SRNL Panel Calls for Improvements Against Brief Tank Vapor Exposures
WC Monitor
10/31/2014
Hanford tank farms contractor Washington River Protection Solutions can take steps to better protect workers from brief exposures to relatively high concentrations of chemicals that are difficult to measure and document, according to the Hanford Tank Vapor Assessment Report released late this week. “The current program is not designed to detect and is incapable of detecting and quantifying this type of transient exposure event,” the report said. Current efforts at the tank farms estimate chemical exposures from vapors released from Hanford waste over eight-hour periods, according to the report commissioned by WRPS and independently led by the Savannah River National Laboratory. Hanford’s current vapor protection program addresses chemical exposures in a way similar to industry programs that monitor for chronic exposure with an emphasis on protecting against long-term health effects that can result from cumulative or ongoing exposures. But the symptoms workers have reported appear to be caused by concentrated chemical exposures over just seconds or minutes, the report said.
The study team made 40 recommendations for improvements to WRPS’s program to monitor for vapors and protect workers, including setting exposure limits for brief exposures as well as the current limits for eight-hour shifts. “Management must acknowledge the health risk associated with episodic releases of tank vapors,” the report said. The chemical vapor protection program must be elevated to the same level as programs to protect workers from radiological hazards and programs to prevent explosions and criticalities within the tanks, it said.
WRPS Has Already Begun Implementing Panel Recommendations
WRPS has begun addressing recommendations, based on preliminary information in an early draft of the report. It will continue to work with the Tank Vapor Assessment Team that produced the report to develop a plan for implementing recommendations. The plan should be available before the end of the year, but full implementation could be a multi-year effort. Some of the report’s recommendations are for cutting-edge technology and research projects. The report recommended real-time detection equipment with alarms for individual workers and “escape” respiratory equipment that workers could carry with them to quickly put on when chemicals are detected. It also discussed the possibility of modifying optical gas imaging cameras used in the petroleum industry to detect clouds of vapors before workers are exposed and to sound an alarm.
Workers already are being better protected with a requirement that they wear at least half-face respirators in single-shell tank farms where underground tanks vent vapors into the atmosphere and in double-shell tank farms when active ventilation systems there are not working. The requirement was set in September based on the early draft of the report. The tank farms already have a well-qualified and well-educated staff of industrial hygiene professionals, but more employees need to be hired to make the protection program more effective, the report said. The tank farm contractor already has added 56 positions to its industrial hygiene staff and is advertising to hire another 50 employees.
Some of the chemical vapors are vented from the head space of underground tanks and ongoing sampling of the head spaces is needed, the report said. Earlier work to determine the types and chemicals in the head space needs to be restarted.
More Than 50 Workers Have Been Evaluated for Exposure
The medical evaluations of workers and decisions on their compensation claims for illness and injury need to take into account the complex mixture of chemicals and the potential, short-term, episodic nature of the vapor incidents, the report said. WRPS does not make decisions on medical issues or compensation claims, but provides exposure data. Since this spring 54 Hanford workers have received medical evaluations for possible exposure to chemical vapors and all have been released to return to work. The key symptoms being reported by workers exposed to chemical vapors this year are upper respiratory irritation, such as sore throats, but workers are concerned that chemical exposure could lead to serious long-term health problems. In one incident this year, a worker was treated for chemical pneumonitis, an inflammation of the lungs caused by chemical exposure.
The report also recommended pursuing more research by Pacific Northwest National Laboratory or other institutions to increase understanding of vapor exposure, effects and protective measures. Researchers could test vapor detection systems, model how plumes of vapors disperse or investigate how the vapors affect health, including over the long term. The report recommended that changes to the infrastructure of the tank farms be accelerated to better protect workers. That includes using exhausters to actively vent tanks that now are passively vented and using air flow promoters on stacks to better disperse vapors they release. Using large fans to sweep air across tank farms and disperse vapors or smaller fans where vapors vent from tanks should also be investigated. A fresh look at past recommendations that were deemed impractical is recommended. That includes “stacks in the sticks,” a proposal to vent vapors into the air a half mile away from areas where workers are based.
Limiting Exposures ‘Represents an Extraordinary Challenge,’ Report Says
The report acknowledged that limiting the emissions of chemical vapors and worker exposure to them “represents an extraordinary challenge that cannot be easily addressed through traditional approaches.” The vapors in the head space of the tanks may contain 1,500 different chemicals undergoing changes due to radiation, heat and chemical reactions. The chemicals and concentrations can vary from tank to tank. There also are multiple places that chemical vapors can be released, including concrete-lined pits near the tanks, the temporary and permanent waste lines between tanks and the cabinets that workers open to take readings.
The study cost about $1.6 million, paid for by DOE, and WRPS plans to continue to contract with at least part of the Tank Vapor Assessment Team that conducted the study. “We want this fixed and fixed once and for all,” said Dave Olson, WRPS president. Work will continue in the tank farms for decades and vapors must be a known hazard that is effectively measured and controlled, he said. DOE agreed that the report would be used to ensure enduring changes to protect workers at the tank farm. The report is posted at http://srnl.doe.gov/documents/Hanford_TVAT_Report_2014-10-30-FINAL.pdf.
DNFSB Wants to Know How DOE Plans to Address Volcanic Ashfall Hazards at WTP
WC Monitor
10/31/2014
The Defense Nuclear Facilities Safety Board is concerned that the Department of Energy is not adequately preparing the Hanford Waste Treatment Plant for the potential threats posed by volcanic ash, according to a letter the Board sent DOE late last week. The WTP’s current design and safety basis do not include the most recent assessment prepared by the U.S. Geological Survey that found a significant increase in ashfall parameters from previous estimates, DNFSB Chairman Peter Winokur wrote in the Oct. 23 letter to acting Assistant Energy Secretary for Environmental Management Mark Whitney, asking the Department to provide within 90 days a response on DOE’s “intent and plan” for incorporating the updated ashfall hazards analysis. “The lack of an ashfall control strategy based on the latest hazard assessment, concurrent with design activities, may lead to the need for significant new designs, design revisions, or retrofits to already-constructed systems,” Winokur wrote.
According to the Board, DOE earlier this year rescinded direction provided to WTP contractor Bechtel National to evaluate the impacts of the updated ashfall hazards analysis. “DOE-ORP personnel explained that they would like BNI to first resolve open technical issues that include the necessary controls for safe hydrogen gas release, the air requirement to support pulse jet mixing, and the subsequent realignment of the design and safety basis. After the resolution of these technical issues, DOE-ORP intends to direct BNI to finalize its previous control strategy with the ashfall loads from the baseline analysis and then to evaluate the impact of incorporating the new ashfall analysis into the design and safety basis,” states a Board staff report. The report goes on to warn, “By continuing design activities without incorporating the latest assessment of the hazard, the project is not meeting the requirement of DOE Order 420. lB, Facility Safety, as listed in the WTP Code of Record, to design and construct facility SSCs to withstand natural phenomena hazards and ensure protection of the public.”
DOE Has Formed ‘Ashfall Working Group,’ Reviewing Board Letter
According to a recently released DNFSB site representative report, dated Sept. 19. the Office of River Protection has formed an “Ashfall Working Group” to identify “sustainable options” for addressing the ashfall hazard. The working group is “evaluating and attempting to refine the magnitude of the ashfall hazard” and is “identifying potential design options to mitigate the increased hazard,” the site representative report says. When asked for comment on the Board’s letter, a DOE spokesperson said in a written response late this week, “The safety of the workers, public and environment is the Department’s top priority. The Department is evaluating the Defense Nuclear Facilities Safety Board’s Oct. 23 letter and will review the WTP design and safety basis to determine if any changes are needed related to the information referenced in the DNFSB letter.”
Jury Finds Four Workers Not Guilty for Time Card Fraud
WC Monitor
10/31/2014
A jury has found four Hanford workers not guilty on all counts related to allegations they aided timecard fraud. The 12-person jury began deliberating the morning of Oct. 30 and announced a verdict about 4:18 p.m. in the Richland, Wash., courtroom of Eastern Washington District U.S. Court. Kenneth Baird, James Hay, Perry Howard and Mark Johnson were all field work supervisors, acting as foremen or “persons in charge” on specific jobs, for former Hanford tank farm contractor CH2M Hill Hanford Group. They were found not guilty after a four-week trial of conspiracy to commit wire fraud, major fraud against the United States and two counts each of submission of false claims. The prosecution did not have the evidence to convince a jury, said attorney John Crowley, representing Baird. “We just believe the jury got it right, and we are so thankful,” said attorney Julie Twyford, representing Johnson.
Eleven former Hanford employees pleaded guilty earlier to charges related to timecard fraud. That included one supervisor who was scheduled to be tried with the four who were exonerated this week. The fraud was related to overtime work that was offered in eight-hour shifts to get workers to volunteer. When jobs were completed in less than eight hours, some workers would go home but claim pay for a full eight hours on their timecards. Federal officials said that CH2M Hill would not have been reimbursed for employee pay for those hours if it knew they had not been worked.
Defense Said Four Did Not Have Hiring or Firing Authority
The prosecution accused the four defendants of aiding in the practice of claiming unworked overtime, or at least turning a blind eye to the practice. “At the end of the day it still comes down to managerial responsibility,” said Tyler Tornabene, assistant U.S. attorney in closing arguments. “It was happening under their noses. They were the boots on the ground.” But defense attorneys said the field work supervisors had no authority to hire fire or discipline the workers they supervised on individual jobs. During closing arguments the defense urged the jury to be skeptical of testimony offered by workers who had pleaded guilty to charges related to timecard fraud. Some had made plea agreements that required them to give substantial help to the prosecution in exchange for a possible reduced sentence. They were under pressure to give compelling testimony against the defendants, the defense attorneys said.
A manager who has pleaded guilty testified that timecard fraud was widespread and well-known. But she also said she was unaware that two of the radiological control technicians she supervised were involved. The two workers also pleaded guilty. If the manager, who supervised the workers, did not know they were committing timecard fraud, then how could the four defendants be expected to know it, asked their attorneys. Among the prosecution’s evidence was a memo from Ed Aromi, the former president of CH2M Hill Hanford Group, in 2004 to all managers saying that some troubling practices were being identified during an audit to look at alleged timecard fraud. “We must take responsibility to validate the time worked,” the memo said. The defense argued that there was no evidence that memo was shared with the four supervisors.
Trial for Remaining Defendants Set for February
Four additional defendants have yet to go to trial after pleading not guilty. U.S. Judge Edward Shea ruled this week that instead of trying them in two more groups as planned earlier, a joint trial for all four remaining defendants will be held in February. They include three upper managers – Ryan Dodd, Terrence Hissong and Patrick Brannon — and Stephanie Livesey, who reviewed worker timecards. In 2013 CH2M Hill agreed to pay $18.5 million to settle civil and criminal allegations of defrauding taxpayers through widespread timecard fraud at the tank farms.
