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Cyanide mitigationand worker protection
April 28, 2014
Presented to: Subgroup of the
Kentucky Chemical Demilitarization
Citizens’ Advisory Commission and
Chemical Destruction Community
Advisory Board
Secondary Waste Working Group
Presented by:
Jeff BrubakerACWA Site Manager
Doug OmichinskiSystems Contractor Project Manager
Roger Thompson, CIH, CSPSystems Contractor Safety & Health Manager
Charlie Satterwhite, CIHSystems Contractor Senior Industrial Hygienist
Dr. John BartonSystems Contractor Chief Scientist
Neil FrenzlSystems Contractor Resident Engineering Manager
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2
Agenda
Potential agent and industrial chemical hazards
Health Hazard Assessment methodology and approach
Worker Safety and Occupational Medicine Program
– Personal Reliability Program
– Medical baseline screening
Cyanide challenge for energetics neutralization process
Cyanide treatment during energetics neutralization process
Cyanide exposure limits vs. BGCAPP levels
Questions and Responses matrix
Responses
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GB
VX
H
aluminum hydroxide
ammonia
carbon monoxide
carbon dioxide
Dicyclohexyl carbodiimide
diisopropylcarbodiimide
diisopropyl methlyphosphonate
diisopropanolamine
diisopropyl urea
EA2192
ethanol
sulfuric acid
3
Potential agent and industrial chemical hazards
tributylamine
tetrytol
tetryl
Composition B
trinitrotoluene
RDX; hexahydro-1,3,5-trinitro-1,3,5 triazine (cyclonite)
M28
HCN
hexane
methylene chloride
compressed air
helium
hydrogen
phosphoric acid
hydrochloric acid
hydrogen fluoride
isopropanol
nitrogen
methyl phosphonate
methyl phosphonic acid
sodium hypochlorite
sodium hydroxide
oxygen
phosphorus pentoxide
dithiane
sulfur
chloroform
Chemical Agents
Hydrogen Cyanide
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Health Hazard Assessments
Preliminary Hazard Assessment completed during design phase
Health Hazard Assessments and Job Hazard Analyses identify potential exposure hazards
– Completed to Project System Safety Program Plan standards
– Completed after procedure development initiated
– Completed to appropriate phases of the project (Design, Construction, Systemization, Operations, Closure)
A Construction worker (above) wears personal protective equipment.Systemization workers (below), inspect energized lock-out/tag-out systems.
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Hazard tracking and communication
Health Hazard Inventory updated after Health Hazard Assessment
Documents shared with Medical Director and emergency preparedness
Hazards identified during analyses are tracked in Hazard Tracking Log
BGCAPP has formal Hazard Communication Program and Hazardous Waste and Emergency Response Program
Employees are educated and trained for potential exposure to hazards
5
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Worker Safety and Occupational Medicine Program
Personal Reliability Program
Workers’ activities involving the potential exposure to nerve agents receive a medical examination to document
1. Exhibit no physical, mental, or emotional impairment that may result in a higher vulnerability to nerve agent exposure
2. Are physically/mentally able to wear and use the required protective clothing and equipment
Individual baseline nerve-agent testing and ongoing surveillance dependent on type of work categories
Medical Screening Program
Medical and Industrial Hygiene programs are in place for industrial work activities depending on potential exposures
As part of ongoing Health Hazard Assessment, the extent of potential exposures identified determine which of programs are required for each worker
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The Technical Challenge
Neutralizing rocket warhead explosives poses unique technical challenge at Blue Grass
Cyanide formation expected during energetics neutralization process, trapped in caustic liquid energetics hydrolysate
Cyanide produced during energetics neutralization process isn’t a public risk, but if not treated, could require additional protective measures during future plant operations in some work locations(Supercritical Water Oxidation Process feed preparation)
BGCAPP has focused on engineering controls and treatment of hazards, to provide better protection for workers during operations
Small piece of Composition B in an aluminum pan
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Treatment Approach
Year long collaborative effort among BGCAPP scientists, engineers and corporate subject matter experts
Mission focused on safely and efficiently treating cyanide hazard during energetics neutralization processing
Focus on energetics neutralization process
– Portion of process where cyanide first occurs
– Un-manned, automated process (i.e. no workers)
– Upstream before Supercritical Water Oxidation Process (where cyanide might have posed worker hazard)
Mettler RC1® Calorimeter Reactor at Battelle’s HERLA Used to Simulate BGCAPPEBH and ENR Operations
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A Safe Solution
Enhance auxiliary systems to Energetics Neutralization Reactors (ENRs) to increase operating temperature
– Safely and efficiently destroys cyanide
– Does not change neutralization process
– Does not alter Supercritical Water Oxidation process
– Does not impact weapons destruction baseline schedule
Auxiliary systems enhancements
– Insulating jacket placed around reactors
– Heat exchanger to increase temperatures
– Heat exchanger to cool sampling line
Munitions Demilitarization Building,ENRs (above). A representative heat exchanger (below).
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Without Treatment With Higher Temperature Treatment
Liquid(mg/L)
Air/Headspace (mg/m3)
Liquid(mg/L)
Air/Headspace (mg/m3)
Energetics Batch Hydrolyzers
600 non-detect 600 non-detect
Energetics Neutralization Reactors
350 non-detect 15 non-detect
Aluminum Precipitation Reactors
40 > 25 5 < 5
Aluminum Filtration System
20 > 25 < 1 non-detect
Anticipated Cyanide Concentrations
cyanide treatment occurs during this step
10
Pilot Plant cyanide levels are below worker safety regulatory standards
National Institute of Occupational Safety & Health assigns short-term maximum limit 15-minute time-weighted average, of 5 mg/m3 for hydrogen cyanide in air
Centers for Disease Control assign an Immediately Dangerous to Life or Health limit of 25 mg/m3 for hydrogen cyanide in air
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Questions & responses matrix
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Question Slide Number
Is one holding tank available to receive leaking tank contents? 12
Can HT/HP Treatment of EH be done on large scale without fouling/failures?
13
What does less than 5 mg/m3 mean? 10, 15
What are the effects of chronic low-level exposure to HCN for more than 15 minutes?
16
What are alarm levels and response actions? 17
Can you ‘hood ventilate’ the gas coming off APR and AFS? 18
Can filters be placed in process flow to capture HCN? 19
Will workers be screened prior to assignment to Supercritical Water Oxidation Process Building and will workers be periodically re-evaluated?
4, 5, 6, 20
Will dermal protection be provided? 4, 5, 21
Will workers receive post-work surveillance? 4, 5, 6, 22
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Questions & Responses (cont.)
Is one holding tank available to have leaking tank contents transferred to it in the event needed?
Both tanks may be in service simultaneously
Tanks are designed with both spill and overfill prevention controls
Spill containment = content of a tank + regulatory defined rainfall (25-year, 24-hour maximum rainfall) and freeboard
Spill response procedures define actions for rapid response to contain leaks
12
Hydrolysate Storage Area (above) construction is nearing completion.The Storage Area is designed and built (below) to environmental regulations.
Hydrolysate Storage Area design, construction and operations regulated by Kentucky Department for Environmental Protection, Environmental Protection Agency and in accordance with the Resource Conservation and Recovery Act (RCRA).
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Can High Temperature/High Pressure (HT/HP) Treatment of Energetics Hydrolysate be done on large scale consistently without fouling or failures?
Preliminary evaluation of fouling, corrosion, and downstream impacts performed
– Accumulated sludge-type material on reactor surfaces readily removed using water rinse
– Corrosion studies demonstrated nickel liner resistant over design life
– No impact to downstream processing or Supercritical Water Oxidation process
Evaluation of potential impacts continues:
– Further studies on potential fouling planned
Questions & Responses (cont.)
13
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The project stated that with a thermal treatment process, the building atmospheric concentrations would be reduced to less than 5 mg/m3. What does less than 5 mg/m3 mean? In other words, is it 0 or 4.9 mg/m3?
Bench scale analyses results:
– Filtercake “drying” air was nondetect for HCN at detection limit ~ 0.4 mg/m3
– Equilibrium headspace measurements of both moist and dry filtercake werenon-detect at detection limit ~ 0.7 mg/m3
– Exposure concentrations would be less than these values
Questions & Responses (cont.)
14
Energetics hydrolysate testing.
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Cont: The project stated that with a thermal treatment process, the building atmospheric
concentrations would be reduced to less than 5 mg/m3. What does less than 5 mg/m3 mean? In
other words, is it 0 or 4.9 mg/m3?
Existing design limits potential exposure:
Processes are largely contained:— APRs vent to carbon filters before release to atmosphere with calculated
emission levels much less than 1 short-term exposure limit (STEL) (5 mg/m3)
— AFS feed tanks/filtrate tank vent outside building
— Pressurized air pushes filtrate through filter, dries filtercake, passes to filtrate tank, and vents outside building
— Cyanide offgassing to building may occur drying and/or filtercake temporary storage in collection bins
Building ventilation lowers concentrations of potentially offgassed HCN— SPB equipped with four separate HVAC systems servicing the control area, RO room,
SCWO processing area and relief tank room, and Aluminum Precipitation (AP)/Aluminum Filtration (AF) room (i.e., AP/AF air is isolated from those areas with a higher occupancy rate)
— AP/AF ventilation system - 13,400 cfm and 2 roof exhaust air fans
Questions & Responses (cont.)
15
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What are the effects on humans of chronic low-level exposure (inhalation, ingestion and dermal) to HCN for more than 15 minutes? What level of atmospheric cyanide has no observable effects on workers?
Exposure concentrations expected to be much less than 1 mg/m3
Based on the automation used in the process, exposure durations expected to be much less than 8 hours/day(i.e., maintenance required to change disposable filter media roller (twice/week), drip pan cleaning (weekly), and other activities (weekly or monthly)
BGCAPP will perform a Health Hazard Assessment for the risks and minimize potential worker exposure
– BGCAPP relies on defined occupational exposure limits for HCN
– Mitigations may include engineering controls and administrative controls
– The Health Hazard Assessment establishes what type of personal protective equipment to use and when to use it
Questions & Responses (cont.)
16
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At what level would alarm systems be set? What is the response to an alarm? Don PPE or evacuate? How often and would HCN in the SPB be measured?
The HHA will consider monitoring requirements based on anticipated breathing zone concentrations and monitoring capabilities (i.e., estimated detection limits)
Monitoring will be conducted during start up operations to confirm estimates of breathing zone concentrations
Start-up operations will establish Energetics Neutralization Reactor (ENR) process parameters confirming destruction of cyanide at required levels to mitigate downstream risks
ENR process controls and monitoring results will establish necessity for additional monitoring
Questions & Responses (cont.)
17
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Can you ‘hood ventilate’ the gas coming off APR and AFS?
Aluminum Precipitator Reactor (APR) offgases through carbon filters to Supercritical Water Oxidation (SCWO) Process Building exterior
Aluminum Filtration System (AFS) vents to release points outside of SCWO Process Building
The design incorporates a roof-mounted exhaust fan to draw vapors from the filter cake bins
The Health Hazard Assessment will review the existing design, breathing zone concentrations, and exposure durations to identify the need for additional mitigation measures
Questions & Responses (cont.)
18
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Can filters be placed somewhere along the process flow to capture HCN prior to it entering the SCWO atmosphere?
Existing SCWO Process Building design minimizes worker exposure:
– The Aluminum Precipitation Reactors (APRs), vent to carbon filters and then outside the building with calculated emission levels much less than 1 short-term-exposure limit (STEL) (5 mg/m3)
– The Aluminum Filtration System (AFS) feed tanks and filtrate tank vent outside building
– The pressurized air used to dry the filtercake passes to the filtrate tank where it is vented outside building
– A roof-mounted exhaust fan draws vapors from filtercake bins to building exterior
The Health Hazard Assessment will identify the need (if any)for additional mitigation measures
Questions & Responses (cont.)
19
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Will workers by screened prior to assignment to SPB for things like thyroid disorders, neurological disorders, normality of liver/renal functions, smoking, pregnancy and child-bearing age females, and cardiovascular problems? Will physical pre-screens and laboratory baselines for blood/urine be conducted and periodically re-evaluated?
BGCAPP workers undergo medical screening at time of employmentfor specific duty fitness requirements
Screening requirements are determined in accordance with Medical Screening Program
For, HCN, the Health Hazard Assessment will establish whether expected exposure conditions in the SCWO Process Buildingwarrant additional measures to control exposure
Hazards will be addressed through a comprehensive workplace Hazard Communication Plan, through existing engineering controls, and through administrative controls
Questions & Responses (cont.)
20
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What about dermal protection if HCN is not significantly reduced below 5 mg/m3?
The established operational exposure limits consider contributions from dermal exposure and therefore are considered protective
Expected building air will be less than 1 mg/m3
Questions & Responses (cont.)
21
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Will workers receive post-work surveillance? If yes, for how many months or years?
The currently expected exposure concentrations/durations do not warrant implementation of post-work surveillance
The Health Hazard Assessment determines whether mitigation measures or medical surveillance is required to address the potential for chronic worker exposure
Questions & Responses (cont.)
22