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5.0 Findings

In the 1950s and 1960s, the workers and

management at the PGDP, then the areaís largest

employer, were performing highly important,

technologically challenging, and secret work

contributing to the national defense. In the midst

of the Cold War, the number one priority at PGDP

was the production of enriched uranium. Federal

and Commonwealth of Kentucky standards for

safety and health were just beginning to evolve.

Environmental protection standards were limited,

and restrictions on waste disposal and

environmental discharges were rudimentary.

ES&H practices have evolved and improved over

the years of Plant operation as knowledge was

gained about hazards and controls and as new

Federal regulations required improvements,

especially in the 1970s, in activities affecting the

environment.

Health and safety programs were established

before startup at PGDP and included policies,

procedures, training, monitoring, and equipment

for protecting personnel from hazards at the Plant.

Industrial safety was emphasized, with safety

committees, publications and posters, frequent

safety meetings, and JHAs developed early on

for most work activities. The Health Physics

and Hygiene Department performed studies of

hazards and health effects and surveys and

evaluations of working conditions. They also

provided line management with recommendations

for engineering and administrative controls for

hazards. PPE, such as coveralls, gloves, safety

glasses, hearing protection, shoes, and respirators,

were provided or made available to workers

deemed to need them. A variety of personnel

monitoring methods, including film badges,

urinalysis, and lung counting, were used to

determine their exposure to radiological and some

chemical hazards and to monitor responses to

significant intakes and exposures.

Although the intention to protect workers

from the radiological (including transuranic)

hazards was apparent, the implementation of the

radiological protection program at PGDP was very

inconsistent between 1952 and 1989. Limited

health physics staffing, a failure to communicate

exposure levels and transuranic hazards to workers,

worker failure to follow radiological control

measures, a failure to consistently enforce

radiological control measures, and a lack of

adequate understanding and appreciation of the

hazards of uranium and transuranics all contributed

to inconsistent implementation. The lack of

understanding was illustrated by crude experiments

at PDGP designed to measure excretion rates,

including voluntary inhalation and ingestion of

uranium compounds to cause intakes. Line

management was responsible for ensuring personnel

protection and compliance, and the Health Physics

and Hygiene Department staff were advisors only,

having no enforcement role. Rigid ìneed to knowî

AEC security requirements, a predominantly military

veteran workforce, and job insecurity all contributed

to an unquestioning attitude, a lack of understanding

of hazards, and the resulting inconsistent compliance

with controls. An additional impediment was the

physical discomfort of wearing ill-fitting PPE,

including early styles of masks and respirators, in

the often hot and dirty work environments in many

areas of the Plant.

There was a widespread belief that uranium

did not present a significant health risk to workers.

Consequently, eating, drinking, and smoking in

contaminated areas; failure to wash or remove

contaminated clothing before entering the

cafeteria; and wearing contaminated clothing off

site without monitoring all occurred during this

period. The Health Physics and Hygiene

Department assumed that nearly all uranium

ingested or inhaled was soluble and quickly

excreted from the body without harm or long-term

effects. In fact, aerosols of insoluble uranium

compounds were generated in some work areas,

such as in the feed plant, and by maintenance

activities, such as grinding, buffing, and welding.

Many hazard controls were recommended or

implemented after significant exposures or as a

result of high bioassay or air sample readings rather

than in a pre-planned, proactive manner. Although

ALARA and its predecessor concepts were stated

policy, they were not actual practice.
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The presence of transuranics including plutonium

and neptunium, with a higher specific activity and

exposure potential than uranium, constituted a significant

inhalation hazard for workers. This was especially true

for workers engaged in activities where the transuranics

were more concentrated or where there was airborne

exposure, such as feed production, ash handling,

neptunium recovery, metals production, reactor tails

feeding or product withdrawals, and cascade

improvement and modification activities. The need for

extremity (hand or foot) monitoring for workers

performing activities in or near high radiation fields was

not recognized, and overexposures may have gone

undetected. The presence of transuranics and the

reasons for additional controls were not shared with

workers. Exposure history was also not provided to

workers unless requested. These practices contributed

to inconsistent compliance with PPE recommendations.

Airborne releases of radiological and chemical

materials were frequent in the 1950s, significantly

decreasing in frequency and quantity after the mid1960s. In some cases, these releases were not adequately

monitored, documented, mitigated, or reported. Until

the mid-1970s, uranium and fluorine were released

unmonitored from process, feed and metals production,

and cleaning (decontamination) building stacks.

Intentional and improper cell venting to the atmosphere

on the backshifts (ìmidnight negativesî) reportedly

occurred. ìPuffsî of UF6

, HF, and fluorine resulted in

hazards to workers, and accidents resulted in the release

of visible clouds of UF6 gas on and off site, often without

adequate monitoring or documentation. Acute and

chronic exposures to chemical hazards such as TCE,

PCBs, and HF occurred, and the potential risks of such

exposures were not fully recognized by workers or the

Health Physics and Hygiene Department. Exposures

to HF resulting in burns, respiratory distress, and

bleeding were frequent in the 1950s and 1960s, and

their potential long-term health effects are unknown.

The determination of the long-term consequences of

potentially unmonitored or chronic exposures to radiation

and other hazards was outside the scope and resources

of this investigation.

Early waste disposal practices at Paducah were

consistent with general industry practices at the time

and included burial, dilution, and incineration. By

todayís standards, there were numerous examples of

inadequate control and monitoring of liquid effluents,

including radiological and chemical waste streams.

Uranium solutions were channeled into the sewage

treatment system and later contained in the sewage

sludge used for fertilizer on site; contaminated laundry

solutions were discharged or dumped into lagoons and

into the North-South Diversion Ditch; and acids and

chromates were discharged into the Bayou Creeks at

such levels that DOE had to purchase the property

adjoining Little Bayou Creek. PCBs and TCE were

discharged to the ground, and liquid radiological and

chemical wastes from process operations were

discharged to unlined lagoons, ditches, and creeks.

Ongoing monitoring and remediation programs are

addressing the impacts of legacy contamination from

these historical discharge practices and events.

Unsegregated radiological and chemical materials

and waste were dumped or buried both inside and

outside the fence on DOE property and were not

controlled or documented. For example, contaminated

concrete rubble and contaminated roofing materials were

dumped outside the fence; contaminated sewage sludge

was placed in landfills or on site lawns as fertilizer; and

contaminated drums, equipment, and materials were

dumped in lagoons, burial holes, or piles. Identification,

characterization, and remediation of these legacy waste

issues are ongoing programs at the Plant.

To put PGDP conditions and activities into

perspective, it must be considered that almost 50 years

ago there was a significantly smaller body of knowledge

about radiation, chemical, and other industrial hazards

and their effects on humans and the environment.

Global political conditions were different, and attitudes

towards openness, worker protection, and

environmental stewardship were less sophisticated.

Industries, including the AEC/ERDA/DOE complex,

were largely self-regulated; guidance and standards were

evolving. Although some PGDP exposures may not

have been identified and recorded, and those that were

measured are high by todayís standards, only two

reported exposures were above the governing regulatory

limits. Total PGDP exposures were generally

comparable to similar activities across AEC/ERDA/

DOE, Defense Department facilities, and commercial

nuclear plants at that time.