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Home My WebLink AboutDERR-2024-009136Utah Underground Storage Tank (UST) Remover Recertification Guide November 2008 INDEX Section 1: UST Notification Requirements EPA Notification Form (7530-1) Section 2: Closure Closure plan requirements Closure Plan Form Permanent Closure Notice Form Temporary Closure Notice Form Section 3: Utah Petroleum Storage Tank Fund Utah's PST Fund Guidebook Section 4: Environmental contamination, Reporting a Release, Hazardous Substances Guidelines for disposition and treatment of petroleum contaminated soils Toxicity characteristics rule cheat sheet Requirements for hazardous substance USTs Section 5: Safety MSDS for gasoline Trenching, shoring and USTs Health and safety training for UST inspectors Oxygen monitors, CGIs and specific chemical monitors UST NOTIFICATION REQUIREMENTS It is important to understand UST notification requirements to determine if an UST is regulated under the Utah UST Program. Of course, the DERR makes the final judgment to determine if an UST is regulated. UST removers should have a general understanding of which USTs are regulated. Owners and operators of non-regulated are not required to follow UST rules and regulations. Regulated USTs include: (See 40 CFR 280.12 Definitions: "LJnderground storage tank") o tank and connected piping that has at least IjVo of its volume underground; and o stores petroleum or certain hazardous substances. Ethylene Glycol (antifreeze) is a hazardous substance. A release from a hazardous substance UST must also be reported to RCRA and cleaned up according to RCRA standards. Non-regulated USTs include (See 40 CFR 280.10 &280.12) . non-commercial farm or residential tanks of 1,100 gallons or less o heating oil tanks for use on the premise . tanks holding 110 gallons or less o flow-through process tanks Review federal regulations: 40 CFR 280 Subpart A 280.10 - 280.12 Program Scope ... Subpart B 280.22, Notification requirements Regulated USTs which are not registered, are not in compliance with UST rules are subject to penalties. See: Utah UST Act 19-6-408. When an UST remover submits a closure plan for a non-registered UST, the DERR will notify the UST owner or operator concerning registration and back fees. Contents: EPA Notification Form (7530- 1) EPA Form 753G1 (Bev. 1 1-98) Electronic and paper versions acceptable Previous editions may be used while supplies last. 9EPA United States Environmental Protection Agency Washington, DC 20460 Notification for Underground Storage Tanks State Agency Name and Address: UTAH DEPARTMENT OF ENVIBONMENTAL QUALIry DIVISION OF ENVIRONMENTAL RESPONSE AND REMEDIATION 168 NORTH 1950 WEST SALT LAKE CITY, UTAH 841 16 n n. New FAcrLrrY - Number of continuation sheets attached Please tvpe or print in ink. Also, be sure you have signatures in ink for sections Vlll and Xl. Complete a notification form for each location containing underground storage tanks. lf more than 5 tanks are owned at this location, you may photocopy pages 3 through 5 and use them for additional tanks. The primary purpose of this notification program is to locate and evaluate underground storage tank systems (USTS) that store or have stored petroleum or hazardous substances. The information you provide will be based on reasonably available records, or in the absence of such records, your knowledge or recollection. Federal law requires UST owners to use this notification torm for all USTs storing regulated substances that are brought into use after May 8, 1986, or USTs in the ground as of May 8, 1986 that have stored regulated substances at any time since January 1, 1974. The information requested is required by Section 9002 of the Resouree Conservation and RecoveryAct (RCRA), as amended. Who Must Notify? Section 9O02 of RCRA, as amended, requires owners of USTS that store regulated substances (unless exempted) to notify designated State or local agencies of the existence of their USTs. "Orvner,' is defined as: . In the case of an UST in use on November 8, 1 984, or brought inlo use after that date, any person who owns an UST used for storage, use, or dispensing of regulated substances; or . In the case of an UST in use before November 8, 1984, but no longer in use on that date, any person who owned the UST immediately before its discontinuation. Also, if the State so requires, any facility that has made any changes to lacility information or UST system status, must submit a ndtification form (only amended information needs to be included). What USTs Are Included? An UST system is defined as any one or combination of tanks that (1) is used to contain an accumulation of regulated.substances, and (2) whose volume (including connected underground piping) is 107" or more beneath the ground. Regulated USTs store petroleum or hazardous substances (see the following lA/hat Substances Are Covered"). What Tanks Are Excluded From Notification? . Tanks removed from the ground before May 8, 1986; . Farm or residential tanks of 1,100 gallons or less capacity storing motor fuel for noncommercial purposes; . Tanks storing heating oil for use on the premises where stored; . Septic tanks; . Pipeline facilities (including gathering lines) regulated under the Natural Gas Pipeline Safety Act of 1968, or the Hazardous Liquid Pipeline Safety Act of 1979, or which is an intrastate pipeline facility regulated under State laws; . Surface impoundments, pits, ponds, or lagoons; . Storm water or waste water collection systems; . Flow-through process tanks; . Liquid traps or associaled gathering lines directly related to oil or gas production and gathering oierations; . Tanks on or above the floor of underground areas, such as basements or tunnels: . Tanks with a capacity of 'l10 gallons or less. What Substances Ane Covered? The notification requiremenls apply to USTs containing petroleum or certain hazardous substances. Petroleum includes gasoline, used oil, diesel fuel, crude oil or any fraction thereof which is liquid at standard conditions of temperature and pressure (60 degrees Fahrenheit and 1 4.7 pounds per square inch absolute). Hazardous substances are those found in Section 1 01 (14) of the Comprehensive Environmenlal Response, Compensation and Liability Act of '1980 (CERCLA), wiih the exception of those substances regulated as hazardous waste under Subtitle C of RCRA. Where To Notify? Send completed forms lo: STATE OF UTAH DIVISION OFENVIRONMENTAL RESPONSE 168 NORTH 19s0 WEST PO BOX 144840 SALT LAKE CITY, UTAH 84114-4840 When To Notify? 1. Owners of USTs in use or that have been taken out of operation after January 1, 1974, but still in the ground, must notify by May I, 1986. 2. Owners who bring USTs into use after May 8, 1986, must notify within 30 days of bringing the UST into use. 3. lf the State requires notification of any amendments to facility, send information to State agency immediately. Penalties: Any owner who knowingly fails to notily or submits false information shall be subiect to a civil penalty not to exceed $11,000 for each tank for which notification is not given or for which false information is given. Name (Corporation, Individual, Public Agency, or Other Entity)ll required by State, give the geographic location of USTs by degrees, minutes, and seconds. Example: Latitude42" 36' 12'N, Longitude 85" 24'17'W Facility Name or Company Site ldentifier, as applicable tr lf address is the same as in Section l, check the box and proceed to section lll. lf address is different, enter address below: Street Address County Phone Number (lnclude Area Code) Page 1 ot 5 9EPA United States Environmental Protection Agency Washington, DC 20460 Notification for Underground Storage Tanks n Federal Government I s,ut" Government I commercial n ucat covemment n Private USTs are located on land within an Indian Reservation or on trust lands outside reservation boundaries. USTs are owned by a Native American nation or tribe. Tribe or Nation where USTs are located: I Gas Station n P"uol"r. Distributor f] Rirraxi (Airline) n Aircraft owner ! Rr,o Dealership n Raitroad fl Federal - Non-Military I Federat - Military I lndustrial fl contractor ! tructingrrransport I urititi"" I Residential n rurt Phone Number (lnclude Area Code): Check All that Apply n s"rr lnsurance n cormercial lnsurance ! ni.t Retention Group ! tocat Government Financial Test nt nuu" met the financial responsibility requirements (in accordance with 40 CFR Subpart H) by using the following mechanisms: J-'l Gurrant"" n surety Bond n Letter of Credit E eonO Rating Test n s,"," rrnd" n TrustFund t] O,r,", Method (describe here) I certify under penalty of law that I have personally examined and am familiar with the information submitted in Sections I through Xl of this notification form and all attached documents, and that based on my inquiry of lhose individuals immediately responsible for obtaining the information, I believe that the submitted intormation is true, accurate, and complete^ Paperwork Reduction Act Notice EPAestimatespub|icreportingburdenforthiSformtoaVerage30minutesperresponseinc|udingtimeforrevieWinginStructions,gatheringandmaintaining comp|etingandreVieWingtheform,SendcommenlSregardingthisburdenestimatetoDire MStreet,waShingtonD.c.20460,marked.AttentionDeskofficerforEPA."Thisforma of this notification lorm may be used while supplies last. Name and official title of owner or owner's authorized representative (Print) EPA Form 753G1 (Rev. 11-98) Electronic and paper versions acteptable. Previous edilions may be used while supplies last. 9EPA Uniled States Environmental Protection Agency washington, DC 20460 Form Approved. OMB No.2050-0068 Notification for Underground Storage Tanks Tank ldentification Number Tank No. -Tank No. -Tank No. -Tank No. -Tank No. - 1. Status of Tank (check only one) Cunently In Use Temporarily Closed Permanently Closed trntr Dntr nnu trtr ! Dtrtr 2. Date of lnstallation (month/year) 3. Eslimated Total Capacity (gallons) Material ot Construction (check all that apply) Asphalt Coated or Bare Steel Cathodically Protected Steel Coated and Cathodically Protected Steel Composite (Steel Clad with Fiberglass) Fiberglass Reinforced Plastic Lined lnterior Excavation Liner Double Walled Polyethylene Tank Jacket Concrete Unknown lf Other, please specify here Check box if tank has ever been repaired n tr ! tr tr !u tr n tru n n tr ! !u !u nu tr ! tr u D tr ! tr n !un D L ! n Dun n ! tr tr n D n tr I tr n ! tr tru n tr tr ! tr 5. Piping Material (check all that apply) Bare Steel Galvanized Steel Fiberglass Reinforced Plaslic Copper Cathodicalty Protected Double Walled Secondary Containment Unknown Other, please specify !u tr ! tr n ! tr ! tr ! D D tr n tr n n u !u n tr ! ! n tr n tr il n tr tr tr ! tr tr n tr n 6. Piping Type "Safe" Suction (no valve at tank) (Check all that apply) "U.S." Suction (valve at tank) Pressure Gravity Feed Check box if piping has ever been repaired tr ! tr D tr ! n ! D I tr n tru tr ! tr I n il tr I I tr ! EPA Form 7530-1 (Rev- 11-98) Electronic and paper versions acceptable Previous editions may be used while supplies last. Page 3 ol 5 9EPA United States Envi ronmental Protection Agency Washington, DC 20460 Form Approved. OMB No.2050-0068 Notification for Underground Storage Tanks Tank ldentification Number Tank No. -Tank No. =-Tank No. -Tank No. -Tank No. - 7. Subslance Currently Stored (or last Gasoline stored in the case of closed tanks) Diesel ( Check all that apply) Gasohol Kerosene Heating Oil Used Oil lf Other, please specify here Dtrtr D tr Dnntrn _n_ u Iu Du il ntr !trntr nHazardous Substance CERCLA name and/or CAS number n n n n Mixture of Substances Please specify here u TIU tr tr n Refease Deteclion (check all that apply) Manual tank gauging Tank tightness testing Inventory Control Automatic tank gauging Vapor monitoring Groundwater monitoring Interstitial monitoring Automatic line leak detectors Line tightness testing No release detection required (such as some types of suction piping, emergency generator tanks or field constructed ianks) Other method allowed by implementing agency (such as SIR) Please specify other method here TANK tr n tr n n n ! tr n PIPE tr tr tr n I tr tr rANK I P|PE !l nl I !1tr nl! trlr rln l! lrnln Inl TANK n tr tr ! tr n n ! ! PIPE ! tr n tr n tr n TANK n u n n n ! tr D ! PIPE n n tr ! n D n TANK tr I tr n ! tr u n tr PIPE n tr n tr n D tr 9. Spill and Overfill Protection Overfill device installed Spill device installed n n nu u n n tr tr n EPA Form 7530-1 (Rev. 1 1 -98) Electronic and paper versions acceptable. Previous editions may be used while supplies last. Page 4 of 5 \9EPA United States Environmental Protection Agency Washington, DC 20460 Notification for Underground Storage Tanks 1. Closure or Change in Service Estimated date the UST was last used lor storing regulated substances (month/day/year) Check box il this is a chanoe in service 2. Tank Closure Estimated date tank closed (month/daylyear) (check all that apply below) Iank was removed from ground Tank was closed in ground Tank filled with inert material Describe the inert fill material here 3. Site Assessment Check box il the site assessment was comoleted Check box if evidence ol a leak was detected Installer Of Tank And Piping Must Check Al That Apply: Installer certified by tank and piping manufacturers Installer certified or licensed by the implementing agency . Installalion inspected by a registered engineer Inslallation inspected and approved by implementing agency Manufacture/s installation checklists have been comDleted ! n tr n n ! n tr tr ! tr n n tr tr fI tr n I n n n n ! u n tr ! n trAnother method.allowed by State.agency I so, prease specfy nere Signature of UST Installer Certifying Proper Installation of UST System EPA Form 7530-1 (Rev. 1 1 -98) Electronic and paper versions acceptable. Previous editions may be used while supplies last Page 5 of 5 UST Permanent Closure Certified UST Removers MUST know every detail of the Utah UST closure process. Review: R311.204 Underground Storage Tanks: Closure and Remediation Review: 40 CFR 280.70 Subpart G: Out-of-Service UST Systems and Closure Review: UST Closure Irtter and attached Closure Plan Review: UST Closure Notice UST Removers should have a basic understanding of samples taken at UST closure. See: R31L- 205 Site Assessment Protocol. Individuals taking samples at UST closures must be Utah certified Soil and Groundwater Samplers. xNotex Closure of any portion of the tank system (tank, piping, dispensers) requires submittal, and approval of a Closure Plan. Environmental soil samples must be taken to determine the presence/absence of contamination. Temporary Closure Some tank owners/operators may want to close their tanks temporarily rather than permanently or convert their tanks to store an unregulated substance. UST Removers should know the requirements concerning temporary closure and change in service. Maintaining Closure Records UST regulations require owners/operators to maintain closure records for a minimum of 3 years after completion of permanent closure or change-in -service. DERR recommends that the records of all closure-related activities, including site maps and photographs revealing the location of the tanks and piping, analytical results, sample collection sites, written reports on the site assessment, etc., be maintained indefinitely. Contents: Closure Plan Requirements Closure Plan Form Permanent Closure Notice Form Temporary Closure Notice Form R311 -204, Utah Administrative Code (U.A.C.), requires Underground Storage Tank (UST) owners/operators to submit a Closure Plan outlining the details of the UST closure to the Executive Secretary (UST), Utah Solid and Hazardous Waste Control Board. 1. The Owner(s)/Operator(s) (O/O) must submit to the Division of Environmental Response and Remediation (DERR) a completed "CLOSURE PLAN" which must be approved before commencing closure of the UST. A contractor may complete the closure plan, however the O/O is responsible for compliance with the UST rules and regulations. 2, For closure in-place or chanqe in service, the Closure Plan must now be submitted and approved prior to completing the site assessment. 3. The approved Closure Plan is valid for one vear from the approval date. lf closure does not take place within one year the O/O must submit a new Closure Plan for approval. 4. The O/O must notity the Local Health and Fire Departments and the DERF/UST at least 72 hours prior to starting closure activities. 5. The certified UST remover and sampler performing the closure must have a current Utah certification and follow the approved Closure Plan. Changes to an approved plan must be submitted in writing to the Executive Secretary and approved before closure. 6. The O/O must have a copy of the approved Closure Plan on-site during closure activities. 7. The O/O must ensure the completion of a site assessment in accordance with 40CFR 28A.72 and R311-205, U.A.C.. lndicate the proposed sample locations on the Facility Site Plat of the Closure Plan and complete the Sample Information Table. lf contamination is encountered or suspected at locations other than the approved sample locations, additional samples must be collected at the location(s) where contamination is most likely to be present. lf groundwater is encountered a soil sample must be collected, in the unsaturated zone, in addition to each groundwater sample. 8. The O/O must report suspected or confirmed contamination (any amount) to the Executive Secretary by reporting to the DERH/Leaking Underground Storage Tanks (LUST) section at (801)536-4100 within 24 hours of discovery. 9. The O/O must submit to the DERR a Closure Notice within 90 davs after the tank closure. The Closure Notice should include: a. A properly completed Closure Notice form signed by the owner and certified groundwater and soil sampler. b. An updated Site Plat and a Sample Information Table with actual depths and locations of all samples, including depth of ground water. c. Analytical results of samples d. A Chain of Custody Form 10. The OiO must pay Registration and PST Fund fees for the assessment period in which the tank is closed and all other unpaid fees. 11. lf contamination is suspected or confirmed during UST closure activities, or is based on analytical results, the O/O may receive a reporting and remediation schedule from the DERF/LUST section, outlining their obligation to characterize and possibly remediate the release. Any person providing remedial assistance for a fee, including over-excavation (of more than 50 yds) and aeration, must be a Gertified UST Consultant (a list is available from the DERR). Expenses to be applied toward the Petroleum Storage Tank (PST) Fund deductible must meet the same test of reasonable, customary and legitimate as expenses submitted for reimbursement. For expenses above tne $10,000 deductible to be eligible for reimbursement from the PST Fund, all work plans and budgets must be approved the State Project Manager before any work begins Refer questions concerning the Closure Plan approval process to the DERF/UST section at (801) 536-4100. Send the completed Closure Plan to: State of Utah Department of Environmental Quality Division of Environmental Response and Remediation UST Section P.O. Box 144840 168 North 1950 West Salt Lake City, Utah 84114-4840 UNDERGROUND STORAGE TAIIK CLOSURE PLAN (rev. 1/05)FACILITY ID# LHD USE ONLY Date Received Reviewer Date LHD Aporoved Date mailed to State A Contractor may prepare this Closure Plan as the owner/operator's agent. In preparing the Closure Plan, the Contractor must act with the owner/operator's knowledge and approval. The owner/operator must sign the Closure Plan. This Closure Plan is submitted in compliance with the requirements contained in 40 CFR 280 Subpart G and R3l l-204 (U.A.C.) *Indicate the specific substance stored in each tank to be closed (regular, unleaded, diesel, waste oil, etc.) For waste oil tanks: Have degreasing or other types of solvents been stored or mixed with the waste oil? Yes (identify if known)Non Not Known f] Analysis for lead or other contaminants may be required prior to disposal of contaminated soil or other material. (Check with your disposal facility.) STATE USE ONLY Date Received Date Mailed to LHD Date Received From LHD Reviewer/Date Aooroved Mer. ReviedDate Closure Plan prepared at the request of the owner/ooerator (identified below) bv of (company name)Phone # Address ciw State Zip FACILITY INFORMATION Tank Owner Phone # f-l sole proprietorship f-l oartnershio f-l corporation Address City State Zro Facilitv Name Address Citv State Zio Contact person Phone # Total number ofregulated underground tanks at this site Total number ofregulated undersround tanks at this site to be closed Tank # Type (SteeI,FRP.etc.) Date Installed Capacitv Substance stored' Date last ooerated Removed/In Place/ Change in Service (CIS)? TANKREMOVERName Cert. # TR Exo. Date Company Phone # Address Citv State Zio SOIL/GROUNDWATER SAMPLER Name Cert. # GS Exp. Date Company Phone # Address Citv State Zio Before the closure plan is submitted for approval, the local health and fire departments where the facility is located must be contacted. If the facility is in Beaver, Carbon, Davis, Emery, Garfield, Grand, Iron, Kane, Salt Lake, San Juan, Wasatch, or lYashington county contact DERR (UST) at (801)536-4100 instead of the local health district. You still must contact the localfire dqparlmmt in these counties. CONTACT LOCAL HEALTH DISTRICT: Name of Dist.Date Contact Title Phone# CONTACT LOCAL FIRE DEPT. Name of Deot.Date Contact Title Phone# DISPOSAL INFORMATION Tank(s) will be disposed at: Facilitv Address City State Zip Contact person Phone# Product lines will either be: [l removed or l-l cleaned. secured in olace- and caooed. Vent lines will either be: ! removed or n cleaned and secured open Pipins will be disposed at: Faciliry Address Citv State Zip Contact person Phone# Tank(s) will be emptied bv: comoanv Phone# Tank(s) will be cleaned by: companv Phone# Contaminated water in the tank/rinsate will be disposed at: Facilitv Contact person Phone# Tank(s) will be: ! purged or ! rendered inert by the followine method: Residual sludges will be disposed at the followine facility: Address ciw State Zip Contact person Phone# FOR CLOSURE IN PLACE ONLY n Approval for in-place closure has been sranted bv the Local Fire Deoartment. Fire Dept.Phone#Contact person Date E Approval for in-place closure has been sranted bv the Local Health Deoartment. Health Dept.Phone#Contact person Date Substance to be used to fill tanks: SITE ASSESSMENT A site assessment must be performed for all UST closures and change-in-service. Site assessments must be performed as outlined in 40 CFR 280.72 and R31l-205 (U.A.C.). If contamination is suspected, additional samples must be collected at the location where contamination is most likely to be present. If groundwater is encountered, a soil sample must be collected, in the unsaturated zone, in addition to each groundwater sample. Soil and groundwater samples must be analyzed for the compounds shown in the following table, using appropriate lab methods. Substance or Product Type Contaminant Compounds to be Analyzed for Each Substance or Product Type ANALYTICAL METHODSI Soil, Groundwater or Surface Water Gasoline Total Petroleum Hydrocarbons (puIggablg TPH as gasoline range organics C6 - Cls) EPA 80158 or EPA 82608 Benzene, Toluene, Ethyl benzene, Xylenes, Naphthalene, (BTEXN) andMTBE EPA 80218 or EPA 82608 Diesel Total Petroleum Hydrocarbons (e$I491Ab19 TPH as diesel range organics C1s - C2s) EPA 8OI58 Benzene, Toluene, Ethyl benzene, Xylenes, and Naphthalene (BTEXN) EPA 80218 or EPA 82608 Used Oil Oil and Grease (O&G) or Total Recoverable Petroleum Hydrocarbons (TRPH) EPA 1664,{ or EPA 16644 (SGT*) Benzene, Toluene, Ethyl benzene, Xylenes, Naphthalene (BTEXN) & MTBE; and Halogenated Volatile Organic Compounds (VOX) EPA 80218 or EPA 8260B New Oil Oil and Grease (O&G) or Total Recoverable Petroleum Hydrocarbons ORPH) EPA 16644 or EPA 1664,4' (SGT*) Other Type ofanalyses will be based upon the substance or product stored, and as approved by the Executive Secretary (UST) Method will be based upon the substance or product type Unknown Total Petroleum Hydrocarbons (purggAble TPH as gasoline range organics C6 - C16) EPA 80158 or EPA 82608 Total Petroleum Hydrocarbons GItTASlablq TPH as diesel range organics C1e - C2s) EPA 80I58 Oil and Grease (O&G) or Total Recoverable Petroleum Hvdrocarbons ffRPH) EPA 1664A' or EPA 1664A (SGT*) Benzene, Toluene, Ethyl benzene, Xylenes, and Naphthalene (BTEXN) and MTBE; and Halogenated Volatile Organic Compounds (VOX) EPA 80218 or EPA 82608 I The following modifications to these certified methods are considered acceptable by the Executive Secretary (UST): r Dual column confirmation may not be required for TPH and BTEXN,MTBE analysis. r A micro-extraction or scale-down technique may be used for aqueous samples, but only for the determination ofextractable TPH as diesel range organics (Cro - Czs). . Hexane may be used as an extraction solvent. r *Silica Gel Treatment (SGT) may be used in the determination of Total Recoverable Petroleum Hydrocarbons. NOTE: The sample preparation method and any modification(s) to a certified method must be reported by the laboratory. CONTAMINATED MATERIALS MUST BE DISPOSED ATAN ACCEPTABLE FACILITY: All materials generated from UST closures must be managed and disposed in a manner that does not place those materials in direct contact with the environment. On-site stockpiling of contaminated soils may be required prior to any soil management activities. Any person Complete the Facility Site Plat and Sample Information Table on pages 4 and 5 to provide site assessment information. CONTAMINATION INFORMATION If contamination at the facility is suspected or confirmed, the information must be reported to the Executive Secretary @ST) at (801) 536- 41 00 within 24 hours. The Division of Water Quality must be notified at (801) 53 8-6 146 if Free Product is encountered or if surface water has been impacted. If contamination is confirmed, any person assisting in the remediation process for a fee must be a Certified UST Consultant. SAMPLE INFORMATION TABLE Complete table for all samples to be taken for closure. remedial assistance for a fee. includins aeralion and over-r xcavation (of more than 50 vd). must be a Certified UST Consultant. Contaminated soils generated as part of tank removal are to be disoosed at the followine faciliw: Address CiN lState lZip Contact person Phone Sample # Substance stored in tank Sample type'Depth2 Compounds3 Analysis method(s)a I L J A Soil (SS), Groundwater (GW), or Unified Soil Classification (USC). Approx.. depth in feet below grade. The required minimum site assessment samples must be taken at 0-2 leet below the backfill/native soil interface. Contamlnant compounds to be analyzed for each sample (from table on o. 3). Appropriate analysis methods for cbntaminant compound(s) in each sarirple (from table on p. 3). Facility Site Plat (Closure Plan) The site plat must be drawn to an appropriate identified scale. It must show planned sampling locations, substances stored in tanks, and other relevant information. Tank and sample identification numbers must be consistent with the information given on p. I and 4 of the Closure Plan. North il ,"u1". 1,,: _ Feet Facilitv ID:Drawn By:Date: X : Sample locations (SS-#, WS-#, USC-#) 0 : Monitoring Wells (MW-#,) z = Soil boring (SB-#), or Geoprobe Boring (GP-#) . = Water Wells (domestic, livestock, etc.) Slope of Surface Topography: (N,NW,W,SW,S,SE,E,NE) Land Use At Site: _Residential _Commercial _Indushial Surrounding Land: _Residential _Commercial Industrial Site Plat Must Indicate Approximate Locations Of: Y Current & former tanks, piping & dispensers Y Location of all samples to be taken Y Buildings, fences, & property boundaries Y Utility conduits (sewers, gas, water, storm drains, electrical. etc.) Approximate depth to groundwater in the viciniff of the tanks: feet. Regional groundwater flow direction: State Certified Laboratory to be used: Address Cirv State Zio Contact Person Phone Please explain any unusual or extenuating circumstances exnected resardins the site assessment or closure: I certify under penalty of law that I am the owner/operator of the tank(s) referenced above and that I am familiar with the information on this form and that it is true, accurate and complete, and further, that the procedures described herein will be followed during tank closure. Sisnature of tank owner Full Name of tank owner Date UNDERGROUND STORAGE TANK PERMANENT CLOSURE NOTICE (rev.3l4l03) FACILITY ID# State Use Onlv Date Processed I bv Date Mailed to LHD LUST ID# Date to LUST Review Closure Notice preoared at the reouest of the owner/oDerator (identified below) bv of (company name)I Phone# Address Citv I State I z;p FACILITY INFORMATION Tank Owner Phone # f-l sole proprietorship l-l oartnershio l-l comoration Address Citv State Zio Facilitv Name Address Citv State Zin Contact Derson Phone # Total number ofresulated undersround tanks at this site before closure Total number ofregulated undersround tanks at this site after closure TANKS CLOSED Tank # Type (Steel,FRP,etc.) Date Installed Caoacitv (Gallons) Substance stored* Date last oDerated Date Closed Removed,4n Place/ Change in Service (CIS)? *Indicate the specific substance stored in each tank to be closed (regular, unleaded, diesel, waste oil, etc.) TANKREMOVERName Cert. # TR Exp. Date Company Phone # Address Citv State Zip SOIL/GROUNDWATER SAMPLER Name Cert. # GS Exp. Date Company Phone # Address Citv State Zip CLOSURE INFORMATION Fuel was emptied ll Sludge was removed ll I Tank was cleaned ll Tank was: I Purged lJ I Inerted l_J I Method Used: Location of Closure Records: For In-Place Closure: tanks filled with: For Change-In-Service: Substance to be stored: DISPOSAL SITES USED Location Name Contact Name Phone # Date Amount Tank(s)Tank # Product From Tank(s) Contaminated Water From Tank Cleanine Sludge Contaminated Water From Excavation Contaminated Soil SITE ASSESSMENT Complete the Facility Site Plat (Closure Notice) and Sample Information Table (Closure Notice) on pages 3 and 4 to show the locations, depths, and other information on all soiVgroundwater samples taken for closure. The samples must be consistently identified by sample ID # on the site plat, table, and lab analysis report. I Completed Facilify Site Plat (Closure Notice) is attached. The following must be included (enter the distance, and direction (N,S,E,W) from the area of contamination or, where applicable, use OH for overhead, NP for not present): Water Line -Sewer Line Natural Gas _Storm Drain Telephone Electrical Property Line _ Buildings I Completed Sample Information Table (Closure Notice) is attached. n CertmeO bb analytical environmental sample results are attached. fl Unifred Soil Classification (USC) sample results are attached. ncnam of Custody form is attached. _ Samples were properly: E Coilected E tabeted I packaged ! Transported I Samples were in sight of the person in custody at all times or in a secured locked place. I certify under penalty of law that the closure site assessment at this facility was conducted in accordance with R31l-202 (parts 280.52 and280.72) and R311-205 U.A.C., and that any additional samples required by R311-202 parts 280.52 and 280.72 and R311- 205-2(a)(1) were properly collected. re of Certified Groundwater/Soil Full name of Certified Date If contamination at the facility is confirmed, any person providing remedial assistance for a fee must be a Certihed UST Consultant. The Certified UST Consultant providing assistance is: CERTIFIED UST CONSULTANT Please explain any unusual or extenuating circumstances expected resardins the site assessment or closure: Name Cert. #CC Exo. Date Company Address City State Zio Phone # Facility Site Plat (Closure Notice) The site plat must be drawn to an appropriate identified scale. It must show planned sampling locations, substances stored in tanks, and other relevant information. Tank and sample identification numbers must be consistent with the information given on p. I and 4 of the Closure Notice. North il Scale: l": Feet Facility ID:Drawn Bv:Date: X : Sample locations (SS-#, WS-#, USC-#) : Monitoring Wells (MW-#,) : Soil boring (SB-#), or Geoprobe Boring (GP-#) . : Water Wells (domestic, livestock, etc.) Slope of Surface Topography: (N,NW,W,SW,S,SE,E,NE) Land Use At Site: _Residential _Commercial Industrial Surrounding Land: _Residential _Commercial _Industrial Site Plat Must Indicate Actual Locations Of: { Current & former tanks, piping & dispensers r,/ Location of all samples to be taken ./ Buildings, fences, & property boundaries { Utility conduits (sewers, gas, water, storm drains, electrical, etc.) { Depth to groundwater (ifencountered) tr Excavations, GW monitoring wells & soil stockpiles SAMPLE INFORMATION TABLE (Closure Notice) Complete table for all samples that were taken for closure. Sample ID numbers on the table must be consistent with the sample lD numbers given on the site plat and in the lab analysis report. Sample # Substance stored in fank Sample fyner Depth2 Compounds3 Analysis method(s)a I 2 J 4 Soil (SS), Groundwater (GW), or Unified Soil Classification (USC). Final depth (in feet.1 below grade at which samples were raken. Contarunant compound(s) analyzed for each sample (TpH, BTEXN, O&G, etc). Appropriate analysis methods for contaminant compound(s) in each sample State Certified Laboratorv used Address Citv State Zio Contact Person Phone # I certify under penalty of law that I am the Owner of the tank(s) described above and that I am familiar with the information on this form and that it is true, accurate and complete and further, that the procedures described herein were followed during tank closure. Signature of UST owner Full Name of owner Date Retum completed Closure Notice form, Facility Site Plat and Sample lnformation Table, SoiVGroundwater sample lab analysis results, USC sample results, and Chain of Custody form within 90 days of UST Closure to: State of Utah Dept. of Environmental Oualirv Division of Enviionmental Response aid Relmediation / UST Section P.O. Box 144840 168 North 1950 West Salt Lake Citv. Utah 84114-4840 4 Temporary Closure Notice prepared at the request of the owner/operator (identified below) by of (company name)Phone # Address Citv State Zio OWNER AND FACILITY INFORMATION TANKS TEMPORARILY CLOSED n Vent lines open and functioning n Fuel was emptied to less than l" n Product lines capped/secured n Corrosion protection is operating FACILITY ID# State Use Date Received Date Processed ! Pumps, manways secured I Release detection equipment is operating Temporary closure requirements : When an UST system is temporarily closed, the owner/opetator must: o continue operation and maintenance of corrosion protection on tanks, lines, flex connectors, and other metallic system components. o continue operation and maintenance ofrelease detection OR empty the UST system to less than 1 inch ofproduct. When an UST system is temporarily closed for 3 months or more, the owner/operator must also: r leave vent lines open and functioning r cap and secure all other lines, pumps, manways, and ancillary equipment o send a properly-completed Temporary Closure Notice form to the DERR/UST Section. I certiff under penalty of law that I am the Owner of the tank(s) described above and that I am familiar with the information on this form and that it is true, accurate and complete and further, that the procedures described herein were followed during tank closure' Full Name of UST Owner: Sienature of UST Owner:Date: Tank Owner Phone # Address ciw State Zio Facilitv Name Address City State Zio Contact Derson Phone # Number of rezulated USTs at this facility:Number of regulated USTs to be temporarily cbq94 Tank # Tvoe (Steel.FRP.etc.) Date Installed Capacity (Gallons) Substance stored* Date last ooerated Inches of Product remaining in tank (to the nearest l/8 incht * Indicate the specific substance stored in oach tank to be closed (regular, unleaded, diesel, waste oil, etc.) Return completed Temporary Closure Notice form to: State of Utah Dept. of Environmental Quality Division of Enviionmental Response and Remediation / UST Section PO Box 144840 168 North 1950 West Salt Lake City, Utah 84114-4840 Closnoticetemp 1 205.doc Utah Petroleum Storage Tank Fund Tank owners/operators are not longer required to participate in the PST Fund. However, they must demonstrate that they meet the required financial responsibility through participating in the PST Fund or providing an alternate mechanism: private insurance, self insurance, etc. It is important to remember that all tank closure activities are ineligible for reimbursement under the PST Fund. Contents: Utah's Petroleum Storase Tank Fund Guidebook.1999 Utahts Petroleum Storase Tank Fund Gui.debook Of the several million underground storage tanks containing petroleum products nationally, tens of thousands have leaked and many more are expected to leak in the future. The Division of Environmental Response and Remediation (DERR) has investigated more than 3,800 cases of petroleum contamination from tanks in Utah. The Underground Storage Tank Program works to assure that tanks are safely managed. Besides the dangers of fire or explosion, leaking underground storage tanks (LUSTs) can contaminate soil and groundwater. Groundwater accounts for 96Vo of Utah's drinking water sources. Toxic and explosive petroleum vapors can also get into utility conduits, homes, schools and workplaces. LUSTs are a serious problem that need proper attention to protect our limited natural resources. The Federal Environmental Protection Agency and the State of Utah require that owners/operators of USTs cleanup petroleum leaks and releases when they occur. The costs of stopping, investigating and cleaning up the damage caused by a petroleum leak or release can be enornous. Several site cleanups in Utah have approached $1,000,000. Federal law requires all tank owners/operators to have the financial ability to pay for investigation, cleanup and other costs associated with damages caused by a petroleum leak or release. The amount of financial assurance varies depending upon the type ofbusiness operated, but the law applies to all owners/operators of regulated systems. In response, Utah's Legislature passed the Underground Storage Tank (UST) Act. Utah's law also created the Petroleum Storage Tank Trust Fund (PST Fund). Owners and operators do not have to use the PST Fund to demonstrate financial assurance. See the section below on alternate financial assurance mechanisms. The PST Fund functions similarly to insurance with the ownerloperator having a "deductible." The first $10,000 or $25,000 in eligible costs must be met by the owner/operator (the larger figure is for releases which occurred and were reported prior to July 1, 1994, the smaller for releases after that date). The fund will then cover eligible costs up to a set limit of either $500,000 or $1,000,000 (minus the deductible), depending upon the type of business - petroleum non-marketer or marketer. Levels Of Coverage Required The law requires all petroleum marketers to have financial assurance or coverage of $1 million per occurrence. Multiple occurrences or aggregate coverage is the same amount if the marketer has fewer than 100 tanks, and $2 million if more than 100 tanks. Marketers are those selling, producing or refining petroleum products. Non-marketers with monthly petroleum usage of less than 10,000 gallons must have $500,000 coverage per occuffence. Multiple occurrences or aggregate coverage is $1 million if the non- marketer has fewer than 100 tanks, $2 million if more than 100 tanks. Non-marketers with monthly usage in excess of 10,000 gallons must have the same coverage as a marketer. Non- marketers are those who own or operate USTs, but do not sell, produce or refine petroleum products. Alternate Financial Assurance Mechanisms Owners/operators are not required to participate in the PST Fund. However, they must demonstrate that they meet the required financial responsibility through an alternate mechanism as specified by Federal law. The most commonly used mechanisms are private insurance and self insurance based on net worth. The existence and adequacy of one or a combination of these altemate mechanisms must be reported to the state yearly. How The PST Fund Is Funded The initial PST Fund tank fee charged the year the tank is installed is $250. Renewal each subsequent year is $50 per tank if the entire facility's petroleum throughput is less than 400,000 gallons per year, or $150 per tank if the throughput exceeds that amount. The PST Fund receives its money from these annual assessments applied to participating USTs and an environmental assurance fee of one quarter cent per gallon on petroleum delivered to these tanks. Certificate Of Compliance A UST may not be used until it is issued aCertificate of Complianceby the Division of Environmental Response and Remediation who ensures that it meets both state and federal rules and regulations. To obtain a Certificate of Compliance, owners/operators must register their USTs and pay an annual tank fee. How To Join the PST Fund r Obtain a Certificate of Compliance. I Conduct a complete system tightness test on each underground storage tank. I Describe any previous pollution incidents at the facility. I Obtain independent financial assurance to cover the deductible amount. I FiII out and submit the ..PETROLEUM STORAGE TANK FUND APPLICATION.'' I Pay the annual PST Fund fee. I In order to rejoin the PST Fund after voluntarily withdrawing or lapsing for non-payment of fees, environmental sampling must be conducted to determine existing levels of contamination, if any. Accessing the PST Fund To access funds, the following eligibility requirements must be met: I The leak or release must have occurred during a period for which the tank was covered by the PST Fund, and; I A claim must be filed during the period when the tank was covered by the PST Fund, or; I Within one year after the PST Fund covered tank was closed, or; I Within six months after the end of the period during which the tank was covered by the PST Fund. HOW TO APPLY There are four steps which must be completed prior to receiving the approval to access the PST Fund: I Report a known or suspected release to the DERR. I Submit a PST FUnd..ELIGIBILITY APPLICATION.'' I Keep all receipts and canceled checks for work done at the site. I A "Work Plan and Budget" must be submitted to the DERR for review and approval prior to initiating any work above the deductible amount. I Submit claims for reimbursement on a "SUMMARY VOUCHER" and attach all supporting documents. Report the Leak or Release When a petroleum leak or release is reported to the DERR, it will be assigned a LUST Release Site designation (four letters) and a project manager. The project manager will be available to assist in completing the approval process and accessing monies needed to complete the site investigation and cleanup. PST Fund Eligibility Application The PST Fund "ELIGIBILITY APPLICATION" is a one page form which organizes information about the facility, tank and what type of petroleum leak or release is known or suspected. Once the form has been submitted a notification of eligibility status will be issued to the owner/operator. Documentation of Expenses Owner/Operators must document what has been spent to meet the deductible amount ($10,000 or $25,000) and all additional expenses for which reimbursement is requested. This documentation should consist of a summary voucher; itemized expenses for labor, services, materials, equipment purchases and rentals, utilities and other expenses; backup invoices for all expenditures including outside services; proof of payment (canceled checks or lien waivers); and proof that all expenses were eligible, reasonable, customary and legitimate. Things to consider when obtaining a contractor or outside services include getting three competitive bids, providing "sole source" justification or other justification such as previous work successfully completed under similar conditions. ff a Pay for Performance agreement is entered into by the owner/operator, the consultant and the DERR, submission of this expense documentation is not necessary. For more information contact your project manager or the PST Fund section manager. Work Plan and Budget Work plans are usually submitted in stages as the investigation proceeds and more data is obtained. A good work plan includes the scope and objectives of the proposed work, a description of the work to be completed broken down by task, any technical details which may apply, and a schedule or time frame for performing each task. An estimated budget which corresponds to the work plan must also be submitted to the DERR for approval. The budget should be itemized by task and include bids for any outside services or subcontractors. A work plan and budget is necessary as the DERR must approve any work (after the standard deductible has been met) at the site before the work is performed. Following this process will help ensure reimbursement from the PST Fund. Starting The Work After receiving approval to access the PST Fund, an owner/operator may continue with the project. When the approved work plan and associated work has been completed, the owner/operator will have claims to submit to the DERR for reimbursement. Claims for reimbursement should be submitted regularly in the same format as the original submission for documenting proof of meeting the deductible. It is recommended that the first claim combine the expenses to meet the deductible with ongoing reimbursable costs. ELIGIBLE COSTS . WHAT THE PST FUND WILL PAY FOR I Abatement - Actions taken to lirnit, reduce or eliminate a petroleum leak or release, or the damage caused by the leak or release from a UST. I Investigation - Activities to determine the degree and extent of contamination. This includes soil borings, groundwater monitoring wells, test pits or excavations, environmental sampling, researching past site history, etc. I Monitoring - Costs include well installation, sample collection, analyical laboratory costs, report writing and other associated costs. I Site Assessments - Those costs necessary to obtain specific information including localized groundwater flow direction, native soil types, area water well information, migration pathways (such as utility conduits, surface water, etc.), potentially affected populations, current land use (i.e., residential, commercial or industrial), etc. I Alternative Drinking Water - Supplies that are needed for the people affected by a LUST site. I Corrective Action - Activities which include cleanup or removal of the release source, containment or isolation of the release, treatment of the release, monitoring and maintenance of the site impacted by the release, reasonable and legitimate costs of repairing surface damage arising from the release and other associated costs. I Risk-Based Corrective Action - Investigation and analysis necessary to determine the potential risks presented by a release and the appropriate site specific cleanup levels to adequately protect human health and the environment. I Third Party Damage Claims and Settlements - As recommended by the State Risk Manager and approved by the Executive Secretary or determined by legal proceedings. I Any other costs determined by the Executive Secretary on a site specific basis. INELIGIBLE COSTS . WHAT THE PST FUND WILL NOT PAY FOR Common ineligible costs include expenses to achieve compliance, upgrading systems and tank removals. Ineligible Expenses To Achieve Compliance Include: I Tank registration fees. I Tank PST Fund fees. I Leak detection equipment. I UST system tightness testing. I UST system repairs. Ineligible Expenses For System Upgrades Include: T I T I Overfill protection. Spill containment basin. Corrosion protection. New tanks and associated supplies, equipment and services. Other Ineligible Expenses Include: I UST system removal - including all expenses related to UST closure activities. I Landscaping to improve the site beyond the previously existing condition. I Asphalt, concrete, gravel or other surfacing materials placed to improve the site beyond the previously existing condition. Percentage markups on subcontractors, outside services, equipment or materials. Loss of business. Irgal fees. Interest. Standard office expenses. Other costs as determined by the Executive Secretary. Last Things Last As an owner/operator follows through on a project and completes the approved work, contact with the state project manager must be maintained. The project manager should be consulted on any changes to the approved work plans or budgets needed to close the site as quickly and as cost effectively as possible. The project manager should also be notified if any emergency work is required. Following completion of the investigation or cleanup project, a close-out letter from the DERR may be requested which explains that "no further action" is required at the site. NOTE: The Eligibitity Application and Summary Voucher along with other tank program information is available on the fnternet at www.eq.state.ut.us/eqerr/errhmpg.htm. I I I t I T Environmental Contamination; Reporting a Release Any contamination found during closure activities must be reported to DERR by both the owner/operator AND the certified tank remover within 24 hours. Review: R3 1 1-201 -6(0 Standards of Perfonnance Any individual who provides consulting service relating to the management, abatement, investigation, corrective action or evaluation of a release for a fee must be a Utah certified UST consultant. Review: R31 1-204-5 Remediation A Utah certified UST Remover can, at the time of tank removal, remove up to 50 cubic yards of contaminated soil and properly dispose of. This is in addition to the amount of soil that is removed in the normal course of tank removal. Any remediation or additional over-excavation must be done under the supervision of a certified UST consultant. Hazardous Substances & Wastes Several hundred substances were designated as "hazardous" in Section 101(14) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA). The UST regulations apply to the same hazardous substances identified by CERCLA, except for those listed as hazardous wastes. These hazardous wastes are already regulated under Subtitle C of the Resource Conservation and Recovery Act and are not covered by the UST regulations. (See 40 CFR Parts 260-270 for the hazardous waste regulations.) Information on the CERCLA hazardous substances is available from EPA throueh the RCRA/CERCLA Hotline at 800 424-9346. UST Removers should understand the Toxicity Characteristic Rule and which o'petroleum- contaminated media and debris" are deferred under Subtitle C of RCRA. Review: A Toxicity Characteristic Rule Cheat Sheet, and Toxicity Characteristic Rule (Regulatory Review) Contents: Guidelines for Disposition and Treatment of Petroleum Contaminated Soils... Toxicity Characteristics Rule Cheat Sheet Requirements for Hazardous Substance USTs, EPA Some of the information may not be known, this is common. The person taking the phone call at the Division of Environmental Response and Remediation (DERR) will assist you with any questions you have. DERR (801) 536-4100. INFORMATION NEEDED AS COMPLETE AS POSSIBLE . Facility lD (7 digit numbers that may begin with a zero used to identify facilities with UST's). . The name and address of the facility where the UST release is being reported. . The name, company, and telephone of the person reporting the release of the UST (anonymous is acceptable, but a name is helpfut if further information is needed). INFORMATION NEEDED AS MUCH AS POSSIBLE OR PERTINENT a a Have fumes been noticed in homes, businesses, utilities, outdoors, soils, and/or water? Has any damage occurred to soils, ground water, surface water, drinking water, utilities, land surface, plants/wildlife, or a 3rd parly? ls free product (any petroleum product that is not dissolved in water or soil) present? What other agencies have been notified (Health Dept., Fire Dept., Department of Environmental Quality, etc.)? What has been done to clean-up this release already? Where did the release come from (i.e., piping, tank itself, spill/overfill, the pump island)? What is the age of the tank and pipe, along with what they are made of (steel or fiberglass for example)? When did the release occur? How much was released (estimate)? How was the release detected (tank tightness test, line tightness test, leak detector, inventory, field instruments, analytical, etc.)? What was the substance released (gasoline, diesel, waste oil, new oil, solvents, other)? What type of soil is present (sand, clay, etc.), and the depth to contaminated soil? How deep is ground water in the area, and its flow direction? What is the slope direction of the land in this area? What is the distance and direction to the nearest water well, underground utilities, surface water, buildings, and property boundaries? What is the current and surrounding land use where the release occurred (commercial, industrial, residential, agricultural)? How much annual precipitation is received in this city? What is the ground cover at the site (lawn, asphalt, gravel, etc.)? a a GUIDELINES FOR DISPOSITION AND TREATMENT OF PETROLEIJM CONTAMINATED SOILS FROM UNDERGROLIND STORAGE TANK SITES Improper disposition and aeration of petroleum-contaminated soils fromleaking underground storage tank (LUST) sites in close proximity to residential and environmentally sensitive areas could present a direct or potential threat to human health and the environment. This document represents advisory guidelines set by the Executive Secretary (UST) of the Utah Solid and Hazardous Wastes Control Board when soil management activities are proposed at any facility. As outlined in Utah Admin. Code Section R3Il-204-2, the Executive Secretary reviews and approves closure plans, which include information concerning management of petroleum contaminated soils. If a closure plan (or corrective action plan for LUST sites) indicates that a specific form of soil management or disposal will be performed at a facility, the Executive Secretary will require additional information concerning this activity. Because of the potential for improper management of petroleum contaminated soils, the following information should be provided to the Executive Secretary (UST) for review*. GENERAL SOIL MANAGEMENT GUIDELINES AND CONDITIONS FOR CONSIDERATION: All underground storage tank owners/operators who are planning to close their tank systems should plan for the possibility that they will be generating contaminated soils during the removal process. Proper disposal of the soil should be arranged before beginning any removal activities to minimize the concerns discussed above. If aeration is not proposed as part of the closure plan, but later proposed following any activity which will probably generate contaminated soil, then the responsible party must immediately take the following actions upon the overexcavation or generation of the impacted soils: . the contaminated soils shouldbe placed on an impermeable liner (to minimize leaching of the contamination into the ground); . the contaminated soils should be covered by an impermeable liner (to minimize both emissions of volatile hydrocarbons to the atmosphere, and to limit potential human contact); and, . the site should be secured from the general public to minimize any potential exposure. A snff member from the UST compliance section will assist you in meeting the UST closure requirements. If petroleum contaminnted soils are reported or confirmed at the site, a project manager from the LUST section will be assigned to assist you. Contacting the appropriate person will save time and avoid confusion. If you have questions about what to do, call either section at G0I) 536-4100. Page2 The proposed soil aeration plan is discussed in more detail below. The following items provide general considerations which must be satisfied or completed prior to submitting the proposal. If the following conditions at a site cannot be met, it is doubtful that approval for the actual aeration would be granted by the Executive Secretary (UST). If that is the case, and you cannot satisfy the following conditions, then you should start making arrangements for the proper disposal of the soil at an acceptable facility. If you canmeetthe following conditions, andplan on submitting aproposal as discussedbelow, andif you have already generated any contaminated soil, it is important that any stockpiled soil should be properly managed pending either the aeration approval, or other final disposition of the soil. . The owner/operator or responsible party of the underground storage tank system is responsible for notifying and obtaining approval from the Local Health Department, the Utah Division of Air Quality, and Local Fire Agency prior to any soil management or treatment activity. The Executive Secretary (UST) will require the documentation of these approvals from other agencies prior to considering granting final authorization of any soil treatment activity. In the event that the other agencies do not approve of the aeration plan, or, even if they have approved the plan, but the Executive Secretary (UST) does not approve of the proposed plan, then the owner will be required to dispose of the soil properly at an acceptable disposal facility. It should be noted that these guidelines do not preempt or supersede any other federal, state or local law, ordinance or jurisdiction. . If the aeration plan is not approved by any of the agencies involved, including the Executive Secretary (UST), then proper disposal of the contaminated soil at an approved facility will need to ' occur within 30 days of the disapproval. . Contaminated soils should not be placed in direct contact with groundwater/surface water or in an area which may impact groundwater/surface water. Soils should not be placed near structures, utility conduits, or other conduits (such as irrigation ditches, water wells, or surface/subsurface drainage systems) that may serve as pathways for migration of contamination. . Contaminated soils shouldbe placed on level ground, on an impermeable liner, cordoned off, and bermed to reduce the potential health risks and prevent runoff from leaving the site. Contaminated soils should be placed such that the environment cannot be affected or degraded. . Contaminated soils should not be placed in close proximity to the general public. The placement of the soils must provide sufficient distance from nearby residences and buildings to prevent potential health risks or nuisance to surrounding populations. The area used for the treaffnent of the soils should be secured to prevent access by the general public. In addition, the contaminated soils should be covered by an impermeable liner (to minimize both emissions of volatile hydrocarbons to the atmosphere, and to limit potential human contact). PROPOSAL FOR SOIL MANAGEMENT OR AERATION: . The notification to the DERR must be in the form of a written underground storage tank closure plan, or leaking underground storage tank corrective action plan which is to be submitted for the Executive Secretary's review and approval, disapproval, or conditional approval. The proposal should give specific information about the following: Verification of the approval from the other referenced regulatory agencies. Documentation that the conditions discussed above have been satisfied. The methodology or treatment technology to be used for the soil management activity. The sampling plan to be used to monitor the progress of the soil treatment activities (e.g., frequency of sample collection, type of samples collected, analyical methods to be used, and certified samplers and laboratories to be used). The proposed final disposition (or the final disposal location to be used) of the soil. A vicinity map and site map providing a complete graphical description of the facility and the land surrounding the facility. The maps should be drawn to scale with proper orientation (showing a North arrow) and should be no larger than 11" x 17". The maps should provide the following information: . The facility address orlocation, with an appropriate scale (e.g., bar scale with 1 inch =20 feet, etc.) and North arrow. . Underground utilities (e.g., water supply, sewer or septic systems, natural gas lines, storm drains, power lines, and telephone lines). . Property boundaries, on-site buildings, on* and off-site land use, and any adjacent buildings surrounding the property where the soil treatment will occur. . Location of soil stockpile(s) and proposed treaffnent area(s). . Land features surrounding the site including; lakes, rivers, streams, irrigation canals, wetlands, slope of land surface, irrigation, agricultural or other types of water wells. etc. The maximum volume and concentration of the contaminated soils to be treated should be indicated in the proposed plan. If the approved levels of volatile emissions are exceeded during the soil management activity, a revised plan must be submitted to the DERR for approval prior to ffeatment of the exceeded amounts. IMPLEMENTATION OF TI{E APPROVED TREATMENT PLAN: Any deviation from the plan, which was approved by the Executive Secretary, should be submitted in written form and approved prior to implementation. Progress reports (in regards to their content and frequency of submittals) for the implemented soil treatment technology or plan are to be submitted to the DERR in accordance with the approval letter issued by the Executive Secretary. Once the soil ffeatment activities are completed, submit a proposal to conduct final confirmation sampling to verify meeting established cleanup levels. Upon meeting cleanup levels, docurnent the same to the DERR by providing the required information as outlined in the approval letter (e.g., sampling, reporting, disposal and other related issues), and request a closure letter for the soil management area. If cleanup levels have not yet been met, additional treatment or work may be required prior to site closure. Page 3 a a a a Ruue Cxenr Sneer In LlISTLine,s Bulletin #1.3 article, A Hazardous Waste, Or What?, we discussed !,PA's neut rule that establishes a toxicity characteristics (TO test for dete,rmining wheth,er a qaste contains hazardous characteristics' This rule includes a proaision that defers from regulation under_Subt'itle C, "pet.roleum-contaminated media and debris" that t'ail the TC test and are regulatecl under RCRATs Subtitle I I,IST ,orlrrrti,, action requirements. Llnder Subtitle C, if these ,mate.rials had failed the TC test , they would haae been regulated trs luzardous wastes and , ther.et'ore, *!!i:',!:,!CRA's " cradle to |raae" hazartlous waste management system. This rleferrsl oryly.appties to the 25 newly listed o.rga.2i9 ch,emical,s' , ," The following "g11gas gt eeT; i.r r riugh.rrp)t:iri 1it wnfiaeitlrred and what's noi det'erred witnin the context of this ,"ii.' fni pe points\f iiterpretition (and there are fine points) are not included: f . Wt*"1, USf--l"t C rpetroleum ConurninateC lledla and Debrls'a]€ wo talklng abouti? Materials inside the UST: Sludge Water Product Tanks with product or sludge in them Materials outside the UST: Soil (before & after treatment) Groundwater (before & after treatment) Floatine Plume Surface Water Rock, Grass, Stumps Empty Tanks (per Subtitle I definition) Piping 2) How do we know nrhlch materiab qe subiect to "UST corrsctrvo actlon Materials listed above as deferred, if generated in re- sponse to known or suspected relea9es f..o* I Petro- leum UST (including contamination founcl at closures, site assessments, and replacements)' 3t How do we know which rnaterials are subiect to subtitle I ol FGRA? Materials fromNon-Subtitle I tanks, e'g', heating oil tanks, farm & residential motor fuel tanks < 1,100 gals., and above-ground tanks. However' under Subtitle C of RCF.A, all wastes generated from households (single and multiple residences) are excluded from EPA's hazardous waste management resulations. For USTs, this includes contaminated solls from household heating oil tanks and house- Materials from USTs as defined in Section 9001 of RCRA and EPA's technical regulations. 4l What ts tlre status of newly generated wastes {e'g., spent carton} resulting fiom treatmsnt ol petnoteum contaminated olurigr a" i"i, tt"sd nisio,ial materials have not been dslgnatod as de'lerrsd. Sl Wtst.bout ahre-gnound tanks, gpelines, and spllls-whlc{r ere not detered undor tll3 rul'a? EpA ts conrtdertngi fffiVo*Cta6-p"Ut,onttrai catlr for dsfarrlng alnve.ercund bd'!L tp.tt;"q "rrd rpliicfrpm tfre iC rcquirement In ctartes wtsr adequate management prcgrars. Not Deferred TOXICITY CHARACTERISTIC RULE Aiter iour vears of comments ano chanoes. rne Er','ri'onmenlat Frotection Aqencv nas olomuroateo ine Toxrcrty Characterrstrc Rute. Tnrs reouratio-n orrnos ,'::'e new wasie rnto the Resource Conien",at,on ano Feccverv Act rFCRA) hazaroous wasre Drcorai-n than anv reoutatton since the orrqrnai oromuioatron ct RCiA rn lg8O. This reguiitton rs so iai-reacnrno rnar ,"nosi rnoustrres. regardless of size. are affecteo. Old testrng melhods must be changed as the Tcxicrtv Characterrsilc Leaching procedure-(TCLp) reolaces the EP Toxrcrtv testing requirements. Twentv_srx (26) specriic organic constituents have to be invesrrgated at levels in the parts-per-billion (ppb) range, to deter- mine whether a waste is characteristic. ChemicalWaste Management, Inc. is prepared to handle these wastes at our facilities across rne country. As a service to our customers. we have preoared this review of the Toxicity Characlerrstic Rule. No maner what business you,re in. vou should famriiarize yourself with this regulatron to determrne the possible eflects on your operation. REGULATORY HISTORY In 1984, Congress passed the Hazardous and Solid Waste Amendments (HSWA) to RCRA. Included in these amendments was a Congressional mandate that EPA identify additional hazardous waste charac- teristics. rncluding measures of toxicrty. On June .13, 1986. EPA proposed the first version of the Toxicitv Characteristic Rule. This version contained the new testrng procedure, TCLP, as well as thirty-eight (38) new organic characteristic wastes wrth codes between D0'18 and D055. The proposed regulatory tevets were as low as 1 ppb. After changes to the test, as well as to the list of wastes, EPA promulgated the Toxicity Characteristic Rule on March 29, 1gg0. The final rule incorporates the changes to the testing procedure, reduces the number ol new characteristic wastes to twenty-six (26) and raises the regulatory levels on most of the new wastes. EFFECTIVE DATE: SEPTEMBER 25, 199O aCRA reouires that hazardous ivasle regulations become effectrve srx months arter the date of promul- gatron. uniess EPA has gooo cause to establish an earrier enective date. As a result. this regulatton ls effecrrve on Septemoer 25. 1990. Since this regula- tion rs subject to the 1984 HSWA. rt is effecttve in every state and does not requtre state approvalprior to the effective date. Due ro the far-reaching rmpact of this regulation, EPA establisned "compltance' dates ior two different cate- gories of waste generators: 1) All generators of more than 100 but less than 1 ,000 kglmonth of hazardous waste (small quantity generators) must come into compliance by March 29, 1991:and 2)allgenerators of 1.000 kg/month or more must comply with the hazardous waste regulations by September 25, 1990. CHARACTERIZING HAZARDOUS WASTE n the current RCRA hazardous v/aste proqram. a Jenerator of a solrd waste has the responsiotiitv to cetermtne whether the waste rs hazai.oous. This decision rs gulded by the regulations contained in 40 CFR Part 261. lf a waste is not subiect to anv exemption. then the generator must determtne whether the waste is listed and characteristic. Ljsted wastes are referred to by F. K. p and U codes. For example. the F wastes reilect waste from non_ specrfic sources (e.g., spent halogenated solvents used in degreasing - F001), while the K wastes identify waste from specific sources (e.g., spent potliner from primary aluminum reduction _ KOgg). The P and U wastes describe discarded, ofi-spec or sprll residues irom commercial chemical products. Characteristic wastes are identified by a *D" code and are not specifically associated with anV manufacturino process. While assessing a waste stream to deter- mine its regulatory status, a generator must identifv whether the waste is ignitable (D001), corrosive (D002), reactive (D003) or Ep toxrc (DOO4-DO17). The new toxrcity characteristic and iis associateO test. the TCLP, wrll replace the Ep toxiciry test on Seotem- ber 25. 1990. After September 25. i990. the toxicitv characteristic will include waste codes DOO4-D043. Under current law, when characterizing a hazardous waste. a generator must assign all the listed and characteristic waste codes for the purpose of comoli_ ance with the land disposal restrictions found in 40 CFR Part 268. Femember. it is the qenerator who bears the responsibility to characteri2e awaste. At the initial point of generation, the waste should be gyigryed against the hazardous waste tistings (i.e., F, K, P and U wastes). Next, the generator must an- swer a second question: that is whether the waste exhibits a characteristic (i.e., D0O1-D017). This two- stage process is not applicable for TC waste codes (D018-D043), untilthey are restricted under the land disposal restrictions. While evaluating a waste's regulatory status. a generator may test the waste or characterize it bv using knowledge of the process. There is no regula- tory requtrement to conduct analVtical testino. How- ever. because ol the low regulatory thresholis for the new 26 organic "D" wastes. CWM recommends that generators conduct a TCLP analysis to minimize their liability by insuring their wastes are accuralelv charac- terized and properly managed. APPLICATION OF LAND DISPOSAL RESTRICTIONS As a result of the HSWA. Congress directed EPA to issue treatment standards for all hazardous wastes prior to land disposai. These standards were required to be issued by certarn dates. or the wastes were banned from land disposal. This reguiatory program, commonly referred to as the "Land Ban." has dramati- cally impacted the way hazardous wastes are man- aged, since most wastes now require treatment prior to land disposal. The HSWA amendments allow EPA to address newly identified wastes (those wastes brought into the RCRA hazardous waste management system after November 8, 1984) differently than pre-HSWA wastes. EPA must evaluate treatment standards for newly identified wastes within six months of promul- gation, but the wastes are not banned from land disposal if EPA fails to meet this deadline. The land disposal restrictions do not apply to the new 26 organic "D" codes. EPA must eventually issue treatment standards for these wastes, and this process is expected to be completed within the next two years. IMPACT ON SPECIFIC WASTE TYPES . Previously Delisted Wastes Thougn EPA belreves that there is no sionificant imoact on previousrv delisted wastes belause the agency consrders rhat the deilsting requtrements are already more strrngent than the new rule. previ- ously delisted wastes are sublect to this regulation. lf a previously delisted waste exhibits a characteris- tic under the Toxicity Characteristic Rule, it is subject to the hazardous waste regulations. . Wastes Previously Excluded from RCRA Wastes previously excluded from RCRA. sucn as household waste. mining waste and oil and gas exploration waste. are not affected by this requla- tion. . Treated Wood Wastes Wood wastes that were treated with arsenic are currently protected from the hazardous waste man- agement standards by a regulatory exemption. lf this wood also contains pentachlorophenol or creosol in excess of the new TC levels, then these wastes are subject to the hazardous waste requla- tions. . Underground Storage Tanks (USTs) With the exception of petroleum-contaminated media and debris subject to Part 280 Corrective Action requirements. materialfrom the cleanup of leaking underground storage tanks is subject to the hazardous waste regulations. . Underground Petroleum Tanks EPA has decided to indefinitely defer a final decision on petroleum-contaminated media and debris subject to the underground storage tank Corrective Action requirements, pending further evaluation. Untilfurther EPA action, these wastes are not subject to the hazardous waste regulations. . Publicly Owned Treatment Works (POTW) Sludges EPA's Office of Water tested t 8 POTW sludoe sampies using the TCLP and found that none of these exhibited the TC at the regulatory levels. Based on that iniormation, EPA has determrned that this rule does not atfect POTW sludges and does not require a specific exemption. Therefore, any POTW sludge that exhibits a characteristic under this rule is subject to the hazardous waste regulations. . Commercial Applicators of Pesticides and Fungicides Commercial applicators of pesticides and fungt- cides. who are not eligible for the spectal require- ments applicable to farmers and wno exceed the generation volumes previously stated, are subiect to hazardous waste regulations ii they generate waste materials that exhibit a characteristic under this rule. . Pharmaceutical and Cosmetic Waste Drug and cosmetic wastes from non-household situations. such as discarded or recalled products' are subiect to hazardous wastes regulations if they exceed the regulatory levels for any of the hazardous waste characteristics. . Used Oil Currently, used oil which is burned for energy re- covery is subiect to a limited number of require- ments. When recycled, it is completely exempt lrom hazardous waste regulations. The toxicity charactertstic regulations do not affect these existing exemptions. Used oil that does not exhibit the characteristic of ignitability, corrosivity' reactivity or EP toxicity can be disposed in nonhaz- ardous waste facilities. After the effective date of the TC Rule, used oil destined for disposalthat ex' ceeds any of the TC levels is subiect to the haz- ardous waste regulations. Used oil that tails the new toxicity characteristic but is recycled, will remain outside of the RCRA standards. EPA is currently examining a number of regulatory options, including stricter regulation of recycled oil, to ensure that these activities do not pose undue risk to health and the environment. . TSCA Wastes PCB-containing dielectric fluids removed from elec- trical transformers and associated PCB contami' nated electrical equipment which are fully regulated under TSCA and that exceed one of the 26 organic characteristic levels (e.g., D018-D043) are exempt from this rule. However, PCB wastes that are con- taminated with any listed wastes (i.e', F' K' P' U) or the characteristic waste codes D001-D017 remain subject to TSCA/FCRA regulation. . Surface lmpoundments iPA has determined that the polnt at which a surface impoundment should be characterized for razaroous waste determination is the polnt of rnfluent (when the waste is generateci). lf a surface imooundment is determined to be receiving a new hazardous waste at this point, rt must meet mini- mum technology requirements (e.9., ieachate ccllectton systems, groundwater monitortng and double liners) within four (4) years or cease opera- tron as a hazardous unit before that date. ln November 1988, it became illegalto dtscharge hazaroous waste into a non-minimum technology surface impoundment. Via court decision, it was ruled that nonhazardous operations could be continued in non-minimum technology units after November, utilizing available capacity and defer- ring closure. These impoundments will continue to be regulated as hazardous waste management unrts and must meet minimum technology require- ments, if they intend to receive waste that is haz- ardous under the TC Rule after September 25,1990. lf operations cannot be changed to continue nonhazardous receipt in these non- minimum technology impoundments, operators must immediatelY begin closure. TCLP Throuqh HSWA. Congress directed EPA to reexam- ine it ,i exrsting EP Toxicity Characteristic and to identrty additional hazardous waste characteristtcs' ;;il;A; was parttcularly concerned that the existing ixtriction Procedure test did not include many orqanic constituents that could pose a threat to fruhan health and the environment' As a result, EPA set out to revtse the test method to utrlize a more aggressive leaching medium and to iO"ntity additional organic constituents', Briefly' in the "q"n"y t new TCLPlest, an acetic acid solution ls ;il;i; thL solids from a sample, and the resultant rniitrttl. tumbled for 18 hours at22t 3'C in azero n""0"p"." extractor which prevents volatilization of certain constituents. The liquids are expressed out of ine container and collected in an airtight bag' An. . liiqr"i J tn" liquid is introduced into a purge.and.trap J"iC" where helium is bubbled through the liquid to. r"to"" the volatile lractions which are concentrated Ln " f"n"i Trap. The trap is then heated' and the volatile organici are swept or flushed-into a gas "ntot"to{taph/mass spectrometer (GC/MS)' The semi-volaiiles in the liquid go through a sample. "iii""ttnlpreparation'stage anC then.are directly I;F;d ili" ihe cc/MS. tne flnat values are then cdmpared to the regulatory thresholds,to determ'ne whether the waste JnoutO be classified as hazardous' Please note that the EPA has recently required the -, use of data correction to account for the re@verles oI r"tpi" ipltes. This change in data calculation may cause more waste to bec;me subiect to the hazard- ous waste regulations' coNcLusloN The Toxicity Characteristic Rule regulates waste containing a numb;i;t organic constituents found in many proiucts and comm-only used in indusffialpro- cess'"i. These regulatory pr6visions should drive g"nli"tot., both sinall "'io tatge, to reexamine their waste management practices' In some instances' this review witt resuii in modilications of the actual production process in order to minimize hazardous waste generation. We recommend that all waste generators carefully re- evaluate the regulatory status of each waste man' "g"J lt tneir taiitities ind, where appropriate ' analyze eich waste to determine whether it is regulated ?t 3 hazardouswasteundertnenewToxicityCharacteris. tic nufe. lf you haveluestions about complying.with the requirerirents ot this regulatiol.?.t o|et regula- tions, contact your local Chemical Wa-ste Manage- *"ni t"pte.e,itatiue or call us at 1'80&84tF3604' TABLE 1. Toxicity Characteristic Constituent and Regulatory Levels EPA #1 Constituent Reg. Level (mg/l) EPA #1 Constituent Reg. Level (mgl1) D004 D005 D01 I D006 D01 9 D020 D021 D022 D007 D0233 D0243 D0253 uv10- D01 6 DO27 D028 D029 D0302 D01 2 UUJ I 5.00 100.00 1.00 ne 100.00 6.00 5.00 200.00 200.00 200.00 200.00 i 0.00 7<n ./u It .02 .008 UVJl' D034 D008 UU IJ D009 D01 4 D035 D036 D037 D0382 D010 D01'1 D039 D01 5 D040 D041 D042 D017 D043 Arsenic Barium Eenzene Caomium Carbon Tetrachloride Chlordane Chlorobenzene Chloroiorm Chromium o-Cresol m-Cresol p-Cresol Cresol arn1,+'U 1 .4-Dichlorobenzene 1 ,2-Dichloroethane '1 . 1 -Dichloroethylene 2.4-Dinitrotoluene Endrin Heptachlor (and its hydroxide) Hexachlorobenzene '13 Hexachloro-1,3-butadiene '50 Hexachloroethane 3.00 Lead 5'oo Lrndane '40 Mercury .2O Methoxychlor 10.00 Methyl Ethyl Ketone 200.00 Nitrobenzene 2.00 Pentachlorophenol 100.00 Pyridine 5.00 Selenium 1.00 Silver 5.00 TetrachloroethYlene .70 Toxaphene .50 Trichloroethylene .50 2,4,S-TrichloroPhenol 400.00 2,4,6-TrichloroPhenol 2.00 2.4.5-T richlorophenoxypropionic Acid (Silvex) Vinyl Chloride 1.00 .20 1. Hazardous Waste Number 2. Quantitation limit is greater than the calculated regulatory level. The quantitation limit therefore becomes the regulatory level. 3. lf o-, m- and p-Cresol concentrations cannot be differentiated, the totalcresol (D026) concentration is used. The reguiatory level for total cresol is 200 mgll. FAQ 7: What Are The Requirements For Hazardous Substance USTs? &Fffi,mm, http ://www.epa. gov/swerust 1 /hazusts/hazusts.htr FAQ 7: What Are The Requirements For Hazardous Substance USTs? ffine d fJ:drElrcmd Sr4ge ra:rBs FOR HAZARDOUS SUBSTANCE USTs ONLY Several hundred substances were designated as "hazaldous" in Section 101(14) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA). The UST regulations apply to the same hazardous substances identified by CERCLA, except tbr those listed as hazardous wastes. These hazardous wastes are already regulated under Subtitle C of the Resource Conservation and Recovery Act and are not covered by the UST regulations. (See 40 CFR Parts 260-270 for the hazardous waste regulations.) lnforrnation on the CERCLA hazardous substances is available from EPA throush the RCRA/CERCLA Hotline at 800 424-9346. What Requirements Apply To New Hazardous Substance USTs? New hazardous substamce tiSTs are those installed after December 22,1988. These USTs have to meet the same requirements described earlier for new petroleum USTs concerning correct installation, spill. overfill and conosion protection, corrective action. and closure. In addition, new hazardous substance USTs must have secondary containment and interstitial monitoring for leak detection. as described below. Secondary Containment All new hazardous substance USTs must have "secondary containment." A single-walled tank is the first or "prifilary" containment. Using only primary containment. a le:rk can escape into the environlnent. But by enclosing an UST within a second wall,leaks can be contained and detected quickly before harming the environment. There are several wavs to construct secondary containment: r Placing one tank inside another tank or one pipe inside another pipe (making them double-walled systems). r Placing the UST system inside a consrcte vault. . Lining the excavation zone around the UST system with a liner that cannot be penetrated by the hazardous substance. Interstitial Monitoring The hazardous substance UST must have a leak detection system that can indicate the presence of a leak in the contined space between the first and the second wall. Several devices are available to monitor this confined "interstitial" space. 1of 4 Lll2lzOOO 1l:31 AM FAQ 7: What Are The Requirements For Hazardous Substance USTs? ("Interstitiai" simpiy means "between the walls.") The UST reguiations describe these various methods and the requirements for their proper use. You can apply for an exception, called a variance, from the requirement for secondary containment and interstitial raonitoring. To obtain a variance you must demonstrate to the regulatory authority that your alternative leak detection method will work effectively by providing detailed studies of your site, proposed leak detection method, and available methods far corrective action. What About Existing Hazardous Substance USTs? Existing UST systems are those installed before December 22,1988. in addition to immediately starting tank filling procedures that prevent spills and overfills, yr:u will need to meet the following requirements tor existing USTs. Leak Detection Deadlines for conrpliance with leak cietection reqr-Liremet{s were phased in according to the age of the UST. By December 22. 1993, all existing IJSTs were required to have leak detection. Pressurized piping must meet the requirements for new pressurized piping. You can meet the leak detection requirements in one of the following three ways: r Until December 1998, you can use any of the leak detection methods clescribed on page 19 but only if the method you choose can effectively detect releases of the hazaldous substance stored in the UST. r After Deceurber 2?,1998, your UST mllst meet the same requirements for secondary containrnent and interstitial monitoring that apply to new hazardous substance LISTs. r After December 22, 1988, a variance can be granted if your meet the same requirements described above fbr receiving a variance for a new hazardous sr.rbstance UST. Spill, Overfill, and Corrosion Protection By Decernber 22, 1998, you must improve your USTs: By using devices that pf.g.y.*LtL..S!,ij,lq_ru . By adding ccrr:rcsitrn plc_te*iion to steel tanks and piping. Although the regulatory deadline is in 1998, you should make these improvements as soon as you can to reduce the chance that you will be liable for damages caused by your unimproved UST. What If You Have A Hazardous Substance Release? http ://www. epa. gov/swerust I /hazustsftrazusts.htr 2of4 UIA2OOO l1:31 AM FAQ 7: What Are The Requirements For Hazardous Substance USTs? You must foilow the basic actions described below for petroleum releases, with the follor.ving two exceptions. r First, you must imrnecliately report hazardous substance spills or overfills that meet or exceed thefu "reportable quantities" to the National Response Center at 800 424-88A2 or 2A2 267 -267 5. r Second, you must also report haz,ardous substance spills or overf-ills that meet or exceed their "reportable quantities" to the regulatory authority within 24 hours. However, if- these spills or overfills are smallcl than their "reportable quantities" and are immediately contained and cleaned up, they do not need to be reported. You can get information on the "reportable quantities" by calling the EPA RCRA/CERCLA Hotline at 800 424-9346. Warning signals indicate that your UST may be leaking and creating problems for the environment and your business. You can minimize these problems by paying careful attention to early warning signals and reacting to them quickly before major problems develop. You shor-rld suspect a leak when you discover the following warning signals: Unusual operating conditions (such as erratic behavior of the dispensing pump). Check first to see if this problem results fiom equipment failure that can be repaired. Results fiorn leak detection monitoring and testing that indicate a leak. What at tirst appeals to be a leak may be the result of faulty equipment that is part of your UST system or its leak detection. Double check this equipment carefully for failures. You need to call your regulatory authority and report suspected leaks. Then find out quickly if these suspected leaks are actual leaks using the following investigative steps: Conduct tightness testing of the entire UST system. Check the site frlr additional information on the presence and source of contamination. If these system tests and site checks confirm a leaking UST, follow the actions fbr responding to confirmed ieaks descr:ibed below. You must also respond quickly to any evidence of ieaked petroleum that appears at or near your site. For example, neighbors might tell you they srnell petroleum vapors in theil basements or taste petroleum in their drinking water. If evidence of this type is discovered" you must report this discovery immediately to the regulatory authority and take the investigative steps and follow-up actions noted above. http://www.epa. gov/swerust 1/hazusts/hazusts.htr 3 of 4 |/12/2OOO 11:31 AM FAQ 7: What Are The Requirements For Hazardous Substance USTs?http ://www.epa. gov/swerust I /hazusts/hazusts.htr C ontact y oar re g ql4tory *ulke&fi-for specifr.c timeframes, necessary steps, and gaidance in doing site assessments and Corrective Action Plans In respanse to a release. you should: r Take immediate action to stop and contain the release. Reporl the release to the regulatory authority within 24 hours. However, petroleum spills and overfills of less than 25 gallons do not have to be reported if you irnmediately contain and clean up these reieases. Make sure the release poses no immediatehazard to human health and safety by removing explosive vapors and fire hazards. Your fire department should be able to help or advise you with this task. You must also make sure you handle contaminated soil properly so that it poses no hazard (for example, from vapors or direct contact). Remove petroleum ir:om the UST system to prevent f'urther release into the environment. Find out how far the petroleum has moved and begin to recover the leaked petrolcum (such as product floating on the water table). Report your progress and any information you have collected to the regulatory authority no later than2} days afler confirming a release. Investigate to determine if the release has damaged or might damage the environtnent. This investigation must determine the extent of contamination both in soils and groundwater. You must repoft to the regulatory authority what you have leamed from an investigation of your site according to the schedule established by the regulatory authority. At the same tirne. you must also submit a leport explaining how you plan to clean up the site. Additional site studies may be required. Based on the information you have provided, the regulatory authority wili decide if you must take further action at your site. You may need to develop and submit a Corrective Action Plan that shows how you will meet requirements established for your site by the regulatory authority. Make sure you implement the corrective action steps approved by the regulatory authority for your site. I gHSF,,Hnme Paqg ][ f.f_q$uentl.v Asked O-pestig]rs l URL: htfp ://www.epa,gov/OUST/hazusts/hazusts.htm 4of4 Last Updated: September 30, 1998 lll2l200011:31 AM UST Safety Nothing is more important than safety on the job site!!! Safety of the work crew should be the primary concern for UST Removers. Review: Health & Safety Notes: Trenching, Shoring and USTs and Health and Safety Training (EPA). Monitoring Equipment The use of environmental monitoring equipment is essential to safe UST removal. Many UST accidents could have been prevented if UST Removers were trained and accurately used environmental monitoring equipment. Review: Oxygen Monitors, CGIs and Specific Chemical Monitors and understand equipment limitations and considerations. Contents: MSDS for gasoline Trenching, Shoring, and USTs Health and Safety Training for Underground Storage Tank Inspectors Oxygen Monitors, CGIs and Specific Chemical Monitors FIM ER FINH H E55 EtrFT FTT]FT FITINru MATERIAL SAFETY DATA SHEET Gasoline. All Grades MSDS No.9950 1. CHEMICAL PRODUCT and COMPANY INFORMATION (rev. Jan-04 Amerada Hess Gorporation 1 Hess Plaza Woodbridge, NJ 07095-0961 EMERGENCY TELEPHONE NUMBER (24 hrs): COMPANY CONTACT (business hours): MSDS Internet Website SYNONYMS: Hess Conventional (Oxygenated and Non-oxygenated) Gasoline; Reformulated Gasoline (RFG); Reformulated Gasoline Blendstock for Oxygenate Blending (RBOB); Unleaded Motor or Automotive Gasoline See Section 16 for abbreviations and acronyms. 2. COMPOSITION and INFORMATION ON INGREDIENTS * (rev. Jan-04 ]NGREDIENT NAME (CAS No.)CONCENTRATION PERCENT BY WEIGHT GHEMTREC (800)424-9300 Corporate Safety (732)750-6000 www. hess. com/abouUenvi ron. html EMERGENCY OVERVIEW DANGER! EXTREMELY FLAMMABLE. EYE AND MUCOUS MEMBRANE IRRITANT . EFFECTS CENTRAL NERVOUS SYSTEM. HARMFUL OR FATAL IF SWALLOWED - ASPIRATION HAZARD High fire hazard. Keep away from heat, spark, open flame, and other ignition sources. lf ingested, do NOT induce vomiting, as this may cause chemical pneumonia (fluid in the lungs). Contact may cause eye, skin and mucous membrane irritation. Harmful if absorbed through the skin. Avoid prolonged breathing of vapors or mists. Inhalation may cause irritation, anesthetic effects (dizziness, nausea, headache, intoxication), and respiratory system effects. Long-term exposure may cause effects to specific organs, such as to the liver, kidneys, blood, nervous system, and skin. Contains benzene, which can cause blood disease, including anemia and leukemia. $ NFPA 704 (Section 16) Gasoline (86290-81-5) Benzene (71-43-2) n-Butane (106-97-8) Ethyl Alcohol (Ethanol) (64-17-5) Ethyl benzene (1 00-41 -a) n-Hexane (1 10-54-3) Methyl{ertiary butyl ether (MTBE) (1634-04-4) Tertiary-amyl methyl ether (TAME) (994-05-8) Toluene (108-88-3) 1,2,4- T rimethylbenzene (95-63-6) Xylene, mixed isomers (1330-20-7) 100 0.1 - 4.9 (0.1 - 1.3 reformulated gasoline) <10 0-10 <3 0.5 to 4 0 to 15.0 a b 17.2 1 -25 <6 1-15 A complex blend of petroleum-derived normal and branched-chain alkane, cycloalkane, alkene, and aromatic hydrocarbons. May cohtain antioxidant and multifunctional additives. Non-oxygenated Conventional Gasoline and RBOB do not have oxygenates (Ethanol or MTBE and/or TAME). Oxygenated Conventional and Reformulated Gasoline will have oxygenates for octane enhancement or as legally required. Revision Date: 01/08/04 Page 1 of8 FIM EFT FII]FI H E55 trtrFI FT]FT RTITIN MATERIAL SAFETY DATA SHEET Gasoline. All Grades MSDS No.9950 3.HAZARDSIDENTIFICATION (rev.Dec-9 EYES Moderate irritant. Contact with liquid or vapor may cause irritation. SKIN Practically non-toxic if absorbed following acute (single) exposure. May cause skin irritation with prolonged or repeated contact. Liquid may be absorbed through the skin in toxic amounts if large areas of skin are exposed repeatedly. INGESTION The major health threat of ingestion occurs from the danger of aspiration (breathing) of liquid drops into the lungs, particularly from vomiting. Aspiration may result in chemical pneumonia (fluid in the lungs), severe lung damage, respiratory failure and even death. Ingestion may cause gastrointestinal disturbances, including irritation, nausea, vomiting and diarrhea, and central nervous system (brain) effects similar to alcohol intoxication. In severe cases, tremors, convulsions, loss of consciousness, coma, respiratory arrest, and death may occur. INHALATION Excessive exposure may cause irritations to the nose, throat, lungs and respiratory tract. Central nervous system (brain) effects may include headache, dizziness, loss of balance and coordination, unconsciousness, coma, respiratory failure, and death. WARNING: the buming of any hydrocarbon as a fuel in an area without adequate ventilation may result in hazardous levels of combustion products, including carbon monoxide, and inadequate oxygen levels, which may cause unconsciousness, suffocation, and death. CHRONIG EFFECTS and CARCINOGENIGITY Contains benzene, a regulated human carcinogen. Benzene has the potential to cause anemia and other blood diseases, including leukemia, after repeated and prolonged exposure. Exposure to light hydrocarbons in the same boiling range as this product has been associated in animal studies with systemic toxicity. See also Section 11 - Toxicological Information. MEDICAL CONDITIONS AGGRAVATED BY EXPOSURE lrritation from skin exposure may aggravate existing open wounds, skin disorders, and dermatitis (rash). Chronic respiratory disease, liver or kidney dysfunction, or pre-existing central neryous system disorders may be aggravated by exposure. 4.FIRST AID MEASURES rev. Dec-97 EYES In case of contact with eyes, immediately flush with clean, low-pressure water for at least 15 min. Hold eyelids open to ensure adequate flushing. Seek medical attention. SKIN Remove contaminated clothing. Wash contaminated areas thoroughly with soap and water or waterless hand cleanser. Obtain medical attention if irritation or redness develops. INGESTION DO NOT INDUCE VOMITING. Do not give liquids. Obtain immediate medical attention. lf spontaneous vomiting occurs, lean victim fonruard to reduce the risk of aspiration. Small amounts of materialwhich enter the mouth should be rinsed out until the taste is dissipated. INHALATION Remove person to fresh air. lf person is not breathing, ensure an open airway and provide artificial respiration. lf necessary, provide additional oxygen once breathing is restored if trained to do so. Seek medical aftention immediately. Revision Date: 01/08/04 Page 2 of 8 FIM EFT FItrFI FI E5E trf]F TTtrFT FITIBH MATERIAL SAFETY DATA SHEET Gasoline, All Grades MSDS No.9950 5.FIRE FIGHTING MEASURES (rev. FLAMMABLE PROPERTIES: FLASH POINT:45oF (-43"C) AUTOIGNITION TEMPERATURE: highly variable; > 530 oF (>280 oC) OSHAJNFPA FLAMMABILIW CLASS: 1A (flammable tiquid) LOWER EXPLOSTVE LrMtT (%): UPPER EXPLOSTVE LtMtT (%): FIRE AND EXPLOSION HAZARDS Vapors may be ignited rapidly when exposed to heat, spark, open flame or other source of ignition. Flowing product may be ignited by self-generated static electricity. When mixed with air and exposed to an ignition source, flammable vapors can burn in the open or explode in confined spaces. Being heavier than air, vapors may travel long distances to an ignition source and flash back. Runoff to sewer may cause fire or explosion hazard. EXTINGUISHING MEDIA SMALL FIRES: Any extinguisher suitable for Class B fires, dry chemical, CO2, water spray, fire fighting foam, or Halon. LARGE FIRES: Water spray, fog or fire fighting foam. Water may be ineffective for fighting the fire, but may be used to cool fire-exposed containers. .: During certain times of the year and/or in certain geographical locations, gasoline may contain MTBE andlor TAME. Firefighting foam suitable for polar solvents is recommended for fuel with greater than 10% oxygenate concentration - refer to NFPA 11 "Low Expansion Foam - 1994 Edition FIRE FIGHTING INSTRUCTIONS Small fires in the incipient (beginning) stage may typically be extinguished using handheld portable fire extinguishers and other fire fighting equipment. Firefighting activities that may result in potential exposure to high heat, smoke or toxic by-products of combustion should require NIOSH/MSHA- approved pressure-demand self-contained breathing apparatus with full facepiece and full protective clothing. lsolate area around container involved in fire. Cool tanks, shells, and containers exposed to fire and excessive heat with water. For massive fires the use of unmanned hose holders or monitor nozzles may be advantageous to further minimize personnel exposure. Major fires may require withdrawal, allowing the tank to burn. Large storage tank fires typically require specially trained personnel and equipment to extinguish the fire, often including the need for properly applied fire fighting foam. See Section 16 for the NFPA 704 Hazard Rating. 6.ACCIDENTAL RELEASE MEASURES (rev. Dec-97 ACTIVATE FAC|Llry SPILL CONTINGENCY or EMERGENCY PLAN. Evacuate nonessential personnel and remove or secure all ignition sources. Consider wind direction; stay upwind and uphill, if possible, Evaluate the direction of product travel, diking, sewers, etc. to confirm spill areas. Spills may infiltrate subsurface soiland groundwater; professionalassistance may be necessary to determine the extent of subsurface impact. Carefully contain and stop the source of the spill, if safe to do so. Protect bodies of water by diking, absorbents, or absorbent boom, if possible. Do not flush down sewer or drainage systems, unless system is designed and permitted to handle such material. The use of fire fighting foam may be useful in certain situations to reduce vapors. The proper use of water spray may effectively disperse product 1.4% 7.6% Revision Date: 01/08/04 Page 3 of 8 RM ER fi ER I{ E55 trBR trT]FI FITIT]IU MATERIAL SAFEW DATA SHEET Gasoline, All Grades MSDS No.9950 vapors or the liquid itself, preventing contact with ignition sources or areas/equipment that require protection. Take up with sand or other oil absorbing materials. Carefully shovel, scoop or sweep up into a waste container for reclamation or disposal - caution, flammable vapors may accumulate in closed containers. Response and clean-up crews must be properly trained and must utilize proper protective equipment (see Section 8). 7.HANDLING and STORAGE (rev. Dec-97 HANDLING PRECAUTIONS******USE ONLY AS A MOTOR FUEL****""******DO NOT SIPHON BY MOUTH****** Handle as a flammable liquid. Keep away from heat, sparks, and open flame! Electrical equipment should be approved for classified area. Bond and ground containers during product transfer to reduce the possibility of static-initiated fire or explosion. Special slow load procedures for "switch loading" must be followed to avoid the static ignition hazard that can exist when higher flash point material (such as fuel oil) is loaded into tanks previously containing low flash point products (such as this product) - see API Publication 2003, "Protection Against lgnitions Arising Out Of Static, Lightning and Stray Currents. STORAGE PRECAUTIONS Keep away from flame, sparks, excessive temperatures and open flame. Use approved vented containers. Keep containers closed and clearly labeled. Empty product containers or vessels may contain explosive vapors. Do not pressurize, cut, heat, weld or expose such containers to sources of ignition. Store in a well-ventilated area. This storage area should comply with NFPA 30 "Flammable and Combustible Liquid Code". Avoid storage near incompatible materials. The cleaning of tanks previously containing this product should follow API Recommended Practice (RP) 2013 "Cleaning Mobile Tanks ln Flammable and Combustible Liquid Service" and API RP 2015 "Cleaning Petroleum Storage Tanks". WORK/HYGIENIC PRACTICES Emergency eye wash capability should be available in the near proximity to operations presenting a . potential splash exposure. Use good personal hygiene practices. Avoid repeated and/or prolonged skin exposure. Wash hands before eating, drinking, smoking, or using toilet facilities. Do not use as a cleaning solvent on the skin. Do not use solvents or harsh abrasive skin cleaners for washing this product from exposed skin areas. Waterless hand cleaners are effective. Promptly remove contaminated clothing and launder before reuse. Use care when laundering to prevent the formation of flammable vapors which could ignite via washer or dryer. Consider the need to discard contaminated leather shoes and gloves. 8. EXPOSURE CONTROLS and PERSONAL PROTECTION (rev. Jan-04 EXPOSURE LIMITS Component (CAS No.)Exposure Limits Revision Date: 01/08/04 Page 4 of 8 FIM EFI FIT]FI I{ E55 trEIFT FIgR FITItrI1I MATERIAL SAFEry DATA SHEET Gasoline. All Grades MSDS No.9950 Gomponent (CAS No.)Exposure Limits Source TWA STEL Note ACGIH 50 - skin .-Metl'vr-rerti-.t-irt!-et!'-":iivnii-(1qi4.qi.4i----AqqH----4a----:-----::----4i-:-------::----------------::-----:-:-:----- .__r_e4iely:eT'y_l-ry-e_t!y!_e_tt'9llr !,!.El-(e_s_1:Q9:QL__ __J!S!-e_g$eD!!91'_e_q-----____Toluene (108-88-3) OSHA 200 Ceiling: 300 ppm; Peak: 500 ppm (10 min.) AGGIH 50 - 41_ts!{!l___---_-_-__.-1;2,i---iiirr'ei[ilb_"_!ie!.'_1_e.5r0.3.-b)_____-_:-____::Aq9]t1-- _25 --'=-'_---::_ Xyrene, mixed isomers (1330-20-7) R33f.l 133 ,!o A4 ENGINEERING CONTROLS Use adequate ventilation to keep vapor concentrations of this product below occupational exposure and flammability limits, particularly in confined spaces. EYE/FACE PROTECTION Safety glasses or goggles are recommended where there is a possibility of splashing or spraying. SKIN PROTECTION Gloves constructed of nitrile or neoprene are recommended. Chemical protective clothing such as that made of of E.l. DuPont Tychem @, products or equivalent is recommended based on degree of exposure. Note: The resistance of specific material may vary from product to product as well as with degree of exposure. Consult manufacturer specifications for further information. RESPIRATORY PROTECTION A NIOSH-approved air-purifying respirator with organic vapor cartridges or canister may be permissible under certain circumstances where airborne concentrations are or may be expected to exceed exposure limits or for odor or irritation. Protection provided by air-purifying respirators is limited. Refer to OSHA 29 CFR 1910.134, NIOSH Respirator Decision Logic, and the manufacturer for additional guidance on respiratory protection selection and limitations. Use a positive pressure, air-supplied respirator if there is a potential for uncontrolled release, exposure levels are not known, in oxygen-deficient atmospheres, or any other circumstance where an air-purifying respirator may not provide adequate protection. 9.PHYSICAL and CHEMICAL PROPERTIES . Jan-04 APPEARANCE A translucent, straw-colored or light yeltow liquid ODOR A strong, characteristic aromatic hydrocarbon odor. Oxygenated gasoline with MTBE and/or TAME may have a sweet, ether-like odor and is detectable at a lower concentration than non-oxygenated gasoline. ODOR THRESHOLD BASIG PHYSICAL PROPERTIES BOILING MNGE: 85 to 437 oF (39 to 200 'C) Non-oxygenated gasoline: Gasoline with 15% MTBE: Gasoline with 15% TAME: Odor Detection 0.5 - 0.6 ppm 0.2 - 0.3 ppm 0.1 ppm 10-1 1 (n-butyl acetate = 1) 100 % Odor Recoqnition 0.8 - 1.1 ppm 0.4 - 0.7 ppm 0.2 ppm VAPOR PRESSURE: VAPOR DENSIry (air = 1): SPECIFIC GMVITY (HzO = 1): 0.70 - 0.78 EVAPORATION RATE: PERCENT VOLATILES: Revision Date: 01/08/04 6.4 - 15 RVP @ 100 "F (38 "C) (275475 mm Hg @ 68'F (20 AP3to4 oc) Page 5 of 8 FIM ER fi NH H E55 CtrFI FItrFT FITITII\I MATERIAL SAFETY DATA SHEET Gasoline. All Grades MSDS No.9950 SoLUBILtTY (H2O):Non-oxygenated gasoline - negligible (< 0.1% @77'F). Gasoline with 15olo MTBE - slight (0.1 - 3Yo @ 77 oF); ethanol is readily soluble in water 10.STABILITY and REACTIVITY . Dec-94 STABILITY: Stable. Hazardous polymerization will not occur. CONDITIONS TO AVOID Avoid high temperatures, open flames, sparks, welding, smoking and other ignition sources INCOMPATIBLE MATERIALS Keep away from strong oxidizers. HAZARDOUS DECOMPOSITION PRODUCTS Carbon monoxide, carbon dioxide and non-combusted hydrocarbons (smoke). Contact with nitric and sulfuric acids will form nitrocresols that can decompose violently. ',1.TOXICOLOGICAL PROPERTIES . Dec-97 ACUTE TOXICITY Acute Dermal LD50 (rabbits): > 5 ml/kg Acute Oral LD50 (rat): 18.75 mllkg Primary dermal irritation (rabbits): slightly initating Draize eye initation (rabbits): non-irritating Guinea pig sensitization: negative CHRONIC EFFECTS AND CARCINOGENICITY Carcinogenicity:OSHA: NO IARC: YES - 28 NTP: NO ACGIH: YES (A3) IARC has determined that gasoline and gasoline exhaust are possibly carcinogenic in humans. lnhalation exposure to completely vaporized unleaded gasoline caused kidney cancers in male rats and liver tumors in female mice. The U.S. EPA has determined that the male kidney tumors are species-specific and are irrelevant for human health dsk assessment. The significance of the tumors seen in female mice is not known. Exposure to light hydrocarbons in the same boiling range as this product has been associated in animal studies with effects to the central and peripheral nervous systems, liver, and kidneys. The significance of these animal models to predict similar human response to gasoline is uncertain. This product contains benzene. Human health studies indicate that prolonged and/or repeated overexposure to benzene may cause damage to the blood-forming system (particularly bone marrow), and serious blood disorders such as aplastic anemia and leukemia. Benzene is listed as a human carcinogen by the NTP, IARC, OSHA and ACGIH. This product may contain methyl tertiary butyl ether (MTBE ): animal and human health effects studies indicate that MTBE may cause eye, skin, and respiratory tract initation, central neryous system depression and neurotoxicity. MTBE is classified as an animal carcinogen (A3) by the ACGIH. 12.ECOLOGICAL IN FORMATION . Jan-04 Keep out of sewers, drainage areas and waterways. Report spills.and releases, as applicable, under Federal and State regulations. lf released, oxygenates such as ethers and alcohols will be expected to exhibit fairly high mobility in soil, and therefore may leach into groundwater. The API (www.api.orq) provides a number of useful references addressing petroleum and oxygenate contamination of groundwater. 13.DISPOSAL CONSIDERATIONS rev. Dec-97 Consult federal, state and local waste regulations to determine appropriate disposal options. Revision Date: 01/08/04 Page 6 of 8 FIM ER FIBR H 855 trgFT trT]R RTIT]N MATERIAL SAFETY DATA SHEET Gasoline. All Grades MSDS No.9950 '14.TRANSPORTATION IN FORMATION . Jan-04 DOT PROPER SHIPPING NAME: DOT HAZARD CLASS and PACKING GROUP: DOT IDENTIFICATION NUMBER: DOT SHIPPING LABEL: Gasoline 3. PG rl uN 1203 FLAMMABLE LIOUID 15.REGULATORY INFORMATION . Jan-04 U.S. FEDERAL. STATE. and LOCAL REGULATORY INFORMATION This product and its constituents listed herein are on the EPA TSCA Inventory. Any spill or uncontrolled release of this product, including any substantial threat of release, may be subject to federal, state and/or local reporting requirements. This product and/or its constituents may also be subject to other federal, state, or local regulations; consult those regulations applicable to your facility/operation. CLEAN WATER ACT (OIL SPILLS) Any spill or release of this product to "navigable waters" (essentially any surface water, including certain wetlands) or adjoining shorelines sufficient to cause a visible sheen or deposit of a sludge or emulsion must be reported immediately to the National Response Center (1-800424-8802) or, if not practical, the U.S. Coast Guard with follow-up to the National Response Center, as required by U.S. Federal Law. Also contact appropriate state and local regulatory agencies as required. CERCLA SEGTION 103 and SARA SECTION 304 (RELEASE TO THE ENVIRONMENT) The CERCLA definition of hazardous substances contains a "petroleum exclusion" clause which exempts crude oil, refined, and unrefined petroleum products and any indigenous components of such. However, other federal reporting requirements (e.9., SARA Section 304 as well as the Clean Water Act if the spill occurs on navigable waters) may still apply. SARA SECTION 311/312. HMARD CLASSES ACUTE HEALTH CHRONIC HEALTH FIRE SUDDEN RELEASEOF PRESSURE REACTIVE SARA SECTION 313. SUPPLIER NOTIFTCATION This product contains the following toxic chemicals subject to the reporting requirements of section 313 of the Emergency Planning and Community Right-To-Know Act (EPCRA) of 1986 and of 40 CFR 372: INGREDlENT NAME CONCENTRATION WT. PERCENT Benzene F143-2) Ethyl benzene (roo+r-+; n-Hexane (ro-s+-sy Methyl{ertiary butyl ether (MTBE) lrosa-oa+1 Toluene (roa-aa-s1 1,2,4- T rimethylbenzene (ss-os-o; Xylene, mixed isomers (rsao-zo-z; US EPA guidance documents (ra44ry-eg,ggy4l| for reporting Persistent Bioaccumulating Toxics (PBTs) indicate this product may contain the following deminimis levels of toxic chemicals subject to Section 313 reporting: INGREDIENT NAME (CAS NUMBER) CONCENTRATION - Parts Der million (Dpm) byWeiqht Polycyclic aromatic compounds (PACs) 17 Benzo (g,h,i) perylene (191-24-2) 2.55 Lead (7439-92-1) 0.079 0.1 to 4.9 (0.1 to 1.3 for <3 0.5 to 4 0 to 15.0 1to15 <6 1to15 gasoline) Revision Date: 01/08/04 Page 7 of 8 FIM ER FItrFI H E55 trtrFT trtrFT FITIIIT MATERIAL SAFEry DATA SHEET Gasoline, All Grades MSDS No.9950 CANADIAN REGULATORY INFORMATION (WHMIS) Class B, Division 2 (Flammable Liquid) Class D, Division 2A (Very toxic by other means) and Class D, Division 28 (Toxic by other means) 16.OTHER INFORMATION Jan-04 NFPA@HAZARDRATING HEALTH: FIRE: REACTIVITY: HMIS@ HAZARD RATING HEALTH: FIRE: REACTIVITY:* CHRONtC SUPERSEDES MSDS DATED: 12130197 ABBREVIATIONS: AP=Approximately < =Lessthan >=Greaterthan N/A = Not Applicable N/D = Not Determined ppm = parts per million AGRONYMS: ACGIH American Conference of Governmental NTP National Toxicology Program Industrial Hygienists OPA Oil Pollution Act of 1990 AIHA American Industrial Hygiene Association OSHA U.S. OccupationalSafety & Health ANSI American NationalStandards lnstitute Administration (212)642-4900 PEL Permissible Exposure Limit (OSHA) API American Petroleum Institute RCRA Resource Conservation and Recovery Act (202)682-8000 REL Recommended Exposure Limit (NIOSH) CERCLA Comprehensive Emergency Response, SARA Superfund Amendments and Compensation, and Liability Act Reauthorization Act of 1986 Title lll' DOT U.S. Department of Transportation SCBA Self-Contained Breathing Apparatus [General Info: (800)467-4922] SPCC Spill Prevention, Control, and 1 Slight 3 Serious 0 Minimal 1" Slight 3 Serious 0 Minimal EPA U.S. Environmental Protection Agency HMIS Hazardous Materials Information System STEL IARC InternationalAgency For Research On Cancer TLV MSHA Mine Safety and Health Administration TSCA NFPA National Fire Protection Association TWA (617)770-3000 WEEL NIOSH National Institute of Occupational Safety and Health NOIC Notice of lntended Change (proposed change to ACGIH TLV) DISCLAIMER OF EXPRESSED AND lMPLIED WARRANTIES Information presented herein has been compiled from sources considered to be dependable, and is accurate and reliable to the best of our knowledge and belief, but is not guaranteed to be so. Since conditions of use are beyond our control, we make no waranties, expressed or implied, except those that may be contained in our written contract of sale or acknowledgment. Vendor assumes no responsibility for injury to vendee or third persons proximately caused by the material if reasonable safety procedures are not adhered to as stipulated in the data sheet. Additionally, vendor assumes no responsibility for injury to vendee or third persons proximately caused by abnormal use of the material, even if reasonable safety procedures are followed. Furthermore, vendee assumes the risk in.their use of the material. Countermeasures Short-Term Exposure Limit (generally 15 minutes) Threshold Limit Value (ACGIH) Toxic Substances Control Act Time Weighted Average (8 hr.) Workplace Environmental Exposure Level(AIHA) WHMIS Workplace Hazardous Materials Information System (Canada) Revision Date: 01/08/04 Page 8 of 8 LUSTLine Bulletin 22 SSIIAs Er=*cavations Standards ffIust Be Met Euring Underground Storage Tank Excavation Work by Matthew E. Fitzgerald standards that coaer excaaations (29 CFR Subpart P, sections 650-65D. After a four-mafl cre?t) had remooed an underground filter tank at a car-wash construction site, they entered the 9-foot deep, 6-foot by 14-foot excaaation to hand grade the bottom. The sides of the excaaation were neither shored nor sloped. Awall of the trench collapsed,killittg one worker and seriously injuring another. The employer was in clear aiolation of the OSHA -f-'lxcAVATroN CAVE-INS ARE REAL fi hazards that happen all too -L-loften, and underground stor- age tank (UST) installation and removal operations are no exception. Bureau of Labor Statistics (BLS) for 1993 state that 138 u'orkers were kiiled by collapsing materials. That figure represents 2 percent of all work-related fatalities that were caused by injury in that year. Yet, there is no shortage of sto- ries about employers who go to great lengths to avoid having to comply with these important OSHA require- ments, which clearly saves lives. (Did you hear the one about the tank installer who was found installing tanks at 3:00 am to avoid the OSHA inspectors?) The safetv requirements for excavations are not unduly bur- densome regulations that have no real life impact on rt orkers; these reouirements save lives...evervdav. Are these reouirements thit tough to meet? Just imagine if you'd been the foreman on the car-wash job described above, and the onus was on you to inform the worker's spouse and children that their loved one was crushed to death at work today. And more often than not, the loved one does have dependent children-BlS reports that 66 percent of workers killed on the job are less than 45 years of age. Considering these potentially tragic consequences, compliance with the OSHA requirements seems the smart thing to do. OSHA Requirements For Excavations The 29 CFR 1926.657 General Reauire- 24 ments for excaaations are laid out in paragraph form and include the fol- lowing subsections: (a) Surface encumbrances. According to ihe standard, "All sur- face encumbrances that are located so as to create ahazard to employees shall be removed or supported, as necessary, to safeguard employees." When trenches are dug alongside of buildings or fixed objects, the weight of the building on the side of the trench may cause the trench wall to collapse. This type of situation can be especially true in the tight areas asso- ciated with remediations. For example: During a pipe laying operation, a tree adjacent to the excaaa- tion was undercut at the roots, 3 feet below ground level. The tree fell and when it did, it pinned a worker against the pipe that was being laid at the bottom of the trench. (b) Underground installations. According to the standard, "The esti- mated location of utility installa- tions-such as sewer, telephone, fuel, electric, or water lines, or any other underground installations that reasonably may be expected to be encountered during excavation work-shall be determined prior to opening an excavation." Clearly, the potential of striking an underground electrical or fuel line needs to be addressed before an excavation is begun. Usually utilities companies can be contacted directly and are very responsive to requests for review of a planned excavation. Potential hazard also lurks in a situa- tion where a trench intersects an area of previously disturbed soils. Many fatalities associated with trenching accidents have occurred at the inter- section of a trench and a previously filled trench (e.B.,a utility conduit). For example: A trench, L0.5 feet long, had been dug in preparation for laying a sewer pipe. A gas main was located 4 feet to the east of the trench. As the zuorker was grading the bottom ot' the trench, the east wall collapsed. The worker was crushed to death. The section that t'ell consisted of fill material from the pretsi- ous installation of the gas main. (c) Access and egtess. This paragraph requires that ade- quate consideration be given to access and egress into and out of the trench and brings to mind the chil- dren's story of Mike Mulligan and his steam shovel, Mary Ann. Taking up a challenge to dig the basement of Popperville's city hall in one day, ihey worked so fast and furiously that they forgot to dig themselves a way out. Fortunately for Mike and Mary Ann, things worked out fine- Mike was hired on as maintenance man at the new town hall, and Mary Ann was transformed into the town hall boiler. In the real world, however, get- ting out of an excavation can be quite hazardous. The very act of scaling a vertical wall can cause it to collapse. Consequently, OSHA requires that either ramps and runways, designed by a "competent person", or stair- ways or ladders be included in all excavations. A competent petson is defined by OSHA as an individual LUSTLine Billetin 22 who is "capable of identifying exist- ing and predictable hazards or work- ing conditions that are hazardous, unsanitary, or dangerous to employ- ees, and who has authorization to take prompt corrective measures to eliminate or control these hazards and conditions." (Note: OSHA pub- lished an "intent" of its definition of a competent person in the 70 / 37 / 89 Federal Register.It states that a com- petent person must have specific training in and be knowledgeable about soil analysis, the use of protec- tive systems, and the requirements of the standards.) A meat " of egress is also required for all excavaiions greater than 4 feet deep and must be placed in such a manner so as to require no more than 25 feet of lat- eral travel distance for employees. (d) Exposure to vehicular traffic. UST operations often take place at gas stations, where vehicular traffic can be a real hazard. In 199j,361 workers died as a result of beine struck by vehicles-6 percent oi occupational fatalities for that year. Because trenching operations often take place adjacent to or in roadways, OSHA requires that workers expoied to vehicular traffic be provided with warning vests or other suitable gar- ments marked with or made of reflec- tive or high visibility material. (e) Exposure to falling loads. There are many examples of workers in trenches being crushed by falling loads. Workers must not be permit- ted underneath loads that are being handled by lifting or digging equip- ment. For example, when a tank is being lifted out of an excavation, workers must be restricted from entering the tank excavation or drop zone. (f) Warning system for mobile equipment. Because construction equipment operators are often unable to see everything that is going on to their rear during operations, a general practice of construction safety is to equip all heavy equipment fhat is used on site with backup alarms. When working from the surface into 4fi excavation, these operators are also very limited in teims of what they can see in the excavation. Con- sequently, where mobile equipment What'e wrong with this picture? is used adjacent to an excavation where the operator does not have a clear and direct view of the edge of the trench, OSHA requires a warning system, such as barricades, hand or mechanical signals, or stop logs, to be utilized. For example: A sewer pipe was being laid in an 8-t'oot deep trench. One end of the trench was being back t'illed by a front end loader. A worker, new to the job, entered the area of the trench that zuas being backfilled and was crushed to death when a load of fill was dropped on him. The other workers in the area did not realize the worker was missing until seaeral minutes had passed. OnIy after searching did they determine that their co-worker must haoe been buried in the backfilled area. The operator of the t'ront end loader,utho's aieu of the excaaation was obscured, had no idea that he had buried his co-usorker. (g) Hazardous atmospheres. Hazardous atmospheres can be a problem in trenches. Because of the nature of a trench (i.e., because a trench is a narrow depression in the earth) hazardous gases may accumu- late as they are released from the soil or groundwater. This potential for concentrations of gases is particu- larly true at hazardous waste sites and may pose a problem at UST remediation sites where the tank has leaked. If there is the potential for a hazardous atmosphere to exist in a trench greater than 4 feet deep, OSHA requires atmospheric testing of the trench before employees are allowed to enter-oxygen levels must be greater than 19.5 percent, the atmosphere must not exceed 20 percent of any lower explosion limit (LEL), and toxics below the permissi- ble exposure limit (PEL). Hazardous atmospheres and entry into confined spaces, such as trenches greater than 4 feet, can be extremely hazardous. For this reason, if an UST removal operation is being performed in cont- aminated soil where the potential exists for hazardous atmospheres, a competent safety professional should be consulted. For example: An UST was remooed from an excaaation approximately 6.5 feet wide and 6 feet deep. There was approximately one foot of water at the bottom of the excaaation. In preparation for installation of the new tank, two workers entered the excaoation to splice two pipes. Unbeknoumst to the entrants, propane gas had leaked from an under- zrater joint on the pressurized side ot' the pipe being spliced. Both workers were killed by asphy xiation. (h) Protection from hazards associated with water accumulation. OSHA requires employers to ade- quately protect workers from the hazards associated with water accu- mulation in an excavation. OSHA outlines three strategies for doing so, including shield systems, removal of accumulated water, or use of a safety harness and life line. Heavy rainfall or water accumulation from ground- water seepage is often associated with trench collapse. Particular care should be taken when inspecting trenches with water accumulation. I continued on page 26 25 LUSTLine Bulletin 22 l Health & Sately yom page 25 (i) Stability of adjacent structures. This paragraph of the standard requires that proper precautions be taken when the stability of an adja- cent structure is jeopardized by the excavation. Support systems must be designed by a competent person, or a professional engineer must certify that the structure is sufficientlv removed from the excavation so as to be unaffected by the excavation activity. The standard also states that if sidewalks and pavements will be undermined, there must be an appropriate support system to pro- tect employees from the possible col- lapse of such structures. (j) Protection of employees from loose rock or soil. OSHA requires that employees be afforded adequate protection from the hazard of loose rock or soil falling or rolling from the face of an excavation. Specifically, OSHA requires that all materials and equip- ment be kept at least two feet from the edge of an excavation. (k) Inspections. OSHA requires that daily inspec- tions be performed to identify evi- dence of situations that could result in possible cave-ins, indications of failure of protective systems, haz- ardous atmospheres, and other haz- ardous conditions. These inspections must be performed by a "competent Person.'/ (l) Fall protection. Where a falling hazard exists, an employer must mitigate the hazard. Because trenches and excavations may pose a fall hazard, employers are required to provide physical bar- riers to prevent inadvertent entry. The standard requires: r Walkways or bridges with stan- dard guardrails where employees or equipment have to cross over an excavation. r "Adequate barrier physical protec- tion" at all remotely located exca- . vations. Wells, pits, shafts, etc.' must be barricaded or covered. Temporary wells, pits, shafts, etc. must be backfilled upon comple- tion of exploration operations. F OSHA Requirements For Sloping And Shoring The following section, 29 CFR't 926.652, Requirements for protectiae systems, describes how employees who must enter excavations are to be protected. There are essentially two options to ensure the safety of work- ers who enter excavations: Sloping or shoring. Proper sloping of trenches is described in paragraph (b) design of sloping and benching systems. Employ- ers have four options for proper compliance: . Option 1 - requires a slope of 1 and \/2horizontal to 1 vertical for a slope of 34 degrees measured from the horizontal. This requires that the slope be cut back 1 and 1./2 foot from the trench for every foot of depth. A 6-foot trench, there- fore, would require a slope 9 feet out from the base of the trench. . Option 2 - allows for steeper slopes, based on the type of soil in which the excavation will be dug. For an in-depth discussion of soil types and required slopes see 29 CFR 1926.652 Appendix A, Soil Classification, and Appendix B, Sloping and Benchins. There are essentially four types of soils: Sta- ble rock, type A, type B, and type C. The angle of sloping in Option 1 assumes a type C soil. By defini- tion, UST remediation work can- not possibly be done in type A soil, because type A soil, as defined by the standard, must never have been previouslv dis- turbed. Soil arLund a tank removal operation has obviously been previously disturbed (i.e., when the tank was installed). Type B soil requires a slope of 1 horizontal unit to one vertical for a slope of 45 degrees. It is proba- bly easiest to simply dispense with the process of classifying soil and to assume it is type C, which requires a slope of 1.5 to 1. . Option 3 - requires the use of tabu- lated data approved by a regis- tered professional engineer. . Option 4 - requires sloping sys- tems designed and approved by a registered professional engineer. The requirements for shoring systems are found in paragraph (c) Design of support systems, shield sys- tems and other protectiae systems. As with sloping, there are several options for using acceptable shoring devices, including systems which meet the requirements of Appen- dices A, C, and D of the standard; systems which are used in accor- dance with the specifications, limita- tions, and recommendations issued or made by the manufacturer; sys- tems based on tabulated data approved by a registered profes- sional engineer; or systems designed by a professional engineer. Protec- tive systems which meet the intent of the standard are discussed in some detail in Appendix C,Timber Shoring for Trenches, and Appendix D, Alu- minum Hydraulic Shoring for Trenches. Staying Out of Harm's Way In 1985 OSHA prepared a report entitled, Selected Occupational Fatalities Related to Trenching and Excaaation as Found in OSHA Fatal- ity I Catastrophe Inaestigations, which was a review of some 206 trenching and shoring fatalities. The conclu- sion listed several recurrent problem areas, including: . Failure to provide adequate sup- port systems (shoring); o Failure to set excavated material back an adequate distance (re- quired 2-foot minimum) from the edge of the excavation; o Inadequate sloping of trench walls; . Causing equipment and vehicles to come into contact with sources of electrical currenU . Operating equipment and vehi- cles too close to the edge of the excavation; o Failure of workers to communi- cate in such a way as to prevent co-workers from being struck by equipment; and o Failure to properly brace standing walls adjacent to trenches. OSHA went on to list secondary causes of fatal accidents. These included: r Inexperienced workers or workers new to a particular job; . Employees taking unnecessary personal risks; . Dangerous work practices (e.g., shortcuts that increase the likeli- hood of an accident); . Failure to coordinate work in small areas; and . Health problems relating to the LUSTL|IT Bulletin 22 phvsical condition of workers (e.9., alcohol). OSHA concludes the report by list- ing several sets of measures which can be taken to prevent the complex events that are a function of human, machine, and environmental interac- tions that too often result in fatal trenching accidents. These preven- tive measures include: r Establishing and strictly enforcing trenching and excavation safety measures, such as shoring, slop- ing, and removal of spoil from the edge of the excavation; . Increasing training and education for work safety procedures and activities; and . Improving supervision required safety measures. Excavations associated with UST installation and remediation are by their nature dangerous, and no worker should be expected to enter a trench without the proper protec- tion. Yet as hazardous as such work may be, there are some very effective strategies for protecting workers. A good place to start is by complying with the OSHA regulations. I References: OSHA,29 CFR Part 1925 Occupational Safety and Health Standards-Excavations; Final Rule. Federal Register, Tuesday October 31, 1989. OSHA, Selected Occupational Fatalitia Relatd to Trenching and Excaoation as Found in QSHA Fatality lCatastrophe lnoestigations. July 1985. OSIIA, Accidmf Reporl - Fatal Facts Number 52. Bureau of Labor Statistics. National Census of Fatal Occapational Injui*. Atgust 1994. ;vltttlirtt, Fitz!(rnlll , DrPH, CIH, is n ,, t i i i tl r i i t Li t t s i r i n ! Hy gi enis t i t, it h S CI - Fl'l-tECH Inc. itt Rockoille, MD. He is ctLrrcttflv rt Ltrking on safetV and heslth lrr)licli issles cortcening tlre Depart- ;ttt:it! tli Errr'rgv's rnsmntotlt effort to ..7 jt t:i' ll;i ;t,, i,',tr tt't'tllttrttr' ccltt7111'.1' .:rrrl r-i:trl'r' ! ];c r't ttirontttettt. Mctttlrctt, rirr:; ;i'rlili'r/ t itrct' cttlter ircslth nntl .,rriir/,7/'i/f/fs ntr t,usTLirrc. Unrted States Envrronmental Protection Agency Solid Waste and Emergency Response (os-420)wF EPA/910/B-92i001 June 1 992 9EPA Health and Safety Training for Underground Storage Tank lnspectors EXHIBIT 2-1 ACCIDENTS INVOLVING HANDLING AND TRANSFER OF PETROLEUM PRODUCTS Some reported accidents involving the Handling and Transfer of Petroleum Products are presented below. Notice that a large number of accidenls occur during closure. Explosion in Tank "Deemed Safe" Kills One Georgia. 1990 - A Snellville. Georgia man dies April 17 when a 10,000-gallon underground gasoline storage tank explodes at Dry Storage ol Georgia. The tank was deemed safe one-half hour beiore the explosion occurred. The worker was a five-year employee of Westinghouse Environmental and Geotechnical Services, a company that specializes in removing underground lanks. This is the third death in Georgia in less than a year involving a tank closure. Worker Dies in "Preventable" Accident Tulsa, 1990 - An underground storage tank explosion kills a worker and blows out the windows in nearby stores. The explosion occurs when two workers are attempting to cut a fill pipe from an UST containing a small amount of water and some residual fuel. The metal cutting saw they are ustng creates Jspark that ignites the gasoline vapors. The ensuing blast blows the S-foot end off the tank' The flying metal disk lravels 20 feet and decapitates a co-worker who is returning to the lob site from a convenience store located across the street. A Tulsa Fire Department spokesman characterizes the incident as "a highly preventable accident." Worker Dies from Trauma Following Explosion Tulsa, 1990 - An explosion in an empty gasoline slorage tank kills a workeras he is dismantling it with an acetylene torch. According to authorities, the steel tank was removed from the ground the week prior to ihe explosion and a substance was placed in rt to help ventilate fumes. The plumbing company retuined to begin dismantling the tank, assuming it to be free of fumes. The 2,000-gallon steei tank explodes when the worker, employed by the plumbing contractor, applies an acetylene torch to it. The end of the tank blows out and propels the worker backwards about 25 feet, where he hits a building. The man dies, apparently from irauma suffered when thrown by the explosion. In addition, a building on the property and a truck owned by the plumbing contractor are damaged. Explosion Crushes Worker lndianapolis, 1990 - Employees of a company which collects empty fuel tanks and cuts them up into scrap metal are in the midst of purging vapors and cutting tanks when the accident occurs' A worker is using an acetylene torch to cut a tank when an adjacent tank explodes, pushing it 6 feet forward into the one he is working on. The worker is crushed between the tank he is working on and a wrecker parked nearby. investigators suspect that the tank that exploded either had not yet been cleaned or had been cleaned improperly. 48 EXHIBIT 2-1 (con.) ACCIDENTS INVOLVING HANDLING AND TRANSFER OF PETROLEUM PRODUCTS Man Killed While "scrapping" Abandoned Underground Storage Tank A scrapion and metal dealer is working alone and using an acetylene torch to cut a tank into scrap when the flame from the torch ignites iume" inside the tank and touches off an explosion. The force of the btast lifls the 10,ooo-gallon tank into the air, sending rt about 50 feet from tts initial spot. A tank end is blown about 450 feet into a nearby field. The tank, measuring 20 feet by 10 feet, was reportedly used for underground storage of residential heating oil. However, individuals at the accident scene speculated the tank actually contained gasoline or gasoline residue, and that fumes from the gasoline igniled. The victtm's brother said the worker was Lxperienced in cutting scrap metal and "knew better than lo cut up a gas tank." OHIO - Sandblasting Incident A man retained to sandblasl an underground storage tank dies when he lurns on an electric vacuum cleaner as he prepares to clean sand from the tani bottom. A spark from the vacuum cleaner ignites the vapors inside the tank, causing it to explode. He dies later as a result of the burns suffered in the blast. Tank Abandonment Kills Three While cutting the top off an empty tank at Kerr-McGee's Cotton Valley Refinery, a piece of equipment apparenfly ignites vapors inside t-he tank. The blast kills three men inside the tank; a fourth man left the tank to get some tools and escaped unharmed. Explosion Narrowly Avoided 19g0 - Two employees breaking out the concrete inside a pump island in order to relocate the product line, instead of capping the exposed line, stuff a rag in it to keep the dirt and broken concrete out' While cleaning fhe island with shovels, a spark igniies the fumes coming through the rag. The rag immediately citches fire and burns until the employees smother it with dirt. Tank Worker Dies During Vapor Check 1990 - An Oregon tank worker places a lighted rag down a fill pipe to delermine if the lank contains vapors. lt does, and an explosion results, killing the worker. 49 THE FIRE TRIANGLE Fire is a rapid and persistent chemical reaction accompanied by the emission of heat and light. Three primary elements, represented by the fire triangle, must be present for a fire to burn: oxygen, fuel, and a source of ignition. Each side of the fire triangle represents one of lhe necessary elements of fire. The center of the triangle represents the optimal fuel-to- oxygen ratio with enough heat to ignite the mixture. lf any of the elements are removed, however, there can be no fire (this is represented by the corners of the triangle). For example, if the wood on a campfire is consumed or removed, the fuel supply is no longer sutficient to sustain combustion. A more modern fire triangle would have these three elements: oxidizer, fuel, and energy source. Energy can be produced by chemical reaction, mechanical action or electrical discharge. Allthese factors may come into play at UST sites. It is important to understand that it is not the liquid which burns. Vapors are produced, which are heated and broken into simpler compounds (such as methane) which will readily oxidize. The flame above a solid material is also the result of the burning of heated gases. Surface burning may occur after all the volatile materials are driven off. as in the case of burning charcoal. Surface burning also occurs when metals burn. Once started. a fire will continue until the fuel or oxygen concentration falls below a minimum value. A fire commonly results from the combination of some combustible materialwith orygen, but the oxidizer does not have to be O.. The oxygen may be part of a chemical compound such as nitric acid or ammonium percholorate. Combustion may also occur, in some cases, without oxygen being involved; for example, break fluid can be ignited by chlorine. Oxidation can occur wilh any chemical material that can easily yield orygen, or a similar element. Similar compounds include fluorine, chlorine, and bromine. However, simply because a compound conlains these elements does not make it a strong oxidizer. Carbon dioxide has two orygens, but is not an oxidizer. 22 FACTORS IMPORTANT IN COMBUSTION Combustion is the burning of any substance, whether gaseous, liquid, or solid. Flammability is the ability of a material to generate a sufficient concenlration of combustible vapors to be igniled. The flammable range is the range of vapor-air mixtures which willsupport combustion. lt is bounded by the upper flammable limit (UFL) or the highest concentration of a product that is flammable and the lower flammable limit (LFL) or lowest concentration of a producl that is flarhmable. Concentrations outside this range that are too vapor-rich or too vapor-poor, will not ignite. Combustion and flammability have technical and regulatory definitions. lt is important to understand this drfference. (The technical, or scientific, definition is given here). The Deparlment of Transportation has its own definitions for flammable and combustible. Any liquid wilh a flash point of 100"F or less is considered flammable. Any liquid with a flash point greater than 100"F is considered combustible. This is strictly a regulalory definition. What's the dfference between material with a flash point of 99'F and one with a ffash point of 102'F? lgnition temperature is the minimum temperature to which a substance in air must be heated in order to inrtiate, or cause, seff- sustained combustion independent of the heating elemenl. lgnition temperature is also referred to as'auto-ignition temperature." lgnition temperalure is important in many applications, btrt not so much for determinino fire hazard. strangely enough. For instance, gasoline is much more of a fire hazard lhan diesel, yet the auto-ignition temp of diesel is at least 100'F less than gasoline! Flash point is the minimum lemperalure at which a substance produces sufficient flammable vapors to support a flame when an ignition source is present. The availabilitv of vapor, not the ionilion temoerature, is the kev indicator of hazard. Table 2-'l delineates fire hazard properties of various flammable liquids, gases, and volatile solids. 24 TABLE 2-1 FIRE HAZARD PROPERTIES OF PETROLEUM PRODUCTS Chemical Benzene Fuel oil, No.6 Gasoline,' C'H,, to c,H20 Gasoline,' aviatIon Toluene m-xylene Chemical Benzene Fuel oil, No. 6 Gasoline,l C,H,, to C*H2O Gasoline,' aviation Toluene m-ryrene Vapor density (Air=t) Hazard ldentification oiling :roint F fc) 176 (80) 3.1 3.7 231 (1 11) 282 (13s) Flammability 3 0 3 ? 3 3 Fire hazad propefties of sl:lme flammabte liquids, ga*s and votatile solids (abstncted lrom NFPA 325M'1984' p' 9-95, 1944) ' Values may vary for different gasoline grades. 2 Water solubilities are very low. 1.4 ie 1.2 1.1 7.6 7.1 7.1 7.0 12 (-11) 1*-270 (66-132) -45 (43) -50 (-46) 40 (4) 81 (27) 928 (4e8) 765 (407) 536 (280) 824 (471) 896 (480) 982 (527) 2 2 I t z 2 Not No2 No2 No' No2 No2 RELATIONSHIP OF FLASH POINT AND FLAMMABILITY The relative flammability of a substance is based on its flash point. Flash point is defined as the mrnimum temperalure at which a substance produces sufficient flammable vapors to ignite when an ignition source is present. An ignition source could be the spark from static electricity, an electricaltool, or a wayward cigarette butt. Note: In the case of liouids, it is nol the liquid itself lhat burns. but the vaoor above rt. Flash point is the single most important factor to look at in determining fire hazards. Flash points are determined by the National Fire Protection Association (NFPA). lf the temperalure of a liquid has reached the flash point, or higher it will be ionited bv a spark, if the fuel/air mixture is right. There is a value called the "Fire Point." The "Fire Poinl" is the temperature the liquid must reach to generate enough vapors to sustain a flame. For practical purposes, however, we are only concerned with the flash point. lf the liquid is at the flash point, and an ignition source is present,lhere will be a fire. There are two methods of measuring flash point: open cup (o.c.) and closed cup (c.c.). The open cup method does not attempt to contain the vapors as they are generated, while the closed cup method does. The closed cup flash point is always lower than the open cup, since the concentration of vapors are not lowered by dispersion. This is important to UST inspectors, who deal with closed containers and confined areas frequently. Flash points do not apply to solids or gases. Finally, flash points are variable. Gasolines are different, and lab tests ditfer. lt is not uncommon to see flash points differ 10" from one relerence to the nexl: therefore, it is recommended that one allow a generous margin of safetY. 27 FW$ffi llEii.c*tlF*GiEffies,,.or,,,GAso|-s|E,,,,,,,,,,,,,,; ififi*es:namrn Olc vapors at alrnospherh fenperaturCu.qruf+n;,,e1 ',.,,.....,..., 45?F Fltm tffir;:l|r*dtsr.:::.::L:F['.;i a *;, Uru,.,1'ie pgryqnt FLAMMABLE CHARACTERISTICS OF GASOLINE Gasoline is one of the most dangerous petroleum products because it readily generates flammable vapors at atmospheric lemperatures (down to -45"F) and generates these vapors within an UST. lt is this vaoor, not liquid oasoline itself. that burns or explodes when mixed with air and an iqnrtion source. ln addition. oasoline has a verv low flash point that means even the smallest source of iqnition can cause an exDlosion. The concentration of vapors in USTs storing gasoline is normally too rich to burn, that is, above the upper flammability limit (UFL). However, if the temperature of tfie liquid gasoline is in the -10"F to -50'F range, the concentralion of vapors will be within the flammable range. The National Fire Protection Association (NFPA) developed Slandard 704M, a five step ranking syslem from 0 (lowest) to 4 (highesl), to identify relative hazard levels. The NFPA standard addresses three categories: flammability, health, and reactivily. Gasoline is rated 3 in the NFPA category for flammability. An NFPA value of three indicates that gasoline is a liquid that readily ignites under typical ambient conditions. NOTES FLAMMABLE CHARACTERISTICS OF GASOLINE (con.) NFPA FlammabilitY Ratinq 0 1 2 Will not bum in air when exposed to 1500' for five minutes. Material must be preheated before it will bum. Materials that must be moderately heated before ignition ean occur. 'Liquids with flash points between 10Oo-200"F." Malerials can be ignited under most ambient conditions. Materials that rapidly disperse in air and burn readily. Example Asbestos Diesel Gasoline Flammable gases ?k. 30 FLAMMABLE CHARACTERISTICS OF MIDDLE DISTILLATES Much of the nomenclature in the petroleum industry is rather vague. For instance, fuel oils can be classed as middle. heavy, or residual distillates. Jet fuel may range from kerosene- like blends, with middle distillate properties, to blends more like gasoline, a light distillate. Don't get hung up on the light-middle-heavy- residual distillate terminology. lt is general. Look at the properties of ihe {uel or oil ol concern. Middle distillates are the iractions of crude oil which possess a moderate boiling point. These fractions include kerosene, aviation fuels, diesel fuels and Fuel Oil Nos. 1 and 2, and have a wide range of tlammabilities. The diesel fuels and fuel oils are relatively non-flammable. They require limited heating at ambient temperatures to ignite. Flammability is expressed in units (percent) by volume ol the material in air. The lower flammability limit (LFL) for diesel fuel is 1.3 percent. The upper flammability limil (UFL) is 6 percent. While diesel is not lypically a flash hazard, it the fuel is spilled on hot concrete or metal, or stored in direct sunlight, the heat may be sufficient to make diesel a serious hazard. Aviation fuels are divided into the kerosene grades (Jet A, A-1, JP-5. 7 and 8) and the "wide cut" blends of gasoline and kerosene (JP-4 and Jet B). Wide cuts are lighter blends The vapor space in a tank storing a low vapor pressuie liquid, such as kerosene, contains a Liittrt" too lean to burn, tlnt is, below the LFL' but the wide cut bleMs reoregent a in the flammable range. 31 FLAMiIAS LE CHARA gTE BIS"NCS Residual Fuels {Fuel Oil Nos. 4,5,8, Retatively non-flamm$le ' NFPA=2 Flash points . Nos.4, 5. No.6 LFL . Nos.4, 5, 6 UFL 1 30"F to 335"F 150"F lo 27VF '1.0 percent Nos. 4, 5, 6 5.0 percenl FLAMMABLE CHARACTEBISTICS OF RESIDUAL FUELS Residual luels (Fuel Oils Nos. 4, 5, and 6) are defined as the product remaining after the removal of appreciable quantities of the more volatile components ol crude oil. They have a high flash point; iqnition will not occur until the liqurd reaches a temperature of 130 or hioher. They are not as dangerous as gasoline, however, they do pose a threat. NOTES FLAMMABLE CHARACTERISTICS OF USED otLs Used oils in general are relatively non- flammable, yet they pose specialdangers. The characteristics of used oils are not uniform because the oils take on additional characteristics and components during use. Thus, used orls may contain toxins or olher dangerous products of which an inspeclor may not be aware. For instance, the "other products" (often solvents) found in used oils can greatly reduce their flash point, making them much more flammable. Virgin lubricating oil has a flash point of 350'F. By comparison, when 1,000 samples of waste oils were tested; 30 percent of them had a flash point under 140'F. The components of some used oils, particularly chlorinated solvenls, pose a special toxicological hazard in a fire because of their ability to release toxic fumes. All associated hazards are affected by ambient conditions. For instance, a used oil may be difficult to ignite, but if a nearlcy fire heats the oil it may ignite and burn fiercely. NOTES EXPLOSIONS Explosions are rapid chemical reactions that produce large quantrties of gas and heat, a shock wave, and noise. Explosivity is expressed as a percentage of a given material in a volume of air. The lower explosivitv limit (LEL) is the lowest concentration of a product that is explosive. The upoer explosivilv limit (UEL) is the hiohest concentration of a product thal is explosive. UEL and LEL, for all intents and purposes, are the same as UFL and LFL. Generally, explosions can do serious harm much more rapidly than toxic exposure. Explosions and fires are the most immediate hazard during tank removal or closure activities, and when release investigation techniques are performed in a confined space. Bear in mind that the difference between a fire and explosion is not a large one. lt can simply be the speed of the reaction. Any malerialthat can burn, if placed under sufficient heat, and confined as in a tank, can explode with tremendous force. Explosions are not necessarily the result of combustion. In a closed container (such as an UST), flammable liquids expand when heated. Gasoline, for example, expands about 0.06 oercent in volume for every 10"F increase in iemperature. When the pr'essure inside the UST exceeds the desiqned pressure resistance. a "Dressure release exolosion" can occur. Although nol directly related to standard pelroleum products, Boiling Liquid Expanding Vapor Explosions (BLEVES) are important due to their tremendous destructive force. BLEVEs occur when compressed gases, such as LPG, are stored as liquids al lemperatures above their normal boiling points lf lhe vessel is exposed to a fire, the rapid buildup of pressure coupled with heat-induced weakening of the tank sides, results in a sudden and violent rupture, with the superheated liquid vaporizing and creating a fireball. 35 ' '' WORKING NEAR TXPTOSIYE'VAPIORS OR tGNrfABLE LI(}I'IDE-- --l ''. ' : ': : : '. j. ..i.useontyexptoxrn,proofcameras:':''.i t..t , Remove:flash camera batteriee, or do not uee ,'''' q,: , Do rpt smoke or us€.rnalctres or lighlers ''''''....' WORKING NEAR EXPLOSIVE VAPORS OR IGNITABLE LIOUIDS lf an inspector discovers that vapors or liquids are present in a confined structure and a rapid assessmeilt rndicates the potential for an explosion or fire, the inspector should take general safety measures at once. . All persons should be kept away from lhe danger area, except those properly trained and equipped. . The localfire department should be alerted . A trained operator of a combustible gas indicator should determine the concentralion of vapors present. Oxygen levels must also be monitored. Persons in the area should not smoke, start or use vehicles or equipment with internal combustion engines, or touch electrical switches or extension cords. Instruments used at UST sites must not contribute to the potential for an explosion or fire. lnsurance and safety organizations have developed codes for testing electrical devices used in hazardous situations, and an electrical instrument certified for use in hazardous locations will indicate this. lf an instrument does not have an approved rating, it should not be used in a hazardous or potentially hazardous situation. NOTES 37 PURGING Purging is an effective method for controlling the luel point of the {ire triangle. The goal of purging a lank is to reduce the flammable vaoors in the tank well below the lower explosive limit. Purging or ventilating the tank dilutes the tank's {lammable vapors with air, reducing the mixture ol fuel and oxygeh. An eductor-type air mover, typically driven by compressed air, draws vapors out of the tank and forces fresh air into the tank. The fill (drop) tube should remain in place to ensure proper ventilation of the tank bottom. Discharge vapors should be dispersed 12 feet from the tank in order to ensure that llammable vapors are being vented eflectively into the upper atmospnere. Most petroleum products have a llammable range of 1 to 10 percent by volume in air, the amount of fuel vapor necessary to become flammable in the presence of oxygen and an ignition source. Below a luel vapor level of 1 percent (the lower explosive limits or LEL)' the mixture of fuel and oxygen is too smallto support combustion. Puroino should not be undertaken on hot, humid. or still davs because the still air will not disperse the llammable vapors. In order to maintain safe conditions, sile work should be put off for a day. Puroinq is a temporary procedure. Product trapped in bottom sludge and wall scale regenerates flammable vapors inside the tank. Therelore, when purging, lower the flammable concentration to 20 percent of the accepted * does not exceed 20 Percenl' Use a Combustible Gas Indicator (CGl) to measure the reduction in the concentration of flammable vapors during purging' Periodically test the percentage LEL inside the tank, in the excavation, and any other below grade areas' CAUTION: In air purging, with plenty of oxygen present, the concentration of vapors in the tank begin in the flammable range' or may go from too rich through the flammable. range 5efore a safe concenlration is achieved' lt is especially important lo ensure atl ignition sources have been removed from the area before beginning this Process. 38 INERTING Oortols,,loxygenl' point of ftre triangle D'ibplaces orrygen,wilh inert gas :, ,,,,: t,,' '. .'.,, ,neduces g,rrlgen below ihe combuslion',teveI Common inerting rnaterials: dry ice (COJ and compreesed nnrogefl Agsure pr:ocedure s effecliveness wilh oxygen meter INERTING Inerting controls the oxygen element of the fire triangle. Inerting reduces the concentration of oxygen needed to support combustton (below 12 to 14 percent oxygen by volume) by replacing the oxygen with an inert gas. Common inerting materials include dry ice (COr) and compressed nitrogen. During the inerting process, gases should be introduced under low pressure in order to avoid producing static electricity. CO, is best applied in solid, dry ice form, rather than as a compressed gas. It is important to recoonize that the inert oas does not "neulralize" the flammable vapors in the tank: it simplv displaces the oxvqen. To measure the effectiveness of the inerting procedure, test the air inside the tank with an NOTES 40 IGNITION SOURCES The lgnition Source is the easiest point of lhe fire triangle lo control. There are many possible sources of ignition during handling and transfer of petroleum products. These sources include static electricrty, sparks generated by tools, monrtoring equipment and engines in the area, lit cigarettes, or even electrical appliances and lightning. Any one of these ignition sources is enough to complete lhe fire triangle. NOTES -' '- ::::::::!'::r:::: :: : SPARK GENERATION Sparks can be generated at an UST site by static electricity, striking metal on metal, such as a hammer on the tank, or striking metal on rock, as when digging with a backhoe. Sparks are also created by the ignition of electrical or combuslion engines and pumps, use of non- intrinsically safe monitoring instruments, and lighlning. Precautions need to be taken to eliminate the possibility of lhese activities causing fire and explosions. NOTES 42 STATIC ELECTRICITY SOURCES The primary mantfestation of static electricity is the discharge or sparking of accumulated charges. Under lhe right conditions, these sparks can be the ignition source for a fire or explosion. Sparks can also be self-generated by humans or created through induction. The static charge resulting from flowing liquids is of primary importance during the transfer of petroleum products. Static electricity is generated by the separation of like and unlike bodies. When liquid flows. charging occurs because absorbed ions are separated from free ions that are carried into lhe body of the liquid by turbulence. For example, static results from liquid dropping into a tank during product deliveries, liquld flowing through a hose when product is pumped from the tank, or compressed gas or air being released into the tank atmosphere. During product transfer, static electricity can be generated by the flow of fuel through small holes into the tank. The movement of lhe fuel against the pipe also generates a static charge. Furlhermore, static electricity can be generated by the settling of rust or sludge particles. Motorized equipment used during tank installation, testing, and closure may generate static electricrty. In order to minimize such risk personnel should qround all equipment durinq ooeration. NOTES REDUCING STATIC ELECTBIC}TY AHg SPARKING Two eflective methods Bonding ' equaliz€Sstatic electrhtty .",.' .,, , . . , ' .,.'..:.......::::]::::::: ' creales conductive connection between lwo entlties (srch as UST and lani ;"uek) ' ,,.,:tit,Grourding . diverts static etectricity into earlh :':: ' '' t' ' elirninates static builduo ",',,,', REDUCING STATIC ELECTRICITY AND SPARKING Bonding and grounding are effective methods to reduce the potential for electrostattc charge generation and sparking, and the subsequent chance of fires and explosions. Bonding entails running a conductive line from one metal object to another. This equalizes static electricity by creating a conductive connection between two objects, reducrng the likelihood of sparks jumping from metalto metal. Carqo tanks should be electricallv bonded to the fill stem, pipinq. or steel loadino rack. Also, all metal parts of the fill pipe assembly should form a continuous electrically conductive path downstream from the point of bond connection. Bonding insures that individual components of a system do not build up charges. In essence, you slow down the charge buildup by distributing it over a bigger area. However, the entire bonded svstem will eventually build a significant charge. Bonded svstems should also be qrounded. Grounding entaiis running a conductive line from a metal object to the ground. This will dissipate any charge on the outside surface of the tank by having it flow into the ground. NOTES 44 Potentiat greatest when handling or tranelerring proOucf tnstal I atior/ Up g ra des Release lnvestigalbn Leak Deteaion Testing lnslallation ol Monitoring Well#Sarnpling '. ' ' .;ExFkrgion oan : oocur, during preesure,te$ting,: :r:r,r: :rr:rrr ::,,,,, FIRE AND EXPLOSION POTENTIAL Assuming an UST is well-maintained, the oreatest tire and explosive hazard occurs durino the trans{er of the product to or lrom storage and during the cleaning and removal ol USTs. Although petroleum products have been handled and translerred salely for decades, UST inspectors should not believe that this transfer is risk- and hazard-free. The transfer of flammable and explosive products (liquids and vapors) may occur during tank testing or repair, tank upgrades, tank closure or removal, tank re{illing or corrective actions. UST inspectors should be aware of the risks associated with these activities. Due to the danoer of violent rupture, use extreme caution when performino pipe and tank testino durino tank installation. Do not pressure-test any piping or tanks that contain flammable or combustible liquids. Do not exceed internaltank pressures of 5 pounds psig during pressure testing. Install a pressure relief valve at 6 pounds psig. Use a pressure gauge with a range ol 10 to 15 psig, and test NOTES :::::1:::::::::::: |ii:::::::::il:;::::::i::i:j::::::::1; I Closure$: iand refriovalg bolh the inner and outer shells of double-wall tanks. Outer wall should be filled by bleeding off pressure from the inner tank. Do not pressurize directly. Avoid standing near endcaps of an UST. The endcaps are the most vulnerable to exolosion. Whether a tank is lo be removed from the ground, or closed in place, product lrapped in the sludge at lhe bottom of the tank, absorbed in the tank walls, or trapped under the scale is a continuous source of vapor regeneration. Cleaning the tank will decrease the amount of vapor regeneration. To make it safe for handling, after the tank is purged or inerted the sludge can be washed to one end of the tank and pumped out while the tank is still in the excavation. Make sure appropriate safety procedures are followed (see Confined Space Entry in Section 3), and a continuous stream of fresh air is introduced into the tank. Make sure the contractor blocks the tank to prevent any movement. lf tank sludge conlains sufficient lead or other substances to be considered a hazardous waste, it must be handled and disposed of consistent with the Resource Conservalion and Recovery Act (RCRA), Subtitle C requirements. Tanks should be removed from the site as promptly as possible after purging or inerting procedures have been completed, preferably the same day. lf the tank remains on-srte overnight or longer, additional vapor may be regenerated from any liquid, sludge, or wall scale remaining in the tank. Regardless of when they are removed, lanks should be checked with an explosimeler to ensure that 20 percent of the lower explosivity limit (LEL) is not exceeded. lf a leak has occurred, contaminated soil and free product will also generale vapors outside of the tank. An explosimeter should be used to check explosive levels in the excavation as well as in the tank itself. CAUSES OF OXYGEN DEPLETION Oxygen conlent in the arr may decrease due lo biologrcal decay, oxidation (rusting;, combustion or displacement by other gases. such as methane, hydrogen sulfide. and cartrcn monoxide. It is critical to keep in mind that even when oxvqen concentration is deficient for human well-beino. there mav be enouoh oxvqen to oxidize a combustion or exolosion. For example, a 16 percent orygen concentration could be sufficient for a fire or explosion, while being too low for humans to comfortably breathe. Eleven percent O, is considered the theoretical lower limit for a fire. However, a reaction with a strong oxidizer could result in a flame in the lotal absence of oxygen. NOTES 53 HAZARD AREAS FOR OXYGEN DEPLETION Oxygen depletion can occur in any confined space, especially those typically encountered by UST inspectors. Tanks and dug-oul trenches are potentially oxygen deficient; basements and sewers are other areas where oxygen may be depleted. Old USTs are particularly susceptible to oxygen depletion through oxidation. lnspectors should always be alert to situations that could create oxygen depletion, and should never enter into such situations without first measurinq the oxvqen level. EPA considers the minimum level of oxvoen for a safe entrv to be 19.5 percent. Below this entry into an oxygen-depleted area is absolutely necessary, inspectors musl enler with an air supplying respirator. Air purifvinq respiralors are not permitted in atmospheres containinq less than 19.5 perceni oxvoen. NOTES 54 PHYSIOLOGICAL EFFECTS OF OXYGEN DEPLETION Orygen depletion produces a range of physiological effects thal worsen as orygen content is lowered or exposure time is increased. Generally, lhere are no detrimental effects above a 21 percent concentration oxygen in air, which is the general concentration of oxygen in air at sea level (it could be more or less in other geographical areas). Below lhis concentration, however, potential life threatening situations exist. The first signs of deplelion occur when oxygen concenlration is between 16 percent and 21 percent. With this level of oxygen, a person's respiration and heartbeat accelerate. Also, attenlion and coordination begin to be impaired. Lower concentrations of orygen can cause rapid fatigue, heart damage, nausea, unconsciousness and death. See Figure 2-1 for an oxygen scale illustrating the physiological effects of depletion. Many times, O, depletion occurs in a very seductive fashion. The viclim may simply become sleepy, and suddenly see nothing wrong with closing the eyes for a shofl nap, from which he does not wake. The imoairment of judgement is drastic, but insidious. After all, it is hard to be alert to symptoms lhat involve loss of alerlness. Plan ahead and use your instrumentallon. When on-sile, UST inspectors should be alert to the svmptoms outlined in the page ab9ve. lf lhev experience anv of lhese svmp!.omq tn a confined space, thev should immgdiqlelv leave iFE area ind seek medical attention if neces9ry. Asphyxiation is most likely to occur in low-lytng areas where heavier-than-air vapors accumulate. An exception to this is methane' or natural gas. which is slightly lighter than air' and may rise to higher levels. Methane is a simple asphyxiant, having no true toxic effect, but it ts extremelY flammable. FIGURE 2.1 SUMMARY OF THE EFFECTS OF OXYGEN DEPLETION Minimum for safe entry to conf ined space 16/o 1 4"/" lmpaired iudgement and breathlng Faulty ludgement and rapid fatigue Difficult brealhing: death in minutes Orygen Scale ll::: NOTES EXHIBIT 2-3 HEAVY EOUIPMENT ACCIDENTS Some examples of reported accidents involving heavy'equipment are presented below. Coal Worker Accidently Crushes Himself Indianapolis, lN, 1990 - A worker using a backhoe to remove four 8,000-gallon fuel tanks from tlie AMAX Coal Co.'s Minehaha mine leans out a broken window of the backhoe cab to remove a chain from the bucket, and accidentally strikes an operaling lever. The bucket drops down and crushes him. The federal Mine Safety and Health Administration cites the company for the broken window in the cab and a broken ignition switch on the backhoe. Worker Maimed in Installation Accident Tulsa. OK, 1990 - A contractor and his sub-contractor are on a job site preparing to compact the backfill material around a new tank installation. The contractor's employee motions for the track hoe operator (the sub-contractor) to use the bucket lo lower the tamper into the hole. The track hoe operator swings the bucket over and sets it down by the employee. who is ready to load the tamper. The employee, thinking the bucket is not moving, lurns his back to the bucket to lift the tamper. The track hoe operator as still in the process of tipping the bucket when the employee turns around and catches his foot underneath the teeth of the bucket. The teeth of the bucket pinch off one of his toes and break two olhers. 92 EXHIBIT 24 GENERAL SITE ACCIDENTS Some reported accidents caused by a vrciation of generai safety procedures are presented below. Notice the wide variety of forms they take Using an air compressor When an employee ustng an atr compressor shuts down the unit the hose is apparently kinked. The employee grabs'the hosJ, releasing the krnk and the pressure that built up in the hose. The force lears lhe employee's safety glassei off and blows the contact lenses from his eyes. Luckily, he is not inlured. Repairing a submersible pump Two mechanics called to a service station to repair a submersible pump disable it by turning off the power at lhe breaker box. As they pull lhe leak detector. someone in the slore turns the breaker back on, causing gasoline to gush out on one of the lechnicians. He is drenched wrth fuel and actually swallows some. The other technician runs into the store to turn the pump off and instructs all employees not to touch the breaker panel The fuel-covered technician loses a day of work due to chemical exposure. The lesson learned by this incident is to make certain every employee in the store is aware that the power is off and that they are not to touch the breaker panel. Working around unsecured obiects A wooden box lid left unsecured atop the box is blown off by a strong wind and strikes an employee working in lhe warehouse yard. The employee is transported to the hospital by ambulance and undergoes x-rays and a CAT scan. Luckily, he escapes with a mild concussion and a minor cul on his ear, and is able lo return to work the following day. Repairing a submersible pump A veleran serviceman is dispatched to a convenience store in response to a report that the customer can not dispense regular unleaded fuel. The serviceman suspects a problem with the submersible pump capacitor. The store operator is present and says he will turn off the power to the unit in question. Upon opening the capacitor hcusing, the serviceman observes that it is filled with fuel. Withot-rt checking ine power (which was still on), the serviceman pulls a lerminal off the capacilor. This creates a spark which ignites the fumes in the cavity. The serviceman has the presence of mind to snuff out the fire immediatety. tnere is no physical damage or injuries caused by this incident, and all involved are very lucky to have avoided a major disaster. The serviceman points out the company procedures that he did not follow: 1) Don't rely solely upon another person to turn off power to a device. See that you agree with what has been done; 2) "Lock-Out" the breaker or switch that has been lurned off by r""n" of a sign or a mechanical device; 3) Check the device being turned off with an elect1cal tester before proceeding with repairs. Haste can also be faulted in this incident as it was late Fridav afternoon. EXHIBIT 2-4 (con.) GENERAL SITE ACCIDENTS Breaking concrete A lackhammer operator breaking concrele is not paying attention lo what he is doino and iackham:'ners his foot. Unforlunately, he is wearing tennis shoes instead of the steei-toed shoes ihe company requires. He lacerates his foot, breaks his toe, and loses several weeks of work. Building a wooden box An'employee building a wooden box steps backward onto a nail which protruded from a board and loses 10 days work is a result of the puncture wound to his foot. This is the second time in the last 2 months the company experiences incidenls involving foot punctures. Both accidents involve employees who were on the job six months or less. Repairing a ceiling-hung reel The reel is hung f rom a 2x4 covered by a suspended ceiling at an automobile dealership. In order to repair the reel, ihe service tech walks oul on the 2x4 framing. As he reaches to unbolt the reel he loses his balance and falls through the ceiling. Fortunately, he is able lo grab a2x4 and pull himself back up. The alternative was a 14-foot fallto the cement. Testing pumps and dispensers A crew bleeds the pressure off the product lines (or so they think) at a new tank installation and begins to prepare the leak detectors for installation. They dope up the first detector and pull lhe two- inch plug off the submersible. Product blows out the 2-inch opening and gasoline soaks both employeLs working in the area. The workmen strip off the clothes they are wearing and wash under a nearby water hose. No fire or explosion results. Procedures now call for pulling the submersible pump completely to drain the product from it before installing leak detectors. Repairing a card lock system with a defective flow switch A mechanic called to repair a defective flow switch at a card lock system shuts off the power at the breaker panel, removes the pump panels, and barricades the area surrounding the pump. A friend of the operator comes to the station for product. He goes into the pump control room, turns on the power at the breaker, and somehow tinds his way around the barricade. As he starts the pump, fuel sprays from the flow swrtch opening. Fortunately, the incident does not cause a fire, Procedures now call ior locking lhe breaker out, locking the pump handle, and plugging the hole from which the flow switch is removed. 94 EXHIBIT 2.4 (con.) GENERAL SITE ACCIDENTS Repairing a faulty petroleum pump A man repairing a faulty pump is working on the hydraulics and electricai components at the same time. A spark irom a shorted wire ignrtes the vapors in lhe test can, causing it to explode. He dies later fhat evening as a result of burns suffered in the blast. Ladder accident A warehouse employee is standing on ladder while transferring 6O-pound boxes from lhe top of a raised forklift to a storage shelf. One of the boxes catches on a rail at the top of the shelf. While struggling lo free the box, the latter starts to tip, causing him to lose his footing. The employee falls appiolimltely 5 feet to the ground, landing on his left hand. He is taken to an area hospital where x- rays revealed a fracture of his lett wrist. Surgery is required to repair the damaged ioint. Several pins remain in the wrist for 8 weeks, and extensive physical therapy is necessary in order for the employee to regain the function of his wrist and hand. The employee is off work 16 weeks. Disconnecting equipment from a truck. A man disconnects a portable air compressor from a truck and forgels to lower the wheel stand on the compressor before disconnecting it from the truck bumper. As he raises the compressor and moves tt away lrom the truck bumper, he loses his balance. The tongue of the compressor chassis drops to the ground and crushes his finger under the hitch. He is off work 5 weeks. Working inside a sump An employee is working inside a piping sump at a convenience store that has iust been built. The manhole lid and sump cover were removed, and an orange lraffic cone was placed adiacent to the hole. As a salesman drives out of the parking lot, he first drives over lhe traffic cone and then over the manhole where the emproyee was working. The salesman stops his car only because the traffic cone became wedged in the undercarriage of his vehicle. The mechanic is low enough in the sump to escape injury. New procedures call for parking a service truck in such a way as to protect the workers from traffic, whether employees are working in an open or closed slation' 95 COMMONLY USED HEAVY EOUIPMENT Installing or moving USTs requires the use of a variety of earth-moving and other heavy equipment. Examples of such equipment include backhoes, front end loaders, dump trucks, cranes, and drill rigs. Any one of these pieces of equipment can be dangerous and €n cause injury or death. Some examples of accidents associated wilh the use of heavy equipment are described in Exhibit 2-3. NOTES SAFETY PRECAUTIONS AROUND HEAVY EOUIPMENT To avoid creating unnecessary hazards, operators of heavy equipment should be properly trained and certified to operate equipment they are using. Vehicles should be parked far enough away from other vehicles and equipment to avoid possible collisions. Stacked pipes can pose a serious construction hazard. Personnel should avoid standing near stacked piping because a single dislodged pipe may cause the entire stack to collapse. Individuals with long hair should have it tied back or otherwise constrained. Applicable protective gear such as hard hats, goggles, high visibility clothing, hearing proteclors, and heavy boots should be wom at all limes. Shirts with loose sleeves, trousers with baggy cuffs, torn clothing, and jewelry have a lendency to get caught in machinery and, therefore. should not be worn. NOTES 82 k ADDITIONAL GENERAL SAFEW PRECAUTIONS Many heavy equipment accidents result when workers touch the moving parts of the machinery. Personnel must pay close attenlion when operating or working near machinery. Furthermore, personnel must be aware of the location of "Emergency Shut Off" switches on the machinery to avoid serious accidents. Do not smoke or use spark-producino equipment around excavations because the use of a backhoe or a drill rio mav release flammable qasses from the subsurface environment. There is also the potential of a backhoe or drill rig coming into contact with buried gas, water, electric, sewer, or product lines and even the USTs themselves. This can cause sudden explosions, electrocution, or f looding. Therefore, all lines should be located and clearly marked prior to initiating operations. An additional electroculion hazard can occur during periods of lightning, as the lightning may be attracted to backhoes or crane booms. All operalions should be stopped during a thunderslorm. Many pieces of diesel equipment are not killed by turning off the key. There is typically a fuel shutoff knob that must be pulled, and, in some cases, held, to kill the engine. lf there is a high concentration of flammable vapor in the air, il may be impossible to shut off a diesel engine. (This is very rare.) Older equipment may start while in gear. Do not stand near the equipment when it is being started. 83 frr:l BACKHOE/FRONT END LOADER HAZARDS Earth moving equipment posing the greatest danger includes backhoes and front end loaders. These machines are generally used for excavating trenches and soil transfer during installation and removal actions. During excavation and soil transfer, backhoes and front end loaders can dig up or break utility or product lines. This can result in death due to electrocution, exposure to toxic chemicals, or flooding. Additionally, operation of this equipment creales physical hazards to those not aware of its presence or operation. The backhoe arm travels from side to side. as well as lengthwise and up and down. Be sure to stand well away from the entire radius of the arm swing. Backhoes are equipped with outriggers, which help stabilize it during digging. No digging or moving of earth usinq the arm should be performed without setting the outriggers. Backhodfront-end loader hybrids are common. The front bucket of these hybrids is operated wrthout the use of outriggers. NOTES DRILL RIGS Drill rigs may be of the mud rotary or the air rotary types. Note lhat using an air rotary drill ,vill increase the likelihood of exoosure via inhalation, while a mud rotary drill will increase the potential for dermal absorption of chemicals. Mud rotary rigs may also pose a disposal oroblem. The muds used often conlain traces of barium and other metals which are toxic. EPA has begun to view drilling muds with a crttical eye. Air rotary drills have a number of high pressure hoses that might break and cause inlury. The rotating parts of either type of drill rig can sever a digit or limb. Furthermore, digging into lhe ground always raises the possibility of electrocution from broken utility lines. Unless wearing the proper protective equipment (see Section 3), avoid contact wrth cuttings, drilling liquids, and groundwater because they may be contaminated. NOTES 86 , ,,,' ,,,,,,.',. , .,,,,,.,,", , '. CRANE$:,:{con;) Place trook directly over load being lifted. Major hazard; ke€p minimum 6feet between boom,and,overhead pgwer:,linee- When operating under power lines, safety guard,instalbtion ls recommended Cranes should be operated only by tratned personnel. Before daily operations start, all equipment used for hoistrng. including cables, sheaves, pulleys. boom and hook stops. shouid be inspected. A standard set of operattng signais should be agreed upon before crane operation. and UST inspectors should become famtliar with them. Only one individual should be permitted to give signals to the crane operator. Personnel should never ride along with loads carried by the crane and crane operalors should not swing a load over the heads of other workers around lhe constructton site. ln order to reduce strain on lhe crane and to prevent the sliding of loads. the crane hook should be directly over the load being lifted. Workers should use cables or rods to posilion suspended tanks. They should not stand undernealh tanks and use their hands and bodies to adjust the tank's position, or to guide il. Another serious potential hazard involving cranes is electrocution through contact with a hanging power iine. Operators should maintatn a minimum distance of 6 feet betweerl the crane's boom and power lines. In order to avoiO possible electrocution. qround personnei must refrain from touchino the crane if it comes in contact with a oower ltne. Operators in cabbed equipment should remain in the cab if they come in contact with a live power line, sit still, and avoid touching the cab controls and all metal surfaces. Installation of a safety guard is also recommended when working beneath power lines. The safety guard, which can consist of an insulated section of the upper boom or an insulated lifting hook, will help to protect both the crane operator and ground personnel. It should be noted that electrocutlon can result from more than just conlact wilh power lines. Durino hiqh humiditv conditions. an eleclrical arc can iump several feet from a Dower line to a crane. OTHER GENERAL SAFETY HAZARDS Besides the specific heavy equipment hazards, UST operations also pose a number of general construction hazards. The maiority of general construclion accidents are small ones. While not fatal, these accidents are responsible for large amounts of lost work time, personal trauma, and costly medical claims. Iniuries due to falls or trips are common, as are puncture wounds, cuts, and abrasions caused by careless use of tools. UST inspectors must be aware that injuries can occur anywhere and at any time. They need to prepare for such eventualities and remain constantlv alert while on the job site. Guidance for the control of general construction hazards can be found in OSHA regulations (29 CFR 1910), which stipulate detailed requirements for the use, storage, and maintenance of equipment and tools. Some examples of generai construction type accidents are described in Exhibit 2-4. NOTES D(POSURE SOUTES t o O lr$alalbn, Sldn,:Absorption lngeslRm,.,. EXPOSURE ROUTES There are a number of general symptoms which resutt from toxic exposure lo most of the compounds found at petroleum UST sttes. These symptoms include irritation of the eyes, mucous membrane and respiratory tract as well as depression or excitation of the central nervous system. Petroleum products generally enter the body through inhalation of vapors, absorptton lskin or eye contact), or ingestion. Of these three roules, inhalation is the quickest and most efficient roule into the body. The adverse affects of inhalation of toxins can be almost instantaneous because lhe lunos quicklv transfer lhe toxin into the bloodstream. The toxic effect will be proportional to the concenlration of the toxin, its toxicity, and the individual's sensitivily to the toxin. The symptoms of inhalation can be vague. Headaches, nausea, dizziness, insomnta, and tremors should not be overlooked. Exposure via ingestion of conlaminated water is generally limited, as petroleum in water can be detected by most people in levels as low as 1 ppm. Visual and olfactory clues as well as site safety screening instrumenls should be used to assess exposure hazards. Visual cues include seeing stained soils, vapors, or iridescence in water. Vapors from petroleum products can be smelled when they are at levels far below those considered toxic to humans. However. UST insoectors should not relv solelv on their senses to detect loxic levels of vaoors. pariicularly since noses become desensitized to some odors after prolonged exposure. Otfactory sensitivity also decreases with age' Table 2-8 summarizes the various types of petroleum products and their exposure potentials, exposure target organs and acute and chronic symptoms. Each of these areas discussed in detail throughout this section. TYPES OF EXPOSURE An insoector can face either chronic or acute exposure at a site. Chronic is defined as long-term, low-level exposure, while acute ts defined as short-term, high-level exposure. Both are dangerous and have immediate and long-term health implications. UST-associated work can also expose workers to multiple chemicals which may have synergistic effects. This means that the effect of lwo chemicals together may be greater than the sum of their separate effects. All exposures should be kept as low as reasonablY achievable. Many materials stored in USTs are very common, and manY have very low acute toxicity. However, the exposures of the UST inspector are more frequent, of longer duration' and higher than those of the average person. It is this repeated, low-level exposure that is so dangerous, as effects may not be seen for many years. Avoiding unnecessary exposure now can help you enjoy your later years, instead of combatting a chronic illness. Most exposure can be eliminated if common clues, such as strong odors and instrument readings, are heeded. NOTES A TV|TIES fIAVING TOXIC E)(POSURE POTENfiAI. Relsa$e rirwestigationslcorrecl$ve actbns pelroleurn product and vapors . HaS:in sewers rub** and terrnrticides in bassments ln-place tank cloeure . , ,tdBuru, product, and slrdges Tanl#pipe repai r/removal . ,,froduct and vaPors . , ,"coaling" chembals and petroleum r-eat,,,u*lcbn testing ' ,..,., .p UOt ard Vapors GEI{ERAL::,SYiIPTOMS OF TOXIC EXPOBURE TOXTCITY OF GASOLINE CONSTITUENTS All petroleum products share the characteristic of causing central nervous system depression. The early symptoms of acute over-exposure can include dizziness, drowsiness, impaired coordination, nausea, euphoria, convulsions, coma, and death, in high enough doses. The primary route of exposure for these products is inhalation. lf the products are ingested, do not induce vomiting, since the product may be aspirated into the lung easily. Activated charcoal, followed by "stomach pumping," is the preferred treatment. Skin contact is not typically an immediate hazard. Prolonged contact will cause burning and blistering. Repeated exposures to skin will resull in defatting and possible dermatrtis. ALKANES Hexane may be the most toxic member of the alkanes. lt comprises 11 to 13 percent of gasoline by weight. Acute exposure lo hexane occurs primarily through inhalation. Vertioo, headaches and nausea are the first svmptoms of exDosure to be noticed. Al high concentrations, central nervous system (CNS) depression resutts in a narcosis-like state. Pre-narcotic symptoms occur al vapor concentrations of 1,500 to 2,500 ppm as the cenlral nervous system is depressed. Skin contact primarily causes fat removal and irritation. Hexane also irritates the eyes and mucous membranes wilh even a fairly short- term exposure, for example. 880 ppm for '15 minutes. Chronic exposure to hexane vapors causes nerve damage. The first clinical siqn of nerve damaoe is a feeling of numbness in the toes and finqers. Further exposure leads to increased numbness in the extremilies and to loss of muscular stretching reflexes. Paralysis develops wiih varying degrees of impaired grasping and walking. ln the most severe cases nerve conduciivity is neutralized and cranial nerve involvement is also observed and may require several years to recover. In mib or moderate cases, recovery begins six to 12 months after exPosure ceases. Octane, if it is taken into the lungs, may cause rapid death due to cardiac arrest' respiratory paralysis, and asphyxia. lt has a narcotic potency similar to heptane. Prolonged skin contact results in a blistering and burning effect. 118 Acnde Exposure '.'. i ,aentral r rous,sypfern e*fects TOXICITY OF AROMATICS It is almost impossible to assign a fuel product's acute effects to any given component, since they all have similar actions. Worrying about air concenlralions of specific components is not practical. We typically look at tolal organics. Benzene is found at concentrations up to 4 percent by weight in gasoline. Older gasolines may contain as much as 13 to '15 percent benzene. Acute exposure will depress the central nervous system (CNS) and may cause acute narcotic reactions. The lowest observed threshold for acute exposures is 25 ppm. Headaches, lassitude, and dizziness may become increasingly evident at exposures between 50-250 ppm. Concentrations of 3,000 to 7,500 ppm may result in toxic signs within the hour. Deoendino on the concenlrations and duration of exposure. these effects ranoe from mild svmptoms such as headaches and liqht-headedness lo more severe effecls such as convulsions. resoiratory paralvsis. and death. Skin absorption is not considered to be as important a route of entry as inhalalion or ingestion because skin absorption is extremely low, with the highest absorption through the palm. Direct contacl with the liquid may cause redness and dermatitis. ' nraycagge.,,d€rrglitis,rvertigo,,:headache, :nausea, gnd vqmi{in$ .:". Chronic Exposure **ne. .i$...a,careihogen, li:nked to leukernid,i,,,,, : .:l::.: incrmsed ridk of,kidney calrcer and lyrnphona j':', .nefve,dartage, pOesible:paralysis :,,,: ,, " NOTES 120 TOXICITY: AROMATICS (con.) Benzene is a known carcinooen. Chronic exposure to benzene has been linked to leukemia and irreversible chromosome damage. At the early stages, reversible leukemia, anemia, or a decrease in the blood platelet count may occur. Continued exposure leads to severe bone marrow damage, which resulls in a deficiency of all cellular elements of the blood. The direct, life-threatening conseouence of this is an increased susceptibility to infection and hemorrhaging. The lowest air levels of benzene capable of producinq these effects are in lhe ranqe of 40 lo 50 pom. Effects of hioh exposure levels (>100 ppm) mav persist for manv vears after exposure has been discontinued. The most important effecl resulting from chronic benzene exposure is its hematotoxicity. the targets being the cells of the bone marrow. UST workers mav be exoosed to as much as 10 ppm in tl'reir evervdav activities. Toluene is found in concentrations of up to 4 to 7 percent in gasoline. The primary hazard of acute inhalation exposure is CNS depression. Reaction times will begin to be impaired after exposures of 20 minutes at 300 ppm. Toluene will also cause eye irrttation, and prolonged or repeated skin contact may cause dermatitis. As concentralions increase, symptoms can include: muscular fatigue, confusion, tingling skin, euphoria, headache, dizziness, lacrimation, dilated pupils, eye irrrtation, nausea, insomnia, nervousness, and impaired reaction time. Occupational exposure to loluene has been linked to a higher reported incidence of menstrual disorders. Children born to lhese women may experience more frequent fetal asphyxia and be underweight. Xylenes are found in concentrations of 6 to 8 percent in gasoline. Short-lerm inhalation exposures are associated with narcotic effects on the cenlral nervous system, and high concentrations may lead to CNS depression. Both liquids and vapors are irritating to the skin, eyes, and mucous membranes. Skin absorption of xylenes occurs readily and rylenes can also be transferred across lhe placenta. Incomplete brain development has been reported in the fetuses NOTES of mothers exposed lo rylene. Chronic, high- level human inhalation exposure results primarily in CNS effects, lack of coordination, nausea, vomiting, and abdominal pain. There are variable effects on the liver, kidneys, and gastro-intestinal tract. Chronic effects of xylenes resemble the acute effecls bul are more severe. They include headache, initability, fatigue, digestive and sleep disorders, CNS excitation followed by depression, tremors, apprehension, impaired memory, weakness, vertigo, and anorexia. Xylenes are skin irritants and prolonged contact may cause formation of blisters. Ethylbenzene is known to be toxic to the liver and kidneys. lt will irrilate the skin, eyes, and upper respiratory tract. Inhalation of small amounls may exacerbate the symptoms of obstructive airway diseases and cause efiensrve fluid buildup and hemorrhaging of lung tissue. Although a tolerance to the eye and respiratory effecls may develop after a few minutes, CNS effects will usually begin at this stage, leading to CNS depression. 121 fetrametnyl ard tetraelhyl lead {TML, and fEL},,,,., Ethytane dituomkte iibel arro ,im1" Tri-ortho-cresyl-phospfrate ffOC B TOXICITY OF ADDITIVES Gasoline often contains substances that have been added to improve the fuel's performance properties. Gasoline additives of general concern for leaded gasolines are tetramethyl lead (TML) and tetraethyl lead (TEL), as well as ethylene dibromide (EDB) and ethylene dichloride (EDC). Both TML and TEL are used as anti-knock agents; EDB and EDC are used to prevent lead deposition. These compounds are present in low concentrations in gasoline (relative to benzene, toluene, and xylene), but they are quite toxic. TML and TEL can be absorbed through the skin, ingested, or inhaled. TEL intoxication is caused by inhalation or absorption through the skin. Acute intoxication can occur through absorption of a sufficient quantity of TEL either through brief exposure at a very high rate (100 mg/m3 for t hour) or for prolonged periods at lower concentrations. Exposure can cause acule intoxication. liver and thymus damage, and possibly death from a combination of depression of the central nervous system, respiratory irritation, and bronchiolar obstruction. Most severe exposure to TEL and TML have resulted from sniffing gasoline. Some victims have shown the symptoms listed as wellas fluid buildup in the brain, resulting in swelling and increased inlracranial pressure. The signs and symptoms of exposure are often vague and easily missed. The onset of NOTES be delaved uP to 8 anorexia, insomnia, and weight loss. As intoxication worsens, there is confusion, delirium, manic excitement' and catatonia' Nightmares, anxiety, and anorexia are also seen. Loss of consciousness and death may follow after several days' Severe intoxication causes recurrent or conlinuous episodes of disorientation and intense hyperaclivity which may rapidly convert to convulsions that may lerminate in coma or death. TEL is likely to have adverse effects on human reproduction and embryonic develoPment. after exposure and include weakness, fatigue, headache, nausea, vomiling, diarrhea. Svmptoms oeculiar to TEL exposur.e .are. the sensation of hairs in th@ 123 GASOLINE ADDITIVES: ACUTE EXPOSURE Acute exposure to gasoline additives is a serious heatth threat. In general, brief exposure to additives (100 mg/m3 for t houQ can cause acute intoxication and depress the central nervous system. Svmptoms include insomnia. confusion, headaches, and tremors. and mav be delaved for up to 8 davs. Specifically, bolh EDB and EDC are highly toxic and klentified as carcinogenic, atthough EDC has a much lower potency. Acute exoosure also causes vomitino. diarrhea. abdominal oain and. in some cases. luno damaqe. The vapor is irritating to the eyes and mtrcous membranes and may cause liver, kidney, and lung damage, including delayed pulmonary lesions. The liquid form is highly initable lo the skin, causing redness and blistering. Death has occurred following ingestion of 4.5 ml. Recent studies by NIOSH have shown adverse reproductive effects in men. GASOLINE ADDITIVES: CHRONIC EXPOSURE Chronic exposure to additives has equally serious health effects. In general, chronic human exposure is associated with adverse effects on the central nervous system, peripheral nerves, kidneys, and vascular system. Adverse effecls are also likely on the human reproductive system and embryonic development. Svmotons_elclhleoie_exBosure include weiqht loss, anemia, emotional instabilitv. and toxic psvchosis. Recovery may take months to years, and 25 lo 30 percent of cases never recover. TOXICITY OF MIDDLE DISTILLATES The middle distillates include kerosene, aviation fuels, diesel fuels, and Fuel Oil Nos. 1 and 2. They are referred to as the middle distillates because of the similarity in lheir degree of volatility during the distillalion process. They can be taken intc the body by ingestion, absorption, or inhalation. Kerosene has the least amount of aromatic hydrocarbons of the middle distillate fuels, with benzenes, indanes, and naphthalenes being the major aromatic components. Kerosene and related hydrocarbons are irritating to the skin and mucous membranes, and skin absorotion mav be sionificant. Jet and aviation fuels are mixtures of distillate hydrocarbons that vary in composition from those similar to motor gasoline to kerosene- based fuels used in commercial aircraft. Jet fuels contain additives such as anlioxidanls, metal deactivators, and de-icing agents. Dieselfuels contain high amounts of naphthalenes, acenaphthalenes, phenanthrenes, and anthracenes. Dermal exposure to diesel oil is toxic to the kklnevs. Generally, No. 2 fuel oil (healing oil) contains a higher volume percentage of benzenes and naphthalenes compared lo kerosene and dieselfuels. Polyn uclear Aromalic Hydrocarbons (PAHs) are present in higher concentrations in middle distillate fuels than in gasoline, but less than in the residual fuels. Specific PAHs detected in the middle dislillates inciude naphthalene, benzo(a)anthracene, and benzo(a)pyrene. Benzo(a)anthracene and benzo(a)pyrene are known to be very carcinogenic (cancer- causing). PAHs have been shown to cause cytotoxicity in rapidly proliferating cells throughout lhe body, apparently inhibiting DNA repair. Cytotoxicity causes changes in the cytoplasm of the cell. The vascular system' lymphoid system, and lestes are frequently noted as targets of PAHs. No information about the carcinogenicity of middle distillates in humans is available. However, several members of the middle distillate family, in particular Fuel Oil No' 2 and diesel, ha ;een shown to be weak to moderate carcinogens in animals. Teratogenic compounds affect fetal development. No teratogenic effects have been observed in animal tests using kerosene, dieselfuel, and Fuel Oil No. 2. The chief systemic reaction to the middle distillates is depression of lhe central nervous system. Effects of exposure are exoected to resemble those of kerosene, that is. low orgL moderate dermal, and hioh inhalation hazard. Svmotoms include irritation to the skin and mucous membranes as well as headaches and nausea. 127 MIDDLE DISTILLATE FUELS: SYMPTOMS OF ACUTE EXPOSURE Acute exposure to middle distillate fuels can lead to headaches. nausea. mental confusion. and irrrtation of the respiratorv svstem. Further exposure can cause hemoiytic anemia and cardiovascular disturbances; in some extreme cases, loss of consciousness can occur. The compounds in the middle distillate fuels that are most likely to be of toxicological concern are non-carcinogenic PAHs, such as naphlhalene; the carcinogenic PAHs, benzo(a)- anthracene and benzo(a)-pyrene; and cresols and phenols. Ingestion or inhalation of naphthalene produces nausea, vomiting and disorientation. It is initating to the skin and eyes and may cause cataracts. Benzo(a)-anthracene and benzo(a)-pyrene have been detected in Fuel Oil No. 2 and have been classified as probable human carcinogens. Cresols are highly irritating to the skin, mucous membranes and eyes. They can impair liver and kidney funclion and cause central nervous syslem and cardiovascular disturlcances. Phenol is toxic to the liver and kidneys. Several of the components of gasoline are also found in the middle distillate fuels. For example, toluene, rylenes, and ethylbenzene are found in the middle distillates, atthough in much lower concentrations than in gasoline. Octane on the other hand, is present at much higher concenlrations in aviation fuels than in motor gasoline. Additionally, a number of other substances may be found in the middle fractions of petroleum derivatives. These are not covered in this course due to their numbers and complexity. These include components of jet fuel as well as iet and dieselfuel additives, such as Dodecane, Methylcyclopentane, N,N- Dimethytformamide, Manganese Compounds, peroxides, and Alkyl Nilrate and NitratdNilro and Nitroso compounds. MIDDLE DISTILLATE FUELS: IMPACTS OF CHRONIC EXPOSURE Chronic exposure to middle dislillate fuels causes neuroloqical effects. One study of aircraft workers consistently exposed to aviation fuel found that a maiority experienced recurrent symptoms such as dizziness, headaches, and nausea. Feelings of suffocation, coughs, and palpilalions were also prevalent. Inhalation of high concenlrations of these vapors can lead lo an acute and often fatal bronchopneumonia. NOTES 131 TOXICITY OF RESIDUAL FUEL OILS Fuel Oils Nos. 4, 5, and 6 are commonly referred to as the residual fuels. They are very vtscous and have low waler solubilities. Residual fuels are blends of predominately high molecular weight compounds and tend to have a higher concentralion of PAHs than gasoline and middle distillates. These luels often contain blending agents including cracked bunker fuel and catalytically cracked clarified oil. Both of these blendino aqents have been classilied as animal carcinooens.. Catalytically cracked clarified oil is recognized as one of the most carcinogenic materials in a petroleum refinery. Acute oral effects of exposure to Fuel Oil No. 6 in animals include lethargy, congestion of liver and kidneys, and intestinal irritation. The heaw metals arsenic. lead, and zinc have been detected in samples of Fuel Oil Nos. 4 and 6. TOXICITY OF USED OILS Used oils are the byproduct of using oil as a lubricant. Through this use, the oils pick up a number of subslances, such as lead, chromium, cadmium, and chlorinated solvents which are hazardous to human health. Analysis also indicates that PCBs contaminate 18 percent of used oils. Automotive used oils tend to have a higher concentration of heavy metals, while industrial used oils tend to have a higher concentralion of chlorinated solvents and PCBs. No differences in the concentralion of aromatic solvenls or PAHs were found' -':I .,",,:.i::., tl.... !:: Heaw metals tvpicallv found in used oil include: . Lead Pre-1980 stock up 1980s stock 100 . Barium . Cadmium . Chromium . Arsenic . Zinc Other contaminants include: . Toluene and xylene . Benzene . Benzo(a)pyrene and benzo(a)anthracene . Naphthalene . Dichlorodifluoromethane . Trichlorotrifluoroethane . 1 .1 .1-Trichloroethane Trichloroethylene <1 to 40,000 ppm Tetrachloroethylene Chlorinated solvents commonlv delected in used oil include: TOXICIW: USED OlLs 20,000 PPm 1,200 ppm 50 to 500 PPm (4'000 PPm) 2 to 10 PPm 3 to 30 PPm 5 to 25 ppm 100 to 1,220 PPm 500 to 10,000 PPm 100 to 300 PPm 50 to 1,000 PPm 100 to 1 ,400 PPm <'l to 2,200 PPm <20 to 550,000 PPm <1 to 110,000 PPm <1 to 32,000 PPm E lE $;=4"€.6 sS Eec o oo a eE:Ci =gE;EFr > Y O.= oF OE€EFtr i !a=:> o ; E$EgEEE E- trH-E9Hr I: !;P=3HE € tq!;B:*EsesHgEfi-$8;E€B$ sfi€5d5{:.;Ee5z ,sp-€E:i 9 - qx :=E;Y->E !x ..* s ;o69c * i *E $-6 _-; ! 0 AH EF 8 i E€ * r 1dE;E:eea: & '6 x(5 6! 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Ur'' I rr ii frl J ^r) Frr ^J X o!r' ='4, E>. 2, X(EuJ o- d= 9.0xoLrJ o- o (! o {, o C ; [rJz.ul:< J od @ tl-l -.ZY._< ts-x JO<I o n-9 Egg isEag: i s 5*€ EE ;EEa$gt ;i:i*g E;s!=c$g.E I 4= 9E-_:O Fj g; if E l1r fr3ffcgs= ;;gE3=ssgst6$;e E 5:a ,8. -I .€Eg;;Bte€E;*e:€Ei iss;igEesg€gEEiiEY i € .6 -= ';v >^- tuIo: 6: ZA gsggciEEEg*iEi (U o oco-o _-oP> oo c> 46 - _E F$*B rgE€ E AE F ;; Eg s"3 =:8 -- e.u eE*1*€ :€ qE si*;F;g "*F" s5! ='==qaE!p ...F ;=E ;E:;;l; *HgtEEi !eaHEsE:gEggp€I o Eo E a 5c e : s ;aigg-9 6, 9. .,u |- irl 'J- lr rrl I ^i\ !rr I orX 'J !J ^l-'..- i-a z (t cF.o €E-Fp€4 . F.E €EFs€4 c !.o €5-F !l.g )t9't a!:< g> 2=XC X(Eul o- jF XOur o- ()--9 o'- Y(! ;5 d o9 6= ::i lA o9 :o:-E o o.o Fg=: ?c= FO= ^: @ ?#F CHEMICAL HAZARDS REOUIRING MONITORING As stated earlier, toxic substances enter the body via the skin, ingestion or inhalation. Of these three roules, inhalation is the quickest and most efficient route into the body. The adverse effects produced by inhalation of a toxic substance can be almost instantaneous because the lungs efficiently and rapidly transfer the inhaled substances to the bloodsiream, which distributes it to all parts of the body. The toxic effect will be proportional to the concentration of the toxin in the air, its toxicity, and an individuals' sensitivity to the toxin. More detailed information on specific toxicity hazards may be found in the section on toxicity in this manual. The objective of this section is to introduce various monitoring instruments which can warn inspectors of some of the major chemical hazards they might face such as airborne toxic substances, orygen deficient atmospheres, combustible gases/vapors, and hydrogen sulfide. These can appear during product handling, transfer or release, or while working in confined spaces. NOTES 199 MONITORING INSTRUMENTS The major chemical hazards faced by UST inspectors can be measured by Direct Reading Instruments (DRls) or Compound Specific Detectors. The most commonly used inslruments are Direcl Reading Instrumenls which can effectively detect both inorganic and organic vapors, orygen deficient atmospheres, explosive atmospheres, and specific compounds such as hydrogen sulfides. Most DRls respond to many different substances. This characteristic is desirable because il allows for fast idenlification of dangerous situations, yet information about specific su[stances often cannot be determined directly. All DRls have inherenl constraints in lheir ability to detect hazards: . They usually detect ancl/or measure only specific classes of chemicals. . They are generally not designed to measure and/or delect airborne concentrations below the 1 ppm level. . Many of the DRls that have been designed to detect one padicular substance also detect other substances (thal is, they are prone to interferences) and may give false readings. For example, some hydrogen cyanide gas DRls, if installed backwards will change color in lhe presence of acetic acid. 200 INSTRUMENT CERTIFICATION Explosion hazards are a major concern at UST sites; instruments used by UST inspectors must not contribute to the hazard by being potential sources of ignilion. A number of engineering, insurance, and safety organizations have established delinitions and developed codes for testing electrical devices used in hazardous situations. The National Fire Protection Association publishes the National Electrical Code (NEC) every three years. Underwriters Laboralories, Factory Mutual, and the Mine Health and Safety Administration conduct tests to certify that monitoring instruments meet the minimum standards of acceptance set by the NEC. An electrical instrument certified for use in hazardous locations under one of these test methods, will carry a permanently affixed plate. This plate will show the logo of the laboratory that granted the certification and the Class(es), Division(s), and Group(s) the instrument was tested against. lf an instrumenl does nol have an approved rating, it should not be used in a hazardous or potentially hazardous situation. NOTES 202 , nrt*UM ENT CERTIFICATION'{con:} The instrument certification categories included are divided into classes, divisions, and groups. There are lwo classes covering 'potenttally flammable gasivapor" and "potentially explosive dust." There are two divisions including "explosive conditions exist routinely" and "explosive conditions extst only afier an uninlentional release." And finally, there are six groups divided according to specific compounds such as acetylene, hydrogen and similar gases, and others. The cateqortes of instruments most likelv to be encountered at UST sites are approved for Class 1 , Division 1. Groups A. B, C, and D. Because of the wide variability of compounds that can be encountered at an UST site, instruments are more typically certified for multigroups of substances. This affords the widest applicabilitY Possible. DIRECT READING,:,:IIFT8UHEHTS. ..' .::::::):.:: : ,., .....',,,,' :::::r::::: .::::: Oxygen m€ler Hydtogen sulffds meter Deleclor tubes Combustible gas indietor (CGl) Flame ionization detector (FlD) Phstoionization oetector ( P lD) DIRECT READING INSTRUMENTS This course discusses six instrument types. all of whrch are Direct Reading Instrumenls. These include oxygen meters. hydrogen sulfide meters, combustible gas indicators, delectot' tubes, flame ionization detectors, and photoionization detectors. UST inspectors should be thoroughly trained in and familiar with the use and interpretation of all of these instruments. NOTES 205 OXYGEN METER The oxygen meter has three orincipal componenls: the air flow system, the oxygen sensing element, and the microamp meter. Air is drawn into the detector with an aspirator bulb or pump. The detector uses an electrochemical sensor to determine the oxygen concentration. The sensor consists of two electrodes (a sensing and a counting electrode), a housing containing the basic electrolytic solution, and a semipermeable teflon membrane. Oxygen molecules diffuse through the membrane into the solution. Reactions between lhe orygen and the electrodes produce a minute electric current which is directly proportional lo the sensor's oxygen content. The current passes through the electronic circuit and the resulting signal is shown as a needle deflection on a meter. Oxvoen measurements are mosl informative when paired with combustible qas measurement. Together they provide quick and reliable hazard data. A lower orygen reading will show a lower combustible gas reading; while a higher oxygen reading will show a higher combustible gas reading. In general, oxygen measurements should be taken before combustible gas indicator readings. NOTES 206 OXYGEN METER LIMITATIONS The use o{ an oxygen meter has limitations, since its operation depends on absolute atmospheric pressure. An oxygen meter calibrated at sea level and operated at an altitude ol several thousand feet will lalsely indicate an oxygen-de{icient almosphere. Furthermore, oxidants, such as ozone and rnterlere with detectors. Chlorine, Fl, Br, and acid gases are all potent oxidants (oxidizers). An oxvoen measurement should be paired with a combustible gas measurement in order to ensure reliabilitv. NOTES 207 HYA[@ Hydrogen sulfide indicators range from simple color change devices lo sophisticated electronic meters. With the electronic verstons, sample air is rnrroduced to the sensor by passive diffusion or active pumps through a gas-porous semlpermeable membrane. The cell electro-oxioizes the gas in proportion to the gas panral pressure rn ihe sample. The resutting electrical signal is lhen amplified to run the meler. Hydrogen sulfide gas can be fatal if inhaled in sufficiently high concentrations. UST inspectors would be most likely to encounter HrS irr selvers. The gas has a slrong "rotten egg" odor. UST inspectors should never rely on their olfactory senses as a means of determining concentralions of HrS, since the gas "deadens" the sense of smell (i.e., the olfactory neryes will adlust to and tolerate concentrations of HrS). Also, some individuals are conoenitallv unable to smeil HrS. No hvdrcoen sulfide meters are sensitive at less than 1 pom. In addition, thev are cross sensitirre to hvdrooen cvanide, therefore, thev can. in certain instances. oive misleadino readinqs. NOTES 208 C OU B U 8Tl BLg,GAS.i.l I@|C-ATOB'...(CG|) Function: mea$Ires fhmmable vapor concentratpns h air . reeulte shown as percentagr-e of blqr f arnmqlb li.tft, , , , . rrreaeure O, percentage before using CGI How it worksl, cperates on "hot wire" pl'ircip{e : :: ,,, ,,,,, : :::r::::r,:::':'':::':':':'. combustion chamber with platinum tilarnenl I , : '.'''''' ' gas combustion raises filament temparaturs, : '':' . increased tenF€rature caus€s resislor circuit "imbalarrceo COMBUSTIBLE GAS INDICATOR The Combustible Gas Indicator (CGl) or explosimeter is one of the first instruments that should be used when surveying a site. lt measures the concentrations of flammable vapors or gases in air and indicates the results as a percentage of the lower explosive limit (LEL) of the calibration gas. Before using a CGl, however, the percentage of oxygen should be measured with an orygen meter. The LEL of a combustible gas is the lowest concentration by volume in air which will explode, ignite, or burn when there is an ignition source. The UEL is the maximum concenlralion of a gas or vapor which will ignite. Above the UEL, there is insufficient oxygen for the fuel level to support combustion. Below the LEL there is insufficient fuel to support ignition. Most CGls operate on the "hot wire principle." ln th* combustion chamber there is a platinum filament that is heated. This filament is an integral part of a balanced resistor circuit called the Wheatstone Bridge. The hot filamenl combusts the gas(es) on the immediate sudace of the elemenl, thus raising the temperature of the filament. Any single gas, or mixlure of combustible gases, will cause the meter to react; the effect of this trait must be understood by the CGI operator. NOTES 209 As the lemperature of the filament increases so does the resistance. This change in resistance causes an imbalance in the Wheatstone Bridge. This is measured as the ratio of combustible vapor present compared to the total required to reach the LEL of the combuslible gas used to calibrate the CGl. lf a concentration greater than the LEL and less than the UEL is present, the meter needle will stav bevond the 1.0 (100 percent) level of the meter. This indicates thal the ambienl atmosphere is readilv combustible. When the almosphere has a gas concentralion above the UEL. the meter will rise above the 1.0 mark and then return lo zero. This occurs because the gas mixture in the combuslion cell is too rich to burn. This permits the filament to conduct a current as if the atmosphere contained no combustibles at all. For this reason. it is critical to alwavs walch lhe meter, since this raoid deflection mav oo undetected. This is not a problem with most of the newer meters equipped with an audible alarm. There is a relatively new detector system for flammables on the market now. Some detectors are using a tin oxide sensor. The tin oxide coating on the sudace of the sensor has only a limited number of electrons available for conduction of electricily. Oxygen, which is highly electronegative, tends to gain electrons. Normal oxygen conlent will pull most of the electrons away from the tin oxide, reducing its ability to conduct electricity (high resistance). As concentrations of a flammable gas increase, oxygen "lurns away" from the tin oxide to interact with the flammable compounds. The newly freed electrons can now flow, and resistance drops. The resistance changes are calibrated to be proportional to a specific flammable gas. This technology can also be used to detect non-flammable vapors as well. Pros and cons of this lechnology are not yet fully field{ested, but it is reasonable to assume that varying oxygen concentrations can cause ambiguous readings, and that cross- sensilivities exist. The sensor is reported to be poisoned by halogenated gases. COMBUSTIBLE GAs INDICATOR (con.) NOTES- 210 COMBUSTIBLE GAS INDICATOR LIMITATIONS There are limitations to the use of a combustible gas indicator. As mentioned previously, the needle of the indicator must be watched conlinuouslv because a readino above UEL will return to zero. For a more accurate measure of combustible gases, readings should be taken at ground, waist, and overhead positions to insure detection of vapors whose densities are greater or less than air. The following substances may "poison" the detection filaments: fuming acids, leaded oasolines, silicones, silicates and other silicon containing compounds. When it is suspected that these substances have been aspirated, the CGI should be checked with a calibration kit; if leaded gasolines are anticipated, additionalfilaments should be on hand. There are also catalytic filters available for use with leaded gasolines. The instrument should not be switched Or/Off unless it is known that you are in a combuslion free environment. The CGI reads only from 0 to 100 percent of the calibration gas, often either methane or propane. Therefore, when another combustible gas is detected, the exact meter reading is not correct and cannot be relied upon. To provide additional safety factors, field crews should discontinue operations where combustible gas is measured above 25 percent of the LEL for a melhane or propane calibrated \/\:t. DETECTOR TUBES Detector tubes (also known as calorimetric and indicator tubes) measure levels of petroleum and other gases. They are small glass tubes filled with a solid absorbent and impregnated with detecting chemicals. Air is drawn through the tube at a controlled rate, and airborne contaminants will change the color of the detecting chemicals. The intensity of the color change is taken as an index of the contaminant concentration. Because specific tubes exist for the detection of hydrocarbons and olher petroleum product constituents, !!g can be effectivelv used at UST sites as a screenino tool, but thev are not very accurate. There are lwo basic types of detector lubes: . Slain length . Color density Stain length tubes are graduated, and the lenqth of the color change is proporlionalto concentration. Stain length tubes are more convenient. One limitation of detector tubes is that thgir accr:racv is limited to within 25 o,erce,nt of tne true concentration ol the conta{ninafl' Furthermore, some gases can interfere with the reading. lt is a relatively slower and more tedious approach to measuring contaminants than some other instruments. The color or stain must be evaluated immediately, as many colors fade rapidly. Finally' wilh some tubes, the air flow must be in one direction only; this is typically indicated by an anow or a dot' This type of tube usually contains a drying agent or a'precleaning layer ahead of the indicating chemical, to remove interlerinq gases or vapors, or an oxidizing layer which releases a certain part of the vapor test molecule which reacts with the indicating chemical' 213 FLAME IONIZATION DETECTOR Flame lonization Detectors (FlDs) (sometimes called organic vapor analyzes or OVAs) are used to detect concentralions of volatile organics. An OVA consists of two major parts: (1) a 9-pound package containing the sampling pump, battery pack, support electronics, flame ionization detector, and hydrogen gas cylinder; and (2) a hand held meter/sampling probe assembly. When the sample reaches the hydrogen flame it burns and the resufting ions carry an electric current. The current is then amplified and displayed on the probe's meler. The measurement equals the total concentration of organic compounds relative to the calibration standard. The FID can operale in two different modes. In the survey mode, it can determine the approximate concentration of all delectable volatile organic chemicals in the air. The gas chromatograph (GC) mode separates and measures individual components. This is done by drawing a sample into the FID's probe which is then carried to the detector by an internal pump. NOTES 215 In the GC mode, a small sample of ambient air is injected into a chromatographic column and carried through the column by a stream of hydrogen gas. Contaminants with different chemical structures are retained on the column for different len$hs of time (known as relention times) and, hence, are detected separately by the flame ionization detector. A strip chart recorder can be used to record the retention times and peaks (concentrations), which are then compared to ihe retention times of a standard with known chemical constituents. Limilations of the OVA include the fact that it is internally calibrated by the manufacturer (usually lo methane), and therefore, does not give an exact reading for other compounds. The OVA can only detect organic compounds, however. since petroleum products are organic compounds, this poses no maior problem. The OVA needs high-quality hydrogen to operate. Hydrogen transport is regulated by the U.S. Department of Transportation. lf the OVA's hydrogen tank is empty, it can be shipped without restriction. Once on-site, however, plans have to be made for the acquisition of high quality hydrogen. Lead-acid batteries are used by the OVA and they tend to lose power in coH weather which could cause problems with on-site usage' Finally, OVA's do not detect compounds less than 1 oPm in concentration. 216 PHOTO IONIZATION DETECTOR Photoionization Detectors (PlDs) are one way to detect organic vapors. The HNu system portable photoionizer delects rcncentralions of organic gases and a few rnorganic gases. The basis for delection is the photoionization of gaseous species. The incoming gas molecules are subiected to ultraviolet radiation which ionizes a number of gaseous compounds. Each particle is changed into charged-ion pairs creating a current between two electrodes which can be read bv a meter. The HNu measures the tolal concentration of those organic (and some inorganic) vapors in air that have an ionization potentia, iess than or equal to the energy of the prooe. The HNu consisls of two modules connected via a signal-power cord; a readout unit consisting of a meter, a battery, and electronics; and a sensor unit consisting of a light source, a pump, and an ionization chamber. The photoionization detector is easier lo use than the OVA and it has a lower detection limit. The system is usually calibraled to a benzene substitute such as isobutylene and reads benzene directlv. Two other photoionization detector models are the TIP manufactured by photovac and lhe OVM manufactured by Envirotherm' These two models, unlike the HNu, have the ability to retain readings in memory which can then be down loaded into the computer at a later date' 218 The HNu syslem does have a number of limrtations. lt can be susceptible lo radio frequency interference from power lines, transformers, high voltage equipment, and radio transmissions. Also, the window of the UV lamp must be cleaned on a regular basis to insure that airborne contaminants are ionized. Finally, the HNu system also uses a lead-acid battery. These batteries lose power in cold weather and can be unreliable. Once the batteries have been severely discharged, they may no longer accept a charge and will need to be replaced. For these reasons, lhe unit should be placed on the batterv charoer after every use. The HNu charge circuil has a protector that prevents overcharging. 220 SAFETY PLAN PREPARATION UST investigations require that all operations be planned ahead of time in order lo keep problems to a minimum. Anticipatinq and preventinq ootential accidents is the best wav to protect workers and the public from iniurv. The major aspect of planning for any hazardous field activity is the development and implementation of a comprehensive safely plan that considers each specific phase of an operation. This plan identifies all potentia hazards, and specifies methods to conlrol these hazards; prescribes work praclice, engineering controls and PPE; and defines areas of responsibility. The plan describes the organizational slructure for site operations (most appropriate for use at state-lead cleanup sites) and plans for coordination with existing response organizations including the local fire marshal, police, ambulance, and emergency care facilily. The plan should be prepared by an individual knowledgeable in health and safety and at a minimum, reviewed and approved by personnel knowledgeable in industrial hygiene and health and safety. SAFETY PLAN PURPOSE The purpose of a safely plan is to provide guidelines and procedures required to assure the health and safety of those personnel working at sites. While it may be impossible to eliminate all risks associated with site work, the goal is to provide state-of{he-art precautionary and responsive measures aimed at assuring the use of proper occupational health and safety procedures for the protection of on-site personnel, the general public, and the environmenl. A written safety plan basically outlines the steps workers should follow when on-sile, and eliminates the uncertainties of memory by providing a checklist for inspectors to use when preparing to go on site. Sample checklists are provided in the aPPendix. SAFETY PLAN CONTENTS The safely plan is intended to: . Provide a systematic consideration of health and safety issues in the preparation and execution of site work and enhance the ability of team members to use their best . professional ludgement in reducing hazards. ' Describe potential hazards and soecifv applicabld guidelines, standards,'and' regulations, and appropriate emergency responses to such hazards. ' Prescribe work practices, engineering controls, and personal protection to protecl leam members. . Prescribe moniloring equipment to detect and measure potential exposures to hazardous substances. ' Prescribe guidance for changing work practices and personal prolection levels in response to changing site conditions. . Provide a list of emergency contacts. A sample safety plan is provided in lhe appendix for your information. NOTES 157 SAFETY PLAN HAZARD ASSESSMENT The most difficult and critical aspect of the safety plan is assessing all possible potential hazards that may arise. lf possible, the plan should identify all of lhe potential hazards and describe methods to control them. Safety is defined as the practical certainty that harm will not occur. A safety plan based on reliable information will reduce lhe measure of risk by preventing, or at least, minimizing human exposure to hazards. Note that exposure consists of human contact with a hazard. A hazard is defined as any substance, situation, or condition that is capable of doing harm to human health, property and/or the environment. Note that this definition does not sav that the hazards will do harm. but merelv that is has the caoabilitv to do so. The activities required to accuralely assess risks and delermine their acceptability can be divided into three interacting elemenls: . Recoonition: ldentifvinq the substances, ffins o? conditicinsihat may be hazardous and the characteristics that determine the degree of hazard. . Evalualiqn: Comparing the potential impact oTTh6-7i5k-to acceptable levels of impact or risk. . Control: Instituting methods to eliminate or EiiucAine impact-of the potential hazards' The risk associated with a potential hazard is defined as the probability of harm to human health, property or the environment' Inspectors need to plan for effective control of both physicaland heatth hazards often encountered it i.lsr facilities. Inspectors are strongly encouraged to use site-specific checklists to ensure control of potential hazards' While on-site, hazardous conditions may be in a continuous state of flux (particularly vapor- related hazards). As new monitoring results become available, inspectors should evaluate the relative risk on-site and if necessary, make adjustments in work practices or PPE' 158 HANDLING EMERGENCIES The sile specilic checklists in the safety plan should identify all nearby emergency services, including fire and rescue services, hospitals, ambulances, medivacs, police departments, public health departments, explosives experts, and hazardous materials response leams. The checklists should also include a list of emergency equipment available on-site. At a minimum, the checklists should include the following: . A list ol emergency service organizations that may be needed. Arrangements for using emergency organizations should be made prior to the initiation of site activities. Evaluate their capability to handle the sort of emergencies lhat might occur. ' A list of emergency equipment. This list should include emergency equipment available on site, as well as transportation, fire fighting and equipment to mitigate emergencies, lor example, booms and sorbents. . A list of utility company contacts, such as power, electrical, gas, and telephone. NOTES 160 SITE HEALTH AND SAFEW PLAN FOR UNDERGROUND STORAGE TANK INSPECTIONS The following is a generic site heatth ,:nd safety plan for underground storage tank inspeAions. As indicated throughout the plan, select,ij sections should only be filled out by people with technical expertise in heatth and safety issues. In addition, State organizations using this plan should set up a system ro ensure that: (1) the plan is used properly and (2) staff follow proper safety procedures. PART I part | (Sections t-lV) should be completed by the UST inspeaor prior to the site visit. SECTION I. GENERAL SITE INFORMATION SITE NAME AND ADDRESS: CONTACT PERSON AND PHONE NUMBER: SITE IDENTIFICATION NUMBER: PROPOSED DATE(S) OF S|TE WORK: SECTION II. DESCRIPTION OF INSPECTION ACTIVITY PURPOSE OF ACTIVITY: New Tank Installation Tank Closure Tank/Pipe Removal TankiPipe Disposal Petroleum Release Investigation TanWPipe Repair Leak Detection Testing Installation of Monitor Wells/Sampling PROVIDE A BRIEF NARRATIVE DESCRIPTION OF THE PROPOSED INSPECT]ON ACTIVITIES: SECTION III. SPECIFIC SITE INFORMATION SPECIFIC TANK SYSTEM INFORMATION: Age/Size/Capacity of Tanks and Piping: Contents of Tank: Other (Specify): TYPE OF SITE CHECK ALL APPROPRIATE: _Active _lnactive _lndustrial facility _Gas station _TSDF _R & D Facility _Military base _Other (Specrty) RELEASE HISTORY No evidence of leaks or soil contamination ( ) Suspected or known leaks and soil contamination ( ) Known groundwater contamination ( ) 2 BACKGROUND AND DESCRIPNON OF ANY PREVIOUS INVESTIGATIONS OR INCIDENCE: i-- BACKGROUND INFORMATION STATUS: ( )COMPLETE ()INCOMPLETE SECTION IV. POTENNAL HEALTH AND SAFEW HAZARDS ANTICIPATED PHYSICAL HAZARDS oF CONCERN: (CHECK ALL THAT APPLY AND DESCRIBE) _Heat (high ambient temp.) _Cold _ Noise _Orygen depletion _Asphyxiation _ Excavation _Cave-ins _Falls. trips, slipping _ Handling and transfer of petroleum produas _Fire Explosions _Heavy equiPment _Ptrysical injury and trauma resulting from moving machinery General construction--Physical iniury and trauma _Electrical Hazards _Confined space entry _Explosions _CIher (Spectfy) ANT1CIPATED BIOLOGICAL HAZABDS: _Snakes _ Insects Rodents (Lrsr BELOW -Poisonous Plants -Other NAFIRAT1VE:(Provide all information which could impact Heafth and Safety - €.9., power lines' integnty of dikes, terrain, etc.) ANT1CIPATED CHEMICAL HAZARDS: (UST BELOW ALL CHEMICALS PRESENT ON SITE; ATTACH MATERIAL SAFETY DATA SHEETS.MSDS) 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. PART II Section V should only be completed by persons with technical expertlse In health and safety. SECTION V. EVALUATION OF POTENTTAL HAZARDS Chemical CHEMICALS OF CONCERN Highest Observable PEU Concentraion (media) TLV Symptoms/ Effects of Acute Exposure PART III Sectlons Vl and Vll should be completed by the UST Inspector prior to the site visit. SECTION VI. METHODS TO CONTROL POTENTIAL HEALTH AND SAFEW HAZARDS MONITORING INSTRUMENTATION: (NOTE: MONITORING INSTRUMENTS MUST BE USED FOR ALL OPEMT1ONS UNLESS APPROPRIATE MTIONALE OR RESTRICT1ONS ARE PROVIDED). _Organic Vapor Analyzer _Photoionization Detector _Combustible Gas Indicator (CGl) _Oxygen Meter _Hydrogen Sulfide Meter _Detector Tubes (spectfy) -Other, specify (toxic gas, air sampling pumPs, etc.) IF MONTTORING TNSTRUMENTS ARE NOT USED, SPECIFY MT1ONALE OR JUST]FICATION OR ACTIVITY/AREA RESTRICTIONS. ACTION LEVELS (breathing zone): Combustible Gas Indicator 0 - 1O"/" LEL No Explosion Hazard 10 -25"/o LEL Potential Explosion Hazud; Notify Site Health and Safety Officer >25o/o LEL Explosion Hazard; lnterrupt Task/Evacuate ACTION Orygen <21.00k <21.0% < 19.5olo LEVELS (breathlng zone): contlnued Meter o2 o2 o2 Orygen Normal Oxygen Deficient; Notify Site Health and Safety Officer. O ygen Deficient; Interrupt Task/Evacuate Photolonlzatlon Detector Type: Specify: 11.7 ev 10.2 ev 9.8 ev Flame lonlzatlon Detector Type: Specify: Detector Tubes Specify: Type Type Type PERSONAL PROTECTIVE EQUIPMENT: List all applicable items Minimum personal protective equipment: 1. Hardhat 2. Safety glasses/goggles 3. Steel toed/shank shoes or boots 4. Flame retardant coveralls 5. Hearing protection (muffs or ear plugs) ls additional PPE reouired?YES / NO PERSONAL PROTECTIVE EQUIPMENT Check all additional necessary items: _ Uncoated tyvek coveralls Saranex tyvek coverails _Rubber boots Overboots _Surgical (inner) gloves _ Butyl/neoprenelvrtonlnitrile outer gloves _Full face resPirators type of cartridge:- -SCBA / SAR _ELSAS _Other (specify): continued VII. EMERGENCY INFORMATION Emergency Contact: Fire/Rescue: Ambulance: Police: Hazardous Waste Material Response Units Heatth and Safety Director: Poison Control Center: On-site medical facility (clinic): Facility hea,lth and safety officer: Name: Phone number: Hospital Name and Address: Directions to hospital (include a map): PART IV YES / NO YES / NO SECTION VIII. PLAN APPROVAL Plan prepared by: Plan approved by: Plan approved bY: (Date) (Date) (Dde) OXYGEN MONITORS, CGIS Afr{D SPECIFIC CIIBMICAL MONITORS I. INTRODUCTION Many hazards may be present when responding to hazardous materials spills or uncontrolled waste sites. These include oxyee@mbustible/explosive aunospheres, toxic atmospheres and radiation. There are several types of instrumentation for detecting hazardous atmospheres. This section will discuss combustible gas indicators, oxygen monitors and monitors for specific chemicals. U. OXYGEN MOMTORS Oxygen monitors are used to evaluate an atmosphere for: oxygen content for respiratory purposes. Generally, if the oxygen content decreases beloHJS*lfr, it is considered oxygen deficient and special respiratory protection is needed, increased risk of combustion. Generally, concentrations above,Z5%lre considered prygeeeruided and increase the risk of combustion, use of other instruments. Some instruments require sufficient oxygen for operation. For example, some combustible gas indicators do not give reliable results at oxygen concentrations below 10%. Also, the inherent safety approvals for instruments are for normal atmospheres and not for oxygen-enriched ones, i the presence of contaminants. A decrease in oxygen content can be due to the consumption Oy combustion or a reaction such as rusting) of oxygen or the displacement of air by a chemical. If it is due to consumption then the concern is the lack of oxygen. If it is due to displacement then there is something present Otat could be flammable or toxic. Since oxvgen makes 20.8% o oxvgen means that about 5 and been displaCal This means that_= 10,000 " so{ne$ itgjjskLhelbetq- Most indicators have meters which display the oxygen concentration from A-25%. There are also oxygen monitors available which measure concentrations from 0-5% and 0-100%. The most useful range for hazardous material response isldrre0-25% oxygen content readout since decisions involving air-supplying respirators and the use of combustible gas indicators fall into this range. The oxygen sensor can be on the outside (external) or inside (internal) r"rf t6s instrument. Internal sensors need a pump - battery operated or hand operated - to draw a sample to it. has 8/91 13 O)ffGEN MONITORS, CGIs, AND SPECIFIC CIIEMICAL MOMTORS Units that combine 02 meters and combustible gas indicators into one instrument are available from many manufacturers. Also, flashing and audible alarms can be found on many instruments. These alarms go off at a pre-set oxygen concentration to alert the users even if they are not watching the meter. A list of manufacturers of oxygen monitors are found iN this manual in section MANUFACTURERS & SUPPLIERS OF AIR MOMTORINC EQUIPMENT. A. Principle of Operation Oxygen monitors use an electrochemical sensor to determine the oxygen concentration in air. A typical sensor consists of: two electrodes; a housing containing a basic electrolytic solution; and a semi-permeable Teflon membrane (FrGriRE 1). FIGURE I SCIIEMATIC OF O)ffGEN SENSOR Source: Atmospheric Monitorinq for Employee Safety, BioMarine Industries Inc. l4 o, I o, I o " o, l Itrtt^l{ErcovER :LEOIFODE E LEOT NOOE ELECTBOLYTE 8/91 OXYGEN MOMTORS, CGIs, AND SPECIFIC CHEMICAL MOMTORS Oxygen molecules (O) diffuse through the membrane into the solution. Reactions between the oxygen, the solution and the electrodes produce a minute electric current proportional to the oxygen content. The current passes through an electronic circuit which amplifies the signal. The resulting signal is shown as a needle deflection on a meter or as a digital reading. rl In some units, air is drawn into the oxygen detector with an aspirator bulb or pump; in other units, the ambient air is allowed to diffuse to the sensor. Limitations and Considerations The operation of oxygen monitors dgpe$q_$.gre absqtt'r" 4 is-ptres$Ug* The concentration of atmospheric oxygen is a function of the atmospheric pressure at a given altinrde. While ttre actual percentage of oxygen does not change with altitude, at sea level ttre weight of the atmosphere above is greater, and more O, molecules (and the other components of air) are compressed into a given volume than at higher elevations. As elevation increases, this compression decreases, resulting in fewer air molecules being "squeezed" into a given volume. Consequently, an Oz indicator calibrated at sea level and operated at an altitude of several thousand feet will falsely indicate an oxygen deficient atmosphere because less oxygen is being "pushed" into the sensor. Therefore, instrument is used. t4d'W The reaction that produces the current in the sensor is non-reversible. Thus, once the sensor is exposed to oxygen, it begins to wear out. The normal li{e-.sp?n qL4 sensors are shipped in seffie been purged with nitrogen. The packet should not be opened until the sensor is to be used. Storing the sensor in an oxygen absent atmosphere after opening the package can prolong the sensor life, but may not be practical. High of carbon dioxide ( As a geneialTileffiiinit can be used in atmospheres greater ttran-te- -€\. 5% CO2only with frequent replacing or rejuvenating of the sensor. Lifetime in a normal atmosphere (0.0470 CO) can be from 6 months to one year depending on the manufacturer's design. The service life of one sensor is 100 days in M Cqand 50 days in 5% CO, Strong oxidizing chemicals, like ozone and chlorine, can cause increased readiligs and indicate high or normal O content when the actual content is normal or even low. @ttheresponseofoxygenindicators.Thenormaloperatingrange for them is between 32'F and 120'F. Between O'F and 32"F the response of the unit is slower. Below OoF ttre solution may freeze and e.ranuge the sensor. The instrument should be calibrated at the temperature it will be used. High temperature can also shorten ttre sensor life. 8/91 15 OXYGEN MOMTORS, CGIS, AND SPECIFIC CIIEMICAL MOMTORS m.COMBUSTIBLE GAS INDICATORS .,," Combustible gas indicators (CGIs) measure the concentration of a flammable vapor or ga$ ( in.air, indicating the results as a_Iglgg[Aggof the lower explosive limit (LEL) of the \calibration sas.\ The LEL (or LFL - lower flammable limit) of a combustible gas or vapor is the rninimum concentration of the material in air which will propagate flame on contact wittr an ignition source. The upper explosive limit (UEL) is the maximum concentration. Below the LEL there is insufficient fuel to support combustion. Above the UEL, the mixture is too nricho to support combustion so ignition is not possible. Concentrations between the LEL and LJEL are considered flammable. CGIs are available in many styles and configurations. The combustible gas sensor can be on the outside (external) or inside (internal) of the instrument. Internal sensors need a pump - battery operated or hand operated - to draw a sample to it. Many units are "combination meters". This means they have m Oz meter and CGI (and sometimes one or two specific gas indicators) combined in ttre same instrument. Flashing and audible alarms are options on many units. The alarms go off at a pre-set concentration to warn the instrument operator of potentially hazardous concentrations. Other options such as longer sampling lines, moisture traps and dust filters are also available. Manufacturers of CGIs are listed in Section 8. A. Principle of Operation Combustible gas indicators use a combustion chamber containing a filament that combusts the flammable gas. To facilitate combustion the filament is heated or is coated with a catalyst (like platinum or palladium), or bottr. The filament is part of a balanced resistor circuit called a Wheatstone bridge (FIGURE 2). on the i f As the temperature of the filament increases so does its ibsistance. This resistance causes an imbalance in the Wheatstone bridge. This is measured as the ratio of combustible vapor present compared to the total required to reach the LEL. For example, if the meter reads 50% (or 0.5, depending upon the readout), this means ttrat 50% of the concentration of combustible gas needed to reach a flammable or combustible situation is present. If the LEL for the gas is 5Vo then the meter would be indicating that a 2.5% concentration is present. Thus, the typical meter indicates concentration up to ttre LEL of the gas. (See FIG{,IRE 3a.) If a concentration greater than the LEL and lower ttran the UEL is present, tlren the meter needle will stay beyond thg 100L(1.0) level on the met€r. (See FIGLIRE 3b.) fnis phere is readily combustible. When the atmosphere has a gas concentration above the UEL the meter needle may rise above the 100% (1.0) mark and then return to zero. (See FIGLJRE 3c.) This occurs 8/91 16 oxYGEN MONITORS, CGIs, AND SPECIFIC CHEMICAL MONITORS ,because the gas mixture in the combustion cell is too rich to burn. This permits the filament to conduct a current just as if the atmosphere contained no combustibles at all. Some instruments have a lock mechanism that prevents the needle from returning to zero when it has reached lW%. This mechanism must be reset in an atmosphere below the LEL. SENgOR COMPENSATING FILAMENT FIGURE 2 WHEATSTONE BRIDGE CIRCUIT Source: Atmospheric Monitoring for Employee Safety, BioMarine Industries Inc. B. Limitations and Considerations The instruments are intended for use only in normal oxygen atmospheres. Oxygen- deficient atmospheres will produce lowered readings. Also, the safety guards that prevent the combustion source from igniting a flammabls otsnsphere are not designed to operate in an oxygen-enriched atmosphere.T OXYGEN MONITORS, CGIs, AND SPECIFIC CHEMICAL MOMTORS vapoqt-(e.g., leaded gasoline), sulfur compounds, ild silicone 6ffibounOi *iilTd[l_lhe filament. Acid gases (e.g., hydrogen chloride and hydrogen . Most units have an optional filter that protects the FIGT,]RE 3 COMPARISON OF METER READINGS TO COMBUSTIBLE GAS CONCENTRATIONS rhe.rp$w_gltl,rggslsJnenj,is t_e"rnp,gBgre.depe{l_99jlj, If the temperature at which ttre'initilment is zeroed differs from the sample iffiperature, the accuracy of the reading is affected. Hotter temperatures raise the temperature of the filament and produce a higher than actual reading. Cooter t"mpergure The instrument should be calibrated and zeroed at the same temperature that a reading will be taken. Some instruments have a compensating filament (see FIGLJRE 2). This filament is similar to the sensor and is exposed to the same atmosphere, but it does not combust the atmosphere. It compensates for any temperature changes not due to the combustible gas. sensor from leaded vapors. u"h %LEL I %LEL I %LEL a Lower than LEL b Between the LEL and the UBL c Above the UEL 8/91 18 oxYGEN MONITORS, CGIs, AND SPECIFIC CHEMICAL MONITORS There is no differentiation between petroleum vapors and combustible gases. If the flammability of the combined vapors and gases in an atmosphere is the concern, this is not a problem. However, if the instrument is being used to detect the presence of a releasid flammable liquid - like gasoline - in a sewer system where methane may be present, the operator can't tell if the reading is the contaminant or the methane. A pre-filter can be used to remove the vapors but will not remove the methane. Ttrus, if readings are made with and without the filter, the user cut compare the readings and can conclude that differences in the values indicate that a petroleurn vapor (i.e., the contaminant) is present. Relative response is also a concern.the is used to monitor the unit is not PH I illustrates the of relative response. GRAPH 1 EXAMPLES OF RELATIVE RESPONSE CURVES FOR MSA I";'TEL 260 Portable Gas Indicator. Model 250 and 260. Response Curves, Mine Safety Appliances Company, Pittsburgh, PA. M E T E R R E A D I N G 100 PENTANE 50 STYRENE 50 PERCENT LEL 100 METHANE / f / Source: 19 ry. OXYGEN MOMTORS, CGIs, AND SPECIFIC CIIEMICAL MOMTORS TOXIC ATMOSPHERE MOMTORS Along wittr oxygen concentration and flammable about chemicals present at toxic concentrations. gases or vapors, there is also a concern involves measurements d monitoring is done to: o identiS airborne chemicals and their concentrations, . evaluate the exposure of workers and the public, . evaluate the need for and type of personal protective equipment, o develop controls for exposure in the form of engineered safe guards, work practices, safety plans, and work zones. There are several different groups of instruments that can be used for these functions. In this manual the following types will be discussed. o Colorimetric irtdicators include detector tubes, chemical impregnated tape and color changing badges. Further discussion will be found in one of the exercise. . Specific chemical sensors are electronic devices that are designed to respond to a specific chemical. More discussion will follow. . Total vapor survey meters have detectors (e.g. PID or FID) ttrat respond to a variety of chemicals. Additional information can be found in Section 4. o Gas chromatographs are used to help identis what chemicals are present in tlre atmosphere. Further information will be found in Section 5. Specific chemical monitors are gas monitors which utilize either electrochemical cells (similar to oxygen sensors) or metal oxide semi-conductors (MOS) for detecting specific chemicals. A. Principle of Operation Electrochemical cells GIGURE 1) contain a chemical solution and np'o or more electrodes. The chemical reacts with the solution or the electrodes. The reaction can be a generation of electrical current or a change in conductivity of the solution. The change in signal is expressed as a needle movement or a digital response on a meter. The selectivity of the sensor depends on the selection of the chemical solution and the electrodes. c ..exysm_ind"ts*o-r-!_glg-o:[!rr_s gas I.tclicator.. There is a need to determine if toxic chemicals are present and identif them so the environmental concentration can be compared to exposure guidelirns. Toxic ahnosphere O)ffGEN MOMTORS, CGIs, AI{D SPECIFIC CIIEMICAL MOMTORS There are electrochemicd sensors for ammonia, carbon monoxide, carbon dioxide, chlorine, hydrogen chloride, hydrogen cyanide and hydrogen sulfide. Examples of these instruments are Compur's MonitorP Personal Monitor Alarms, MDA's MSTox t6fi) series, and National Draeger's PAC series of personal monitors. MOS detectors, also called solid-state sensors, consist of a nretal oxide film coating on heated ceramic substrate fused or wrapped around a platinum wire coil. When a gas comes in contact with the metal oxide, it replaces oxygen in the oxide and alters the conductivity of the semiconductor. The change in conductivity can be ' expressed in a meter readout. The bead is heated to give a constant baseline as oxygen in ttre air can combine with the oxide. Selectivity can be delermined by selecting specific metal oxides and/or using specific temperatures from the heater to prevent chemicals reacting. There are MOS detectors for ammonia, carbon monoxide, hydrogen chloride, hydrogen cyanide, hydrogen sulfide, methyl chloride, nitrogen oxides and sulfur dioxide. Examples of instruments that use a MOS to detect specific toxic compounds are the Enmet Tlitechtoro and Biosystem's Model lill series. Specific chemical sensors can be used in a single unit for monitoring just ttrat chemical or can be combined in a unit with a combustible gas indicator and oxygen meter. B. Limitxions and Considerations. The sensors are not always specific. There can be interferences. For example, many of the carbon monoxide sensors will also respond !o hydrogen sulfide. In fact, one manufacturer uses the same sensor for bottr carbon monoxide and hydrogen sulfide detection. The user must inform the instrument which chemical is being monitored so the readout is in the proper units. The sensors are designed for temperatures between 32'F and 14O'F. Lower temperatures can reduce response time or even freeze the sensor. MOSs are also effected by elevated t€mpera$re since the resistance of the sensor changes with temperature. Electrochemical sensors may wear out faster at higher temperatures. Some of the reactions are non-reversible. The sensors will wear out during use. The life span of an elecuoctremical sensor is about 6 months to I year. I fAOSs cannot be operated in an absence ofoxygen. They can also be saturated by ffi concentrations of ctremicals. ! fvtoss need a minimum of 10% humidity. They may also b. a{lected by htgh lhumidity. Electrochemical cells can be "dried out" by low humidity atmospheres. \- 8t9l 2l OXYGEN MOMTORS, CGIs, AND SPECIFIC CIIEMICAL MOMTORS V. CONCLUSION There are many hazards that can be present at a hazardous materials operation. There are instruments for determining the presence of hazardous situations like combustible aunospheres, oxygen deficient atmospheres and toxic atrnospheres. The instruments discussed in this section can only identify certain hazardous situations and should be selectod and used accordingly. Additional instrumentation on identising and evaluating toxic atmospheres will be discussed in the following sections. 8/91 o I I E)(POSTJRE LIMITS AI\D ACTION LEVELS NOTE: The correct interpretation of any instrument readout is difficult. If the instrument operator is uncertain of the significance of a reading, especially if conditions could be unsafe, a technical specialist should immediately be consulted. Consideration shouli be given to withdrawing personnel from the area until approval, by the safety officer, is given to continue operations. TABLE 1 ATMOSPITERIC HAZARD ACTION GTIIDES Combustible Gas Indicator Explosive IO% LEL 10-25% LEL > 25% LEL Continue monitoring with caution. Continue monitoring, but with extreme caution, especially as higher levels are encountered. Explosion hazard! Withdraw from area immediately. Oxygen Concentration 19.5% 19.5-25% 25% Monitor wearing SCBA. NOTE: Combustible gas readings not valid in atmospheres < 19.5% oxygen. Continue Monitoring with caution. SCBA not needed based only on oxygen cont€nt. Discontinue monitoring. Fire potential! Consult specialist. Radiation Survey Instrument Gamma Radiation ( lmR/hr ) 1mR/hr Continue monitoring. Consult a Health Physicist. Continue monitoring only upon the advice of a Health Phvsicist. Colorimetric Tubes Organic & inorganic vapors/gases Depends on chemical Consult reference manuals for air concentration vs. toxicity data. Photoionization Detector Organic va1nre/gases Depends on chemical Consult reference manuals for air concentration vs. toxicity data. Flame Ionization Detector Organic vapors/gasas Depends on chemical Consult reference manuals for air concentration vs. toxicity data. 8/91 25