WIPP Report - DOE VPP Onsite Review
Westinghouse Waste Isolation Pilot Plant: Report from the DOE Voluntary Protection Program Onsite Review
August 29 through September 2, 1994



U.S. Department of Energy



Office of Safety and Quality Assurance

Office of Occupational Safety

Technical Support Division

Washington, D.C. 20585

September 19, 1994





Foreword

--------



     The Department of Energy (DOE) recognizes that true excellence can be

encouraged and guided but not standardized. For this reason, on January 26,

1994, the Department initiated the DOE Voluntary Protection Program

(DOE-VPP) to encourage and recognize excellence in occupational safety and

health protection. This program closely parallels the Occupational Safety

and Health Administration s (OSHA) Voluntary Protection Programs

(VPP). Since their creation by OSHA in 1982, the VPP programs have

demonstrated that cooperative action among government, industry, and labor

can achieve excellence in worker health and safety.



     DOE-VPP outlines areas where DOE contractors and subcontractors can

surpass mere compliance with DOE Orders and OSHA standards. The program

encourages the creative stretch for excellence through systematic

approaches involving everyone in the contractor or subcontractor workforce

at DOE sites. DOE-VPP emphasizes creative solutions through cooperative

efforts by managers, employees, and DOE.



     Requirements for DOE-VPP participation are based on comprehensive

management systems, with employees actively involved in assessing,

preventing, and controlling the potential health and safety hazards at

their sites. DOE-VPP is designed to apply to all contractors in the DOE

complex and encompasses production facilities, research and development

operations, and various subcontractors and support organizations.



     DOE contractors are not required to apply for participation in the

DOE-VPP. In keeping with OSHA s VPP philosophy, participation is strictly

voluntary. Additionally, any participant may withdraw from the program at

any time.



     DOE-VPP consists of three programs, with names and functions

similar to those in OSHA s VPP. These programs are STAR, MERIT, and

DEMONSTRATION. The STAR program is the core of DOE-VPP. This program is

aimed at truly outstanding protectors of employee safety and health. The

MERIT program is a steppingstone for contractors and subcontractors that

have good safety and health programs but need time and DOE guidance to

achieve true STAR status. The DEMONSTRATION program is expected to be used

rarely; it exists to allow DOE to recognize achievements in unusual

situations about which DOE needs to learn more before determining approval

requirements for the STAR program.



     By approving an applicant for participation in DOE-VPP, DOE recognizes

that the applicant is meeting, at a minimum, the basic elements of ongoing,

systematic protection of employees at the site. The symbols of this

recognition provided by DOE are certificates of approval and the right to

use flags showing the program in which the site is participating. The

participant may also choose to use the DOE-VPP logo on letterhead or on

award items for employee incentive programs. DOE will provide the

opportunity for contractors to work cooperatively with the agency to

resolve health and safety problems. Each approved site will have a

designated DOE staff person to handle information and assistance requests

from DOE contractors.



     This report, the first DOE-VPP Onsite Review Team report, summarizes

the team s findings from the evaluation of Westinghouse Waste Isolation

Division activities at the Waste Isolation Pilot Plant (WIPP) during the

week of August 29 through September 2, 1994. It is a milestone in the

Department s efforts to encourage the empowerment of employees and to

change the safety culture in DOE from compliance-driven reactivity to

continuous improvement driven proactivity.





     The purpose of this report is to provide the Assistant Secretary for

Environment, Safety and Health with the necessary information to make the

final decision regarding the disposition of Westinghouse s application

efforts for DOE-VPP. Included are synopses of team member findings, and the

team s final recommendation for the site.





Contents

--------





Section                                                          Page

-------                                                          ----



Foreword....................................................      iii

Acronyms and Abbreviations..................................      vii

Executive Summary...........................................       ix



I.        Introduction......................................        1



II.        Quantifiable program results.....................        2



III.        Management leadership...........................        3

        A.        Policy and Goals..........................        3

        B.        Written Program...........................        3

        C.        Responsibility............................        3

        D.        Authority and Resources...................        3

        E.        Line Accountability.......................        3

        F.        Management Visibility.....................        4

        G.        Subcontractor Programs....................        4

        H.        Annual Self-Evaluation....................        5



IV.        Employee involvement.............................        5



V.        Safety and health program.........................        7

        A.        Worksite Analysis.........................        7

                (1)        Change analysis..................        7

                (2)        Comprehensive surveys............        8

                (3)        Routine hazard assessments.......        9

                (4)        Routine hazard analyses..........       10

                (5)        Employee reports of hazards......       11

                (6)        Accident investigations..........       11

                (7)        Trend analysis...................       12

        B.        Hazard Prevention.........................       13

                (1)        Access to certified professionals       13

                (2)        Methods of hazard control........       13

                (3)        Positive reinforcement...........       15

                (4)        Disciplinary system..............       16

                (5)        Preventive/predictive maintenance   16

                (6)        Tracking systems.................       17

                (7)        Emergency procedures.............       18

                (8)        Medical programs.................       18



        C.        Safety and Health Training................       19

        D.        General Review of Safety and Health Conditions   20

        E.        Overall Safety and Health Program Assessment     20



VI.        Recommendation...................................       20



Appendix. DOE-VPP Onsite Review Team Members for 

          the Waste Isolation Pilot Plant...................       21







Acronyms and Abbreviations

--------------------------



ACE - ALARA and Chemical Exposure (a committee at WIPP)

ALARA - as low as reasonably achievable (referring to workers exposure to

        radiation)

ANSI - American National Standards Institute (New York, NY)

ASME - American Society of Mechanical Engineers

BLS - Bureau of Labor Statistics (of the U.S. Department of Labor)

CFR - Code of Federal Regulations

CMR - Central Monitoring Room

DOE - [U.S.] Department of Energy

EHS - Environment, Health, and Safety (a council at WIPP)

EPA - [U.S.] Environmental Protection Agency

EPADS - Employee Performance Appraisal & Development System

ESH - environmental safety and health (at WIPP)

ESH&RC - environmental safety and health and radiological control (at WIPP)

GET - general employee training

HASP - Health and Safety Plan (an EPA term; called Site-Specific Safety

       and Health Plan by OSHA and Site Safety and Health Plan by the

       U.S. Army Corps of Engineers)

IH - industrial hygiene

INEL - Idaho National Energy Laboratory (Idaho Falls, ID)

IS - industrial safety [Department at WIPP]

JHA - job hazard analysis

LWC - lost workday case

LWDI - lost workday incidence

MAST - management and supervisor training

MSDS - material safety data sheet

MSHA - Mine Safety and Health Administration

NEPA - National Environmental Policy Act of 1969

NIOSH - National Institute for Occupational Safety and Health

NIST - National Institute of Standards and Technology (Gaithersburg, MD)

NQAO - National Quality Assurance Organization

NRC - Nuclear Regulatory Commission

ORPS - Occurrence Reporting and Processing System

OSHA - Occupational Safety and Health Administration (of the U.S.

       Department of Labor)

PM - preventive maintenance

PMS - performance measurement system

PPE - personal protective equipment

QIP - Quality Improvement Plan

QIT - Quality Improvement Team

RAC - risk assessment code

RCA - root cause analysis

RII - recordable injury and illness

SAR - safety analysis report 

SIC - standard industrial classification

START - Supervisor Training and Accident Reduction Training

VPP - Voluntary Protection Program

WID - Waste Isolation Division (of Westinghouse)

WIPP - Waste Isolation Pilot Plant (Carlsbad, NM)

WP - Westinghouse Procedure





Executive Summary

-----------------



     The U.S. Department of Energy s Voluntary Protection Program team

completed the five-day onsite review of the Waste Isolation Pilot Plant

(WIPP) site on September 2, 1994.  The team consisted of 14 members

(including three observers) representing a diverse cross section of the

Department. Members included managers and professionals from DOE

Headquarters; a representative from the Rocky Flats Operations Office; a

representative from the Oil, Chemical and Atomic Workers Union at Oak

Ridge; an individual from the Occupational Safety and Health Administration

(OSHA); an individual from the Voluntary Protection Program Participants

Association (as an observer); a representative from Environmental

Management (consultant- observer); and consulting professionals.



     The site was evaluated for the degree to which it had successfully

implemented the five tenets of DOE-VPP. Included in the evaluation were 162

interviews of both staff and management. A capsule summary of the team s

conclusions for each tenet is as follows:





1.  Management Commitment.  An extremely high level of management

    commitment was demonstrated during the review of the WIPP site. This

    commitment was confirmed by employees who were interviewed. Management

    is visibly involved in the safety and health program, most notably

    through regular walkaround visits that are performed as a part of the

    Landlord Program. Under this program, senior-level managers are

    designated as landlords for a portion of the site and are responsible

    for ensuring that these areas are in good repair and are free of

    routine hazards. Each landlord is tasked with developing a personal

    checklist for a requisite monthly safety walkaround. During these

    walkarounds the landlords also talk with employees about safety issues.



2.  Employee Involvement.  Employee involvement at the WIPP site is truly

    outstanding. Interviewed employees expressed a sense of ownership for

    the site and for the safety and health program. The employees were

    candid and cooperative with the team, and indicated that they had no

    fear of reprisal for relaying any safety concerns to

    management. Employees related instances where they had stopped work

    because they believed a situation might be unsafe, and pointed out that

    they have never been reprimanded for doing so. In fact, instead of

    being admonished, they were always assisted by management in resolving

    their concerns. Employees felt that management was truly concerned

    about their well-being, and were empowered to immediately correct a

    hazardous situation or bring the condition to management s attention.



3.  Worksite Analysis.  Worksite analysis at WIPP was thorough and

    comprehensive. Extensive programs were in place to identify hazards in

    new or modified processes as well as in existing

    processes. Comprehensive surveys performed by the site staff and by

    expert consultants had been exhaustive and were well documented. Any

    items requiring correction were tracked to completion. Review of the

    work-control system revealed that there are no backlogs for any

    safety-related work requests. Interviewed employees verified that

    safety-related work requests are given the number one priority, and

    that correction of hazards is always timely, if not

    immediate. Employees are specifically involved in worksite analysis

    through their development of both procedures and job hazard

    analyses. The team noted several instances, most notably during safety

    and health committee meetings, where the employees were also involved

    in hazard correction.



4.  Hazard Prevention and Control.  Management, safety and health staff,

    and workers at the WIPP site have been aggressively focused on

    preventing and eliminating hazards. There has been a consistent

    campaign to eliminate chemicals at the site, and where that is not

    practical, to substitute less-hazardous chemicals or at least to reduce

    the quantities used.



    Also of particular note is the strong coordination and cooperation

    observed between the occupational health nurses and the safety and

    industrial hygiene staff. Located in the same building, they

    communicate regularly and conduct evaluations together. The industrial

    hygienist typically provides the nurses a copy of sampling

    data. Following the classic hierarchy of control, the safety and health

    staff evaluates the use of engineering controls if the identified

    hazards cannot be eliminated. Many excellent examples of engineering

    controls of hazards were pointed out during the DOE-VPP visit. The most

    impressive engineering effort is the mine ventilation system, which

    moves 425,000 cubic feet (12,000 m3) of air into the underground each

    minute.



    The team unanimously voted to recommend the Waste Isolation Pilot

    Plant for official designation as a STAR site.



    The WIPP site places considerable emphasis on professional

    certification and experience for its safety and health staff. The

    safety and health staff consists of seven full-time professionals with

    over 60 combined years of safety and health experience.



5.  Safety and Health Training.  WIPP has an exceptional safety and health

    training program that has been in place for more than 5 years.  Site

    employees reported that safety training helps them understand the

    potential hazards of their job and ways to protect themselves.

    Employees were observed to be properly using personal protective

    equipment (PPE), and when questioned they were knowledgeable about its

    limitations and care. The employees could also explain in detail what

    their responsibilities and actions would be for different types of

    emergencies at the site.  The training staff was found to be highly

    skilled and motivated.  Top management fully supports the training

    program, as evidenced by interviews with employees and supervisors,

    funding levels, and by their active review and approval of training

    materials.



Recommendation

--------------



     Based on the information gleaned during the onsite visit, the team

unanimously voted to recommend the Waste Isolation Pilot Plant for official

designation as a STAR site.





I. Introduction

---------------



     The Westinghouse Waste Isolation Division (WID) DOE-VPP onsite review

was conducted from August 29, 1994, through September 2, 1994, at the Waste

Isolation Pilot Plant (WIPP) in Carlsbad, NM. The Onsite Review Team was

composed of 11 members, representing various disciplines and complemented

by 3 observers. The names and titles of the team members and observers can

be found in the Appendix.



     WIPP is a U.S. Department of Energy (DOE) facility, operated under

contract by Westinghouse Electric Corporation. It is designed to

demonstrate the safe handling, transportation, and disposal of transuranic

waste in deep salt beds. (The deep-bedded salt formation has been

geologically stable for more than 225 million years.) Stationed at the site

are some 1,020 employees. Of these, 782 are employed by Westinghouse, 45 by

DOE, 46 by Sandia Laboratories, and 147 by subcontractors.



     There are no outstanding safety and health noncompliance items that

require correction.



     Under Public Law 96-164, the U.S. Congress mandated the construction

and development of WIPP as a research and development project. The facility

will dispose of transuranic wastes exclusively not commercial or high-level

wastes. Transuranic wastes are those containing, or contaminated with,

radioactive elements heavier than uranium. Most of the waste consists of

contaminated laboratory gloves, tools, dried sludges, and other material

discarded from laboratory or production facilities.



     The site is located about 26 miles east of Carlsbad, NM. Construction

of the facility began in 1979. It is estimated that the site will not be

fully operational (that is, will not be receiving wastes) until at least

mid-1998. The site comprises three kinds of facilities:



     * Assorted surface buildings

     * Four vertical shafts, each 2,150 feet (655 m) deep

     * A 7.2-mile (11.6-km) underground network of horizontal storage rooms,

       alcoves, and tunnels.



     The surface buildings house the site personnel and equipment needed

for WIPP operations and research activities. The shafts connect the surface

facilities to the underground; in this way, it will be possible to move

transuranic waste to its underground destination.



     The site is slated to receive defense-generated transuranic wastes

from DOE facilities throughout the complex.  Once WIPP is operational, the

defense sites can ship directly to the facility.  Presently, transuranic

wastes are stored in sealed containers above ground at sites such as the

Idaho National Engineering Laboratory (INEL).



     This onsite review was the first DOE-VPP review to be conducted by the

Department at one of its contractor sites. The primary purpose was to

verify information provided by the WIPP site in its DOE- VPP

application. Because of the WIPP site s mission to safely dispose of

transuranic wastes the site is classified with a standard industrial

classification (SIC) code of 4953, which denotes refuse systems. Until such

wastes are received, the predominant activity at WIPP is mine maintenance;

the aim is to prevent the site from undergoing subsidence and, as a

consequence, premature closure.



     Because WIPP deals exclusively with transuranic wastes, the site has

no peer in the private sector. To compare its lost workday incidence (LWDI)

and recordable injury and illness (RII) rates with those of comparable

facilities, the team chose as a benchmark the nonmetal mining industry s

average rates published by the Bureau of Labor Statistics (BLS). Therefore,

an SIC code of 1490 has been chosen for comparison purposes. In 1998, when

the site begins receiving wastes, the WIPP site will again be evaluated by

an Onsite Review Team. At that time, the LWDI and RII rates will be

compared to sites bearing the SIC code of 4953 for refuse systems.



     This report is based on three sources of information:



     * Information submitted with the application

     * Additional onsite documentation

     * Formal and informal interviews of various levels of managerial and

       nonmanagerial Westinghouse employees.



The team conducted 57 formal and 105 informal interviews.



     No collective bargaining employees are stationed at the site. There

has never been a Tiger Team Assessment, nor are there any outstanding

safety and health noncompliance items that require correction.



II. Quantifiable Program Results

--------------------------------



     The team reviewed OSHA 200 logs for the preceding 3 calendar years,

and for the current year. To calculate the LWDI and RII rates, the team

used two standard formulas:



               No. of RIs [Col(1) + Col(2) + Col(6)] * 200,000

    RII Rate = -----------------------------------------------

                          No. of Employee Hours Worked







                No. of LWD cases [Col(2)] * 200,000

    LWDI Rate = -----------------------------------

                   No. of Employee Hours Worked





     The following table provides the data and rates for the preceding

three calendar years, together with the three-year average.





Injury and Illness Rates at WIPP

--------------------------------

Calendar Year     LWD Cases    RI Cases   Employee-Hours   LWDI   RII

---------------------------------------------------------------------

1991                  4           11        1,529,932      0.53  1.44



1992                  4           10        1,632,452      0.49  1.23



1993                  2            7        1,677,380      0.24  0.83



3-Year Avg.          10           28        4,839,764      0.41  1.15



BLS National Average

for SIC code of 1490 =                                     4.0  6.7





     The 3-year average rate for both RII and LWDI is substantially below

the industry average published by BLS. These rate calculations include both

WIPP and temporary workers. The information entered on the OSHA 200 log

generally supports the information submitted in the application and

contained in the supporting injury/illness documents. The person

responsible for maintaining the log was found to be knowledgeable in the

OSHA 200 log requirements.



     The 3-year average rate for both recordable injury and illness rates

and lost workday incidence is substantially below the industry average

published by the Bureau of Labor Statistics.



     During the first 3 months of 1994, the site s historically favorable

LWDI and RII rates rose somewhat. Most of the additional injuries involved

employees with administrative duties. In a departure from national trends,

their injuries did not involve cumulative trauma disorders such as carpal

tunnel syndrome or lower-back pain. To determine what caused the injury

rates to rise, WIPP surveyed employees and was compiling the survey results

during the review. Attempts were underway to reduce injuries to a rate at

or below their former level.





III.        Management Leadership

---------------------------------



A.        Policy and Goals



     The WIPP facility has a written safety and health policy that has been

communicated to all levels of employees. This broadband communication

strategy was verified by many employees through formal and informal

interviews. Until July 1994, goals were set twice a year during the

development of the Quality Improvement Plan (QIP). In July, the QIP

development frequency was changed to yearly.  Safety is a cornerstone of

the QIP goal-setting process. Goals are developed by the Quality

Improvement Team (QIT), which comprises representatives from every

department, including Industrial Safety. The most recent QIP included

safety and health improvement goals to be addressed next year.



B.        Written Program



     The written safety and health program is described in the WIPP Safety

Manual, WP 12-1, Rev. 3. The manual prescribes in detail how to implement

the administrative aspects of the safety and health program. The manual

also provides for safety and health requirements, electrical requirements,

industrial hygiene, and fire protection. Where appropriate, other resource

materials are referenced (for example, OSHA 29 CFRs, MSDSs, ANSI, ASME) for

additional guidance. This revision of the written program has been in place

since the first half of 1993.



C.        Responsibility



     The written program clearly assigns safety and health responsibility

at all levels of management in the worksite WIPP Safety Manual 12-1,

Rev. 3. At the time of the onsite review, these assignments had been in

place for well over a year.  Responsibilities are further defined in the

Management and Supervisor Training (MAST) Program (the MAS-123 document),

which all supervisors must complete. The guide also reinforces the site

philosophy that safety is the number one priority. This philosophy was

confirmed through interviews with several personnel representing various

levels of management and nonexempt employees.



     Employees are authorized to shut down a piece of equipment, or an

operation, that they believe to be unsafe.



     Safety and health professionals are used by the line as

resources. These individuals lend technical expertise on an as-needed basis

while providing guidance, policies, and procedures.



D.        Authority and Resources



     WIPP management provides its organizations with enough workers,

training, and equipment to fulfill their responsibilities. This was

evidenced by an adequate level of staffing and the provision of adequate

personal protective equipment, the absence of equipment maintenance

backlogs, and the extensive training provided. The team observed no

conditions that would suggest a lack of resources for occupational safety

and health. Employee interviews revealed no situation where their safety

and health concerns were not addressed for want of resources and

funding. Indeed, in a policy uncommon among DOE sites, all employees are

authorized to shut down a piece of equipment, or an operation, that they

believe to be unsafe.



E.        Line Accountability



     According to documentation reviewed onsite, management accountability

has been assessed under a performance appraisal system known as the

Performance Measurement System (PMS). In reviewing performance records, it

was discovered that safety is one of seven equally weighted elements under

the PMS. The PMS is essentially a qualitative evaluation; for each element,

performance is described in narrative form. The PMS was in use until June

30, 1993, at which time a transition was initiated to a newer system, the

Employee Performance Appraisal & Development System (EPADS).



     During the transition appraisal period (July 1, 1993, to June 30,

1994), employees were evaluated under a hybrid system which combined

elements of PMS and EPADS. Since the end of the transition appraisal

period, EPADS has been and will continue to be used exclusively.



     The EPADS is a quantitatively based system consisting of 20 equally

weighted job elements. Each is rated from 1 to 5, with 5 being the highest

rating. Overall performance is calculated as a simple arithmetic mean: the

20 individual ratings for the elements are added up and the sum is divided

by 20. Since safety comprises but one element, it accounts for 5 percent of

the overall score. According to management personnel interviewed, an

element can be given additional weighting at the discretion of the rating

official.



     For the evaluation year that began July 1, 1994, management introduced

an improvement to the EPADS. In the revised system, the evaluation form for

each element includes a section for listing specific written goals for the

safety element. The goals are jointly developed by the person to be rated

and the rating official; they must be measurable and attainable. Making

safety an integral part of each element s score is a positive step and a

key part of ensuring accountability.



     Another key provision for ensuring accountability in safety

performance is assigning appropriate weight to the safety element in the

performance appraisal process.  Management is in the process of identifying

those employees with jobs in which safety represents a critical component

of their performance. The actual weighting accorded the safety element will

be based on the importance of safety performance coupled with the

successful attainment of the written safety goals for the particular

position. By applying a proportional weight for the safety element in the

facility s performance appraisal process, WIPP ensures that a meaningful

assessment of accountability and performance occurs.



F.        Management Visibility



     Top management is highly visible to exempt and nonexempt employees in

demonstrating their commitment to and leadership in the safety and health

program. Top management participates in the all-employee

meetings. Moreover, employees affirmed that management exhibits a strong

presence in both surface facilities and underground.



G.        Subcontractor Programs



     Before subcontractors are finally selected and given a notice to

proceed at the site, they must undergo a rigorous preapproval process. This

process includes an in-depth screening of their health and safety plans

(HASPs), job hazard analyses (JHAs), safety training, and OSHA 200 injury

and illness logs. The WIPP Safety Office reviews the data and recommends a

final selection to the contracts office .



     Top management is highly visible to exempt and nonexempt employees in

demonstrating their commitment to and leadership in the safety and health

program.

 

     Subcontractor workers adhere to the same safety and health rules that

apply to the Westinghouse employees. The subcontractors that were

interviewed recognized that their safety and health performance was

important to the selection process and to their continued tenure at

WIPP. There have been documented cases in which subcontractor workers were

asked not to return to work because of serious or repeat safety violations.



     The Industrial Safety Department oversees all subcontractor

operations. The office periodically audits the work areas, documenting

discrepancies on a standard form used during audits. Usually these

discrepancies are corrected expeditiously or mitigated by the appropriate

subcontractor. Discrepancies that are not corrected immediately are entered

onto the site s hazard abatement listing. If need be, work can be stopped

by any employee, including a subcontractor. The Industrial Safety

Department also requires subcontractors to complete their own

self-audits. Team walkaround inspections indicated that these audits were

being performed and documented.



     Subcontractor injuries and illnesses are reported to the medical

clinic. The Industrial Safety Office maintains OSHA Form 101s (First Report

of Injury) for inspection by the site technical representatives. The

subcontractor rates for the preceding 3 years are also maintained in the

office and they fall well below the industry SIC average. A review of the

OSHA 200 logs for subcontractors verified that information listed on the

records was accurate.



H.        Annual Self-Evaluation



     As evidenced by documents provided to the DOE Onsite Review Team, the

WIPP site conducts a formal self-evaluation of safety and health program

performance. The ESH&RC Internal Assessment Program Plan requires that the

effectiveness of all aspects of the safety and health program must be

evaluated by an independent assessment group. Those persons internally

involved in the assessment process must receive self-assessment training

(in accordance with WP 15-MD3050). The results of the assessments must be

monitored, tracked, and trended.



     The most recent evaluation had been conducted in April 1994; copies of

the report were distributed to all department managers the following

June. All program elements were assessed in accordance with DOE-VPP

requirements.  The WIPP site provided the DOE- VPP team with the status on

all recommendations made.



     In addition to the April 1994 self-evaluation, a safety and health

program performance evaluation was conducted by the Corporate EHS Council

in July 1994. This evaluation has been conducted at the WIPP site for more

than 10 years. The evaluators assigned numeric ratings to all elements of

the safety and health program. Narrative explanations were provided in

areas where a program element received a less-than- perfect score, followed

by a recommendation.  For program elements receiving a perfect rating, no

narrative was provided.



     The team was provided with an assessment of the progress made on the

safety goals in the Quality Improvement Plan. The site is considering

revising the annual assessment to better track and evaluate accomplishment

of past QIP safety goals and timing the assessment to correspond with

development of future QIP goals.





IV.        Employee Involvement

-------------------------------



     The Onsite Review Team observed that WIPP employees actively

participate in the structure and operation of the WIPP safety and health

program.  The site s policy is to involve employees in the development of

policies and procedures. Random interviews with 29 workers and managers

confirmed that employees are, indeed, involved.



     The team observed that WIPP employees actively participate in the

structure and operation of the WIPP safety and health program.



     The safety culture at WIPP became most apparent during interviews with

rank-and-file employees. Their comments were candid and almost uniformly

positive, as illustrated by the following typical examples.



          "Supervisors really respect the crafts here at WIPP."

          "Management circulated a memo yesterday giving the typical

          questions you guys would ask, but I threw it away because I

          believe in telling it like it is."



          "I had only been working for 2 months when I stopped work for an

          unsafe condition, when the boss came over I thought he would be

          mad and tell me that I was too new to be stopping work, but he

          only asked what we could do to make the job safe."



     All of those interviewed noted that they had never experienced

retaliation for stopping work. Many remarked that, compared to previous

sites at which they had worked, WIPP had the safest working conditions by

far.



     Management was extremely cooperative in providing access to employees

who had been selected at random to be interviewed. In many cases, the

supervisor pulled the workers from their duties and made them available on

the spot or within 10 minutes. One of the first-line supervisors commented,

"This is the first place I worked [where] upper management doesn t put

pressure on the line to get the job done right away or take shortcuts."



     "This is the first place I worked where upper management doesn t put

pressure on the line to get the job done right away or take shortcuts."



     Another indicator that employees are fully involved in their workplace

safety is their active participation on the WIPP safety committees. There

are three major safety committees:



     * the ALARA and Chemical Exposure (ACE) Committee,

     * the Safety and Security Committee, and

     * the Operations Safety and Communications Committee.



     Employees stated that the Operations Safety and Communications

Committee (referred to by the workers as the safety committee ) was the

primary means of bringing employee concerns to upper management s

attention. Meeting weekly, this joint manager/worker committee assigns the

relevant manager the duty of resolving the concern and setting a reasonable

milestone deadline of getting back to the committee with the settlement

results.



     There are also ad hoc committees, assembled to enhance employee

involvement when certain situations arise. A difficulty emerged last year

when some employees voiced concern over indoor air quality and the site

smoking policy. The safety committee appointed an ad hoc smoking committee

of managers and workers to resolve the issue. When WIPP amended the smoking

policy six months later to ban smoking in all WIPP surface buildings, the

committee was dissolved.



     Another example is the root cause analysis (RCA) teams which are

formed to investigate any accidents at WIPP. These are joint manager/worker

teams in which the team leader is required to be fully trained as a

certified RCA team leader. Since nonexempt workers are certified team

leaders, RCA teams led by nonexempt workers are routine. Once the team

results are obtained, the ad hoc team members are released to return to

their normal duties.



     The DOE-VPP team found that WIPP nonexempt employees exert

considerable influence on the design and operation of the safety and health

program. Many write their own job task packages, including a job hazards

analysis, which they forward to technical writers. After the technical

writer smoothes the draft package, it is returned to the worker, who must

approve the technical writer's changes before the analysis can be forwarded

up the managerial chain.



     WIPP uses dedicated nonexempt workers to act as independent safety

observers. These workers, known as rovers, walk the spaces of both surface

and underground facilities, looking for safety deficiencies and notifying

the area supervisor of any safety or health shortcomings. After notifying

the area supervisor, subject matter experts are summoned to take corrective

action or resolve the concern.



     Another indicator that employee involvement is genuine at WIPP is the

sense of ownership and pride that workers exhibited during the

evaluation. Most were very comfortable in speaking with the team about

safety and health issues. The team is convinced that the information

imparted during these interviews was candid and truthful.



     It is worth noting that the interviews went extremely well despite the

obvious stress of the recent DOE announcement, two weeks prior to the team

review, that the site will experience an 11 to 15 percent reduction in

budget for FY95. It is difficult for a worker to praise the safety and

health efforts of management when that worker s job may be eliminated in

the near future. Likewise, WIPP management s commitment to continue

spending resources on safety and health rather than cutting corners in the

face of austere budgets is extremely commendable.



V.        Safety and Health Program

-----------------------------------



A.        Worksite Analysis



     (1)  Change analysis



     The team observed that changes and modifications of equipment are

introduced into WIPP in two ways.



     *  The engineering design change process

     *  The routine maintenance of plant systems and equipment.



     New systems and equipment planned for installation at the WIPP site

are designed in accordance with the WIPP Safety Manual, Chapter 1, Section

12.7, Design and Design Review.  The process involves the following seven

phases.



1.  Engineering change proposal.  The process begins with an engineering

    change proposal that defines the conceptual design features of the

    proposed system or equipment. At this stage, the design engineer and

    the cognizant design manager determine the impact level of the design

    and the manager prepares a Design Review Plan. Impact levels determine

    how much scrutiny and rigor will be applied to the design. Impact

    levels range from impact level I assigned to the most complex and

    important designs to impact level IV assigned to systems or equipment

    of minor importance.



2.  Design.  For systems designs that have been assigned a lower impact

    level (III or IV), the Design Review Plan may apply a graded design

    review approach by conducting an independent review that is formally

    documented.



    For system and equipment designs assigned impact level I or II, the

    design process is formal and rigorous. After completing conceptual

    design, as specified in the Design Review Plan, WID Engineering may

    conduct a conceptual or preliminary design review that includes review

    by engineers from the following organizations:



         Environment, Safety, and Health (including fire protection)

         Regulatory Compliance

         Waste Handling Operations

         Radiological Safety

         Industrial Safety

         Other Engineering Disciplines

         NEPA designated staff.



3.  Comments.  Comments are formally received and dispositioned as the

    final design is being prepared.



4.  Final design review.  When the design is 90-percent complete, a formal

    final design review is conducted, as specified in the Design Review

    Plan. All of the applicable reviewers who helped review the conceptual

    design return to participate. As a part of this review, WIPP uses a

    Design Review Checklist. As its name suggests, the checklist

    systematically helps ensure that reviewers address all aspects of the

    design. The checklist includes sections on environmental protection,

    industrial safety, process safety, and Safety Analysis Report (SAR)

    impacts. As was done during the conceptual design review, formal

    comments are received and formally dispositioned before the system is

    constructed or installed.



5.  System turnover package.  Once the system is fabricated or built and

    startup testing is complete, WIPP engineering prepares a system

    turnover package for operations. The system turnover package is an

    engineering evaluation confirming that all of the people, parts, and

    procedures are in place and ready for use by operations. The review

    includes an individual review of operator training, spare parts, as

    well as field verification of procedures.



6.  Maintenance.  Maintenance work is controlled by the maintenance work

    request process. The hazards associated with the work are identified

    while work request packages and maintenance procedures are prepared. If

    the work involves an activity or piece of equipment that has an

    existing JHA (such as welding and cutting operations or certain

    hoisting and rigging activities), the JHA is included in the work

    package. Packages are planned with input from planners, maintenance

    engineering, safety, and crafts. Hazards that will be encountered in

    the work are identified in the prerequisites section and reiterated in

    the work instructions as CAUTION statements. Safe work practices are

    identified. Lockout points are recommended in the work requests and

    installed by operations. Maintenance personnel are given personal

    locking devices, which they use to overlock the operations

    locks. Safe-energy checks are used to confirm zero energy.



7.  Preventive maintenance. Preventive maintenance (PM) procedures are used

    for recurring PM activities. Maintenance engineering, planning, and

    crafts participate in the development of these procedures. Maintenance

    procedures are validated the first time the procedure is used. The Work

    Control Center attaches a validation form, and the procedure is

    performed while the planner, the engineer, and others, including safety

    personnel, if appropriate, observe to determine whether the procedure

    is adequate and practical. If the procedure cannot be performed as

    written, or needs changes, it is sent back to the Work Control Center,

    where the planner and the engineer, if need be, can revise the

    procedure.



    In reviewing a set of procedure validation packages, team members found

    one on which observers had contributed several changes to improve the

    workability and safety of the activity.



    As a precaution, the preventive maintenance procedure (like the

    maintenance work package) will state in the prerequisites section what

    hazards are likely to be encountered. Following good practice, cautions

    are placed in the work instructions before the steps where the hazards

    will be encountered, and safe work practices are described.



     (2)  Comprehensive surveys



     Baseline survey Baseline surveys are an integral part of every

successful safety and health program. For this reason, they are assigned

considerable significance in DOE-VPP. DOE-VPP criteria require that the

surveys be conducted by qualified individuals at intervals appropriately

frequent for the nature of a given workplace operation. The surveys must

cover all contractor spaces as well.



     From June 26 to July 3, 1990, a baseline survey was conducted at WIPP

by a qualified outside consulting firm. The survey team was composed of

Professional Engineers, Certified Industrial Hygienists, and Certified

Safety Professionals with decades of safety and health experience,

including employment with OSHA. The survey included not only a wall-to-wall

inspection of every building and trailer, but also a review of written

programs.



     The 1990 reviewers looked at seven programs:

         Hearing conservation

         Respiratory protection

         Hazard communication

         Confined space entry

         Fire protection

         Lockout/tagout

         Preventive maintenance.



     The programs received generally favorable responses, and only limited

changes were recommended.



     The 1990 survey found that there were no instances of industrial

hygiene significance observed in any of the buildings, shops, trailers, or

other workplaces visited.  The inspectors did find, however, more than 80

violations of OSHA general industry standards in 300 different instances.



     To abate these hazards, the site completely shut down operations for a

day and tackled the bulk of the findings. Coordinated teams of

electricians, carpenters, and other trades fixed roughly 95 percent of the

items that same day. Remaining items required more significant engineering

controls.



     1991 survey Westinghouse hired the same outside consultant to return

to the plant in 1991 to evaluate the company's abatement efforts through

another comprehensive survey. This second survey included some 60

buildings, trailers, and work areas. The firm found that:



            for the most part, significant improvement was

            noted particularly in many of the locations

            revisited where serious hazards and discrepancy

            trends reported as a result of the 1990 survey had

            been adequately corrected.



As in the earlier survey, the team reported during the walkthrough that:



            there were no observations of employee exposures

            to any particular health hazards. The potential

            for employee over exposures to airborne

            contaminants appears to be minimal for the most

            part. However, as noted in the 1990 report,

            systems are in place to allow the safety and

            health staff to effectively deal with any

            potential risks of overexposure that may

            occur. There were no areas, locations, or

            processes noted during the survey where

            ventilation was lacking but appeared necessary by

            virtue of toxic hazardous releases.



     The consulting team did note several areas in Buildings 411, 456, 463,

and 485 where noise levels were found to equal or exceed the OSHA action

level and for which they recommended posting caution signs and continued

monitoring. During the DOE-VPP team visit, several of these areas were

checked by the team and found to have been posted as recommended.



     The findings of these two surveys were used as a basis for the

Landlord Program, which is still in place.  Under this program,

senior-level managers are designated as landlords for a portion of the site

and are responsible for ensuring that these areas are in good repair and

are free of routine hazards. Each landlord is tasked with developing a

personal checklist for a requisite monthly safety walkaround. During these

walkarounds, the landlords also talk with employees in their cognizant area

about safety concerns and issues.



     In addition to the Landlord Program, the safety and health staff

developed a baseline worksheet that has been used since 1993 to evaluate

the buildings more thoroughly, including information on life safety, fire

protection, process hazard identification, operational hazards, and

chemicals used in the facility. Several of these forms were reviewed by the

team and found to be an important hazard assessment tool. According to the

DOE-VPP application, a total of 85 buildings and facilities have been

surveyed 100 percent of the buildings onsite.



     To abate the hazards revealed in the 1990 baseline survey, the site

completely shut down operations for a day and fixed 95 percent of the

findings.



     Industrial hygiene information from these individual building surveys

has been compiled into an important database called the Industrial Hygiene

Status Report & Assessment Strategy, which lists the chemical and physical

agents found in each work area and indicates the medical surveillance

requirements and what monitoring frequency is appropriate.



     Interviews with the WIPP safety staff and the occupational health

nurses indicated that they have conducted joint inspections, such as a

noise evaluation in the hoist operation and an indoor air quality survey of

Building 411.



     (3)  Routine hazard assessments



     Because of the unique hazards posed by WIPP s extensive underground

facilities, two varieties of routine hazard assessment are performed: one

for surface areas, the other for underground areas.



     Surface.  Westinghouse performs several types of self-conducted routine

hazard assessment for the WIPP surface facilities. These include:



1.  A daily inspection by facility operations, covering the entire

    facility. These inspections have been conducted since 1987.



2.  Monthly inspections by facility engineers, Emergency Services

    technicians, and landlords. Once a month, the facility engineers cover

    select areas of the site, while the Emergency Services technicians

    cover each building. These inspections have been conducted since the

    inception of the site.



    The Landlord Program has been covering all surface facilities at least

    quarterly for the past three years. Today, the landlord program covers

    the entire surface area on a monthly frequency. This assessment is

    focused primarily on safety- and health- related items. Currently, the

    surface is divided into 17 areas, each with its own cognizant

    landlord. The landlords are typically managers or professionals who

    work in the appointed area. Trained in developing checklists and

    recognizing hazards, they are responsible for developing a checklist,

    in conjunction with the safety department, based on the activities,

    operations, and hazards in their cognizant area. Each month, the

    landlord completes this checklist and submits it to the safety

    department.



    As the landlords walk around, employees are free to approach them and

    voice any safety and health concerns. Deficiencies noted in the

    landlord inspection are handled by persons in the cognizant area, or,

    if required, entered into the work control system to be prioritized and

    corrected. If an item requires a significant time for correction,

    mitigative actions are taken. Landlords have shutdown authority.



3.  The safety organization inspects all surface areas and equipment using

    a risk-based scheme to determine the interval of inspection. The entire

    site is covered annually; higher-risk facilities are covered quarterly.



     Underground.  Several kinds of routine hazard assessments are conducted

underground. Performed at varying intervals, they focus on different areas:



1.  Each day, personnel inspect their work areas, the equipment they use,

    and the grounds in which they work.



2.  Daily inspections are likewise performed by Industrial Safety, Mining

    Operations, rovers, and Facility Operations. The Facility Operations

    inspections cover the entire underground area each day.



3.  The entire underground area is also inspected each week by two groups

    from Mining Operations.



4.  Heavy scaling inspections are performed approximately monthly; these,

    too, cover the entire underground area.



5.  Heavy scaling inspections are also performed in advance of quarterly

    inspections by the Mine Safety and Health Administration (MSHA).



6.  Finally, an annual comprehensive and intensive inspection of the entire

    underground is performed by the entire Mining Operations staff.



     Most of these inspections generate written reports that must be signed

off by cognizant personnel.



     The team found that the various inspection systems were very

successful in documenting hazards and tracking them to completion. All

underground hazard assessment systems examined had been in place since 1989

or earlier.



     Overall.  Each of the groups performing the inspections noted above is

trained to recognize hazards. Each is expected to note and report any

hazards. The Onsite Review Team s evaluation of inspection reports,

particularly those generated by the landlord inspections, confirmed that,

once noted, a hazard is tracked to correction by the cognizant

landlords. Interviewed employees were very aware of the self-inspections;

they regarded the self-inspections as thorough, and they felt free to

express any concerns or point out any hazards to the various organizations

performing the self- inspections.



     (4)  Routine hazard analyses 



     Routine hazard analyses at WIPP are conducted in a variety of

ways. Hazard analyses of non- routine onsite work are documented in

process- oriented Job Hazard Analyses (JHAs). Hazards of operating WIPP

equipment are documented in equipment JHAs. Hazard analyses of routine work

are a part of the site s procedures.



     The WIPP JHA system was significantly upgraded to its present level of

effectiveness and rigor in 1991.



     JHAs for both process hazards and equipment hazards are prepared

according to WP 12-111, Job Hazard Analysis, of the WIPP Safety Manual.

The procedure outlines the four steps of a JHA:



1.  Select a job to be analyzed.

2.  Break the job into steps, activities, or phases.

3.  Identify the hazard and potential accidents.

4.  Develop safe job instructions.



     Process-type JHAs are kept with the work package for which they were

developed. Equipment JHAs are used to train personnel on the equipment and

are incorporated into work packages when needed.



     A number of JHAs were reviewed by the team for underground operations

and experimental operations.  Recommended practices to control or eliminate

the hazard were listed for each procedure step. The JHAs reviewed were

complete and thorough. Tours through the site revealed no areas that had

been left unaddressed in JHAs. Staff working on packages and in shops were

familiar with the JHAs and the hazards associated with the work activity.



     Contractors to WIPP are required by contract to identify and control

the hazards associated with their scope of work. One subcontractor

organization interviewed had no formal procedure for conducting and

preparing JHAs. However, for more than a year an informal system had been

in place and was being used effectively to generate, review, and update

JHAs for construction activities.



     (5)  Employee reports of hazards



     Employee concerns about the safety and health program at the WIPP site

are communicated by five avenues:



1.  Process Improvement Program forms

2.  Safety and Health Committee meetings

3.  Safety and Health Observation forms

4.  Safety and Health Hotline

5.  Westinghouse Employee Concerns Program.



     A review of the official Westinghouse Employee Concerns forms revealed

that none had been submitted during the first eight months of 1994. The

coordinator for employee concerns indicated that in 1993 WIPP expanded the

lines of communication to include the Process Improvement Program forms,

Safety and Health Committee meetings, and the Safety and Health Hotline,

and that these avenues, set up to facilitate a quick response, had become

the communication lines of choice when employees needed to have safety

concerns addressed in a timely manner. The majority of the forms reviewed

for 1993 had the box indicating the name of the person could be revealed

checked positive, indicating little fear of reprisal for reporting

concerns. All concerns systems are formally tracked in writing, and

responses to concerns are usually communicated within three days. All

concern systems include options to preserve an individual's anonymity by

request.



     Interviewed employees indicated knowledge about the concerns systems

through formal training, but indicated that, in most cases, safety concerns

are initially communicated to the first- line supervisor for immediate

correction at the lowest organizational level. If the first-line supervisor

cannot alleviate the concern, the concern might then be written up in the

official Westinghouse system, or presented by a safety representative

during a safety committee meeting. Concerns that arise in safety committee

meetings are formally documented on safety committee concern forms. These

are formally tracked to closeout. Employees are also free to file concerns

directly to DOE through DOE concern forms.



     All employees interviewed indicated that they were strongly encouraged

to express any safety and health concern.  Review of the work controls

system verified that no safety items had been left uncorrected once

reported.  Interviewees felt that management followed up on their concerns

and corrected deficiencies in a timely manner. Employees also indicated

that they are free to write an action request, which is then prioritized

and, if necessary, entered into the work controls system for resolution.



     (6)  Accident investigations



     The team observed written procedures that describe an excellent

accident/incident investigation system. These procedures include guidance

on the reporting of incidents or events which occur at WIPP, using a root

cause analysis to identify the source of the incident/event, and developing

an incident/event lessons learned for dissemination to WIPP management and

workers.



     The team s evaluation, based on document review and 29 random personal

interviews, confirmed that WIPP maintains a high-quality accident/incident

investigation program. The team also examined 18 incidents/events which met

the criteria of DOE 5000.3B and were reported to the Occurrence Reporting

and Processing System (ORPS) database since January 1993. Interviews

indicated that employees knew about the lessons learned bulletins, and the

root causes of events/incidents were readily available to all employees.



     All incidents/events are reported to the Central Monitoring Room which

is staffed around the clock and logged in by the duty officer. The duty

officer relays serious incidents or events to the WIPP Occurrence Reporting

Manager. If the incident/event meets the criteria of DOE 5000.3B, then an

occurrence report is generated in ORPS. Subsequent root cause analysis and

tracking are performed, and corrective actions taken, as specified in the

ORPS Order.



     If the incident/event merits attention but falls short of the

requirements of the ORPS Order, the incident/event s root cause analysis,

tracking, and corrective action are usually performed more informally.



     Those incidents/events which fall in either of the two categories

mentioned above are investigated by a root cause analysis (RCA) team

composed of exempt managers and nonexempt workers. Only individuals fully

trained and qualified as team leaders may serve as the RCA team

leader. Nonexempt workers can be qualified as RCA team leaders and

routinely perform in this capacity.



     The RCA, together with the provisions for preventive or corrective

action, are developed into a lessons learned bulletin by a lessons learned

board. This board consists of five members representing Engineering,

Safety, Training, the ORPS Manager, and the WIPP Facility Manager

designee. The board issues these bulletins at irregular intervals as

noteworthy safety lessons are developed from incidents at WIPP or elsewhere

in the DOE complex and reported on the ORPS database. Twenty such bulletins

had been issued from January through August 1994. The bulletin is

disseminated to WIPP managers and nonexempt craft workers (electricians and

the maintenance staff) through a required reading procedure which requires

the employee s signature. They are also posted on several of the site

bulletin boards and published in the WIPP weekly newsletter.



     The Onsite Review Team noted that new WIPP supervisors are trained in

the Supervisor Training and Accident Reduction Training (START) program,

and that annual refresher courses are provided to update the training. This

training program complements the written policies of WIPP s

accident/incident investigation program.



     The extremely low injury incidence rate and lost workday rate for the

site (far below the standard industrial classification statistics for

organizations performing operations similar to WIPP), as well as the low

number of ORPS reports, support the team s observations that WIPP maintains

an excellent training program.



     (7)  Trend analysis



     WIPP maintains a trending program for industrial safety items. Data on

facility inspections, injuries and illnesses, employee concerns, and fire

protection impairments are tracked monthly, quarterly, and yearly and

communicated to WIPP employees. These reports categorize and trend various

inspection results and injuries to keep management informed and provide

summary data for safety awareness programs.



     The 1994 yearly report a summary of the four previous quarterly

reports featured several statistical analyses of the injury/illness data

from 1985 to 1993. A review of these analyses revealed a direct correlation

between a rise in injuries and the number of hours worked.



     In addition to these statistical analyses, Westinghouse provides a

variety of information regarding its recordable injury incidence rate and

its lost workday incidence rate. All injuries (first- aid and recordable)

occurring at WIPP are broken down into four categories:



1.  Nature of injury 

2.  Body part affected

3.  Type of injury 

4.  Injury by task.



     These categories are then charted to determine any similarities or

trends.



     Interviews with management personnel showed that they were cognizant

of the report and were using the injury/illness data in their day-to-day

hazard-prevention activities.



     Facility inspections performed by Industrial Safety and Facility

Operations are also tabulated for trending. Inspection results are

categorized into several areas, such as electrical and

housekeeping. Inspection results are combined into these general areas and

formally communicated to WIPP employees via monthly, quarterly, and yearly

reports.



     Additional value may be realized by categorizing the inspection

results by location and responsible section manager, or examining them zone

by zone. As prepared, inspection summaries are presented to management in

site-wide fashion. Westinghouse is considering reporting the illness and

injury data for each zone to allow the responsible zone or operations

managers to concentrate on problems specific to their areas.



B.        Hazard Prevention and Control



     (1)  Access to certified professionals



     The WIPP site places considerable emphasis on professional

certification and experience.  Review of credentials by the DOE-VPP team

revealed that the safety and health staff consists of seven full-time

professionals representing more than 60 years of safety and health

experience. The site industrial hygienist was certified in the

Comprehensive Practice of Industrial Hygiene in 1984. His immediate

supervisor was certified by the Board of Certified Safety Professionals in

Management Aspects in 1991.



     Both occupational health nurses are studying to take the Certified

Occupational Health Nurse examination. They draw upon the expertise of

several certified occupational health nurses within the corporate

Westinghouse organization. Similarly, the staff can draw upon the corporate

physician, who is board certified in occupational medicine. A certified

electrical inspector and fire protection engineers are also available,

offering years of significant experience.



     Of particular note is the strong coordination and cooperation observed

between the occupational health nurses and the safety and industrial

hygiene staff. Located in the same building, they communicate regularly and

conduct evaluations together. The industrial hygienist regularly provides

the nurses a copy of his sampling data.



     When industrial hygiene samples must be analyzed, WIPP uses only

laboratories that have been accredited by the American Industrial Hygiene

Association. The ANSI/ASME-NQAO 1989 quality assurance requirements are

referenced in the purchase orders to the laboratories as a part of the

subcontract.



     (2)  Methods of hazard control



     The safety and health staff at the WIPP site are clearly and

aggressively focused on seeing that hazards are eliminated, not merely

controlled.



     Chemicals.  There has been a consistent campaign to eliminate

chemicals at the site. Where that is not practical, the staff strives to

substitute less hazardous chemicals, or at least to reduce the quantities

used. For example, instead of using 1,1,1-trichloroethane as the site s

electromotive cleaner, the staff now uses petroleum distillates. On metal

pipes, glues have been substituted for solder. No listing for perchloric

acid appeared among the 2,500 entries on the chemical database, although it

was listed in older documents.



     Quantities of chemicals at the site are closely managed through the

hazard communication program run by the industrial hygiene staff. All of

the material safety data sheets for the site have been entered into a

database that allows quantities of the chemicals to be tracked. One of the

site s industrial hygienists demonstrated how reviews are performed on all

purchase requisitions that involve chemicals to determine whether the

chemical is already available onsite in some other department. If the

requisition seeks to obtain a new chemical, the document is reviewed by the

industrial hygienist to determine whether it should be allowed onsite. One

of the workers in the warehouse has been trained to constantly verify that

chemical shipments are accompanied by a material safety data sheet. He has

been personally responsible for substitutions of chemicals at WIPP. Many of

the chemicals that appear in sampling data from the early 1980s are no

longer found onsite. Additionally, the industrial hygienist has

participated in DOE s chemical vulnerability study.



     Ventilation.  Following the classic hierarchy of control, the safety

and health staff turns to engineering controls if the hazards cannot be

eliminated or substitutes cannot be found. Many excellent examples of

engineering control of hazards were pointed out during the VPP visit. The

most impressive engineering effort is the mine ventilation system, which

moves a prodigious 425,000 cubic feet of air into the underground each

minute. Underground, a series of local exhaust systems composed of flexible

duct are used to move air to operations that may generate contaminants in

smaller, experimental shafts.



     Welding above ground as well as below ground is performed under local

exhaust ventilation. The industrial hygiene group checks the welding hoods

annually. Similarly, the hoods used in the laboratories are regularly

checked for face velocity. WIPP policy WP12-107 requires that all work with

carcinogens be conducted in a fume hood.



     Noise.  Noise was pointed out in the baseline survey as a concern

above and below ground. A sound-attenuating booth was constructed in the

transuranic packaging area to allow the control personnel to monitor the

operation without being exposed to the mildly elevated noise levels on the

main floor. In the underground areas, noise levels are considerably

higher. Drilling observed during the DOE-VPP tour produced significant

levels of low-frequency noise. Engineering controls are not sufficient;

consequently, hearing protection is worn during any drilling or scaling

operation underground. Informal interviews of workers from the underground

indicated that they have ready access to hearing protection, understand how

to use the equipment, and consistently wear protection on noisy jobs.



     Personal protective equipment.  The personal protective equipment

program at the site above and below ground is exemplary. High-noise areas

are clearly marked and hearing protection, both moldable ear plugs and

muffs, is readily available. The respiratory protection program is

administered by the industrial hygiene staff, which had conducted an

internal assessment of the program in July 1994. Each of the 148

requirements from the OSHA respirator standard (1910.134) and the latest

ANSI respirator standard was compared with the WIPP program. The staff

identified only two requirements that were not completely being met. Both

were ANSI requirements and were immediately addressed by the staff.



     Workers at the WIPP site who need respiratory protection are

quantitatively fit tested, using a full test booth. The industrial hygiene

staff had purchased and begun testing a Portacount condensation nuclei

counter for conducting quantitative fit testing. Several different brands

of respirator are provided to assure a comfortable and tight fit for anyone

who needs to wear one. In addition to providing quantitative-fit testing,

IH tests each respirator on a Biosystem leak-test unit to determine whether

it may have a leak apart from any unacceptable facepiece-to- face seal.



     Storage of the respirators is excellent; parts are stored in clearly

labeled cabinets that are in a different location from the actual

respirators. The latter are stored in plastic bags containing the leak-test

printouts. Respirators are kept in a locked cabinet which only the IH staff

has access to, preventing individuals from getting respirators unless

supervised by an IH professional. Respirators are the last line of defense,

and WIPP treats them that way.



     Heat stress.  Heat stress is a significant concern for the above

ground workers, particularly those who work outdoors in direct

sunlight. The WIPP heat stress program provides solid coverage to workers

above and below ground. The industrial hygiene staff has characterized the

hot jobs by monitoring heat loads through Wet Bulb Globe Temperatures. The

staff has set work/rest schedules for these jobs. Gatorade is provided to

workers on hot jobs and is readily available for any outside activity it

was available for participants in a confined-space training exercise. No

significant heat stress incidents were reported during the summer of 1994,

despite many days with temperatures above 100°F. The site even maintains

several full protective suits to deal with the threat of killer bees which

are moving north toward Carlsbad, NM.



     Ergonomics.  The site has launched an excellent ergonomics program

which recently received formal approval. The program is based on

recommendations from the OSHA meatpacking document, the NIOSH lifting

guide, the work of the Joyce Institute, and DOE s proposed approach. To

analyze ergonomic trends, the IH staff reviewed OSHA 200 logs for the

preceding 5 years and graphed the results. They also conducted a

questionnaire of computer users and their supervisors as well as a

site-wide inspection of more than 100 workstations.



     The program provides a wrist support to any computer user on the site

who wants one. Lifting belts are available to warehouse personnel, but

their use is encouraged only for performing individual heavy lifts, and

then only after considering the use of a dolly or assistance from a

coworker. Antivibration gloves are provided for drilling operations

underground. An ergonomics videotape will be included in the General

Employee Training program; two other tapes will be included in the MAST

training for supervisors.



     Sampling data.  The IH sampling data were reviewed to assess the

effectiveness of engineering controls. The written results are kept under

lock in the Industrial Hygiene lab and are chronologically well

organized. The results are also entered into a database called the

Westinghouse Information System for Health, Environment, and Safety. This

system allows significant trending; for example, it will print out any

sampling results that have exceeded the OSHA permissible exposure limit.



     A review of these data indicated that very few samples collected at

the site have exceeded any OSHA action level or permissible exposure

limit. Most results were far below these criteria, often by an order of

magnitude. The one exception was airborne lead levels measured in the

breathing zone of security officers at the firing range. Firing practice

was subsequently discontinued.



     Calibration.  Calibration practices for industrial hygiene sampling

are excellent, lending sufficient credence to WIPP data. Calibration gases

meeting National Institute of Standards and Technology (NIST) requirements

are maintained in the tool crib for daily calibration of the real- time

instruments used underground.



     Work control.  The Work Control Program at WIPP integrates a formal

safety review into every work package. Interviews with work control team

leaders demonstrated concern with safety and health equal to the

operational considerations of each work package. The leaders reported that

all preventive maintenance work packages go to the industrial hygiene and

safety groups for formal review. Any nonroutine corrective maintenance

request also goes for review. Engineers responsible for the work packages

are strongly encouraged to go into the field to work down every package in

order to fully understand the work and the safety implications. Workers are

encouraged to stop any activity they regard as unsafe; interviews confirmed

that many had exercised that prerogative.  Material safety data sheets for

any chemicals involved in the proposed work are included in the working

package. Job hazard analyses are routinely performed for work packages.



     (3)  Positive reinforcement



     Westinghouse uses several different methods to positively emphasize

the importance of safety:



     * Monthly awards for the Safety and Security Employee of the Month

     * A Six Weeks of Safety program, featuring various safety-related kiosks

     * Giveaways for correctly answering safety- related questions

     * Safety calendars

     * A WIPP kids  safety poster.



     Interviewed employees indicated that they felt management s emphasis

on safety was very positive. All employees showed an awareness of the

positive reinforcement programs listed above and others.  Several employees

echoed the point that they were encouraged to stop an activity if they had

a safety concern, and that the focus was on getting the job done safely,

not just getting the job done. Every employee interviewed who had stopped a

job with a safety concern indicated that both supervisors and managers were

pleased that the employee had done so, and in some cases the concern had

resulted in a lessons learned that was communicated to other employees. All

the positive reinforcement activities have been in place for at least 1

year; the annual Six Weeks of Safety program was initiated 3 years ago.



     (4)  Disciplinary system



     Westinghouse uses a three-tiered approach for their disciplinary

system. The system examined had been in place since Westinghouse had become

involved with the WIPP site. Offenses are divided into three main groups,

depending on the seriousness of the infraction:



1.  The most serious infractions, which include deliberate violations of

    established safety rules, are considered inexcusable, and may result in

    immediate discharge.



2.  Second-tier offenses, which include pranks and horseplay, may result in

    three days off without pay for the first act, and may result in

    discharge for the second act.



3.  The least serious group of offenses, which include failure to report a

    personal injury to your supervisor and/or Health Services Administrator

    on the day it occurs, can result in a reprimand for the first offense,

    may result in three days off without pay for the second offense, and

    may result in discharge for the third offense.



     For second- and third-tier offenses, the repeat offense need not be

the same as the original.



     Documents that the team examined, including the log of disciplinary

actions, indicated that management had applied the disciplinary program

fairly and consistently. All interviewed employees indicated that they had

been trained on the safety rules during their initial orientations, and

that their knowledge of safety rules was frequently refreshed with

training. Further, employees felt that safety rules were enforced

consistently, strictly, and fairly.



     (5)  Preventive/predictive maintenance



     Westinghouse s preventive maintenance program is highly effective. All

equipment that the team reviewed was in good working condition. Several

employee and management interviews revealed that Westinghouse places strong

emphasis on preventative/predictive maintenance. The team checked the

equipment ID numbers on overhead cranes, electrical distribution panels,

pressure relief valves, and operational equipment (mine exhaust fans, fork

lifts, temporary generators) against the preventive maintenance inventory

and scheduling system. All were verified to be in the preventive

maintenance program and had a thorough preventive maintenance history. The

team was especially impressed with WIPP s maintenance of transportable

pieces of equipment such as air compressors, electrical test equipment, and

ladders. very employee interviewed who had stopped a job with a safety

concern indicated that both supervisors and managers were pleased that the

employee had done so, and in some cases the concern had resulted in a

lessons learned that was communicated to other employees.



     All preventive maintenance work is scheduled in accordance with

regulatory requirements and manufacturers recommendations and tracked

through a consistent, computerized, site-wide work control system. Each

morning, the WIPP site holds a plan-of-the-day meeting. This highly

effective meeting documents all work occurring at WIPP during that day. The

DOE-VPP team was very impressed with the sense of ownership for equipment,

mechanical and electrical systems, and work areas. Employee interviews

revealed that employees frequently inquired about the status of preventive

maintenance activities in their work areas.



     Ownership can be attributed to a zone concept introduced in 1991. This

system defines who owns all work areas, equipment and systems at

WIPP. Until then, the WIPP site was plagued by high maintenance

backlogs. However, the zone concept has carried the idea of owning

equipment, systems, and work areas to the floor level. By owning their work

areas, employees feel accountable. The team could not find a single orphan

(ownerless) piece of equipment on the site. This strong sense of employee

ownership has added to the program s success and decreased the

safety-related backlog.



     Westinghouse has initiated a cutting-edge predictive maintenance

thermography program and has completed this survey on all electrical

distribution panels at WIPP. This noteworthy effort has identified several

potential problem areas. By identifying these precursor situations, WIPP

management is able to take action before conditions evolve into

problems. Downtime is thereby averted. Additionally, the maintenance

organization has a highly effective process for identifying National

Electric Code violations.



     The team was very impressed with the Westinghouse preventive

maintenance program as well as the site-wide process for controlling and

prioritizing work. The work prioritization process was consistently

implemented across WIPP and addressed issues affecting worker safety in a

highly responsive manner. Interim actions on items requiring the work

control process were effective in ensuring employee safety.



(6)        Tracking systems



     Several systems are used at the WIPP site for tracking hazards and

ensuring closure.



     Industrial safety programs.  The WIPP Industrial Safety (IS)

Department uses a computer database to track inspection results. Shortly

before the team s visit, responsibility for maintaining the database and

its software was transferred from a safety engineer to a database

specialist. This transfer allows the safety engineer to spend more time in

the field while providing him with additional resources for manipulating

and analyzing the collected data.



     The system requires that all IS observations be field-logged on a

safety observation form which requires approval by a line employee

responsible for correction. A copy of this form is provided to the

individual for documentation. Included on the form is a section in which

the employee must document either:



     * what immediate corrective action was taken (if such action was

       possible or needed), or



     * a date and proposed corrective action and a risk assessment code

       (RAC) ranking the deficiency.



     Information on the safety observation form is then entered into the IS

database for tracking and assigned a numerical code that defines the item s

status (open or closed). Interviews with the responsible safety engineer

revealed that open items entered into the work-control system are tracked

by the responsible safety engineer to ensure permanent closeout. In

reviewing the closed items, the team determined that the industrial safety

database was effective.



     Landlord inspection program.  In another hazard analysis activity,

various line organizations inspect their areas daily and monthly. These

activities are not tracked in any standardized fashion. From most

interviews, it was impossible to verify that an item from the current month

s inspection report was closed until an inspection was carried out the

following month. All inspections are documented through an area- specific

checklist developed by the cognizant line organization and approved by the

WIPP Industrial Safety Department. Several past inspection reports were

reviewed to verify that corrective actions were being taken. All reviewed

items were determined to have been corrected or logged into the site-wide

work control system, where they were being prioritized. For such items,

appropriate interim abatement was adequate and was being performed through

approved guidance contained in the site-wide work control system.



     Site-wide work control process.  The tracking of corrective actions in

the site-wide work control program is very effective. If an item identified

in a hazard analysis process requires that a maintenance work request be

formally generated, the item is entered into the work controls database for

correction. The work is prioritized according to a consistent site-wide

process and resolved accordingly.



     Review of the this prioritization process determined that the system

addressed occupational safety issues appropriately. A team member walked

down several items that had been entered into the system to verify that

they had been appropriately closed out. In addition, maintenance work

requests that had been completed and signed off were reviewed in the

field. This review validated that all items in the database that had been

marked as closed were indeed closed.



     (7)  Emergency procedures



     The WIPP Emergency Management Plan, the Emergency Readiness Assurance

Plan, the Site Hazards Assessment, and the Emergency Services Program Plan

define the responsibilities and lines of authority for emergency response

organizations and personnel, the detailed procedures, pertinent

information, and the training needed to respond to emergencies that might

occur at the site.  WIPP is prepared to respond to all anticipated

emergencies, including underground, industrial, security, national, and

continuity-of-government emergencies. At the present time, WIPP emergency

plans and procedures are in place to respond to radiological

emergencies. However, because no radiological waste has yet been stored in

the facility, these provisions and procedures have not yet been

implemented.



     Emergency reporting and mobilizing.  Emergencies of all types are

reported to the Central Monitoring Room (CMR) operator via the emergency

phone number (8111) or the mine paging system. The CMR uses established

procedures to determine the degree of response that the emergency requires

and activates the needed response. For very serious incidents, the

Emergency Management Team can be mobilized to staff the Emergency

Operations Center. For less serious occurrences, the CMR operator can

direct the response of fire, medical, hazardous materials, medical, and/or

rescue teams.



     Rescue teams.  In response to surface emergencies and most underground

emergencies (those not involving a mine evacuation and a subsequent mine

rescue-team response), the on- duty emergency service technician becomes

the incident commander and assumes control of the emergency response. The

incident commander directs the response efforts of the responding teams

that include fire, medical, hazardous materials, and rescue personnel.



     Training and equipment.  Personal protective equipment is available

for all types of responders. Training is thorough and current. Necessary

emergency equipment is staged, ready for use.



     Mine rescues.  Response to serious underground mine emergencies is

provided by two highly trained mine rescue teams. These teams meet all

requirements and criteria set by the Mine Safety and Health Administration

(MSHA) and have successfully demonstrated their capabilities and skills in

semiannual in-mine drills as well as national competitions. The annual

evacuation drill is usually conducted concurrently with one of the

semiannual mine rescue team drills.



     Site Emergency Plan.  The WIPP site Emergency Plan was expanded from

the MSHA-required elements to its present state in 1991 to address all DOE

and OSHA requirements. WIPP further indicated that the Emergency Plan was

in the process of being reviewed by a physician.



     Annual exercises and more frequent, smaller- scale drills are

conducted to maintain training and awareness. Lessons learned from the

exercises and drills are used to improve elements of the Site Emergency

Plan.



      (8)  Medical programs



      The WIPP site has an active medical program that sees 25 to 45

patients each day. Two full-time nurses provide the onsite services under

the direction of an occupational medical director located in Carlsbad,

approximately 34 miles from the site.  Twenty seven emergency medical

technicians are reported to be on site with a fire engine, rescue truck,

and ambulance available 24 hours a day. Agreements have been made for

additional emergency services from the hospitals in Carlsbad and Hobbs.



     Nurses.  Both nurses are Advanced Cardiac Life Support Certified and

are certified for pulmonary function testing by the National Institute for

Occupational Safety and Health (NIOSH). One nurse has also been certified

by NIOSH for performing audiometric testing; the other was scheduled to

receive the audiometric training shortly after the team s visit. The

facility is small but equipped with an audiometric test booth that is

calibrated annually, a miniaturized spirometer that is easily transported

to the field, an examination table, and instrumentation for conducting

lipid profiles as part of a growing wellness program.



     While neither nurse has received certification as an occupational

health nurse, one is planning to take the examination in April 1995, the

other in 1996. They show great enthusiasm for their work and are apparently

well respected by the work force, as indicated through informal

interviews. There is strong rapport and coordination between the IH staff

and the nurses the nurses receive copies of sampling results from the IH

staff and often accompany them during site inspections, such as ergonomic

surveys.



     A formal review of the occupational medical program was conducted on

June 15 and 16, 1994 by a board-certified occupational physician working

for the DOE Albuquerque Operations Office.  At the time of the DOE-VPP

review, the site was in the process of addressing all the concerns raised

in the occupational medical program review.



C.        Safety and Health Training



     The site has an exceptional safety and health training program that

has been in operation since 1989. The evaluation and interviews revealed no

specific patterns or problems that might affect the safety and health

training program. Employees reported that safety training helps them

understand the potential hazards of their jobs and ways to protect

themselves. The training staff is highly motivated and provides high

quality training by virtue of their credentials and experience. Top

management fully supports the training program, as evidenced by interviews

with employees and supervisors, funding levels, and reviews and approvals

on training documentation. The training staff recently moved into a new

facility that will help them continue to meet the site s training

needs. The facility has five classrooms, two laboratories, and a studio

designed for developing interactive videos.



     Several of the safety courses developed by the site are required by

Federal and State regulations; others come from supervisory job and task

analyses. Training is completed in a setting that can be formal (held in a

classroom) or job-specific (typically on-the-job training).



     New employees are given a 1-day newcomer s orientation, followed by 3

days of General Employee Training (GET). Twelve hours of GET are in

safety-related topics, including a 2-hour segment on hazard communications

(hazcom). Training courses are fine-tuned and updated continually using

feedback furnished by the student s supervisor or manager. Also,

supervisors and employees are sometimes used as subject matter

experts. After receiving 40 hours of instructor training, they are

qualified and serve as on-the-job trainers. Courses developed by the

training staff are also used by other divisions of Westinghouse, DOE, State

agencies, and, in some instances, private companies in Carlsbad. The

Training Department is also responsible for issuing and maintaining formal

certifications, such as hoisting and rigging, lockout/tagout, and permitted

confined space. Subcontractors are included in the same elements of the

safety training programs as Westinghouse employees and are given courses

relevant to the work they are performing. mployees reported that safety

training helps them understand the potential hazards of their jobs and ways

to protect themselves.



     Training is recorded in a computer database and backed up by hard

copies. The computer program is a state-of-the-art system and fulfills all

the site s documentation needs. For example, the system provides employees

and supervisors a quarterly updated history of their training. A monthly

calendar of classes is also published and distributed to managers,

supervisors, and hourly employees.



     Top-level managers and supervisors are required to take a self-paced

training course called Managers and Supervisors Training (MAST). They also

take another program called Supervisor Training and Accident Reduction

Techniques (START). Safety and health training for radiation workers

includes radiation (rad) training, levels one and two. The site course was

designed to match DOE s rad core course and follows its curriculum

elements. In 1993, 284 rad workers were trained. However, training has been

scaled back until the site begins accepting low- level hazardous wastes.



     From interviews, it was established that employees knew how to protect

themselves and others from hazards of the job. Employees were also observed

using personal protective equipment (PPE). When questioned about their use

of PPE, they were knowledgeable about its limitations and care. The

employees could also explain in detail what their responsibilities would be

for different types of emergencies at the site.



D.        General Review of Safety and Health Conditions



     The team conducted a number of walkarounds, both as a group and

individually, and the consensus was that the site was exceptionally well

maintained. Housekeeping was extraordinary in all areas, but most

significantly in the mine. The mine was free of any debris, and all

underground areas from offices to machine shops were well organized and

clean. To quote managers and workers, "this [the WIPP mine] is the Cadillac

of mines."  The team would tend to agree.



E.         Overall Safety and Health Program Assessment



     Taken as a whole, the team found the WIPP safety and health program to

be very impressive. The program is comprehensive, innovative, and well

communicated. All 162 interviews confirmed the fact that the WIPP site

makes worker safety and health its first priority.



VI.        Recommendation

-------------------------



     It is the unanimous recommendation of the DOE- VPP Onsite Review Team

that the Westinghouse Waste Isolation Division at the Waste Isolation Pilot

Plant in Carlsbad, NM, be accepted into the U.S. Department of Energy

Voluntary Protection Program at the STAR level.



Appendix. DOE-VPP Onsite Review Team Members for the Waste Isolation

          Pilot Plant





Name       Area(s) of Responsibility     Title              Affiliation

-----------------------------------------------------------------------

Kanth,     Team Leader                   Safety and Health  U.S. Department

Sanjeeva   Management Leadership         Program Manager    of Energy

         

Evat,      Backup Team Leader            Safety Specialist  OSHA

Pamela     Management Leadership



Eimer,     Program Director              Acting Director,   U.S. Department

Ron        Management Leadership         Technical Support  of Energy

                                         Division



Rogers,    Subcontractors                Safety and Health  U.S. Department

Raymond    Safety and Health Training    Program Manager    of Energy



McCabe,    Employee Involvement          Safety and Health  U.S. Department

Larry      Accident Investigations       Program Manager    of Energy



Lawson,    Employee Involvement          Employee           OCAW(1)/Oak Ridge,

Bruce      Accident Investigations       Representative     TN



Emch,      Tracking                      Safety             U.S. Department

Dan        Trending                      Specialist         of Energy

           Preventive Maintenance



Lippy,     Industrial Hygiene            Industrial         SCIENTECH, Inc.

Bruce      Medical Programs              Hygienist

           Comprehensive Survey



Scott,     Pre-Use, Pre-Startup Analysis   Safety           COMPA Industries, 

Walter     Routine Hazard Analysis         Engineer         Inc.

           Emergency Preparedness



Ulm,       Subcontractors                Safety             Lawrence

Bill       Safety and Health Training    Engineer           Livermore National

                                                            Laboratory



Carson,    Routine Hazard Assessments    Nuclear/Safety     COMPA Industries,

Robert     Employee Records of Hazards   Engineer           Inc.

           Positive Reinforcement and

           Dicipline



Gibbs,     Observer                      Acting Director,   U.S. Department

Roy                                      Office of          of Energy

                                         Occupational

                                         Safety



Richardson,  Observer                    Executive          Voluntary

Peggy                                    Director           Protection Program

                                                            Participants'

                                                            Association



Esposito,  Observer                      Industrial         Representing the

Paul                                     Hygienist/         Office of

                                         Consultant         Environmental

                                                            Management, U.S.

                                                            DOE