Safety in the Underground Construction and Operation of the Exploratory Studies Facility at Yucca Mountain (1995)

Byron M. Ishkanian

The Yucca Mountain Project (YMP) safety effort benefits not only from the experience of other major projects but also from recent innovative safety ideas. The project has access to an excellent reservoir of knowledgeable personnel. If a cooperative team spirit is built among all participants—agencies, contractors, subcontractors, and subsidiary personnel—many problems can be solved before they become obstacles. The YMP will benefit from an environment promoting common sense in safety through prudent use of safety codes, inspections, job hazard analyses, communication, and a climate of safety.

Of primary importance during the planning phase of a safety effort for a massive program, such as the YMP, is the imposition of a practical base that addresses the outstanding needs of all who will work on the premises. The building blocks of this foundation include:

• the agency that has employee-safety jurisdiction over the project;
• the safety codes that apply at the site;
• a cooperative safety effort among all participants;
• development and maintenance of good channels of communication;
• meaningful safety monitoring of all operations;
• job hazard analysis of planned operations;
• analysis of accidents to correct conditions;
• initiation of changes in safety and health requirements, when necessary;

• safety training for all levels of personnel;
• increased awareness of expected exposures and risks associated with the use of different types of excavation equipment;
• management of safety liability on a multicontract work site; and
• handling of emergency response in case of accidents, fires, or a disaster.

Each of these items is discussed below and, where appropriate, accompanied by examples. The examples are the result of distillation of ideas from a number of projects and may be freely adapted for a given project after revision for local conditions.

The YMP is situated on a federal reservation in the state of Nevada and is being constructed under the auspices of the Department of Energy (DOE). Nevada has state-plan status within the federal Occupational Safety and Health Administration (OSHA) framework, and as such the Nevada OSHA may be designated as the YMP enforcement agency. States with state-plan status obtain funds from the federal government, add their own funds, and run their own job safety programs. There are about 28 states in this category. These states operate within a tight framework that is designed by the federal OSHA and receive approximately one-half of their program funds from the federal government.

Experience dictates, however, that should the Nevada OSHA be given the job safety responsibility, there will be very close scrutiny of the project by the federal OSHA's area and regional offices. Another scenario might have the Nevada OSHA watching private entities at the YMP, while the federal OSHA watches the federal agencies; this approach could be a bureaucratic nightmare.

Operating a safety program in the state-plan mode, a state may choose to use its own safety orders or adopt the federal OSHA orders. California maintains its own safety orders, which is possible as long as the orders are at least as stringent as parallel federal regulations.

States that maintain their own safety orders are constantly at loggerheads with the federal OSHA over regulations that the federal agency determines are not as good as its own—not as stringent; not timely; and basically, not the same as the federal OSHA's.

A state with state-plan status has the choice (1) to go its own way, not accepting federal monies and the accompanying dual safety jurisdiction within the state or (2) to accept the federal safety orders, receive the federal monies, and tolerate federal micromanagement. Nevada retains a measure of its identity by holding state-plan status while adopting the federal safety regulations. As a result, regardless of who has safety jurisdiction, the federal regulations will be in effect at the YMP.

Passage of the Federal Occupational Safety and Health Act in 1970 caused a flurry of activity regarding regulations for the new agency. For the most part, American National Standards Institute standards were quickly adopted, though they were not written with compliance enforcement in mind. In the underground construction arena, a set of standards was adopted as a stopgap measure. The revision of the stopgap orders in Title 29, Section 1926.800 of the Code of Federal Regulations (29CFR1926.800) for underground construction began in 1973. California tunnel safety orders, which were being rewritten, were held up, since they would have to be as stringent in the new orders as the proposed federal orders. As time passed, however, state regulators went ahead, since the federal process appeared to be moving slowly.

The federal rewriting of 29CFR1926.800 took almost 17 years. Were it not for the Milwaukee Tunnel accident, where three people were killed in a methane explosion during construction, the old regulations might still be on the books. Although many involved in the underground industry contributed to the new regulations through hearings, verbal communications, and letters to the authors, the final role issued on Friday, June 2, 1989, was far from what was expected. This role was a set of underground construction regulations that appeared to have been thrown together quickly in the wake of the Milwaukee accident. The orders have many shortcomings that leave those who wish to comply in a quandary. Some of the most obvious of these shortcomings are described below.

Subsection k (1)ii of 29CFR1926.800 seems to allow the use of natural ventilation in some instances. This regulation opens the door to other-than-mechanical ventilation, a dangerous loophole. Section (4) states that mechanical air flow shall be reversible. This would appear to preclude the use of a flexible vent line, since reversal of the air flow would collapse the vent line. Has this eliminated the use of a flexible vent line? Absolutely not. In fact, flexible, nonmetallic vent lines are finding greater use than ever before. The federal OSHA regulation confounds itself further by stating in Section (11)(i) that vent lines should "be constructed of fire-resistant materials."

How are these regulations being implemented in the real world? Operators are selling OSHA on the idea that the reversal fan is placed within the tunnel atmosphere, usually on the excavation equipment. When reversal is needed in the ventilation system, one fan in the blowing mode is shut down, and the other, at the distant end of the main ventilation line, is started up. The primary purpose of any reversal of ventilation requirement is to retain some semblance of control of the underground atmosphere from the surface, in case of an underground emergency, fire, or ground collapse. When the reversal fan is at or near the heading, any occurrence that cuts off the vent line between the fan and the portal, destroys the fan, or closes the tunnel cross section negates the reversal capability. Furthermore, inferring that the use of fire-resistant materials are required in potentially gassy and gassy classified operations, by exclusion, appears to allow the use of other than fire-resistant vent-line materials in all other operations.

Of great importance to the YMP is the rule requiring that, because of the possible contamination of formations for the characterization study, much of the excavation, whether by road header, tunnel boring machine (TBM), or drilling, be done with as little water or other lubricants as possible. This requirement automatically dictates an exhausting ventilation configuration, wherein the generated dust is collected in the ventilation line as quickly as possible and discharged at the surface. This will lead to the placement of the main fan in the tunnel, at or near the advancing face, blowing down the vent line to the surface. The fan at the surface will be idle, used only to provide the reversal capability required in the underground construction orders.

In many underground operations, federal, state, and local laws prohibit dry drilling of rock. It will be interesting to see how these contrasting philosophies affect the YMP. Serious consideration should be given to requiring metallic vent lines only in the main ventilation systems. All controls would be at the surface. This would allow the emplacement of one reversible fan in fresh air at the surface and a line that is not fire-resistant but fire-proof.

This Subsection h of 29CFR1926.800 pertains to the actions that must be taken in an underground construction atmosphere to protect employees from explosive gases. It is unlikely that explosive gases, which are natural in origin, will be encountered during excavation at the YMP site.

Section (1)(i) states that if explosive gases are encountered at 10 percent or more of the lower explosive limit (LEL) for a period exceeding 24 hours, then the operation is classified as potentially gassy. Section (2)(i) goes a step further and states that if

explosive gases are encountered or intrusion continues for three consecutive days, then the operation is classified as gassy at 10 percent LEL. No sane operator, agency, or contractor would allow explosive gas intrusions at 10 percent of the LEL for 1 hour, much less 24 hours or three days, before taking corrective action. Intrusions of that magnitude demand immediate, instantaneous action. What is now intrusion at 10 percent LEL, in the next bedding plane, fracture, or push could be 100 percent of the LEL and in the explosive range. Adjustments of the ventilation system, excavation rate, and any other valid control must be made immediately. Disaster is just around the next comer. Another unanswered question is who makes this classification change determination.

Section (2)(ii) makes matters even more difficult to discern, stating that if there has been an ignition of methane or flammable gases emanating from the strata, then the classification is automatically gassy. This does not provide much guidance to an operator who encounters explosive gas in small amounts within a period of less than 24 hours or experiences a gas ignition underground. The operator wants and needs a classification change, but from whom? The operator must write the change order while trying to protect the tunnel atmosphere. This has occurred on several projects.

Illumination requirements for underground work areas and other construction locations are noted in Table 1, which is taken from Table D-3 of 29CFR1926.56(a). This table requires, albeit not clearly, 5 foot-candles (ft-c) of illumination in tunnels, assumed to be along the lengths of all tunnels, and 10 ft-c (see exception) at the "tunnel and shaft heading during drilling, mucking, and scaling." In addition, it indicates that "Bureau of Mines approved cap lamps shall be acceptable for use in the tunnel heading." Loosely interpreting this regulation, one might say that 5 ft-c of illumination is required along the length of all tunnels under construction and 10 ft-c is required at the heading. In reality, this can be and has been interpreted in many ways. Some tunnel projects have provided 10 ft-c at the heading; required all personnel to wear a cap lamp; and required no lighting along the length of the balance of the tunnel, except at emergency phone, first aid, and pump and valve control stations. The author has seen few tunnels having 5 ft-c of illumination along the entire length. In those where cap lamps are required to be worn, one soon finds few actually being worn but rather the majority being hung on equipment near the individual.

Ventilation, hazardous classifications, and illumination are but three of many regulations in 29CFR1926.800 that lack clarity and guidance and are instead ambiguous and impractical. The YMP must eliminate as many of these critical regulatory conflicts as possible, before they become obstructions to the work process.

Since a number of federal agencies will be participating in the work at the YMP, a cooperative effort early on is important. This effort can take many forms. Continuous communication by DOE on successive phases of project development would make other

agencies feel they are an integral part of the action, enabling these agencies to contribute meaningfully.

One of the primary efforts in this area is the writing of a safety manual for the entire project. Those who take part in the writing of such a manual, or comment on or contribute to the document, often feel that it is their own. Through this and other means, continuous contact of the prime management parties can diffuse problems before they develop into major obstacles. In addition, contact among top safety individuals in these agencies and companies tends to lessen personality conflicts and build a team effort and atmosphere.

Communications start to slip as a project matures and nears the completion stage. The birth of a large project sees various meetings, conferences, and exchanges of information of all types, but gradually a degree of complacency sets in, and communication channels start to weaken. A constant communication effort is required to maintain life in these channels during the construction phase. The operational phase is another subject. Sometimes attending a multitude of meetings is self-defeating, leaving little time to do meaningful work. Concentrating on a few safety meetings, maintaining meaningful content, and discussing current problems and solutions are far more effective than meeting just to be meeting.

Most major projects settle down to the following schedule:

1. tailgate safety meetings of foremen and personnel (weekly);
2. progress meetings, with a safety section (usually biweekly); and
3. supervisors' safety meetings, for overall project safety direction (monthly).

There will be other meetings prior to major occurrences or hazard analyses, but the three types listed above usually suffice. The information that is generated is then distributed throughout the project work force.

Continuing efforts should be made to apprise contractors, subcontractors, and others of information vital to their work. For example, many times the contractor's hands-on personnel are the last to know what is contained in geotechnical and similar reports. These reports should be available to all who are involved in the work, especially to those involved in underground operations. Figure 1 is a sample form for a safety meeting report.

Safety monitoring or inspections are an integral part of any construction project. Questions for which specific answers are dependent on specific projects include: Who does this monitoring? What is the frequency of monitoring? What are the results of the inspection? And what actions do safety violations trigger?

If each agency chooses to have its own safety officer, then the cooperation among entities must be spelled out in the project safety manual. If all agencies work solely from checklists, then the lists must be uniform throughout the project. Figure 2 shows the first page of a construction safety inspection checklist. Although some feel that safety checklists blur the safety instincts of those with responsibility, a combination of the two philosophies is an excellent blending. Competent people who do not operate by rote can use a checklist as a back up, so as not to miss the smaller items. The individual's competency, knowledge, and safety instinct will ferret out the major exposures.

If a safety officer is assigned on a given project, then the frequency of inspections is constant. However, there is some question as to whether this is a valid method of operation. In some instances, a mine safety inspector, permanently assigned to a mine location from an oversight agency, loses his effectiveness in a very short period of time. Therefore, when he attempts to take corrective actions, his efforts are taken lightly. However, company—or contractor—assigned safety officers tend to maintain their effectiveness. A balance is necessary, so that inspections are meaningful and not done continuously but accomplish the task with strategic time lapses.

A job hazard analysis is a necessity before any phase of construction that is known to be dangerous. Development of a hazard analysis plan for such a phase is in the hands of the safety officer and the manager directly responsible for the work. This plan then serves as a training vehicle for all those who will take part in the operation. The primary consideration in the development and implementation of any hazard analysis plan is the safety of the personnel who will actually do the work. Such plan development is a giant step forward in assessing all of the effects and exposures in dangerous operations. However, adequate time must be allowed for these deliberations, so that individuals can judge the adequacy of the analysis and submit comments. For an example of a generic job hazard analysis form that might be adapted for the YMP, see Figure 3.

Industrial accidents occur daily and are investigated, sometimes in great detail. This information is forwarded to management or the heads of companies or agencies, but what happens next is critical to the whole process. Is the information used to prevent a recurrence? Is it used to fortify a legal position? Or, is it simply buried in the files? It is important for these reports to be used and for corrective action to be taken immediately.

Figures 4 and 5 show a supervisor's accident investigation report form and a monthly accident experience summary form.

When the project's safety manual has been written and put in place, all portions of the manual must be at least as stringent as applicable federal OSHA regulations. The manual may include requirements that are more stringent. However, as operations proceed, changes may be necessary in certain portions of the manual. What is the most suitable way to make these changes?

Bureaucracies that write and enforce regulations must go through the following procedures during promulgation of the safety orders:

1. A demonstrated need for new regulations must be shown.
2. An advisory committee is convened to study the problem and to write the regulations.
3. The written changes are then massaged for clarity, conciseness, consistency, and appropriateness.
4. Public hearings are held for comments.
5. Revisions are made and comments are solicited from the public, the advisory committee, and other regulatory and oversight administrative agencies.
6. The regulations are rewritten and issued.

This system works quite well but takes an inordinate amount of time. Projects like the YMP can use the basic framework of this system for proposed changes in safety and health requirements. Using a committee format, the public procedures can be adapted to specific projects. Solicitations of comments defuse complaints that one or another party was not informed of the changes.

Safety philosophy incorporates the constant need for training all levels of personnel on a given project. However, with a project such as the YMP, how is this training effort organized? There are three groupings of persons on this and similar projects: full-time underground personnel, personnel who periodically go into the underground environment, and visitors.

Full-time underground personnel and those who go underground periodically should receive an initial eight hours of training and follow-up or specialized training, according to the subject and the demand. It is imperative that accurate records be kept of the participants in these training sessions. This record is crucial when dealing with exposures of employees to hazardous materials, radon daughters,¹ and various contaminants. Visitors must be given an orientation that discusses exposure to hazards on the premises. If visitors must wear protective equipment during tours, that instruction should be included during their orientation. Experience from other projects dictates that visitors must be kept in a tight group and escorted throughout the tour.

Three different methods of excavation are to be used in the YMP: conventional drill-and-blast, TBMs, and road headers. The following exposures are common to all methods of excavation:

• haulage equipment accidents;
• collapse of ground support;
• hoisting of personnel and equipment;
• radon-daughter encounters in the welded tuffs;
• high dust concentrations, if the characterization studies preclude the use of water for drilling and excavation lubrication and dust control; and
• contaminants from diesel exhaust in the underground atmosphere.

Exposures that are common to TBM and road-header operations include:

• personnel being caught in or between moving parts of machinery;
• falling ribs and lagging segments;
• high-voltage exposures underground, trailing cables, and transformers;
• and ignition of atomized lubricants and hydraulic fluids.

Exposures that are common to drill-and-blast methods include:

• explosives handling and usage;
• static electricity;
• storage and transportation of explosives; and
• propagation of energy release along fractures and fault planes.

Each of the three methods of excavation has its strengths and weaknesses. Injury and accident statistics in the mining industry, with category breakdown, can be obtained from the Mining Safety and Health Administration (MSHA). However, federal OSHA statistics for the construction industry lump TBM and road-header accidents with others and are almost impossible to break out.

One can imagine, then, that expected exposures will be high for dust, heat, noise, and vibration in the mechanical excavation modes (i.e., TBM and road-header methods), and for dust and noise in the drill-and-blast work.

Organization, communication, shared responsibility, one safety manual to which all involved contractors and managers contributed, and the development of a favorable safety climate will have a beneficial effect on liability experience. A team effort will prevent or greatly lessen conflict on the site.

Many projects are built in the center of urban areas (e.g., The Metro Rail Project in Los Angeles) where the general public is exposed to all of the surface manifestations of underground work (e.g., noise, traffic congestion, dust, dirt, mud, ground settlement, exhausting of gases and vapors, and general disturbance of life around the project site). On the other hand, at remotely located project sites (e.g., the YMP) the actions of one contractor and its employees have an impact on another contractor and its employees working at that same site. It is necessary that safety engineers and management, with the guidance of the construction manager, coordinate efforts to solve many safety problems

in their infancy or before work progresses. At the same time, the public must be protected from the cumulative exposures that are created by the contractors' efforts.

A construction safety report may help lessen confusion and clarify expectations from contractors and their supervisory personnel. Figure 6 shows a summary of construction safety reports. It is in the submission, writing, and research for these reports that team effort and cooperation starts.

An incident command organization chart (Figure 7) is essential to handle the response in case of an accident, fire, or disaster. This chart should not be so cumbersome and complicated that personnel decline to study it. The task of responding to accidents, fires, or disasters should be less complicated in a remote area, where urban fire departments are not involved. Ascending levels of emergency are the following:

1. a primary level for accidents, treatment, transportation of the injured, and so on;
2. the next level for fires, explosions, underground adjustments, command posts, and responses by select personnel; and
3. the highest level of response to a disaster, including the first two levels above.

Incident commanders should organize their forces by calling for drills; organizing the various components; and selecting key personnel, rescue crews, and surface back-up personnel.

Safety jurisdiction of the YMP may be in the hands of federal OSHA, of Nevada OSHA in the private sector and federal OSHA in the governmental sector, or of DOE. Regardless of jurisdiction, federal OSHA regulations will be in effect, with reference to MSHA regulations in specific areas and instances.

Site stratigraphic characterization studies may preclude the use of water or other lubricants during drilling and excavation to prevent native rock contamination. This will increase the hazard from dusts and possibly force the main ventilation systems to be in

the exhausting mode, whether excavation is done by drill-and-blast, TBM, or road-header equipment.

To build an atmosphere of team safety on the project, there must be an all-encompassing safety manual, good communication among all agencies and contractors, and continuous contact among prime participants. Safety monitoring must be meaningful, coupled with job hazard analyses of proposed operations and a gleaning of every bit of useful information from accident investigations in order to prevent recurrence.

Clear lines of responsibility must be drawn to designate those who are authorized, designated, qualified, and competent to complete assigned tasks. Changes in the safety and health regulations must have input from all those with legitimate interest. Safety training is a continuing process. Expected exposures during various work operations pose a challenge in that one must ensure that the personnel actually doing the work are knowledgeable of the hazards to which they are to be exposed and the methods of mitigation of these hazards.

Emergency response plans must be rehearsed to ensure preparation and no last-minute surprises. Safety liability on adjoining contracts must be clear, but a cooperative effort at the management level is necessary to prevent the actions of one phase of the work unfavorably impacting another.

There is no excuse for the YMP not to have the highest level of safety effort and Success.

After the presentation, Russ Baumeister, occupational safety and health specialist at DOE, said that the YMP received notification from the state of Nevada recognizing that the state OSHA has the authority to enforce project compliance with federal OSHA regulations. However, DOE also has rights in a crisis situation and, as in the Superconducting Supercollider Project, is likely to negotiate with the state authority.²

Regarding the need for DOE and other agencies to work together, it was noted that the Army Corps of Engineers has suggested that federal agencies involved in construction put together a construction safety manual. This document might then supplant 29CFR1926 for federal construction projects. Although DOE could have conflicting

issues that preclude total participation, its best interest would be served in reaching a meeting of the minds with other agencies.

U.S. Department of Labor. Code of Federal Regulations 29, Part 1926: Safety and health regulations for construction.

World Tunneling Magazine, November 1991.

Rail Construction Corporation. 1993. Safety and Security Manual, Revision 6. February 22. Los Angeles, California.

California Administrative Code. 1973. Title 8, Chapter 4, Subchapter 20: Division of Occupational Safety and Health. Tunnel Safety Orders.

Los Angeles Fire Department. 1990. Tunnel Incident Command Organization. California.

California Administrative Code. 1966. Title 8, Chapter 4, Subchapter 17: Division of Occupational Safety and Health. Mine Safety Orders.