WRPS Issues Plan to Protect Workers From Tank Vapors
WC Monitor
2/13/2015
A new plan to better protect workers from chemical vapors from Hanford tanks will be implemented in two phases, with the first phase completing 30 of 47 recommendations made in an independent review of issues. Those steps should be completed by September 2016. Hanford tank farms contractor Washington River Protection Solutions released the implementation plan this week for recommendations made in the Hanford Tank Vapor Assessment Report, written by a team of independent experts led by the Savannah River National Laboratory. The proposed strategy should reduce the current high reliance on administrative controls, such as ropes strung to keep workers away from potentially hazardous areas, and personal protective equipment, according to WRPS. Instead, worker protection will move toward engineered controls and technologies, such as new ventilation systems and new methods to detect vapors to reduce potential worker exposure to chemical vapors.
The implementation plan addresses all 47 recommendations, but results from Phase I will be used to inform the potential actions outlined in Phase II of the report and make sure the best actions are being pursued. The second phase will be highly dependent on the outcome of Phase I activities, the Department of Energy said. In the meantime, workers will continue to wear supplied-air respirators for most of the work in the Hanford tank farms “We will take a very technical approach to any changes” to that requirement and make them for specific tank farms and specific activities, said Tom Fletcher, DOE assistant manager of the Hanford tank farms.
First Phase to Cost Approx. $61 Million
Phase I is estimated to cost about $61 million, with $20 million of that spent this fiscal year and $41 million spent in fiscal 2016 as work ramps up to hire industrial hygiene workers, buy equipment and determine its capabilities, and collect and analyze data. Work will include reducing chemical vapor exposure on a tank farm by tank farm plan. More will be learned about the chemicals in the waste. Technology to detect and sample vapors will be improved. In addition, more real-time monitoring of vapors is planned, with monitors both for the tank farms and individual workers. New technology will be investigated, including possibly destroying vapors with ultraviolet lights, a technology proposed during a DOE Grand Challenge Workshop. DOE wants equipment for chemical vapors equivalent to dosimeters now used to detect radiation and sound alarms, Fletcher said.
The Hanford Tank Vapor Assessment Report concluded that short, unpredictable and intense releases of vapors, or bolus events, were the likely cause of health effects being reported by workers, particularly upper respiratory irritation. Since April, 56 Hanford workers have received medical evaluations for potential exposure to chemical vapors. For now exposures being caused by vapors that have high concentrations of chemicals but quickly disperse is a working hypothesis. The implementation plan calls for verifying that and studying what triggers the vapor releases, where the vapors come from, how they move and how workers can best be protected.
One of the major challenges to implementing the recommendations will be finding the additional workers needed, Fletcher said. Almost 100 industrial hygiene technicians have been hired since the start of 2014 and local resources have been exhausted to hire more, he said. Technology will be the other major challenge, said Mark Lindholm, chief operations officer for the tank farms. Much of Phase I is based on technology development, including technology to monitor individual workers and tank farm areas.
Second Phase to Get Underway in Late 2017
By October 2017, Washington River Protection Solutions should be moving on to the second phase of its plan, which calls for institutionalizing improvements in all programs to protect workers, including ongoing monitoring, continued sampling and new vapor management controls. “WRPS and (DOE) recognize that verifying the existence of and addressing potential exposures to chemical vapors over a large area and number of tank farms will take a sustained, ongoing effort,” the implementation plan said. An epidemiological study of tank farm workers to learn more about possible long-term health effects is planned. The first step is making sure adequate data exists to provide useful results, Fletcher said. The Washington State Department of Health has been asked to provide input on what data would be needed for a study.
A panel of experts named by DOE will monitor implementation of the plan, serving as an extra set of eyes, Fletcher said. It will make sure that technical responses are appropriate and justified and information on implementation of the plan is communicated well. It will review a report at the end of Phase I and make sure the proposed actions for Phase II are appropriate. Members of the panel include Chairman Keith Klein, the former manager of the DOE Richland Operations Office; Tom Fitzsimmons, the former director of the Washington State Department of Ecology; George Jackson, a former Fluor Hanford executive; Joseph Iannelli, executive director of engineering and computer science at Washington State University Tri-Cities; Debra Cherry, physician at Harborview Medical Center’s Occupational and Environmental Health Clinic; John Henshaw, former Occupational Safety and Health Administration administrator; and Andrew Maier, professor at the University of Cincinnati College of Medicine.
Wash. State Wants Legally Enforceable Agreement
The Washington State attorney general, Bob Ferguson, notified DOE and Washington River Protection Solutions in November that he was preparing to file a lawsuit to protect Hanford workers from chemical vapors. At that time WRPS had received the recommendation, had started to implement more than half of them and was working on a full implementation plan. The state wants to reach a legally enforceable agreement with DOE or get a court order that lays out plans to eliminate risks to workers, Ferguson said then.
DOE has not responded to the notice and Ferguson has not entered talks with DOE, WRPS or the Tank Vapors Assessment Team concerning chemical vapor protection, according to his staff. “I intend to hold the federal government accountable to their responsibility to maintain a safe work environment for Washingtonians,” Ferguson said this week. He said he was reviewing the implementation plan. A second notice of an intent to file a lawsuit was sent by Hanford Challenge, union Local 598 and Washington Physicians for Social Responsibility.
The Washington State Department of Health also weighed in on worker vapor protection in a letter to DOE as it waited for the release of the implementation plan. It praised the Hanford Tank Vapor Assessment Report saying it was based on sound scientific assessments. “While the report is good, we will continue to have serious concerns for worker safety until worker exposures are eliminated or properly controlled using appropriate industrial hygiene and safety protocols,” said David Jansen, director of the Department of Health Office of Radiation Protection. Hanford must not continue to rely on sensory perception to detect problems, he said. Many chemicals can only be detected with appropriate air monitoring, according to the state Department of Health. The frequency of reports of possible exposure shows that engineering methods used to control vapors now are not adequate, Jansen said. Inadequate information about the chemicals creates difficulty in evaluating whether workers have been exposed to chemicals at levels that could cause health effects, evaluating strategies for sampling and worker exposure monitoring, and evaluating transitory chemical reactions, the letter said.
The Department of Health is offering its assistance, including applying its expertise in radioactive air emissions systems to chemical release concerns, Jansen said. “We understand that updated engineering controls and protective equipment must be provided to support tank maintenance and clean-up activities,” he said. “Ultimately, the best worker protection will be when these aging tanks are permanently closed and workers no longer have to maintain them.” The state expects the federal government to expedite proper worker protection and complete tank cleanup, he said. “We are taking this very seriously,” said JD Dowell, deputy manager of the DOE Office of River Protection, at a meeting of the Hanford Advisory Board last week. The steps being taken are increasing the time needed to conduct work and the cost of work, but “it’s the right thing to do,” Dowell said.