EP 1110-1-27
27 Jan 00
Chapter 7
Health and Safety Concerns
HTRW well system O&M has a number of critical health and safety issues related to general well and
pump mechanical and electrical operation and control, as well as specific concerns of handling potentially
hazardous formation and treatment fluids, and related issues such as confined space operation.
7-1 Health and Safety Plan
O&M safety must be a component of overall site safety. The development and implementation of a
specific but flexible plan is needed, including personnel expertise and compliance, and training to make
personnel thoroughly familiar with chemical and mechanical activities. Depending on the specific nature
of the well system and the nature of the contaminants and treatment chemicals, O&M activities will
require worker hazard analyses and compliance with any applicable OSHA standard found in 29 CFR
1910 and/or 29 CFR 1926, in addition to any applicable requirements of EM 385-1-1. In all cases, the
O&M safety and health managers will be required to comply with 29 CFR 1910.132 through the
performance of a site-specific hazard analysis, the selection of personal protective equipment (PPE)
appropriate to protect workers from the hazards identified, a written hazard assessment certification, and
worker training in the hazards and PPE to be used. The following guidance will assist in that effort.
7-2 Level of Protection for Mixing and Well Application
Well maintenance treatments involve the use of reactive chemicals (Sections 6-1 and 6-2). Once a
chemical regime is selected, the appropriate use of chemical-resistant gloves, boots, and apparel, full-face
splash shields, and other specific protection such as for handling hot and supercold solutions should be
specified. See Section 6-1 and other references. An excellent strategic policy for safety is to, as a rule,
employ treatment mixtures that minimize hazard and the likelihood of personal injury due to error, while
still being effective. The mixture in Appendix C is one such treatment.
7-3 Chemical Handling Hazards
a. Transferring chemical solutions. Typically, the major exposure injury risk point during PM
treatment is at drums containing concentrated acid, caustic, or oxidizing agent solutions. Spilling or
transfer hose troubles may result in skin exposure. Vapors may cause mucous membrane and eye tissue
irritation or damage. Persons handling concentrated chemicals should wear full-face splash guards and
respirators and chemical resistant clothing and gloves. Persons handling dilute solutions may work with
care in OSHA Level D gear (29 CFR 1910).
7-4 Mixing Chemicals
a. Mixing hazards. Mixing of concentrated reactive solutions can result in personal hazards. For
example, neutralization of acids poses a potential hazard if basic compounds are added too rapidly to
strongly acid solutions (pH <5). Significant foaming may occur.
b. Hazard review. Personnel should review how to handle specific chemical source stock and
solutions. MSDS provide general guidance but should not be relied upon for complete instructions, which
should be in the site-specific O&M Site Safety and Health Plan (Section 7-1). General chemical mixing
safety requirements are listed below:
7-1