17

significant volumes of TCE leakage from C-400 to the

site sewer system, discovered in June 1986. Three fatalities

were reported as a result of Plant events: an explosion and

fire in C-340 in 1962, electrocution of an electrical

maintenance trainee in 1977, and the suffocation of an

operator in the collapse of a coal bridge at the steam plant

in the 1970s. In addition, in June 1958, a release of HF

severely burned a worker who did not return to work.

2.5 Industrial Hygiene and

Radiation Protection

Programs for industrial hygiene and radiation

protection were in existence from the beginning of Plant

operation. Initial Plant training classes included theory

and protective actions for working with radioactive and

hazardous materials. There were policies and

procedures that addressed the radiological protection

of workers. PPE was provided and available to workers

and in work areas where hazards were deemed greatest

and protection was deemed necessary. The amount of

formal training given to employees diminished after Plant

startup, and much of the knowledge concerning both

operations and hazard communication and controls

resulted from on-the-job training of new workers by

more experienced personnel and by supervisors. Starting

in the early 1960s, job hazard analyses (JHAs) were

prepared for most work activities and addressed many

safety hazards, but not all JHAs adequately addressed

radiation protection. Safety committees and regularly

scheduled safety meetings, which included radiological

subjects, were important elements of the process of

hazard communication.

Non-radiation hazards, such as industrial and chemical

exposures (primarily HF), were evaluated and addressed

throughout the history of the Plant. The evolution of

awareness and the application of protection and controls

for significant hazards, such as asbestos and

polychlorinated biphenyls (PCBs), essentially paralleled

that of the regulatory bodies and general industry. Air

monitoring of hazardous job sites existed from Plant

startup, and health physics personnel monitored air and

surface contamination in work areas and recommended

additional or modifications to engineering controls or PPE,

if deemed necessary. As early as 1952, Plant health

physics personnel were aware of the potential hazards of

personnel contamination and instituted measures such as

monitoring work areas, providing company clothing, and

providing frisking devices for workers to monitor

themselves before eating or leaving work. However,

survey records from the early 1950s indicated that few

workers performed self-monitoring.

Identification of asbestos and PCB hazards did not

emerge until the 1970s or later. During the fourth quarter

of 1973, some of the first air samples for asbestos were

taken and sent to Oak Ridge National Laboratory

(ORNL) for analysis; however, no formal asbestos

program existed until 1987. During this period, OSHA

adopted 14 carcinogen standards. In 1975, preparations

were under way for a two-year program to provide

formal respiratory training on a sitewide basis. There

was less concern over worker exposure to PCBs through

absorption, and many workers wore PCB-contaminated

clothing. Some workers considered PCBs to be an

effective remedy for dry skin.

The health physics staff provided exposure

monitoring services, recommended training and

protective measures for supervisors, maintained

exposure and radiation measurement records,

administered a bioassay program, investigated air

samples and personnel exposures that were outside of

specifications, studied Plant hazards and needed

controls, and performed Plant environmental

monitoring. However, the size of the Health Physics

Section (i.e., two to six people during the first 37 years

of operation) limited the amount and effectiveness of

surveillance and monitoring of hazardous conditions and

activities for the approximately 1,200 to 2,500 people

in numerous and diverse work environments. While

line supervision had always been responsible for

implementing recommended controls and protective

measures, supervisory oversight and worker

implementation of PPE and related measures were

inconsistent. Non-compliant PPE use by workers can

in part be attributed to the pressures to maintain normal

process operations, a lack of knowledge and

understanding of the risks involved and why the

protection was needed, and the physical discomfort and

vision impairment associated with wearing PPE, such

as respirators, in hot, dirty environments.

Safety Equipment
18

Most radiological work controls, including time limits

on worker exposures to uranium, were based on the

assumptions that the primary risks for uranium exposure

were chemical, not radiological, and that uranium was

soluble and would be eliminated by the body quickly

through the kidneys. Thus, inhalation protection was

encouraged, and bioassay urinalysis was employed from

Plant startup to monitor intakes by workers who might

be exposed to uranium or fluoride materials. However,

the solubility assumption may not have been appropriate

for some Plant areas, such as the metals plant and

grinding and welding operations, where small particle

sizes and relatively insoluble uranium compounds were

present.

Limitations were established for uranium and

fluoride levels and excretion rates, and personnel were

removed from work areas with potential exposure until

concentrations returned to acceptable levels. In 1968,

in vivo radiation monitoring by lung counting was

initiated, first by sending workers to Fernald or to Oak

Ridge and later using a mobile counter periodically sent

to PGDP from Oak Ridge. The intent of in vivo counting

was to determine the activity of radionuclides trapped

inside the body; for uranium, insoluble forms

concentrate in the lungs and remain there for a relatively

long time. Urinalysis would not detect intakes of

insoluble uranium reliably and at sufficient sensitivity.

However, lung-counting methods are not particularly

sensitive and are suitable only for assessing relatively

large intakes retrospectively. In vivo monitoring was

performed on a sampling basis and, in the early years,

typically relied on volunteers from work areas subject

to uranium exposure. Film badges were used from the

beginning of Plant operation to monitor personnel

exposures to beta and gamma radiation, although prior

to 1960, only selected workers were included in the

film badge service based on their work activities.

In the mid- to late 1970s, health physics surveys of

work practices, continuous airborne activity monitor

analysis, and contamination surveys were routinely

documented. Health physics personnel were aware of

the presence of and hazards associated with neptunium237, plutonium-239, and technetium-99, and actively

encouraged proper respirator use, identifying instances

of improper respirator use and recommending other

changes to improve ventilation and minimize exposures.

The sophistication and rigor of health physics surveys

improved during the late 1970s; uranium, uranium

daughter products, neptunium-237, plutonium-239,

thorium-230, and technetium-99 were monitored,

reported, and discussed with personnel. In the mid1980s, the NRC and DOE were promulgating more

stringent regulations for radiological control, and

practices related to respiratory protection, contamination

control, and personnel monitoring improved

considerably.

2.6 Waste and Material

Management

Over the years, solid wastes were disposed of in

various locations including two landfills, four scrap

yards, and three radioactive materials disposal sites. In

addition, there were a number of smaller holding areas

and special disposal sites. A burn pit in the northwest

corner of the site was used for combustible waste until

1967. The landfill used for early construction rubble

north of the Plant continued in operation as the Plant

came on line, and another landfill outside the fence

southwest of the Plant (known as the C-746 K Landfill)

was created for steam plant ash disposal and evolved

into a general landfill. Although there were some early

specifications limiting placement of radioactive material

in the landfills, there is no record of sampling to

demonstrate compliance. Further, since records indicate

that floor sweepings were disposed of in the landfills

and spills of green salt and yellowcake were routine in

several areas of the Plant, it is clear that radioactive

materials were improperly sent to the sanitary landfills.

In addition, waste materials (including radioactively

contaminated materials) were disposed of in various

areas outside the Plant boundary in what is now the

Kentucky Wildlife Area. These areas are accessible to

the public for recreational use. Unauthorized salvaging

of scrap materials also occurred.

Some of the materials disposed of outside the Plant

boundary have been identified as radioactive by

subsequent site surveys or investigations carried out

under the Federal Facility Agreement and by this

investigation team. Scrap metals from C-340, the

cascades, the feed plant, and the C-720 maintenance

shop went to C-746F (classified burial), C-746E

(contaminated material yard), C-746C (clean materials),

or unclassified burial yards all within the security fence.

From the beginning of Plant operations, efforts were

made to control the spread of contamination and to

separate contaminated materials from other waste.

However, records and interviews indicated that

compliance was inconsistent and monitoring minimal.

Pyrophoric uranium metal shavings were disposed of

in the C-749 burial ground from 1957 to 1977. In the

1950s, uranium powder scrap from C-340 was dumped

into onsite pits. The primary radioactive waste disposal

site was the original C-400 holding pond, which was