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 Foreword 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 requirec 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 workshop 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. Rocky Flats Plant James Melius Thomas Bailey U.S. Department of Energy Division of Occupational Health and Environmental Kleinfelder, Inc. Denny Dobbins Epidemiology Worker Education and Training New York State Deparatment of Martin S. Mathamel Branch Health Health and Safety Division Occupational Health and Technical CH2M-Hill Services John Moran Safety and Health Laborers’ Carolyn M. Kiely National Institute of Environmental Hazardous Waste Action Health Sciences National Health and Safety Fund Contractors 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 Preject 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 List of Abbreviations ACE-United States Army Corps of Engineers NIOSH—National Institute of Occupational Safety and DOE-United States Department of Energy Health EH—-DOE Office of Environment, Safety and Health NWC-nuclear weapons complex EM—DOE Office of Environmental Restoration and OSH-occupational safety and health Waste Management OSHA-Occupational Safety and Health ERMC-Environmental Restoration Management Administration 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 contents 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 and Findings 1 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 largestT 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- plete. The cost and length of the cleanup are uncertain because DOE is the true extent of pollution and the means to remedy it areas yet only dimly understood, Some areas of the Weapons Complex responsible for may never be restored to pristine conditions.2 The tasks involved in the cleanup of environmental contami- protecting those nation are unfamiliar to DOE. Indeed, the entire field of hazard- who will do ous waste management and environmental remediation is in its infancy. Methods of characterizing contaminated sites are highly the work of uncertain, 3 and approaches to cleaning up are largely unproved at both waste sites owned by private industry and government- cleaning up owned facilities such as DOE reservations.4 5 It is clear,