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
19

converted into a solid waste disposal area in 1957. By

1977, over 6 million pounds of uranium had been put

into drums and placed in this disposal area.

PGDP had no integrated waste management

program until the early 1980s. Before then, waste

disposal was performed by each organization performing

work in conjunction with the Maintenance Department,

which operated several disposal sites. When requested

by the operating departments, limited guidance was

provided by the site safety and health organization.

In 1978, the site Environmental Control Department

conducted a study of PGDP waste management

practices. The report recommended better management

of solid waste, closure of miscellaneous burial areas,

improved management of existing facilities, provision

of additional space for facilities, and construction of

facilities for recovery and reduction of waste. The report

stated that the passage of the Resource Conservation

and Recovery Act (RCRA) in 1976 required Federal

facilities to comply with all state solid waste regulations

and that the Plant ìis only partially meeting both present

and planned regulations.î In part, this study led to the

creation of the Material Terminal Management (MTM)

Department within the Maintenance organization. The

MTM Department implemented the integrated waste

management program by gaining control of waste

management facilities and developing waste

management procedures for the Plant.

The 1978 study and the formation of the MTM

Department also impacted the disposal of radioactive

waste on site. In 1978 and 1979, the amount of

radioactive waste disposed of on site was 330,690

pounds annually, but this declined significantly to 18,000

pounds per year in the 1980s. An overriding assumption

regarding the stability of the radioactive disposal sites

was that the underlying clay layer would prevent

contamination from leaching into the groundwater and

travelling off site.

In the early 1980s, the MTM Department began

addressing hazardous waste disposal practices by

working with waste generators to ensure that waste

streams would be in compliance with RCRA

requirements and by implementing standard practice

procedures for waste management. Concurrently, the

MTM and the Environmental Control Departments

worked with regulators to obtain permits for storage,

treatment, and disposal facilities, including the C-400

gold dissolver precipitation system and C-410

neutralization pit. Legacy hazardous waste was brought

to several locations, including the C-733 Hazardous

Waste Storage Area, the C-746R Waste Solvent Storage

Area, and the C-746Q Hazardous Waste Storage Area.

However, the absence of sufficient characterization to

ensure long-term storage and compliance with disposal

acceptance criteria has led to existing hazardous waste

storage problems and the need for significant

recharacterization.

PCBs, which were in widespread use by the Plant

throughout its early history, were not considered a hazard

nationwide until the early 1980s. In 1980, the newly

formed MTM Department performed the first sitewide

PCB inventory in response to new Toxic Substances

Control Act (TSCA) regulations on PCBs. By 1982, a

PCB program was established that addressed PCBs as

an environmental contaminant and a regulated waste.

Based on site records, there was a clear

understanding in the 1950s that materials contaminated

above certain limits could not be released to the public.

Procedures were used to govern the handling of scrap

materials, which were generally categorized into one of

four groups: classified scrap, unclassified clean scrap,

unclassified contaminated scrap, and unclassified

nonmetal scrap. However, there was a concern in the

mid-1970s that the contaminated items were being

released to public parties as part of equipment and scrap

sales. In mid-1975 a Scrap Handling Committee was

established to evaluate onsite solid waste disposal

problems. The source of these problems included the

ongoing upgrade program, lack of awareness of the

proper procedures ñ especially among new workers and

supervisors ñ and an increase in the number of entities

hauling waste to the scrap yards. The Scrap Handling

Committee also examined the effectiveness of

equipment and scrap sales to the public, and despite

recommendations for improvements, continued

problems were evident in 1977. The extent to which

proper procedures were not followed, combined with

the small number of health physics personnel, suggests

that materials exceeding proper radiological limits were

likely released off site until the late 1980s.

2.7 Air and Water Emissions

Radioactive air emissions began with startup

operations in 1952 and have continued to present. Air

emissions from the site were released from process

stacks, diffuse and fugitive emission sources, accidental

releases, and a limited number of planned releases. No

evidence of measurements or monitoring of stack

emissions was found prior to 1975. From 1959 to 1974,

the air emission reports consisted of ambient air

monitoring. Starting in mid-1960, continuous ambient

air samples were taken at four locations at the perimeter

fence and were analyzed for alpha and beta