An Approach to Chemical Life-Cycle Management Sharing

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An Approach to Chemical Life-Cycle
ManagementSharing Lessons Learned
Anthony M. (Tony) Umek
Vice President, Environment, Safety, Health
Quality Savannah River Nuclear Solutions,
LLC March 10, 2009
Joint EFCOG/DOE Chemical Safety and Lifecycle
Management Workshop
Washington, DC
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EFCOG ESH Working Group
How the EFCOG ESH Working Group can help

• Integrates Chemical Safety and Lifecycle
  Management with other key ESH elements (e.g.
  Industrial Hygiene)
• Leverages DOE contractors experience expertise
• Leverages Chemical Safety Boards experience
  expertise
• Info link www.EFCOG.org

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SRS Chemical Safety and Lifecycle Management
Lessons Learned a DOE site perspective

• The Savannah River Site has a history of
  excellent occupational safety performance
• At SRS we are expanding the concept of Zero
  Accidents to Zero Incidents, to encompass all
  aspects of health, safety, security and the
  environment
• The potential for chemical exposures is receiving
  an elevated level of visibility resulting from
  10CFR851
• Managing the chemical life cycle is key to
  achieving Zero Incidents

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Implementing ISMS into Chemical Safety Life
Cycle Management
The DOE Savannah River Site approach

• OBJECTIVE Manage chemicals to minimize the
  potential for exposures (applying ISMS)
• SRS approach (work in progress)
• Establish vision and strategic tactical
  approach to achieve objective in place
• Define and implement effective leading indicators
  in work
• Measure progress in work

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SRS Chemical Safety and Lifecycle Management
Program
Vision

• At SRS, CSLM is the effective strategic
  tactical application of Integrated Safety
  Management principles to safely manage the life
  cycle of chemical use (planning, acquisition,
  storage, transportation, use, and disposition) in
  a manner that protects workers and the general
  public, maximizes efficiency, and is protective
  of the environment

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SRS Chemical Safety and Lifecycle Management
Strategic Approach

• Savannah River Site chemical safety strategic
  approach
• Reduce footprint of toxic chemicals
• Recycle/reuse
• Increase competition (expanded vendor base)
• Reduce inventory (Just-in-Time deliveries)
• Measure results
• Historically, chemical tracking relies on lagging
  indicators (e.g., consumption, accidents/incidents
  )
• An approach using leading indicators improves
  upstream management of chemicals

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Tactical Approach Chemical Management at SRS

CMC Chemical Mgt. Center Integrated, Site-wide
chemical management
Department Line Organization Chemical
Coordinators
Site Employees
Immediate access to MSDS and other Chemical
Information HazCom Training
Matrix to CMC for Procedures Training
Chemical Safety Lifecycle Management
Committee SPC for each Vice President Line
Organization Subject Matter Experts
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ISMS is Tactically Integrated into Chemical
Lifecycle Management

• Defining the scope of work clearly evaluating
  needs changes
• Using best practices to augment minimum
  requirements (federal, DOE, contract, state)
• Identifying all hazards
• Implementing effective hazards prevention/control,
  including hazardous materials (e.g. piping,
  hoses)

• Minimizing unnecessary transportation and
  inventories/storage
• Minimizing potential waste streams
• Involving trained, qualified workers and SMEs
• Engaging suppliers and subcontractors fully
• Effective use of lessons learned and
  metrics/indicators

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Chemical Tracking Examples of Leading Indicators

• Toxic footprint reduction (92.5 percent
  reduction)
• 1995 400,000,000 pounds
• 2006 70,000,000 pounds
• Savings from reuse and recycling 17.9 million
• Acquisition and waste cost avoidance (FY03-FY06)

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Chemical Tracking Examples of Leading Indicators

• Just-in-Time contract chemicals
• 1995 Less than 100
• 2008 1,070
• Stores inventory reduction of 90 percent
• Risk reduction associated with storage and
  handling
• Restricted warehousing minimizes hazardous
  inventory
• Cross dock to delivery and end user minimizes
  redundant handling

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Consequences of Ineffective Chemical Management

• DOE Complex events lower consequence
• Hanford Tank Farm (Type A investigation)
• Tank vapors
• Chemical exposures (e.g., Cr6 Maganese)
• Commercial events higher consequence
• Pesticide Waste Tank explosion in Institute, WV
  (2008) 2 fatalities
• Packaging Corporation of America (PCA) corrugated
  cardboard mill in Tomahawk, Wisconsin (2008) 3
  fatalities
• Ongoing CSB current investigations
• Silver Eagle refinery in Woods Cross, Utah
  January 2009 serious injuries
• Chemical hazards are real and require management
  attention
• Reinforces the need for ISMS, for the life cycle

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Future Challenges

• Maintaining an effective program during changes
  in missions and funding challenges
• Preventing higher consequence events from
  occurring
• Integrating EO 13423 with energy policy evolution
• Implementation of potential changes to HAZCOM as
  OSHA moves toward the UN program Globally
  Harmonized System of Classification and Labeling
  of Chemicals (GHS)
• Developing a set of Leading Indicators upon which
  Management can make effective decisions

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Where Can You Get More Information?

• Learn more about chemical safety
• Review DOE handbook
• Access EFCOG web sites
• Access DOE HSS and lessons learned
• Review Chemical Safety and Hazard Investigation
  Board (www.csb.gov)
• Benchmark successful companies
• Get involved at your site and company levels
• Walk your spaces for a first hand view
• Determine what your company/industry is doing
  relative to chemical safety (baseline)
• Establish roles and responsibilities and an
  organization and SME
• Contact the EFCOG Chemical Safety and Life-Cycle
  Management Subgroup Chair Jim Morgan
  (james.morgan_at_srs.gov)

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Environmental Safety and Health Working Group
DOE HQ ESH Working Group Sponsors Pat
Worthington, DOE-HQ, HS-10 Frank Russo, DOE-HQ,
NA-1
DOE Subgroup Points of Contact DOE/HSS DOE/Line Ch
emical Safety and Lifecycle management Bill
McArthur, DOE-HQ, HS-11 TBD Electrical
Safety Brad Davey, DOE-HQ, HS-12 Cliff Ashley,
RL Mike Hicks, ID Environmental Steve Woodbury,
DOE-HQ, HS-21 TBD Industrial Hygiene/Industrial
Safety Bill McArthur, DOE-HQ, HS-11 Don Harvey,
DOE-HQ, NA-1 Occupational Medicine Bonnie
Richter, DOE-HQ, HS-13 Don Harvey, DOE-HQ,
NA-1 Radiation Protection Pete OConnell, DOE-HQ,
HS-11 J.E. Parsons, DOE-RL
ESH Working Group Organization Chart Effective
date 1-22-09 Rev.5
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Attachment to Briefing by Tony Umekto the Joint
DOE/EFCOG Chemical Safety Management
WorkshopMarch 10, 2009
Current CSB Investigations
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Chemical Safety Board Current InvestigationsMarch
2009

• Silver Eagle Refinery, Woods Cross vapor fire,
  UtahTerminalOn the evening of January 12, 2009,
  a petroleum storage tank, known as Tank 105, was
  ignited by an as yet undetermined ignition
  source, causing a massive flash fire. The storage
  tank continued to burn for a number of hours,
  until the flames were extinguished by the South
  Davis Metro Fire Agency and local refinery fire
  brigades early the following morning.
• Two refinery operators and two contractors, who
  were standing in a shed 230-238 feet from the
  tank, were engulfed by the flame front and
  suffered serious burns. All four were
  hospitalized and are now recovering.

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Chemical Safety Board Current InvestigationsMarch
2009

• Allied Terminal Fertilizer Tank Collapse,
  Chesapeake, VANovember 12, 2008 A
  two-million-gallon liquid fertilizer storage tank
  collapsed at the Allied Terminal distribution
  facility in Chesapeake, VA. The incident
  critically injured two contract workers, who were
  hospitalized. Two members of the public who tried
  to aid the injured men required treatment likely
  related to exposure to ammonia vapor from the
  released fertilizer. The fertilizer over topped a
  containment dike and flooded sections of a nearby
  residential neighborhood. At least 200,000
  gallons of spilled fertilizer could not be
  accounted for, and some reached the nearby
  Elizabeth River, which flows into the Chesapeake
  Bay.
• Bayer CropScience Pesticide Waste Tank Explosion,
  Institute, WVAugust 28, 2008 Two workers were
  fatally injured when a waste tank containing the
  pesticide methomyl violently exploded, damaging a
  process unit at the Bayer CropScience chemical
  plant in Institute, West Virginia.
• Packaging Corporation Storage Tank Explosion,
  Tomahawk, WIJuly 29, 2008 Three workers died
  and a fourth was injured when an explosion
  occurred inside an 80-foot-tall storage tank at
  the Packaging Corporation of America (PCA)
  corrugated cardboard mill in Tomahawk, Wisconsin.
  The workers were on a catwalk above the tank and
  performing hot work (welding) at the time of the
  explosion. The storage tank held a mixture of
  recycled paper pulp and water. The CSB is
  performing microbiological and chemical testing
  to determine what caused flammable gas to be
  present inside the tank.

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Chemical Safety Board Current InvestigationsMarch
2009

• Goodyear Heat Exchanger Rupture, Houston, TXJune
  11, 2008 One worker was killed and
  approximately seven others were injured, during a
  maintenance operation on a heat exchanger.
  Ammonia overpressured inside the exchanger,
  causing it to rupture.
• Imperial Sugar Company Explosion and Fire, Port
  Wentworth, GAFebruary 7, 2008 A huge explosion
  and fire occurred at the Imperial Sugar refinery
  northwest of Savannah, Georgia, causing 14 deaths
  and injuring 38 others, including 14 with serious
  and life-threatening burns. The explosion was
  fueled by massive accumulations of combustible
  sugar dust throughout the packaging building.
• BP America Refinery Accident, Texas City,
  TXJanuary 14, 2008 A worker was fatally
  injured when the top of a large steel filter
  housing suddenly blew off in the refinery's
  ultracracker unit. This unit is across a roadway
  from the ISOM unit, where a 2005 accident killed
  15 workers and injured 180 others.

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Chemical Safety Board Current InvestigationsMarch
2009

• T2 Laboratories Inc. Explosion and Fire,
  Jacksonville, FLDecember 19, 2007 Four people
  were killed and 13 others were transported to the
  hospital when an explosion occured at T2
  Laboratories Inc. during the production of a
  gasoline additive called methylcyclopentadienyl
  manganese tricarbonyl.
• Xcel Energy Company Fire, Georgetown, COOctober
  2, 2007 Five people were killed and three
  others injured when a fire erupted 1,000 feet
  underground in a tunnel at Xcel Energy Company's
  hydroelectric power plant in Georgetown,
  Colorado, located approximately 45 miles west of
  Denver. The fatally injured workers were trapped
  deep underground during an operation to coat the
  inside of the tunnel with epoxy using highly
  flammable solvents. The tunnel is several
  thousand feet long and connects two reservoirs
  with electricity-generating turbines.