Complete Issue 1993-Winter-part 1
DOE-EH-0245 Winter 1993 (Part 1)
THE SAFETY CONNECTION
Assistant Secretary for Environment, Safety and Health
U.S. Department of Energy
Washington, DC 20585
O'TOOLE CONFIRMED AS ASSISTANT SECRETARY FOR ENVIRONMENT,
SAFETY AND HEALTH
The Senate confirmed Dr. Tara O'Toole as the Department of Energy's (DOE)
Assistant Secretary for Environment, Safety and Health, EH-1, on October 7,
1993. Confirmation followed a favorable vote of 18-2 by the Senate Energy
Committee. Soon after her June nomination, Dr. O'Toole provided consultation
to the Secretary on plans to implement the safety and health (S&H) initiatives
which Secretary O'Leary announced in early May.
The initiatives are designed to strengthen the DOE safety program
through measures such as the following:
o Placing all DOE facilities under Occupational Safety and Health
Administration (OSHA) jurisdiction.
o Reinstating the authority of the Assistant Secretary for
Environment, Safety and Health to close down any DOE facility
where operations pose an imminent risk to safety and health to
employees or the public.
o Rescinding the requirement to give DOE field offices 60 days'
notice prior to inspections and assessments.
o Establishing employee/management S&H committees at ALL DOE sites.
In statements during the confirmation process, Dr. O'Toole made it clear
that she firmly supports the Secretary's initiatives and expressed her
intention to work closely with Departmental and contractor personnel to create
a safety and health program that will "move beyond words and promises" to make
real improvements in DOE's performance. She also emphasizes that stronger
programs must focus on preventing accidents, illnesses, and injuries. Over
the years that she spent practicing internal and occupational medicine, Dr.
O'Toole became frustrated with treating illnesses that resulted from
occupational exposures and events, an activity she has described as "trying to
carry teaspoons of water to the ocean." The "trend of the future," she has
insisted, "must be to prevent accidents and illnesses" from happening in the
first place.
Dr. O'Toole was a principal analyst and contributing author of the 1991
Office of Technology Assessment (OTA) report Complex Cleanup: The
Environmental Legacy of Nuclear Weapons Production. This assessment,
conducted at the request of the Senate Committee on Armed Services, evaluated
environmental restoration and waste management programs at DOE's nuclear
weapons complex. She was responsible for those aspects of the report dealing
with the potential off-site health impacts of the contamination from DOE
facilities. She was Project Director of the OTA background paper Hazards
Ahead: Managing Cleanup Worker Health and Safety at the Nuclear Weapons
Complex.
In addition to practicing as an internist at the North Central Baltimore
Community Health Center, Dr. O'Toole served as a physician at Johns Hopkins
Hospital, Baltimore, MD, and taught both internal and preventive medicine at
the University of Maryland School of Medicine, Baltimore, MD. Dr. O'Toole
obtained her medical degree from George Washington University and a Master of
Public Health from Johns Hopkins University.
SAFE WORKPLACES--A MAJOR GOAL FOR ENVIRONMENTAL MANAGEMENT
Providing "a safe workplace that is free from accidents, injuries, and adverse
health effects" is one of six goals that Assistant Secretary Thomas Grumbly,
EM-1, has set for the Office of Environmental Restoration and Waste Management
(EM). Mr. Grumbly also specified two performance objectives to improve
workplace safety:
(1) Develop a workforce (labor and management) that is skilled, experienced,
accountable, and committed to safety and health.
(2) Identify and mitigate hazards at environmental management facilities.
Workforce development will require resources and training as well as the
incorporation of S&H elements into all contracts and performance plans.
Hazard identification and mitigation require focused safety baseline
determinations, including safety analyses reviews and health and safety
planning for the numerous facilities transitioning into the environmental
management program.
Owen Thompson, Director, Office of Safety and Health Oversight, EM-23,
stresses that the goal is "zero injuries, accidents, and adverse consequences
to workers." Progress toward zero will require "new directions and new
efforts in safety and health," said Dr. Thompson. New approaches are
necessary because EM work, with all its uncertainties and unknowns, is "a
different world" from research and development or weapons production, Dr.
Thompson observed. Most EM tasks do not have the potential for the
catastrophic, low probability events which are of concern in nuclear weapons
production and testing. Instead, EM must control events that have higher
probabilities, but less dramatic consequences offsite. "The focus must be on
the workers--both their immediate safety and the longer-term health effects of
exposures, which they may experience in the course of cleanup work."
Planning the Safety Basis
Planning is essential to achieve EM's S&H goals. The Office of Safety and
Health Oversight sees a need for EM programs to improve both their planning
for S&H protection and their ability to capture safety and health resource
needs in the larger budget planning process. Instances of failure to plan for
the S&H requirements of specific EM jobs continue to appear in the unusual
occurrence reports and elsewhere. Inadequate pre-job planning not only
exposes employees to unnecessary risks, but also leads to higher costs and
missed milestones.
Planning can be a relatively costly step in some EM projects. For
example, in some weapons facilities, the process was simply turned off with
materials still in the pipelines rather than operated through a normal
shutdown mode into a standby condition. Before remediation of these
facilities can begin, the production processing may have to be restarted to
clear materials from the lines. Planning those startups with all risks
anticipated and addressed may be a larger step than actually performing them.
Technology development is another area where EM must plan for S&H
impacts. "We have to look at S&H issues in the implementation of new
technologies," Dr. Thompson noted, "and establish a good solid safety basis
for all demonstrations." New technologies cannot be effectively used by DOE
or transferred to the private sector unless the S&H implications are clearly
articulated.
Identifying Safety Standards and Requirements
The Office of Safety and Health Oversight has begun a number of initiatives to
assure safer EM workplaces. Work continues in response to the Defense Nuclear
Facility Safety Board (DNFSB) Recommendation 90-2, which requires DOE to
identify the specific standards that apply to defense nuclear facilities,
assess the adequacy of these standards for protecting workers, and determine
if they are being implemented. EM is working closely with the Offices of
Defense Programs (DP) and Environment, Safety and Health (EH) to develop one
DOE process for meeting the recommendation.
The cornerstone of the approach is the development of
Standards/Requirements Identification Documents (S/RIDs) by the responsible
site and facility managers. The S/RID covers 20 functional areas of
environmental, safety, and health (ES&H) for a given facility or activity, and
is the sum of individual requirements applicable to the life cycle phases of
design, construction, operation, and decommissioning of facilities and as
applicable to each of the four categories of facility mission. The S/RIDs are
developed from laws and regulations, DOE Orders, and other industry standards.
For some EM activities, such as decontamination and decommissioning (D&D)
where no consensus standards exist, DOE will develop standards.
The S/RIDs process firmly places the responsibility for proposing which
requirements apply to which facilities and activities in the hands of the
operating contractor. Creating the S/RID will also necessitate deciding who
has responsibility for which requirements. For example, an EM facility
manager must assure that maintenance occurs as needed, but the requirements
for performing maintenance may be the responsibility of the sitewide
department manager.
After an initial S/RID is established, the next step is an adequacy
assessment at the facility and site level (see Figure 1). At this point,
subject matter experts review and validate the document; and the responsible
contractor manager approves the final draft. A second assessment of adequacy
is conducted by DOE staff and its experts in the approval process. Identified
inadequacies in the requirements may generate new guidance or new standards.
EM anticipates that the new requirements and standards created by S/RIDs can
be merged with DP's Requirements Self-Assessment Database (RSAD), converging
the two programs' efforts.
A pilot S/RIDs development process is underway at eight locations, two
facilities each in operating, mission transitional, D&D, and environmental
remediation categories.
Although the exact character of the full program will depend on the
results of the pilot, Dr. Thompson believes that the S/RID process will not
only satisfy the DNFSB's concerns about EM facilities, but also improve
compliance and efficiency in the long run. Because requirements are derived
at the facility level, EM can avoid the confusion and waste of resources that
result from attempts to apply Orders written for nuclear processing to
remediation activities and similar operations.
Compliance and Performance Assessment
Contractors with S/RIDs in place will have a clear means of measuring their
compliance both in their self-assessments and in external performance
assessments. Freed from the uncertainties about which standards they will be
held to, they can get on with the job of accomplishing their mission and
achieving excellence beyond compliance in their S&H programs. DOE, in turn,
can focus on spot-checking for administrative compliance, developing
appropriate performance measures, and assessing the effectiveness of
contractor programs against these performance objectives and criteria. S&H
Oversight envisions the interactions among these processes over time as shown
in Figure 2. (See article, "DOE 90-2 Standards/Requirements Program
Workshop," on page 8.)
New Tools and Training for Program Staff
Early in 1994, the Office of Safety and Health Oversight will begin a training
program for Headquarters managers to improve their understanding of DOE
requirements in safety and health. This S&H orientation, designed
specifically with the EM program and project manager in mind, explains the
basic elements of safety and health activities as well as how an effective S&H
program can be achieved. This course is intended to ensure the manager's
understanding of general requirements as well as roles, responsibilities, and
authorities that are expected in effective S&H programs throughout EM.
EM objectives for improving workplace safety--workforce development and
hazard mitigation--are supported by these recent efforts to clearly define
what is required, what constitutes excellence in safety and health, and how to
provide personnel with training and other tools they need to make EM work
safe. As these initiatives show results, Dr. Thompson looks forward to an
added benefit of better morale and commitment in EM: "People try to do good
work and want to do what they think is right. Getting the right support to
them will change the view of our safety and health problems as 'they oughta's'
to 'we're gonna's.'"
HIGHLY HAZARDOUS CHEMICALS AND OSHA'S APPROACH
TO PROCESS SAFETY MANAGEMENT
A systematic approach, an integrated effort, a process-oriented perspective--
each of these terms describes OSHA's new standard, Process Safety Management
(PSM) of Highly Hazardous Chemicals, Explosives, and Blasting Agents. The
goal of this performance-oriented standard is to prevent chemical releases and
explosions.
"We had permissible exposure limits for individual exposure limits, but
no requirements for the overall process," says Tom Seymour, Deputy Director of
OSHA's Directorate of Safety Standards Programs.
Following the 1984 toxic chemical release in Bhopal, India, which
resulted in 2,000 deaths, OSHA began considering what steps the agency could
take to help employers prevent a similar tragedy in this country. "We really
had no standards for preventing catastrophic incidents," says Seymour.
"There was a continuing problem with significant chemical releases,"
adds Joanne Slattery, project officer for PSM.
Seymour calls OSHA's PSM standard "the most comprehensive standard
written for this kind of purpose anywhere in the world." He says it covers
more materials and more facilities than other similar standards.
To develop the standard, the agency's safety staff looked at chemical
plants, refineries, and explosives manufacturers. The economic analysis staff
also visited plants to collect data for the rule--about 50 in all. They found
cooperation and help from experts like Ray Brandeis of ICI Americas, Art Burke
of DuPont, Vin Boyen of Monsanto, and Mike Wright of the United Steelworkers
Union.
Trade associations, such as the American Petroleum Institute and the
Chemical Manufacturers Association, also had developed model guidelines that
proved useful in fashioning the OSHA standard. Organization Resources
Counselors, a consulting group, also prepared a draft standard that it
submitted to the agency for consideration.
Hugh Conway, Director of OSHA's Office of Regulatory Analysis, calls
process safety "one of the best projects I've worked on, with the least amount
of antagonism" between labor and management. "Organized labor was behind PSM
and representatives of companies that had already begun doing process safety
came out as advocates," Conway says.
Conway sees in PSM the right approach to safety and health. He cited
faulty processes and operations, where the smallest mistake on the part of
employees invites disaster, as prime sources for accidents and injuries.
Slattery and Seymour agree that determining the optimum phase-in period
for conducting the process hazard analysis was the most difficult issue the
agency faced during the rulemaking. Ultimately, OSHA settled on a 5-year
phase-in, with 25 percent of the process hazard analyses to be completed by
the end of the second year following promulgation and an additional 25 percent
to be completed each succeeding year.
A second major issue, according to Seymour, was the scope of the
standard. On the economic side, Conway was concerned that the significant "up
front cost" of the process hazard analyses would distract attention from "the
potential longer-term benefits."
Slattery says, "Process hazard analysis will ultimately be helpful to
everybody." Conway agrees. He says that increased environmental concerns and
the expense of storing, disposing, and treating waste have increased scrutiny
on plant machinery. "It would be a terrible missed opportunity if in the
process of redesigning the workplace to conform to environmental concerns, we
failed to consider worker safety and health at the same time," Conway says.
PSM Calls for employers to do the following:
o Compile process safety information.
o Prepare a process hazard analysis for affected processes.
o Involve employees in analyzing processes.
o Develop written operating procedures for covered processes.
o Train employees on hazard emergency operations and safe work
practices.
o Establish safety as a priority for contractors.
o Work with contractors to ensure safety.
o Conduct pre-startup safety reviews for new/modified facilities.
o Ensure mechanical integrity of equipment. Use a permit system for
hot work.
o Prepare a written program for management of change in chemicals,
technology, equipment, and procedures.
o Investigate chemical releases and near misses.
o Implement an emergency action plan.
o Audit compliance with process safety requirements.
o Protect trade secrets, if they wish, through confidentiality
agreements.
For more published information on process safety management, contact OSHA's
Publication Office, 200 Constitution Avenue, N.W., Room N3101, Washington, DC
20210, telephone (202) 523-9667.
Conway also indicates the agency found evidence that the standard also
offers the potential for increasing productivity. As employers consider
design changes to improve safety, they will be able, simultaneously, to
enhance productivity.
Another benefit will be reduced insurance costs over the long run. Conway
points out that underwriters became "... real proponents of the standard--an
unexpected source of support for the rule."
In developing the standard, "We tried to steer a balanced course,"
Seymour says. "The people who were part of the hearings deserve praise," he
adds, noting that comments from academicians, industry, and unions were
responsive and supportive. Commentors also were willing "to chastise and
criticize" when they thought that necessary, Seymour adds.
The performance-oriented approach chosen by the agency will provide the
flexibility needed for the varied workplaces that will need to comply. This
approach, however, is more difficult to enforce. "We can't just do a walk
around for hazards....We will need to look at documents....and then determine
whether they have a paper program or a real program," says Seymour. He notes
that this kind of program evaluation takes longer than a traditional OSHA
inspection.
Ms. Fleming is a public affairs specialist in OSHA's Office of Information
and Consumer Affairs.
Acronym List
CERCLA Comprehensive Environmental Response, Compensation, and
Liability Act
CFR Code of Federal Regulations
D&D Decontamination and Decommissioning
DOE U.S. Department of Energy
DNFSB Defense Nuclear Facilities Safety Board
DP Office of Defense Programs
EH Office of Environment, Safety and Health
EM Office of Environmental Restoration and Waste Management
ES&H Environment, Safety, and Health
ERWM Environmental Restoration and Waste Management
HAZWOPER Hazardous Waste Operations and Emergency Response
INEL Idaho National Engineering Laboratory
MMES Martin Marietta Energy Systems, Inc.
OSH Occupational Safety and Health
OSHA Occupational Safety and Health Administration
PSM Process Safety Management
RCRA Resource Conservation and Recovery Act
RL DOE Richland Operations Office
SAR Safety Analysis Report
S&H Safety and Health
S/RIDs Standards/Requirements Identification Documents
SRS Savannah River Site
WHC Westinghouse Hanford Company
SAFETY INITIATIVES
DOE 90-2 Standards/Requirements Program Workshop
Top managers for DOE Headquarters and Operations and field offices urged more
than 200 participants at the DOE 90-2 Standards/Requirements Program Workshop
on November 2-3, 1993, to move aggressively in initiating the first phase of
the DOE Standards/Requirements Program. Developed in response to the DNFSB's
Recommendation 90-2, the program will help ensure adequate worker and public
safety, health and environmental protection at all DOE sites and facilities.
The 2-day workshop, cosponsored by EM and DP, consisted of progress
reports, breakout sessions, and question and answer periods. These dialogue-
intensive activities centered around EM's and DP's coordinated efforts to
resolve remaining issues and potential obstacles that may hinder the
contractors' implementation of the program. "When you send your people home
every night and expect them to come to work every morning," asserts Mr.
Grumbly, EM-1, "you need to assure that they are going to be safe on the job,
conforming with the highest occupational safety and health (OSH) standards."
Opening remarks by Mr. Grumbly, Dr. O'Toole, EH-1; Victor Stello,
Principal Deputy Assistant Secretary for Facilities, DP-6; Randal Scott,
Deputy Assistant Secretary for Oversight and Self-Assessment, EM-20; Owen
Thompson, EM-23; and Jack Crawford, member of DNFSB; emphasized DOE's "new way
of doing business." The program transforms the traditional expert-based
management system into a more reliable standards-based system by assuring that
retiring or transferred employees do not leave with the site's only
understanding of how and why specific activities are performed and controls
are in place.
DP first tackled the issue when Recommendation 90-2, requesting that DOE
identify and determine the adequacy and extent to which specific standards are
implemented at DOE defense nuclear facilities, was forwarded to the Secretary
of Energy in March 1990. However, as some facility and site missions evolved
from nuclear weapons production to environmental restoration and waste
management, these facilities and sites were transferred from DP to EM
oversight. EM joined the program in early 1992.
Randal Scott encouraged contractors to begin the S/RID development
process, cornerstone of the DOE program. An S/RID comprises all appropriate
(meaning site- or facility-specific) requirements culled from regulations, DOE
Orders, and other industry standards that are applicable to the life cycle
phases of a DOE site or facility. For multi-owned, multi-program sites or
facilities, the program requires coordination with even more players and
creates the potential for more conflict.
Mr. Grumbly believes the program offers the best promise to reconcile
conflicting demands of various stakeholders by refocusing our attention "on
what we need to do at each site given the particular activities we need to
perform." Designed to accommodate different operations and hazard levels, the
program places responsibility squarely on the managers' shoulders. Managers
identify all applicable regulations with the help of subject matter experts
and the experience of long-term employees, propose requirements and standards
for which they should be responsible and accountable, and show by reasonable
assessment how they comply. Approval by DOE of the requirements and standards
will provide the mutual agreement between DOE and contractors for the way
business will be conducted to protect workers, the public, and the
environment.
"To continue to get funds and employ up to 150,000 people for clean-up
activities," notes Mr. Grumbly, "we need results in concert with environmental
laws at a lower unit cost." Jack Crawford of the DNFSB confirmed the trend of
"increasing Congressional emphasis on the effective utilization of standards."
Case in point: Both Comprehensive Occupational Safety and Health Reform Act
bills introduced in Congress this spring will give OSHA jurisdiction in DOE
contractor facilities. No doubt, Mr. Crawford predicts, such a change will
further confuse contractor's priorities of cost, schedule, and safety.
Communication and Coordination Stressed
Dr. O'Toole said she "applauded DP and Em's efforts and progress thus far."
To minimize confusion in the field, she recommended special attention to
several issues, such as DOE-wide consistency in the application of standards.
Dr. O'Toole committed EH's technical support to the program by instituting an
initiative to discriminate between requirements and guidance ("shalls" and
"shoulds") for all parts of the ES&H Orders and guidance within 1 year.
In addition to top management support at Headquarters and in the field,
Deputy Manager Al Pauole, Rocky Flats Office, stressed the need for an idea
champion, "someone to push the program in line managers' faces to compete with
all other daily activities." Mr. Pauole also noted the importance of
infrastructure, such as operating procedures and information management
systems.
A lack of resources, both financial and personnel, and specific program
guidance topped the participants' list of immediate obstacles to the S/RID
development process. Rocky Flats, for example, implemented quality
improvement processes to continue program funding. Breakout sessions allowed
participants to discuss unresolved issues in detail, such as the approval and
exemption processes. Following the sessions, participants discussed
recommendations to address these issues with DOE program managers. The
participants agreed with a challenge from Gerry Gears, Acting Director, Office
of Engineering and Operations Support, DP-62, that there were no impediments
to getting on with the program. Financial issues would be flagged to
Headquarters for resolution.
Dr. Thompson concluded the workshop with unanimous consensus from the
participants that there is now sufficient understanding and direction for
contractors to proceed with the S/RID development process. He reiterated
DOE's commitment to facilitate this process by issuing an S/RID format and
content guidance document, submitting a prioritized list of facilities which
should undergo immediate Order compliance and self-assessment, and assuring
full coordination with other related programs.
A two-tape video of the workshop's opening session and another set with
an overview of the program are available. For more information on the 90-2
Standards/Requirements Program, please contact Owen Thompson (EM-23) at (301)
903-7910.
EH Assistance Team to Support Hanford Tank Farms
An EH Assistance Team, led by Robert W. Barber, Director, Office of Risk
Analysis and Technology (EH-33), is forming to provide direct assistance to
the Richland Operations Office (RL) and Westinghouse Hanford Company (WHC) to
improve management and operations, particularly at the site's Tank Farm
facilities. The purpose of the Assistance Team is to upgrade line management
capability in ES&H by empowering them with better ways to conduct operations.
The Assistance Team is especially concerned about improving the conduct of
operations program for ES&H-related issues.
Nonessential Tank Farm operations (those not related to regulatory
requirements or needed to maintain Tank Farm safety) were curtailed in July
1993 by WHC because of a failure to apply basic conduct of operations
requirements. EH responded to the situation quickly, and, in a matter of
days, agreed to provide support and assistance to EM in identifying and
correcting systemic ES&H deficiencies at Hanford.
While the complete EH team is still being formed, some members are
onsite already and providing assistance in the analysis of safety issues and
corrective actions, and in the development of S/RIDs for the Tank Farm
operations. Team members have been tasked with helping RL and WHC in
developing solutions rather than identifying problems through use of a
nonadversarial approach to provide assistance and not dictate solutions. Team
members will provide direct feedback to RL and WHC by working directly with
Tank Farms managers and staff to find appropriate solutions to operations
issues. The project is expected to last 6-9 months.
Both short- and long-term goals are being developed for the new
assistance program. Immediate aims include providing assistance on safety
issues, work activities, and maintenance. Longer term goals seek to help
Richland and Tank Farm managers comply more effectively with conduct of
operations requirements and better address safety management issues. To this
end, EH team members will offer a broad background of technical and managerial
experience. Team members also will devote time to the assistance program and
will be required to interface directly with RL and WHC managers and staff on
site to help facilitate the change process.
Curtailment of Tank Farm operations resulted in a series of operational
problems at the Tank Farms, including numerous off-normal and unusual
occurrences and a dramatic increase in the rate of lost-time injuries. Lack
of ownership and accountability were cited as the central concerns leading to
the administrative curtailment of work at the Hanford Tank Farm operation.
The EH Assistance Team's mission will be to address the underlying causes of
the problems at these facilities and to change the culture rather than simply
identify problems. For more information on the EH Assistance Team's efforts
to support the Hanford Tank Farms, call Robert Barber (EH-33) at (301) 903-
3477.
Transportation and Packaging Division Supports Waste Management Activities
The Transportation and Packaging Safety Division staff, EH-332, is providing
both interim and long-range support to the Environmental Restoration and Waste
Management (ERWM) hazardous waste cleanup program. Interim support includes
establishing a "technical partnership" with EM and developing various forms of
guidance for the safe packaging and transport of hazardous wastes. In
particular, D&D personnel will be instructed about pertinent DOE Orders,
Department of Transportation (DOT) regulations, and related OSHA regulations.
This training will focus on applicable regulations for shipping samples of
hazardous wastes and will enhance EM's capabilities for meeting all regulatory
requirements and addressing cleanup worker safety.
The proposed short course in transportation and packaging safety for D&D
personnel will address the following:
DOE Orders 1540.1a, Materials Transportation and Traffic Management;
1540.2, Hazardous Materials Packaging for Transport-Administrative
Procedures; and 5480.3, Safety Requirements for the Packaging and
Transportation of Hazardous Materials, Hazardous Substances, and
Hazardous Wastes.
o DOE regulations; selected topics in packaging and shipping; OSHA
transportation topics.
o DOT exemptions and DOE alternatives.
o Proper shipment of hazardous waste samples.
o Federal motor carrier regulations.
The EH/EM partnership also involves work on determining specific onsite
transportation and packaging needs at each ERWM D&D site. EH-332 staff will
help EM classify the hazardous wastes that need to be packaged, stored, and
transported at these sites. Guidance in this area will ensure safe transport
of hazardous wastes on ERWM sites and the appropriate criteria for waste
packaging will be provided. Staff will also provide the ERWM sites with
information on the safe storage and transport of hazardous wastes to ensure
the containment necessary for worker safety.
Another component of the EH/EM partnership is providing information and
assistance on the appropriate shipment of hazardous waste samples, a
representative portion of an unidentified material for which analysis is
required to determine the characteristics or composition of the material.
This presents a unique challenge to the transport community because of small
sample sizes, high radioactivity, and the need for a large number of
shipments.
The long-range D&D assistance strategy provides for EH staff to continue
working with EM staff to perform transportation and packaging safety program
assessments at selected sites. Well established EH-332 performance objectives
and procedures include document reviews, personnel interviews, and inspections
of hazardous waste transportation and packaging operations. These objectives
and procedures will provide a basis for the assessments. EH participation
will not include traditional oversight activities. Instead, evaluations of
progress will be emphasized, areas where more guidance is necessary will be
identified, and findings will be used as a basis for developing corrective
actions that address deficiencies affecting worker safety. For more
information, please contact Ted Needels (EH-322) at (301) 903-4684.
Two New Transportation and Packaging Safety Initiatives
Packaging radioactive and other hazardous materials is a highly visible
activity in the United States. The public expects all DOE safety operations
to be conducted according to regulations applicable to the private sector or
their equivalent. Recently, the Secretary of Energy emphasized the
Department's policy to comply with all regulatory requirements to the maximum
extent. EH-322 staff are conducting the lead program for EH, with the
responsibility to oversee the safety of DOE packaging and transportation
operations. Pursuant to this new direction from the Secretary, development of
the following two new activities was initiated: the EH Quality Assurance
Assessment Program for Hazardous Materials Transport Packaging and the EH
Transportation and Packaging Technical Assistance Program.
EH Quality Assurance Assessment Program For Hazardous Materials Transport
Packaging
A program for conducting quality assurance assessments of DOE's hazardous
materials transport packagings to ensure these packages and associated
transportation activities comply with applicable Federal regulations and DOE
Orders was initiated. A guide for conducting quality assurance assessments of
transport packagings is in development to support this program.
EH Transportation and Packaging Technical Assistance Program
Four transportation and packaging safety assessments, which supported the EH
Resident Program Staff, were conducted at DOE Operations Offices during 1992.
A review of these performance assessments identified commonly recurring
deficiencies in the implementation of transportation and packaging safety
responsibilities at DOE Operations Offices. As a result, a program to support
EH's mission to followup performance assessments at Operations Offices with
assistance efforts was initiated. The followup program involves using EH-332
staff's unique technical expertise and experience to provide guidance and
assistance to the Operations Offices for correcting program deficiencies and
implementing a more effective transportation and packaging safety program.
For more information, contact Ashok Kapoor (EH-332) at (301) 903-6838.
Cleanup Worker Safety and Health During Environmental
Restoration and Waste Activities
Program activities continue under the Office of Safety and Quality Assurance's
(EH-30) ERWM Baseline Program. An important part of the program includes
Headquarters staff visits to DOE and non-DOE sites to learn about their safety
and health programs. Notable programs and activities, including problems, are
identified and shared with the DOE community. Interactive outreach meetings
are an important part of the ERWM Baseline Program. They are conducted with
experts, who are involved in cleanup activities from government, labor, and
industry. The meetings are designed to help DOE take advantage of the
experiences and lessons learned from the experts' activities.
Site Visit to Idaho
On September 14 and 15, 1993, a group of EH safety and health professionals
visited the Idaho National Engineering Laboratory (INEL) facility located in
Idaho Falls, ID, to discuss current and planned S&H processes designed to
protect workers during ERWM activities. Much of the visit focused on the
Idaho Chemical Processing Plant (ICPP).
The team observed and noted worker S&H practices related to INEL's ERWM
activities. Among the safety and management principles being applied at INEL
to support ERWM activities are the following.
o Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA) removal actions are a top priority at INEL. Safety
considerations under CERCLA are the primary drivers at these
locations.
o Westinghouse Idaho Nuclear Company's (WINCO) biannual safety
review of supervisors conducted by the safety management
committee.
o MK-Ferguson's safety requirements for private companies bidding
for construction jobs.
o Trend and root cause analyses conducted by DOE's Idaho Operations
Office (ID). ID integrates lessons learned with the respective
OSH program.
o ID-approved safety analysis reports (SARs) for all operations-
related activities at ICPP. The SARs, numbering over 10,000
pages, are compiled into 18 volumes known as the Plant Safety
Document (PSD). Health and Safety Plans (HASPs) are developed for
each job specific task at INEL.
o INEL is planning to eliminate redundant documentation through the
use of site-wide SARs and emphasizing auditable hazards analyses
(HAs) on individual processes or facilities.
ERWM Activities at INEL
The INEL ERWM Program was established in 1977. Of the original 45 surplus
contaminated facilities identified at INEL in 1977, 24 have been
decommissioned. The range and types of facilities decommissioned to date
include projects from concrete storage pads to complex reactor and fuel
reprocessing facilities. Disassembly techniques have included plasma torches,
headache balls, and linear-shaped high explosives. During the decommissioning
of these 24 facilities, no personal injury, accident, or contamination release
to the environment has occurred.
The INEL ERWM Program is considered a "mature" program with long-range
plans in place to decommission the remaining surplus facilities, accept new
facilities into the program as they become excess, and conduct all planning
and operations in a prescribed manner as defined in a complete set of program
directives. For more information regarding INEL ERWM activities, contact E.
F. Perry (EG&G) at (208) 526-9711 or R. H. Meservey (EG&G) at (208) 525-1834.
ES&H Training
Training plays an important role at INEL. In addition to the OSHA-required
training, WINCO conducts a program for safety observers and trains others in
the safety observer effort. In one particular case, workers upgrading the
Evaporation Storage Tank Vault were trained in a mock-up of the tank, thereby
reducing by half the expected radiation dose per worker. Courses leading to
accreditation are offered for occupational health physics technicians in
conjunction with the Savannah River Site (SRS). EG&G has experimented with
behavior-based training for the last 3 years using vehicle mechanics. Bidders
for contracts with MK-Ferguson are required to have specific safety-related
training before bidding.
WINCO safety programs include a safety management committee, an
employee-management safety council, and an innovative Safety Observer Program
(performing over 1,100 reviews so far in 1993). The DuPont Safety Training
Observation Program (STOP), ergonomic reviews of workstations, safety and
health manuals, permits, and regulatory alerts are included in the overall
safety programs. Safety is also a factor in conducting performance appraisals
of worker supervisors.
Construction
MK-Ferguson, under the primary contractor (EG&G), handles all construction
activities at INEL and relies on job safety analysis, program ownership (both
employee and subcontractor), and prequalification. MK-Ferguson is
experimenting with a behavior-based training program developed by EG&G. In
addition, MK-Ferguson has used targeted surveillance (in areas of greatest
hazard), a safe work index (SWI = targeted surveillance points and lost
workday rate), individual worker critiques, S&H committees, labor-management
committees, subcontractor performance appraisals, and safety incentives.
Worthy of note is the prequalification of subcontractor bidders. Before
any construction company can bid a specific job, it must, at a minimum,
perform a job safety analysis for that job, claim an EMR (workers'
compensation factor) less than 1, submit an ES&H plan, and have an MK-Ferguson
performance rating greater than 700. All subcontractors are required to craft
their own ES&H plan.
Transportation and Packaging Safety
WINCO regards transportation and packaging safety as strictly an operations
function, not included in a HASP. This function, handled by Materials
Management at EG&G, was not on the agenda during the EH visit, and thus was
not among the elements of worker health and safety presented by WINCO.
A representative from ID's site-wide programs addressed transportation
and packaging safety as a critical area that should be incorporated into the
Federal Facilities Compliance Act (FFCA) and HASPs. To date, there has been
one report produced, First Annual Office of Oversight Report 0-50-93-06. It
was noted that most HASPs dealing with recent cleanup operations viewed
transportation and packaging as insignificant issues during the early and
middle phases of the D&D phases. This situation could result in the
insufficient safety measures being taken.
ID's OSH programs staff are currently reviewing the Occurrence Reporting
and Processing System (ORPS) for site-side occurrences which include packaging
and transportation. From this data, the group conducts both trend and root
cause analysis and then applies the lessons learned into the respective OSH
program.
Implementation of DOE Order 5480.23
On April 30, 1992, DOE Order 5480.23, Safety Analysis Reports became
effective. The Order has particular significance to the EM safe shutdown and
decommissioning effort in that it guides facilities in their effort to perform
these activities safely in accordance with applicable laws and regulations.
The SAR safety commitments, along with the WINCO Technical Safety Requirements
(TSRs), form the DOE-approved authorization basis for safe shutdown and ERWM
activities.
In evaluating the safety of a safe shutdown or ERWM activity, the safety
analysis process provides a systematic identification of the hazards; an
analysis of the adequacy of measures taken to eliminate, control, or mitigate
identified hazards; and an assessment of their risks associated with the
potential accidents. To assess adequately the risk during safe shutdown or
ERWM activities, WINCO determines the probability and consequence of the
potential accidents, which can be combined to determine the risks associated
with the activity.
The ICPP currently has ID approved SARs for all operations-related
activities. The SARs, numbering over 10,000 pages, are compiled into 18
volumes, a collection known as the Plant Safety Document (PSD). Each PSD
section is reviewed on a 5-year cycle and updated as needed. This activity
between ID and ICPP has been ongoing for the past 25 years.
The only nuclear operations not associated directly with a facility at
ICPP involves environmental restoration activities. These non-facility
nuclear operations, such as site-wide remedial cleanup activities and the
final disposition of surplus facilities, are covered by the INEL Environmental
Restoration Program (ERP). A separate implementation plan for DOE Order
5480.23 has been prepared for ERP activities. As future ERWM activities are
identified, specific SARs will be developed to support those projects.
DOE-ID - Safety Analysis
Idaho staff are developing the Baseline Safety Analysis File (BSAF) Program,
which will standardize the safety analyses for EM's remediation and ERWM
activities. The staff reviewed all of the varied safety analysis requirements
and integrated them into programs designed to eliminate unnecessary and
marginal analyses while emphasizing those of safety significance. Idaho staff
intend to eliminate redundant documentation through the use of site-wide SARs
and an emphasis on auditable hazards analyses of individual processes and
facilities that feed into HASPs focusing on worker safety. The EH team noted
ID's unique plan to review all planned ERWM technologies and develop Standard
Technical Safety Requirements (STSRs) for each technology. This will
streamline the assignment of STSRs to EM projects by adopting standard, off-
the-shelf requirements.
For more information on the Idaho visit, contact Ken Murphy (EH-331) at
(301) 903-6514. For information on EH's ERWM Baseline Program, contact Tony
Eng (EH-331) at (301) 903-4210.
Environmental Restoration and Waste Management Outreach Meetings Continue
Outreach meetings with organizations from outside DOE are continuing. The
purpose of the meetings is to gather information on the experiences and
lessons learned of other government and industry cleanup activities, and
provide it to the DOE community.
Prosecution of Environmental Crimes
On September 22, 1993, Jane R. Barrett, Assistant U.S. Attorney, presented
"Prosecution of Environmental Crimes: the Aberdeen Proving Grounds Trial," a
discussion of the 1991 case in which three high-level Federal employees were
convicted of environmental criminal violations and charged with four counts of
illegal disposal of hazardous waste. Ms. Barrett served as the prosecuting
attorney in the trial and successfully defended the indictments in Federal
court.
According to Joseph E. Fitzgerald, Deputy Assistant Secretary for Safety
and Quality Assurance (EH-30), the purpose of Ms. Barrett's discussion was "to
sensitize DOE safety and health staff to the bases and implications of
criminal enforcement actions for violations of environmental regulations." In
addition, "her presentation helped explain the distinctions between civil and
criminal proceedings under environmental statutes," said Mr. Fitzgerald.
Ms. Barrett's presentation included a discussion of environmental
criminal violations at the Fort Meade, MD, water treatment plant and the 32nd
Street Naval Station, San Diego, CA, where other Federal employees were also
convicted. These violations occurred after the lessons learned from the
Aberdeen Proving Grounds trial were distributed widely in a news release. Ms.
Barrett noted that the conviction of Federal employees in the case had not
proved to be a deterrent to future environmental violations.
Cleanup Technologies
On October 28, 1993, Michael Taylor, PhD, Director of Science and Technology
at International Technology (IT) Corporation, discussed "Decontaminating
Buildings and Debris: EPA Research." Dr. Taylor's work is funded by the
Environmental Protection Agency's (EPA) Risk Reduction Engineering Laboratory
at EPA's Cincinnati, OH, office, which is responsible for evaluating new
technologies for building decontamination.
The first part of Dr. Taylor's presentation focused on the development
of debris washing technologies and a case study of IT's cleanup operations at
an Akron, OH, scrap yard. In the case study, PCB-contaminated oils at the
site had been used both to fuel an onsite smelter, which created dioxins, and
to control dust at the site. Using a manual system (which has since been
developed into an automated system), IT was able to treat approximately 3,000
tons of metallic debris, which could then be sold to a scrap dealer for metal
recycling.
Dr. Taylor then discussed other emerging cleanup technologies, noting
that while no one specific technology may be appropriate for all cleanup
needs, each has certain advantages.
o Soil Washing--This process, described by Dr. Taylor, is "materials
handling coupled with particle separation." This technique is
highly effective when used on sandy soils, but less so with soils
that have more than a 30 percent clay content.
o Solvent Extraction--This technique typically employs the chemical
triethalimine (TEA) to remove organic contaminants, such as PCBs
and pesticides, from soils and sludges. Following treatment, the
TEA is recovered and purified. Another process involves using a
pressurized liquefied gas, such as propane, butane, or carbon
dioxide, to extract the contaminants.
o Chemical dechlorination--In this process, PCB-contaminated soil is
treated in a reactor and then returned to the excavation site.
The contaminated gases are then treated and/or disposed of.
o Chemical Oxidation--This process uses hydrogen peroxide, ozone, or
ultraviolet light to oxidize contaminants.
For more information on EH ERWM activities, contact Tony Eng (EH-331) at (301)
903-4210.
EH Steps Up Efforts to Improve Workplace Safety
and Health for DOE Federal Employees
Among the actions resulting from the Secretary's safety and health initiatives
which were announced on May 5, 1993, was the transfer of responsibility for
the development and management of the DOE Federal Employee Occupational Safety
and Health (FEOSH) Program from the Office of Human Resources and
Administration (HR) to EH. This transfer was effective on September 14, 1993.
Committed to the intent of these initiatives, the newly-established Federal
Employee Program Division, EH-315, Office of Safety and Quality Assurance,
will step up efforts designed to improve the FEOSH program's implementation
and effectiveness throughout the DOE complex.
Implementation of the FEOSH program remains a line management
responsibility. EH staff will oversee implementation of the FEOSH program at
all DOE facilities, provide technical assistance to DOE line organizations,
and create supplemental policies and guidance as outlined under 29 CFR 1960,
Basic Program Elements for Federal Employee OSH Programs and Related Matters.
EH staff will chart strategic, tactical, and operational plans, such as
increasing interagency cooperative efforts and employee involvement, to
fulfill its new program responsibility of assuring safe and healthful working
conditions for Federal employees. Announcements, flyers, etc., from the newly
developed FEOSH office will be distributed in the near future.
Increase Interagency Cooperative Efforts
One of EH's first initiatives of the FEOSH program was the formation of a
joint task force comprised of EH, HR, and union leaders that was established
to conduct a special review of DOE Headquarters' facilities to determine the
effectiveness of the existing FEOSH program and identify potential hazards.
The walk-throughs, which began in November, were conducted by teams staffed by
DOE, OSHA, and other Federal agencies' experts and consultants, as well as HR
and union representatives. The multi-disciplinary teams focused on five
safety and health areas targeted by Dr. O'Toole, EH-1, including ergonomics;
electrical safety; fire protection; elevator safety; and slip, trips, and
falls.
Capitalizing on the extensive research and support services offered by
other Federal agencies such as the Department of Veterans Affairs and the
National Institute for Occupational Safety and Health, EH staff seeks to
optimize the findings of these research investigations to further improve the
DOE-wide FEOSH program, as well as its own.
Increase Employee Involvement
Critical to the success of the program, methods to increase employee
involvement will be sought. These methods may include designing a suggestion
system, establishing awards programs and safety circles, and training
employees in hazards identification.
Of course, hazards identification assumes the employee's ability to
recognize and report onsite hazards. To this end, DOE employees will be
encouraged to become thoroughly familiar with the basic program requirements
defined in DOE Order 3790.1B, Federal Employee Occupational Safety and Health
Program, and DOE Order 5480.29, Employee Concerns Management System. By
empowering employees to seek actual and potential safety and health hazards,
employees become additional sets of eyes and ears capable of detecting safety
and health risks.
EH staff emphasize that the feasibility and success of the initiatives
identified above, as well as others to come, depend upon the active support of
the Federal employees. For more information on the FEOSH program and its
current initiatives, contact Dennis Lubow, Acting Director (EH-315), at (301)
903-2075.
Observations of Hazwoper Training
The OSHA standard (29 CFR 1910.190), referred to as the HAZWOPER standard,
provides separate training requirements for uncontrolled hazardous waste
facilities and for treatment, storage and disposal (TSD) facilities that are
regulated under the Resource Conservation and Recovery Act (RCRA) and for
environmental restoration sites that are regulated under RCRA corrective
action authority and/or CERCLA. DOE mandates the use of this regulation to
ensure that hazardous waste operations and emergency response activities are
conducted safely. The training required by this regulation includes basic
information designed to ensure the safety and health of workers and emergency
responders.
Over the course of the last year, EH site representatives conducted
performance assessments at various cleanup sites throughout the DOE complex to
determine the effectiveness of HAZWOPER training in preparing workers to
conduct waste operations and emergency response activities. The results of
these assessments indicate a need for improvement in HAZWOPER training. Some
pertinent observations from these assessments follow.
To be effective, HAZWOPER training must be based on the observed and
potential hazards on the specific cleanup site. Yet, at many sites, "generic"
training, which is often watered down for the broad audience, is used. It is
often given to everyone, including secretaries and office personnel who are
never expected to enter the cleanup site. This cost in time spent away from
normal duties and wasted effort adds to the total cost of cleanup. In
addition, such generic training leaves cleanup workers ill-prepared to deal
with practical situations at the cleanup site. Even when the initial training
is adequate, DOE and its contractors should be prepared to provide
supplemental training when new or unexpected hazards are identified during the
course of site remediation or investigation. Additionally, the annual
refresher training should include practical lessons learned in the cleanup or
emergency response process.
Both technical and "instructional" skills are mandated by OSHA for
HAZWOPER instructors. But oftentimes the instructors in the field come from
either the training group (with no practical experience in HAZWOPER) or the
technical group (with no training in instructional skills). Additional
instructors' training or practical experience should be mandated for those
deficient in either.
According to OSHA, specific training related to the anticipated hazards,
such as confined space entry training and respiratory protection training, can
be substituted for some of the 40 hours of classroom training that OSHA
requires. However, DOE has not used equivalent training to shorten the
HAZWOPER training time.
Site specific 1- and 3-day supervised field experience is not well
documented nor controlled. In some cases, this is nothing more than a waiting
period for the worker until he can be turned loose on his own. This field
experience needs to be well planned, in order to apply the safety principles
taught. No employee should be permitted to enter any cleanup site without
adequate documentation of HAZWOPER training.
The foregoing discussion has been offered as an aid to determine the
adequacy and effectiveness of training programs at hazardous waste sites.
This training should be viewed as an opportunity to provide the workers,
supervisors, and managers with the tools necessary to protect themselves,
their co-workers, and the public.
If you would like additional information on these observations, contact
your local EH site representative or call Michael Hillman, Director, Resident
Program Office (EH-30.2) at (301) 903-3886.
CURRENT PROJECTS
Hazwoper Task Force
The TRADE HAZWOPER Task Force, a group of contractor personnel responsible for
hazardous waste operations and emergency response (HAZWOPER) training,
convened in 1992 to identify issues that would help DOE contractors improve
their HAZWOPER programs. The Task Force met the evening of November 15, 1993,
during the TRADE conference in Indianapolis, Indiana, for discussion of such
topics as the recent grant programs for training, the development of the DOE
HAZWOPER standard and handbook on OSHA and EM perspectives on the
requirements. Task Force Chair, Merri McNamer of Martin Marietta Energy
Systems, Inc. (MMES), moderated presentations and panel discussion by Cynthia
Weaver, OSHA; John Moran, Laborers' Health and Safety Fund of North America;
and, from DOE, Don Harvey, DP-624; Gail Kleiner, EH-412; John Serocki, EM-23;
and Gerry Kassalow, EM-431. Panelists also answered questions from the
audience. For more information, call Merri McNamer (MMES) at (615) 576-6030.
UPDATE
Nevada's Compliance Assessment Program
The DOE Nevada Operations Office (NV) Compliance Assessment Program
(CAP), now in the followup and closure stages, is defined as a "cross-
educational venture that helped to set the stage for a shifting culture to
behavior-based safety," according to John Robson, Chief of the Facility Safety
Branch at NV. Begun in October 1990, CAP combines all required safety and
health inspections and appraisals into a single program, improving NV
compliance in the areas of occupational safety, industrial hygiene,
radiological safety, occupational medicine, and fire protection.
An automated tracking system, which monitors closure of the CAP
findings, provides information on each CAP finding, including a description of
the finding, the requirement violated, and corrective actions or abatement
plans. The information in this database has been validated, and a procedure
has been developed to ensure standardized data entry of CAP information, as
well as all current and future oversight data. This enables NV to review data
across assessments for trending purposes and to focus future programs on
problem areas.
The program proves to be a valuable endeavor, defining an OSHA
compliance baseline and encouraging employee-management and DOE-contractor
interface through NV community members' participation on compliance assessment
teams. Currently, CAP staff are incorporating CAP data into functional
appraisal reports. Of 4,722 validated deficiencies, 1,568 remain open, but
are being closed daily, said NV Occupational Safety Branch Chief Wayne Crane.
Many of the deficiencies that remain open, Mr. Crane explains, are those that
will require more extensive measures for abatement, such as program
development and implementation. For more information on CAP, contact Wayne
Crane (NV) at (702) 295-1177.
FIELD ACTIVITIES
Hanford Safety Team Seeks Best Safety Practices
In keeping with Secretary O'Leary's commitment to continuous improvement in
occupational safety and health (OSH), representatives from Westinghouse
Electric Corporation, Westinghouse government-owned, contractor-operated
(GOCO) sites, DOE, and private industry formed the Hanford Safety Team in
September 1993. As a result of a meeting between Westinghouse Group President
John Yasinsky and Secretary O'Leary, the Hanford Safety Team will help Hanford
improve its safety performance and benchmark the best safety practices of
other companies to bring them into the Hanford Site and the entire DOE
complex.
Chaired by Westinghouse Vice President of Environmental Affairs Sam
Pitts, the Hanford Safety Team includes representatives from Westinghouse
Corporate Headquarters; EH; EM; RL; WHC; Westinghouse Savannah River Company;
the Westinghouse Waste Isolation Division, Westinghouse Idaho Nuclear Company;
the Westinghouse Productivity and Quality Center; the Hanford Atomic Metals
Trade Council; Pacific Northwest Laboratories (PNL); MMES; Dow Chemical; and
an independent consultant.
"This is a very strong team with the right stakeholders," said Steve
Green, Manager of GOCO ES&H Programs at Westinghouse Electric Corporation. "I
have every confidence that the group will help Hanford become a safety
leader," remarked Mr. Green.
Team activities are being aligned and conducted in accordance with
OSHA's Voluntary Protection Program's (VPP) operative principles, which
include management commitment, employee involvement, and hazard analysis,
prevention, and control. The team will propose a number of measures to
Secretary O'Leary that are designed to improve the safety culture at Hanford,
including safety standards, baseline information, and performance improvement
targets. The benchmarking task team seeks to identify not only the best
safety practices for Hanford and the DOE complex, but also methods to overcome
barriers and implementation techniques that will help achieve these site- and
complex-wide improvements. For more information on the Hanford Safety Team,
call Steve Green (Westinghouse Electric Corporation) at (412) 642-2455.
Robots Reduce Risks to Workers at the Savannah River Site
The Savannah River Technology Center (SRTC) at SRS has developed two robotic
systems that protect employee health by detecting radiological contamination
and reducing risks of personnel exposure to hazardous, radioactive, and mixed
waste drums.
Semi-Intelligent Mobile Observing Navigator (SIMON)
Meet SIMON, an autonomous robot that scans potentially contaminated floors at
a speed of 1 inch per second, alarming SRTC workers if it encounters alpha or
beta/gamma contamination. SIMON has been employed for the past 2 years to
scan the floors nightly in one wing of the SRTC building by traveling a
preprogrammed path with the help of ultrasonic sensors to avoid collisions.
Two downward-facing, gas proportional detectors are used to scan the floors,
and one upward-facing detector is used for radiation background compensation.
SIMON is a modified version of a commercially available robotic base
known as the K2A Navmaster by Cybermotion. The standard vehicle communicates
over a radio link and navigates by counting wheel revolutions in a process
known as dead reckoning. Its three wheels and "Syncho-Drive" feature allow it
to turn on its axis and climb a 1/4-inch step.
If SIMON's onboard computer detects contamination, SIMON stops in his
tracks, sounds an alarm, flashes a red strobe light, and activates a voice
synthesizer. An intelligent creature, SIMON can distinguish between real and
false alarms, responding accordingly to both situations. More importantly,
SIMON is capable of collecting and storing radiation and positioning data in
its onboard memory.
SIMON participated in a technology development exhibit at the Rayburn
House Office Building in Washington, D.C., in the September 1993 demonstration
of innovative technologies solving national problems. SIMON is sponsored by
DOE's Office of Technology Development.
Stored Waste Autonomous Mobile Inspector (SWAMI)
Tens of thousands of hazardous, radioactive, and mixed waste drums are stored
on an interim basis at DOE sites throughout the United States. What's more,
anticipated decommissioning of facilities will generate additional drums of
waste, requiring additional storage space. Federal regulations dictate that
stored waste drums be inspected weekly to check for drum degradation and
periodically to verify inventories. Currently, all DOE waste storage
facilities are inspected manually.
Question: How to keep tabs on an ever-multiplying inventory of drums and
protect worker safety and health? Answer: Call in SWAMI, the stored waste
autonomous mobile inspector.
SWAMI will perform inspections of hazardous, radioactive, and mixed
waste drums and create accurate, high-quality documentation to ensure
regulatory compliance. SWAMI can be sent on an inspection via its host
computer. Its four subsystems perform the following functions: floor
radiation monitoring, drum bar code reading, drum image capture/storage, and
vehicle position determination. While autonomously performing the inspection,
SWAMI stores data as acquired and transmits data back to the host computer so
the operator can monitor the vehicle's location, condition, and other mission
data in real time. Drum images will be automatically downloaded to the host
computer so they can be viewed and processed after the inspection to detect
nonconforming drums. SWAMI is a modified version of the HelpMate mobile robot
produced by Transitions Research Corporation.
Engineers are using a composite of general features found at existing
and planned storage facilities to guide the robot's development. SWAMI will
be capable of operating at any of several DOE target sites including: the Oak
Ridge Reservation, Hanford Site, Fernald Operations Office, Rocky Flats Plant,
INEL, and SRS.
SWAMI is in the development phase at SRS. A "pre-prototype" vehicle,
currently under development at SRTC, will be built during FY 94 and deployed
at Fernald for a field demonstration in the following year. For more
information on SIMON and SWAMI, contact Pat Weber (WSRC) at (803) 725-9518.
Perchlorate Salts Spark Intense Abatement Program
at Oak Ridge National Laboratory
In September 1990, industrial hygienists conducting a routine surveillance of
individual laboratories at ORNL discovered a potentially explosive situation
that had been building since the earliest days of the Laboratory's existence.
During the walk-through, one of the ORNL industrial hygienists observed the
use of hot (>100oC) perchloric acid in a laboratory hood, a protective
enclosure that provides ventilation of noxious fumes, dusts, and gases to
enable the safe handling of chemical, biological, or radioactive materials.
The problem was that the hood was not approved for perchloric acid. A quick
check confirmed that the acid, in fact, had been used more than once in the
hood, which had a ventilation system that was unable to handle the chemical
properly.
Charles Phillips, an ORNL industrial hygiene group leader, regarded the
episode as a safety-and-health red flag for all of ORNL. For him, it raised
the question of how many other hoods not rated for perchloric acid had been
used for such work at the laboratory in the last 5 decades.
Perchloric acid is popular in chemical processing because it offers all
the desirable properties of mineral acids without introducing ions such as
chloride, nitrate, and sulfate, which often interfere with other chemical
reactions. But perchloric acid has a dangerous downside: When it dries, it
leaves behind a perchlorate salt that can be flammable and highly explosive
when subjected to heat, impact, or reaction with other specific chemicals. If
hot perchloric acid is used in a vent system that does not have internal wash-
down capabilities, the salts will show up in the hood, baffles, filters, fans,
ducts, and exhaust stacks over time.
Red Flag Findings
When additional research by ORNL industrial hygiene personnel indicated that,
indeed, hot perchloric acid had been used in other unapproved fume hoods
during ORNL's 50-year history, laboratory management acted swiftly. They
placed an immediate moratorium on the use of hot perchloric acid, halted all
maintenance on lab hoods, and convened a special committee to launch a survey
of ORNL's 700-plus fume hood systems.
The findings? Forty fume hood vent systems were contaminated with the
salts at levels deemed dangerous by the National Fire Protection Association
(NFPA). "It doesn't take much of this stuff to be dangerous," says Mr.
Phillips, who manages ORNL's perchloric acid project. "A single gram of
perchlorate salt has been linked to disastrous explosions in vent systems."
Although no such accidents occurred at ORNL, the industrial hygienists
were aware that a maintenance worker on an Atomic Energy Commission-related
project was killed and two others were seriously injured in a 1962 explosion
ignited by the routine use of a small ball-peen hammer and 6-inch chisel. The
workers were dismantling a perchloric acid fume vent system when the
explosion--violent enough to be heard 4 miles away--occurred.
Several other accidents involving perchloric acid are documented in the
literature, and rumors circulate about explosions and fires during numerous
informal salvage operations around the country, Mr. Phillips said. "With this
in mind, we knew we had to act right away to ensure the safety and health of
ORNL personnel," said Marwan Bader, an ORNL industrial hygienist and
perchloric acid project site manager. The Tennessee Department of Environment
and Conservation, recognizing the need for quick action, agreed to allow
removal of the perchlorates as an emergency response action under RCRA.
"It was decided that a committee must be put in place quickly to oversee
the handling of the project, and this committee should represent all aspects
of the work at ORNL, including industrial hygienists, chemists, industrial
safety experts, health physicists, engineers, fire safety engineers,
maintenance personnel, and environmental compliance advisors," Mr. Bader
explained. In addition to identifying hoods in which perchloric acid had been
used over the years, the committee directed the development of sampling and
analysis protocols and techniques to analyze the amount of perchlorates
present, set a threshold designating serious contamination, and generated a
plan to decontaminate the hoods and return them to use.
The threshold for contamination was set conservatively, Mr. Bader said,
accommodating national standards. "The NFPA code pertaining to perchlorate
contamination says that if a methylene blue test turn to violet--that's
positive for the presence of perchlorates," he explained. "We found that this
color change occurs at a level of about 750 parts per million. We went a step
further and set our own standard at 500 ppm," he said. (A methylene blue test
is similar in principle to a litmus test. A few drops of the test solution in
a small quantity of water washed from the tested area will produce a violet
precipitate if perchlorates are present.)
The committee chose 3 of the 40 contaminated hoods for a pilot
decontamination study, and a temporary enclosure was built in which the hood
baffles, fans, ducts and other parts were to be cleaned. The enclosure
included four 96-cubic-foot tanks and facilities for decontaminating parts on
which any radiological material was found. The main superstructures of hoods
were cleaned in place, in the laboratory.
Before any testing or hood dismantling began, health physics surveys and
industrial hygiene evaluations were performed, workers were trained in all
areas necessary--including RCRA--and any protective clothing or gear necessary
was issued. Maintenance workers who disassembled the vent systems donned
ballistic gear similar to that used by police bomb squads.
The key to dismantling the hood systems, Mr. Phillips says, is to keep
everything wet. "Perchlorates aren't a problem as long as they are kept wet,"
he said. "It's the anhydrous form that poses a potential for instantaneous
fire or explosion." Team members, who wet the hoods and other vent system
components simply by spraying them with water, peered through fiber-optic
scopes into confined areas, such as behind hood baffles, to ensure that even
the hard-to-reach spots were wetted down. Once dismantled and while still
thoroughly wetted, the hood baffles, fans, exhaust stacks, and sections of
duct were plastic-wrapped and carefully transported to the temporary enclosure
for thorough decontamination.
The highest concentration of perchlorates found ranged from 800,000 ppm
on the inlet side of a filter housing to 140,000 ppm at an elbow in a duct.
"Those are very high concentrations," Mr. Bader said, "considering the small
amount of perchlorates necessary to trigger a powerful explosion under the
right circumstances."
But that's not the number of greatest concern that came out of the pilot
project: Workers removed nearly 3 pounds of perchlorate salts from a single
hood vent system. The perchlorate buildup gave inner walls of the duct the
soft, chilly appearance of a freezer in need of defrosting.
"It's likely that many other Federal labs, university labs and
industrial facilities throughout the country have these same legacy buildups
of perchlorate contamination in their systems and just aren't aware of it,"
Mr. Phillips said, "or aren't fully aware of the potential safety and health
risks involved."
In fact, since the presentation of the ORNL perchlorate contaminated
ventilation system pilot D&D project at the April 1992 meeting of the American
Chemical Society, the details of the procedures for the ORNL-developed
decontamination methods have been in great demand by universities and
industry. ORNL presentations at the American Glovebox Society conference in
Seattle, Washington, August 1993, have further piqued the interest of those
who suspect they may have similar problems. An ORNL presentation and exhibit
at the Second Annual DOE Occupational Safety Conference held October 6-8,
1993, in Chicago, Illinois, generated still more interest.
"The pilot study was fantastic, very well accomplished, and the
techniques developed for the three test hood systems proved completely
effective," said Mr. Bader. Furthermore, the ORNL methods were one-fifth the
amount of outside contract estimates to decontaminate and dismantle a typical
hood.
But the cost savings did not stop there. A welcome surprise, Mr.
Phillips said, was that the procedure deregulated low-level radioactive
contamination in several of the treated vent systems. "This alone will save
approximately $12,000 per hood each year because those hoods no longer require
'contamination area' posting and the related expenses," he explained.
Not only were the protocols effective, efficient, and practical, they
were convincing. So much so that the NFPA modified its methods for testing
perchlorate salts based on an ORNL proposal submitted to the organization.
A full-blown effort is now underway at ORNL to remedy the remaining 37
contaminated hood vent systems. To date, one cleanup operation is
operational, and funding proposals are circulating for more startups projects.
Mr. Phillips is pleased. "We had to abate a possibly substantial fire
and safety hazard, and we did it well. We did it within environmental safety,
OSHA, and RAD controls," he said. "Most importantly, the safety and health of
ORNL workers are being significantly enhanced and protected." For more
information on the perchloric contaminated ventilation system pilot project,
call Charles Phillips or Marwan Bader (ORNL) at (615) 576-5048.
Noteworthy Sidebar Points of Perchlorate Work
ORNL team developed a unique procedure for decontamination and removal of
hoods contaminated with perchlorate salts.
OSH-led team demonstrated the presence in vent systems of perchlorate salt
deposits up to 200 times the recommended decontamination level by NFPA.
NFPA modified its own testing methods for perchlorate salts after reviewing
the new, improved, copyrighted procedures developed by the ORNL team.
ORNL team identified a research need to quantify specific compounds and their
associated risks with perchlorate salts in vent systems. Amazingly though
perchloric acid has been used extensively in laboratories throughout the
nation for many years; such a quantification has never been conducted. ORNL
is investigating this research need as a funding initiative.
ORNL team removed, washed, and reinstalled vent systems within safety, RAD,
and environmental constraints.
ORNL team deregulated radiological contaminated fume hoods, fans, and duct
work.
ORNL methods cost one-fifth the amount of outside contract estimates to
decontaminate and dismantle a typical hood.
Process Hazard Analysis (PrHA) Report Available
EH-30 staff released a report of its May 17-21, 1993, technical assistance
visit to conduct PrHAs at Westinghouse Company's water treatment facility.
The Example Process Hazard Analysis of a Department of Energy Water
Chlorination Process report, released October 1993, serves as a PrHA example
for DOE sites using chlorine at their facilities. Contractors who use
chlorine in excess of the threshold quantity, defined as 1,500 pounds, are
required to perform PrHAs under the PSM Rule (29 CFR 1910.119). The report
"share(s) information with other users of large quantities of chlorine, and
show(s) how to perform these analyses," said Sanjeeva Kanth, EH-312. The rule
also applies to other listed chemicals used in excess of their respective
threshold quantities.
Affected facilities must complete PrHAs for 25 percent of the processes
covered in the PSM rule by May 26, 1994. DOE contractors may choose to
conduct PrHAs for quantities of chemicals not covered by the PSM rule if they
believe those quantities pose a significant hazard to workers. For a copy of
the report, contact Sanjeeva Kanth (EH-312) at (301) 903-4516, or Kenneth
Murphy (EH-331) at (301) 903-6514.