OPERATING ENGINEERS NATIONAL HAZMAT PROGRAM

Transcription

1 OPERATING ENGINEERS NATIONAL HAZMAT PROGRAM INTERNATIONAL ENVIRONMENTAL TECHNOLOGY & TRAINING CENTER FRAMATOME TECHNOLOGIES VICTOR OXY-ACETYLENE TORCH (Equipment Dismantlement) HUMAN FACTORS ASSESSMENT JANUARY 1999

2 FRAMATOME TECHNOLOGIES VICTOR OXY-ACETYLENE TORCH TABLE OF CONTENTS ACKNOWLEDGMENTS... iii EXECUTIVE SUMMARY... iv SECTION 1 SUMMARY Technology Description...1 Key Results...4 SECTION 2 SYSTEM OPERATION...4 SECTION 3 HEALTH AND SAFETY EVALUATION General Health and Safety Concerns...6 Core Issues...6 Best Management Practices...7 Industrial Hygiene Monitoring...8 Human Factors Interface...11 Technology Applicability...11 SECTION 4 JOB SAFETY ANALYSIS (JSA)...13 SECTION 5 FAILURE MODES AND EFFECTS ANALYSIS (FMEA)...20 SECTION 6 TECHNOLOGY SAFETY DATA SHEET (TSDS)...22 SECTION 7 EMERGENCY RESPONSE/PREPAREDNESS...30 SECTION 8 REGULATORY POLICY ISSUES Core Requirements...30 Technology Specific Requirements...31 Special Requirements...32 Best Management Practices...33 Core Training Requirements...33 Technology Specific Training...33 Special Training...33 Best Management Practice Training...34

3 TABLE OF CONTENTS (continued) SECTION 9 OPERATIONAL CONSIDERATIONS AND RECOMMENDATIONS...34 APPENDIX A - REFERENCES...41 APPENDIX B - INDUSTRIAL HYGIENE DATA...43 APPENDIX C - ACRONYMS...44

4 ACKNOWLEDGMENTS The human factors assessment of the Framatome Oxy-acetylene Torch was conducted under support of the U.S. Department of Energy s Federal Energy Technology Center, under cooperative agreement DE-FC21-95MC32260 with the Operating Engineers National HAZMAT Program. The Operating Engineers National HAZMAT Program would like to thank the following people for their participation on the "research action team" and the professional expertise they provided for this assessment: Barbara McCabe Operating Engineers National Hazmat Program Pat Bell Operating Engineers National Hazmat Program David Curry Operating Engineers Local Union 280 Jim Leslie Operating Engineers Local Union 12

5 EXECUTIVE SUMMARY The Framatome Victor Oxy-acetylene Torch technology was tested and is being evaluated by Florida International University (FIU). The equipment dismantlement technology demonstrations are designed to evaluate technologies for decontamination and decommissioning (D&D) work. The human factors assessment conducted in conjunction with FIU s evaluation of efficiency and cost, covers the hazard analysis and safety evaluation for the torch. The Framatome Torch is a commercially available technology and has been used for various projects at locations throughout this country. While the torch itself does not inherently involve safety and health hazards associated with D&D work, the activities that are being conducted using the technology do. Safety and health hazards associated with the torch are addressed in this report and although not addressed here, the specific hazards involved in D&D activities need to be addressed prior to the start of the project. The oxy-acetylene torch provides a thermal cutting technique to cut metal pieces. The torch burns the metal and coatings, producing smoke and fumes. The torch can be manipulated manually or it can be placed on a motorized track. The system consists of an oxygen and fuel supply (acetylene), regulators, hose, torch handle, and cutting attachment and tip. The torch handle is a set of gas tubes with control valves. One tube and valve controls the fuel supply and one tube and valve controls the oxygen supply. The handle is a means of control for the gas supply and the cutting apparatus attached to the handle mixes the oxygen and fuel gas. The elements of the torch handle are the control valves with internal reverse flow check valves, the body Y, the barrel and tubes, and the torch head. The control valves are installed in the body Y and the valve bodies are marked to distinguish between the two valves. The body of one valve has left-hand threads to accept the fuel gas hose and the other has right-hand threads to accept the oxygen hose. The barrel and inner oxygen tube unit is designed to keep the oxygen and fuel gases separated. A tube-within-a-tube design is used to allow the oxygen to flow through the inner tube and the fuel supply to travel through the interior barrel cavity. The torch head is threaded onto the barrel, creating a metal-to-metal seal. The oxygen is directed through the center hole in the head while the fuel supply passes through drilled orifices around the centered oxygen port. When the cutting attachment is connected, a gas-tight seal is made. The torch handle has internal reverse flow check valves to reduce the possibility of explosion or fire which may occur as a result of fuel gases and oxygen becoming mixed inside the hoses or regulators. Flashback arrestors are designed to prevent a flashback from reaching upstream equipment. The cutting attachment functions as a cutting torch. The cutting attachment consists of the cone end and coupling nut, the preheat oxygen control valve, the mixing chamber, the cutting oxygen lever and tube, and the cutting attachment head. The cone end and coupling nut permit easy attachment to the torch handle. O-rings allow continued separation of the oxygen and fuel gases. The center orifice of the cone end allows the passage of oxygen supply and the orifices around the oxygen port allow the fuel gas to

6 travel to the mixing chamber in the lower tube of the cutting attachment. The preheat oxygen control valve controls the preheat oxygen supply from the regulator. The mixing chamber tube is where the oxygen and fuel gas are brought together to produce the desired preheating flame. The cutting oxygen lever and tube allows cutting oxygen to flow through the upper tube of the cutting attachment and the center port of the cutting attachment head. The cutting attachment head allows the oxygen and the mixed preheat gas to stay separated in the cutting operation and the cutting tip keeps the preheat gas mixture and cutting oxygen stream separated to provide flame characteristics needed for a particular cutting application. Cylinders of oxygen and acetylene are used to supply the gases for cutting. Oxygen and fuel pressure regulators are attached to the cylinder manifold outlets to reduce high cylinder or supply pressures for cutting applications. The regulator consists of the inlet connection with filter, pressure adjusting screw, high pressure gauge, low pressure gauge, outlet connection, and relief valve. The high pressure gauge indicates the cylinder or supply pressure entering the regulator and the low pressure gauge indicates the delivery pressure from the regulator to the hose. The hose transports low pressure gas (maximum 200 psig) from the regulators to the cutting torch. Hoses are usually color-coded for gas service identification. Oxygen hose is usually green and the fuel hose is usually red. The hoses are flame-retardant. During the assessment sampling was conducted for welding fume, as total particulate, nitrogen dioxide, carbon monoxide, carbon dioxide, and formaldehyde and noise. General observational techniques were conducted for ergonomics that showed potential for some ergonomic stressors during setup, operation, maintenance, and decontamination of the oxy-acetylene torch. Awkward positions the operator has to assume to access pieces to be cut are the main ergonomic concerns associated with the torch. Area air sampling was conducted during operation of the oxy-acetylene torch. The actual cutting of pipes, tubes, I-beams, etc. took approximately 5-10 minutes per piece. Therefore, area sampling was conducted throughout the entire process to assess the potential for worker exposure during cutting operations with the oxy-acetylene torch. Personal samples were collected on the workers for nitrogen dioxide and area samples were collected for nitrogen dioxide, carbon dioxide, and carbon monoxide. Area formaldehyde samples were taken because of the coating used, and were collected in the area of the coated steel plate during cutting. All other area samples were taken at a central location in the general work area where the cutting operation was taking place. A forklift was periodically operated in the area to remove the piece that was cut. The area welding fume, as total particulate samples showed results of mg/m 3 and mg/m 3. These results are all below the OSHA PEL of 15 mg/m 3 and the ACGIH TLV of 5 mg/m 3. All personal sampling for nitrogen dioxide showed results of < 1.45 ppm and area sampling showed a result of <1.67 ppm. These are below the OSHA PEL of 5 ppm (as a ceiling level) and the ACGIH TLV of 3 ppm. Carbon dioxide monitoring showed a result of < 8.33 ppm which is below the OSHA PEL and the ACGIH TLV of 5000 ppm. Carbon monoxide monitoring showed a result of

7 < 1.67 ppm which is below the OSHA PEL of 50 ppm and the ACGIH TLV of 25 ppm. Formaldehyde monitoring showed a result of <0.2 ppm which is below the OSHA PEL of 0.75 ppm and the ACGIH TLV of 0.3 ppm. Although sampling for the contaminants discussed above did not show any exposures above the OSHA PEL or the ACGIH TLV, fumes were visible during the operation of the oxy-acetylene torch. The time spent in the work area, the distance from the actual cutting operation, and ventilation in the work area will affect an individual worker s exposure level. A monitoring plan will need to be developed to account for the site specific conditions where the torch is being used, including contaminants specific to the D&D project. The metal being cut with the torch needs to be taken into consideration and contaminants specific to the metal need to be monitored. Area noise sampling was conducted during operation of the oxy-acetylene torch. Since the actual cutting of pipes, tubes, I-beams, etc. took approximately 5-10 minutes per piece, area noise sampling was conducted throughout the entire process to assess the potential for worker noise exposure during cutting operations with the torch. Area samples were taken at a central location in the general work area where the cutting operation was taking place. A forklift was periodically operated in the area to remove the piece that was cut. Monitoring was conducted for 1.9 hours (115 minutes) and 6.2 hours (370 minutes). Noise monitoring showed a noise dose of 3.9% which would give a time-weighted average (TWA), assuming no further noise exposure for the 8-hour shift, of dba and a noise dose of 11.0% (TWA dba). These results show exposures below the OSHA action level of 85 dba and the PEL of 90 dba. A projected 8-hour noise dose and resultant TWA showed the following results for the respective area samples: 11.76% (TWA dba) and 25.96% (TWA dba). These projected 8-hour noise doses also show exposures below the OSHA action level and the PEL. The OSHA action level is a noise dose of 50% or an 8-hour TWA of 85 dba and the PEL for noise is a 100% dose or an 8-hour TWA of 90 dba. The levels of exposure recorded during the testing demonstration show noise was not a concern. Operators may need to be included in a hearing conservation program based on the noise levels specific to the location where the torch is being used. Differences in noise exposure will be based on the location of the worker in relation to the cutting operation and the amount of time the worker spends there. A sampling plan will need to be developed to address the site specific conditions where the thermal cutting operation takes place. A sampling plan should also take into consideration the work environment since the noise levels may increase or decrease based on the construction of the enclosure where the cutting operation is taking place. Recommendations for improved worker safety and health during use of the Oxyacetylene Torch include: 1. keeping all hoses and lines as orderly as possible in compliance with good housekeeping requirements; 2. ergonomic training to include techniques in lifting, bending, stooping, twisting, etc.; 3. assessment of heat stress to include the extra heat load created by the sparks, flame, and hot metal; 4. use of safety glasses, goggles, or other appropriate eye protection under the welding helmet; 5. the

8 use of a welding helmet with the correct filter in place; 6. using only a chipping hammer or chisel to chip slag; 7. avoiding touching cement or stone surfaces with the torch; 8. the use of puncture resistant gloves when handling cut metal pieces; 9. the use of gloves appropriate for hot work when handling hot metal pieces; 10. adequate ventilation in the area where the cutting operation is taking place; and 11. requiring proper handling, storage, and usage of compressed gas cylinders.

9 FRAMATOME TECHNOLOGIES Victor Oxy-acetylene Torch Human Factors Assessment (Equipment Dismantlement) TECHNOLOGY DESCRIPTION SECTION 1 - SUMMARY The Framatome Technologies Oxy-acetylene Torch technology was tested and is being evaluated BY Florida International University (FIU). The equipment dismantlement technology demonstrations are designed to evaluate technologies for decontamination and decommissioning (D&D) work. The human factors assessment conducted in conjunction with FIU s evaluation of efficiency and cost covers the hazard analysis and safety evaluation for the torch. The Framatome oxy-acetylene torch is a commercially available technology and has been used for various projects at locations throughout this country. While the torch itself does not inherently involve safety and health hazards associated with D&D work, the activities that are being conducted using the technology do. Safety and health hazards associated with the oxy-acetylene torch are addressed in this report and although not addressed here, the specific hazards involved in D&D activities need to be addressed prior to the start of the project. D&D activities within the Department of Energy (DOE) require that personnel have access to all areas of structures, some of which are over 40 years old and many are deteriorated and lack any preventive maintenance over the years. D&D activities and the associated hazards to workers involve not only the contaminants specific to the environment but general construction safety and health. A safety and health program specific for the project needs to be developed and should include but not be limited to: responsibilities for safety and health, including reporting hazards and accidents, obtaining and using personal protective equipment, conducting safety inspections, maintaining a safe and healthful work environment, enforcing safety and health requirements; procedures for conducting safety and health orientation and periodic training sessions; procedures for reporting accidents; procedures for obtaining first aid and emergency treatment; procedures for reporting work hazards; procedures for testing and certifying equipment; job-site sanitation; the use and purpose of equipment lockout and confined space entry;

10 the technical requirements (personal protective equipment, hazardous materials, welding and cutting, electrical, material handling, rigging, pressurized systems, scaffolding, etc.). Workers must be trained in accordance with all applicable OSHA safety and health regulations and only workers trained and certified, as applicable, should be allowed to perform operations and/or operate equipment used during the D&D activities. For example, only workers trained in fall protection in accordance with OSHA 29 CFR are allowed to work from a height, only operators trained on forklifts in accordance with OSHA 29 CFR are allowed to operate a forklift, and functions such as welding and cutting and the operation of heavy equipment should only be done by workers trained and/or certified to perform them. Inspection programs and preventive maintenance programs need to be in place to assure all equipment is in good working condition and removed if it is not. In addition, job pre-planning is essential to assure all work to be performed will be done so in a safe manner. Hoisting and rigging activities which often account for accidents with injuries and/or fatalities, will be an integral part of all D&D projects. Considerations for hoisting and rigging during a D&D project should include but not be limited to: All hoisting and rigging activities must be conducted in accordance with OSHA 29 CFR 1926 Subpart N Cranes, Derricks, Hoists, Elevators, and Conveyors. Only workers with the appropriate qualifications and training be allowed to perform hoisting and rigging functions during the D&D project. All workers, including supervisory personnel, should review and follow established procedures and regulations. When proper procedures, planning, or equipment is not available for the job, work should be stopped. Only manufacturer-approved or properly engineered equipment should be used and it should be used appropriately. Preventive maintenance activities should be scheduled and the process for performance reviewed for adequacy. Hoisting and rigging activities, including the use of forklifts, should be properly planned before work begins to ensure proper procedures and equipment are available and the hazards are identified. Workers, including supervisory personnel, should familiarize themselves with the equipment, work area hazards, transportation routes, and the layout of the facility before starting the job. Before beginning hoisting and rigging activities, including the use of a forklift, assure the center of gravity and weight of the load have been properly calculated. Assure workers have training and experience directly applicable to the type of activities to be conducted. Inspect all chain, wire rope, slings, etc. to assure it is in good working condition before the hoisting and rigging work is started.

11 Another frequent cause of accidents with injuries is the use of forklifts. Considerations for the use of forklifts during a D&D project should include but not be limited to: All forklift activities must be conducted in accordance with OSHA 29 CFR Powered Industrial Trucks. Only trained and authorized operators shall be permitted to operate the forklift. Modifications to the forklift should be approved by the forklift manufacturer. If the modifications affect the capacity and safe operation of the forklift, they must be approved in writing by the forklift manufacturer and capacity, operation, and maintenance instruction plates, tags, or decals shall be changed accordingly. Modification designs should be approved by a professional engineer. Any welding on modifications should be done by a certified welder and inspected in accordance with ASTM guidelines. All parts used, such as bolts, must be rated for the load. No one shall be allowed to stand or pass under an elevated portion of the forklift, whether loaded or empty. The forklift must not be left unattended with a suspended load. If the operator of the forklift is within 25 ft. and has a view of the forklift, the load engaging means must be fully lowered, controls neutralized, and the brakes set to prevent movement. If the operator is greater than 25 ft. or does not have a view of the forklift, the load engaging means shall be fully lowered, controls neutralized, power shut off, and brakes set. The forklift must be rated for the load. All hoisting and rigging equipment must be rated for the load. It needs to be assured that the forklift is properly equipped with a working backup alarm, beacon light, seat belt, and fire extinguisher. A maintenance and inspection program should be in place to assure that any forklift that is not in safe operating condition is removed from service. The oxy-acetylene torch provides a thermal cutting technique to cut metal pieces. The torch burns the metal and coatings, producing smoke and fumes. The torch can be manipulated manually or it can be placed on a motorized track. The system consists of an oxygen and fuel supply (acetylene), regulators, hose, torch handle, and cutting attachment and tip. The torch handle is a set of gas tubes with control valves. One tube and valve controls the fuel supply and one tube and valve controls the oxygen supply. The handle is a means of control for the gas supply and the cutting apparatus attached to the handle mixes the oxygen and fuel gas. When connected to the torch handle, the cutting attachment functions as a cutting torch. KEY RESULTS Figure 1. Oxy-acetyle Torch attached to a motorized track. The safety and health evaluation during the testing demonstration focused on two types of potential exposure: welding fume, as total particulate and noise. Smoke and fume was visible during operation of the oxy-acetylene torch but air sampling results showed

12 values below the Occupational Safety and Health Administration (OSHA) permissible exposure limit (PEL) and the American Conference of Governmental Industrial Hygienists (ACGIH) threshold limit value (TLV). This will be discussed in greater detail in the Industrial Hygiene Monitoring section of this report. Noise exposure was below the "action level". This will also be discussed in greater detail in the Industrial Hygiene section of this report. Further testing for each of these exposures is recommended because the environment where the technology is being used, the time the worker spends in the area, and the distance the worker is from the operational area may cause exposures to be higher or lower. Air sampling and noise monitoring will be required in all operational settings. Other safety and health hazards found were ergonomics, heat stress, tripping hazards, fire hazards, burn hazards, physical eye hazards and exposure to ultraviolet light, lockout/tagout, and hazards associated with the use of compressed gases. SECTION 2 - SYSTEM OPERATION The oxy-acetylene torch provides a thermal cutting technique to cut metal pieces. The torch burns the metal and coatings, producing smoke and fumes. The torch can be manipulated manually or it can be placed on a motorized track. The system consists of an oxygen and fuel supply (acetylene), regulators, hose, torch handle, and cutting attachment and tip. The torch handle is a set of gas tubes with control valves. One tube and valve controls the fuel supply and one tube and valve controls the oxygen supply. The handle is a means of control for the gas supply and the cutting apparatus attached to the handle mixes the oxygen and fuel gas. The elements of the torch handle are the control valves with internal reverse flow check valves, the body Y, the barrel and tubes, and the torch head. The control valves are installed in the body Y and the valve bodies are marked to distinguish between the two valves. The body of one valve has left-hand threads to accept the fuel gas hose and the other has right-hand threads to accept the oxygen hose. The barrel and inner oxygen tube unit is designed to keep the oxygen and fuel gases separated. A tube-within-a-tube design is used to allow the oxygen to flow through the inner tube and the fuel supply to travel through the interior barrel cavity. The torch head is threaded onto the barrel, creating a metal-to-metal seal. The oxygen is directed through the center hole in the head while the fuel supply passes through drilled orifices around the centered oxygen port. When the cutting attachment is connected, a gas-tight seal is made. The torch handle has internal reverse flow check valves to reduce the possibility of explosion or fire which may occur as a result of fuel gases and oxygen becoming mixed inside the hoses or regulators. Flashback arrestors are designed to prevent a flashback from reaching upstream equipment. The cutting attachment functions as a cutting torch. The cutting attachment consists of the cone end and coupling nut, the preheat oxygen control valve, the mixing chamber, the cutting oxygen lever and tube, and the cutting attachment head. The cone end and coupling nut permit easy attachment to the torch handle. O-rings allow continued separation of the oxygen and fuel gases. The center orifice of the cone end allows the

13 passage of oxygen supply and the orifices around the oxygen port allow the fuel gas to travel to the mixing chamber in the lower tube of the cutting attachment. The preheat oxygen control valve controls the preheat oxygen supply from the regulator. The mixing chamber tube is where the oxygen and fuel gas are brought together to produce the desired preheating flame. The cutting oxygen lever and tube allows cutting oxygen to flow through the upper tube of the cutting attachment and the center port of the cutting attachment head. The cutting attachment head allows the oxygen and the mixed preheat gas to stay separated in the cutting operation and the cutting tip keeps the preheat gas mixture and cutting oxygen stream separated to provide flame characteristics needed for a particular cutting application. Cylinders of oxygen and acetylene are used to supply the gases for cutting. Oxygen and fuel pressure regulators are attached to the cylinder manifold outlets to reduce high cylinder or supply pressures for cutting applications. The regulator consists of the inlet connection with filter, pressure adjusting screw, high pressure gauge, low pressure gauge, outlet connection, and relief valve. The high pressure gauge indicates the cylinder or supply pressure entering the regulator and the low pressure gauge indicates the delivery pressure from the regulator to the hose. The hose transports low pressure gas (maximum 200 psig) from the regulators to the cutting torch. Hoses are usually color-coded for gas service identification. Oxygen hose is usually green and the fuel hose is usually red. The hoses are flame retardant. SECTION 3 - HEALTH AND SAFETY EVALUATION GENERAL SAFETY AND HEALTH CONCERNS Personnel where the oxy-acetylene torch technology is being used need to be concerned with two categories of safety and health issues. Core issues are those that are based on current safety and health regulatory requirements. Best management practices are related to issues that are not based on current safety and health regulations, but are key elements in preventing worker injury and illness on the job. Safety and health issues of concern with the oxy-acetylene technology included: Core Issues: Tripping Hazards - The hoses, while necessary for the operation of the equipment, can become tripping hazards. Stringent housekeeping must be addressed. Pinch Points - The potential exists for the operator to have his/her fingers/hand injured moving gas cylinders or the motorized track, if caught between two stationary objects. Lockout/Tagout - The user of the technology will need to develop a lockout/tagout program to assure there is no accidental release of energy during maintenance/repair activities.

14 Noise - The operator and workers in the area were subjected to noise levels below the OSHA action level. The "action level" is 85 dba for an 8-hour work shift. The level of exposure will be influenced by the amount of time the worker spends in the area where the cutting operation is taking place and the distance the operator is from the work. Therefore, noise may be a concern under certain circumstances and will be discussed in greater detail in the Industrial Hygiene section of this report. Fume - Visible smoke and fumes were generated during operation of the torch. Air sampling results showed a level of welding fume, as total particulate less than the OSHA PEL and the ACGIH TLV. The PEL is 15 mg/m 3 and the TLV is 5 mg/m 3. Welding fume, however, may be a concern under certain operational conditions and a sampling plan to address this on a job-by-job site-by-site basis will need to be developed. Other contaminants sampled during the testing demonstration were carbon monoxide, carbon dioxide, nitrogen dioxide, and formaldehyde. These will be discussed in detail in the Industrial Hygiene Monitoring Section of this report. Sparks and slag are of concern during cutting operations using the oxy-acetylene torch. They are spread throughout the area during cutting and therefore, have the potential to create additional airborne contaminants, such as metal particulate. They also present a fire, burn, and physical eye hazard. Fire hazards Heat, sparks, or flame present during thermal cutting has the potential to cause a fire hazard. When fire hazards present in the area cannot be moved, then guards must be set up to contain heat, sparks, and slag. Ventilation Adequate breathing air must be provided for in thermal cutting operations. Adequate ventilation will depend on the dimensions and layout of the work area, number of cutting operations, contaminants in the area and the allowable level for each, and the natural air flow in the area. Mechanical ventilation and, as a last resort, respirators may be needed to provide adequate breathing air and protect workers. PPE The sparks and spatter present severe physical eye hazards. The welding helmet will protect the eyes from sparks and spatter that strike directly against it but they are not intended to protect against those that ricochet under the helmet. Safety glasses with side shields, goggles, or other appropriate eye protection must also be worn to protect against these impact hazards. The oxy-gasoline torch produces ultraviolet light which can damage the eyes in the form of a flash or after long term exposure, cataracts. Proper protection for the eyes while performing cutting operations with the oxy-gasoline torch is the welding helmet with the correct filter in place. Filter darkness needs to chosen in compliance with OSHA 29 CFR Subpart Q Welding, Cutting, Brazing. Other workers in the area during cutting operations need to wear safety glasses with an appropriate darkness rating. The sparks, spatter, and ultraviolet light may cause skin burns. Protective clothing needs to provide sufficient coverage and be made of flame-retardant materials to

15 minimize skin burns. Covering all parts of the body is recommended to prevent flash burn from ultraviolet and infrared rays. Best Management Practices: Heat Stress - The operator may be subjected to an increase in heat stress due to the heat generated during thermal cutting operations. Sparks, flame, slag, and hot metal will add to the heat load. The need to utilize personal protective equipment (PPE), flame-resistant garments, will also add to the heat load. The user will need to develop a heat stress program for the environment in which the technology is being used, taking into consideration any necessary PPE, ambient temperatures, etc. Ergonomics - The worker is subjected to ergonomic stressors that need to be taken into consideration, such as stooping, bending, twisting, kneeling, lifting, and static postures. Communication - Due to the noise generated by the technology, at times, during operation, communication may be difficult. Personnel working in the area should be familiar with and use hand signals when needed. INDUSTRIAL HYGIENE MONITORING During this testing demonstration with the oxy-acetylene torch, sampling was conducted for welding fume, as total particulate, carbon monoxide, carbon dioxide, nitrogen dioxide, formaldehyde, and noise. In addition, the wet-bulb globe temperature was monitored to evaluate heat stress. Observational evaluation was conducted for ergonomics. Through general observational techniques the potential for ergonomic problems was evaluated during the testing demonstration. There is potential for upper and lower back, arm, and leg stress and/or injuries due to bending, twisting, and lifting associated with setup, operation, maintenance, and decontamination. Figure 2. Ergonomic stressors are created by awkward positions required to cut I-beam lying at ground level. During cutting operations, many ergonomic stressors were placed on the body from working in awkward and static postures. There is also concern for the manual force and repetitive motions that may be required. In order to make a cut, the workers had to get into tight places by twisting themselves into place or by propping their bodies into awkward positions. Stresses occur from holding the head and arms in unnatural, fixed positions for long amounts of time. This often results in stiffness and soreness in the body. Overhead work can result in a condition know as shoulder tendonitis (inflammation of the tendons of the shoulder) and there is concern for the stress placed on the back from bending to cut pieces located on ground level.

16 Pre-planning to place the operator in the best position for ergonomics and safety should be done before operations begin and periodically as the job progresses. Workers should not place themselves in positions that cause the body discomfort but since many times these awkward postures are unavoidable, workers should, at the first sign of soreness, stop and stretch. Heat stress parameters were monitored using a Quest QuestTemp 15 Heat Stress Monitor. The wet-bulb globe temperature was used to determine the work/rest regimen in accordance with the ACGIH recommendations. The wet-bulb globe temperature was adjusted for the type of clothing, including PPE that the worker was wearing, in accordance with ACGIH guidelines. While heat stress will be increased when wearing PPE, the overall heat stress response will vary from worker to worker. Each situation in which the current technology is used will need to be evaluated for the heat stress potential, taking into consideration the wetbulb globe temperature, PPE in use, physical condition of the worker, and worker acclimatization. Welding fume, as total particulate monitoring was conducted with a sampling train consisting of an MSA Escort Elf air-sampling pump and a pre-weighed cassette with a 5 µg PVC filter. Pre- and post- sampling calibration was accomplished using a BIOS International DryCal DC1 primary calibration system. The Sampling was conducted and analyzed in accordance with National Institute of Occupational Safety and Health (NIOSH) Method Samples were analyzed by a laboratory accredited by the American Industrial Hygiene Association (AIHA). Carbon dioxide, carbon monoxide, and nitrogen dioxide were monitored using Dräger direct reading diffusion tubes and formaldehyde was monitored using a Dräger short-term measurement tube. Area air sampling was conducted during operation of the oxy-acetylene torch. The actual cutting of pipes, tubes, I-beams, etc. took approximately 5-10 minutes per piece. Therefore, area sampling was conducted throughout the entire process to assess the potential for worker exposure during cutting operations with the oxy-acetylene torch. Personal samples were collected on the workers for nitrogen dioxide and area samples were collected for nitrogen dioxide, carbon dioxide, and carbon monoxide. Area formaldehyde samples were taken because of the coating used, and were collected in the area of the coated steel plate during cutting. All other area samples were taken at a central location in the general work area where the cutting operation was taking place. A forklift was periodically operated in the area to remove the piece that was cut. The area welding fume, as total particulate samples showed results of mg/m 3 and mg/m 3. These results are all below the OSHA PEL of 15 mg/m 3 and the ACGIH TLV of 5 mg/m 3. (See Appendix B for sampling data). All personal sampling for nitrogen dioxide showed results of < 1.45 ppm and area sampling showed a result of <1.67 ppm. These are below the OSHA PEL of 5 ppm (as a ceiling level) and the ACGIH TLV of 3 ppm. Carbon dioxide monitoring showed a result of < 8.33 ppm which is below the OSHA PEL and the ACGIH TLV of 5000 ppm. Carbon monoxide monitoring showed a result of < 1.67 ppm which is below the OSHA PEL of 50 ppm and the ACGIH TLV of 25 ppm. Formaldehyde monitoring showed a

17 result of <0.2 ppm which is below the OSHA PEL of 0.75 ppm and the ACGIH TLV of 0.3 ppm. Although sampling for the contaminants discussed above did not show any exposures above the OSHA PEL or the ACGIH TLV, fumes were visible during the operation of the oxy-acetylene torch. The time spent in the work area, the distance from the actual cutting operation, and ventilation in the work area will affect an individual worker s exposure level. A monitoring plan will need to be developed to account for the site specific conditions where the torch is being used, including contaminants specific to the D&D project. The metal being cut with the torch needs to be taken into consideration and contaminants specific to the metal need to be monitored. Area noise sampling was conducted during operation of the oxy-acetylene torch. Since the actual cutting of pipes, tubes, I-beams, etc. took approximately 5-10 minutes per piece, area noise sampling was conducted throughout the entire process to assess the potential for worker noise exposure during cutting operations with the torch. Area samples were taken at a central location in the general work area where the cutting operation was taking place. A forklift was periodically operated in the area to remove the piece that was cut. Area noise sampling was conducted using Quest Q-300 noise dosimeters. Calibration was conducted pre- and post- monitoring using a Quest QC-10 acoustical calibrator. Monitoring was conducted for 1.9 hours (115 minutes) and 6.2 hours (370 minutes). Noise monitoring showed a noise doses of 3.9% which would give a time-weighted average (TWA), assuming no further noise exposure for the 8-hour shift, of dba and a noise dose of 11.0% (TWA dba). These results show exposures below the OSHA action level of 85 dba and the PEL of 90 dba. A projected 8-hour noise dose and resultant TWA showed the following results for the respective area samples: 11.76% (TWA dba) and 25.96% (TWA dba). These projected 8-hour noise doses also show exposures below the OSHA action level and the PEL. During the monitoring periods, the noise levels were averaged for each one-minute period and then an overall average was calculated. This gave an average exposure level of 61.0 db and 80.6 db for the respective area samples. The maximum sound levels observed during monitoring were db and db. The OSHA action level is a noise dose of 50% or an 8-hour TWA of 85 dba and the PEL for noise is a 100% dose or an 8-hour TWA of 90 dba. The levels of exposure recorded during the testing demonstration show noise was not a concern. Operators may need to be included in a hearing conservation program based on the noise levels specific to the location where the torch is being used. Differences in noise exposure will be based on the location of the worker in relation to the cutting operation and the amount of time the worker spends there. A sampling plan will need to be developed to address the site specific conditions where the thermal cutting operation takes place. A sampling plan should also take into consideration the work environment since the noise levels may increase or decrease based on the construction of the enclosure where the cutting operation is taking place.

18 HUMAN FACTORS INTERFACE Workers using a technology for cutting pieces during D&D activities may encounter a variety of contaminants when working in a hazardous waste site environment. This may include contaminants associated with the pieces being dismantled, the material the pieces are constructed of, or contamination inherent in the environment where the pieces are located. Therefore, different levels of PPE, such as level A, B, C, or D or different types as PPE such as Anti-C, for radiation contamination may need to be utilized. These contaminants should be identified by the site characterization prior to the start of the D&D project. The level of protection being utilized has the potential to cause several human factors interface problems. These may include, but not be limited to, visibility, manual dexterity, tactile sensation, an increase in heat stress, and an overall increase in physical stress. An additional concern with thermal cutting is the need for the worker to utilize flameretardant PPE. This will need to be taken into consideration when choosing the PPE to protect against other types of contamination. TECHNOLOGY APPLICABILITY There was visible smoke and fume during the cutting operation but the air sampling results showed sampling values below the OSHA PELs and the ACGIH TLVs. A sampling plan will need to be developed to assess contaminants under site specific conditions. The torch and all of the system's components will need to be disassembled to be decontaminated. This will not necessarily guarantee that decontamination will be complete. If total decontamination is not possible, the equipment and/or parts of the equipment may need to be considered a consumable.

19 SECTION 4 - JOB SAFETY ANALYSIS JOB SAFETY ANALYSIS FRAMATOME TECHNOLOGIES Victor Oxy-acetylene Torch (Equipment Dismantlement) HAZARD CORRECTIVE ACTION SETUP AND TEAR DOWN * Pinch Points * Use of hand protection * Use of proper hand tools for the job * Slips/Trips/Falls * Awareness of the specific hazards * Organization of materials (housekeeping) * Walking around areas that are congested when possible * Walking around tripping hazards when possible * Marking, isolating, and/or bunching together tripping hazards * Stuck by (gas cylinder/parts) * Assure gas cylinders are properly secured in vertical position and cannot fall * Do not allow cylinders to be dropped or knocked over * Be sure valve protection caps are secure when moving cylinders or when cylinders are being stored * Stand so the cylinder is between you and the regulator; never stand in front of the regulator when opening

20 HAZARD CORRECTIVE ACTION SETUP AND TEAR DOWN (CONTINUED) * Exposure to fuel gas (acetylene) * Open cylinder valve only slightly * Do not stand directly in front of the valve when cracking the cylinder valve * Crack cylinder valve only in well ventilated areas * If acetylene cylinder sprays a mist when cracked, let it stand for 15 minutes; if it does it again do not use contact gas supplier * Clear hoses in well ventilated areas * Inspect hoses before attaching to the regulator or torch handle * Fire/explosion hazard * Assure there is no oil, grease, or damaged parts on the regulator or valves (of oxygen cylinder); if there is, do not use * Never use any rags with oil or grease on them to wipe the cylinder, valve, or regulator * Never lay acetylene cylinder on its side; When it is up-righted could get liquid in regulator and/or hoses and there is potential for an explosion * Muscular/Back Injury * Ergonomic training including safe lifting techniques CUTTING (OPERATION) * Muscular/Back Injury (from stooping, bending, awkward positions) * Ergonomics training * Pre-planning job * Slips/Trips/Falls * Awareness of site specific hazards (cords, umbilical line, etc.) * Job site organization of materials (housekeeping) * Walk around hazards when possible * Marking, isolating, and/or bunching together tripping hazards * Pinch Points * Assure worker training in the proper operation of the oxy-acetylene torch and use of compressed gas cylinders

21 HAZARD CORRECTIVE ACTION CUTTING (OPERATION) (CONTINUED) * Eye hazard/struck by (sparking) * Wear safety glasses with side shields, goggles, or other appropriate eye protection under the welding helmet * Eye hazard (ultraviolet/infrared * Wear a welding helmet with the correct filter in light) place; filter darkness needs to be selected in accordance with OSHA 29 CFR Subpart Q Welding, Cutting, Brazing * Workers in the area where the cutting operation is taking place need to wear safety glasses with an appropriate darkness rating * Assure all filters and lenses meet the test for transmission of radiant energy prescribed in ANSI Z87.1 Practice for Occupational and Educational Eye and Face Protection * Wear dark clothing to reduce reflection under * Burn hazards (sparks, spatter, radiation) the welding helmet * Use appropriate flame-resistant PPE, as required (gauntlet gloves, jacket, apron, etc.) * Cover all parts of the body to protect against ultraviolet and infrared ray flash burn * Do not wear clothing that can melt or can cause severe burn due to sparks that may lodge in rolled-up sleeves, pockets of clothing, or pant cuffs * Point the tip away from yourself, other people in the area, equipment, and any combustible materials when lighting the torch * Never light the torch with anything other than a striker designed for that purpose * Pre-planning to allow cut to be made as safely as possible and direct sparking away from worker when possible * Assure all workers in the area are aware of where a cut has been made and the metal is hot * Use gloves for hot work to handle hot pieces of metal

22 HAZARD CORRECTIVE ACTION CUTTING (OPERATION) (CONTINUED) * Fire/Explosion hazards * Assure workers are aware of all combustibles in the area before the cutting operation begins * Move as many of the combustibles away from the area as possible * If combustibles/fire hazards cannot be moved, set up guards to contain heat, sparks, and flame * Assure no grease or oil is present on the PPE or work clothes of the workers in the area * Assure fire watch is present, as required *Have portable fire extinguishers and/or other appropriate fire protection equipment available in the area, and assure workers are trained, as required * Assure no flammables are in or near the area where cutting is being done * Special precautions on drums, tanks, and closed containers; have they held flammable materials? * Assure all hoses and fittings are inspected for leaks before use * Assure flashback arrestors are present and operational * When cutting operation is complete, turn off acetylene first to blow out the flame; if turn off the oxygen, first have chance to have a burn up inside the tip * Turn off oxygen and acetylene bottles any time cutting not in progress * Cut/Laceration hazards * Use puncture resistant gloves when handling metal pieces that have been cut

23 HAZARD CORRECTIVE ACTION CUTTING (OPERATION) (CONTINUED) * Struck by hazards * Aim torch away from cement or stone surfaces; moisture within these materials could cause them to explode when they reach a certain temperature * Only use chipping hammers and chisels which are designed for slag removal * Always wear safety glasses with side shields when chipping slag; a face shield may also be required * Workers must always be aware of where the cutting is being done; do not allow any one under the area where cuts are made on elevated pieces * Noise * Use engineering controls, as required * Use administrative controls, as required * Use proper hearing protection devices, as required * Heat stress * Have a heat stress program in place * Assure the heat stress program accounts for the added heat load from the thermal cutting process * Use cooling devices, as required

24 HAZARD CORRECTIVE ACTION CUTTING (OPERATION) (CONTINUED) * Exposure to Contaminants * Assure workers are aware of the hazards in the area where they are using the torch * Use of proper PPE, including respiratory protection * Worker training to use good work practices that will enable worker to avoid contact with any contaminated surfaces, i.e. the floor, walls, other structures in the area * Only perform cutting operations in well ventilated areas * Check hoses, regulator, and valves for leaks before use * Keep cylinder wrench, if one is required, on cylinder valve so can quickly be turned off * Turn oxygen and acetylene bottles off any time cutting is not in progress * Evaluation of possible hazards from metal being cut, coatings on the metal, contamination inherent to the area, etc. be made before the cutting process begins GENERAL MAINTENANCE * Exposure to contaminant * Wear proper PPE, including respiratory protection * Have something to sit or kneel on so do not have additional personnel exposure from sitting or kneeling on contaminated surface * Assure the torch is disconnected from gases before any work is performed * Pinch Points * Use of hand protection * Use of hand tools appropriate for the job * Slips/Trips/Falls * Awareness of the specific hazards * Organization of materials (housekeeping) * Walking around areas that are congested when possible * Walking around tripping hazards, when possible

25 HAZARD CORRECTIVE ACTION GENERAL MAINTENANCE (CONTINUED) * Ergonomics/Bending/Kneeling/ Lifting * Use proper lifting techniques * Ergonomic training to include proper lifting techniques

26 SECTION 5 - FAILURE MODE AND EFFECTS ANALYSIS FAILURE MODE AND EFFECTS ANALYSIS FRAMATOME TECHNOLOGIES Victor Oxy-acetylene Torch (Equipment Dismantlement) FAILURE MODE * Barrier placed between cutting operation and combustibles fails or is inappropriate EFFECT * Fire with potential to cause burns and related fire injuries to workers * Oxygen cylinder/valve/regulator fails * Injury to workers from being struck by projectiles from cylinder exploding, or from cylinder, valve, or regulator itself * Injuries to workers from fire/explosion due to materials in area (oil, grease) * Workers exposed to oxygen enriched atmosphere * Acetylene cylinder/valve/regulator fails * Injury to workers from being struck by projectiles from cylinder exploding, or from cylinder, valve, or regulator itself * Potential for fire causing burns and related fire injuries to workers * Potential for explosion causing injuries to workers * Pressure gauge fails (acetylene unstable at greater than 15 psig) * Potential for fire or explosion causing injuries to workers * Relief valve on regulator fails * Low pressure side of regulator builds up pressure with resultant rupture potential for injury to workers from regulator or pieces of regulator becoming projectiles * Hose ruptures/leaks/disconnects * Potential for worker exposure to acetylene or oxygen enriched atmosphere * Potential for fire or explosion with resultant injuries to workers

27 FAILURE MODE EFFECT * Flow Check valve fails * Potential for fire or explosion with resultant injuries to workers from oxygen and acetylene mixing inside the hoses or regulator * Flash Arrestor fails * Potential for fire or explosion with resultant injuries to workers from flashback reaching upstream equipment * O-ring on cone end of cutting attachment missing, torn, damaged (only one of two needs to be affected) * Damaged seating surface (cutting tip or torch head) * Cutting tip has too much capacity for the equipment * Potential for fire or explosion with resultant injuries to workers from flashback caused by premixing and leaks of oxygen and acetylene * Potential for fire or explosion with resultant injuries to workers from fire or flashback that may result * Potential for fire or explosion with resultant injuries to workers from flashback caused by overheating head because the tip has been starved or choked

28 SECTION 6 - TECHNOLOGY SAFETY DATA SHEET TECHNOLOGY SAFETY DATA SHEET FRAMATOME TECHNOLOGIES Victor Oxy-acetylene Torch (Equipment Dismantlement) SECTION 1: TECHNOLOGY IDENTITY Manufacturer s Name and Address: Framatome Technologies 3315 Old Forest Road PO Box Lynchburg, VA Emergency Contact: Ken R. Palazzi (804) Information Contact: Ken R. Palazzi (804) Date Prepared: Other Names: Oxy-fuel gas Torch Signature of Preparer: Operating Engineers National Hazmat Program 1293 Airport Road, Beaver, WV 25813, phone , fax Under cooperative agreement DE-FC21-95 MC 32260

29 SECTION 2: PROCESS DESCRIPTION The oxy-acetylene torch provides a thermal cutting technique to cut metal pieces. The torch burns the metal and coatings, producing smoke and fumes. The torch can be manipulated manually or it can be placed on a motorized track. The system consists of an oxygen and fuel supply (acetylene), regulators, hose, torch handle, and cutting attachment and tip. The torch handle is a set of gas tubes with control valves. One tube and valve controls the fuel supply and one tube and valve controls the oxygen supply. The handle is a means of control for the gas supply and the cutting apparatus attached to the handle mixes the oxygen and fuel gas. The elements of the torch handle are the control valves with internal reverse flow check valves, the body Y, the barrel and tubes, and the torch head. The control valves are installed in the body Y and the valve bodies are marked to distinguish between the two valves. The body of one valve has left-hand threads to accept the fuel gas hose and the other has right-hand threads to accept the oxygen hose. The barrel and inner oxygen tube unit is designed to keep the oxygen and fuel gases separated. A tube-within-a-tube design is used to allow the oxygen to flow through the inner tube and the fuel supply to travel through the interior barrel cavity. The torch head is threaded onto the barrel, creating a metal-to-metal seal. The oxygen is directed through the center hole in the head while the fuel supply passes through drilled orifices around the centered oxygen port. When the cutting attachment is connected, a gas-tight seal is made. The torch handle has internal reverse flow check valves to reduce the possibility of explosion or fire which may occur as a result of fuel gases and oxygen becoming mixed inside the hoses or regulators. Flashback arrestors are designed to prevent a flashback from reaching upstream equipment. The cutting attachment functions as a cutting torch. The cutting attachment consists of the cone end and coupling nut, the preheat oxygen control valve, the mixing chamber, the cutting oxygen lever and tube, and the cutting attachment head. The cone end and coupling nut permit easy attachment to the torch handle. O-rings allow continued separation of the oxygen and fuel gases. The center orifice of the cone end allows the passage of oxygen supply and the orifices around the oxygen port allow the fuel gas to travel to the mixing chamber in the lower tube of the cutting attachment. The preheat oxygen control valve controls the preheat oxygen supply from the regulator. The mixing chamber tube is where the oxygen and fuel gas are brought together to produce the desired preheating flame. The cutting oxygen lever and tube allows cutting oxygen to flow through the upper tube of the cutting attachment and the center port of the cutting attachment head. The cutting attachment head allows the oxygen and the mixed preheat gas to stay separated in the cutting operation and the cutting tip keeps the preheat gas mixture and cutting oxygen stream separated to provide flame characteristics needed for a particular cutting application. Cylinders of oxygen and acetylene are used to supply the gases for cutting. Oxygen and fuel pressure regulators are attached to the cylinder manifold outlets to reduce

30 SECTION 2: PROCESS DESCRIPTION high cylinder or supply pressures for cutting applications. The regulator consists of the inlet connection with filter, pressure adjusting screw, high pressure gauge, low pressure gauge, outlet connection, and relief valve. The high pressure gauge indicates the cylinder or supply pressure entering the regulator and the low pressure gauge indicates the delivery pressure from the regulator to the hose. The hose transports low pressure gas (maximum 200 psig) from the regulators to the cutting torch. Hoses are usually color-coded for gas service identification. Oxygen hose is usually green and the fuel hose is usually red. The hoses are flame retardant. SECTION 3: PROCESS DIAGRAMS Process diagram not available. SECTION 4: CONTAMINANTS AND MEDIA Smoke and fume are generated during thermal cutting with the oxy-acetylene torch. Consideration needs to be given to the contaminants of the metal being cut, any contaminants of coatings on the metal, and contamination in the area where the torch is being used for D&D activities. An air sampling plan will need to be developed, as appropriate for the site where the torch is used. SECTION 5: ASSOCIATED SAFETY HAZARDS Probability of Occurrence of Hazard: 1 Hazard may be present but not expected over background level 2 Some level of hazard above background level known to be present 3 High hazard potential 4 Potential for imminent danger to life and health A. ELECTRICAL (LOCKOUT/TAGOUT) RISK RATING: N/A Not part of this technology. B. FIRE AND EXPLOSION RISK RATING: 4 Heat, sparks, and flame present during thermal cutting have the potential to cause fire or explosion. When fire hazards present in the area cannot be moved, guards must be set up to contain heat, sparks, and slag. Acetylene used as the fuel gas for the cutting operation is a very dangerous fire hazard when exposed to heat, flame, or oxidizers. It is a moderate explosion hazard when exposed to heat or flame or by spontaneous chemical reaction. Oxygen itself is not flammable but it supports the burning process. Pure oxygen will drastically increase the speed and force with which burning takes place. C. CONFINED SPACE ENTRY RISK RATING: 1-4 Not part of this technology unless the specific location where the torch is being used is a confined space. Thermal cutting operations can present additional hazards in a confined space. Confined space entry and rescue procedures must be followed and

31 SECTION 5: ASSOCIATED SAFETY HAZARDS additional consideration given to the limited work space, hazardous atmosphere, slipping hazards, flammability, combustibility, and toxic fumes in relation to their ability to be caused by the thermal cutting process itself. D. MECHANICAL HAZARDS RISK RATING: 1 Assembling the cylinders and the cutting torch poses pinch points. E. PRESSURE HAZARDS RISK RATING: 4 The compressed gas cylinder presents a hazard and is discussed under "K" of this section. F. TRIPPING AND FALLING RISK RATING: 2 Hoses present potential hazards. G. LADDERS AND PLATFORM RISK RATING: 2 Not part of this technology but may be required for D&D activities. All regulations for working from ladders and platforms, including the OSHA scaffolding standard must be followed. H. MOVING VEHICLE RISK RATING: 2 Not part of this technology but may be required for D&D activities. All precautions and safety requirements for large pieces of equipment will need to be followed. For example, all moving vehicles should have working back-up alarms, warning lights, etc. I. BURIED UTILITIES, DRUMS, AND TANKS RISK RATING: N/A Not part of this technology. J. PROTRUDING OBJECTS RISK RATING: N/A Not part of this technology. K. GAS CYLINDERS RISK RATING: 4 The compressed gas cylinders of oxygen and acetylene account for one of the primary hazards associated with the oxy-acetylene torch. If the compressed gas cylinders are damaged, gas can escape with great force and the cylinder itself can explode causing injury to workers and possibly damaging property. One example of this type of hazard is called rocketing. The cylinder acts as a rocket if damaged or ruptured. The rocket (cylinder) can break through concrete walls or travel through open spaces. L. TRENCHING AND EXCAVATIONS RISK RATING: N/A Not part of this technology. M. OVERHEAD LIFTS RISK RATING: 2 Not part of this technology but may be required during D&D activities. All applicable standards and precautions must be followed for the type of equipment used. At a minimum, anyone in the work area should be wearing a hard hat. N. OVERHEAD HAZARDS RISK RATING: 2 May be part of this technology if the piece being cut is overhead. At a minimum, anyone working in the area should be wearing a hard hat. It needs to be assured that all workers in the area are aware of the overhead work being done and avoid the area when possible.

32 SECTION 6: ASSOCIATED HEALTH HAZARDS A. INHALATION HAZARD RISK RATING: 3 Fumes and gases produced by the thermal cutting process vary widely and are relative to the metal being worked, coatings on the metal, and contaminants inherent in the environment where the metal is located. B. SKIN ABSORPTION RISK RATING: 1 This would be dependent on the contaminants at the site and would be identified by the site characterization. C. HEAT STRESS RISK RATING: 1-4 Ambient conditions, work rates, and PPE levels must be considered. The worker may be subjected to an increase in heat stress due to the heat generated during thermal cutting operations. The sparking, flame, slag, and hot metal will add to the heat load. D. NOISE RISK RATING: 2 The technology presents a potential noise hazard. E. NON-IONIZING RADIATION RISK RATING: 4 The ultraviolet light produced by the thermal cutting process can damage the eyes. This can be in the form of a flash burn or after long term exposure, cataracts. Proper protection for eyes when performing cutting operations using the oxyacetylene torch is the welding helmet with the correct filter in place. The filter lenses and plates must meet the test for transmission of radiant energy as prescribed in ANSI Z87.1, Practice for Occupational and Educational Eye and Face Protection. Filter darkness needs to be chosen in compliance with OSHA 29 CFR Subpart Q Welding, Cutting, Brazing. Other workers in the area must wear safety glasses with an appropriate darkness rating. It is also recommended that dark clothing be worn to reduce reflection under the welding helmet. F. IONIZING RADIATION RISK RATING: 1-4 Not part of this technology, but may be associated with the area where D&D activities are taking place. G. COLD STRESS RISK RATING: 1 Technology does not produce a hazard, but ambient conditions need to be considered. H. ERGONOMIC HAZARDS RISK RATING: 3 During cutting operations, many ergonomic stressors can be placed on the body from working in awkward and static postures. There is also concern for the manual force and repetitive motions that may be required. In order to make a cut, workers may have to get into tight places by twisting themselves into place or by propping their bodies into awkward positions. Stresses occur from holding the head and arms in unnatural, fixed positions for long amounts of time. This often results in stiffness and soreness in the body. Overhead work can result in a condition know as shoulder tendonitis (inflammation of the tendons of the shoulder) and there is concern for the stress placed on the back from bending to cut pieces located on ground level. I. OTHER RISK RATING: N/A None noted at this time.

33 SECTION 7: PHASE ANALYSIS A. CONSTRUCTION/START-UP The set-up/start-up phase presents several hazards including pinch points, struck by hazards slips/trips/falls, muscular/back injury, and exposure to gases (oxygen and acetylene). B. OPERATION The operational phase presents several hazards including exposure to contaminant, muscular/back injury, pinch points, laceration hazards, slips/trips/falls, struck by hazards, exposure to noise, eye hazards (ultraviolet and infrared light), burn hazards, fire/explosion hazards, heat stress, and exposure to contaminants. C. MAINTENANCE The maintenance phase presents several hazards including pinch points, slips/trips/falls, muscular/back injury, and exposure to contaminants. D. DECOMMISSIONING The decommissioning phase presents several hazards, including exposure to the contaminant, pinch points, slips/trips/falls, and muscular/back injury. SECTION 8: HEALTH AND SAFETY PLAN REQUIRED ELEMENTS A. AIR MONITORING Fumes and gases produced by the thermal cutting process vary widely and are relative to the metal being worked, coatings on the metal, and contaminants inherent in the environment where the metal is located. Iron oxide, nickel, cadmium, zinc, lead, oxides of nitrogen, and carbon dioxide are examples of the types of inhalation hazards that may be present during thermal cutting operations. A sampling plan specific for the site and the pieces being cut will need to be developed. Noise monitoring will need to be conducted. B. WORKER TRAINING Training that may apply in this case may include but not be limited to: HAZWOPER (Hazardous Waste Operations and Emergency Response), HAZCOM (Hazard Communication), Respiratory Protection, PPE (Personal Protective Equipment) Training, Hearing Conservation, Fire Extinguisher, Heat Stress, Working with Compressed Gases, non-ionizing radiation training, Ergonomics (proper lifting, bending, stooping, kneeling), specific training for equipment operation, CPR/First Aid/Emergency Response/Bloodborne Pathogens, Lockout/Tagout, Hand Signal Communication, and Construction Safety (OSHA 500) and/or General Industry Safety (OSHA 501).

34 SECTION 8: HEALTH AND SAFETY PLAN REQUIRED ELEMENTS (CONTINUED) C. EMERGENCY RESPONSE Emergency response planning for a site needs to assure adequate coverage for hazards described in the TSDS. Having at least one person per shift trained in CPR and first aid is recommended. D. MEDICAL SURVEILLANCE Evaluation of personnel s general health with emphasis on the cardiovascular and respiratory system and the back. In addition, medical surveillance as required by OSHA standards must be conducted. Initial and annual audiograms may be required. E. INFORMATIONAL PROGRAM Workers must be trained in specific operation of equipment before use. SECTION 9: COMMENTS AND SPECIAL CONSIDERATIONS Only personnel who have been adequately trained in the operation of this technology should be permitted to operate and/or work with the equipment.

35 SECTION 7 - EMERGENCY RESPONSE/PREPAREDNESS The use of the Oxy-acetylene Torch may be applicable to use in an emergency response situation to access the area where the emergency has occurred or to cut up pieces that need to be moved. It would not be able to be used if there was the potential for a flammable or explosive atmosphere. Emergency response/preparedness must be part of every hazardous waste site safety and health plan. In addition to credible site emergencies, site personnel must plan for credible emergencies in connection with the oxy-acetylene torch. All precautions used when responding to an emergency situation at the site will apply. Before entering an area where the oxy-acetylene torch is being used, the equipment needs to be completely shut down (de-energized: oxygen and acetylene sources turned off). This technology does not appear to present conditions that could lead to out-of-theordinary emergency. Consideration does, however, need to be given to the fire hazards associated with thermal cutting and the hazards associated with the use of pressurized gases. SECTION 8 - REGULATORY/POLICY ISSUES The site safety and health personnel where the Framatome Oxy-acetylene Torch is being used need to be concerned with safety and health regulations applicable to the issues discussed above. Regulations that apply may be divided into four categories. Core requirements are those regulations that would apply to any hazardous waste work site, regardless of the type of job. Technology specific requirements are those regulations that apply due to the specific technology being used. Special requirements are standards and policies that are specific to the technology itself and are required by reference in a regulation. Best management practices are not required but are recommended by organizations such as the American National Standards Institute (ANSI), NIOSH, Department of Energy (DOE), National Fire Protection Association (NFPA), etc. These regulations/standards may include but not be limited to the following: Core Requirements: OSHA 29 CFR Housekeeping OSHA 29 CFR Sanitation ( (a)(3) covers housekeeping) OSHA 29 CFR 1926 Subpart Z Toxic and Hazardous Substances OSHA 29 CFR 1910 Subpart Z Toxic and Hazardous Substances OSHA 29 CFR Hazard Communication

36 OSHA 29 CFR Hazard Communication OSHA 29 CFR Hazardous Waste Operations and Emergency Response OSHA 29 CFR Hazardous Waste Operations and Emergency Response Occupational Safety and Health Act 1970(5)(a)(1) General Duty Clause Technology Specific Requirements: OSHA 29 CFR 1910 Subpart Q Welding, Cutting and Brazing OSHA 29 CFR 1926 Subpart J Welding and Cutting OSHA 29 CFR The Control of Hazardous Energy (Lockout/Tagout) 29 CFR Ventilation OSHA 29 CFR Ventilation OSHA 29 CFR Fire Protection OSHA 29 CFR Portable Fire Extinguishers OSHA 29 CFR Compressed Gases (general requirements) OSHA 29 CFR Acetylene OSHA 29 CFR Respiratory Protection OSHA Respiratory Protection OSHA 29 CFR Occupational Noise Exposure OSHA 29 CFR Occupational Noise Exposure OSHA 29 CFR Eye and Face Protection OSHA 29 CFR Eye and Face Protection OSHA 29 CFR Personal Protective Equipment OSHA 29 CFR General Requirements (Personal Protective Equipment) OSHA 29 CFR First Aid and Medical Attention OSHA 29 CFR Medical Services and First Aid

37 OSHA 29 CFR Toxic and Hazardous Substances Special Requirements: ANSI Z Safety in Welding and Cutting published by the American Welding Society 49 CFR Parts Subchapter C Hazardous Materials Regulations ANSI Z48.1 Method for Marking Portable Compressed Gas Containers to Identify the Material Contained ANSI B Compressed Gas Cylinder Valve Outlet and Inlet Connections ANSI Z Practice for Occupational Eye and Face Protection NFPA Welding and Cutting Oxygen Fuel Gas System Compressed Gas Association Pamphlet G Compressed Gas Association Pamphlet P Best Management Practices: ACGIH Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices NIOSH Revised Lifting Equation, 1994 In addition to the above regulations and policies, it is imperative that all workers have appropriate and adequate training for the task and associated safety and health hazards. Training that would be required may be divided into four categories. Core training is that which is required for anyone entering a hazardous waste site to perform work, regardless of the type of job. Technology specific training is that training which is specific to the technology and required by safety and health standards. Special training is that which is specific to the technology to assure the worker is adequately trained for the task, but is not necessarily required by safety and health standards. Best management practices are trainings that while not mandated by health and safety standards, provide information and knowledge to the worker that will allow the worker to perform his/her job safely. Training to be applied for the Framatome Oxy-acetylene Torch may include but not be limited to: Core Training Requirements: HAZWOPER HAZCOM

38 Technology Specific Training: Hearing Conservation Respiratory Protection Personal Protective Equipment Lockout/Tagout Fire Extinguisher Special Training: Job specific training for equipment operation Best Management Practice Training: Ergonomics (proper lifting, bending, stooping, kneeling) Heat stress (learning to recognize signs and symptoms) Working with Compressed Gases Non-ionizing Radiation CPR/First Aid/Emergency Response/Blood-borne Pathogens Hand Signal Communication Construction Safety (OSHA 500) and or General Industry Safety (OSHA 501) SECTION 9 - OPERATIONAL CONSIDERATIONS & RECOMMENDATIONS Recommendations made here for improved worker safety and health take into consideration the operation of the Oxy-acetylene Torch. Specific recommendations include: Workers must be aware of the tripping hazards associated with hoses that are necessary to operate the equipment. Keeping these as orderly as possible in compliance with good housekeeping regulations will help avoid injury due to tripping. The operators need to have training in ergonomics to assure proper techniques in lifting, bending, stooping, twisting, etc. during equipment setup, operation, maintenance and decontamination.

39 During cutting operations, many ergonomic stressors were placed on the body from working in awkward and static postures. There is also concern for the manual force and repetitive motions that may be required. In order to make a cut, the workers had to get into tight places by twisting themselves into place or by propping their bodies into awkward positions. Stresses occur from holding the head and arms in unnatural, fixed positions for long amounts of time. This often results in stiffness and soreness in the body. Overhead work can result in a condition know as shoulder tendonitis (inflammation of the tendons of the shoulder) and there is concern for the stress placed on the back from bending to cut pieces located on ground level. Figure 3. Ergonomic stressors are created by awkward positions required to cut part of a tank lying at ground level. It is recommended that pre-planning to place the operator in the best position for ergonomics and safety be done before operations begin and periodically as the job progresses. Workers should not place themselves in positions that cause the body discomfort but since many times these awkward postures are unavoidable, workers should, at the first sign of soreness, stop and stretch. Workers may need to be included in a hearing conservation based on the noise levels specific to the location where the torch is being used. Differences in noise exposure will be based on the location of the worker in relation to the cutting operation and the amount of time the worker spends there. A sampling plan will need to be developed to address the site specific conditions where the thermal cutting operation takes place. A sampling plan should also take into consideration the work environment since the noise levels may increase or decrease based on the construction of the enclosure where the cutting operation is taking place. Air sampling for welding fume, as total particulate, nitrogen dioxide, carbon monoxide, carbon dioxide, and formaldehyde did not show any exposures above the OSHA PEL or the ACGIH TLV. Smoke and fumes, however, were visible during the operation of the oxy-acetylene torch. The time spent in the work area, the distance from the actual cutting operation, and ventilation in the work area will affect an individual worker s exposure level. A complete sampling plan will need to be developed to account for the site specific conditions including contaminants specific to the D&D project. The metal being cut with the torch needs to be taken into consideration and contaminants specific to the metal and any coatings on the metal need to be monitored. Heat stress is a hazard for all workers. When the worker must use certain types of PPE the heat stress on the worker is increased. This is a concern because during thermal cutting operations flame-resistant clothing must be worn, sometimes in addition to PPE necessary to protect against other contaminants in the area where the cutting operation is being conducted. In addition, there may be an increase in heat stress due to the heat generated from sparks, flame, slag,