26-2 Hazard Analysis

Principal unique hazards associated with open burn/open detonation include:

a. Physical Hazards

(1) Description: Burning ignition systems may not reliably ignite the waste material. The wick or flame used to ignite the waste material may be temporarily extinguished by moisture or wind, only to re-ignite shortly thereafter. The delay in ignition may cause workers to believe the burning ignition system has failed, and approach the burn area to investigate, at which time detonation may occur.

Control: Proper training and experience for personnel is critical. Design and construction of reliable, remote, intrinsically-safe ignition systems is required. CONTROL POINT: Design, Construction, Operations, Maintenance

(2) Description: An explosion may damage the pit construction and injure any workers in the vicinity if more than the design quantity or type of explosives is detonated in one charge.

Control: The design quantities and types of explosives must be known and never exceeded. Control procedures must be rigorously followed. Uneven distribution of wastes containing explosives can create an excessive density of explosive material, resulting in explosive conditions. CONTROL POINT: Operations

(3) Description: Sharp and hot fragments and residue may be present when entering the pit after prior burns or detonations. Workers may also be exposed to potential wall collapse, or confined-space entry hazards.

Control: Workers should wear appropriate personal protective equipment (PPE). Walls must be shored to prevent collapse. Prior to each entry into the pit, a competent person may need to inspect its structural integrity. CONTROL POINT: Design, Construction, Operations

(4) Description: Hazards inherent in open burn and open detonation techniques may involve the handling of unstable waste materials, such as unusable munitions and explosive materials. Workers handling these materials face the risk of these materials auto-detonating, especially if the explosives have become unstable due to age or other factors.

Control: Transportation of these materials to the site and the handling of materials at the site should only be performed by persons specifically trained in detonation and disposal techniques. The OE CX should be consulted prior to any handling or movement of explosive items, or of soils/materials significantly contaminated with explosives. CONTROL POINT: Operations

(5) Description: One or repeated explosions may cause fragmentation of concrete or cinder block walls of buildings or structures at or near the detonation area, particularly if large quantities of explosive materials are detonated.

Control: The amount of waste materials to be detonated at any one time should be limited based on the known effects of the explosives. Larger volumes of wastes should be subdivided and detonated in a series of smaller explosions. The location of the treatment facility should be carefully chosen so that sensitive structures are not present or nearby. Structures constructed for shelter or containment of the explosions or burnings should be designed to adequately withstand the expected use of the system. CONTROL POINT: Design, Operations

(6) Description: During site activities, workers may be exposed to direct and indirect sunlight and the corresponding ultraviolet (UV) radiation. Even short-term exposure to sunlight can cause burns and dermal damage. Exposure to hot and humid conditions may also result in heat stress, which can manifest itself as heat exhaustion and heat stroke.

Control: Exposure to direct and indirect sunlight should be minimized where possible in the summer months. Workers can minimize direct sun exposure by wearing long-sleeve shirts and full-length pants, and by applying UV barrier sunscreen. If possible, the work and break areas should be shaded. Exposure to heat stress conditions can be minimized by taking frequent breaks, drinking adequate fluids, and performing work during the early morning and late afternoon hours. CONTROL POINT: Construction, Operations

b. Chemical Hazards

(1) Description: If detonation or burning fails to fully neutralize the material, workers entering the burn pit may be exposed to the material or the unreacted material may be carried downwind, exposing workers in the area. Heavy metal primer materials (metal azides and silver compounds) and residual explosive components (e.g. nitroglycerin) may cause heart arrhythmias, headaches, and other physical effects.

Control: Personnel should remain upwind of the pit during burning and detonations. Appropriate personal protective equipment (PPE), as determined by a qualified health and safety professional, should be used to enter the pit after burning and explosions. Examples of appropriate PPE include steel shank boots, coveralls to protect from dermal contact, nitrile or butyl gloves if soil handling is expected, and an appropriate air-purifying respirator if fumes or smoke are present. Expertise in detonations and burning, including accelerants or fuels or initiator explosives, should be used to assure the maximum consumption of the explosives or materials to be burned. CONTROL POINT: Design, Operations

(2) Description: Workers who enter the pit may be exposed to an atmosphere containing a toxic materials or to one which is oxygen deficient.

Control: Entry into the trench may require testing of the atmosphere within the trench to determine the level of airborne contaminants and the level of oxygen present. Workers should also adhere to pre-established confined-space entry protocols, which may necessitate the use of PPE, such as an air-purifying respirator equipped with an organic vapor cartridge or a supplied-air respirator. CONTROL POINT: Operations, Maintenance

c. Radiological Hazards

Description: NONAPPLICABLE

Control: NONAPPLICABLE

d. Biological Hazards

Description: NONAPPLICABLE

Control: NONAPPLICABLE