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DEPARTMENT OF ENERGY
-2- 2) Emergency Response Plan An emergency response plan is in effect which provides for rapid response by local emergency services providers, whenever they are needed. Our plan also includes on-site familiarization briefings to local emergency service personnel and is coordinated with the Praxair facility emergency response plan. The carbon monoxide incident on April 7 is not considered an emergency; therefore, the response plan was not activated. All four workers were offered immediate medical attention and all declined. In addition, none of the workers were experiencing any obvious symptoms which would constitute an emergency. 3) Breaches of contaiment There were two instances which occurred during the decontamination work at the Praxair Building 14 facility involving possible release of airborne dust outside of the containment areas. The first incident occurred on October 15, 1996, and the second occurred on March 25, 1997. Air monitoring instruments were functioning properly during both of these incidents. The results of these instrument measurements, as well as subsequent swipe samples of settled dust from outside of the containment areas, confirmed that no Praxair workers were exposed to radioactivity contaminated dust. Nevertheless, both of these incidents were considered to be serious. Steps were taken following each incident to make changes in the work plans to minimize the potential for reoccurrence. In addition, all workers in Praxair Building 14 were provided a detailed briefing following each incident, and all of their individual concerns were addressed. In the first incident, workers within Area 12 were decontaminating a concrete block wall using high-pressure sponge blast equipment. The contaiment area was ventilated to the exterior of the building through a large High Efficiency Particulate Air Filter unit. This produced a slight negative air pressure within the containment area, which provided an extra level of protection because air flow through any potential leak would be moving into the containment area rather than out of it. The workers within the containment area were all wearing air-purifying respirators. Approximately two days after this work began, a Praxair worker noticed what appeared to be suspended dust particles in an adjacent room (Area 15). Closer examination indicated that the dust included expended sponge blast media which had escaped from the containment are. There were no Praxair employees working in the area at the time of the incident, so it is not known how long this dust had been escaping. Subsequent investigation determined that the material had escaped through a hidden crack in the concrete block near the top of the wall. The resulting dust was collected and analyzed and was found to be at -3- or near background levels. This result was consistent with the measurements from the two exterior air samplers, which also indicated only background levels of radioactivity. Ed. note: How can the sponge blast media that escaped be only "at or near background?" The sponge blast media was used to remove above level contamination in the containment area. Following the October 15 incident, several steps were taken to further reduce the risk to personnel in Building 14. Decontamination methods and equipment were modified to further reduce dust generation within the containment areas, and periodic visual inspections were initiated around the outside perimeter of containment areas whenever aggressive decontamination work was initiated or changed. In the second incident on March 25, workers were decontaminating a concrete wall in Area 12 with hand-held vacublast tools. This type of equipment features a manifold at the face of the toll with a vacuum to collect dust and pass it to a High Efficiency Particulate Air Filter unit. Although this equipment minimizes dust generation, the workers within the containment are were wearing air-purifying respirators. The containment area itself was ventilated through a small High Efficiency Particulate Air Filter unit. The entrance to this containment area was sealed off with plastic sheeting and duct tape. During decontamination activities, a Praxair worker noticed what he thought was a higher than typical level of airborne fine dust in a room adjacent to the containment area (Area 14). He reported this observation to the containment workers, and the work was then stopped until the situation could be evaluated. Subsequent inspection was inconclusive because the containment area seals appeared to be intact. No obvious dust migration path was identified between the areas. It is possible that the observed dust was unrelated to the work going on in the containment area. Air samples from the exterior high volume air samplers and swipe samples of settled dust all indicated background levels for radioactivity. As an added precaution, the frequency of periodic visual inspections around the perimeter of this containment area was increased significantly following the March 25 incident. 4) Worker Training All workers performing decontamination activities at the Praxair facilities are fully trained for work in both hazardous and radioactive work environments. The minimum training requirements include: Worker Category Training Required All 40-Hour Hazardous Waste Operations Training (29 CFR 1926.65) All Annual 8-Hours Hazardous Waste Operations Refresher Training (29 CFR 1926.65) All Respirator Training & Fit Test (29 CFR 1926.65) All Radiation Worker Training (10 CFR 835.902) -4- All Three Day On-The-Job Training (29 CFR 1926.65) All Asbestos Awareness Training (29 CFR 1926.1101) All Lead Awareness Training (29 CFR 1926.62) All Site-Specific Training All Safety and Health Procedure Training All Task Hazard Analysis Briefings All Equipment Training Briefings All Daily Safety Meetings Health Physics Techs Radiological Controlled Technician (10 CFR 835.903) First Aid Personnel CPR Training First Aid Personnel First Aid Training First Aid Personnel Blood Borne Pathogen Training (29 CFR 1910.1030) Asbestos Supervisor Asbestos Supervisor Training (29 CFR 1926.1101) Site Superintendent Hazardous Waste Operations Supervisor (29 Training CFR 1926.65) SSHR - Gen. Foreman DOT HAZMAT Training (49 CFR 172) No amount of personnel training can totally eliminate the potential for accidents. The formal training, along with on-the-job oversight and reinforcement, provides the basis for a "safety culture." Safety concerns or deficiencies will continue to be addressed promptly and decisively. 5) Contamination surveys and cleanup costs The surveys which are identified all predated the designation of Praxair Building 14 under the Formerly Utilized Sites Remedial Action Program. The characterization of the building was conducted in 1989, and the results are presented in the Remedial Investigation report. Characterization sampling was conducted over a period of two days, and because the building was occupied at the time, access to sampling locations was necessarily limited. Ed. note: Seems that a more detailed characterization sampling could have been done. Or was the sampling limited so as to not arouse Praxair workers' concerns? Nevertheless, the few sampling results which were obtained indicated that the building had areas which were only marginally above the applicable surface cleanup criteria. In an effort to avoid disruptions to Praxair operations, a decision was made to proceed with decontamination of the building based on this limited characterization data. Once work began in early 1996, it quickly became apparent that the extent of contamination was much greater than predicted. Ed. note: This is undoubtedly the understatement of the year. F.A.C.T.S. had warned of this very probable possibility in its newsletter. At first, the decontamination of Building 14 was to be completed in about two months. Here we are, approximately a year and a half into the decontamination and still at it. Also remember that Praxair workers were required to work in the contaminated areas (not only in Building 14, but other buildings as well) day in day out, year in year out without knowing of the possible radioactive health hazards Consequently, the scope of decontamination activities has grown considerably from the original plan. This is not an uncommon situation on the Formerly Utilized Sites Remedial Action Program where we are working in occupied structures and trying to minimize disruption to workers and property owners. -5- In the case of Praxair Building 14, once the larger extent of the decontamination work became clear, a comparative cost estimate was prepared to evaluate the relative costs of decontamination versus demolition of the building. This cost evaluation led to the conclusion that decontamination would be the most cost-effective approach. Among the factors leading to this conclusion are the significant cost difference between fair market value and replacement cost for the building structure, the high cost of specialized industrial equipment and research and development process relocations, business disruption impact costs, and the high cost of waste transportation and disposal for the larger volume of waste which would be generated by building demolition as compared with decontamination. Ed. note: It would be interesting to learn just how much money has been spent on the decontamination of Building 14 up to present. Then be able to compare this figure to the cost of demolishing the building, removal of the contaminated debris and build another building to replace the one that was demolished. Apparently, Praxair doesn't suffer from lack of funding. They are planning on constructing yet another new building in the near future. |
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