Vapor Management Expert Panel (VMEP) Report SUMMARY (Feb. 2015 – Sept. 2016 Implementation of the Tank Vapor Assessment Team’s Report Recommendations)
The Vapor Management Expert Panel (VMEP) was chartered by the Department of Energy Office of River Protection (DOE-ORP) in February of 2015 to “provide assurance to ORP that actions committed to following the Tank Vapor Assessment Team’s (TVAT) report (SRNL-RP-2014-00791) and actions resulting from any new, emergent issues are being carried out and effective in protecting workers from potential vapor exposures”.
The VMEP provided a report to DOE-ORP spanning the team’s activities from February 2015 through September 2016. In the report, the VMEP members evaluated multiple topics and provided observations on each. The topics covered were:
- Technical bases and validation
- Exposure control
- Health effects, data, studies, results, and conclusions
- Education and communication strategy and implementation
- Institutionalization of improvement changes, and
- Cross-cutting areas and general observations on improvement opportunities.
General Comments
The VMEP team noted the increased conservatism employed by WRPS and DOE in response to the emotion, controversy and legal challenges involved with the Tank Operations Contract (TOC), resulting in a minimization of work in and around the farms, and requiring the use of SCBA regardless of whether waste disturbing activities are taking place, or tanks are under active ventilation. They recommend a risk-informed decision-making approach be used at Hanford and believe that the data required for such a process have already been collected.
Technical Bases and Validation
The VMEP team evaluated the steps that WRPS and ORP have taken to address the TVAT’s recommendations. VMEP members found that considerable work has been done and progress made in many areas to address these recommendations. Several new technologies being tested on site were first tested at PNNL and in simulated field settings, and are now being tested within the farms.
VMEP members noted that while many of the instruments and technologies being tested are advancing detection capabilities, it may be very difficult or impossible to monitor, in real-time, many of these chemicals without collecting and concentrating them to determine their concentrations in air. They also warned against stating that the technologies under review are currently capable of immediate and direct hazard condition identification, as it could further diminish worker morale.
Exposure Control
The VMEP evaluated progress on vapor exposure control using the hierarchy of controls method. This method employs the following steps in the stated order:
- Elimination of vapor sources
- Installation of engineering controls
- Establishment of administrative controls
- Providing Personal Protective Equipment (PPE) to the workforce.
The team noted the effort invested by WRPS in performing tests on the ability of respirator cartridges to protect workers from chemical mixtures found in tank headspace. The testing is conducted on select tanks (representative of headspace vapor composition), with some tanks selected per the request of worker representatives, and data evaluation is performed by Pacific Northwest National Laboratory (PNNL). There is no absolute process for testing cartridges in every conceivable work environment. Nonetheless, they commented it appears there has been good worker engagement in the cartridge testing effort through the CVST.
On the administrative controls front, the VMEP team observed that considerable effort is being devoted by WRPS to reexamine and strengthen the basis for determining vapor control zones and vapor reduction zones.
Health effects, data, studies, results, and conclusions
The VMEP team assessed these topics by evaluating what is known, what is not known, and what to do to close these gaps.
What is known
The VMEP team stated that the aggregate health data specifically related to tank farm workers does not suggest pervasive or systematic chronic health effects associated with exposure to tank farm vapors, or a pattern of chronic disease emerging later in life. This finding was gleaned from a variety of sources, including long-term studies.
What is not known
VMEP members noted that reported health effects associated with odors from the tank farms have increased in the last three years. The reported symptoms are generally transient and reversible, with no objective findings on a medical exam. Since such effects are non-specific, the committee members observed it is difficult to determine the precise cause since many different chemicals, bad odors, naturally occurring allergens, or other factors may cause similar symptoms as those reported.
In contrast, accidental chemical releases such as spilled liquid waste or sudden release of trapped gas resulting in clinically apparent adverse health effects with objective findings has occurred relatively rarely at Hanford. The report stated that the rate of such events is lower than in other chemical industries but may raise more concern due to the complexity of hazardous waste stored at Hanford. They further noted it is important not to confuse the health effects from an accidental release with the health-related effects of a minor reversible nature associated with most cases of tank farm vapor exposures.
Since aggregate data are not designed to capture every individual case of effects, it is possible for the standard onsite worker exams and the worker’s compensation claim system to miss cases of occupational illness related to tank vapors, if such cases exist.
The report also noted that a number of former and current Hanford workers are suffering from serious respiratory, neurological, and other conditions, which occur at some rate in any human population. It is not clear however, to what extent those medical conditions are a direct result of exposure to tank farm vapors or other possible exposures or conditions.
Closing the Gap
The VMEP members identified several options to help close the gap including:
- Linking the health data from worker’s compensation claims to the existing AOP-15 and annual surveillance data to add a dimension of follow-through in addition to what is already being done, to address the question of how many of the workers reporting under an AOP-15 have or may be expected to experience consequences from those exposures.
- Development of better tools for tracking, integrating, and aggregating data which would be extremely useful for informing health decisions and providing the best care for workers, and
- Engaging in efforts to better monitor the atmosphere in and around the tank farms and tank farm workers on a continuous basis and/or right when workers smell something to get more or better information on what exactly workers are smelling or were exposed to and for how long.
The report also observed that recommendations from other entities are in process. For example, PNNL is preparing a Hanford Tank Farm Occupational Exposure and Risk Assessment Plan, which will refine and update chemicals of potential concern and associated exposure limits.
Education and communication strategy and implementation
All VMEP members, and particularly those with expertise in organizational and risk-based communications, believe progress is being made to inform workers and interested parties about the facts and challenges related to vapors and the strategies and activities related to worker safety.
VMEP members believe the recent development of a formalized vapors communication strategy, and the designation and dedication of a vapor issues high-level manager for implementing that strategy, is an important step. The development of fact-based and risk-based consistent messaging however, needs to be developed and key staff need to better understand and use it in daily operations.
While there are significant efforts underway to improve mechanisms for communicating with the workers, several VMEP members believe that what is communicated is far more important than how.
Institutionalization of Improvement Changes
The VMEP found that WRPS has implemented many of the TVAT recommendations and other improvements while continuing to explore additional improvements through its Phase 1 efforts (FY2015-2016). As these and other changes are implemented and experience is gained, these improvements become “institutionalized” by being documented and incorporated into revised requirements documents, written and controlled work and reporting procedures, training programs, and other vehicles. Considering all the different areas of improvement (e.g., new technologies, new requirements and procedures, new information, and the introduction of new personnel with limited tank farm experience), VMEP members believe an updated integrated control strategy should be documented incorporating the results of the new hazard understandings, abatement technologies, engineering controls, administrative controls, and PPE examined or implemented during this phase.
Another observation or concern expressed by VMEP members relative to institutionalization of improvement changes is the frequency and degree of turnover or reassignments affecting key WRPS managers. Lack of stability among senior and mid-level managerial positions makes it more difficult to maintain institutional knowledge of lessons learned, what has been tried and the outcomes, what was not tried and why, etc. In addition, management turnover typically works against resolution of trust, confidence, communication, and engagement issues between the workers and management that appear to underlie some of the vapor issues and be key to their resolution.
Cross-cutting areas and general observations on improvement opportunities
The VMEP observed there is still much that needs to be done to resolve the non-technical issues impeding resolution of vapor issues. This is evidenced by worker concerns, lawsuits, the HAMTC “demand letter” (2016), emotional or inflammatory news reports, intervention by senators, and continuous calls for new investigations and assessments. Management credibility among certain segments of the workforce seems low and there are a number of possible contributing factors. The committee suggested that the entirety of the efforts to address the “vapor issue” still seems lacking in the definition of succinct goals, critical decision points, and decision strategies governing the various initiatives.
The VMEP report recommended ORP and WRPS consider options for changing criteria for who may work in farms and under what circumstances. Efforts should also continue to reach understanding among the workforce, medical community, union leadership, elected officials, media, stakeholders, and others regarding the prospect that there will always be a likelihood that some odors and health risks will persist in the tank farms, as in everyday life and other work areas and industries.
The team commented that it is unclear, when and how larger risk assessment and cost/benefit decisions driving the tank farm activities have been or are being made. Given today’s circumstances and new understandings, the VMEP felt it would be highly desirable to further refine a workable, higher-level, risk-informed, decision-making process that better considers the risks to workers working in the tank farms. Unfortunately, those risks are still perceived differently, sometimes even dramatically so, among workers, between some workers and most of management, and among stakeholders.
Read the full Vapor Management Expert Panel Report.
Read the Second Vapor Management Expert Panel Periodic Report and Recommendations October 2016 through June 2017. A summary of the report is available here.