OPERATING ENGINEERS NATIONAL

HAZMAT PROGRAM
INTERNATIONAL ENVIRONMENTAL TECHNOLOGY &
TRAINING CENTER

TRI TOOL, INC.

Split Frame Clamshell
(Equipment Dismantlement)

HUMAN FACTORS ASSESSMENT

JANUARY 1999
 TRI TOOL, INC.
SPLIT FRAME CLAMSHELL
TABLE OF CONTENTS

ACKNOWLEDGMENTS ..................................................................................... iii

EXECUTIVE SUMMARY .................................................................................... iv

SECTION 1 SUMMARY
Technology Description ..................................................................................1
Key Results ....................................................................................................4

SECTION 2 SYSTEM OPERATION ....................................................................5

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 ...............................................................................12

SECTION 4 JOB SAFETY ANALYSIS (JSA) ....................................................13

SECTION 5 FAILURE MODES AND EFFECTS ANALYSIS (FMEA) ................18

SECTION 6 TECHNOLOGY SAFETY DATA SHEET (TSDS) ..........................19

SECTION 7 EMERGENCY RESPONSE/PREPAREDNESS ............................27

SECTION 8 REGULATORY POLICY ISSUES

Core Requirements.......................................................................................27
Technology Specific Requirements ..............................................................27
Best Management Practices.........................................................................29
Core Training Requirements.........................................................................29
Technology Specific Training........................................................................29
Special Training............................................................................................29
Best Management Practice Training.............................................................29
 TABLE OF CONTENTS
(continued)

SECTION 9 OPERATIONAL CONSIDERATIONS AND

RECOMMENDATIONS ................................................................................30

APPENDIX A - REFERENCES..........................................................................35
APPENDIX B - INDUSTRIAL HYGIENE DATA .................................................36
APPENDIX C - ACRONYMS .............................................................................39
 ACKNOWLEDGMENTS

The human factors assessment of the Tri Tool Inc. Split Frame Clamshell 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

David Curry Operating Engineers Local Union 280
 EXECUTIVE SUMMARY

The Tri Tool Split Frame Clamshell 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 clamshell. The Tri Tool Split Frame Clamshell is a
commercially available technology and has been used for various projects at locations
throughout this country.

While the split frame clamshell 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 clamshell are addressed
in this report and although not addressed in this summary, the specific hazards involved
in D&D activities need to be addressed prior to the start of the project.

The Tri Tool Split Frame Clamshell is a pipe lathe which employs a split rotary bearing
design that can be divided into two or more sections (depending on the size of the
clamshell). The clamshell requires minimal axial or radial clearances. The sections are
placed around the outside of the pipe/tube to be cut and bolted together. The rotating
cutting heads then cut either a straight or beveled cut from the outside diameter (O.D.)
inward. The clamshell clamps completely around the O.D. of the pipe with clamp pads
and jackscrews to provide a stable and secure clamp-up.

Clamshells are designed to cut pipe from ¼-inch to 60-inches in diameter. This is
accomplished by having clamshells of varying sizes and incorporating an adjustable
O.D. mounting system, as required, to fit the pipe diameter. The clamshell also features
an enclosed drive gear and bearing surface and a multi-positionable motor mount.
Additional features of the Split Frame Clamshell, which may vary depending on the size
of the clamshell, include internal counterbore machining and worm drive tool modules to
reduce vibration and extend tool bit life.

The automatic feed star wheels and adjustable slideways provide incremental tool bit
feed for controlled cut depth. The star wheels mount on the rotating face of the
clamshell and carry the tool bits within the tool holder section. The tool bit is fed into the
pipe/tube at a fixed revolution of the head stock with one tripper pin assembly engaged.
Multiple trippers increase the total feed of the tool bit per revolution. The star wheels
provide 0.0025-inch of radial feed per revolution. The tool bits are carbide cutting bits.

The Split Frame Clamshell can be pneumatically, hydraulically, or electrically powered.

Pneumatic power provides the maximum power per unit weight, electric powered are for
light duty machining, and hydraulic motors provide the maximum power and speed
range capabilities. Dual drives can be fitted for additional power and machining
capabilities. The clamshell used during the testing demonstration was pneumatically
powered.

The operator control for the Split Frame Clamshell is located on the shaft of the multi-
positionable motor mount. The on-off control is a lever mechanism designed for four-
finger operation. It works as a “dead man” switch, shutting down the clamshell if
pressure is released off the lever.

During the assessment sampling was conducted for dust and noise and general
observational techniques were conducted for ergonomics. General observational
techniques for ergonomics showed the potential for ergonomic stressors during setup,
operation, maintenance, and decontamination of the clamshell. Awkward postures that
are assumed by the operator, because of the way the clamshell has to be placed on the
pipe/tube to be cut, is the main ergonomic concern.

Area dust monitoring was conducted during the operation of the split frame clamshell.
The area dust samples showed results of <0.072 mg/m3 and <0.157 mg/m3. These
results are all below the OSHA PEL of 15 mg/m3 and the ACGIH TLV of 10 mg/m3.
Dust generation does not appear to be a concern during the operation of the split frame
clamshell. However, since the time spent in the work area, the distance from the actual
cutting operation, and ventilation in the work area may affect an individual worker’s
exposure level, a monitoring plan will need to be developed to account for the site
specific conditions where the split frame clamshell is being used. A complete air
sampling plan for a site will need to be developed to include not only dust but other
contaminants specific to the D&D project.

Noise monitoring conducted during operation of the split frame clamshell showed a
noise dose of 12.52% which would give a time-weighted average (TWA), assuming no
further noise exposure for the 8-hour shift, of 75.0 dBA and a noise dose of 34.28%
(TWA – 82.3dBA). These area results show potential exposures from below to close to
the OSHA “action level” of 85 dBA but are below the PEL of 90 dBA. A projected 8-
hour noise dose and resultant TWA showed the following results for the respective area
samples: 41.60% (TWA – 83.6 dBA) and 46.66% (TWA – 84.5 dBA). These projected
8-hour noise doses also show the potential exposure range from below to close to the
OSHA “action level” but below the PEL.

The OSHA allowable “action level” is a noise dose of 50% or an 8-hour TWA of 85 dBA
and the PEL is a 100% dose or an 8-hour TWA of 90 dBA. The levels of exposure
recorded during the testing demonstration may require the operators to be included in a
hearing conservation program. In addition, engineering controls, administrative
controls, and/or personal protective equipment (PPE - hearing protection devices) may
be required. 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. The
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.

It should be noted that during operation of the clamshell, it became necessary to

remove the muffler. This was due to problems associated with the humidity at the test
demonstration site. It was noted that noise levels that had ranged from 92 – 94 dBA
during operation of the clamshell rose to 99 – 100 dBA. Normal operation of the
clamshell should not be done without the muffler in place.

Recommendations for improved worker safety and health during use of the Split Frame
Clamshell 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. padding the metal operator lever; 4. allowing
only sweeping or vacuuming to clean up metal shavings; 5. guarding the area of the
rotating star wheels and cutting tip;
6. safety lines on the air hose connections; 7. the operator keeping his/her face away
from the rotating/cutting area of the clamshell during operation; and
8. assuring the pipe/tube to be cut can handle the load of the clamshell.
 TRI TOOL INC.
Split Frame Clamshell
Human Factors Assessment
(Equipment Dismantlement)

SECTION 1 - SUMMARY

TECHNOLOGY DESCRIPTION

The Tri Tool Split Frame Clamshell 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 clamshell. The Tri Tool Split Frame Clamshell is a
commercially available technology and has been used for various projects at locations
throughout this country.

While the split frame clamshell 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 clamshell 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
• 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
1926.503 are allowed to work from a height; only operators trained on forklifts in
accordance with OSHA 29 CFR 1910.178 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 those duties.

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 shall 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 has been properly calculated.

♦ Assure workers have training and experience directly applicable to the type of
activities to be conducted.

♦ Inspection of all chain, wire rope, slings, etc.

shall be performed to assure it is in good working
condition before the hoisting and rigging work is
started.

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 Figure 1. Forklift being

accordance with OSHA 29 CFR 1910.178 used during hoisting &
Powered Industrial Trucks. rigging activities

♦ 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 Tri Tool Split Frame Clamshell is a pipe lathe which employs a split rotary bearing
design that can be divided into two or more sections (depending on the size of the
clamshell). The sections are placed around the outside of the pipe/tube to be cut and
bolted together. The rotating cutting heads then cut either a straight or beveled cut from
the outside diameter inward. The clamshell clamps completely around the outside
diameter (O.D.) of the pipe with clamp pads and jackscrews to provide a stable and
secure clamp-up. Clamshells are designed to cut pipe from ¼-inch to 60-inches in
diameter. This is accomplished by having clamshells of varying sizes and incorporating
an adjustable O.D. mounting system, as required, to fit the pipe diameter. The
clamshell also features an enclosed drive gear and a multi-positionable motor mount.
The star wheels on the tool provide incremental tool bit feed for controlled cut depth.
The tool bits are carbide cutting bits.

The Split Frame Clamshell can be pneumatically, hydraulically, or electrically powered.

The clamshell used during the testing demonstration was pneumatically powered.

KEY RESULTS

The safety and health evaluation during the testing demonstration focused on two types
of potential exposure: dust and noise. Visible dust was not seen during operation of the
clamshell and the air sampling results showed values below the Occupational Safety
and Health Administration (OSHA) permissible exposure limits (PEL), as well as 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 ranged from below to near 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. In addition, since there is potential for noise exposure during cutting
operations, noise surveys appear to be required in all operational settings. Other safety
and health hazards found were ergonomics, heat
stress, pinch points, tripping hazards, struck by
hazards, lockout/tagout, and moving machinery.

SECTION 2 - SYSTEM OPERATION

The Tri Tool Split Frame Clamshell is a pipe lathe

which employs a split rotary bearing design that can
be divided into two or more sections (depending on
the size of the clamshell). The clamshell requires
Figure 2. Split Frame minimal axial or radial clearances. The sections are
Clamshell placed around the outside of the pipe/tube to be cut
and bolted together. The rotating cutting heads then
cut either a straight or beveled cut from the O.D. inward. The clamshell clamps
completely around the O.D. of the pipe with clamp pads and jackscrews to provide a
stable and secure clamp-up.

Clamshells are designed to cut pipe from ¼-inch to 60-inches in diameter. This is
accomplished by having clamshells of varying sizes and incorporating an adjustable
O.D. mounting system, as required, to fit the pipe diameter. The clamshell also features
an enclosed drive gear and bearing surface and a multi-positionable motor mount.
Additional features of the Split Frame Clamshell, which may vary depending on the size
of the clamshell, include internal counterbore machining and worm drive tool modules to
reduce vibration and extend tool bit life.

The automatic feed star wheels and adjustable slideways provide incremental tool bit
feed for controlled cut depth. The star wheels mount on the rotating face of the
clamshell and carry the tool bits within the tool holder section. The tool bit is fed into the
pipe/tube at a fixed revolution of the head stock with one tripper pin assembly engaged.
Multiple trippers increase the total feed of the tool bit per revolution. The star wheels
provide 0.0025-inch of radial feed per revolution. The tool bits are carbide cutting bits.

The Split Frame Clamshell can be pneumatically, hydraulically, or electrically powered.

Pneumatic power provides the maximum power per unit weight, electric powered are for
light duty machining, and hydraulic motors provide the maximum power and speed
range capabilities at the machine. Dual drives can be fitted for additional power and
machining capabilities. The clamshell used during the testing demonstration was
pneumatically powered.
The operator control for the Split Frame Clamshell is located on the shaft of the multi-
positionable motor mount. The on-off control is a lever mechanism designed for four
finger operation. It works as a “dead man” switch, shutting down the clamshell if
pressure is released off the lever.

SECTION 3 - HEALTH AND SAFETY EVALUATION

GENERAL SAFETY AND HEALTH CONCERNS

Personnel where the clamshell cutting 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 clamshell cutting technology included:

Core Issues:

♦ Tripping Hazards - The air lines, 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 during operation if caught in the clamshell during attachment to or removal
from the pipe/tube. There is also potential for injury if the fingers/hand are
caught/struck by the star wheels as they rotate about the pipe/tube being cut.

♦ Lockout/Tagout - The user of the technology will need to develop a lockout/tagout

program to assure there is not an accidental release of energy during
maintenance/repair activities.

♦ Noise - The operator and workers in the area were subjected to noise levels below
and at the OSHA “action level” for noise. The "action level" is 85 dBA for an 8-hour
work shift. The potential exists for the operator to be exposed above the OSHA
PEL. 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 operation. Therefore, noise is a potential concern and will be
discussed in greater detail in the Industrial Hygiene section of this report.

♦ Dust - The equipment did not generate any visible dust during operation. Air
sampling results showed a level of total dust exposure less than the OSHA PEL and
the ACGIH TLV. The PEL is 15 mg/m3 and the TLV is 10 mg/m3. Dust does not
appear to be a concern during cutting operations with the split frame clamshell but
 other contaminants that may be present in the work area need to be considered and
a sampling plan developed as appropriate.

♦ Metal shavings were left on the surface below the

pipe/tube being cut by the split frame clamshell.
These shavings are sharp and could therefore be a
hazard to the worker when cleaning them up. They
may also stick to the bottom of the worker’s
shoes/boots and be carried from the contaminated
area to a clean area. One additional concern with the
sharp metal shavings is dragging the air hoses across
them. This has the potential to cause cuts, scrapes,
and/or additional wear on the hoses and could cause
them to weaken and rupture.

♦ Machine Guarding – The rotating star wheels with the

cutting tip presents hazards if the operator were to get Figure 3. Metal shavings
his/her hand, fingers, etc. in the area of rotation. In on walking surface after
addition, any loose pieces of clothing has the potential cutting completed.
to get caught in this area and result in injury. This
needs to be considered and machine guarding designed for this area.

Best Management Practices:

♦ Heat Stress - The operator may be subjected to an increase in heat stress due to the
need to utilize personal protective equipment (PPE). 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 user was subjected to some ergonomic stressors that need to be
taken into consideration, such as stooping, bending, twisting, kneeling, and lifting.

♦ Struck by Hazards - The shavings created by the cutting process have the potential
to be projected upward and outward during cutting operations. This could become a
severe eye injury hazard. The operator may need to utilize a face-shield in addition
to safety glasses with side shields or goggles. Long sleeves may also need to be
worn. Work practices should include never placing the face near the area of
operation. If the operator needs to inspect the cut before continuing, the clamshell
should be stopped first.

♦ 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 split frame clamshell, sampling was
conducted for dust 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.

Attaching and removing the clamshell to the

pipe/tube to be cut may require the operator to
Figure 4. Clamshell mounted at assume awkward positions, in particular when the
floor level. pipe/tube is in a difficult to reach location, in a
congested area, or elevated. This has the
potential to place strain on the back, neck, shoulders, arms, knees, and legs. This
needs to be taken into consideration and work practices to mitigate this as much as
possible need to applied. In addition, training in ergonomics, including using proper
lifting techniques needs to be conducted for operators of the split frame clamshell.

Operating the split frame clamshell has the

potential to cause the operator to assume
positions which place stress on the back, neck,
shoulders, arms, knees, and legs. This is
partially due to the position in which the
clamshell has to be placed on the pipe/tube.
The multi-positionable motor mount with the
operating lever helps to alleviate a lot of the
stress causing positions but there is still the
potential for stress to the body areas discussed
above.

One situation where awkward operator Figure 5. Deviant wrist position caused
positioning is most prevalent during operation is by placement of the clamshell.
when the cut on the pipe/tube must be made at
floor level. The clamshell is placed at the bottom of the pipe/tube with the star wheels
and cutting tool facing toward the floor. The motor mount with the operating lever is
placed on the part of the clamshell facing the ceiling. This will allow the operator to
comfortably operate the clamshell without additional stress on the back, neck,
shoulders, arms, etc. However, if the operator needs to observe the cutting operation,
he/she must kneel, bend at the waist and turn the neck toward the cutting operation
while at the same time, reaching up to the operating lever on the motor mount. The arm
will be in a laterally rotated, hyper-extended position and the wrist will be in a deviated
position. This has the potential to place a significant amount of stress on the knees,
back, neck, shoulder, arm, and wrist. Consideration needs to be given to the placement
of the clamshell in relation to operational parameters. In this situation, as well as others
that may arise, two person operation may need to be used, one to observe the
operation and one to operate the control lever. Note: the person observing the
operation should not place his/her face near the area of operation due to the potential
for sharp metal shavings to be thrown from the area.

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 wet-
bulb globe temperature, PPE in use, physical condition of the worker, and worker
acclimatization.

Total dust 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 0500.
Samples were analyzed by a laboratory accredited by the American Industrial Hygiene
Association (AIHA).

Area dust sampling was conducted during operation of the split frame clamshell. The
actual cutting of pipes/tubes took approximately 2-5 minutes per pipe/tube. Therefore,
area dust sampling was conducted throughout the entire process to assess the potential
for dust generation and worker exposure during cutting operations. Area samples were
taken at a central location in the general work area. A forklift was periodically operated
in the area to remove the pipe/tube that was cut.

The area dust samples showed results of <0.072 mg/m3 and <0.157 mg/m3. These
results are below the OSHA PEL of 15 mg/m3 and the ACGIH TLV of 10 mg/m3. (See
Appendix B for sampling data).
Dust generation does not appear to be a concern during the operation of the split frame
clamshell but since the time spent in the work area, the distance from the actual cutting
operation, and ventilation in the work area may affect an individual worker’s exposure
level, a monitoring plan will need to be developed to account for the site specific
conditions where the split frame clamshell is being used. A complete air sampling plan
for a site will need to be developed to include not only dust but also other contaminants
specific to the D&D project.

Area noise sampling was conducted during operation of the split frame clamshell. Since
the actual cutting of pipes/tubes took approximately 2-5 minutes per pipe/tube, area
noise sampling was conducted throughout the entire process to assess the potential for
worker noise exposure during cutting operations with the split frame clamshell. Area
samples were taken at a central location in the general work area. A forklift was
periodically operated in the area to remove the pipe/tube that was cut. Area noise
sampling was conducted using a Metrosonics db-3100 noise dosimeter. Calibration
was conducted pre-and-post monitoring using a Metrosonics CL304 acoustical
calibrator.

Monitoring was conducted for 2.4 hours (144 minutes) and 5.9 hours (352 minutes).
Noise monitoring showed a noise dose of 12.52% which would give a time-weighted
average (TWA), assuming no further noise exposure for the 8-hour shift, of 75.0 dBA
and a noise dose of 34.28% (TWA – 82.3dBA). These area results show potential
exposures from below to near to the OSHA “action level” of 85 dBA but below the PEL
of 90 dBA. A projected 8-hour noise dose and resultant TWA showed the following
results for the respective area samples: 41.60% (TWA – 83.6 dBA) and 46.66% (TWA –
84.5 dBA). These projected 8-hour noise doses also show potential exposures ranging
from below to near to the OSHA “action level” but below 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 83.6 dB and 84.5 dB for the respective area samples. The maximum sound
levels observed during monitoring were 106.5 dB and 107.1 dB.

The OSHA allowable “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 may require the operators to be
included in a hearing conservation program. In addition, engineering controls,
administrative controls, and/or personal protective equipment (PPE - hearing protection
devices) may be required. 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 in that location. The 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.
It should be noted that during operation of the clamshell, it became necessary to
remove the muffler. This was due to problems associated with the humidity at the test
demonstration site. It was noted that noise levels that had ranged from 92 – 94 dBA
during operation of the clamshell rose to 99 – 100 dBA. Normal operation of the
clamshell should not be done without the muffler in place.

HUMAN FACTORS INTERFACE

Workers using a technology for pipe/tube D&D activities may encounter a variety of
contaminants when working in a hazardous waste site environment. This may include
contaminants associated with the pipe/tube being dismantled, the material the pipe/tube
is constructed of, or contamination inherent in the environment where the pipe/tube is
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.

TECHNOLOGY APPLICABILITY

There was no visible dust during the cutting operation and the air sampling results
showed sampling values below the OSHA PEL and the ACGIH TLV. Metal shavings
were left on the surface below the pipe/tube being cut by the split frame clamshell.
These shavings were sharp and could therefore be a hazard to the worker when
cleaning them up. They may also stick to the bottom of the worker’s shoes/boots and
be carried from the contaminated area to a clean area. One additional concern is
dragging the air hoses across the sharp metal shavings. This has the potential to cause
cuts, scrapes, and/or additional wear on the hoses and could cause them to weaken
and rupture.

The split frame clamshell 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.
 SECTION 4 - JOB SAFETY ANALYSIS

JOB SAFETY ANALYSIS

TRI TOOL INC.
Split Frame Clamshell
(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 such as air lines
* Muscular/Back Injury * Ergonomic training including safe lifting
techniques
ATTACHING/REMOVING CLAMSHELL (FROM PIPE/TUBE)
* 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 such as air lines
 HAZARD CORRECTIVE ACTION
ATTACHING/REMOVING CLAMSHELL (FROM PIPE/TUBE)
* Struck By/Fall from above * Assure all workers in the area are aware of
(clamshell unintentionally where the clamshell is being attached. Do not
releasing from pipe/tube) allow workers to stand under the area where the
clamshell has been attached to elevated
pipes/tubes
* Assure all workers have proper training before
attaching and using the clamshell
* Assure proper tools are used to tighten screws
and that screws are tight before releasing hold
on clamshell
* Exposure to Contaminant (when * Use of proper PPE, including respiratory
attaching/removing clamshell) protection
* Pinch Points * Use of hand protection
* Use of proper hand tools for the job
* Assure workers are trained in proper method of
attaching/removing the clamshell.
* Muscular/Back Injury * Ergonomics training to include proper lifting
techniques
* Use two workers to lift, hold and tighten/loosen
the screws to attach/remove the clamshell
* Cut/Laceration Hazard * Assure workers are aware of the cutting tip
location and proper positioning without coming
into contact with it
* Label on clamshell to indicate location of sharp
cutting tip
* Do not allow workers to rotate cutting tips with
hands
* Use tool to remove and replace cutting tip
instead of using hands
ADJUSTING CUTTING TIP
* Exposure to Contaminants * 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
 HAZARD CORRECTIVE ACTION
ADJUSTING CUTTING TIP (CONTINUED)
* Muscular/Back Injury (from * Ergonomics training
stooping, bending, etc.)
* 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
* Pinch Points * Use hand protection
* Use of hand tools appropriate for the job
* Cut/Laceration Hazards * Assure workers are aware of the cutting tip
location and proper positioning without coming
into contact with it
* Label on clamshell to indicate location of sharp
cutting tip
* Do not allow workers to rotate cutting tips with
hands
* Use tool to remove and replace cutting tip
instead of using hands
CUTTING (OPERATION)
* Muscular/Back Injury (from * Ergonomics training
stooping, bending, awkward arm
positions)
* 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 such as air lines
* Pinch Points (from rotating * Assure worker training in the proper operation
cutting rotating parts) of the clamshell
* Guarding rotating parts so hand/fingers cannot
be placed near the point of operation
* Cut/Laceration Hazard * Assure worker training in the proper operation
of the clamshell
* Guarding rotating parts so hand/fingers cannot
be placed near the point of operation of the
cutting tip

CUTTING (OPERATION)
 HAZARD CORRECTIVE ACTION
* Eye hazard/struck by (shavings) * Use face shield with safety glasses with side
shields or goggles
* Standard Operating Procedures (SOPs) to
prohibit placing face near the rotating parts area
and cutting tip as it cuts the pipe/tube
* Wear long sleeved clothing when operating
clamshell
* Assure clothing (PPE) is puncture resistant
* Struck by (air hose/high * Safety line to male and female end of fitting
pressure air)
* Noise * Use engineering controls (do not operate
clamshell without muffler)
* Use administrative controls
* Use proper hearing protection devices, as
required
* Pressure Points * Pad operating level so fingers not in direct
contact with metal
* Exposure to Contaminants * Assure workers are aware of the hazards in the
area where they are using the clamshell
* 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
* Exposure to Oil (used in air * Assure Hazard Communication training for
lines) workers
* Use as little oil as required for proper operation
* Assure clamshell adjusted to keep oil spray at a
minimum
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
 HAZARD CORRECTIVE ACTION
* Accidental activation of moving * Use proper lockout/tagout techniques
parts (pinch points)
* Pinch Points * Use of hand protection
* Use of hand tools appropriate for the job
* Use of appropriate lockout/tagout procedures
* 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
* Ergonomics/Bending/Kneeling/ * Use proper lifting techniques
Lifting * Ergonomic training to include proper lifting
techniques
 SECTION 5 - FAILURE MODE AND EFFECTS ANALYSIS

FAILURE MODE AND EFFECTS ANALYSIS

TRI TOOL INC.
Split Frame Clamshell
(Equipment Dismantlement)

FAILURE MODE EFFECT

* Air line punctures/ruptures * Potential for injury to worker from being
struck by air line
* Potential for injury to worker from high
pressure air
* Air line fitting fails * Potential for injury to worker from being
struck by air line
* Potential for injury to worker from high
pressure air
* Cutting tip breaks/shatters * Potential for worker to be struck by
sharp piece of tip causing injury, of
particular concern are eye injuries
* Potential for pipe/tube being cut to
become off center and break off striking
worker, thereby causing injury
* Pipe/tube being cut fails * Potential for injury to worker from being
struck by the pipe/tube and/or clamshell
as it falls
* Clamshell attachment mechanism fails * Potential for injury to worker from being
struck by clamshell as it falls
 SECTION 6 - TECHNOLOGY SAFETY DATA SHEET

TECHNOLOGY SAFETY DATA SHEET

TRI TOOL INC.
Split Frame Clamshell
(Equipment Dismantlement)

SECTION 1: TECHNOLOGY IDENTITY

Manufacturer’s Name and Address: Emergency Contact:
(916) 351-0144
Tri Tool Inc. (800) 345-5015
3806 Security Park Drive
Information Contact:
Schenley, PA 15682 (916) 351-0144
(800) 345-5015
Date Prepared:

Other Names: Signature of Preparer:

Clamshell
Split Lathe Operating Engineers National Hazmat
Program
1293 Airport Road, Beaver, WV 25813,
phone 304-253-8674, fax 304-253-7758

Under cooperative agreement DE-FC21-

95 MC 32260
SECTION 2: PROCESS DESCRIPTION
The Tri Tool Split Frame Clamshell is a pipe lathe which employs a split rotary
bearing design which can be divided into two or more sections (depending on the size
of the clamshell). The clamshell requires minimal axial or radial clearances. The
sections are placed around the outside of the pipe/tube to be cut and bolted together.
The rotating cutting heads then cut either a straight or beveled cut from the outside
diameter (O.D.) inward. The clamshell clamps completely around the O.D. of the pipe
with clamp pads and jackscrews to provide a stable and secure clamp-up.

Clamshells are designed to cut pipe from ¼-inch to 60-inches in diameter. This is
accomplished by having clamshells of varying sizes and incorporating an adjustable
O.D. mounting system, as required, to fit the pipe diameter. The clamshell also
features an enclosed drive gear and bearing surface and a multi-positionable motor
mount. Additional features of the Split Frame Clamshell may vary depending on the
size of the clamshell, including internal counterbore machining and worm drive tool
modules to reduce vibration and extend tool bit life.

The automatic feed star wheels and adjustable slideways provide incremental tool bit
feed for controlled cut depth. The star wheels mount on the rotating face of the
clamshell and carry the tool bits within the tool holder section. The tool bit is fed into
the pipe/tube at a fixed revolution of the head stock with one tripper pin assembly
engaged. Multiple trippers increase the total feed of the tool bit per revolution. The
star wheels provide 0.0025-inch of radial feed per revolution. The tool bits are
carbide cutting bits.

The Split Frame Clamshell can be pneumatically, hydraulically, or electrically

powered. Pneumatic power provides the maximum power per unit weight, electric
powered are for light duty machining, and hydraulic motors provide the maximum
power and speed range capabilities at the machine. Dual drives can be fitted for
additional power and machining capabilities.

The operator control for the Split Frame Clamshell is located on the shaft of the multi-
positionable motor mount. The on-off control is a lever mechanism designed for four
finger operation. It works as a “dead man” switch, shutting down the clamshell if
pressure is released off of the lever.
SECTION 3: PROCESS DIAGRAMS
SECTION 3: PROCESS DIAGRAMS
SECTION 4: CONTAMINANTS AND MEDIA
Dust generation does not appear to be a concern with the split frame clamshell.
Consideration does need to be given to contamination in the area where the
clamshell is being used for D&D activities. An air sampling plan will need to be
developed, as appropriate for the site where the clamshell is being 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 (unless electrically operated model is used).
B. FIRE AND EXPLOSION RISK RATING: 1
Technology does not pose this hazard in and of itself but could not be used in an
explosive environment due to the potential for sparking.
C. CONFINED SPACE ENTRY RISK RATING: 1
Not part of this technology unless the specific location where the clamshell is being
used is a confined space. In this case, confined space procedures would need to be
followed.
D. MECHANICAL HAZARDS RISK RATING: 4
Attaching and removing the clamshell from the pipe/tube to be cut may pose the
following: pinch points and struck by hazards. There is potential for injury from the
rotating star wheels. Guarding of the area needs to be considered and proper
precautions taken. Loose clothing should not be worn when working around the
clamshell.
E. PRESSURE HAZARDS RISK RATING: 2
The airlines and high pressure air may present hazards, proper precautions indicated.
The airline fittings should have safety lines connecting the male and female half of the
fitting.
F. TRIPPING AND FALLING RISK RATING: 3
Air lines present potential hazards.
SECTION 5: ASSOCIATED SAFETY HAZARDS (CONTINUED)
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: N/A
Not part of this technology.
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 pipe/tube 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 clamshell placement and avoid the area when
the clamshell is overhead.

SECTION 6: ASSOCIATED HEALTH HAZARDS

A. INHALATION HAZARD RISK RATING: 1
Technology does not appear to produce dust during operation. Other hazards that
may be present in the area will be identified from the site characterization.
B. SKIN ABSORPTION RISK RATING: 2
This would be dependent on the contaminants at the site and would be identified by
the site characterization. The oil used in the air lines may present a skin hazard.
SECTION 6: ASSOCIATED HEALTH HAZARDS (CONTINUED)
C. HEAT STRESS RISK RATING: 1-4
Ambient conditions, work rates, and PPE levels must be considered.
D. NOISE RISK RATING: 2
The technology presents a potential noise hazard.
E. NON-IONIZING RADIATION RISK RATING: N/A
Not part of this technology.
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
Poses ergonomic hazards associated with lifting, bending, twisting, stooping and
kneeling. These may cause injury/strain to the back, shoulders, arms, knees, hips
and/or legs.
I. OTHER RISK RATING: 3
Laceration/cutting hazards present from the cutting tip of the clamshell, the sharp
shavings from the metal being cut, and the edge of the piece that was cut.
Appropriate hand protection should be used.

SECTION 7: PHASE ANALYSIS

A. CONSTRUCTION/START-UP
The set-up/start-up phase presents several hazards including pinch points, laceration
hazards, slips/trips/falls struck by, fall from above hazards, and muscular/back injury.
B. OPERATION
The operational phase presents several hazards including exposure to contaminant,
muscular/back injury, pinch points, laceration hazards, slips/trips/falls, pinch points,
struck by hazards, fall from above hazards, and exposure to noise.
C. MAINTENANCE
The maintenance phase presents several hazards including pinch points, laceration
hazards, slips/trips/falls, muscular/back injury, exposure to contaminants, and
accidental activation of moving parts.
SECTION 7: PHASE ANALYSIS (CONTINUED)
D. DECOMMISSIONING
The decommissioning phase presents several hazards, including exposure to the
contaminant, pinch points, laceration hazards, slips/trips/falls, and muscular/back
injury.

SECTION 8: HEALTH AND SAFETY PLAN REQUIRED ELEMENTS

A. AIR MONITORING
Dust does not appear to be a concern during operation of the clamshell. Monitoring
may need to be conducted for contaminants in the area where the D&D activities take
place. This will be determined by the site characterization prior to the initiation of the
D&D project. 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), PPE (Personal Protective Equipment) Training, Hearing
Conservation, 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).
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 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.
 SECTION 7 - EMERGENCY RESPONSE/PREPAREDNESS

The use of the Tri Tool Split Frame Clamshell would not be applicable in an emergency
response situation.

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 split frame clamshell.

All precautions used when responding to an emergency situation at the site will apply.
Before entering an area where the split frame clamshell is being used, the equipment
needs to be completely shut down (de-energized).

This technology does not appear to present conditions that could lead to an out-of-the-
ordinary emergency. Consideration does, however, need to be given to assuring the
pipe/tube being cut can handle the load of the clamshell placed on it.

SECTION 8 - REGULATORY/POLICY ISSUES

The site safety and health personnel where the Tri Tool Split Frame Clamshell 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:

t OSHA 29 CFR 1926.25 Housekeeping

t OSHA 29 CFR 1910.141 Sanitation (1910.141(a)(3) covers housekeeping)

t OSHA 29 CFR 1926 Subpart Z Toxic and Hazardous Substances

t OSHA 29 CFR 1910 Subpart Z Toxic and Hazardous Substances

t OSHA 29 CFR 1926.59 Hazard Communication

t OSHA 29 CFR 1910.1200 Hazard Communication

t OSHA 29 CFR 1926.65 Hazardous Waste Operations and Emergency Response

t OSHA 29 CFR 1910.120 Hazardous Waste Operations and Emergency

Response

t Occupational Safety and Health Act 1970(5)(a)(1) General Duty Clause

Technology Specific Requirements:

t OSHA 29 CFR 1910.147 The Control of Hazardous Energy (Lockout/Tagout)

t OSHA 29 CFR 1910 Subpart O Machinery and Machine Guarding

t OSHA 29 CFR 1910 Subpart P Hand and Portable Powered Tools

t OSHA 29 CFR 1926 Subpart I Tools – Hand and Power

t OSHA 29 CFR 1926.52 Occupational Noise Exposure

t OSHA 29 CFR 1910.95 Occupational Noise Exposure

t OSHA 29 CFR 1926.102 Eye and Face Protection

t OSHA 29 CFR 1910.133 Eye and Face Protection

t OSHA 29 CFR 1926.28 Personal Protective Equipment

t OSHA 29 CFR 1910.132 General Requirements (Personal Protective

Equipment)

t OSHA 29 CFR 1926.23 First Aid and Medical Attention

t OSHA 29 CFR 1910.151 Medical Services and First Aid

t OSHA 29 CFR 1910.1000 Toxic and Hazardous Substances

Best Management Practices:

t ACGIH Threshold Limit Values for Chemical Substances and Physical Agents
and Biological Exposure Indices

t 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 Tri Tool Split Frame Clamshell
may include but not be limited to:

Core Training Requirements:

t HAZWOPER

t HAZCOM

Technology Specific Training:

t Hearing Conservation

t Personal Protective Equipment

t Lockout/Tagout

Special Training:

t Job specific training for equipment operation

Best Management Practice Training:

t Machine Guarding

t Ergonomics (proper lifting, bending, stooping, kneeling)

t Heat stress (learning to recognize signs and symptoms)

t CPR/First Aid/Emergency Response/Blood-borne Pathogens

t Hand Signal Communication

t 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 split frame clamshell with a pneumatically powered
motor. Specific recommendations include:

t 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.

t 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.

Attaching and removing the clamshell to the pipe/tube to be cut may require the
operator to assume awkward positions, in particular when the pipe/tube is in a
difficult to reach location, in a congested area, or elevated. This has the potential
to place strain on the back, neck, shoulders, arms, knees, and legs. It is
recommended that this be taken into consideration prior to the start of the job
and work practices to mitigate this be applied. In addition, training in
ergonomics, including using proper lifting techniques needs to be conducted for
operators of the split frame clamshell.

Operating the split frame clamshell has the potential to cause the operator to
assume positions which place stress on the back, neck, shoulders, arms, knees,
and legs. This is partially due to the position in which the clamshell had to be
placed on the pipe/tube. The multi-positionable motor mount with the operating
lever helps to alleviate a lot of the stress causing positions, but there is still the
potential for stress to the body areas discussed above.

One situation where awkward operator positioning is most prevalent during

operation is when the cut on the pipe/tube must be made at floor level. The
clamshell is placed at the bottom of the pipe/tube with the star wheels and cutting
tool facing toward the floor. The motor mount with the operating lever is placed
on the part of the clamshell facing the ceiling. This will allow the operator to
comfortably operate the clamshell without additional stress on the back, neck,
shoulders, arms, etc. If, however, the operator needs to observe the cutting
operation, he/she must kneel, bend at the waist and turn the neck toward the
cutting operation. At the same time, he/she must reach up to the operating lever
on the motor mount. The arm will be in a laterally rotated, hyper-extended
 position and the wrist will be in a deviated position. This has the potential to
place a significant amount of stress on the knees, back, neck, shoulder, arm, and
wrist. Consideration needs to be given to the placement of the clamshell in
relation to operational parameters. In this situation, as well as others that may
arise, it is recommended that a two person operation be used, one to observe the
operation and one to operate the control lever. Note: the person observing the
operation should not place the face near the area of operation due to the
potential for sharp metal shavings to be thrown from the area.

t The operating lever is a metal lever designed for multiple finger operation. It is
recommended that the lever be padded to avoid pressure points on the
operator's fingers/hand.

The operating lever acts as a “dead-man” switch, meaning that if the operator
releases pressure on the lever the clamshell stops. Therefore, the lever should
never be held down by anything other than the operator's fingers/hand during
cutting operations.

t Noise monitoring showed the potential for operators to be below or at the "action
level" of 85 dBA. If this level of exposure had continued for an 8-hour work shift,
the potential exists for the operator to be exposed above the OSHA PEL of 90
dBA. Noise needs to be considered a potential hazard when the cutting
operation is taking place. The operators may be required to be included in a
hearing conservation program. In addition, engineering controls, administrative
controls and/or PPE (hearing protection devices) may be required. 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 operation. Exposure will also be influenced by the construction of the area
where the clamshell is being used and the size of the clamshell. A monitoring
program will need to be developed to address the site specific conditions where
the split frame clamshell is being used. Additionally, the clamshell should never
be operated without the muffler in place. Noise levels are increased when the
muffler is removed.

t The equipment did not generate any visible dust during operation and air
sampling results showed total dust levels below the OSHA PEL of 15 mg/m3 and
the ACGIH TLV of 10 mg/m3. Dust does not appear to be a concern during
cutting operations but it is recommended that a sampling plan be developed, as
appropriate, based on any other contaminants in the work area that were
identified by the site characterization.

t Metal shavings were left on the surface below the pipe/tube being cut by the split
frame clamshell. These shavings are sharp and therefore, present a hazard to
the workers when cleaning up the work area. It is recommended that the
 shavings be cleaned up by sweeping or vacuuming. Hands or compressed air
should never be used to clean up the shavings. Puncture resistant gloves should
be utilized, as appropriate.

The metal shavings may be thrown outward from the area where the cut is being
made. These have the potential to cause injury, especially eye injury. Safety
glasses with side shields or goggles should always
be worn during operation of the clamshell. There
may be instances where the use of face shields
are also warranted. It is also recommended that
SOPs disallow the practice of placing the face in
the area of the clamshell during operation.

The cut pipe/tube pieces may have sharp edges.

This presents the potential for laceration/cut

Figure 6. Clamshell showing

injuries from handling these pieces. It is
rotating mechanism with star recommended that puncture resistant gloves be
wheels and cutting tip in worn when handling cut pieces.
place.
t The rotating star wheels with the cutting tip
have the potential to cause serious injury if the operator were to place his/her
fingers in this area during operation. It is recommended that machine guarding
be used on this area to prohibit fingers/hands being placed at the point of
operation during cutting. Consideration should be given to a clear shield with an
interlock to stop operation if raised. Guarding this area would also prohibit the
operator from trying to stop the star wheels with his/her hands and removing
shavings while the star wheels are rotating. Both of these practices have the
potential to cause severe injury.

There is also the potential for worker injury if a piece of loose clothing, jewelry, or
long hair were to get caught in the rotating parts during cutting operations. It is
recommended that loose clothing and jewelry not be worn when operating the
clamshell and that long hair be held back. Special consideration needs to be
given to the type of PPE that may be required and any hazards this may present
in relation to the rotating parts of the clamshell.

t The split frame clamshell was pneumatically powered. The air hoses required to
provide high pressure air for operation have the potential to cause injury to the
operator if a fitting were to fail. The airlines were connected with quick connect
fittings. It is recommended that a safety line between the male and female
halves of the fitting be used to keep the hose from becoming a struck by hazard if
the fitting failed.
 The air hoses or the high pressure air itself has the potential to cause injury to an
operator if the air hose were to rupture. It is recommended that all hoses be
inspected to assure they are in good condition before use. This is particularly
important because of the sharp edges (shavings and cut pipe/tube) the hose may
be in contact with throughout the cutting operation.

t The clamshell weights vary, depending on the size of the clamshell, from 11.5
pounds to 1120 pounds. If the pipe/tube or the anchors on the pipe/tube to be
cut cannot hold the weight of the clamshell, worker injury could result from
collapse of the pipe/tube. It is recommended that before the cutting operation
begins, the pipe/tube structure and/or anchors be evaluated to assure they can
support the weight of the clamshell.

t As with any lathe-type operation, the system can bind during operation. It is
recommended that the clamshell have an automatic shut-off should this occur.
Binding can cause the cutting tip to shatter and become a projectile with the
potential to cause worker injury.

t As with any pneumatically operated piece of equipment, oil must be used. This
presents the potential for the operator to be exposed to the oil either when
putting the oil into the air hose or if the oil sprays from the piece of equipment. It
must be assured that all workers have had Hazard Communication Training for
the hazardous chemicals they are working with and material safety data sheets
(MSDS) must be provided.

If oil gets on the worker's PPE, if required, the PPE could be compromised. This
needs to be taken into consideration and it needs to be assured that any PPE
being used in the area where cutting operations are taking place be compatible
with the oil. This may be of particular concern if Anti-C PPE is being worn.

If oil gets on the surfaces in the work area, it has the potential to then be a
secondary contamination. If the oil gets on the walking surfaces in the work
area, it can cause these surfaces to be slippery, thereby having the potential to
cause injury to workers from falls. It is recommended that the initial pre-
operational checks for the clamshell be conducted before entering the work area
to assure the proper adjustments have been made to control the oil spray. Any
oil spilled or sprayed should be cleaned up immediately in compliance with good
housekeeping standards.

The environment where the D&D activities are taking place has the potential to affect
both the dust and noise levels generated. Therefore, the need for an air sampling and
noise monitoring program needs to be assessed on a site-by-site job-by-job basis.
 APPENDIX A
REFERENCES

DOE Lessons Learned, Identifier 1997-RL-FDH-0001,

http://www.hanford.gov/lessons/site11/1197/970001b.htm

DOE Lessons Learned, Identifier 1995-RL-WHC-040,

http://www.hanford.gov/lessons/site11/1195/95e040.txt

DOE Lessons Learned, Identifier 1995-RL-WHC-0037,

http://www.hanford.gov/lessons/site11/1195/95i037.txt

Keller’s Official OSHA Safety Handbook, J.J. Keller & Associates, Nihau, Wisconsin,
1996

National Safety Council, Accident Prevention Manual for Business and Industry, 11th
Edition, 1997

Occupational Safety and Health Standards for General Industry, 29 CFR Part 1910,
Occupational Safety and Health Administration United States Department of Labor

Occupational Safety and Health Standards for the Construction Industry, 29 CFR Part
1926, Occupational Safety and Health Administration United States Department of
Labor

Threshold Limit Values (TLV’s) for Chemical Substances and Physical Agents and
Biological Exposure Indices (BEI’s), American Conference of Governmental Industrial
Hygienists, 1995-1996

U.S. Department of Health and Human Services, Manual for the Revised NIOSH Lifting
Equation, January 1994
 APPENDIX B
IH SAMPLING DATA

Pegasus International, Inc. EBE 250VHC Shot Blasting System

Total Dust Sampling
Date Sample Number Analyte * Results
8/18/98 081898-FIU-015 Total dust < 0.157 mg/m3
8/18/98 081898-FIU-016 Total dust < 0.072 mg/m3
8/18/98 081898-FIU-017 Blank < 0.05 mg

* The OSHA PEL for total dust is 15 mg/m3 and the ACGIH TLV is 10 mg/m3. Current
sampling was conducted for total dust. The need to sample for respirable dust and
silica has to be considered during the coating and concrete removal process.
 NOISE SAMPLING

The percentage of time spent at each decibel level can be obtained from the graph. As
shown, 82.869% of the time the noise exposure was less than 85 dBA, which means
17.131% of the time, was spent at sound levels above 85 dBA. OSHA requires that a
hearing conservation program be initiated if the 8-hour TWA is 85 dBA.
 NOISE SAMPLING

The percentage of time spent at each decibel level can be obtained from the
graph. As shown, 86.510% of the time the noise exposure was less than 85
dBA, which means 13.490% of the time, was spent at sound levels above 85
dBA. OSHA requires that a hearing conservation program be initiated if the 8-
hour TWA is 85 dBA.
 APPENDIX C
ACRONYM SHEET

ACGIH - American Conference of Governmental Industrial Hygienists

AIHA - American Industrial Hygiene Association
ANSI - American National Standards Institute
ASTM - American Standards for Testing Materials
CFR - Code of Federal Regulations
D&D - decontamination and decommissioning
DOE - Department of Energy
FIU - Florida International University
HAZCOM - Hazard Communication
HAZWOPER - Hazardous Waste Operations
HEPA - high efficiency particular air (filter)
MSDS - Material Safety Data Sheet
NIOSH - National Institute of Occupational Safety and Health
NFPA - National Fire Protection Association
O.D. - outside diameter
OSHA - Occupational Safety and Health Administration
PEL - permissible exposure limit
PPE - personal protective equipment
PVC - polyvinyl chloride
SOP’s - standard operating procedures
TLV - threshold limit value
TSDS - Technology Safety Data Sheet
TWA - Time Weighted Average
µg - micrograms