Howard Adventure at the Department of Energys Hanford, WA Reservation - - PowerPoint PPT Presentation

Howard’ Adventure at the Department

• f Energy’s Hanford, WA Reservation

Hanford’s tank farms are generally considered the most toxic waste site in the U.S.

The Beginning

A Call from Dr. Knut Ringen

• Health complaints from union workers in Tank Farms
• Distrust of management
• Union created a stop work order
• MOA that all work to be done with SCBA until

Independent 3rd party confirms that air-purifying respirators could be worn

STC and CPWR assembled a team of seasoned respirator experts

Knut Ringen, DrPH, MHA, MPH, STC Project Director Subject Matter Experts

• Howard Cohen, PhD, CIH, UNH/Yale U. (ret)
• James S. Johnson, PhD, CIH, Lawrence Livermore

National Lab (ret)

• Bill Kojola, PhD (ABT), MS, AFL-CIO (ret)
• Bruce Lippy, PhD, CIH, CSP, CPWR, J. Hopkins U.
• Richard Metzler, MSIE, NIOSH (ret)
• Pete Stafford, BS, CPWR (ret) Liaison to HAMTC

More than 250 years of professional expertise

Team Onsite visit 3-30-17, photo courtesy Bruce Lippy

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Hanford was 640 square miles purchased by the government in 1943

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Photo courtesy Washington State Historical Society

*Enrico Fermi’s lab at University of Chicago proved less than 2 years earlier that a controlled reaction was possible

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Photo courtesy Wikipedia and DOE

The scale of work at Hanford was astounding

PUREX Facility

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Move from Production to Waste Mgmt

• In 1986, the DOE converted Hanford operations from weapons

production to remediation and waste management. A so-called Tri- party Agreement between DOE, the US Environmental Protection Agency and the Washington State Department of Ecology was established to govern the waste management.

• It was focused on environmental protection, particularly to prevent

contamination of the Columbia River, and did not focus on worker protection.

“The Energy Department issued a new cost estimate to remediate the entire Hanford site, taking it from $110 billion to as much as $660 billion... [WA] state wants a low-level treatment system operating by no later than 2023, full production of high-level waste glass by 2036.”

June 4, 2019 Los Angeles Times, Nation’s most ambitious project to clean up nuclear weapons waste has stalled at Hanford

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Vitrification plant

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Photo courtesy Wikipedia and DOE

The tanks have a long and difficult history

• Hanford had 40% of all

radioactivity that exists across the nuclear weapons complex

• Each tank holds 53,000-1.4

million gallons

• Up to 45% of SSTs believed

to be leaking (1 million gallons)

The tanks differ in how they are ventilated

• Most SST are passively ventilated
• Most DST are actively ventilated

Diagram courtesy WRPS

AP Tank Farm Stack

The chemical compositions and concentrations vary by tank and change over time

• Approximately 1,500 chemicals
• PNNL has identified 60+ chemicals of potential

concern (COPCs) that may exist in the tanks headspace at 10% or more of their OEL.

• WRPS assembled a team of toxicology experts to

establish OELs where none existed.

A History of Adverse Health Incidents

• Between July 1987 and December 2001, 16 different vapor exposure

events were reported in the tank farms. They ranged considerably in severity from no medical complaints to minor first aid complaints to treatment at a local hospital to disability.

• In the first quarter of 2002, a DOE investigation was completed. It

concluded, “The direct cause was failure to characterize the work environment and develop the appropriate engineering controls.”

• A NIOSH Health Hazard Evaluation performed in 2004 reported that

70 exposure events took place from 2001 to March 2004.

A History of Adverse Health Incidents

• In the spring of 2014 another outbreak of short-term exposures led more

than two dozen workers to seek medical attention. As a result, WRPS hired the Savannah River National Laboratory to conduct an investigation.

• in 2015 more exposure episodes were reported, leading to two law suits

being filed by the unions and State of WA against DOE and WRPS, demanding better chemical vapors protection for workers.

• In the middle of that process, in 2016, HAMTC union issued a general stop

work order and demanded mandatory supplied air (SCBAs) respiratory protection throughout the tank farms. An agreement was established between HAMTC and WRPS which included the assessments that STC has been conducting.

The 2014 report made the specific recommendation

“WRPS should confirm that the air-purifying respirator cartridges in the tank farm are effective for the unique chemical mixtures that may be present in the tank farms. In addition, breakthrough evaluations should be conducted using representative tank farm mixtures to assure the chemical cartridges will remain effective during work activities.”

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Part 1 Testing APR Cartridges

• WRPS hired a local contractor to build a unit to test cartridges using

the headspace vapors of various tanks.

• The unit cost approximately $1MM to build
• It took a team of IHs and technicians days to set up and sample the

headspace of various different tanks in different farms (all workers had to be in SCBAs).

• Tests were run on consecutive days in each tank headspace using the

two different Scott organic vapor-acid gas cartridges.

• Test conditions such as chemical concentrations, humidity and

temperature were “as received”.

Respirator test apparatus

Cartridge Cartridge

Top View Side View

Laptop

Vacuum pump Vacuum pump

Temp/RH Monitor

Sampling tubes Sampling tubes Down stream Up stream

Sampling ports Sampling ports Riser

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The Cartridge Testing Equipment

During our first visit to WRPS we were taken to a facility where the cartridge sampling apparatus was built, designed and stored. Several of us had experience in building and testing of cartridge service life equipment for NIOSH, National Laboratories and private industry. We thought that this equipment was quite exceptional.

WRPS’s Sampling and Analysis Plan for Respirator Cartridge Testing identifies the following important features of the study:

• Field calibration of all flow rates used in the study traceable to NIST

primary standards.

• Industrial hygiene field blank samples taken for all of the sorbent

tubes in the study.

• Established analytical methods published by EPA, NIOSH and OSHA

used for COPC collection and analyses.

• Chain of custody for all samples.
• All laboratories performing the analyses were required to comply

DOE quality assurance plans and contracting laboratories were also required to be AIHA-Accredited and participate in their PAT program (proficiency testing).

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WRPS Testing Protocol

• Upstream measurements of 59 COPCs every two hours

(some tests only at the first and last two hours) as well as temperature and humidity

• Downstream measurements of 59 COPCs every two hours as

well as temperature and humidity

• Testing was conducted for 16 hrs at 30 L/min per cartridge
• Environmental Conditions: 32 to 115°F; RH: 5% to 100%

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SCOTT 7422 SC-1 SCOTT 7422 SD-1

P100

Two Scott cartridges were tested

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STC Involvement

• STC was asked to provide an independent review of respirator

cartridge tests conducted by WRPS from the headspace and exhauster of eight different tanks and tank farms

• Our involvement began after the protocol and all testing had

been completed by WRPS personnel.

• Our analyses of the results and our conclusions were based on

eight PNNL issued reports.

The STC team agreed on a review protocol that would be:

Evidence based: WRPS must provide adequate information Systematic: We follow a list of review questions Consensus: All our review findings are agreed upon by all team members Certified: all our reports are signed Independent: Our team's reviews are completely independent of WRPS and HAMTC

The Overall Approach

In general we agreed with the approach taken by WRPS in conducted these studies for the following reasons:

• An understanding of the use of APRs including the adsorption

capacity of the Scott cartridges for the 59 COPCs present in the tank farm could not have been accomplished by modeling nor by attempting to conduct controlled laboratory testing (due to the complexity of the mixture).

• Examining the service life, by modeling or laboratory testing, of
• nly one or two target COPCs (e.g. ammonia) would be

insufficient.

The WRPS Protocol

“We agreed with PNNL that cartridge service-life is affected by temperature, humidity, COPC concentration, breathing rate, and cartridge adsorption capacity. We agreed with their primary conclusion that cartridge service life performance (breakthrough period) is applicable to the conditions under which the measurements were made. “

Notable Findings

• Ammonia: The first (and often only) COPC that broke through

cartridges in almost all of the studies.

• Nitrosamines: Carcinogens found at high concentrations in the inlet

in a couple of studies. Well adsorbed onto the cartridges.

• Furans: Carcinogens that were detected downstream of the

cartridges at very low concentrations.

• Elemental mercury: Detected at the inlet >10% of OEL at some sites.

Although the cartridges showed good adsorption, Scott cartridges tested were not NIOSH approved for protection against mercury as they lack an end-of-service-life indicator.

• Very low concentrations of many COPCs were detected downstream
• f cartridges.

Cartridge Change Schedules

• Current union-management agreement limits the use of APRs to

3 continuous hours. Fresh cartridges are used if respirators are worn again.

• Cartridges should not be reused due to concerns of COPCs

migrating through the carbon beds during non-use times.

• Attention should be taken when high temperatures and low

humidity exist (mid-summer times) as ammonia will be poorly adsorbed.

• Always change cartridges whenever any odor is detected which

is current WRPS procedure.

Conclusions

• We view the respirator cartridge test program as a positive effort to assure

workers that they will be protected at the tank farms when wearing a FFAPR should a gas-release event occur. Future testing is likely to reinforce the safety and value of wearing these air-purifying respirators

• Monitoring of the headspace of tanks and the exhausters of tank farms

remains an important step in identifying COPCs and their concentrations that could be emitted during a gas-release event.

• The current industrial hygiene program that monitors long-term or full-shift

worker exposures to COPCs in the tank farms remains an important exposure assessment task. However, it may not adequately detect brief short-term exposures that may occur with gas-release events. .

Part 2 The Industrial Hygiene Program

• The 2014 TVAT Report recommended that management work to have industrial

hygiene programs on par with health physics programs

• Prior to our work WRPS had a minimal IH function included as part of its

Industrial Safety Department consisting of roughly two IHs; one of these a Certified Industrial Hygienist (CIH) and about 20 Industrial Hygiene Technicians (IHTs).

• Today Today, WRPS has a distinct IH program with a staff of 225 professional

and support personnel, including 47 IHs (of whom 15 are CIHs) and 170 IHTs.

• All industrial hygiene (approximately 200) procedures have been revised and

stand alone equivalent to safety and health physics.

The industrial hygiene program is impressive for just one area of one DOE site

• Their database has hundreds of thousands of IH results
• Currently assessing 62 chemicals >10% of their OEL in the

source

• Less than 10 BZ samples that exceeded 50% of the OEL
• Majority of the samples are below detection

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The Problem

• The issue that caused our group to be hired was:
• short-term unexpected exposure episodes (USEEs)
• The IH program has focused on TWA data
• because it corresponds to most of their OELs
• because short-term exposures are difficult or impossible to

measure without real-time instrumentation

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The Solution

• Hinges on whether Ammonia can be used as a leading

indicator of other tank vapors

• Ammonia exists in all of the chemical waste tanks (it is a by

product of the use of nitric acid among other chemicals used in the process)

• Ammonia levels correlate but do not specifically predict
• ther key vapors

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Our Recommendation

• Real-time ammonia monitors for all tank workers that

alarm at a low level (6 ppm) above background levels to alert them to leave an area.

• Real-time ammonia monitors on tank exhausters to provide

warnings when levels have increased beyond a normal range

• WRPS have developed a QRA model that incorporates

ammonia emissions

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Our team recommended and WRPS has adopted real time personal monitoring for ammonia as an indicator gas 300 units issued per day, alarm at 6 ppm

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The Current Respirator Requirements

• Workers wear FFAPRs in the ventilated tank farms and SCBA

in the non-ventilated farms.

• Workers continue to have the option of requesting SCBAs if

they prefer to an FFAPR

• Some non-intrusive work in ventilated farms will begin to

allow workers to eliminate wearing respirators if there are real-time ammonia monitors on the stacks

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Conclusions

• Our initial 3 month contract to help resolve worker distrust
• f management has morphed into 3+ years of work
• We have made numerous trips to Hanford (5+) to meet with

management and union members and observed work

• We have issued 25 reports to management and union
• Our last report summarizing our findings was extensive

(154 pages)

• We anticipate working into 2020 to assist in moving the

respirator program from management to risk based

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