(ENG) EHS Lessons from Nuclear Research

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Excerpts

Una Jefferson: You told me a story about a job you did at the H.C. Starck factory in Massachusetts back in 1993, which I thought was a good story. Would you start by just telling what happened at this factory in 1993?

Jim Joyce: In 1993, we had a process whereby we were reducing a chemical into a powder using molten sodium. To dispose the remainder of the molten sodium, we would take the molten sodium drum to a safe environment and put water onto it. The quantity of the remainder sodium was usually about 10 pounds. One day the supervisor made a mistake. He had 10 times the usual sodium in the drum, so instead of 10 pounds, he had a 100 pounds. And when that 100 pounds was hit with water, it reacted as sodium reacts naturally, it began to burn intensely. It burned through the barrel and it burned up through the roof of the building. We couldn’t control the fire through the roof with normal means. So the group on the shift called the fire department. The Fire Department responded and as is the case with a fire department, once they respond to the building, they own it. They made our employees leave and they got into this room where this drum was burning. They somehow knocked the drum over and the molten sodium dropped below the surface of the grading and spread out on some water and there was a violent explosion. Two firefighters were severely burnt, one was burned over 80% of his body and another burned about 35% of his body. The other nine firemen were knocked unconscious. The explosion shifted that room about two inches off its foundation. So it was a pretty dramatic explosion and fire.

Una Jefferson: So you were brought in about two years later to help diagnose and clean up this company’s operation. What did you find when you got in there and started looking around?

Jim Joyce: I had been sent to help turn around one of the businesses at that location and I was there working on turning this business around when this explosion and fire took place. We were taken to task by the state of Massachusetts, by the Attorney General’s office, and the Environmental Strike Force. In two years, by 1995, we had a real mess on our hands. We had to operate this facility under the terms and conditions of a consent order. That consent order was written so that we had 400 environment health and safety issues to remediate over a period of 18 months. And the costs associated with each one of those issues was $10,000 per violation per day. If somebody wants to do the math, they can add that up. It was imperative that we cleaned up each of those issues according to that 18 month timeline. So it was really critical to the operation of that facility.

Una Jefferson: How does one go about tackling a workload like that?

Jim Joyce: One has to get immediately humble and one has to look for the best available help. It was assigned to me because I was kind of a fixer and I was a representative of the parent company. We built a team that was made up of operations people from the facility, we had manufacturing people, engineering people, we had financial people. We had third party legal representation and corporate legal representation. So there were a lot of resources at hand and everybody was focused on meeting the spirit and intent of the consent order and doing it as practically and efficiently as possible and making sure that everybody involved, whether it was the fire department, their responders, the state and federal EPA, we wanted everybody to be pleased with our response and we obviously wanted to get that plant back in operating the right way and generating revenue as it was designed to do.

Una Jefferson: Can you give us a sense of the general problems that you identified? You mentioned there were hundreds of individual violations, but what were the trends?

Jim Joyce: It was an interesting environment because that plant was originally a spinoff of some technology that was developed at MIT back in the 60s. It was a great company and still is but sometimes when you’re founded by folks that are engaged in R&D as opposed to someone who knows the process and practices of a chemical company, it’s very different. The risks that were taken by R&D folks were very different than those taken by folks raised in a chemical company environment. So there were a lot of things that we had to fix. We had to fix the outlook towards process safety management and ensure reviews by multiple sets of eyes before something was designed and implemented. We had to link environment, health and safety to a quality system. We had to install a quality system. We had to look for ways to set up compliance on a number of levels; environmental compliance, emissions, water, making sure we had all of the permits for the emissions and so forth. One of the big challenges we saw was with a linkage between the Federal Code and the local code for air, water, and waste emissions. We had to make sure that everything we were doing was done exactly and precisely according to the law and that the process was absolutely the same every time. We had to go from a fast and loose developmental environment to a steady state manufacturing environment in very short order.

Una Jefferson: You brought this man on board named John Buick who formerly worked in nuclear research. What inspired you to bring this man on board and what types of lessons were you drawing from nuclear research?

Jim Joyce: This was really interesting. John Buick, was a local guy in Massachusetts. He was a trained at Cornell in nuclear engineering and then did his graduate work at the University of Michigan. He went to Pittsburgh to work in Battelle laboratories, which was owned by Westinghouse Corporation and was also a part of the nuclear navy that was being developed by Admiral Rickover. What John learned academically and then through his experience, he applied to the environmental end of managing Massachusetts, which has really tricky environmental set of standards. Everything John did and everything he designed was built with great rigor and with great adherence to the law. Together we broke down every task according to the manufacturing process and we looked at the risks and requirements at every step along the way. Everything we did was building a paper trail, because it was before systems like Nimonik were available, but there was a paper trail and we could prove with really rigorous set of processes, procedures and paper that we were doing exactly what was required from a quality viewpoint, from an environmental compliance viewpoint, and health and safety viewpoint. It brought great rigor and discipline to the manufacturing process and the compliance process. Those were things that we learned from Dr Buick and really we were given access to everything he learned in his formative times in the nuclear business.

Una Jefferson: So what would the system look like concretely? Is it a big binder of paper with clause by clause regulatory requirements and what they correspond to you in your facility?

Jim Joyce: Yes. With every process, you have a certain set of standard operating procedures and upon those standard operating procedures were built a job safety analysis. There were certain steps along the way.You  can think of it as a three column worksheet with the procedure in the left hand column, the risks in the center column and then the actions that were taken to overcome or mitigate or eliminate those risks in the third call. What we added to it was another column that explained the compliance tasks or checks necessary to comply with the law and prove that at every step along the way this was being done. It was a massive undertaking originally, but it gave everybody in the plant responsibility and that went from the floor up to the top levels of the company. It was a very interesting process because the paperwork was gathered and sorted and it eventually became very simple. It was just a mountain of paperwork. And then of course as time moved along and technology developed, we began to look for ways to make this an electronic task and much less wasteful when it came to paper. But it was exactly what you guys are doing with the Nimonik system in that is was based on the law and based on the regulatory requirements, whether local, state, county, federal, national or provincial. It was all built into the system and the labor was divided among all the participants in the process. It emphasized environmental compliance, health & safety and the wellbeing in the workplace.

Una Jefferson: There’s this challenge of getting everybody on board at all different levels of the organization. When you just had this big binder full of paper, how did you go about dividing responsibility for different clauses among different representatives and different levels?

Jim Joyce: We justified the ask by showing exactly what the law said, what the requirements were and what the penalties would be for non-compliance. The timing was good too because the incident of 1993 by 97 was still very fresh in everyone’s minds. People at first, like any other change, viewed it as a painful thing to do. Once we talked to them, convinced and cajoled them to get them to at least try it, they saw how simple it was, and how non-invasive it was to the manufacturing process. Then enthusiasm began to build for it. People became genuinely excited about helping the company be compliant and improving the way things were done. They began to relax and gave a lot more of discretionary effort. They felt really proud of what they were doing. It turned from kind of being viewed as, « oh my God, this is so much more » to « hey, this isn’t so bad, and by the way, we’re contributing and we’re safer and we’re compliant, and we’ve got a little more job security than we had in the past. »

Una Jefferson: You make it sound like it was kind of a new idea that you stumbled across at the time. How has that idea been adopted? How widespread has this become and to what extent are the lessons you learned in this facility being applied elsewhere in general?

Jim Joyce: One of the great lessons that you learned from a disaster like that, especially where the lives of so many human beings were changed is that environmental compliance and health and safety rules and regulations are designed to keep people in the workplace at every level safe and they’re designed to make companies involved in manufacturing good corporate citizens. I found in some companies that I worked in afterwards that there was remarkably little formal process safety management. That was kind of the big difference. Because the other industries that I’ve worked in, whether it was the cement and aggregates business or even the glass making business, they were at various levels of development when it came to process safety management and adherence to it. I was certainly able to use what I learned at Stark in the 90s and apply it to a number of different manufacturing situations and of course a number of different environment and health and safety considerations. But the fundamental aspects of the rigor and discipline that come with compliance are the same.