DOE Enterprise Assessment follow-up report on vapors – February 2018
The Department of Energy’s Office of Enterprise Assessments (EA) conducted an independent oversight assessment of progress on actions taken to address tank vapor concerns at the Hanford Tank Farm Site. This follow-up assessment focused on actions taken to address recommendations from a previous EA Assessment, Office of Enterprise Assessments Follow-up Assessment of Progress on Actions Taken to Address Tank Vapor Concerns at the Hanford Site – January 2017 (available at www.hanfordvapors.com). EA’s recommendations, including those associated with communications, engineering controls, and the industrial hygiene program have been beneficial to WRPS’ efforts to address concerns associated with chemical vapors in and around Hanford’s tank farms.
Today, Washington River Protection Solutions, LLC (WRPS) received the final follow-up report from the EA team, available here. We are pleased to see that the report describes WRPS’ progress in addressing the January 2017 EA assessment report recommendations, and recognition that we have effectively implemented a number of planned actions related to the EA recommendations. WRPS will continue to evaluate this report as we work to address remaining tasks and as a part of our overall efforts to continually strengthen our worker safety program.
Office of Enterprise Assessments (EA-32)
The Hanford Tank Vapor Assessment Report, produced by the Tank Vapor Assessment Team (TVAT) in October 2014 included several recommendations aimed at addressing concerns about chemical vapors in and around the tank farms at the Hanford Site. In 2016, the U.S. Department of Energy Office of Enterprise Assessments, Office of Worker Safety and Health Assessments (EA-32) conducted an assessment to evaluate progress made by Washington River Protection Solutions (WRPS) on actions taken to address the recommendations made by the TVAT.
Specific focus areas for EA-32’s follow-up assessment were:
- Whether Department of Energy (DOE) and WRPS line management have addressed the recommendations made by the TVAT
- Whether the new technology and supporting equipment selected for tank vapor control and measurement have the potential to be effective in reducing and/or measuring worker exposure, and
- Whether Tank Farm workers and medical personnel have been effectively involved in the development and implementation of actions to address TVAT recommendations.
EA-32’s Findings on the WRPS and DOE Office of River Protection (ORP) Response to TVAT Recommendations
The EA-32 report observed that managing Tank Farm vapor issues has historically been a challenge because of longstanding, complex issues in vapor characterization; the identification and control of fugitive releases; and potential exposures to personnel. Additionally, the current environment involving lawsuits, injunctions, press inquiries and extensive coverage, union stop-works, congressional oversight, and multiple internal and external reviews has created another barrier to open communication on key issues.
The Tank Vapor Assessment Report (TVAR) provided 10 overarching recommendations (ORs), as well as 47 supporting recommendations designed to improve the safety and health management program as it relates to Hanford tank vapors. In response to a preliminary draft of the TVAT, WRPS required workers to wear at least half-face air purifying respirators in the single-shell tank (SST) farms beginning in the summer of 2014. Subsequently, starting in November 2014, WRPS required the use of self-contained breathing apparatus (SCBA) in all SST farms and for any double-shell tank (DST) farms with a low threshold odor potential.
WRPS developed a two-phase implementation plan (IP) for addressing the recommendations in the TVAR. Key components of Phase 1 of the IP were directed toward addressing respiratory protection issues, improvements in the industrial hygiene (IH) program, and the testing and implementation of technology improvements.
The EA-32 team found that overall, WRPS has made measurable progress towards addressing the TVAT recommendations. In many cases, WRPS has taken appropriate actions to address the tank vapor issues, and ORP has provided dedicated resources for oversight. However, some obstacles remain.
EA-32’s findings on new detection technology and reducing/measuring worker exposure
EA-32 found that WRPS has made measurable progress in the identification, prototyping, and field deployment of new detection equipment. WRPS is using an integrated safety management system (ISMS) approach as the basis for the selection of new technology and supporting equipment. The selection of new detection instrumentation is intended to address current Tank Farm vapor instrument deficiencies with respect to new technologies and to focus on real-time and space measurements, remote operation, spectroscopy, wireless communications, and integrating software.
Several recent engineering control actions that WRPS has undertaken were noted in the report including:
- Atmospheric dispersion modeling of emissions from tanks within the 200 East area
- Installation of exhauster upgrades and stack extensions in AP farm, and
- Design of a 242-A Evaporator vessel vent extension and evaluation of actions for installation in AW farm in the 2017/2018 timeframe.
Furthermore, technology improvements designed to improve the accuracy, data recording, and communication of IH technician (IHT) monitoring data on a real-time basis have been implemented into the IH rounds and routines programs.
The EA-32 team observed that the respirator cartridge testing station provides a unique measurement and test system for evaluating respirator cartridges when exposed to actual headspace gases. WRPS assembled a team of over 50 workers from various Tank Farm organizations to develop and operate the system, which is designed to determine the breakthrough times of actual headspace vapors for selected respirator cartridges. Although the respirator cartridge testing station shows promise in evaluating the application of certain cartridges to actual headspace gases, the EA-32 report noted a few potential limitations:
- Limited sampling data
- Limited analytical sensitivity
- Limited meteorological data for each sample set
- Tanks sampled were based on work activity instead of number of chemicals of potential concern (COPCs) present, and
- Limited data on how changes in the airflow rate affect the sampling train.
EA-32’s findings on worker involvement
After several vapor events in 2014, WRPS re-established the 12-member Chemical Vapor Solutions Team (CVST), which was originally founded in 2012. The CVST consists of 12 members (and 12 alternates), half of whom are members of a bargaining unit. The CVST members also serve on the various CVST sub-teams. CVST meetings occur twice a month and are open to all employees to attend.
Apart from the CVST, EA-32 found no effective mechanisms for routinely involving the workforce in the selection and implementation of new technologies (with the exception of field IHT’s who have been actively involved in the selection of monitoring locations in the Tank Farms). Furthermore, since the bulk of the prototype development activities are subcontracted, and subcontractors use their own employees, WRPS IH and workers have been only minimally involved in these activities.
The EA-32 team also found little indication of worker involvement (outside of the CVST) in the following activities related to the vapor issues:
- IP development, particularly in the determination of action priorities (i.e., whether the recommendations would be addressed in Phase 1 or in Phase 2)
- Developing headspace sampling priorities
- IHT training
- Searching for the sources of fugitive emissions
- Communication strategies for keeping workers informed of vapor issues, and
- Addressing problems with and improvements in work control processes and communications.
The CVST is a mechanism for giving employees the opportunity to learn about vapor issues and express their opinions and ideas, however, the report found the CVST has not been effective in soliciting worker input and communicating to the entire workforce about Tank Farm vapor issues. As a result, the EA-32 team suggested that increased management attention and involvement are needed to ensure that CVST activities are representative of worker input and are communicated to the entire workforce.
The EA-32 team recommended that to promote better communication and improved trust among workers with respect to tank vapor issues, ORP and WRPS establish and implement strategies that include: enhanced, empathetic dialogue regarding ongoing actions, and workforce notification of and response to vapor-related events. They also suggested that WRPS improve its management processes for responding to the TVAT recommendations through clear identification of action details, action owners, action status, and objective evidence for closure.
The EA-32 team noted that WRPS should also expedite improvements in the IH program as recommended by the TVAT, including: additional tank headspace sampling with a focus on the waste tanks that pose the greatest risk to workers, further development of short-term chemical vapor exposure limits, and updating the COPC list.
As IP Phase 2 actions are developed, the EA-32 team also suggested that WRPS consider refocusing and documenting the analysis and use of engineered controls to reduce the potential for vapor exposures to workers, such as increasing exhaust stack heights for selected tanks. The participation of IH and other key professionals in the selection and evaluation process should also be ensured.
Additionally, the EA-32 team recommended that DOE Richland Operations Office (DOE-RL), DOE-ORP, Penser North America, Inc. (the third party Worker’s Compensation Administrator for WRPS), HPM Corporation (the Hanford Site Occupational Medicine contractor), WRPS, and other Hanford Site contractors work together to promptly address the obstruction in the flow of injury/illness information. The assessment also noted that WRPS (and other Hanford Site contractors) need timely and accurate injury/illness information to conduct effective case management to determine recordability/reportability under Occupational Safety & Health Administration (OSHA) and DOE injury reporting processes and, most important, to provide the appropriate services to the workers.
The EA-32 team also suggested the DOE Office of Environment, Health, Safety and Security consider including the Tank Farm Worker designation in its health studies to evaluate potential worker health effects from exposure to hazardous materials associated with DOE operations, and in its medical surveillance and screening programs for current and former workers.
Finally, the team recommended that HPMC reassess both their communication protocols (to ensure workers fully understand the medical evaluation activities when symptoms from vapor exposures are reported), and the laboratory test panel used for acute exposures and annual monitoring of Tank Farm workers.
Read the full EA-32 assessment, published in January 2017, Office of Enterprise Assessments Follow-up Assessment of Progress on Actions Taken to Address Tank Vapor Concerns at the Hanford Site.