| WIPP Report - DOE VPP Onsite Review Westinghouse Waste Isolation Pilot Plant: Report from the DOE Voluntary Protection Program Onsite Review August 29 through September 2, 1994 |
U.S. Department of Energy
Office of Safety and Quality Assurance
Office of Occupational Safety
Technical Support Division
Washington, D.C. 20585
September 19, 1994
Foreword
--------
The Department of Energy (DOE) recognizes that true excellence can be
encouraged and guided but not standardized. For this reason, on January 26,
1994, the Department initiated the DOE Voluntary Protection Program
(DOE-VPP) to encourage and recognize excellence in occupational safety and
health protection. This program closely parallels the Occupational Safety
and Health Administration s (OSHA) Voluntary Protection Programs
(VPP). Since their creation by OSHA in 1982, the VPP programs have
demonstrated that cooperative action among government, industry, and labor
can achieve excellence in worker health and safety.
DOE-VPP outlines areas where DOE contractors and subcontractors can
surpass mere compliance with DOE Orders and OSHA standards. The program
encourages the creative stretch for excellence through systematic
approaches involving everyone in the contractor or subcontractor workforce
at DOE sites. DOE-VPP emphasizes creative solutions through cooperative
efforts by managers, employees, and DOE.
Requirements for DOE-VPP participation are based on comprehensive
management systems, with employees actively involved in assessing,
preventing, and controlling the potential health and safety hazards at
their sites. DOE-VPP is designed to apply to all contractors in the DOE
complex and encompasses production facilities, research and development
operations, and various subcontractors and support organizations.
DOE contractors are not required to apply for participation in the
DOE-VPP. In keeping with OSHA s VPP philosophy, participation is strictly
voluntary. Additionally, any participant may withdraw from the program at
any time.
DOE-VPP consists of three programs, with names and functions
similar to those in OSHA s VPP. These programs are STAR, MERIT, and
DEMONSTRATION. The STAR program is the core of DOE-VPP. This program is
aimed at truly outstanding protectors of employee safety and health. The
MERIT program is a steppingstone for contractors and subcontractors that
have good safety and health programs but need time and DOE guidance to
achieve true STAR status. The DEMONSTRATION program is expected to be used
rarely; it exists to allow DOE to recognize achievements in unusual
situations about which DOE needs to learn more before determining approval
requirements for the STAR program.
By approving an applicant for participation in DOE-VPP, DOE recognizes
that the applicant is meeting, at a minimum, the basic elements of ongoing,
systematic protection of employees at the site. The symbols of this
recognition provided by DOE are certificates of approval and the right to
use flags showing the program in which the site is participating. The
participant may also choose to use the DOE-VPP logo on letterhead or on
award items for employee incentive programs. DOE will provide the
opportunity for contractors to work cooperatively with the agency to
resolve health and safety problems. Each approved site will have a
designated DOE staff person to handle information and assistance requests
from DOE contractors.
This report, the first DOE-VPP Onsite Review Team report, summarizes
the team s findings from the evaluation of Westinghouse Waste Isolation
Division activities at the Waste Isolation Pilot Plant (WIPP) during the
week of August 29 through September 2, 1994. It is a milestone in the
Department s efforts to encourage the empowerment of employees and to
change the safety culture in DOE from compliance-driven reactivity to
continuous improvement driven proactivity.
The purpose of this report is to provide the Assistant Secretary for
Environment, Safety and Health with the necessary information to make the
final decision regarding the disposition of Westinghouse s application
efforts for DOE-VPP. Included are synopses of team member findings, and the
team s final recommendation for the site.
Contents
--------
Section Page
------- ----
Foreword.................................................... iii
Acronyms and Abbreviations.................................. vii
Executive Summary........................................... ix
I. Introduction...................................... 1
II. Quantifiable program results..................... 2
III. Management leadership........................... 3
A. Policy and Goals.......................... 3
B. Written Program........................... 3
C. Responsibility............................ 3
D. Authority and Resources................... 3
E. Line Accountability....................... 3
F. Management Visibility..................... 4
G. Subcontractor Programs.................... 4
H. Annual Self-Evaluation.................... 5
IV. Employee involvement............................. 5
V. Safety and health program......................... 7
A. Worksite Analysis......................... 7
(1) Change analysis.................. 7
(2) Comprehensive surveys............ 8
(3) Routine hazard assessments....... 9
(4) Routine hazard analyses.......... 10
(5) Employee reports of hazards...... 11
(6) Accident investigations.......... 11
(7) Trend analysis................... 12
B. Hazard Prevention......................... 13
(1) Access to certified professionals 13
(2) Methods of hazard control........ 13
(3) Positive reinforcement........... 15
(4) Disciplinary system.............. 16
(5) Preventive/predictive maintenance 16
(6) Tracking systems................. 17
(7) Emergency procedures............. 18
(8) Medical programs................. 18
C. Safety and Health Training................ 19
D. General Review of Safety and Health Conditions 20
E. Overall Safety and Health Program Assessment 20
VI. Recommendation................................... 20
Appendix. DOE-VPP Onsite Review Team Members for
the Waste Isolation Pilot Plant................... 21
Acronyms and Abbreviations
--------------------------
ACE - ALARA and Chemical Exposure (a committee at WIPP)
ALARA - as low as reasonably achievable (referring to workers exposure to
radiation)
ANSI - American National Standards Institute (New York, NY)
ASME - American Society of Mechanical Engineers
BLS - Bureau of Labor Statistics (of the U.S. Department of Labor)
CFR - Code of Federal Regulations
CMR - Central Monitoring Room
DOE - [U.S.] Department of Energy
EHS - Environment, Health, and Safety (a council at WIPP)
EPA - [U.S.] Environmental Protection Agency
EPADS - Employee Performance Appraisal & Development System
ESH - environmental safety and health (at WIPP)
ESH&RC - environmental safety and health and radiological control (at WIPP)
GET - general employee training
HASP - Health and Safety Plan (an EPA term; called Site-Specific Safety
and Health Plan by OSHA and Site Safety and Health Plan by the
U.S. Army Corps of Engineers)
IH - industrial hygiene
INEL - Idaho National Energy Laboratory (Idaho Falls, ID)
IS - industrial safety [Department at WIPP]
JHA - job hazard analysis
LWC - lost workday case
LWDI - lost workday incidence
MAST - management and supervisor training
MSDS - material safety data sheet
MSHA - Mine Safety and Health Administration
NEPA - National Environmental Policy Act of 1969
NIOSH - National Institute for Occupational Safety and Health
NIST - National Institute of Standards and Technology (Gaithersburg, MD)
NQAO - National Quality Assurance Organization
NRC - Nuclear Regulatory Commission
ORPS - Occurrence Reporting and Processing System
OSHA - Occupational Safety and Health Administration (of the U.S.
Department of Labor)
PM - preventive maintenance
PMS - performance measurement system
PPE - personal protective equipment
QIP - Quality Improvement Plan
QIT - Quality Improvement Team
RAC - risk assessment code
RCA - root cause analysis
RII - recordable injury and illness
SAR - safety analysis report
SIC - standard industrial classification
START - Supervisor Training and Accident Reduction Training
VPP - Voluntary Protection Program
WID - Waste Isolation Division (of Westinghouse)
WIPP - Waste Isolation Pilot Plant (Carlsbad, NM)
WP - Westinghouse Procedure
Executive Summary
-----------------
The U.S. Department of Energy s Voluntary Protection Program team
completed the five-day onsite review of the Waste Isolation Pilot Plant
(WIPP) site on September 2, 1994. The team consisted of 14 members
(including three observers) representing a diverse cross section of the
Department. Members included managers and professionals from DOE
Headquarters; a representative from the Rocky Flats Operations Office; a
representative from the Oil, Chemical and Atomic Workers Union at Oak
Ridge; an individual from the Occupational Safety and Health Administration
(OSHA); an individual from the Voluntary Protection Program Participants
Association (as an observer); a representative from Environmental
Management (consultant- observer); and consulting professionals.
The site was evaluated for the degree to which it had successfully
implemented the five tenets of DOE-VPP. Included in the evaluation were 162
interviews of both staff and management. A capsule summary of the team s
conclusions for each tenet is as follows:
1. Management Commitment. An extremely high level of management
commitment was demonstrated during the review of the WIPP site. This
commitment was confirmed by employees who were interviewed. Management
is visibly involved in the safety and health program, most notably
through regular walkaround visits that are performed as a part of the
Landlord Program. Under this program, senior-level managers are
designated as landlords for a portion of the site and are responsible
for ensuring that these areas are in good repair and are free of
routine hazards. Each landlord is tasked with developing a personal
checklist for a requisite monthly safety walkaround. During these
walkarounds the landlords also talk with employees about safety issues.
2. Employee Involvement. Employee involvement at the WIPP site is truly
outstanding. Interviewed employees expressed a sense of ownership for
the site and for the safety and health program. The employees were
candid and cooperative with the team, and indicated that they had no
fear of reprisal for relaying any safety concerns to
management. Employees related instances where they had stopped work
because they believed a situation might be unsafe, and pointed out that
they have never been reprimanded for doing so. In fact, instead of
being admonished, they were always assisted by management in resolving
their concerns. Employees felt that management was truly concerned
about their well-being, and were empowered to immediately correct a
hazardous situation or bring the condition to management s attention.
3. Worksite Analysis. Worksite analysis at WIPP was thorough and
comprehensive. Extensive programs were in place to identify hazards in
new or modified processes as well as in existing
processes. Comprehensive surveys performed by the site staff and by
expert consultants had been exhaustive and were well documented. Any
items requiring correction were tracked to completion. Review of the
work-control system revealed that there are no backlogs for any
safety-related work requests. Interviewed employees verified that
safety-related work requests are given the number one priority, and
that correction of hazards is always timely, if not
immediate. Employees are specifically involved in worksite analysis
through their development of both procedures and job hazard
analyses. The team noted several instances, most notably during safety
and health committee meetings, where the employees were also involved
in hazard correction.
4. Hazard Prevention and Control. Management, safety and health staff,
and workers at the WIPP site have been aggressively focused on
preventing and eliminating hazards. There has been a consistent
campaign to eliminate chemicals at the site, and where that is not
practical, to substitute less-hazardous chemicals or at least to reduce
the quantities used.
Also of particular note is the strong coordination and cooperation
observed between the occupational health nurses and the safety and
industrial hygiene staff. Located in the same building, they
communicate regularly and conduct evaluations together. The industrial
hygienist typically provides the nurses a copy of sampling
data. Following the classic hierarchy of control, the safety and health
staff evaluates the use of engineering controls if the identified
hazards cannot be eliminated. Many excellent examples of engineering
controls of hazards were pointed out during the DOE-VPP visit. The most
impressive engineering effort is the mine ventilation system, which
moves 425,000 cubic feet (12,000 m3) of air into the underground each
minute.
The team unanimously voted to recommend the Waste Isolation Pilot
Plant for official designation as a STAR site.
The WIPP site places considerable emphasis on professional
certification and experience for its safety and health staff. The
safety and health staff consists of seven full-time professionals with
over 60 combined years of safety and health experience.
5. Safety and Health Training. WIPP has an exceptional safety and health
training program that has been in place for more than 5 years. Site
employees reported that safety training helps them understand the
potential hazards of their job and ways to protect themselves.
Employees were observed to be properly using personal protective
equipment (PPE), and when questioned they were knowledgeable about its
limitations and care. The employees could also explain in detail what
their responsibilities and actions would be for different types of
emergencies at the site. The training staff was found to be highly
skilled and motivated. Top management fully supports the training
program, as evidenced by interviews with employees and supervisors,
funding levels, and by their active review and approval of training
materials.
Recommendation
--------------
Based on the information gleaned during the onsite visit, the team
unanimously voted to recommend the Waste Isolation Pilot Plant for official
designation as a STAR site.
I. Introduction
---------------
The Westinghouse Waste Isolation Division (WID) DOE-VPP onsite review
was conducted from August 29, 1994, through September 2, 1994, at the Waste
Isolation Pilot Plant (WIPP) in Carlsbad, NM. The Onsite Review Team was
composed of 11 members, representing various disciplines and complemented
by 3 observers. The names and titles of the team members and observers can
be found in the Appendix.
WIPP is a U.S. Department of Energy (DOE) facility, operated under
contract by Westinghouse Electric Corporation. It is designed to
demonstrate the safe handling, transportation, and disposal of transuranic
waste in deep salt beds. (The deep-bedded salt formation has been
geologically stable for more than 225 million years.) Stationed at the site
are some 1,020 employees. Of these, 782 are employed by Westinghouse, 45 by
DOE, 46 by Sandia Laboratories, and 147 by subcontractors.
There are no outstanding safety and health noncompliance items that
require correction.
Under Public Law 96-164, the U.S. Congress mandated the construction
and development of WIPP as a research and development project. The facility
will dispose of transuranic wastes exclusively not commercial or high-level
wastes. Transuranic wastes are those containing, or contaminated with,
radioactive elements heavier than uranium. Most of the waste consists of
contaminated laboratory gloves, tools, dried sludges, and other material
discarded from laboratory or production facilities.
The site is located about 26 miles east of Carlsbad, NM. Construction
of the facility began in 1979. It is estimated that the site will not be
fully operational (that is, will not be receiving wastes) until at least
mid-1998. The site comprises three kinds of facilities:
* Assorted surface buildings
* Four vertical shafts, each 2,150 feet (655 m) deep
* A 7.2-mile (11.6-km) underground network of horizontal storage rooms,
alcoves, and tunnels.
The surface buildings house the site personnel and equipment needed
for WIPP operations and research activities. The shafts connect the surface
facilities to the underground; in this way, it will be possible to move
transuranic waste to its underground destination.
The site is slated to receive defense-generated transuranic wastes
from DOE facilities throughout the complex. Once WIPP is operational, the
defense sites can ship directly to the facility. Presently, transuranic
wastes are stored in sealed containers above ground at sites such as the
Idaho National Engineering Laboratory (INEL).
This onsite review was the first DOE-VPP review to be conducted by the
Department at one of its contractor sites. The primary purpose was to
verify information provided by the WIPP site in its DOE- VPP
application. Because of the WIPP site s mission to safely dispose of
transuranic wastes the site is classified with a standard industrial
classification (SIC) code of 4953, which denotes refuse systems. Until such
wastes are received, the predominant activity at WIPP is mine maintenance;
the aim is to prevent the site from undergoing subsidence and, as a
consequence, premature closure.
Because WIPP deals exclusively with transuranic wastes, the site has
no peer in the private sector. To compare its lost workday incidence (LWDI)
and recordable injury and illness (RII) rates with those of comparable
facilities, the team chose as a benchmark the nonmetal mining industry s
average rates published by the Bureau of Labor Statistics (BLS). Therefore,
an SIC code of 1490 has been chosen for comparison purposes. In 1998, when
the site begins receiving wastes, the WIPP site will again be evaluated by
an Onsite Review Team. At that time, the LWDI and RII rates will be
compared to sites bearing the SIC code of 4953 for refuse systems.
This report is based on three sources of information:
* Information submitted with the application
* Additional onsite documentation
* Formal and informal interviews of various levels of managerial and
nonmanagerial Westinghouse employees.
The team conducted 57 formal and 105 informal interviews.
No collective bargaining employees are stationed at the site. There
has never been a Tiger Team Assessment, nor are there any outstanding
safety and health noncompliance items that require correction.
II. Quantifiable Program Results
--------------------------------
The team reviewed OSHA 200 logs for the preceding 3 calendar years,
and for the current year. To calculate the LWDI and RII rates, the team
used two standard formulas:
No. of RIs [Col(1) + Col(2) + Col(6)] * 200,000
RII Rate = -----------------------------------------------
No. of Employee Hours Worked
No. of LWD cases [Col(2)] * 200,000
LWDI Rate = -----------------------------------
No. of Employee Hours Worked
The following table provides the data and rates for the preceding
three calendar years, together with the three-year average.
Injury and Illness Rates at WIPP
--------------------------------
Calendar Year LWD Cases RI Cases Employee-Hours LWDI RII
---------------------------------------------------------------------
1991 4 11 1,529,932 0.53 1.44
1992 4 10 1,632,452 0.49 1.23
1993 2 7 1,677,380 0.24 0.83
3-Year Avg. 10 28 4,839,764 0.41 1.15
BLS National Average
for SIC code of 1490 = 4.0 6.7
The 3-year average rate for both RII and LWDI is substantially below
the industry average published by BLS. These rate calculations include both
WIPP and temporary workers. The information entered on the OSHA 200 log
generally supports the information submitted in the application and
contained in the supporting injury/illness documents. The person
responsible for maintaining the log was found to be knowledgeable in the
OSHA 200 log requirements.
The 3-year average rate for both recordable injury and illness rates
and lost workday incidence is substantially below the industry average
published by the Bureau of Labor Statistics.
During the first 3 months of 1994, the site s historically favorable
LWDI and RII rates rose somewhat. Most of the additional injuries involved
employees with administrative duties. In a departure from national trends,
their injuries did not involve cumulative trauma disorders such as carpal
tunnel syndrome or lower-back pain. To determine what caused the injury
rates to rise, WIPP surveyed employees and was compiling the survey results
during the review. Attempts were underway to reduce injuries to a rate at
or below their former level.
III. Management Leadership
---------------------------------
A. Policy and Goals
The WIPP facility has a written safety and health policy that has been
communicated to all levels of employees. This broadband communication
strategy was verified by many employees through formal and informal
interviews. Until July 1994, goals were set twice a year during the
development of the Quality Improvement Plan (QIP). In July, the QIP
development frequency was changed to yearly. Safety is a cornerstone of
the QIP goal-setting process. Goals are developed by the Quality
Improvement Team (QIT), which comprises representatives from every
department, including Industrial Safety. The most recent QIP included
safety and health improvement goals to be addressed next year.
B. Written Program
The written safety and health program is described in the WIPP Safety
Manual, WP 12-1, Rev. 3. The manual prescribes in detail how to implement
the administrative aspects of the safety and health program. The manual
also provides for safety and health requirements, electrical requirements,
industrial hygiene, and fire protection. Where appropriate, other resource
materials are referenced (for example, OSHA 29 CFRs, MSDSs, ANSI, ASME) for
additional guidance. This revision of the written program has been in place
since the first half of 1993.
C. Responsibility
The written program clearly assigns safety and health responsibility
at all levels of management in the worksite WIPP Safety Manual 12-1,
Rev. 3. At the time of the onsite review, these assignments had been in
place for well over a year. Responsibilities are further defined in the
Management and Supervisor Training (MAST) Program (the MAS-123 document),
which all supervisors must complete. The guide also reinforces the site
philosophy that safety is the number one priority. This philosophy was
confirmed through interviews with several personnel representing various
levels of management and nonexempt employees.
Employees are authorized to shut down a piece of equipment, or an
operation, that they believe to be unsafe.
Safety and health professionals are used by the line as
resources. These individuals lend technical expertise on an as-needed basis
while providing guidance, policies, and procedures.
D. Authority and Resources
WIPP management provides its organizations with enough workers,
training, and equipment to fulfill their responsibilities. This was
evidenced by an adequate level of staffing and the provision of adequate
personal protective equipment, the absence of equipment maintenance
backlogs, and the extensive training provided. The team observed no
conditions that would suggest a lack of resources for occupational safety
and health. Employee interviews revealed no situation where their safety
and health concerns were not addressed for want of resources and
funding. Indeed, in a policy uncommon among DOE sites, all employees are
authorized to shut down a piece of equipment, or an operation, that they
believe to be unsafe.
E. Line Accountability
According to documentation reviewed onsite, management accountability
has been assessed under a performance appraisal system known as the
Performance Measurement System (PMS). In reviewing performance records, it
was discovered that safety is one of seven equally weighted elements under
the PMS. The PMS is essentially a qualitative evaluation; for each element,
performance is described in narrative form. The PMS was in use until June
30, 1993, at which time a transition was initiated to a newer system, the
Employee Performance Appraisal & Development System (EPADS).
During the transition appraisal period (July 1, 1993, to June 30,
1994), employees were evaluated under a hybrid system which combined
elements of PMS and EPADS. Since the end of the transition appraisal
period, EPADS has been and will continue to be used exclusively.
The EPADS is a quantitatively based system consisting of 20 equally
weighted job elements. Each is rated from 1 to 5, with 5 being the highest
rating. Overall performance is calculated as a simple arithmetic mean: the
20 individual ratings for the elements are added up and the sum is divided
by 20. Since safety comprises but one element, it accounts for 5 percent of
the overall score. According to management personnel interviewed, an
element can be given additional weighting at the discretion of the rating
official.
For the evaluation year that began July 1, 1994, management introduced
an improvement to the EPADS. In the revised system, the evaluation form for
each element includes a section for listing specific written goals for the
safety element. The goals are jointly developed by the person to be rated
and the rating official; they must be measurable and attainable. Making
safety an integral part of each element s score is a positive step and a
key part of ensuring accountability.
Another key provision for ensuring accountability in safety
performance is assigning appropriate weight to the safety element in the
performance appraisal process. Management is in the process of identifying
those employees with jobs in which safety represents a critical component
of their performance. The actual weighting accorded the safety element will
be based on the importance of safety performance coupled with the
successful attainment of the written safety goals for the particular
position. By applying a proportional weight for the safety element in the
facility s performance appraisal process, WIPP ensures that a meaningful
assessment of accountability and performance occurs.
F. Management Visibility
Top management is highly visible to exempt and nonexempt employees in
demonstrating their commitment to and leadership in the safety and health
program. Top management participates in the all-employee
meetings. Moreover, employees affirmed that management exhibits a strong
presence in both surface facilities and underground.
G. Subcontractor Programs
Before subcontractors are finally selected and given a notice to
proceed at the site, they must undergo a rigorous preapproval process. This
process includes an in-depth screening of their health and safety plans
(HASPs), job hazard analyses (JHAs), safety training, and OSHA 200 injury
and illness logs. The WIPP Safety Office reviews the data and recommends a
final selection to the contracts office .
Top management is highly visible to exempt and nonexempt employees in
demonstrating their commitment to and leadership in the safety and health
program.
Subcontractor workers adhere to the same safety and health rules that
apply to the Westinghouse employees. The subcontractors that were
interviewed recognized that their safety and health performance was
important to the selection process and to their continued tenure at
WIPP. There have been documented cases in which subcontractor workers were
asked not to return to work because of serious or repeat safety violations.
The Industrial Safety Department oversees all subcontractor
operations. The office periodically audits the work areas, documenting
discrepancies on a standard form used during audits. Usually these
discrepancies are corrected expeditiously or mitigated by the appropriate
subcontractor. Discrepancies that are not corrected immediately are entered
onto the site s hazard abatement listing. If need be, work can be stopped
by any employee, including a subcontractor. The Industrial Safety
Department also requires subcontractors to complete their own
self-audits. Team walkaround inspections indicated that these audits were
being performed and documented.
Subcontractor injuries and illnesses are reported to the medical
clinic. The Industrial Safety Office maintains OSHA Form 101s (First Report
of Injury) for inspection by the site technical representatives. The
subcontractor rates for the preceding 3 years are also maintained in the
office and they fall well below the industry SIC average. A review of the
OSHA 200 logs for subcontractors verified that information listed on the
records was accurate.
H. Annual Self-Evaluation
As evidenced by documents provided to the DOE Onsite Review Team, the
WIPP site conducts a formal self-evaluation of safety and health program
performance. The ESH&RC Internal Assessment Program Plan requires that the
effectiveness of all aspects of the safety and health program must be
evaluated by an independent assessment group. Those persons internally
involved in the assessment process must receive self-assessment training
(in accordance with WP 15-MD3050). The results of the assessments must be
monitored, tracked, and trended.
The most recent evaluation had been conducted in April 1994; copies of
the report were distributed to all department managers the following
June. All program elements were assessed in accordance with DOE-VPP
requirements. The WIPP site provided the DOE- VPP team with the status on
all recommendations made.
In addition to the April 1994 self-evaluation, a safety and health
program performance evaluation was conducted by the Corporate EHS Council
in July 1994. This evaluation has been conducted at the WIPP site for more
than 10 years. The evaluators assigned numeric ratings to all elements of
the safety and health program. Narrative explanations were provided in
areas where a program element received a less-than- perfect score, followed
by a recommendation. For program elements receiving a perfect rating, no
narrative was provided.
The team was provided with an assessment of the progress made on the
safety goals in the Quality Improvement Plan. The site is considering
revising the annual assessment to better track and evaluate accomplishment
of past QIP safety goals and timing the assessment to correspond with
development of future QIP goals.
IV. Employee Involvement
-------------------------------
The Onsite Review Team observed that WIPP employees actively
participate in the structure and operation of the WIPP safety and health
program. The site s policy is to involve employees in the development of
policies and procedures. Random interviews with 29 workers and managers
confirmed that employees are, indeed, involved.
The team observed that WIPP employees actively participate in the
structure and operation of the WIPP safety and health program.
The safety culture at WIPP became most apparent during interviews with
rank-and-file employees. Their comments were candid and almost uniformly
positive, as illustrated by the following typical examples.
"Supervisors really respect the crafts here at WIPP."
"Management circulated a memo yesterday giving the typical
questions you guys would ask, but I threw it away because I
believe in telling it like it is."
"I had only been working for 2 months when I stopped work for an
unsafe condition, when the boss came over I thought he would be
mad and tell me that I was too new to be stopping work, but he
only asked what we could do to make the job safe."
All of those interviewed noted that they had never experienced
retaliation for stopping work. Many remarked that, compared to previous
sites at which they had worked, WIPP had the safest working conditions by
far.
Management was extremely cooperative in providing access to employees
who had been selected at random to be interviewed. In many cases, the
supervisor pulled the workers from their duties and made them available on
the spot or within 10 minutes. One of the first-line supervisors commented,
"This is the first place I worked [where] upper management doesn t put
pressure on the line to get the job done right away or take shortcuts."
"This is the first place I worked where upper management doesn t put
pressure on the line to get the job done right away or take shortcuts."
Another indicator that employees are fully involved in their workplace
safety is their active participation on the WIPP safety committees. There
are three major safety committees:
* the ALARA and Chemical Exposure (ACE) Committee,
* the Safety and Security Committee, and
* the Operations Safety and Communications Committee.
Employees stated that the Operations Safety and Communications
Committee (referred to by the workers as the safety committee ) was the
primary means of bringing employee concerns to upper management s
attention. Meeting weekly, this joint manager/worker committee assigns the
relevant manager the duty of resolving the concern and setting a reasonable
milestone deadline of getting back to the committee with the settlement
results.
There are also ad hoc committees, assembled to enhance employee
involvement when certain situations arise. A difficulty emerged last year
when some employees voiced concern over indoor air quality and the site
smoking policy. The safety committee appointed an ad hoc smoking committee
of managers and workers to resolve the issue. When WIPP amended the smoking
policy six months later to ban smoking in all WIPP surface buildings, the
committee was dissolved.
Another example is the root cause analysis (RCA) teams which are
formed to investigate any accidents at WIPP. These are joint manager/worker
teams in which the team leader is required to be fully trained as a
certified RCA team leader. Since nonexempt workers are certified team
leaders, RCA teams led by nonexempt workers are routine. Once the team
results are obtained, the ad hoc team members are released to return to
their normal duties.
The DOE-VPP team found that WIPP nonexempt employees exert
considerable influence on the design and operation of the safety and health
program. Many write their own job task packages, including a job hazards
analysis, which they forward to technical writers. After the technical
writer smoothes the draft package, it is returned to the worker, who must
approve the technical writer's changes before the analysis can be forwarded
up the managerial chain.
WIPP uses dedicated nonexempt workers to act as independent safety
observers. These workers, known as rovers, walk the spaces of both surface
and underground facilities, looking for safety deficiencies and notifying
the area supervisor of any safety or health shortcomings. After notifying
the area supervisor, subject matter experts are summoned to take corrective
action or resolve the concern.
Another indicator that employee involvement is genuine at WIPP is the
sense of ownership and pride that workers exhibited during the
evaluation. Most were very comfortable in speaking with the team about
safety and health issues. The team is convinced that the information
imparted during these interviews was candid and truthful.
It is worth noting that the interviews went extremely well despite the
obvious stress of the recent DOE announcement, two weeks prior to the team
review, that the site will experience an 11 to 15 percent reduction in
budget for FY95. It is difficult for a worker to praise the safety and
health efforts of management when that worker s job may be eliminated in
the near future. Likewise, WIPP management s commitment to continue
spending resources on safety and health rather than cutting corners in the
face of austere budgets is extremely commendable.
V. Safety and Health Program
-----------------------------------
A. Worksite Analysis
(1) Change analysis
The team observed that changes and modifications of equipment are
introduced into WIPP in two ways.
* The engineering design change process
* The routine maintenance of plant systems and equipment.
New systems and equipment planned for installation at the WIPP site
are designed in accordance with the WIPP Safety Manual, Chapter 1, Section
12.7, Design and Design Review. The process involves the following seven
phases.
1. Engineering change proposal. The process begins with an engineering
change proposal that defines the conceptual design features of the
proposed system or equipment. At this stage, the design engineer and
the cognizant design manager determine the impact level of the design
and the manager prepares a Design Review Plan. Impact levels determine
how much scrutiny and rigor will be applied to the design. Impact
levels range from impact level I assigned to the most complex and
important designs to impact level IV assigned to systems or equipment
of minor importance.
2. Design. For systems designs that have been assigned a lower impact
level (III or IV), the Design Review Plan may apply a graded design
review approach by conducting an independent review that is formally
documented.
For system and equipment designs assigned impact level I or II, the
design process is formal and rigorous. After completing conceptual
design, as specified in the Design Review Plan, WID Engineering may
conduct a conceptual or preliminary design review that includes review
by engineers from the following organizations:
Environment, Safety, and Health (including fire protection)
Regulatory Compliance
Waste Handling Operations
Radiological Safety
Industrial Safety
Other Engineering Disciplines
NEPA designated staff.
3. Comments. Comments are formally received and dispositioned as the
final design is being prepared.
4. Final design review. When the design is 90-percent complete, a formal
final design review is conducted, as specified in the Design Review
Plan. All of the applicable reviewers who helped review the conceptual
design return to participate. As a part of this review, WIPP uses a
Design Review Checklist. As its name suggests, the checklist
systematically helps ensure that reviewers address all aspects of the
design. The checklist includes sections on environmental protection,
industrial safety, process safety, and Safety Analysis Report (SAR)
impacts. As was done during the conceptual design review, formal
comments are received and formally dispositioned before the system is
constructed or installed.
5. System turnover package. Once the system is fabricated or built and
startup testing is complete, WIPP engineering prepares a system
turnover package for operations. The system turnover package is an
engineering evaluation confirming that all of the people, parts, and
procedures are in place and ready for use by operations. The review
includes an individual review of operator training, spare parts, as
well as field verification of procedures.
6. Maintenance. Maintenance work is controlled by the maintenance work
request process. The hazards associated with the work are identified
while work request packages and maintenance procedures are prepared. If
the work involves an activity or piece of equipment that has an
existing JHA (such as welding and cutting operations or certain
hoisting and rigging activities), the JHA is included in the work
package. Packages are planned with input from planners, maintenance
engineering, safety, and crafts. Hazards that will be encountered in
the work are identified in the prerequisites section and reiterated in
the work instructions as CAUTION statements. Safe work practices are
identified. Lockout points are recommended in the work requests and
installed by operations. Maintenance personnel are given personal
locking devices, which they use to overlock the operations
locks. Safe-energy checks are used to confirm zero energy.
7. Preventive maintenance. Preventive maintenance (PM) procedures are used
for recurring PM activities. Maintenance engineering, planning, and
crafts participate in the development of these procedures. Maintenance
procedures are validated the first time the procedure is used. The Work
Control Center attaches a validation form, and the procedure is
performed while the planner, the engineer, and others, including safety
personnel, if appropriate, observe to determine whether the procedure
is adequate and practical. If the procedure cannot be performed as
written, or needs changes, it is sent back to the Work Control Center,
where the planner and the engineer, if need be, can revise the
procedure.
In reviewing a set of procedure validation packages, team members found
one on which observers had contributed several changes to improve the
workability and safety of the activity.
As a precaution, the preventive maintenance procedure (like the
maintenance work package) will state in the prerequisites section what
hazards are likely to be encountered. Following good practice, cautions
are placed in the work instructions before the steps where the hazards
will be encountered, and safe work practices are described.
(2) Comprehensive surveys
Baseline survey Baseline surveys are an integral part of every
successful safety and health program. For this reason, they are assigned
considerable significance in DOE-VPP. DOE-VPP criteria require that the
surveys be conducted by qualified individuals at intervals appropriately
frequent for the nature of a given workplace operation. The surveys must
cover all contractor spaces as well.
From June 26 to July 3, 1990, a baseline survey was conducted at WIPP
by a qualified outside consulting firm. The survey team was composed of
Professional Engineers, Certified Industrial Hygienists, and Certified
Safety Professionals with decades of safety and health experience,
including employment with OSHA. The survey included not only a wall-to-wall
inspection of every building and trailer, but also a review of written
programs.
The 1990 reviewers looked at seven programs:
Hearing conservation
Respiratory protection
Hazard communication
Confined space entry
Fire protection
Lockout/tagout
Preventive maintenance.
The programs received generally favorable responses, and only limited
changes were recommended.
The 1990 survey found that there were no instances of industrial
hygiene significance observed in any of the buildings, shops, trailers, or
other workplaces visited. The inspectors did find, however, more than 80
violations of OSHA general industry standards in 300 different instances.
To abate these hazards, the site completely shut down operations for a
day and tackled the bulk of the findings. Coordinated teams of
electricians, carpenters, and other trades fixed roughly 95 percent of the
items that same day. Remaining items required more significant engineering
controls.
1991 survey Westinghouse hired the same outside consultant to return
to the plant in 1991 to evaluate the company's abatement efforts through
another comprehensive survey. This second survey included some 60
buildings, trailers, and work areas. The firm found that:
for the most part, significant improvement was
noted particularly in many of the locations
revisited where serious hazards and discrepancy
trends reported as a result of the 1990 survey had
been adequately corrected.
As in the earlier survey, the team reported during the walkthrough that:
there were no observations of employee exposures
to any particular health hazards. The potential
for employee over exposures to airborne
contaminants appears to be minimal for the most
part. However, as noted in the 1990 report,
systems are in place to allow the safety and
health staff to effectively deal with any
potential risks of overexposure that may
occur. There were no areas, locations, or
processes noted during the survey where
ventilation was lacking but appeared necessary by
virtue of toxic hazardous releases.
The consulting team did note several areas in Buildings 411, 456, 463,
and 485 where noise levels were found to equal or exceed the OSHA action
level and for which they recommended posting caution signs and continued
monitoring. During the DOE-VPP team visit, several of these areas were
checked by the team and found to have been posted as recommended.
The findings of these two surveys were used as a basis for the
Landlord Program, which is still in place. Under this program,
senior-level managers are designated as landlords for a portion of the site
and are responsible for ensuring that these areas are in good repair and
are free of routine hazards. Each landlord is tasked with developing a
personal checklist for a requisite monthly safety walkaround. During these
walkarounds, the landlords also talk with employees in their cognizant area
about safety concerns and issues.
In addition to the Landlord Program, the safety and health staff
developed a baseline worksheet that has been used since 1993 to evaluate
the buildings more thoroughly, including information on life safety, fire
protection, process hazard identification, operational hazards, and
chemicals used in the facility. Several of these forms were reviewed by the
team and found to be an important hazard assessment tool. According to the
DOE-VPP application, a total of 85 buildings and facilities have been
surveyed 100 percent of the buildings onsite.
To abate the hazards revealed in the 1990 baseline survey, the site
completely shut down operations for a day and fixed 95 percent of the
findings.
Industrial hygiene information from these individual building surveys
has been compiled into an important database called the Industrial Hygiene
Status Report & Assessment Strategy, which lists the chemical and physical
agents found in each work area and indicates the medical surveillance
requirements and what monitoring frequency is appropriate.
Interviews with the WIPP safety staff and the occupational health
nurses indicated that they have conducted joint inspections, such as a
noise evaluation in the hoist operation and an indoor air quality survey of
Building 411.
(3) Routine hazard assessments
Because of the unique hazards posed by WIPP s extensive underground
facilities, two varieties of routine hazard assessment are performed: one
for surface areas, the other for underground areas.
Surface. Westinghouse performs several types of self-conducted routine
hazard assessment for the WIPP surface facilities. These include:
1. A daily inspection by facility operations, covering the entire
facility. These inspections have been conducted since 1987.
2. Monthly inspections by facility engineers, Emergency Services
technicians, and landlords. Once a month, the facility engineers cover
select areas of the site, while the Emergency Services technicians
cover each building. These inspections have been conducted since the
inception of the site.
The Landlord Program has been covering all surface facilities at least
quarterly for the past three years. Today, the landlord program covers
the entire surface area on a monthly frequency. This assessment is
focused primarily on safety- and health- related items. Currently, the
surface is divided into 17 areas, each with its own cognizant
landlord. The landlords are typically managers or professionals who
work in the appointed area. Trained in developing checklists and
recognizing hazards, they are responsible for developing a checklist,
in conjunction with the safety department, based on the activities,
operations, and hazards in their cognizant area. Each month, the
landlord completes this checklist and submits it to the safety
department.
As the landlords walk around, employees are free to approach them and
voice any safety and health concerns. Deficiencies noted in the
landlord inspection are handled by persons in the cognizant area, or,
if required, entered into the work control system to be prioritized and
corrected. If an item requires a significant time for correction,
mitigative actions are taken. Landlords have shutdown authority.
3. The safety organization inspects all surface areas and equipment using
a risk-based scheme to determine the interval of inspection. The entire
site is covered annually; higher-risk facilities are covered quarterly.
Underground. Several kinds of routine hazard assessments are conducted
underground. Performed at varying intervals, they focus on different areas:
1. Each day, personnel inspect their work areas, the equipment they use,
and the grounds in which they work.
2. Daily inspections are likewise performed by Industrial Safety, Mining
Operations, rovers, and Facility Operations. The Facility Operations
inspections cover the entire underground area each day.
3. The entire underground area is also inspected each week by two groups
from Mining Operations.
4. Heavy scaling inspections are performed approximately monthly; these,
too, cover the entire underground area.
5. Heavy scaling inspections are also performed in advance of quarterly
inspections by the Mine Safety and Health Administration (MSHA).
6. Finally, an annual comprehensive and intensive inspection of the entire
underground is performed by the entire Mining Operations staff.
Most of these inspections generate written reports that must be signed
off by cognizant personnel.
The team found that the various inspection systems were very
successful in documenting hazards and tracking them to completion. All
underground hazard assessment systems examined had been in place since 1989
or earlier.
Overall. Each of the groups performing the inspections noted above is
trained to recognize hazards. Each is expected to note and report any
hazards. The Onsite Review Team s evaluation of inspection reports,
particularly those generated by the landlord inspections, confirmed that,
once noted, a hazard is tracked to correction by the cognizant
landlords. Interviewed employees were very aware of the self-inspections;
they regarded the self-inspections as thorough, and they felt free to
express any concerns or point out any hazards to the various organizations
performing the self- inspections.
(4) Routine hazard analyses
Routine hazard analyses at WIPP are conducted in a variety of
ways. Hazard analyses of non- routine onsite work are documented in
process- oriented Job Hazard Analyses (JHAs). Hazards of operating WIPP
equipment are documented in equipment JHAs. Hazard analyses of routine work
are a part of the site s procedures.
The WIPP JHA system was significantly upgraded to its present level of
effectiveness and rigor in 1991.
JHAs for both process hazards and equipment hazards are prepared
according to WP 12-111, Job Hazard Analysis, of the WIPP Safety Manual.
The procedure outlines the four steps of a JHA:
1. Select a job to be analyzed.
2. Break the job into steps, activities, or phases.
3. Identify the hazard and potential accidents.
4. Develop safe job instructions.
Process-type JHAs are kept with the work package for which they were
developed. Equipment JHAs are used to train personnel on the equipment and
are incorporated into work packages when needed.
A number of JHAs were reviewed by the team for underground operations
and experimental operations. Recommended practices to control or eliminate
the hazard were listed for each procedure step. The JHAs reviewed were
complete and thorough. Tours through the site revealed no areas that had
been left unaddressed in JHAs. Staff working on packages and in shops were
familiar with the JHAs and the hazards associated with the work activity.
Contractors to WIPP are required by contract to identify and control
the hazards associated with their scope of work. One subcontractor
organization interviewed had no formal procedure for conducting and
preparing JHAs. However, for more than a year an informal system had been
in place and was being used effectively to generate, review, and update
JHAs for construction activities.
(5) Employee reports of hazards
Employee concerns about the safety and health program at the WIPP site
are communicated by five avenues:
1. Process Improvement Program forms
2. Safety and Health Committee meetings
3. Safety and Health Observation forms
4. Safety and Health Hotline
5. Westinghouse Employee Concerns Program.
A review of the official Westinghouse Employee Concerns forms revealed
that none had been submitted during the first eight months of 1994. The
coordinator for employee concerns indicated that in 1993 WIPP expanded the
lines of communication to include the Process Improvement Program forms,
Safety and Health Committee meetings, and the Safety and Health Hotline,
and that these avenues, set up to facilitate a quick response, had become
the communication lines of choice when employees needed to have safety
concerns addressed in a timely manner. The majority of the forms reviewed
for 1993 had the box indicating the name of the person could be revealed
checked positive, indicating little fear of reprisal for reporting
concerns. All concerns systems are formally tracked in writing, and
responses to concerns are usually communicated within three days. All
concern systems include options to preserve an individual's anonymity by
request.
Interviewed employees indicated knowledge about the concerns systems
through formal training, but indicated that, in most cases, safety concerns
are initially communicated to the first- line supervisor for immediate
correction at the lowest organizational level. If the first-line supervisor
cannot alleviate the concern, the concern might then be written up in the
official Westinghouse system, or presented by a safety representative
during a safety committee meeting. Concerns that arise in safety committee
meetings are formally documented on safety committee concern forms. These
are formally tracked to closeout. Employees are also free to file concerns
directly to DOE through DOE concern forms.
All employees interviewed indicated that they were strongly encouraged
to express any safety and health concern. Review of the work controls
system verified that no safety items had been left uncorrected once
reported. Interviewees felt that management followed up on their concerns
and corrected deficiencies in a timely manner. Employees also indicated
that they are free to write an action request, which is then prioritized
and, if necessary, entered into the work controls system for resolution.
(6) Accident investigations
The team observed written procedures that describe an excellent
accident/incident investigation system. These procedures include guidance
on the reporting of incidents or events which occur at WIPP, using a root
cause analysis to identify the source of the incident/event, and developing
an incident/event lessons learned for dissemination to WIPP management and
workers.
The team s evaluation, based on document review and 29 random personal
interviews, confirmed that WIPP maintains a high-quality accident/incident
investigation program. The team also examined 18 incidents/events which met
the criteria of DOE 5000.3B and were reported to the Occurrence Reporting
and Processing System (ORPS) database since January 1993. Interviews
indicated that employees knew about the lessons learned bulletins, and the
root causes of events/incidents were readily available to all employees.
All incidents/events are reported to the Central Monitoring Room which
is staffed around the clock and logged in by the duty officer. The duty
officer relays serious incidents or events to the WIPP Occurrence Reporting
Manager. If the incident/event meets the criteria of DOE 5000.3B, then an
occurrence report is generated in ORPS. Subsequent root cause analysis and
tracking are performed, and corrective actions taken, as specified in the
ORPS Order.
If the incident/event merits attention but falls short of the
requirements of the ORPS Order, the incident/event s root cause analysis,
tracking, and corrective action are usually performed more informally.
Those incidents/events which fall in either of the two categories
mentioned above are investigated by a root cause analysis (RCA) team
composed of exempt managers and nonexempt workers. Only individuals fully
trained and qualified as team leaders may serve as the RCA team
leader. Nonexempt workers can be qualified as RCA team leaders and
routinely perform in this capacity.
The RCA, together with the provisions for preventive or corrective
action, are developed into a lessons learned bulletin by a lessons learned
board. This board consists of five members representing Engineering,
Safety, Training, the ORPS Manager, and the WIPP Facility Manager
designee. The board issues these bulletins at irregular intervals as
noteworthy safety lessons are developed from incidents at WIPP or elsewhere
in the DOE complex and reported on the ORPS database. Twenty such bulletins
had been issued from January through August 1994. The bulletin is
disseminated to WIPP managers and nonexempt craft workers (electricians and
the maintenance staff) through a required reading procedure which requires
the employee s signature. They are also posted on several of the site
bulletin boards and published in the WIPP weekly newsletter.
The Onsite Review Team noted that new WIPP supervisors are trained in
the Supervisor Training and Accident Reduction Training (START) program,
and that annual refresher courses are provided to update the training. This
training program complements the written policies of WIPP s
accident/incident investigation program.
The extremely low injury incidence rate and lost workday rate for the
site (far below the standard industrial classification statistics for
organizations performing operations similar to WIPP), as well as the low
number of ORPS reports, support the team s observations that WIPP maintains
an excellent training program.
(7) Trend analysis
WIPP maintains a trending program for industrial safety items. Data on
facility inspections, injuries and illnesses, employee concerns, and fire
protection impairments are tracked monthly, quarterly, and yearly and
communicated to WIPP employees. These reports categorize and trend various
inspection results and injuries to keep management informed and provide
summary data for safety awareness programs.
The 1994 yearly report a summary of the four previous quarterly
reports featured several statistical analyses of the injury/illness data
from 1985 to 1993. A review of these analyses revealed a direct correlation
between a rise in injuries and the number of hours worked.
In addition to these statistical analyses, Westinghouse provides a
variety of information regarding its recordable injury incidence rate and
its lost workday incidence rate. All injuries (first- aid and recordable)
occurring at WIPP are broken down into four categories:
1. Nature of injury
2. Body part affected
3. Type of injury
4. Injury by task.
These categories are then charted to determine any similarities or
trends.
Interviews with management personnel showed that they were cognizant
of the report and were using the injury/illness data in their day-to-day
hazard-prevention activities.
Facility inspections performed by Industrial Safety and Facility
Operations are also tabulated for trending. Inspection results are
categorized into several areas, such as electrical and
housekeeping. Inspection results are combined into these general areas and
formally communicated to WIPP employees via monthly, quarterly, and yearly
reports.
Additional value may be realized by categorizing the inspection
results by location and responsible section manager, or examining them zone
by zone. As prepared, inspection summaries are presented to management in
site-wide fashion. Westinghouse is considering reporting the illness and
injury data for each zone to allow the responsible zone or operations
managers to concentrate on problems specific to their areas.
B. Hazard Prevention and Control
(1) Access to certified professionals
The WIPP site places considerable emphasis on professional
certification and experience. Review of credentials by the DOE-VPP team
revealed that the safety and health staff consists of seven full-time
professionals representing more than 60 years of safety and health
experience. The site industrial hygienist was certified in the
Comprehensive Practice of Industrial Hygiene in 1984. His immediate
supervisor was certified by the Board of Certified Safety Professionals in
Management Aspects in 1991.
Both occupational health nurses are studying to take the Certified
Occupational Health Nurse examination. They draw upon the expertise of
several certified occupational health nurses within the corporate
Westinghouse organization. Similarly, the staff can draw upon the corporate
physician, who is board certified in occupational medicine. A certified
electrical inspector and fire protection engineers are also available,
offering years of significant experience.
Of particular note is the strong coordination and cooperation observed
between the occupational health nurses and the safety and industrial
hygiene staff. Located in the same building, they communicate regularly and
conduct evaluations together. The industrial hygienist regularly provides
the nurses a copy of his sampling data.
When industrial hygiene samples must be analyzed, WIPP uses only
laboratories that have been accredited by the American Industrial Hygiene
Association. The ANSI/ASME-NQAO 1989 quality assurance requirements are
referenced in the purchase orders to the laboratories as a part of the
subcontract.
(2) Methods of hazard control
The safety and health staff at the WIPP site are clearly and
aggressively focused on seeing that hazards are eliminated, not merely
controlled.
Chemicals. There has been a consistent campaign to eliminate
chemicals at the site. Where that is not practical, the staff strives to
substitute less hazardous chemicals, or at least to reduce the quantities
used. For example, instead of using 1,1,1-trichloroethane as the site s
electromotive cleaner, the staff now uses petroleum distillates. On metal
pipes, glues have been substituted for solder. No listing for perchloric
acid appeared among the 2,500 entries on the chemical database, although it
was listed in older documents.
Quantities of chemicals at the site are closely managed through the
hazard communication program run by the industrial hygiene staff. All of
the material safety data sheets for the site have been entered into a
database that allows quantities of the chemicals to be tracked. One of the
site s industrial hygienists demonstrated how reviews are performed on all
purchase requisitions that involve chemicals to determine whether the
chemical is already available onsite in some other department. If the
requisition seeks to obtain a new chemical, the document is reviewed by the
industrial hygienist to determine whether it should be allowed onsite. One
of the workers in the warehouse has been trained to constantly verify that
chemical shipments are accompanied by a material safety data sheet. He has
been personally responsible for substitutions of chemicals at WIPP. Many of
the chemicals that appear in sampling data from the early 1980s are no
longer found onsite. Additionally, the industrial hygienist has
participated in DOE s chemical vulnerability study.
Ventilation. Following the classic hierarchy of control, the safety
and health staff turns to engineering controls if the hazards cannot be
eliminated or substitutes cannot be found. Many excellent examples of
engineering control of hazards were pointed out during the VPP visit. The
most impressive engineering effort is the mine ventilation system, which
moves a prodigious 425,000 cubic feet of air into the underground each
minute. Underground, a series of local exhaust systems composed of flexible
duct are used to move air to operations that may generate contaminants in
smaller, experimental shafts.
Welding above ground as well as below ground is performed under local
exhaust ventilation. The industrial hygiene group checks the welding hoods
annually. Similarly, the hoods used in the laboratories are regularly
checked for face velocity. WIPP policy WP12-107 requires that all work with
carcinogens be conducted in a fume hood.
Noise. Noise was pointed out in the baseline survey as a concern
above and below ground. A sound-attenuating booth was constructed in the
transuranic packaging area to allow the control personnel to monitor the
operation without being exposed to the mildly elevated noise levels on the
main floor. In the underground areas, noise levels are considerably
higher. Drilling observed during the DOE-VPP tour produced significant
levels of low-frequency noise. Engineering controls are not sufficient;
consequently, hearing protection is worn during any drilling or scaling
operation underground. Informal interviews of workers from the underground
indicated that they have ready access to hearing protection, understand how
to use the equipment, and consistently wear protection on noisy jobs.
Personal protective equipment. The personal protective equipment
program at the site above and below ground is exemplary. High-noise areas
are clearly marked and hearing protection, both moldable ear plugs and
muffs, is readily available. The respiratory protection program is
administered by the industrial hygiene staff, which had conducted an
internal assessment of the program in July 1994. Each of the 148
requirements from the OSHA respirator standard (1910.134) and the latest
ANSI respirator standard was compared with the WIPP program. The staff
identified only two requirements that were not completely being met. Both
were ANSI requirements and were immediately addressed by the staff.
Workers at the WIPP site who need respiratory protection are
quantitatively fit tested, using a full test booth. The industrial hygiene
staff had purchased and begun testing a Portacount condensation nuclei
counter for conducting quantitative fit testing. Several different brands
of respirator are provided to assure a comfortable and tight fit for anyone
who needs to wear one. In addition to providing quantitative-fit testing,
IH tests each respirator on a Biosystem leak-test unit to determine whether
it may have a leak apart from any unacceptable facepiece-to- face seal.
Storage of the respirators is excellent; parts are stored in clearly
labeled cabinets that are in a different location from the actual
respirators. The latter are stored in plastic bags containing the leak-test
printouts. Respirators are kept in a locked cabinet which only the IH staff
has access to, preventing individuals from getting respirators unless
supervised by an IH professional. Respirators are the last line of defense,
and WIPP treats them that way.
Heat stress. Heat stress is a significant concern for the above
ground workers, particularly those who work outdoors in direct
sunlight. The WIPP heat stress program provides solid coverage to workers
above and below ground. The industrial hygiene staff has characterized the
hot jobs by monitoring heat loads through Wet Bulb Globe Temperatures. The
staff has set work/rest schedules for these jobs. Gatorade is provided to
workers on hot jobs and is readily available for any outside activity it
was available for participants in a confined-space training exercise. No
significant heat stress incidents were reported during the summer of 1994,
despite many days with temperatures above 100°F. The site even maintains
several full protective suits to deal with the threat of killer bees which
are moving north toward Carlsbad, NM.
Ergonomics. The site has launched an excellent ergonomics program
which recently received formal approval. The program is based on
recommendations from the OSHA meatpacking document, the NIOSH lifting
guide, the work of the Joyce Institute, and DOE s proposed approach. To
analyze ergonomic trends, the IH staff reviewed OSHA 200 logs for the
preceding 5 years and graphed the results. They also conducted a
questionnaire of computer users and their supervisors as well as a
site-wide inspection of more than 100 workstations.
The program provides a wrist support to any computer user on the site
who wants one. Lifting belts are available to warehouse personnel, but
their use is encouraged only for performing individual heavy lifts, and
then only after considering the use of a dolly or assistance from a
coworker. Antivibration gloves are provided for drilling operations
underground. An ergonomics videotape will be included in the General
Employee Training program; two other tapes will be included in the MAST
training for supervisors.
Sampling data. The IH sampling data were reviewed to assess the
effectiveness of engineering controls. The written results are kept under
lock in the Industrial Hygiene lab and are chronologically well
organized. The results are also entered into a database called the
Westinghouse Information System for Health, Environment, and Safety. This
system allows significant trending; for example, it will print out any
sampling results that have exceeded the OSHA permissible exposure limit.
A review of these data indicated that very few samples collected at
the site have exceeded any OSHA action level or permissible exposure
limit. Most results were far below these criteria, often by an order of
magnitude. The one exception was airborne lead levels measured in the
breathing zone of security officers at the firing range. Firing practice
was subsequently discontinued.
Calibration. Calibration practices for industrial hygiene sampling
are excellent, lending sufficient credence to WIPP data. Calibration gases
meeting National Institute of Standards and Technology (NIST) requirements
are maintained in the tool crib for daily calibration of the real- time
instruments used underground.
Work control. The Work Control Program at WIPP integrates a formal
safety review into every work package. Interviews with work control team
leaders demonstrated concern with safety and health equal to the
operational considerations of each work package. The leaders reported that
all preventive maintenance work packages go to the industrial hygiene and
safety groups for formal review. Any nonroutine corrective maintenance
request also goes for review. Engineers responsible for the work packages
are strongly encouraged to go into the field to work down every package in
order to fully understand the work and the safety implications. Workers are
encouraged to stop any activity they regard as unsafe; interviews confirmed
that many had exercised that prerogative. Material safety data sheets for
any chemicals involved in the proposed work are included in the working
package. Job hazard analyses are routinely performed for work packages.
(3) Positive reinforcement
Westinghouse uses several different methods to positively emphasize
the importance of safety:
* Monthly awards for the Safety and Security Employee of the Month
* A Six Weeks of Safety program, featuring various safety-related kiosks
* Giveaways for correctly answering safety- related questions
* Safety calendars
* A WIPP kids safety poster.
Interviewed employees indicated that they felt management s emphasis
on safety was very positive. All employees showed an awareness of the
positive reinforcement programs listed above and others. Several employees
echoed the point that they were encouraged to stop an activity if they had
a safety concern, and that the focus was on getting the job done safely,
not just getting the job done. Every employee interviewed who had stopped a
job with a safety concern indicated that both supervisors and managers were
pleased that the employee had done so, and in some cases the concern had
resulted in a lessons learned that was communicated to other employees. All
the positive reinforcement activities have been in place for at least 1
year; the annual Six Weeks of Safety program was initiated 3 years ago.
(4) Disciplinary system
Westinghouse uses a three-tiered approach for their disciplinary
system. The system examined had been in place since Westinghouse had become
involved with the WIPP site. Offenses are divided into three main groups,
depending on the seriousness of the infraction:
1. The most serious infractions, which include deliberate violations of
established safety rules, are considered inexcusable, and may result in
immediate discharge.
2. Second-tier offenses, which include pranks and horseplay, may result in
three days off without pay for the first act, and may result in
discharge for the second act.
3. The least serious group of offenses, which include failure to report a
personal injury to your supervisor and/or Health Services Administrator
on the day it occurs, can result in a reprimand for the first offense,
may result in three days off without pay for the second offense, and
may result in discharge for the third offense.
For second- and third-tier offenses, the repeat offense need not be
the same as the original.
Documents that the team examined, including the log of disciplinary
actions, indicated that management had applied the disciplinary program
fairly and consistently. All interviewed employees indicated that they had
been trained on the safety rules during their initial orientations, and
that their knowledge of safety rules was frequently refreshed with
training. Further, employees felt that safety rules were enforced
consistently, strictly, and fairly.
(5) Preventive/predictive maintenance
Westinghouse s preventive maintenance program is highly effective. All
equipment that the team reviewed was in good working condition. Several
employee and management interviews revealed that Westinghouse places strong
emphasis on preventative/predictive maintenance. The team checked the
equipment ID numbers on overhead cranes, electrical distribution panels,
pressure relief valves, and operational equipment (mine exhaust fans, fork
lifts, temporary generators) against the preventive maintenance inventory
and scheduling system. All were verified to be in the preventive
maintenance program and had a thorough preventive maintenance history. The
team was especially impressed with WIPP s maintenance of transportable
pieces of equipment such as air compressors, electrical test equipment, and
ladders. very employee interviewed who had stopped a job with a safety
concern indicated that both supervisors and managers were pleased that the
employee had done so, and in some cases the concern had resulted in a
lessons learned that was communicated to other employees.
All preventive maintenance work is scheduled in accordance with
regulatory requirements and manufacturers recommendations and tracked
through a consistent, computerized, site-wide work control system. Each
morning, the WIPP site holds a plan-of-the-day meeting. This highly
effective meeting documents all work occurring at WIPP during that day. The
DOE-VPP team was very impressed with the sense of ownership for equipment,
mechanical and electrical systems, and work areas. Employee interviews
revealed that employees frequently inquired about the status of preventive
maintenance activities in their work areas.
Ownership can be attributed to a zone concept introduced in 1991. This
system defines who owns all work areas, equipment and systems at
WIPP. Until then, the WIPP site was plagued by high maintenance
backlogs. However, the zone concept has carried the idea of owning
equipment, systems, and work areas to the floor level. By owning their work
areas, employees feel accountable. The team could not find a single orphan
(ownerless) piece of equipment on the site. This strong sense of employee
ownership has added to the program s success and decreased the
safety-related backlog.
Westinghouse has initiated a cutting-edge predictive maintenance
thermography program and has completed this survey on all electrical
distribution panels at WIPP. This noteworthy effort has identified several
potential problem areas. By identifying these precursor situations, WIPP
management is able to take action before conditions evolve into
problems. Downtime is thereby averted. Additionally, the maintenance
organization has a highly effective process for identifying National
Electric Code violations.
The team was very impressed with the Westinghouse preventive
maintenance program as well as the site-wide process for controlling and
prioritizing work. The work prioritization process was consistently
implemented across WIPP and addressed issues affecting worker safety in a
highly responsive manner. Interim actions on items requiring the work
control process were effective in ensuring employee safety.
(6) Tracking systems
Several systems are used at the WIPP site for tracking hazards and
ensuring closure.
Industrial safety programs. The WIPP Industrial Safety (IS)
Department uses a computer database to track inspection results. Shortly
before the team s visit, responsibility for maintaining the database and
its software was transferred from a safety engineer to a database
specialist. This transfer allows the safety engineer to spend more time in
the field while providing him with additional resources for manipulating
and analyzing the collected data.
The system requires that all IS observations be field-logged on a
safety observation form which requires approval by a line employee
responsible for correction. A copy of this form is provided to the
individual for documentation. Included on the form is a section in which
the employee must document either:
* what immediate corrective action was taken (if such action was
possible or needed), or
* a date and proposed corrective action and a risk assessment code
(RAC) ranking the deficiency.
Information on the safety observation form is then entered into the IS
database for tracking and assigned a numerical code that defines the item s
status (open or closed). Interviews with the responsible safety engineer
revealed that open items entered into the work-control system are tracked
by the responsible safety engineer to ensure permanent closeout. In
reviewing the closed items, the team determined that the industrial safety
database was effective.
Landlord inspection program. In another hazard analysis activity,
various line organizations inspect their areas daily and monthly. These
activities are not tracked in any standardized fashion. From most
interviews, it was impossible to verify that an item from the current month
s inspection report was closed until an inspection was carried out the
following month. All inspections are documented through an area- specific
checklist developed by the cognizant line organization and approved by the
WIPP Industrial Safety Department. Several past inspection reports were
reviewed to verify that corrective actions were being taken. All reviewed
items were determined to have been corrected or logged into the site-wide
work control system, where they were being prioritized. For such items,
appropriate interim abatement was adequate and was being performed through
approved guidance contained in the site-wide work control system.
Site-wide work control process. The tracking of corrective actions in
the site-wide work control program is very effective. If an item identified
in a hazard analysis process requires that a maintenance work request be
formally generated, the item is entered into the work controls database for
correction. The work is prioritized according to a consistent site-wide
process and resolved accordingly.
Review of the this prioritization process determined that the system
addressed occupational safety issues appropriately. A team member walked
down several items that had been entered into the system to verify that
they had been appropriately closed out. In addition, maintenance work
requests that had been completed and signed off were reviewed in the
field. This review validated that all items in the database that had been
marked as closed were indeed closed.
(7) Emergency procedures
The WIPP Emergency Management Plan, the Emergency Readiness Assurance
Plan, the Site Hazards Assessment, and the Emergency Services Program Plan
define the responsibilities and lines of authority for emergency response
organizations and personnel, the detailed procedures, pertinent
information, and the training needed to respond to emergencies that might
occur at the site. WIPP is prepared to respond to all anticipated
emergencies, including underground, industrial, security, national, and
continuity-of-government emergencies. At the present time, WIPP emergency
plans and procedures are in place to respond to radiological
emergencies. However, because no radiological waste has yet been stored in
the facility, these provisions and procedures have not yet been
implemented.
Emergency reporting and mobilizing. Emergencies of all types are
reported to the Central Monitoring Room (CMR) operator via the emergency
phone number (8111) or the mine paging system. The CMR uses established
procedures to determine the degree of response that the emergency requires
and activates the needed response. For very serious incidents, the
Emergency Management Team can be mobilized to staff the Emergency
Operations Center. For less serious occurrences, the CMR operator can
direct the response of fire, medical, hazardous materials, medical, and/or
rescue teams.
Rescue teams. In response to surface emergencies and most underground
emergencies (those not involving a mine evacuation and a subsequent mine
rescue-team response), the on- duty emergency service technician becomes
the incident commander and assumes control of the emergency response. The
incident commander directs the response efforts of the responding teams
that include fire, medical, hazardous materials, and rescue personnel.
Training and equipment. Personal protective equipment is available
for all types of responders. Training is thorough and current. Necessary
emergency equipment is staged, ready for use.
Mine rescues. Response to serious underground mine emergencies is
provided by two highly trained mine rescue teams. These teams meet all
requirements and criteria set by the Mine Safety and Health Administration
(MSHA) and have successfully demonstrated their capabilities and skills in
semiannual in-mine drills as well as national competitions. The annual
evacuation drill is usually conducted concurrently with one of the
semiannual mine rescue team drills.
Site Emergency Plan. The WIPP site Emergency Plan was expanded from
the MSHA-required elements to its present state in 1991 to address all DOE
and OSHA requirements. WIPP further indicated that the Emergency Plan was
in the process of being reviewed by a physician.
Annual exercises and more frequent, smaller- scale drills are
conducted to maintain training and awareness. Lessons learned from the
exercises and drills are used to improve elements of the Site Emergency
Plan.
(8) Medical programs
The WIPP site has an active medical program that sees 25 to 45
patients each day. Two full-time nurses provide the onsite services under
the direction of an occupational medical director located in Carlsbad,
approximately 34 miles from the site. Twenty seven emergency medical
technicians are reported to be on site with a fire engine, rescue truck,
and ambulance available 24 hours a day. Agreements have been made for
additional emergency services from the hospitals in Carlsbad and Hobbs.
Nurses. Both nurses are Advanced Cardiac Life Support Certified and
are certified for pulmonary function testing by the National Institute for
Occupational Safety and Health (NIOSH). One nurse has also been certified
by NIOSH for performing audiometric testing; the other was scheduled to
receive the audiometric training shortly after the team s visit. The
facility is small but equipped with an audiometric test booth that is
calibrated annually, a miniaturized spirometer that is easily transported
to the field, an examination table, and instrumentation for conducting
lipid profiles as part of a growing wellness program.
While neither nurse has received certification as an occupational
health nurse, one is planning to take the examination in April 1995, the
other in 1996. They show great enthusiasm for their work and are apparently
well respected by the work force, as indicated through informal
interviews. There is strong rapport and coordination between the IH staff
and the nurses the nurses receive copies of sampling results from the IH
staff and often accompany them during site inspections, such as ergonomic
surveys.
A formal review of the occupational medical program was conducted on
June 15 and 16, 1994 by a board-certified occupational physician working
for the DOE Albuquerque Operations Office. At the time of the DOE-VPP
review, the site was in the process of addressing all the concerns raised
in the occupational medical program review.
C. Safety and Health Training
The site has an exceptional safety and health training program that
has been in operation since 1989. The evaluation and interviews revealed no
specific patterns or problems that might affect the safety and health
training program. Employees reported that safety training helps them
understand the potential hazards of their jobs and ways to protect
themselves. The training staff is highly motivated and provides high
quality training by virtue of their credentials and experience. Top
management fully supports the training program, as evidenced by interviews
with employees and supervisors, funding levels, and reviews and approvals
on training documentation. The training staff recently moved into a new
facility that will help them continue to meet the site s training
needs. The facility has five classrooms, two laboratories, and a studio
designed for developing interactive videos.
Several of the safety courses developed by the site are required by
Federal and State regulations; others come from supervisory job and task
analyses. Training is completed in a setting that can be formal (held in a
classroom) or job-specific (typically on-the-job training).
New employees are given a 1-day newcomer s orientation, followed by 3
days of General Employee Training (GET). Twelve hours of GET are in
safety-related topics, including a 2-hour segment on hazard communications
(hazcom). Training courses are fine-tuned and updated continually using
feedback furnished by the student s supervisor or manager. Also,
supervisors and employees are sometimes used as subject matter
experts. After receiving 40 hours of instructor training, they are
qualified and serve as on-the-job trainers. Courses developed by the
training staff are also used by other divisions of Westinghouse, DOE, State
agencies, and, in some instances, private companies in Carlsbad. The
Training Department is also responsible for issuing and maintaining formal
certifications, such as hoisting and rigging, lockout/tagout, and permitted
confined space. Subcontractors are included in the same elements of the
safety training programs as Westinghouse employees and are given courses
relevant to the work they are performing. mployees reported that safety
training helps them understand the potential hazards of their jobs and ways
to protect themselves.
Training is recorded in a computer database and backed up by hard
copies. The computer program is a state-of-the-art system and fulfills all
the site s documentation needs. For example, the system provides employees
and supervisors a quarterly updated history of their training. A monthly
calendar of classes is also published and distributed to managers,
supervisors, and hourly employees.
Top-level managers and supervisors are required to take a self-paced
training course called Managers and Supervisors Training (MAST). They also
take another program called Supervisor Training and Accident Reduction
Techniques (START). Safety and health training for radiation workers
includes radiation (rad) training, levels one and two. The site course was
designed to match DOE s rad core course and follows its curriculum
elements. In 1993, 284 rad workers were trained. However, training has been
scaled back until the site begins accepting low- level hazardous wastes.
From interviews, it was established that employees knew how to protect
themselves and others from hazards of the job. Employees were also observed
using personal protective equipment (PPE). When questioned about their use
of PPE, they were knowledgeable about its limitations and care. The
employees could also explain in detail what their responsibilities would be
for different types of emergencies at the site.
D. General Review of Safety and Health Conditions
The team conducted a number of walkarounds, both as a group and
individually, and the consensus was that the site was exceptionally well
maintained. Housekeeping was extraordinary in all areas, but most
significantly in the mine. The mine was free of any debris, and all
underground areas from offices to machine shops were well organized and
clean. To quote managers and workers, "this [the WIPP mine] is the Cadillac
of mines." The team would tend to agree.
E. Overall Safety and Health Program Assessment
Taken as a whole, the team found the WIPP safety and health program to
be very impressive. The program is comprehensive, innovative, and well
communicated. All 162 interviews confirmed the fact that the WIPP site
makes worker safety and health its first priority.
VI. Recommendation
-------------------------
It is the unanimous recommendation of the DOE- VPP Onsite Review Team
that the Westinghouse Waste Isolation Division at the Waste Isolation Pilot
Plant in Carlsbad, NM, be accepted into the U.S. Department of Energy
Voluntary Protection Program at the STAR level.
Appendix. DOE-VPP Onsite Review Team Members for the Waste Isolation
Pilot Plant
Name Area(s) of Responsibility Title Affiliation
-----------------------------------------------------------------------
Kanth, Team Leader Safety and Health U.S. Department
Sanjeeva Management Leadership Program Manager of Energy
Evat, Backup Team Leader Safety Specialist OSHA
Pamela Management Leadership
Eimer, Program Director Acting Director, U.S. Department
Ron Management Leadership Technical Support of Energy
Division
Rogers, Subcontractors Safety and Health U.S. Department
Raymond Safety and Health Training Program Manager of Energy
McCabe, Employee Involvement Safety and Health U.S. Department
Larry Accident Investigations Program Manager of Energy
Lawson, Employee Involvement Employee OCAW(1)/Oak Ridge,
Bruce Accident Investigations Representative TN
Emch, Tracking Safety U.S. Department
Dan Trending Specialist of Energy
Preventive Maintenance
Lippy, Industrial Hygiene Industrial SCIENTECH, Inc.
Bruce Medical Programs Hygienist
Comprehensive Survey
Scott, Pre-Use, Pre-Startup Analysis Safety COMPA Industries,
Walter Routine Hazard Analysis Engineer Inc.
Emergency Preparedness
Ulm, Subcontractors Safety Lawrence
Bill Safety and Health Training Engineer Livermore National
Laboratory
Carson, Routine Hazard Assessments Nuclear/Safety COMPA Industries,
Robert Employee Records of Hazards Engineer Inc.
Positive Reinforcement and
Dicipline
Gibbs, Observer Acting Director, U.S. Department
Roy Office of of Energy
Occupational
Safety
Richardson, Observer Executive Voluntary
Peggy Director Protection Program
Participants'
Association
Esposito, Observer Industrial Representing the
Paul Hygienist/ Office of
Consultant Environmental
Management, U.S.
DOE