Hazards Ahead: Managing Cleanup Worker Health and Safety at the Nuclear Weapons Complex February 1993 OTA-BP-O-85 NTIS order #PB93-163368 GPO stock #052-003-01316-9 Recommended Citation: U.S. Congress, Office of Technology Assessment, Hazards Ahead: Managing Cleanup Worker Health and Safety at the Nuclear Weapons Complex, OTA-BP-O-85 (Washington, DC: U.S. Government Printing Office, February 1993). For sale by the U.S. Goverment Printing Office Superintendent of Documents.Mail Stop.Stop SSOP Washington, DC 20402-9328 ISBN 0-16 -041667-1 F oreword c old War nuclear weapons production has left a legacy of environmental contamination that is unprecented in scope and complexity. The Department of Energy has begun cleaning up pollution at the Nuclear Weapons Complex (NWC)-an expensive, decades-long task that will require a workforce numbering tens of thousands of scientists, technicians, and laborers. Protecting their health and safety must be a major goal of this cleanup effort. Achieving this goal will require DOE to successfully confront significant technical and managerial challenges, but it also poses a unique opportunity to advance state-of-the-art occupational health and safety technologies and practices. The Senate Committee on Armed Services asked OTA to undertake this project as part of OTA’s evaluation of environmental restoration and waste management at the DOE Nuclear Weapons Complex. The Committee directed OTA to examine risks workers might face in cleaning up contamination at the Complex and to evaluate the effectiveness of DOE’s occupational safety and health programs for cleanup workers. This background paper concludes that, thus far, DOE and its contractors have devoted little attention to cleanup worker health and safety. They have not convinced workers and managers that a “new culture” of accountability in environment, safety, and health is truly ascendent. DOE’s plans call for ambitious increased capability in occupational safety and health matters, but DOE has devoted few resources to these efforts. Policies and programs needed to protect cleanup workers are not yet in place. Yet DOE could apply to great advantage both its own technical strengths and the lessons learned by the Nation’s experience with protecting cleanup workers at non-Federal waste sites. If the Department aggressively addresses its organizational problems, it could become a major force in establishing the principles, practices, and technologies needed to restore contaminated environments to safe conditions-in a manner that ensures that the “cure” for contaminated environments does not do more harm than the pollution itself. In the course of preparing this background paper, OTA received important assistance from many individuals and organizations. Workshop participants, employees of OSHA, EPA, and DOE, and numerous contributors and reviewers from academia, industry, and organized labor gave generously of their advice and time. In the absence of such expert advice and guidance, OTA would have been unable to accomplish this study. The analysis and conclusions of this background paper are, of course, OTA’s, and OTA assumes full responsibility for the paper and the accuracy of its contents. . . . Roger Herdman, Acting Director Ill w orkshop Participants DOE CLEANUP WORKER Robert Goldsmith Michael Silverstein HEALTH AND SAFETY Office of Health Surveillance and Occupational Safety and Health Epidemiology Washington State Department of Ed Bergin U.S. Department of Energy Labor and Industry Occupational Safety and Health Administration Lanny Graves Sandra Tillet U.S. Department of Labor Atomic Trades and Labor Council Occupational Health Foundation Y-12 Plant Joseph Cocalis Office of Solid Waste and William H. Greendyke HAZARDOUS WASTE ACTION Emergency Response Los Alamos National Laboratory CONTRACTORS (HWAC) U.S. Environmental Protection WORKSHOP Agency Ellen J. Mangione Disease Control and Environmental Richard C. Gerlach Steven Cordova Epidemiology Health Sciences Division Joint Company Union Safety Colorado Department of Health Halliburton NUS Environmental committee Corp. James Melius Rocky Flats Plant Division of Occupational Health Thomas Bailey U.S. Department of Energy and Environmental Kleinfelder, Inc. Denny Dobbins Epidemiology Martin S. Mathamel Worker Education and Training New York State Deparatment of Health and Safety Division Branch Health CH2M-Hill Occupational Health and Technical John Moran Services Carolyn M. Kiely Safety and Health Laborers’ National Institute of Environmental Hazardous Waste Action National Health and Safety Health Sciences Contractors Fund John Serocki Brad Whitehurst Diane Morrel Office of Environmental State & Technical Affairs Health & Safety Restoration and Waste Hazardous Waste Action Ebasco Environmental Management Contractors U.S. Department of Energy Glenn Paulsen Illinois Institute of Technology NOTE: OTA appreciates and is grateful for the valuable assistance and thoughtful critiques provided by the workshop partici- pants. The participants do not, however, necessarily approve, disapprove, or endorse this background paper. OTA assumes full responsibility for the background paper and the accuracy of its contents. iv P reject Staff John Andelin PRINCIPAL STAFF ADMINISTRATIVE STAFF Assistant Director OTA Science, Information, and Tara O’Toole Kathleen Beil Natural Resources Division Project Director Office Administrator Robert W. Niblock Joan Ham Kim Holmlund Oceans and Environment Program Principal Analyst Administrative Secretary Manager Sharon Knarvik CONTRIBUTING ANALYSTS Secretary Emilia Govan Senior Analyst CONTRIBUTOR Peter Johnson Florence Poilon Senior Associate Editor German Reyes Analyst v L ist of Abbreviations ACE-United States Army Corps of Engineers NIOSH—National Institute of Occupational Safety and Health DOE-United States Department of Energy NWC-nuclear weapons complex EH—-DOE Office of Environment, Safety and Health OSH-occupational safety and health EM—DOE Office of Environmental Restoration and Waste Management OSHA-Occupational Safety and Health Administration ERMC-Environmental Restoration Management Contractor PEL—permissible exposure limit GAO-United States General Accounting Office PPE-personal protective equipment HASP-Health and Safety Plan RCRA—Resources Conservation and Recovery Act HAZWOPER-Hazardous Waste Operations and RFI-Remedial Facility Investigation Emergency Response Standard RIFS-Remedial Investigation/Feasibility Study HWAC-Hazardous Waste Action Contractors USCG—United States Coast Guard LANL--Los Alamos National Laboratory WAS—Westinghouse Hanford Corporation M+O-Management and Operation Contractor vi c ontents 1 Overview and Findings, 1 Cleanup Worker Health and Safety Risks, 3 Consequences of Failure To Protect Weapons Complex Cleanup Workers, 5 Approach Used in This Study, 5 Superfund and RCRA Experience: Worker Protection Lessons, 6 Cleanup Worker Protection in the DOE Nuclear Weapons Complex Cleanup Program, 11 Summary of Findings, 13 Chapter 1 Endnotes, 14 2 Lessons From Superfund and RCRA, 19 Worker Protection Issues Within the Regulatory Process, 19 Problems With Contracting Practices, 24 Effectiveness of Cleanup Worker Health and Safety Regulations, 27 Chapter 2 Endnotes, 43 3 Cleanup Worker Protection at the DOE Nuclear Weapons Complex, 49 Management Commitment to Occupational Safety and Health Priorities, 50 Line Management Responsibility for Occupational Safety and Health, 52 Oversight of Occupational Safety and Health Practices, 56 Worker Protection Competes With Other Cleanup Priorities, 59 DOE Site Characterization Data, 60 Impacts of DOE Contracting Practices, 62 Application of HAZWOPER to DOE Cleanup, 64 Chapter 3 Endnotes, 73 Conclusion–Opportunities and Dangers, 79 vii Overview 1 and Findings T he Manhattan Project-the secret effort to invent and build the first atomic bomb-was accomplished in less than 4 years at a cost of approximately $2 billion.l The project was backed by the resources of America’s largest and most advanced corporations and engineering fins, and employed the talents of thousands of the world’s best scien- tists, technicians, and workers. A half century later, the institutional descendant of the Man- hattan Project, the U.S. Department of Energy (DOE), cofronts a new mission: cleaning up the environmental pollution left by cold war nuclear weapons production. This new mission pre- sents DOE with daunting technical and organizational chal- lenges as it strives to revise policies that led to widespread pollu- tion throughout the Nuclear Weapons Complex and to restore contaminated environments to safe conditions, It is estimated that cleanup of environmental contamination from nearly 50 years of nuclear weapons manufacture will cost more than $100 billion and require more than 30 years to com- DOE is plete. The cost and length of the cleanup are uncertain because the true extent of pollution and the means to remedy it areas yet responsible for only dimly understood, Some areas of the Weapons Complex may never be restored to pristine conditions.2 protecting those The tasks involved in the cleanup of environmental contami- nation are unfamiliar to DOE. Indeed, the entire field of hazard- who will do ous waste management and environmental remediation is in its the work of infancy. Methods of characterizing contaminate dsites are highly uncertain,3 and approaches to cleaning up are largely unproved cleaning up at both waste sites owned by private industry and government- owned facilities such as DOE reservations.4 5 It is clear, however, that cleaning up the 14 facilities in 13 States that make up the Nuclear Weapons Complex (NWC) will 1 2 Hazards Ahead: Managing Cleanup Worker Health and Safety at the Nuclear Weapons Complex demand the application of great talent and re- As DOE turns its attention toward its new mis- sources. The tens of thousands of people who sion of environmental restoration and waste will be engaged in cleanup of the Weapons Com- management, the Department assumes responsi- plex will join a large and growing industry devot- bility for providing safe and healthful working ed to the characterization and restoration of con- conditions for those who will do the work of taminated environments. It is estimated that over cleaning up. The vigor and success with which the next 5 years, DOE’s Office of Environmental DOE implements health and safety programs for Restoration and Waste Management could re- cleanup workers will be a signal of its willing- quire the services of as many as 25,000 scien- ness and ability to embrace the “new culture” tists, engineers, and technicians.6 spoken of by the Secretary of Energy—a culture Some workers will be involved in collecting that honors protection of the environment, environmental samples, studying groundwater health, and safety as a fundamental priority.8 If movement, and designing remediation projects. effectively conducted, the DOE cleanup could Others will be operating earth moving equip- serve as a model of how workers engaged in haz- ment; handling, inspecting, and repacking waste ardous waste and emergency response operations drums; or building dams, digging trenches, and should be protected from work-related illness constructing complex waste treatment facilities. and injury. Still others will be plant operators, maintenance Environmental restoration and waste manage- personnel, and technical experts at vitrification ment activities at DOE provide an opportunity to plants, wastewater treatment facilities, and incin- advance the state of the art of occupational health erators. Municipal firefighters, police, medical and safety programs for cleanup workers. DOE’s experts, and other emergency response personnel stated commitment to attain a new culture that may be called on in the event of fire, explosion, respects the environment, health, and safety; its or accidental release of toxic materials. search for new ways of incorporating effective The NWC cleanup will be one of the largest worker protection programs into contract agree- environmental remediation efforts ever, and very ments; and its intent to pursue cleanup in a re- likely the largest undertaken by the Federal Gov- sponsible and cost-effective manner-all place ernment at taxpayers’ expense. If conducted ef- DOE in a position to become a major force in ad- fectively, the DOE cleanup could serve as a vancing the programs and technologies needed to model of how workers engaged in hazardous adequately protect workers from safety hazards waste and emergency response operations should and from the adverse effects of exposure to toxic be protected from work-related illness and in- materials. jury. DOE’s past refusal to acknowledge its Achieving such a leadership position in occu- obligation to comply with environmental laws pational health and safety will require DOE to and regulations means that the Department is adopt policies and undertake actions now only in starting environmental characterization and re- their incipient stages. To apply management mediation activities more than a decade after the lessons gleaned from experience at non-Federal private sector began cleaning up Superfund and cleanup operations, DOE must first recognize the Resource Conservation and Recovery Act need for strong management commitment to the (RCRA) sites. During those years, much has occupational safety and health (OSH) of its been learned about how to protect the health and cleanup workers. Comprehensive, DOE-wide safety of cleanup workers; DOE could apply OSH policies, objectives, programs, and means these lessons to great advantage. of assessing progress must be developed. The co- operative efforts of line managers and health and Chapter l–Overview and Findings 3 safety professionals will be required along with input from experienced workers. Consultation and interaction with other government agencies and organizations with expertise in worker pro- tection issues will also be needed if DOE is to formulate a timely and effective approach to cleanup worker protection. The policies adopted then will have to be implemented and enforced. Finally, truly independent oversight of OSH poli- cies will be necessary at DOE facilities, with mechanisms developed to reward or penalize ad- herence to or violation of these policies. CLEANUP WORKER HEALTH AND SAFETY RISKS In addition to many of the safety hazards asso- ciated with conventional construction operations, such as manual lifting, operation of heavy ma- chinery, electrical hazards, exposure to extreme heat and cold, and confined space operations, workers involved in characterizing or remediat- ing toxic waste sites may encounter fire and ex- plosion hazards, as well as the health threats as- sociated with exposure to toxic chemicals and radiation.9 10 Stress-related illness can also af- flict cleanup workers because of the unusual de- Cleanup workers face safety hazards associated with traditional construction tasks as well as health risks mands and uncertainties associated with this work.11 Finally cleanup workers at DOE facili- from exposure to toxic chemicals and radionuclides. ties will confront-in addition to all of the usual radiation are in dispute.14-17 The long-term con- risks encountered in hazardous waste work— sequences of exposure to chronic, low dosages of other hazards, such as high-level radioactive toxic materials, radiation, or mixtures of these— waste and mixed waste, that are unique to the the types of exposures most likely to be encoun- Weapons Complex. tered by cleanup workers—remain largely unin- It is not known what specific health risks vestigated. 12 No prospective studies cleanup workers face. The construction trades, which include many have been done of health effects among workers workers engaged in environmental cleanup, are employed in the new industry of environmental among the most hazardous occupations in the remediation. It is highly uncertain what, if any, United States and have long been associated with specific biologic effects result from exposure to a high rate of worker injuries.18 19 An estimated toxic substances encountered during work with $8.9 billion is spent annually on costs related to hazardous waste. The health outcomes associat- construction accidents.20 Indirect costs, includ- ed with exposure to most of the chemicals in ing reduced productivity, schedule delays, and commercial use are poorly understood,13 and the damage to equipment or facilities, account for health consequences of exposure to low doses of most of this amount.
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