist of sixteen members appointed by the Secretary, of whom
eight shall be representatives of Federal agencies and eight shall be repre-
sentatives of labor organizations representing Federal employees. The mem-
bers shall serve three-year terms with the terms of five or six members
expiring each year, provided this Council is renewed every two years in
accordance with the Federal Advisory Committee Act. The members currently
serving- on the Council shall be deemed to be its initial members under this
order and their terms shall expire in accordance with the terms of their
appointment.
1-502. The Secretary, or a designee, shall serve as the Chairman of the
Council, and shall prescribe rules for the conduct of its business.
C-6
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12772 Federal Register / Vol. 45. No. 40 / Wednesday. February 27. 1980 / Presidential Documents
|FR Due dO-KUO
Filrd :-:&-«> 11 39 «m|
B-lling code 3I9S-OI-M
1-503. The Secretary shall make available necessary office space and furniNh
the Council necessary equipment, supplies, and staff services, find nlmll
perform such functions with respect to the Council as may be required by the
Federal Advisory Committee Act. as amended (5 U.S.C. App. 1).
1-6. General Services Administration.
1-601. Within six months of the effective date of this order the Secrclnry of
Labor and the Administrator of the General Services Administration shiill
initiate a study of conflicts that may exist in their standards and other
"requirements affecting Federal employee safety and health, and shall establish
a procedure for resolving conflicting standards for space leased by the
General Services Administration.
1-602. In order to assist the agencies in carrying out their duties under Section
19 of the Act and this order the Administrator shall:
(a) Upon request, require personnel of the General Services Administration to
accompany the Secretary or an agency head on any inspection or investiga-
tion conducted pursuant to this order of a facility subject to the authority of
the General Services Administration.
(b) Assure prompt attention to reports from agencies of unsafe or unhealthy
conditions of facilities subject to the authority of the General Services Admin-
istration: where abatement cannot be promptly effected, submit to the ngrncy
head a timetable for action to correct the conditions: and give priority in the
allocation of resources available to the Administrator for prompt abatement of
the conditions.
(c) Procure and provide safe supplies, devices, and equipment, and establish
and maintain a product safety program for those supplies, devices, equipment
and services furnished to agencies, including the issuance of Material Safety
Data Sheets when hazardous substances are furnished them.
1-7. General Provisions.
1-701. Employees shall be authorized official time to participate in the activi-
ties provided for by this order.
1-702. Nothing in this order shall be construed to impair or alter the powers
and duties of the Secretary or heads of other Federal agencies pursuant to
Section 19 of the Occupational Safety and Health Act of 1970. Chapter 71 of
Title 5 of the United States Code. Sections 7901. 7902. and 7903 of Title 5 of the
United States Code, nor shall it be construed to alter any other provisions of
law or Executive Order providing for collective bargnining agreements and
related procedures, or affect the responsibilities of the Director of Central
Intelligence to protect intelligence sources and methods (50 U.S.C. 40.i(d)|.1)).
1-703. Executive Order No. 11807 of September 28.1974. is revoked.
1-704. This order is effective July 1.1980.
THE WHITE HOUSE.
February 26. 1980.
CPO aas-44i
C-7
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ENVIRONMENTAL
PROTECTION
AGENCY
ORDER
3100.1
December 8,. 1972
PERSONNEL - GENERAL
UNIFORMS. PROTECTIVE CLOTHING. AND PROTECTIVE EQUIPMENT
1. PURPOSE. This Order establishes responsibilities and guidelines
for the issue and use of uniforms, protective clothing, and protective
equipment. This Order implements OMB Circular No. A-30 Revised
August 20, 1966, which remains in effect until the Civil Service
Commission issues superseding instructions pursuant to Executive
Order 11609.
2. REFERENCES.
a. Uniform allowance, 5 U.S.C. 5901 - 5903;
b. Executive Order 11609 (Executive Order 11609 delegates the
authority and responsibilities provided in 5 U.S.C. 5903 to the Civil
Service Commission.); ,
c. Protective clothing and equipment, 5 U.S.C. 7903; and
d. Occupational Safety and Health Act, P.L. 91-596, 29 U.S.C.
651, et. seq.
3. POLICY. Uniforms, protective clothing, and protective equipment
will be prescribed for use, at Government expense, only where the
wearing of such items is necessary because of the nature of the
employee's duties. This includes the safety of personnel and contacts
with the public in an official capacity requiring an employee's
identification on sight.
4. RESPONSIBILITIES.
a. Deputy Assistant Administrator for Administration. The Deputy
Assistant Administrator for Administration is responsible for making
the final determination as to the categories of employees who may be
required to wear uniforms, protective clothing, and protective
equipment, the composition of the items, and the circumstances under
which they shall be worn.
Oist. Directives
Initiated by
PM-212
C-8
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ORDER 3100.1 CHGE 1
March 11, 1977
b. Assistant Administrators, Regional Administrators, Heads of
Staff Offices, Laboratory Directors, and the Executive Officer, Office
of the Administrator. These officials are responsible within their
jurisdiction for submitting recommendations to the Deputy Assistant
Administrator for Administration regarding categories of employees who
should be required to wear uniforms, protective clothing, or protective
equipment. Recommendations for protective items shall be made in con-
junction with respective EPA Safety and Health Officials.
c. Director, Financial Management Division. The Director, Finan-
cial Management Division, is responsible for maintaining accounting
control of allowances paid to employees for uniforms and collection of
refunds of allowance payments due the Government.
d. Director, Contracts Management Division. The Director, Con-
tracts Management Division, is responsible for procuring uniforms,
protective clothing, and protective equipment with Government funds
for issuance to employees. (Requests for such items should be made on
EPA Form 1900-8 in accordance with the EPA Contracts Management Manual.)
e. Director, Facilities and Support Services Division. The Director,
Facilities and Support Services Division, is responsible for the account-
ability and stocking of uniforms, protective clothing, and protective
equipment. These will be issued as custodial items in accordance with
EPPMR 115-27.5008-4.
f. Director. Occupational Safety and Health Office. The Director,
Occupational Safety and Health Office, is responsible for the establish-
ment and management of an agency safety management program for the protec*-
tion of EPA employees, property, and those for whom it has a responsi-
bility.
5. UNIFORMS. The Agency may supply uniforms as provided for in the
Appropriation Act. (See 5 U.S.C. 5901-5902.) Uniforms may be provided
to employees in two ways: (1) direct issuance or (2) payment of uniform
allowances. Officials listed in subparagraph 4b shall determine the
method which is more advantageous to the Government and the employee.
a. Issuance. When uniforms are authorized they may be purchased or
rented. Rental contracts shall not include provisions for cleaning or
laundry service at Government expense. Uniforms may be purchased out-
right, stocked and issued, or an agreement may be entered into with a
local vendor who will issue uniforms and bill the Agency.
PAR 4 2
C-9
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ORDER
3100.1
December 8, 1972
(1) The officials listed in subparagraph 4b shall establish
a schedule of initial issuance and annual replacement (see Attachment
A). The cost of the initial issue or annual replacement, including the
expense of any initial alteration (tailoring), shall not exceed the $125
maximum established by law (5 U.S.C. 5901).
(2) The cost of subsequent alterations or the cost of repair,
laundry, and dry cleaning shall be borne by the employee. Uniforms
being turned-in do not need to be cleaned beforehand.
(3) Uniforms issued remain the property of the Government and
will be turned-in to the local property accountability officer when
no longer needed.
b. Allowance. When allowances are to be paid in lieu of issuance,
an official listed in subparagraph 4b shall establish an initial uniform
requirement (see Attachment A) and annual replacement schedule. He
shall estimate the cost of initially required uniforms and reasonable
replacement needs (including the cost of initial alterations if any)
based on current prices of representatives suppliers and shall specify
a definite allowance for the initial purchase'and annual replacement,"
not to exceed the $125 maximum established by law.
(1) The initial allowance shall be paid at the beginning of
the 'service period when a uniform is required and cannot be reclaimed
once the uniform has been purchased. Uniforms obtained via allowance
become the property of the employee and need not be turned-in.
(2) The replacement allowance for uniforms may be paid (a) in
a lump sum on each anniversary date of the employee's service or (b) in
quarterly or semiannual amounts. The employee may retain one-quarter
of the annual replacement allowance for each quarter or part of a
quarter of a year he remains in service. The balance of the allowance
shall be recovered from him.
(3) Allowances shall not include payment for subsequent
alterations or for repair, washing, or dry cleaning of uniforms/uniform
items. Such costs will be borne by the employee.
FAR 5
C-10
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3100.1
December 8, 1972
6. PROTECTIVE CLOTHING AND EQUIPMENT.
a. Protective clothing and equipment vill be issued to employees
whose duties require them to perform work of an especially dirty or
unusual nature and employees whose duties may be hazardous in nature.
Expenditures from appropriations are available for the procurement
of supplies and materials or equipment and may be made for the
purchase and maintenance of items for the protection of personnel in
the performance of their assigned casks as provided under 5 U.S.C. 7903.
Guidelines may be found in Occupational Safety Health Standards,
29 CFR 1910 and the EPA Safety Manual (to be issued shortly). A recent
decision of the Comptroller General B-174629, 51 Comptroller General
446, in addition to 36 F.R. 10590 which adds section 1910.132
-1910.136 to 29 CFR, provides that protective equipment, including
personal protective equipment for eyes, face, head and extremities,
and protective clothing, shall be provided, used, and maintained
whenever, it is necessary for reasons of hazards or processes of
environment encountered in a manner capable of causing injury or physical
Impairment. Local Safety Officer is also available for advice and
guidance. Attachment B contains a general list of protective items.
b. If the clothing or equipment is solely for the protection of
the employee without resulting benefits to the Government, and such as
the employee might reasonably be expected to furnish as part of the
official equipment of his position, appropriated funds would not be
available for such purpose.
c. Protective clothing and equipaent issued to employees remain
the property of the Government in strict adherence to the usual
requirements of accountability, responsibility, inventorying, and
maintenance.
7. WEARING AND CARE OF UNIFORMS AND PROTECTIVE ITEMS.
a. Uni fo rms.
(1) After an initial period of ninety days, full-tice,
permanent employees in the categories listed in Attachment A, may be
required by an official listed in subparagraph 4b to wear uniforms
while performing their official duties. This may include the time in
transit between their homes and places of employment or between EPA
duty locations. The uniform shall not be worn when an employee is
PAR 6
C-ll
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ORDER
3100.1
December 8, 1972
participating in non-EPA employment or unauthorized activities.
Temporary employees appointed for less than a. vear will not be required
to wear uniforms.
(2) Each employee who has been issued a uniform shall be
responsible for its care and will be expected to maintain it in good
condition. Loss or destruction may result in financial liability if
found Co be caused by carelessness or neglect.
b. Protective Items.
(1) Employees and authorized visitors are required to wear
protective clothing and equipment provided for their protection while
performing hazardous duties.
(2) Each employee who has been issued protective clothing and
equipment shall be responsible for its care, except for disposable
items such as cotton gloves, plastic aorons, etc. Loss or destruction
may result in financial liability if found to be caused by carelessness
or neglect.
8. NOTIFICATION OF PAYMENTS TO BE MADE OR REFUNDS TO BE COLLECTED FOR
UNIFORMS. The^ official listed in subparagraph 4b" "authorizing the
wearing of uniforms shall notify the Financial Management Division of
allowances to be made or refunds to be collected. The notification
shall contain the following information:
a. Employee's name, position title, and organizational unit;
b. Amount and frequency of allowance payments (or the amount to
be collected, when appropriate);
c. Period covered by the payment (or refund) ;
d. Reason for refund; and
e. Certification that the employee has not previously been paid
an allowance for this period.
PAR 7
C-12
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ORDER
3100.1
December 8, 1972
9. STATUS OF BENEFITS AS COMPENSATION. The value of uniforms or
protective items furnished or che amount of the uniform allowance
paid shall not be construed as pay, salary, or compensation within the
meaning of the Civil Service Retirement Act, as amended, or wages within
the meaning of the Social Security Act, as amended, or the Internal
Revenue Code.
10. SUPERSESSION. All existing instructions and directives previously
issued by EPA components which pertain to uniforms, protective clothing,
and protective equipment are superseded.
Howard M. Messner
Deputy Assistant Administrator
for Administration
PAR 9
C-13
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ATTACHMENT A
Standard Articles of Uniforms
Uniforms listed below are approved for the following categories
of personnel. Additional uniforms may be added (subject to monetary
limitations) as well as additional emplovee categories when approved
by the Deputy Assistant Administrator- for Administration.
Item Description
Coat, blouse, all
purpose weight*
Trousers, all purpose
weight
Shirts, Long-sleeve*
Short-sleeve*
Necktie
Cap, visor
Chauffeurs
Color
Dark blue or black
Dark blue or black
White
White
Black
Dark blue, black
If Issued
Initial Quantity
2
3
3
4
2
Craft. Custodial, Maintenance, and Supply Enrolovees
Male Employees
Trousers, Wash and Wear Royal Blue 6
Royal Blue
Shirts, Wash and Wear*
Long-sleeve
Short-sleeve
3
3
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Craft. Custodial, Maintenance, and Supply Employees
If Issued
Item Description
Female Employees
Dress, 1-piece*
Wash and Wear or*
Slacks, Polyester-cotton
blend, with
Blouse*
Color
Royal Blue
Royal Blue
Royal Blue
Initial Quantity
6
6
Coat, blouse all
purpose weight*
Trousers, all purpose
weight
Trousers, light-weight
Cap
Shirt, long or short
sleeve*
Necktie
Overcoat
Raincoat, nylon twill,
plastic coated
Cap Cover, with detachable
cape of same material
as raincoat with plastic
insert
Guards
Dark Blue
Dark Blue
Dark Blue
Dark Blue
Light blue/white
Dark Blue
Dark Blue
Dark Blue
3
3
2
t
A
1
Dark Blue
C-15
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Engineering and Scientific Employees
having Environmental Investigative, and Tesc Functions
or Assigned to Assist in Pollution Emergencies
If Issued
Item Description Color Initial Quantity
Coveralls* Royal Blue 3
or
Trousers, wash and wear Royal Blue 3
Shires, wash and wear* Royal Blue 3
* EPA seal/patch to be affixed to coat, shirt, blouse, or overalls on
left side and employee's name patch to be affixed on right side above
the breast pockets or centered approximately four inches below the
shoulder seams if there are no pockets.
Patches are to be procured by EPA and furnished to employees. EPA
seal/patches remain the property of EPA and must be turned-in to the
local property accountability officer, upon termination of employment.
C-16
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ATTACHMENT B
GENERAL TYPES OF PROTECTIVE ITEMS
Goggles, Safety Glasses, Face Shields ^
Respirators
Hard Hats
Life Belt and Safety Block
Safety-toe Shoes
Electrical Protective Devices
Electrical Hazard Shoes
Radiator Film Badge
Rubber Aprons
Lab Smocks or Coats
Life Jackets
Hearing Protective Devices
Hand and Arm Protective Devices
Rubber Boots
Officials listed in paragraph 4 of the Order will be responsible
for determining when protective items should be issued, replaced, and
maintained, to employees whose duties require the use of protective
items. These items will be provided at Government cost. (See
paragraph 6.)
C-17
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DRAFT #4, Slagle, 5/19/80
ORDER
PROTECTIVE SERVICES - SAFETY
RESPIRATORY PROTECTION
1. PURPOSE. This Order establishes Agencywide policy, responsibilities,
training, and occupational medical monitoring requirements for employees
required to use respiratory protective devices.
2. REFERENCES.
a. Occupational Safety and Health Act, P.L. 91-596, 29 USC 651, et.seq.
b. CFR 1910, Subpa*t I, Subsection 134, General Industry Standards
c. Title 30 CFR Part 11, U.S. Bureau of Mines
d. American National Standards Institute standards Z 88.2-1969 and
K 13.1-1973
e. EPA Order 3100.1, Uniforms, Protective Clothing, and Protective
Equipment.
f. Cumulative Supplement: NIOSH Certified Equipment, June 1977,
or most current issue.
3. BACKGROUND. Inhalation of airborne contaminants can cause serious
harm to employees who work in areas where toxic substances are used or
stored, or where hazardous wastes and spill exist. Whenever possible,
the EPA uses effective local exhaust ventilation to prevent exposure to
airborne contaminants but, when it is not feasible to eliminate the
hazards, such as during field operations, it is necessary to protect
the employee by use of approved respiratory protective devices.
4. POLICY. The EPA shall provide certified respiratory protective devices,
and employees shall use such devices when it is necessary due to the nature
C-1S
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2.
of the employee's working environment. All employees whose duties require
the use of respiratory protective equipment shall be determined physically
able to perform expected duties with the increased resistance to breathing,
and shall not have facial hair which will prevent a tight face seal.
5. RESPONSIBILITY.
a. Assistant Administrators and Regional Administrators. These officials
are responsible within their jurisdiction for determining the categories of
employees required to wear respiratory protective devices and for assuring
that monies are available for proper training programs and purchase of the
respiratory protective devices.
b. Supervisors. Supervisors are responsible for ensuring that: proper
respiratory protective devices are provided, inspected, and maintained for
employees after assessment of the need; employees wear respiratory protective
devices when they are required; employees are properly trained; records are
employee
kept on/training and maintenance of these devices; and respiratory protective
device users are included in the Agency's occupational medical monitoring
program and are medically approved for wearing the devices.
c. Occupational Health and Safety Designees. OHS Designees are responsible
for assuring that approved programs are available for training the users of
»
respiratory protective devices and for assisting supervisors in selecting
the appropriate types and models of approved respiratory protective devices.
d. Employees. Employees are responsible for using and maintaining the
respiratory protective devices issued to them in accordance with the instructions
and training they receive, and for reporting a malfunction of a device to their
supervisor.
e. Personnel Offices and Supervisors. Together, personnel officers and
supervisors shall ensure that descriptions of positions requiring the use of
C-19
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3.
respiratory protectives devices contain the medical fitness and facial hair
requirements, and that job applicants and reassigned employees are instructed
on the importance of these requirements.
f. Director. Office of Occupational Health and Safety. The Director,
Office of Occupational Health and Safety, is responsible for establishing
policy and guidelines for the Agency's respiratory protection program and
for furnishing technical advice and assistance to agency programs.
6. RESPIRATORY HAZARDS. Toxic materials can enter the body in three ways:
(1) by ingestion, through the gastro-intestinal tract, (2) by absorption
through the skin or through cuts and punctures and (3) by inhalation through
the respiratory system. The human respiratory system not only presents the
quickest and most direct avenue of entry but also for many agents is the
critical target. There are two types of hazardous atmospheres:
a. Oxygen-deficient atmospheres - Air normally is 20.9 percent
oxygen by volume. Oxygen concentrations below 16 percent are considered
unsafe for human exposure. Current legislation requires that oxygen per-
centage in a workplace be not less than 19.5 percent. Oxygen-deficient
atmospheres can occur when air is displaced by gases and vapors or where
there are oxidation processes such as fire, rusting, aerobic bacterial
action, etc.
b. Air contaminants - Air contaminants include solid and liquid parti-
culate matter and gaseous material, whether a true gas or vapor, or a com-
bination of these.
7. SITUATIONS REQUIRING RESPIRATORY PROTECTIVE DEVICES. Respiratory protective
devices may be required for three different types of situations:
a. When there is a high potential for a sudden release of
C-20
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4.
toxic/flammable gases or vapors or there has been such a release; e.g.,
connecting anhydrous ammonia tanks or egress from a fire area.
b. When making predetermined entries into environments or locations
where there is strong reason to suspect the presence of toxic airborne
contaminants; e.g., entering hazardous waste or spill sites or manholes.
c. During infrequent but routine operations, primarily in a laboratory,
where engineering controls are not feasible or adequate for the toxicity
of the material involved; e.g., bulk solvent transfers in a remote storage
building.
4
It is important to know the type of situation the respiratory protective
devices are to be used in, because the selection will depend not only on
the situation but also on qualitative and quantitative information from an
assessment of the potential hazard and on the degree of control that can be
exercised over the situation. The amount of information that can be obtained
and the degree of control that can be exercised differs markedly among the
three situations.
8. HAZARD ASSESSMENT AND CONTROL. Prior to donning respiratory protective
devices, the potential or anticipated hazards shall be assessed and engineering
controls shall be used to mitigate the problem.
a. Assessment - The first step to specifying appropriate protection is
proper assessment of the hazard. This assessment involves obtaining qualitative
and quantitative information on contaminants, or making predictions of
potential concentrations in the situation of emergency releases. As a minimum,
the assessment shall consist of determining explosivity of the atmosphere,
radiation levels, and, in the case of confined spaces, the oxygen content of
the atmosphere. First entry for obtaining information shall only be done
using air supplied or SCBA respiratory protective devices.
C-21
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5.
With detailed information, a selection can be made from the various types of
available respiratory protective devices for specific contaminant levels
by following manufacturers instructions or NIOSH/OSHA recommendations.
b. Control - Respiratory protective devices are not control devices;
they are used in the absence of or as adjuncts to inadequate controls.
Whenever possible, even when it is known that respiratory protective devices
will eventually be required for a situation, engineering controls or substi-
tution of less toxic materials should be used to lessen the hazard or to miti-
gate the consequences of an untoward event, and thereby lessen the consequences
t
in the event of failure of the respirator. Engineering controls consist of
good local exhaust ventilation or isolation and/or enclosure of the process.
9. SELECTION. Respiratory protective devices vary in design, application,
and protective capability. The inhalation hazard must be assessed and the
specific use and limitations of available equipment understood to assure proper
selection. There are three classes of respiratory protective devices:
a. Air purifying devices remove contaminants from the inhaled air stream.
They are to be used only in atmospheres containing sufficient oxygen to
sustain life and when contaminant concentrations do not exceed specified limits
for the device. Basic types are mechanical filter respirators, chemical cart-
ridge respirators, chemical cannister respirators, and combinations of chemical
cartridge/cannister and mechanical filter respirators.
b. Atmosphere-supplying
1) Supplied-air devices deliver air through a supply hose connected
to the wearer's facepiece. These devices ahll be used only in atmospheres not
immediately dangerous to life or health. One basic type is the air-line or
hose mask respirator.
C-22
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6.
2) Self-Contained Breathing Apparatus (SCBA) provides a respirable
atmosphere for various periods of time based on the amount of breathing air or
oxygen supplied and the demand of the wearer. Basic types are open circuit,
for which the exhaled air is discharged from the face piece, and closed circuit,
in which the exhaled air is scrubbed for carbon dioxide removal and fortified
in oxygen.
c. Combination respirators are any combination of air-purifying and
stmosphere-suppling respirator, or any combination of supplied-air and self-
<
contained breathing apparatus. These units are bimodal. They are generally
used for emergency entry into and escape from atmospheres immediately dangerous
to life.
10. LIMITATIONS. The following limitations must be understood by all employees
required to wear respiratory protective devices.
a. Chemical cartridge or chemical cannister respirators shall not be worn
to protect against gases or vapors which have no properties to warn the user of
"break-through," i.e., the contaminant penetrating the adsorptive media.
(This caveat is not required for dust respirators; these will plug instead of
saturating to restrict breathing.)
b. Some gases and vapors can be absorbed through the skin (e.g.,
hydrogen cyanide) and others will attack tissue surfaces (e.g., strong acid
gases). In many cases protective clothing will be needed in addition to
respiratory protective devices.
c. Persons with perforated ear drums shall not wear respirators.
•.
d. Contact lens shall not be permitted while wearing a respirator.
e. Any facial hair lying between the sealing surface of a respirator
:'
facepiece and the wearer's skin that will prevent a good seal shall not be
allowed. This includes stubble, a moustache, sideburns, or a beard that extends
C-23
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7.
outward between the face and the sealing surface of the respirator.
f. Spectacle temple bars or straps that pass between the sealing surface
of a facepiece and the wearer's face prevent a good seal and shall not be
permitted with a full-face respiratory protective device.
g. Specific warning signs which require immediate return to fresh air are:
1) Uncomfortable heat in the inhaled air stream coming from the
adsorption material in chemical cartridge or chemical cannister respirators.
This heat of adsorption indicates a high concentration of contaminant and the
potential for immediate "break-through."
2) Indications of "break-through" or a poor faceseal as determined
from the warning properties of the contaminant.
3) Any signs of physiological stress resulting from the increased
physical effort required to wear a respirator or from the increased resistance
to breathing (e.g., light headedness, dizziness, heat stress.)
11. TRAINING. For safe use of respiratory protective devices, it is
essential that employees be instructed in their selection, use, fit, and
maintenance. Training shall include the following:
a. Instructions in the nature of the hazard, whether acute, chronic, or
both, and an honest appraisal of what may happen if the proper device is not
used.
b. Explanation of why more positive control is not immediately feasible.
This shall include recognition that every reasonable effort is being made
to reduce or eliminate the need for respiratory protection.
c. A discussion of why this is the proper type of unit for the particular
purpose.
d. A discussion of the device's capabilities and limitations.
e. Instruction and training in actual use.
f. Other special training as needed.
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8.
A minimum of six hours of training shall be provided initially, and 2-4 hours
annually. This can be a part of occupational health and safety training for
other reasons, and it can count as credit for both programs. Records of training
and fit testing shall be maintained by the supervisor. Employees shall be
issued a pocket card identifying the types of respiratory protective devices
they can safely wear.
12. INSPECTION. MAINTENANCE. STORAGE. AND REPAIR. Proper inspection, maintenance,
storage, and repair of respiratory protective devices are mandatory to insure a
successful respiratory protection program.
4
a. Inspection. All equipment must be inspected before and after each use.
Equipment used only for emergencies shall be Inspected at least monthly. A
record shall be kept by date and results of all inspections.
b. Maintenance. All respiratory protective devices shall be cleaned and
disinfected after each use. Maintenance includes replacement of disposable
elements such as filters and cartridges whenever necessary.
c. Repair. Replacement of other than disposable parts and any repair shall
be done only by personnel with adequate training and test equipment to insure
the equipment is functioning properly after the work is accomplished. Only
parts supplied by the manufacturer for the product being repaired shall be used.
d. Storage. Respirators shall be stored in atmospheres that will protect
them from dust, sunlight, extreme heat or cold and from sources of damaging
chemicals.
13. OCCUPATIONAL MEDICAL MONITORING. Employees shall not be assigned to tasks
requiring the use of respiratory protective devices unless they have had a
medical evaluation and it has been determined that they are physically capable
of performing the work while wearing the devices. An annual medical review
should be scheduled for these employees.
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9.
14. SAVINGS PROVISION. Changes in the Act or standards and regulations
which occur after the effective date of this Order will automatically come
under the purview of this Order on the effective date of the change.
C-26
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DRAFT #4, Slagle, 9/12/80
ORDER
Protective Services - Safety
Health and Safety Requirements for Employees Engaged
in Field Activities
1. PURPOSE. This Order establishes policy, responsibilities, and mandatory
requirements for occupational health and safety training/ certification, and
occupational medical monitoring of Agency employees engaged in field activities.
2. DEFINITIONS.
a. The term "field activities" as used in this Order means EPA program
activities that are conducted by EPA employees outside of EPA administered
facilities involving environmental, pesticides, water and wastewater treatment
plants, hazardous materials spills and waste sites investigations, inspections,
and sampling.
b. The term "health and safety training" means scheduled, formal or
informal training courses, approved, sponsored and conducted by EPA or its
contracted agents which are designed to develop, improve and upgrade the health
and safety knowledge of EPA employees involved in field activities.
c. The term "occupational medical monitoring" means surveillance over the
health status of employees by means of periodic medical examinations or screening
in accordance with the Agency's Occupational Medical Monitoring guidelines.
d. The term "certification" as used in this order means' that the employee
has fulfilled the minimum training requirements specified for the level of
training/certification received.
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2.
3. REFERENCES.
a. 29 CFR 1910, Parts 16, 94, 96, 106, 109, 111, 134, 151, Occupational
Health and Safety Standards.
b. Executive Order 12196, Section 1-201, Sec. (k), Occupational Health
and Safety Programs for Federal Employees.
c. 29 CFR 1960.20(1), Occupational Safety and Health for the Federal
Employee
d. EPA Occupational Health and Safety Manual, Chapter 7(1).
e. EPA Training and Development Manual, Chapter 3, Par. 7(b).
f. Occupational Health and Safety Act of 1971, P.L. 91-596, Sec. 6.
g. EPA Order on Respiratory Protection (Proposed).
h. 49 CFR, Parts 100-177, Transportation of Hazardous Materials.
i. EPA Order 1000.18, Transportation of Hazardous Materials.
j. EPA Order 3100.1, Uniforms, Protective Clothing, and Protective
Equipment.
4. BACKGROUND. Field activities are a critical part of most EPA programs.
These activities range from routine environmental reconnaisance sampling,
inspections, and monitoring, through entering and working in environments with
known and suspected hazards. Since protection cannot be built into the
field working environment, the protection of personnel involved in field
activities takes on the forms of training employees in the application of
safe operational procedures, and the proper use of appropriate personal
protective clothing and equipment.
5. APPLICABILITY. This Order applies to all EPA organizational units which
have employees engaged in field activities.
6. POLICY. It is the policy of the Environmental Protection Agency to carry
out its field activities in a manner that assures the protection of its
employees to the greatest extent feasible.
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3.
7. RESPONSIBILITIES.
a. Assistant Administrators. Regional Administrators. Deputy Assistant
Administrators. Laboratory Directors, and Division Directors. These
officials are responsible within their jurisdictions for implementing the pro-
visions of this Order and for budgeting the necessary funds for employee
training/certification and occupational medical monitoring programs.
b. Supervisors. Supervisors are responsible for complying with the
requirements of this Order for employee training/certification and occupational
medical monitoring programs. They will identify those employees who require
training/certification, and occupational medical monitoring to comply with the
provisions of this Order.
c. Employees. Employees are responsible for making known upon request from
their supervisors, the extent of their individual occupational health and
and
safety training,/the history of their occupational medical monitoring parti-
cipation. Employees should notify their supervisor of any hazardous work
situation and make suggestions for corrective measures, and for applying the
knowledge, skills, and techniques acquired through training/certification in a
manner that will help assure their health and safety and that of fellow workers.
d. Occupational Health and Safety Designees. The Occupational Health and
Safety Designees are responsible for identifying program areas that require
training/certification and occupational medical monitoring; recommending or
providing training/certification resources to meet the requirements of this
Order; and maintaining records of persons receiving training/certification.
e. Office of Occupational Health and Safety. The Director, Office of
Occupational Health and Safety is responsible for establishing policy and
requirements for adequate training/certification programs for field activities,
developing and maintaining an occupational medical monitoring program
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4.
approving health and safety training/certification programs for employees
involved in field activities, and for evaluating the results of these training/
certification programs.
8. OBJECTIVES.
a. Training/Certification. The objectives of the health and safety training/
certification programs for employees involved in field activities are:
1) To assure that EPA employees are aware of the nature of the potential
hazards that may be encountered during the performance of field activities;
2) To provide the knowledge and skills necessary to perform the work
with the lowest feasible risk to personal health and safety;
3) To assure that Agency program goals can be accomplished in as safe
and healthful manner as feasible.
b. Occupational Medical Monitoring. The objectives of the occupational
Medical Monitoring program are:
1) To detect any adverse effects of occupational exposure on the
employees health.
2) Initiate prompt corrective actions when indicated.
9. TRAINING/CERTIFICATION REQUIREMENTS. Employees shall not be permitted to
engage in routine field activities until they have been trained/certified to a
level commensurate with the degree of anticipated hazards.
a. Basic Level; All employees shall be provided a minimum of 24 hours of
health and safety training prior to their becoming involved in normal, routine
field activities. The training shall include but not be limited to classroom
instruction in all the following subject areas:
1) Employee Rights and Responsibilities
2) Nature of Anticipated Hazards
3) Emergency Help and Self-Rescue
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5.
4) Vehicles - Mandatory Rules and Regulations
5) Safe Use of Field Equipment
6) Use, Handling, Storage, and Transportation of Hazardous Materials
7) Personal Protective Equipment and Clothing
8) Safe Sampling Techniques
In addition to classroom instruction, the employee shall accompany an employee
experienced in field activities and perform actual field tasks for a minimum
of three days within a period of one month after classroom instruction.
Employees satisfactorily completing these requirements will receive certification
at the basic level of training from the Occupational Health and Safety Designee.
b. Intermediate Level. All inexperienced employees who are to work with
experienced employees in hazardous waste and spill site investigations shall
be provided a minimum of 8 hours of additional health and safety training. This
(in addition to the Basic Level requirements)
training shall include Jut not be limited to the following subject matter:
9) Site surveillance/observation/plan development
10) Use and decontamination of totally enclosed protective clothing and
equipment
11) Field test equipment for radioactivity, explosivity, and others.
In addition to classroom instruction, the employee shall accompany another
employee experienced in hazardous waste and spill site investigation!-, and/or
cleanup operations and perform actual field tasks for a minimum of three days
within a period of three months after classroom instruction. The employee
should also be able to provide on-the-job training and instructions to in-
experienced employees during normal, routine field activities. Employees
satisfactorily completing these requirements will be certified at the Inter-
mediate Level by the Occupational Health and Safety Designee.
c. Advanced Level. All employees who conduct and/or manage hazardous
waste and spill site monitoring, sampling, investigations, and cleanup operations
shall be provided a minimum of 8 hours additional health and safety training.
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6.
The classroom training shall include but not be limited to (in addition to the
Basic and Intermediate Level requirements), instruction in the following subject
areas:
12) Management of restrue ted and safe zones
13) Rules of Handling the Press and VIP's
14) Safe Use of Specialized Sampling Equipment
In addition to classroom instruction, the employee shall accompany another
employee with experience in managing hazardous waste and spill site investi-
gations and/or cleanup operations and perform actual field tasks for a minimum
of three days within a three month period after receiving classroom -instruction.
After satisfactorily completing these requirements, employees will receive
Advanced Level certification from the Occupational Health and Safety Designee.
d. General.
1) An employee may receive certification at the next higher level by
completing only the additional training requirements if certified at the next
lower level within the previous 9-month period.
2) The Director, Office of Occupational Health and Safety, may
certify employees based on an evaluation of previous training, education, and
experience. Recommendations for this type certification should be made to the
Director by the local Occupational Health and Safety Designee.
10. FREQUENCY OF TRAINING. Employees at the Basic, Intermediate, and
Advanced Level shall complete a minimum of 8 hours of classroom instruction
annually to maintain their certification. In addition to the classroom intru-
ction, employees shall have demonstrated by performing actual field tasks
that they have sufficient practical experience to perform their assigned duties.
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7.
11. RECORD OF TRAINING.
a. A record of the level of training/certification shall be maintained
in the employee's official personnel file.
b. The Occupational Health and Safety Designee shall maintain a roster
of employee training/certification so that a schedule of annual training
can be established.
c. The Occupational Health and Safety Designee shall issue a certificate
to the employee showing the level of training/certification.
12. OCCUPATIONAL MEDICAL MONITORING REQUIREMENTS. All employees routinely
engaged in field activities which present the probability of exposure to
hazardous or toxic substances or require the use of respiratory protective
equipment shall be included in the Agency's Occupational Medical Monitoring
Program. Employees should not be permitted to engage in field activities
unless they have undergone a baseline medical examination as defined in the
Agency's Occupational Medical Monitoring Guidelines showing physical fitness
and providing a base to measure any adverse effects their activities may have
on these individuals.
13. SAVINGS PROVISION. Changes in the Act, Executive Order, or EPA and
OSHA standards and guidelines which occur after the effective date of this
Order will automatically come under the purview of this Order on the effective
date of the change.
Full implementation of this Order shall be within 6 months of its effective
date.
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ENVIRONMENTAL PROTECTION AGENCY
FY 1980-31
MEDICAL MONITORING PROGRAM GUIDELINES
The following information and attachments are intended for use by
Agency components that conduct occupational medical monitoring programs.
These guidelines outline the minimum essential elements for such a program
and should not be regarded as being comprehensive. Some Agency workolaces
may have potential exposure hazards that will require medical monitoring
procedures not covered in this basic description; however, it is essential
chat each local program include at least the elements described herein. As
more Federal regulations and recommendations appear for emoloyees
potentially exposed to toxic chemical and ohysical agents, program uodates
and modifications are to be expected. When such changes occur, they will
be presented by the Agency's Office of Occupational Health ana Safety.
Who should oe included in a medical monitoring program?
This medical monitoring program is designed basically for laboratory
and field workers whose work regularly poses the possibility of exoosure to
toxic materials. In addition, the program should meet the needs of other
diverse groups of emoloyees whose 'jobs require preplacement and/or
periodic health assessment. Generally, aaministrative, fiscal,
secretarial, statistical, and other suoport personnel who are exoosed to
toxic materials indirectly, infrequently, or inconsequentially should not
be included. Representative job categories that should have meaical
monitoring made available on exposure include chemists, microbiologjsts,
toxicologists, physical scientists, and the technical oersonnel who
suoport these disciplines. Employees who collect various types of
polluted samples should be included if the sampling requires exposure to
pollutants significantly in excess of ambient concentrations. Maintenance
personnel normally should be included, since they are occasionally exposed
to toxicants at unexpectedly high concentrations, as should those who
perform custodial services in actual laboratories or in areas where toxic
materials are stored. Part-time and temporary emoloyees should be
included if their jobs are similar to the categories previously mentioned.
The decision as to which emoloyees are nominated should rest .-nth the
program director or suoervisor most familiar with the possible hazards
involved.
Is the program voluntary?
Employees whose jobs justify inclusion in the program have the option
to participate or not, with the exception of those few persons whose jobs
require such examinations as a condition of employment. Future Agency
policy may expand the numoer of job categories that will require
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preplacement and periodic health assessment. -Experience indicates that
about 85% of nominated employees will elect to participate in the program.
A written record of those deferring or declining particioation shoulo be
kept to protect the Agency against accusations chat such a program was not
made available. A simple notation to the effect that an individual has
declined is sufficient. Declining employees should be reinvited to
participate regularly if they remain eligible for the program. Sach
facility should review its entire roster periodically to assure the
inclusion of all "at-risk" personnel.
Who will gay for the program?
Medical monitoring is the responsioility of the employer, and the
Agency must bear the entire cost. When a preexisting or non-job-related
condition is detected in the course of a health monitoring examination, the
individual is to be referred to his/her private physician for further
evaluation, treatment, and followup. The individual must bear these addi-
tional costs. When a condition appears to have resulted from employment,
the employee may seek compensation and the payment or recovery of medical
expenses from the Department of Labor, Office of Workers' Comoensation
Programs.
Consultation is available from the Agency Office of Occuoational
Health and Safety when job-related illness is detected or suspected.
How are physician services obtained?
The fact that most EPA operations are able to use purchase orders to
obtain local physician services simplifies this orocurement. Ideally, the
physician chosen should be board certified in occupational medicine; how-
ever, this is unrealistic because the number of such physicians available
is quite small and most serve as full-time program directors for large
industrial corporations.
For the purpose of this program, a local physician m a practice of
internal medicine or in general practice will usually suffice. A physician
who belongs to the American Occupational Medical Association or a local
occupational health society is preferred; the names of these physicians
may be obtained from the American Occupational Medical Association, 150
North Wacker Drive, Chicago, Illinois 60606 (312/732-2166).
The important requirements are that the physician is caoable, is
equipped to conduct a thorough physical examination, and has a high
interest in the program. A local ohysician is in the best position to
provide a continuity of service over the years and to handle referrals when
non-job-related conditions are detected. On occasion, local U.S. P'jblic
Health Service facilities are willing to perform this service. The use of
a Federal facility generally offers an economic advantage and is
encouraged whenever such services are offered.
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How ars related laboratory services ootained?
These services must be performed by a clinical laooratory chat is
competent, is licensed, participates in a proficiency testing progr2m(s),
and maintains rigorous quality control. It should be licensed by the
Feaeral government. A numoer of large interstate laboratories provide
satisfactory service, rapid turnaround, and reasonable fees. These labo-
ratories usually provide their own collection and mailing containers at no
extra cost, and most have government "rates" that are competitive. Since
these are large laboratories, they can provide, at a reasonable additional
cost, special tests that may be essential for those emoloyees wno have been
exposed to specified chemicals. Many hosoital and local laooratones can
supply only a portion of the laooratory tests that may be needed; also, in
performing more complex tests, these hospitals and laooratones may be
less reliable than the large interstate laboratories that routinely carry
out such procedures.
The local examining physician will be responsible for requesting, in-
terpreting, and evaluating laboratory reports. A laboratory of the ohysi-
cian's choice is preferable, provided that it meets quality ana cost rea-
sonability standards.
How often should examinations be offered?
Ideally, the periodicity and content of monitoring examinations should
be determined by an evaluation of the occupational risk; i.e., the proba-
bility of adverse effects of exoosure. When the orogram was initiated, it
was recommended that an annual examination suffice for most participants.
Until better criteria are developed from a study of EPA ooerations ana
monitoring findings, an annual evaluation is still recommenced.
The first, or baseline, examination offered to each oarticipant should
consist of a complete medical examination. This examination will oe useful
in providing reference information for the evaluation of subsequent
periodic examination findings. Subsequent monitoring examinations, for
most EPA operations, can be of more limited scope.
Is the program a substitute for "general checkups"7
Participants should be advised that this program of medical monitoring
examinations is not a direct substitute for "general cneckups" or other
periodic examinations designed to monitor or promote general health. The
occupational medical monitoring program is designed to screen for eviaence
of adverse effects of occuoational exposure, particularly axoosure to
toxic substances. The examinations ao not provide a comprehensive health
evaluation; neither do they oroviae significant screening for many of the
common nonoccupational chronic disorders.
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Meaical -examination content recommencations
Current rY 1930-31 recommendations are to continue to provide a
comprehensive baseline examination for new particioants in tne program and
to provide periodic screening examinations for other participants.
Periodic monitoring should include, as a minimum, an interim medical
and occuoational history review, a screening ohysical examination, basic
blood and urine laboratory tests (as discussed below), and a physician's
evaluation. The monitoring examination should be suoolemented by proce-
dures ano special tests only as warranted ay exposure to specific signifi-
cant hazards or stresses.
What are the basic laboratory tests to be included for each participant?
Each individual should receive a oasic oanel of blood counts and
chemistries to evaluate blood-forming, 'oaney, liver, and ando-
crine/metabolic function. The following blood tasts are considered co be
the minimum desirable:
• White blood cell count and differential call count
t Hemoglobin and/or hematocrit
• Albumin, globulin, and total protein
• Total bill rub in
• Serum glutamic oxalacetic transaminase (SGOT)
0 Lactic dehydrogenase (LDH)
• Alkaline phosphatase
• Calcium
• Phosphorus
• Uric acid
• Creatinine
• Urea nitrogen
• Cholesterol
• Glucose
Each employee should have a routine urinalysis that consists of the
following:
• Specific gravity
• pH
0 Microscopic examination
• Protein
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• Acetone
• Glucose
What other fasts are recommended?
X-Say
A baseline chest X-ray should be a standard i*- x 17-inch P-A
(posterior-anterior) exposure. The lateral view is not necessary for
routine screening purposes. The X-ray may be obtained from tne examining
physician, a local radiologist, or a local hospital. The film should be
read or reviewed by a board-certified radiologist or other comoetent
medical specialist. Subsequent periodic chest X-Vays should be oe<"formea
only when clinically indicated and not as a routine measure.
electrocardiogram
An electrocardiogram should be included in the baseline examination.
It ordinarily should be of the standard 12-lead resting type and inter-
preted by an internist or caraiologist. Subsequent perioaic electrocar-
diograms should be ootained only when recommendea oy che examining
physician, and not as a routine measure.
Pulmonary function
Pulmonary function testing is aesirable as a part of the baseline
examination. It may be indicated periodically for employees at respira-
tory system risk, such as those with significant exposure to :oxic austs
and irritants. As a minimum, it should consist of simple tests of lung
ventilation: forced expiratory volume in 1 secona (FEV.) and forced vital
capacity (FVC). -
Other special tests
Workers who are significantly exoosed to certain designated materials
may require additional special procedures in addition co the basic panel of
tests. These tests are listed in Table 1 and are obtainable at an addi-
tional cost. The physician should determine who is in need of saecial
tests after reviewing the history forms and after consulting with suoer-
visors and/or medical monitoring coordinators and health and safety
aesignees. Provision should be made for reoeating tests when necessary.
Consultative assistance is availaole from the Office of Occuoational
Health and Safety regarding special tests.
Tests drooped from 1977 guidelines
The following tests, recommended in the 1977 guidelines, are no longer
recommended as routine tests for occupational monitoring, either baseline
or periodic:
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• VDRL or other ssrologic cast for syphilis
0 Serum specimen for freezing and storage
• Female cervical cytology test (Pao test)
• Serum glutamic oyruvic cransarmnase (SGPT)
t Serum triglycerides
• Serum sodium, chloride, and potassium
• Care 1no-embryonic antigen
What medical monitoring records and forms are required?
Forms
To provide uniformity of data collection and to expedite analysis, it
would be desirable to have an SPA standard form(s) for use in medical
monitoring examinations. However desirable, this goal does -not appear
possible in the immediate future. Private medical examiners use a variety
of forms and automated systems to obtain and record medical information.
The scope and quality of information-gathering and recording systems uses
should be at least equal to that of the forms discussed oelow.
Participants should be advised that the medical monitoring examina-
tions are voluntary and that they are not required to answer any specific
questions.
Medical history
The medical history will normally be obtained by having each partici-
pant fill out a medical and occupational history form before seeing a
physician (Attacnment L provides an £PA-develooed samole). Usually, this
is done several days preceding the date of the physical examination. All
programs are urged to adopt this form, or ics equivalent, since most
"standard" medical history forms are coo sketchy, especially in terms of
occupational history and exposure. The occupational exposure information
may be reviewed by occuoational health and safety personnel to assist tne
examining physician in performing an examination of appropriate scooe.
When completed, the form should be turned over to the physician or physi-
cian's designee in a manner safeguarding privacy and confidentiality of
the participant.
Physical examination form
The physical examination should be recorded on a standard form such as
Government Standard Form 38 (Attachment 2). This form is availaole in
quantity and is used by nearly all governmental health providers. Although
the local physician may have similar forms chat he or she uses routinely,
all workplaces are urged to adopt S.F. 38 to acmeve Agencywide uniform-
ity. Sections 50-53, 56-59, and 70-72 are not normally carried out as oart
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of monitoring physical examinations ana .nay .be emitted. Aucliometry,
item 71, is indicated for all emoloyees regularly axoosed to hi ah ncise
levels; i.e., over 35 aS.
Privacy Act
Since the Health Monitoring Program will establish a set of records on
incnvidual citizens, it must meet the requirements of tne Privacy Act of
1974 (P.L. 93-579). Each participant is reauired to read and sign a copy
of the Privacy Statement (Attachment 3), whicn explains the authority for
collecting the information, uses to be made of the information, rules of
confidentiality, ana aisclosurs information. T'ne original of this state-
ment should be made oart of the employee's medical monitoring records, and
a copy should oe oroviaed to the emoloyee. Written reauests for release of
this information may be made by the emoloyee, and such requests "should also
be made a permanent oart of the record, each Agency orogram area will oe
responsible for seeing that the provisions of this Act are met.
Required reports and actions
The examining physician must communicate all examination finaings and
ooinions to the examinee. In aadition, the examining physician should
furnish the Agency a written report on any examinee with findings that, in
the physician's ooinion, indicate an adverse effect of occupational expo-
sure. This report should detail the occuoational ly related findings and
the basis for the physician's opinion. The ohysician should be instructed,
however, not to reveal any specific finaings or diagnoses unrelated to
occuoational axoosure in the report to the Agency.
On receipt of such a report, the local meaical monitoring coordinator
shall promptly send a copy to:
Manager of Meaical Monitoring
Office of Occuoational Health and Safety (PM-273)
401 M Street, S.W.
Washington, O.C. 20^60
Local management, safety officers, and suoervisors should take oromot
investigative and remedial action after being alerted to a possible occu-
pational health and safety problem by a medical report. Technical assist-
ance is available from the Office of Occupational Health and Safety.
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TABLE 1
SPECIAL TESTS
An annual mom toring examination will be satisfactory for most
workers. Additional saecial tests may be indicated for those workers who
have significant exoosures to chemical or physical agents, in accordance
with OSHA or other aoohcable standards.
Substance
Special Tests
Acrylonitrile
Inorganic arsenic
Asbestos
3enzene
Coke oven emissions
Cotton dust
Oichlorooromopropane
i
Inorganic lead
Noise (above 35 dB)
Organophosphate pesticides
Chest X-ray, fecal occult blood, orocto-
sigmoidoscopy
Chest X-ray, sputum cytology
Chest X-ray, pulmonary function
Reticulocyte count
Chest X-ray, oulmonary function, sputum
cytology, urinary seaiment cytology
Pulmonary function
Sperm count (male), serum follicle
stimulating hormone, serum lucemizing
hormone, serum total estrogen (female)
Slood lead, perioheral olooa smear
morphology, blood zinc orotoporohyrin
Audiometry
Slood cholinesterase
Primate handlers should have an annual HB Ag (heoatitis 3 surface
antigen) test and a tuberculin test (unless known to be tuoerculin posi-
tive).
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Attachment 3
environmental Protection Agency
Privacy Statement
Occupational Medical Monitoring Program Records
A. Authority under which the information is reauested:
£xecutive Order 11307 which requires that the Occupational Safety
and Health Act, P.I. 91-596 with its standards, Code of Federal Regula-
tions, Title 29, Chapter XVII, Part 1910 of the Code of Federal Regu-
lations be applied to Federal emoloyees; Code of Federal Regulations
Title 29, Chapter XVII, Part 1960, Federal Workers Safety ana Health.
Other authority: FPM Chaotar 339 (Meaical examination for appoint-
ment); FPM Chapter 752 (Adverse actions); FPM Chapter 810 (Claims for
disability under worker's compensation); FPM Chapter 331 (Disability
retirement); and FPM Chapter 339.
3. Uses to be made of the information:
The purpose of requesting personal information is to enable the
Agency Occupational Medical Officer, examining physician, and otner
health personnel to provide an occupational health orogram directed
primarily to protecting you and your fellow workers from potential
hazards in your work environment and the reduction of these hazards.
The records will document your health status, cnanges in physical
conditions through the years, and provide an account of any care
rendered, advice "given, and consultations that are recommenced.
This information may be used to determine unusual susceptibility
to illness or injury from exposures in your work environment, to deter-
mine suitability for assignments, to permit medical surveillance for
potential harmful effects of toxicants used in your work, and to oro-
vide medical treatment ana advice. It may be used to plan, implement
and evaluate occupational and preventive health programs, conduct eoi-
demiologic research, teach, and compile statistical data. It may be
used to adjudicate claims ana determine benefits, and reaort medical
conditions required by law to Federal, State ana local agencies. It
may be used for other lawful purposes including litigation.
C. Rules of confidentiality:
The information contained in these files will be open to review
and usage by the Agency Medical Office, the examining pnysician and/or
duly autnorized assistants except as noted below.
Information to be utilized for research, teaching, statistical,
or epidemiologic purposes will have all identifying data oonterataa
and made unrecognizaole as to the identity of an individual.
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Attachment 3
The records will be in the local custody of tne examining onysi-
cian and will oe maintained in a locxeo filing caoinet. Access will be
limited to the custodian ana/or auly aooointed health assistants. A
copy of these records may be maintained in cne Agency Occuoational
Medical Office. These will be maintained in locked caoinets with
access limited to the Director or to authorized assistants.
Upon death, retirement, resignation, or other termination of
Government service, the records will be forwarded to the US Office of
Personnel Management or Puolic Health Service Commissioned Officer De-
partment of Personnel for inclusion with the Official Personnel
Records and the custoay thereof will fall to the custodian of such
records.
Medical information about an applicant, employee or annuitant
shall not be made availaole to the puolic.
Medical information about an aoolicant, emoloyee or annuitant may
be disclosed to the aoplicant, emoloyee, or annuitant, or a reore-
sentative designated in writing, except that medical information con-
cerning a mental or other condition of such a nature that a oruaent
physician would hesitate to inform a person suffering from it of its
exact nature and probable outcome may be disclosed only to a licensed
physician designated in writing for that purpose by the incividual or
his designated representative. The determination on whether informa-
tion falls into the purview above will rest with the custodian.
The applicant, employee, or annuitant may request release of
records or information, and/or designate a rearesentative, in a letter
directed to the custodian of the records. The request will give the
full name of the representative and indicate the records co be re-
leased.
0. Disclosure of information by participants:
Disclosure of the required information is entirely voluntary ex-
cept for employees for whom disclosure is a condition of employment or
where a medical certificate is required before assignment to positions
which involve: (a) operation of motor vehicles; (b) exceotional
stress; (c) food handling; (d) direct physical contact with people -
for example, nurses and physical therapists; (e) wor'< above grouna
level or around hazardous power-driven machinery; or, (f) strenuous
exertion or hazardous duty or physical requirements more arduous than
those described on SF-177 - for examole, aircraft pilots ana flight
crew memoers, underwater divers, and firefignters. Pilots, flight
crew members, and divers will not be certified or recertified if the
information is not furnished. Other persons may decline to partici-
pate in or withdraw from the Occuoational Medical Monitoring Program
at any time without prejudice to themselves or to their jobs. If cue
information is not furnished, however, a complete occupational health
C-43
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Attachment 3
evaluation cannot be done ana will not oe attemotaa; optimum advice and
care may therefore not be oossible. Delay in certain benefits may
result from the lack of available information about an employee.
E. Certification:
I have received a copy of this statement which I may retain and i
understana that I may receive additional copies of this statement upon
request. I understand that a copy of this statement will oe placed in
my health records as evidence of this notificacion.
(lyped or printed name)
(Signature) (data)
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ENVIRONMENTAL PROTECTION AGENCY
CHAPTER 9 - HAZARDOUS WASTE SITE INVESTIGATIONS
AND ENVIRONMENTAL SPILL RESPONSES
TABLE OF CONTENTS
MANUAL
OCCUPATIONAL
HEALTH AND SAFETY
PARAGRAPH
TITLES
Policy and Responsibilities
Health and Safety Program Requirements
Work Practices
PARAGRAPH
NUMBERS
1
2
3
APPENDICES
APPENDIX
NUMBER
Safety Plan 1
Periodic Health Assessment 2
Personal Protection Level Determinations 3
Packaging, Marking, Label ing,, and Shipping of Hazardous Waste
Site/Environmental Spill Samples 4
Sampl ing Procedures 5
Decontamination Procedures 6
TNI )
ORIGINATOR:
DRAFT 3
PM-273
August 29, 1980
CHAP 9
David Weitzman, Manager
Industrial Hygiene Programs
Office of Occupational Health
and Safety
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ENVIRONMENTAL PROTECTION AGENCY
CHAPTER 9
HEALTH AND SAFETY
HAZARDOUS WASTE SITE INVESTIGATIONS AND
ENVIRONMENTAL SPILL RESPONSES
MANUAL
OCCUPATIONAL
1. POLICY AND RESPONSIBILITY.
a. Purpose. This chapter establishes policy, responsibilities,
and procedures for the conduct of the Agency occupational health and
safety program for hazardous waste site (HWS) investigations and
environmental spill (ES) responses.
b. Policy. The EPA is committed to providing safe and healthful
working conditions for EPA employees at hazardous waste sites and
environmental spills.
c. Background. Executive Order 12196, 29 CFR 1960, and this EPA
Occupational Health and Safety Manual require the EPA to provide safe
and healthful working conditions for its employees. The EPA is respond-
ing to this requirement with this chapter, which is an adaptation of
the "Safety Manual for Hazardous Waste Site Investigations", originally
drafted by EPA's National Enforcement Investigation Center (NEIC).
The draft manual has been developed further by a Work Group of the
Hazardous Waste Task Force, NEIC, and the Office of Occupational
Health and Safety (OOHS).
d. Discussion. Investigators and response personnel must effectively
deal with the potential of facing a very high risk of incurring illness
or injury while investigating a HWS or responding to an ES. They cannot
anticipate every safety hazard associated with HWS investigations and ES
responses,so they must take extraordinary precautions to prevent illness
or injury to themselves, other workers, and the public.
Since the investigators and response personnel cannot obtain the ideal
objective of complete elimination of risk, they must reduce the risk to
the lowest feasible level. No set of rules can be applied uniformly to
every situation. The application of the rules presented in this safety
manual chapter to a specific HWS investigation or ES response must be
based on the judgement of the Project Leader who is responsible
for the safety of the investigation or response*. It is imperative, there-
fore, that the Project Leader assess those variables peculiar to each planned
activity in establishing appropriate safeguards.
*The designation, Project Leader, originated from policies and procedures
developed by NEIC for HWS investigations. The corresponding position at
spill responses is the On-scene Coordinator. For the purposes of this
manual, Project Leader will be used to designate both Project Leaders
and On-scene Coordinators.
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e. Responsibilities.
(1) Assistant Administrators (AA) and Regional Administrators (RA).
AA's and RA's are responsible for:
0 developing and implementing a health and safety program, con-
sistent with this manual, for HWS investigations and ES responses
conducted under their organizational jurisdiction;
0 coordinating the development of their health and safety
program with the Director, Office of Occupational Health
and Safety (OOHS); and
0 submitting their health and safety program to the Director,
OOHS, for review to assure consistency of these programs
throughout the EPA.
i
The AA for Planning and Management, as the Designated Agency Safety
and Health Official, is responsible for:
0 administering the EPA's health and safety program for HWS
investigations and ES responses;
0 ensuring the allocation of adequate resources in the EPA's
Budget to support and monitor these programs; and
0 identifying, with designated object class codes, the resources
as required by OMB Circular No. A-ll.
(2) Officers-in-Charge of Reporting Units (QIC's). QIC's are
responsible for:
0 implementing the health and safety program for HWS investigations
and ES responses conducted by employees of their reporting unit.
(See EPA Occupational Health and Safety Manual, CHAP 1, PAR 5, for
a detailed description of QIC's health and safety responsibilities);
0 assuring that any PL conducting a HWS investigation or ES response
is qualified by training or experience, has the equipment to con-
duct the investigation or response safely, and plans an investigation
or response which is safe to all concerned; and
0 assuring the completion of semi-annual program reviews and audits.
(3) Safety Committee.
The Safety Committee is responsible for:
0 aiding and advising the QIC on employee health and safety matters and
policies and procedures for the Agency occupational health and safety
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program for HWS investigations and ES responses. (See EPA Occupa-
tional Health and Safety Manual, CHAP 5 PAR 4, for a detailed
description of the Safety Committee's health and safety respons-
ibilities);
0 promtly reviewing and approving Safety Plans prepared by each Pro-
ject Leader and forwarding them to the Safety Designee; and
0 advising the QIC on specific programs for medical surveillance.
(The Safety Committee should include or have access to individuals
with a variety of technical backgrounds, so while not being able to solve
technical problems or totally analyzing proposed activities, it can call
to the attention of safety experts areas of concern.)
(4) Occupational Health and Safety Designee.
The Safety Designee is responsible for:
0 advising and assisting the QIC in developing, organizing,
directing, and evaluating the health and safety program for
HWS investigations and ES responses; and
0 coordinating accident reporting, recordkeeping and often
the medical surveillance program. (See EPA Occupational Health
and Safety Manual, CHAP 1, PAR 3 for a detailed description
of the Safety Designee1s health and saffety responsibilities).
Safety Designees must have either backgrounds and training in recognizing,
evaluating, and controlling hazards at HWSs and ESs or access to this
expertise. (Safety Designees should have or have access to expertise in
field safety, industrial hygiene, respiratory protection, transportation
of hazardous materials, occupational medicine, and geology.)
(5) Project Leader.
The Project Leader has the primary responsibility for:
0 assuring the availability of personal protective equipment
and selecting the level of personnel protection needed for
use at HWS investigations and ES responses;
0 selecting work practices and engineering controls for HWS
investigations and ES responses;
0 preparing a Safety Plan prior to the investigation or response
(See Appendix 2 for details of the Safety Plan);
0 submitting the Safety Plan prior to the investigation or response
to the Safety Committee for their review and approval;
0 making available to program and support staff copies of
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the approved Safety Plan;
0 assuring that the program and support staff are instructed,
trained and certified in the work practices required to ensure
safety and in planned procedures for dealing with emergencies, and
are informed of the potential hazards associated with the planned
investigation or response;
0 designating one member of the investigation or response team
as the site Safety Officer, and assuring that that person
fulfills all safety responsibilities necessary for safe
operations;
0 supervising the safety performance of the staff to ensure
that the required work practices are employed;
0 arranging for immediate medical attention and reporting to
the Safety Designee any incident that results in injury or overt
exposure personnel by hazardous materials;
0 assisting the Safety Designee in investigating accidents;
0 investigating and reporting in writing to the Safety Designee any
problem pertaining to operation and implementation of work practices;
0 correcting work errors and conditions that may result in
injury or exposure to hazardous materials; and
0 assuring the health, welfare and safety of all Staff members
at the HWS or ES.
(6) Safety Officer. The Safety Officer is responsible for
implementing the Safety Plan at the site.
(7) Employees. Employees are responsible for:
0 complying with the health and safety program established by
this chapter on HWS investigations and ES responses;
0 reporting to their supervisors or the Safety Designee any unsafe
condition and all facts pertaining to incidents which resulted in
employee injury or exposure to hazardous materials; and
0 cooperating in the medical surveillance activities.
(8) Director, Office of Occupational Health and Safety.
Under the supervision of the AA for Planning and Management, the
Director, OOHS, is responsible for:
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0 reviewing and coordinating the health and safety programs
developed by AA's and RA's for HWS investigations and ES responses
for consistency with this chapter (See I.e. (1));
0 auditing investigation and response activities for compliance with
Agency policy and practices and good work practices.
0 informing responsible EPA officials of any problem areas;
0 providing technical support; and
0 approving training courses.
The Director, OOHS, is the top technical advisor for EPA on health
and safety for HWS investigations and ES responses.
2. HEALTH AND SAFETY PROGRAM REQUIREMENTS
<
a. Safety Plan- The Project Leader must prepare and obtain approval
of a Safety Plan (Appendix 2) before conducting a HWS investigation or
ES response.* The Safety Committee, or similar group set up for this
purpose, must review the Safety Plan and forward it to the Safety Designee
with comments. The Safety Designee and the QIC must approve the Safety
Plan before the investigation or response can proceed on-site. The Safety
Designee must maintain the Safety Plan on file and available for distribution,
provide a copy to each employee participating in the HWS investigation or
ES response, and forward an information copy to the Director, OOHS.
b. Audit. The QIC must ensure that semi-annual program reviews,
including on-site inspections, of the health and safety program for HWS
investigations and ES responses are conducted by persons with appropriate
background and training, and that any deficiencies are corrected as soon
as possible (or immediately if the deficiency is an- imminent hazard).
The QIC must forward a copy of the program review and abatement actions to
the Director, OOHS, for review. The Director, OOHS, may conduct inde-
pendent audits.
c. Accident Reporting. The Safety Designee must coordinate the report-
ing of anyincident involving injury or exposure (inoculation, injestion,
dermal contact, inhalation) to a hazardous material in accordance with the
procedures detailed in CHAP 3 of the Occupational Health and Safety Manual.
In addition, the Safety Deesignee must forward a copy of the accident report
to the employee's medical record (See 2.f.(3)).
*For ES responses, generic Safety Plans must be prepared in advance,
dealing with groups of possible spills, eg., Safety Plan for acid
gas spill, etc. In addition, emergency support groups including
fire, rescue and medical staffs, with telephone number, must be
grouped together by area for easy access in the event of a hurried
departure to a spill. This information must be readily available prior
to spill response for attachment to the Safety Plan.
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d. Training. The QIC must ensure that all employees, before con-
ducting HWS investigations and ES responses, receive a minimum of 24 hours
of training on HWS and ES safety (followed by 24 hour refresher courses
annually) and receive training by 3 separate field experiences before
conducting investigations and responses. The Safety Designee must obtain
the approval of Director, OOHS, of the initial and annual 24 hour courses
and must issue a certificate to employees upon completion of the courses
and field experiences. In addition, the Safety Designee must maintain
records of training and forward individual records to employees' personnel
files. EPA ORDER , "Health and Safety Requirements for Employees Engaged
in Field Activities", provides detailed training requirements.
The Safety Designee must keep the Safety Plan, and other appropriate
written information describing the potential health and physical injury
hazards of a HWS investigation or ES response, in a file that is continuously
and readily availably to employees.
e. Emergency Procedures. The Safety Designee must develop procedures
to protect personnel in case of emergencies at the HWS or ES. The emergency
procedures should include notifying emergency and other affected personnel
and the locations and emergency telephone number of the nearest emergency
medical facility, ambulance service, fire department, police department
and Poison Control Center.
f. Medical Surveillance. EPA ORDER _ "Health and Safety Require-
ments for Employees Engaged in Field Activities" provides medical surveil-
lance requirements consistent with the requirements presented below.
(1) Pre-assignment Health Assessment. The QIC must ensure that
all employees who work at HWSs and ESs receive a base-line health assessment.
These health assessments must be consistent with the EPA Medical Monitor-
ing Gui del ines.
The purpose of this pre-assignment assessment is to establish a baseline
health record and to seek conditions which would predispose the employee
to illness due to exposure to hazardous materials or due to the physical
demands of using personal protective equipment. The pre-assignment assess-
ment includes a work history, a medical history, and a physical exami-
nation, which includes customary laboratory studies and agent-specific
studies when appropriate.
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(2) Periodic Health Assessments. The QIC must ensure that all em-
ployees who work at HWSs and ESs are offered periodic health assessments. The
periodicity and content of these assessments must be determined by the
QIC after consultation with an occupational physician, the Safety Designee,
the medical monitoring coordinator, and the Project Leader.
These assessments include an updating of the employee's work and medical
histories, including occurrences of any accidental exposures previously
unreported. The following information must be included in the employee's
medical record: names of hazardous materials to which the employees may
have been exposed, information on the probability, frequency, and extent
of exposures, and any environmental measurements relating to hazardous
materials that may have been made. The periodic health assessment must
include a physical examination and may also include biochemical or other
surveillance of body fluids, and an evaluation of pertinent functional
systems of the body (See Appendix 2).
<
The medical monitoring coordinator at each location is responsible for
requesting and helping to schedule examinations and, assisted by the Safety
Designee, must furnish employees, prior to each examination, exposure
and environmental monitoring data as specified above for inclusion in
their medical records.
(3) Records. Medical records must be maintained by the respective
occupational physician for the duration of the employee's employment.
Upon termination of the employee's employment, including retirement or
death, the medical records must be maintained for an extended period of
time in a manner that will ensure ready access as needed by the medical
monitoring program of the EPA. The extended period of time must be at
least 30 years after the individual's last work with hazardous materials.
Forward the records to the Medical Monitoring Program Manager, OOHS, if
custody of the records cannot be maintained locally.
3. WORK PRACTICES
The work practices specified in this section must be used by all HWS investigators
and ES personnel.
a. Personnel Practices.
(1) Protective Clothing. Protective clothing must be worn by all
personnel while on a suspected or confirmed HWS or ES unless sufficient data
has been acquired to enable the Project Leader to make an informed judg-
ment that pro tective clothing is not needed. In the absence of clear
indications that work can proceed safely without protective clothing,
required items include chemical-resistant pants, jacket, boots, gloves,
and hard hat or head cover, and may include a fully encapsulating chemical
protective suit.
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Project Leader's must also consider the potential hazards of wearing
protective clothing since protective clothing is cumbersome, hastens
the on-set of fatigue, increases heat stress, and increases the time the
personnel must spend in the high risk area.
(2) Heat Stress. Employees must compensate for the increased
heat stress caused by wearing protective clothing in hot weather in order
to prevent the on set of heat induced illnesses. Employees must maintain
an appropriate work-rest regimen and water and salt balances (see 3.b. (9)
for details).
(3) Eye Protection. Devices to provide appropriate eye protection
must be worn on any HWS or ES and should meet ANSI Z87.1, "Practice for Occu-
pational and Educational Eye and Face Protection".
(4) Forbidden Practices. The following practices are expressly
forbidden during operations on suspected or known HWSs and ESs:
0 Smoking, eating, drinking, chewing gum or tobacco; applying
cosmetics; storing utensils, food or food containers while
on site.
0 Ignition of flammable liquids within, on, or through im-
provised heating devices (barrels, etc.) or space heaters.
0 Approach or entry into areas or spaces where toxic or explo-
sive concentrations of gases or dust may exist without
proper equipment available to enable safe entry.
0 Conduct of on-site operations without off-site backup
personnel*
(5) Personal Hygiene. All personnel must wash the affected area
immediately after obvious contact with a hazardous substance.
b. Operational Practices.
(1) Information Review and Reconnaissance. The Safety
Plan for a HWS investigation or ES response must be based upon a thorough
evaluation of existing data and a reconnaissance (see "Waste Disposal Site
Hazard Assessment Manual", available from NEIC.) The information search
may indicate possible chemical hazards such as the presence of incompatible
chemicals, toxic gases, explosives, etc. (see Appendix D). Such indications
may provide insight to specific safety precautions needed. Similarly, a
perimeter inspection or aerial imagery, followed by an on-site reconnais-
sance, may reveal safety hazards requiring special attention.
*0n-scene Project Leader's may exericse informed judgment regarding
the need for off- site backup at active sites, or in cases where sites
have been repeatedly entered or occupied without apparent harm. In
any case where doubt exists, backup personnel must be present.
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Investigators and response personnel will normally become better able
to specify appropriate safety precautions as they get progressively closer
to, and measure, hazardous materials in air, runoff, groundwater, soil,
spilled material, barrels, etc.
(2) Protection Levels. Although the Project Leader must deter-
mine the level of protection which is appropriate for each HWS and ES,
four specific Protection Levels have been provided in this chapter as
bench marks for the Project Leader to select from (See Appendix 3). The
Project Leader must select a level based on aavailable information.
(3) Zones. Two or more zones must be established, clearly de-
lineated, and posted.
0 Decontamination Zone. During operations on a suspect or known
HWS or ES, a zone must be established for decontamination of equipment and
personel and access control just outside the area of suspected contam-
ination. At least one employee will remain in this zone to:
00 Assist in emergency removal of personnel from the HWS or ES in
the event of accident or injury. The backup must have readily
available protective clothing, breathing apparatus and first
aid equipment.
00 Assist in moving equipment, samples and supplies.
00 Provide communication to emergency units.
00 Assist in decontamination or removal of contaminated
clothing from the individuals emerging from the con-
taminated area.
00 As appropriate, prevent entry of unauthorized persons
to the HWS or ES while operations are underway.
00 Provide other assistance as necessary, but with the
primary objective of facilitating safe transfer of
personnel and equipment to and from the affected area.
0 Contamination Zone(s). The area(s) which contain, or are suspected
of containing, hazardous materials must be clearly delineated and posted.
The Project Leader may establish more than one contamination zone for
areas of different levels of potential personnel hazard. Only persons
authorized by the Project Leader may enter a contamination zone.
(4) Radioactivity and Explosivity. All HWSs and ESs must be
checked for radioactivity and explosivity during first entry onto the
site. Normal background radioactivity is approximately 0.01 to 0.02 mR/hr.
Detecting levels of activity significantly greater than normal background
is cause for a very careful survey of the entire site; if levels approach-
ing 2 mR/hr are encountered, the advice of a competent radiation health
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physicist must be sought before continuing operations on the site. (EPA's
Office of Air, Noise, and Radiation has radiation specialists in each
Region as well as staff at HQ, EER-Montgomery and ORD Las-Vegas.)
If explosivity readings greater than 20% LEL* are detected, very careful
survey of the area must be made. Readings approaching or exceeding 50%
LEL are cause for immediately withdrawing personnel and notifying the
emergency, fire, and explosion units. The Project Leader must be con-
sulted before continuing operations.
(5) Buddy System. A minimum of two employees, in constant commu-
nication* with each other, are required to perform any work in contamination
zones.
(6) Sampling Procedures. Sampling procedures must minimize the
risk of personnel exposure to hazardous materials during sampling, packaging,
shipping and analysis, and minimize the risk of exposure of others to spilled
or residual waste materials. Disposable sampling equipment should be used
wherever possible. (See Appendix 4, Sampling Procedures for more details).
(7) Sample Handing. Samples of runoff, ambient air, or groundwa-
ter from a HWS or ES or possibly affected areas, may be moved directly into
laboratories and handled with normal safety precautions, unless the Project
Leader determines that special handling is appropriate. However, samples of
liquids or solid materials removed from containers or obviously contami-
nated spill areas must be assumed to be hazardous materials and handled in
compliance with OOHS Safety Manual CHAP 8 "Laboratory Use of Toxic Subs-
tances".
(8) Use of Respirators as Personal Protective Devices. A respira-
tor use program must be provided for HWS investigators and ES personnel
who enter areas where a potential for inhalation exposure to a hazardous
material is present. This program will meet the requirements of
the OSHA General Industry Standards for respiratory protection as detailed
in 29 CFR 1310.134 and EPA Order . The respirators must be certified in
accordance with the requirements of the National Institute for Occupational
Safety and Health (NIOSH) under the provisions of 30 CFR Part 11. The
selection and use of respirators must be approved by the Safety Designee.
(9) Use of Respirators. This section provides procedures which
must be followed at HWSs and ESs but is not a substitute for the respirator
use program described in 3.b.(8) directly above.
*Lower Explosive Limit
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0 Self Contained Breathing Apparatus (SCBA). SCBA must be worn on-
site when:
00 Containers of unknown or known hazardous materials are being
opened.
00 When in enclosed spaces where hazardous materials are present,
such as abandoned waste chemical storage buildings or man-
holes which have received spilled chemicals.
00 When the Project Leader judges that the concentration of hazardous
materials in the air is greater than 10 times the OSHA PEL**.
0 Cartridge Respirators. Cartridge respirators, which are easier to
use but provide less protection than SCBA's, can be worn on-site
only when:
00 Hazardous materials in the air are not greater than 10 times
the PEL, and have good warning properties.
00 The Project Leader judges that respirators are needed as a precaution
against generation of low levels of toxic substances in
air due to sampling, handling, decontaminating, or other
operations.
00 Extended periods of use on-site, which would cause the capacity
of the cartridge to be exceeded, are not required.
00 Measurements have verified that at least 19.5% oxygen is
present.
00 Emergency escape respirators are carried by cartridge respi-
rator users. Escape respirator must be donned immediately
upon experiencing any warning property such as difficulty
breathing, dizziness, or other distress, strong taste,or
smell. User must then leave the site.
0 Carrying respirators. Cartridge or emergency escape respirators
must be carried on-site when the Project Leader judges that, al-
though the risk is very low, hazardous materials may become
present in the air during operations. The respirators must be donned
immediately upon experiencing any of the warning properties described
immediately above. The user must leave the site immediately
after donning an escape respirator or if the warning properties
persist after donning a cartridge respirator.
* Radio contact must be maintained when visual contact cannot be maintained.
** Permissible Exposure Level
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(10) Heat Stress. The effectiveness of employees rest-regimen
should be confirmed by monitoring heart rate. Use the Brouha guideline:
pulse rate is counted for the last 30 seconds of the first three minutes
after rest begins. If the first recovery pulse (i.e., from 30 to 60 sec
onds) is maintained at 110 beats per minute or below and deceleration
between the first and third minute is at least 10 beats per minute, no
increasing strain occurs as the work day progresses.
Employees must replace water and salts lost from sweating. Use either
0.1% salt solution or commercial mixes (such as Gatorade). The commercial
mixes may be preferable for employees on low sodium diets. In addition,
on days when the potential for heat stress is apparent, advise employees
to salt food more than usual.
(11) Sampling Equipment. As a general rule, sampling equipment
used on a HWS or ES should be disposable. Sampling instruments and other
non-disposable equipment should be kept clean with disposable protective
covers. Dippers, scoops, and' similar devices for solids samples should be
buried on-site, or placed in plastic bags for disposal or later decontam-
ination. Liquid samples from barrels or tanks should be withdrawn in
inert tubing, such as glass, and tubing should then be broken and abandoned
within the barrel or tank. If incineration or recycling of barrel contents
is contemplated, the tubing may be disposed of in other suitable con-
tainers, or buried on the sites. The widely discussed Composite Liquid
Waste Sampler (or "Coliwasa") is unsuitable because it is extremely diffi-
cult to decontaminate under field conditions.
(12) Decontamination. Whenever possible, equipment should be decon-
taminated prior to leaving the HWS or ES. Equipment which can not be de-
contaminated at the scene must be double bagged and transported to another
area for eventual decontamination. Where possible, verify completeness
of decontamination with sniffers, swipe tests, or other appropriate
tests (See Appendix 6, Decontamination Procedures, for more detail).
(13) Packaging and Shipping. Hazardous materials must be packaged to
withstand shocks, pressure changes, and any other conditions which might
cause the leakage of contents incident to ordinary handling during trans-
portation. Shipments of hazardous materials must be in accordance with DOT
regulations. (See Appendix 4 for packaging and shipping guidance for hazardous
waste samples).
(14) Leaving the Site. Procedures for leaving the suspect contam-
inated area must be planned before entry. Provision must be made for:
decontamination and safe packaging of protective clothing; burial or safe
packaging of disposable gear; handling of samples and preparation of samples
for shipment; transfer of equipment, gear, and samples from the "contam-
inated" area to the "clean" area; etc. Sequences will depend on several
variables — such as SCBA inside or outside of protective clothing —
but must be worked out in advance.
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(15) HWS and ES Monitoring Equipment. For immediate evaluat-on of
potential health hazards, use direct reading instruments such as portable
combustible gas and oxygen meters, photoionization meters, gas chromatographs,
infrared spectrometers, radiation survey meters, and colorimetric detector
tubes. The Project Leader must be aware of the limitation of these portable direct
reading instruments when characterizing the unknown chemicals at unknown
concentrations at HWSs and ESs.
(16) Decontamination Equipment. Equipment and supplies for decon-
tamination must be available on-site. The equipment and supplies must allow
employees to wash exposed areas of their bodies as well as equipment or
other items which have been in the contamination zone, and collect the
washwater and other contaminated materials for disposal. The equipment
must include at least a 20 gallon emergency eye wash and may include a
personnel shower.
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APPENDIX I
SAFETY PLAN
Assistance in preparing the safety plan can be obtained from the Safety
Designee located in Room of Building
or by telephoning
REVIEW
Safety Committee Chairperson
APPROVALS
Project Leader
Safety Designee_
QIC
PROJECT LEADER
Branch
Building
Room
Phone
DATE OF PLAN PREPARATION
HAZARDOUS WASTE SITE OR ENVIRONMENTAL SPILL RESPONSE
Site Name Site No.
HAZARDOUS/TOXIC MATERIAL (known or suspected, contaminated media or in
storage container, etc.):
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HAZARD ASSESSMENT(toxic and pharmacologic effects, reactivity, stability,
flammability, and operational concernssampling, decontam-
inating, etc.):
MONITORING PROCEDURES(If required by the Project Leader)
Monitoring the site for identify and concentration of contamination:
Medical surveillance procedures for evidence of personnel exposure:
Personnel monitoring procedures:
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DECONTAMINATION AND DISPOSAL
Decontamination Procedures (contaminated: personnel surfaces, mater-
ials, instruments, equipment, etc.):
Disposal Procedures (contaminated equipment, supplies, disposable,
washwater):
EMERGENCY PROCEDURES
In event of overt personnel exposure (skin contact, inhalation,
ingestion):
In event of personnel injury:
In event of potential or actual fire or explosion:
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In event of potential or actual ionizing radiation exposure:
In event of environmental accident (spread of contamination
outside HWS or ES):
PERSONNEL POTENTIALLY EXPOSED TO HAZARDOUS MATERIALS
Personnel Authorized to Enter HWS or ES
1.
2.
3.
4.
5.
Other Personnel Assigned to Handle Hazardous Materials (decontaminate,
analyze samples)
1.
2.
3.
4.
5.
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APPENDIX 2
PERIODIC HEALTH ASSESSMENT
1. ASSESSMENT FOR EVIDENCE OF EXPOSURE.
The nature of a program for providing periodic health assessments is com-
plicated by several factors: (1) many workers handle a variety of hazardous
materials so that the medical surveillance should ideally seek evidence
of adverse effects from all these substances, (2) the hazardous materials
may not be identified, (3) some hazardous materials may have chronic
effects such as cancer but have little or no toxicity other than the production
of neoplasms, and most tumors do not become evident until many years (often
20-30) after the initiating events.
Biologic monitoring will sometimes be a useful method of detecting exposure
and, perhaps, of estimating the degree of exposure. Biologic monitoring
usually involves the analysis of body fluids or excreta (usually urine,
sometimes blood, rarely expired air) for the hazardous material or a bio-
transformation product. An example is the detection of reaction products
of biphenyl amines in the urines of persons absorbing benzidine or its
derivatives. Even if exposure cannot be quantitated, as is sometimes the
case, the mere detection of the metabolite, if its presence is specific to
the individual hazardous material or class, is sufficient to indicate the
need for corrective action.
For chronic effects, medical monitoring will, sometimes for necessity and
more often for efficiency, usually concentrate on events likely to precede
overt evidence of serious health effects such as tumorigenesis. For ex-
ample, some carcinogens, such as dimethylnitrosamine, have high acute
toxicity, especially to the liver, and evidence of such acute toxicity can
be obtained within a few hours or days following exposure. Some tumors,
such as those induced by carbon tetrachloride, are normally preceded by
marked changes in liver cells, usually detectable by clinical tests.
Others, e.g., angiosarcomas induced by such substances as vinyl chloride,
will often cause detectable cell changes in nearby tissue as the probable
result of space occupation. It should be noted that detection of such
toxic changes does not necessarily presage tumor development, but should
nevertheless precipitate the institution of corrective work practices.
The occupational physician, to be effective, must have relevent information,
such as mode and mechanism of toxic action, frequency and severity of
exposure, and exposure concentrations, if known. Some of this infor-
mation will be available in individual safety data sheets for hazardous
wastes once identified. However, this information should be supplemented
by the Project Leader when appropriate.
In some cases, especially with some lesser known hazardous materials,
there will be EPA investigators in research and analysis laboratories who
will be better informed on possible biologic monitoring procedures than
will the occupational physician. In such cases, the HWS investigators
or ES response personnel should discuss the possibilities of specialized
testing with the occupational physician and refer the physician to the
appropriate EPA investigator for information. It may also be that specialized
c-64
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analytical procedures and equipment will be needed for some of this monitoring,
procedures and equipment that may not be available to the medical laboratory
but which are available in the research laboratory. The investigators
should have such monitoring procedures performed by EPA laboratories only
with prior approval by and participation of the occupational physician.
This is to ensure that appropriate precautions will be taken; such as (1)
precautions necessary to data interpretation, such as standard corrections
for dilution of urine, (2) precautions for the individual, such as assurance
that invasive procedures will not be used, and (3) precautions for the
individual's privacy, such as maintenance of appropriate security for
individual records.
2. PREEMPLOYMENT EXAMINATIONS. The U.S. Office of Personnel Management
MUST approve the requirement for having a preemployment examination of ap-
plicants for a federal employment position.
a. Criteria. The following criteria are recommended for individuals
selected for arduous duty positions:
Vision—Binocular vision is required and must be at least 20/40
(Snellen) in one eye and 20/20 in the other, with or without
corrective lenses. Near vision must be sufficient to read with-
out strain printed material the size of typewritten characters.
Normal depth perception, accommodation, and field of vision are
required, as is the ability to distinguish basic colors.
Hearing—Without using a hearing aid, applicant must have no
hearing loss in either ear of more than 30 decibels at 500-,
1,000-, or 2,000-cps range.
Speech—Diseases or conditions resulting in indistinct speech are
disqualifying.
Olfactory Sense—Applicant must possess a normal sense of smell.
Respiratory System--Any chronic disease or condition affecting the
respiratory system that would impair the full performance of duties
is disqualifying; e.g., conditions that result in reduced pulmonary
function, shortness of breath, or painful respiration.
Cardiovascular System—The following conditions are disqualifying:
a. Organic heart disease (compensated or not)
b. Hypertension with repeated readings that exceed 150 systolic
and 90 diastolic without medication
c. Symptomatic peripheral vascular disease and severe varicose
veins
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Gastrointestinal System—Chronic symptomatic disabling diseases
or conditions of the gastrointestinal tract are disqualifying.
Endocrine System—An uncontrolled systemic metabolic disease,
such as diabetes or gout, is disqualifying.
Genitourinary Disorders—Chronic, symptomatic diseases or con-
ditions of the genitourinary tract are disqualifying.
Extremities and Spine—Any deformity or disease that would in-
terfere with range of motion or dexterity or that is severe
enough to affect adversely the full performance of position
duties is disqualifying.
Nervous System—Applicants must possess emotional and mental
stability. Applicants' with a history of epilepsy or convulsive
disorder must have been seizure-free for the past 2 years with-
out medication. Any neurological disorder with resulting de-
creased neurological or muscular function is disqualifying.
Miscellaneous—Although not mentioned specifically above, any
other disease or condition that interferes with the full pre-
formance of duties is also grounds for medical rejection.
b. Medical Examinations.
The arduous duty medical examination must include for each
applicant:
A. A complete medical examination, by or under the super-
vision of a licensed physician, consisting of:
1. The obtaining of a thorough occupational and medical
history.
2. The performance of a comprehensive physical exami-
nation of the following:
a. head, face, neck, and scalp
b. nose
c. mouth and throat, including general dental
condition and hygiene
d. speech
e. ears, including drums
f. eyes, including pupils, ocular motility, field
of vision, and fundi
c-66
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g. lungs and chest
h. heart
i. vascular system
j. abdomen, viscera, and hernia
k. anus and rectum
1. endocrine system
m. genitourinary system
n. upper extremities
o. lower extremities, including feet
<
p. spine and musculoskeletal system
q. skin and lymphatics
r. identifying body marks, scars, or tatoos
s. neurological system
t. psychiatric system
Pelvic examination of females is not required. Proctosigmoidoscopic
examination is not required.
3. The following parameters must be measured/tested
and results recorded:
a. height (without shoes)
b. weight (undressed)
c. visual acuity, including distant and near vision
corrected and uncorrected
d. color vision, using Ishihara or other color-
plate method
e. depth perception
f. hearing acuity, by pure tone audiometry
g. blood pressure
h. pulse rate
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4. The following tests must be performed, interpreted,
and recorded:
a. electrocardiogram (12 lead, resting)
b. chest X-ray (PA single view, 14x17 inches)
c. pulmonary function (forced vital capacity and
forced expiratory volume in 1 second)
d. urinalysis, complete (pH, glucose, ketones,
albumin, occult blood)
e. blood count, complete (white cell count, red
cell count, hemoglobin determination, hematocrit
determination, platelet estimation, scan of
blood smear, and calculations of MCV, MCH, and
MCHC Indices)
f. blood chemistries (cholesterol, glucose, urea
nitrogen, uric acid, transaminase (SGOT), bilirubin,
calcium, total protein, inorganic phosphate,
alkaline phosphatase, lactic dehydrogenase (LDH),
creatinine)
B. The applicant shall be advised of findings and counseled
to seek medical attention as may be indicated.
3
C. The examination findings, results, recommendations, and
opinions shall be reported to EPA on the Certificate of
Medical Examination, Standard Form No. 78, revision of
October 1969, Part C, to which may be appended test and
other reports.
The preemployment medical examination for respirator users should
consist of a general medical examination, similar in scope to the
arduous duty examination, but with special attention to evaluation
of the skin, cardiac and pulmonary systems, and evaluations of any
history or symptoms of allergy. The examining physician should also
be alert to any personality or psychological factors which may affect
respirator use. The physician will usually not be knowledgeable
about types and uses of respirators. He or she will need to evaluate
the stress that may be associated with the assigned duties and re-
spirator(s) used. Therefore, the physician should be informed of
the characteristics of the required respirator(s): use and type,
frequency and duration of expected use, use in hot or cold environ-
ments, etc. Detailed medical standards for respirator users are
not available; the physician must form a medical judgement based on
evaluation of respirator demands and stress and on the clinical
findings in individual applicants.
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APPENDIX 3
PERSONAL PROTECTION LEVEL DETERMINATIONS
a. Introduction
It is of the utmost importance that the Project Leader specify the
correct level of protective equipment for each HWS investigation or ES
response. The level of protective equipment shall be determined by the
type and levels of waste or spill material present at the site. In situations
where the types of waste or spill material on-site are unknown or the
hazards are not clearly established, the Project Leader must make a reasonable
determination of the level of protection that will assure the safety of
investigators and response personnel until the potential hazards have been
characterized. This level shall be maintained until the hazards have been
determined through monitoring; sampling, informational access, or other
reliable methods. Once the hazards have been determined, then protective
levels commensurate with the hazards will be used.
The appropriate level of protection shall be determined prior to entering a
hazardous waste site or responding to an environmental spill. The levels
of protection are explained below and itemized in Table 3-1.
Level A
Level A protection must be worn when the Project Leader makes an reasonable
determiantion that the highest available level of both respiratory and skin
(and eye) contact protection is needed. It should be noted that while
Level A provides maximum available protection, it does not protect against
all possible hazards. Consideration of the heat stress that can arise
from wearing Level A protection should also enter into the Project Leader's
decision. (Comfort is not a decision factor, but heat stress will
influence work rate, scheduling, and other work practices.)
Level B
The Project Leader must select Level B protection when the highest level of
respiratory protection is needed, but hazardous material exposure to the
few unprotected areas of the body(i.e., the back of the neck) is unlikely
with Level B protective clothing.
Level C
The Project Leader may select Level C when the required level of respiratory
protection is known, or reasonably assumed to be, not greater than the
level of protection afforded by air purifying respirators; and hazardous
materials exposure to the few unprotected areas of the body(i.e., the back
of the neck) is unlikely with Level C protective clothing. Level C requires
carrying an emergency escape respirator.
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Level D
Level D is the basic work uniform. Investigators and response personnel
must not be permitted to work in civilian clothes.
b. Protective equipment and criteria
Level A
(1) Personal Protective Equipment
0 Open circuit, pressure-demand SCBA
0 Totally encapsulated suit
0 Gloves, inner (surgical type)
0 Gloves, outer, chemical protective
0 Boots, chemical protective, steel toe and shank
0 Booties, chemical protective
i
(2) Criteria
0 Sites known to contain hazards which
00 require the highest level of respiratory protection (as
stated above)
00 will cause illness as a result of personal exposure, and
00 the Project Leader makes a reasonable determination that
personal exposure could occur to any part of the body.
0 Sites for which the Project Leader makes a reasonable determina-
tion that, based on the lack of information to the contrary,
the site may be described as stated directly above.
Level B
(1) Personal Protective Equipment
0 Open circuit, pressure-demand SCBA
0 Chemical protective
00 Overalls and long sleeved jacket, or
00 Coveralls
0 Gloves, inner (surgical type)
0 Gloves, outer, chemical protective
0 Boots, chemical protective, steel toe and shank
0 Booties, chemical protective
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(2) Criteria
Sites known to contain hazards which require the highest level
of respiratory protection as stated above
will cause illness as a result of personal exposure, and
the Project Leader makes a reasonable de
personal exposure to areas of the body n
Level B protective clothing is unlikely.
for which the Project Leader makes a
:hat, based on the lack of informatio
the site may be described as stated above.
00 the Project Leader makes a reasonable determination that
personal exposure to areas of the body not covered by
0 Sites for which the Project Leader makes a reasonable determina-
tion that, based on the lack of information to the contrary,
Level C
(1) Personal Protective'Equipment
0 Full face-piece air-purifying respirator
0 Emergency escape respirator (carried)
0 Chemical protective
00 Overalls and long sleeved jacket, or
00 Coveralls
0 Gloves, inner (surgical type)
0 Gloves, outer, chemical protective
0 Boots, chemical protective, steel toe and shank
0 Booties, chemical protective
(2) Criteria
0 Sites known to contain hazards which
00 do not require a level of respiratory protection greater
than the level afforded by air purifying respirators
(nominal protection factor of 10) as stated above,
00 will cause illness as a result of personal exposure, and
00 the Project Leader makes a reasonble determination that per-
sonal exposure to areas of the body not covered by
Level C protective clothing is unlikely.
0 Sites for which the Project Leader makes a reasonable determina-
tion that, based on the lack of information to the contrary,
the site may be described as stated above.
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Level D
(1) Personal Protective Equipment
0 Coveralls, cotton
0 Boots/shoes, safety
0 Safety glasses
0 Hard hat with optional faceshield
0 Air purifying respirator (readily available)
(2) Criteria
0 Sites where the Project Leader makes a reasonable
determination.that hazards due to exposure to hazardous mate-
rials is unlikely.
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APPENDIX 4
(These procedures are currently under revision to reflect the May 19, 1980
changes in the Department of Transportation regulations for shipment of
hazardous materials.)
PACKAGING. MARKING, LABELING. AND SHIPPING OF HAZARDOUS WASTE SITE AND
ENVIRONMENTAL SPILLS SAMPLES
General Provisions. Samples that are judged to be environmental samples
may be shipped according to letters of understanding granted EPA by DOT.
Other specific exemptions may also apply (e.g., use of Labelmaster,
Inc. package #38, or Dow Chemical Co. Imbiber Pack for shipment of
Poison B, n.o.s. by United Parcel Service).
The following procedures apply to samples collected from a hazardous
waste site or environmental spill, and which in the judgment of the
Project Leader cannot be considered to be "environmental samples".
0 Unanalyzed HWS and ES samples may not be fixed with any preservative or
preserved with ice or dry ice.
0 If a material specifically identified in the Department of Transpor-
tation (DOT) Hazardous Material Table (49 CFR 172.101) is known to
be contained in an HWS or ES sample, that sample should be transported
as prescribed in the table.
0 Unanalyzed HWS and ES samples may be transported by rented or common
carrier truck, bus railroad, and by Federal Express Corporation*
(air cargo); but they may not be transported by any other common
carrier air transport, even "cargo only" aircraft. Those samples
taken from closed drums or tanks, however, should not ordinarily be
transported by Federal Express. (See 1 and 2 in "Packaging, Marking
and Labeling Requirements for Unanalyzed Hazardous Waste Site Samples
Taken From Closed Drums").
0 If samples are transported by any type of government-owned vehicle,
including aircraft, DOT regulations are not applicable. However,
EPA and FIT personnel will use the packaging procedures described
below except that the Bill of Lading with certification form does
not have to be executed (see "Shipping Papers" on under b.8).
These procedures are designed to enable shipment by entities like
Federal Express; however, they should not be construed as an endorsement
by EPA of a particular commercial carrier.
C-73
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0 Irrespective of type sample or container, after completion of the
analyses the contractor will repackage the original sample bottles
in the coolers or containers received, and return them to the origi-
nating Regional office. The packages will be sealed and shipped
under custody procedures as they were received. Each originating
office should make arrangements with the contractor through the
Sample Management Office (VIAR) for the method of return and payment
for shipping charges within 30 days after sample shipment. Organic
extracts from the samples will be shipped by the analytical contrac-
tors to EPA's EMSL/Las Vegas office for archival storage.
b. Packaging, Marking and Labeling Requirements for Unanalyzed
Hazardous Waste Site Samples, Excluding Drum Samples.
(1) Collect sample in an 8-ounce* or smaller glass container with
nonmetallic, teflon-lined screw cap. Allow sufficient ullage
(approximately 10% by volume) so container is not liquid full at
130 F. If collecting a solid material, the container plus con-
tents shall not exceed 1 pound net weight.
(2) Attach properly completed sample identification tag [Figure 4]
to sample container.
(3) Seal sample container and place in 2-mil-thick (or thicker) poly-
ethylene bag, one sample per bag. (Tags should be positioned to
enable them to be read through bag.)
(4) Place sealed bag inside a metal can with Incombustible, absorbent
cushioning material (e.g., vermiculite or earth) to prevent break-
age, one bag per can. Pressure-close the can and use clips, tape
or other positive means to hold the lid securely, tightly and
effectively.
(5) Mark and label this container as indicated in No. 8 below.
(6) Place one or more metal cans (or a single 1-gallon bottle*) sur-
rounded with incombustible packaging material for stability during
transport, into a strong outside container, such as a metal picnic
cooler or a fiberboard box.
(7) Mark and label the outside container and complete shipping papers
as described below.
Large quantities, up to one gallon, taken from wells may be collected
if the flash point of the sample can be determined to be 73 F or higher.
In this case, such should be marked on the outside container (carton,
etc.) but only a single (one gallon or less) bottle may be packed in an
outside container. Ten percent ullage and requirements 2,5,6, and 7
below must also followed. On the shipping papers state that "flash
point is 73° or higher".
c-74
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(8) Marking and labeling: Use abbreviations only where specifed.
Place the following information on a metal can (or bottle), either
hand printed or in label form: laboratory name and address and
"Flammable Liquid, n.o.s.", (if not liquid, write "Flammable
Solid, n.o.s.").* Place the following labels on the outside of
the can (or bottle)
"Cargo Aircraft Only"; "Flammable Liquid";
if not liquid, "Flammable Solid" ("Dangerous
When Wet" label should be used if the solid
has not been exposed to wet environment).
Note: If the cans are placed in an exterior container, both that
container and inside cans must have the same markings and labels
as above. "Laboratory Samples" and "THIS SIDE UP" or "THIS END
UP" should also be marked on the top of the outside container,
and upward pointing arrows should be placed on all four sides of
the exterior container.
Shipping Papers: Use abbreviations only where specified below:
Complete the carrier-provided bill of lading and sign the certifi-
cation statement (if carrier does not provide, use standard indus-
try form) with the following information in the order listed. One
form may be used for more than one exterior container.
"Flammable Liquid, n.o.s." (or Flammable Solid,
n.o.s.", as appropriate); "Cargo Aircraft Only";
"Limited Quantity" or "Ltd. Qty."; "Laboratory
Samples"; "Net Weight " or "Net Volume
" (of hazardous contents), by item,
if more than one metal can is inside an exterior
container. The net weight or net volume must be
placed just before or just after the "Flammable
Liquid, n.o.s." or "Flammable Solid, n.o.s."
description.
A Chain-of-Custody Record form should also be properly executed,
and included in the exterior container.
(9) Unless samples are driven to the laboratory, a team member must
accompany shipping container(s) to the transport carrier and, if
required, open outside container(s) for freight inspection.
Using "Flammable" does not convey the certain knowledge that a sample
is in fact flammable, or how flammable, but is intended to prescribe
the class of packaging in order to comply with DOT regulations; "n.o.s."
means not otherwise specified.
c-75
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Packaging, Marking and Labeling Requirements for Unanalyzed Hazardous
Waste Site Samples Taken from Closed Drums"
(1) All samples from closed drums do no necessarily have to be
shipped as below. The Project Leader must make a judgement,
based on the information available, as to the hazard class of
samples gathered. This packaging, marking, labeling and
shipping method provides a worst-case procedure for materials
classed as "Poison A" {49 CFR 173.328).
(2) These samples may not be transported by Federal Express Corpora-
tion (air cargo) or other common carrier aircraft, or by rental,
non-government aircraft. (Samples may be shipped by ground trans-
port or government aircraft.)
(3) Collect sample in a polyethlylene or glass container which is of
an outer diameter narrower than the valve hole on a DOT Spec.
3A1800 or 3AA1800 metal cylinder. Fill sample container allowing
sufficient ullage (approximately 10% by volume) so it will not be
liquid-full at 130° F. Seal sample container.
(4) Attach properly completed Sample Identification Tag (Figure 4) to
sample container.
(5) With a string or flexible wire attached to the neck of the sample
container, lower it into a metal cylinder which has been partially
filled with incombustible, absorbent loose packaging material
(vermiculite or earth). Allow sufficient cushioning material
between the bottom and sides of the container and the metal cylin-
der to prevent breakage. After the cylinder is filled with cush-
ioning material, drop the ends of the string or wire into the
cylinder valve hole. Only one sample container may be placed in
a metal cylinder.
(6) Replace valve, torque to 250 ft-lb (for 1 inch opening) and re-
place valve protector on metal cylinder, using teflon tape.
(7) Mark and label cylinder as described below.
(8) One or more cylinders may be placed in a strong outside container.
(9) Mark and label outside container and complete shipping papers as
described below.
(10) Marking and labeling: Use abbreviations only where specified.
Place the following information on the side of the cylinder, or
on a tag wired to the cylinder valve protector, either hand-
printed or in label form.
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"Poisonous Liquid or Gas, n.o.s.", laboratory name and address.*
Place the following label on the cylinder: "Poisonous Gas".
("Poisonous Liquid" label not acceptable here, even if liquid.)
Note: If the metal cylinders are placed in an outside container,
both the container and cylinders inside must have the same mark-
ings and labels as above. In addition, "Laboratory Sample", and
"Inside Packages Comply With Prescribed Specifications" should be
marked on the top of the outside container. "THIS SIDE UP" mark-
ing should be placed on the outside container and upward pointing
arrows on four sides.
Shipping Papers: Complete the shipper-provided Bill of Lading
and sign the certification statement (if carrier does not provide,
use standard industry form) with the following information in the
order listed. One form may be used for more than one exterior
container; use abbreviations only as specified:
"Poisonous Liquid, n.o.s."; "Limited Quantity" or
"Ltd. Qty."; "Laboratory Samples"; "Net Weight
or "Net Volume " (of hazardous contents), by cy-
linder, if more than one cylinder is inside an exterior
container. The net weight or net volume must be placed
just before or just after the "Poisonous Liquid, n.o.s."
marking.
A Chain-of-Custody Record form (Figure 5) should also be
properly executed and included in the container, or with the
cylinder.
(11) Unless samples are driven to the laboratory, an EPA employee
will accompany shipping container to the transport carrier
and, if required, open outside container(s) for freight
inspection.
*Using "Poisonous" does not convey the certain knowledge that a sample is
in fact poisonous, or how poisonous, but is intended to prescribe the class
of packaging in order to comply with DOT regulations.
c-77
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APPENDIX 5
SAMPLING PROCEDURES
Containers (drums, tanks, etc.) should only be sampled when necessary
to meet enforcement or cleanup requirements. Opening drums or other sealed
containers may be hazardous to sampling personnel unless proper safety
procedures are followed. Gases can be released, pressurized liquids can
be expelled, or explosions can occur. A drum should not be moved or
opened unless it can be ascertained beyond reasonable doubt that the drum
is structurally sound. Drums standing on end, with bung up, should be
opened by pneumatic impact wrench, operated from a remote site (Figure 5.1).
Drums on sides may be opened similarly if it is possible to safely rotate
the drum so that the bung is high. If the bung can be removed, sampling
contained liquids may be safel'y accomplished by glass tube, which is then
broken and discarded within the barrel. A barrel that has a badly rusted
bung, or that cannot be sampled as above, may be safely sampled with a
hydraulic penetrating device (Figure 5.2) operated remotely. The device is
then abandoned in place, and disabled to prevent further withdrawal of
liquids. Sealed or closed tanks should be opened remotely, using ropes to
lift hatches, etc.
In general, metal sample containers should not be used on HWS in-
vestigations and ES responses; if used, they must be grounded, preferably to
the drum or tank being sampled, while sample transfer is accomplished. In
all cases of entry into closed containers, the local fire departmnt should
be asked to stand by. In any case wherein presence of explosives is sus-
pected or known, Army EOD or police bomb squads should be requested to
remove or neutralize such materials. In no event may EPA employees handle
explosives encountered on sites.
Subsurface sampling of an HWS or ES can also create hazards to employees
and the public, unless adequate safety precautions as followed. Biodegrad-
ation of refuse in dumps produces methane and other explosive gases. The
escaping gases may be ignited by drill rigs or other ignition sources.
Drilling into dump sites may cause discarded incompatibles to be mixed and
thereby create reactive mixtures. Dump or spill sites where leachate plumes
are contained in impervious strata may be interconnected with producing aqui-
fers if drilling is not planned according to competent ground water tech-
nology and data.
Drilling in HWS investigations and ES responses should be confined to the
periphery of sites, with the objective of characterizing the leachate
that may be moving away from the site. If subsurface sampling of dump
sites is necessary, excavation must be accomplished by hand, and with
sparkfree equipment.
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All drilling associated with HWS and ES activities must be accomplished
under the responsible supervision of a competent geohydrologist, ground
water geologist, geological engineer, or a person similarly qualified by
experience. Drilling must be preceded by sweeps with metal detectors,
and drilling must be limited to areas where the presence of buried drums
or tanks is not indicated. Test holes must be cased or plugged when
the activites is completed.
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FIGURE 5.1
K'-Af&'Z'&ite-
^".C;!";«^^^*A>-,-
f^^^^^f^^y^^&i
S*^," -A "> ^%--^^>»'*&i^V^V^^i~^,V-?i^''^*^^^^^"':-?'
•/^
Remote bung removal. Man in back-
ground, dressed in protective cloth-
ing, operates bung-removal equipment
on drum in foreground.
^^P^ffTOl^^^^
^SS.IiyWR- ^-.vv^^^.'sy
l^i^miJ^y^ -^^&
Equipment closeup.
III-8
(9/79)
i
1
.
Bung-removal equipment; drum
on end.
Remote bung-removal setup;
drum on side.
FIGURE 2. REMOTE REMOVAL OF BARREL BUNG
C-80
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FIGURE 5.2
III-?
(9/79)
Remote operation of penetrating
sampling device.
----t- •.
"^^.-.^' *':^
Drum attachment, connecting
tube, and hand-held activator.
r-i-«-£Vs-*'5^: ^:^-U-''r
':-^ -
Sampling device penetrating drum.
Remote sampling equipment.
FIGURE 3. REMOTE SAMPLING
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APPENDIX 6
DECONTAMINATION PROCEDURES
A. Introduction
The need for personnel decontamination can vary greatly. Operations
such as walking through an area may require only a simple controlled
undressing procedure and bagging of contaminated clothing. In oper-
ations in which extensive work is performed in a contaminated area,
cross contamination of protective clothing and equipment can occur.
In this case, a controlled undressing and bathing facility will be
needed.
For those situations in which gross contamination may occur, a
sophisticated personnel decontamination station, as illustrated in
Figure 6.1, should be established. It provides for a controlled
undressing and washing system that is designed to avoid transfer
of chemical contamination from protective clothing. The number of
stations can be adjusted to the protective clothing system being
used. All field personnel should shower as soon as possible after
leaving a contaminated area.
Full-decontamination of reusable suits is accomplished in two steps.
The first step is performed on-site using solutions selected beforehand
in consultation with chemists and lexicologists based on limited knowl-
edge of the hazardous materials on the site at the time (see Figure 6.2).
Usually an adequate decontamination solution consists only of water.
However, the decontamination solutions may be solutions of water and
detergents, water and chemical compounds designed to react with and
neutralize specific contaminents, or solvents. After cleansing, protec-
tive clothing is turned inside out, if feasible, and sealed in plastic
bags for return shipment. The second decontamination step is taken
later, after the contaminant has been latoratory-analyzed to determine
what decontamination reagents are most suitable for each case. This
second cleaning is then performed by personnel wearing disposable
protective clothing. Waste decontamination solution from the second
step should be treated as hazardous waste and disposed of accordingly.
B. Model for Decontamination Procedures-
Organization of the Personnel Decontamination Station (PDS)
Once the contamination zone and the clean zone have been established,
the PDS is set up.
1. Layout of the PDS
An example of a PDS is shown in Figure C-l and is as follows:
STATION A - A plastic ground sheet on which field equipment is
dropped by returning members team.
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STATION B - A wash tub filled with a decontamination solution
- A second wash tub filled with rinse solution
- A third wash tub filled with decontamination solution
- A fourth wash tub filled with rinse solution
- Each wash tub should be equipped with a large sponge
and brush
STATION C - A bench or stool for personnel to sit on during removal
of booties
- A ten (10) gallon pail with plastic liner where dispos-
able boot covers are discarded
<
STATION D - Two ten (10) gallon buckets filled with decontamination
solution
STATION E - A ten (10) gallon bucket filled with rinse solution
STATION F - A 32 gallon trash can with plastic liner (container for
rubber items)
STATION G - 30 meters upwind from Station F
- A plastic ground sheet for SCBA drop
STATION H - A bench or stool for personnel
- A 32 gallon trash can with plastic liner (container for
cloth items)
STATION I - A field shower set-up
STATION J - A redressing and first aid station. This station defines
the boundary between the Contamination Control Area and
the Clean Area
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TYPICAL LAYOUT OF THE PDS
(LEVEL A PROTECTION)
WIND DIRECTION
20"
o
oo
EQUIPMENT
DROP
"»>
^
^^^^"^ ^**"
20°-^
PLASTIC
SHEET
31
l_ 1
TANK CHANGE OVER POINT
, B ij C D E
DECON
OUTER
GARMENT
GO
SOL A RINSE
fo©
SOL B RINSE
REMOVE
BOOT
COVERS
I (
b
DECON
BOOTS
AND
GLOVES
RINSE
BOOTS
AND
GLOVES
i -
/\/\ ^
o+e . b
0 CAN SOL A SOL B WATER
I1 (10 GALLON) (10 GALLON)
F
REMOVE
BOOTS
. AND
OUTER
GARMENTS
b
CAN
(32 GALLON)
AD CM IT •»nulc^r.a CCPAH ATIHM niCTAMPP —
(WASH
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*
G HI
r
REMOVE
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REMOVE
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GLOVES,
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COTTON
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FIELD
SHOWER
j
^
REDRESS
FIRST
AID
PLASTIC
SHEET
b
\
FIELD
EXPEDIENT
CAN
(32 GALLON)
FIGURE C-l
-------
III-5
(9/79)
FIGURE 6.2
, . •.Trrsrss**'." v-=u^, .-..^....j^vr 75"-^" ^:^SSPSV?->^
FIGURE 1. ON-SITE DECONTAMINATION OF PROTECTIVE CLOTHING
C-85
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FIRST AID
GENERAL
First aid is generally defined as the immediate and temporary care given
the victim of an accident or sudden illness until the services of a physician
can be obtained. Common sense and a few simple rules are the keys to effective
first aid.
The first objective is to save life by:
o Ensuring an open airway and maintaining breathing.
o Preventing heavy loss of blood.
o Giving first aid for poisoning.
o Preventing or reducing shock.
o Preventing further injury.
o Sending for medical aid.
The first-aider should also:
o Avoid panic.
o Inspire confidence.
o Do no more than necessary until professional help arrives.
HEAVY BLEEDING
A victim who has profuse bleeding may die within one minute or less,
therefore:
o DO NOT WASTE TIME.
o USE PRESSURE DIRECTLY OVER THE WOUND.
o Place a pad, clean handkerchief, clean cloth, etc., directly
over the wound and press firmly with one or both of your hands.
If a pad or bandage is not available, close the wound with your
hand or fingers.
C-86
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o Hold the pad firmly in place with a strong bandage, necktie,
strips of cloth, etc. Unless bones arc broken, raise the bleed-
ing part higher than the rest of the body.
o Keep the victim lying down.
o Keep the victim warm to prevent loss of body heat. Cover with
blankets, coat, or anything available and put something under him
if he is on a cold or damp surface. Do not add heat.
o Give fluids only if victim does not have head or abdominal inju-
ries, probably will not require surgery, and professional help
will be more than one hour arriving. If the victim is conscious
and can swallow, give him plenty of liquids to drink. Give him
sips and do not give stimulants.
o Call a physician.
o APPLY PRESSURE TO PRESSURE POINTS. If direct pressure and
elevation do not stop the bleeding apply pressure to pressure
points in the body to slow down or stop the flow of blood.
(Pressure points are where an artery is close to the bony
structure of the body and can be restricted by pressure
on the artery against the bone.)
o Use a tourniquet only if victim is bleeding profusely and other
methods have failed and the victim's life is in danger.
o DO NOT give the victim alcoholic drinks.
o If the victim is UNCONSCIOUS or if abdominal injury is suspected,
DO NOT give him fluids.
BREATHING STOPPED
A person who has stopped breathing will die if breathing is not restored
immediately.
If breathing is restored, victims who had stopped breathing need hos-
pitalization.
The following are major factors in breathing stoppage.
Poisonous gases in the air or lack of oxygen
O Move victim to fresh air.
o Begin mouth-to-mouth breathing.
o Control the source of poisonous gases, if possible.
o Keep others away from area.
o DO NOT enter an enclosed area to rescue an unconscious victim without
first being equipped with a self-contained or air-supplied breathing
apparatus.
2.
C-87
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Electric shock
o If electrical hazard persists-. Indoors, open main electrical breaker
if appropriate individual breaker cannot bo immediately identified;
outdoors, contact pov.-er company to turn current off.
O DO NOT TO'JCi-I the vicci.Ti vntil 'r.c is separated from the current.
o Begin mouth-to-inouth re5-js»cititio:i or cardiopulmonary resuscitation,
if needed r.nr» if trainco in thir. technique, as soon as the victim is
free of contact with tlifc curiv...-.
o DO NOT try to remove a person fron an out-of-doors wire unless you
have had special training for nl.io type of rescue work.
Heart attack
Laryngeal obstruction
Accident or drowning
VThen breathing movements stop or lips, tongue, and fingernails become
blue, there is need for help with breathing.
When in doubt, bsgin artificial respiration. No harm can result from
its use. Delay may cost the victim his life.
ARTIFICIAL RESPIRATION
General
o Seconds count. Start immediately.
o Remove any obvious obstruction from mouth and throat.
o Place victim in appropriate position and begin artificial respiration.
o Maintain steady rhythm of 12 breaths per minute.
»
o Maintain an open airway and periodically check the victim. Be ready
to resume artificial respiration if necessary.
o Call a physician.
o DO NOT move the victim unless absolutely necessary to remove from
danger.
o DO NOT wait or look for help.
o DO NOT stop to loosen clothing or warm the victim.
O DO NOT GIVE UP.
3.
C-88
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Mouth-to-raouth breathing for adults
o Place victim in supine position (on back).
o Tilt victim's head back by pressing on his forehead with your other
hand.
o Place your check and ear over the victim's nose and mouth, looking at
his chest. Look, listen and feel for breathing for about 5 seconds.
o Pinch the victim's nose shut with the thumb and forefinger of the
hand on victim's forehead. Take a deep breath and place your mouth
over the victim's mouth or nose making a leak-proof seal.
o Blow your breath into the victim's mouth or nose until you see the
chest rise; repeat these breaths 4 times in rapid succession without
allowing the lungs tp fully deflate between breaths.
o Maintain the head tilt and again check the victim for breathing for
approximately 5 seconds.
o Remove your mouth and let the victim exhale while you take another
deep breath. As soon as you hear the victim breathe out, replace your
mouth over his mouth or nose and repeat the procedure.
o Repeat this procedure of giving one breath, turning to look, listen
and feel for return of air, and blowing again, once every five seconds
(12 times per minute).
Manual method of artificial respiration
o Place victim in a face-up position but allow his head to turn to the
side to avoid aspiration.
o Place something under the victim's shoulders to raise them to allow
the head to drop backward.
o ^ Kneel above victim's head, facing the victim.
o Grasp victim's arm at the wrists, crossing and pressing victim's
wrists against the lower chest.
o Immediately, pull arras* upward, outward, and backward as far as
possible.
o Repeat 15 times per minute.
o If a second person is present, he should hold the victim's head so
that it tilts backward and the jaw juts forward.
o This method should be used when mouth-to-mouth resuscitation is ad-
vised against.
4.
C-89
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Cardiopulmonary resuscitation
Heart-lung resuscitation is an emergency procedure which requires the
ability to recognize a cardiac arrest and special training in its performance.
All training programs should adhere to the standards put forth in JAMA "Sup-
plement on Standards for CarcUopulivorsry Resuscitation (CPR) and Emergency
Cardiac Care (ECC)". 18 February 1974, Volume 227, Number 7. Information
provided here on cardiopulncnary resuscitation is not designed to supplant a
complete course of instruction und.'-r direction of a qualified instructor.
Such instruction is strongly reccn?:.f-,:.lcd for all personnel who must respond to
hazardous materials spill sites.
Emergency cardiopulmonary resuscitation involves the following steps:
o Airway opened.
o Breathing restored.
o Circulation res-tored.
External cardiac compression should be started after providing four quick
breaths and checking for pulse and breathing. If apnea (breathing stoppage)
persists, and there is unconsciousness, death-like appearance and absence of
carotid pulse, external cardiac compression should be started.
External cardiac compression consists of the application of rhythmic
pressure over the lower half of the sternum.• This compresses the heart and
produces artificial circulation because the heart lies almost in the middle of
the chest between the lower stermm and the spine.
External cardiac compression should always be accompanied by artificial
respiration. To be effective it requires sufficient pressure to depress the
victim's lower sternum 1-1/2 to 2 inches (3.8 to 5.1 centimeters) in an
adult; the rate should be once a second. Considerably less effort will be
required to achieve such depression in a child. The victim should be on his
back on a firm surface. The rescuer stations himself at the side of the
patient and places only the heel of one hand over the lower half of the ster-
num. He then places his other hand on top of the first one and rocks forward
so that his shoulders are almost directly above the patient's chest. Keeping
the arms straight and elbows locked, he exerts adequate pressure almost verti-
cally downward. The preferred rate of 60 per minute is usually rapid enough
to maintain blood flow and slow enough to allow cardiac refill. The com-
pressions should be regularT smooth, and uninterrupted, with compression and
relaxation being of equal duration. Under no circumstances should compression
be interrupted for more than 5 seconds.
When there are two rescuers, optimum ventilation and circulation are
achieved by quickly interposing one inflation after five chest compressions
without any pause in compressions (5:1 ratio). Every interruption in cardiac
compression results in a drop of blood pressure to zero. One rescuer performs
external cardiac compression while the other one keeps the patient's head
tilted back and continues ventilation. When there is only one rescuer he must
5.
C-90
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perform both artificial respiration and artificial circulation using a 15:2
ratio; two quick lung inflations after every 15 chest compressions. Periodic
palpation of the carotid pulse should be employed to check the effectiveness
of external cardiac compressions or the return of a spontaneous heartbeat.
Complications occurring from the use of cardiopulmonary resuscitation may
include fracture of the ribs and sternum, laceration of the liver, and fat
emboli.
Several rules to follow are:
o Never compress over the xiphoid- process, the lower tip of the
sternum. It extends down'over the abdomen and pressure on it may
cause a dangerous laceration of the liver.
o Never let the fingers touch the patient's ribs when compressing.
Keep just the heel of the hand in the middle of the victim's
chest over the "lower half of his sternum.
o Never use sudden or jerking movements to compress the chest.
o Never compress the chest and abdomen simultaneously. This traps
the liver and may cause it to rupture.
SHOCK
Severe injury or emotional upset is usually followed by shock. It can
also follow infection, pain, disturbance of circulation from bleeding, stroke,
heart attack, heat exhaustion, food or chemical poisoning, extensive burns,
etc. The following information pertains to traumatic, injury-related shock
rather than to emotional shock, per se.
The signs of shock include:
o Cold and clammy skin with beads of perspiration on the forehead and
palms of hands.
O' Pale face, weakness, dilated pupils, and weak, rapid pulse.
o Complaint by the victim of feeling cold, or even shaking chills.
o Frequent nausea or vomiting.
o Shallow breathing.
To prevent shock;
o If possible, correct cause of shock (e.g., control bleeding).
o Keep victim lying down.
o.
C-91
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o Keep the airvay open. J*f victim is vomiting, turn his head to the
side so that the neck is arched.
o Keep victim warm if weather is cold or damp.
o Give fluids only if victim does not have head or abdominal injuries,
probably will not require surgery, £.nd professional help will be more
than one hour arriving. Give hir-, sips and do not give stimulants,
A suggested formula is one pinch baking soda and two pinches salt per
glass (10 02.) of water.
o Reassure victim.
o NEVER give alcoholic beverctges.
o DO NOT give fluids to unconscious or semiconscious persons.
O PREVENTION OF SHOCK SHOULD BE CONSIDERED WITH EVERY INJURY.
POISONING
Before medical aid ^s_ available, the following should be done.
SPEED IS_ ESSENTIAL;
»
o Act before the body has time to absorb the poison.
o When medical aid is available, give physician all possible knowledge
available on the poison.
The nature of_ the poison will determine the first aid measure to use;
Swallowed poisons
o If victim is conscious, give water or milk immediately.
DO NOT INDUCE VOMITING (except on the advice of doctor or Poison Control
Center):
»
o If the victim is unconscious,
o Is in convulsions,
o Is known to have swallowed a petroleum product (kerosene, gasoline,
lighter fluid), toilet bowl cleaner, rust remover, drain cleaner, lye,
acids for personal or household use, iodine, styptic pencil, washing
soda, ammonia water, or household bleach, or has symptoms of severe
pain, or a burning sensation in mouth or throat.
G-92
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DO NOT INDUCE VOMITING if*"do not induce vomiting" is indicated in the
first aid segment of the chemical data sheets.
•
o Information on labels may be incorrect; contact physician or Poison
Control Center immediately for proper advice.
o Call for medical aid immediately.
o Begin mouth-to-mouth resuscitation if the victim has difficulty
breathing.
o If safe (see above), induce vomiting.
o Induce vomiting by use of 10 grams salt in 200 cc of warm water
(2 teaspoonfuls in a glass of warm water) or use 30 cc's or one ounce
of syrup of ipecac.
o When vomiting begins, place the victim face down with head lower than
hips. This prevents vomitus from entering the airways and causing
further damage.
Inhaled poisons
o Assist or carry victim to fresh air immediately.
o Apply artificial respiration if breathing has stopped or is irregular.
o Call physician.
o Treat for shock.
o Keep victim as quiet as possible.
o DO NOT give alcohol in any form.
o DO NOT become a victim by exposure to the same poison.
o Rescuer should employ appropriate protective clothing and breathing
apparatus until clear of hazard.
EVES
First aid for chemicals In the eyes is the immediate washing of the eyes
with large quantities of water. Hold the eyelids open and roll the eye while
irrigating with water. Emphasis should be placed on the amount of water, the
speed with which it is applied, amd washing the eye "from the inside outward".
Eyes should be washed for at least 10 minutes. A delay of_ 30^ seconds can mean
the difference between no injury to the eye and permanent loss of vision.
Sr
C-93
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Chemical burns to the eyes ican be aggravated by contact lenses. Chemicals
spilled in the eyes tend to accumulate under contact lenses. In addition, for
proper irrigation, contact lenses need to be removed. It is advisable not to
wear contact lenses at a spill site.
In cases of alkaline or acid chemicals in the eyes, irrigation with
neutralizing agents should not be used as first-aid treatment. Acids in
contact with the cornea will react with protein to form an insoluble barrier.
This barrier prevents penetration of the acid into the eye. An alkaline
solution does not form this barrier and is free to soak deep into the eye. If
this happens with an alkaline solution and an acid neutralizing agent is used,
the alkaline solution will be trapped under the insoluble barrier formed by
the acid-protein reaction. This will prevent the leaching out of the alkaline
solution by irrigation.
Most serious chemical injuries to eyes can be avoided by quickly and
properly washing the eyes with large amounts of water.
BURNS
General
o Burns can result from heat (thermal burns) or from chemicals (chemical
burns).
o Shock can complicate every type of burn,
o A person with "burn shock" may die unless he receives immediate first
aid.
o In "burn shock" the liquid part of the blood is sent by the body into
the burned areas. There may not be enough blood volume left to keep
the brain, heart, and other organs functioning normally.
o All burns should be seen by a physician or nurse.
Objectives of first aid care for burns are to;
o 'Prevent and treat shock.
o Prevent contamination.
o Control pain.
Extensive thermal burns
o Place the cleanest available cloth material over all burned body areas
to exclude air. Covering for burns should be a clean, thick, dry
dressing. Clean newspaper can be substituted if no clean cloth is
available.
?' 9.
C-94
-------
o Have victim lie down.
o Call physician.
o Place victim's head and chest a little lower than the rest of the
body. Elevate the legs slightly if possible.
o If the victim is conscious and can swallow, give him plenty of non-
alcoholic liquids x.o drink (water, tea, coffee, dilute salt solution).
o Move to hospital immediately.
Small thermal burns
o If SKIN IS NOT BROKEN, immerse burned part in clean, cold water to
relieve pain-, reduce inflamination. Do not apply ice directly to the
skin.
o Soak a sterile gauze-pad or clean cloth in baking soda solution:
2 tablespoonfuls baking soda (sodium bicarbonate) to 1 quart of luke-
warm water.
o Place pad over burn and bandage it loosely.
o DO NOT disturb or open blisters.
Chemical burns
o Immediately flush with water; speed in washing is most important in
reducing the extent of injury.
o Flush affected area with plenty of water.
o Remove all contaminated clothing and shoes.
o Place the cleanest available material over the burned area.
o Treat for shock.
o ' If the burned area is extensive, have victim lie down.
o Keep him down until medical aid is available.
o Place his chest and head a Jittle lower than the rest of the body
(raise the legs slightly if possible).
o Maintain an open airway.
o If he is conscious and can swallow, give him plenty of non-alcoholic
liquids to drink.
10.
C-95
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o DO NOT APPLY OINTMENTS, greases, baking soda, or other substances to
extensive burns.
ENVIRONMENTAL TEMPERATURE EXTREMES
Heat exhaustion
SYMPTOMS:
o Pale and clammy skin.
o Pulse rapid and weak.
o Victim complains of weakness, headache, or nausea.
o Victim may have cramps in abdomen or limbs.
FIRST AID:
o Have victim lie down with his head level with or lower than his body.
o Move victim to a cool place, but protect him from chilling.
o Give the victim salt water (1 teaspoonful salt to 1 quart water) to
drink if_ he_ is_ conscious.
o Loosen tight clothing.
o Call for medical aid.
Heat stroke
SYMPTOMS:
o Flushed and hot skin.
o Pulse rapid and strong.
o Victim often is unconscious.
r
FIRST AID:
o Call for medical aid.
o Cool body by sponging it with cold water or by cold applications.
o If. the victim i£ fully conscious and can swallow, give him salt water
(1 teaspoonful salt to 1 quart water).
o DO NOT give alcohol in any form.
11.
C-96
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Frostbite
SYMPTOMS:
o Skin' color changes to white or greyish-yellow as frostbite develops.
o Initial pain which quickly subsides.
o Victim feels cold and numb; he usually is not aware of frostbite.
FIRST AID:
o Cover the frostbitten part with a warm hand or woolen material.
o If fingers or hand are frostbitten, have victim hold his hand in his
armpit, next to his body.
o Bring victim inside as soon as possible.
o Place frostbitten part in warm water, about 42 C. (108 F.).
o Gently wrap the part in blankets if warm water is not available or is
impractical to use.
o Let circulation reestablish itself naturally.
o When the part is warmed, encourage the victim to exercise fingers and
toes.
o Give victim a warm, sweet, non-alcoholic drink.
o DO NOT RUB with snow or ice. DO NOT USE HOT WATER, hot water
bottles, or heat lamps over the frostbitten area.
MOVING THE INJURED
General
Do not move an injured person until an experienced crew arrives, unless
there is real danger of his receiving further injury by remaining at accident
site.
Control bleeding if possible, maintain breathing, and immobilize all
suspected fracture sites before moving.
Treat for shock.
Pulling the victim to safety
Pull the victim head first or feet first, not sideways.
BE SURE HEAD IS PROTECTED.
12.
C-97
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Lifting the victim to safety
If he must be lifted before a check for injuries can be made, every part
of the body should be supported. The body should be kept in a straight line
and should not be bent. Once victim is lifted, the lifter is responsible for
the victim's safe return to the ground/floor.
Exercise care in the approach of any "downed" co-worker or bystander
victim. Rapid action may be called for, but hasty and careless intervention
may lead to additional injury or loss of life, avoidable if a few moments are
taken to assess the immediacy and severity of the situation. Once again, the
exercise of careful, informed judgement and plain common sense is the most
important safeguard of personnel health.
13.
C-98
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-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
21 BAR BSD
Setting Priorities for Activities Relative to Hazardous Waste Sites
1+
Kenneth Z. Biglane, Director
Oil & Special Materials Control Division (WH-548)
.
Douglas MacMillanJ Acting Director
Hazardous Waste Enforcement Task Force (EN-335)
To: Regional Hazardous Waste Coordinators
Draft site prioritization criteria were distributed and discussed
in August 1979 as part of the first round of Regional/Headquarters
meetings on the Hazardous Waste Site Enforcement and Response System.
Clearly, as the number of sites on Regional investigation lists grows
the issue of risk assessment and prioritization becomes increasingly
important.
Since the development of the first set of criteria, a somewhat mere
sophisticated approach has been developed with contractor assistance.
Earlier drafts of this new approach have been reviewed with generally
positive ratings by representatives of Regions I, II, and IV and the
States of Connecticut and New Jersey.
We recommend that Regions quickly begin to use the attached hazard
evaluation system to determine which sites should receive immediate
attention. In attempting to determine those sites mosc likely to
present serious hazards to the public or the environment, the system
reflects the fact that decisions must sometimes be made on the basis
of limited information. We recommend that sites be rated using this
method after both the preliminary assessment and site inspection
phases of investigations. (Once a site has been fully inspected and
the extent of the problem has been well defined, it is obviously
necessary to reassess priorities for enforcement or response
activities. )
Given the variety of problems which might occur, it is often
difficult to objectively compare the danger or harm found at one
site with that of another. To some degree the attached ranking
system will aid in comparing severity of problems, since concerns
regarding public health or sensitivity of the environment are built
into the weighing of the various factors. Thus, the ranking system
should be employed setting enforcement and response priorities.
However, other factors such as immediacy of the threat, probability
of a successful outcome, anticipated costs, and the level of public
concern must also be considered.
e PA F°'.-n 13:0-4 (Rev. 3-76) D-l
-------
-2-
We encourage you,, to put this method into immediate use and suggest
that you compare the resulting rating scores to your own professional
iudgrr.ents regarding the relative severity of problems as verification
of this method. Any comments regarding shortcomings or the value of
the rating system will be appreciated. These may be communicated to
either Steve Caldwell, OSZ4CD, 245-3051 cr Mike Kilpatrick, HWETF,
472-3500.
Attachments
D-2
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METHOD FOR RATING RISKS AT HAZARDOUS WASTE SITES
INTRODUCTION
This document describes a method for evaluating the relative risks
to the public or environment posed by various hazardous waste sites.*
The nethod takes into account risks which include fires and explosions,
direct human exposure to dangerous substances, and contamination of
air, land, waters, or the food chain. The method presented for
evaluating such risks is to assign numerical scores to a series of
rating factors describing the wastes, waste management practices,
potential pathways or routes of discharge, and the site environs which
could be affected. The method is designed to give a single numerical
score, thus allowing comparison among sites under consideration for
investigative work or response activities.
Included in the document is a set of scoring forms, instructions,
tables describing scoring criteria, and examples based on case
histories.
GENERAL CONSIDERATIONS
The critical element in the risk evaluation method is the score
assigned for each rating factor (see number 1 below). Very specific
criteria for assigning scores are given. Since the method is designed
for use when only limited information is available, these criteria will
not be applicable for all factors at all sites evaluated. Where some
information is available, although inadequate to fully characterize the
factor considered, one's best professional judgment should be exercised
in assigning a score. If no reliable information is available, the
factor may either be ignored or a conservative assumption may be made.
A conservative assumption in this case raeans assuming a worst case
scenario (e.g. , assume an unknown waste is extremely dangerous). The
scorer must also use best professional judgment in deciding if the
number of unknown factors is large enough to render the final score
invalid.
INSTRUCTIONS
1. Assign Values to Each Rating Factor - Using the scoring fona
on the following pages, assign a score from 0 to 3 for each rating
factor. Sources of information and criteria for assigning scores are
given in Table I. For example, assume that in the site under
consideration, phenols are the most toxic substance reported in
significant amounts. Table I indicates that the Sax's Dangerous
Properties of Industrial Materials should be consulted. Sax assigns a
toxicity rating of "3" for phenols; thus, according to Table I a score
of 3 should be given for toxicity. Continuing with " ignitabi lity"
assign scores to all data elements where sufficient information is
* K o r a that this method is not currently applicable to
incine ra tors.
D-3
-------
available to form a judgment. If no information is available (*•>§••
deorh to bedrock is unknown; no surveys have been conducted in the
vicinity of the site) leave that section blank. Do not assign scores
to "additional points" at this time.
2 Mi.lElolv by Assigned Weights - Each rating factor has an
,ssioned weight representing its relative importance. These are given
"he "multiplier" column of the scoring form. Multiply each rating
factor score by its assigned weight to obtain the "site score for that
rating factor. For example, since phenols are believed present, a
score'of 3 vas assigned to toxicity. The multiplier for tox city is_
"7" Thus the site score for toxicity in the example is (3) X
-------
RATING FOR i".
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D-5
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£YI==NCS Cr CCNTAMl'.ATtCri
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SGiL r£.=^EA5tL!TY
NET PRECIPITATION
SETTH 70 SE*OC<
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8
7
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0 T A L S
TOTAL ADDITIONAL POINTS.
PERCENTAGE OF HISS IMG OR
ASSUf.ED VALUES =
TOTAL SCORE
(SITE SCORES PLUS ADDITIONAL POINTS)
TOTAL MAXIMUM FOSSI2LE SITE SCORE
2 0
SITE SEORITY -
I'JCOPATiSLE WASTES
R.VT10 C? KAZAAMUS 70 l^tt-
nAcA%3C\JS ViASTE CUA.'«i!7IES
SE A.'3 CaOITIOJ Ce CCf.TAINESS
; Cr LEAOV.7E COLLiCTIC-N SYSTET
USE OF L1ISSS
,03i7IC'^L POIfrS FCfi OTH.ES
8
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5
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n
4
TOTALS
2'0
NUMBER CF MISSING OR ASSUMED TOTAL SITE SCOPES .
NORMALIZED
(TOTAL SCORE DIVIDED 3Y MAXIKUM SCORE A.'IB "lULT|oL|ED BY ICG)
PRE=ARED 3Y:
D-6
-------
7A2L£ i_ '^7::.
SCALiS U.D SC!.?CiS OF I:* FOP-TAT ICS Toil LAC3
OF ~aL RATING r ACTORS
UT::>C -AC7G3
sou-Lei or ::;?o«AT!3:(
0 I
SAT
INC 5CA1Z
3
--•A5Tr CHAMC7S«STICS
1.
Quantity jf ° u=e
-lazardoud
.asces Weigr.e
Toxic icy '
Irvforaacisa derived
frso local sources
lazardeus Properties of
Industrial "acerlals by
S. I. Sax
National Fire Protection
Association's Gui:e on
Xaaarcous "acerials
Xesiscrv of "eric Effects
of Chaiiial Suastar.ces
Leas c.nan 299 3GO co
c-isie yaros c-jblc
Less Chan 210 251 co
COO3 C323
1139
yards
1000
Sax's level 0 Sax's level 1
or XrPA's level 0 or SFPA's
levU 1
1130 co 2370
cuolc yards
1C01 co 2300
cons
Sax's level 2
or N??A's
level 2
Creacer cl-an 2370
cubic yards
Creacer eS-an 2SGO
coss
Sax's level 3 or
NF?A's levels 3
or t
Farcicion Coe'ficiencs (see
"?arti:icr. Csefficior.cs and
3ioacf^2ulacicr. of Selecced
Organic Chcaicals",
inv.r3rj:e''.;al Selarce ana
78C.-.-'O-3g'. Vol II. SO. 5,
•Hay 1577, p. 475.)
Scientific Jua;e=e=c
Soc persistent
psrsiscenc
Saciaacc-.-icy
ISaiCiDility 3
3
Corrosivlcy
Inieccisusr.eas
Soluollity 4
Volatility *
loiorsaticn derive: fron local
sources
:;r?A Guide
Lanz's -accbooit c- Chesiscrv
V7»A Cuid,
Proposed .-C?A Regulations,
Decerser 13, 1'73.
Inforaacion derived ::oa local
sources
In;or=aci=n deriveo :r=a local
sources
CSC -ianorooit of Che=lscrv a-.d
Physics
Lass's ua-dboo'< of Cheaiscrv
Merck tr.dex
Handbook of invxron-sencal Data
on Orzanic Clericals
CSC -andbook 3f Cne=iscr-r and
Phvsics
Laic's Handbook of Chesiscry
Hancaook o: r-vlronrental Oata
an Orear.i: C.-.e=i:als
Flss.i point of
greater Chan
200°: sr Sf?A's
level 0
S7?A's level 0
pri of 6 co 9
N'oc Infectious
Cnsoluoie
Vapor pressure
less than 0.1 ra
Hg
—
Flash polr.c of
H0a? co 200°?
or ';F?A'S
level 1
.sr?A's level I
pri of S co 6
or 10 co 11
—
Sllgncly
soluble
Vapor pressure
of 0.1 co 25
= Hg
—
rlasn soi=e
of 30°F co
liO F or
N'FPA's
level 2
m
SF?A's level
pri of 3 CO 4
or 11 co 12
—
Soluole
Vasor
pressure of
25 co 73
Veil above sacl>-
grouad
Flasn point lass
Chan. 83°: or SF?\'s
levels 3 or 1
2 NFPA's Ic.-els 3 or -
pri of 1 co 3 or
12 co l&
Hlgbl/ Infect uus
Very loluole
Vaoor pressure
greater c.'-an
78 ca Kg
Physical Scaca
Incarsacion derived fros local
sources
Solid
Gas
D-7
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?.\7l!*G r ^CTCR
j».. S ^
SAT:
i
:a:lacal
eavirsr^ier.tal groups
State ar.d local eivironaental
groups
U.S. risa aad -Uldlife S«r.'ise
State deoartaer.ts of Fish and
Ga=e
-
1 to 3 alles'
1 to 2 ailes
Agriculcurai
1 co 2S Greater t.-an IS
3001 feec 0 -a :000 feec
to 1 aile
1001 feec to 0 co 1000 f«et
1 alle
Cc-sercial or ^esicentiai
industrial
— Y«s
PATHWAYS
-•.-id etc e of
ua-.;a=iaati-n
3ista-.ce ta '.'earesc
Surface .,acer
Deota to Ccouao,
•acer
Soil ?ar=eaDiiicy
lee Precipitation 3
Ir.£cr=atioa serived fron local So evidence of
sour:es coataairatioa
OSC3 :o3o;rasnic saps or Greater tnan
reports 5 ailea
yaps aad reports :roa state or
local Hig--ay 3eaartaencs or
:r:= universities or state
geolo;i:al surveys
L'SGS -.ater supoly paoers. Greater than
jround -acer aulletias and 100 feec
geologic reports
Local i.ell drillers, vaeer
suppliers, universities
(geology separt=ents) , and
residents
'.'S3A Soil Conservation Service Greater cr&n 50*
county aaps reports clay (clay soils)
L'SCS soil aaps and reports
NOAA a-.=jal •.eac'ier s^aaaries Less than -10
General precipitation and inches
Indirect
evidence
of coatasi-
sation (e. g. ,
suspicious
dead /e;e-
tacion
1 to S ailes
51 to 100 feec
30 to SOZ clay
(aosc clay
loans, silcy
clay loons,
siicy clays,
and sandy
clay3)
-10 to -5
l.-.cnes
Positive Positive proo:
proof of (i.e., creaicil
coctaair.acion analysis) a:
ac any level conta=i-jtiai at
or direct ,-.i;r. levels
evider.fe of
(e.g., cheai-
cal eaers)
1000 feet to 0 co 1000 feec
1 aile
21 to 50 feet Less thaa 20 feet
IS to 30* Less than 15* clav
clay (aosc (cose sandy loans.
Loans and silty loans, sands
sardy clay and silts)
loans)
*S "a "19 Greater t'-.an ^10
inches inches
evaaotrsnsairacian =acs
D-8
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7.A7INC -ACTC3
Depth co 3esr3Cic
3edrac!& Peraeabilicy
SOU'.Ci 3? [:.'fC3.u-MIOS
I'SDA Soil Cooservatioa
Service causey saps aed
repor:s
L'SCS sail =aps aad reports
1 Ci'SCS water supply saoers,
geologic reports
Local veil drillers, .-ate;
suppliers, uaiversieias
(geology depar:=enca) , and
resicecu
0
Greater c.ka,a SO
feet
I=pemeable
(e.g., ucfractured
shales, evaoorices
or cryscalliie
rociu)
SATING SCALI
31 to 60 fiat
Relatively
(e.g., un-
fraetured.
rairly--.eli
ceaeated
clascic
racks)
11 co 33 :eec 0 to 10 ceec
Relatively Very ?er=eable
per=eaole (e.g., carbonates,
(.e.g., well-fract.red
zoderacaly clascic rocics)
cenentes,
•-nfraet-ired.
clascic
rocks)
VASTS >UNACS!£:.T PlACTICZS
Sice Secjricy
?rsse=:e /Absence
CE laccsracibie
Wastes
?.acio e: rtasarc'cus
Vasce Quantities
Use a=d Caeeiiion
of «'as:e
i'se of ^eacnace
Gallic: ion 3vs:an
-se oc Li.-.ers
!=far=acion serived free local
!=:ar=a:iar. derivec frcn local
sources
lafcrracicn derived croc Iccal
sources
Is:'5r=acicr. derixed :r:a local
sources
Ir.fsrsacias derived froa local
sources
l.-.for=a:ica derived froo local
sources
Secure fence
No lnca=pacible
wastes are
presesc
Less t'lan 0.01
Containers are
used and appear
Co be la good
condition
Yes
Yes
Security
guard but
fence
?resent Due
soes not pose
a ia=ard
0.01 CO 0.25
Containers
are i.sea but
a feu are
leaning
~
—
3e=ote \'o barriers
location or
breachable
fesse
?reser.c ana Present and ?os.:g
=av pose a an L=;«ci2te -.azard
fucur* hazard
0.25 ca 0.50 0.50 co 1.0
Coccai-.ers ",y csr.cai.-ers are
are used sue used
ra-y are
leaking
So
So
1. 3asea or. a soecific gravity of 1.0
2. "Sax" refers Co Che bock "azardoua aroosseciatlan
». Sol-.ailicy, visor press-re. a.ie p-.ysical scace at 25° C
5. Annual preciplcacica iir.us acnt.al evapacraospiracion
D-9
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TA2LE 2 EXAMPLES Cr SITUATIONS THAT ^ECUIR-I ADD IT IO.\'a.L POINTS
/A 57 E C:-" ° ACT £?-1 S TIC S
o Substances r'lat are carcinogenic, teratacenic, or nutacenic
o An hf^h-level radioactive wastes
o Substances witn a very high bioeccurnu I at ion potential
o Priority pollutants
o Hazardous substance as defined by Sec. 311 of Clean Water Act
o Very large quantities of wastes
Quantity Additional Poinys
5,000 to 9,999 tons 5
10,000 to 19,999 tons 1
20,000 to 49,999 tons 12
50,000 to 74,999 tons 16
75,000 to 100,000 tons 20
over 100,000 tons 24
WASTE MANAGEMENT
o No training/safety measures for personnel
o Inadequate treatment systems for collected leachate
o Site abandonment
o No waste mapping or records
o Power lines near sites having explosive or flammable wastes
o Less than IS inches of cover over inactive landfills
o Less than 6 inches of daily cover
o Grading and surface water control
PATHWAYS
0 Open soiI srructures
o Erosion problems D-10
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o Slope stability problems
c Seis~,ic activity
c Severity of contanination, e.g., surface seeps on the site vs
ancnalously-high incidences of birth defects in families bordering
the site
o Surface impoundment used as an evaporation pond for volatile organics
RECEPTORS
o Use of site by nearby residents, especially children (for example,
a site nay be remote and/or fenced, but nay sti II be used
frequently by children as a play area or by adults with recreational
veh icles)
o Type-?of building nearby, (e.g., school vs warehouse)
o Presence cf najor surface water supplies or aquifers near the site
o Tyce of adjacent land use (e.g., dairy farms, rr.eat packing plants, muni
cipal water treatnent plant, etc. would cause extreme concern)
o Presence of economicaIly-rnportant, natural resources
D-ll
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0. WITNESS GUIDELINES
The role of a RCRA inspector may include serving as a witness in a RCRA
enforcement case which is brought to court. The following suggestions are
made to prospective witnesses in order to lessen the fears and apprehensions
which almost everyone has when first testifying before a board, a commission
OP a hearing officer or in a court. Even those who have testified previous-
ly encounter a certain anxiety when called for a repeat performance. When a
witness is properly prepared, both with regard to the subject matter of the
testimony and conduct on the witness stand, there should be little fear
about testifying.
It is of utmost importance that the witness be thoroughly prepared on
to the subject matter of his testimony. Only the witness can recall what
occurred in the field and why. Since many cases are tried substantially
after field activities are conducted, it is imperative that adequate docu-
mentation be originally prepared in order that a witness's memory may be
refreshed. A thorough and detailed review of all survey documents is the
only way prospective witnesses can be adequately prepared.
In order to assist witnesses on how they should conduct themselves, the
following suggestions are given.
The witness will be required to take an oath to tell nothing but the
truth. The important point is to remember that there are two ways to tell
the truth; one is in a halting, stumbling, hesitant manner, which makes the
board member, hearing officer, judge or jury doubt that the witness is
7/8/80 VII1-3 RCRA INSPECTION MANUAL
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telling all the facts in a truthful way; the otl confident,
straightforward manner, which inspires faith in whataid. It is
important that the witness testify in the latter ma;sist a wit-
ness in testifying in such a manner, a list of timits and aids
are provided below.
1. General Instructions for a Witness
As a witness in a case involving testimony concppearance of
an object, place, condition, etc., try to recoilectspecting the
object, place, condition, field notes and recordfin possible,
before the hearing or trial. While making such ar, close your
eyes and try to picture the item to recall, if he important
points of the testimony. Repeat the test until thor'iarized with
the features of the testimony to be given.
Before testifying, visit a court trial or boaind listen to
other witnesses testifying to become familiar withidings and to
understand some of the things that will come up fying. When
testifying, be present in sufficient time to heatfsses testify
before taking the witness chair. This, however, ms be possible
since, on occasion, witnesses are exlcuded from the
Listen to the questions and then answer calmtly in a sin-
cere manner. The facts should be well known so communicated.
Testimony in this manner applies to cross-examiOl as direct
examination.
7/8/80 VI11-4 RON MANUAL
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Wear neat, clean clothes when you are to testifying. Dress conserva-
tively.
Do not chew gum while testifying or taking an oath. Speak clearly and
'do not mumble. Smoking will not be permitted while testifying.
2. Direct Examination
In a discussion on administrative procedures, E. Barrett Prettyman,
Retired Chief Judge, U.S. Court of Appeals for the District of Columbia,
gave the following advice:
The best form of oral testimony is a series of short,
accurate, and complete statements of fact. Again, it is
to be emphasized that'the testimony will be read by the
finder of the facts, and that he/she will draw his/her
findings from what he/she reads Confused, discur-
sive, incomplete statements of fact do not yield satis-
factory findings.
During direct examination, stand upright when taking the oath. Pay
attention and say "I do" clearly. Do not slouch in the witness chair.
Do not memorize what is to be said as a witness. Prepare answers to
possible questions, but by all means do not memorize such answers. It is,
however, very important to become as familiar as possible with the facts on
which to testify.
During direct examination, elaborate and respond more fully than is
advisable during cross-examination. However, when testifying, do not ramble
and do not stray from the main point raised in your lawyer's questions. The
taking of testimony is a dialogue, not a monologue. If testimony concerns a
7/8/80 VII1-5 RCRA INSPECTION MANUAL
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specialized technical area, the Court or hearing board will find it easier
to understand if it is presented in the form of short answers to a logical
progression of questions. In addition, letting the lawyer control the
direction of testimony will help you avoid making remarks which are legally
objectionable or tactically unwise.
Be serious at all times. Avoid laughing and talking about the case in
the halls, restrooms or any place in the building where the hearing or trial
is being held.
While testifying, talk to the judge, hearing officer or jury. Look at
him/her or them most of the time, and speak frankly and openly as to any
friend or neighbor. Keep your hands away from your mouth. Speak clearly
and loudly enough so that anyone in the hearing room or courtroom can hear
easily. At all times make certain that the reporter taking the verbatim
record of testimony is able to hear and record what is actually said. The
case will be decided entirely on the words that are finally reported as
having been the testimony given at the hearing or trial. Always make sure
to give a complete statement in a complete sentence. Half statements or
incomplete sentences may convey thoughts in the context of the hearing, but
may be unintelligible when read from the cold record many months later.
3. Cross Examination
Concerning cross-examination, Judge Prettyman gives the following
advice to prospective witnesses: .
7/8/80 VIII-6 RCRA INSPECTION MANUAL
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Don't argue. Don't fence. Don't guess. Don't make
wisecracks. Don't take sides. Don't get irritated.
Think first, then speak. If you do not know the answer
but have an opinion or belief on the subject based on
information, say exactly that and let the hearing offi-
cer decide whether you shall or shall not give such
information as you have. If a "yes or no" answer to a
question is demanded but you think that a qualification
should be made to any such answer, give the "yes or no"
and at once request permission to explain your answer.
Don't worry about the effect an answer may have. Don't
worry about being bulldozed or embarrassed; counsel will
protect you. If you know the answer to a question,
state it as precisely and succinctly as you can. The
best protection against extensive cross-examination is
to be brief, absolutely accurate, and entirely calm.
The hearing officer, board, or member of a jury wants only the facts,
not hearsay, conclusions, or opinions. Testimony about what someone else
has told you will not be allowed.
Always be polite, even to the attorney for the opposing party.
iDo not be a smart aleck or a cocky witness. This will lose you the
respect and objectivity of the trier of the facts in the case.
Do not exaggerate or embroider testimony.
Stop instantly when the judge, hearing officer, or board member inter-
rupts or when the other attorney objects to what is said. Do not try to
sneak answers in.
Do not nod for a "yes" or "no" answer. Speak out clearly. The report-
er must hear an answer to record it.
7/8/80 VIII-7 RCRA INSPECTION MANUAL
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If the question is about distances or time and the answer is only an
estimate, be certain to state it is only an estimate.
Listen carefully to the question asked. No matter how nice the other
attorney may seem on cross-examination, he/she may be trying to hurt you as
a witness. Understand the question. Have ft repeated if necessary; then
give a thoughtful, considered answer. Do not give a snap answer without
thinking. Do not be rushed into answering, although, of course, it would
look bad to take so much time on each question that the board member, hear-
ing officer, or jury will think the answers are being made up.
Answer the question that is asked—not the question that you think the
examiner (particularly the cross-examiner) intended to ask. The printed
record shows only the question asked, not what was in the examiner's mind,
and a nonresponsive answer may be very detrimental to your side's case.
This situation exists when the witness thinks "I know what he/she is after
but he/she hasn't asked for it." Answer only what is asked.
Explain answers if necessary. This is better than a simple "yes" or
"no." Give an answer in your own words. If a question cannot be answered
truthfully with a "yes" or "no," you have a right to explain the answer.
Answer directly and simply the question asked and then stop. Never
volunteer information.
If by chance you answer was wrong, correct it immediately; if your
answer was not clear, clarify it immediately.
7/8/80 VII1-8 RCRA INSPECTION MANUAL
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You are sworn to tell the truth. Tell it. Every material truth should
be readily admitted, even if not to the advantage of the party for whom you
are testifying. Do not stop to figure out whether your answer will help or
hurt your side. Just answer the question to the best of your ability.
Give positive, definite answers when at all possible. Avoid saying "I
think," "I believe," "in my opinion." If you do not know, say so. Do not
make up an answer. 8e positive about the important things which you natur-
ally would remember. If asked about little details which a person naturally
would not remember, it is best to say that you do not remember.
Do not act nervous. Avoid mannerisms which will make it appear that
you are frightened or not telling the truth or not telling all that you
,'
know.
Above all, it is most important that you do not lose your temper.
Testifying at length is tiring. It causes fatigue. You will recognize
fatigue by certain symptoms: (a) crossness, (b) nervousness, (c) anger, (d)
careless answers, (e) willingness to say anything or answer any question in
order to leave the witness stand. When you feel these symptoms, recognize
them and strive to overcome fatigue. Remember that some attorneys on cross-
examination are trying to wear you out so you will lose your temper and say
things that are not correct or that will hurt you or your testimony. Do not
let this happen.
If you do not want to answer a question, do not ask the judge, hearing
officer or board member whether you must answer it. If it is an improper
7/8/80 VIII-9 RCRA INSPECTION MANUAL
£-7
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question, your attorney will object for you. ' Do not ask the presiding
officer, judge, or board member for advice.
Do not look at your attorney or at the judge, hearing officer, or board
member for help in answering a question. You are on your own. If the
question is an improper one, your attorney will object. If the judge,
hearing officer, or board member then says to answer it, do so.
Do not hedge or argue with the opposing attorney.
There are several questions which are known as "trick questions." That
is, if you answer them the way the opposing attorney hopes you will, he can
make your answer sound bad. Hare are two of them:
"Have you talked to anybody about this matter?" If you say "no," the
hearing officer or board member, or a seasoned jury, will know that is not
right because good lawyers always talk to the witness before they testify.
If you say "yes," the lawyer may try to imply that you were told what to
say. The best thing to say is that you have talked to Mr. ,
your lawyer, to the appellant, etc., and that you were just asked what the
facts were. All he wants you to do is simply to tell the truth.
"Are you getting paid to testify in this appeal?" The lawyer asking
this question hopes your answer will be "yes," thereby implying that you are
being paid to say what your side wants you to say. Your answer should be
something like, "No, I am not getting paid to testify; I am only getting
compensation for my time off from work and the expense it is costing me to
""be here."
E-8
7/8/80 VIII-10 RCRA INSPECTION MANUAL
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4. References
In addition to the above suggestions and guidelines, several additional
references are available for further background:
Expert Witness and Environmental Litigation, J. L.
Sullivan and R. J. Roberts, Journal of the Air Pollution
Control Assoc., April 1975, Vol. 25, No. 4.
Environmental Litigation and the In-House Engineer, F.
Finn; R.C. Heidrick; K. Thompson, .-Journal of the Air
Pollution Control Assoc., Feb. 1977, Vol. 27, No. 2.
Essentials of Cross-Examination, Leo R. Friedman, CEB
1968.
7/8/80 VIII-11 RCRA INSPECTION MANUAL
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EXPERT WITNESSES
AND
ENVIRONMENTAL LITIGATION
J. L. Sullivan and R. J. Roberts
The University of Western Ontario
Eirrironmofilal logMallon to deiretepho. rap«dr». to addition. ecnsld-
erabto attention to being *»•« '» IJ>e emlronmenul Impact o« now
lochnoteolcal de»o*opm*ntt. &jv.imment* at ««d •• clUiens,
often through organtied group* •/• placing unprecatienlod proa-
•ure* on many Industrie* end even on other parU ef !f.o go«em-
rnonL Pupu't- feeuVig ha* b««n extranet? ttrong en cuch mailan
•nd mWanco 10 far haa not boon strong. Thto Is Ifcorr »o change
•ubctantlaOy and tho lulufO mil »ao a rapid Increase to the num-
bor of omlionmonUI suHa ofaodafiy If In* conUnuod aiMenco of
cerlaot kiduatrloa to thiaatoned. Eipwl o»Woneo wffl IM noodod to
tupped gmoinmort laglalatlen and to tupport aetlona to proMnro
KM •mrfrormont 8«ch measure* crtll ha«o hortUWo oeonemle tov
pOcaUona and wM ««0k« pradeiaMo lOfpensoo. RaconcUig Uiaw
liavpeMa «a provide a chatango lor the eommunHy which <••
protubty depond to a larger «*>ont en Marpratal!an to courta of
tow. Tho tOUi of .artou. a.parta to e>o adrieo ihroogh tfi* toqal
preeoM «rfi bo •***# H ma mort aff«ett»« compromlto* aro to
b* found. » to Bio pwpoca of IMa P«paf to tBacuM lha aalhortng
end uaa cl net) •otonttno o»h!onc« to omtramMfltal lavrtuRa.
Environmental Initiation ii developing rapidly. In addi-
tion, eon»ld*rabl« attention Ii being given to the environ-
mental Impact of new technological development*. Govern-
ment* »» well u cilizsni, often through organised group*
are placing unprecedented preuurat on many Industrie*
and even on other parU of the government.
To a gmt oiunt. praoenl formi of leglilation itill re-
main to b* tenttd and to prove their efhctlvoniu. Authori-
tie* on the whole have ««ed with retlralnl and »here proa-
April 1873 Volume 25. No 4
ecutions have been launched the causes ha*e betn clear As
a result, «uita relating to environmental pniblems ruv*
been comparatively few and in many cases have not he*n
vigorously contested. Companies faced with prosecution.-.
by governments for breaches of regulations have olien ad-
mitted responsibility and received nominal punishment, .n
many cases, these settlement! are pruate and unr-omled.
Because of this dearth of luxation the need for eipert
technical witnesses ha» not been fell very stron«l% and
comparatively little experience has been gained in the envi-
ronmental area.
This situation is likely to change substantially in the rut-
ure. Aided by what can only be retarded as an astonishing
emergence of public awakening, environmental group* have
scored major victories. These hav«. in sorao ccses. Bad pn»-
found financial implications. Stronger government pro-
grams in air and water pollution control are also oeginmng
to have more impact and to threaten the future ecwmaiic
well-being of some industries. A» these trends continue ana
as more developmental projects «r« ilapped or delayed o>
environmental actions there are bound to be mow vyjorou*
reactions from industry and other organizations.
The resulting upsurge in litigation will «mprta»«e the
need for more technical esperta to a»u»i in pniMOini:
knowledge of the implications from both the en\ irunnwnia
and the economic pointa of view. A« kinds of expert, will
be required. Until recently. It could »» airno.1 Uken lor
zranted thai eipert wilneM«« In environmental liti«ati«ii
would bo enginwr. or chemUu. Tho lypw ol ca»e. wnwh
PnifeHor SuMlvan I* on \ta Fccully ul t1
8cl»nc« *nd Pw/«Mr Rot.ru I. <* J»t Kscull* u
Univ* rauy at Wwlem Untaf w. URU.IO, C«n*i».
E-10
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occurred were usually related to specific problems. How-
ever, in the past few years the question of the environmen-
tal impact of such developments as the supersonic trans-
port, new airports, pipelines, power stations, dams. etc..
have brought about marked changes. Biologists, ecolcgisu
and social scientists have become involved in legal tuita
often through a sense of commitment concerning the istues
in dispute.
Expert Testimony hi Environmental LJUoatton
el Technical Expert
(i) Who may qualify at a technical expert—and haw to
find him. Generally, anyone who is "qualified by some spe-
cial skill, training or experience"1 can be an expert witness.
"(T)he witness must have sufficient skill, knowledge or ex-
perience in that field or calling as to make it appear that
his opinion or inference will probably aid the tner (of fact)
in his search for truth."1
It is not essential that the witness be a scholar or spe-
cialist in his field. "The knowledge may in some fields be
derived from reading alone, in some from practice alone, or
as is more commonly the case, from both. While the court
may rule that « certain subject of inquiry requires that a
member of a given profession, as a doctor, an engineer, or a
chemist, be called, usually a specialist in a particular
branch within the profession will not be required."-1
The question whether a person qualifies as an expert in a
particular field is a matter for the discretion of the trial
judge. For this reason—and also to enhance the credibility
of their expert in the eyes of the trier of fact—most envi-
ronmental lawyers choose to err on the side of over-qualifi-
cation. They avoid the physicist or engineer who is a mem-
ber of a concerned citizens' group and wants to volunteer
his services. "A fellow who is just a volunteer, who does not
have practical experience in the field, may be damaging as
a witness because of weakness during cross-examination.
He may be vulnerable as to his academic experience in the
field, as to his practical experience in the field, or as to his
empirical study of the problems at hand."4
When finances permit.1 environmental lawyers will tend
to select their technical experts on the basis of "academic
credentials (to initially impress the judge or the decision
makers), professional experience, and attitudes."6 the lat-
ter quality referring to the ability of the expert to refrain
from coloring his testimony with socio-economic judgments
adverse to the lawyer's position such as. "Industry should
not have to do this.
Where to find these technical experts? There are many
sources. Government agencies such as the Ontario Ministry
of. the Environment have a number of highly qualified
technical experts who are their employees. However, while
the government may find these experts useful in its own
cases, tnere may be drawbacks to their usefulness to pri-
vate litigants. For example, in Ontario it is virtually impos-
nble for a government employed technical expert to testify
ThTonE!,mplM" c'thi" t:" !cope of his "»Ptay™"t
The Ontario Public Service Act' provide, that every civil
servant must take an oath of secrecy that "except as I may
be legally required. I w.ll not d.sclose or give to any person
.nylnfom,at,on or document that come, to my knowledge
b, eSm1 V ttU0!1 °f my b6lng ' elvl1 »"«"t."" Slml.
tar prohibitions may also restrict the availability of experts
who are employees of private Industry. •°"lly Ol "*"*
Man fertile Heidi In which to recruit competent eipert
314
witnesses include university farurun. private pranu »>n»n
consulting engineers, recent retirees from cowmmrni *nd
industry, and authors of technical books and articfe* M.nv
professional and technical sooetiea mainum rmi»n „<
their membership by specially. Societies m Canada m«m
taming such lists include, inter alia, the Chemical InMit.rt*
of Canada and the professional engineering a-aocuuoo, «w
many provinces.*
Finally, it has been suggested that when an environmen.
tal lawsuit requires more than one technical exprrt. it » ad-
visable to "have one expert find another. You need torn*.
one whose judgment you can trust, because there an • lot
of people, particularly in the air pollution field, who hold
themselves out to be experts but who are just tembU at it
... One precaution, when you find your first good expert, a
to give him the job of finding experts in related fields. He
can do a much better job by checking profeiMooal reputa-
tions in the scientific community than you can by lookinc
at a resume."10
(ii) Delineating the field of expertise. Many environ-
mental lawsuits do require the services of more than one
expert witness. They contain a range of technical issues
much broader than the ranee of competence of any one ex-
pert. "The man who knows about radioactive emissions
may not know about dissemination in the soU or the atmo-
sphere; and those experts who are knowledzeabie about
dissemination may have no expertise in the health prob-
lems raised by the emissions. And so it goes down the
line.""
As a result, it is necessary carefully to delineate the field
of expertise of any one expert before he takes the stand.
The opposition can open a sometimes fatal weakness in the
environmental lawyer's case if the tatter's expert offers an
opinion in an area beyond his competence and then is made
to look a fool on cross-examination. Karaganis suggests
that to avoid this possibility, the lawyer should M(b)ncg the
experts in for staff conferences, for allocation of research
functions, and have them try the case to (the lawyer) and
to one another. One of the best methods of finding out the
weaknesses in your case is to let a scientist posit hu find-
ings before a group of friendly but critical colleagues.
Weaknesses will become very evident, and. believe me. pol-
lution cases are not always solidly on the side of the (plain-
tiff) and against the defendant. The defendant very often
has some good arguments."12
(iii) Limiting /actor*. Perhaps the moat significant limi-
tation on the lawyer in his choice of expert witnesses is fi-
nances. It has been said that.. "(c)ompetent experts will
run between four and six hundred dollars a day."11 and
that "(s)everal hundred thousand dollars is not an uncom.
mon expenditure in tho development of environmental tes-
timony. Such testimony is little different in terms of the
money spent, because of the complexity of the isauen in-
volved, from patent litigation. Those ... who are familiar
with the development of experts in patent litigation know
how costly it can be We estimate that the coil of ex-
pert testimony in our big cases will run between twenty and
thirty thousand dollars psr case,11"
If there ara no funds from which to pay these large wit-
ness fees, the environmental lawyer may be required to foil
back on concerned cluunY groups and conservation orga-
nisations for technical experts. Aa Sive points out. "there
are numerous experta mho are willing to contribute th»ir
time without charge becauM they are< dedicated to tna
causa of conservation. The dedication axwU to an inspiring
degree among surprisingly large numbers of espwi physical
Journal ol m» Air Pollution Control Asscc:anan
E-ll
-------
•nd ineul scientists and other* who we officer*, employee*.
or merely members of major coiuervaiion organization* or
citizen*' groups... "" The lawyer must keep in mind, how
ever, that volunteer eiperu obtained through these chan-
nel* may be particularly vulnerable during the croM-eumi-
nation. To avoid opening weaknenaes in hu came, the lawyer
should take tpecial care to delineate these persona' field* of
expertise and itay within theme bound* during direct exam-
ination.18
It is possible that in important cases, tome members of
university faculties and others might be persuaded to testi-
fy without compensation. "Expert testimony in an impor-
tant environmental litigation u a mark of prestige in al-
most anyone's curriculum vitae It is no derogation of
the nobility and selflessness of those who have given many
whole days and weeks, with no or ridiculously small com-
pensation, to point out that such recognition may be help-
ful to the expert witnesses in intangible ways."17
ForKttans elite Technical Expert
(i) Pre-trial. In complex environmental litigation, the
technical expert can fulfill a variety of important functions
at the pre-trial stage. For this reason, the wise lawyer will
retain hu technical experts as far as possible in advance of
the actual trial.
First, having his experts available early in the proceeding
gives the lawyer a chance to make effective discovery
against the polluter. The lawyer can be educated by the ex-
pert about the details necessary to make discovery effec-
tive, such as the nature and history of the industry in-
volved; the technology available to correct the pollution
problem; efforts, if any, by the industry to alleviate such
pollution; the physical and chemical nature of the pollu-
tant; the potential sources of the pollution within the of-
fending plant; and the short and long-term biological ef-
fects of the pollutants. If the experts are not available to
assist in discovery, important areas of investigation may be
foreclosed.
Second, the expert brought in at the pre-trial stage of the
litigation also has time to marshal! hard evidence that may
prove indispensable at trial, analyze the data already col-
lected, and m»lce recommendations for additional research
or testing which might buttress the case against the pollut-
er. The importance to courts of such hard evidence is high-
lighted in Bom Coal Company us. Air Pollution Commis-
nan. Commonwealth of Pennsylvania >* In that case, the
air pollution commission issued an abatement order which,
in effect, required the coal company's coke ovens to shut
down. The coal company took the Commission to court. In
court, the Commission presented as its chief witness one of
its own air pollution control engineers. In the words of the
court:
Thi* engineering uiitneii teitified. in addition to hit
qualification*, to a uuit to the teene of Bart*'* take
ouent . . and to hu abtervatiant concerning the emi*-
lion of tmoke from the operation of Horti'i coke oven*
From hit observation*, he leitified that the tmoke
emiiiiont unre;n eicen of the permmible allowance of
tmoke a» eitabiiihed by the Commimon't regulation
utillting the Kingelmann Smoke Chart... '•
Those observations were r*jactad IMCHUM the Commis-
sion's expert did not have any hard evidence to back thorn
jp. Tha court said:
The pioblem oritet in that thii uitneii. although ed-
mitttdly an r*prrt. far thf purrm** ••/ thit <•••. ' i ,im
not meke any ttaek Ittlt. nor aid he ulilitr an-, i /»» u n, ,*r>ail
matter To permit thf Commtuunn In nroVr an n>»itr
menl bated tolely upon the iitual tr*tm itnkr* • • .*,
heart of fairneu *°
Third, the sooner the expert h ahle to impart In lh» U«
yer a thorough understanding of the problem* in thf <-a**
the more successful th« lawyer i* hkrly to be in {<*rm\i>r\irat
snd developing an effective trul siralrgy to irapi*n»rni in
the courtroom. A thorough undemanding ol the lechm.!.*;
ieal problems involved can be invaluable la the law.fr in
deciding nfvat hard evidence to pment. who mhnuld br hit
witnesses, the question* to ask and how far h* tiXMiM c" m
cross-examining the witnesses fnr the other *id* On ;hn
score, it has been pointed out that in environmental .VI.M
lion it is necessary "that the attorney be a* exprrt a«. »r
more expert than the expert."
Lastly, the expert must sit down with the Uwvt* m a
pre-trial conference and carefully prepare ha own rfinrct
testimony. The lawyer will "try to have the expert mil-pre-
pared to present his subtle theories in ta articulate at'J a»
concrete language as possible. The more vogue and ethereal
such testimony is, the more likely it is thai the oppuiiUon'*
attempts at dension will be complemented and thus fur-
thered, by the general psychological effect the witn«-u has
on the court-"41
This is also the point at which "clashes of temperartrr.ts
end techniques"7-' ere resolved. "Such a conference ac-
quaints both lawyer and witness with their rc^p-ctiv*
methods of presentation, the issue* considered rrunni -u»d
the questions to be asked—in short a complete rapport re-
sulting in a smooth convincing presentation.**
(ii) Trial. At trial, the technical eipert has twit pnaci-
pal functions:
To give testimony interpreting thr meaning of t»chru »l-e_;euly
causing pollullun with plainuir* claimed injury (rum tnet
Ar.il '975
Volume 3S. No 4
S5S
E-12
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pollution ~" Thru* pr'ililem* can «ri»c in a variety of con-
Uil*. for rumple, showing thai air. water or notse pottw-
Imn trim the defendant '• operation and not the operation*!
of hi* neighbor* rained I he injury, thowina thai an oil tltrk
whirh damaged bvarhm or property came from a particular
•hip: or ihowing thai health problems mulled from the de-
fendant's pollution and not from dmeMe In tueh cirrurn-
stances Ihe technical ripert may prove invaluable In either
fingering or exculpating the defendant aa the responsible
party.
Kor example, in Rumftl Transport Lid vs. Ontario Mai-
Irablr Iran.1'' technical expert* uaed carefully gathered and
documented evidence U> prove that pollutant* emitted into
the air from the defendant1* foundry nperntinn caused the
plaintiffs injury. The plaintiff corporation opersb-d • new
car itnraee yard adjacent to thia foundry A short while
after commencing operation! at thi» location, it came In the
plaintiffs attention that the paint on a number at can in
the yard waa becoming pitied and corroded. When a chem-
i»t inspected (he danwge on lome of these cam, he found
particles which were determined through microacopic ex-
animation to be "red iron ru»t. black iron icale. while cast
iron, chilled caat iron, grey cait iron or malleable pearl caat
imn particle*, tome of which were spherical in form, and
manganese sulphide crystal.... panicles incident to found-
ry operation*."* To ihow conclusively that the-e panicle*
came from defendant'i foundry. »pecial panela of ateel
painted in the same way as the can-*7 were exposed in vari-
ous pana of the plaintiff* premise*. After forty-six days
the panels were examined and showed marked pitting. It
won found that "(t)he pl.ites »hi«.h were exposed in areaa
on the plaintiffs properly more remote from the defen-
dant's plant show that the surface waa affected to a lesser
degree."*
CauMtinn difficulties requiring the assistance of experts
also have arisen in disputes over oil spills. For example, in
United Statn vs. Tanker Mamutan.n the evidence of an
expert witness showed conclusively that the Mnntoon did
nut cause an nil spill that fouled a part of the Piscataqua
Iliver in New Hampshire, despite substantial circumstan-
tial evidence indicating responsibility. The Coast Guard »-
ceived a complaint of an mi spill m the river just as the
Mimiaan wan finishing ducharicmg a cargo of No. 6 Bunker
Oil at a terminal in the same vicinity. There were no traces
of oil around the Monsoon's hull or the pier, but she waa
the only tanker at any of the terminals and the spillage waa
N« 6 oil. On this basis, the Mnruoon was charged by the
Coa»l Guard with a violation of the Oil Pollution Act10 and
required to pint a SIO.OOO bond and arrange for the clean.
up of the pollution at her own expense before being permit-
ted u, set sail. At trial, chemical analysis of an expert
"showed conclusively ... that although the oil spillage w»
No. 8 oil. it was special Navy oil. an irony which was not
pursued-and not the commercial grade carried by the
Monsoon.
The testimony of experts on Ihe Issue of causation can
become crucial In dealing with suspected Injuries to health
from environmental hazards which are sophisticated and
i.ot easily traced. There has been recent eminence with
this In Toronto In connection with hlgh-leid hlood levels, a
condition which causes brain damage in children. In OHIO.
da Metal Company Lid. vs. MatFarlane." ih. Ontario
Ministry of the Environment Issued two stop orders essen-
tially shutting down thg plants of the Canada Metal Cora-
pany and Rolo-Caat Limited. "The stop orders war* Issued
Irainediatily tftcr data showln3 some high-lead blood lev-
els In persons residing near the Canada Maul plant had
IM
beoti rerirved by the Aw >fa«icrnn» u B»«/i.
City nf Tnmwta's UedmJ OrTirv* at HM|.H •
the stnp order. we*, q^ttrwd b, t*. >«c~~ i
saw after I>r H«nn.t(* Sn. . u*d ..p^, ^
dWerwtenu taMrn«( MI ihe rnmc*M« r»h.ir T>
uy of the RmnromneiM did ant pnmM MV •«4>m
fly in MiutUl. rttntmn* to n»fr upon M •fT»(a*ti .j
n>rtor at the Air KaiMxumral hrsmrft oco»t » «
' H **.i~-
..,„ .w i S,
| „
^ pi«M
-i
rwer's report "thet sod.
surveyi in the vinmly el ib. Cm**
hod shown knrtk of iMd emaiMerahry m
found m nonMJ urtan emwMOMM. -" The
misted thw report. Mrin*. -\*hsj« powMe
value it Uier* in the wenis -meu^mV* m ew«. o/
found in the nntntt urban emnranmrnf* Th»r. «n
idence as to what the lr*d Irvvts w^.
menu let alone what the deponent a> ku own
M a. a normal urban ermranawnt. To My that bed **.
m the soil, vcrtalion snd amtneiM air m the. wmiv «t the
Canada MeUl PUnt were in .sre*. d trme f«,«i ,« .
normal urban environment, whatever that moam. «» aa-
soluuly werthleea.-* The ceurt *i>o r^rrted » «t«:ou«o.
liaJ. evtdencs) eitad in the •fTidavn of bhod UHMJI tjim hv
Dr. Cordon Slopps, Senior Conmhaal. Knvwnm^ntai
Health, for the OnUno Miiustr* at Hearth. -(Tine r-«rt
laid great enpha*» on the fact that, at 725 pertom u-«*-l
"22 were in effect found not to have uawfe blond Uad >*r.
els. In other wonia. on the baia at the aflida-nt. 39 fr\ at
those tested living in the vxvutv of the ple&t showed no
unsafe blood lead level*. Even the Neeons for h*h I
level content in the three penata wm a:tnbwta«4e
some cases, to other causes."
It is not unusuaJ for expert witnesses to be called UPITA la
testify whether there b technolocy avaiUbt* whxh B at*.
bie of averting the polluttoo problem in quMion. S>xh im-
timony can make or bresJi a case wen aa a nunanre action.
when the relief sought ia an iniunctien *ztmn emiUiat tb»
offending pollutant. In the absence of technology neaor*
of controlling the pollution an injunction might resutt in
closing down the plaat and throwinsr Ur«« Qumbm ol two-
pie out of work— a prospect same courta find unthinkable.
The problem aa it esuta in many courts ia the U.S. was put
this way:
(The pntreulor) mua aUo tiUH* tkai Iccnita/ixy rfi*n: to
rnjotn major economic attiuttitt I am ntmntty dmititg
witn our industry m JUineu uhie* emptoy* *Uw* tkou-
land ptoplt. Ther* u not murn du0ule aecul lAr /.«»
that they art raiaiiv; teriout tnmnamnnal dtgroda-
tion. Wt demoiufratrrf ttiu to «A« rou*. nut tnr n>ur«
timply laid to ui, "If you tnink list muv ntotufh tu p*i
ttfven Ikouiand uiorHtn cut e/ BMV*. yasi>v <«df\ m».
taken. "...Th* rait of tk» putiit pnuerufo*. Aoti*t»r, M
fo do tiMrythint pouiof« la euawnaie tttt eeuuian
lourti. 7>us. in Utieu of proa/. (A* ta praMew i. n
proving thf pollution 6u< iht***«4 tkat (erflne
of curing the palluikm probbxa b &BM Important lo Can*.
d!an courla. though painapa to • ka*sr •naat than in ihe
Journal ol ttw Wr Peftution Control Aiiocuaioo
E-13
-------
U-S- Before iuuing a preliminary injunction, i.e.. a tempo-
rary injunction again*! emitting the offending pollutant*.
Canadian court* follow the traditional American approach
of "balancing the equities." a process which necessarily in-
volve* consideration of the overall social and economic ef-
fort* of such action. Some Canadian court* have applied
the Mine principles in determining whether to ianue a per-
manent injunction. The importance that the*e courts at-
tach to knowing whether there in technology available ca-
pable of alleviating the pollution problem is illustrated in
the opinion of MacOonnell. J. A., in Bottom vs. Ontario
Ltaf Tobacco, where he stated:
The defendant '* factory, employing it u taut tome two
hundred men, hat been equipped with every known de-
vice for preventing the escape of fume* and smells: it it
impossible to avoid the discomfort caused to the plain-
tiff without stopping the operation of the factory alto-
gether: to grant an injunction prohibiting the prevent
nuisance would mean the closing of the plant, resulting
not merely in loss to the defendant but in unemploy-
ment disastrous to a small community . 1S
The court substituted money damages for the injunction.
On the other hand, there have been Canadian cases issu-
ing permanent injunctions against pollution by large indus-
trial operations without even considering whether technol-
ogy exists capable of alleviating the problem. A classic ex-
ample is the case of McKie vs. The K.VP Co Lid.17
where the court, with no idea v' -ther technology capable
of curing the pollution problem j available, permanently
enjoined a kraft paper mill in the Town of Espanola "from
depositing foreign substances or matur in the Spanish
river which alter the character or quality of the water flow-
ing over the lands of the plaintiff." M In so doing, the court
apparently followed the English tradition in granting per-
manent injunctive relief which eschews as a function of the
legislature and not the judiciary consideration of the ques-
tion whether the exercise of the rights of the plaintiff
should be subjugated to the economic interests of the de-
fendant or the community. Several other Canadian cases
have taken the same tack.
A noted Canadian authority suggests that this apparent
conflict in the approach of Canadian courts towards issuing
permanent injunctions is tending to resolve itself in favour
of the English tradition.'19 But even if this prediction
proves to be correct, Canadian courts cannot help but be
influenced by the potential economic impact of decisions
affecting major industries. It appears that for this reason
alone, the expert witness will continue to be called upon to
testify whether technology exists capable of curing the pol-
lution problem under examination.
kVcech of Irrasalon Standards
Ona of the least complex issues calling for the evidence
of a technical expert is tha question whether a statutory
•mission standard or regulation has been breached. The
lasua la usually cut-and-dned—was the level of the pollu-
tant greater than that prescribed in the standard? The ser-
vices of an expert are required because many pollutants
cannot be dttected and measured without sophisticated
equipment «nd technique*.
For example. In air pollution cases it la often necessary to
undertake stack sampling, a complex technique for deter-
mining whit pollutants are emitted Into tha air An access,
usually an outside Uddar, mutt bo trect«d along; th« «ido of
tha irooka itMk. Than an opening of approiimately U In.
April 1978 Velum* 26. No. 4
in diameter must he mad* into Ow walb of thr .t*ck >n
order to insert the pmb? Once the moke » roll* ini n
mu»l be analyzed in • laboratory to determine if *nv -uiu
lory limitations have been exceeded. If the plaintiff rf.»»
not have occes* to the slack, he may undertake • n.nipin
testing prop-am wing elaborate equipment *t thv rwnvir.c
end of the pollution. Thi* a what Umk place in the Ku*Mfit
Transport cane.4" where an analyst* of the dual drpt-ii* «l
the receiving end proved that the defendant wa* ropmui.
ble for the damage.
Some testa which appear relatively simple to perform
create many problem* when a layman attempt* to prcwnt
the results as evidence. One of these drnptivrly v.mpJe
testa involve* the measurement of smoke dermtv twins u
Ringelmann Chart. The chart cornprxes a number of *had
ed squares which represent various densities of mn»ke Th*
instructions inform the operator that he must stand with
the sun at his back, hold the chart at arm's lenicth
-------
eluded that there was no injury, (hat the complaint* of the
newhbon were the result of suggestion or attributable to
causes other than the fume* from the plant.
The stele flinched lU MM with teilimony from medical
experts which not only linked (he ailment* complained of
by the neighbor* with the rumen from the plant hut aim
suggested that the absence of «ymptom» in other* did not
mean that they were unaffected. Three different medical
doctors testified that they had examined a number of the
complaining neighbor* and their laboratory tent* confirmed
thai these people were suffering from pancreatitis, an ail-
ment that can damage the pancreas and lead to diabetes
One of these expert* testified that "r rrtl n.
Isle expert* might be calM upon to ettinwce tnr dmp m
market value of property which ha* detomntrd ,«r~,
physically or aesthetically at the rmnri* nl the oVfcndanl -%
It n importjint to diMingunh the question of Aira*t«
from the question of injury. SomeUmen. the failurr of s
lawyer or expert to separate thrs, Mue* in h» own mind
can affect the witness* credibility mulling m harm to th*
lawyers case This M particularly (rue in caMm whrn- inpirv
lUelf is in dispute—there n no lou to menurv in terms of
cash if there i» no injury Fur example, in Kama Klrtlnc
Cooperative Ltd vs. Ciuhard."* an expert witnru who ap-
parently failed to distinguish damaeri from injury testified
at one point that "(Me did not think the value of any ml
estate w ever affected by the appearance of power lines."
At the same time, he "put the before and the after VS.'UM
(of the farm affected by the power lines) at &S1 700 and
SS0.1SO total damage of $1^50.- Needles, to say. the elec-
tric cooperative that called him as lU expert witne» lest
the cane.
The usefulness of a technical expert at trial » nm con-
fined to giving testimony. The technical expert LI alto use-
ful as an advisor to the taw>er throughout the course of the
trial. Having his expert "on call for momentary advice on
technical points ... particularly when rureimng the op-
posing expen'47 can be a boon to the lawver faced with un-
anticipated evidence or a response he doesn't quite under-
stand.
Also, keeping the technical expert on hand throughout
the trial facilitates communication between the lawver and
expert so that &t the end of the trial day. they can quickly
"recap the events of the day. discussing ways toatrvn? n*n
the weak areas and capilalixa on the strong points thus far
developed. "**
Moreover, the technical expert who ia available to ob-
serve all of the proceedings at trial prior to taking the stand
will often be able to present his evidence mo--» effectively
This is usually the COM when the opposing experts testify
first The technical expert then has an opportunity to un-
dersUnd the techniques used by the other ud« for nunplex
measurements such aa calculation uf i-pnmum chimney
height. Technical witnesses who take the stand witKtiut un-
derstanding the techniques used by tho other ud* may wrll
give testimony which will serve only to confuM the cuun
and unjustifiably cause them to app»cr incompetent.'"
" r i-t-iai Hi Tirum minm,
The testimony of • technical expert ka wnrthkw if it u
not believed, and. In finenJ, mott courts are inclined to be
skeptical of expsrt opinion. As a result, the cndibiliiv of
(he expert fcecnmea a major laaue in atonal ewry nue. The
lawyer for the other tide can be expected to prud un cnw
examination ewry aspect uf the Iwhnical expert's prrttn-
" If he finds • fUw he will r«Ur.tUuly pursue it in
Journal o< the Atr Pollution Control Atsoci4i
-------
an attempt la hurt irreparably the caute of the ude that
called the expert. Such flaws art commonly found
In the manner in which the expert present* hi» testimo-
ny:
In the use by the eipert of dubious testing equipment or
procedure*; or.
In a conflict between the testimony of the expert being
exami..«d and the testimony of another expert.
Some expert! have be«n *o emotionally wrenched by such
attacks that they are paranoid about taking the lUnd
again. This need not ruppen; the credibility i»ue may not
be a stumbling block to success if the lawyer and hia eipert
properly prepare before the latter lakes the itand.
It is no aecret that generally couru do nut truxl the opin-
ion of technical expert*. Thia bia* ia aptly illustrated in
cues where court* have been confronted with conflict* be-
tween the scientific evidence of expert* and the practical
evidence of lay witnesses. For example, in Southern Cana-
da Power Co Ltd vs. TVie Kin*.tl the Supreme Court ap-
proved a lower court judgment in which lay testimony of
residents in the area as to the cause of a rush of water and
ke that washed out a railway embankment was accepted
over conflicting expert testimony as to causation. Mr. Jus-
tice Davis stated in his opinion that it could be appreciated
if the trial judge has d.sregarded the expert opinion and re-
lied solely upon the testimony of the lay witnesses. Similar-
ly, in Canadian Copper Co. vs. Ltndala." the Ontario
Court of Appeals affirmed a trial court opinion preferring
the testimony of e>e witnesses that crop damage resulted
from sulfur fumes from the defendant's plant over the tes-
timony of technical experts that the damage resulted from
disease and not the sulfur fumes.
In cases where both sides present expert evidence, this
natural bias against trusting expert opinion can crystallize
into complete rejection of the opinion of one side's expert if
there are flaws to be found in his presentation. Even the
expert's looks, mannerisms, and speech are important.
They may be attacked if the oth«r side believes that they
fail to convey an image of competence and sincerity. As
Sive points out, "(o)ne of the most significant... problems
involves the degree to which opposing counsel will attempt
to portray the witness as a composite of several objects of
derision, among which are the feminized male, the un-
worldly sentimentalist, the professor who has never met a
payroll, the enemy of the poor who need more kilowatts
and hard goods, and the intellectual snob."*3
The expert's attitude on the stand may also destroy the
impact of his testimony. If he appears to be arrogant or ar-
gumentative, he risks having his testimony discounted alto-
gether. An example of tho harm assuming »uch a stance can
do occurred in AtcKte vs. The K V P Company Ltd M In
that case, Mr. Justice McHuer, complaining that some of
the expert witnesses called for the defendant found It diffi-
cult to distinguish between tha function of a witnesa and
those of an advocate, rejected outright these witnesses' sci-
entific evidence. He took refuse in Ota opinion of Sir 0. J.
Turner, L.J. In Goldimith va. The Tunnbrtdqe Well* Im-
provement Co/n/mifioncr*** which stated. In effect, that
with all due resp«ct to scientific gentlemen their scientific
examination mus( nova depended much on the slat* of cir-
cumstances which existed et the times of Investigation, the
force of the stream, the state of tha weather, etc. On this
bails, he concluded that these expert*' scientific evidence
was sacoirflsry to other evidence u to the fact*.
Tha credibility of a technical eipert may also he under-
mlnod on crou-eumlruiUon If the other side can foroe hia
Apvll 1979 Volume 36. No 4
to admit thai then might have b*M a dWert n ttm .
procedure or equipment. A food •iwnpfc at this orrumd
in Nfltan vs. C & C Plytrmd Corporation.** a nusunr»
action in which ih* plaintiffs rtainwd that thnr w*n.ru*g» and ahouW pracoKi ia • logical
fishlon readily understandable to hyreen. Tta jury will
remember little. If any. of Uetiaony givea In oigniy tachiu-
cal Jargon."
"It b Important thci, whila obtoUunij mm u Mpen hia
opinion, ha alao statea hb ncM* for It. \1 part of thooe raa-
luna b b«aed on MI iihibtl you shouid Uve that exhibit
Identified at tha tin*, o M expert b uniii«ly lo b» teati-
fyi»* cgun In Uxa Court of Appeal"
"It b Imnorvaal thai conUauoua refet«aoa bo saade to
E-16
-------
the empirical teat*, investCation*, etc carried out by your
•itncsaes. for Mich data will have more imprnaion on the
jury...-"
fa to the tnta performed by the eipert. care mu»c Ke
taken that lhay are carried out in an unimpeachable fash-
ion with reliable equipment. The eipert should have on
hand detailed account* of the condition* under which each
lest wa* performed, eg., temperature, wind velocity, atmo-
apheric condition*, etc. In addition, the eipert ihould be
present, if pouible. throughout the trial in order to be bet.
ier equipped to explain any apparent contradictions be-
tween hu own testimony and that of other eiperta giving
evidence in the sane proceeding.
Environmental litigation ia about to mushroom— and
with it, the number of scientist* entering the court room aa
expert witnesses. "The social-values and tocial-conflicta
questions, resulting from the 'good guys versus the bad
guvs' issues, will increasingly give way to factual issues in
which the scientists1 participation becomes mure and more
important. "?* More than ever before, lawyer and scientist
will be melding their talents to produce hopefully convinc-
ing presentations to put before the courts. Their success in
meeting this challenge will depend on how well both under-
stand the role of the technical expert in environmental
cases.
Re4erencea
I. Rnu Cm-man. (1947). Ontario Report* 395. (1947). 4 Domm-
ion Law neport* 69.
2. McCornuck on Evidence, at 30 (2nd ed. 1972)
im"o £.* R'" ", 5ocl""- . 27 Ontario Law Report*
410. 8 Dominion Law Report* 84 (H C.). where the court wal-
ed that not only a coiuulting engineer but ilu peraoru en-
faced in cement construction and concrete work were to be
classed as eiperu. Ste al,o. Ke W,nnipf, Golf Club. (1928). 3
Dom.mon Law Repona 522 (Man C A ): Afarcnv.nyn u Fane
lii!" r °:'['0L"n2ed- (u'932>- 4 Dci=»n'°« La« Report* 618
(Alia. C.A.) Regarding the absence of necruity for • apecioliai
in • particular branch within the pmteaion. tee McCouthtrty
" S^ftl*," * *uUer Co n9031' ! Ont»"° W^'y £•
port* 2O4 (C.A ).
4. Karangani*. Public Suit* TTie fkanh for Evident r . in Hataet,
Environmental Law at 56 (Institute n/ Continuing Legal Edii-
cation. University of Michigan. 1971) ' "
S. See later leu *nd accompanying footnotes.
'''71 Klliln '"«*"» «*-» "<'>« e*Ubli»hing your
* ?" b"n f°und v'lu*ble lf • ««neraJ out-
y»««»'«'«My i"ch .urn, a. n.me.
of ?ork- edu««">n. chronoiogicil
feuional affi utians authnnhi
Conn- BJ-
ive »tvle. elabo-
ly «nd auth.nti-
Klein.
eallv, with emphasi* to mil the cue
,.i?i?B ™ Moit of You* E*P»rt. 46
11972).
7. Revoed Statutes ofOntano 1970. c. 386
maiion normally will not b» avmlsb e until trial—* I*V«M
dr.»b«k to ./«,„» preparation Md prLnutlon of thl
9. Technical aocieild In the Uniud SUIM which
«oci,iuei.
•M c ort.nu
«. .» ' » M«mb«n °' «*>•'' r»io*.t|ye Cod*
are en axcillent sourca of eiperU*.." 8. J. KUIn,
MO
10
11912* '**
.'
l«-hn<4 . »
to b* Fcrnonpif km Tm»t. ,,1. ,„.„.,
tmtnn DIMOM Auorvuoa o/fm. ru h* ..r. «.,
found TS» Umud Sun** r>evi
*nd Weir.,. pufcW^, !„„ ,wu «
*NM UMful in/oraut.on .nrf ih. lor^ oodut.™ w,
nay b* utWui . . " D
o
II. loteph L. Su, Wn. Ouvrtion in M» £«». m H
«nm,«a/ ^,, ., 6-7. ||M Con, L.,. Ed.. A,."
13 Karintanio. AWir .?«,/, n, .««,„ nrf,«,
4. at 60 Snre numale* the r*iw» lo rw -frum u»r»» n
.even hund«d fifty dollar. p« d.v pJu. Mprm^
Steunng. k.ianuurj. and CVapi fcxomuunx Eijvrr
""lenunM/wrua/CiU'i.eaMich L*w R«* n;j
14 Xarancani*. Reference 4 it 57-40
15. Sive. Reference 13. *i 1 180
16. See Uur UxL
17. Sive. at 1 180
ia 279 A. 2d IS* (Pa. Cmwlth. 1971)
19 tdrm. it 397.
20 Idem. at39a
21. Sive. Serunnf. Examining, and Crau-£«a'mn,-u
Uw
21 W»m. Such dashes may be common. rnuJljpf fmoi u '-' .,.-4
Kientuu «nd enpneerm to ba nwrow in Iheu vxiu ou-.kiu*
and provincial in Uwir approach to preWems:
ScienlJti* uod to ipcculue in profnuniuJ lurjurcs «nd
the po*:uona they advocate foil lo rarocno. th* Lr.>»ier
cenrral iraplicaliona.
Most tcwntiau remain academician*, aloo/ from thr ran-
Runity
Scientula . . . tend to measure human reapoiues bv
. . their political notion* on absurd.
The veracity and ob.wctivity of tcwoinu and encinnn -tn
questioned by a Urge proportion of the mpondenu
Scientiiu are otun arbitrary about aullen, fa*.wxin«
that they have th* only act answer* . . u)he uilnncmttun
a inaccurau, bated on icdntduoJ opuuoa ni**t ihoo
iBCL
Scunlau' attitude* are Influenced by tha prope«ui<«« of
their enployan.
ScienUiu are too dogaiauc. vuionary aad uaprarti.-^ ,n
their ducuuion of ecological problems . . . (Ov»*» » «.> »•
enviraamenuJcU are too emouoaal to provide II* pncli.
cal iiiias needed.
Sciential* load lo eiteod thaw eiperta** la eonranm.« i*j
mailer* Into UM* of poliuc* oad *ocH«y which u. ne
yoad their eomptwne*. . ."
J. Curhn. Laa. Srienre. and Pubbe Policy- A PnMrm in Cunt-
muiurafion. In W. Taonuu. Srirn/»K m l*e Ltfol S<,.tf* «t
40-41. 'Ann Arbor Scueoe Pub. 1371).
A. M*Jon*y, QC. Eiptrl Svuttnn in Dtftitdimt a (>ici»o(
f ste. *t 94. (Law Sot al Upper Canada Special Uctiuc •MIN.
24.
.
J. MacDoiuld ft J. Ccnmiy. £>tivon«*e«il*W L)4ur*«iiM. «t til
(UnivenityofWIiconilo 1975).
28. (1922) 4 Don. L.R. 721 (Ont H.C.)
37. Tha*e puneb wen furnlihed by G*JM*«| Motor* of 1'ane.U.
t>.» oaaui'acturar of th* new cor* atared on tK* pUiniufa
SI (I0i3) 4 Don. L.R. at 120. TtU (vtdaec* aisht haw ba.a im
proved, fot (iimpi*. by raaapuuif iha euMUtdtive mioa uf
daposilioei on CM pUinlUCi property with kx-«lwfti m the
same gcncnj *TM but auto NOXM* nwa th* f»m
JetiintJ oi th« AH Pollution Control Auocniioo
E-17
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10
.11
34
wrtkm a d»lawr. ,4 a few fcvndnrt IWi <•* IS. rup,4a Th«i may
km f.,TMI*J!*d a p.M.Sfe rWfmr. lKa< Ik* ptamlrff. w*f. .»,.
near talk* CaaadMii Pat .to Ka.lRMd Pan.....** '
lorufMnvi nfi»aj n«iam Urr* panirl*. WKM S i
did nm aff.rlnr.ly pma |S« iv.nl a« an ali.riwiim'.i'p
Ihm fn* the dame*. One terknwal wniw*. railed by in. rirf.n
danl wea ornrtnu.1. irwf'm.uil He <(VMr.ni I v rfuin.il .
Ik* nwrl thai S. we. .uffvi.nlly f.mifiar w.ih IS. ,rMr
51 "/"^."I.1 •"""' •*"«"«• •"<* «»e«iw* kept nn pmper rw
nrd of wind direvtmn
Knvirimmmial H»fk«i»r l7irT. V.4 |. Nn 7AM Met fir On
21. IW7(>|
I'niledMI C.«ie. V.J 1 .Hr.1i.rfi 411 417
(1174 if ml K A77
II Canadian Knvir.Him.nlal U. Nrw. 161 1111711
/
'*" l<>fU
by M'C H949)
4.1
44
i T "if19 Hl~'wlh'«*««««-ti«-id.dn..« hav. a» much
da>h a> the qu,ried n.-.tfr el fin! hluth mif hi indicate The
murl .impended Ih* .n,.,nrt,.-, f.,, ... „„„,„. -in ,«j,f „, ^
Ih. defendant an ..pp..n.,n.lv u. pr.nr.de irih*r mean. ..f d.7
pntal «f lla m.li.i.i. .murnl " Idrm al «0 Ulrr. ih* H.rlui
mrnl nf Ontario u.>i»d « .pn ul an permitting K V !• lii ci«.
linu*iiprralin(
.19 Mrljirrn. Thr Common /^,u. Huuanrr Arliiuu and Ihr Ann.
naimrntal Halllr— WrH-Trmprrrd Suordi ,»• MmArn «rrd,'
10 OwmKie Hall I. .1 SOV V,->. ',W 119721
4() Hujm-ll Trnntpiirt \ tlnlann Mallrohtr Inm t „ I id Hrf *
41 lo.i'"1"11 & J Sw«'««n- fc™ '"""""if «i Tno/ lN*w Pri-
1974)
42. A l.uca». Thr Holr o/ tHr I'tihltr. 6 Univrmly .>f Hnti.h C...
lumbia I jw Keview IIH71I
Kev»*d KeKulatwn* nf Ontario 197(1 H« IS. N*r 7 .suli..S*r
linn .L
S..me wunt that th» rrnuUlinn may h* invalid "a. Inerv i>
nulhing in th* Ihnvimnmrnlal I'mlertuin Aril itvlf In auihii
rue a reiulalum rrxnrting the rnmmon law niihl nf a riiirrn
In testify nn «irh an everyday iirrurrenrr " hniinmmrni nn
Trial. Ref 42
41 Wr.lrrn Alfalfa Carp v Air P'tUiilum Vananrr Hmrd nf Ihr
toolr nfCntnradn. I Knvirunmrnl Kepirtrr Caw< I I'J9 iCiiJ
48 I Knv Kepnrur-Cawi Ihfil IMd Cir Cl 197(11 prrmanrnf in
JUKI Hun rnlrrrd. 2 Knv Kepiirter-Cava 1199. IMd Cir C'l
47. Idrm. al 1662
48 Idrm. at IGSn
49 Idrm. al I66H
AU, 461 Krdrral Kapiirlar. 2nd .Senri. 010 «'l Cl IU72I
SI Thai level u M paria uf rarlmn mnnuiidr per milliirti h waa
nut*d in Maryland y Ca'aiy Cnrnnraf ci, /.id. thai "in
Wuhmflon. D C . fur the general pnpulaiinn they have aduul
?2 • "*"'• «" W P""" P" "iilliun »f carbon dunide " Id al
16A at
A2 Idrm. ml H17
AJ. Idrm. Cnurti may h* reluilanl to ci.nrlud* that «..me ~.rt ,J
Injury mutt have reaullrd from over ttpi.urp in pullulant. U-
rauwi of uneaimeu rtyirdiim (he way in which the i» i.iled
aafe llmita muhl have heen HI Thev mey fp.1 that >u. h
llmlta were HI on the ha.i. ,,f .kimpy rvidenr. ,rf harm ..r aa
the rnult uf hifhly luhi-r-ilv, jud.-meni. X..m* mmmenlaliir.
Oelieve that there may !>• irnund. fur mrh »u>pirnina f>rr ha
eiamnla, the CMvrlu.mn of J Hewing* In Walrr Uualily 'and
Mir rfa.ard lo ««/(«. llniv.r.ily uf Pnriinl,,. I9BH
M. '3rr V *"V,«|, Uama., Su,,.. In Haa-
April 1878 Volume 26. No 4
62
r> lh» rnurt M rla dmrMnai Mar
mak« rl«ar Ik*
^
fnrw 7Ti» renm for «•»«.*( iru. rv.^^^
by Ihr Muyn nn Cnuri m ih* (.^b^nn. *.
Im rax • wivrrr lhr>ip»rl KIM »
inal and Ikm M nvflirt h>i
mWy uiM«H/arl.«> u. a.k Km N. ,,pr^» .„ ^.n.^.
baHed upon Ih* nrimn -h»-h s, h» k,ani »«..^. „,
•«"••• •« »urb a qmn.Mi im.rf«x id* •ip.n .« [,<. ^^ ..
rran«»» Ik* nnHiri m arrantm. ..iS h. ,«n , ,.. ^ . ^,
CTMtihidly nf Ih* »Hnr~*. and IS. >ir« h^ n.. . .. 4
is. ..,„„
,„ ..„..
;>,, L«.,
^
. Ihrr* ^ nnrnnfUrl in In* *+*irr»f
firully dor. nnt Mnwarihr a»r— and fliff.
alum auy Iheref.tf* afw Htr-a .
11964,.SCR VI -A-, wrv«! I. M i.Miir
"iTlh* M-tenlM who err«|M. Ik. ft4. x .ip.n ..
aware nf Ih* lar>>n nimm.«rv rrapiin*<< during
icatnn by oppmin* all<«wvL Tk. m._i „««,
i «lly by ronfuunt h.m nr by »..n«"i,,']nf^,X'noC"m"1™
qunUm. that he rannin amww ArtuaIN .hai ih. .«>_ -,
alUimry d.M->. and IAM i> . i. .-ai.
Ih* fartuaJ vtuai>.« u. iSr ripm ...r and .~.r ma.n > ..i ,". n
limr pw-kirsc away at it by iitthlhr rhanzine the r.n un»i .-v ~.
vfrt whirh the r»prft haji i ha .ipin»i« "I) -»<4, •+.,.*
11,1, in Ihr Couaroun .n V* Thima. .Sfi^nfi.r. m in, /,s-,
••--•r-ni al lift-IO6 (Ann Arfanr Nrvn.rfur> 19741
" -»C.R «. I IV« I.H 131 Th, e,p.n WM«««, ' .1
*— arnunf thefiueK*. to ih. th*f«viirai wnfitM »\*
dene* (iv*n
II9S7I 0 R 2M 1C A ) Cher, the' ^n.^,X',"p1, T«* ,«''/..
in rruitvirc a amflin hrtwern Uv and riprrt iMtinv.n< •
Onl. Wkly Nole.4.17. Kfml Hkly k>~7tl rirt' A ' *** S
Siv*. at II.
Referenc. 37
"'«Sllj"'R»P«rt»V.4 I Chawm^Sal 11.1
I KRC 1131 IS Cl Mn I97III
Idrm S^r AUn th* d»>u».i.«t ,rf H*tt C.«l To v M./- J*. ;,
IKMI f u^mii.i.Mi m Irit and In. H»ruuiun of A P Wnt-r-\
S*n,tar\ Walrr H-ard Knv RC. 1497 (Pa Ca»tih 11'n
wn*r* in. nwrt invalidaltd I he bnard « rpvnrelion , p»r
liirmed which nn(hl hav* ruoclwuv.lv .huwr '
IHM >>elw.*n ih* mimni uprral.x ,nd i|
•irram Th* court >a>d
We are by no nvraro certain ,rf ik* .OVary uf dv. tni> «u
thu utuattim »r rven if lurh te*u rnr* •till powuije )xn t
would >**m thai traor. » >-«*«» lodlluu a I.UH «»
. .»!» a. a v,,¥ rare M|u.tHm. ,f ., ^ |, „„, |K..B
b. thai w.nda .hirh Muw fMU» . ^n.fkuM d,rert«,
only . .mall piun^iM -rf ihv IIRM. In r.k.
oe inai winda .hick Wow fr.ua , u*n.fK.j,i dir*vii.« «,aM
L**11"* ""'* • amall pruniirihM >if ihv Have. In re/ktilalnw
heiiihla uf chimney. .l< alm.B»n*(ic .utuluy r.w«,tfM.. r,.,»
nn fnun A U, r ar* p.««ij. lit, Ual B ..prewnuiiv. ,rf .,
tremely itahie air and ta Ih. HMI unfav.wr.hle rr.it .....r.
tremely
I. u n- I ,-.
u. ally la an^pied f.* ralrublwiu. »'M .» ihu, r«.u» «~U| r.
ml" \"1UChJ'^"f '"'»"•» »»««»l •« I— n.l lh.M«l« ih.
"nail ruk ««ld b.. .1 W*.|. lfeur.lic.ilv ,«„,„ ,»„„»>, «„
laau* a raulMiu* eipen may be al H«M d.lf.reoc. «,
***!? /lh* "t'IUVJ **" |K>
118 Klaln. Kefervncv A7, al 481
70 Hlv*Hefer*nre-;i. at IC44
71 A. Maliuuv. yC, Ajprrl
It li'L*,' " ^V IU* *"* "f »!1>P»« «'aiv»da »n*r«1 £«.."._
I .fc^' i»^«i««a m I*. • .«.rln«-» la W Thimaa. Stiantuu
In Ihe l^vjb. 11.741
E-18
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4 VTjr? 4 UNITED STATE5 ENVIRONMENTAL PROTECTION AGENCY
\ '' .•/ WASHINGTON. O.C. 20460
-------
- 2 -
Biis document focuses en the preparation for and conduct cf inspec-
tions, including (1) new to crcceed ween entry is denied, (2) ur.cer wnat
circumstances a" warrant is necessary, and (3) what shewing is neces-
sary to cbtain a warrant.
II. Conduct of Inspections
Tte following icatarial examines the procedural aspects of conducting
inspections under ssfr-adainistered Acts. Inspections are considered in
tfare~ stsces: (1) precaraticn for inspection of premises, (2) entry onto
premises, "and (3) procedures to be followed where entry is refused.
A. Preparation
fideouata cceoaraticn should include consideration of the following
factors concerning the general nature of warrants and the role of personnel
coniucting inspections.
(1) Seeking a Warrant Sef ore Inspection
Boe g^rlcw' s decision racccnized that, on occasion, the Agency nay
wish to obtain a warrant to conduct an inspection even before tears nas
been anv refusal to allow entry. Sucn a warrant may be necessary wen
surprise is carticularlv crucial to the inspection, or when a company s
or or bad conduct and ccior refusals make it likely that warrantless
entry will be refused." Fre-ins?ecticn warrants fliay also be obtained wnere
the distance to a U.S. Attorney or a magistrate is consiceraoxe so tnat
excessive travel time would not be wasted if entry were ceniec.
At cresent, the seekim of such a warrant crier to an initial inspection
should be an exceptional circumstance, and should be clearec tnrougn
Eeaccuarte^s^ If "refusals to allow entry without a warrant increase, seer.
warrants may be sought mere frequently. (For specific instructions on
how to obtain a warrant , see Part. D.)
(2) administrative inspections v. Criminal Investigations
It is oarticularly inpartant for both inspectors and attorneys to
be awar» of the extent to which evidence sought, in a civil inspection can
be used" in a criminal natter, and to knew when it is necessary to secure a
criminal ^-th«^ than a ci^/il search warrant. There are three basic rules
to re^erre"- in this recard: (1) If the purpose of the inspection is to
discov— and correct, through civil procedures, nenccnpliance wite regulatsry
r^uir-ients an administrative inspection (civil) warrant nay be used;
(2)^~the insoecticn is in fact intended, in -vnole or Li cart, to gather
eviderc- ^r a'ccssible criasinal crcseeuticn, a criminal searcn warrant
must bVcbtained under Sale 41 cf the Federal Sules cf Crioir^l Prccsc-^e;
and (3) evidence cbtair.ed curing a valid civil inspection is generally
admissibi- Li crininal proceedires. "Ciese priKiples arise rron tr.e recent
Sucrans Ccurt cases cf Marshall v. 3arle^'s, Inc. , supra; Micmcan v. -?rL5r,
" D S , Q8 S.Ct. 1942 (1973); and U.S. v. La5aj.le Maticnal 3anx,
- -jlsl - , 57 L. Ed. 2d 221 (1978). Ic is not carEJ.eceiy clear wnecher
FcaK5irea~Irwesticaticn for civil and criminal violations risy be prcperly
conducted under a civil cr "adnanistrative" warrant, but we believe tnat
E-2u
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- 3 -
a civil warrant can properly be used unless the intention is clearly to
conduct a criiainal inves tigaticn .
»
(3) The Use of Contractors to Conduct Inspections
Several crograms utilise private contractors to aid in the conduct
of inspections." since, for the purpose of inspections, these contractors
are agents of the Federal gcverrment, the restrictions of the 3arlcw's
decision also apoly to then. If contractors are to be conducting
inspections without the crsser.cs cr actual SPA inspectors, these con—
tractors should he given" training in hew ca conduct themselves when
entry is refused. With respect to obtaining cr executing a warrant,
an SPA inspector should always participate in the process, even if
he was not" at the inspection" where entry was refused.
(4) Inspections Conducted bv State Personnel
TSie Barlow's holding applies to inspections conducted by Stats
cersonnel and to }oint Federal/State inspections. Because sane EPA
are largely implemented through the States, it is essential
'"
that the Regions 'assure" that State-conductsd ir.specticns are conducted
in comDliancs with the Barlow's decision, and encourage the State inspec-
tors to consult with their legal advisers when there is a refusal to
allow entry for inspection purposes. State personnel should fee encouraged
to contact the EPA Regional Enforcement Office when any questions cor>-
ceming compliance with Sarlcw's arise.
With regard to specific procedures for States to follow, the
important points to renenber are: (1) The State should not seek for-
cible entry without a warrant cr penalize an owner for insisting upon
a warrant, "and (2) the State legal system should provide a mechanism for
issuance of civil administrative inspection warrants. If a State is
enforcina an EPA i^Ug^i through a Stats statute, the warrant process
should be conducted through the Stats judicial system. Where a State
inspector is acting as a contractor to the Agency, any refusal to allow
entrv should be handled as would a refusal to an Agency inspector as
described in section II. 3 .3. Where a State inspector is acting as a
Stats emplcvee with both Federal and Stats credentials, he should utilize
Stats crccrsduras unless the Federal warrant procadurss are more advantageous,
in which case, the warrant should be sought under the general procedures
described belcw. The Regions should also assure that all States which
enforce EPA orcgrans report any denials of entry to the appropriate
Headquarters" Enforcsnent Attorney for the reasons discussed in section
II. 3. "4.
-3 . '-Entry
(1) Consensual Entry
-One of che - assumptions underlying che -Court's decision is that:
nest "inspections will be ccrsensual and that che esrainistrative inspec-
tion frair/eviork will thus not be severely disrupted. Consequently, irspec-
E-21
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- 4 -
ticns will normally continue as before the Barlow1 s decision was issued.
This means that the inspector will not radially secure a warrant before
undertaking an inspection but, Li an attempt to gain admittance, will
present his credentials and issue a notice"of inspection where required.
The establishment owner may complain aoout allcwxr.g an inspector to~enter
or otherwise express his displeasure with EPA or the Federal coverrmenti""
However, as long as he allcws the inspector to enter, the entrv is""voluntarv
and consensual unless the inspector is expressly told to leave" the premises".
Cn^the other hand, if the inspector has gained entry in a coercive manner
(either in a verbal or physical sense), the entry would not be consensual.
Consent inust be given by the owner of the premises or the person in
charge of the premises at the tine of the inspection. In the" absence
of the owner, the inspector should make a coco faith effort to determine
who is in charge of the establishment and present his credentials to
that person. Consent is generally needed only to inspect the r.on-cublic
portions of an establishment - i.e., anv evidence that an inspector obtains
while in an area open to the public is admissible in an enforcement
proceeding.
(2) Withdrawal of Consent
The owner may withdraw his consent to the inspection at anv time.
The inspection is valid to the extent to which it has progressed before
consent was withdrawn. Thus, observations by the inspector, includirsi
samples and photographs obtained before consent was withdrawn, would "be
admissible in any subsequent enforcsne.it action. Withdrawal of consent
is tantamount to a refusal to alle.v entry and should be trs-ated as
discussed in section II.3.3. below, unless the inspection had crogressed
far enough to accomplish its purposes.
(3) When Sntrv is Refused
Barlow's clearly establishes that the owner dees have the richt
to ask for a warrant, under normal circumstances.1 Therefore, refusal
to anew entry for inspecticnal purposes will net lead to civil or cri.-nir.ai
penalties if the refusal is based on the inspector's lack of a warrant
and one of the exemptions discussed in Part C does not apoly. If the '
cwner were to allow the inspector to enter his establishnsnt only in"~
response to a threat of enforcement liability, it is quite possible that
any evidence obtained in such an inspection would be inadmissible. An
inspector may, however, infoca the cwner who refuses entry that he intends
to seek a warrant to compel tr.e inspection. Li any event, when er.trv is
1
FIF3A inspections are arguably not subject to this aspect of Barlow's
See disejssicn, p. 5 and 6. " ~—~
E-22
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- 5 -
refused, the inspector should leave the premises iaaasdiataly and telephone
the designated regional Enforcement Attorney as seen as possible for
further instructions. The Regional Enforcement Attorney should contact
the a.S. Attorney's Office for the district in wnicn the establishment
desired to be inspected is located and explain to t=e appropriate Assistant
Onitad States Attorney the need for a warrant to conduct the particular
Samples are provided in the appendix to thjj
(4) Headquarters Motificaticn
It is essential that the Peg ions keep Headquarters informed of
all refusals to allow entry. Ihe Psgicnal Attorney should infora the
accrccriate Headcuartars Enforcement Attorney of any refusals to entar
and should send a copy cf all papers filed to Headquarters. It is
necessary for Headquarters to ronitor refusals and 3egicnal success in
obtaining -warrants "to evaluata the need for improved procedures and to
assess the inpact cf Barlow's on cur compliance scnitoring programs.
C. Areas Where a -tight of Warrantless Entry Still Exists
1. Emergency Situations.
In an emergency.. where there is no t±ae to get a warrant, a warrant-
less inspection is permissible. In Cazsara v. Municipal Court, 237 C.S. 523
(1967), the Suprame" Court states that "nothing we say today is intended
to Ssraclcse crcrrct inspections, even without a warrant, that the law has
"traditionally" urheld in" scergency situations" . Nothing statad in Bar lew's
indicatas anv intention by the court to retreat from this position. The
Segicns will" always hs/e to exercise ccnsiderable judcment concerni.Tg
whether to secure" a warrant when dealing with an emergency situation.
However, if entry is refused curing an emergency, the Agency would need
the assistance cf the U.S. Marshal to gain entry, and a warrant could
probably be obtained curing the tine necessary to secure that Marshal's
assistance.
An emergency situation would include potential iinninent hazard
situations, as well as, situations where there is potential for destruction
of evidence or where evidence cf a suspectad violation may disappear curirg
the tine that a warrant is being obtained.
(2) FIF5ft. Inssecticns.
Thera are scrce grounds for interpreting Sarlcw's as not being
anolicable to FITHA inspecticxis. The 3arlcv' s restrictions do not apply
to" areas that have been suoject to a long starcirsg and pervasive history
E-23
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- 6 -
of gcverrment regulation. An Agency administrative law judge held recently
that even aftsr tre garlcw1 s decision, refusal to allow a warrantless
inspection of a FIFRA regulated establishment properly subjected the
owner to civil penalty. N. Jcnas & Co., Inc., I.?. S R CccJcet No. III-121C
(July 27, 1973)". For" the present, ncwever, FLFFA inspections should be
conducted under the sana requiresEnts applicsole to other enforcement
progrsins.
(3) "Ccen Fields" and "In Plain View* situations.
Observation by inspectors of things that are in plain view, (.i.e_. /
of thiixrs that a roenber of the public could be in a position co observe) dees
not require a warrant, Thus, an inspector's observations front the public
area of a plant or even from certain private property not closed to
the public"are admissible. Observations inace even before presentation of
credentials while on private property which is not normally closed T=J the
public are admissible.
D. Securing a Warrant
There are several general rules for securing warrants. TSaree
documents have ta be drafted: (a) an application for a warrant, (b) an
accxiiicanving affidavit, ana (c) the warrant itself. Each document should be
captioned with the District Court of jurisdiction, the title of the action,
and the title of the particular document.
(including, if possible, the owner and/or operator of the site).
The application csn be a one or two pace cccusanc if all cf the factual
background for seeking the warrant is stated in the affidavit, arc the
application so states. The application should be signed by che U.S.
Attorney or by his Assistant U.S. Attorney.
Sbe affidavits in support of che warrant application are crucial
documents. Each affidavit should consist cf consecutivelv numbered para-
If
or incorporate tne neutraj. acnunistzative sevens vvni« j-s t^-« ' *-,n i ^ ror
inspecting the particular establishment. Each affidavit srjsuld be signed
bv scrascne with"personal kr.cwlege of all the facts stated. In cases where
eritrv h^s been denied, this person would mst likely be the inspector
who was denied entry. Note that an affidavit is a sworn statement chat
must either by notarized or personally sworn co before cne magistrate.
E-2A
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- 7 -
Tbe warrant is a direction to an appropriate- official (an H3A
inspector, U.S. Marshal or other Federal officer) to enter a
specifically described location and perfom specifically described
inspection functions. Sir.ce the inspection is United by the terms of
the warrant, it is uncortsnt to specify to the broadest extent possible
the areas that are intended to be inspected, any records to be inspec-
ted,' any samples to be taken, any articles to be seized, etc. While
a bread warrant may be permissible in civil administrative inspections,
a vague or overly broad warrant will probably not be signed by the
magistrate and may prcve susceptible to constitutional challenge
The craft warrant snculd be reedy for tile magistrate's signature at the
time of submission via a motion to quash and suppress evidence in
Federal District court. Once the magistrate signs the draft warrant, it
is an enforceaole document. Either following the magistrate's signature
or on a separate page, the draft warrant should contain a "return of
service" or "certificate of service". This portion of the warrant should
indicate upon whan the warrant: was personally served and should be signed
and dated by the inspector. As they are developed, more specific warrant-
issuance documents will be drafted and submitted to the Segicns.
E. Standards or Bases for the Issuance of Administrative Warrants.
The Barlow's decision establishes three standards or bases for the
issuance of administrative warrants. Accordingly, warrants may be cotained
upon a shewing: 1) of traditional criminal probable cause, 2) of civil
probable cause, or 3) that the establishment was selected for inspection
pursuant to a neutral administrative inspection scheme.
1. Civil specific probable cause warrant.
Where there is seme specific probable cause for issuance of a warrant,
such as an employee complaint or competitor's tip, the inspector shculd be
prepared to describe to the U.S. Attorney in detail the basis for this
prcbaole cause.
The basis for prccable cause will be stated in the affidavit in
support of the warrant. This warrant should be used when the suspected
violation is one that would result in a civil penalty or other civil
action.
2. Civil prc^-^"le cause based on a neutral administrative
inscecto.cn scneme.
Where there is no specific reason to think that a violation has been
committed, a warrant may still be issued if the Agency can snow that the
establishment is being inspected pursuant to a neutral administrative
scnene. As the Succame Court stated in Sarlow's:
E-25
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- a -
"Probable causa in the criinir.al law sense is not required.
For purposes of an administrative search, such as this, crccable
cause justifying the issuance of a warrant nay be based not: cnlv
on specific e/icence cf an existing violation^ but also en a
shewing that "reascnaole legislative or administrative standards
for conducting an ... inspection are satisfied with resect
to a particular [estaolishnsnt] " . A warrant shewing that" a speci-
ric business has been cncsen for an OSES. search en the basis cf a
general acnrLnistrative plan for the enforcement of che act derived
from neutral sources such as, for example, dispersion cf snslcvees
in varicus type cf industries acrcss a given area, and che desired
frequency of searches in any of the lesser divisions of the area,
would protect an employers Fcurtn Amerjfnsnt riches." ~~
Every program enforced by the Agency has such a scheme bv which it cricritizes
ana scaeoules its inspections. For example, a scheme under v
-------
-9-
distincticn between administrative inspections arc criaiir.al varrant
situations is discussed in Section II .A.2.
F. Inspectiix: with a Warrant
Cnca the warrant has been issued by tie magistrate or judge, the
inspector mav crccsed to cr.e establishment to connence or continue che
inspection, "where there is a high probability that entry will be refused
even with a vsrrant or vcere there are threats of violence, the inspector
should be accompanied bv a U.S. Marshal when he goes to serve the warrant
on the recalcitrant cwner. Tie inspector should never himself attempt
to make an-/ forceful enrry of the establishment. If che cwner refuses
entry to an inspector holding a warrant but not accompanied by a U.S.
Marshal/ the ir.spector should leave the establishment and infora the
Assistant U.S. Attorney and the designated Regional Attorney. The/ will
take sncrccriate action such as seeking a citation for contempt. Where
the inspector is accompanied by a U.S. Marshal, the Marshal is principally
charsed'with executing" the warrant. Thus, if a refusal or toreat to
refuse occurs, the inspector should abide by the U.S. Marshal's cecisicn
whether it is to leave", to seek forcible entry, or otherwise.
The inspector should conduct the inspection strictly in accordance
with the warrant. If sampling is authorized, the inspector must be sure
to carefullv follow all crccedures, including the presentation of receipts
for all samples taken. If records or other property are authorized to be
taken, the Inspector rrust receipt the property taken and nsir.tain an
inventory of anything taken, from the premises. This inventory will be
examined by the magistrate to assure that the warrant's authority has
not been exceeded.
2 centuaied rron page a.
to Federal court enforcement when entry is refused". There is thus
sons cuesticn as to lether the existence cf a non-'Aarrant Federal
court "enforcsaent 3iechanisn in a statute requires the use of taat
aechanisni rather than warrant issuance. Wa believe that the Barlcw1 s
decision gives the scencv the choice of whether to proceed thrcugr. warrant
issuance or thrcugn an snplicaticn for an injmcticn, since the cecisicn
is largely based on the "fact that a warrant procedure imposes virtually
no burden on tae inspecting agency. In addition, an agency could attempt
to secure a warrant crier to inspecticn on an ex carte basis, scrrething
not available under normal injunction proceedings. Several cf che acts
enforced bv Z?A have crovisicns allcwing the acministratcr to seec
injunctive" relief to assure compliance wizh the various parts cf a
carticular statute. There may be instances wnere it vvculd be rcre acprc-
criate to seek injunctive relief to gain entry o a facility than to
attsmot to secura a warrant for irspecticn, althcucn at chis point '«e
cannot toinlc cf any. Ecwever, since the arrant crccess will be far
nere exredizicus than cr.e see,
-------
- 10 -
G. fietizninc the Warrant.
After the inspection has been completed, the warrant must be *-« tr-—*
to the magistrate. Whoever executes the warrant, (i.e., whoever ce-fbnrs
t.c inspection), must sign the return cf service fora irdicatim to'wrcm
the warrant was served and the date cf service. Se «*.culd chen^^ur^
the executed warrant to the U.S. Attorney who will fomalV ~*-jmV to
toe issuing ssgiatrate or judge. _ If anything has been physically" taken
from ^.e premises, such as records or sanples, an inventory of such i^sns
mos^ oe sucmittsa to the court, and the inspector rcust be oresent to c~-'*•/
«-hat the inventory is accurata and ccrasleta. " "
III. Osnclusicn
Except for requiring che Agency a foaalj-ze its neutral insoec='cn
acoesBs^ana rsr generally ending the a-cency's autboriw for initi»circr~
civil anc/pr criminal actions for ref'jsal to allow warrantless inscect^cns
^Slav's anould net interfsre with EPA enforeenent inspections.
Where there is doubt as to how to proceed in anv entrv case,
do not^hesitate to call the respective Eeadquarters crccrsa contact far
^^^^^^^^^
Marvin 3. Durning
E-28
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APPENDIX
•Re Appendix contains three attachments.
Attachment I is a warrant application, affidavit: and warrant to
conduct an inspection, viiere the Agency has specific prcbaole cause to
believe that a'cLvil violation of an EPA regulation or Act has cccured.
In particular, care should be taken Li spelling cue tr.e specific facts
that give rise to prccaole cause. Note also, that che sccpe of tr.e
warrant is carefully articulated.
Attachment II is a warrant application, affidavit and warrant to
conduct an inspection in wnich the estaolishner.c to be inspected has
been selected under a neutral administrative inspection scheme. Note
che extraordinary detail cf tr.e adrainistrative scneire describe in
paragraphs 3-2Q of tr.e affidavit:. Such detail s«:uld not be r.ecessary
for IECST: Z?A neutral administrative inspection schsres. ^3ote also
the executed inventory and return of service forxs attached to
Attachment II.
Attachment III contains a neutral adTonistrative scheme for
CFC inspections. In implairenting sucr. a scheise/ tne Regions nsust still
utilize" neutral criteria in selecting the individual establishment to
be inspected.
E-29
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Attachment I
UHITZD STATES DISTRICT C3URT
MI3DLZ DISTRICT OF 13UISZA2IA.
IS TIE MATTZ3 OF
CT.7AN LA::D AIR ,\;:o VATTS.,
CORPORATION. D/3/A CLAW:
SOLLIES e::vi?.c::::i::TAL sxnviczs
OF LOUISIANA i:;CGSJ?G3.\TID;
ESVI?JON:!3£H7AL PURIFICATION
SO'.
APPLICATION FOP. WARRANT 70
EHTZX, i:isp=:c7. PHOTOGRAPH.
SAMPLE. CCLLZC7 ZITFOK'-ATICif .
INSPECT AND COPY
SPA, INC. ; IN I3S3VTLL2
PARISH, LOUISIANA :
TO THS UNITZD STATZ3 IIAGISTZATZ. by the Unicad
Scares of Acerica, Envirsnnentai Pracacrian Agency, through
James Stanley Laselle, Assistanc Unitad Stares Actamey. far
the Kiddie Discrier of Louisiana, hereby applies far a
m franc pursuant ta seerian 208 oz the Federal Wacar Politician
General.. Acr,, 33 C.S.C. L313, and the Sesource Conservation
and Secavery Acr oz 1976, 42 U.S.C. 6927, far rhe purpose of
conducting as inspection as fallows:
To earar ta, upon, or thrau:, . the prasises of a
vaare disposal operation rciawn by variaus naaas including
CLAW facility, vnich consists of three sires, to win
iajecciaa well siia, a field offica and storage tank3,
and waste pits and landfill sira located ia Iber-rilla Parish,
TArt-f si ana ia or near- the Zaycu Scrrslls ccc=ssiry. The
faeiliry can be reached for disposal purposes by truck or
The ownership and operation, of the CLAW faeiliry
disposal operacisri has been Seiovn. by several diff aranr
, tn vie: Clean Land Air Watar Corporation (CLAW);
Z?A, Incarporacad; Snvirsncental Purificacian Advancas^nc;
Eaviransencal Purification Afcaca=anr (ZPA, Inc.) and Hailins
Environmental Services of Louisiana. .A caapany letterhead
usiag the nases of CLAW and IPA, Inc. lists an address of
Bonce 2, 3ox 5302, Plaquesine, Louisiana 70764. Ir is
reported ia the newspapers and elsewhcra, that on July 23,
1978 - three days after the death of the truck criver on the
CLAW facility - that the injection well on the CLAW facilicy
was. sold ta the pjllins Envir=r=cncal Scrviaas of Louisiana.
Unsubstantiatad raports say that CLAW so langer has any
E-30
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assccs , leaving che pics and landfills under che ownership
of I? A, lac. and che isjccsian veil under che ownership of
Bollias. CLAW and Z?A, lac. ass, raporcad co be dif fares,-
coopany and/or corporate aaces far che -sane people. Despice
these passible ownership changss , che CLAW facility apparencly
continues co be aperacad as a single unic. Further, it is
reported chat CLAW or Rollins is under _ a, federal catrrz order
ca honor ica cancrarz wich. a cl'.gTE co acsapc wasca. Far
purposes of chi,^ applies cian, af^idavic and varranc, che
three sices and all operacicns vill be referred ca as CLAW.
Toe field office and scarage .canks are ia o? on
the edge of 3ayou Sorreils; che iajeccian veil sice is abouc
1.6 niles eorchwes-c of Bayou Scrreils- on *** read; che vasce
open piss-Landfills -are locaced appraxinaceiy 7.7 ailes
aorrhvesc of 3ayon Sorrels on che levee- read* Tae address
o£ the CLAW facilirj is Clean. Land Air Kacar Ccrporacicn Z?A
Incarporacad, Saure 2, Box 330 2, Plasueziae, Louisiana.
These CLAW facilicies are kaswo. Ca Z?A iaspecrars and veil
known co local people.
•» The CLAW facility is an escablishaenc subjecc ca
the ret^uiresenss- and prohibicians of che Federal Wacar ?ol-
•
«•
lacion Concrol Ace, iacludia^ b-cc ooc liaiced ca aeecicns
301, 303 and 311, and sections 3007 and 7003 of che SLasotsrra
Canservsdan and Sacavery Acs of 1376 (42 7.3. C. 6901 ee •
Oa Friday, Augusc 4, 1373, Zdward HcHaa, an
enplayee o£ cha U.S. Znviraanens ?racacrion Agency, racuascad
perslssian, ca encar and iaspecc'-che said presises. Despi'ce
such raquesc, esaloyees of said facilicy refused ca gran:
access ca said prcsises ca Mr. 2£c£as, a duly authorised.
inspector of che Isviracsencal ?raceccian Agency.
The deterainacian ca inspeer. said presisas vas
based on che following:
The sheriffs office os Iber'/ille Parish raquascad
EPA 's assiscancs and reporred a deach ac said preaises.
-2-
E-31
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Local unrasc and fear as. che facility was reporcad ca che
Sofarcsseac Division, of Xasisn 71, Dallas, Texas on Tuesday,
jtesusc l. 1973 and E?A was rae-jescad ca iaspecc -he faciliry
vhich is a disposal sica far chesical wascas and an=arsus
oil. vascas of a hazardous sad caxic mc-crs.
>•»«•* local caresc-, aad agicacian and casplaiacs
hanre bees raporcad on. selevislaa. and in nevs-papers csncarr^s.^
tJxe oceracisa of che CLAW facility as well as cha isacisely
deach. of a 19 year old =rosk driver at: said facility while
he va.s di-schar^izg vasca i=ra an open pi: ac che faciliry.
The deach was possibly caused by his -i-halasiac or raxia
f~*m»«» caused by a raaczisn of sixiss- ~cacpacibla caxic
vascaa ia cha open pi=. Allesedly tvo «ye vi.=nesses ca che
-j«a^H of che driver rapcrzad che praaer.es of choking f'^ses
la Che area vfaea chey. opeaed che doors ca cheir cruck zs
esslsc che driver who died< They also raporrad rhac his
srack. was parked ac rhe edge cf cie opea pic cruck ra=p,
vich doors cpea as che ci=e of his daach. Subseeueac
laboraxary cases of wasce eakas frca che pics hava shawa
vasce cac^rials praseac ia che pic, vaich, vaea aiixad wica
^
-------
as wall as hazardous =3 cha health and-welfare of cicisess.
Be furzher observed hish wacar sarkisgs on =he adjacanc
trees ac che pic sica asd a lack of levees bervees che siras
and che Crasd £iver asd ocher wacarvays. Is addiries, chare
nay be hazardous wastes asd ccsdicicss which say pose a
8ubscas:ial prases:, or* pocascial hazard ~a husas healch
or Che esviran-sess whes ispraperly creaced, scared, crass-
porced. or disposed of, or ocherwise sasagad.
-Th" isspecrias will be esssascad is dayrise
vichia regular bxuisess hours asd will begis as soon as
pracsicabla afrar issuance of *•*••' -«» warrasc and will be
co-solaced wirh raasosable pra-aptness.
The. isspecciatL will be conducted by che
Onicad Stacas Isviras-aescal Pracaccios Agescy (Z?A) isspec-
Cars, who will be acsscpasied by che Usired S&aces Marshal
Co ensure esrry so chac che S?A isspecrors say perfars as
laspeccian of che prasises, isspecs asd copy records, Cake
photographs, gacher isf arsacios asd evidence and collacrz
'saaples is accord wich 33 nSC L21S asd 42 USC 6927.
A recurs will be sade co che .Caur-c upcs canplccioa
of Che isspeccics.
\J2E22J02S, ic is respectfully ra^uescad char, a
^snr ca encar and isspecc che CLAW facility be issued.
Ra-sgecr^ully susmicred.
DONALD L. 3ZL.Ut.-L
UNTIZD
/dAitES STAi^L^'i •-£!•:£•—L (
^A/s.iscanc U.S. Acrsrsay
E-33
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AFFIDAVIT
STATS OF LOUIS IA3A
PARISH OF EAST HA~II 5C'JCZ
I. Zaward McKaa. being duly sworn, hereby depose
and say:
1. I am a duly authorised employee of che 'Caicad
Scacss Znviran=encal rracsczion Agency, and sry cicla is
CaesrLcal Sagiseer. Surveillance and Analysis Division,
Bagiou 71. which includes =he Scaca of Louisiana. la =7-
• »
capacity, I a= responsible far inspeccir.S facilizies sxibjecr
Co vasioxis federal «aviraB=aneai srsruces as direc=ad by ay
2* On Tuesday, Augusc 1, 1S73 frcn, aboiis 7:4.5
p.m. ca 8:45 ?.=.,! =ada a prelizrisary iss?ec=ica of she
CLAW -acilicy a=d cook =vo sasples ac =he opes piss. Oa
Wednesday. Augasc 2, 1973 I cack. a fav phocagrapha of zha
faeilicias fraa arausd 2:20 ?.=. vssLL 5:20 p. a. OB Thursday.
Angusr 3. 197S aceanpanied by a=acher SA errplsyee, 1 -7isi=ad
Che ficiliry a=d area, froa abouc 11:20 a.a. ca 2:00 p. a. and
also caok a fav additional ? coca graphs. Thase brief visizs
ts Cha sire have only i=volved facility asp lay ess a few
miaures each ci=e is crdar ca cbcai= parses f-aa she fiald
o££Lc& and =a open gacas ac various guard houses.
3, On. Friday, Auguac 4, 1973, a local depucy
aheriff . sca=a and local officials and I vere rafused ad=i=-
eatnca =a zhe CLAW facility. Also, CLAW officials wers so
langes ac Che field house or available elsewhere c= issue
passes -a encar. Xy previous sa=?li=3 and inspcecion was
noc snfficienc far lahcracary purposes and seeds =o be
ed.
4. Infarsacion 1 have gacharad in rhe local
ai=7. in newspapers, on raiavisian, fraa laboracary
E-34
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Cases of she sasales, frsa che Ibcrvil'le Sheriff's Office,
and ac cha CLAW facilicy scrangly sugsesc sad supporc che
need Co ericar and inspeec che facilicies far passible Seccion
301. 311 and ocher vielacicns of Che Federal Wacer Pollucion
General. Acs. Further, -ic is possible chas chers are hazardous
vasces and condiciaas an che presises as defined ia Saccisa
lflOA<5^ o£ cha Sasoursa Cccsesvaeiaa asrd Recovery Acs of 1976,
(42 USC 6903) (5) - which, cans ci rue a an *—ri-eag hazard under-
gecciou 7003 of che Rasourcs Ccnsar-/acian and Kacavcry Acz
of 1976 (42 USC 6973). Tiese obs^r-^acians are:
a. Obvious spillage or vasce =acari_al on
the gra\jnds of cha CLAW faciliry suhjeec ca ennari=§ vacervays.
b, Ccncaralnacad landfills vich obvious 17
exposed and danage-d barrels vizb. "hftir cancencs aapcied or
nearly eapcj.
c. Drainage frs= landfills lues a "fishing"
laig'a and other adjaceac areas leading ca variaus wacerways.
d. Open airs esnr-'-Ir.-'.rg oil vasres and
hazaxdaus, caxie cheoical wasces wizb, che appearance of
overflow wasras en che adjacenc grounds as veil &a high
•wacear carks ca trees nexr, ca che open, pics equal ca or
higher rhan che pics.
e. Th-* lack of levees becveen che facilicy
gronnds and drainage areas ca Che Grand River, "fishing
lake", bayous and barrow dicahes.
*J Capias of a faw fa,cili=7 lag recards and
ochor dccT=encs vhish vera praviausly capiad 37 che laeal
Sheriff's office. Tiese recards iadicaca che raceipc and con-
tent: of oil and hazardous cheaical vasces acaepced ac che
facdlir/.
g. 7oor naincananca and slap-p7 "hausekaeping"
praccicas ac che facility vhich laads a raascnable person ca
-2-
E-35
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eacarias inca nearby vacarviys ir.clucir.g vscers of che
Uoiced Screes aad ics cribucirias, as veil as posiag a
earsac ca che e:r;-ircr=eas aad che public aeaich and we
of the Caized Seacas.
h. The reporcad death of a 19 year old
crack driver- ac che CLAK (Z?A, lac.) opea piss an July 25.
1978 while he vas discharsi=s vasca is=a an opes ?iz ac che
f«cilir7. lie deach was posaiily caused by his v-Lha.la.-lan
caxic fisaea caused, by a reaczica of 3iixir.s ir.cc=pa=iile
wascaa ia che opea pic. Two eye wirseases Co che
•
death of che driver rasorrad rha praseaca of chokiag fu=es
.ia. eae area vhea chey opened che doors ca chair cr-^ck. ca
aaaisc che driver- who died. .They al_so- reported chac sia
crack was parked ac che edge of che cpea pic wish che dears
open ac che ci~ff of deach. Suhsequeas Liboracary. cases of
vasca eakfin fron che pica have shcva vasca aacariiis vera
preseac ia, che pic, which, vaea =Lxad virh che speas causcic
beiag discharsad frcs che driver's crack could have caused
Che deash. Tiaal aucapsy raporcs are scill peadiag. Is is
' allegedly raporrrad chac CLAW facility officials dirascad che
driver co cake and dischar^s. his vas-ces ca che crusk racp cri
Che edge of aa opea pic. Discharging caxic vasca iaca aa
opea pic ac che edge cf a. pic is aoc a safe, desiraola, or
acsapcabla practice siaca caxic r'~=-tn~*T raaccieas ara very
probable aad caa resulc ia che deach of sayaae aearby.
5. Seesiaa 203 of che. Federal Wacar Pallucian
Csneral Ace. 33 DSC 1313, aad secrica 3007 of che P-esourca
•
Conser-J-acica aad Secavery Ace of 1575, (42 CISC 6527), pra-
vidias far eaary, iaspeericn, racard iaspeccioa aad capyir.g
sad saspliagare raascnable, ia che public iacarssc aad
oecsasary ia order "cd csrry cue che pravisians cf chase
Ae&s, vhich Aces ara designed ca pracacc che eaviren=aac, as
-3-
E-36
-------
veil as she publis heairh. and velfara. la chc iascoac
aatrar i= i.s reasonable sa assu=e iha r.eed far i=spec==.aa
baaed on che iafsrrasion and ohservscioaa sec Quc i» ?aragraph
4 above and is che public iacerass.
EEWAAD C. «C .-
CHFMICAL z:;Gi:;zz3
?2DTZCTIC:i ACZXC'i
Subscribed aad svora ca bezsrs =e
AC Bacon Range, Staca of Lauisiaai.
thia /a , °£ ^ ^- 1973.
E-37 -4-
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srArrs gi3T7_:cT CCUST
DISTRICT cr icur
is TSS :uvrr2?. or
CL2AN LAJTO A£3 AMD
COBPCRATIGN. d/b/a. CLAW;
ETC,/. ST At.
WARRANT Or iHTSY, ISISSiCTICJI
AMD MCN^rOSISG PCTSSUAJfT TC
33 U.S.C.51313 and 42 U.S.C.S5327
TO* TSS CICTSa S-TATIS 0? AT-SSZCA. ONirSB STATSS -Sr^S
?383TSC7:CX AGSJICV. THP.CC'GK ITS 3CT.? CiSZuIIATZS S
OR SEPSSSrzrTATT'/iS, THZ KirTZ3 STACSS MAiiSHAZi OR AMX CT2Z
An application having been aade by the aai^aci Stacss of
America, United Starss i=.Trir=c=entai ?rst«eiics Acency, for- a
warrant of enzrv, issreetiaa aad acnitariig sursTiast t3 33 a.S.S.51313
and 42 U.S.C.SS327, as part of an inspection prsgras designed ta
aassre cc==lia=ca with the Federal. Water 'Sall-itisn Centre! Act
(cc&sionly referred ta as the- Clean Hater Act) , 23 O.S.C.S12S1, et
[., and the Sescurce and Secaver? Act of 137S (42 0.S.C.S52Q1, et
j.J ,. and an Affidavit having been =ade before me by Edward Kc2a=x,
a..duly authorised esplcyee of the United States Znvirocsental
rrotacticn Agency/ that he'has reason ta believe that on the prasises
•hereinafter described- there- exist a danger ta the public's health,
weifare and safety and ta the property, rivers and envirannent of
th» Onitsd States, and that in order ta c*etar=ine whether the
Pederai Watar 5olliitian Central Act (ca=enly referred ta as the
dean Water Act), 33 a.S.C-51251, et aeq., and the Hescurce and
Seeovery Act of 1376 (42 O.S.C.SS3C1, et seq.), and the rules,
regulations and orders issued pursuant ta the Acts have been or
are being violated, an entry on, and inspection and =onitaring
of the said described property is rec^iired and necessary;
E-38
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And, tie Court being satisfied that thera has been a
sufficient shewing thai raasor.ohle legislative or adainistr stive
standards for canducting as iaspectian and investigation have been
satisfied wish res=ec^ ta the said deserved prcper-y and that
Frcoafals. cause exist ta issue a warrant far the e->— T <-,«-,«—:-„
' ' *••• ^-^ ^ f MMdfeJGW -a _ "H /
iavestigatiaa and =cait=riae- or the said described preaisesi
IS IS HS2S3? OHEZ3S3 AMD CSSffittHDEO taat the Caitad Statas
e£ America, Gaited Statas SaviransansaL Sratacxion Agency, thrauch
1*3 diLy designated re=reser.tittive p=- representatives, the United
States Marshal, or any other federal officer are hereby entitled t=
and saali be au*acriied and cerai—ad ta have entry upca. the
folicwing described sroaeirry waica is lacated ia the kiddie Ois-=rict
Ty^T* «;«' irnn
•Taese presises tacwn as the Claw Ccrrcrat-'cn
vasta disposal facility in lierrille Parisn,
Louisiana, also :
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•Trcn the Maid office of d^;j, return ta tic
site of the i.-.iar3cc-isr. as the saved lower ' evee
read and the raid leading =a tne'dca? well in-ecrion
site (Hallos ravirsnsssnsalJ. Proceed sortnwesc
on the ur.paved snail/gravel lower Isvea read
appraxi.T.ai3i-/ 6.1 aiies ta tha entrance read and
bridge leading ra tha gate guard house and gate
°* ta* S3A, lac. waste disposal pits. This sa=e
«n*=anc= road is 7.7 ailas" r.ort-iwesc aiang- tne
lower levee road fzca the iszsrsacticn of the iawer
levee- read and Bayou Scrrei Pcntaca asidge Scac.
IT IS
G2DS3SD that the entsrv, isspesrsiaa.
ti cation a=d =cnit=rl=c aathoripad hereia .^n he caaductad
•
regular- worJeiag hc«rs or at other reasanabla ti=es, wit
rsasonable li=its acd is a. reasonable aanser fraa Si 00 a.a. ta
'10:00 p.a..
2T 2S jU^C'Hii-i OSDSasa that the warrant issued, beraia shaii
be far the ctrrpose of eanducting an entry, inspeetiaa, investigatiaa
and acaitaring pursuant ta 33 C,S.C.SU13 and 42 C.S,C-SSJ27
consisting of the fallowing:
(1} entry ta, open or throuch the above
preaises, JLaeludir.? all * buildings . srruc^ras
equipsent, =achir.es , devices, =areriaJ_s and
ai*as> -a iaspetrr, saspls-, phorserapn, nanitar
or investigate -=ha said pr
(231 access ta, seizure of and copying of ali records
P^s^ai^i^1? ^a or relarsd. ta"ihe oseratian of
the facility, e=Tii=:en-c, vasts satsriais
wnich, are accep-ad and starsd en me =rs=isea
and records which are racjuirad ta be i
tmder 33 Q.S.C.51313 (a) (A) , and 42 a.S..
e-fc ses>^. including any rules.. and rsguia-iion
and orders prcsulgatsd
(3) inspection, including pnotographinc, of any
33 a.S.C.SUiaTaHAf, and 42~tT.S~cl5Z927;"'
<4) inspection, including photographing,of any
equipaent, processes or set-icds used ia sa=n:
aonitaring or ia waste caaracteriaaticn;
(5) inspection, including phatagraphing, of any
ccuipsenu or aethods used ta cisucsa of cr" star?
vasts subscansas; * .
(67 sample and seise any pollutants, effluents.
s™0--/ soil, or otner aateriais or substances
which .T.ay reasonably ie e:
-------
(7} seise, inspect. sanols. and ahetrraph anv
evidence wnic.1 constitutes or raiatas ca'cr
is part o£ a. violatica or tha Faderai '.
-------
inspector presents credentials). However, if the inspector does not have a
warrant the owner may limit the inspector's access to any portion of the
facility.
If an inspector is refused entry into a facility for the purposes of an
inspection under Section 3007 of RCRA, certain procedural steps must be
carefully followed. These steps are as follows:
1 Present proper identification to the facility representative
authorized to consent to an inspection. Consent must be
given at the time of the inspection.
2. Thoroughly document the event, noting time, date, and facil-
ity personnel encountered.
3. If entry is denied, ask the reason for denial.
4 If the problem is beyond the inspector's authority, suggest
' that the official contact an attorney to obtain logs! advice
on his/her responsibility under Section 300/ or Rv.RA.
5 Under no circumstances di-scuss potential penalties or do anv-
which may be construed as tnreatemng.
6 If entrv is denied a second time, exist from the oreir.ises and
document any observations made pertaining to Jie denial,
particularly any suspicions of violations being covered i.p.
7 Report all aspects of denial of entry to the Enforcement
Division for appropriate action to be ta
-------
Conducting an inspection under a search warrant will differ from con-
ducting a normal inspection. The following procedures should be complied
with in these situations:
1. Use of a Warrant to Gain Entry
a. If there is a high probability that entry will be re-
fused even with a warrant or where there are threats of
violence, the inspector should be accompanied by a U.S.
Marshall.
b. The inspector should never himself/herself atts^ot to
make any forceful entry of the establishment.
c. If entry is refused to an inspector holding a warrant
but not accompanied by a U.S. Marsnall, the inspector
should leave the establishment and inform the Enforce-
ment Division Attorney.
2. Conducting The Inspection
a. The inspection must be conducted strictly in accordance
with the warrant. If the warrant restricts the inspec-
tion to certain areas of the premises or to certain
records, those restrictions must be adhered to.
b. If sampling is authorized, all procedures must be care-
fully followed including presentation of receipts for
all samples taken. The facility should also be informed
of its right to retain a portion of the samples obtained
fay the inspector.
c. If records or property are authorized to-be taken, tha
inspector must provide receipts and maintain an inven-
tory of all items removed from the premises.
Inspectors should consult MEIC's procedures for further guidance (sae
Appendix III).
C. PRE-INSPECTIGfl DISCUSSIGM
During the initial inspection, the inspector should, if necessary,
discuss tha provisions of the Act and, if requested, furnish a copy of the
Act and appropriate regulations. The inspector than should outline the
objective; of the inspection and tha order in which various aspects of the
7/8/80 V-5 RCRA INSPECTION MANUAL
E-4J
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STAFF BIOGRAPHIES
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LOUIS W. ADAMS National Program Manager,
Ecology and Environment, Inc. Oil and Hazardous Materials Spill
Control
Hazardous and Radioactive Materials
Specialist
EDUCATION:
M.B.A., Business Administration, University of Alabama, 1967
B.S., Chemical Engineering, Drexel Institute of Technology, 1957
Military training in explosive ordnance disposal and radiological
safety
EXPERIENCE: . .
Mr. Adams is national program manager for E & E's TAT. He directs the
company's 11 teams one in each city where EPA has a regional office as
well as in Cincinnati, where the Environmental Emergency Response Team
is located. His responsibilities include program decision-making
authority, access to E & E's president and to the program's Technical
Advisory Committee for resolution of managerial or technical problems,
interface with the administrative services department, program and TAT
staff coordination, project expediting, implementation of quality
assurance and quality control functions, and interface with E & E's
staff.
Mr. Adams joined E & E as Region II TAT leader for the EPA project.
He directed TAT activities, assigning manpower to and taking part in
oil and hazardous materials spill responses while fulfilling his man-
agerial, communication, and documentation responsibilities. In re-
sponding to oil and chemical spills within a region which includes New
York, New Jersey, Puerto Rico, and the Virgin Islands, Mr. Adams was
involved in determining the extent of the spill; assessing environ-
mental damage; coordinating activities with federal, state, and local
officials; assisting the on-scene coordinator and, upon occasion,
acting as his field representative; and monitoring cleanup activities.
He provided support to the EPA in the investigation of hazardous waste
sites, supervising containment and cleanup activities and assisting in
Federal Emergency Management Agency (FEMA) damage assessments.
In addition to fulfilling the administrative, managerial, and communi-
cation responsibilities of a TAT leader, Mr. Adams provided support to
the National Project Management office in the development of technical
and administrative special projects, including the development of
standard operating procedures regarding entry into hazardous waste
sites and the coordination of the project's respiratory protection
program.
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Louis W. Adams (Cont.)
SPECIAL EXPERIENCE:
EPA TAT Responses (Region II TAIL)
Mr. Adams spent three weeks in Puerto Rico assisting the EPA and the
FEMA in assessing the damages resulting from .hurricanes Frederick and
David. The assessment included damage surveys of waste and drinking
water systems and containment and cleanup of oil released from damaged
tankers and planes. Under Mr. Adams' direction, Region II TAT members
also aided in the coordination of FEMA damage surveys in Chautauqua
County, New York, following a severe flash flood.
He monitored the collection of toxic materials at a hazardous waste
landfill in Edison, New Jersey. He assisted the EPA, Coast Guard, and
state representatives in collecting data, developing a sampling plan,
and providing technical support for an operations center in response
to an intense chemical fire that erupted in a warehouse in Elizabeth,
New Jersey. In Wellsville, New York, Mr. Adams monitored cleanup
operations of a fire involving pesticides and herbicides which, when
extinguished with water, entered and contaminated Dyke Creek and the
Genesee River.
He responded to a major oil spill in Oldwick, New Jersey, monitoring
the containment and cleanup of 7,000 gallons of oil, and assisting in
the investigation of the resultant fishkill. Mr. Adams represented
the on-scene coordinator, determining the proper procedures for
cleanup of a salt brine spill in Linden, New Jersey. In another
response situation in Linden, he provided technical assistance,
conducted water quality surveys, and assessed the resulting fishkill
after the derailment of a tank . car containing 30,000 gallons of
sulfuric acid. He performed perimeter and on-site inspections for
eight hazardous waste sites, compiling and reviewing background
information on these and eight other sites within the region, and
conducted Spill Prevention, Control, and Counter-measure (SPCC)
inspections for oil bulk storage and distribution centers. Mr. Adams
directed the cleanup of a 50,000-gallon jet fuel spill on Staten
Island, New York; the asbestos contamination of a drainage area in the
Bronx, New York; and a methyl alcohol spill in Edison, New Jersey.
Hazardous and Radioactive Materials—Army
During his 21-year military career as a Chemical Corps officer, Mr.
Adams developed a wealth of experience in the handling, transporta-
tion, security, and disposal of hazardous and radioactive materials.
As radiation protection officer, he supervised packaging, loading, and
transporting of hazardous and radioactive materials in accordance with
Interstate Commerce Commission and Atomic Energy Commission regula-
tions and directed disposal operations for such materials in the
United States and abroad.
While directing activities of 15 army bomb squads located in Greece,
Italy, Turkey, and Germany, he was in charge of mission assignments,
-------
Louis W. Adams (Cont.)
financial planning, training, and inspection of operations involving
nuclear weapons disposal and detection and dismantling of terrorist
bombs. He was principal advisor to the Commanding General, U. S. Army
Euro.pe, for these activities and directed a special program countering
explosive devices of the Baader-Meinhoff terrorist organization.
Mr. Adams acted as army staff executive agent for the security of
chemical weapons storage testing and training sites. In this regard,
he developed and published the first comprehensive army procedures for
site protection including chemical accident and incident control,
emergency reaction force deployment, and personnel screening and eval-
uation. He assessed the adequacy of local security programs at chemi-
cal installations and served as advisor to the army staff on develop-
ment of bomb squad procedures for chemical weapons.
During his army career, Mr. Adams administered and instructed programs
for the security of radioactive isotopes and hazardous chemicals dur-
ing storage, transit, and dismantling. He created and directed units
to escort hazardous and radioactive materials and was responsible for
developing army policies and procedures regarding the control of chem-
ical accidents. He developed and published the first comprehensive
army directive prescribing security procedures for the protection of
chemical sites against a terrorist threat.
As part of his work on army security programs, Mr. Adams screened and
evaluated security personnel, wrote security procedures, controlled
chemical accidents and incidents, and handled emergency reaction force
procedures. As studies officer, he conducted long-range studies for
equipment, training, and organizational requirements for handling
hazardous and radioactive materials.
As army radiation protection officer, Mr. Adams organized and directed
a special unit to escort chemical ammunition from the manufacturing
plant to storage depots. The safety program he developed resulted in
an accident-free record for the two years he was in the unit.
He has served as director of a military school and has taught tech-
niques for dismantling terrorist bombs, military ordnance, and nuclear
weapons. Most civilian bomb squads are trained at this school. Dur-
ing his tenure, the school he directed was honored for its contribu-
tions to law enforcement and public safety by a resolution of the
Mississippi legislature.
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RICHARD C. BENSON
Technos, Inc.
EDUCATION:
B.S. , Geophysics
Graduate Studies in Ocean Engineering
Registered Geologist GA #312
A.I.P.G. Prof. Geologist #3686
EXPERIENCE:
Mr. Benson is the senior executive and chief scientist for Technos
Inc. He founded the company in 1972 .to provide state-of-the-art
consulting services within the field of the earth sciences. He
possesses a broad background in many of the earth sciences and is
considered an authority in engineering geology and Karst problems.
His development of the hazardous Karst model used by Technos was a
major breakthrough in dealing with subsidence in Karst areas. He has
evaluated numerous geotechnical problem sites including landslides,
dams, sinkhole collapses, and subsidence. In addition, his experience
covers a wide range of geohydrologic problems including landfills,
saltwater intrusion, and aquifer exploration and assessment, as well
as extensive hazardous material site assessments. Such work has been
carried out for chemical manufacturers, mining operations, municipal
governments, and Federal agencies, including the Array Corps of
Engineers, USDA Soil Conservation Service, and Bureau of Land
Management, and USGS Water Resources Division.
Under his guidance Technos has achieved numerous technical break-
throughs in the application of new approaches for assessing geohydro-
logic and engineering geologic problems. Many of these methodologies
are unique to the firm. Mr. Benson is author or co-author of 16
technical papers and a member of numerous professional societies.
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DAVID A. BUECKER
Ecology and Environment, Inc.
Region IX, FIT Member
Environmental Health Specialist
Toxic and Hazardous Materials
Specialist
Industrial Health Specialist
Safety and Risk Analyst
EDUCATION:
M.S., Public Health, University of North Carolina, 1978
Additional graduate courses, Environmental Engineering, State
University of New York at Buffalo, 1980
B.S., Biology, Florida State University, 1975
EXPERIENCE:
Mr. Buecker of E & E's San Francisco office has experience in hazard
and risk analysis and in the design of comprehensive environmental
health programs. He has performed industrial hygiene investigations
for methylene chloride and for methane gas. He has investigated the
public and occupational aspects of coal gasification. His training
and experience include the handling of toxic and hazardous substances.
He has provided expert testimony and has given public presentations
concerning his projects.
He designed an occupational health program for an industrial complex
in Santa Cruz, Bolivia. The program required the identification of
potential industrial health and safety hazards and the development of
organizational structure, equipment, and personnel requirements for
its industrial hygiene and occupational medicine components.
He conducted E & E's investigation of methane gas generation from a
sanitary landfill, the operator of which was applying for a facility
extension permit in Garfield Heights, Ohio. The project required Mr.
Buecker to determine and clarify qualitative and quantitative differ-
ences in the composition of landfill and natural gas, gas migration
patterns through compacted solid wastes, gas formation processes,
environmental parameters affecting gas generation, and analytical
testing methodologies. He performed an on-site survey and evaluated
gas samples. He provided expert testimony at an administrative hear-
ing before the Ohio Environmental Review Board concerning the gener-
ation of gas at the landfill.
.He prepared a risk analysis of the movement of hazardous materials by
rail, including accident probability and severity analysis, failure
mode analysis, demographic profiling, and determination of potential
liability. He has investigated asbestos exposure and use in community
schools and has recommended corrective action. He has researched the
causes of byssinosis in textile workers through the use of pulmonary
function testing and laboratory bioassays.
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STEVE CALDWELL
U.S.. Environmental Protection Agency
EDUCATION:
B.A., History and Geography, Valparaiso University, 1969
Graduate work in Geography,' University of Arizona
Research at the University of Arizona Dendrochronology Laboratory
EXPERIENCE:
Mr. Caldwell's experience includes:
o Drafting of notification (Section 3010) guidelines under RCRA
o Developing a damage assessment program to support RCRA regula-
tions
o Developing enforcement suppport in imminent hazard cases
o Developing the Guidance Manual for the Investigation of
Hazardous Waste Disposal Sites
o Managing the project to develop guidance for setting
priorities and the development of the form for use in a data
management system
SPECIAL EXPERIENCE:
Mr. Caldwell taught for three years at the International Christian
University in Tokyo, Japan.
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PAUL F. CLAY Region I, Assistant
Ecology and Environment, Inc. FIT Leader
EDUCATION:
M.S., Chemistry, University of New Hampshire at Durham, 1973
B.A., Zoology, cum laude,. University of New Hampshire at Durham, 1969
EXPERIENCE:
Mr. Clay is E & E's Assistant Team Leader for its Region I (Boston)
team for the Field Investigation of Uncontrolled Hazardous Waste
Sites. He has developed an inventory of hazardous waste cleanup
contractors in Region I, including information on their licensing and
equipment capabilities. He also developed a list of well-boring
contractors for possible use in groundwater monitoring at hazardous
waste sites. He is presently involved in developing standard
operating procedures for collection of environmental and hazardous
waste samples.
Mr. Clay has attended courses concerning the field monitoring and
analysis of hazardous materials both in Buffalo and in Cincinnati at
the EPA's National Training Center. He is familiar with field and
laboratory analytical techniques and sampling methods for hazardous
waste sites. He has served as the designated training officer for the
Region I field investigation team.
As an environmental administrator for the city of Haverhill, Massachu-
setts, he interfaced with local, state, and federal government agen-
cies and with the community. He was also involved with the solid and
hazardous waste disposal problems of the Boston area. He reviewed
existing solid waste facilities in New York and New England and pro-
vided input for the proposed siting of a solid waste disposal facility
in Haverhill. He reviewed environmental impact statements pertaining
to wetlands and the Massachusetts State Wetlands Protection Act. He
wrote a watershed/wetlands zoning ordinance, that was subsequently
adopted by the city council. His responsibilities also included bud-
get administration, personnel supervision, and the holding of public
hearings pertaining to environmental quality.
SPECIAL EXPERIENCE:
Gas Chromatography/Infrared Spectrophotometry
Paul Clay was the recipient of a National Science Foundation grant to
obtain a master's degree at the University of New Hampshire. His
independent research involved the use of gas chromatography and infra-
red spectrophotometry to analyze human tissue fat for DDT residues.
Teaching
His experience includes 11 years of teaching chemistry at the
secondary and community college levels.
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Paul F. Clay (Cont.)
SPECIAL EXPERIENCE:
Gas Chrotnatography/Infrared Spectrophotometry
Paul Clay was the recipient of a National Science Foundation grant to
obtain a master's degree at the University of New Hampshire. His
independent research involved the use of gas chromatography and infra-
red spectrophotometry to analyze human tissue fat for DDT residues.
Teaching
His experience includes 11 years of teaching chemistry at the
secondary and community college levels.
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Paul F. Clay (Cont.)
EMPLOYMENT:
Ecology and Environment, Inc., Buffalo, New York, 1980-present
Danvers High School, Danvers, Massachusetts, Biology, Chemistry, and
Ecology Teacher, 1969-1980
Northern Essex Community College, Haverhill, Massachusetts, Division
of Continuing Education, Instructor of Chemistry, Anatomy, and
Physiology, 1974-1980
City of Haverhill, Massachusetts, Member of Solid Waste Technical
Committee, 1975-1978
City of Haverhill, Massachusetts, Member of Conservation Commission,
1973-1978
Massachusetts Department of Mental Health, Danvers State Hospital,
Danvers, Massachusetts, Psychiatric Aide, 1966-1969
BIBLIOGRAPHY:
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Paul F. Clay (Cont.)
PROJECTS AT E & E:
EPA-2, EP-980
See experience Summary.
LANGUAGE CAPABILITIES: GERMAN
Reading: Fair, semitechnical
Writing: Passable, nontechnical
Speaking: Fair
BID PROPOSALS AND REPORTS BIOGRAPHY HAS BEEN USED IN:
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DAVID L. DAHLSTROM
Ecology and Environment, Inc.
Occupat ional/Environmental
Health Specialist
Radiological Health and Safety
Specialist
E & E Corporate Safety
Director
EDUCATION:
M.S., Environmental Sciences and Engineering, Drexel University, 1978
B.S., Chemistry/Biology, University of Tennessee, 1973
EXPERIENCE:
Mr. Dahlstrom is E & E's corporate safety director. He has served as
E & E's technical assistance team leader in Cincinnati for the Oil and
Hazardous Substances Spill Prevention and Environmental Emergency
Response Program for the United States Environmental Protection
Agency.
He has been responsible for training EPA, Coast Guard, and E & E
personnel about hazardous material incident mitigation and response,
respiratory protection and protective clothing, field instrumentation
and analysis, hazard assessment, and standard, operating procedures
concerning hazardous materials. As a member of E & E's health sur-
veillance committee, he has provided input concerning general safety
practices for personnel involved with hazardous waste sites and toxic
material spills. He was extensively involved in the formulation of
E & E's hazardous materials response program. He has also developed a
technical plan for E & E's activities regarding the Toxic Substances
Control Act and is experienced in applying the regulations stemming
from the Occupational Safety and Health Act.
He has participated in numerous hazardous waste site investigations
and emergency responses including on-site surveillance of a two-day
fire involving hazardous materials in Denver, Colorado.
In previous assignments, he used acid containment principles in con-
trolling low-grade thorium emissions which had reached a stream after
leaking through a containment dike. He is experienced in handling
inorganic chemical compounds including a wide range of solvents and
hazardous dust, often containing radioisotopes.
SPECIAL EXPERIENCE:
Toxic and Hazardous Substances Management
Mr. Dahlstrom has worked on control and containment of oil and haz-
ardous chemicals. He participated in the containment of an oil spill
on the Tennessee River which threatened to affect municipal water sup-
plies. He has studied the use of biological controls to degrade oil
spills, specifically Acinebacter phosphadevorus, a microorganism
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David L. Dahlstrom (Cent.)
capable of assimilating phosphates and oil which is superior to other
microorganisms for oil cleanup because of its capability to digest a
large number of carbon compounds. He studied the hazards and risks
involved with an LNG terminal near Pascogoula, Mississippi.
While at W. R. .Grace Chemicals, Mr. Dahlstrom also was involved with
the planning for control and containment of a low-grade thorium
compound which had reached a stream after leaking through a
containment dike. He traced the dispersion of the thorium in the
environment. He learned and applied the principles of acid
containment and protection, particularly with hydrofluoric,
hydrochloric, perchloric, and sulfuric acid. While in this position,
he served as chairman of the Plant Communications Council.
Prior to his association with Grace, Mr. Dahlstrom worked for Cutter
Laboratories in Chattanooga where his activities involved biological
analysis of raw materials and finished products, clean room opera-
tions, and the biological seeding of intravenous solutions. He gained
extensive experience in the control of hazardous microbiological
materials, including yeasts, molds, and fungi. He was involved with
the requalification by the United States Food and Drug Administration
of a plant producing intravenous solutions.
During his graduate studies, Mr. Dahlstrom specialized in radiological
health and safety and occupational/environmental health. In his
master's dissertation, which contributed to the State Health Plan for
Pennsylvania, he examined environmental and occupational factors as
causes for lung cancers and other cancers in terms of industrial and
community health.
Laboratory Analysis
Mr. Dahlstrom is proficient in analytical procedures using infrared
spectroscopy, gas chromatography, ultraviolet adsorption, atomic
adsorption, magnetic resonance, and emission spectroscopy and is
experienced with the use of radioisotope survey and monitoring
instruments and systems.
At Velsicol Chemical Corporation, where he worked as an analytical/
quality control chemist, he was involved with the handling of many
organic solvents, including benzene compounds, toluene, MBK, and MIBK.
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ANTHONY A. FUSCALDO Region III, Assistant FITL
Ecology and Environment, Inc. . Safety,Officer
EDUCATION:
Ph.D., Microbiology, Indiana University, 1967
M.S., Virology, St. John's University, 1963
B.S., Biology, St. John's University, 1961
Special training in Biohazard and Injury Control, Minnesota School of
Public Health; Cancer Research Safety, National Cancer Insti-
tute; Town Planning, West Chester State College
EXPERIENCE:
Dr. Fuscaldo joined E & E as assistant team leader for the Region III
(Philadelphia) team for the Field Investigation of Uncontrolled Haz-
ardous Waste Sites. His primary responsibilities have concerned
health and safety including personnel training, decisions regarding
procedure and equipment in the field, and input to standard operating
procedures during field investigations. He is also responsible for
coordinating safety procedures for subcontractor personnel and for
directing Region III FIT field operations. This involves scheduling,
planning, and supervision of operations from preliminary assessment of
hazardous waste sites through the site visit and final report.
Prior to joining E & E he was employed at the Cancer Institute of
Hahnemann Medical College as Director of the Electron Microscopy
Laboratory. He headed the research laboratories for the Institute s
Medical Oncology Division. He directed the Division of Tumor Biology
for the Department of Medical Oncology and Hematology, with responsi-
bility for the electron microscopy laboratories, the viral oncology
laboratories, the tissue culture laboratories, the biochemistry
laboratories, the biohazard laboratory suite, the instrumentation
laboratory, the cytogenetic facilities, and the division library.
Because of his experience with biohazard laboratories at the Army
Biological Laboratories at Fort Detrick, Maryland; radiological safety
at Merrell-National Laboratories; carcinogenic safety at the Cancer
Institute; and various National Institute of Health Safety symposia,
he was appointed Carcinogenic and Biosafety Officer at Hahnemann Medi-
cal College and Hospital. In this capacity, he wrote "Hahnemann
Institutional Life Safety Committee Standards for Laboratory Opera-
tions Involving Carcinogens" and instituted procedures to implement
the regulations. He was appointed Chairman of the Institutional
Biosafety Committee which is charged with monitoring recombinant DNA
research and other biohazards within the medical school and hospital
complex.
He edited the "Handbook of Laboratory Safety" for Academic Press, Inc.
It covers all aspects of laboratory safety from psychological factors
and medical surveillance; through physical and electrical safety; to
laboratory techniques such as animal handling, radiation safety, bio-
safety, and carcinogenic and toxicological problems. He assisted in
planning and teaching a course in environmental hazards of the labora-
tory at Hahnemann Medical College.
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AnChony A. Fuscaldo (Cont.)
SPECIAL EXPERIENCE:
Cancer Research
As a principal investigator in the viral genetics branch of the Army's
Virus Rickettsia Division at Fort Detrick, Maryland, Dr. Fuscaldo was
responsible for overseeing the work of three research teams. He held
administrative responsibilities for personnel, budget, technical plan-
ning, and reports.
In 1970, he was a member of a committee of five scientists lobbying
for the conversion of Fort Detrick to a Cancer Research Center. His
primary task was political liaison with federal and state officials..
He maintained an active relationship with members of Congress and
their staffs. He was also the public relations officer for the group^
His efforts in this area resulted in favorable reports in newspapers
such as the Washington Po s t, Washing.tq n S tar, and Baltimore jun; in
national scientific publications such as Science and Nature; and on
television including Metro Media TV. and the ABC evening news. In
1972, Fort Detrick was converted to the Frederick Cancer Research
Center.
He was the sole editor-consultant for the Cancergram entitled "Virus
Studies in Humans and Other Primates," an information service provided
to researchers .by the Franklin Institute under contract from the
International Cancer Research Data Bank (ICRDB) program of the
National Cancer Institute. In addition, he has also acted as a con-
sultant for the Cancergrams entitled "Antigens Associated with Cancer-
Related Viruses" and "RNA Viruses Associated with Cancer" (excluding
Studies in Avian and Primate Systems).
Viral Vaccine Research
At Merrell National Laboratories in Pennsylvania, his responsibilities
included the development of testing procedures for vaccine purity and
the development of new viral vaccine strains. The former responsibil-
ity involved the use of isotope dilution techniques, as well as
developing new radioimmunoassay techniques. The latter responsibility
included the writing of IND1s for new virus vaccine strains. He was
also the radiation safety officer for the Swiftwater plant. During
his tenure, Atomic Energy Commission radiation inspections resulted in
approved ratings.
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RAYMOND D. HARBISON, PH.D. Advisor for Health
Department of Pharmacology Surveillance Program
and Biochemistry and Training Pro-
Vanderbilt University grams, Oil and Haz-
School of Medicine ardous Substances
Spill Prevention and
Emergency Response
Program
Dr. Harbison has worked as a consultant to E & E. During early phase
of both the TAT and FIT, he served as a lecturer in toxicology and
health, and safety aspects of handling hazardous and toxic wastes. He
was the advisor and monitor of the health surveillance program which
was developed for E & E TAT and FIT programs.
For E & E, Dr. Harbison has a 24-hour emergency toxicological service
in case E & E personnel are exposed to chemicals. Dr. Harbison
directs the National Hazardous Materials Training Course which is
sponsored by the Toxic Substance Control Institute. The course was
originally developed in conjunction with the EPA, and has been used to
train EPA on-scene coordinators of hazardous materials spills and
United States Coast Guard and Navy personnel.
Dr. Harbison's additional background and experience are summarized
below:
o Editorial Board, Teratogenicity, Mutagenicity, Carcinogen-
icity, 1979-present
o Society of Toxicology Achievement Award, 1978
o Scientific Program of National Center for Toxicological
Research, 1977-1978
o Professional Affairs Committee, . American Society for
Pharmacology and Experimental Therapeutics, 1977-present
o National Institute on Drug Abuse—review of DAWN (Drug Abuse
Warning Network), 1977-present
o Editorial Board, Environmental Health Sciences, 1976-present
o National Academy of Science, Advisory Center for Toxicology—
revision of Toxicity Testing Procedures for Consumer Protec-
tion Agency, 1976-1977
o National Institute on Drug Abuse Center Review Committee,
1975-1976
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Raymond D. Harbison (Cont.)
o National Institute on Drug Abuse, Clinical Behavioral Review
Committee, 1974-1975
o Standing Policy Committee on Biomedical Sciences, Vanderbilt
School of Medicine
o Consultant, Congressional Committee on Safety Assessment of
Chemical Additives and Drugs, 1974-present
o Editorial Board, International Journal of Addictive Diseases,
1974-present
o Chairman, Technical Committee of the Society of Toxicology,
1975-1976
o Co-chairman, Technical Committee of the Society of Toxicology,
1974-1975
o National Institute of Mental Health—Narcotic Addiction and
Drug Abuse Review Committee, Biomedical—Ph'armacology—Toxico-
logy, 1971-1975
o Vanderbilt University School of Medicine, Associate Professor
of Pharmacology and Biochemistry, 1977-present
o Vanderbilt School of Medicine, Assistant Professor of Pharma-
cology and Biochemistry, 1972—1976
o Director of Teratology Section, Laboratory of Environmental
Health, Department of Medicine, School of Medicine, Tulane
University., 1971-1972
o Tulane Medical School, Assistant Professor, Department of
Pharmacology, 1971-1972
o Tulane Medical School, Instructor of Pharmacology, 1969-1970
o USPHS Trainee, University of Iowa, Department of Pharmacology,
College of Medicine, Iowa City, Iowa, 1965-1969
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ROBERT J. KING Assistant National Project Manager
Ecology and Environment, Inc. for Training and Safety, Field
Investigation
Public Health Specialist
Technical Advisor
EDUCATION:
M.P.H., University of Minnesota, 1972
United Nations Graduate Program on the Human Environment, 1972
B.M.E., University of Minnesota, 1968
EXPERIENCE:
Mr. King recently returned to E & E as the assistant national project
manager for training and safety for E & E's contract with the United
States Environmental Protection Agency for the Field Investigation of
Uncontrolled Hazardous Waste Sites. In addition to his public health
training and managerial experience, he has a long history of practi-
cal field experience .with the oil, gas, and synthetic fuel industries.
Mr. King was responsible for environmental work on a $40—million tech-
nical support contract with the Department of Energy's (DOE's) Divi-
sion of Fossil Fuel Processing coal conversion program. He acted as
environmental advisor for coal conversion programs including the SRC I
and SRC II coal liquefaction demonstration facilities in Kentucky and
West Virginia. He also managed a number of coal conversion investiga-
tions entailing environmental studies for a coal gasification multi-
test facility; environmental surveillance on the construction of a
gasifier-in-industry program; and a peat gasification development pro-
gram.
For the multi-test facility, Mr. King managed and participated in site
feasibility studies, evaluated environmental regulations, and estab-
lished design criteria for waste treatment process. . For the coal gas-
ification demonstration program, he evaluated requirements and compli-
ance needs of the Resources Conservation and Recovery Act. For the
gasifiers-in-industry program, he evaluated environmental permit re-
quirements and monitored the construction of facilities for compli-
ance. He participated in employee and public safety reviews for two
competing processes for the coal liquefaction program.
In addition, he headed a team which evaluated the environmental and
technical issues that could potentially constrain development of al-
ternate fuel technologies. The issues included the siting of coal
liquefaction facilities to meet the President's Executive Order and
peat gasification program. In support of DOE Headquarters, he moni-
tored the environmental work of other support contractors, process
developers, ORNL and ORO.
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Robert J. King (Cont.)
Mr. King has worked as an air pollution/public hea-lth specialist and
project engineer at E & E. He was assigned to environmental assess-
ments of energy-related .facilities and evaluation of OSHA require-
ments. He was responsible for characterization of all potential pol-
lution sources, dissemination of these analyses to other members of
the review team, and direction of the air pollution analyses of the
atmospheric environment and proposed projects' impacts.
SPECIAL EXPERIENCE:
Alaska
As assistant project manager for E & E's Trans-Alaska Pipeline proj-
ect, Mr. King assembled a five-report summary of procedures for envi-
ronmental design considerations, the oil spill contingency plan, envi-
ronmental compliance, fuel gas line construction, and the evaluation
of oil spill incidents at Alyeska's Marine Terminal. These reports
represented a compendium of extensive field experience and were writ-
ten to serve as training guides and field manuals for future major
arctic construction activities such as the approved ALCAN gas pipeline
project.
-He devised and conducted an oil spill demonstration program to eval-
uate Alyeska's readiness to execute its oil spill contingency plan.
This program evaluated equipment allocation and readiness, personnel
training, and the actual response to spill conditions which would be
encountered in Alaska.
He also held responsibility for the design review of the Trans-Alaska
Pipeline System's Valdez terminal. He managed E & E's field surveil-
lance program. His responsibilities included the response to oil
spills; improvement of fuel handling procedures; and evaluation of
life support systems such as sewage plants, potable water supply fa-
cilities, incineration, and other waste disposal techniques.
In addition to field surveillance duties, Mr.'King directed the devel-
opment of the Alaska Pipeline Office Oil Spill Response Manual for the
Department of the Interior. He prepared and conducted a training pro-
gram for government representatives who will be on-scene coordinators
in the event .of pipeline-related spills. During startup of the TAPS,
he was the lead environmentalist on the control and cleanup of four
crude oil spills involving a sabotage incident, explosion of a pump
station and leaks from valves.
Air
He has managed environmental projects dealing with ambient air moni-
toring, air pollution source compliance testing, solid and liquid
waste management studies, and studies of leachate from landfills.
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MARTIN S. MATHAMEL Region V, FIT Member
Ecology and Environment, Inc. Chemist
EDUCATION:
B.S., Chemistry, University of Michigan at Ann Arbor, 1971
Graduate courses, Chemistry, Loyola University, 1979; Eastern Michigan
University at Ypsilanti, 1973
EXPERIENCE:
Mr. Mathamel joined E & E as a member of its Region V (Chicago) team
for the Field Investigation of Uncontrolled Hazardous Waste Sites.
He previously supervised-a computer-assisted forensic and industrial
consulting laboratory in Illinois. His work included the use of gas
and high-performance liquid chromatography, infrared and ultraviolet
spectroscopy, microscopy, and wet chemistry. He has performed EPA
stationary source and hydrocarbon compliance testing, as well as
Occupational Safety and Health Act (OSHA) sampling. He has provided
expert testimony in conjunction with his assignments.
Mr. Mathamel has conducted arson investigations and has analyzed fire
accelerants in fire debris and has performed flashpoint and flammabil-
ity testing. He has evaluated explosives and assisted in the prepara-
tion and presentation of a seminar entitled "Professional Techniques
in Investigating Accidents."
In addition, he has applied instrumental and analytical laboratory
procedures to air and water pollution, and to plastic and rubber
analysis. ' In Illinois, he supervised a year-long ambient air sampling
program with the EPA in conjunction with the University of Illinois.
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JAMES B. MOORE Region IV, FIT Member
Ecology and Environment, Inc. Hydrologist
EDUCATION:
M.S. Candidate, Forest Resources/Forest Hydrology, University of
Georgia
B.S., Biology, The Citadel, 1970 •
EXPERIENCE:
Mr. Moore joined E & E as a member of its Region IV (Atlanta) team for
the Field Investigation of Hazardous Waste Sites.
Mr. Moore has 10 years' experience in hazardous waste management and
environmental assessment, remote sensing, water quality research, and
military administration and command. He has experience in Georgia as
an ecologist and engineer on hazardous and residual waste management,
flood insurance, and terrain analysis projects. He has used remote
sensing data in environmental- assessments of land use changes, water
quality research, and non-point-source pollution control.
Mr. Moore developed hazardous waste management planning programs for
the states of Tennessee and Alabama. He supervised a six-month survey
of 400 industrial residual and hazardous waste generators, trans-
porters, and disposers in the state of Alabama to determine best
residual waste management plans for the state and private industry.
In addition, he supervised an intensive effort to determine disposal
methods at 17 army ammunition plants and depots.
SPECIAL EXPERIENCE:
Hydrology/Water Quality
Mr. Moore has assisted in base condition hydrologic analysis and
hydraulic modeling for flood insurance studies for several cities and
counties in Georgia. He supervised the preparation of -environmental
assessments for a beach nourishment project on the Gulf Coast, an
industrial effluent pipeline route through an endangered species hab-
itat, and a metropolitan water supply study.
As a graduate research assistant, Mr. Moore collected, collated, and
analyzed water quality data from first experimental watersheds located
in Piedmont physiographic region of Georgia. Implemented experimental
procedures used in water quality, erosion, sedimentation, and non-
point-source .pollution control studies.
Lanj Use
Mr. Moore coordinated acquisition and analysis of data from remote-
sensing satellites (LANDSAT) to determine the state-wide environmental
and economic impacts of placing marginal, sub-marginal, and Soil Bank
land into crop production. He used R-Index Method and specially
developed land resource units to determine state-wide, non-point-
source pollution caused by herbicide, insecticide, and fertilizer use.
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BOYD N. POSSIN Region V, FIT Member
Ecology and Environment, Inc. .Hydrogeologist
EDUCATION:
M.S., Geology, University of Wisconsin at Madison, 1973
M.S., Water Resources Management, University of Wisconsin at Madison,
1972
B.S., Earth Science Secondary Education, University of Wisconsin at
Madison, 1970
PROFESSIONAL AFFILIATIONS:
Geological Society of America
American Water Resources Association
American Water Well Association
EXPERIENCE: .
Mr. Possin is the assistant team leader and training officer for
E & E's Region V (Chicago), office under the FIT contract. He has
eight years of hydrogeplogical experience in the Great Lakes area and
has conducted and managed a wide variety of environmental studies.
With E & E, he has acquired field experience in the investigation of
hazardous waste sites. He has completed onsite evaluations of soil
and groundwater contamination in Minnesota and Ohio. In Michigan, he
has determined the effects of a hazardous waste landfill on the
Detroit River. In previous experience as a team leader on a contam-
inated waste processor project for the Corps of Engineers in
Huntsville, Alabama, he developed waste handling and processing alter-
natives for pyrotechnics, explosives, and propellants.
As the manager of a regional office of an environmental consulting
firm in Chicago, he was previously responsible for environmental moni-
toring, preparation of environmental impact statements and reports,
and preparation of reports dealing with various aspects of flood
control.
As a self-employed environmental consultant, he performed monitoring
and feasibility studies for 27 Inland Lake Protection and Rehabili-
tation districts in Wisconsin. He also conducted studies of ground-
water contamination from waste disposal operations.
As a researcher at the University of Wisconsin, he was responsible for
designing and implementing a field program for developing the surface
and groundwater hydrologic regimes of two lakes in Wisconsin.
In Pennsylvania, he participated in several types of hydrogeological
consulting projects including the preparation of draft environmental
report modules for sanitary landfills and spray irrigation sites. He
also served as project manager for the preparation of the groundwater
quality plan for the seven-county Philadelphia region as part of
Pennsylvania's version of the 208 planning process.
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JOHN. R. TOTIN Region VI, Assistant FIT Leader
Ecology and Environment, Inc. Chemical Engineer
EDUCATION:
B.S., Chemistry, Boston College, 1957
EXPERIENCE:
Mr. Totin joined E &. E as assistant team leader for the Region V.I
(Dallas) Field Investigation of Uncontrolled Hazardous Waste Sites
which the company is performing for the United States Environmental
Protection Agency. He previously served for 21 years with the United
States Army, earning the rank of lieutenant colonel in the Chemical
Corps. He has extensive experience in problem solving and planning
and allocation of scarce resources to provide environmental protection
.from toxic chemical and radiological agents. He expedited and direc-
ted the massive movement and storage of chemicals; developed and mon-
itored training exercises for the handling of toxic agents including
substance identification, decontamination, and casualty management;
and wrote contingency plans for both military operations and regional-
management, of nuclear, or chemical accidents within a four-state area.
He is skilled in training and directing .technical work groups, inter-'
personal communications, and budget planning and coordination. He
also has prepared environmental impact assessments to support the. use
of simulated toxic chemical agents in training.
Mr. Totin has considerable expertise in coping with nuclear and chem-
ical accidents, as well as in the study of technical analysis and com-
putations related to protection of personnel and work- environments
from harmful dosages.of radiation.
Mr. Totin has been a speaker at several National Governors Association
conferences on landfill, hazardous waste, and resource conservation
and-recovery task forces. He has addressed special interest groups in
the Chicago area and has participated in public hearings regarding
toxic substances.
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