.. .- 21? .- -. . 14.. a? 9512-?- 95"cam- r' . . all: . - '2 $3331 ?HE-yd I if1?25! day: ?Us? {Ev-99321% 245?t?u .3- It .. ?pg-1? - v. . 3 by inf-?3 a- . .g Hi." 11" a . . July.?Tiri9?12 I Wi?eu?41arky?r-f I. yii?c?gfgy - w-r- . - 1' @355 pt Arrwa-ii'wq- :3 3?3 I. EXECUTIVE SUMMARY I.A. Background The Independent Technical Assessment of the Hanford Tank Farm Operations was commissioned by the Assistant Secretary for Environmental Restoration and Waste Management on November 1, 1991. The Independent Technical Assessment team conducted on-site interviews and inspections during the following periods: November 18 to 22, 1991; April 13 to 17; and April 27 to May 1,1992. Westinghouse Hanford Company is the management and operating contractor for the Department of Energy at the Hanford site. The Hanford Tank Farm Operations consists of 177 underground storage tanks containing 61 million gallons of high-level radioactive mixed wastes from the chemical reprocessing of nuclear fuel. The Tank Farm Operations also includes associated transfer lines, ancillary equipment, and instrumentation. I.B. Introduction The Independent Technical Assessment of the Hanford Tank Farm Operations builds upon the prior assessments of the Hanford Waste Vitrification System and the Hanford Site Tank Waste Disposal Strategy. The objective of this technical assessment was to determine whether an integrated and sound program exists to manage the tank-waste storage and tankfarm operations consistent with the Assistant Secretary for Environmental Restoration and Waste Management's guidance of overall risk minimization. The scope of this review includes the organization, management, operation, planning, facilities, and mitigation of the safety-concerns of the Hanford Tank Waste Remediation System. The assessments presented in the body of this report are based on the detailed observations discussed in the appendices. When the assessments use the term "Hanford" as an organizational body it means DOE-RL and Westinghouse Hanford Company as a minimum, and in many instances all of the stake holders for the Hanford site. I.C. General Assessment • The condition of the tank farms is poor and continues to deteriorate further because corrective maintenance is not keeping up with the equipment failure and the tank farm upgrade program is not being implemented fast enough. I-1 • Tank safety issues and the deteriorated state of the tank farms have been designated as the highest priority concerns within the DOE complex, yet the majority of the funds reprogrammed to address the tank safety issues have come from tank farm operations rather than the other programs at the Hanford site. • Westinghouse Corporation has not fully accomplished the primary objective of a managing and operating contractor: the implementation of business planning and methods in the operation of a government facility. I.D. Major Observations The tank-farm equipment and instrumentation are in poor condition and deteriorating. I.D.l. • The time required to repair the older equipment (e.g. compressors and blowers) in the tank farm often exceeds nine months. • About one third of the instrumentation is nonfunctional; the majority of the instrumentation is old, not designed for calibration, and producing output of indeterminate quality. • It is unlikely that leaks would be immediately detected in any single-shell tanks. • The lack of an accurate, reliable document infrastructure (for example, technical drawings, equipment specifications, safety equipment lists) prevents an understanding of the hardware and of the control systems. The tank farms continue to deteriorate due to a multiplicity of problems, many of which arise from institutional culture. I.D.2. • The multiple barriers to change and improvement in the tank farms appear to be primarily imposed by Hanford (USDOE, Westinghouse Hanford Company, unions, supporting contractors, and the long-term workforce). The constraints appear to be rooted in a culture of fiefdoms, crises management, rationalization of existing conditions, and justification of additional resources. Emphasis of the DOE-RL and WHC management teams should be on a change of culture. • While the Westinghouse Hanford Company needs to make considerable improvement in their business operation (efficient and optimum use of people and budget) a second element necessary for success in the Hanford operations is an improvement in the leadership provided by DOE-RL (clear guidance and prioritization, responsive approval cycles, integration of 1-2 ~- multiple contractors, coordination of approach to problem solving, and reprogramming of funds to solve emergencies). • Strict, conservative interpretation of the Department of Energy Orders, rather than thoughtful, graded application, has created artificial barriers to improving tank-farm conditions. • DOE line management has not provided coordinated guidance concerning the implementation of the many newly revised or issued Orders. • Integration of activities at Hanford has not occurred. The reprogramming of funds to cope with the unreviewed safety questions of the stored tank wastes has been entirely within the DOE-RLTank Farms Project Office rather than site-wide. The result is a delay in tank farm upgrades which is contrary to risk minimization. Emergency response capability for a tank breach is weak because of the poor condition of the tank farm equipment. I.D.3. • In the event of a leaking single shell tank, response options that require pumping from the leaking tank(s) could not be carried out expeditiously in most instances. Transfer lines, valves, and pumps are not readily available for emergency response. • The existing situation (inadequate drawings, out of service instrumentation, inadequate waste characterization, and inadequate tank vapor characterization) necessitates an over-reaction to incidents in order to ensure safety. I I II I I.D.4. The Operational Safety Requirements are not adequate to provide for the secure storage of the wastes, and there are instances of non-adherence to the Operational Specifications. • The Operational Safety Requirements and Operational Specifications are incomplete and out-of-date. • No corrective action has been taken on a double-shell tank that since 1985 has been below its Operational Specification limit for hydroxide concentration. • Tank sampling is so limited that in most cases it is unknown if the waste in a tank is within the Operational Specification limit. • The philosophy of waste tank stewardship at Hanford has historically been inadequate and although currently improving still suffers from the I-3 rationalization of existing conditions by a workforce conditioned by the old atttitude. 1.0.5. The Environmental, Safety, and Quality oversight from Westinghouse Hanford is compliance-based rather than performance-based; it has not been effective in identifying and reversing the years-long trend of continued tank farm deterioration. • The Westinghouse Hanford ES&Q organization functions as both an independent oversight body and a matrix support organization to tank farm work activities, thereby creating a conflict of responsibilities. The maintenance program is constrained by the following correctable conditions in the tank farms: 1.0.6. • Absence of creative solutions to solve or reduce the access restrictions and fresh-air breathing equipment requirements for those tank farms having radioactive contamination and the possible presence of hazardous gases; • Inaccurate drawings of the equipment and instrumentation; • Excessive review signoffs for job control packages; • Ineffective safety classification of equipment and lack of a master equipment list; • Inadequate bases for the preventive maintenance program; and • Difficulties in coordinating multiple support groups (e.g., safety, crafts, industrial hygiene, operations). • The observed level of activity at the tank farms is below that required to change the condition of the tank farm, and is inconsistent with the size of the work force or budget for operations and maintenance. I.0.7. The Tank Farm Operations does not have a current risk-assessment baseline. • Task prioritization is based on subjective or perceived risk reduction instead of formal safety I risk assessments. • This situation precludes optimum use of the budget and creates a potential for unnecessary exposure of personnel to chemical and radiation hazards. • Westinghouse Hanford is developing revised risk assessments, and has recently begun establishing the bases for interim operation. 1-4 I.D.S. The limited ability to sample and characterize the tank wastes has been an · impediment to many Hanford programs for years and is still a constraint to resolving tank safety issues, obtaining RCRA permits, and planning for the TWRS. • The current capability for high level waste analysis is still short of demand, but Westinghouse Hanford is now becoming proactive in managing the shortfall between sample analysis needs and the laboratory capability. • The expanded operation of the two Hanford analytical laboratories for radioactive sample analysis (Buildings 2225 and 325) is critical for the operation and the permitting of all of the Tank Waste Remediation System activities (tank-safety-concern mitigation, evaporator, Liquid Effluent Treatment Facility, grout, pretreatment, and vitrification). • Until very recently the analytical laboratories have not received the management attention and support commensurate with their importance to the program. The Westinghouse Hanford plans and concepts for the Tank Waste Remediation System are based on optimistic assumptions regarding the volume of waste to be treated, the schedule for upgrade or construction, and the operating availability of the unit processes. I.D.9. • The planning assumes that all of the units (retrieval, pretreatment, evaporator, Liquid Effluent Treatment Facility, grout, and vitrification) will operate in a continuous mode with high availability. Historically, this appears to be a poor assumption. • The projected need for new waste tanks is very dependent on factors having large uncertainties (waste type and volume to be added to the tank farm and on the efficiency and availability of the evaporator, Liquid Effluent Treatment Facility and the grout disposal). The projections assume optimistic values for these factors and the need for new tanks, a long leadtime procurement, may be underestimated. • Unless the tank farm upgrade program is expanded and accelerated, the high-visibility projects (cross-site transfer lines and new treatment/storage tanks) may be of limited use because the overall condition of the ancillary equipment is so poor and the diversion boxes, valve pits and intertank lines are not doubly-contained as required by current regulations, thereby restricting their use to "emergencies." • Westinghouse Hanford has prepared schedules they cannot meet using unrealistic assumptions and milestones provided by DOE. Apparently these plans arid schedules serve as the basis from which Westinghouse Hanford and the DOE line management develope a desired budget request. I-5 When the actual budget is significantly below the request levels there are no sound plans and schedules with which to actually operate. The ITR Team found this false planning to be one of the major reasons for worker frustration at the plant. The activities to understand some of the safety issues for the watch-list tanks are well founded while programs to address the other safety issues are still being formulated. I.D.lO. o The program to understand and develop mitigation plans for the tanks that are emitting flammable gases is well founded and proceeding on a realistic schedule. o The program to address the tanks believed to contain ferrocyanide compounds is not as far along as that of the flammable gases and is on a longer schedule. Mitigation planning is limited, pending the results of waste characterization. This program should be expanded and accelerated. o The tank safety issues of organic-nitrate compounds, high heat, criticality and toxic vapor emissions are currently receiving only minimal funding. Program managers are in place and programs are being defined. These programs should be expanded and accelerated. o The coordination of the operations and maintenance activities at the tank farms containing the watch list tanks needs improvement. The Conduct of Operations program should ensure that all operators assigned to these tank farms be familiar with the status of all equipment in these farms. Westinghouse Hanford Company has begun to assemble a technically competent and dedicated management team for the Tank Farm Operations. I.D.ll. o Westinghouse Hanford management has instituted several initiatives that are now improving the Tank Farm Operations. 0 The ITR team encountered many Westinghouse Hanford managers and staff who are working diligently to solve the problems of the Tank Waste Operations. I-6 III.A.2. The tank farms continue to deteriorate due to a multiplicity of problems. many of which arise from institutional culture [ 1.0.2 ]. The multiple barriers to change and improvement in the tank farms appear to be primarily imposed by Hanford (USDOE, Westinghouse Hanford Company, unions, supporting contractors, and the long-term workforce). The constraints appear to be rooted in a culture of fiefdoms, crises management, rationalization of existing conditions, and justification of additional resources. Emphasis of the DOE-RL and WHC management teams should be on a change of this culture. Westinghouse Corporation must provide the business methods typical of industry and DOE-RL must provide the leadership. Maximum application and strict interpretation of DOE orders, rather than thoughtful, graded application, has created artificial barriers to improving tankfarm conditions and resulted in an increase of the maintenance activities backlog. The safety classification of components is a primary example. For systems that have been interim-classified as safety class, the engineering organization has decreed that all parts of that system must be assigned the same classification (the procedure allows an option but engineering has not permitted exceptions), even if the part itself performs no safety function and its failure would not prevent the overall system from performing its safety function. The philosophy of piecemeal upgrade of systems to the interim-safety classification ignores the fact that in most cases the entire system can never be completely qualified. The extensive delays in trying to qualify individual components is creating a safety problem. The tank-farm maintenance operation needs an approved policy that allows repairs maintenance activities to use commercial-grade replacement parts (equivalent to those being replaced) rather than safety-grade components if failure of the commercial- grade component would not create a more serious safety problem than one caused by having the component out of service. Although the WHC-SD-WM-PLN-014 procedure permitted such repairs, an employee raised concern and because there was no approval for this practice from DOE, the WHC-SD-WM-PLN-028 procedure requiring safety-grade replacement parts was implemented. A second example of maximum application of a DOE Order is that the implementation plan for DOE Order 5480.19, Conduct of Operations, is based on full application even though the order permits a graded approach. Two reasons were given for not taking the graded approach: (1) WHC wanted to demonstrate through conduct of operations that it could run an exemplary facility, and (2) WHC did not believe DOE would approve a graded approach. WHC has recently instituted a graded approach to the analytical characterization of waste samples. DOE line management has not provided coordinated guidance concerning the implementation of the newly revised or issued orders. DOE-RL and DOEEM have not established guidelines for the format and content of the documentation of compliance (matrix) required by 5480.19 and the more general III-3 implementation plans for the new 5480 series orders required by Paragraph 8.d(6) of DOE Order 5480.18, "Environment, Safety, and Health program for Department of Energy Operations." DOE-RL does not have a structure, documented review and approval process for such implementation plans, including (1) assignment of responsibility (what can the Site Representative approve, what requires DOE-RL Manager approval, what requires specific levels of DOE Headquarters approval); (2) the approach for review and approval of minor and major changes to implementation plans (including those resulting from reprogramming of funds); (3) acceptance criteria; and (4) guidelines for the time allotted for the preparation and review of implementation plans for each new DOE 5480 series order that does not contain a specific, mandatory implementation of schedule. Team members who have had extensive experience in the commercial nuclear power industry commented that WHC does not know how to be a regulated party, and that DOE does not know how to be both a regulator and a regulated party, roles that are now required. Integration of activities at the Hanford site has not occurred. Although this is true in many aspects, the reprogramming of funds to cope with the unreviewed safety questions (USQs) of the stored tank wastes is the aspect with the most implications for risk minimization. The reprogramming of funds to deal with the USQs has been entirely within the DOE-RL Tank Farms Project Office rather than site-wide, resulting in a delay in tank farm upgrades, which is contrary to risk minimization. III.A.3 Emergency response capability for a tank breach is weak because of the poor condition of the tank farm equipment [ I.D.3 ]. The limitations and out-of-service condition of the instrumentation that is available to detect a leak in the tanks were discussed in Section III. A. I. In many cases, a single-shell tank (SST) could begin leaking without being immediately detected. Forty-four SSTs have not been stabilized (free liquid removed) and the tanks that have been stabilized still contain interstitial liquid that could leak. The ability to pump the remaining liquid out of a tank that begins to leak varies with the location of the tank farm. Although two submersibies, two jet transfer pumps, and a portable pump trailer are currently available to remove liquid from a tank in case of a leak, the limited availability of transfer lines is a problem. Not only would the singly-contained lines have to be tested before use but also the tank contents would have to be sampled before transfer to ensure compatibility with the host tank. Transfer from 200 West area to 200 East area (where most of the spare tank capacity resides) would be even more problematic. For tanks having no viable underground transfer line, an above-ground line would have to be fabricated. Currently, no SAR addresses this possibility and the SAR revision to support this option is 18 months from scheduled completion. The piping for the above- ground option will not be fabricated until the SAR revision is prepared and approved. A report was published in March, 1991, detailing how the transfer from each tank would be accomplished. Operations personnel III-4 interviewed thought that the plan was too optimistic and that it might take up to six months to remove the free liquid from a leaking SST. The existing documentation of the tank-farm support facilities, ancillary equipment and instrumentation is recognized to be deficient, and WHC has programs to correct the deficiencies. Presently, it is conceivable that, in an emergency, proper actions would rely solely on the knowledge of one or two operators rather than on proper. documentation of the facilities. The upgrading efforts for safety-related instrumentation and support facilities should continue to be high priority. During January, 1992, workers in the tank farm reported an exposure to noxious gases. The WHC and DOE response was immediate and extensive. The result was a significant disruption of work that lasted several weeks because the existing knowledge of the kinds of gases generated by the tanks was insufficient to warrant a graded approach to the occurrence. The disruption was prolonged by lack of installed instrumentation to characterize the event in real time and by a delay in obtaining the instrumentation needed for a sufficiently sophisticated post-incident investigation. The exposure was eventually traced to a battery in a mobile unit upwind of the workers that had leaked because of overcharging. The substandard condition of the tank-farm infrastructure, including design basis documentation and instrumentation, will result in continued over-reaction to occurrences to ensure worker safety. III.A.4 The Operational Safety Requirements are not adequate to provide for the safe storage of the wastes. and there are instances of non-adherence to the Operational Specifications [ I.D.4 ]. The Operational Safety Requirements and Operational Specifications are incomplete and out-of-date. The Operational Specification Documents (OSDs) contain specifications limiting the concentration of chemical species in the waste. The material tests from which these specifications were developed included only base metal, not test coupons with welds, the most likely point of corrosion. The synthetic solutions used for the tests did not include all of the anions potentially found in the waste streams. In particular, it did not include chloride, a relatively corrosive anion. The issue of chloride content has important implications for the long term durability of the DSTs. This is because the stabilization program for the SSTs is suspected of concentrating chloride in the supernate that is stored in the DSTs. The OSDs do not require a routine sampling program to ensure that the tanks are within compositional requirements. The limited sampling that has been performed has shown several tanks with chloride levels significantly above the limits established for the waste tanks at the Savannah River Plant (SRP). The limited sampling has also shown that the DSTs 241-AN-102 and 241-AN-107 are III-5 consuming hydroxide. Tank 241-AN-1 07 has been below the required hydroxide level for over seven years. The chemical condition of this tank is adequate to initiate a corrosion sequence. The philosophy of waste tank stewardship at Hanford has historically been inadequate and although currently improving still suffers from the rationalization of existing conditions by a workforce conditioned by the old attitudes. The EnvironmentaL Safety. Health and Quality oversight from III.A.5 Westinghouse Hanford is compliance based rather than performance based; it has not been effective in identifying and reversing the years long trend of continued tank farm deterioration [ I.D.5]. WHC has a very large Environmental, Safety, Health and Quality (ESH&Q) organization, including many on site representatives. A common perception prevails among Tank Farm management that the WHC ESH&Q groups are compliance- (or paper-) oriented rather than performance based, and this view was supported by the observations made by the ITR Team. One of the primary roles of the QA function with the ESH&Q organization should be the identification of major problems to the president of WHC. Although aware of the increasing percentage of out-of-service equipment in the tank farm, lower level WHC ESH&Q managers had not identified this issue as a source of increased operational risk to the senior management. After the deteriorating condition of the tank farm was brought to their attention by the ITR Team, ESH&Q senior management took aggressive action to remove a major hurdle (safety classification of equipment) that was delaying work-package preparation and repair parts procurement. The ESH&Q organization is attempting to be both an independent oversight body and a matrix support organization to tank farm work activities. The matrix support functions provided by ESH&Q include health physicists, industrial hygienists, QA review of JCS work packages, QA review of procurement requests, and inspections of maintenance repairs and system performance testing. These activities compromise the primary purpose of an independent oversight group. The maintenance program is constrained by the following III.A.6 correctable conditions in the tank farms [ I.D.6]. The low work productivity in the tank farms is a major problem. During tank farm inspections and while driving past the tank farms, the ITR noticed that almost no activity was in progress. The observed level of activity is below that required to change the condition of the tank farm, and is not consistent with the size of the work force or budget for operations and maintenance. III-6 Poor working conditions in the tank farms are one source of low productivity. Physical conditions include radioactive contamination, low radiation fields, and potential exposure to incompletely characterized noxious fumes from the tank vents. All of these hazards can be mitigated and WHC is to be commended for carrying out projects to reduce the contamination and radiation fields in some of the tank farms. Creative solutions are needed to mitigate the exposure to radioactivity and the noxious vapor problem. These solutions might include portable work rooms with controlled ventilation, prefabricated modular replacements for the current tank ventilation systems, higher ventilation discharge stacks for existing ventilation systems, localized shielding curtains, fixed or portable lighting to allow night work, and job site telephones. In addition to the plant related or facility related reasons for low work productivity in the tank farms, many institutional problems exist, some of which were discussed in Sections III.A.l and III.A.2. Other barriers include the large team of people from different organizations required to carry out any work in the tank farm. If a member does not appear or decides to leave, the work activity will close down. No single foreman has jurisdiction over all organizations and crafts present. If the work package doesn't agree with the as-found conditions, the job activity must be stopped and the work package put back into the system for revision. III.A.7 The Tank Farm Operations does not have a current risk-assessment baseline [ I.D.7]. Current TWRS prioritization and planning is not based on formal safetyrisk assessments, which appears to be true for the Hanford site as a whole. Whether resources are applied to the most important work is impossible to assess. In the past WHC's local reprioritization of work in response to changing requirements (self-imposed and external) was often started without the knowledge of DOE-RL, thus placing DOE in the position of assuming unknown .levels of risk. The ITR team is aware that DOE-RL is making progress in working closely with WHC as work needs to be redirected and rescheduled. Also WHC is now addressing the lack of a formal risk-assessment baseline with an SAR upgrade program and an establishment of an interim safety envelope. Approximately 17 obsolete SARs cover the tank farms. WHC has many activities underway that will eventually lead to risk assessments for the tank farms, to revised OSRs, to revised essential and support drawing, to safety equipment classifications, and to new SARs. All these activities are interdependent and the extended schedule for the drawing upgrades will delay the entire design basis documentation upgrade program. III-7 WHC has begun a program to address the bases for interim operation until formal documentation is in place. The interim effort is called the Tank Farm Safety Documentation program. The purposes of the program are to establish a defensible Interim Safety Envelope for normal and routine operations, and to establish a current safety analysis that meets emerging requirements and sets a working Operating Safety Envelope. The program includes a multi phase Safety Equipment List development strategy. An interim OSR for DSTs is being developed and transmittal to DOE-RL is planned for June 30, 1992. Implementation will commence as soon as DOE-RL gives approval to the OSR. A Safety Equipment List for DSTs is to be prepared this year in conjunction with the DST Interim OSR, both of which will be incorporated into the SAR during 1993 and 1994. The OSRs for SSTs and the Aging Waste Facility have not yet been started, but lists of OSR topics are to be generated by September 30, 1992. Interim OSRs are to be drafted and reviewed in FY 93. III.A.8 The limited ability to sample and characterize the tank wastes has been an impediment to many Hanford programs for years and is still a constraint to resolving tank safety issues, obtain RCRA permits, and planning for the TWRS [ 1.0.8]. Until recently Hanford has had very limited capability to sample the waste tanks and analyze the samples, particularly anything but the top liquid level. The limited sampling capability has created uncertainties in all of the tank waste management and remediation programs, including normal operations, tank safety, Hanford Waste Vitrification Plant, grout, and pretreatment. The effect of these uncertainties cannot be overemphasized, and it is likely that they have translated into years of schedule delay and inefficient program activities. The ITR Team sought to determine whether the planning for sampling and analysis is currently realistic and consistent with programmatic risk minimization. The projection of analytical need and analytical capability is a very complex issue with many variables. The following assessment attempts to explain the major issues. WHC recently released the Integrated Sampling and Analysis Plan, For Samples Measuring> 10 mrem/hour, WHC -EP-0533, March, 1992. The integration of the sampling needs is a step in the right direction because it attempts to quantify the demands on the laboratory facilities. However, the emphasis remains on meeting the demands of the current project schedules and does not account for new needs that might be identified (such as decontamination and decommissioning of the chemical process canyons and the Hanford production reactors), nor does it allow for accelerating the analysis to enable the acquisition of needed information earlier than called for on the basis of current planning. (It should be noted that the analytical schedules developed for projects were based not on when the information would be needed, but rather on when it could be obtained, given the constraints of inadequate analytical laboratory capacity.) III-8 WHC has recently become proactive in managing the analytical shortfall, sending 99 percent of all environmental protocol samples with activity of less than 10 mrem/hour to off-site laboratories. Sampling and analytical requests are being reviewed to see if needs can be combined or if the data requirements can be reduced and still meet the purpose of the sample. Although the addition of another sampling truck has removed sampling as the constraining function, many opportunities for improvement remain. For example, there is no trained backup for a chemist who is running some of the more sophisticated analytical equipment; and data package preparation and handling has not yet been automated. Current projections show a shortfall until approximately 1998 when capability is projected to exceed demand. The sampling and analytical projections are based on many assumptions. One of the most important assumptions is that the laboratories upgrade programs will continue on schedule. The 325 laboratory is under the control of Battelle Pacific Northwest Laboratory (PNL) and it must receive adequate operating funds in addition to the facility and equipment upgrades planned. In carrying out the analytical program, PNL has often been underfunded. In May, after the ITR Team made its site visits, the analytical laboratories had to severely constrain operations because they could not transfer their wastes to the tank farm. The ban on waste transfer was due to criticality concerns in the tank farms, but the details show this to be another instance of throwing up an artificial barrier and not seeking immediate relief. The effects of a shortfall in sampling and analysis are felt by the regulatory issues. The Regulatory subpanel of the ITR found that lack of adequate data on the composition of waste in the tanks is delaying the completion of RCRA Part B permits for the tank farms and grout facility; and characterization data is needed to satisfy Tri-party milestones M-01, M-03, M-10, and M-20. At the present time, the capacity of the analytical laboratory to test radioactive and mixed wastes having radiation greater than 10 mrem/hr is not sufficient at Hanford to meet the demands of the multiple programs. As a result, operations permits for the tank farms or for the grout facility cannot be issued by WDOE because WDOE does not have adequate data to establish permit conditions for operation of the facilities. WHC management needs to recognize sampling and analysis as a critical path issue. If the time lines are optimistic (or unrealistic), improper prioritization of resources can result. If a milestone cannot be realistically met, planning should address that fact and develop an alternate plan. III-9 Changes of temperatures or temperature profiles within a tank could signal other problems. Problems in temperature monitoring include the following: (1) present thermocouples are generally about 40 years old and in poor physical condition; (2) cannot be certified or calibrated; and (3) at least one-third of all thermocouples are not functioning or cannot be monitored at any given time (see Section D.S.A.). Installation of new thermocouple trees should be expedited for tanks having a potential for temperature excursions. Vapor Inhalation Incidents Problems involving noxious gases released from various tanks have been met; sometimes personnel have sustained lost-time injuries. The gases have not been completely identified and monitoring systems are absent. A study conducted in 1989 identified 51 incidents of worker injury due to vapor inhalation that had occurred inC, BY and TX Tank Farms from 1957 to 1989. Injuries varied from minor problems requiring only first aid to more serious occurrences requiring hospitalization. Apparently several tanks have been identified as frequent sources of problems. For example, Tank 103-C emits organic vapors at a concentration which routinely disables the HEPA filters on its ventilation system. Filters on this tank typically have to be replaced at a rate of seven times per year. This rate is significantly greater than that for any other tank. Even with a large store of analytical and empirical data on vapor releases from the tanks, WHC continues to treat each instance of vapor inhalation injury as an isolated incident and has not attempted to develop a comprehensive mitigation and response plan to resolve this problem. Because of the potential problems with emitted gases, workers use air suits, greatly limiting the work that can be accomplished by the staff; this will become a very major problem in the summer as temperatures increase. It is likely that personnel will be limited to between 15 and 30 minutes of effort in an air suit unless they carry a cold pack. D.4.D. D.4.E. Limited Transfer Capabilities Two submersible pumps and two jet-transfer pumps are currently available to remove liquid from a tank in case of a leak. Three years have elapsed since HTFO has had to pump a leaking tank. Since the previous average was one leak per year, the subpanel feels that a leaker is overdue. Most of the transfer lines are singly contained; they are not to be used in normal operations but can be used in an emergency to transfer tank contents. The lines are tested before use at 200 psi (4 times the required transfer pressure) for leaks. A material balance is performed on the leaker and on receiver tanks during a transfer, and alarm monitors are positioned along the transfer line to detect leaks. Before the transfer, two samples are removed from the tank: one for determining the contents and assessing which receiver tank can be used without mixing incompatible waste types, and the other for RCRA records. WHC expects the leak rates to be low and feels that a delay of a few days for response is of small technical significance. Forty-four of the SSTs are not interim stabilized and would have to transfer significant volumes of liquid in case of a leak. One of D-7