Académique Documents
Professionnel Documents
Culture Documents
1, 2001
This study presents an evaluation of the risks due to the physical hazards associated with two
remedial alternatives for a former chemical manufacturing facility in New Jersey. Both the
on-site and off-site risk of work-related fatalities during remedy implementation and the risks
of accident or accident-related fatalities during the off-site transport of site-related materials
were evaluated. The two remedial alternatives evaluated were on-site containment and excavation with off-site incineration. The risk of at least one fatality due to a work-related accident was estimated for on-site activities associated with each remedial alternative, and for
off-site incineration. The risks of at least one accident and of one accident-related fatality
were calculated with accident and fatality data from the U.S. Department of Transportation.
In addition, the risk of at least one accident that might potentially affect a natural resource
(e.g., river, lake, or national park) was evaluated. This evaluation indicates that the risk of a
work-related fatality is over an order of magnitude higher, and the risk of an accident or accidentrelated fatality is over three orders of magnitude higher, for the excavation/off-site incineration remedial alternative than for the on-site containment alternative. Overall, this study indicates that the physical hazards associated with excavation and off-site incineration are much
greater than those associated with on-site containment for this site. Therefore, if a choice between the two remedial alternatives were to be made based solely on physical hazards and accident risk, the on-site containment alternative would be more protective of human health
and the environment than the excavation/off-site incineration alternative.
KEY WORDS: Physical hazard; work-related fatality; accident risk; evaluation of remedial alternatives
1. INTRODUCTION
53
54
or capping, may be higher than those associated with
chemical exposure at hazardous waste sites. Cohen et
al.(4) compared the risk of worker fatality calculated
by Hoskin et al. with the cancer risks incurred by residents living near a hazardous waste site using the
Years-of-Potential-Life-Lost (YPLL) metric. They
found that the YPLL for remediation workers was
higher than that for the nearby residents. Given the
tremendous number of man-hours that are required
to implement some of the longer term remedial options in addition to the significant use of heavy machinery and, in some cases, the nations highway and
rail system (for transporting contaminated material),
it would seem that in many instances the physical hazards of remedy implementation might significantly
exceed the chemical risk. Therefore, to fully comply
with the spirit of the NCP, a quantitative physical hazard evaluation should be an important component of
the risk management decision-making process for
remedy selection at Superfund sites.
A complete evaluation of physical hazards
would consider on-site remediation activities and any
off-site treatment or disposal activities involved in the
remedy. On-site physical hazards consist of worker injuries and fatalities, and the probability of these incidents occurring can be estimated in a fairly straightforward manner. Consideration of off-site activities
can become very complex. If a significant amount of
material must be transported to (e.g., clean fill) or
from (e.g., contaminated debris) the site, then worker
and nonworker (e.g., pedestrians) transportation accidents and fatalities must be considered. These could
consist of road, rail, and shipping transportation incidents. In addition, the potential for spills of contaminated materials into heavily populated or pristine
areas would need to be considered. Additionally, one
must consider worker accidents and fatalities associated with treatment of the contaminated material at
an off-site location (landfilling, incineration, etc.).
This article presents a case-study comparison of
the physical hazards associated with two different remedial alternatives for a former 2,4,5-Trichlorophenoxyacetic acid manufacturing facility in New Jersey. The
primary purpose of remediation at this site is to reduce exposures to dioxin-contaminated soil and other
site material (building walls, scrap, etc.). The estimated
amount of dioxin-contaminated material ranges from
94,720 to 167,500 tons. The first alternative, which is
the USEPA-approved remedy for the site, involves
on-site containment and capping of contaminated material. The second involves excavation, transportation,
and off-site incineration of contaminated material.
55
Excavation/off-site incineration
Installation of a new bulkhead sheet piling around the laid-lock perimeter
of the site
Dewatering of the site
Excavation of site soil
Demolition of structures
Decontamination of scrap metal
Sorting and sizing of debris prior to shipment
Importation and placement of clean fill
Transportation of excavated soil and other site-related material to
incinerator in Coffeyville, KS
Incineration of site-related material
mentation. It was also assumed that site-related material would be transported to Coffeyville via rail; recyclable metals would be transported to a local recycling
center via truck; and clean fill would be imported from
a nearby location via truck. For this alternative, the volume of soil to be excavated (i.e., the volume of soil and
other site-related material that exceeds a cleanup
level of 1 ppb) is 97,374 yd3, or 167,500 tons.
2.1. Evaluation of Work-Related Fatality
The source of work-related fatality data used in
this analysis is Causes of Death in the Workplace,(2)
which contains work-related fatality rates for several
occupations by Standard Industrial Classification
(SIC) job title. This book compiles the work-related fatality rates from the Bureau of Labor Statistics Supplementary Data System (SDS), which contains selected
states worker compensation files. While Leigh(6) does
not present the work-related fatality rates specifically
for hazardous waste site remediation workers, fatality
rates are presented for the trades and occupations that
are needed to implement a remedial alternative. While
other sources of work-related fatality data exist,(7,8)
these sources were not used because they do not contain fatality rates for each specific trade and occupation needed, and they are not substantially different
than those from Leigh.
To calculate the probability of at least one workrelated fatality, the methods presented by Hoskin et
al.(3) were used. When the probability of failures, in
this case fatalities, is small and the number of trials
(opportunities for fatality) is large, the Poisson probability distribution can be used to model the number
of deaths per year given the expected number of
deaths per person-year (m).(3) The expected number
of deaths can be calculated as
m 5
^H
i51
Fi,
(1)
2m
. (2)
56
On-site containment
SIC code
11
85
245
245
245
245
394
424
421
436
436
436
441
441
481
666
715
751
751
780
Excavation/off-site
incineration
Job category
Fatality ratea
Projected
person-yearsb
Weighted
fatality ratec
Projected
person-yearsd
Weighted
fatality ratec
Engineering Staff
Safety officer
Project manager
Superintendent
Company employees
USEPA representative
Timekeeper
Crane operator
Cement finisher
Pile driver
Equipment operator
Treatment plant operator
Foreman
Piling foreman
Mechanic
Incinerator worker
Truck driver
General laborer
Decon attendant
Railroad worker
3.28E-05
0.00E100
5.94E-05
5.94E-05
5.94E-05
5.94E-05
3.70E-06
1.77E-04
6.60E-05
2.16E-04
2.16E-04
2.16E-04
1.17E-04
1.17E-04
5.40E-05
2.33E-04
3.88E-04
3.29E-04
3.29E-04
7.62E-04
7.50
2.15
2.15
2.15
8.50
2.95
2.15
0.35
0.31
1.15
8.68
2.19
3.68
0.22
2.06
NA
1.06
21.4
1.30
NA
3.52E-06
0.00E100
1.83E-06
1.83E-06
7.22E-06
2.50E-06
1.14E-07
8.85E-07
2.92E-07
3.54E-06
2.68E-05
6.76E-06
6.16E-06
3.60E-07
1.59E-06
NA
5.89E-06
1.01E-04
6.11E-06
NA
11.7
3.35
3.35
3.35
13.3
4.60
3.35
0.35
NA
0.86
13.6
3.61
5.75
0.16
3.21
3,150
2.41
33.4
2.03
74.2
1.15E-07
0.00E100
5.98E-08
5.98E-08
2.36E-07
8.21E-08
3.73E-09
1.86E-08
NA
5.57E-08
8.78E-07
2.34E-07
2.02E-07
5.67E-09
5.20E-08
2.20E-04
2.81E-07
3.30E-06
2.00E-07
1.70E-05
70
1.23E-02
1.22E-02
3,330
8.09E-01
5.55E-01
Note: SIC 5 standard industrial classification; NA 5 not applicable to the remedial alternative.
a
Fatality rates as listed in Leigh.(6)
b
Person-year estimates based on standard engineering practices.
c
Weighted fatality rate is (percent of total person-years) 3 (fatality rate).
d
Person-year estimates based on standard engineering practices and volume of soil to be excavated, transported, and incinerated.
e
Expected number of fatalities is (sum of the weighted fatality rates across job category)/(total projected person-years).
f
Probability of at least 1 fatality is 1 2 exp[2(expected number of fatalities per person-year)].
presents the job-specific person-year estimates, the jobspecific fatality rates, and the probabilities of at least
one fatality for these two alternatives. In addition,
Fig. 1 presents the probabilities for at least one workrelated fatality for the two remedial alternatives.
2.2. Evaluation of Transportation-Related
Fatalities and Accidents
In addition to the work-related fatalities for all
worker categories, the physical hazards associated
with other endpoints specifically related to transportation, such as vehicle accidents, fatalities during vehicle accidents, and accidents that could affect natural resources, were evaluated. To estimate the total
57
ers, truck and rail passengers, drivers of other vehicles involved in the collision, and pedestrians. Based
on the fatality data, 96% of railroad fatalities involved persons not employed by the railroad, and
47% involved highway rail-crossing incidents.(10)
The probability of vehicle accidents in an area of
natural resource importance during remedy implementation can also be estimated. For the purposes of
this analysis, a natural resource is defined as a major
water body, state/national park, or state/national forest. Any form of transport that brings site-related material within 0.5 mile of a natural resource is assumed
to constitute a potential scenario in which a vehicle
accident could affect a natural resource, and the human and ecological receptors associated with it. The
0.5-mile radius was selected because it is the standard
radius of effect used in transportation risk assessment.(11213) The per-mile accident rates used to evaluate accidents in natural resource areas are the same
as those used for all accidents. The exception is that
the number of miles used for this endpoint is equal to
the total number of miles the vehicle travels through
a natural resource area, rather than the total mileage
per trip.
The only significant volume of transportation associated with the on-site containment remedial alternative involves the transport by truck of groundwater
residuals to a landfill, and of scrap metal to a recycling center. While a small amount of residual material will have to be incinerated (,1%), this amount is
58
Scenario
Total
mileage
(miles)
Mileage
Expected number
in natural
of accidents
resource
Expected number
in a natural
areas
Accident rate
of accidents
resource area
(miles) (accidents/mile)a,b
(accidents)c
(accidents)c
Risk of
at least 1
accidentd
Risk of at
least 1 accident
in a natural
resource aread
8,480
NA
1.28E-09
1.37E-09
4.68E-05
1.11E-04
1.09E-05
NA
4.68E-05
1.11E-04
1.58E-04
1.09E-05
NA
1.09E-05
1.37E-09
1.37E-09
3.43E-06
3.64E-04
3.95E-06
5.14E100
NA
NA
1.77E100
3.64E-04
3.95E-06
9.94E-01
9.94E-01
NA
NA
8.29E-01
8.29E-01
Note: NA 5 Not applicable because no natural resources are located along route.
a
Accident rate for any type of vehicle accident is mileage-weighted rate based on rates for each state or each railroad line.
b
Accident rate for accidents involving potential natural resource impacts same as those for total accidents. Trip mileage includes areas of
route near a surface water body, state/national park, or state/national forest.
c
Expected number of accidents is (accident rate) 3 (total mileage) or (accident rate) 3 (mileage in natural resource areas).
d
Risk of at least 1 accident is 1 2 exp[2(expected number of accidents)] and 1 2 exp[2(expected number of accidents in a natural resource area)].
site containment alternative. This remedial alternative would require over 6.5 million man-hours, or
3,330 person-years to implement. Conversely, the onsite containment alternative would require approximately 140,000 man-hours, or 70 person-yearsonly
2% of the time needed for the excavation/off-site incineration alternative. The largest contribution to the
total person-years needed for the excavation/off-site
incineration alternative is from the incinerator workers, who contribute almost 95% of the total personyears. Therefore, the primary cause for the large
number of person-years necessary for this remedial
Table IV. Calculation of Risk of Transportation-Related Fatalities for the Two Remedial Alternatives
Accident fatality rate
(deaths/mile)a
Expected number
of fatalities (deaths)b
Risk of at least
1 fatalityc
36,560
80,736
7.76E-10
1.63E-09
2.84E-05
1.32E-04
2.84E-05
1.32E-04
1.60E-04
1.63E-09
1.63E-09
1.65E-06
4.33E-04
4.69E-06
2.47E100
4.33E-04
4.69E-06
9.16E-01
9.16E-01
Scenario
On-site containment alternative
Waste to landfill
Metal to recycler
Total
Total mileage
(miles)
Accident rate for any type of vehicle accident is mileage-weighted rate based on rates for each state or each railroad line.
Expected number of accidents is (accident fatality rate) 3 (total mileage).
c
Risk of at least 1 fatality is 1 2 exp[2(expected number of fatalities)].
b
59
Fig. 3. Summary of transportation-related accident fatalities associated with each remedial alternative.
60
probability of these events occurring during the excavation/off-site incineration alternative is at least
5,000 times greater than in the on-site containment
remedial alternative. Also, the probability of these
events occurring during the excavation/off-site incineration alternative is over 50%, a very high likelihood caused by the large number of trips involved.
Hence, it is clear that the excavation/off-site incineration alternative would be associated with a significantly greater number of deaths and accidents.
It is also important to note that trucking the soils
to the incinerator would not significantly decrease
the risk of fatality or accident. In fact, the risk of at
least one accident occurring during truck transport of
site-related materials to the incinerator is higher than
that for rail transport. Assuming the same mileage
per trip, it would take 7,614 one-way, 22-ton truck
trips to the incinerator to haul the entire tonnage of
site-related material to the incinerator. Using an
overall accident rate for the United States of 9.49 3
1027 accidents per mile per year,(9) this gives an accident risk of over 99% and an expected number of accidents of 10.5.
Finally, it should be noted that while the on-site
containment alternative can be implemented over a
relatively short time frame, the excavation/off-site incineration alternative would require several years to
complete. Based on an incinerator burn rate of 30
tons/day, 5,580 days or 15.3 years of continuous 24hour/day burning would be required to incinerate all
the site-related material. Given the inherent scheduling conflicts with rail transportation, the storage limitations of the incinerator, and periods of incinerator
inoperation, it is likely that 40 years or more might be
required to incinerate all the site-related material. In
short, not only would more total fatalities occur during the implementation of the excavation/off-site incineration remedial alternative, they would continue
to occur for a time period far beyond the time interval necessary to complete the on-site containment remedial alternative.
The actual numbers of chemical spills and catastrophic accidents were not considered here but
could be quantified. While the chances of such incidents occurring under the on-site containment alternative are minimal, there are several plausible scenarios under which persons or natural resources
could be acutely exposed to site-related material during the shipment of over 100,000 tons of highly contaminated material across seven states. Other accidents or releases could also occur as a result of
incinerator failure.
61
ated with the excavation of site soil, transportation, and
off-site incineration were much higher than those associated with on-site containment. Thus, the on-site containment alternative is more protective of worker
health and safety, and is much less likely to lead to a potential accidental release of contaminated material offsite than the off-site incineration alternative.
REFERENCES
1. U.S. Environmental Protection Agency (USEPA). (1988).
Guidance for conducting remedial investigations and feasibility
studies under CERCLA (USEPA 540/G-89/004). Washington,
DC: Office of Emergency and Remedial Response.
2. U.S. Environmental Protection Agency (USEPA). (1991).
Risk assessment guidance for Superfund: Vol. 1. Human health
evaluation manual (Part C, Risk evaluation of remedial alternatives) Interim. (PB92-963334). Washington, DC: Office of
Emergency and Remedial Response.
3. Hoskin, A. F., Leigh, J. P., & Planek, T. W. (1994). Estimated
risk of occupational fatalities associated with hazardous waste
site remediation. Risk Analysis, 14, 10111017.
4. Cohen, J. T., Beck, B. D., & Rudel, R. (1997). Life years lost at
hazardous waste sites: Remediation worker fatalities vs. cancer deaths to nearby residents. Risk Analysis, 17, 419425.
5. Mar, T., Frost, F., & Tollestrup, K. (1993). Physical injury risk
versus risk from hazardous waste remediation: A case history.
Regulatory Toxicology and Pharmacology, 17, 130135.
6. Leigh, J. P. (1995). Causes of death in the workplace. Westport,
CT: Quorum Books.
7. U.S. Bureau of Labor Statistics. (1994). Census of fatal occupational injuries. Washington, DC: Author.
8. U.S. Bureau of Labor Statistics. (1995). Census of fatal occupational injuries. Washington, DC: Author.
9. U.S. Department of Transportation. (1996). Highway statistics
1995. Washington, DC: Federal Highway Administration.
10. U.S. Department of Transportation. (1996). Accident/incident
bulletin no. 164. Calendar year 1995. Washington, DC: Federal
Railroad Administration.
11. U.S. Department of Transportation. (1990). Present practices of
highway transportation of hazardous materials (FHWA-RD-89018). Washington, DC: Federal Highway Administration.
12. Mills, G. S., & Neuhauser, K. S. (1999). Statistical evaluation of
population data for calculation of radioactive material transport accident risks. Risk Analysis, 19, 613619.
13. Mills, G. S., & Neuhauser, K. S. (1998). Truck transport of
RAM: Risk effects of avoiding metropolitan area. In Proceedings of the 12th International Conference on the Packaging and
Transportation of Radioactive Materials (PATRA 98). Paris,
France.
14. Leigh, J. P. (1985). Fatal occupational injuriesTexas, 1982.
Morbidity and Mortality Weekly Register, 34(10), 130134, 139.
15. Meng, R. (1991). How dangerous is work in Canada? Estimates of job-related fatalities in 482 occupations. Journal of
Occupational Medicine, 33, 10841090.