OSHA Inspection: DOMINION ENERGY NUCLEAR CONNECTICUT, INC.

Issued

Apr 24, 2024

Abate by

Jun 11, 2024

Penalty

Initial $16,131 · Current $0 Reduced

General-duty citation text

29 CFR 1926.62(c)(1): The employer did not ensure that no employees were exposed to lead at concentrations greater than fifty micrograms per cubic meter of air (50 ug/m3) averaged over an 8-hour period:   Decommissioned Millstone Power Station Unit No. 1 Roof:   On or about October 24, 2023, and sometime thereafter, employees were presumed to be exposed to lead during high exposure plasma torch cutting tasks where the degree of overexposures to lead were at concentrations greater than fifty micrograms per cubic meter of air (50 ug/m3) over an averaged 8-hour period. Employees were presumed to be exposed to lead at levels in the absence of monitoring required to be performed in accordance with 29 CFR 1926.62(d) verifying employees were not exposed to levels that exceeded the 2,500 �g/m3 lead concentration levels for the (d)(2)(iv) "trigger tasks" performed. This occurred when rooftop building structures, among other structures, had a lead-painted boiler system unit that was presumed to expose employees to elevated aerosolized contaminant lead levels during plasma torch cutting and power cutting operations that induced heavy smoke formation in the Auxiliary Boiler Room where the boiler piping surface tested positive for lead. Additional lead-coated surfaces such as air handling recirculating units (HVHs); exhaust filter fan units (HVEs); and HVAC ductwork were removed non-intact from the following rooftop Millstone Power Station Unit 1 locations:  a) Maintenance Shop Roof b) Turbine Building Roof c) Reactor Building Roof d) Yard - Radwaste & Radwaste Storage Roof

Issued

Apr 24, 2024

Abate by

Jun 11, 2024

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1926.62(e)(1): The employer did not implement all feasible engineering and work practice controls, including administrative controls, to reduce and maintain employee exposure to lead to or below the permissible exposure limit:  Decommissioned Millstone Power Station Unit No. 1 Roof:   On or about October 24, 2023, and sometime thereafter, employees were presumed to be exposed to lead during high exposure plasma torch cutting tasks at concentrations greater than fifty micrograms per cubic meter of air (50 ug/m3) over an averaged 8-hour period. The employer did not implement feasible engineering and work practice controls that included, among others, local exhaust ventilation and stripping back lead-containing coating to reduce employee exposure presumed to be in excess of 2,500 ?g/m3 for the "trigger tasks" tasks listed in paragraph (d)(2)(iv) when employees were presumed to be exposed to excess levels in the absence of monitoring required per 29 CFR 1926.62(d), which verifies that employees were not exposed to levels that exceeded the 2,500 �g/m3 lead concentration levels for the (d)(2)(iv) "trigger tasks" performed. . This occurred while employees used a plasma cutter and power cutting tools to aggressively cut lead-painted building structures that included, but were not limited to, boiler system piping; roof penetrations, electrical conduits, air handling recirculation units (HVHs), exhaust filter fan units (HVEs), and ductwork that was removed from some of the following rooftop Millstone Power Station Unit 1 locations:  a) Maintenance Shop Roof b) Turbine Building Roof c) Reactor Building Roof d) Yard - Radwaste & Radwaste Storage Roof

Issued

Apr 24, 2024

Abate by

Jun 11, 2024

Penalty

Initial $13,828 · Current $0 Reduced

General-duty citation text

29 CFR 1926.62(d)(2)(v)(A): In the interim, until the employer performs an employee exposure assessment as required under 29 CFR 1926.62(d) and determines actual employee exposure, the employer did not provide to employees performing the tasks described in 29 CFR 1926.62(d)(2)(iv) with respiratory protection in accordance with 29 CFR 1926.62(f):  Decommissioned Millstone Power Station Unit No. 1 Roof:   On or about October 24, 2023, and sometime thereafter, without having performed an exposure assessment, the employer failed to provide employees performing high risk "trigger tasks" described in 29 CFR 1926.62(d)(2)(iv) with respiratory protection in accordance with the provisions of 29 CFR 1926.62(f).  This occurred while employees torch cut lead-painted surfaces and steel structures such as boiler system piping; roof penetrations, electrical conduits, air handling recirculation units (HVHs), exhaust filter fan units (HVEs), and ductwork, flashing to name a few, that were removed from the following rooftop Unit 1 locations at the Millstone Power Station:    a) Maintenance Shop Roof b) Turbine Building Roof c) Reactor Building Roof d) Yard - Radwaste & Radwaste Storage Roof

Issued

Apr 24, 2024

Abate by

Jun 11, 2024

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1926.62(f)(1)(iv): Respirators were not used during periods when respirators were required to provide interim protection for employees while they performed the operations specified in 29 CFR 1926.62(d)(2)(iv):   Decommissioned Millstone Power Station Unit No. 1 Roof:   On or about October 24, 2023, and sometime thereafter, the employer did not provide employees with respiratory protection in accordance with the appropriate assigned protection factor (APF) for the presumed exposure above 2,500 ?g/m3, which required a protection factor of at least 50 for the 1926.62(d)(2)(iv) tasks performed. The employer offered half face dust mask respirators with an APF of 10 that employees could voluntarily use while engaging in torch cutting, power cutting, and other manual demolition "non-intact" methods. Given the APF of the dust mask, and the presumed exposure concentrations, the maximum concentration of lead dust that employees were expected to be protected from with the respirator provided was up to 500 ?g/m3 (MUC= APF 10 x PEL 50 ug/m3 = 500 ug/m3). The remaining concentration exposes employees to 2,000 ?g/m3 of lead dust, more than three times the 50 ug/m3 PEL for an 8-hr time-weighted average period during torch cutting operations on lead-painted surfaces and steel structures within the following rooftop Millstone Power Station Unit 1 locations:  a) Maintenance Shop Roof b) Turbine Building Roof c) Reactor Building Roof d) Yard - Radwaste & Radwaste Storage Roof

Issued

Apr 24, 2024

Abate by

Jun 11, 2024

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1926.62(f)(2)(i): The employer did not implement a respiratory protection program in accordance with 29 CFR 1910.134(b) through (d) (except (d)(1)(iii)), and (f) through (m) for each employee required by 29 CFR 1926.62 to use a respirator:  Decommissioned Millstone Power Station Unit No. 1 Roof:   On or about October 24, 2023, and sometime thereafter, the employer did not implement a respiratory protection program in accordance with 29 CFR 1910.134(b) through (d) (except (d)(1)(iii)), and (f) through (m) for each employee required by 29 CFR 1926.62 to use a respirator while engaging in torch cutting and power cutting operations on lead-painted surfaces and steel structures within the following rooftop Millstone Power Station Unit 1 locations:  a) Maintenance Shop Roof b) Turbine Building Roof c) Reactor Building Roof d) Yard - Radwaste & Radwaste Storage Roof

Issued

Apr 24, 2024

Abate by

Jun 11, 2024

Penalty

Initial $9,218 · Current $0 Reduced

General-duty citation text

29 CFR 1926.1101(g)(8)(ii)(B): Feasible wet methods were not used to remove roofing materials that were not intact or that were rendered not intact during removal:  Decommissioned Millstone Power Station Unit No. 1 Roof:   On or about October 24, 2023, and sometime thereafter, the employer did not ensure that feasible wet methods were used to reduce dust fibers generated while disposing demolished roofing materials that were not intact or that were rendered not intact during removal of lead-painted surfaces and structural steel components containing thermal system insulation (TSI), surfacing material, and other insulation and material presumed to be asbestos containing roofing material (PACM) while in the following rooftop Millstone Power Station Unit 1 locations:  a) Maintenance Shop Roof b) Turbine Building Roof c) Reactor Building Roof d) Yard - Radwaste & Radwaste Storage Roof

Issued

Apr 24, 2024

Abate by

Jun 11, 2024

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1926.1101(g)(8)(ii)(D): When built-up roofing with asbestos-containing roofing felts and an aggregate surface were removed using a power roof cutter, the dust resulting from the cutting operation was not collected by a HEPA dust collector or was not vacuumed along the cut line:  Decommissioned Millstone Power Station Unit No. 1 Roof:   On or about October 24, 2023, and sometime thereafter, when built-up roofing with asbestos-containing roofing felts and an aggregate surface were removed using power roof cutting tools that included, but were not limited to, a Milwaukee Sawzall Reciprocating Saw, the employer did not ensure that a HEPA dust collector or that HEPA vacuuming was performed along the cut line.

Issued

Apr 24, 2024

Abate by

Jun 11, 2024

Penalty

Initial $11,524 · Current $0 Reduced

General-duty citation text

29 CFR 1926.1101(j)(2): The hygiene facilities and practices listed in sections (i) through (v) of this paragraph were not followed for employees performing Class I work involving less than 25 linear or 10 square feet of TSI or surfacing ACM and PACM, and for Class II and Class III asbestos work operations where exposures exceed a PEL or where there is no negative exposure assessment produced before the operation:  Decommissioned Millstone Power Station Unit No. 1 Roof:   On or about October 24, 2023, and sometime thereafter, the employer did not ensure that hygiene facilities and practices listed in sections (i) through (v) of this paragraph were followed for employees performing Class I work involving less than 25 linear or 10 square feet of TSI or surfacing ACM and PACM, and for Class II asbestos work operations where exposures exceed a PEL or where there is no negative exposure assessment produced before the operation. Hygiene facilities were unavailable for employees after they aggressively cut and removed lead-coated surfaces and structures containing thermal system insulation (TSI), surfacing material, and other insulation and material presumed to be asbestos containing material (PACM), including, but not limited to, auxiliary boiler systems; abandoned exhaust roof penetrations, water heating units, and HVAC gaskets in the following rooftop Millstone Power Station Unit 1 locations:  a) Maintenance Shop Roof b) Turbine Building Roof c) Reactor Building Roof d) Yard - Radwaste & Radwaste Storage Roof

Issued

Apr 24, 2024

Abate by

Jun 11, 2024

Penalty

Initial $11,524 · Current $0 Reduced

General-duty citation text

29 CFR 1926.1101(k)(2)(i): Before work subject to this standard began, the building and/or facility owner(s) did not determine the presence, location and quantity of asbestos containing material (ACM) and/or presumed asbestos containing material (PACM) at the worksite pursuant to 29 CFR 1926.1101(k)(1):  Decommissioned Millstone Power Station Unit No. 1 Roof:   On or about October 24, 2023, and sometime thereafter, where the demolition of roofing material began at the worksite of a decommissioned building that was constructed on May 19, 1966 (AEC Docket 50-245), completed for fuel loading in October 1970, and then went into commercial operation on December 28, 1970, the building and/or facility owner(s) did not determine the presence, location and quantity of asbestos containing material (ACM) and/or presumed asbestos containing material (PACM) for work that involved the destruction of various air; water; HVAC; plumbing; and electrical system units. This was not determined prior to aggressively cutting and removing non-intact roofing material or that will be rendered not intact during removal, for operations performed in the following rooftop Millstone Power Station Unit 1 locations:  a) Maintenance Shop Roof b) Turbine Building Roof c) Reactor Building Roof d) Yard - Radwaste & Radwaste Storage Roof

Issued

Apr 24, 2024

Abate by

Jun 11, 2024

Penalty

Initial $6,913 · Current $0 Reduced

General-duty citation text

29 CFR  1926.1101(k)(8)(vii): After the building owner or employer identified previously installed presumed asbestos containing material (PACM) and/or asbestos containing material (ACM), labels or signs were not affixed or posted so that employees would be notified of what materials contain PACM and/or ACM, and/or the employer did not post signs in lieu of labels, and/or ensure, to the extent feasible, that employees who come in contact with these signs or labels could comprehend them:  Decommissioned Millstone Power Station Unit No. 1 Roof:   On or about October 24, 2023, and sometime thereafter,  after the building owner or employer identified previously installed presumed asbestos containing material (PACM) and/or asbestos containing material (ACM) at the worksite of a decommissioned building, Unit 1, that was constructed on May 19, 1966 (AEC Docket 50-245), and went into commercial operation on December 28, 1970, labels or signs were not affixed or posted so that employees would be notified of what materials contain PACM and/or ACM, and/or the employer did not post signs in lieu of labels, and/or ensure, to the extent feasible, that employees who come in contact with these signs or labels could comprehend them. This hazard awareness was not provided in locations where employees came into contact with ACM and PACM while engaging in torch cutting, power cutting, and other manual demolition "non-intact" operations within the following rooftop Unit 1 locations at the Millstone Power Station:    a) Maintenance Shop Roof b) Turbine Building Roof c) Reactor Building Roof d) Yard - Radwaste & Radwaste Storage Roof

Issued

Apr 24, 2024

Abate by

Jun 11, 2024

Penalty

Initial $16,131 · Current $0 Reduced

General-duty citation text

29 CFR 1926.1101(k)(9)(iii): Training for Class I operations and for Class II operations that require the use of critical barriers and/or negative pressure enclosures, was not equivalent in curriculum, training method and length to the EPA Model Accreditation Plan (MAP) asbestos abatement workers training:  Decommissioned Millstone Power Station Unit No. 1 Roof:   On or about October 24, 2023, and sometime thereafter, employees who demolished Unit 1 rooftop structures, where ACM; surfacing material; and/or PACM was removed, did not have the appropriate training for Class I and Class II operations that required the use of critical barriers and/or negative pressure enclosures that should be equivalent in curriculum, training method, and length to the EPA Model Accreditation Plan (MAP) asbestos abatement workers training.

Issued

Apr 24, 2024

Abate by

Jun 11, 2024

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1926.1101(k)(9)(iv)(A): Employees performing Class II work were not trained in all the elements included in 29 CFR 1926.1101(k)(9)(viii) and the specific work practices and engineering controls set forth in 29 CFR 1926.1101(g):  Decommissioned Millstone Power Station Unit No. 1 Roof:   On or about October 24, 2023, and sometime thereafter, when employees performed Class II work operations, in addition to the Class I operations performed, they were not trained in all of the elements included in 29 CFR 1926.1101(k)(9)(viii) and the specific work practices and engineering controls set forth in 29 CFR 1926.1101(g) during the removal of ACM and/or PACM roofing and siding shingles, among other tasks.

Issued

Apr 24, 2024

Abate by

Jun 11, 2024

Penalty

Initial $16,131 · Current $0 Reduced

General-duty citation text

29 CFR 1926.1101(o)(4)(i): For Class I and II asbestos work the competent person was not trained in all aspects of asbestos removal and handling, including: abatement, installation, removal and handling; the contents of this standard; the identification of asbestos; removal procedures, where appropriate; and other practices for reducing the hazard:  Decommissioned Millstone Power Station Unit No. 1 Roof:   On or about October 24, 2023, and sometime thereafter, for Class I and II asbestos work performed on existing Unit 1  roof structures including, but not limited to, boiler systems; air handling units; and ductwork in a building constructed on May 19, 1966 (AEC Docket 50-245), the competent person was not trained in all aspects of asbestos removal and handling, including: abatement, installation, removal and handling; the contents of this standard; the identification of asbestos; removal procedures, where appropriate; and other practices for reducing the hazard. Where employees aggressively cut coated surfaces and structures containing TSI; surfacing material; and PACM, the competent person(s) repeatedly indicated that work activity did not expose or potentially expose workers to ACM and/or PACM, or lead, and that the corresponding PPE necessary was not required for the worksite.

Issued

Mar 18, 2024

Abate by

May 2, 2024

Penalty

Initial $11,524 · Current $0 Reduced

Hazardous substances 9020

General-duty citation text

29 CFR 1926.1101(f)(1)(iii): The employer did not determine representative 8-hour time weighted average employee exposure on the basis of one or more samples representing full-shift exposure for employees in each work area:  Unit 1 Roof: On or about September 19, 2023, and sometime thereafter, the employer did not determine representative 8-hour time weighted average employee exposure on the basis of one or more samples representing full-shift exposure when employees in each work area performed Class I asbestos work. Employees were required to remove thermal system insulation (TSI) from ductwork, fittings, and supports in the following locations where they were exposed:  A) Exhaust ductwork to Maintenance Shop Roof Vent Exhaust Fan (HVR-5) B) Exhaust ductwork to Maintenance Shop Roof Vent Exhaust Fan (HVR-4) C) Exhaust ventilation to Unit 1 Millstone Stack

Issued

Mar 18, 2024

Abate by

May 2, 2024

Penalty

Initial $11,524 · Current $0 Reduced

General-duty citation text

29 CFR 1926.1101(f)(2)(i): The employer with a work operation covered by the asbestos standard did not ensure that a "competent person" conducted an exposure assessment immediately before or at the initiation of the operation to ascertain expected exposures during that operation or workplace:  On or about September 19, 2023, when employees removed Thermal System Insulation (TSI) roofing material as well as other surface material that contained asbestos (ACM), or was presumed asbestos containing (ACM), the employer did not ensure that a "competent person" conducted an exposure assessment immediately before or at the initiation of the operation to ascertain expected exposures during that operation or workplace.