Inspection of the Hanford Site Chronic Beryllium Disease Prevention Program
The U.S. Department of Energy (DOE) Office of Independent Oversight, within the Office of Health, Safety and Security (HSS), conducted an inspection of the beryllium program at the Hanford Site during March and April 2010. The inspection was performed by the Office of Independent Oversight’s Office of Environment, Safety and Health Evaluations at the request of the DOE Headquarters Office of Environmental Management (EM) and focused on the Hanford Site’s implementation of its recently developed sitewide chronic beryllium disease prevention program (CBDPP).
After the onsite portion of the HSS team inspection, RL and ORP reacted promptly to many of the non-compliances and weaknesses identified during this inspection and issued direction to their contractors to take a number of corrective and interim actions to address identified deficiencies. The direction appropriately called for timely action, with many of the interim and corrective actions to be completed within 30 days; for the others, an implementation plan was to be completed within 30 days. In addition, the interim actions cover most of the areas of weakness identified during this inspection. While the direction is a positive step, some aspects warrant additional refinement, including additional focus on refining the characterization process to ensure its effectiveness before completing the outstanding assessments and improving certain controls (e.g., boundary barriers) in areas of known contamination.
Section 2 presents an overall assessment of the effectiveness of the management and oversight of the new Hanford sitewide CBDPP. Section 3 identifies the findings that require corrective action by site management. Section 4 provides the Independent Oversight team’s overall conclusions and cross-cutting opportunities for improving the beryllium program at the Hanford Site.
Appendix A provides supplemental information, including team composition and additional information about the inspection activities. Appendix B presents background information for readers who are not familiar with the Hanford Site or beryllium programs. It identifies the DOE organizations and prime contractors at the Hanford Site, including those that have the potential to work with beryllium or in beryllium-contaminated facilities, and describes other organizations with a role in the efforts to protect workers from beryllium effects. It also briefly summarizes key information about beryllium and its health impacts.
Appendix C presents the results of the review of the beryllium medical surveillance program, which is managed by AMH. Appendices D through G provide the results of the review of implementation of the CBDPP by the four major Hanford Site contractors with operational responsibilities that were reviewed on this inspection (i.e., WRPS, CHPRC, MSA, and WCH). Appendix H discusses a number of issues related to the CBDPP that are cross-cutting (i.e., potentially relevant to multiple contractors) or that could have DOE-wide implications, including issues involving soil background levels for beryllium; the 2009 American Conference of Governmental Industrial Hygienists threshold limit value for beryllium; the status of research efforts for monitoring and sampling beryllium; and the use of the DOE Regulatory and Policy Response Line.