?a LIL $30? 1?1 If?; DEPARTMENT OF HEALTH AND HUMAN SERVICES Public Health Service National Institute for Occupational Safety and Health Robert A. Taft Laboratories 4676 Columbia Parkway Cincinnati OH 45226-1998 December 21, 2015 HHB 2013-0220 Mr. Barry Ko . Occupational Safety and Health Manager Fluor-B&W Portsmouth PO Box 548 - Piketon, Ohio 45661 Attn: Barry K0 7C) Dear Mr. K0, This letter is in response to aseptember 2013 health hazard evaluation (HHE) request to the National Institute for Occupational Safety and Health from management and union representatives at Fluor?B&W Portsmouth. The request concerned dismantling and decommissioning of uranium enrichment process equipment (referred to as ?out and cap?) at the former'Portsmouth Gaseous Diffusion Plant Building in Piketon, Ohio. Concerns listed on the request included employee exposures to radionuclides, hydrogen ?uoride, volatile organic compounds, asbestos, and heavy metals such as nickel, arsenic, and beryllium; After discussions with management and union representatives, all parties agreed that we should focus our evaluation on exposure and health issues possibly related to hydrogen ?uoride, heavy metals, and chlorine. Health concerns included rashes and skin burning, and and throat irritation. Additional concerns involved the occasional presence of a green or yellow odorless gas and unidenti?ed odors in and around the building. This letter summarizes our evaluation and provides our ?ndings and recommendations. Site Visit ,On December 10?1 1, 2013, we met with employer and union representatives at the facility to discuss-the HI-IE request. Our objective was to. review the worker health protection program as it relates to industrial hygiene monitoring and medical surveillance. We discussed work processes, practices, and workplace conditions, and spoke With employees. We attended brie?ngs about historical 'and'current site Operations and activities, including information about historical uranium'enrichment operations and converter cell treatments used to recover uranium. Additional information was provided regarding procedures used to clean and purge residual contaminants within processing equipment when uranium enrichment ceased. We were briefed on current cutland cap work and associated job-hazard analysis procedures used prior to beginning any work activity. A site-speci?c job Safety pocket guide provided by the company - contained information on health and safety prOCedures, personal'protective equipment, and safety measures related to certain jobs [Fluor-B&W Portsmouth 2013]. Finally, we discussed the results Page 2 Mr. Barry K0 of recent industrial hygiene air sampling and procedures for implementing the Department of Energy?s Integrated Safety Management System. We met separately with union and management representatives on the second day of our visit to learn more about their speol?c concerns. We held 16 con?dential medical interviews with employees; our industrial hygienists Spoke separately with these employees to further address work practices and exposure concerns. These interviews were with employees who 1) had requested to speak with us, 2) we randomly selected from a job roster, or 3) were identi?ed by the union as an informational resource because of their employment at the facility or ?ling of workplace event report's. During our visit,-management gave us and all Opening conference participants a binder with information abo?t historical plant operations, current work practices, industrial hygiene sampling methods,_some sampling results, training programs, and pictures of cut and cap operations. We reviewed these pictures as a substitute for a walk-through tour of the actual work area. Entering the work area required extensive radiological training and personal protective equipment, which was not feasible during our visit. - In December 2013, we sent managers and union representatives a letter that summarized our observations and ?ndings from the site visit. In 2014, we held separate and joint teleconferences with union representatives and managers, as well as' a call with a chemist hired by the union who had prior experience at the facility. In these calls we discussed ongoing Operations, status of employee concerns, and steps taken by managers and the union to investigate ongoing issues. In September 2014 we held a ?nal conference call with all parties to summarize our ?ndings and recommendations,'which are highlighted below. Document Review/Industrial Hygiene Data Discussion As part of our evaluation we reviewed documents that addressed the following t0pics: a. the gaseous diffusion prooess I b. employee training, work practices, and equipment?for removing and decommissioning process equipment 0. potential eXposure hazards (mostly radioactivity, metals, hydrogen ?uoride, and chlorine) and. exposure assessment methods - . . d. examples of industrial hygiene sampling date ?om 2011?2013" used to assess?potential hazards and exposure - I . . e. respiratory protection program and other personal protective equipment-used by employees Page 3 Mr. Barry K0 Industrial hygiene sampling strategies and methods were selected on the basis of a job hazard analysis that involved anticipated and previously recognized hazards associated with speci?c work tasks. Samples were collected each day to determine the magnitude of the hazard(s) during different tasks. However, the maj o'rity of samples collected were of short duration, and were collected using direct reading gas and vapor detector tubes. On occasion, a small number of partial-shift area air samples were also collected using portable sampling pumps. For example, we found the instantaneous air sampling results for hydrogen ?uoride ranged ?om <02 84 parts per million. The NIOSH ceiling limit for hydrogen ?uoride (a value that should never be exceeded) is 6 parts per million 2010]. On the basis of these data, the ceiling limit for this compound was exceeded on multiple occasions. However, it should be'noted that there were no personal breathing zone air samples collected. Also, the lack of information linking a speci?c task(s) to these samples makes it dif?cult to relate exposure to such a task(s). We noticed that only a few metals were selected for analysis in air samples instead of doing a full elemental scan using NIOSH Method 7300 2015]. The industrial hygiene department manager reported that full scans were performed on air samples at the beginning of the cut and cap operation and the most prevalent metals were subsequently selected for routine analysis. Furthermore, we noticed no sampling plan for nitrogen dioxide, a contaminant that could be generated during'thermal cutting of metal pipes, compressors, and converters. We later learned that the identi?cation of a possible thermal decomposition product such as nitrogen- dioxide was overlooked during the job hazard analysis conducted by the industrial hygiene department. Alter our discussion about potential generation of- nitrogen dioxide during thermal cutting, the company indicated it would purchase a direct-reading, monitor to check for nitrogen dioxide at the beginning of each thermal cut-In mid-December 2013, management and union representatives informed us that a ?stop work order? had been instituted due to the detection of nitrogen dioxide. Management instituted plans to use full facepiece supplied air respirators in accordance with NIOSH recommendations 2010] for all cutting activities until the use of local-exhaust ventilation could be evaluated. During a June 2014 call, management reported that supplied air was still used during hot cutting procedures as levels of nitrogen dioxide up to 5 parts per million had been measured. ?Medical and Industrial Hygiene Interviews During our interviews, we asked 16 employees about their. workplace exposures, potential health concerns, and views=regarding training and communication between employees, management, and the union. A majority of workers (10 of 16) expressed concerns about poorcommunication between management and employees and concerns about retaliation for reporting safety problems. Concerns included having inadequate information about chemical(s) used, chemical exposures, and potential health effects. A few employees stated they were not given copies of Page 4 Mr. Barry K0 their medical test results or summary industrial hygiene sampling results. Management stated that results of personal medical tests are provided to employees as required by the Department of Energy 10 CFR Part 851 Worker Safety and Health Program. Additionally, management stated that industrial hygiene sampling results are available upon employee request and summaries of results were provided to employees during periodic safety meetings. Five employees reported rashes that they felt were work?related; not all employees had reported their rashes to management. Two of these employees reported nickel allergy prior to working at the facility; nickel is a component of the lining of some of the process equipment. Several employees expressed concern thatthey felt rushed to complete job tasks and that some managers placed production goals ahead of safety. Employees believed these problems have led to near misses and accidents. Finally, several employees expressed concern about the out-sourcing of laundry and respirator cleaning services, and stated personal protective equipment was often returned dirty or appeared contaminated. We reviewed medical records for four employees who reported health concerns they felt were associated with their work in the building. Employees reported localized and generalized rashes that improved when not at work. Onset of rash ranged from an acute single episode to a chronic recurring rash over a number of years. A de?nitive diagnosis was not reported in employee medical records. We determined that making a de?nitive diagnosis in this workplace is dif?cult due to the large number of potential exposures and the inability to do skin patch testing, - for these exposures. Two employees who reported reSpiratory irritation and shortness of breath I received chest x?rays and pulmonary function tests; results were reported as within normal'limits. These employees reported their occurred after? one. of the odor events investigated by the Unidenti?ed Odor Investigation Team. In September 2014, you gave us a cepy of a ?nal report prepared by the X-326 Unidenti?ed Odor Investigation Team. This team was made up of representatives from management, operations, engineering, X7326 cut and cap employees, industrial hygiene, occupational -medicine,.and the union. This report summarized the investigation of 13 separate incidents of odors in the X-326 building from July 2013 to June 2014. Some incidents reported the detection of odors by employees while others did'not. Additionally, acute health effects such as and reSpiratoryirritation and headache were reported during some incidents but not in others. While this team did not ?nd the source of these odors, the approach used by the team and the plan to communicate team investigation activities to the workforce seem appropriate. A potential limitation of our evaluation is that we interviewed a small percentage of the approximately 200 workers'involved in thecut and cap operation; however, the purpose of our interviews was to get a general sense of concerns. We did review the results of a June 2013 Page 5 Mr. Barry K0 Safety Barometer Survey completed by 896 employees at the Piketon site where similar concerns were reported. We encouraged management and union representatives to use these survey results to address employee perceptions and concerns. Recommendations The following recommendations are offered. Most of these were discussed during cur Onsite evaluation, in subsequent conference calls, or in our follow-up site visit letter. Some additional recommendations are made following ourreview of interview results and written. documents. 0 Use the multidisciplinary unidenti?ed odor investigation team approach to evaluate any new workplace safety and health concerns. . 0 Improve communication between employees, supervisors, management, and the union. In consultation with the union, hiring an external, third-party consultant may be useful to explore communication and retaliation concerns expressed by some employees. 0 Review training materials and procedures to ensure that technical aSpects of how to perform job duties as well as potential hazards and acute and long?term health effects are discussed with new employees. Provide periodic refresher training to employees. The occUpational- medicine consultant who implements the medical surveillance program for employees is a good resource for health-related information. - 0 Perform comprehensive job hazard analyses, including review of historical information, that consider all potential hazards associated with processes and work practices nitrogen dioxide formation during thermal cutting). 0 Increase the number of personal?air samples (short-term and full shift) for elements (full scan), chlorine, hydrogen ?uoride, and nitrogen dioxide. Fully document work tasks, sampling times, and sampling methodology for all samples. This information should be reviewed periodically to help identify tasks that substantially contribute to exposure and ensure that current controls are adequate. - - Use local exhaust ventilation equipped with appropriate ?ltration media (particulate, acid gases, nitrogen dioxide) as close as possible to the plume created by thermal cutting. In October 2015?, we requested that you provide NIOSH with a brief summary of the steps taken thus fa'rto address recommendations made at the end of our site visit and on subsequent teleconferences. The letter you sent to us dated December 03, 2015 is attached. To summarize, you reported an increase in worker training related to historical operations of the X326 building and also brie?ngs about industrial hygiene and radiological air sampling results. Additionally, you noted an increase in the number of persOnal samples for some of the substances identi?ed as potential hazards. Finally, you reported that your September 2015 National Safety Council survey results showed improved employee satisfaction with worker safety and health programs. Page 6 Mr. Barry Ko .We encourage you to continue to work with union health and safety personnel and employees to address issues as they arise during the continued remediation of the X-326 building and the entire Piketon facility. This letter serves as a ?nal report and closes this HHE request. We encourage you to share this letter with your employees. If you have questions, please contact Dr. John Gibbins at 513-841- 4585, Dr. Mark Methner at 513-841?4325, or Dr. Steven Ahrenholz at 513-841?4471. Sincerely yours, Digitally slgned by John D. -55 J0 . ON: Government. -. ou=People. G'bb' "5 John D. Gibbins, DVM, MPH Medical Section Team Leader Captain, Public Health Service - Digitally signed byMark Methner-Ss Mark . ?n=Mark Methner-SS, oo.1.1=1ooaa43 I Date: 201531211 09:33:00 -05'00' Mark M. Methner, CIH Senior Industrial Hygienist Captain, US. Public Health Service Digllally signed by Steven H. - DH: 0-05. 0-05. Government. CID-HHS. 3 ouPl Qua-mimic?? 13011 1001235010. A 0 H. Ahmnnol'z 15 Date: 2015.12.21 11:12:44 Steven H. Ahrenholz, MS, CIH Senior Industrial Hygienist Hazard Evaluations and Technical Assistance Branch Division of Surveillance, Hazard Evaluations and Field Studies attachment 1: Communication dated December 03, 2015 cc: Mr. Herman Potter United Steelworkers Local 1?6 89 Safety Representative P.O. Box 467 Piketon, Ohio 45661 Page 7 Mr. Barry K0 References Fluor?B&W Portsmouth [2013]. PORTS Safety Works: Employee Safety Pocket Guide. DOE PORTS Project. NIOSH [2010]. NIOSH pocket guide to chemical hazards. Cincinnati, OH: US. Department of Health and Human Services, Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health, DHHS (NIOSH) Publication No. 2010-1680. Date accessed: December 2015. NIOSH [2015]. NIOSH manual of analytical methods 4th ed. Schlecht PC, O?Connor PF, eds. Cincinnati, OH: US. Department of Health and Human Services, Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health, DHHS (N IO SH) Publication 94-113 (August 1994); 1st Supplement Publication 96-135; 2nd Supplement Publication 98?1 19; 3rd Supplement 2003-154. docs/2003-154/1. Date accessed: December 2015. Page 8 Mr. Barry K0 P4ngiszm-mrh- . I .Hugbe?WKT'Pbi??mauthLG .. fall-154179 . '=Pik?i?n; chine-456.53- .Qgcember 3d 2m AGVPM Public: . occupational safety and Health 13090 Tusculumme; MB 81.10: sGi?thti. amaze-1:998- 1ifsu?je?t?: Portsmouthrs "can'tinuinggactivii'?e? Taker'i {O'Minlmize Pq?t'?'nti'al i'n .Uhite?dgsitat'iafs E?quyiiportsmuuth- Site i-B?ar-Br. Gibbih5, you reque'sfqd,- here is additional summary information" cqveriqgrsome key action's? FBP has taken-to miinimiz'eaworkers? Ipotent'iai for chamica! exposures work:- - Go .eaqqaaigitiemm me =As= i-Wbrk?r Program,_ we . a) iaenti?ca'tion well eXchfedL.? In. ?E'Qditimi. ES part Of?th? hazard analysis? iaenii?ed and-implemented . . . . #1139,- as?arf?iqfi??si HealthP-fog'ram; FBjP's?j NU?GIE?g?r'thpili? empower raise EBB-worker, quali?catign and-Mining .pgogra'm ensures: knawledgei ?rev?nmx?osurg?. r-rhe .. ER-trgining, con?ned -- {a b?t?g?ti??itr?ining. ThaX?Q??jQr?gj?c? ??sia'ls'ofm? 1?1 1'01 ge??jpi?f?b?fs-f "siwglgaliaifsa?ipti?gire? Its; ?i??Y-bfh?wmarS?f??iisqme??s? f, 'af?tyipie-rsotrzi??l rate-amt . .perfumed-Fan?lth?ifftezams; ?si Egr-j?my; .. . . .. .. 51-41-2011; Labiale Elia: ll?u'?f??ivenfija?; 35:" gsg?-arhu?h?lyit?; {:8th ??bnde;andaare??edi in r?si?i??tor?f I. I - . dqqsacemsurga Page 9 Mr. Barry K0 Dr. John D, _Gj_bbins.. FBP-1 5-1179 Deqe'm ber 2 7). We closelymonitbrithese-hazards input Wo?plaGB-I . . a) ?E??nsivejp?rsqnal-air sampling .asgwell as general gjatea?airsam'pling'fqr .ch?ergjj?al' h'afi?rdS'i'h'ajs been" peifbtm'e?d during X1326: activiti?sgaespeciially during. 'th cutting acti?ities; 'or personal'sammes and area Sampies since-201,2 lifsTe'd below. P?f?g?al'Sa'm'ples of Sam pies Total .fo?s'ampl?sf?l'aka?n mum-mum 215 6.3.8 993 ?ts'QEn'ic: 2'15 713' 9,25" 2114' 5.222 1126. gadr?ium 215' "52.9 894- 2.15 3:12; 9'29 Fluprides': 1:08 .542?- 55:35 Iran, 215' 721?} 9,29 Leg-ad - 12:15 63:7 902 215 7.04. .9319 5,87 Nick?i. 2.15 7.95 1920. 'Tungsten, 231.5, 226 . 4.4.1. .Zihtc 215 7'10 '925 b) 1n additijcsm ?XteHs'ive sampling for radiologicai hazards has 315:0. i'b?enpe?me?d Sam?2912:. river-572900 a'i'r' hazards hawmenperfocme'd'ain'xagza task: work; airisampling Emits; gquiedwhhioassay sampling: .resuttmave :s?ho'win nepavrtablg .of?ou'r- work; [??dditiom W'e' h'afve'gif?uj?hiq?d'hslinw in-dur-Workemsafety Health Pm?gfam-g?d ?e?t'ed "thial?'QNSG' $511110": '19. ma?urgd?rea emmwerinenr clo?tifb Shagldquu questions-with twai?t' a - J'rle?iar LLB- awakens.- ?m-Ta?ltz?g?? Ea? Barr-y: K63. EBP I