DEPARTMENT OF ENERGY
WASHINGTON, DC 20585


Mr. Don Finch May 16, 1997 Editor, FACTS Newsletter Box 566 Kenmore, NY 14217-0566 Dear Mr. Finch: This is in response to your letter dated April 29, 1997, regarding the Department of Energy cleanup activities at the Praxair site in Tonawanda, New York. The Department shares your concern for the safety of its workers and the general public. Safety has been, and will continue to be, the top priority for all of our activities in Tonawanda. The Formerly Utilized Sites Remedial Action Program maintains an extremely high standard for safety in the workplace. The Formerly Utilized Sites Remedial Action Program "zero accidents" philosophy has been very effective on all of our sites, as evidenced by the recent milestone of one million work hours without a lost-time accident. This impressive achievement was realized with rigorous adherence by all Formerly Utilized Sites Remedial Action Program workers and subcontractors to a safety culture where there is absolutely zero tolerance for any unsafe work practices. Enclosed is a detailed response to the specific points raised in your letter. I invite you to discuss any further safety questions that may arise with Mr. Pat Griffin, Bechtel's Site Manager located in Tonawanda, or contact the Department's Site Manager, Mr. Jim Kopotic, at 423-576-9441. Sincerely, /s/ James M. Owendoff James M. Owendoff Acting Principal Deputy Assistant Secretary for Environmental Management Enclosure
Detailed response to issues raised: 1) Incident involving carbon monoxide fumes Clearly, carbon monoxide has been the cause of numerous industrial and household fatalities. Therefore, incidents involving potentially fatal substances are extremely serious. On April 9, 1997, four decontamination workers were using a propane- powered scabbling machine to remove mastic from the floor of Area 4 (Praxair Building 14). Exhaust fumes from the machine were being vented outside of the building via two High Efficiency Particulate Air Filter units set up in series. All four workers were wearing air-purifying respirators. During the cleanup, a worker turned off one of the two High Efficiency Particulate Air Filter units, reducing the effectiveness of the air ventilation system. After a few minutes the workers noticed that fumes appeared to be building up and all four workers walked out of the containment area. Once outside, the workers were asked if they felt ill or if they needed medical attention. All four workers complained of dizziness and one complained of nausea. The workers were offered immediate medical attention or transport to the hospital and all declined. The symptoms were very short lived and within an hour all the workers were able to return to their normal work duties. Although the workers no longer exhibited adverse symptoms, as an added precaution, the subcontractor (IDM Environmental Corp.) arranged for two of the workers to have blood tests performed the following morning to measure carbon monoxide levels in the bloodstream. these tests showed that neither of the two workers had carbon monoxide levels above the normal range. The other two workers were not tested because they were not working adjacent to the propane- powered machine, and they appeared to be less affected by the fumes. As a consequence of this incident, a thorough safety-focused audit was conducted of the subcontractor's operations. This audit identified other potential safety deficiencies leading Bechtel to impose a one-week work suspension in order to allow time for IDM Environmental to address the audit findings and reindoctrinate the employees. Prior experience with this subcontractor indicated that it is a very safety-conscious organization, and the situation uncovered during the audit was inconsistent with prior experience. The subcontractor's management took the audit findings and the work suspension very seriously and sent the corporate safety and health officer to personally direct the worker reindoctrination efforts. Department of Energy personnel independently assessed IDM's safety program and concurred that appropriate corrective actions had been implemented.

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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

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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)

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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.

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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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