Chemical Management Laboratory Implementation Requirement. A Laboratory Implementation Requirement (LIR) on chemical management was issued on December 23, 1999, and became effective on April 1, 2000. The LIR defines elements of the laboratory's chemical safety program. It includes a chemical hygiene plan that applies to laboratory activities; a hazard communication plan that applies to production, construction, or maintenance activities; and several attachments on storage, labeling, spill control, personal protective equipment (PPE), and handling. The LIR consolidates requirements from nine documents in one directive and establishes a comprehensive laboratory-wide program for managing chemicals.

The Automated Chemical Inventory System (ACIS) is now required to be used for tracked chemicals, and provides the capability to maintain a database on and to display and report receipt, content, quantity, location, ownership and disposal of tracked chemicals. User requirements are being reviewed for the development of enhancements. Before 1999, chemical users were not required to use ACIS. The inventory became inflated because new chemicals were added to the system when received by materials purchasing, but not removed from the system when disposed of by owners. The ACIS was rebaselined following a March - September 1999 inventory conducted by the Industrial Hygiene and Safety Group (ESH-5), which identified 134,230 of 238,000 containers on the starting inventory as no longer being in the inventory. Requirements for owners to maintain the ACIS database were established in July 1999 and incorporated in the chemical management LIR. The hazardous material protection officer in the Nuclear Material Technology (NMT) division has independently developed some new capabilities using an off-the-shelf chemical management program and spreadsheet software, linking the inventory database to the LIR storage requirements.

In January 1999, the Laboratory Operations Working Group started a chemical management initiative, and a project team with laboratory-wide representation to champion chemical management at LANL. The team's activities include identifying and developing elements of an effective program, requesting and justifying resources to support the program, developing user requirements for a new tracking database, developing a methodology to manage various ways of purchasing chemicals, defining a procurement specification for selecting a chemical vendor, and helping to determine which chemicals should be tracked.

Some problems with implementation of the LIR for chemical management may exist at the activity level. For example, the staff reviewed a survey of a small chemical analysis laboratory untechnical Area 55 (TA-55), conducted on March 28, 2000, by the NMT safety officer and the NMT hazardous material protection officer. The staff found that corrective actions from that review involving serious chemical incompatibilities had not been completed. The occupant of the laboratory appeared to be unaware of the responsibilities of a chemical owner, including requirements to maintain familiarity with the chemical management LIR, the identity of carcinogens in the room, and the use of ACIS. TA-48¹ may also be out of compliance. The DOE Los Alamos Area Office (DOE-LAAO) completed a conduct-of-operations review of TA-48 in anticipation of the staff's review, and reported several chemical safety and radiological issues

The Board's staff believes the new LIR is a positive step, but its impact on chemical safety cannot yet be assessed. Most divisions have not met the April 1, 2000 implementation date. ESH-5, the document owner, has received numerous questions about implementation, and a focus team will be reconvened to consider issues and revisions to the LIR. Assessments of implementation are planned for summer 2000.

Status of Previous DOE Chemical Safety Initiatives. Chemical safety was the object of two previous DOE safety initiatives at LANL. The Chemical Safety Vulnerability Review (CSVR) conducted in 1994 and the Secretary of Energy's directives following the 1997 Hanford explosion required assessment of several specified vulnerabilities. LANL reported that all corrective actions identified in response to the CSVR and DOE 1997 initiatives have been completed. Additional vulnerabilities maybe present in facilities with significant chemical inventories that were not included in either of these studies. An example is TA-48, Building RC-1, as noted above.

Perchlorate Issues in CMR and TA-48. Since the review of the Chemistry and Metallurgy Research (CMR) facility perchlorate issue by the Board's staff, conducted on September 9, 1999, CMR has begun facility maintenance inside the heating, ventilation, and air conditioning (HVAC) ducts. All work in the ducts has been done under strict work controls, including extensive and heavy personal protective equipment (65-75 lbs). The Energetic Materials Research and Testing Center (EMRTC), Socorro, New Mexico, carried out drop hammer impact and thermal tests on several surrogate perchlorate mixtures thought to be conservatively representative of the CMR residues. The results of these tests, presented in a EMRTC report, indicate that the materials' threshold areal densities for shock sensitivity are 1.5 to 7 grams/ft²--at least three times greater than any densities found. Thermal tests, in which some perchlorate mixtures underwent violent reactions when heated in small chambers, indicate that sensitivity to thermal explosion remains a hazard. Planned system upgrades include completion of the manual washdown system and replacement of the HVAC High Efficiency Particulate Air (HEPA) filters, known to contain perchlorates. The duct washdown system upgrade and reactivation will be coordinated with the replacement of the HEPA filters in Wings 2,3,5, and 7 so as not to degrade the new filters. Future fuming operations in CMR with perchloric acid must await development of a qualified and tested fume capture system, which has not yet been completed.

The perchlorate problem in Building RC-1, TA-48, is less extensive, but involves heavier deposits of perchlorates--up to 3,600 mg/ft². However, testing done in LANL DX Division on samples of the material obtained from the ducts indicates that the material is inert to the drop hammer impact, spark, and friction tests, and it does not propagate a flame when ignited with a torch. It appears that perchlorates may not be the contact hazard they were originally thought to be. The staff will monitor any new results as they become available.

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¹TA-48, Building RC-1, RadioChemistry Facility, is designated as a hazard category 3 nuclear facility. Earlier this year it had not been identified as a defense nuclear facility since it was thought that defense activities were not performed there. As a result, DOE-LAAO plans to require a Basis for Interim Operation within a year, followed by an Authorization Agreement.