## OAP-2004-01: Formal Report for the Operational Awareness Program (OAP) Walk-Through of the Chemical Sciences Division (CSD) Performed in February and March 2004

## 

## 

## Introduction

The OAP is in the process of being redesigned to incorporate a
performance based approach along with the compliance component. This
redesign resulted in changes in OAP management and goals. Due to these
changes, the CSD OAP compliance assessment was conducted in two parts.
The first part was initiated in October 2003 and continued through
December 11, 2003. Results were presented to the operations manager as
prescribed under the former OAP process. The second part of the OAP
assessment began February 5, 2004, with the final walk-through on March
11, 2004. This report covers the second part of the OAP assessment.

The CSD point-of-contact for each walk-through was Kim Jeskie,
Operations Manager. The facilities toured were located in Buildings
4500S, 5505, 5507, 5507A, 2026, 7900, and 7920. The last OAP
walk-through of CSD facilities was performed in July 1999.

Each walk-through took approximately 3.5 hours and was performed on
Thursday mornings. After each walk-through, immediate feedback was
provided to the operations manager during a debriefing with OAP members.
The specific walk-through observations included noteworthy practices,
items of concern, non-compliance issues, and "best management practices"
(BMP). All walk-through field observation notes were sent to Ms. Jeskie
for factual accuracy review within one week of each assessment. These
finalized weekly field notes, which document the weekly assessments, are
provided in Attachment 1. All walk-through assessment notes were the
summation of both ORNL and DOE representatives. OAP team members for
this assessment are listed in Attachment 2.

### Summary of Results

The field notes containing the OAP team's observations were used as
documentation in determining note-worthy practices and the major items
of concern or non-compliance issues. It is recommended that CSD address
these items and take action to mitigate the causes of existing
non-compliances, deficiencies, or other undesirable situations in order
to prevent recurrence.

A total of 284 observations were made during the walk-throughs. The
observations are categorized into five areas: Environmental,
Radiological, Safety, Noteworthy Practices, and Other. Approximately 56
percent of the observations noted for CSD were categorized under Safety.
Environmental accounted for 14 percent of the total observations while
Radiological was 4 percent. The Other category, which consists of
observations concerning calibration, training, and BMP accounted for 22
percent of the observations. Noteworthy Practices consisted of 4 percent
of the observations. A detailed breakdown of the observations can be
found in Attachment 3.

##### Interpretation of Requirements

Interpretation or clarification of requirements was occasionally
required during the assessment. These items are addressed in this report
to ensure a consistent understanding of the requirements for future use.

Interpretation was required for the requirement concerning the labeling
of secondary solutions. The Subject Matter Expert (SME) was contacted on
February 18, 2004, by an OAP team member, Angela Barnard, for
clarification on the requirement in regards to the hazard information
from the primary container and what was considered readily available.
The SME defined readily available as staff knowing where the primary
container was located and staff being able to access the material safety
data sheets during the work shift. Refer to Section 7.5.2 of the ORNL
Chemical Hygiene Plan for the guidance in question:

<http://sbms.ornl.gov/sbms/sbmsearch/subjarea/chemsafe/chp1.cfm>.\
 \
Secondary containers must be marked or labeled with the identity and
concentration, if known, of their contents. Although dates of
preparation are recommended for all containers, this information is
required only for those containers where the contents may become
unstable with time. When the marking/labeling is impractical due to the
size of the container, area labeling, such as of a tray in which the
container sits, may be used. This method for labeling secondary
containers is acceptable only when the hazard information from the
primary container is readily available. Employees must be aware of the
location of the primary container. If the primary container is not
available, a complete label including hazard warning as described under
the \"Primary Chemicals Containers" section in the reference above, is
required.

Note: All containers containing a chemical must be identified with a
label, except when they are intended for the employee\'s immediate use,
are to be used in the employee\'s work shift, and remain under the
employee\'s control. In short, if you leave it unattended it must have
some type of label.

#### Laboratory-Wide Issues

Some issues were noted as items that occur not only in CSD but are
common issues across other divisions and require senior level management
participation for satisfactory resolution. These items are discussed
here.

1.  Flammable liquids are currently stored in asbestos-lined
    cabinets/compartments beneath hoods in several areas. The Operations
    Manager pointed out the Fire Department has allowed this practice
    due to the limited volume of flammables. Fire Protection Engineering
    (FPE) personnel were contacted and further investigation has
    indicated the built-in flammable storage cabinets that are located
    under the hoods in 4500S laboratories no longer meet fire codes
    according to Fire Protection Engineering personnel (email from
    Gordon Earhart dated March 9, 2004); refer to Attachment 4. These
    cabinets are useful as ordinary cabinets, but are not flammable and
    combustible liquids storage cabinets.  Small amounts (e.g., small
    aerosol containers or lab squeeze bottles) of flammable and
    combustible liquids may be in this type of cabinet in accordance
    with the guidance from the Fire Protection, Prevention, and Control
    subject area and the Chemical Safety subject area.

2.  Peeling paint from walls and ceilings was seen in many laboratories.
    A few staff have resorted to covering their immediate work areas
    with plastic to keep paint debris out of their work. Also, paint
    peelings may contain PCBs and/or lead depending on the age of the
    paint.

3.  There is concern about the level of detail required in a Research
    Safety Summary (RSS). Some are written to cover several areas and
    activities making it difficult to determine the specific
    requirements and hazards associated with a specific work activity.

[Noteworthy Practices]{.underline}

1.  The operations manager, Ms. Jeskie, was the single point of contact
    for all of the walk-throughs. She was very knowledgeable and
    responded to all team questions and concerns promptly. The OAP team
    appreciated her cooperation and professionalism during the
    assessment period.

2.  There was a noted improvement in the area of housekeeping for some
    of the areas since the last assessment.

3.  The Laboratory Space Manager notebook compiled for Building 5507A
    was considered a BMP. This notebook contained information relative
    to the authorization and operation of the building in a neat and
    concise format.

[Items of Concern or Non-compliance]{.underline}

It is recommended that CSD address the items listed in this section.
These items were listed due to the possible risk that they pose for
staff safety or the environment and/or the percentage of observations in
relation to the total number of observations within a category.

Safety Observations

1.  It was extremely difficult to hear the public address system
    announcements while performing the February 5, 2004, walk-through in
    some of the laboratory spaces. The Operations Manager indicated this
    was a problem in other areas of the building. There is a concern
    that personnel working in these areas would not be able to hear an
    emergency announcement and take appropriate action.

2.  In the basement of building 5507, water was leaking from an overhead
    pipe. The water on the floor from the leak is located beneath an
    electric-powered generator and near a storm drain. The potential
    exists for electric shock. The operations manager reported this
    issue to the responsible group leader. CSD should follow-up on this
    issue to ensure the problem has been corrected.

3.  Several observations concerned electrical issues such as cracked and
    frayed cords, piggybacked extension cords and clearance for
    electrical panels. Refer to

<http://sbms.ornl.gov/sbms/sbmsearch/subjarea/elec/exh_elecrules.cfm>.
This

observation was noted several times in the OAP 1999 report.

4.  Several observations concerned the improper storage and labeling of
    hazardous chemicals. For guidance refer to the following:

> <http://sbms.ornl.gov/sbms/sbmsearch/subjarea/chemsafe/chp1.cfm>
> <http://sbms.ornl.gov/sbms/SBMSearch/SubjArea/Chemsafe/RecIndPrac.pdf>.
>
> This observation was noted several times in the OAP 1999 report.

5.  Improper storage of flammable chemicals and unlabeled or incorrectly
    labeled flammable storage cabinets were noted in several areas.
    Refer to

> <http://sbms.ornl.gov/sbms/sbmsearch/subjarea/chemsafe/chemsafepro4.cfm>.

Environmental Observation

6.  Several Satellite Accumulation Areas' logbooks need improvement in
    documentation of waste identification, traceability and disposal
    dates. For guidance refer to

> <http://sbms.ornl.gov/sbms/sbmsearch/SubjArea/Hmwm/HMWMpro3.cfm>
> Although not required, it is recommended that the \"Satellite
> Accumulation (SAA) Inspection Form\" be utilized for each SAA as a
> BMP. This checklist can be found at
> <http://home.ornl.gov/general/forms/pdf/ORNL-SAA.pdf>

Radiological Observation

7.  OAP team members discovered elevated radiological levels during the
    walk-throughs on February 5, 2004, in Building 4500S, Room S215,
    concerning a sink; on February 12, 2004, in Room S255, concerning a
    sink; and Room S235, involving drawers from a wooden toolbox. As a
    result, the Radiation Control Technician(s) assigned to these
    specific areas was requested to perform a more comprehensive
    radiological survey. Further investigation by the radiological
    control technicians resulted in two occurrence reports
    (ORO-ORNL-X10CENTRAL-2004-0001 and ORO-ORNL-X10CENTRAL-2004-0004).

Other Observation

8.  Laboratory personnel training qualifications need to be updated. A
    random number of laboratory user's training files were reviewed on
    the SAP system. Several deficiencies were noted with training
    pertaining to the Waste Certification Program-General Awareness
    training, No-rad added training, and RCRA SAA training. The
    Operations Manager stated that it had been several years since the
    CSD laboratory personnel had uniformly revisited their training
    baselines. Some module numbers and qualifications have changed
    during that time and the CSD records are in need of updating. SBMS
    training guidelines for use and handling of hazardous chemicals can
    be found at:

> <http://sbms.ornl.gov/sbms/SBMSearch/SubjArea/Chemsafe/chemsafepro8.cfm>.
> It is recommended the CSD laboratory personnel revisit the ORNL
> Institutional Training Requirements Development Tool located at:
> <http://train.ornl.gov/itrm/>. There is a concern that staff may not
> have the necessary training to adequately perform work in a safe
> manner.

**Conclusion**

CSD has made improvements in response to the laboratory certification
process and has implemented a corrective action program to correct
additional problems self identified during their certification process.
During the walk-throughs, the operations manager took immediate action
when OAP team members noted items that needed immediate attention. Many
observations noted in the field reports could be easily resolved with
the implementation of a preventative maintence program (e.g. electrical,
calibration, gas cylinders). It is recommended that CSD use this report
as part of their continued efforts for process improvement.

**ATTACHMENT 1**

Finalized Field Notes

**Date:** February 26, 2004

**To:** K. Jeskie

**ec:** G. Anderson M. Henderson

> A. Barnard L. Manis

M. Belvin J. Pearson

> C. Cantwell B. Powers
>
> R. Chung M. Robinson
>
> T. Cochran P. Scofield
>
> J. Flynn C. Stachowiak

**Subject: Revised Finalized Field Notes from Operational Awareness
Program Walk-Through Performed on 2/5/04.**

**From:** Angela Barnard

On February 5, 2004, OAP Team members participated in a walk-through
assessment of Chemical Science Division laboratories R223, R227, R231,
R235, S207, S211, S215, and S219, which were located in Building 4500S.
The following persons participated in the walk-through:

> A. Barnard L. Manis
>
> M. Belvin J. Pearson
>
> R. Chung B. Powers
>
> T. Cochran P. Scofield
>
> J. Flynn C. Stachowiak

M. Henderson

The following observations were noted by the visiting team and are the
summation of both the ORNL ES&H and DOE ES&H disciplines.

**General Comments:**

1.  All labs toured today looked much better housekeeping-wise than most
    of those toured last fall.

> 2\. It was extremely difficult to here the public address system
> announcements while performing the walk-through in the laboratory
> spaces. The Operations Manager said this was a problem in other
> laboratories as well.

3.  All flammable liquids were stored in asbestos-lined
    cabinets/compartments beneath hoods in several areas. The Operations
    Manager pointed out the Fire Department has allowed this practice
    due to the limited volume of flammables. OAP and CSD personnel have
    contacted the Fire Protection Engineering (FPE) personnel and have
    received some information on this issue. (See attachment 1).
    However, there are on-going discussions between OAP and FPE
    personnel for clarification.

Doors to asbestos-lined flammable storage compartments/cabinetry beneath
hoods were not marked flammable storage area. This practice was observed
in storage areas in several labs. Refer to SBMS subject area "Chemical
Safety- Storing and Handling Flammable and Combustible Materials"
located at

> <http://sbms.ornl.gov/sbms/sbmsearch/subjarea/chemsafe/chemsafepro4.cfm>.

4.  Several outdated documents (HMIS lists, Chemical Hygiene Plan,
    radiological surveys, etc.) were in the laboratories. The laboratory
    should ensure that posted HMIS inventory sheets, procedures and
    plans reflect the most recent revisions. Several "historical" survey
    maps that were noted on hoods and pipe chases were at one time
    de-posted or found "clean", dating back 10 to 12 years.  These
    should be removed by Radiological Support Services (RSS) personnel
    and sent back to the HP field office file for future reference
    before a current survey is performed.  The conditions stated at that
    time may be considerably different from today.

5.  There were no RCRA SAA inspection checklists available at any RCRA
    Satellite Accumulation Areas (SAAs). Although not a requirement, it
    is recommended as good laboratory practice. An example checklist may
    be found at:
    <http://sbms.ornl.gov/sbms/SBMSearch/SubjArea/hmwm/epp01ac.cfm>.

6.  Laboratory personnel training qualifications need to be updated. A
    random number of laboratory user's training files were reviewed on
    the SAP system. Several deficiencies were noted with training
    pertaining to the Waste Certification Program-General Awareness
    training, Non-rad added training, and RCRA SAA training. The
    Operations Manager stated that it had been several years since the
    CSD laboratory personnel had uniformly revisited their training
    baselines. Some module numbers and qualifications have changed
    during that time and the CSD records are in need of updating. SBMS
    training guidelines for use and handling hazardous chemicals can be
    found at:
    <http://sbms.ornl.gov/sbms/SBMSearch/SubjArea/Chemsafe/chemsafepro8.cfm>.
    It is recommended the CSD laboratory personnel revisit the ORNL
    Institutional Training Requirements Development Tool located at:
    <http://train.ornl.gov/itrm/>.

7.  The laboratories contained many primary and secondary chemicals. The
    laboratory users should ensure that all primary and secondary
    labeling comply with Section 7.5.2 of the ORNL Chemical Hygiene
    Plan, located at
    <http://sbms.ornl.gov/sbms/sbmsearch/subjarea/chemsafe/chp1.cfm>.
    Proper labeling of primary and secondary chemicals will be verified
    during future OAP visits.

**Room R223**

1.  The plastic shield used for containment of UV light from the
    instrument was not stabilized and could easily be knocked down.

2.  There was an instrument lying on a desk/table/cart. The face of the
    instrument identified it as a "Certified Hygrometer." There was no
    calibration sticker on the instrument.

3.  The following out-of-date documents were in the laboratory. All
    except item d were removed during the assessment.

    a.  Chemical Hygiene Plan dated April 14, 2000

    b.  Project report dated February 1, 2002

    c.  ES&H Evaluation and Summary dated May 15, 1999

    d.  A radiological survey map from 1992

4.  A sheet of paper that contained laser operating instructions was
    hanging near a laser. There was nothing on the paper that indicated
    who had reviewed or approved these operating instructions.

5.  The door to the laboratory is interlocked to turn off the laser if
    the door is opened. There are two limit switches that serve as
    redundant interlocks. It is not clear that these are tested in such
    a way as to verify that both interlocks are functional.

6.  A few small cylinders were stored with regulators

7.  Extension cords were piggybacked.

8.  There was a question regarding whether the metal table was grounded
    properly.

9.  The floor drain label needs replacing.

10. The room needs a few new ceiling tiles.

**Room R227**

1.  There was no secondary containment for the plastic and glass
    drainage bottles located on the floor in the back of the room. The
    bottles could easily be knocked over.

2.  Two balances were out of calibration as indicated on the calibration
    stickers with an expiration date of 7/13/03. The laboratory stated
    these balances were in use.

3.  A boom-like piece of equipment used for hoisting/rigging was
    attached to a load. The Quality sticker on the equipment indicated
    inspection was due in February 2003. There was also a signoff sheet
    attached that was initialed by the user when the device was actually
    used. This was most recently initialed on October 11, 2003.

4.  An instrument (M097600) had a calibration due date of July 2003,
    according to the calibration sticker on the instrument.

5.  An instrument (M071964) had a calibration due date of November 1998,
    according to the calibration sticker on the instrument.

6.  Peeling paint on the wall by the sink was observed.

7.  The protective cover for the furnace in the hood had been burned
    though in a few places. It is recommended the protective covering be
    replaced**.**

**Room R231**

1.  The East hood is posted as a "Contamination Buffer Area & Radiation
    Buffer Area."  From the posted radiological survey map, the
    Radiation Buffer Area posting is not warranted by the dose rates
    shown and the apparent occupancy factor wouldn't warrant the posting
    for the possibility of anyone receiving 100 mrem in a year.

2.  On the northside wall, there was significant paint peeling

3.  The glass disposal containers were filled to capacity. It was stated
    these would be treated as radwaste and the laboratory was waiting
    for pick-up.

> 4\. The storage cabinet used for acids needs to be labeled "Acid
> Storage".

5.  Tethylammonium hydroxide, a flammable liquid, was stored on the
    counter with 0.1N Ammonium hydroxide. Flammable liquids should be
    stored properly in a flammable storage cabinet when not in use.

6.  Improper storage of a Class IC flammable liquid CAS 107-15-3
    (ethylenediamine). Item was not in a flammable storage cabinet,
    stored with solids, and not in secondary containment.

7.  Chemicals located in the storage cabinet near the entrance appeared
    to be stored in alphabetical order. There is a concern whether
    chemical compatibility was considered. These chemicals should be
    stored in accordance with
    <http://sbms.ornl.gov/sbms/SBMSearch/SubjArea/Chemsafe/RecIndPrac.pdf>,,
    which states "Do not store chemical alphabetically as a general
    group. Chemicals may be separated into compatible groups and stored
    alphabetically within compatible groups".

**Room R235**

1.  The balance did not contain a calibration sticker.

2.  A four-wheeled cart was found probing up to 250 counts/minute
    beta-gamma. It was later determined that the elevated counts were
    from potassium hydroxide which is a naturally occurring radioactive
    material.

3.  Two satellite accumulation areas, 39 and 966, had no well-defined
    boundaries. This is considered a Good Laboratory Practice since,
    SBMS does not require that boundaries be identified.

4.  RCRA Satellite Area 39 was filled to physical capacity. An unlabeled
    dessicator filled with small vials was identified in the SAA area.
    It was removed during the visit.

5.  Old bottles of acids were observed under the hood (east side of
    lab). It was undetermined if these acids are used. If not, proper
    disposal is recommended.

6.  A stepladder that could be used to reach materials located on the
    upper shelves was not available.

7.  The eyewash located in the hallway outside Room R-235 expired as of
    January 2004.

8.  The eyewash in the laboratory near the sink does not have an
    expiration date on the eyewash solutions (2) and the security seals
    were still on the caps, preventing immediate access in case of an
    emergency.

9.  The index card containing the oven setting information for the
    Thelco Oven Model is disintegrating

> 10\. Improper chemical storage of toxic, corrosive, and water-reactive
> chemical in a flammable cabinet. Thionyl chloride (CAS 7719-09-7,
> RECID 01087) is not flammable.

**Room S207**

1.  The front exit was partially blocked with a gas cylinder dolly.

2.  Sodium hypochlorite was stored with acids.

3.  A beaker clamp was found probing to 150 counts/minute beta-gamma.

4.  There were regulators on a few lecture bottles found in the drawer
    labeled 'lecture bottles'.

5.  No stepladder was observed that could be used to access materials
    located on upper shelves.

6.  The glass disposal containers were filled to capacity. It was stated
    these would be treated as radwaste and the laboratory was waiting
    for pick-up.

7.  Loose steel tubing was observed under the bench, which could result
    in a slip/trip hazard. In other laboratories we observed metal trays
    used to confine similar tubing.

8 The Narco Model 5831 Vacuum Oven did not have a "Hot Surface" label
attached.

9\. There were two post-it notes with critical information attached to
the Doric thermocouple indicator.

10. The PDR-D-1 Readout Pressure gauge was taped together with non
    electrical tape and was sitting on a wood block which was not
    secured to the counter.

> 11\. Blue electrical power strip in use without UL labeling on it.
> (Manufacturer SL Waber)
>
> 12\. Small cylinder of bromine pentafluoride (CAS 7789-30-2), an
> oxidizer was stored in a flammable gas cabinet but within 20 feet of a
> cylinder of flammable gas (hydrogen).
>
> 13\. Four electrical cords had inspection stickers labeled "Inspection
> due 1997". One electrical cord had an inspection sticker labeled
> "Inspection due 1995". It is recommended that the stickers be removed
> since inspections of electrical cords are no longer performed.

**Room S211**

1.  A wooden tool drawer was found probing to 250 counts/minute
    beta-gamma.

2.  A floor drain was plugged with what looked like a rubber stopper,
    which is not a proper floor drain plugging method. Contact Charles
    Valentine if you have any questions regarding proper drain plugging
    methods.

3.  Flammable chemicals were not stored in a flammable storage cabinet
    and the cabinet was not labeled as containing flammable substances.
    Also one chemical container was stored with a cardboard sleeve
    (which was removed).

4.  VWR Scientific Products Oven and Blue M Oven (X80648) do not have
    "Hot Surface" labels attached to them.

5.  There was a satellite accumulation area (SAA) check sheet lying next
    to the SAA. The check sheet was dated July 30, 1996. The operations
    manager removed the check sheet at the end of the walk-through.

6.  RSS1611 identified training requirements "based on requirements of
    neutron or X-ray user facilities." It is not clear what this means.

7.  The laboratory contained a chain fall that was used to lift the head
    off a reactor. RSS 1611 required an "attached job aid to ensure user
    inspection before each us." No such job aid was attached.

8.  RSS 1611 also said there was no pressure vessels as defined by the
    American Society of Mechanical Engineers (ASME) Boiler and Pressure
    Vessel Code (B&PVC) because there were no vessels that exceeded the
    B&PV limits. The B&PVC defines the limits as "vessels having an
    inside diameter, width, height, or cross section diagonal not
    exceeding 6 in." However, there was a reactor in the laboratory that
    had an inside diameter considerably larger than 6 in. A researcher
    said the reactor had been evaluated by a committee, now defunct, and
    was judged not to be a pressure vessel per the B&PV code
    requirements, because it operated at less than 1000 psig. The B&PVC
    excludes vessels from the B&PVC requirements if the vessels have "an
    internal or external operating pressure not exceeding 15 psi
    (103kPa)."

9.  A plastic cylinder approximately 4 feet tall was near the room
    entrance. This cylinder was free-standing (not attached or secured).
    The Operations Manager moved the cylinder to a secure location
    during the visit.

**Room S215**

1.  The RCRA SAA 17 logbook entries were difficult to follow. There were
    several waste containers of nitric acid, but no unique waste
    container identifiers were evident to verify if all the nitric acid
    waste was from the same or different sources. For wastes containers
    that contained identification, it was difficult to link them to the
    waste log. The waste log contained entries that could not be
    associated with waste containers currently in the SAA.

2.  The East sink was found probing to 200 counts/minute beta-gamma. On
    2/6/04, the Oak Ridge Operations Office requested that ORNL
    Radiation Control Technicians conduct a survey. The results of this
    survey are in Attachment 2. It was determined that the area is
    within the ORNL controlled area boundaries and no personnel received
    a radiological exposure. This report was sent to the Operational
    Manager on 2/11/04.

3.  A drain was observed (on laboratory bench --northeast corner) that
    was not labeled nor on the sink and drain list.

4.  Secondary containment did not extend the length of the pump located
    on the southside of the lab (on floor).

5.  Satellite Accumulation Area 17: it was difficult to link the wastes
    to the waste log in some cases and the waste log was difficult to
    maneuver through to see which wastes were already disposed, those
    that were left, etc.

6.  Similar issue as was noted in Room S211 regarding flammable
    chemicals not being stored in flammable cabinets. The cabinet was
    labeled as 'organic solvent storage. There was no labeling of the
    cabinets as containing flammable chemicals and gasoline, petroleum
    ethers (as well as other chemicals).

7.  Small cylinder of carbon dioxide was not properly secured to a
    table.

8.  Several floor tiles near table in center of room were loose and
    raised, presenting a tripping hazard. Historical records indicate
    that the tiles and mastic in the room contain asbestos.

> **Note:** Asbestos sampling results recorded in the ORNL Condition
> Assessment Survey (CAS) online database at
> <http://www.pe.ornl.gov/cais/> confirmed that floor tile and mastic in
> 4500S/Room S215 is asbestos-containing material.

9.  Several of the temperature gauges on the thermocoupler were past due
    on calibration. The gauges were MO 77960, MO 77961, MO 77963, MO
    77957, and MO 77955.

10. Post-it notes with critical information were posted on the Precise
    Sensor (ID number 131318). This instrument was also past due (2/01)
    on calibration.

11. The Ruska Digital Positive Displacement Pump had post-it notes with
    critical information posted on Pump 2.

12. Manifolds on left front wall had post-it notes with critical
    information posted.

First row 4^th^ manifold has post-it with "Pump N2"

First row 6^th^ manifold has post-it note with "Take-up pump"

Second row, 1^st^ manifold is not labeled

13. Manifolds located on right wall at door have masking tape taped over
    to prevent use (lock-out/tag-out mechanism). There is no sign that
    states these should not be used.

**Room S219**

1.  A storage cabinet used for flammable storage was partially blocked.

2.  The waste log was not up to date for Satellite Area 40. The waste
    had been removed but had not been logged out accordingly.

3.  Best Management Practice (BMP)- equipment was observed very near the
    floor drain which has the potential to leak oil onto the floor,
    though none was observed. It is suggested that the drain be
    protected (e.g, oil absorbing material).

4.  BMP -- consider moving tanks for they are limiting egress from the
    laboratory.

5.  A chromate water bath approximately 4.5 feet tall next to an
    entrance way and very heavy was not secure. The bath was labeled as
    "Bath contains H20 and Potassium Chromate". Upon discussion with
    laboratory personnel, it was determined that the bath was empty and
    was no longer needed.

**Attachment 1**

Flammable and Combustible Liquid Storage

By: Brent M. Albertsen, FPE

**Problem:**

FPE was contacted on the issue of storing flammable and combustible
liquids. This issue extends from whether or not storing flammable with
combustible liquids is feasible to whether or not it is appropriate to
store these liquids in the existing asbestos lined cabinets which are
provided in the various labs. The cabinets of concern are mainly located
under the exhaust hoods in many of the labs. It has been laboratory
practice over many years to store flammable and combustible liquids
under these cabinets.

**Resources:** *NFPA 30, Storage of Flammable and Combustible liquids*.

**Requirements from NFPA 30:**

[Section 4.3.3]{.underline}

Storage cabinets that meet at least one of the following sets of
requirements shall be acceptable for storage of liquids:

\(a\) Storage cabinets that are designed and constructed to limit the
internal temperature at the center of the cabinet and 1 in. (25 mm) from
the top of the cabinet to not more than 325°F (162.8°C), when subjected
to a 10-minute fire test that simulates the fire exposure of the
standard time-temperature curve specified in NFPA 251, Standard Methods
of Tests of Fire Endurance of Building Construction and Materials, shall
be acceptable. All joints and seams shall remain tight and the door
shall remain securely closed during the test.

\(b\) Metal storage cabinets that are constructed in the following
manner shall be acceptable. The bottom, top, door, and sides of the
cabinet shall be at least No. 18 gauge sheet steel and shall be
double-walled, with 11/2 in. (38 mm) air space. Joints shall be riveted,
welded, or made tight by some equally effective means. The door shall be
provided with a three-point latch arrangement, and the door sill shall
be raised at least 2 in. (50 mm) above the bottom of the cabinet to
retain spilled liquid within the cabinet.

\(c\) Wooden cabinets constructed in the following manner shall be
acceptable. The bottom, sides, and top shall be constructed of exterior
grade plywood that is at least 1 in. (25 mm) thick and of a type that
will not break down or delaminate under fire conditions. All joints
shall be rabbetted and shall be fastened in two directions with wood
screws. Where more than one door is used, there shall be a rabbetted
overlap of not less than 1 in. (25 mm). Doors shall be equipped with a
means of latching and hinges shall be constructed and mounted in such a
manner as to not lose their holding capacity when subjected to fire
exposure. A raised sill or pan capable of containing a 2 in. (50 mm)
depth of liquid shall be provided at the bottom of the cabinet to retain
spilled liquid within the cabinet.

\(d\) Listed storage cabinets that have been constructed and tested in
accordance with 4.3.3(a) shall be acceptable.

**FPE Concurrences:**

1.  There are no provisions to storing flammable and combustible liquids
    together. They can be stored together in an approved UL listed
    Flammable/Combustible liquid storage cabinet provided the materials
    that are being stored together are compatible. All items stored in
    the cabinet need to be labeled appropriately.

2.  Using the guidance provided from NFPA 30, section 4.3.3, if the
    asbestos lined cabinets meet any of the four guidelines listed in
    this section the cabinets can be approved for storage of flammable
    and combustible liquids. If it is determined that these asbestos
    lined cabinets are not suitable for flammable and combustible
    liquids it will be necessary to provide UL listed and approved
    flammable liquid cabinets for storage of these materials.

**Attachment 2**

**OAK RIDGE OPERATIONS OFFICE**

EventLog Entries Received from

Print Date 02/10/2004 0800 to 02/11/2004 0830

02/11/2004 0841 Page 1 of 1

**Reported By** **Event Date and Location** **ORPS Number**

Jeskie, K B 02/10/2004 1418 02/05/2004 0332 EST ORO - ORNL -
X10CENTRAL - 2004 - 0001

Research Support Manager Plant: ORNL Event Report Received?: Yes

\(865\) 574-4945 Building: 4500S Initial Occurrence Category: 4

Description: Categorized: 02/06/2004 0730 EST

ReCategorized:

EOC Activated?: No

Time Activated:?

**ORO Staff Notified** **Offsite Notification** **HQ EOC Notification**

Branton, Michele 02/10/2004 1453 None HQ EOC Notified?: No

DOE-FR

Johnson, Steve 02/10/2004 1543

DOE-ORO

**Description of Event**

During Operational Awareness Program (OAP) walkthroughs, a team member
discovered elevated radiological levels in the bottom of a laboratory
sink (two

team members normally use portable beta/gamma detectors to conduct
cursory surveys). RCTs were called to conduct a comprehensive survey.
Smears

were taken and some of the contamination was found to be removable. The
survey indicated maximum readings 53,000 dpm/1000cm2\^fixed beta gamma

with 750 dpm/100cm\^2 removable beta gamma and 3900 dpm/100cm\^2 fixed
alpha with 110 dpm/100cm\^2 removable alpha. The isotope(s) is currently

unknown. Smears, as well as large area smears of the surrounding area
indicated no spread of contamination. The laboratory where the
contamination was

discovered is not posted as a radiological area, but within the ORNL
controlled area boundaries. No personnel received a radiological
exposure as a result of

this discovery.

Entry Date/Time: 02/11/2004 0815 Operator: Hatmaker, O. E.

**Date:** March 3, 2004

**To:** K. Jeskie

**ec:** G. Anderson M. Henderson

> A. Barnard J. Pearson

M. Belvin K. Petherick

> C. Cantwell B. Powers
>
> T. Cochran M. Robinson
>
> S. Gregory D. Rosine
>
> C. Stachowiak

**From:** Angela Barnard

**Subject: Finalized Field Notes for Operational Awareness Program (OAP)
Walk-Through Performed 2/12/04**

On February 12, 2004, OAP Team members participated in a walk-through
assessment of Chemical Science Division laboratories S223, S227, S231,
S235, S251, S255, located in Building 4500S. The following persons
participated in the walk-through:

> A. Barnard J. Pearson
>
> M. Belvin K. Petherick
>
> T. Cochran B. Powers
>
> S. Gregory D. Rosine
>
> M. Henderson C. Stachowiak

**Follow-Up Items**

1.  Labeling of secondary solutions: Further discussion was held on
    2/18/04 with the Subject Matter Expert (SME) for clarification on
    the requirement in regards to the hazard information from the
    primary container and what was considered readily available. The SME
    defined readily available as staff knowing where the primary
    container was located and staff being able to access the MSDS during
    the work shift. Refer to Section 7.5.2 of the ORNL Chemical Hygiene
    Plan for the guidance in question:\
    <http://sbms.ornl.gov/sbms/sbmsearch/subjarea/chemsafe/chp1.cfm>.\
     \
    Secondary containers must be marked or labeled with the identity and
    concentration, if known, of their contents. Although dates of
    preparation are recommended for all containers, this information is
    required only for those containers where the contents may become
    unstable with time. When the marking/labeling is impractical due to
    the size of the container, area labeling, such as of a tray in which
    the container sits, may be used. This method for labeling secondary
    containers is acceptable only when the hazard information from the
    primary container is readily available. Employees must be aware of
    the location of the primary container. If the primary container is
    not available, a complete label including hazard warning as
    described under \"Primary Chemicals Containers" above is required.

> Note: All containers containing a chemical must be identified with a
> label, except when they are intended for the employees\'s immediate
> use, are to be used in the employee\'s work shift, and remain under
> the employee\'s control. In short, if you leave it unattended it must
> have some type of label.

The following observations were noted by the visiting team and are the
summation of both the ORNL ES&H and DOE ES&H disciplines.

**General Comments:**

1.  An OAP team member discovered elevated radiological levels (400
    counts/minute) in the bottom of a laboratory sink in room S255. The
    sink was taped off to prevent further use. In room S235 several
    drawers from an old wooden toolbox were found probing to 2000
    counts/minute. Further investigation by the radiological control
    technicians resulted in an occurrence report (see Attachment) This
    is the second observation noted by the OAP team that has resulted in
    an occurrence report since 2/5/04.

> During the OAP walk-thru, Areas S223, S227, S231, S235,and S255 were
> identified as containing items with radiation counts above the
> background. As a result, the Radiation Control Technician(s) assigned
> to these specific areas was requested to perform a more comprehensive
> radiological survey.
>
> The operations manager stated that these incidents were all attributed
> to legacy contamination.

2.  The operation manager raised a concern when asked if a procedure
    existed for routine inspection of the dry box gloves before use in
    room S227 (see comment #3 for Room S227). She stated there were no
    procedures or systems in place for safety inspections for dry box
    gloves, glove box apparatus, centrifuge use, etc. She requested
    these issues be added in this report to identify these concerns. The
    goal will be to determine the appropriate level of guidance,
    procedure, etc. for these types of equipment.

3.  Several laboratories have peeling paint falling from the ceiling and
    walls. Chips of old paint may contain lead and/or PCBs. In two
    cases, laboratory staff has been required to cover work areas with
    plastic to keep them free of falling debris. This is considered a
    facility maintenance issue that cannot be readily resolved by the
    division.

4.  Several dark areas in the laboratories were noticed. The laboratory
    should consider performing illumination survey and relamping as
    needed to required illumination levels.

5.  Several defective gas cylinder straps observed in which the clasping
    mechanism did not secure the strap. Refer to
    <http://sbms.ornl.gov/sbms/sbmsearch/subjarea/cgc/cgc_sa.cfm> .

6.  Several instruments, balances, and other equipment contained
    past-due calibration stickers. The operations manager stated that
    CSD was working to provide documentation of calibration status for
    these items. For guidance, refer to

> <http://sbms.ornl.gov/sbms/SBMSearch/subjarea/CALIBRATION/pro1.cfm>

**Room S223**

1.  There was a past due (4/02) calibration sticker on instrument
    M070031.

2.  The glass sliding door on the second storage system located in the
    back of the laboratory was cracked and held together with masking
    tape. It is recommended that the glass be replaced or secured more
    safely.

3.  Best Management Practice (BMP) - There were hand-written post-it
    notes with critical information located on the Linberg Furnace #2.
    Critical information or instructions for operating equipment should
    be located in a secure logbook or procedure.

4.  150 counts/minute readings were found in the sink.

5.  Verify grounding of metallic tables in clean room.

6.  Several dark areas in lab - consider performing illumination survey
    and relamping as needed to required illumination levels.

7.  Several defective gas cylinder straps observed - clasping mechanism
    does not secure strap.

8.  Lamp with integrated switch on cord has electrical tape applied to
    switch housing. Discard or tagout and remove from service until
    repairs are made.

9.  Four products (EPO-TEK 353ND Part A, EPO-Kwick Resin, EPO-Kwick
    Hardener and Buehler Release Agent) containing hazardous chemicals
    do not have an affixed HMIS barcode label. It is recommended the
    laboratory user deterimed if these chemicals are classified/managed
    under the OSHA Chemical Laboratory or HAZCOM Standard and evaluate
    for proper storage.

**Room S227**

1.  There were two unlabeled containers of chemicals located in the
    room. One beaker of unidentified material was located in the sliding
    glass cabinet near the entrance. A plastic container of solid
    material, orange in color, was located on the counter top next to
    the glass cabinet. Refer to
    <http://sbms.ornl.gov/sbms/SBMSearch/SubjArea/chemsafe/chp1.cfm>,
    Section 7.5.2. Labeling.

2.  On the counter near the entrance entry, was a container of Devcon
    Plastic Steel Liquid (epoxy compound) sitting in a open box. The box
    was stuck to the container and the container had the epoxy substance
    covering the lid as evidence of leakage.

3.  BMP - An OAP team member noticed gloves connected to the dry box and
    asked the operation manager if these were inspected before use for
    signs of degradation. It was stated that there were no current
    procedures in place for this type of inspection and she could not
    confirm if or how the laboratory user performed routine inspections
    of the gloves.

4.  Hood #151 needs-relamping.

5.  A large mortar was found with 300 counts/minute readings on the
    interior, on the N.E. bench top.

6.  Several dark areas in lab - consider performing illumination survey
    and relamping as needed to required illumination levels.

7.  Several broken floor tiles observed - due to the age of the
    building, evaluate to determine if tiles or mastic contain asbestos.

**Room S231**

1.  On the north wall of the room, substantial paint peeling was
    evident. The Laminar hood was draped with plastic to prevent the
    peeling paint chips from entering the hood where work was performed.

2.  The air filters on the north wall are very dirty and need replacing.

3.  The flammable cabinet needs to be relabeled from "Organic Storage"
    to "Flammable Storage".

4.  A ring stand sitting on a center benchtop was found with 100
    counts/minute on its base.

5.  Toxic/corrosive lecture bottle of sulfur dioxide was observed ontop
    of a bench. This was moved to inside a functioning laboratory hood
    during the inspection. For chemical storage guidance, refer to
    <http://sbms.ornl.gov/sbms/SBMSearch/SubjArea/Chemsafe/Chemsafepro3.cfm>.

6.  Five (5) high temperature refractory bricks (high crystalline silica
    content) observed in laboratory. Consider IH evaluation of similar
    operations - coatings can be applied to brick to minimize airborne
    crystalline silica.

7.  Hastings and other gages - Open electrical contacts observed on the
    rear of open panel. Evaluate to determine if voltage is
    [\>]{.underline} 50 V. Live parts of electric equipment operating at
    50 volts or more shall be guarded against accidental contact by
    approved cabinets or other forms of covering. Refer to
    <http://sbms.ornl.gov/sbms/sbmsearch/subjarea/elec/exh_elecrules.cfm>.

**Room S235**

1.  There was a past due calibration stickers on instruments M079072,
    M079869, and M097099.

2.  The hoisting/rigging equipment inspection form attached to the
    California hood indicates the last inspection entry was 9/4/95. This
    inspection form refers to a 100 lbs. hoist when the actual hoist in
    the hood is labeled as 300 lbs. The inspection form should be
    updated if the equipment is still in use. Refer to
    <http://sbms.ornl.gov/sbms/sbmsearch/subjarea/hoistrig/preopinspecthoists.cfm>

3.  In the California hood near the door, the surface of the hood was
    oily near the Neslab instrument (the oil may not be from this
    instrument; an oil can was noticed near the oily patch). The paper
    towel that was on the surface of the hood was soaked through, and
    therefore had no capacity to absorb additional leaked or spilled
    oil. New absorbent material is needed and the oily residue should be
    cleaned up before it spills onto the floor.

4.  BMP -- There were hand-written post-it notes with critical
    information located on instrument ID M079873. Critical information
    or instructions for operating equipment should be located in a
    secure logbook or procedure.

5.  The flammable cabinet needs to be relabeled from "Organic Storage"
    to "Flammable Storage".

6.  A plastic bin containing several chemicals is currently stored on a
    high shelf. The current storage on a high shelf poses a potential
    for injury due to the location, weight, and contents of the plastic
    bin. It was recommended the plastic bin with the chemicals be placed
    on a lower shelf.

7.  The Dynamax Solvent Delivery System instrument and a secondary
    container filled with laboratory solutions was stored on a moveable
    cart that was unstable (wobbly). It was recommended both be placed
    on a more stable location.

8.  Several drawers from an ancient wooden toolbox were found probing to
    2000 counts/minute, under center aisle.

9.  Verify grounding of metallic tables

10. Oil reside observed on interior base of California hood.

11. Wire insulation observed on cord plug (240 Volt) - PNL. 2R14 Cir 9.
    Refer to
    <http://sbms.ornl.gov/sbms/sbmsearch/subjarea/elec/Exh_elecrules.cfm#cord>

12. Ruska Porporting Pump - improper guarding of nip point.

13. Five (5) cylinders of Hydrogen gas - consider having Fire Protection
    evaluate to determine if this quantity exceeds use/storage
    quantities. Refer to
    <http://sbms.ornl.gov/sbms/sbmsearch/subjarea/cgc/ExhReqHandUseCompGas.cfm>.

14. Open electrical contacts observed on the rear of gages. Evaluate to
    determine if voltage is [\>]{.underline} 50 V. Live parts of
    electric equipment operating at 50 volts or more shall be guarded
    against accidental contact by approved cabinets or other forms of
    covering. Refer to
    <http://sbms.ornl.gov/sbms/sbmsearch/subjarea/elec/exh_elecrules.cfm>.

15. Open "bay" on computer - obtain and install cover plate to prevent
    accidental contact with energized parts. See reference above.

**Room S251**

1.  The Mettler balance IDX82665 was past due for calibration (8/02).

2.  A gas cylinder was not secured. The LSM was notified and took action
    to secure the cylinder. A Nitrogen gas cylinder was inappropriately
    secured to the lip of the hood.

3.  There was combustible material (paper) located in the flammable
    storage area. This was removed during the visit. A bottle (contents
    unknown) was found laying on its side in the back of the flammable
    cabinet. The bottle was placed upright during the visit. It was
    recommended that the laboratory user ensure the contents had not
    spilled into the secondary containment.

4.  There was substantial peeling paint on the front and right walls
    resulting in a considerable accumulation of paint chips on the
    floor.

5.  For RCRA SAA #31, the last inspection date was performed on 3/8/96.
    It is recommended the inspections be kept up-to-date. An inspection
    form can be located at
    <http://sbms.ornl.gov/sbms/SBMSearch/SubjArea/hmwm/epp01ac.cfm>.

6.  Some of the entries onto the RCRA satellite accumulation area (SAA)
    log sheets lacked units on the quantity entries. It was noted that a
    different person will be responsible for this SSA in the future.

7.  The pan under the vacuum pump below a California hood was about 1/2
    full of oil. Because the pump filled most of the storage space in
    the pan, emptying the accumulation of oil more often is recommended
    as a BMP.

8.  Dark areas in lab - consider performing illumination survey and
    relamping as needed to required illumination levels.

9.  Two trays of assorted flammable chemicals located under lab hood
    need to be evaluated for compatibility and final disposition. For
    guidance refer to
    http://sbms.ornl.gov/sbms/sbmsearch/subjarea/chemsafe/chemsafepro4.cfm.

10. Piles of paint chips observed on floor - consider evaluating for
    hazardous constituents and dispose of according (based on analytic
    results).

11. Oil soaked wood blocks observed adjacent to heat source.

12. BMP - Glass tubing protruding into aisle - potential cut hazard.

13. BMP - Sharp items (Exacto knives, razor blade, etc. ) stored in open
    without sheaths or covers.

14. Two improperly secured gas cylinders observed.

15. Housekeeping in area needs improvement.

**Room S255**

1.  A vacuum pump on the floor near the entrance was leaking. Although
    the pump contained a secondary storage tray, it was lined with paper
    towels that were saturated and dripping onto the floor.

2.  A Hastings vacuum gauge located on top of an instrument had a bent
    needle and was missing the front cover. It appeared to be
    inoperable, although attached to instrument circuitry.

3.  There was no ID sticker on door identifying the LSM and appropriate
    personnel for this laboratory.

4.  There is considerable accumulation of flaked paint on the floor
    adjacent to the walls in this room. Paint chips are falling into the
    sink that is located in the northwest corner of the room. Chips of
    old paint may contain lead and/or PCBs. The concentration of lead
    and PCBs acceptable in wastewaters discharged to Process Waste
    Treatment Systems are limited by the Waste Acceptance Criteria for
    that system
    ([http://www-ep.ornl.gov/water/wdc/process%20wdc.htm](http://www-ep.ornl.gov/water/wdc/process wdc.htm)).
    It is recommended that action be taken to keep paint chips out of
    the sink since it may not be known whether the paint contains lead
    and/or PCBs.

5.  There was a vacuum pump under the glove box that didn't have a catch
    pan under it.

6.  Sink probes to 400 counts/minute on bottom and smearable activity is
    indicated.  Sink was taped-off.

7.  Ungrounded metallic instrument rack.

8.  No "Quality" inspection sticker on local instrument exhaust hood
    EF-24 (said to have been recently installed). Refer to Section 6.3
    of the Chemical Hygiene Plan located at
    http://sbms.ornl.gov/sbms/SBMSearch/SubjArea/chemsafe/chp1.cfm#4

9.  In use gas cylinder storage rack observed to have bolts pulling out
    from wall.

**Room T005**

1.  The sign on the entrance door identifies that safety glasses must be
    worn in this area. An employee working in the room was observed not
    wearing safety glasses with side shields.

2.  The calibration sticker on the Mettler A240 balance was unreadable.
    The reviewer could not determine if the calibration was up-to-date.

> 3\. There are no drain labels on the new sink in this lab. Drain
> labels are also needed at two other locations ("Managing Wastewater
> Disposal Systems"
> <http://sbms.ornl.gov/sbms/sbmsearch/SubjArea/Water/pro4.cfm>[)]{.underline}.
> One is where the drainpipe from the new sink enters the standpipe at
> floor level. A label is needed here because it is possible to
> discharge waste at this location by lifting the metal trim ring that
> is installed around the pipe leading from the sink. There is a label
> by this standpipe that says "Drains to 4500S W2," but a standard ORNL
> drain label should be posted because a drain label must identify the
> system ultimately receiving that wastewater and give some information
> about what types of wastewater are appropriate for discharge to that
> drain. Second, a drain label is needed for the drain standpipe near
> the floor beside the north wall of the lab (between the clean room and
> the wall). There is a label beside this drain that says "Sump in
> E-46," but the label must identify the system ultimately receiving
> that wastewater and give some information about what types of waste
> are appropriate for discharge to that drain. The label to use for this
> location would be the label for the drain system that accepts water
> from the "sump in E-46." A concern was also expressed that there might
> not be a trap in this drain that would keep water from backing up into
> the room from the sump E-46 drain system, which is rad contaminated.
> This potential vulnerability should be investigated and mitigated if
> necessary.
>
> 4\. The drain labeled "Sump in E-46" currently receives a discharge of
> once-through cooling water. An occupant in the lab mentioned that a
> closed-loop cooling system was installed but was never finalized
> (perhaps due to high water pressure somewhere in the system). Because
> a recirculation cooling system is in place, resolving the problem
> first encountered in implementing that system is a good opportunity
> for waste minimization, and offers potential cost savings for the
> Laboratory. In addition to the water procurement costs, waste
> treatment cost could be avoided. This cost avoidance could be
> significant if the cooling water usage is significant, especially if
> the sump in E-46 discharges to the Process Waste Treatment System.

5.  Small calibration sized bottle of 1-Butene stored on shelf.

```{=html}
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```
1.  No eyewash located in laboratory. This is a change condition when
    corrosive material will be introduced into the lab. The laboratory
    users must ensure an eyewash is available when corrosives are
    introduced.

> 7\. 3-M dusk masks observed, Discussions with researchers revealed
> that the dusk masks (i.e. filtering face piece respirators) were being
> worn by a bearded researcher to prevent "contamination" of samples
> during preparation. Dusk masked were discarded researchers were
> advised use other methods to protect samples. This is a potential
> respiratory protection issue.

1.  Minimize trip hazard on floor by uncoiling hoses and optimizing
    orderly arrangement of hose.

> 9\. Coffee cup observed in laboratory adjacent to sink - removed at
> the time of the inspection.
>
> 10\. VDT not adequately secured - was straddling a piece of equipment.

**Attachment**

**(Occurrence report)**

![](media/image1.jpeg){width="5.992361111111111in"
height="7.75in"}![](media/image2.jpeg){width="5.992361111111111in"
height="7.75in"}![](media/image3.jpeg){width="5.992361111111111in"
height="7.75in"}![](media/image4.jpeg){width="5.992361111111111in"
height="7.75in"}

**Date:** March 3, 2004

**To:** K. Jeskie

**ec:** G. Anderson L. Manis

> A. Barnard J. Pearson

M. Belvin K. Petherick

> C. Cantwell B. Powers
>
> T. Cochran M. Robinson
>
> S. Gregory D. Rosine
>
> M. Henderson P. Scofield
>
> C. Stachowiak

**From:** Angela Barnard

**Subject: Finalized Field Notes for Operational Awareness Program (OAP)
Walk-Through Performed 2/19/04**

On February 19, 2004, OAP Team members participated in a walk-through
assessment of Chemical Science Division Buildings 5507, 5507A, and rooms
5, 25, 29, 33A, and 46 in Building 5505. The following persons
participated in the walk-through:

> A. Barnard B. Powers
>
> M. Henderson D. Rosine
>
> L. Manis P. Scofield
>
> J. Pearson C. Stachowiak

Building 5507

Upstairs

1.  The PCB inspection sheet was up to date, and there was secondary
    containment for TSCA waste, as well as appropriate labeling on the
    doors. The Environmental Protection Subject Matter Expert (SME)
    noted that the area looked very good.

2.  Housekeeping was very good. The operations manager noted that the
    researchers had worked hard to clean up their space and it was
    evident.

3.  There were some floor tiles that were broken or loose. Historical
    records indicate that the tiles in the room contain asbestos. It was
    observed that some of the cracks were filled but there were other
    tiles that needed repair.

4.  Past due calibration stickers were noted for balances X-111821,
    X-119190, and X-88479. Refer to
    <http://sbms.ornl.gov/sbms/SBMSearch/subjarea/CALIBRATION/pro1.cfm>.

5.  A bottle of ion exchange resin, which is labeled as flammable, was
    being stored in a drawer. Refer to
    <http://sbms.ornl.gov/sbms/sbmsearch/subjarea/chemsafe/chemsafepro4.cfm>.

6.  A small container of acetone was found in an enclosed workbox. There
    is a note on the enclosure that states "Enclosure is not provided
    with explosion proof electrical equipment and should not be used
    with flammable or explosive atmospheres". Refer to reference cited
    in comment \# 4, Building 5507, Upstairs.

Upstairs -- back laboratory

1.  Isopropyl alcohol (CAS 67-63-0), Acetone (CAS 67-64-1), Methanol
    (CAS 67-56-1), and Toluene (CAS 108-88-3), all Class IB flammable
    liquids, and Dichloromethane (CAS 75-09-2) a combustible and
    carcinogen were stored under the hood (nonflammable cabinet) in the
    back room -- there has been a discussion regarding how these
    materials should be stored. Refer to reference cited in comment \#
    4, Building 5507, Upstairs.

2.  There was less than 36 inches clearance for the electrical panel --
    we were told that you can obtain a variance from this clearance
    limit if it is unavoidable -- usually, there is a label on the
    electrical panel that states that this has been approved, no label
    was observed. Refer to
    <https://sbms.ornl.gov/sbms/sbmsearch/subjarea/elec/exh_elecrules.cfm>

3.  The entrance to an electrical cabinet (next to the hood) was blocked
    by furniture. Refer to reference cited in comment #2, Building 5507,
    Upstairs - back laboratory.

Basement

1.  In the back corner of the basement (near the exterior door) some of
    the insulation on the pipes looked like it could use some repair.
    The labeling on the insulation indicated that it contained asbestos.

2.  Water was leaking from an overhead pipe in the basement. The water
    on the floor from the leak is located beneath an electric-powered
    generator and near a storm drain. Potential exists for electric
    shock. The operations manager has reported this issue to the
    responsible group leader.

3.  On the back wall, near the leak are two storm drains. Along this
    back wall was the PCB waste in secondary containment as well as a
    number of \<50 ppm PCB detectable containers. All of these
    containers (\<50 ppm PCB) appeared to be good condition. However, it
    would be a best management practice (BMP) to move these materials
    away from the leak and the storm drains.

4.  The logbook use to record information for SSA 793 is contained in a
    three-ring binder. It is recommended that the SAA number be recorded
    on the pages in the notebook. This is considered a BMP.

5.  It is recommended that a more appropriate place to house the
    explosive storage area be located. If the requirement is 50 ft from
    any combustible sources this is not being met in the current
    location. CSD personnel have been working with the OSSD explosive
    SME on this issue.

6.  A few used batteries were observed on the second shelf of a cart.
    Refer to
    <http://sbms.ornl.gov/sbms/sbmsearch/SubjArea/Hmwm/HMWMpro1.cfm>.

7.  There was a general question regarding whether the SAA 940 was still
    necessary; it is an ESD SAA. The last entrance to the waste log was
    May 2003. Note: The waste was removed from this SAA on 2/25/04.

8.  Noticed that there were Standard Operation Procedures, concerning
    refrigerator temperature checks, from 1995 taped to the
    refrigerator. These are out of date and should be removed as well as
    the sticker for the responsible property manager. This is considered
    a BMP.

9.  Permanent Caution signs warning of possible head injury should be
    placed at both entrances to the room with the low ceiling. This is
    considered a BMP that could be done, since the ceiling heights do
    not meet OSHA requirements.

10. In one of the refrigerators there appeared to be samples but there
    did not appear to be temperature check information. Need to
    determine if temperature controls are required for these samples.
    This is considered a BMP.

11. In the back room (near the stairs) there were 2 to 3 small tanks
    (SF6) that were blocking the entrance to drawers of a workbench.

12. A drawer in a wooden toolbox probed to 100 counts per minute beta.
     It was labeled with tape on the drawer.

13. Respirators and cartridges improperly stored per SBMS requirements
    under *Respiratory Protection* procedure for *Using/Managing
    Air-purifying Respiratory Protective Equipment:* Respirators were
    not stored in a manner which protects them against dust, sunlight,
    heat, extreme cold, excessive moisture, damaging chemicals and
    mechanical damage. In addition, respirators were not stored a secure
    location to prevent unauthorized access to the respirators.

14. Lead/tin, nickel, and chromium solder wire stored in drawer was not
    labeled with any health hazard information. Solder not barcoded,
    likely not included on HMIS inventory. Use of solder not recognized
    or addressed in the RSS (if performed in this facility). Soldering
    operations fall under SBMS for Hot Work and would require evaluation
    of the area by fire protection engineering, especially as any such
    operation would be within 50 ft of explosives stored in basement of
    5507.

15. Outside there were a number of cardboard boxes and other excess
    materials -- these should be picked up. We were told this was a rare
    occurrence resulting from the LSM cleanout.\
     

Building 5507A

1.  Personnel for this building have generated a Laboratory Space
    Manager notebook containing the laboratory authorization
    information, RSS, self -assessment, LSM R2A2, and related documents.
    This is considered a BMP that would be good to share across the
    complex.

2.  As a BMP, consider labeling the sink and drains even though these
    all go to tanks.

3.  Outside: Signage indicating "No Smoking" was not present at outdoor
    Hydrogen system for 5507A.

Building 5505 (Rooms 5, 25, 29, 33A, 46)

Room 5

1.  One of the vacuum pumps in this area did not have secondary
    containment.

2.  In SAA 554, the hazardous waste labels were either off or coming off
    of the waste containers. Refer to
    <http://sbms.ornl.gov/sbms/sbmsearch/SubjArea/Hmwm/HMWMpro3.cfm>

Room 25

1.  The Argon gas cylinder was not secured properly. Laboratory
    personnel secured the cylinder by tightening the strap. The clasp on
    the strap is noticeable rusted. It is recommended that the clasp be
    replaced. Refer to
    <http://sbms.ornl.gov/sbms/sbmsearch/subjarea/cgc/ExhGasCylStorReq.cfm>

2.  The area on the left front of the Neptune unit needs to have a cover
    installed to guard employees from the potential for electrical
    shock. The original cover is not in place, and apparently would not
    fit because of modifications to the unit. An alternative cover
    should be considered. Refer to reference cited in comment #2,
    Building 5507, Upstairs - back laboratory.

Room 29

> On the waste container for SAA 392, an old RCRA training document was
> observed. The operations manager stated that it contained very useful
> information and suggested that the ORNL SMEs provide a similar updated
> version for generators to use. Although the web-based training
> provides this information, it is cumbersome to print out. It might a
> good idea to see if there are updated training materials that might
> also be useful. Also there were dated RCRA regulations (for waste
> characterization) posted on the wall. It would be useful to update
> these regulations.

Room 46

1.  The flammable storage cabinet contained a cardboard box. The box was
    removed. Refer to reference cited in comment \# 4, Building 5507,
    Upstairs.

2.  Debris on counter tops from peeling paint on wall.

3.  The cabinet used for corrosive storage would not open due to a
    problem with the hinge (bent and rusted).

4.  Comparing the contents of the refrigerators (in back of room) to the
    inventory, it appeared that the inventory was not current.

5.  A leak was observed underneath the sink in the back of the room.

6.  Single-use supplemental eyewash station installed on side of hood
    was within 5 feet of a non-GFCI protected wall electrical outlet.
    Potential exists for electric shock Refer to reference cited in
    comment #2, Building 5507, Upstairs - back laboratory.

7.  Improper chemical storage under sink. Isopropyl alcohol (CAS
    67-63-0) is a Class IA flammable liquid; MSDS recommends storage in
    a dry location. Nitric acid (7697-37-2) is a corrosive and oxidizer;
    MSDS indicates incompatibility with alcohol advises against storage
    near moisture. A pan containing liquid was also under sink, believed
    to be water from leak.

**Date:** March 12, 2004

**To:** K. Jeskie

**ec:** G. Anderson D. Paul

> A. Barnard J. Pearson

M. Belvin K. Petherick

> C. Cantwell B. Powers
>
> T. Cochran M. Robinson
>
> S. Gregory D. Rosine
>
> M. Henderson P. Scofield
>
> L. Manis C. Stachowiak

**From:** Angela Barnard

**Subject: Final Field Notes for Operational Awareness Program (OAP)
Walk-Through Performed 3/4/04**

On March 4, 2004, OAP Team members participated in a walk-through
assessment of Chemical Science Division Building 5505, rooms 1,
7,9,13,15,21, 37, 39, and 43, and the service corridor. The following
persons participated in the walk-through:

> A. Barnard B. Powers
>
> M. Belvin D. Rosine
>
> R. Chung P. Scofield
>
> M. Henderson C. Stachowiak

Building 5505

General Comments

7.  The OAP team commended the staff for their effort in significantly
    improving the condition and ownership of the facility from the last
    OAP visit a few years ago. Laboratory personnel did an excellent job
    of ensuring staff were briefed on hazards of laboratory areas prior
    to entering.

8.  Many of the posted chemical storage inventory lists in the rooms
    visited were dated January 2003. If the occupants choose to post the
    chemical inventory, they must ensure that a more recent copy is
    used. The operations manager is aware of this and is in the process
    of resolving this issue.

Lobby

Improperly secured cylinder of P10 gas (90% argon/10% methane) due to
defective restraining strap. There was a concern if the "non-hazardous"
placarding on the cylinder was correct. The BOC gas MSDS (received
10/11/2002) for P10 gas has a statement under the "fire fighting"
section that states, "concentrations of methane equal to or greater than
9.81% in argon are considered flammable". The operations manager stated
that CGA P-23 states "A mixture of less than or equal to 10% methane in
argon is nonflammable according to DOT interpretation". There are
inconsistencies between DOT and other sources that must be resolved.
This situation also has ramifications for proper storage of gas
cylinders.

Room 1

1.  A motor located on top of a wood counter did not have any secondary
    containment. It was noted that oil had been leaking at one time due
    to the discoloration of the counter. Refer to section 8.2 of the
    ORNL Chemical Hygiene Plan, located at
    <http://sbms.ornl.gov/sbms/sbmsearch/subjarea/chemsafe/chp1.cfm> .

2.  The pumps mounted on the wall should have some type of secondary
    containment. No oil leaks were observed. Refer to reference cited in
    comment #1, Room 1.

3.  Improperly secured cylinder of Nitrogen due to defective restraining
    strap. Refer to
    <http://sbms.ornl.gov/sbms/sbmsearch/subjarea/cgc/ExhGasCylStorReq.cfm>

4.  Laser protective eye ware lying on bench top. Storage/maintenance of
    Laser eye protection is contrary to Step 8 of the SBMS Subject Area:
    Personal Protection Equipment, Procedure: Eye and Face Protection

5.  Four (4) electric plugs inserted into receptacles on a glove box
    were observed to have deterioration of outer insulation which is
    contrary to Step 1 of SBMS Subject Area: *Electrical Work*, Exhibit:
    *Electrical Rules and Practice*, *Corded Electrical Equipment*.

6.  Differential AMPL -- Open electrical contacts observed on the rear
    of open panel. Evaluate to determine if voltage is [\>]{.underline}
    50 V. Live parts of electric equipment operating at 50 volts or more
    shall be guarded against accidental contact by approved cabinets or
    other forms of covering. Refer to
    <http://sbms.ornl.gov/sbms/sbmsearch/subjarea/elec/exh_elecrules.cfm>.

Service Corridor

1.  Pumps on floor next to flammable storage cabinet outside Room 1 did
    not have secondary containment. These pumps were tagged for
    disposal.

2.  Two (2) old bench centrifuges stored on bottom shelf were observed.
    The centrifuges did not have an interlock feature to stop rotation
    when the lid was raised. This is contrary to Subject Area:
    *Occupational Hazard Controls*, Exhibit: *Rules for Machine
    Guarding* requirements.

3.  Several improperly secured compressed gas cylinders due to defective
    restraining strap. Refer to reference cited in comment #3, Room 1.

4.  A \~18 inch diameter area of ceiling is degrading and "white"
    material observed below on floor outside of Room 18. Consider
    testing material to determine if it contains asbestos.

5.  Ten (10) empty 6-ounce container of liquid propane were stored in a
    cabinet in the hallway. There was concern as to whether the propane
    was stored properly. The operations manager has contacted FPE for
    storage information.

6.  Flammable liquid fire cabinet has trays (for secondary containment)
    made of combustible plastic. Additionally, a cardboard box was
    stored in the cabinet which is contrary to Subject Area: *Chemical
    Safety*, Procedure: *Storing and Handling Flammable and Combustible
    Liquids* storage requirements. The operations manager has contacted
    FPE for clarification on use of plastic trays used for secondary
    containment.

7.  There was a question regarding the status of the isopropyl magnesium
    chloride located in the Satellite Accumulation area (SAA). The
    chemical was not labeled as hazardous waste, however it was packaged
    for removal.

8.  The SAA waste log was full and it's recommended that a few more
    sheets be added for waste recording.

9.  Spill Kit was observed on top of a tall chemical cabinet. There is a
    question as to the best location for this kit and how staff would
    get to it easily in its current location.

10. Chemical storage was observed, within secondary containment on an
    open cabinet. The lip of the secondary containment extended slightly
    beyond the shelf and the chemicals were at eye-level. As a BMP, it
    might be best to put these in a more secure location.

11. In flammable cabinets (3 and 8) there was a question regarding
    chemical compatibility, e.g., proper storage of acetic acid with
    other chemicals.

12. An unlabelled container of used oil was observed. It was labeled as
    "Used Oil": during the walk-through. Refer to
    <http://sbms.ornl.gov/sbms/sbmssearch/SubjArea/Oil/UsedOilsa.cfm>

13. Fluorescent bulbs (appeared to be used) taped together were observed
    in a box on the floor. It is recommended as a BMP that the box be
    removed to a more secure location.

Room 7

1.  A sign written on a paper towel and attached to a knob, saying not
    to bump the equipment was observed. Not the best signage method. In
    addition, you had to bend over to read it.

2.  Radiological package (Type II) was on top of a cabinet. Not sure how
    much it weighs but it would be a BMP to have it located in a more
    accessible location.

Room 9

1.  Boxes of utility wipes were stored next to corrosive solutions. It
    is recommended as a BMP that the wipes be moved.

2.  A lead brick was observed under a cabinet. It was suggested that it
    was being used to reduce vibration. However, it did look like there
    might be some oxidation. It is recommended the brick be removed and
    another mechanism to reduce the vibration be used.

3.  Glove box foot pedal has tape applied on cord at the box/cord
    interface. There is a concern for a potential contact with energized
    parts.

4.  An electric cord was observed that had several deep cuts. The
    operation manager confirmed that the equipment was not in use and
    was unplugged, but the equipment must be taken out of service until
    repairs are made and the cause of mechanical insult to the cord is
    determined. This condition is contrary to SBMS Subject Area:
    *Electrical Work*, Exhibit: *Electrical Rules and Practice*, *Corded
    Electrical Equipment*.

5.  A protective measure such as hazard marking of pipe (yellow and
    black tape or equivalent), blocking of the aisle, etc., in the aisle
    between the two doors is needed to minimize trip hazard. This is
    inconsistent with Subject Area: *Occupational Hazard Controls,*
    Procedure: Walking/Working Surfaces and Fall Protection.

6.  Laser eye protection (glasses and goggles) observed hanging from a
    coat rack inside the lab. Three (3) pairs of laser goggles, removed
    from service by Kim Jeskie, had defective restraining straps (no
    elasticity). The lenses of the other laser protective eye were
    covered with grime. Storage, maintenance and inspection of Laser eye
    protection was contrary to Steps 7 and 8 of the SBMS Subject Area:
    Personal Protection Equipment, Procedure: Eye and Face Protection.
    (see below).

+-----------+----------------------------------------------------------+
| **Step    | Staff member inspects the eye and/or face protection     |
| 7**       | prior to using it to verify its integrity. Staff do not  |
|           | use eye and/or face protection if it is defective.       |
+-----------+----------------------------------------------------------+
| **Step    | Staff member uses, stores, and maintains the eye or face |
| 8**       | protection meeting the recommendations of the            |
|           | manufacturer.                                            |
|           |                                                          |
|           | **NOTE:** PPE potentially contaminated should remain in  |
|           | the work area. It should not be worn into lunch rooms or |
|           | taken home.                                              |
+-----------+----------------------------------------------------------+

As a follow-up, the operations manager identified another set of glasses
that were stored correctly and the laboratory user identified these as
ones currently used.

Room 13

No comments.

Room 15

1.  A Welch pump, located on the floor, did not have secondary
    containment. Absorbent paper had been placed under the pump.

2.  Peeling paint was noted on the back wall of the room.

3.  Improper chemical storage of gas cylinders in chemical storage
    cabinet. Some flammable cylinders were located in this cabinet.

4.  Access to the Laser Button and door for egress was behind storage
    cabinets. It is suggested that storage cabinets be moved to allow
    better access.

Room 21

1.  Balance (X163074) had a calibration sticker indicating calibration
    was due 12/9/00. Refer to
    <http://sbms.ornl.gov/sbms/SBMSearch/subjarea/CALIBRATION/pro1.cfm>

2.  A procedure, "CASD-OP-000-SH01, Rev 0, dated 7/15/95, outlining
    laser operations should be reviewed. Procedures should be reviewed
    every five years. Refer to
    [http://sbms.ornl.gov/sbms/sbmsearch/subjarea/IOP/pro6.cfm.](http://sbms.ornl.gov/sbms/sbmsearch/subjarea/IOP/pro6.cfm)
    The operations manager followed up and confirmed that the document
    was reviewed on July 10, 2000 and it was determined that no changes
    were needed. She stated that a new cover page should have been
    issued with the review date.

3.  There was a question regarding the grounding of one of the metal
    tables.

Room 37

The tray that was Satellite Accumulation Area 20 was full and it
appeared that the waste had been there since 4/26/95. It would be useful
to have this waste removed and consider closing the SAA, if no hazardous
waste is being generated in that laboratory.

Room 39

Glove box foot pedal had exposed wires where cord enters box. This
condition is contrary to SBMS Subject Area: *Electrical Work*, Exhibit:
*Electrical Rules and Practice*, *Corded Electrical Equipment*.

Room 43

1.  Post-it notes with critical information stuck on instruments. It is
    recommended as a BMP that this information be contained in a
    procedure or work aid.

2.  Linoleum flooring cracked and pulling up near the door presents a
    potential tripping hazard. This is contrary to requirements for
    waling working surfaces contained in Subject Area: *Occupational
    Hazard Controls,* Procedure: Walking/Working Surfaces and Fall
    Protection. Also consider sampling exposed mastic to ensure that it
    does not contain asbestos.

3.  Source focus instrument - Open electrical contacts observed on open
    front panel. Evaluate to determine if voltage is [\>]{.underline}
    50 V. Live parts of electric equipment operating at 50 volts or more
    shall be guarded against accidental contact by approved cabinets or
    other forms of covering. Refer to reference cited in comment #6,
    Room 1.

**Date:** March 18, 2004

**To:** K. Jeskie

**ec:** G. Anderson D. Paul

> A. Barnard J. Pearson

M. Belvin K. Petherick

> C. Cantwell B. Powers
>
> T. Cochran M. Robinson
>
> S. Gregory D. Rosine
>
> M. Henderson P. Scofield
>
> L. Manis C. Stachowiak

**From:** Angela Barnard

**Subject: Finalized Field Notes for Operational Awareness Program (OAP)
Walk-Through Performed 3/11/04**

On March 11, 2004, OAP Team members participated in a walk-through
assessment of Chemical Science Division Buildings 2026, 7900, and 7920.
The following persons participated in the walk-through:

> A. Barnard M. Henderson
>
> M. Belvin D. Paul
>
> R. Chung K. Petherick
>
> T. Cochran B. Powers
>
> S. Gregory C. Stachowiak

**[Building 2026]{.underline}**

General Comments

The following rooms in Building 2026 were not entered by the OAP team
due to Radiological Work Controls: Rooms 100, 101, 102, 103, 133, 136,
138, and 212.The team was able to look through the door window into each
room for a limited view in each area. Observations were provided for the
following rooms:

Room 101

There was some concern in regards to proper grounding of a metals table.
An electrical cord was taped to the table.

Room 102

The open access panel on the side of the hood was not attached correctly
and there was concern as to whether electrical wires were exposed. The
laboratory manager later verified that the access panel was for water,
vacuum, and gas values and no electrical wires were exposed.

*The following rooms were available for walk-through inspection:*

Room 107

1.  The SAA 321 had three 1-liter size bottles of waste that had been in
    the SAA since 1994-95 according to the waste log. The operations
    manger stated that these waste items would be pick-up on a more
    frequent schedule now that CSD had two Waste Services
    Representatives (WSRs) assigned to their division.

2.  The acid cabinet needs to be checked to see if it contains secondary
    containment. The operations manager later verified that the cabinets
    had a polypropylene-lined shelf and a two inch deep well for spill
    protection.

Room 108

1.  The balance X199322 was past due for calibration on 1/29/03. Refer
    to
    <http://sbms.ornl.gov/sbms/SBMSSearch/subjarea/CALIBRATION/pro1.cfm>
    The laboratory manager noted that the balance belongs to and is used
    by NSTD in Cell 3 for the Pu-238 project.

2.  There was an unlabeled 500 mL Wheaton bottle with clear liquid on
    the counter. Refer to Section 7.5.2 of the ORNL Chemical Hygiene
    Plan, located at
    <http://sbms.ornl.gov/sbms/SBMSearch/SubjArea/chemsafe/chp1.cfm> The
    laboratory manager noted that this bottle was in the NSTD/NNFD work
    space by Cell 3.

3.  The area was cluttered and needs improvement in housekeeping.

4.  Improper storage of PPE was noted. Ear muffs covered with a coating
    of fine white dust were observed on-top of an empty pail. Refer to
    <http://sbms.ornl.gov/sbms/sbmsearch/subjarea/ppe/ppe_sa.cfm>

5.  There is not an eyewash station in an area where corrosive liquids
    are stored/used. This issue was self identified by CSD and an action
    plan is in-place to abate this issue.

6.  There exists a potential trip hazard caused by wires emanating from
    a conduit. It is recommended that wires be taped, tie rapped, or
    other appropriate methods be used to minimize trip hazard potential.
    Refer to <http://sbms.ornl.gov/sbms/sbmsearch/subjarea/GSH/pro2.cfm>

Room 130

1.  Labeling of solutions in this laboratory was very good.

2.  The sample refrigerator temperature logbooks were not up-to-date.
    The operations manager later verified that the refrigerators were
    not in use for quality controlled items.

3.  There was a floor drain between the HVAC unit and the wall that was
    not labeled. Refer to ORNL Liquid Waste Systems at
    <http://sbms.ornl.gov/sbmsearch/SubjArea/Water/pro4.cfm> .

4.  A box was observed in front of an electric disconnect. Refer to
    <http://sbms.ornl.gov/sbms/sbmsearch/subjarea/elec/exh_elecrules.cfm>.

5.  There was inadequate machine guarding of a rotating shaft (HVAC
    blower motor). Refer to
    <http://sbms.ornl.gov/sbms/sbmsearch/subjarea/GSH/Exhibit9.cfm>

6.  The HVAC filter house needs to be evaluated to determine its
    classification as a non-permit or permit-required confined space.

Room 131

1.  Labeling of solutions in this laboratory was very good.

2.  There is not an eyewash station in this area where corrosive liquids
    are used. This issue was self identified by CSD and an action plan
    is in-place to abate this issue.

3.  Kudos to the researchers using the facilities for their attention to
    detail and great housekeeping.

Room 132

1.  Labeling of solutions in this laboratory was very good.

2.  See comments #2 and #3 for room 131.

Room 139

There was no emergency lighting in this area. It is noted that this was
recently identified by CSD.

Room 140

1.  It was undetermined if the laboratory requires safety glasses to be
    worn since there was no signage on the door. The operations manager
    will determine if this is a requirement for this area's operations.

2.  The electrical cord on the back of the alpha counter must be
    replaced. The cord was cracking near the outlet. This condition is
    contrary to SBMS Subject Area: *Electrical Work*, Exhibit:
    *Electrical Rules and Practice*, *Corded Electrical Equipment*,
    located at
    <http://sbms.ornl.gov/sbms/sbmsearch/subjarea/elec/exh_elecrules.cfm>
    .

3.  The electrical outlet near the sink is not GFCI protected. See
    reference for comment \# 2 above.

4.  There was a potential trip hazard caused by the drain line, which
    did not have hazard markings. Refer to reference cited in Room 108,
    comment #6.

5.  There was a fire safety concern regarding an unfilled penetration in
    the wall caused by a conduit. This needs to be evaluated to
    determine if penetration separates fire areas.

**[Upper Stairwell]{.underline}**

Emergency lights were not operational. It was determined that the
circuit breaker was tripped the previous night to conduct facility wide
testing of emergency lights. Circuit breaker was reset. Recommend
retesting to ensure battery is operational.

Room 209

1.  There was an unlabeled vial with a clear liquid on the counter.
    There were two unlabeled containers in refrigerator #6. See
    reference cited for Room 108, comment #2.

2.  There was a note on the hood that says "items in hood will be
    disposed." Since these items have already been designated waste, if
    they are RCRA hazardous waste, they need to be stored in a Satellite
    Accumulation Area.

3.  There were two unfilled penetration sites in the wall caused by
    conduit. This needs to be evaluate to determine if penetrations
    separates fire areas.

Room 213

1.  The SAA 596 has not been used since 5/3/02. It was recommended to
    close this SAA. The operations manager later stated that the SAA
    were needed while the laboratory was being cleaned out.

2.  A spray bottle near the sink was not labeled. The laboratory user
    identified the contents as water, and labeled the bottle accordingly
    during the walk-through. See reference cited for Room 108, comment
    #2.

3.  A pair of nitrile gloves with visible signs of chemical degradation
    was observed. The gloves were immediately removed from service.
    Refer to reference cited in Room 108, comment 4

South Docks

Compressed Gas -- Three defective straps were observed to be in-use to
secure compressed gas cylinders. Refer to
<http://sbms.ornl.gov/sbms/sbmsearch/subjarea/cgc/ExhGasCylStorReq.cfm>

**[Building 7900]{.underline}**

1.  The laboratory was very neat and organized.

2.  The laboratory user noted that there were unused, legacy chemicals
    within the area that would be removed.

3.  Uneven walking-working surface (potential trip hazard) observed due
    to cracked flooring in ground floor laboratory. Room 108, comment
    #6.

**[Building 7920]{.underline}**

Room 108

1.  It was discussed whether or not emergency lights are needed in the
    laboratory. The facility manager will verify the requirement.

2.  The centrifuges did not have an interlock feature to stop rotation
    when the lid was raised. This is contrary to Subject Area:
    *Occupational Hazard Controls*, Exhibit: *Rules for Machine
    Guarding* requirements.

Room 208

The centrifuges did not have an interlock feature to stop rotation when
the lid was raised. See subject area reference cited for Room 108.

Room 210

1.  The centrifuges did not have an interlock feature to stop rotation
    when the lid was raised. See subject area reference cited for Room
    108.

2.  The HMIS inventory sheet in the laboratory was dated 11/4/02. The
    laboratory should ensure the most updated inventory is used when
    displayed in the area.

3.  The outside entryway baseboard was coming loose from the wall
    causing a potential tripping hazard. Room 108, comment #6.

4.  It was noted that a HP meter was due for calibration on this day.
    Refer to
    <http://sbms.ornl.gov/sbms/SBMSearch/subjarea/CALIBRATION/pro1.cfm>
    .

**ATTACHMENT 2**

OAP Team Memebers

OAP Team Members

Anderson, Glenn Pearson, John

Barnard, Angela Petherick, Kevin

Belvin, Mark Powers, Bryce

Cochran, Teresa Robinson, Mark

Gregory, Scott Rosine, David

Henderson, Mike Scofield, Pat

> Paul, Doug Stachowiak, Cathy

**ATTACHMENT 3**

Observation Details

![](media/image5.wmf){width="5.997222222222222in"
height="4.111805555555556in"}

![](media/image6.wmf){width="6.1090277777777775in"
height="4.403472222222222in"}-

![](media/image7.wmf) ![](media/image8.wmf)

ATTACHMENT 4

Fire Cabinet Email

Fire Cabinet Email

Angela, Kim:\
\
As we discussed during our 4500 N \"cabinet tour,\" these under hood
cabinets may have met a legacy standard of some sort but are no longer
appropriate for use as a flammable and combustible liquids storage
cabinet where a listed/labeled cabinet is required (the yellow cabinets
seen throughout lab spaces).  Upgrades of any sort would produce a very
expensive cabinet that would not be not listed/labeled for flammable and
combustible liquids storage.\
\
We arrived at a single conclusion:  these type cabinets are useful as an
ordinary cabinet, but are not flammable and combustible liquids storage
cabinets.  Small amounts of flammable and combustible liquids may be in
these type cabinets in accordance with the guidance from both the Fire
Protection, Prevention, and Control subject area and the Chemical Safety
subject area.\
\
Thanks for your time\-- let me know if I can help again.   \
\
Gordon Earhart, PE, CSP\
Fire Protection Engineering\
Nuclear & Facility Safety Services\
Oak Ridge National Laboratory\
PO Box 2008  MS 6424\
Oak Ridge TN  37831-6424\
Office: 865-241-5674\
Fax: 865-241-5253