U.S. Department of Energy 

Office of Inspector General 

Office of Inspections and Special Inquiries 

Inspection Report 

Chemical Safety Protocols at the 

Pantex Plant 

DOE/IG-0756 February 2007 


CHEMICAL SAFETY PROTOCOLS AT THE PANTEX PLANT 

TABLE OF 

CONTENTS 

OVERVIEW

Introduction and Objective .................................... 1 

Observations and Conclusions .............................. 1 

DETAILS OF FINDINGS 

Background ....................................................... 2 

Fire Safety Concerns ........................................... 2 

Safety Warning Signs .......................................... 4 

Eye Wash and Safety Shower ................................ 5 

Observation ...................................................... 5 

RECOMMENDATIONS ....................................... 7 

MANAGEMENT COMMENTS .............................. 7 

INSPECTOR COMMENTS ................................... 7 

APPENDICES

A. Scope and Methodology ................................... 8 

B. Management Comments................................. 9 
Overview

Page 1 Chemical Safety Protocols 

 at the Pantex Plant 

INTRODUCTION The Pantex Plant (Pantex) mission includes, among other things, 

AND OBJECTIVE the assembly and disassembly of nuclear weapons and the 

manufacturing and testing of non-nuclear high explosives. To 

accomplish this mission, Pantex uses approximately 3,000 

different kinds of hazardous chemicals. Effective management of 

these chemicals is an important element in protecting the health 

and safety of the Pantex workforce. BWXT Pantex (BWXT) is the 

prime contractor that operates Pantex for the Department of 

Energy’s (DOE’s) National Nuclear Security Administration. As 

such, BWXT is responsible for managing the Pantex occupational 

safety and health program. 

 To properly manage its hazardous chemicals, BWXT must follow 

various safety and health regulations, including Occupational 

Safety and Health Administration (OSHA) regulations, National 

Fire Protection Association (NFPA) standards, and DOE orders 

that are included in the BWXT prime contract. 

 The objective of this inspection was to determine if BWXT 

implemented an effective chemical safety program. 

OBSERVATIONS AND We concluded that in most respects, BWXT implemented an effective 

CONCLUSIONS chemical safety program; however, we identified several areas that 

needed improvement. Specifically, we found that: 

• A compressed gas facility that contained numerous flammable 

chemicals lacked a fire extinguisher, as required by OSHA, and 

a means to summon the fire department, as required by DOE; 

• Safety warning signs were not posted outside several facilities 

that contained hazardous chemicals such as flammables and 

explosives, as required by OSHA and the NFPA; and 

• An eye wash and a safety shower in a hazardous chemicals 

storage building were not inspected, as required by Pantex 

procedures. 

We also observed significant discrepancies in the hazardous 

chemicals inventory. For example, the database quantities of 

acetic anhydride, ammonia, dimethyl sulfoxide, and hydrochloric 

acid were significantly different than actual quantities. 
Details of Findings 

Page 2 Details of Findings 

BACKGROUND An August 10, 1992, Memorandum of Understanding 

(Memorandum) between OSHA and DOE states that DOE 

contractors must comply with applicable OSHA standards as well 

as other safety and health requirements. DOE’s contract with 

BWXT contains Safety Requirements Identification Documents 

(S/RIDS) for safety and health and fire protection that BWXT must 

follow. These S/RIDS apply to aspects of Pantex’ hazardous 

chemicals protocols and cite the OSHA Memorandum as well as 

numerous OSHA and NFPA standards and DOE orders as 

applicable to BWXT. 

According to OSHA, a hazardous chemical refers to any chemical 

that is a physical or health hazard. A chemical that is a physical 

hazard includes combustible liquids, compressed gases, explosives, 

flammables, organic peroxides, oxidizers, or water-reactives. A 

chemical that is a health hazard may cause acute or chronic 

unhealthy effects in exposed employees. Health hazards include 

carcinogens, corrosives, toxic chemicals, and irritants. 

Hazardous chemicals examined during this Office of Inspector 

General (OIG) review included acids, bases, other corrosives, 

flammable and combustible liquids, compressed gases, toxics, and 

explosives, including shock sensitive compounds. We also 

inspected indoor and outdoor hazardous chemical storage areas, as 

well as buildings and laboratories that contained hazardous 

chemicals. 

FIRE SAFETY We found that a compressed gas facility that contained numerous 

CONCERNS flammable chemicals lacked a fire extinguisher, as required by 

OSHA, and a means to summon the fire department, as required by 

DOE. 

The compressed gas facility, known as the 12-5 North Yard, is an 

outdoor 3-sided building surrounded by a fence that also encloses a 

large area around the building. The facility is also adjacent to a 

primary road and a populated building containing large quantities 

of hazardous chemicals. We observed the following flammable 

compressed gas cylinders stored at the 12-5 North Yard: 6 

acetylene cylinders, an ethane cylinder, several hydrogen 

cylinders, and numerous compressed oxygen cylinders. Acetylene, 

ethane, and hydrogen are highly flammable under pressure. 

Ethane and hydrogen also readily form explosive mixtures when in 

contact with air. Compressed oxygen enhances combustion and 

may increase the risk of fire in flammable materials.
Page 3 Details of Findings 

 The Pantex Fire Protection S/RID states that the contractor is 

required to perform fire prevention engineering activities to ensure 

that facilities and processes are provided with the required level of 

fire protection. OSHA 29 CFR 1910.106, “Flammable and 

Combustible Liquids,” states that suitable fire control devices, such 

as portable fire extinguishers, shall be available at locations where 

flammable or combustible liquids or flammable aerosols are 

stored, including outdoor container storage areas. A DOE EH Fire 

Protection Engineer stated that this regulation applied to the 

flammable compressed gases that the OIG identified at the 12-5 

North Yard. Additionally, the Pantex Fire Protection S/RID states 

that fire protection systems and equipment shall be provided to 

detect, suppress, and limit the spread of fires in its facilities, and 

that portable fire extinguishers are maintained and located to 

permit personnel to extinguish incipient fires. DOE Order 420.1, 

“Facility Safety,” states that an approved means to summon the 

fire department shall be provided. 

During our site inspection, we informed BWXT officials of our 

concerns that there were numerous cylinders of flammable 

compressed gases stored at the 12-5 North Yard, and that the 

facility did not have a fire suppression system or a means to notify 

the fire department in the event of a fire. After we raised our 

concerns, BWXT officials advised us that they subsequently 

determined that both were needed and would install a fire 

extinguisher and a telephone at or near the 12-5 North Yard. 

DOE Order 420.1, “Facility Safety,” states that comprehensive, 

documented fire protection self-assessments shall be performed 

and include all aspects of the fire protection program. We noted 

that the applicable Fire Hazards Facility Assessment covering the 

12-5 North Yard was completed by BWXT in February 2005. This 

Assessment indicated that all of the stored gases were inert and 

that no fire suppression systems were required. A DOE Office of 

Environment, Safety and Health (EH) Fire Protection Engineer 

advised us that there is a continuing obligation to ensure that all 

fire hazards are identified and mitigated. The DOE EH Fire 

Protection Engineer also advised that installation of a fire 

extinguisher and telephone are minimal mitigating actions. He 

further advised that a thorough assessment of the storage facility 

could also lead to additional mitigating actions by BWXT. 

Therefore, it may be appropriate for BWXT to assess whether 

additional corrective actions should be taken. 
Page 4 Details of Findings 

SAFETY WARNING We found that safety warning signs were not posted outside 

SIGNS several facilities that contained hazardous chemicals such as 

flammables and explosives, as required by OSHA and the NFPA.1 

These facilities included the High Explosives Synthesis Facility, a 

nearby portable storage facility, and the 12-5 North Yard. 

Subsequent to our inspection of the portable buildings, we were 

told that Pantex posted warning signs on the portable buildings. 

Also subsequent to our site visit, a Pantex Division Manager said 

that he developed an implementation plan and posted warning 

signs on the doors of the High Explosives Synthesis Facility. 

The Pantex Occupational Safety and Health and Fire Protection 

S/RIDS states that both OSHA and NFPA posting requirements are 

applicable to facilities where flammable and other hazardous materials 

are present. OSHA posting requirements state that signs or tags shall 

be posted to ensure awareness of the hazards present. The NFPA lists 

numerous specific posting requirements for facilities where flammable 

and other hazardous materials are present. The DOE EH Fire 

Protection Engineer stated that these OSHA and NFPA requirements 

were applicable and should be followed. 

The High Explosives Synthesis Facility contained numerous 

hazardous solids, liquids, and gases, including flammables and 

explosives. During our site inspection, we observed that a large 

sign marked “Danger - Hazardous Operations” was lying on the 

ground in back of the building. We also observed that a portable 

storage building, which was located about 65 feet beyond the High 

Explosives Synthesis Facility, contained flammable chemicals; 

however, warning signs were not posted. Further, the 12-5 North 

Yard contained flammable and potentially explosive compressed 

gas cylinders, but there were no warning signs posted. 

BWXT officials told us that the hazardous operations warning sign 

on the ground in back of the High Explosives Synthesis Facility had 

fallen down from in front of the building “a long time ago.” A 

BWXT official said that BWXT planned to re-install the hazardous 

operations warning sign in front of the High Explosives Synthesis 

Facility. BWXT agreed that warning signs should be posted on the 

portable flammable chemicals building as well as on the nearby 

acids and bases portable buildings. 

 

1

 The Pantex Occupational Safety and Health S/RID states that signs or tags shall be posted to ensure awareness of the hazards present, and cites 

OSHA 29 CFR 1910.145, “Specifications for Accident Prevention Signs and Tags,” and OSHA 1926.200, “Accident Prevention Signs and Tags,” 

as the applicable standards. Further, the Pantex Fire Protection S/RID identifies NFPA 30, “Flammable and Combustible Liquids Code,” (which 

incorporates NFPA 704, “Identification of the Fire Hazards of Materials for Emergency Response),” and NFPA 55, “Standard for the Storage, 

Use, and Handling of Compressed Gases” as applicable. Additionally, NFPA 30 and NFPA 704 are OSHA requirements pursuant to OSHA 29 

CFR 1910.6, “Incorporated by Reference.” Thus, these OSHA and NFPA provisions are applicable at Pantex. 
Page 5 Details of Findings 

EYE WASH AND We found that an eye wash and safety shower in a hazardous 

SAFETY SHOWER chemicals storage building were not inspected, as required by 

Pantex procedures. When a hazardous chemical is splashed in the eye 

or on the body, decontamination with water from an eyewash or safety 

shower is the standard first aid response to mitigate potential serious 

injury. A Pantex site procedure titled “How to Inspect, Identify, 

Evaluate, and Abate Safety Hazards in or Around Facilities,” required 

Pantex to conduct quarterly inspections of its eyewashes and safety 

showers to ensure their proper function. The Pantex Building 

Facilities Manager acknowledged that they were required to conduct 

the inspections on a quarterly basis. We determined, however, that 

they were not inspected during the last four quarterly safety 

inspections. The eye wash and safety shower were in Building 12-

118, a large hazardous chemicals storage building with repackaging 

laboratories. 

OBSERVATION We also observed significant discrepancies in the hazardous 

chemicals inventory. For example, the database quantities of 

acetic anhydride, ammonia, dimethyl sulfoxide, and hydrochloric 

acid were significantly different than actual quantities that we 

identified at Pantex Building 11-55. 

 As outlined in the chart below, we observed significantly less 

quantities of acetic anhydride, ammonia, and dimethyl sulfoxide in 

the Pantex hazardous chemicals database compared to the actual 

quantities that we identified at Building 11-55. We also observed 

that the database listed significantly more hydrochloric acid 

compared to the actual quantity that we identified at Building 11-55. 

Quantities of Hazardous Chemicals Listed in 

Pantex Database vs. Actual Quantities

106

287

600

146

346

117

200

59

0 100 200 300 400 500 600 700

Hydrochloric

Acid (gal)

Dimethyl

Sulfoxide (gal)

Ammonia (lbs)

Acetic Anhydride

(gal) Database

Actual
Page 6 Details of Findings 

Chemical Database 

Quantities 

Actual 

Quantities Difference 

Acetic Anhydride 59 gallons 146 gallons 87 gallons 

Ammonia 200 pounds 600 pounds 400 pounds 

Dimethyl Sulfoxide 117 gallons 287 gallons 170 gallons 

Hydrochloric Acid 346 gallons 106 gallons 240 gallons 

Acetic anhydride is flammable and corrosive and is a health 

hazard. Ammonia gas is flammable, corrosive, and a toxic 

inhalation hazard, and can also be fatal if inhaled. Dimethyl 

sulfoxide reacts violently with a number of materials and is an eye, 

skin, and respiratory irritant. Hydrochloric acid is extremely 

corrosive; vapor inhalation can cause serious injury, and ingestion 

can be fatal. 

BWXT officials acknowledged that these discrepancies were a 

concern and that they were taking actions to try to improve the 

accuracy of their inventory. They stated that the centralized 

hazardous chemicals database was antiquated and limited and that 

they were upgrading the computer software. The central database 

is used for compiling an annual inventory of the site’s hazardous 

chemicals, which is an important part of the site’s Emergency 

Planning Hazards Assessment (EPHA). The EPHA is the basis of 

the site Emergency Management Program. Thus, having an 

accurate site inventory of hazardous materials is key to the 

adequacy of the Emergency Planning Hazards Assessment and the 

Emergency Management Plan. 

During our site visit, we were told that Pantex last conducted a 

physical inventory of all its buildings in 1997. A DOE official 

responsible for issuing DOE-wide safety and health policies 

advised that, although there is no specific requirement for the site 

to periodically conduct a physical inventory of all of its hazardous 

chemicals, he considers it to be a best practice. Pantex, however, 

has a 2006 performance measure to conduct a physical inventory 

of all hazardous chemicals. Subsequent to our site visit, we were 

told that BWXT completed a physical inventory of all of the 

hazardous chemicals located at Pantex. 

We believe that upgrading the database and having an accurate 

physical inventory are significant steps towards improving site 

emergency assessment and planning. These actions should 

improve current accuracy of the hazardous chemicals database, 

which in turn, should increase the adequacy and effectiveness of 

emergency assessments and planning at Pantex. Therefore, we 
Page 7 Recommendations 

 Management and Inspector Comments 

believe that conducting periodic physical inventories of hazardous 

chemicals should be a continuing performance measure and/or site 

requirement. 

RECOMMENDATIONS We recommend that the Manager, Pantex Site Office, ensures that 

BWXT: 

1. Assesses all hazards and conducts fire protection engineering 

activities to mitigate any hazards on an ongoing basis; 

2. Posts appropriate safety warning signs at appropriate locations 

at all facilities that contain hazardous chemicals; 

3. Inspects all eye wash and safety showers in buildings that 

contain hazardous chemicals to ensure their proper function; 

and 

4. Continues to implement improvements that will enhance the 

accuracy of the central hazardous chemicals database and 

considers establishing a requirement to conduct recurring 

periodic physical inventories of its hazardous chemicals. 

MANAGEMENT The National Nuclear Security Administration (NNSA) agreed 

COMMENTS with the report’s findings and recommendations and directed the 

contractor to develop a corrective action plan. Management’s 

comments are provided in their entirety in Appendix B. 

INSPECTOR We found NNSA’s comments to be responsive to our report. 

COMMENTS However, because the comments did not include planned 

corrective actions with target completion dates, a Management 

Decision is required.
Appendix A 

 

Page 8 Scope and Methodology 

SCOPE AND We interviewed Federal and contractor officials at the Pantex 

METHODOLOGY Plant and DOE officials at DOE Headquarters. We reviewed 

relevant site, DOE-wide, and Government-wide documents. We 

also conducted a physical check of hazardous chemicals at several 

indoor and outdoor storage areas. 

 As part of our review, we evaluated BWXT’s implementation of 

the “Government Performance Results Act of 1993.” Specifically, 

we reviewed a performance measure that required BWXT to 

conduct a physical inventory in fiscal year 2006 of all hazardous 

chemicals present. 

 This inspection was conducted in accordance with the “Quality 

Standards for Inspections” issued by the President’s Council on 

Integrity and Efficiency. 
Appendix B 

____________________________________________________ 

_____________________________________________________________________________ 

Page 9 Management Comments 

 
 IG Report No. DOE/IG-0756 

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