Using Engineering, Administrative and Personal Protective Equipment Controls to Remediate Hazardous and Radioactive Constituents

This paper documents how utilizing available source term information, integrated safety management, and associated engineering, administrative and personal protective equipment (PPE) controls are used in concert to perform work safely. Two field projects consisting of 1) a room containing both hazardous (e.g., hydrofluoric acid) and radioactive constituents and 2) a former reaction vessel containing approximately 568 liters (150 gallons) of lime sludge and technetium-99 (Tc-99) were organized using the Department of Energy’s (DOE’s) Integrated Safety Management System (ISMS). This system allowed the project teams to control work-related decisions based on their knowledge, experience, expertise, and field observations. The information and experience gained from each project stage and rehearsals contributed to modifying subsequent entries, further emphasizing the importance of developing hold points and incorporating lessons learned. Furthermore, selecting the appropriate PPE is based on providing an adequate level of employee protection relative to the task-specific conditions and hazards. PPE is categorized into four ensembles based on the degree of protection afforded, e.g., Levels A (most restrictive), B, C, and D (least restrictive). What is often overlooked in preparing an ensemble is that the PPE itself can create significant worker hazards, i.e., the greater the level of PPE, the greater the associated risks. Furthermore, there is confusion as to whether a more “conservative approach” should always be taken since Level B provides the same level of respiratory protection as Level A but less skin protection. Additional information summarizes the Occupational Safety and Health Administration regulations addressing Level A versus Level B, and provides justification for selecting Level B over Level A without under-protecting the employee. The hazards and the chemical nature of hydrofluoric acid provide qualitative evidence to justify Level A. Once hydrofluoric acid is removed as a source term constituent, PPE performance is evaluated against the remaining chemical inventory. If chemical breakthrough from direct contact is not expected to occur and instrument readings confirm the absence of any hazardous vapors, additional skin protection afforded by wearing a vapor-tight, totally encapsulated suit is not required. Therefore, PPE performance and instrument data provide quantitative evidence to justify Level B. These projects exemplify that using guidance provided by DOE’s ISMS and the Occupational Safety and Health Administration (OSHA) demonstrates how a detailed and thorough planning process integrating safe work practices and commitment to teamwork can result in the safe and effective completion of very complex and highly hazardous projects.