10

review processes, the investigation team walked down

high hazard buildings and surveyed a variety of

equipment, material, and waste storage areas.

Radiological surveys were performed at a variety of

locations, both inside and outside the perimeter security

fence.

This extensive data collection process allowed the

investigation team to proceed in a structured fashion to

(1) determine whether ES&H activities and practices

from 1952 to 1990 were consistent with the knowledge,

standards, and local requirements applicable at the time,

and (2) identify any ES&H concerns that had not

previously been documented.

1.4 Data Considerations

The scope of the Phase II portion of the

investigation required that the investigation team examine

legacy data and information. This involved both the

review and evaluation of archived material and the

assessment of recorded interviews documenting

individualsí recollections of previous events and

conditions. The investigation team recognized the

inherent difficulty of current and former workersí

accurately recalling details related to activities and events

happening 20 to 40 years ago. While the interview

solicitation indicated the teamís desire to speak with

personnel who were involved in a variety of functions

at the Plant, many individuals were self-selected for

the interviews; that is, their participation resulted from

their personal interest in the investigation. Accordingly,

the team was cautious and conservative in its use of

information recorded in interviews for judgments

contained in this report.

The identification and review of historical

documentation was a tedious and time-consuming

process. Many historical PGDP documents were not

catalogued or filed in central locations. Many documents

could not be located, and some records that were

examined were contaminated or located in abandoned,

contaminated buildings. Due to the volume of records

and other documentation generated over almost 40

years, it was not possible to locate and review all

documents. Documents were examined based on

focused subject searches and targeted sampling.

1.5 Report Structure

The balance of this document is structured to

provide the reader with a comprehensive understanding

of past activities at PGDP and a thorough description

of operational, maintenance, and environmental

management practices and their effectiveness in

minimizing impacts on workers, the public, and the

environment. To ensure that the full range of

information is provided in an understandable manner,

the balance of the report is organized into a series of

discussions outlining various elements of the Plantís

operation in the context of when and how they were

conducted. Accordingly, Section 2 of the report provides

a chronological description of past activities at PGDP

within a series of functional areas that summarize key

operations relating to the safety and health of workers,

the public, and the environment. The objective of

Section 2 is to provide to the reader an overall

understanding of the major activities performed at

PGDP and to indicate how these activities may have

changed over time.

Section 3 describes in detail the hazards that existed

at PGDP; operational and maintenance activities;

practices used to identify, monitor, and control these

hazards; and the effectiveness of these practices in

addressing these hazards. Similarly, Section 4 describes

past environmental management practices at the Plant

and their effectiveness in mitigating impacts to the public

and the environment. Section 5 provides the

investigation teamís findings regarding ES&H activities

and practices from 1952 to 1990. The roster of the

Office of Oversight investigation team is provided in

Appendix A. Appendix B summarizes the principal

hazardous activities conducted at PGDP during the

period 1952 to 1990 and provides an assessment of the

hazards presented by these activities, the controls used

to mitigate the hazards, and the effectiveness of the

controls.

Recent Sampling Activity