Outstanding Environmental and Occupational Health Issues - Comparing the Situation in the United States and Globally


Tuesday, May 24, 2016, 2:00 PM - 4:40 PM


Investigation and Remediation of a Former Cadmium Telluride (CdTe) Solar Panel Manufacturing Facility

R. Strode, C. Strode, W. Mele, S. Funk, and D. Hall, Chemistry & Industrial Hygiene, Inc., Wheat Ridge, CO

Situation/Problem: A former solar panel manufacturing facility utilizing a CdTe thin film technology closed abruptly, leaving behind contaminated equipment and building surfaces. The building owner ultimately assumed responsibility for characterization and remediation, utilizing a voluntary clean up option. Without consensus standards, and with limited regulator experience ​​​with surface clean-up actions, the owner was required to propose and negotiate a remediation plan with State risk assessors to achieve a mutually acceptable clean-up. The RI/RA plan needed to characterize and remediate the building and equipment with the ultimate goal of achieving safe reoccupancy and a no further action (NFA) letter from State regulators. Due to the nature and extent of site contamination, a multidisciplinary approach was implemented that involved a significant IH component.

Resolution: A thorough review of the available literature was performed to identify existing surface standards and guidance criteria, and to identify potential detection limits and endpoints for investigative data and risk-based clearance criteria. Site-specific sampling, exposure, and risk assessment methods were developed and negotiated with regulators to achieve risk-based clearance concentrations for scope and NFA requirements. Industrial hygiene principles and methods played a key role since equipment and building surface contamination are rarely associated with voluntary clean-up actions, and the RI required novel surface sampling approaches.

Results: Surface concentration guidance criteria and sampling methods were identified from multiple sources, and selected methods were used to characterize existing contamination and develop a RA scope. Health-based clearance standards were then developed in cooperation with State regulators utilizing site-specific data and US EPA environmental risk assessment methods. DQOs were established for clearance standards, and the RI/RA activities successfully achieved the cleanup goals, allowing reoccupancy and receipt of a NFA from the State regulators.

Lessons learned: Industrial hygienists may be uniquely qualified to support atypical environmental cleanups due to their knowledge base regarding sampling, analysis, exposure, and risk assessment methods. Establishing surface clearance criteria presented a unique challenge from both a characterization and remediation perspective. Risk-based cleanups for building and equipment surface contamination can be accomplished using a multidisciplinary approach.



Environmental Forensic Investigation of Surface Particulates in a Residential Community, Allegedly from Foundry Fugitive Emissions

J. Kominsky, Environmental Quality Management, Inc., Cincinnati, OH

Situation/Problem: A residential neighbor alleged the source of “dark particulate-like material” present on exterior surfaces (e.g., lawn furniture) was fugitive particulates from a ferrous foundry. Study objectives were to determine the chemical and physical characteristics of the material and compare the particulate to known particles from the foundry that produces ductile and gray iron castings.

Resolution: Potential source particulate samples (air and surface) obtained from the foundry were examined using polarized light microscopy (PLM) and scanning electron microscopy (SEM) techniques to establish source fingerprints based on particle morphology and individual particle compositions. Suspect particulate samples (wipe and tape-lift) were examined using direct phase contrast optical microscopy (PCOM), PLM, and SEM to determine whether the particulate matter had characteristics similar to the potential source samples. Prevailing wind conditions (wind direction and speed) were determined over 12 years from data obtained from a NOAA Regional Climate Center.

Results: PLM analysis of potential source surface dust samples showed that quartz, iron oxide, and iron spheres were major components; SEM-EDS identified iron spheres, quartz, and magnesium/aluminum-rich silicate particles. SEM-EDS analysis of airborne particulate obtained from process emissions identified iron spheres, magnesium oxide particles, and magnesium/aluminum-rich silicate particles. Analyses indicated that magnesium oxide and magnesium/aluminum-rich particles represented a chemical fingerprint of particulate generated from melting and pouring operations. Direct PCOM examination of tape-lift samples collected of the dark particulate-like material showed the dominant presence of fungal conidiophores, vegetative fungal structures, and fungal spores. PLM examination of tape-lift samples showed dominance of mold/biofilm. SEM-EDS analysis showed the presence of silicate particles. However, the silicate particles were inconsistent with the magnesium/aluminum containing silicates present in surface and airborne particulate samples obtained from foundry operations.

Lessons learned: Dark particulate-like material on outdoor surfaces at the residential property was predominantly fungal matter. Identification based on presence of common silicate particles would have falsely indicated that fugitive particulate from foundry emissions was also present on the outdoor surfaces.



Nuclear Regulatory Commission Groundwater Supplemental to the Environmental Impact Statement (EIS): A Critique on Scientific and Regulatory Issues

J. Paz, Dr. Jacob Paz Consultant, Henderson, NV

Situation/Problem: On Aug 15, 2015 the NRC published a draft Supplement to the groundwater environmental impact statement (EIS) related to the proposed Yucca Mountain Project (YMP) and stated the following: “The NRC staff concludes that the estimated radiological doses are SMALL because they are a small fraction of the background radiation dose of 300 mrem/yr. (including radon), and much less than the NRC annual dose standards for a Yucca Mountain repository in 10 CFR Part 63, 15 mrem for the first 10,000 years, and 100 mrem for one million years, after permanent closure. Based on conservative assumptions about the potential for health effects from exposure to low doses of radiation, the NRC staff expects that the estimated radiation dose would contribute only a negligible increase in the risk of cancer or severe hereditary effects in the potentially exposed population. Impacts to other resources at all of the affected environments beyond the regulatory compliance location from radiological and nonradiological material from the repository would also be SMALL.”

Resolution: The NRC conclusion raises very serious scientific issues and possible noncompliance with the NEPA Act of 1969, and its regulations, including U.S. Supreme Court ruling in the cases of: Kloppe v. Sierra Club, 1976 (synergism), and the Citizens to Preserve Overton Park, Inc., et al., v. Volpe, Secretary of Transportation 1971.

Results: There is lack of credible scientific input into DOE Model to support the NRC calculation and analysis since: 1) unanswered questions exist: will the waste canisters be corroded or not? 2) the DOE-YMP sorption model did not consider the competing effects between radionuclides and metals in the near field, 3) why was chromium, a potent carcinogenic agent and a component of the waste canisters, not considered in the Armargosa Farm groundwater? and 4) should the NRC or the DOE study the risk associated with mixtures of metals and radionuclides?

Lessons learned: Provide credible scientific evidence and all applicable regulations



Remediation of Semiconductor Facilities in International Practice: Challenges and Solutions

E. Sawicki, Microsafe, Santa Clara, CA

Situation/Problem: With the move of the Semiconductor Industry from Silicon Valley to Shanghai, legal closures of Semiconductor Fabrication Factories within the heavily governmental regulated Silicon Valley were closely monitored by regulatory agencies. This presentation will take the audience through the regulator maize based on case histories.

Resolution: Hazards encounter in closing these factories are unique to the Semiconductor Industry. Toxic, pyrophoric, shock sensitive, and corrosive hazards to decontamination technicians and the surrounding community are reviewed. Effective engineering controls to mitigate these hazards are demonstrated. The presenter will reveal his unique long-term experience in effective closure projects.

Results: The Semiconductor closure process goes from good preplanning, regulatory notification, decontamination, shipment of hazardous waste, testing, post closure documentation and regulatory and landlord signoff.

Lessons learned: When properly done, these closures prevent environmental and occupational health effects. When improperly done, closures of semiconductor facilities can lead to hundreds of millions of dollars in losses and adverse health outcomes. It is vital to share the experience and success stories for a wide audience of industrial hygienists, environmental professionals, and regulators.



Asbestos Changes in Australia—Is There a Role for Occupational Hygienists?

S. Clarke, AIOH, Launceston, TAS, Australia

Situation/Problem: Prior to 2012, work health and safety legislation varied between all of the Australian states and territories. Recently, National Model legislation and Codes of Practice have been developed and adopted by most jurisdictions. Part of this change includes the role of Licensed Asbestos Assessor, a role previously less formal, but reserved for Occupational Hygienists. Now, this license can be gained after a 5 day training program and any experience in the asbestos industry. This increase in Licensed Asbestos assessors, without the mentoring of experience Occupational Hygienists, risks reducing the level of independence and scrutiny within the asbestos industry.

Resolution: With an influx of Licensed Asbestos Assessors, we need to either compete for this traditional role, or reconsider our role in the asbestos industry. Some ideas tested include: 1. Educating the market of our profession. Occupational Hygienist is not well recognised in Australia. 2. Value-adding to the traditional asbestos role by utilising our other skills. 3. Creating a new role for Occupational Hygiene in the Asbestos Industry. One that cannot be conducted by any Licensed Asbestos Assessor. This may involve strategic alliances with our competitors.

Results: With respect to the points above, and in the opinion and experience of one humble COH: 1. We have been successful in educating many of our clients, but have picked our battles with others. We know that price not value is the key in decision making. 2. Where possible, we have moved away from the previous model of working directly for the Asbestos Removalist, enabling us to build relationships directly with the client. This provides opportunities beyond asbestos work. 3. We've created additional services, like providing nationally certified Asbestos Assessor training to future competitors, as well as mentoring and practical training programs.

Lessons learned: 1. Don't lose sight of our role. The art and science of Occupational Hygiene first, not consultant! 2. Don't overplay the risk. Accept that we are overqualified for some jobs, so need to stop competing with non-Occupation Hygienists. 3. Don't fight change. It is inevitable and we need to evolve with it.



Industrial Hygiene and Worker Welfare at the Barzan Onshore Project

R. DeHart, Rasgas Barzan Project, Ras Laffan Qatar, Matthews, NC; R. Zamuco and J. Brand, JGC Corporation, Al Khor, Qatar

Situation/Problem: The Barzan Gas Project is being developed by Barzan Gas Company Limited, a joint venture between Qatar Petroleum and ExxonMobil Barzan Limited, with RasGas Company Limited assigned to develop and operate the facilities. The project is located in Ras Laffan Industrial City in Qatar, and is situated on a greenfield site. The project manpower peaked at 30,000 in 2014 with a multinational workforce of 45 nationalities, speaking 20+ languages. This paper illustrates various industrial hygiene and worker welfare activities undertaken by the project to provide workers with a safe and healthy workplace and a comfortable and safe living camp environment.

Resolution: Worksite health and hygiene activities included: monitoring surveys for noise, toxic gases, vibration, breathing air quality, particulates, organic solvents, radiation, heat stress, confined space ventilation and drinking water quality; hygiene specific training courses; and a fitness to work review including respiratory fitness testing. Worksite monitoring has been mainly focused on determining the magnitude of hazards generated for a particular work activity. Follow-up verification of the effectiveness of implemented control measures was based on the actual exposure to these hazards.

Results: Significant efforts have also been expended in the three worker accommodation camps to meet requirements for worker welfare including living accommodations, menus, recreational facilities and internet cafes. For camp infrastructure, routine health and hygiene inspections for food and life safety are performed in the canteens, kitchens, accommodations, laundry services and recreational areas. Ongoing field inspections and surveys have ensured that an environment of continuous improvement in health and hygiene is fostered for camp operations in the following areas: canteens, kitchens, accommodations and ablution facilities; recreational facilities; and overall improvements for personnel transportation from the camp to the worksite.

Lessons learned: In summary, the project’s efforts for workers’ health and safety, and related worker welfare activities have successfully contributed to a positive and sustainable safety culture within the Barzan Onshore Project.



Developing Sustainable Industrial Hygiene Program in the Region by GE

S. Ranpura, GE, Bangalore, India

Situation/Problem: India is the second largest country in world where workers are employed in the manufacturing sector. Local regulations do not have robust Industrial hygiene requirements for industry to follow and it is up to the employer to develop, implement and maintain industrial hygiene programs. Multinational companies have their own standards, which often exceed the local IH requirements. The challenge is to implement a robust IH program with quality. The social culture outside the factory is not of high standard with poor hygiene practices, which alters program management inside the factory for acceptability among workers. Lack of educational background is another challenge to implement sustainable IH programs.

Resolution: An industrial hygiene program containing comprehensive industrial hygiene risk assessment is implemented across a region. IH program element contained: program responsibilities, implementation methods, communication, training and effectiveness evaluation. Each element was owned by a champion from the shop floor for effective implementation. Maintaining quality during implementation of IH program is a key challenge due to lack of educational background and culture.

Results: Substantial results were achieved by implementing an IH program. These included zero occupational injuries, increased employee satisfaction, a better workplace with reduced occupational hazards, prioritizing risk and technical justification to fund industrial hygiene infrastructure like noise control and ventilation system improvements, substitution of hazardous chemical with less hazardous chemical, and reduced personal exposure to workplace chemicals. Various ways were adopted to ensure quality assurance during implementation of IH program.

Lessons learned: Do not get discouraged with cultural and educational limitations. Focus on core IH areas and train employees on sustaining IH programs. We can change the culture with effective program implementation.​